RECORD OF DECISION
ARMSTRONG WORLD INDUSTRIES
SUPERFUND SITE
OPERABLE UNITS 1 AND 2
Macon, Macon-Bibb County, Georgia
EPA ID: GAN000410033
Prepared By:
U.S. Environmental Protection Agency
Region 4
Superfund Division
Atlanta, Georgia
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RECORD OF DECISION
Table of Contents
PART 1: DECLARATION 1
1.0 Site Name and Location 1
2.0 Statement of Basis and Purpose 1
3.0 Assessment of Site 1
4.0 Description of Selected Remedy 2
5.0 Statutory Determinations 3
6.0 Data Certification Checklist 3
7.0 Authorizing Signature 4
PART 2: THE DECISION SUMMARY 5
1.0 Site Name, Location and Brief Description 5
2.0 Site History and Enforcement Activities 5
2.1 History of Site Activities 5
2.2 History of Investigations and Cleanup Actions 6
2.3 History of CERCLA Enforcement Activities 8
3.0 Community Participation 8
4.0 Scope and Role of Operable Units 9
5.0 Site Characteristics 9
5.1 Conceptual Site Model (CSM) 9
5.2 Overview of the Site 9
5.3 Sampling Strategy 10
5.4 Known or Suspected Sources of Contamination 12
5.5 Nature and Extent of Contamination 12
5.6 Location and Potential Routes of Migration 15
6.0 Current and Potential Future Uses 17
6.1 Land Uses 17
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7.0 Summary of Site Risks 17
7.1 Human Health Baseline Risk Assessment 18
7.2 Ecological Risk Assessment 21
7.3 Basis for Action 25
7.4 Remedial Action Objectives 26
7.5 Cleanup Levels 26
8.0 Description of Alternatives 27
8.1 SU-7 Remedial Alternatives 29
8.2 Landfill Remedial Alternatives 32
8.3 Common Elements and Distinguishing Features of Each Alternative 34
8.4 Expected Outcomes of Each Alternative 35
9.0 Comparative Analysis of Alternatives 35
9.1 Overall Protection of Human Health and the Environment 37
9.2 Compliance with ARARs 37
9.3 Long-Term Effectiveness and Permanence 37
9.4 Reduction of Toxicity, Mobility, or Volume 38
9.5 Short-Term Effectiveness 39
9.6 Implementability 39
9.7 Cost 40
9.8 State Acceptance 41
9.9 Community Acceptance 41
10.0 Principal Threat Wastes 41
11.0 Selected Remedy 41
11.1 Summary of the Rationale for the Selected Remedy 41
11.2 Detailed Description of the Selected Remedy 42
11.3 Cost Estimate for the Selected Remedy 44
11.4 Estimated Outcomes of Selected Remedies 45
11.5 Environmental and Ecological Benefits 45
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12.0 Statutory Determinations 45
12.1 Protection of Human Health and the Environment 46
12.2 Compliance with ARARs 46
12.3 Cost Effectiveness 47
12.4 Five-Year Review Requirements 48
13.0 Documentation of Significant Changes from Preferred Alternative of Proposed Plan
48
14.0 References 48
PART 3: RESPONSIVENESS SUMMARY 49
1.0 Stakeholder Issues and Lead Agency Responses 50
2.0 References 55
Tables
Table 1: COC Concentrations in Soil Sampling Units 15
Table 2: Human Health Risks at OU2 and SU-7 21
Table 3: COPECs, by Environmental Media 22
Table 4: Ecological Risks for SU-3, SU-5, SU-7 and FMNOL 24
Table 5: SU-7 PCB Soil Cleanup Levels and Post-Cleanup Risks 27
Table 6: SU-7 Alternatives Cost Summary 40
Table 7: Landfill Alternatives Cost Summary 40
Table 8: Comparative Analysis of SU-7 Remedial Alternatives 61
Table 9: Comparative Analysis of Landfill Remedial Alternatives 63
Table 10: Low-End Cost Estimate for RA-SU7-6 65
Table 11: High-End Cost Estimate for RA-SU7-6 67
Table 12: Detailed Cost Estimate for RA-LF-2 69
Table 13: OU2 Chemical-Specific ARARs and TBC 71
Table 14: OU2 Location-Specific ARARs and TBC 72
Table 15: OU2 Action-Specific ARARs and TBC 85
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Figures
Figure 1: Site Location and Features 103
Figure 2: OU2 Land Ownership 104
Figure 3: Soil Sampling Units 105
Figure 4: Human Health Conceptual Site Model 106
Figure 5: OU2 Topography 107
Figure 6: Wetlands Inventory 108
Figure 7: Fish Collection Zones 109
Figure 8: PCB Concentrations in SU-7 Soils 110
Figure 9: Action Area Option #1 Ill
Figure 10: Action Area Option #2 112
Figure 11: Action Area Option #3 113
Figure 12: Schematic of RA-LF-2 114
Figure 13: Schematic of RA-LF-3 114
Figure 14: RA-SU7-6 115
Appendices
State of Georgia Concurrence A-l
Comment and Response Index B-l
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Acronyms and Abbreviations
ALT
Alternative
AOC
Administrative Order on Consent
ARAR
Applicable or Relevant and Appropriate Requirement
AR
Administrative Record
ATSDR
Agency for Toxic Substances and Disease Registry
AWI
Armstrong World Industries
BEHP
Bis(2-ethylhexyl) phthalate
BERA
Baseline Ecological Risk Assessment
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
CIP
Community Involvement Plan
COC
Chemical of Concern
CO PC
Chemical of Potential Concern
COPEC
Chemical of Potential Ecological Concern
CSM
Conceptual Site Model
EPA
U.S. Environmental Protection Agency
FCM
Food Chain Modeling
FMNOL
Former Macon Naval Ordnance Landfill
FS
Feasibility Study
GDPH
Georgia Department of Public Health
GAEPD
Georgia Environmental Protection Department
HHBRA
Human Health Baseline Risk Assessment
HI
Hazard Index
HMWPAH
High Molecular Weight Polycyclic Aromatic Hydrocarbon
HQ
Hazard Quotient
IRIS
Integrated Risk Information System
ISM
Incremental Sampling Methodology
LMWPAH
Low Molecular Weight Polycyclic Aromatic Hydrocarbon
LOAEL
Lowest Observed Adverse Effect Level
MNOP
Macon Naval Ordnance Plant
MWA
Macon Water Authority
NCP
National Oil and Hazardous Substances Contingency Plan
NPL
National Priorities List
O&M
Operation and Maintenance
OU
Operable Unit
PCB
Polychlorinated Biphenyl
PPm
Parts Per Million
PRG
Preliminary Remediation Goal
PRP
Potentially Responsible Party
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
Rl
Remedial Investigation
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RME
Reasonable Maximum Exposure Assumptions
ROD
Record of Decision
RUST
Rust Environment and Infrastructure, Inc.
SAIC
Science Applications International Corporation
SARA
Superfund Amendments and Reauthorization Act
SHHRA
Supplemental Human Health Risk Assessment
SU
Sampling Unit
TBC
To-Be-Considered
TSCA
Toxic Substances Control Act
USACE
U.S. Army Corp of Engineers
use
United States Code
VOC
Volatile Organic Compounds
WWTP
Wastewater Treatment Plant
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PART 1: DECLARATION
1.0 Site Name and Location
This Record of Decision (ROD) for the Armstrong World Industries (AWI) Superfund Site (the
Site) is located at 4520 Broadway Street, in Macon, Georgia (see Figure 1). The
U.S. Environmental Protection Agency (EPA) Superfund Site Identification Number
is GAN000410033.
2.0 Statement of Basis and Purpose
This decision document presents two selected remedies for Operable Unit 2 (OU2) at the Site.
The scope of OU2 included soils/sediment, the Former Macon Naval Ordnance Landfill (FMNOL)
and Remote Landfill, as shown on Figure 1; in addition, 0U2 also addressed Rocky Creek surface
water/sediment and biota (including fish). The first 0U2 selected remedy will address soils in
the SU-7 sample unit, while the second 0U2 selected remedy will address the Remote Landfill
and FMNOL.
This decision document also selects institutional controls (ICs) as a remedy component for 0U1
at the Site. 0U1 addressed the Wastewater Treatment Plant (WWTP) Landfill using the removal
authority granted by the Comprehensive Environmental Response, Compensation, and Liability
Action of 1980 (CERCLA). Construction on the OU1 Non-time Critical Removal Action was
completed in 2016.
The OU1 and OU2 remedies selected in this decision document were chosen in accordance with
CERCLA, 42 United States Code (USC) § 9601 etseq., as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 Code of Federal
Regulations (CFR) Part 300 et seq., as amended. This decision is based on the Administrative
Record (AR) file for the Site.
The EPA is the lead agency for Site CERCLA remediation activities. The Georgia Environmental
Protection Department (GAEPD) is the support agency. In accordance with 40 CFR Part
300.430(f)(2), the GAEPD has provided input during the remedial investigation (Rl), feasibility
study (FS), and Proposed Plan (PP). The GAEPD concurs with the selected remedies presented in
this ROD.
3.0 Assessment of Site
The remedial action selected in this ROD is necessary to protect public health or welfare or the
environment from actual or threatened releases of hazardous substances and pollutants or
contaminants from the Site that may present an imminent and substantial endangerment to
public health or welfare.
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4.0 Description of Selected Remedy
The EPA is managing the cleanup of the Site as three Operable Units (OUs). OU1 addressed the
approximately 4-acre WWTP Landfill (see Figure 1). OU2, the primary subject of this ROD, is
southeast of OU1. It consists of uplands and lowlands and includes the AWI Remote Landfill
(Remote Landfill) and the Former Macon Naval Ordnance Landfill (FMNOL). The Remote Landfill
received waste from the AWI facility while the FMNOL historically received waste from the
Macon Naval Ordnance Plant (MNOP). OU2 also includes an explosives demolition area, Rocky
Creek, and several drainage ditches. OU3 will address groundwater beneath OU2.
In 2013, the EPA issued a Non-Time Critical Action Memorandum for a removal action at OU1. It
called for an engineered cap/liner system on the landfill, a mechanically stabilized earthen
barrier wall, and replacement of the drainage swale. Construction for the OU1 removal action
was completed in 2016. The EPA, in consultation with the GAEPD, will implement institutional
controls for OU1 as part of the remedies described in this ROD for OU1 and OU2.
The response actions in this ROD are intended to address threats to human health and the
environment in OU2 posed by two landfills, the Remote Landfill and FMNOL (collectively
referred to in this ROD as "the landfills"), and by contamination in surface soil at sampling unit
(SU-7). Contaminants at the Site include polychlorinated biphenyls (PCBs) that exceed cleanup
levels for low-occupancy areas, as specified in the Toxic Substances Control Act (TSCA) PCB
regulations at 40 CFR § 761.61(a)(4), which are considered relevant and appropriate
requirements consistent with the NCP. PCBs also represent a principal threat waste in SU-7
soils, where it was reported at 934 ppm (see Section 10.0).
The selected remedy for SU-7, Alternative RA-SU7-6, includes the following elements:
• Excavation of soils to 1 foot below ground surface across the full lateral extent of areas
where soil sampling results found PCB concentrations greater than 25 parts per million
(ppm), and excavation to 2 feet below ground surface where PCB concentrations
exceeded 25 ppm at depths below 1 foot below ground surface;
• Characterization and profiling of excavated soil;
• Temporary storage and/or staging of PCB remediation waste;
• Transportation and off-site disposal of excavated soil to an appropriate permitted
disposal facility: soils with PCB concentrations greater than 50 ppm will be disposed of
at a TSCA-approved facility, while soils less than 50 ppm will be disposed of at a
permitted solid waste landfill;
• Restoration of excavated areas using clean, imported backfill material; and
• Institutional controls to prevent residential land use, prohibit the use of groundwater
and installation of groundwater wells, and prohibit future activities that would disturb
the integrity of the SU-7 selected remedy.
The selected remedy for the landfills, Alternative RA-LF-2, includes the following elements:
• Removal of protruding waste materials and large surface debris;
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• Repair/replacement of the existing soil cover while conserving the current ecologically
diverse land cover, especially mature trees, to the extent possible;
• Revegetation of disturbed areas and allowing the natural ecosystem to redevelop;
• Rock armoring the downgradient boundaries of each landfill to prevent erosion of
waste materials;
• Installation of a fence around the contiguous landfills to protect the repaired soil cover;
• Institutional controls to prevent residential land use, prohibit the use of groundwater
and installation of groundwater wells, and prohibit future activities that would disturb
the integrity of the landfills' selected remedy; and
• Long-term operation and maintenance (O&M) activities to maintain the soil cover and
perimeter fencing and signage.
5.0 Statutory Determinations
The selected remedy for OU1 And OU2 meets the requirements for remedial actions set forth in
CERCLA §121 and, to the extent practicable, the NCP. The selected remedy is protective of
human health and the environment, complies with federal and more stringent state
environmental requirements that are applicable or relevant and appropriate to the remedial
action, is cost-effective, and utilizes permanent solutions and alternative treatment
technologies (or resource recovery technologies) to the maximum extent practicable.
The selected remedy does not satisfy the statutory preference for treatment as a principal
element of the remedy (i.e., reduces the toxicity, mobility, or volume of hazardous substances,
pollutants, or contaminants as a principal element through treatment). Several potentially
applicable treatment technologies were identified: phytoremediation, vitrification, thermal
desorption, and soil washing. The Site's FS determined these treatment technologies were not
feasible, applicable, and/or adequately protective.
Because this remedy will result in hazardous substances, pollutants, or contaminants remaining
on-Site above levels that allow for unlimited use and unrestricted exposure, a statutory
review per CERCLA section 121(c) will be conducted within five years after initiation of the
remedial action to ensure that the remedy is, or will be, protective of human health and
the environment.
6.0 Data Certification Checklist
The following information is included in the Decision Summary section of this ROD:
• Chemicals of concern (COCs) and their respective concentrations (Section 5.5);
• Baseline risk represented by the COCs (Section 7);
• COC cleanup levels and the basis for these levels (Section 7);
• How source materials constituting principal threats are addressed (Section 10);
• Current and reasonably anticipated future land use assumptions used in the baseline
risk assessment and ROD (Section 6);
• Potential land use that will be available at the Site as a result of the selected
remedy (Section 6);
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• Estimated capital, annual O&M, and total present worth costs, discount rate, and the
number of years over which the remedy cost estimates are projected (Section 9); and
• Key factors that led to selecting the remedy (Section 11).
The Site's AR file provides more information. The OU2 AR includes the OU1 AR by
cross-reference.
7.0 Authorizing Signature
FREEMAN
08/01/2024
Caroline Y. Freeman, Director
Superfund & Emergency Management Division
U.S. Environmental Protection Agency, Region 4
Date
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PART 2: THE DECISION SUMMARY
1.0 Site Name, Location and Brief Description
The Site is located at 4520 Broadway Street in Macon, Georgia, in a primarily industrial area. It
is about 5 miles south-southwest of downtown Macon. From 1948 to the present, the AWI
facility has manufactured acoustic ceiling tiles. The EPA listed the Site on the Superfund
program's National Priorities List (NPL) in September 2011. The MNOP Superfund site borders
OU2 to the north (see Figure 1).
OU1 includes a 4-acre Wastewater Treatment Plant (WWTP) Landfill. The EPA issued an Action
Memorandum for a removal action at OUlin 2013. The removal action included installation of
an engineered cap/liner system on the landfill, a mechanically stabilized earthen barrier wall
and replacement of the drainage swale. Construction of the OU1 removal action was completed
in 2016.
OU2 is southeast of OU1. It consists of uplands and lowlands and includes the
following features:
• The Remote Landfill, which received waste from AWI;
• The Former Macon Naval Ordnance Landfill (FMNOL), east of the Remote Landfill, which
historically received waste from the MNOP (located north of OU2);
• The explosives demolition area near the southeastern toe of the FMNOL;
• Rocky Creek and several contributing drainage ditches;
• An abandoned railroad spur; and
• The Macon Water Authority (MWA) water reclamation facility.
Land use around the Site is mostly commercial and heavy industrial, with the nearest residential
area located north of Guy Paine Road which bounds the AWI Site to the north. AWI OU2 is part
of a large area that is zoned as "M-2 Heavy Industrial District" by Macon-Bibb County. The
majority of OU2 is an undeveloped forested/wetland area located within a floodplain. Figure 2
shows land ownership in OU2.
The EPA is the lead agency for Site CERCLA remediation activities. The GAEPD is the support
agency. All RI/FS activities have been financed by the Potentially Responsible Parties (PRPs). The
Site's Superfund Identification Number is GAN000410033.
2.0 Site History and Enforcement Activities
2.1 History of Site Activities
AWI has manufactured acoustic ceiling tiles at the facility since 1948. It has owned the property
containing the Remote Landfill since 1959. Historically, waste material from the manufacturing
process included biosolids sludge, raw materials, and waste from the fabrication process. This
material was sent to the three landfills on the AWI property consisting of the Remote Landfill
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(part of OU2), the WWTP Landfill (part of OU1), and the Woodyard Landfill. The AWI facility may
also have recycled materials, including newspaper with older dye formulations containing
PCBs.
AWI began disposing of general and industrial trash, old equipment, and excess bark and scrap
wood, in the Remote Landfill in the 1960s, although aerial photographs indicate disturbance in
this area sometime after 1955 and before 1958. As of 1971, fibrous material filtered from
wastewater was disposed of in the Remote Landfill or in the WWTP Landfill. The Woodyard
Landfill, west of the WWTP Landfill, received filtered fiber sludge from the WWTP in the 1970s
and 1980s. It was capped with GAEPD oversight in 2004.
The FMNOL was first used by the Reynolds Corporation from 1941 to 1945, under contract with
and on behalf of the U.S. Navy in connection with operations at the MNOP. The FMNOL was
reportedly used for the disposal of solid wastes and ordnance throughout the operation of the
MNOP until 1973, when Allied Chemical Corporation purchased it. Allied Chemical Corporation
used the FMNOL from 1973 to 1977, for general refuse and solid waste disposal. Under various
owners, the FMNOL was used for disposal of used parts and construction debris through 1988.
The MWA now owns the FMNOL and some of the surrounding area. (See Figure 2).
SU-7, shown in Figure 3, is an area that had allegedly been used as a drum disposal area in the
1970s; therefore, an additional investigation was conducted in 2021 as part of the Rl. This
investigation included the use of geophysical technologies such as electromagnetic ground
conductivity and ground penetrating radar. Subsurface anomalies were not detected, and it was
concluded that buried drums were not present in SU-7. However, additional soil sampling at
SU-7 did find elevated levels of PCBs, cadmium, copper, and lead.
An explosives demolition area near the southeastern toe of the FMNOL was historically used for
testing and demolishing explosives, primarily detonators, flares, and primers made at the
MNOP. Flammable materials were reportedly burned in this area as well.
In 1977, at the request of the GAEPD, AWI ceased disposing of fibrous material and sludge in
the Remote Landfill and a 2-foot-thick soil cover was placed atop both the FMNOL and the
Remote Landfill. An analysis of aerial photographs taken over 50 years, from 1938 to 1988,
indicates that the Remote Landfill and the FMNOL appear as one large landfill from 1975
through 1988.
2.2 History of Investigations and Cleanup Actions
Previous investigations at OU2 include:
• 1990: The U.S. Army Corps of Engineers (USACE) and Environmental Science &
Engineering, Inc., sampled groundwater and soil at the FMNOL.
• 1992,1994, and 1995: ERM, Inc. analyzed soil borings at the Remote Landfill.
• 1996: AWI collected sludge samples from the Remote Landfill as part of its solid waste
management program. The sampling identified PCBs, chromium, copper, lead, nickel,
and zinc.
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• 1996: Rust Environment and Infrastructure, Inc. (RUST) completed extensive
characterizations, including soil borings, groundwater sampling, sediment, and surface
water sampling from drainage ditches and Rocky Creek, as well as fish tissue sampling
in Rocky Creek.
• 1998 and 1999: Science Applications International Corporation (SAIC) completed an
investigation to supplement RUST's activities. The investigation included more
environmental and biological sampling, continuous soil coring, and slug testing to
inform the hydrogeologic conceptual model, and geotechnical testing to evaluate
landfill settlement.
• 2001: SAIC performed an additional investigation to characterize deep groundwater
conditions across the upland terrace of OU2 and refine the hydrogeologic
conceptual model.
• 2005: The GAEPD sampled surface water near the Remote Landfill and the FMNOL.
• 2009: EPA contractor Tetra Tech completed an expanded Site inspection to support the
Hazard Ranking System package used to propose the Site for listing on the NPL. The
expanded Site inspection included surface and subsurface soil sampling at the FMNOL
and the Remote Landfill, groundwater sampling east of the FMNOL and the upland
terrace, and sediment and surface water sampling in drainage ditches and Rocky Creek.
• 2013 to 2016: As the sole PRP for OU1, and using Superfund's removal authority, AWI
completed a removal action at OU1 in 2016. It included the construction of an
engineered cap/liner system over the WWTP Landfill, a mechanically stabilized earthen
barrier wall, and replacement of the drainage swale.
• 2020 to 2023: Potentially responsible parties (PRPs) and their contractor, Montrose
Environmental, completed the Site's Rl, which characterized the nature and extent of
contamination in the early action elements of OU2. The Rl included sampling of soil,
groundwater, sediment, surface water, landfill waste, and fish tissue as well as
topographical and ecological surveys and a geotechnical assessment of landfill
foundation materials. The PRPs also completed a human health baseline risk assessment
(HHBRA) and a baseline ecological risk assessment (BERA) as part of the Rl.
During the initial Site characterization in 1990, the USACE observed about 500 deteriorated
drums near the toe of the FMNOL. The USACE reportedly removed many of the drums, but
documentation confirming the removal cannot be found. In 2006, GAEPD personnel observed
deteriorated drums at the Remote Landfill and the explosives demolition area but did not
specify the number of drums observed.
The Georgia Division of Public Health (GDPH) and the Agency of Toxic Substances and Disease
Registry (ATSDR) issued a Public Health Assessment for the Site in 2013. The assessment
addressed the limited number offish samples collected in 1996 and 1999 and stated that
people who ate fish caught in Rocky Creek could be exposed to PCBs at levels that could harm
their health. It also noted that exposure to contaminated soil at the WWTP Landfill, the Remote
Landfill, and the FMNOL, is unlikely because it is in a forested, wetland area that is prone to
flooding and difficult to access.
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Since 2011, based on the limited fish data collected from 1996 and 1999, the EPA has advised
the public that fish should not be eaten from Rocky Creek downstream of Houston Road.
However, in December 2019 and May 2020, more extensive fish sampling was conducted in
Rocky Creek as part of the OU2 Rl. The results showed that PCBs in Rocky Creek fish have
declined significantly. The EPA now advises that the public should avoid channel catfish and
sucker fish from Rocky Creek downstream of Houston Road, as these two bottom-feeder fish
had the highest levels of PCBs among all fish sampled in 2019 and 2020 (however, only one of
the 357 fish collected in 2019 and 2020 was a channel catfish). The public can also reduce PCB
exposure further by following the fish preparation guidelines found on page 6 of the 2023
Guidelines for Eating Fish from Georgia Waters published by the Georgia Department of Natural
Resources. Outreach, such as the distribution of factsheets and hosting a public meeting to
notify the public of updated fish sampling data, was conducted in May 2024.
2.3 History of CERCLA Enforcement Activities
The EPA issued an Action Memorandum for OU1 in September 2013. In July 2014, AWI and the
EPA entered into an Administrative Order on Consent (AOC) for a non-time-critical removal
action, which called for an engineered cap/liner system on the WWTP Landfill, a mechanically
stabilized earthen barrier wall, and replacement of the drainage swale. This response action
was designed to manage surface and subsurface soils while also preventing subsurface water
infiltration. The final design of the engineered cap also included a meadow to provide habitat
for butterflies, bees, and other species. AWI completed construction on the WWTP Landfill in
April 2016.
In September 2018, the EPA and a group of PRPs entered into an AOC for the performance of an
RI/FS for OU2. The PRPs finalized the Rl in March 2023. The FS was finalized in November 2023.
3.0 Community Participation
EPA released the draft Proposed Plan for the Site for public comment on May 30, 2024. The
draft Proposed Plan, the RI/FS Report, and other Site-related documents were made available
to the community in the Site's AR file maintained online at
http://www.epa.gov/superfund/armstrong-world-industries. The AR is also accessible on public
computers at the Site's information repository, Middle Georgia Regional Library, located at
1180 Washington Avenue in Macon, Georgia. People can contact the library directly at
(478) 300-6744.
The notice of availability of these documents was published in the Macon Telegraph on
May 24, 2024. A public comment period was held from May 30, 2024, through July 1, 2024.
A public meeting was held virtually via Zoom on May 30, 2024, where the EPA presented
information about the Site and the remedial alternatives for SU-7 and the landfills that were
presented in the 2023 FS. Following the meeting, representatives from the EPA answered
questions about the Site, nearby areas, and the remedial alternatives.
Comments received by the EPA during the public comment period are summarized and
addressed in the Responsiveness Summary, which is a part of this ROD.
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The EPA issued a Community Involvement Plan (CIP) for the Site in March 2020. The CIP
includes a history of community participation and can be accessed online at:
https://semspub.epa.eov/src/document/04/11149257.
4.0 Scope and Role of Operable Units
The EPA is managing the cleanup of the Site as three OUs, as follows (see Figure 1):
• OU1 addressed the approximately 4-acre WWTP Landfill;
• OU2, the subject of this ROD, addresses SU-7 soils/sediment, the Remote and FMNOL
landfills, and rocky creek surface water, sediment, and biota (including fish); and
• OU3 will address groundwater beneath OU2.
As the sole PRP for OU1, and using Superfund's removal authority, AWI completed a removal
action at OU1 in 2016. It included the construction of an engineered cap/liner system over
the WWTP Landfill, a mechanically stabilized earthen barrier wall, and replacement of the
drainage swale.
Addressing the groundwater beneath OU2 will require coordination with the ongoing
investigations at the MNOP Superfund Site. The MNOP Site is situated north and adjacent
to OU2.
5.0 Site Characteristics
5.1 Conceptual Site Model (CSM)
The CSM incorporates information on potential chemical sources, affected media, release
mechanisms, routes of migration, and known or potential human and ecological receptors. In
this way, it illustrates the physical, chemical, and biological relationships between contaminant
sources and affected resources. This CSM evaluates potential human exposure pathways for
soil, sediment, surface water, groundwater, and biota collected at OU2. Potential exposure
pathways are shown in the human health CSM in Figure 4.
5.2 Overview of the Site
5.2.1 Geologic. Hydrogeologic. and Topographic Information
Site Topography and Drainage: OU2 is approximately 350 acres and is densely forested land on
a south-facing slope along Rocky Creek. Land surface elevation along the slope ranges from
340 feet above mean sea level near the MNOP, to 275 feet above mean sea level along Rocky
Creek. Figure 5 shows Site topography. OU2 is bisected by an abandoned rail spur and a water
reclamation facility operated by the M WA, which act as a natural boundary between the upland
terrace and bottomland. Low-lying areas within the bottomland, much of which is designated as
wetlands, are prone to flooding from Rocky Creek.
Site Geology and Hydrogeology. OU2 is situated at the western margin of the Coastal Plain
physiographic province within the Fall Line Sand Hills District. The topography of the region is
mostly flat, with shallowly sloping hills and discontinuous ridges. OU2 is underlain by two
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distinct hydrogeologic units separated by a regionally continuous kaolin clay layer. The
accumulation of rainfall infiltration above the clay layer produces a "perched" water-bearing
zone suspended above the regional aquifer (the Tuscaloosa Aquifer). Rl and FS activity
related to groundwater is ongoing and remedial action for groundwater, will be selected in a
separate ROD.
Site Hydrology. OU2 is located in the Ocmulgee River Basin, about 5 miles northwest of the
Ocmulgee River. Rocky Creek is a secondary tributary of the Ocmulgee River and the dominant
surface water feature at OU2 (see Figure 1). Rocky Creek is a perennial stream with a low
gradient and low flow velocity that floods frequently. It transitions from a shallow, braided
stream to a wider and deeper single channel across OU2. The creek is bordered upstream by
Lake Wildwood dam and Tobesofkee Creek (originating at Lake Tobesofkee dam), inland by
forested wetlands and upland areas, and downstream at its confluence with Tobesofkee Creek
(which flows into the Ocmulgee River).
Three drainage ditches, originating at the neighboring MNOP Superfund Site and the AWI
facility property, meander through 0U2 and drain into Rocky Creek: Ditch #2, Ditch #3, and
Ditch #4. Ditch #2, a perennial channel, carries commingled process wastewater/water and
stormwater discharge from the AWI manufacturing facility. Ditch #3 and Ditch #4 are poorly
defined, ephemeral channels. Ditch #2 frequently forms new channels and is therefore a multi-
channel network through which the predominant flow path changes continually.
During a typical year, large expanses of the 0U2 bottomland floodplain are temporarily flooded
by Rocky Creek. The submerged surface area expands and contracts as the flood water
advances and recedes, respectively, with changes in Rocky Creek water elevation. Backwater
caused by downstream flow restriction can cause floodwater to be retained in the floodplain
over a period of days to weeks. Consequently, some parts of 0U2 south of the abandoned
rail spur are classified as wetlands according to the National Wetlands Inventory, as shown
in Figure 6.
5.3 Sampling Strategy
The 2023 0U2 Rl included sampling of soil, groundwater, sediment, surface water, landfill
waste, and fish tissue. The Rl also included topographical, ecological, and water use surveys.
Based on the investigation and subsequent risk assessment, soil was identified as the only non-
groundwater media of concern at 0U2.
Soil: Soil sampling was performed using incremental sampling methodology (ISM) (ITRC, 2020a)
to accommodate large-scale spatial heterogeneity (i.e., variation in chemical concentration
across an area orvolume). The soil sampling design included 21 Sampling Units (SUs) and
targeted the top 6-inches of the soil. SU boundaries were determined based on
physical/topographic features and wetlands inventory maps. On average, the size of the SUs
was 4-5 acres in accordance with the Local Assessment Population Area (LAPA) for a mammal
with a small home/foraging range (ODEQ, 2017). Three replicate samples comprising 30
aliquots of soil were established from each SU. Thus, a total of 90 aliquots were collected in
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each SU providing representative coverage across the SU. Discrete soil sampling was conducted
at SU-7 after its area-average sampling revealed the elevated contamination.
Sediment: Sediment sampling was performed as dictated by weather and flood stage
conditions from January 2020 to April 2020. Eight sediment characterization was performed
using ISM and involved 15 SUs spanning the drainage ditches, Rocky Creek (upstream of and
adjacent to OU2), and Tobesofkee Creek within Bond Swamp. The analytical testing regimen
comprised of PCBs (Aroclors and congeners), polycyclic aromatic hydrocarbons (PAHs),
and metals.
Surface Water. Discrete (grab) surface water samples were collected from Rocky Creek, the
drainage ditches, and a groundwater seep emanating from the Landfills. The surface water
samples were tested for metals, PCBs (Aroclors and congeners), and specific volatile organic
compounds (VOCs) (same list as for groundwater). The seep sample was tested for the same list
of analytes as for surface water, PAHs, Bis(2-ethylhexyl) phthalate (BEHP), perchlorates, and
energetics. At the request of EPD, additional surface water samples were collected in
November 2021 to confirm the presence/absence of PCBs in Ditch #2.
Fish Tissue: During the Rl, fish were collected from Rocky Creek and Tobesofkee Creek to test
the edible tissue for evaluation of potential human health risk from fish consumption. This fish
sampling was done in three zones within Rocky and Tobesofkee Creeks: the first zone was
upstream of the Site near Houston Road; the second zone was in OU2 near and downstream of
the railroad trestle; and the third zone was downstream of the confluence of Rocky and
Tobesofkee Creeks (see Figure 7). Fish collection was performed in December 2019 and May
2020, with a total of 357 individual specimens collected, representing 17 fish species. These fish
samples were composited into 76 samples representing the same or similar species, in
accordance with the memorandum entitled "Fish Compositing Strategy for Evaluating Risk
to Human Health" (EPS, 2020a). The 76 composite samples were then tested for PCBs
and mercury.
Landfill: A sample of landfill material (i.e., the residuum beneath the soil cover) was collected
from the FMNOL and from the Remote Landfill and tested for degradable organic matter
(volatile suspended solids) and moisture content. The purpose of this testing was to
evaluate potential future settlement due to biodegradation and dissipation of pore water
from void spaces.
Topographical, Ecological, and Water Use Surveys: Drone-based light detection and ranging
(LiDAR) topography was collected for OU2 to determine the current land surface elevation of
the FMNOL and Remote Landfill and to evaluate past settlement across the Landfills. An
ecological use survey was conducted in OU2 to evaluate the small mammal population. A
records survey was conducted to determine the nature of surface water and groundwater use
within a 3-mile radius of OU2. The classification and extent of wetlands across OU2 and along
Rocky Creek from lnterstate-75 to the Ocmulgee River according to the National Wetlands
Inventory (NWI) database is depicted in Figure 6.
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5.4 Known or Suspected Sources of Contamination
PCBs: Historically, PCBs were used in a variety of industrial applications. While there is no direct
evidence, historical operations at AWI and the MNOP may have contributed to soil PCB
concentrations in OU2. PCBs (primarily Aroclor-1248) were the primary COCs at OU1, at which
the 2016 OU1 removal action addressed the potential for PCB transport from waste material to
the adjacent Ditch #1. Manufacturing-related sources of PCBs from the MNOP have not been
identified, although transformers were reportedly used at the Site in the past.
The modestly decreasing PCB concentration gradient in surficial soil along the historical path of
Ditch #2, and east along Rocky Creek, suggests Ditch #2 as a potential historical transport
pathway for PCBs. However, the concentration distributions observed in OU2 soils and
sediments suggest that another source within OU2 (e.g., a local source at SU-7) not associated
with Ditch #2 is possible. Sediment chemistry at upstream reference stations within Rocky
Creek indicates that upstream industrial activity along Rocky Creek is not a source of
PCB contamination.
Metals: Heavy metal pollution has been linked to military and textile operations. Live-fire
training or testing, low-order detonations of munitions used in training or testing, or open
burning and open detonation treatment/destruction activities at military sites can cause
cadmium, copper, and lead residues in the environment. Process water generated from
machining and plating of munitions and ordnance is known to contain cadmium, copper,
and lead. Similarly, textile manufacturing effluents contain metals such as cadmium,
copper, and lead from metallic salts, metal complex dyes, and/or dye mordants used in the
'wet-forming' process.
Cadmium, copper, and lead contamination in OU2 soil may be attributable to: (1) historical
discharges from the AWI and MNOP WWTPs to Ditch #1 and/or Ditch #2; (2) former burning
and explosives testing operations at the explosives demolition area; and/or (3) leaching from
waste materials deposited in the landfills.
5.5 Nature and Extent of Contamination
The 2023 OU2 Rl Report presents detailed information regarding the nature and extent of
contamination associated with each area of OU2.
Soil: The 2023 OU2 Rl sampling results found PCBs, which are expressed as total PCB Aroclors,
and metals, specifically cadmium, copper, and lead, in soil throughout OU2. The highest area-
average total PCBs concentration (70.9 ppm) occurs in SU-7 adjacent to Ditch #2 in the
northwest corner of OU2 upgradient of the FMNOL (see Figure 8, which refers to SU-7 as SU-7-
SO). Within SU-7, PCB concentrations decrease with depth. SU-5 and SU-3 have total PCBs
concentration of 37.9 ppm and 21.2 ppm respectively.
A second soil sampling event was conducted at SU-7 after its area-average sampling found the
elevated PCB level of 70.9 ppm. Within SU-7, the highest PCB level found in the discrete soil
samples was 934 ppm, as shown in Figure 8.
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The highest concentrations of cadmium occur along the floodplain bordering the historical path
of Ditch #2. Cadmium is more prevalent at the FMNOL than at the Remote Landfill. Cadmium is
distributed in a relatively uniform manner in the near-channel floodplain soil north of Rocky
Creek. Cadmium concentrations decrease with depth. Cadmium was also reported in SU-3 soils
at 26.5 ppm (see Table 1).
Copper concentrations are highest in surface soil at the FMNOL and in the explosives
demolition area and SU-2. Copper detections in subsurface soil are generally consistent with
background conditions, except at the southwest toe of the FMNOL where the copper
concentration at depth is similar to the surficial condition.
Lead concentrations are relatively uniform across OU2 in the range of 90 ppm to 105 ppm, with
no discernable concentration gradient. The highest area-average concentration (134.6 ppm)
occurs in SU-7. Subsurface lead detections are generally consistent with background conditions,
except at the southwest toe of the FMNOL where discrete samples report lead concentrations
exceeding 100 ppm.
Landfill: The FMNOL and Remote Landfill are non-engineered features that began accumulating
waste prior to the enactment of the Resource Conservation and Recovery Act (RCRA) in 1976.
The Remote Landfill was used to dispose of excess bark and scrap wood, old equipment, and
general refuse from the AWI manufacturing process, as well as fibrous material and sludge from
the AWI WWTP process. The FMNOL was used to dispose of construction rubble (e.g., concrete,
rebar, metal sheeting), used machinery parts, ordnance, and other miscellaneous solid waste
during operation of the MNOP.
In 1977 both landfills, which had merged by that time, were covered with soil and are no longer
in use. The landfills are currently overgrown with grasses, brush, large shrubs and mature
hardwoods and pines. They show evidence of irregular surface settlement. Deteriorated drum
carcasses are present in the areas around the landfills, with some debris protruding from the
surface of the Remote Landfill. The AWI OU2 Rl determined that over the last 30 years the
Remote Landfill has settled irregularly, with settlement ranging from 0.5 feet to 4.6 feet. The
FMNOL has settled more evenly, with settlement of about 2.8 feet. Significant future
settlement is not anticipated.
Average PCB concentrations were reported below 25 ppm at the Remote and FMNOL landfills
during the 2023 Rl sampling events.
Sediment: PCB mass is distributed relatively uniformly along the drainage ditches and in Rocky
Creek east of the landfills, at a lower concentration relative to that of adjacent floodplain soil
areas. The highest PCB detection in OU2 sediments (15 ppm) occurs in Ditch #2 east of the
FMNOL. PCBs are present in nominal concentrations (non-detect to trace level) in Rocky Creek
upstream of the OU2. PCB concentrations in Rocky Creek decline significantly downstream of
the OU2 boundary. The reach of Rocky Creek between OU2 and Tobesofkee Creek is
characterized by relatively low levels of PCBs (<1 ppm).
Metals in the sediments in the drainage ditches and Rocky Creek were screened out for
ecological risk consideration based either on comparison to background or as a result of
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ecological risk-based evaluations. Human exposure from sediment in Rocky Creek was not
evaluated quantitatively, as EPA guidance indicates that it usually unnecessary to assess the risk
of human exposure to sediments covered by water. Human exposure to sediment from
ephemeral ditches was assessed as a part of exposure to surface soil.
Fish Tissue: Since 2011, based on the limited fish data collected in 1996 and 1999, the EPA has
advised the public that all fish should not be eaten from Rocky Creek downstream of Houston
Road. However, during the OU-2 Rl, in December 2019 and May 2020 more extensive fish
sampling was conducted in Rocky Creek. The results from this updated fish sampling showed
that PCBs in Rocky Creek fish have declined significantly (by approximately 80%). The EPA now
advises that the public should avoid channel catfish and spotted sucker fish from Rocky Creek
downgradient of Houston Road, as these two bottom feeder fish had the highest
concentrations of PCBs among all fish sampled between 2019 - 2020 (however, only one of the
357 fish was a channel catfish).
5.5.1 Chemicals of Concern tCOCs)
COCs in Site soils and sediments include PCBs, cadmium, copper, lead, benzo(a)pyrene, and
dibenzo(a,h)anthracene.
5.5.2 Amount of Waste to be Addressed
The OU2 FS identified three different remedial action footprints in SU-7 for the cleanup of PCB-
contaminated soil allowable under TSCA regulations to reduce human health and ecological
risks in SU-7 to an acceptable level. These options are discussed below. The FMNOL and
Remote Landfill will also be addressed, collectively totaling about 12 acres.
The first two SU-7 remedial action footprints (Action Area Option #1 and Action Area Option #2)
are based on unacceptable risk to ecological receptors, while the third remedial action footprint
(Action Area Option #3) is based on a designated remedial action level of 25 ppm. It
encompasses the area included in Action Area Option #1 and Action Area Option #2. The Action
Areas are described as follows:
• Action Area #1, derived through a geospatial, ecological risk-based statistical approach,
encompasses 1.1 acres to 1 foot below ground surface (about 1,775 cubic yards). Figure
9 shows Action Area #1;
• Action Area #2, based on unacceptable risk to ecological receptors at discrete sampling
locations, encompasses 1.7 acres to 1 foot below ground surface (about 2,743 cubic
yards). Figure 10 shows Action Area #2; and
• Action Area #3, based on an action level of 25 ppm at discrete sampling locations,
encompasses 2.3 acres to 1 foot below ground surface or 2 feet below ground surface in
a small area where soil PCB concentrations exceeded the action level below 1 foot
below ground surface. The total volume is 4,087 cubic yards (selected remedy RA-SU7-
6). Figure 11 shows Action Area #3.
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5.5.3 Concentrations of COCs
The average PCB concentrations within SU-3, SU-5, and SU-7 are 37.9 ppm, 21.2 ppm, and 70.9
ppm, respectively. Copper concentrations are highest in the FMNOL. Lead concentrations are
relatively uniform across the OU2 sampling units in the range of 11.9 ppm to 134.6 ppm, with
no discernable concentration gradient. The average lead concentration in SU-7 is 134.6 ppm.
Table 1: COC Concentrations in Soil Sampling Units
Sampling Unit
Chemical of Concern
Average
Concentration
(PPM)
Quantity/volume of
Waste
SU-7
PCBs
70.9
4,087 cubic yards
(selected remedy
RA-SU7-6)
Benzo(a)pyrene
4.3
Dibenzo(a,h)anthracene
0.84
Lead
134.6
SU-3
PCB
21.2
Not Applicable*
Cadmium
26.5
SU-5
PCBs
37.9
FMNOL/Remote
Landfills
Copper
191.7
12 acres of debris
removal
*Remediation is not currently proposed at SU-3 and SU-5.
5.5.4 TSCA PCB Waste and Affected Media
As shown in Table 1, the estimated volume of soil to be addressed by the selected remedy for
SU-7 is 4,087 cubic yards. Of the 102 discrete surface soil samples collected in SU-7, there were
36 samples that found PCBs above the TSCA PCB waste threshold of 50 ppm. Based on that
data, it is estimated that roughly a third of this volume, or 1,400 CY, may be TSCA PCB waste
requiring disposal at an approved TSCA Chemical Waste landfill or a permitted RCRA Subtitle C
landfill approved by EPA. The remaining PCB contaminated soil is considered PCB remediation
waste as defined in 40 CFR 761.3.
5.6 Location and Potential Routes of Migration
5.6.1 Surface and Subsurface Routes of Exposure
The Human Health Baseline Risk Assessment (HHBRA) for OU2, discussed in Section 7.1 of this
ROD and in the OU2 Rl Report, evaluated the following current human receptor populations
and exposure routes:
• Site receptors were evaluated for ingestion, dermal contact, and inhalation exposure
to soil;
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• Adult and adolescent trespassers were evaluated for ingestion, dermal contact, and
inhalation exposure to soil, including sediment in ephemeral ditches; and
• Adult and adolescent anglers were evaluated for ingestion offish and dermal contact
with surface water from Rocky Creek.
A supplemental human health risk assessment also evaluated risks to the potential future
industrial worker, from exposure to SU-7 surface soils (see Section 7.1.4).
The Baseline Ecological Risk Assessment (BERA) evaluated 13 representative species based on
ingestion of contaminated food items, incidental soil or sediment ingestion, and/or ingestion of
surface water. The BERA is summarized in Section 7.2 of this ROD and in the OU2 Rl Report.
5.6.2 Location and Migration of COCs to Other Media
PCBs: PCBs released to the environment preferentially bind to organic matter and thus are
retained and accumulated in soil and creek bed sediments. PCBs sorbed to particles can
become suspended in surface water, transported, settled, and buried in Rocky Creek and its
floodplain. Fish foraging near OU2 and downstream in Tobesofkee Creek accumulate higher
amounts of PCBs relative to fish foraging upstream of OU2. However, the PCB concentrations
in fish decrease downstream of OU2 and fish concentrations have improved significantly
over time.
Metals: In floodplain soil, the metals not bound in primary minerals are considered potentially
mobile as cyclic flooding and drainage affect the retention of metals through changes in redox
and pH conditions. However, except where a flooded soil or sediment becomes strongly acidic
upon drainage and oxidation, the processes immobilizing metals tend to prevent large-scale
metal releases from contaminated soils with changing redox conditions. In fact, metals tend to
be retained more strongly in flooded soils compared to upland soils. In general, floodplain
settings (e.g., high degree of saturation, reducing conditions, circumneutral pH, and organic-
and sulfur-enriched) promote microbially mediated sulfate reduction and formation of
insoluble sulfides for metals with constant valence (e.g., cadmium, copper, and lead).
The soil and sediment conditions in OU2 are considered mature and stable. The establishment
of significant vegetative growth in the floodplain following remedial action in SU-7 is expected
to stabilize these areas and the broader Site as root systems increase soil cohesion and
facilitate soil retention. At the Remote Landfill, differential settlement of the vegetated soil
cover creates areas for potentially minor releases of waste materials although, significant
additional settlement is not predicted to occur.
Rocky Creek may experience transient increases in sediment transport in response to high
flows. However, the low gradient of the channel limits the propensity for sediment erosion and
thus the extent that sediments are redistributed within the channel and the rate of deposition
in the near-channel floodplain.
5.6.3 Affected Populations
Human and ecological population that could be affected currently are discussed below:
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• Human Population
o Current: Site inspectors, adult and adolescent trespassers, and anglers,
o Anticipated Future: Commercial/industrial workers.
• Ecological Population: Insectivorous birds.
6.0 Current and Potential Future Uses
6.1 Land Uses
The EPA evaluates reasonably anticipated future land use based on information and
assumptions such as zoning maps, nearby development, 20-year development plans, dialogue
with local land use planning officials and citizens, and reuse assessment. AWI OU2 is part of a
large area that is zoned as "M-2 Heavy Industrial District" by Macon-Bibb County. This zoning
designation anticipates non-residential land uses, which may be "obnoxious or offensive by
reason of emission of odors, dust, smoke, gas, noise, or vibration." Current use of the land
outside the FMNOL and the Remote Landfill is limited to activity related to the MWA sewer
easement and water reclamation facility. OU2 is not readily accessible or near residential areas,
while the dense undergrowth and frequent flooding make it unattractive for trespassers.
The 2040 Future Land Use Plan published by Macon-Bibb County (Macon-Bibb Planning &
Zoning Commission, 2017) shows portions of OU2 (the areas outside the 100-year floodplain) as
designated for future industrial use. Chapter 5 of the Future Land Use Plan indicates that it is
not the policy of the county to categorically prohibit all development in a floodplain, "though
any development deserves extra scrutiny." Thus, no portion of OU2 is excluded from future
industrial land use consideration. However, upland areas (e.g., areas above the abandoned rail
spur and the landfills) are more conducive to future industrial development.
Conditions at OU2 (the presence of landfills, expansive wetlands, and frequent flooding) make
the area undesirable for development. The property owners have no intention of converting any
portion of the property to residential use, and this restriction as part of any sale in the future will
be recorded (i.e., an environmental covenant) to prevent residential use, prohibit the use of
groundwater for potable purposes, and impose restrictions on soil and landfill cover disturbance.
EPA's risk assessments were based on the following land use assumptions:
• Human health:
o current receptors (angler, trespasser, site inspector) for all sampling units,
including areas located within the 100-year floodplain (such as SU-3 and SU-5)
(Figure 6);
o future potential worker based on industrial land use in SU-7, an area located
above the 100-year floodplain; and
• Environmental: insectivorous birds based on current land use (ecological habitat).
7.0 Summary of Site Risks
The baseline risk assessment provides the basis for taking action and identifies the
contaminants and exposure pathways that need to be addressed by the remedial action. As
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part of the RI/FS, the PRPs conducted baseline risk assessments to estimate the current and
future effects of contaminants on human health and the environment.
The baseline risk assessments include an HHBRA Report and a BERA Report. The EPA's Scientific
Support Section also performed a supplemental human health risk assessment (HHRA) for
SU-7 soils. This section of the ROD summarizes the results of the baseline risk assessments for
the Site.
7.1 Human Health Baseline Risk Assessment
The 2022 OU2 HHBRA estimated human health risks for the Site inspector, trespasser, and
angler based on current land use. Unacceptable risks to humans, both carcinogenic and non-
carcinogenic, were not found for these three exposure scenarios.
However, because the Site is zoned for potential industrial use, a supplemental HHRA was also
performed to estimate human health risks for the future potential industrial worker. This
supplemental HHRA focused on SU-7, the sampling unit where the highest levels of PCBs had
been found. The results showed that SU-7 presented an unacceptable non-carcinogenic risk to
the future potential industrial worker, as shown in Table 2.
Groundwater was not evaluated as part of the 2022 OU2 HHBRA because groundwater will be
addressed as OU3.
7.1.1 Hazard Identification
The HHBRA considered soil, surface water, and fish tissue data collected during the Rl, while the
supplemental HHRA considered surface soil data collected in SU-7. Human health chemicals of
potential concern (COPCs) evaluated for the potential for excess lifetime cancer risks and
noncancer hazards to current and future receptors are as follows:
• PCBs in surface soil and surface water;
• PCBs (Aroclors and congeners) and mercury in fish;
• Benzo(a)pyrene in surface soil; and
• Dibenzo(a,h)anthracene in surface soil.
7.1.2 Exposure Assessment
The HHBRA and supplemental HHRA evaluated the following receptors and pathways:
• Site inspectors, who infrequently visit the area to inspect the MWA sewer easement,
keep roads clear, and maintain fences in the landfill area, were evaluated for ingestion,
dermal contact, and inhalation exposure to soil in the remote landfill, the FMNOL, SU-2
(including sediment, which is treated as soil for the risk assessment), and portions of
SU-22, SU-7, SU-4, SU-8, and SU-10;
• Adult and adolescent trespassers were evaluated for ingestion, dermal contact, and
inhalation exposure to soil in the entirety of OU2, including sediment in ephemeral
ditches, which is treated as soil;
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• Adult and adolescent anglers were evaluated for ingestion offish and dermal contact
with surface water from Rocky Creek; and
• Future potential industrial workers were evaluated based on incidental ingestion of soil,
dermal contact with soil, and fugitive dust.
7.1.3 T oxicitv Assessment
The risks associated with estimated exposures to the COPCs detected at OU2 are a function of
the inherent toxicity of each constituent, as well as the estimated exposure dose. Generally,
two categories of information are considered related to toxicity: potential acute or chronic
noncancer effects of constituents, and the potential for constituents to initiate or promote
cancers. Non-carcinogenic and carcinogenic toxicity values were taken from the EPA's
Integrated Risk Information System (IRIS). Noncarcinogenic toxicity criteria are not available for
total PCBs, so the HHBRA and supplemental HHRA used the toxicity values for Aroclor-1254
because it was the most commonly detected Aroclor for which toxicity criteria are available.
7.1.4 Risk Characterization
The EPA considers two types of risk: cancer risk and noncancer risk. The likelihood of any kind
of cancer resulting from a Superfund site is generally expressed as an upper bound probability,
for example, a "1 in 10,000 chance." In other words, for every 10,000 people that could be
exposed, one additional cancer case may occur because of exposure to site contaminants. An
extra cancer case means that one more person could get cancer than would normally be
expected to from all other causes. For noncancer health effects, the EPA calculates a hazard
index (HI). The key concept is that a "threshold level" (measured as a hazard index of less than
1) exists below which noncancer health effects are no longer predicted. A CERCLA response
action is generally warranted when cancer risk is greater than 1 x 10"4 or when noncancer
health effects are greater than an HI of 1.
The 2022 HHBRA, reflecting current Site conditions for trespasser and site inspector exposure
scenarios, concluded that none of the reasonable maximum exposure scenarios assessed pose
an excess lifetime cancer risk or exceed noncancer risk thresholds. However, because the AWI
Site is zoned for industrial use, a supplemental HHRA for potential human health risk for future
industrial receptors in SU-7 was performed by EPA. Based on the data collected for the 2022
HHBRA, there is a potential for noncarcinogenic unacceptable risk from total PCBs in surface
soil to future industrial workers.
While the conditions at AWI OU2 are not currently suitable for redevelopment, the site is zoned
for industrial use, so carcinogenic and non-carcinogenic risks from SU-7 surface soils were
calculated for the future potential industrial worker scenario in the supplemental HHRA. The
cancer risk for the future worker from exposure to SU-7 surface soil is lxlO"4; this carcinogenic
risk equals the upper range of the EPA's acceptable risk range of lxlO"6 to lxlO"4. The
noncarcinogenic risk for the future worker from SU-7 surface soils is 7, expressed as a hazard
index (HI); this risk exceeds the EPA's target HI of 1, indicating a potential for unacceptable risk
in SU-7 surface soils for the future Site worker. As a result, remediation of surface soils in SU-7
is recommended.
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The results from the December 2019 and May 2020 fish sampling showed that PCBs in Rocky
Creek fish have declined significantly. Based on this data, the HHBRA found that the fish tissue
does not pose an unacceptable risk (Cancer Risk of 6x106 and HI of 0.6) and thus no remedial
action is required to address fish in Rocky Creek. However, it is noted that bottom-feeding fish,
channel catfish and spotted sucker fish, from Rocky Creek downgradient of Houston Road have
the highest concentrations of PCBs among all fish sampled.
As outlined in Section 7.2.1 of the 2022 HHBRA, fish were collected from Rocky Creek and
Tobesofkee Creek to test chemical residue concentrations in the edible tissue for evaluation of
potential human health risk from fish consumption. The sampling design was adapted from the
historical fish collection included six distinct collection zones (reaches) within Rocky Creek
(three upstream of AWI OU2 and three adjacent to AWI OU2) and one additional collection
zone within Tobesofkee Creek downstream of AWI OU2 (in the Bond Swamp National
Wildlife Refuge).
Table 2 summarizes human health risks in AWI OU2, and SU-7 based on reasonable maximum
exposure assumptions (RME). The results of human health are below the risk thresholds,
indicating no unacceptable risk for human health for current receptors (angler, trespasser, and
site inspector) based on current usage of the Site. There is potential unacceptable risk from
exposure to total PCBs in surface soil to future industrial workers in SU-7.
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Table 2: Human Health Risks at OU2 and SU-7
Current Risks for the 0U2 Site Inspector, Trespasser, and Angler
Site Inspector
Exposure
Medium
Contaminant
Carcinogenic Risks
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Soil
PCBs
1 x 10"6
0.09
Benzo(a)pyrene
1 x 10"7
0.001
Dibenzo(a,h)anthracene
3 x 10 s
-
Total = 2 x 10"6
Total = 0.09
Trespasser
Exposure
Medium
Contaminant
Carcinogenic Risks
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Soil
PCBs
5 x 10"7
0.08
Benzo(a)pyrene
6 x 10"8
0.001
Dibenzo(a,h)anthracene
1 x 10 s
-
Total = 6xl0"7
Total = 0.08
Angler
Exposure
Medium
Contaminant
Carcinogenic Risk
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Surface
Water
PCBs
6 x 10 s
-
Fish
PCBs
3 x 10"6
0.5
Mercury
--
0.1
Total = 3 x 10"6
Total = 0.6
Risks for SU-7 Sampling Unit
Potential Future Industrial Worker
Exposure
Medium
Contaminant
Carcinogenic Risk
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Soil
PCBs
1 x 10"4
7.23
Benzo(a)pyrene
3 x 10"6
0.0257
Dibenzo(a,h)anthracene
5 x 10"7
-
Total = 1 x 10"4
Total = 7
7.2 Ecological Risk Assessment
The BERA, which is summarized in Section 11 of the OU2 Rl Report, evaluated the potential for
ecological risks posed by site contamination to ecological receptors representative of general
community types found in and around the OU2 area. Site contaminant concentrations were
initially screened against ecological screening values and compared to background
concentrations. For contaminants that did not screen out, food chain modeling (FCM) was
employed to estimate exposures of representative bird and mammal species to Site
contamination and what risks these contaminant exposures might pose. As part of the FCM,
invertebrates (earthworms, terrestrial insects) and plants (primarily berries) were collected
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from areas across OU2 and analyzed for Site contaminants to better estimate exposure of birds
and mammals to Site contaminants that might occur from consuming food items on the Site.
Additionally, benthic community surveys and small mammal surveys were performed to
determine if potential risks that had been calculated were supported or refuted by actual
field observations.
7.2.1 Identification of Chemical of Concern
The BERA evaluated 10 contaminants of potential ecological concern (COPECs) including PCB
Aroclors, high molecular weight PAHs (HMWPAHs) and low molecular weight PAHs (LMWPAHs),
and various metals (aluminum, cadmium, copper, iron, lead, mercury, and zinc). Table 3
summarizes COPECs for each environmental media.
Table 3: COPECs, by Environmental Media
Constituent
Soil
Sediment
Surface Water
PCB Aroclors
X
X
X
HMWPAHs
X
X
LMWPAHs
X
Aluminum
X
Cadmium
X
X
Copper
X
X
Iron
X
Lead
X
Mercury
X
X
Zinc
X
X
Notes:
"X" denotes that constituent is a COPEC for corresponding environmental media.
Source: Section 2.7 of 2022 OU2 BERA.
7.2.2 7.2.2 Exposure Assessment
The BERA presented a risk characterization for the following endpoints, species, and
exposure pathways:
• Granivorous mammals, represented by the eastern gray squirrel, based on ingestion of
contaminated seeds;
• Granivorous birds, represented by the mourning dove, based on ingestion of
contaminated seeds;
• Herbivorous mammals, represented by the muskrat and eastern cottontail, based on
ingestion of contaminated plant matter;
• Insectivorous mammals, represented by the cotton mouse, based on ingestion of
contaminated insects (and to a lesser extent earthworms and plant matter);
• Insectivorous birds, represented by the American robin, ingestion of contaminated
invertebrates (and to a lesser extent vegetation);
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• Omnivorous mammals, represented by the racoon, based on ingestion of contaminated
crayfish, insects, berries, plant matter, and seeds;
• Terrestrial-feeding carnivorous mammals, represented by the red fox, based on
ingestion of contaminated small mammals;
• Carnivorous birds, represented by the red-tailed hawk, based on ingestion of
contaminated small mammals;
• Piscivorous mammals, represented by the American mink, based on ingestion of
contaminated fish and crayfish;
• Piscivorous birds, represented by the green heron, based on ingestion of contaminated
fish and crayfish;
• Omnivorous reptile populations, represented by the eastern box turtle, based on
ingestion of contaminated vegetation, earthworms, insects, and crayfish;
• Carnivorous reptiles, represented by the common garter snake, based on ingestion of
contaminated small mammals and insects; and
• The benthic community, based on contact with contaminated sediment.
7.2.3 Ecological Effects Assessment
The BERA determined that COPECs in sediment likely pose no unacceptable risks to OU2
ecology based upon comparisons to refinement screening values and background sediment
concentrations of the COPECs. This anticipated lack of adverse effects was confirmed by the
results of a benthic community study performed in the site drainages near Rocky Creek and in
Rocky Creek itself. Similarly, the COPECs in surface water were determined to not pose risks to
ecological receptors in 0U2 as they screened out after comparing the filtered surface water
sample COPEC concentrations to surface water screening values.
There was still some concern for risks posed by the Site contaminants in 0U2 surface soils. The
BERA evaluated the viability (i.e., growth, reproductive ability, and survival) of the various
mammalian and avian assessment endpoints inhabiting 0U2 through food-web exposure
models, with estimated risks expressed in terms of hazard quotients (HQs). After the initial
round of FCM was performed, potentially unacceptable risks were identified for
insectivorous/omnivorous birds and small home range mammals. To investigate the potential
for adverse effects on the small home range mammal community, a small mammal
demographic study was performed to determine the health of the small home range mammal
community in 0U2 vs. a nearby reference site. The results of the study indicated that the 0U2
small mammal community was as robust as the reference site, and consequently there did not
appear to be any identifiable adverse effects from Site contaminants on the small mammal
community in 0U2.
To refine the risk estimates for the remaining receptors for which potentially unacceptable risk
had been estimated, which was insectivorous/omnivorous birds (represented by the American
Robin in the FCM), site-specific data on the bioaccumulation of surface soil contaminants by
food items ("prey items") in 0U2 were collected. This was determined to be the most
important type of data needed for risk refinement in this case as the vast majority of the
contaminant doses to the birds were calculated to be coming from ingestion of contaminated
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food. At selected locations across most of the Sampling Units, collocated samples of surface
soils, earthworms, terrestrial (aboveground) invertebrates, and vegetation (primarily berries)
were collected and analyzed for Site contaminants. The data from these samples were used to
calculate site-specific soil-to-prey-item bioaccumulation factors (BAFs) for OU2, and these
OU2 BAFs were used in the revised FCM to replace the generic BAFs used in the initial FCM
risk calculations.
7.2.4 Ecological Risk Characterization
The BERA determined that the only ecological receptors in OU2 at potentially unacceptable
risks from Site contamination were terrestrial insectivorous/omnivorous birds. The risk
estimates in the BERA show that the primary risks to insectivorous/omnivorous birds are from
eating PCB-contaminated earthworms in SU-7. Other risks to insectivorous/omnivorous birds,
lower yet still potentially unacceptable, also exist from other contaminants in both SU-7 and
the sampling units SU-3 and FMNOL.
These ecological risks expressed as a hazard quotient (HQ) are summarized below and in
Table 4, where a HQ greater than 1 indicates the potential for adverse effects.
• Potentially significant risks from PCBs in SU-7;
• Potentially modest risks from lead in SU-7;
• Potentially modest risks from PCBs and cadmium in SU-3; and
• Potentially modest risks from copper in FMNOL.
Table 4: Ecological Risks for SU-3, SU-5, SU-7 and FMNOL
Receptor
Media/Pathway
Sampling Unit of
AWI OU2
Contaminants of
Concern (COC)
HQ
Ingestion of prey
SU-7
PCB
19
Insectivorous/
(insects and
invertebrates such
as earthworms),
fruits/berries, and
incidental
ingestion of
surface soil
Lead
3
Omnivorous
SU-3
PCB
1.4-2.7*
Bird
Cadmium
2.6
(American
SU-5
PCB
1.2
Robin)
FMNOL
Copper
3.6
*The measured soi
PCB concentrations in SU-3 were highly variable resulting in significant uncertainty on
the exposure concentration for insectivorous birds; therefore, two HQs were calculated for SU-3. The HQ of
2.7 is based on the highest PCB soil concentration statistical estimate and has the most uncertainty, while
the HQ of 1.4 is based on the maximum measured PCB soil concentration.
The following sources of uncertainty were identified in the ecological risk assessment:
• Assuming 100% bioavailability to the birds of contaminants ingested;
• the birds being able to use the area 100% of the time (temporal use factor);
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• predicting adverse population-level effects from chemical exposures using individual-
based extrapolative risk assessment methods, such as HQ estimates;
• lack of ecotoxicity data for reptiles;
• using modestly conservative assumptions; and
• potentially compounding effects from the multiplicity of conservative inputs.
An additional source of conservatism for the SU-3 and SU-5 sampling units are that they are
located in the floodplain and are often flooded by Rocky Creek for days to weeks at a time, as
discussed in Section 7 of the BERA (see Figures 3, 5, and 6), which reduces the amount of time
birds can forage in an area and reduces exposure to both contaminated soil and invertebrates.
Ecological risks in SU-7
Ecological risks due to PCBs in SU-7 are the primary concern, as represented by its HQ value of
19. By removing SU-7 soils with total PCBs above 25 ppm the ecological risk is reduced from a
hazard quotient of 19 to 0.7.
Ecological risks in SU-3 and SU-5
For the SU-3 and SU-5 sampling units, ecological risk estimates range from 1.2 to 2.7,
representing a modest exceedance of an environmental risk criterion of 1.0. These are
considered moderately conservative risk estimates, as they assume, for example, 100% site use
by the birds and 100% bioavailability to the birds of contaminants ingested. Given the
magnitude of the HQs calculated even with the moderate conservativeness of the assumptions,
it was determined that the SU-3 and SU-5 sampling units do not pose unacceptable risks to
insectivorous birds.
Ecological risks in FMNOL
There is potential for ecological risk due to exposure to copper in the FMNOL surface soils
based on an HQ 3.6, which would be effectively addressed by either remedial alternative
RA-LF-2 or RA-LF-3, discussed in Section 8.2.
7.3 Basis for Action
The response actions selected in this Record of Decision are necessary to protect human
health or the environment from actual or threatened releases of hazardous substances into
the environment.
For the current trespasser/Site inspector exposure scenarios, the EPA did not find unacceptable
cancer or noncancer human health risks; however, PCBs in surface soils at SU-7 present an
unacceptable non-carcinogenic risk to future potential commercial/industrial workers. PCBs in
surface soils at SU-7 also present an unacceptable environmental risk to insectivorous birds.
The FMNOL and the Remote Landfill show surface settlement and erosion that has exposed
debris and waste materials, including old drum carcasses, related to historical industrial
dumping. These materials present a physical hazard to current receptors (trespassers and
Site inspectors).
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7.4 Remedial Action Objectives
Before developing cleanup alternatives for a Superfund site, the EPA establishes remedial
action objectives (RAOs) as part of the FS. RAOs are specific goals and objectives to protect
human health and the environment. These objectives address contaminated media, exposure
pathways and risks posed by the site. RAOs may also include reference to preliminary
remediation goals (PRGs), which are based on applicable or relevant and appropriate
requirements (ARARs) such as promulgated chemical-specific standards, where available or
other information and standards, such as to-be-considered (TBC) guidance, and site-specific,
risk-based levels.
The EPA identified the following RAOs for the OU2 cleanup:
• SU-7: Reduce to acceptable levels the risks to the insectivorous bird population from
exposure to PCBs in surficial soil within SU-7 by achieving the cleanup levels;
• SU-7: Reduce to acceptable levels the carcinogenic and non-carcinogenic risks to the
future industrial worker from exposure to PCBs in soil within SU-7 by achieving the
cleanup levels; and
• Landfills: Protect human health and the environment by preventing exposure to physical
hazards, such as buried drums and other industrial waste-related materials.
7.5 Cleanup Levels
Cleanup levels are concentrations of contaminants in environmental media that, when
attained, are protective and achieve RAOs. Cleanup levels for response actions under CERCLA
are generally based on site-specific risk and ARARs. EPA typically uses the results of the
HHRA to establish the basis for taking remedial action. Action is generally warranted for those
impacted media at a site when the baseline HHRA indicates that a cumulative risk exceeds an HI
of 1 using reasonable maximum exposure assumptions for either current or future land use. At
sites where the excess cancer risk is less than lx 10~4 and/or the non-carcinogenic HI is
less than 1, action may still be warranted when a chemical-specific ARAR that defines
acceptable risk is exceeded (e.g., state numeric water quality criteria promulgated under the
Clean Water Act). Only those state standards that are promulgated and that are more stringent
than federal requirements may be applicable or relevant and appropriate.
In addition to chemical-specific ARARs, other advisories, criteria, or guidance may be
considered for a particular release if useful in developing Superfund remedies; see 40 CFR
§300.400(g)(3). This TBC category consists of advisories, criteria, or guidance that were
developed by EPA, other federal agencies, or states that may assist in determining, for example,
health-based or ecological-risk based levels for a particular contaminant or medium for which
there are no chemical-specific ARARs. TBCs are not considered legally enforceable and,
therefore, are not considered to be applicable for a site but typically are evaluated along with
chemical-specific ARARs as part of the risk assessment to determine protective cleanup levels.
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For the SU-7 sampling unit, the area-wide average PCB concentration in surface soils that
results in an estimated HQ of 1.0 for the insectivorous/omnivorous birds is 6.5 ppm. For the
future industrial worker, an area-wide average PCB concentration of 15 ppm or below would be
protective for human health. The RA-SU7-6 selected remedy (Section 8.1.6) will remove all soils
in SU-7 that exceed a PCB concentration of 25 ppm, which is the TSCA standard for a "low
occupancy" area (40 CFR § 761.61(a)(4)(i)(B)(1). After PCBs >25 ppm in soils are removed off-
site, it is estimated that the post-remediation area-wide average PCB concentration in SU-7
surface soils will be 4.3 ppm. This post-remediation area-wide average will be protective of the
future industrial worker as well as the insectivorous/omnivorous birds. The area-wide average
PCB concentrations stated above are based on 95% Upper Confidence Limit of the mean
estimates (see Table 5).
For the SU-5 sampling unit, an area-wide PCB level of 37.9 ppm was found during the Rl. This
PCB level exceeds the 25 ppm TSCA PCB remediation waste cleanup level for a "low
occupancy"; however, TSCA's self-implementing PCB remediation waste cleanup level for a
"low occupancy area" does not apply to the wetlands or sediments such as those at SU-5.
Table 5: SU-7 PCB Soil Cleanup Levels and Post-Cleanup Risks
PCB Cleanup
Level
(area avg.)
Receptors
Basis of Cleanup
Level
Post Cleanup
Level
(area avg. soil
concentration)
Risks Post
Cleanup1
6.5 ppm
Future
Industrial
Worker
ARAR TSCA 40 CFR
§761.61(a)(4)(i)(B)(l)
( < 25 ppm PCB)
Human Health Risk-
Based4
(area average of
< 15 ppm)
4.3 ppm
HQ3 = 0.3
CR2 = 5xl0"6
Insectivorous
Bird
Ecological Risk-
Based4
(area average of
< 6.5 ppm)
HQ3 = 0.7
195% UCL estimate of the mean contaminant concentration as the EPC
2Cancer risk
3HQ = Hazard Quotient
4Total PCB concentrations of 6.5 and 15 were calculated to be protective of the insectivorous bird and the
future industrial worker in SU-7, respectively
8.0 Description of Alternatives
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1), mandates that remedial actions must be
protective of human health and the environment, be cost-effective, comply with ARARs, and
utilize permanent solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 121(b)(1) of CERCLA also establishes a
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preference for remedial actions that employ, as a principal element, treatment to reduce
permanently and significantly the volume, toxicity, or mobility of the hazardous substances,
pollutants, and contaminants at a site. Section 121(d)(2) of CERCLA, 42 U.S.C. § 9621(d), further
specifies that a remedial action must attain a level or standard of control of the hazardous
substances, pollutants, and contaminants, that at least attains ARARs under federal and state
environmental laws, unless a waiver can be justified pursuant to Section 121(d)(4) of CERCLA,
42 U.S.C. § 9621(d)(4).
The 2023 OU2 FS Report evaluated six remedial alternatives for SU-7 and three remedial
alternatives to address the Remote Landfill and the FMNOL. SU-7 Action Area Options are
discussed in Section 5.5.2 and shown in Figures 9, 10, and 11. The Action Area Options
encompass progressively larger areas. Action Area Option #3 encompasses all of Action Area
Option #1 and Action Area Option #2.
SU-7 Alternatives:
• RA-SU7-1: No action
• RA-SU7-2: Soil cover and fencing in Action Area Option #1, and institutional controls
• RA-SU7-3: Partial removal with off-site disposal, soil cover, and fencing in Action Area
Option #1, and institutional controls
• RA-SU7-4: Removal of PCB-impacted soils in Action Area Option #1 with off-site
disposal, and institutional controls
• RA-SU7-5: Removal of PCB-impacted soils > 50 ppm in Action Area Option #2 with off-
site disposal, and institutional controls
• RA-SU7-6: Removal of PCB-impacted soils < 25 ppm in Action Area Option #3 with off-
site disposal, and institutional controls
Landfill Alternatives:
• RA-LF-1: No action
• RA-LF-2: Restoration/repair of existing soil cover, fencing, and institutional controls
• RA-LF-3: Solid waste landfill engineered cap, fencing, and institutional controls
Summaries of the alternatives are presented below. Several of the options include institutional
controls. The institutional controls (such as an environmental restrictive covenant that meets
Georgia Uniform Environmental Covenant Act requirements) would prevent residential land
use, restrict the future use of groundwater and installation of groundwater wells, and prohibit
future activities that might disturb the integrity of the remedy including the capped landfills.
These ICs would also contain appropriate provisions regarding enforceability, notification,
recording, amendment, and termination of the institutional control.
Terminology used to describe and differentiate the alternatives includes:
• Capital costs are those expenditures that are required to construct a
remedial alternative;
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• O&M costs are those post-construction costs necessary to ensure or verify the
continued effectiveness of a remedial alternative and are estimated on an annual basis;
• Total present value means the amount of money that, if invested in the current year,
would be sufficient to cover all the costs over time associated with a project, calculated
using a discount rate of 7% and a 30-year time interval. This discount rate is based on
Office of Management and Budget Circular No. A-94, which states that constant-dollar
benefit-cost analyses of proposed investments and regulations should report net
present value and other outcomes determined using a real discount rate of 7%, because
it approximates the marginal pretax rate of return on an average investment in the
private sector; and
• Construction timeframe is the time required to construct and implement the alternative
and does not include the time required to design the remedy, negotiate performance of
the remedy with responsible parties, or procure contracts for design and construction.
8.1 SU-7 Remedial Alternatives
8.1.1 RA-SU7-1: No action
The "no action" alternative (RA-SU7-1) must be evaluated under the NCP as a baseline against
which all other alternatives are compared. Under this alternative, no remedial actions would
take place. There are no capital costs associated with RA-SU7-1, though the comparative
analysis includes a cost estimate for five-year reviews.
• Capital Cost: $0
• 30-year O&M Cost: $0
• Total Present Worth: $0
• Estimated Construction Timeframe: none
• Estimated Time to Achieve the SU-7 RAOs: SU-7 RAOs would not be met.
• ARARs Met: none
8.1.2 RA-SU7-2: Soil cover and fencing in Action Area Option #1. and institutional controls
RA-SU7-2 involves installing a soil cover in Action Area Option #1 (see Figure 9), installing
fencing along the perimeter, and implementing institutional controls. It would first require
denuding the existing vegetation and then placing a clean soil layer above the original grade to
a minimum thickness of 2 feet (about 5,300 cubic yards of soil). The area would be revegetated,
and rock armoring would be placed along the western bank of Ditch #2 to prevent erosion of
the soil cover. Perimeter fencing and institutional controls would restrict trespassers and guard
against disruption of the soil cover.
RA-SU7-2 would reduce the HI for insectivorous birds to between 1 and 4 by isolating
potential receptors from contaminant concentrations within Area #1. Risk to human health
would be reduced by fencing and institutional controls, but soil with concentrations above 25
ppm would remain in place. The remedy would remain effective over time, with proper long-
term O&M activities involving periodic inspections to assess the stability and integrity of the
soil cover and perimeter fencing, and repairs as necessary to maintain the integrity of the
remedy components.
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• Capital Cost: $1,190,000
• 30-year O&M Cost: $260,000
• Total Present Worth: $1,298,000
• Estimated Construction Timeframe: two to three months
• Estimated Time to Achieve the SU-7 RAOs: SU-7 RAOs would not be met.
• ARARs Met: does not comply with chemical-specific ARARs (PCBs would remain in on-
Site soils at concentrations greater than 25 ppm or 50 ppm). Action- and location-
specific ARARs would be achieved through appropriate control measures
during construction.
8.1.3 RA-SU7-3: Partial removal with off-site disposal, soil cover and fencing in Action Area
Option #1. and institutional controls
RA-SU7-3 involves a partial removal action supplemented with a soil cover in Action Area
Option #1 (see Figure 9), installing fencing along the perimeter, and implementing institutional
controls. The soil removal would target the zone of >500 ppm PCBs in soil to 1 foot below
ground surface, totaling about 65 cubic yards. The original grade would be restored in the
excavation area using clean backfill. Excavated materials would be characterized and profiled,
then transported off-site and disposed of at an appropriate permitted facility (soils with
concentrations of PCBs greater than 50 ppm would be disposed of at a TSCA-approved facility).
A soil cover with a minimum thickness of 2 feet would then be placed across all of Action Area
Option #1 in the same manner as described for RA-SU7-2 (about 5,300 cubic yards). The other
elements of RA-SU7-2 also apply to RA-SU7-3.
RA-SU7-3 would reduce risks to insectivorous birds to a HQ between 1 and 4 through a
combination of removal and isolation of COC-impacted soils within Action Area Option #1. This
alternative would leave soils greater than 25 ppm in place but would reduce human exposure
through fencing and institutional controls. RA-SU7-3 is expected to endure over time with O&M
similar to RA-SU7- 2.
• Capital Cost: $1,260,000
• 30-year O&M Cost: $260,000
• Total Present Worth: $1,368,000
• Estimated Construction Timeframe: two to three months
• Estimated Time to Achieve the SU-7 RAOs: SU-7 RAOs would not be met.
• ARARs Met: does not comply with chemical-specific ARARs (PCBs would remain in on-
Site soils at concentrations greater than 25 ppm or 50 ppm). Action- and location-
specific ARARs would be achieved through appropriate control measures during
construction and proper management and disposal of excavated soils.
8.1.4 RA-SU7-4: Removal of PCB-impacted soils in Action Area Option #1 with off-site
disposal, and institutional controls
RA-SU7-4 involves excavation of soils from 0 feet to 1 foot below ground surface (about 1,775
cubic yards) across the full lateral extent of Action Area Option #1 (see Figure 9). Risks would
remain in Action Area Options #2 and #3 where they fall outside of Action Area Option #1.
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Excavated materials would be characterized and profiled, then transported off-site and
disposed of at an appropriate permitted facility (soils with concentrations of PCBs greater than
50 ppm would be disposed of at a TSCA-approved facility). Pre-removal land surface elevation
would be restored using clean, imported backfill material and the area would be revegetated.
RA-SU7-4 reduces risks to insectivorous birds through the removal of COC-impacted soil within
Action Area Option #1. This remedy would provide an immediate and permanent reduction in
the HQ for insectivorous birds to between 1 and 4 but will not address soils above 25 ppm
elsewhere within SU-7. Long-term O&M would not be necessary to maintain the effectiveness
of the remedy.
• Capital Cost: $1,970,000
• 30-year O&M Cost: $0
• Total Present Worth: $1,970,000
• Estimated Construction Timeframe: two months
• Estimated Time to Achieve the SU-7 RAOs: SU-7 RAOs would not be met.
• ARARs Met: does not comply with chemical-specific ARARs (PCBs would remain in on-
Site soils at concentrations greater than 25 ppm or 50 ppm). Action- and location-
specific ARARs would be achieved through appropriate control measures during
construction and proper management and disposal of excavated soils.
8.1.5 RA-SU7-5: Removal of PCB-impacted soils in Action Area Option #2 with off-site
disposal, and institutional controls
RA-SU7-5 involves excavation of soils from 0 feet to 1 foot below ground surface (about 2,743
cubic yards) across the full lateral extent of Action Area Option #2 (see Figure 10), but soil
contamination with PCBs at concentrations of 50 ppm or less would remain. Excavated
materials would be characterized and profiled, then transported off-site and disposed of at an
appropriate permitted facility (soils with concentrations of PCBs 50 ppm or greater would be
disposed of at a TSCA-approved facility). Pre-removal land surface elevation would be restored
using clean, imported backfill material and the area would be revegetated.
RA-SU7-5 would achieve the first SU-7 RAO through the removal of COC-impacted soil in Action
Area Option #2, reducing risks to insectivorous birds to below an HI of 1. However, soil PCB
concentrations greater than 25 ppm would remain in place. Long-term O&M activities would
not be necessary to maintain the effectiveness of the remedy.
• Capital Cost: $2,830,000
• 30-year O&M Cost: $0
• Total Present Worth: $2,830,000
• Estimated Construction Timeframe: two to three months
• Estimated Time to Achieve the SU-7 RAOs: SU-7 RAOs would not be met.
• ARARs Met: does comply with chemical-specific ARARs namely the TSCA PCB
remediation waste cleanup provision in 40 CFR § 761.61(a)(4)(i)(B)(2) since PCBs would
remain in on-site soils at concentrations greater than 25 ppm but less than or equal to
50ppm. Action- and location-specific ARARs would be achieved through appropriate
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control measures during construction and proper management and disposal of
excavated soils.
8.1.6 RA-SU7-6: Removal of PCB-impacted soils in Action Area Option #3 with off-site
disposal
RA-SU7-6 involves excavation of soils from 0 feet to 1 foot below ground surface (about 4,087
cubic yards) across the full lateral extent of Action Area Option #3 (see Figure 11), and from 0-2
feet below ground surface where PCBs were reported above 25 ppm at depths below 1 foot
below ground surface (see Figure 8). Excavated materials would be characterized and profiled,
then transported off-site and disposed of at an appropriate permitted facility (soils with
concentrations of PCBs 50 ppm or greater would be disposed of at a TSCA-approved facility).
Pre-removal land surface elevation would be restored using clean, imported backfill material
and the area would be revegetated.
RA-SU7-6 would achieve both SU-7 RAO through the removal of COC-impacted soil in Action
Area Option #3. Action Area Option #3 reduces risk to insectivorous birds below an HI of 0.5
and addresses human health risks by removing all soils with 25 ppm or greater PCBs. Other than
the institutional controls, long-term O&M activities would not be necessary to maintain the
effectiveness of the remedy.
• Capital Cost: $3,270,000
• 30-year O&M Cost: $0
• Total Present Worth: $3,270,000
• Estimated Construction Timeframe: three to four months
• Estimated Time to Achieve the SU-7 RAOs: three to four months
• ARARs Met: complies with chemical-specific ARARs namely the TSCA PCB remediation
waste cleanup provision in 40 CFR § 761.61(a)(4)(i)(B)(l) that allows PCBs to remain in a
'low occupancy' area at 25 ppm or less. Action- and location-specific ARARs would be
achieved through appropriate control measures during construction and proper
management and disposal of excavated soils.
8.2 Landfill Remedial Alternatives
8.2.1 RA-LF-1: No action
The "no action" alternative (RA-LF-1) would rely on the existing soil cover without further
intervention or any institutional controls. Changes in the landfill condition over time would not
be evaluated.
• Capital Cost: $0
• 30-year O&M Cost: $0
• Total Present Worth: $0
• Estimated Construction Timeframe: none
• Estimated Time to Achieve the Landfill RAO: the landfill RAO would not be met.
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• ARARs Met: complies with the chemical-specific ARARs. Location-specific ARARs would
not be met as the landfills would not be maintained to prevent washout of waste
material by flooding. There are no action-specific ARARs.
8.2.2 RA-LF-2: Restore/repair existing soil cover, fencing, and institutional controls
RA-LF-2 will replace and restore the soil cover that was placed in 1977 under state oversight.
Existing trees and vegetation will be maintained to the extent feasible. Fencing and institutional
controls will be implemented. For this alternative, the EPA determined that the GAEPD solid
waste landfill closure requirements for a final engineered cover were relevant but not
appropriate. Although 'relevant' due to the historical disposal of industrial solid waste, the
landfill closure requirements are not 'appropriate' to RA-LF-2 because this alternative leaves
the forested landfill areas intact (to the extent feasible) with limited tree/vegetation removal.
The GAEPD solid waste landfill final cover requirements apply to regulated facilities designed
and constructed to meet all landfill requirements, including applying soil cover daily on
operating cells before closure. This necessarily requires that the areas of the closed landfill for
which the final cover is installed should be clear of any vegetation and be relatively level. The
limited tree/vegetation removal under RA-LF-2 results in Site conditions that are very different
from a regulated solid waste landfill undergoing closure such that the application of the final
cover requirements is not appropriate in this situation. The RA-LF-2 remedial alternative will
protect human health from physical hazards presented by waste materials at the landfills, while
also conserving ecological habitat and providing better flood/erosion control.
Protruding waste materials such as drums and large surface debris would be removed as part of
Site preparation. Some land clearing would be needed to access and remove the debris, but
protection of the habitat, especially large, mature trees, would be considered as part of the
remedial design. Areas disturbed would be restored and/or repaired and would be seeded and
allowed to naturally recover forming the same or similar habitat, consistent with the natural
Site habitat. The precise method of restoration, soil placement, leveling and/or grading, and
erosion control would be determined during the remedial design. Figure 12 provides a
schematic illustration of RA-LF-2.
Rock armoring would be applied at the toe of each landfill to prevent washout of waste
materials from flooding. Other appropriate erosion protection may also be evaluated during the
remedial design. Installing perimeter fencing and implementing institutional controls would
protect the long-term integrity of the soil cover from public access.
RA-LF-2 would achieve the landfill RAO by removing large surface debris, restoring/repairing
the soil cover (barrier) previously applied, and installing rock armoring to provide further
protection against flood-induced washout of waste materials. The soil cover would be
maintained through a long-term O&M program involving specified scheduled inspections to
assess the stability and integrity of the soil cover and perimeter fencing/signage. Repairs would
be completed as necessary to maintain the integrity of the remedy components.
• Capital Cost: $4,280,000
• 30-year O&M Cost: $540,000
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• Total Present Worth: $4,503,000
• Estimated Construction Timeframe: three to four months
• Estimated Time to Achieve the Landfill RAO: three to four months
• ARARs Met: complies with chemical-specific ARARs for PCBs. Action- and location-
specific ARARs would be achieved through appropriate control measures during
construction to control stormwater runoff as well as minimize impacts within
the floodplain.
8.2.3 RA-LF-3: Solid waste landfill engineered cap, fencing, and institutional controls
RA-LF-3 involves installing a conventional solid waste landfill engineered cap and perimeter
fencing and implementing institutional controls. The cap would span both landfills, as one cell
and would be designed and constructed consistent with GAEPD solid waste landfill closure
requirements that would be considered relevant and appropriate requirements. The final cap
design would be determined during the remedial design. The cap system may include adaptive
measures such as rock armoring to prevent washout during flooding from Rocky Creek,
drainage improvements, a leveling layer, and/or a structural geosynthetic and gas venting layer.
Installing perimeter fencing and implementing institutional controls would protect the long-
term integrity of the cover system from public access. Site preparation would primarily include
removing vegetation and trees, many of which are large and mature from the landfills (as well
as some surrounding areas for access roads and staging areas), and removing much of the
surface debris, protruding waste, and other extraneous material.
RA-LF-3 would achieve the landfill RAO by placing an engineered cap across the landfills
augmented with rock armoring to provide further protection against flood-induced washout of
waste materials and maintaining it through a long-term O&M program. The O&M program
would include periodic inspection to: (1) assess the stability and integrity of the engineered cap
system, drainage system, and security controls; (2) monitor and evaluate differential
settlement; and (3) maintain (e.g., mow) the vegetated layer. Repairs would be completed as
necessary to maintain the integrity of the remedy components. Figure 13 provides a schematic
illustration of RA-LF-3.
• Capital Cost: $9,680,000
• 30-year O&M Cost: $870,000
• Total Present Worth: $10,040,000
• Estimated Construction Timeframe: 10 months
• Estimated Time to Achieve the Landfill RAO: 10 months
• ARARs Met: complies with chemical-specific ARARs. Action-specific requirements for
closure of a solid waste landfill with a final cover would be achieved during construction.
8.3 Common Elements and Distinguishing Features of Each Alternative
All SU-7 and landfill alternatives, except for the no action alternatives, include institutional
controls such as recordation of an environmental restrictive covenant that meets Georgia
Uniform Environmental Covenant Act requirements to prevent residential land use, prohibit the
use of groundwater for potable purposes, and impose controls on intrusive work in the
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remediation areas including the landfills. Both landfill action alternatives include long-term
maintenance of the soil cover or engineered cap. Alternatives that include a soil cover or
engineered cap for both SU-7 (RA-SU7-2 and RA-SU7-3) and the landfills (RA-LF-2 and RA-LF-3)
include fencing to prevent access and protect the integrity of the remedy. Long-term
maintenance and inspections of fencing installed will be required.
SU-7 Alternatives: Under all SU-7 alternatives, hazardous substances will remain at the Site
above levels that allow for unlimited use and unrestricted exposure and the EPA will continue
to conduct a review of the Site every five years (Superfund five-year reviews) pursuant to
CERCLA Section 121(c) and the NCP at 40 CFR 300.430(f)(4)(ii).
The primary distinguishing feature among the SU-7 alternatives, except for RA-SU7-1 (no
action), is that RA-SU7-2 and RA-SU7-3 rely on soil cover or a combination of removal and soil
cover to reduce the mobility of contamination and require long-term O&M activities.
Additionally, RA-SU7-6 addresses the greatest amount of PCB-contaminated soils than the
other alternatives, and RA-SU7-5 addresses a greater amount than RA-SU7-2, RA-SU7-3, and
RA-SU7-4. RA-SU7-6 is also the only alternative that does not leave soil with PCB concentrations
greater than 25 ppm in place. In addition, after removing PCBs > 25 ppm in soils, it is estimated
that the post-remediation area-wide average PCB concentration in SU-7 surface soils will be
4.3 ppm (based on 95% Upper Confidence Limit), which is protective of the future industrial
worker and the insectivorous bird.
Landfill Alternatives: Among the landfill alternatives, both action alternatives reduce mobility
of soil and waste materials at the landfills similarly by protecting against erosion and flood-
induced washout. Neither action alternative would reduce the toxicity, nor appreciably reduce
the volume of waste material in the landfills. RA-LF-2 maintains the current diverse and
valuable ecological habitat and provides additional protection from hazards associated with
flooding or storm events, whereas RA-LF-3 further reduces the mobility of soil or waste by
reducing precipitation infiltration through the landfill.
8.4 Expected Outcomes of Each Alternative
SU-7 Alternatives'. All alternatives except for RA-SU7-1 (No Further Action) will reduce human
health and ecological risks. RA-SU7-6 reduces both ecological and human health risks to an
acceptable level for the reasonably anticipated future commercial/industrial use.
Landfill Alternatives: Both action alternatives provide an acceptable level of protection for
human health and the environment. They both require long-term stewardship to routinely
evaluate the effectiveness of the remedy and assure that the various elements are functioning
as intended.
9.0 Comparative Analysis of Alternatives
In selecting a remedy, the EPA considered the factors set out in Section 121 of CERCLA,
42 U.S.C.§ 9621, by conducting a detailed analysis of the viable remedial alternatives pursuant
to the NCP, 40 CFR §300.430(e)(9), and Office of Solid Waste and Emergency Response
Directive 9355.3-01.
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The EPA uses nine criteria to evaluate the remedial alternatives, both individually and relative
to each other, to select a remedy. The NCP identifies two threshold criteria, five primary
balancing criteria, and two modifying criteria. Threshold criteria must be satisfied in order for
an alternative to be eligible for selection. Primary balancing criteria are used to weigh major
trade-offs among alternatives. Modifying criteria are taken into account after public comments
have been received.
This section of the ROD provides a comparative analysis of each of the alternatives for SU-7 and
the landfills, with respect to these nine NCP criteria (see Tables 6 and 7). The 2023 FS Report
also includes a detailed evaluation of the remedial alternatives.
The NCP criteria are:
Threshold Criteria
1) Overall Protection of Human Health and the Environment addresses whether an
alternative provides adequate protection of human health and the environment and
describes how risks posed through each exposure pathway are eliminated, reduced, or
controlled, through treatment, engineering controls, and/or institutional controls.
2) Compliance with ARARs considers whether an alternative will meet all federal or more
stringent state environmental laws and regulations or whether there is justification for
waiving a requirement under CERCLA section 121(d)(4).
Primary Balancing Criteria
3) Reduction of Toxicity. Mobility, or Volume through Treatment indicates the EPA's
preference for alternatives that include treatment processes to lower or eliminate the
hazardous nature of material, its ability to move in the environment, and the amount
left after treatment.
4) Long-Term Effectiveness and Permanence considers the long-term effectiveness and
permanence of maintaining the protection of human health and the environment after
implementing each alternative.
5) Short-Term Effectiveness considers the effect of each remedial alternative on the
protection of human health and the environment during the construction and
implementation phase.
6) Implementability considers the technical and administrative feasibility of
implementing each alternative and the availability of the services and materials
required during implementation.
7) Cost considers construction costs as well as long-term O&M costs of each alternative by
considering whether costlier alternatives provide additional public health benefits for
the increased cost.
Modifying Criteria
8) State Acceptance considers whether the state agrees with, disagrees with, or has no
comment on the EPA's preferred alternative.
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9) Community Acceptance considers the concerns or support the public may offer
regarding each alternative.
9.1 Overall Protection of Human Health and the Environment
SU-7 Alternatives: The no action alternative (RA-SU7-1) and alternatives RA-SU7-2, RA-SU7-3,
RA-SU7-4, and RA-SU7-5 protect human health through institutional controls and/or fencing,
but do not meet the RAO of reducing ecological risk to insectivorous birds below an HQ of 1.
RA-SU7-6 provides adequate protection to insectivorous birds and meets the criteria for the
protection of human health without the use of institutional controls or fencing through removal
of soils in Action Area #3.
Landfill Alternatives: RA-LF-1, the no action alternative, would not address known Site hazards
(exposed debris and landfill settling) or meet the landfill RAO of protecting human health and
the environment by preventing exposure to soil and waste materials at the landfills. Both
RA-LF-2 and RA-LF-3 satisfy the landfill RAO by isolating soil and waste materials from humans
and ecological receptors. RA-LF-2 satisfies the landfill RAO by repairing the existing soil cover,
installing fencing, and maintaining these remedy components through a long-term O&M
program. RA-LF-3 satisfies the landfill RAO through a conventional solid waste landfill cap
maintained by a long-term O&M program. Both action alternatives would be augmented with
rock armoring to protect against flood induced washout of waste materials.
9.2 Compliance with ARARs
SU-7 Alternatives: Remedial alternative RA-SU7-6 would comply with the chemical specific
ARARs identified for OU2 based on the TSCA cleanup level in 40 CFR § 761.61(a)(4)(i)(B)(l) for a
"low occupancy area" as defined in 40 CFR 761.3. Remedial alternative RA-SU7-5 would also
comply with the chemical specific ARARs identified for OU2 based on TSCA 40 CFR §
761.61(a)(4)(i)(B)(2) where PCB remediation wastes may remain at a cleanup site at
concentrations >25 ppm and <50 ppm if the site is secured by a fence and marked with a sign
including the Ml mark.
Appropriate control measures would be implemented during construction such that the
substantive requirements of the action- and location-specific ARARs would be achieved. Soils
excavated under RA-SU7-6 would be managed and disposed of pursuant to TSCA regulations
identified as action-specific ARARs.
Landfill Alternatives: RA-LF-1 would not meet location-specific ARARs to prevent washout of
waste material by flooding. Both action alternatives (RA-LF-2 and RA-LF-3) comply with
chemical-specific ARARs. Action- and location-specific ARARs would be achieved by
implementing appropriate control measures. RA-LF-3 will have the added benefit of being
compliant with certain solid waste landfill closure ARARs.
9.3 Long-Term Effectiveness and Permanence
SU-7 Alternatives: RA-SU7-2 and RA-SU7-3 are effective long-term remedies. However, RA-SU7-
3 has slightly better long-term effectiveness because the soils with greater than 500 ppm total
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PCBs would be removed in addition to the placement of a soil cover, which is a component of
both alternatives. Long-term O&M and institutional controls are necessary for both alternatives
to verify that the remedy is functioning as intended.
RA-SU7-6 provides insectivorous birds with immediate and permanent protection from COC
exposure through the removal of PCB-contaminated soils and reduces the HQ for insectivorous
birds below 1 (see Table 4). RA-SU7-6 also permanently reduces risk to potential future
industrial workers to an acceptable level. Long-term O&M activities would not be necessary to
maintain the effectiveness of these remedies.
Landfill Alternatives: Both action alternatives are effective long-term remedial strategies with
proper long-term O&M activities. RA-LF-2 would protect the diverse habitat, especially large,
mature trees, that provide additional protection from hazards associated with flooding and
storm events. RA-LF-2 O&M would involve periodic inspections ascertaining the stability and
integrity of the soil cover and perimeter fencing, with repairs as necessary to maintain the
integrity of the remedy components.
O&M for the RA-LF-3 alternative would include periodic inspection to: (1) ascertain the stability
and integrity of the engineered cap system, drainage system, and security controls; (2) monitor
and evaluate differential settlement; and (3) maintain (e.g., mow) the vegetated layer, with
repairs completed as necessary to maintain the integrity of the remedy components. Land
cover conversion from the bottomland hardwood forest to vegetated topsoil cover under
RA-LF-3 may cause loss of ecosystem services, destruction of the diverse wildlife habitat, and
increased stormwater runoff due to the placement of a low-permeability cap.
9.4 Reduction of Toxicity, Mobility, or Volume
SU-7 Alternatives: This criterion addresses the preference under CERCLA for remedial
alternatives that permanently and significantly reduce the mobility, toxicity, or volume of
hazardous substances through treatment. This preference is satisfied when treatment is used to
reduce any principal threats at a site through destruction of toxic contaminants, reduction of
the total mass of toxic contaminants, irreversible reduction in contaminant mobility, or
reduction of total volume of contaminated media.
However, the remedial alternatives, through containment or removal, do achieve varying
degrees of reduction of the mobility, toxicity, or volume of hazardous substances. RA-SU7-2
relies on engineering controls. Thus, it would not reduce the toxicity or volume of waste
material in SU-7. RA-SU7-2 would reduce the mobility of contaminants in SU-7 by protecting
against erosion and runoff of the surface soil condition. RA-SU7-3 would reduce the volume of
COC-impacted soils by an estimated 65 cubic yards through excavation and off-site disposal and
the soil cover reduces the mobility of COCs in SU-7 by protecting against erosion and runoff of
surface soil. RA-SU7-4, RA-SU7-5, and RA-SU7-6 would each reduce the volume of COC-
impacted soils in SU-7 by an estimated 1,775 cubic yards, 2,443 cubic yards, and 4,087 cubic
yards, respectively.
Landfill Alternatives: None of the landfill remedial alternatives includes treatment as a
remedial component because there is no principal threat waste present in the landfills and
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treatment technologies do not address the hazards addressed in the landfills. Both action
alternatives address the entire area of the landfills, which are collectively 12 acres. Neither of
the action alternatives would reduce the toxicity nor appreciably reduce the volume of waste
material in the landfills. However, RA-LF-2 and RA-LF-3 both reduce the mobility of soil and
waste materials by isolating them and protecting against erosion and flood-induced washout.
The low permeability cap in RA-LF-3 further reduces the mobility of soil or waste by reducing
precipitation infiltration through the landfill. However, the benefit of RA-LF-2 is that the existing
trees and other vegetation are expected to reduce erosion and other adverse impacts from
rainfall and/or flood events by slowing stormwater runoff.
9.5 Short-Term Effectiveness
SU-7 Alternatives: For all of the action alternatives, operators of construction equipment may
be exposed to various physical hazards and dust. RA-SU7-3, RA-SU7-4, RA-SU7-5, and RA-SU7-6
may additionally expose workers to soil particulates or vapors. These risks would be managed
through safe work practices and appropriate personal protective equipment.
All the action alternatives provide immediate ecological risk reduction, but short-term loss of
the existing diverse ecosystem would occur. However, with time, the ecosystem would
naturally recover, forming the same or similar environment that occurred before remediation.
Landfill Alternatives: Both action alternatives would provide immediate protection to human
health and the environment from exposure to soil and waste materials at the landfills. RA-LF-2
would likely cause short-term loss of some of the existing diverse ecosystem. However, with
time, the ecosystem at the landfills is expected to naturally recover forming a similar
environment as before remediation. The potentially long duration of implementation for
RA-LF-3 (10 months) would create the potential for additional erosion during construction.
During the implementation of both action alternatives, operators of construction equipment
may be exposed to various physical hazards, though worker health risk is expected to be
minimal. Human health implementation risks would be managed through safe work practices
and appropriate personal protective equipment. Traffic and noise in the community
surrounding OU2 is expected as a result of construction activities, creating a temporary public
nuisance for the duration of construction.
9.6 Implementability
SU-7 Alternatives: All action alternatives are feasible to implement and employ technologies
with straightforward practices and procedures (soil cover and/or removal). Necessary
construction equipment, operators, and clean backfill/soil are readily available. For alternatives
RA-SU7-3, RA-SU7-4, RA-SU7-5, and RA-SU7-6, excavated materials would be characterized and
profiled, then transported off-site and disposed of at an appropriate permitted facility (soils
with concentrations of PCBs greater than 50 ppm disposed of at a TSCA-approved facility).
The action alternatives require several Site preparation activities, including land clearing and
construction of access roads and equipment staging areas. The construction timeframe is
similar for all of the action alternatives. RA-SU7-2 and RA-SU7-3, however, would require a
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long-term O&M program, fencing, and more institutional controls. Development of
institutional controls is administrative in nature and thus simple to implement with low
capital and O&M costs.
Landfill Alternatives: RA-LF-2 and RA-LF-3 are similarly feasible to implement with proper Site
preparation and employ established technologies. Equipment and materials necessary for
RA-LF-2 land clearing and cover construction are readily available, and the practices and
procedures for remedy implementation are relatively straightforward. Due to the longer
duration of the construction for RA-LF-3 (10 months compared to three to four months for
RA-LF-2) and the significantly greater amount of disturbance and earth moving, there is a
greater likelihood of potential issues related to stormwater runoff and/or erosion issues
during construction.
9.7 Cost
SU-7 Alternatives: Table 8 compares capital and O&M costs for each of the SU-7 remedial
alternatives. These costs are estimates based on the best available information and have an
expected accuracy of +50% to -30%.
Table 6: SU-7 Alternatives Cost Summary
Cost Category
RA-SU7-1:
No Action
RA-SU7-2:
Soil Cover,
Fencing,
Institutional
Controls
RA-SU7-3:
Partial
Removal,
Soil Cover,
Fencing,
Institutional
Controls
RA-SU7-4:
Removal
(Action
Area
Option #1)
RA-SU7-5:
Removal
(Action
Area
Option #2)
RA-SU7-6:
Removal
(Action
Area
Option #3)
Capital Cost
$0
$1,190,000
$1,260,000
$1,970,000
$2,830,000
$3,270,000
to
$4,940,000
30-year O&M
Cost
$0
$260,000
$260,000
$0
$0
$0
Total Cost
$0
$1,450,000
$1,520,000
$1,970,000
$2,830,000
$3,270,000
to
$4,940,000
Landfill Alternatives: Table 9 compares capital and O&M costs for each of the landfill
remedial alternatives.
Table 7: Landfill Alternatives Cost Summary
Cost Category
RA-LF-1:
No Action
RA-LF-2:
Soil Cover, Fencing,
Institutional Controls
RA-LF-3:
Engineered Landfill
Cap, Fencing,
Institutional Controls
Capital Cost
$0
$4,280,000
$9,680,000
O&M Cost
$0
$540,000
$870,000
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Total Cost
$0
$4,820,000
$10,550,000
9.8 State Acceptance
The state of Georgia, as represented by GAEPD, has expressed its support for the Selected
Remedies (RA-LF-2 and RA-SU7-6).
9.9 Community Acceptance
The EPA and GAEPD conducted a public meeting on May 30, 2024, to present the
Proposed Plan to the public. The preferred alternatives in the Proposed Plan were presented at
the public meeting were alternative RA-LF-2 and RA-SU7-6. No written comments were
received by EPA and no request for extension of the comment period was made.
10.0 Principal Threat Wastes
The NCP establishes an expectation that the EPA will use treatment to address the principal
threats posed by a site wherever practicable (NCP Section 300.430(a)(l)(iii)(A)). The "principal
threat" concept is applied to the characterization of "source materials" at a Superfund site. A
source material is material that includes or contains hazardous substances, pollutants, or
contaminants that act as a reservoir for migration of contamination to groundwater, surface
water, or air, or acts as a source for direct exposure. Principal threat wastes are those source
materials considered to be highly toxic or highly mobile that generally cannot be reliably
contained or would present a significant risk to human health or the environment should
exposure occur.
PCBs above a level of 500 ppm are generally considered by EPA to be principal threat material.
The soil sampling conducted as part of the Rl show only one sample that had a PCB level greater
than 500 ppm: that sample was taken in SU-7 and showed a PCB level of 934 ppm. Due to the
low volume of principal threat material anticipated, none of the SU-7 or landfill remedial
alternatives include treatment as a remedial component. However, two of the remedial
alternatives remove PCB contaminated soil at 25 ppm or 50 ppm or greater for off-site disposal,
thereby addressing the PCB soil contamination that could constitute principal threat waste.
11.0 Selected Remedy
11.1 Summary of the Rationale for the Selected Remedy
Based on the available information, the EPA has selected alternative RA-SU7-6 (full removal in
Action Area Option #3 with off-site disposal) for SU-7. For the landfills, the EPA has selected
alternative RA-LF-2: restore/repair existing soil cover, install fencing/signage, and implement
institutional controls. For the OU1 WWTP Landfill, EPA has selected institutional controls as a
final remedy in order to protect human health and the maintain the integrity of landfill cover
installed under the non-time critical removal action that was completed in 2016.
The EPA selected RA-SU7-6 because it is one of the alternatives that meets both the threshold
criteria of protection of human health and the environment, as well as satisfying ARARs. RA-
SU7-6 also provides the greatest reduction in the volume of contaminated soil and the highest
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level of protection to the environment, with only a marginal increase in cost. The EPA expects
the RA-SU7-6 to satisfy the following statutory requirements of CERCLA §121(b): (1) to be
protective of human health and the environment; (2) to comply with ARARs; (3) to be cost-
effective; (4) to use permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and (5) to satisfy the preference for
treatment as a principal element, or explain why the preference for treatment will not be met.
However, RA-SU7-6 does not satisfy the preference for treatment. Several potentially
applicable treatment technologies were identified: phytoremediation, vitrification, thermal
desorption, and soil washing. During the OU2 FS, these treatment technologies were not
considered feasible. Based on available data from the Rl, and pursuant to the TSCA ARAR, SU-7
soils with PCBs greater than 50 ppm will instead be disposed of off-site at an EPA approved
facility (e.g., a RCRA Subtitle C landfill or a TSCA chemical waste landfill).
The EPA selected RA-LF-2 because, in addition to meeting the landfill RAO and complying with
certain ARARs, it conserves ecological habitat and provides better flood/erosion control while
providing protection from physical hazards. RA-LF-2 can be implemented for less than half the
cost of RA-LF-3.
11.2 Detailed Description of the Selected Remedy
SU-7 Remedy. The selected remedy, RA-SU7-6, consists of the following elements:
• Excavation of soils from 0 feet to 1 foot below ground surface across the full lateral
extent of Action Area Option #3, and from 0 feet to 2 feet below ground surface where
PCBs were reported at concentrations greater than 25 ppm at depths below 1 foot
below ground surface.
• Characterization and profiling of excavated soil.
• Temporary storage of PCB remediation waste in containers or staging pile.
• Transportation of excavated soil off-site to an appropriate permitted solid waste
disposal facility (soils with concentrations of PCBs greater than 50 ppm would be
disposed of at a TSCA-approved facility).
• Restoration of excavated areas using clean, imported backfill material.
• Institutional controls such as recordation of an environmental restrictive covenant that
meets Georgia Uniform Environmental Covenant Act requirements to prevent
residential use, restrict the future use of groundwater or installation of groundwater
wells, and prohibit future activities that might disturb the integrity of the remedy.
Figure 14 shows RA-SU7-6. Soils will be excavated across the full lateral extent of Action Area
Option #3, which encompasses all discrete samples with PCB concentrations greater than 25
ppm. Excavation will be completed to include the biotic zone to 1 foot below ground surface,
with additional excavation to 2 feet below ground surface in a smaller area where soil PCB
concentrations exceed 25 ppm PCB below 1 foot below ground surface. PCB concentrations in
all samples below 2 feet below ground surface were less than 1 ppm). The extent of the
excavations may change based on additional information or data collected either during
remedial design or implementation.
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Soil remediation waste will be taken off-site for disposal. Excavated materials will be segregated
based on pre-excavation sampling data. Soil with greater than 50 ppm PCBs will be temporarily
stored or directly loaded and transported to an EPA approved TSCA-chemical waste landfill or
permitted RCRA Subtitle C landfill for disposal as TSCA PCB waste. Contaminated soil below
50 ppm PCBs will be temporarily stored then transported for disposal at an EPA-approved RCRA
permitted Subtitle D landfill.
The excavated areas will be restored using clean, imported backfill material and re-vegetated.
Landfill Remedy. The selected remedy, RA-LF-2, consists of the following elements:
• Removal of protruding waste materials and large surface debris.
• Repair/replacement of the existing soil cover while conserving the current ecological
diverse land cover, especially mature trees, to the extent possible.
• Revegetation of disturbed areas and allowing the natural ecosystem to redevelop.
• Rock armoring the toe of each landfill to prevent erosion of waste materials.
• Installation of fencing around the landfills.
• Institutional controls such as recordation of an environmental restrictive covenant that
meets Georgia Uniform Environmental Covenant Act requirements to prevent
residential land use, restrict the future use of groundwater or installation of
groundwater wells, and prohibit future activities that might disturb the integrity of
the remedy.
• Implementation of a long-term O&M program to maintain the soil cover and perimeter
fencing and signage.
RA-LF-2, as shown in Figure 12, involves restoration or repair of the soil cover previously
applied to the landfills, while maintaining existing trees and vegetation to the extent feasible.
Protruding waste materials (e.g., drums, drum carcasses) and large surface debris (e.g.,
construction debris, suspended monitoring wells) will be removed as part of Site preparation.
Some degree of land clearing will be needed to access and remove the debris, but protection of
the habitat (specifically large, mature trees) will be considered as part of the remedial design.
Areas disturbed, restored, and/or repaired will be seeded and allowed to naturally recover,
consistent with the natural Site habitat.
The precise method of restoration, soil placement, leveling and/or grading, and erosion control
will be determined during the remedial design. Disturbed areas will be actively maintained and
stabilized against erosion while native vegetation is reestablished. The remedial design will
consider the protection of the critical root zone (the root area around the tree necessary for its
survival) around specimen trees. In addition to providing a valuable ecological habitat, existing
mature and reestablished trees are expected to reduce erosion and lessen the force of storms
and flooding by precipitation interception, reducing erosion and maintaining soil water holding
capacity, lowering surface and air temperatures due to evapotranspiration and the canopy
shade, and promoting precipitation infiltration into the groundwater table instead of as
stormwater runoff.
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Rock armoring will be applied at the toe of each landfill to prevent washout of waste materials
from flooding. Additional appropriate erosion protection may also be evaluated during the
remedial design.
Perimeter fencing and institutional controls will protect the long-term integrity of the soil cover
from public access. Long-term O&M activities would involve periodic inspections to ascertain
the stability and integrity of the soil cover and perimeter fencing. Repairs would be completed
as necessary to maintain the integrity of the remedy components.
OU1 Selected Remedy
As discussed in the Declaration of this ROD (see p.2), institutional controls (ICs) will be
implemented for the OU1 for the WWTP Landfill that was previously addressed by non-time
critical removal action that was completed in 2016.
The ICs will be in the form of a recorded environmental restrictive covenant, consistent with
the Georgia Uniform Environment Covenants Act (O.C.G.A. § 44-16-1 et seq.). The
environmental restrictive covenant will prevent residential land use, prohibit the use of
groundwater and installation of groundwater wells, and prohibit future activities that would
disturb the integrity of the remedies. The environmental covenant will also contain appropriate
provisions regarding enforceability, notification, recording, amendment, and termination of the
environmental covenant.
11.3 Cost Estimate for the Selected Remedy
The total present worth cost of the selected remedy for SU-7 ranges from $3,270,000 to
$4,940,000, all of which is capital cost because O&M activities are not necessary under this
selected remedy. These costs are estimates based on the best available information and have
an expected accuracy of +50% to -30%. Tables 10 and 11 show a detailed breakdown of both
the lower and upper cost range for the selected SU-7 remedy, RA-SU7-6.
The total present worth of the selected remedy for the landfills is $4,820,000, for which the
estimated capital cost is $4,280,000 and the 30-year O&M cost estimate is $540,000. Table 12
shows a detailed cost estimate for the landfills selected remedy RA-LF-2.
The estimated costs to implement each environmental covenant, containing the institutional
controls, for each of the remedial alternatives for OU2, and for the OU1 removal action, is
approximately $75,000. The costs shown in Sections 8.1 and 8.2 for each of the OU2 remedial
alternatives (except for the No Action alternatives) does not include this $75,000 cost of
implementing ICs.
These costs are estimates based on the best available information and have an expected
accuracy of +50% to -30%.
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11.4 Estimated Outcomes of Selected Remedies
11.4.1 Available Land Use
The selected remedy for the landfills includes fencing of areas with a soil cover to restrict
human trespasser access, thereby protecting the long-term integrity of the remedy. The
selected remedies for the landfills and SU-7 as well as OU1 WWTP Landfill also include
institutional controls in the form of an environmental covenant (recorded into the property
deed), consistent with the Georgia Uniform Environment Covenants Act (O.C.G.A. § 44-16-1 et
seq.), to prevent residential land use, prohibit the use of groundwater for potable purposes,
and impose controls on intrusive work.
Aside from the landfills, activity related to the MWA Rocky Creek Water Reclamation Facility is
the only OU2 land use. The majority of OU2 is a forested bottomland floodplain prone to
flooding from Rocky Creek and is classified as wetlands.
OU2 is currently zoned for industrial land use. However, upland areas (e.g., areas above the
abandoned rail spur) are more conducive to future industrial development.
11.4.2 Cleanup Levels
Excavation of PCB-contaminated soil > 25 ppm that is based on the area-average cleanup level
of 6.5 ppm in the SU-7 sampling unit (see Table 5, Section 7.5) results in an SU-7 area-average
PCB concentration of 4.3 ppm, which reduces the HQ for both insectivorous birds and the
future industrial worker to less than 1.
11.5 Environmental and Ecological Benefits
The RA-LF-2 remedial alternative will conserve ecological habitat and provide flood/erosion
control. Protruding waste materials such as drums and large surface debris would be removed
as part of Site preparation. Some land clearing would be needed to access and remove the
debris, but protection of the habitat, especially large, mature trees, would be considered as
part of the remedial design. Areas disturbed would be restored and/or repaired and would be
seeded and allowed to naturally recover forming the same or similar habitat, consistent with
the natural Site habitat.
12.0 Statutory Determinations
Under CERCLA §121 and the NCP, the lead agency must select remedies that are protective of
human health and the environment, comply with ARARs, are cost-effective, and utilize
permanent solutions and alternative treatment technologies, or resource recovery technologies
to the maximum extent practicable. In addition, CERCLA includes a preference for remedies
that employ treatment that permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes as a principal element, and a bias against off-site disposal of
untreated wastes. The following sections discuss how the selected remedy meets these
statutory requirements.
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12.1 Protection of Human Health and the Environment
The selected remedy for SU-7 will protect human health and the environment and meet the SU-
7 RAOs by removing soils that exceed 25 ppm, which achieves a post-remediation area-wide
average PCB soil concentration of 4.3 ppm. The excavated soils will be disposed at an approved
facility, while the excavated areas will be restored using clean, imported backfill material.
The selected remedy for the landfills will protect human health and the environment by
isolating soil and waste materials from humans and ecological receptors. The selected remedy
will repair the existing soil cover, erect a fence, and maintain these remedy components
through a long-term O&M program.
Both the SU-7 and landfill selected remedies (including OU1) will include institutional controls
to prevent residential use, restrict the future use of groundwater or installation of groundwater
wells, and prohibit future activities that might disturb the integrity of the remedies.
12.2 Compliance with ARARs
Section 121(d) of CERCLA, as amended, specifies, in part, that remedial actions for cleanup of
hazardous substances must comply with requirements and standards under federal or more
stringent state environmental laws and regulations that are applicable or relevant and
appropriate (i.e., ARARs to the hazardous substances or particular circumstances at a site unless
such ARARs are waived under CERCLA section 121(d)(4). See also 40 CFR § 300.430(f)(l)(ii)(B).
ARARs include only federal and state environmental or facility siting laws/regulations and do
not include occupational safety or worker protection requirements. Compliance with OSHA
standards is required by 40 CFR § 300.150 and therefore the CERCLA requirement for
compliance with or waiver of ARARs does not apply to OSHA standards.
Under CERCLA Section 121(e)(1), federal, state, or local permits are not required for the portion
of any removal or RA conducted entirely on-site as defined in 40 CFR § 300.5. See also 40 CFR
§§ 300.400(e)(1) & (2). Also, CERCLA actions must only comply with the "substantive
requirements," not the administrative requirements of a regulation. Administrative
requirements include permit applications, reporting, record keeping, and consultation with
administrative bodies. Although consultation with state and federal agencies responsible for
issuing permits is not required, it is recommended for determining compliance with certain
requirements such as those typically identified as location-Specific ARARs.
Applicable requirements means those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under federal environmental or
state environmental or facility siting laws that specifically address a hazardous substance,
pollutant, or contaminant, remedial action, location, or other circumstance at a CERCLA site.
Only those state standards that are identified by the state in a timely manner and that are more
stringent than federal requirements may be applicable. [40 CFR § 300.5 Definitions]
Relevant and appropriate requirements means those cleanup standards, standards of control,
and other substantive requirements, criteria, or limitations promulgated under federal
environmental or state environmental or facility siting laws that, while not 'applicable' to a
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hazardous substance, pollutant, or contaminant, remedial action, location, or other
circumstance at a CERCLA site, address problems or situations sufficiently similar to those
encountered at a CERCLA site that their use is well suited to the particular site. Only those state
standards that are identified by the state in a timely manner and that are more stringent than
federal requirements may be relevant and appropriate. [40 CFR § 300.5 Definitions]
In addition to ARARs, the lead and support agencies may identify other measures to be
considered for a particular release. "The TBC category consists of advisories, criteria, or
guidance that were developed by EPA, other federal agencies, or states that may be useful in
developing CERCLA remedies." See 40 CFR § 300.400(g)(3).
The selected remedy complies with all identified chemical-specific, location-specific, and action-
specific ARARs and TBC identified for the Site in Tables 13, 14, and 15. A waiver of an ARARs
pursuant to CERCLA section 121(d)(4) is not necessary. The cleanup level for PCB in SU-7 is
based on the TSCA self-implementing cleanup level in 40 CFR § 761.61(a)(4)(i)(B)(1) which is a
relevant and appropriate chemical-specific requirement. Important action-specific ARARs
include TSCA regulations for the characterization, temporary staging of waste in a storage pile,
and performance-based disposal of PCB remediation waste as well as TSCA PCB waste. All land
disturbing activities associated with excavation of contaminated soil will comply with GAEPD
requirements for control of fugitive dust and stormwater runoff from construction activity.
Location-specific ARARs include requirements to minimize the potential adverse impacts and
support to or within floodplains and wetlands.
12.3 Cost Effectiveness
The selected remedies are cost-effective and represent a reasonable value for the remedial
work anticipated. The selected remedy for SU-7 provides the highest level of protection to the
environment, while costing an 15.5% more than remedial alternative RA-SU7-5. The selected
remedy for the landfills conserves ecological habitat and provides better flood/erosion control
while providing protection from physical hazards for less than half of the cost of RA-LF-3.
12.3.1 Use of Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
The selected remedy for SU-7 provides insectivorous birds and future potential industrial
workers with immediate and permanent protection from COC exposure through the removal of
PCB-contaminated soils. Long-term O&M activities are not necessary to maintain the
effectiveness of the remedy.
The selected remedy for the landfills is an effective long-term remedial strategy with proper
long-term O&M activities. The remedy would protect the diverse habitat, especially large,
mature trees, that provide additional protection from hazards associated with flooding and
storm events. O&M activities would involve periodic inspections to ascertain the stability and
integrity of the soil cover and perimeter fencing, with repairs as necessary to maintain the
integrity of the remedy components.
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12.3.2 Preference for Treatment as a Principal Element
CERCLA Section 121(b) specifies remedial actions, which permanently and significantly reduce
the toxicity, mobility or volume of the hazardous substances, pollutants, and contaminants as a
principal element, are to be preferred over remedial actions not involving such treatment. The
OU2 SU-7 and landfills selected remedy do not satisfy the statutory preference for treatment.
12.4 Five-Year Review Requirements
Because hazardous substances, pollutants, or contaminants will remain at the Site above levels
that allow for unlimited use and unrestricted exposure, the EPA will continue to review the
remedial actions taken at the Site no less than every five years per CERCLA Section 121(c) and
the NCP at 40 CFR § 300.430(f)(4)(ii). If the results of the five-year reviews reveal that remedy
integrity is compromised and not protective of human health and the environment, then the
EPA and the GAEPD will evaluate the need for more action.
During a FYR, EPA is required to evaluate if the exposure assumptions, toxicity data, cleanup
levels, and RAOs used at the time of the remedy are still valid. For the SU-3 and SU-5 sampling
units, for example, the EPA will evaluate any changes in PCB toxicity to avian receptors, the
amount of time SU-3 and SU-5 are flooded, whether flooding has caused erosion or deposition
of soil, or if other physical conditions have changed that may impact EPA's risk assumptions. As
with any FYR, EPA will determine what sampling is needed, if any, is warranted to assess
changes to Site conditions.
13.0 Documentation of Significant Changes from Preferred Alternative of
Proposed Plan
To fulfill CERCLA §117(b) and NCP §300.430(f)(5)(iii)(B) and §300.430(f)(3)(ii)(A), the ROD must
document and discuss the reasons for any significant changes made to the Selected Remedy
from the time the Proposed Plan was released for public comment to the final selection of the
remedy. The final remedy selected for the Site in this ROD is the same as the preferred remedy
released in the Proposed Plan for public comment with no changes.
14.0 References
EPA. May 2024. Region 4. Proposed Plan for Record of Decision, Armstrong World Industries
Superfund Site, Operable Unit 2, Macon, Macon-Bibb County, Georgia.
EPA. January 2024. Scientific Support Section, Superfund & Emergency Management Division.
AWI SU-7 Supplemental HHRA, Armstrong World Industries Site, Macon Georgia.
EPA. April 2024. Region 4. Memorandum: Armstrong World Industries Superfund NPL Site,
Operable Unit Two, Macon, Macon-Bibb County, Georgia, Feasibility Study Report, Early Action
Elements, OU2, Revision 1.
ENVIRON International Corporation. February 2013. Engineering Evaluation/Cost Analysis
(Revision 1), WWTP Landfill, Operable Unit 1, Armstrong World Industries, Inc.
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Environmental Planning Specialists, Inc. June 2020. Technical Memorandum: Fish Compositing
Strategy for Evaluating Risk to Human Health - Armstrong World Industries Superfund Site,
Operable Unit 2. June.
Farrier, Brian Memorandum to Franklin E. Hill. July 2013. Request for a Non-Time-Critical
Removal Action for Operable Unit 1 at the Armstrong World Industries Superfund Site, Macon,
Bibb County, Georgia.
Interstate Technology and Regulatory Council. October 2020. Incremental Sampling
Methodology (ISM) Update.
Montrose Environmental. November 2023. Feasibility Study Report, Early Action Elements,
Operable Unit 2, Armstrong World Industries Superfund Site, Macon, Georgia.
Montrose Environmental. June 2023. Remedial Investigation Report, Early Action Elements,
Operable Unit 2, Armstrong World Industries Superfund Site, Macon, Georgia.
Montrose Environmental. December 2022. Final Human Health Baseline Risk Assessment,
Operable Unit 2, Armstrong World Industries Superfund Site, Macon, Georgia.
Montrose Environmental. December 2022. Final Baseline Ecological Risk Assessment, Operable
Unit 2, Armstrong World Industries Superfund Site, Macon, Georgia.
Montrose Environmental. March 2022. Site Characterization Summary Report, Operable Unit 2,
Armstrong World Industries Superfund Site, Macon, Georgia.
Montrose Environmental. May 2023. Feasibility Study Technical Memorandum #2: Screening of
Candidate Technologies and Assembly of Preliminary Remedial Alternatives for Early Action,
Operable Unit 2, Armstrong World Industries Superfund Site, Macon, Georgia.
Montrose Environmental. April 2023. Feasibility Study Technical Memorandum #1:
Identification of Early Remedial Action Objectives, Operable Unit 2, Armstrong World Industries
Superfund Site, Macon, Georgia.
Oregon Department of Environmental Quality Technical Work Group, Environmental Cleanup
Program. May 2017. Ecological Risk Assessment Technical Workgroup Recommendation Report.
PART 3: RESPONSIVENESS SUMMARY
This Responsiveness Summary for the Armstrong World Industries Superfund Site, OU1 and
OU2, was prepared in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act (SARA), and the National Contingency Plan (NCP), 40 CFR §300.430(f).
The Responsiveness Summary documents, for the public record, EPA's response to comments
received on the Proposed Plan during the public comment period.
The Proposed Plan for the Site was issued on May 29, 2024. A public meeting was held virtually
on Zoom on May 30, 2024. A written transcript from the meeting is included Appendix B of this
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ROD and in the Administrative Record file. The 30-day public comment period started on
May 30, 2024, and ended on July 1, 2024. Written comments on behalf of the Performing
Respondents to the AOC for the Armstrong World Industries Site were received by the EPA. No
request for extension of the comment period was made. The EPA's responses to questions
asked at the public meeting by the attendees, which did not pertain to the specific cleanup
alternatives, are documented in the meeting transcript in Appendix B.
The Proposed Plan and supporting documents were made available to the public Administrative
Record File, which was compiled to support the selection of this Remedial Action. The EPA
provided notice to the public that the Administrative Record files could be viewed online at
http://www.epa.gov/superfund/armstrong-world-industries. or accessible on public computers
available at the Site's information repository at the Middle Georgia Regional Library, 1180
Washington Avenue, Macon, Georgia.
The notice of availability of these documents was published on May 24, 2024, in the local
newspaper, The Telegraph (often referred to as The Macon Telegraph). In addition, the EPA
sent a fact sheet summarizing the EPA's preferred Remedial Action alternatives to residences in
Macon, Georgia, in May 2024. The fact sheet also included the Site's webpage link (listed
above) encouraging the public to sign up to attend the public meeting and submit comments.
After reviewing and considering all public comments received during the public comment
period, the EPA's selected remedial alternatives remained unchanged from what was presented
in the Proposed Plan, and are as follows:
• RA-SU7-6 (for SU-7): removal of PCB-impacted soils with concentrations > 25 ppm in
Action Area Option #3 with off-site disposal Sampling Unit 7; and
• RA-LF-2 (for the landfills): Restore/repair existing soil cover, fencing, and implement
institutional controls.
1.0 Stakeholder Issues and Lead Agency Responses
Below is a summary of the written comments that were received on behalf of the PRP
Respondents for the Armstrong World Industries Site on June 28, 2024. All comments from the
PRP Respondents are on the May 2024 Proposed Plan. No other comments were received
before, during, or after the public comment period.
Comments related to Sampling Units 3 and 5 (SU-3 and SU-5)
Comment 1: EPA establishes a preliminary remedial goal (PRG) of 15 mg/kg for protection of
human health under an industrial land use scenario. A remedial action level (RAL) of 25 mg/kg
PCB (pg. 17) based on TSCA clean-up levels for low occupancy areas (TSCA was identified as an
ARAR), is established to meet the PRG. TSCA's clean-up levels are, in fact, risk-based thresholds
for protection of human health. However, EPA's PRG is not based on the same exposure factors
described for low occupancy areas. Had EPA considered consistent exposure factors for low
occupancy, the resultant PRG would be higher than what is reflected in the Proposed Remedial
Action Plan.
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EPA Response: The RA-SU7-6 selected remedy will remove all soils in SU-7 that exceed a PCB
concentration of 25 ppm, which is the TSCA standard for a "low occupancy" area (40 CFR §
761.61(a)(4)(i)(B)(l). Excavation of PCB-contaminated soil > 25 ppm that is based on the area-
average cleanup level of 6.5 ppm in the SU-7 sampling unit (see Table 5, Section 7.5) results in
an SU-7 post cleanup area-average PCB concentration of 4.3 ppm, which reduces the HQ for
both insectivorous birds and the future industrial worker to less than 1. The post cleanup area-
wide average PCB concentrations are based on 95% Upper Confidence Limit of the mean
estimates (See Table 5, Section 7.5.
Comment 2: EPA acknowledges that TSCA does not apply to the wetlands in SU-5 (and
presumably SU-3, which is also wetland area) (pg. 16, para. 3). Therefore, RAO #2 does not
apply to SU-3 and SU-5, and the clean-up level (i.e., RAL) to achieve an HQ of 1 (RAO #1)
remains open to interpretation.
EPA Response: RAO #2 is "Reduce to acceptable levels the carcinogenic and non-carcinogenic
risks to the future industrial worker from exposure to PCBs in soil within SU-7 by achieving the
cleanup levels." The EPA agrees that RAO #2 focuses on SU-7 and that no action is needed at
SU-3 or SU-5.
Comment 3: MNR is not viable in low-energy setting with nominal sediment accretion, so eco
risk is expected to remain stable over the next 5 years.
EPA Response: The EPA agrees, and MNR was not stated to be a consideration for SU-3/5.
Comments related to risk results Sampling Units 3 and 5 (SU-3 and SU-5), specific to Table 2 in
the Proposed Plan
Comment 4: The HQ is calculated to one significant figure (this is not reflected in EPA's table).
Therefore, the PCB condition in SU-5 (1 instead of 1.2) meets RAO #1.
EPA Response: The EPA reported the ecological risk HQs to two significant figures to prevent
losing the information that might occur when rounding to one significant figure (such as 1.2 to
1, or 2.7 to 3, or 19 to 20). Final human health risks were reported to one significant figure.
Comment 5: The PCB ISM data in SU-3 is highly skewed. EPA acknowledges in the footnote of
Table 2 that the high-end HQ of 2.7 based on the 95% UCL has the most uncertainty.
EPA Response: The EPA agrees that the ISM PCB concentration data for soil in SU-3 has a lot of
uncertainty in it, which is reflected in the statistical estimates of the mean and results in the
higher HQ estimate of 2.7. The HQ of 1.4 resulting from the use of the highest measured PCB
concentration in SU-3 surface soil as the EPC is included in the table in recognition that the 95%
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UCL estimate of the mean PCB surface soil concentration is likely skewed high from the one
seemingly anomalous sample result.
Comment 6: EPA does not mention that the risk estimates for SU-3 and SU-5 do not include the
effects of flood inundation from Rocky Creek. The flood study showed 12% and 17% inundation
(as cumulative acre-day inundation/total number of acre-days during the study period) of SU-3
and SU-5, respectively.
EPA Response: The EPA believes there are a number of uncertainties that affect the risk
estimates, as outlined in Section 7.2.4. The EPA agrees that the potential for periodic flooding
could be an additional uncertainty. The impacts of flooding at SU-3 and SU-5 are discussed in
Section 12.4.
Comment 7: The risk calculations performed in the BERA and by EPA conservatively use the
95% UCL as the Exposure Point Concentration (EPC). However, in determining ecological-based
remedial action it is common to use the average concentration instead of 95% UCL. Using the
average concentrations results in an HQ of 1 (PCBs) and 2 (Cd) for SU-3 and 1 (PCBs) for SU-5).
Thus, based on the average concentrations and rounding to one significant digit, SU-3 and SU-5
meet the HQ of 1 for PCB, thus meeting RAO #1.
EPA Response: Depending on the situation, either the maximum contaminant concentration,
simple mean contaminant concentration, or the 95% UCL estimate of the mean concentration
can be used in remedial decision making. The EPA will typically use the 95% UCL estimate in its
risk estimates.
Comment 8: The HQ for cadmium in SU-3 is above 1; however, this does not account for the
effects of flood inundation. As stated in the BERA: Avian response to flooding varies based on
the extent and duration of flood events and species ecology. Prolonged flooding has been
shown to cause changes in population density, occupancy, and community structure of ground
foraging birds. Additionally, flooding can induce habitat alteration and impact the availability of
avian food resources. For example, flooding generally has a negative impact on earthworm
abundance, which represent a significant portion of the modeled diet of the cotton mouse and
insectivorous bird and a key pathway for exposure to soil COPECs (as discussed in Section
4.4.2.1). In summary, the flood study suggests that this risk assessment over-estimates risk to
nonarboreal small mammals and certain avail species in inundated areas.
EPA Response: It is understood that the occasional flooding could impact the exposure of the
birds and mammals to contamination in SU-3. For some exposure parameters, such as
bioavailability, the EPA responded to the uncertainty of not having site specific information by
leaning towards higher protectiveness, in this case assuming 100% bioavailability. However, in
some instances the EPA were more moderate in our assumptions, notably in our dietary
percentage assumptions. For example, for the Robin the EPA assumed only 25% ingestion of
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their daily food intake as earthworms, which were the highest contaminant concentration prey
item that was evaluated. In general, by leaning more conservative in its assumptions, the EPA
believes the HQ estimates calculated for SU-3 and SU-5 warrant no action.
Comment 9: The inputs into the risk calculations are "modestly conservative exposure
assumptions." Using exposure assumptions that we feel are more realistic (as presented in the
BERA), the resulting HQ for avian exposure to cadmium at SU-3 is 0.6.
EPA Response: It is understood that the PRP Respondents proposed using different exposure
parameters and toxicity values than the EPA used. As stated above, by leaning more
conservative in its assumptions, the EPA believes the HQ estimates calculated for SU-3 and SU-5
warrant no action.
Comments related to future sampling at Sampling Units 3 and 5 (SU-3 and SU-5)
Comment 10: Additional sampling at SU-3 and SU-5 is not warranted as these areas do not pose
an unreasonable ecological risk. Additionally, it is likely that the concentrations will remain
stable over the next 5 years and, more importantly, using average concentrations in SU-3 and
SU-5 results in acceptable HQ values (considering flood inundation) indicating that there is not
an unacceptable ecological risk.
EPA Response: The ROD does not mandate further sampling at SU-3/5, as was stated in the
May 2024 Proposed Plan. As stated in Section 12.4 of the ROD, "For the SU-3 and SU-5 sampling
units, for example, the EPA will evaluate any changes in PCB toxicity to avian receptors, the
amount of time SU-3 and SU-5 are flooded, whether flooding has caused erosion or deposition
of soil, or if other physical conditions have changed that may impact EPA's risk assumptions. As
with any FYR, EPA will determine what sampling is needed, if any, is warranted to assess
changes to Site conditions."
Comment 11: If the risk estimates of 1.2 to 2.7 for these areas don't warrant remedial action
today, there is no basis to conclude that the same concentrations will warrant a remediation in
5 years.
EPA Response: The ROD does not mandate remedial action in SU-3 and SU-5. See EPA's
response to Comment #10.
Comment 12: It is notable that the highest HQ (2.7) is based on a "statistical estimate" - not a
measured concentration or the representative exposure concentration for these areas.
Excluding this estimate, the HQs associated with PCBs are 1.2 and 1.4 (both of which round to 1).
53
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
EPA Response: As noted in the footnote on Table 4 in Section 7.2.4, "The measured soil PCB
concentrations in SU-3 were highly variable resulting in significant uncertainty on the exposure
concentration for insectivorous birds; therefore, two HQs were calculated for SU-3. The HQ of
2.7 is based on the highest PCB soil concentration statistical estimate and has the most
uncertainty, while the HQ of 1.4 is based on the maximum measured PCB soil concentration."
Comment 13: The reduction in risk from maximum of 2.6 to less than 1 is insignificant
compared to the recognized damage that would occur to the ecological habitat from
implementing an intrusive remedy - the risk reduction achieved by an active remedy does not
justify an intrusive remedy. In the event that any reevaluation is performed at the Five Year
Review, we suggest rewording the penultimate sentence above to allow for the concept of a
potential NEBA evaluation. "However, as part of the first Five Year Review for the Site ... to the
extent that environmental risks are re-evaluated... the evaluation may incorporate net
environmental benefit analysis concepts."
EPA Response: The ROD does not mandate any further sampling in SU-3/5. Therefore, the
inclusion of NEBA as part of the narrative in the ROD is not warranted. However, as noted in
Comment #10, as stated in Section 12.4 of the ROD, "For the SU-3 and SU-5 sampling units, for
example, the EPA will evaluate any changes in PCB toxicity to avian receptors, the amount of
time SU-3 and SU-5 are flooded, whether flooding has caused erosion or deposition of soil, or if
other physical conditions have changed that may impact EPA's risk assumptions. As with any
FYR, EPA will determine what sampling is needed, if any, is warranted to assess changes to
Site conditions."
Comments related to Page 14, Paragraph 3 of the Proposed Plan: The HHBRA found that the
fish tissue does not pose an unacceptable risk (Cancer Risk of6x 10-6 and HI of 0.6)
Comment 14: The cancer risk should be 3 x 10-6, not 6 x 10-6. (Note: EPA used results for the
Adolescent Angler in this table.)
EPA Response: The values have been updated in this table (Table 2 in the ROD) to reflect
consistency.
Comments related to Page 14, Last Paragraph of the Proposed Plan: By removing SU-7 soils
with total PCBs above 25 ppm the human health risk is reduced from a hazard quotient of 7.3
to 0.3
Comment 15: It is unclear how the EPA derived an HQ of 0.3. Per the Feasibility Study, the post-
action EPC in SU-7 is 3 mg/kg, which results in a HQ of 0.2 for the Composite Worker using the
EPA RSL Calculator. (Note: the values shown in Table 1 that were calculated by the EPA were
based on the Composite Worker.)
54
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
EPA Response: An HQ of 0.3 was calculated based on the 95% UCL of the area-wide average,
4.77 mg/kg, based on expected post-remediation concentrations. In areas where soil was
removed, a concentration of V* the detection limit (0.0085 mg/kg) was used, resulting in post-
remediation concentrations of 0.00425 mg/kg. For more information as to how this HQ was
calculated, please see the April 2024 memorandum "AWI PCB Cleanup Levels in SU-7."
Comments related to Page 15, Table 1 of the Proposed Plan
Comment 16: Noted several errors in this table. It looks like CTE values were entered into the
table for the Trespasser instead of the RME values that were used for the other receptors. The
table should indicate that these values are based on the RME scenario and thus represent an
elevated potential risk.
EPA Response: The EPA has updated this table (Table 2 in the ROD) using the RME scenario.
Comment 17: The summary of risk for the industrial worker indicates the estimates are "future
risks" potentially implying risks post-remediation. As noted above, the post-remediation HQ
would be 0.2. The table should indicate more clearly that the risk estimates are pertinent to a
hypothetical future industrial land use scenario if remediation is not conducted and not
reflective of the post-remediation condition.
EPA Response: Table 2 of this ROD has been updated to reflect that these risks are for a
potential worker.
Comments related to Page 16, Paragraph 4: "By removing SU-7 soils with total PCBs above 25
ppm the ecological risk is reduced from a hazard quotient of 19 to 0.7.
Comment 18: It is unclear how the EPA derived a post-action HQ of 0.7. Per the Feasibility
Study, the post-action EPC in SU-7 is 3 mg/kg, which results in a HQ for the robin of 0.1 - 0.5 as
presented in Appendix D of the Feasibility Study.
EPA Response: As noted in Table 5, Section 7.5, the EPA calculated a post cleanup level for SU-7
of 4.3 mg/kg (based on the area average soil concentration), which results in an HQ for the
Robin of 0.7.
2.0 References
For the full comments received on behalf of the Respondents to the AOC for the Armstrong
World Industries Site, please see Comments on the Proposed Plan for Armstrong World
Industries Superfund Site, Operable Unit 2, in Appendix C.
55
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
TABLES
56
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 1: COC Concentrations in Soil Sampling Units
Sampling Unit
Chemical of Concern
Concentration
(PPM)
Quantity/volume of
Waste
SU-7
PCBs
70.9
4,087 cubic yards
(selected remedy
RA-SU7-6)
Benzo(a)pyrene
4.3
Dibenzo(a,h)anthracene
0.84
Lead
134.6
SU-3
PCB
21.2
Remediation not
proposed
Cadmium
26.5
SU-5
PCBs
37.9
FMNOL/Remote
Landfills
Copper
191.7
12 acres of debris
removal
57
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 2: Human Health Risks at OU2 and SU-7
Current Risks for the 0U2 Site Inspector, Trespasser, and Angler
Site Inspector
Exposure
Medium
Contaminant
Carcinogenic Risks
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Soil
PCBs
1 x 10"6
0.09
Benzo(a)pyrene
1 x 10"7
0.001
Dibenzo(a,h)anthracene
3 x 10 s
-
Total = 2 x 10"6
Total = 0.09
Trespasser
Exposure
Medium
Contaminant
Carcinogenic Risks
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Soil
PCBs
5 x 10"7
0.08
Benzo(a)pyrene
6 x 10"8
0.001
Dibenzo(a,h)anthracene
1 x 10 s
-
Total = 6xl0"7
Total = 0.08
Angler
Exposure
Medium
Contaminant
Carcinogenic Risk
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Surface
Water
PCBs
6 x 10 s
-
Fish
PCBs
3 x 10"6
0.5
Mercury
--
0.1
Total = 3 x 10"6
Total = 0.6
Future Risks for SU-7 Sampling Unit
Industrial Worker
Exposure
Medium
Contaminant
Carcinogenic Risk
(Ingestion, Dermal, Inhalation)
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
Soil
PCBs
1 x 10"4
7.23
Benzo(a)pyrene
3 x 10"6
0.0257
Dibenzo(a,h)anthracene
5 x 10"7
-
Total = 1 x 10"4
Total = 7
58
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 3: COPECs, by Environmental Media
Constituent
Soil
Sediment
Surface Water
PCB Aroclors
X
X
X
HMWPAHs
X
X
LMWPAHs
X
Aluminum
X
Cadmium
X
X
Copper
X
X
Iron
X
Lead
X
Mercury
X
X
Zinc
X
X
Notes:
"X" denotes that constituent is a COPEC for corresponding environmental media.
Source: Section 2.7 of 2022 OU2 BERA.
Table 4: Ecological Risks for SU-3, SU-5, SU-7 and FMNOL
Receptor
Media/Pathway
Sampling Unit of
AWI OU2
Contaminants of
Concern (COC)
HQ
Insectivorous/
Omnivorous
Bird
(American
Robin)
Ingestion of prey (insects
SU-7
PCB
19
and invertebrates such as
Lead
3
earthworms),
SU-3
PCB
1.4-2.7*
fruits/berries, and
Cadmium
2.6
incidental ingestion of
SU-5
PCB
1.2
surface soil
FMNOL
Copper
3.6
*The measured soi
PCB concentrations in SU-3 were highly variable resulting in significant uncertainty on the exposure
concentration for insectivorous birds; therefore, two HQs were calculated for SU-3. The HQ of 2.7 is based on the highest
PCB soil concentration statistical estimate and has the most uncertainty, while the HQ of 1.4 is based on the maximum
measured PCB soil concentration.
59
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 8: SU-7 PCB Soil Cleanup Levels and Post-Cleanup Risks
PCB Cleanup
Level
(area avg.)
Receptors
Basis of Cleanup
Level
Post Cleanup
Level
(area avg. soil
concentration)
Risks Post
Cleanup1
6.5 ppm
Future
Industrial
Worker
ARAR TSCA 40 CFR
§761.61(a)(4)(i)(B)(l)
(not to exceed < 25
ppm)
Human Health Risk-
Based4
(area average of
< 15 ppm)
4.3 ppm
HQ3 = 0.3
CR2 = 5xl0"6
Insectivorous
Bird
Ecological Risk-
Based4
(area average of
< 6.5 ppm)
HQ3 = 0.7
*95% UCL estimate of the mean contaminant concentration as the EPC
2Cancer risk
3HQ = Hazard Quotient
4Total PCB concentrations of 6.5 and 15 were calculated to be protective of the insectivorous bird and the
future industrial worker in SU-7, respectively
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 9: Comparative Analysis of SU-7 Remedial Alternatives1
Remedial Alternative
Overall Protectfoi
i Compliancew
Appropri:
Long-term Effectiveness and Permanence Reduction of Toxicity, Mobility, orVoiur
The potential for PCB attenuation in SU-7
i itcd and RA S U7 lisnotexpected to
eliminate or reduce ecological risk; as sucl
R.A SU7-1 would not meet RAO HI.
Com bines a soil cover, fencing, and an EC. The cover
would span Action Area Option #1 and be placed above
the original grade at a minimum thickness of two feet.
Rock armoring would be placed along the western bank
of Ditch H2, to prevent an avulsion into the area of the
soil cover. Perimeter fencing and the UEC would protect
the long term integrity of the soil cover from public
access and to prohibit residential use.
RA-5U7-2 reducesthe ecological risk profile
in SU-7 to an acceptable level using the OU2-
v/ide DAF (i.e., with an IIQ ofl achieves RAO
HI) by isolating potential receptors from
contaminant concentrations within Action
Area Option #1; however, using the SU7
specificBAF would result in an HQ of 4, whid
is above the preferred HQ ofl.
The sc
:a partial removal action supplemented with
r in Action Area Option HI, fencing, and an E
removal uvill target the zone of>500 mg/kg I
IW-5U7-3: Partial re
extend one feet below ground surface (ft-bgs)
¦ ring the bioticzone. Pre-removal land surface would
estored using clean backfill. Excavated materials
Id be characterized and profiled, and transported off-
to aTSCA-permitted facility. A soil cover minimum of
feet in thickness would be placed across the full
'al extent of Action Area Option 01. The surface
topography Ipirrh) of the rover would he ronton red in r.
surface covering. Ruck aimuring would be placed along
tine western bank of Ditch #2, to prevent an avulsion into
tine area of the cover. Perimeter fencing and an EC would
be implemented to protect the long-term integrity of the
cover from public access and to prohibit residential u se.
|location-specific ARARsidentified for OU2.
KA-SU/-2 meets the action-specific ARAK fo
PCB cleanup using the risk-based option.
Appropriate control measures would be
implemented during construction such that
the substantive requirements of the action-
jrind luirflkm-^ieiilic: ARARs would be
j achieved. The chemical-specific ARARs do rh
apply to RA-SU7-2 due to use of the de-
based cleanup option.
RA-SU7-3 reducesthe ecological risk profile
to an acceptable level using the OU2-wide
DAF (i.e., with an IIQ ofl it achieves RAO #1)
through a combination of removal and
9olation of COP EC-impacted soil within
Action Are a Option #1; however, using the
SU7-specific BAr would result in an HQ of 4,
which is above the preferred HQ ofl.
jSame as P.A-SU7-2. Exc
aged and diqiosec
regulations.
RA-SU7-1: Removal in Action Area
:e disposal
al controls
n Area Option #1 to a depth of one fl-bgs (the bio lie
i and ofF-site disposal of soil remediation waste,
ated materials would be characterized and profiled,
and tranported off-ate to a TSCA-permitted facility. Pre-
noval land surface elevation will be restored u sing
an, imported backfill material. An EC would be placed
the property to prohibit residential use.
RA SU7 4achieves RAO#1 by reducir
; the
ecological rid< profile to an acceptable level
OU2-wide BAF (ie., HQ -1)
through removal of COPEC-impacted soil in
i Option CI; however, using the
SU7-specific BAF would result in an HQ of 4,
which is above the preferred HQ ofl.
ivated soilsi
in effective long term
RA SU7 1 would not meaningfully reduce
¦toxicity, mobility, or volume of PCBsin SU 7.
RA-5U7-1 does not
protection to insoc
lack of action tor th
le immediate
isbirdsin SU 7. The
on would protect
RA-SU7-2 is an effective long-term strategy
for protecting insectivorous birds from
chemical exposure in SU-7. Long-term O&M
is necessary to routinely evaluate rhe
RA-SU7-2 relies
RA-SU7-? provides immediate emlogiral risk
ecowsLem is expected to nalui ally recover
forming the same or similar environment that
occurred prior to remediation,
n engineering controls and, Implementation of RA-SU7-2 is expected
educe the toxicity or volume temporarily increase traffic and noise in t
e functioning a;
of waste material in the Landfills; however.
RA-SU7-2 would reduce the mobility of
COPECsin SU 7 by protecting against cro si or
¦ Id reduce the volume ofCOPEC
sby an estimated 65 C Y. The soil
sthe mobility of PCBsin SU-7 by
ain st erosio n an d runoff o f the
surrounding OU2. Operators of
equipment may be exposed to
various physical hazard^ though worker
health risk is expected to be minimal;
however, worker exposure to soil particulate:
or vapors may necessitate the need for dust
control and/or other measures. Human
health implementation risks would be
managed through safe work practice sand
PPE.
Similar to the RA-SU7-2, RA-SU7-3 would
provide immediate reduction in ecological
risk. Potential human health implementation
risks are the same as those described for RA-
SU7-2, plus worker exposure to soil
partiaila te s or vapors du ring excavati on m ay
necessitate the need for dust control and/or
other measures. These risks v/ould be
managed through safe v/ork practice sand
appropriate PPE.
RA-SU7-4 providesimmediate ar
permanent protection to insectii
long-term O&M wou Id not be n<
RASU7-1 w
RA SU7 2isimplcmcntablc with several siti
preparation activities, including land clearir
t staging areas. I he equipment at
necessary for land clearing and
.. bulldozers, dump trucks,
ush chipper, stump grinders, etc.) are
ladily available, and the prartiresand
datively straightforward.
The estimated construction timeframe is2-3
months. Long-term O&M, annual reporting,
and five-year EAROD review support is
anticipated for 30 years.
RA-SU7-3 is readily implemented with similar
sire preparation acrivirie s as for RA-SU7-?.
pr epar ati oil and i e medy con sir u cliori ar e
readily available, and the practices and
procedures for implementing RA-SU7-3 are
relatively straightforward. Excavated soils
would be temporarily placed in staging piles
or loaded directly into dump trucks, and
ultimately transported to a TSCA-permitted
facility.
The estimated c<
months. Long-term stewardship involving
O&M, annual reporting, and five-year EAKUD
review support isanticipated for 30 years.
RA-SU7-4can be implemented with similar
site preparation activities as described for P.A-
5U7-2 and RA-SU7-3. Equipment and
materials necessary for site preparation and
remedy construction arc readily available,
and the practices and procedures tor
implementing RA-SU7-4 are relatively
temporarily placed in staging piles or loaded
directly into dump trucks, and ultimately
transported to a TSCA-permitted facility.
e estimated construction timeframe
inths I ong-rerm stewardship is nor
1 Source: Table 8-2 of the Site's 2023 OU-2 FS Report.
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Remedial Alternative
I Overall Protectioi
Threshold Criteria
in Health and the Complian
s with Applicable or Relevant and
Qriate Requirements (ARARs)
Long-term Effectiveness and Permanence Reduction of Toxicity, Mobility, or Volume ;
Involve 5 excavation across the full lateral extent of
Action Area Option #2 to one ft-bgs and off-site disposal
of soil remediation v/aste. Excavated materials would be
characterized and profiled, and transported off-site to a
TSCA-permitted facility. Pre-removal land surface
elevation will be restored u sing clean, imported backfill
material. An EC would be placed on the property to
prohibit residential use.
A-SU/-b
isthe 0i
to an acceptable level (i.e. , HQ of U.3 to 1,
meeting KAO Bl) in SU-/ through removal of
cuPEt-impacted soil in Action Area Option !
Si. Action Area Option B2 providesa greater
level of reduction in the robin HQ compared
to Action Area Option Bl.
KASU/-S A'
impacted s<
PA-SU7-G: Removal in ActionA
Option #3 with off-site disposa
il controls
Involves excavation auoss the full Idleidl extent of
Action Area Option #3 to one ft-bgs with additional
excavation to approximately 2 ft-bgs in a sin al lei portion
of the area, off-site disposal of soil remediation waste,
and execution of an EC. Excavated materials would be
a characterized and profiled, and transported off-site. Soil
with concentrations* 50 mg/kg PCB would be
transported to a TSCA-permitted facility and soil
characterized below SO mg/kg PCB could potentially be
transported for disposal at a Subtitle D landfill. Pre-
removal land surface elevation will be restored using
clean, imported backfill material. An EC v/ould be placed
on the property to prohibit residential use.
RA-SU7-b achieves RAO#1 by reducing ths
ecological rid< profile in SU-7 to an
acceptable level |/e., HQ= 0.1-0.5) throiif
removal of COPEC-impacted soil in Action
Area Option S3. RA-SU7-5 and RA-SU7-6
provide a similar level of protection.
KA-su /-b complies with the EPA selected !
chemical-specific and action-specific A KAKs •
for PCB cleanup using the self-implementing •
option for low occupancy areas, appropriate •
gpd and rliiposprl of
is RA-SU7-4and RA-SU7-S.
RA SU7-G would reduce the volume ofCOPEC
impacted soils by an estimated 4,087 cubic 5
yards.
is RA-SU7-3, RA-SU7-4 and RA-SU7-
:Same as RA-SU7-5, although there is
! efficiency loss with segregating hazai
:and non-hazardous soil. Estimated
$5,270,000-
$4,940,000
62
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 10: Comparative Analysis of Landfill Remedial Alternatives2
Remedial Alternative
Armstrong World Industries ond Former Macon Novel Ordnance Landfills
Threshold Criteria
Environment
The Land fills bear evidence ofirregulai
.1 (Rem
placement of additional material on top
the soil cover (FMNOL). Differential
settlement across the Kemote Landfill hi
landfill condition ;partially exposed deteriorated drum
impliance with Applicable or Relevant ai
Appropriate Requirements (ARARs)
RA-LF-1 complies with the chemical-specific
ARARs identified for OU2; however, RA-LF-1
would not meet location-specific ARARs as
the Landfill s wou Id not be m ai nta ine d to
m Effectiveness and Permanence Reduction of Toxicity, Mobility, or Volume
reduce toxicity, mobility,
/aste materials Surface prevent w
vastcm
debrisand protruding waste materials
represent a physical safety hazard and an
I aesthetic nuisance. Consequently, the soi
jcover is not pioviding proper funclion (i.e
duns nil I in eel RAO 07).
alby
[Involvesrestoring or repairing the
¦the Landfills. Protruding waste ma
[drum carcasses, and su spended m
large surface debris would be rem
litoring weIIsi and
[preparation. The surface cc
[tree fallow is established, u
protection against erosion.
;ring would actively
is expected to provide
[Rock armoring would be applied at the toe ot each
[landfill to prevent washout ot waste materials Irom
iflooding. Perimeter fencing and the UEC will protect the
long-term integrity of the soil cover from public access.
RA-LF-2 protects human health and the
environment by isolating soil and waste
i mate rial sat the Landfills (i.e., achieves RAO
#2) by repairing and maintaining (through a
long-term O&M program) the existing soil
[cover. The cover would be augmented with
iflooding. P.A-Lr-1 doe snot involve an action;
j thu s, there are no action-specific ARARs
under thi s alternative.
! RA-LF-2 compile s wi th che m ical -speafi c
ARARs identified for OU2. This alternative
| doe snot comply with the LPA selected solid
waste landfill cover ARARs; however, EPA car
igrant a 'greater risk to health and the
I environment waiver" given that installing a
; solid waste landfill cover (to comply with the
: EPA selected ARAR) would result in the
; diverse land cover and the loss of habitat at
jOU2. In addition, an equivalent performance
i s RA-LF-2 and RA-LF-3 provide a
functionally similar level ot protection.
; Appropriate control measures would be
implemented during construction such that
j tine other substantive requirements of the
RA-LF-2 is an effective long-term rem
strategy. Long-term O&M isnecessar
iroutinely evaluate the effectiveness c
remedy and certify that the variouse
I RA-LF-2 provides protection and/or
maintenance of a diverse and valuabl
and provides additional protection tr<
| hazards associated with flooding or s
RA-LF-2 would not reduce the toxicity nor
appreciably reduce the volume of waste
riirfleriril in Ihe I and Ills however, RA-IF-7
would reduce the mobility of soil and wasti
materials at the Landfills by protecting
against erosion/runoff and flood-induced
Implementability
)t providing proper RA-LF-1 di
The re stored/re paired surface covering at the
Landfills would provide immediate protection
to human health and the environment from
soil and waste materials at the Landfills Short
term loss of the existing diverse ecosysterr
expected; with time the ecosystem is
expected to naturally recover forming the
prior to remediation. By not removing all
vegetation (especially by leaving as many
mature trees as possible), recover)' v/ill be
taster than it all vegetation were removed.
Traffic and noise in the community
surroundingOU2is expe cted a s a re su It of
in activities, creating a public
RA-LF-2 is implementable with several site
preparation activitie s (described in text),
txposed drums encountered during surface
preparation activitie s will be excavated and
characterized for the need (and type) of off-
s site disposal. Other large debris such as
I concrete rubble will be reduced to rubble and
transported off-site for disposal.
Equipment and materials necessary for land ;
clearing and cover construction are readily
available, and the practices and procedures
for remedy implementation are relatively
straightforward.
The estimated construction timeframe is 3-4
months. Long-term O&M, annual reporting,
arid five-yeai FAROD review support is
hnvolvesan engineered cap following the conventional
tsolid waste landfill cover 9/stem design, fencing, and an
EC. The cap would span both Landfills (i.e., the Landfills
[will be "dosed" asone cell) and be designed and
'constructed consistent with Georgia solid v/aste landfill
e closure requirements. The final cap design is expected to
RA-I I
pIThi:
iflooding from Rocky Cre
The need for a leveling I:
and gas venting layer v/c
process. Perimeter fend
'long term integrity otth
id drainage improvements.
)r structural geosynthetic
ie evaluated during the RD
id the LL would protect the
and waste materials at the Landfills Irom
potential human and ecological receptors
(satisfying RAO 12). I he cap would be
maintained through a long term O&M
program. The cap would be augmented wit
rock armoring to protect against flood-
induced v/a shout of waste materials
PA LF 3 complies with chemical sped lie
ARARs identified for OU2 and is consistent
jv/ith the EPA selected relevant and
appropriate (but not applicable) solid v/aste
s. Appr
> s would be
?nted during
j requirements of the at
specific ARARs would I
i RA-LF-3 is an effective long-term remedial
| strategy. Long term O&M is necessary to
{routinely evaluate the effectiveness otthc
{remedy and certify that the various element
are functioning as intended.
'hardwood forest to vegetated top soil cover
in dude I oss of eco syste m service s,
destruction of diverse wildlife habitat, and
| in creased storm water runoff due to the low
permeable nature of the cap.
A-LF-3 v
ju Id in
reduce the tc
the ei
(see text) are necessary to reshape the
Landfills as one contiguous surface with the
desired contouring across the working face
and ensure proper functioning and long-term
| stability of the cap. Surface contouring will be
in health and achieved using clean fill material imported
e to soil and from an off-site borrow aiea and a&giegale
11(1 fill s.
it the The potentially long duration of the
off, implementation would also cause the
lout potential for additional erosion during
i materia I in the Landfills RA-LF-3 reduc
I mobility of the soil and v/aste material
Landfills by promoting surface water a
minimizing erosion, and preventing v/a
[ of waste material. The engineered cap
expected to provide immediate, robusl
; prote cti on against e ro sio n an d flood-ind u ce d Pote ntial hum an hea Ith im plem entation ri sk s prep arati on. The lo ng co nstru ction c
washout. are the same as those described for RA-LF-2; and amount of earth moving increa;
related to storm water runoff and/or
the FMNOL. Exposed drums<
during surface preparation activities will be
excavated and characterized for the need
(and type) ot off site disposal. Other large
debris such as concrete rubble v/ill be
reduced to rubble as part of the surface
s the
The estimated constructioi
months. Long-term O&M,
and five year EAROD re vie
anticipated for 30 years.
timeframe is 10
nnual reporting,
2 Source: Table 8-4 of the Site's 2023 OU-2 FS Report.
63
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Armstrong World Industries, Macon-Bibb County, Georgia, 0U1 and OU2
Record of Decision
July 2024
Table 6: SU-7 Alternatives Cost Summary
Cost Category
RA-SU7-1:
No Action
RA-SU7-2:
Soil Cover,
Fencing,
Institutional
Controls
RA-SU7-3:
Partial
Removal,
Soil Cover,
Fencing,
Institutional
Controls
RA-SU7-4:
Removal
(Action
Area
Option #1)
RA-SU7-5:
Removal
(Action
Area
Option #2)
RA-SU7-6:
Removal
(Action
Area
Option #3)
Capital Cost
$0
$1,190,000
$1,260,000
$1,970,000
$2,830,000
$3,270,000
to
$4,940,000
30-yr O&M
Cost
$0
$260,000
$260,000
$0
$0
$0
Total Cost
$0
$1,450,000
$1,520,000
$1,970,000
$2,830,000
$3,270,000
to
$4,940,000
Table 7: Landfill Alternatives Cost Summary
Cost Category
RA-LF-1:
No Action
RA-LF-2:
Soil Cover, Fencing,
Institutional Controls
RA-LF-3:
Engineered Landfill
Cap, Fencing,
Institutional Controls
Capital Cost
$0
$4,280,000
$9,680,000
O&M Cost
$0
$540,000
$870,000
Total Cost
$0
$4,820,000
$10,550,000
64
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 11: Low-End Cost Estimate for RA-SU7-63
SU-7 Remedial Alternative SU7-G (RA-SU7-6): Full Removal with Off-site (Hazardous and NonHazardous) Disposal (Action Area Option #3) and IC
Cost Summary
Est. Field Work Duration
Alternative Summary
Capital Cost:
$3,270,000
Site improvements:
27
Days
(1) Excavate entire Action Area Option #3 to 1 ft
30 year O&M Cost:
$0
Soil Excavation:
35
Days
(2) Additional excavation to 2ft for one area within Action Area Option #3
Total: $3,270,000
Soil Dermal Cover:
0
Days
(3) Stockpiling/characterization of soil found in place < 50 mgAg PCB
Annual O&M: $0
Fencing:
0
Days
(4) Backfill Action Area Option #3
(5) EC to prohibit residential use
IC MMP
Item
Task
Quantity
Units
Unit Cost
Total Cost
Comment
1.1
Monitoring & Maintenance Plan
0
1
$15,000
$0
Established Site Inspection/Reporting Protocols
TOTAL:
$0
FIELD CONSTRUCTION PLANNING
2.1
Pre-Remedial Design
0
LS
$0
$0
Not Applicable
2.2
System Design/Construction Plan
1
LS
$75,000
$75,000
Engineering design/drawings
2.3
Contracting - RFB
1
LS
$12,000
$12,000
Request for Bid (RFP)Preparation; Contractor site visit
2.4
Contracting - Review/Award
1
LS
$7,500
$7,500
RFB review, COI verification, Contract management
2.5
Permits
1
LS
$20,000
$20,000
Wetland
Total:
$114,500
SU-7 IMPROVEMENTS
3.1
Access Road
30,000
sq ft
$2.35
$70,500
Grade/com pa ct/Geo-textile/6" GAC Layer (2,500x12ft)
3.2
Site Clearing
2.5
acres
$30,000
$75,000
Clear trees from remediation footprint/footprint offset/access road path
3.3
Stream Bank Armoring (Ditch#2)
0
LF
$85
$0
6" Riprap/placement
3.4
Construction Oversight - Field
21
Days
$1,820
$38,220
3.5
Construction Oversight - Office Support
21
Days
$675
$14,175
3.6
Survey and survey controls
1
LS
$30,000
$30,000
Survey and markers/subcontractor; denote haz/non-haz
Lost Days (weather)
6
Lost Work Efficiency Cost
$52,500
Total:
$280,500
SOIL EXCAVATION & DISPOSAL
5.1
Contractor Mobilization
1
LS
$40,000
$40,000
Support office(s), equipment mobilization
5.2
Erosion-Storm water Management
1,200
LF
$4.25
$5,100
Sediment fencing and controls; surface drainage checks
5.3
Excavation & On-Site Handling
4,087
CY
$8
$32,699
2.3 acre to 1 ft (0.23 acre to 2 ft) Segregate above/below 50 mg/kg PCB
5.4
Characterization of stockpiles
3
sample
$500
$1,500
Assuming 500 CY stockpiles, one composite sample per stockpile
5.5
Subtitle C Soil T&D: Emelle, Al
3,230
ton
$460
$1,485,751
T&D
5.6
Microencapsulation Hot Spot: Emelle, AL
17
roll-off
$17,000
$289,000
assume 22.5 CY/roll-off; assume laterally to next point and vertically 1 ft
5.7
Subtitle D Soil T&D: Local
1,601
ton
$100
$160,131
T&D
5.8
Backfill - Import, Placement, Compaction
4,087
CY
$38
$155,320
Assume local source clean fill
5.9
Restoration
2.5
Acre
$12,000
$30,402
Reseed/straw
5.10
Construction Oversight - Field
28
Days
$1,820
$50,960
5.11
Construction Oversight - Office Support
28
Days
$675
$18,900
Lost Days (weather)
7
Lost Work Efficiency Cost
$78,600
Total:
$0
65
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
SU-7 Remedial Alternative SU7-6 (RA-SU7-6): Full Removal with Off-site (Hazardous and NonHazardous) Disposal (Action Area Option #3) and IC
Cost Summarv
Est. Field Work Duration
Alternative Summary
Capital Cost;
$3,270,000
Site Improvements:
27
Days
(1) Excavate entire Action Area Option #3 to 1 ft
30 year O&M Cost:
$0
Soil Excavation:
35
Days
(2) Additional excavation to 2ft for one area within Action Area Option #3
Total:
$3,270,000
Soil Dermal Cover:
0
Days
(3) Stockpiling/characterization of soil found in place < 50 mgAg PCB
Annual O&M:
$0
Fencing:
0
Days
(4) Backfill Action Area Option #3
(5) EC to prohibit residential use
FIELDWORK CONTINGENCY
Item
Task
Quantity
Units
Unit Cost
Total Cost
Comment
7.1
Total Fieldwork Contingency
20%
%
$525,820
Procurement Issues or interruptions
Total:
$526,000
O&M COST Soil Cover &
dicing Inspection
Item
Task
Quantity
Unit
Unit Cost
Total Cost
Comment
8.1
Field Inspection
0
Event
$6,000
$0
Verify Site Controls & Land Use
8.2
Reporting
0
Event
$2,500
$0
Annual Reporting
TOTAL:
$0
3 Source: Table 8-le of the Site's 2023 OU-2 FS Report.
66
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 12: High-End Cost Estimate for RA-SU7-64
SU-7 Remedial Alternative SU7-6 (RA-SU7-6): Full Removal with Off-site (All Hazardous] Disposal (Action Area Option #3) and IC
Cost Summary
Est. Field Work Duration
Alternative Summary
Capital Cost: $4,940,000
Site Improvements:
27
Days
(1) Excavate entire Action Area Option #3 (to next point below 25 mg/kg) to 1 ft
30 year O&M Cost:
$0
Soil Excavation:
43
Days
(2) Additional excavation to 2ft for one area within Action Area Option #3
Total:
$4,940,000
Soil Dermal Cover:
0
Days
(3) Backfill Action Area Option #3
Annual O&M: $0
Fencing:
0
Days
(4) EC to prohibit residential use
IC MMP
Item
Task
Quantity
Units
Unit Cost
Total Cost
Comment
1.1
Monitoring & Maintenance Plan
0
1
$15,000
$0
Established Site Inspection/Reporting Protocols
TOTAL:
$0
FIELD CONSTRUCTION PLANNING
2.1
Pre-Remedial Design
0
LS
$0
$0
Not Applicable
2.2
System Design/Construction Plan
1
LS
$75,000
$75,000
Engineering design/drawings
2.3
Contracting - RFB
1
LS
$12,000
$12,000
Request for Bid (RFP) Preparation; Contractor site visit
2.4
Contracting - Review/Award
1
LS
$7,500
$7,500
RFB review, COI verification, Contract management
2.5
Permits
1
LS
$20,000
$20,000
Wetland
Total:
$114,500
SU-7 IMPROVEMENTS
3.1
Access Road
30,000
sq ft
$2.35
$70,500
Grade/compact/Geo-textile/6" GAC Layer (2,500x12ft)
3.2
Site Clearing
2.5
acres
$30,000
$75,000
Clear trees from remediation footprint/footprint offset/access road path
3.3
Stream Bank Armoring (Ditch#2)
0
LF
$85
$0
6" Riprap/placement
3.4
Construction Oversight - Field
21
Days
$1,820
$38,220
3.5
Construction Oversight - Office Support
21
Days
$675
$14,175
3.6
Survey and survey controls
1
LS
$15,000
$15,000
Survey and markers/subcontractor
Lost Days (weather)
6
Lost Work Efficiency Cost
$52,500
Total:
$265,500
SOIL EXCAVATION & DISPOSAL
5.1
Contractor Mobilization
1
LS
$40,000
$40,000
Support office(s), equipment mobilization
5.2
Erosion-Stormwater Management
1,200
LF
$4.25
$5,100
Sediment fencing and controls; surface drainage checks
5.3
Excavation & On-Site Handling
5,259
CY
$6
$30,242
2.8 acre (to next point below 25mg/kg) to 1 ft (0.23 acre to 2 ft)
5.4
Subtitle C Soil T&D: Emelle, Al
5,873
ton
$460
$2,701,365
T&D
5.5
Microencapsulation Hot Spot: Emelle, AL
33
roll-off
$17,000
$561,000
assume 22.5 CY/roll-off; assume laterally to next point and vertically 2 ft
5.6
Subtitle D Soil T&D: Local
0
ton
$100
$0
T&D
5.7
Backfill - Import, Placement, Compaction
5,259
CY
$38
$199,860
Assume local source clean fill
5.8
Restoration
3.0
Acre
$12,000
$36,360
Reseed/straw
5.9
Construction Oversight - Field
36
Days
$1,820
$65,520
5.10
Construction Oversight - Office Support
36
Days
$675
$24,300
Lost Days (weather)
7
Lost Work Efficiency Cost
$94,300
Total:
$3,754,300
4 Source: Figure 8-If of the Site's 2023 QU-2 FS Report.
67
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
SU 7 Remedial Alternative SU7 6 (RA SU7 6): Full Removal with Off 5
te [All Hjiardou
s) Disposal (Action Area Option #3) and IC
Cost Summary
Est. Field Work Duration
Alternative Summary
Capital Cost: $4,940,000
Site Improvements:
27
Days
(1] Excavate entire Action Area Option #3 (to next point below 25 mg/kg) to 1 fir
30 year O&M Cost: $0
Soil Excavation:
43
Days
(2) Additional excavation to 2ft for one area within Action Area Option #3
Total: $4,940,000
Soil Dermal Cover:
0
Days
(3} Backfill Action Area Option #3
Annual O&M:
$0
Fencing:
0
Days
(4) EC to prohibit residential use
FIELDWORk CONTINGENCY
Item
Task
Quantity
Units
Unit Cost
Total Cost
Comment
7.1
Total Fieldwork Contingency
20%
%
-
$803,960
Procurement Issues or interruptions
Total:
$804,000
O&M COST - Soil Cover & Fencing Inspection
Item
Task
Quantity
Unit
Unit Cost
Total Cost
Comment
8.1
Field Inspection
0
Event
$6,000
$0
Verify Site Controls & Land Use
8.2
Reporting
0
Event
$2,500
$0
Annual Reporting
TOTAL:
So
68
-------
Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 13: Detailed Cost Estimate for RA-LF-25
Landfills Remedial Alternative #2 (RA-LF-2}: Soil Cover, Fencing, Institutional Controls
Cost Summary
$4,280,000
$540,000
$4,820,000
$18,000
Est. Field Work Duration
Months
Months
Alternative Summary
Capital Cost:
O&M Cost:
Total:
Annual O&M:
Site Preparations: 1.27
Soil Cover Construction: 2.05
Remote Landfill: Removal of surface debris and replacement of soil cover.
FMNOL: Removal of surface debris and soil placement where debris removed.
Item |Task
Quantity | Units | Unit Cost | Total Cost
Comment
CAPITAL COST
PHASE 1: PLANNING
1.1
Pre-Remedial Design
1
LS
$60,000
$60,000
Pre~RD Work Plans, detailed site survey/recon
1.2
System Design/Construction Plan
1
LS
$30,000
$30,000
Engineering design. Work Plan, Health & Safety Plan
1.3
Contracting - RFB
1
LS
$50,000
$50,000
Request for Bid (RFP) Preparation; Contractor site visit
1.4
Contracting - Review/Award
1
LS
$30,000
$30,000
RFB review, COI verification, Contract management
1.5
Permits
1
LS
$30,000
$30,000
Construction SW permit, SWPPP, etc.
Total:
$200,000
PHASE 2: SITE PF
tEPARATIONS/SETUP
2.1
Field management/oversight
1.27
Months
$30,000
$38,000
50 hr/wk x $100/hr + $2500/wk per diem
2.2
Survey and survey controls
1
LS
$20,000
$20,000
Survey and markers
2.3
Abandon Landfill Monitoring Wells
7
each
$2,500
$17,500
Abandon Monitoring Wells
2.4
Remove Surficial Waste
1
LS
$692,000
$692,000
Characterize and dispose of waste at ground surface; 20% Remote Landfill surface, 5% FMNOL
surface.
2.5
Partial Clearing of Vegetation
12
Acre
$6,000
$72,000
Partial clearing of small trees and shrubs for soil cover and staging area/road
2.6
Erosion-Stormwater Management
3,000
LF
$9.00
$27,000
Sediment fencing and controls; surface drainage checks
2.7
Staging Area and Entrance Road
2,000
LF
$120.00
$240,000
Entrance road from landfill to industrial facility
2.8
Storm Water Sediment Basin
1
LS
$65,000
$65,000
Temporary basin required by SWPPP
Lost Days (weather)
8
Lost Work Efficiency Cost
$307,100
Total:
$1,479,100
PHASE 3: SOILC
OVER RESTORATION/REPAIR
3.1
Contractor mobilization
1
LS
$278,800
$278,800
Contractor estimate
3.2
Clean Fill/Contouring - Remote LF
29,010
CY
$37
$1,073,370
Off-site source, transport, spreading, and compaction; repair FMNOL surface where debris is
removed, full 2 ft soil cover atop entire Remote Landfill
3.3
18 inch Low Perm Soil Cover
0
CY
$38
$0
3.4
6 inch Topsoil Cover
0
CY
$38
$0
3.5
Restoration and Hydroseeding
1
LS
$202,800
$202,800
3.6
Storm Water Letdown Structures
0
LFT
$70
$0
3.7
Toe of Slope Rip-Rap
700
Tons
$180
$126,000
Off-site source, transport, spreading/installation
3.8
Drainage Berms, Storm Water Outlets
0
LFT
$15
$0
3.9
Storm Water Outlets
0
Unit
$10,000
$0
3.10
Construction Oversight - Field
1.5
Months
$40,000
$60,000
50 hr/wk x $100/hr + $2500/wk per diem
3.11
Construction Oversight - Office Support
1.5
Months
$10,000
$15,000
3.12
Perimeter Roadway
0
LF
$120
$0
Perimeter roads on east and west sides of landfill
3.13
Gas Vents
0
each
$15,000
$0
2 per acre on remote landfill only
Lost Days (weather)
9
Lost Work Efficiency Cost
$435,200
Total:
$2,195,200
69
-------
Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Landfills Remedial Alternative #2 (RA-LF-2): Soil Cover, Fencing, Institutional Controls
Cost Summary
Est. Field Work Duration
Alternative Summary
Capital Cost:
$4,280,000
Site Preparations:
1.27
Months
Remote Landfill: Removal of surface debris and replacement of soil cover.
O&M Cost:
$540,000
Soil Cover Construction:
2.05
Months
FMNOL: Removal of surface debris and soil placement where debris removed.
Total:
$4,820,000
Annual O&M:
$18,000
Item
Task
Quantity
Units
Unit Cost
Total Cost
Comment
SUPPORTING TASKS
4.1
Construction Contingency
20%
$351,194
Procurement Issues or interruptions
4.2
Health & Safety
1
LF
$20,000
$20,000
Inspection, meetings, safety supplies and equipment
4.3
Completion Report
1
LS
$35,000
$35,000
4.4
O&M Manual
1
LS
$15,000
$15,000
Total:
$406,000
TOTAL:
$4,280,000
O&M COST
Item
Task
Quantity
Unit
Unit Cost
Total Cost 30 Years
Comment
5.1
Cap Inspection
30
1
$4,000
$120,000
Semiannual, 30 years, $2,000/event
5.2
Cap Maintenance Event
30
1
$10,000
$300,000
Every year, 30 events, $10,000/event
5.3
Mowing
0
1
$16,000
$0
Quarterly, 30 years, $4,000/event
5.4
Groundwater Monitoring
0
1
$20,000
$0
Semiannual, 30 years, $10,000/event
5.5
Reporting
30
1
$4,000
$120,000
Annual, 30 years, $4,000/event
Cost Per Year
$18,000
TOTAL:
$540,000
5 Source: Table 8-3b of the Site's 2023 OU-2 FS Report.
70
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 14: OU2 Chemical-Specific ARARs and TBC
<: HEMIC Al-SPEC 1TTC ARAR;
Acrion-'Media
Rfrqimemwin
Pi erwjfiisite
C itiHIOtll sj
Bulk PCB remediation
waste left in, place (self
implmtmtmg optimf}
Bulk PoljcUofiiiatedBi|iienyl (PCS) remediation waste in
low occupancy areas ant be cleaned up 'to <25 ppni unless
otherwise specified.
Bulk PCB reme 25 ppm and <
50 ppm—Relevant and Appropriate
40 C.FJL § 76l..«l{a)C4){i)CBX2)1
ARAR = Applicable or Relevant arid Appropriate Requirement
C.F.R. = Code of Federal Regulations
EPA = U.S. Environmental Protection Agency
PCB = polychlorinated biphenyl
3 Bulk PCB remediation wastes may remain at a cleanup sste at concentratioas 25 ppm and ^ 100 ppm if the site is covered with a cap mediae the requirements of paragraphs
isjd} and i j)fS) of 40 C.F.R. § 761.61.
71
-------
Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Table 15: OU2 Location-Specific ARARs and TBC
LOCATION-SPECIFIC ARAR; and TBC
Location
R«juii emenH
Prerequisite
Citation
Fwodntem s
Presence of floodphio,
designated as such on a map1
Stall take action to reduce tlie risk of flood loss, to minimize the
impact of floods on. human safety, health and welfare, and to restore
and preserve tie natural and. beneficial values sewed bv floodf laias.
Shall consider alternatives to avoid, to the extent possible. adverse
effects and incompatible development in the floodplatn Desiei or
naxfcfi' ik action in cider to nuittntre potential to: to or witlun tlie
Soodplam
Federal acions'iiat involve potential
impacts to. of take place within,
floodplains - TBC:
NOTE: Federal a§aides required to
comply with E 0 11PSS lequneaieiits.
Executive Order 11988 -
Section 1. Floodphin Mtmogment
Executive Order 11PS3
Section 2 < a n 1} rloodphvn
Miwcigcmcn'
Section 2(a i(2) of 10 113S5 is amended by inserting the following
sentence after tlie first sentence:
Where possible. an agency shall use liatiiral systems. ecosystem
processes, and nature-based approaches when developing
alternatives for consideration
NOTE: Federal agencies required to
comply with E.G. 13690 requirements
Executive Order !3-®0
Section 2 I c)
Establishing a Federal Flood Risk
ifam^ewem Shmmwd ivid j Proas;
1 Under 44CFR. § P. 7 Deumtnatom of proposed action's ¦•xation. Paragraph {c, i F'oodptain dmrmmatfon. One should consult tlie FESIA Flood Insurance Rate Map iFIKMi,
flie Flood Boundary Floodway Map! FBFM) and the Flood Insurance Study sFIS"? to determine if ttie Agency proposed action is within the base floodphin Per Executive Order
13690. "To determine whether an agency action is located in a floodplaia the agency iixall use one of the approaches in Section 6i c) of tliis Order based on the best-available
uifomiatioQ and tie Federal Emergency Management Agency" s effective Flood Insurance Rate Map"'
72
-------
Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION-SPECIFIC ARAR? and TBC
Location
Requirement;
Pieit'Cjiiiiirf
C'itatiou
Presence of floodplain
designated as such on a map
Step 4, Identify the potential direct and indirect impacts associated
with fie occupancy or modification, of flcwdplaias and wetlands and
the potential, direct and indirect support of floodplain and wetland
development that couli result from lie proposed action;
Step S. Mmaee 'the potential adverse impacts and support to or
within: icwiplaifts and wetlands to be identified under Step 4, testae
and preserve the natural and beneficial values sm«i by floodplains,
and preserve' and enhance the natural and beneficial values served bv
wetlands (see § 9.11)
NOTE: Identification of potential direct and indirect impacts
associated, "wifli occupancy or modification, of floodplains can be
performed in an FS when evaluating remedial alternatives
against criteria, iirttie NCP at. 40 CFR § 300.430(e)(9) including
Federal actions affecting or affected M
Floodplain as defined in 44 C.F.M. § 9.4 -
Kelrrant and Appropriate
-44 C.FJL § 9.
SlmfjtK-f]
The Agency shall restore and preserve natural and beneficial
floodptam values.
44 C FS j ? I:ib;i3'»
Mmeatfc.ii
Hie Agency shall mininuze:
• Potential harm to lives and die iiTOStaient at risk from
base flood, or in the case of critical actions-", from the 500-
year flood.
• Potential adverse impacts that action may have on
floodplain values
Federal ctctms affecmtg or affected in
Fax,dp!am as defined in 44 C F R. 5 94-
Relevant and Appropriate
44 C F R I 9 *, h•:;<11 and (3:¦
Mmmvcjtiiw pi twskhs
: Minimte means to reduce to smallest amount or degree possible. 44 C F.R. $ 9.4 Definitions
5 See 44 C JF.R. § 9.4 Defmitiotii, Crilfcai action means an action for which even a slight chance of flooding is too great. The minimngi floodplain of concern for critical actions»
the 500-year floodplain i.e . critical action floodplain. Critical actions include, tot are not limited to. those which create or extend the useful life of structures or facilities' Such as
those that produce, use or store hi.slilv volatile, flammable, explosive, toxic or water-reactive materials.
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOC ATION SPEC rFIC ARAR-- and TBC
Lcifflrioii
R«)U1I «-Ul «-!!(<
Pi'wequisire
Cm? ion
Endangered mid or Threnwned Species
Presence of federally
endangered or threatened
species. a* designated in. 50
C' F.R. 17.11 and 17 12 -
or- cnticai habitat of such
species listed in 50 C P R
§ 17 0j
Actions that Jeopardize the existence of a fisted species or resiils in
the destruction or adverse, modification of critical, habitat must be
avoided, or reasonable and proctent mitigation measures taken.
Action tai is likely to jeoparite fist
wildlife, or plant species oi destroy or
adversely modify critical habitat-
Apphrabte
W U.S.C. § 1538(a)
Each Federal agency shall, ui consultation 'vith and with the
assistance of the Secretary [ofDOFI. ensure that anv action
authorized, fended, or carried out bv such agency is nor likelv to
jeopardize tlie continued existence of anv endaneered species or
threatened species or result ia tie destruction or adverse
modification of ha carat of such species which is detemiiiied by [DOI]
to be critical-
Actions authorized funded. or carried cut
by anv Federal aeencv. airaiant to 16
U.S.C $ 1536 - Relevant and
Appiopri.ire
lei U S C. j 1536(a):2v
5QCF.R. §§ 402.13(a). 402.14
Presence of Threatened and
Endangered Wildlife kited in
50C.FR 17.11th!
It is -jniawfjl to take threatened or endangered wildlife m the United
States.
XOTE: Under 50 C F R, 10 12 Definitions, tlie term lake"
means to pursue him!, shoot, wound. kill. trap, capture, or
collect, or attempt to pursue, limit, -.boot. wound kill. trap,
capture, or collect
Action that rnav jeopardize listed wildlife
species - Applicable-
50 C F R Part 17 21io
5(i C F R Part 17 31(a)
50C FR. Part 1742(a){2j
Presence of Endangered.
Threatened. Rare, or Unusual
Species listed ia Rule j 3? 1-
4-10-,0P
It is prohibited to harass, cap®*, kill, or otherwise directly cause
death of any protected amm.il species except as specifically
authorized by law or by regulation as adopted by the Board of
Natural Resources.
Action that may jeopardize listed
"protected species' of plant and animal life
as defined ai GA Rule § 3° 1-4-10-02; d)-
Applicable
GA Rule 5 391-4-10- 061 l}fa)
Prohibited.lets
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION-SPECIFIC aR
Location 1 R^quti euK-uc:
AR ' ami TBC
Prerequisite
Ciurion
Mfgraten Birth
Presence of any migratory
bird, as defined fey 50 C.F.E..
§ 10.13
It shall be unlawful at any time, by any means or m any manner. to
pursue, bust take, capture. kill, attempt to take, capture, or kill,
possess, offer for sale. sell. offer to barter, barter, offer ro purchase,
purchase, deliver for shipment ship, export, imp on. cause to be
slapped, exported or imported, deliver for transportation, transport
or cause to be transported, cany or cause to be carried, or receive for
shipment, transportation carriage, or export, any migratory bird, any
part, nest or eggs of any such bird.
Actions that have, or are likely to taw, a
measurable negative effect an migratory
bird populations -Applicable
IfiUS.C. § 703(a)
Tatinz tailing, or possessing
migratory birds tmlmfitl
Migratory Btrd Treaty Act*
Wvr/tf.'irfs
Presence of wetlands (is
defined in.44CJ.il. §9.4)
Shall take action to wwwrafaaB 'Hie destruction, loss or degradation of
wetlands and to preserve and enhance benefic ial values of wetlands
Shall avoid uiidertakins construehon located m wetland; unless
11 ;• there is no practicable alternative to such construction, and
12 i that the proposed action includes all practicable measures
to niiaimtze liami to wetlands tvinch ruay result ftoai such
use.
Federal actions that involve potential
impacts to. or take place within, wetlands -
TBC
N'OTE: Federal agencies required to
comply with E O. 119P0 requirements
Executive Order 11990 - Protection of
Wetlands
Section Lia)
Executive Order 11PP0.
Section 2.:ai Pi'i)t;k1s
~ Migrator; Bird Treaty Refrain Acr of 2004 -1 Sec, 1021 Amends the Migratory Bird Treaty Act (MBTAjto clarify that the MBTA's prohibiten on taking, killing, or possessing
migratory birds applies only to native migratory bird species whose occurrence m the United States results from natural biological or ecological conditions..
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
IOC ATION-SPEC EFIC AK
locaiiou 1 Requirement;
AR-' ,hk! TBC
Prerequisite
C itarion
Presence of Wellaails (as
defined in. 44 C JF.1L §9.4}
Step 4. IdentifV Hie potential direct .and indirect izqacts associated
witti tie occupancy or modification of floodplatns ami wetlands and
flie potential direct and indirect support of floodplain and wetland
development that cmMirantt from the proposed action;
Step 5. Minimize the potential adverse impacts and support to or
within ffoodplains and wetfands to be identified tinder S'ep 4. restore
and preserve the natural and beneficial values served bv ftoodplams.
and present and enhance tile natural and beneficial values served bv
wetlands nee ? 9.1 Is:
XOTE: Identification of potential direct and indirect impacts
associated with csecwpancv or modification of'.vetlands can be
performed in a FS when evaluating remedial alternatives aeainst
catena in the NCP at 40 CFR 300 4J0te')f ? > including lane-tew
ej?"ec*h'e>ies j and pamaucucc.
Federal actions' affecting or affected by
Wetlands iaclwfiiig tie de&troctian .am!
modification of wetlands and the direct or
indirect support of new consfniction in
wetlands as defined in 44 CF.R. § 9,4 -
Relevant awl Appropriate
44 CJFit § 9.6(b)
Dectim-maMttg Process
The Agency shall minimize' the destruction, loss or degradation of
wetlands
44 CF.R 5 9 liibii;*
Mitigation
* Minimize means ro reduce to smallest amount or degree possible. 44 C" F R. $ 9.4 Definitions
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION-SPEC EFIC AR
Location 1 Requirement;
AR: ami TEC
Prerequisite
Citation
Presence of Wetlands (as
defined in 44 C.FJR. § 9.4)
The Agency shall preserve and enhance die natural and beneficial
wetlands values
Xatiira' Viimej of Flood Plains and H'etimds means die qualities of
or flmciiotss served bv floodplains and wetlands which uictode but
are oot limited to:
(aj Water resource values (natural moderation of floods, water
quality maintenance. eroancfcvater recharge i:
(bi kvins resource values (fish wildlife, plant resources and
habitats);
(c i- cultural resource values ('open space, natural beauty,
scientific shtdv. outdoor education, archeclojrieal and
historic sites, recreation): mid
id) cultivated re,source values (agriculture, aqiiactilmre. forestry).
Federal actions affecting or affected' iy
Wetlands including the fctaictioa and
modification of wetlands and the direct or
indirect support of new construction ill
wetlands as defiled in 44 C.F.R S 9 4 -
Relevant and Appiopi iatf
44 C F 3. j P Il(bX4)
Mitigation
Hie Agency shall minimize:
• Potential adverse impacts the action may have on others:
and
• Potential adverse tmpact the action mar have on wetland
values
44 C.F.R. !• o.llieii2) acd(3i
M'tmmiZiitmn pjwfctcms
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION SPECIFIC aK
Location 1 Requirement;
AR^ slid TBC
Piwtqiusiw
Citation
Compensatory Mitigation*
for Losses of Aquatic
Resources
Compensator,' mitigation required to offset una voidable impacts to
waters of the United States. Consultation with the USAGE District
Engineer recommended
» Amount of required compensatory mitigation mist be. to the
extent practicable, sufficient to replace lost aqtatic resource
functions.
• Compensatory mitigation may be provided
throuzh mitotic® banks or tn-lseu fee proerams
• Implementation of the compensatory mitigation project shall
be. to the maximum extent practicable, m advance of or
concurrent with the impact-causing activity.
including wetlands - Apple.*
40 C.F.K. § 230.93(a)(1)
General compensatory mitigation
requirements
Compensatory mitigation may be performed using file methods of
restoration enhancement. establishment, and in certain
circumstances preservation.
Restoration should generally be the first option considered because
the likelihood of success is sreater and the impacts to potentially
ecologically important uplands are reduced compared to
establishment. and the potential pains in terras of aquatic resource
functions are .greater, compared to enhancement and preservation.
40 CFR ; 250 P3t aK-'
Genera! compensator) 'Pingimon
reqiiatmcm
Required compensatory mitigation should be located within the same
watershed as the impact site and should be located where it is most
likelr to successfully replace lost functions and services, taking into
account such watershed scale features as aquatic habitat diversity,
habitat connectivity, relationships to hvdrologic sources i includme
the availability of water rights), treads m land use. ecological
benefits, and compatibility with adjacent land uses.
Unavoidable impacts to waters of the U S
requiring compensatory mitigation to offset
environmental losses to aquatic resources
including wetlands - Applicable
40CFR.5 230.P3lb!
hpe and location of mitigation
5 40 C F R. j 230 P2 "Oxhpairafon mmirattai tneani tlie restoration ire-establishment or rehabilitationi. establishment (creation). enhancement. and or m certain circumstances
preservation of aquatic resources fur Tlie purposes of offsetting unavoidable adverse impacts which remain after all appropriate and practicable avoidance and mmmnzation has
been achieved/' For impacts authorized under section 404. compensatory mitigation is act considereduntil after all appropriate and practicable steps have been takes to first avoid
and thai minimize adverse impacts to the aquatic ecosystem pursuant to 40 CFR part 230 ti.e. the CWA Section 404(b)( 1 > Guidelines,!
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION-SPECIFIC AR
Location 1 Requirements
AR? and TBC
Pi(-requisite
Cit.itioii
Compensatoiy Mitigation for
Losses of Asiatic Resources
(coat.)
Project site mnst be ecologically suitable for providing the desired
aquatic resource functions. Ia tSetennkiiiig the ecological siiilability
of the coH|jensatoiy iniligatioii project site, fie district engineer
must consider, to tie extent practicable, the factors in sobsectioos ©
thru (vi).
resources or where aqiwtic resources previously e'xisteii
In general, m-kind mitigation ts preferable to out-of-fatx! mitieanon
became it is most likeiv to compensate lor the functions and services
lost at the impact site. Except as provided hi paragraph < e)( 2) of this
section, the required compensatory mmgation shall be of a similar
Tvpe to tlie affected aquatic resource
Unavoidable impacts to waters of the U. S.
reqnking compensatoiy- mitigation to offset
environmental losses to aquatic resources
including -wetlands - Applicable
40 C.F.K, § 230.93(d>(l) & (3)
Site selection
40C.F.B. ? 230°3te;il;
Mnigivmn T\f(
C ompensarorv Mitigation
Planning
Hie amount of required compensatory mitigation must be. to the
extern practicable, sufficient to replace tost aquatic resource
functions. Where appropriate functional or condition assessment
methods or other suitable metrics are available, these methods should
be used where practicable to determine how much compensatory
mitigation is required If a functional or condition assessment or
other statable metric is not used, a mimmam one-to-one acreage or
linear foot compensation ratio must be used
Prepare a nntisatton plan addressuie obfectves. site selection. site
protection, baseline infonnatioii. determination of credits, mitigation
work plm maintenance plan. perfom^mce standards. monitoring
requirements. long-term management. and adaptive management
XOTE: Plan would be part of CERCLA document. such as a
Remedial Action Work Plan. Plan to include items described in
40 C F R. j ^30 P4;ciOj through scji 14,i."
Unavoidable impacts to waters of the U S
requiring compensator.' mitigation to offset
environmental losses to aquatic resources
including wetlands - Applicable
40 C .F R_ § 230.P3i"fiu)
Mitigation Type
40C.FR. §30.Mic)
Mitigation Pkm
* If mitigation obligations will be met toy secori&g credits from approved mitigation banks or in-lies fee programs, mitigation plan,need include only items described ia SecliaB
3£i.P4i c :-i 5; and iextfK and name ofmitigation bank or in-lreo fee program. 40 CJJL 5 230 94ic ii I».
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION-SPEC IHC ARARs and TBC
Location
Requirement;
Prerequisite
C ir.inon
Shall co'aa; ecological i
nb'.ie = ::«kc
40 CJA §230.95
Ecological Perfomumce Standards
Compensator.- Mitigation
Pro;ect Monitoring
Momtormz the compensatory mitieatson project site is necessarr to
determine if the pro-ect is nwetrne its performance standards. and to
determine if measures are necessary to ensure that tlx compensatorr
niitigafson project is acconipkskitg its objective;
Unavoidable impact; to waters of the U S
reqwrmc compensatory imwsatioii to offset
environmental losses to aauatic resources
including wetlands - Applicable
40C.FR j 250 !P6iasf 1
Mitigation Pirni - Mowkwfte
The mitigation plan muss address the itiomtonng requirements for
the compensator,- mitigation project including the parameters to be
monitored, the ienstJi of the momtorine -period , the party responsible
for conducting the monitoring. the frequency fos submittiriE
monitoring reports to the district engineer, and the party responsible
for submitting those monitoring reports to tlie district engineer.
XOIE' Mitigation Plan would be pan of CERCLA document
such as a Remedial Action Work Han
Compensatory Mitigation
Pro-ect Mcsuronne
Compensatory mitigation project monitoring penod shall be
sufficient to demonstrate that project has met performance standards,
but not less than fire ! 51 -.'ears A leaser monitoring period must be
required for acfiiaiic resources with stow development rates te.g..
forested wetland;. bozsV
Unatxr.dable impacts to waters of the U S.
requiring compensatory nuttaatkm to offset
environmental losses to aauatic resources
including wetlands - Applicable
40 CIS. 5 230.9t>i'b 1
Momtormg pcic-J
XOIE. Monitoring Plan would be part of CER.CLA document,
such as a Remedial Action Work Plan and or Operations &
Maintenance Plan
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION-SPECIFIC AR
Location 1 Requueintiits
ARs and TBC
PvereqtiKire
Citation
CoK^ensatoiy Mitigation
Project Management
The aquatic habitats, riparian areas, buffers, and uplands flat
comprise (be overall compensatory mitigation project must be
provided long-term protection, through real estate instruments or
other availabte mectaaisitis, as appropriate.
Long-term protection may be provided through real estate
instalments such as conservation easements hekl by entities such as
federal tribal state, or local resource agencies, noa-profit
conservation organizations, or private land managers: the transfer of
title to sndt entities; or by restrictive covenants..
NOTE Plan would be part of CERCLA document siicli as a
Remedial Action Work 'Plaa. anitar Operations and Maintenance
Plan-
Unavoidable 'impacts to wafers of the U. S,
requiring compensatory mitigation to offset
environmental tosses to aquatic resources
including wetlands - Applicable
40 C.FJM 230.97(b)
SMSfamabiUty
C ff J Section 4'''Hb) Guidelines - Speci^ceiioti ofDnpmai Sites fot Dredged or Fiil Material Into Ho.vr! of the I'miedStttm
Location encompassing
aquatic ecosystem8
Except as provided under section 404(b)(2) [of flic Clean Water Act]
no discharge of dredged, or ill material stall be permitted if there is
a practicable alternative to (he proposed discharge which would have
less adverse impact on the aquatic ecosystem, so long as the
alternative does not have other significant adverse environmental
consequences.
or fill aiateiial'iJito waters of fc U, S.,
tacliisfing wetlands - AppieaMe
40 C.F.R. §230.10(a)
Restrictions on Discharge
For ilie pn*po=e of this requirement practicable alternatives include,
but are not limited to
! i j Aetmtie; vrfiidi do not involve a discharge of dredged
or rill material into the waters ct the United States or
ocean water;.
;it,i »wi Diicharce; of dredsed or fill material at other
locations in -.raters of the United States or ocean
waters
40 C FR 5 230 10ia;.(l!
Reitnc'ion: on Discharge
J 40 C.F R. 5 230.3(b) The terms ctqh-.Wc tvn,rgnwent and aquatic eastern mean waters of the United States including wetlands. that we a* habitat for interrelated and
interacting communities and populations of plants ,mi animal5.
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOC ATION-SPECIFIC AR
Location 1 Rc-quircuM-nts
ARs mid TBC
Prerequisite
C itnnon
An alternative is practicable if it is available 2nd capable of being
done, after taking into consideration cost mating technology. aid
logistics is light of overall project purposes. If it is otherwise a
practicable alternative, an area Brt presently owned by the applicant
which could reasonably be obtained, utilized* expanded or managed
m order to fulfill the basic purpose of tie proposed activity may be
considered.
40 CJFJL § 230.10(a)(2)
Xm'trktiom on Discharge
Location encompassing
aquatic ecosystem con r
No discharge of dredged or fill material -.hall be permitted if it
* C auses or contributes. after consideration of disposal site
dilution aid dispersion, ro violations of any applicable State
water quality standard:
» V; olate s any applic able toxic effluent 5 tandard or prohibition
under Section 307 of the Clean Water Act.
* Jeopardizes the continued existence of species listed as
endangered or threatened under the Endangered Species Act of
1P73. or res-airs 111 the likelihood of the destruction or adverse
modification of critical habitat.
* Violates .my reqvurement imposed by the Secretary of
Commerce ro protect any marine sanctuary designated under
title IH of the Marine Protection. Research, and Sanctuaries Act
of 19T2.
Except as provided under CWA section 404{>jj 2.1. no discharge of
dredged or fill materia! shall be permitted witch wil cause or
contribute to significant degradation of t!ie waters of the United
States FaiduiBS of siemf.cant degradation related to tie proposed
discharge shall be based upon appropriate factual determinations,
evaluations, and tests required bv subparts B and G. after
consideration of subparts C through F. with special emphasis on the
persistence and permanence of the effects outlined in those subparts.
Action that involves discharge of dredeed
or fill material into waters of the U S .
including wetlands - Applicable
40 C FR. 5 230.1 Otb 1
Rtivicmm onDischinga
40 C FR. S 230 lOic.
J?csrn:nvits j'i DtJOnP^tt
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Location
LOCATION-SPECIFIC AK
Requirements
ARs and TBC
Prerequisite
Citation
Location encompassing
aquatic ecosystem con't
Under these Guidelines, effects contributing to significant
degradation considered individually or collectively, include:
(1) Significantly adverse effects of the discharge of pollutants on
hitman health or welfare, including but not limited to effects on
municipal water supplies, plankton, fish, shellfish, wildlife, and
special aquatic sites.
(2) Significantly adverse effects of the discharge of pollutants on
life stages of aquatic life and other wildlife dependent on aquatic
ecosystems, including the transfer conceiitratioa and spread of
pollutants or their by- products outside of the disposal site
through biological, physical, and chemical processes:
(3) Significantly adverse effects of the discharge of pollutants on
aquatic ecosystem diversity, productivity, and stability. Such
effects may include, but are not limited to. loss of fish and
wildlife habitat or loss of the capacity of a w'etland to assimilate
nutrients, purify water, or reduce wave energy; or
(4) Significantly adverse effects of discharge of pollutants on
recreational, aesthetic, and economic values.
Action that involves discharge of dredged
or fill material into waters of the U. S.,
including wetlands - Applicable
40 Cf R § 230 10(c)(l)-{4)
Restrictions on Discharge
No discharge of dredged or fill material shall be permitted unless
appropriate and practicable steps haw been taken which will
minimize potential adverse impacts of the discharge on the aquatic
ecosystem.
NOTE: There are many actions which can be undertaken in
response to § 230.10(d) to minimize the adverse effects of
discharges of dredged or fill material. Some of these, grouped by
type of activity, are listed in this subpart H Actions To Minimize
Adverse Effects. Additional criteria for compensation measures
are provided in subpart J of this part.
40 CJF.R_ §230.10(d)
Restrictions on Discharge
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
LOCATION SPECIFIC AK
Loc.iriou 1 Rfq«i.remeu(?
AR.5 aud TBC
Pmeqiiisiff
C it a [ion
Actions to ntiianiize effect;
of discharge of dredged or
fill, material into an aquatic
ecosystem.
Minimization of adverse effects on populations of plants and snmials
can be achieved by:
fa ,i Avoiding changes in water current and circulation patterns
which would interfere with die movement of aaiinals:
I'M Selecting sites or inanasm? chscharses to prevent or avoid
creasing: habitat conducive to the de-.TiOpraerit of
undesirable predators or species which ten* a competiti\*
edge ecologically over indigenous plants or annuals:
{c) Avoiding sites having wmque habitat or other value.
including habitat of threatened or endangered species:
Id1* Usias planning and coasmiction practices to institute
habitat development and restoration to produce a new or
modified environmental state of higher ecoloeical value bv
displacement of some or all of the existing environmental
characteristics Habitat development and restoration
techniques can be used to minimize adverse impacts and to
compensate for destroyed habitat,
fe) Timing discharge to avoid spawning or migration seasons
and other biologically critical time periods:
! f! Avoiding die destruction of remnant natural sites within
areas already affected by development.
Action thai involves discharge of Aedaed
or fill material into waters of the U. S.!"
40 C F S. ? 230.75
Act'vns trfft-cMr plan! andatmhii
popriamm
ARAR = Applicable or Relevant and Appropriate Requsreaient
C.F R = Code of Federal Regit iattcis
CWA = Clean Water Act
DOI -1' S Department of the Interior
E 0. = Executive Order
FS = Feasibility Study
= greater than
- less than
_ = greater than or equal to
_ - If: 7 than or equal to
TBC = To Be C onsidered
I" S - United States
USAGE = U.S. Ajiuy Corp; or Engineers
LIS C. =U.S. Code"
84
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Armstrong World Industries, Macon-Bibb County, Georgia, 0U1 and OU2
Record of Decision
July 2024
Table 16: OU2 Action-Specific ARARs and TBC
ACTION-SIM t il IC AKAKs I I5(
Ailicui
Ki'<|iiimiU'iils
I'mviliiisilr
('ilulinn
(n'liiTiil ( nii\lrin linn Sltimltirtls \ll l.tiinl-tlislm hiiix . \clivilic\ (i i¦. c.wiiviiiion. clearing, ^i iitlui^. t'lc)
Managing stormwater
runoff from land-
disturbing activities
Shall implement best management practices, including sound
conservation and engineering practices to prevent and minimize erosion
and resultant sedimentation, as provided in O.G.C.A. § 12-7-6(b), during
excavation activity.
Land-disturbing activity (as defined in
O.C.G.A. § 12-7-3(9)) of more than one
acre of land - Applicable
GA Erosion and
Sedimentation Act
O.G.C.A. § 12-7-6(b)
Shall control turbidity of stormwater runoff discharges to the extent the
limits in O.C.G.A. § 12-7-6 shall not be exceeded.
Land-disturbing activity (as defined in
O.C.G.A. § 12-7-3(9)) of more than one
acre of land - Applicable
GA Rule 391-3-7-.06
Protection of buffers on
state waters from land-
disturbing activities
having vegetation
wrested from the
channel by normal
stream flow
Must implement adequate erosion control measures in project plans and
specifications such that impacts to the buffer have been avoided or
minimized to the fullest extent practicable.
Land-disturbing activity in buffer land
immediately adjacent to the banks of state
waters that will result in restoration or
enhancement to improve water quality
and/or aquatic habitat quality - Applicable
GA Rule 391-3-7-.05
Managing fugitive dust
emissions
Shall take all reasonable precautions to prevent fugitive dust from
becoming airborne, including the following precautions:
(i) use of water or chemicals for dust control;
(ii) application of asphalt, water, or chemicals on surfaces that
can give rise to airborne dusts;
(iii) installation of hoods, fans, and filters to enclose and vent
the handling of dusty materials;
(iv) covering, at all times when in motion, open bodied trucks
transporting materials likely to give rise to airborne dusts;
and
(v) prompt removal of earth or other material from paved
streets onto which it has been deposited.
Operations, processes, handling,
transportation or storage which may result
in fugitive dust - Relevant and
Appropriate
Georgia Air Quality Control
Regulations Rule 391-3-1-
¦02(2)(n)(l)
85
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Armstrong World Industries, Macon-Bibb County, Georgia, 0U1 and OU2
Record of Decision
July 2024
ACTION-SIM t il IC AKAKs I I5(
Ailinn
Kc(|iiiiviiU'iilN
I'mviiiiKiU'
Cihiliiui
Shall not allow the percent opacity from any fugitive dust source to equal
or exceed 20 percent.
Georgia Air Quality Control
Regulations Rule 391-3-1-
¦02(2)(n)(2)
86
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Armstrong World Industries, Macon-Bibb County, Georgia, 0U1 and OU2
Record of Decision
July 2024
ACTION-SIM t il IC AKAKs I I5(
Aclinn
Kc(|iiiiviiU'iilN
I'mviiiiKiU'
Ciluliiui
ll'tiMr ( liiiiihlrnziilioii I'riniury Hash's (('.if. rxiwiiinl coiihiniiiiiilcil soil iiml debris)
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Characterization of
solid waste (all primary
and secondary wastes)
and listed hazardous
waste determination
Must make an accurate determination as to whether that waste is a
hazardous waste in order to ensure wastes are properly managed
according to applicable RCRA regulations. A hazardous waste
determination is made using the following steps:
(a) Must be made at the point of waste generation, before any
dilution, mixing, or other alteration of the waste occurs, and at
any time in the course of its management that it has, or may
have, changed its properties as a result of exposure to the
environment or other factors that may change the properties of
the waste such that the RCRA classification of the waste may
change
(b) Must determine whether the waste is excluded from regulation
under 40 C.F.R. §261.4
(c) Must use the knowledge of the waste to determine whether
waste meets any of the listing descriptions under subpart D of
40 C.F.R. Part 261. Acceptable knowledge that may be used in
making an accurate determination as to whether the waste is
listed may include waste origin, composition, the process
producing the waste, feedstock, and other reliable and relevant
information
Generation of solid waste as defined in 40
C.F.R. §261.2 Applicable
40 C.F.R. § 262.11(a), (b)
and (c)
GA Rule 391 -3-11 -.08
Determination of
characteristic
hazardous waste
The person then must also determine whether the waste exhibits one or
more hazardous characteristics as identified in subpart C of 40 C.F.R. part
261 by following the procedures in paragraph (d)(1) or (2) of this section,
or a combination of both.
Generation of solid waste which is not
excluded under 40 C.F.R. § 261.4(a) -
Applicable
40 C.F.R. § 262.11(d)
GA Rule 391 -3-11 -.08
Determination of
characteristic
hazardous waste
through knowledge
The person must apply knowledge of the hazard characteristic of the
waste in light of the materials or the processes used to generate the waste.
Acceptable knowledge may include process knowledge (e.g., information
about chemical feedstocks and other inputs to the production process);
knowledge of products, by-products, and intermediates produced by the
manufacturing process; chemical or physical characterization of wastes;
information on the chemical and physical properties of the chemicals
used or produced by the process or otherwise contained in the waste;
testing that illustrates the properties of the waste; or other reliable and
relevant information about the properties of the waste or its constituents.
40 C.F.R. § 262.11(d)(1)
GA Rule 391 -3-11 -.08
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Action
Requirements
Prerequisite
Citation
A test other than a test method set forth in subpart C of 40 C.F.R. part
261, or an equivalent test method approved by the Administrator under 40
C.F.R. 260.21, may be used as part of a person's knowledge to determine
whether a solid waste exhibits a characteristic of hazardous waste.
However, such tests do not, by themselves, provide definitive results.
Persons testing their waste must obtain a representative sample of the
waste for the testing, as defined at 40 C.F.R. 260.10.
Determination of
characteristic
hazardous waste
through testing
When available knowledge is inadequate to make an accurate
determination, the person must test the waste according to the applicable
methods set forth in subpart C of 40 C.F.R. part 261 or according to an
equivalent method approved by the Administrator under 40 C.F.R. §
260.2 U or and in accordance with the following:
(i) Persons testing their waste must obtain a representative sample
of the waste for the testing, as defined at 40 C.F.R. § 260.10.
(ii) Where a test method is specified in subpart C of 40 C.F.R. part
261, the results of the regulatory test, when properly performed,
are definitive for determining the regulatory status of the waste.
Generation of solid waste which is not
excluded under 40 C.F.R. § 261.4(a) -
Applicable
40 C.F.R. § 262.11(d)(2)
GA Rule 391 -3-11 -.08
Must refer to Parts 261, 262, 264,265,266, 268, and 273 of Chapter 40
for possible exclusions or restrictions pertaining to management of the
specific waste.
Generation of solid waste which is
determined to be hazardous - Applicable
40 C.F.R. 262.11(e)
GA Rule § 391-3-11-.08
Identifying hazardous
waste numbers for
small and large
quantity generators
Must identify all applicable EPA hazardous waste numbers (EPA
hazardous waste codes) in subparts C and D of part 261 of this chapter.
Prior to shipping the waste off site, the generator also must mark its
containers with all applicable EPA hazardous waste numbers (EPA
hazardous waste codes) according to § 262.32.
40 C.F.R. § 262.11(g)
GA Rule 391 -3-11 -.08
General Waste
Analysis
Must obtain a detailed chemical and physical analysis on a representative
sample of the waste(s), which at a minimum contains all the information
that must be known to treat, store, or dispose of the waste in accordance
with pertinent sections of 40 C.F.R. §§ 264 and 268.
Generation of RCRA hazardous waste or
nonhazardous wastes if applicable under §
264.113(d) for storage, treatment or
disposal Applicable
40 C.F.R. § 264.13(a)(1)
GA Rule 391 -3-11 -. 10
Special rules for
characteristic
hazardous waste
Must determine each EPA Flazardous Waste Number (waste code)
applicable to the waste in order to determine the applicable treatment
standards under subpart D of this part. This determination may be made
concurrently with the hazardous waste determination required in § 262.11
of this chapter. For purposes of part 268, the waste will carry the waste
code for any applicable listed waste (40 C.F.R. part 261, subpart D). In
addition, where the waste exhibits a characteristic, the waste will carry
Generation of characteristic hazardous
waste for storage, treatment, or disposal -
Applicable
40 C.F.R. § 268.9(a)
GA Rule 391 -3-11 -. 16
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one or more of the characteristic waste codes (40 C.F.R. part 261, subpart
C), except when the treatment standard for the listed waste operates in
lieu of the treatment standard for the characteristic waste, as specified in
paragraph (b) of this section.
Must determine the underlying hazardous constituents [as defined in 40
C.F.R. § 268.2(i)] in the characteristic waste.
Generation of RCRA characteristic
hazardous waste (and is not D001
nonwastewaters treated by CMBST,
RORGS, or POLYM of § 268.42 Table 1)
for storage, treatment, or disposal -
Applicable
40 C.F.R. § 268.9(a)
GA Rule 391-3-11-. 16
Determinations for
land disposal of
hazardous waste
Must determine if the waste has to be treated before it can be land
disposed. This is done by determining if the hazardous waste meets the
treatment standards in §268.40,268.45, or §268.49. This determination
can be made concurrently with the hazardous waste determination
required in §262.11 of this chapter, in either of two ways: testing the
waste or using knowledge of the waste. If the generator tests the waste,
testing would normally determine the total concentration of hazardous
constituents, or the concentration of hazardous constituents in an extract
of the waste obtained using test method 1311 in "Test Methods of
Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication
SW-846, (incorporated by reference, see §260.11 of this chapter),
depending on whether the treatment standard for the waste is expressed as
a total concentration or concentration of hazardous constituent in the
waste's extract. (Alternatively, the generator must send the waste to a
RCRA-permitted hazardous waste treatment facility, where the waste
treatment facility must comply with the requirements of §264.13 of this
chapter and paragraph (b) of this section.)
Generation of hazardous waste for storage,
treatment, or disposal - Applicable
40 C.F.R. § 268.7(a)
GA Rule 391-3-11-. 16
Must comply with the special requirements of 40 C.F.R. § 268.9 in
addition to any applicable requirements in 40 C.F.R. § 268.7.
Generation of waste or soil that displays a
hazardous characteristic of ignitability,
corrosivity, reactivity, or toxicity for
storage, treatment or disposal - Applicable
40 C.F.R. § 268.7(a)(1)
GA Rule 391-3-11-. 16
Management of PCB
waste (e.g.,
contaminated PPE,
equipment,
wastewater)
Any person storing or disposing of PCB waste must do so in accordance
with 40 C.F.R. 761, Subpart D.
Generation of waste containing PCBs at
concentrations > 50 ppm - Applicable
40 C.F.R. 761.50(a)
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Any person cleaning up and disposing of PCBs shall do so based on the
concentration at which the PCBs are found.
Generation of PCB remediation waste as
defined in 40 C.F.R. § 761.3 - Applicable
40 C.F.R. §761.61
rrmponiry Sioniffc oj II d\lc\ I'rmiiiry ll'tislcs (t'.i;. iwtiiviilcd cnnhiniiiiiilcd soil iind dchns)
and Secondary II titles (c ^ . wiisicniilcis. ciinltiiniiiiilcd i,i/iiii'iiii,nl. iind l'1'i.)
Temporary on-site
accumulation of
hazardous waste in
containers
A small quantity generator may accumulate hazardous waste on site
without a permit or interim status, and without complying with the
requirements of parts 124, 264 through 267, and 270 of this chapter, or
the notification requirements of section 3010 of RCRA, provided that all
the substantive conditions for exemption listed in this section are met.
Accumulation of RCRA hazardous waste
on site as defined in 40 C.F.R. § 260.10 -
Applicable
40 C.F.R. § 262.16(a)
GA Rule 391 -3-11 -.08
Condition of containers
If a container holding hazardous waste is not in good condition, or if it
begins to leak, the small quantity generator must immediately transfer the
hazardous waste from this container to a container that is in good
condition, or immediately manage the waste in some other way that
complies with the conditions for exemption of this section.
40 C.F.R. §262.16(b)(2)(i)
GA Rule 391 -3-11 -.08
Compatibility of waste
with container
Must use a container made of or lined with materials that will not react
with, and are otherwise compatible with, the hazardous waste to be
accumulated, so that the ability of the container to contain the waste is not
impaired.
40 C.F.R. § 262.16(b)(2)(h)
GA Rule 391 -3-11 -.08
Management of
containers
(A) A container holding hazardous waste must always be closed during
accumulation, except when it is necessary to add or remove waste.
(B) A container holding hazardous waste must not be opened, handled, or
accumulated in a manner that may rupture the container or cause it to
leak.
40 C.F.R. § 262.16(b)(2)(iii)
GA Rule 391 -3-11 -.08
Special conditions for
accumulation of
incompatible wastes
(A) Incompatible wastes, or incompatible wastes and materials, (see
appendix V of part 265 for examples) must not be placed in the same
container, unless § 265.17(b) of this chapter is complied with.
(B) Hazardous waste must not be placed in an unwashed container that
previously held an incompatible waste or material (see appendix V of part
265 for examples), unless § 265.17(b) of this chapter is complied with.
(C) A container accumulating hazardous waste that is incompatible with
any waste or other materials accumulated or stored nearby in other
containers, piles, open tanks, or surface impoundments must be separated
Accumulation of incompatible wastes, or
incompatible wastes and materials on site -
Applicable
40 C.F.R. §262.16(b)(2)(v)
GA Rule 391 -3-11 -.08
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from the other materials or protected from them by means of a dike,
berm, wall, or other device.
Labeling and marking
of containers
A small quantity generator must mark or label its containers with the
following:
(A) The words "Hazardous Waste";
(B) An indication of the hazards of the contents (examples include,
but are not limited to, the applicable hazardous waste
characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard
communication consistent with the Department of Transportation
requirements at 49 C.F.R. part 172 subpart E (labeling) or subpart F
(placarding); a hazard statement or pictogram consistent with the
Occupational Safety and Health Administration Hazard
Communication Standard at 29 C.F.R. § 1910.1200; or a chemical
hazard label consistent with the National Fire Protection Association
code 704); and
(C) The date upon which each period of accumulation begins clearly
visible for inspection on each container.
Accumulation of RCRA hazardous waste
on site as defined in 40 C.F.R. §260.10 -
Applicable
40 C.F.R. §262.16(b)(6)(i)
GA Rule 391 -3-11 -.08
Condition of container
If a container holding hazardous waste is not in good condition, or if it
begins to leak, the owner or operator must transfer the hazardous waste
from this container to a container that is in good condition, or manage the
waste in some other way that complies with the requirements of this part.
Storage of RCRA hazardous waste in
containers Applicable
40 C.F.R. §265.171
GA Rule 391-3-11-.10
Compatibility of waste
with container
Must use a container made of or lined with materials which will not react
with, and are otherwise compatible with, the hazardous waste to be
stored, so that the ability of the container to contain the waste is not
impaired.
40 C.F.R. §265.172
GA Rule 391-3-11-.10
Containers must always be closed during storage, except when necessary
to add or remove waste.
Container must not be opened, handled, or stored in a manner which may
rupture the container or cause it to leak.
40 C.F.R. § 265.173(a) and
(b)
GA Rule 391-3-11-.10
Storage of hazardous
waste in container area
Area must have a containment system designed and operated in
accordance with 40 C.F.R. 264.175(b).
Storage of RCRA hazardous waste in
containers with free liquids - Applicable
40 C.F.R. § 264.175(a)
GA Rule 391-3-11-.10
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Area must be sloped or otherwise designed and operated to drain liquid
from precipitation, or
Containers must be elevated or otherwise protected from contact with
accumulated liquid.
Storage of RCRA hazardous waste in
containers that do not contain free liquids
(other than F020, F021, F022, F023, F026
and F027) - Applicable
40 C.F.R. § 264.175(c)(1)
and (2)
GA Rule 391-3-11-. 10
Closure performance
standard for RCRA
container storage unit
Must close the facility (e.g., container storage unit) in a manner that:
• Minimizes the need for further maintenance;
• Controls minimizes or eliminates to the extent necessary to
protect human health and the environment, post-closure escape
of hazardous waste, hazardous constituents, leachate,
contaminated run -off, or hazardous waste decomposition
products to the ground or surface waters or the atmosphere; and
• Complies with the closure requirements of subpart, but not
limited to, the requirements of 40 C.F.R. 264.178 for
containers.
Storage of RCRA hazardous waste in
containers - Applicable
40 C.F.R. §264.111
GA Rule 391-3-11-. 10
Closure of RCRA
container storage unit
At closure, all hazardous waste and hazardous waste residues must be
removed from the containment system. Remaining containers, liners,
bases, and soils containing or contaminated with hazardous waste and
hazardous waste residues must be decontaminated or removed.
[Comment: At closure, as throughout the operating period, unless the
owner or operator can demonstrate in accordance with 40 C.F.R. 261.3(d)
of this chapter that the solid waste removed from the containment system
is not a hazardous waste, the owner or operator becomes a generator of
hazardous waste and must manage it in accordance with all applicable
requirements of parts 262 through 266 of this chapter].
Storage of RCRA hazardous waste in
containers in a unit with a containment
system - Applicable
40 C.F.R. §264.178
GA Rule 391-3-11-. 10
Temporary storage of
PCB waste (e.g., soil
and PPE) in a
container(s)
Container(s) shall be marked as illustrated in 40 CFR 761.45(a).
Storage of PCBs and PCB Items at
concentrations > 50 ppm for disposal -
Applicable
40 C.F.R. § 761.40(a)(1)
Storage area must be properly marked as required by 40 CFR
761.40(a)(10).
40 C.F.R. § 761.65(c)(3)
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Any leaking PCB Items and their contents shall be transferred
immediately to a properly marked non-leaking container(s).
40 C.F.R. § 761.65(c)(5)
Container(s) shall be in accordance with requirements set forth in DOT
HMR at 49 CFR 171-180.
40 C.F.R. § 761.65(c)(6)
Storage of PCB waste
in a RCRA-regulated
container storage area
Does not have to meet storage unit requirements in 40 CFR 761.65(b)(1)
provided unit:
• is permitted by EPA under RCRA §3004, or
• qualifies for interim status under RCRA §3005; or
• is permitted by an authorized state under RCRA §3006 and,
• PCB spills cleaned up in accordance with Subpart G of 40 CFR
761.
Storage of PCBs and PCB Items designated
for disposal - Applicable
Temporary storage of
bulk PCB remediation
waste or PCB bulk
product waste in a
waste pile
Waste must be placed in a pile that:
• is designed and operated to control dispersal by wind, where
necessary, by means other than wetting;
• does not generate leachate through decomposition or other
reactions.
Storage of PCB remediation waste or PCB
bulk product waste at cleanup site or site of
generation for up to 180 days - Applicable
40 C.F.R. § 761.65(c)(9)(i)
and (ii)
Waste pile liner
performance
The storage site must have a liner designed, constructed, and installed to
prevent any migration of wastes off or through liner into adjacent
subsurface soil, groundwater or surface water at any time during active
life (including closure period) of the storage site.
40 C.F.R. §
761.65(c)(9)(iii)(A)
Construction of storage
pile liner
Liner must be:
• constructed of materials that have appropriate chemical
properties and sufficient strength and thickness to prevent
failure because of pressure gradients, physical contact with
waste or leachate to which they are exposed, climatic
conditions, the stress of installation, and the stress of daily
operation;
• placed on foundation or base capable of providing support to
liner and resistance to pressure gradients above and below the
40 C.F.R. §
761.65(c)(9)(iii)(A)(l)-(3)
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liner to present failure because of settlement compression or
uplift;
• installed to cover all surrounding earth likely to be in contact
with waste.
Construction of storage
pile cover
The storage site must have a cover that:
• meets the requirements of 40 C.F.R. 761.65(c)(9)(iii)(A);
• is installed to cover all of the stored waste likely to be contacted
by precipitation; and
• is secured so as not to be functionally disabled by winds
expected under normal weather conditions; and
Storage of PCB remediation waste or PCB
bulk product waste at cleanup site or site of
generation for up to 180 days - Applicable
40 C.F.R. §
761.65(c)(9)(iii)(B)
Construction of storage
pile run-on control
system
The storage site must have a run-on control system designed, constructed,
operated and maintained such that it:
• prevents flow on the stored waste during peak discharge from at
least a 25-year storm;
• collects and controls at least the water volume resulting from a
24-hour, 25-year storm. Collection and holding facilities (e.g.,
tanks or basins) must be emptied or otherwise managed
expeditiously after storms to maintain design capacity of the
system.
40 C.F.R. §
761.65(c)(9)(iii)(C)( 1) and
(2)
Modification of waste
pile requirements
Requirements of 40 C.F.R. 761.65(c)(9) may be modified under the risk-
based disposal option of 40 C.F.R. 761.61(c).
40 C.F.R. § 761.65(c)(9)(iv)
II lisle treatment and Disposal I'rimary II astes (e.^.. excavated contaminated soil and debris)
iiikI Secondary H ash* fetf.. wastewater. contaminated equipment. I'I'lj
Disposal of RCRA-
hazardous waste in a
land-based unit
May be land disposed if it meets the requirements in the table "Treatment
Standards for Hazardous Waste" at 40 C.F.R. 268.40 before land
disposal.
Land disposal, as defined in 40 C.F.R.
268.2, of restricted RCRA waste -
Applicable
40 C.F.R. 268.40(a)
GA Rule 391-3-11-. 16
Must be treated according to the alternative treatment standards of 40
C.F.R. 268.49(c) or
Land disposal, as defined in 40 C.F.R.
268.2, of restricted hazardous soils -
Applicable
40 C.F.R. 268.49(b)
GA Rule 391-3-11-. 16
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Must be treated according to the UTSs [specified in 40 C.F.R. 268.48
Table UTS] applicable to the listed and/or characteristic waste
contaminating the soil prior to land disposal.
All underlying hazardous constituents [as defined in 40 C.F.R. § 268.2(i)]
must meet the Universal Treatment Standards, found in 40 C.F.R. §
268.48 Table UTS prior to land disposal
Land disposal of restricted RCRA
characteristic wastes (D001-D043) that are
not managed in a wastewater treatment
system that is regulated under the CWA,
that is CWA equivalent, or that is injected
into a Class I nonhazardous injection well
— Applicable
40 C.F.R. § 268.40(e)
GA Rule 391-3-11-. 16
Disposal of RCRA-
hazardous waste soil in
a land-based unit
To determine whether a hazardous waste identified in this section exceeds
the applicable treatment standards of 40 C.F.R. § 268.40, the initial
generator must test a sample of the waste extract or the entire waste,
depending on whether the treatment standards are expressed as
concentration in the waste extract or waste, or the generator may use
knowledge of the waste. If the waste contains constituents (including
UHCs in the characteristic wastes) in excess of the applicable UTS levels
in 40 C.F.R. § 268.48, the waste is prohibited from land disposal, and all
requirements of part 268 are applicable, except as otherwise specified.
Land disposal of RCRA toxicity
characteristic wastes (D004-D011) that are
newly identified (i.e., wastes, soil, or debris
identified by the TCLP but not the
Extraction Procedure) — Applicable
40 C.F.R. § 268.34(f)
GA Rule 391-3-11-. 16
Treatment of RCRA
hazardous waste soil
Prior to land disposal, all "constituents subject to treatment" as defined in
40 C.F.R. § 268.49(d) must be treated as follows:
• For non-metals (except carbon disulfide, cyclohexanone, and
methanol), treatment must achieve a 90 percent reduction in total
constituent concentrations, except as provided in 40 C.F.R. §
268.49(c)(1)(C)
• For metals and carbon disulfide, cyclohexanone, and methanol,
treatment must achieve a 90 percent reduction in total constituent
concentrations as measured in leachate from the treated media
(tested according to TCLP) or 90 percent reduction in total
constituent concentrations (when a metal removal technology is
used), except as provided in 40 C.F.R. § 268.49(c)(1)(C)
• When treatment of any constituent subject to treatment to a 90
percent reduction standard would result in a concentration less than
10 times the Universal Treatment Standard for that constituent,
treatment to achieve constituent concentrations less than 10 times
the universal treatment standard is not required. Universal Treatment
Treatment of restricted hazardous waste
soils - Applicable
40 C.F.R. § 268.49(c)(1)(A)-
(C)
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Standards are identified in 40 C.F.R. § 268.48 Table UTS.
In addition to the treatment requirement required by paragraph (c)(1) of
this section, prior to land disposal, soils must be treated to eliminate these
characteristics.
Soils that exhibit the characteristic of
ignitability, corrosivity or reactivity
intended for land disposal - Applicable
40 C.F.R. § 268.49(c)(2)
GA Rule 391-3-11-.16
Provides methods on how to demonstrate compliance with the alternative
treatment standards for contaminated soils that will be land disposed.
On-site treatment of restricted hazardous
waste soils following alternative soil
treatment of 40 C.F.R. 268.49(c) - TBC
Guidance on Demonstrating
Compliance with the LDR
Alternative Soil Treatment
Standards [EPA 530 -R -02
-003, July 2002]
Constituents subject to
treatment
When applying the soil treatment standards in paragraph (c) of this
section, constituents subject to treatment are any constituents listed in §
268.48 Table UTS-Universal Treatment Standards that are reasonably
expected to be present in any given volume of contaminated soil, except
fluoride, selenium, sulfides, vanadium, zinc, and that are present at
concentrations greater than 10 times the universal treatment standard.
PCBs are not constituents subject to treatment in any given volume of soil
that exhibits the toxicity characteristic solely because of presence of
metals.
40 C.F.R. § 268.49(d)
GA Rule 391-3-11-.16
Disposal of PCB
decontamination waste
and residues
Shall be disposed of in accordance with provisions for wastes from
cleanup of PCB remediation waste at 40 C.F.R. 761.61(a)(5)(v).
Non-liquid cleaning materials and PPE at
any concentration PCBs, including non-
porous surfaces and other non-liquid
materials (e.g., rags, gloves, booties)
resulting from decontamination -
Applicable
40 C.F.R. 761.79(g)(6)
Disposal of PCB bulk
product waste (e.g.,
building demolition
debris) in solid waste
landfill
May dispose of in a facility permitted, licensed, or registered by a State as
a municipal solid waste or non-municipal non-hazardous waste landfill.
Includes Plastics (such as plastic insulation from wire or cable; radio,
television and computer casings; vehicle parts; or furniture laminates);
preformed or molded rubber parts and components; applied dried paints,
varnishes, waxes or other similar coatings or sealants; caulking;
PCB bulk product waste listed in 40 C.F.R.
761.62(b)(l)(i) including non-liquid
building debris - Applicable
40 C.F.R. 761.62(b)(1)
96
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Galbestos; non-liquid building demolition debris; or non-liquid PCB bulk
product waste from the shredding of automobiles or household appliances
from which PCB small capacitors have been removed (shredder fluff).
Disposal of bulk PCB
remediation waste off-
site
(.self-implementing
option)
May be sent off-site for decontamination or disposal provided the waste
is either dewatered on-site or transported off-site in containers meeting
the requirements of DOT HMR at 49 C.F.R. parts 171-180.
Generation of bulk PCB remediation waste
(as defined in 40 C.F.R. 761.3) for disposal
- Relevant and Appropriate
40 C.F.R. 761.61(a)(5)(i)(B)
Must provide written notice including the quantity to be shipped and
highest concentration of PCBs [using extraction EPA Method
3500B/3540C or Method 3500B/3550B followed by chemical analysis
using Method 8082 in SW-846 or methods validated under 40 C.F.R.
761.320-26 (Subpart Q)] at least 15 days before the first shipment of
waste to each off-site facility
Generation of bulk PCB remediation waste
(as defined in 40 C.F.R. 761.3) for disposal
at an off-site facility where the waste is
destined for an area not subject to a TSCA
PCB Disposal Approval - Relevant and
Appropriate
40 C.F.R.
761.61 (a)(5)(i)(B)(2)(iv)
Shall be disposed of in accordance with the provisions for cleanup wastes
at 40 C.F.R. 761.61(a)(5)(v)(A).
Bulk PCB remediation waste which has
been de-watered and with a PCB
concentration < 50 ppm - Relevant and
Appropriate
40 C.F.R. §
761.61 (a)(5)(i)(B)(2)(ii)
Shall be disposed of:
• in a hazardous waste landfill permitted by EPA under §3004 of
RCRA;
• in a hazardous waste landfill permitted by a State authorized
under §3006 of RCRA; or
• in a PCB disposal facility approved under 40 C.F.R. 761.60.
Bulk PCB remediation waste which has
been de-watered and with a PCB
concentration > 50 ppm - Relevant and
Appropriate
40 C.F.R.
761.61(a)(5)(i)(B)(2)(zzz)
Performance-based
disposal of PCB
remediation waste
Shall dispose by one of the following methods:
• in a high-temperature incinerator approved under 40 C.F.R.
761.70(b);
• by an alternate disposal method approved under 40 C.F.R.
761.60(e);
• in a chemical waste landfill approved under 40 C.F.R. 761.75;
Disposal of non-liquid PCB remediation
waste (as defined in 40 C.F.R. 761.3) -
Applicable
40 C.F.R. § 761.61(b)(2)
40 C.F.R. §761.61(b)(2)(i)
97
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Record of Decision
July 2024
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• in a facility with a coordinated approval issued under 40 C.F.R.
761.77; or
• through decontamination in accordance with 40 C.F.R. 761.79.
40 C.F.R. §761.61(b)(2)(ii)
Disposal of PCB
cleanup wastes (e.g.,
PPE, rags, non-liquid
cleaning materials)
(self- implementing
option)
Shall be disposed of either:
• in a facility permitted, licensed or registered by a State to
manage municipal solid waste under 40 C.F.R. 258 or non-
municipal, non-hazardous waste subject to 40 C.F.R. 257.5 thru
257.30; or
• in a RCRA Subtitle C landfill permitted by a State to accept
PCB waste; or
• in an approved PCB disposal facility; or
• through decontamination under 40 C.F.R. 761.79(b) or (c).
Generation of non-liquid PCBs at any
concentration during and from the cleanup
of PCB remediation waste - Applicable
40 C.F.R. §
761.61 (a)(5)(v)(A)( 1 )-(4)
Performance-based
disposal of PCB bulk
product waste
May dispose of by one of the following:
• in an incinerator approved under 40 C.F.R. 761.70;
• in a chemical waste landfill approved under 40 C.F.R. 761.75;
• in a hazardous waste landfill permitted by EPA under §3004 of
RCRA or by authorized state under §3006 of RCRA;
• under alternate disposal approved under 40 C.F.R. 761.60(e);
• in accordance with decontamination provisions of 40 C.F.R.
761.79; or
• in accordance with thermal decontamination provisions of 40
C.F.R. 761.79(c)(6) for metal surfaces in contact with PCBs.
Disposal of PCB bulk product waste as
defined in 40 C.F.R. 761.3 - Applicable
40 C.F.R. 761.62(a)
40 C.F.R. 761.62(a)(l)-(6)
1'ritiispnrhilioii <>J ll'ti\lc\ iiml Siimplcs
Transportation of
hazardous waste on-
site
The generator manifesting requirements of 40 C.F.R. 262.20-262.32(b)
do not apply. Generator or transporter must comply with the requirements
set forth in 40 C.F.R. 263.30 and 263.31 in the event of a discharge of
hazardous waste on a private or public right-of-way.
Transportation of hazardous wastes on a
public or private right-of-way within or
along the border of contiguous property
under the control of the same person, even
if such contiguous property is divided by a
public or private right-of-way - Applicable
40 C.F.R. § 262.20(f)
GA Rule 391-3-11-.08
98
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
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Transportation of
hazardous waste off-
site
Must comply with the generator requirements of
40 C.F.R. 262.20-23 for manifesting, Sect. 262.30 for packaging, Sect.
262.31 for labeling, Sect. 262.32 for marking, Sect. 262.33 for
placarding, Sect. 262.40, 262.41(a) for record keeping requirements, and
Sect. 262.12 to obtain EPA ID number.
Preparation and initiation of shipment of
hazardous waste off site - Applicable
40 C.F.R. § 262.10(h)
GA Rule 391-3-11-.08
Must comply with the requirements of 40 C.F.R. 263.11-263.31.
A transporter who meets all applicable requirements of 49 C.F.R. 171-
179 and the requirements of 40 C.F.R. 263.11 and 263.31 will be deemed
in compliance with 40 C.F.R. 263.
Transportation of hazardous waste within
the United States requiring a manifest -
Applicable
40 C.F.R. § 263.10(a)
GA Rule 391-3-11-.09
Transportation of
hazardous materials
Shall be subject to and must comply with all applicable provisions of the
HMTA and DOT F1MR at 49 C.F.R. 171-180 related to marking,
labeling, placarding, packaging, emergency response, etc.
In addition to any specific requirements set forth in GA Rule 672-10, all
hazardous materials shall be packaged, marked, labeled, handled, loaded,
unloaded, stored, detained, transported, placarded, and monitored in
compliance with 49 C.F.R..
Any person who, under contract with a
department or agency of the federal
government, transports "in commerce," or
causes to be transported or shipped, a
hazardous material — Applicable
49 C.F.R. § 171.1(c)
GA Rule 672-10
Transportation of
samples (i.e.,
contaminated soils and
wastewaters)
Are not subject to any requirements of 40 C.F.R. Parts 261 through 268
or 270 when:
• the sample is being transported to a laboratory for the purpose
of testing; or
• the sample is being transported back to the sample collector
after testing.
• the sample is being stored by sample collector before transport
to a lab for testing
Samples of solid waste or a sample of
water, soil for purpose of conducting
testing to determine its characteristics or
composition - Applicable
40 C.F.R. §261.4(d)(l)(i)-
(iii)
GA Rule 391-3-11-.07
In order to qualify for the exemption in paragraphs (d)(l)(i) and (ii), a
sample collector shipping samples to a laboratory must:
• Comply with U.S. DOT, U.S. Postal Service, or any other
applicable shipping requirements
• Assure that the information provided in (1) thru (5) of this
section accompanies the sample.
• Package the sample so that it does not leak, spill, or vaporize
from its packaging.
Samples of solid waste or a sample of
water, soil for purpose of conducting
testing to determine its characteristics or
composition - Applicable
40 C.F.R. §261.4(d)(2)(i)(A)
and (B)
GA Rule 391-3-11-.07
99
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Armstrong World Industries, Macon-Bibb County, Georgia, 0U1 and OU2
Record of Decision
July 2024
ACTION-SIM t il IC AKAKs I I5(
Aclinn
Kc(|iiiiviiU'iilN
I'mviiiiKiU'
Ciluliiui
Transportation and
handling of solid waste
No person shall engage in solid waste or special solid waste handling in
Georgia or construct or operate a solid waste handling facility in Georgia,
except those individuals exempted from this part under Code Section 12-
8-30.10, without first obtaining a permit from the director authorizing
such activity.
Management of solid waste in Georgia -
Applicable
Georgia Solid Waste
Management Act of 1990
O.C.G.A. § 12-8-24
Transportation of PCB
wastes off-site
Must comply with the manifesting provisions at 40 C.F.R. 761.207
through 218.
Relinquishment of control over PCB wastes
by transporting, or offering for transport -
Applicable
40 C.F.R. § 761.207(a)
ARAR = Applicable or Relevant and Appropriate Requirement
C.F.R. = Code of Federal Regulations
CWA = Clean Water Act of 1972
DOT = U.S. Department of Transportation
EPA = U.S. Environmental Protection Agency
EPD = Georgia Environmental Protection Division of the Georgia Department of Natural Resources
HMR = Hazardous Materials Regulations
HMTA = Hazardous Materials Transportation Act
GA Rule = Rules and Regulations, Section as noted
LDR = Land Disposal Restrictions
O.C.G.A. = Official Code of Georgia Annotated, Chapter as noted
PCB = polychlorinated biphenyl
RCRA = Resource Conservation and Recovery Act of 1976
TBC = to be considered
TCLP = Toxicity Characteristic Leaching Procedure
U.S. = United States
UTS = Universal Treatment Standard
100
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
FIGURES
101
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
|OU1
OU2
MNOP
SU-7
Ephemeral - Ditch FMNOl
Perennial - Ditch [ ] Remote Landfill
Perennial • Tributary Explosives Demo Area
Site Location
Figure 1: Site Location and Features6
6 Source: Figure 1-1 of the Site's 2023 OU-2 Rl Report, with modifications.
102
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
ou2 fmnol Ephemeral - Ditch Land Ownership in OU2
Parcels I | Remote Landfill Perennial - Ditch
1 1 ^ MONTROSE
Exp losives Dem o Area Peren n ial - Tri butary
Figure 2: OU2 Land Ownership7
7 Source: Figure A-l of the Site's 2023 OU-2 Rl Report.
103
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
OU2 Explosives Demo Area Ephemeral - Ditch ISM Soil Characterization
AIP FMNOL Perennial - Ditch
MONTROSE
I I Remote Landfill - - Perennial - Tributary
Figure 3: Soil Sampling Units8
8 Source: Figure 5-1 of the Site's 2023 OU-2 R! Report. Excludes the off-site, background SU. The "SO" designation in each SU refers to soil.
104
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
I'RIMUO
MiiRi y
F'RIM\k%
KM VASh SK( OMIAKY
MECHANISM Mil Kl K
SKCOMWH
I'OIKYIHI. RECEPTORS
KKI.K\SK
TERTIARY
EAI'OSt RK
Si!t inipt'Ctir
TrL"t[wsM;r*. |
MECHANISM
SOIRCE
KIH It
(¦•uniiclwastT |—->
Rur>>tt
i
S. i r...
W .iL r
S^vfmwin
•"I Vn"j,lil,/^:ini( | ~*| \ir A , lo.Kb-1 j ~ *
1
1 &
_
»| lupu^v | - *
1
|
| «z» |
-
>n
—
Birvut 1"i if u
***>
—
In; u
CD>
i'r.'ii! - v Ki
G>
o
*Zb
fn» j >ii
«s>
lvir.'L» ki
sss
piIT| H M" 1 - I - i
Ia'ci'Iw!
<¦»
= i ,|MJ. Mj|b* tl\
©
= P<* thL ts« -o a 1 i J . Ji i .5 i'.cI.
«S5>
= P.^ihL ¦¦ iMivt i\ tn oa > .u. I ^ n~'j, :i'* J\ rt _r"1
C~5
= Pu™ibL. u» s. -ahii i niiujw\
—
- K r } Li*. rmru».s\
Figure 4; Human Health Conceptual Site Model9
9 Source: Figure 2 of Technical Memorandum #2, Exposure Assessment, Human Health Baseline Risk Assessment, March 2022.
105
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0U2 I D FMNOL
AIP ~ Remote Landfill
Explosives Demo Area —|—| Current Railroads
—I 1 Former Railroad
Ephemeral - Ditch Elevation (ft amsl)
- High : 344,322
Perennial - Ditch —
Perennial - Tributary L
LOW: 266.273
Figure 5: OU2 Topography
Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Site Setting
10 Source: Figure 3-1 of the Site's 2023 OU-2 Rl Report
106
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
PFOIAh,
PSS1A
PEM1F
PEM1F;
[PF01A]
Local Area Extent
senhower-Pkwy |
Macon
Famtly Goll
tarttey BncJgfl
Jiick
Sources: Esn, HERE. Qarmin, Inter map,
GeoBase, IGN, Kadaster NL, Ordnance ;
OpenStreetMap contributors, and, the Qj|
psri Japan?K^g",l,psr^c1
lornmunityir^faajBSJ
National Wetlands
Ephemeral - Ditch
Explosives Demo Area
Ml
Wetland Type Not Listed Below__
PF01/2F
PF01A
PF01C
Site Extent
Figure 6: Wetlands Inventory11
11 Source'. Figure 5-8a of the Site's 2023 OU-2 Rl Report,
107
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
•3uy Paine R=j
421 H
S^rrfy Qtf
1,500 aooo
M I
Feet
VVM IN"
Lak«~»
Sources: Esri. HrfERE, Garmin, Intermap, increment P Corp&GEBCO, USGS, FAO; NPSr NRCAN.
GeoBase, !GNT Kadaster NL Ordnance Survey. Esri Japan;-METlt Esri China (Hong Kong), (c)
OpenStreetMap contributors, and the G!S User Community
OU2
AIP
FMNOL
I Remote Landfill
Explosives Demo Area
Ephemeral - Ditch
Perennial - Ditch
Perennial - Tributary
Zone 1
Zone 2 ^
~ Zone 3 «
Zone 4
* Zone 5
»Zone 6
Zone 7
Fish Collection Zones
Figure 7: Fish Collection Zones12
12 Source: Figure 5-4 of the Site's 2023 OU-2 Rl Report.
108
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
N
Abandoned Concrete Culvert Low Lying Areas •
"Rocky Creek Outfall Sewer 50' R/W" (approx) ~ FMNOL
Topographic 1ft Contours from LiDAR
~
Remote Landfill
Current/H istorical Railroads
Ephemeral - Ditch
Perennial - Ditch
PCB Aroclors (mg/kg) O 10-100
O ND
® <1
G 1-10
Figure 8: PCB Concentrations in SU-7 Soils13
100-500
500-934
Nature and Extent:
PCBs in SU-7
13 Source: Figure 8-lc of the Site's 2023 OU-2 Rl Report.
Subsurface Soil (1.5-4 ft bgs)
Note: Larger circles beneath smaller circles represent a deeper
sampling depth.
T I
Surficial Soil (0.5 ft bgs)
Note: Triangles denote samples collected along centerline
of SU-7 drainage ditch.
SU-2-SO
SU-ARMREM-SO
SU-2-SO
SU-4-SO
SU-ARMREM-SO
SU-4-SO
SU-22-SO
109
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
PCB (mg/kg)
o <1
O 1-25
O 25-50
• 50-100
• 100 - 250
• 250 - 500
• 500 - 935
PCB Interpolation (mg/kg)
<1
1 - 25
25-50
50 -100
100 - 160
160- 215
~ 215 - 291
| 291 - 400
| 400 - 530
| 530 - 675
675 - 935
a
Area #1 SU-7 Action Area Option #1
SU7 Risk-Based Cleanup
Ephemeral - Ditch
Perennial - Ditch
Figure 9: Action Area Option #114
14 Source: Figure 7-1 of the Site's 2023 OU-2 FS Report.
110
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*] Action Area Option #2
PCB (mg/kg)
O <1
O 1-25
O 25-50
# 50-100
# 100-250
• 250 - 500
• 500 - 935
Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
r°S Action Area Option #2 SU"7 Action Area °Ption #2
" M su7 Risk-Based Targeted Removal Cleanup
Ephemeral - Ditch
Perennial - Ditch
Figure 10: Action Area Option #215
15 Source: Figure 7-2 of the Site's 2023 OU-2 FS Report
111
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Action Area Option #3
PCB (mg/kg)
o
< 1
o
1 -25
o
25-50
o
50-100
•
100-250
•
250 - 500
•
500 - 935
SU7
Ephemeral - Ditch
Perennial - Ditch
jl* " "j Action Area Option #3
SU-7 Action Area Option #3
25 mg/kg Action Level
Figure 11: Action Area Option #3
16
' Source: Figure 7-3 of the Site's 2023 OU-2 FS Report.
112
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
Waste M.=it?ral
Figure 12: Schematic of RA-LF-217
* G'
Wail? Moferip"
Figure 13: Schematic of RA-LF-318
17 Source: Section 8.3.3 of the Site's 2023 OU-2 FS Report.
18 Source: Section 8.3.4 of the Site's 2023 OU-2 FS Report.
113
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
N
soil Removal to 1 ft-bgs su7 Depiction of RA-SU7-6
Soil Removal to 2 ft-bgs Ephemeral - Ditch
Perennial - Ditch
Figure 14: RA-SU7-619
19 Source: Figure 8-5 of the Site's 2023 OU-2 FS Report.
PCB (mg/kg)
o
<1
o
1 -25
G
25-50
•
50-100
•
100-250
•
250 - 500
•
500 - 935
Squares denote samples collected between 0.5 and 2 ft-bgs.
All samples collected below 2 ft-bgs were < 1 mg/kg.
114
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
APPENDIX A
State of Georgia Concurrence
A-l
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GEORGIA
Jeffrey W. Cown, Director
EPD Director's Office
2 Martin Luther King, Jr. Drive
Department of Natural Resources
Suite 1456, East Tower
Atlanta, Georgia 30334
404-656-4713
Environmental Protection Division
July 26, 2024
Ms. Caroline Freeman
Director, Superfund and Emergency Management Division
US Environmental Protection Agency, Region 4
Atlanta Federal Center
61 Forsyth Street SW
Mail Code: 9T25
Atlanta, Georgia 30303-8960
Dear Ms. Freeman:
The Georgia Environmental Protection Division (EPD) has reviewed the July 2024 Record of Decision
(ROD) for Operable Units (OU) 1 and 2 at the Armstrong World Industries National Priorities List (NPL)
Site in Macon, which documents the work conducted thus far and the selected remedy to clean up the OUs
at the Site. The major components of the selected remedies documented in the ROD include the following:
For OU1 (Wastewater Treatment Plant Landfill):
• Establishment of institutional controls (ICs) at OU 1 to prohibit residential land use, use of
groundwater, the installation of groundwater wells, and prohibit future use that would
disturb the selected remedy. This OU was part of a non-time critical removal action in
2016 that included capping the landfill, installing an earthen barrier wall and replacing a
drainage swale.
For OU2 (AWI Remote Landfill and Former Macon Naval Ordnance Plant Landfill):
For Sampling Unit #7 (SU-7):
• Excavation of soils to 1 foot below ground surface across the full lateral extent of areas
where soil sampling results found PCB concentrations greater than 25 parts per
million(ppm), and excavation to 2 feet below ground surface where PCB concentrations
exceeded 25 ppm at depths below 1 foot below ground surface;
• Characterization, profiling, temporary storage/staging, and transportation and off-site
disposal at a TSCA-approved facility of the excavated PCB-containing soils;
• Restoration of excavation area with clean, imported backfill; and
• Establishment of ICs to prevent exposure and protect the remedy.
o Removal of protruding waste materials and large surface debris;
o Repair/replacement of the existing soil cover, while conserving current ecologically
diverse land cover, especially large trees, to the extent possible;
Re: Record of Decision
Armstrong World Industries
Operable Units 1 and 2
Macon, GA
For the landfills:
-------
Ms. Freeman
US EPA Region 4
July 26, 2024
Page 2
o Revegetat ion of disturbed areas;
o Rock armoring the downgradient portion of the landfill to prevent erosion of the waste
materials;
o Installation of a fence around the contiguous landfills to protect the replaced soil cover;
o Establishment of ICs to prevent exposure and protect the remedy; and
o Long-term operation and maintenance to maintain integrity of the soil cover and perimeter
fencing and signage.
The above remedy was selected due to its protection of human health and the environment, cost, and overall
implementability. This letter confirms that EPD concurs with the above selected remedies for OU1 and
OU2 at Armstrong World Industries NPL Site. EPD appreciates EPA working so closely with us since site
discovery, and throughout the Remedial Investigation, Feasibility Study, Proposed Plan and ROD. If you
have any questions, please contact Amy Potter at 470-524-0565.
Sincerely,
Jeffrey W. Cown
Director
C: Peter Johnson, EPA
File: AWI (B)
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
APPENDIX B
MAY 30,2024, PUBLIC MEETING TRANSCRIPT
B-l
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
1 BEFORE THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
2
3 ARMSTRONG WORLD INDUSTRIES
OPERABLE UNITS 1 & 2
4 PROPOSED PLAN FOR REMEDIAL ACTION
5 Macon, Macon-Bibb County, Georgia
6
7 PUBLIC HEARING
8
9 WHEREUPON, the following proceedings
10 were transcribed by Suzanne Lee, Certified Court
11 Reporter No. 476 and Notary Public for the State of
12 Alabama at Large, with all participants appearing
13 remotely, on May 30, 2024, commencing at
14 approximately 5:04 p.m.
15
16
]_7 *************
18
19
20
21
22
23
www.huseby.com
Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Page 2
1
APPEARANCES
2
FOR THE EPA:
3
Ron Tolliver. . .
Community Involvement Coordinator
4
Brian Farrier . .
Project Manager
5
Anita Saha. . . .
Project Manager
6
Peter Johnson . .
Project Manager
7
Zariah Lewis. . .
Staff
8
9
SUPPORT PERSONNEL:
10
Tahsin Zahid. . .
Georgia Environmental
11
Protection Division
12
Faith Flack-Walker
Georgia Department of
Public Health
13
Franklin Sanchez,
Georgia Department of
14
Public Health
15
16
17
18
19
20
21
22
23
www.huseby.com
Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Page 3
1 TABLE OF CONTENTS
2 PAGE
3 Title Page 1
4 Appearances Page 2
5 Table of Contents 3
6
7 PRESENTATIONS:
8 By Anita Saha 11
9 By Peter Johnson 14
10
11 COMMENTS PRESENTED:
12 By Carrie Redmond 25
13 By Carrie Redmond's daughter 28
14
15 Certificate Page 40
16
17
18
19
20
21
22
23
www.huseby.com
Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Page 4
1 MR. TOLLIVER: All right. So we're going
2 to go ahead and get started. So welcome. My name
3 is Ron Tolliver. I am the community involvement
4 coordinator for the site. And we're going to --
5 tonight we're going to have a public meeting, and
6 we're going to talk about the Armstrong World
7 Industries Operable Units 1 and 2 proposed plan for
8 remedial action. The site is located in Macon,
9 Georgia.
10 All right. We're going to get started.
11 Next slide.
12 All right. So we'll start off with
13 introductions, and then we'll have the presentation,
14 and then following the presentation, we'll also have
15 the question and answer session.
16 All right. So, after I introduce these
17 organizations that are in support of our current and
18 future cleanup work at the site, we will go through
19 the presentation and then our question and answer
20 session.
21 Next slide.
22 So these are our site contacts. So these
23 are the support personnel for the site. EPA is a
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1 lead agency, and we oversee the potentially
2 responsible parties' role in this cleanup. Our
3 project managers for EPA are in an oversight role
4 during this cleanup. And I will -- my -- of course,
5 I'm Ron Tolliver, your community involvement
6 coordinator, and then your remedial project managers
7 are Brian Farrier -- if you want to come on camera,
8 Brian -- Anita Saha, and Peter Johnson. All right,
9 they're waving.
10 Okay. And then we also have our support
11 personnel as well from the state of Georgia, Tahsin
12 Zahid, and then also from the Georgia Department of
13 Public Health, Faith Flack-Walker and Franklin
14 Sanchez.
15 So if there are any other organizations
16 that are present tonight and would like -- and would
17 like to be acknowledged, you can do so at this time.
18 You can put your information in the chat. We can
19 acknowledge you at this time, or if you'd like to
2 0 say a word.
21 Okay. All right. So we'll get started.
22 All right. Now, just let's go over a few
23 of our meeting instructions. I do want to make sure
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1 that everyone can access the meeting and can have a
2 viewing -- have their proper viewing of this
3 meeting. So those of you who are on the phone, if
4 you are to press star 6, if you're -- if you're
5 calling on the phone, you press star 6 to mute and
6 unmute, star 9 as well to raise your hand.
7 So we're going to utilize the
8 raise-your-hand function. There's an icon tray at
9 the bottom of your screen, so those of you who
10 have -- may not have used Zoom before, there's an
11 icon tray -- when you hover your mouse over the
12 bottom of the screen, there should be an icon tray.
13 And then you should be able to select the
14 raise-your-hand function, and we will acknowledge
15 you at -- during the Q&A session.
16 Okay. And there's also for audio, there's
17 a "join audio," so once you come on to the -- join
18 the meeting, you need to make sure that your
19 audio -- you join the audio and connect with the
2 0 meeting through your speakers.
21 We also have closed captioning that's
22 available for those of you who need closed
23 captioning. That icon is in the tray as well. And
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1 then the Q&A session we will have --we will
2 facilitate that towards the end.
3 So, during the Q&A session, our EPA
4 personnel will acknowledge those questions and
5 comments that are in the chat. And through the --
6 and then also through the use of the raise-your-hand
7 function. We ask that you-all stay muted, until it
8 is your turn to be acknowledged, and then you can
9 unmute yourself if you would like to fo- -- a
10 follow-up question or a comment during that portion.
11 We will go in order from which the hands were
12 raised, and we'll go in that order.
13 All right. And then we also have a
14 transcriptionist that will be capturing all of your
15 questions and comments during the -- this meeting.
16 So if you have a question or comment and you would
17 like for it to be addressed formally, okay, we ask
18 that you would state your name for the -- and spell
19 it for the transcriptionist to capture, or you can
2 0 make sure it's in the -- on your -- on your -- make
21 sure your name is on your ID and make sure it's
22 spelled correctly, so the transcriptionist can
23 capture that and that information. And then we'll
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1 respond formally to your comments with that
2 information. We'll respond formally.
3 So after questions and comments have been
4 acknowledged at the -- we'll end the meeting, and
5 the report from the transcriptionist will be used to
6 formally address any of your questions and comments
7 that were received during our comment period.
8 So, with that, let's talk about the
9 comment period, which is a very important part of
10 our meeting. So during the comment period, that
11 officially begins tonight. All right? And the
12 purpose of this comment period is to receive input
13 from you-all in the communities that have been
14 impacted by our cleanup plan. We would like to know
15 things from your perspective. All right? So.
16 So we'll formally -- like I said before,
17 we'll formally address those comments in our
18 decision- -- in our decision-making documents. One
19 of them is called the "Responsiveness Summary." All
20 right. And then together they'll be put together in
21 what we call an "administrative record." Once
22 everything has been finalized, this will -- these
23 documents will be available on our website, on
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1 Armstrong World Industries' Superfund site. All
2 right? And you may access this website at home or
3 in the information repository for the site, and that
4 repository is located here at the Middle Georgia
5 Regional Library. And that's at 180 Washington
6 Avenue in Macon, Georgia.
7 You'll have access to the Internet there
8 to obtain those documents. And so, if you have any
9 questions or concerns, you feel free to reach out to
10 me, and I can help you with that. All right?
11 And with that being said, we'll begin the
12 presentation. And then after the presentation,
13 again, we'll have the Q&A session where you can
14 answer your questions. And while the presentation
15 is going on, you may access the chat feature where
16 you can submit any comments or questions that you
17 have during the presentation, and we'll acknowledge
18 them during the Q&A session.
19 So let's begin the presentation.
2 0 As your community involvement coordinator,
21 one of my roles is to help you understand the
22 Superfund process. This process is required by a
23 law called "CERCLA." The slide shows those
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1 milestones associated with the Superfund
2 decision-making process.
3 Currently we're at the -- we're at the
4 proposed plan stage. This is highlighted red. The
5 proposed plan is a cleanup strategy that has been
6 developed after completing the previous milestones
7 on this slide. In 2019, responsible parties at this
8 site began the remedial investigation for Operable
9 Unit 2, after which the feasibility study was
10 finalized in late 2023.
11 A remedial investigation and feasibility
12 study is just a process that defines the nature and
13 the extent of contamination, while assessing risks
14 to human health and the environment. Now that a
15 cleanup remedy has been chosen, we're presenting it
16 to you for input before we finalize our decision.
17 After that, the responsible parties will
18 conduct the remedial design before doing the actual
19 cleanup themselves, or what we'll call the "remedial
20 action."
21 Again, tonight's meeting is for public
22 comment. Public comment is important for feedback
23 throughout this decision-making process.
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1
With that, I'll turn it over to EPA's
2 project managers Peter Johnson and Anita Saha.
3 They'll explain a little more detail about the
4 information that these proposed cleanup plan
5 remedies are based on.
6
Anita?
7
MS. SAHA: Thank you, Ron.
8
I'm Anita. I'm one of the EPA assigned
9 project manager for the site. As Ron mentioned,
10 proposed plan is an important milestone for the
11 Superfund process. EPA proposes cleanup options,
12 also known as "preferred remedies," during the
13 proposed plan phase.
14 This slide shows the important parts of
15 today's proposed plan. I will summarize you some of
16 these topics and explain to you how they relate to
17 you and the entire Superfund process. Let's begin.
18 Now . . . Now ... I am having a little
19 bit of technical issues. Let me --
2 0 MR. TOLLIVER: Let's see if we can --
21 okay.
22 MS. SAHA: Yeah. Let's start with the
23 history of the site.
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1 MR. TOLLIVER: There we go.
2 MS. SAHA: Since 1948 to present,
3 Armstrong World Industries site, or "AWI" for short,
4 manufactured ceiling tiles. AWI began disposing
5 general and industrial trash, old equipment, and
6 excess bark and scrap wood in the remote landfill in
7 the 1960s. Another landfill, the Former Macon Naval
8 Ordnance Landfill, or "FMNOL" for short, was used
9 for disposal of solid waste, munition, used parts,
10 and construction debris.
11 In 1977, Georgia Environmental Protection
12 Division closed both of these landfills and placed
13 soil covers. Another landfill, the Woodyard
14 Landfill, was addressed by Georgia EPD too by
15 putting a clay cap.
16 After these were -- were completed,
17 further evaluation were needed. Georgia EPD
18 determined that more resources were needed to
19 protect the human health and the environment, and
20 the site was listed for national priority listing in
21 2011.
22 After that, EPA capped Wastewater
23 Treatment Plant Landfill in 2016 and conducted some
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1 investigative studies. EPA found the contaminants
2 of concern at this site are PCB, polychlorinated
3 biphenyl, cadmium, copper, and lead.
4 Today, we are here to present what cleanup
5 options or preferred remedies are available for 0U2.
6 This site investigation and cleanup are paid by
7 several responsible parties.
8 Now I will explain how the cleanup at this
9 site are divided. At AWI, cleanup work has been
10 divided into two areas. These areas are called
11 "operable unit," or "OU" in short. OU1 is a
12 landfill. It has a barrier wall and an engineered
13 soil cover cap. EPA will also be placing
14 restriction for groundwater use, land use, and any
15 activity that may disturb the cap and the wall.
16 These kind of restriction are known as
17 "institutional control," or "IC."
18 Now we will talk about OU2, shown in the
19 yellow dashed border. This is the focus -- focus
20 for this proposed plan. OU2 includes two landfill,
21 explosive demolition area, Rocky Creek, and fish
22 sampling.
23 Now Peter will explain the OU2 site
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1 setting.
2
Off to you, Peter.
3
MR. JOHNSON: Thanks, Anita.
4
As Ron mentioned earlier, my name is Peter
5 Johnson, and I am one of the EPA remedial project
6 managers that work on this site.
8 we are addressing in this proposed plan. The lower
9 right image with the green dot shows the number and
10 sizes of the trees within the landfills and gives a
11 good sense of how heavily wooded this area really
12 is. Also, you can see from these photos, much of
13 OU2 is prone to frequent flooding and is located in
14 wetlands.
15 Now we will be describing the remedial
16 investigation portion of the presentation, which
17 includes sampling results, risks to human health and
18 the environment, and fish sampling. After a site is
19 listed on the National Priorities List, or the NPL,
20 a remedial investigation is performed at the site.
21 At this phase, EPA collects data to characterize
22 site conditions, assess risk to human health and the
23 environment, and evaluate the costs of treatment
7
Here's some photos of the second OU that
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1 technologies that are being considered.
2 During the remedial investigation, OU2 is
3 divided into 21 smaller areas known as "sampling
4 units" to efficiently address the contamination.
5 These sampling units, or SUs, are shown on the
6 figure here on the left, the primary concerns
7 reported at SU-7 and the landfills located on the
8 upper left portion of this figure. PCBs were
9 reported at the highest levels in soil at SU-7.
10 Just southwest of SU-7, a soil cover had been placed
11 atop the landfills in 1977, but much of this has
12 since eroded away.
13 During the remedial investigation, which
14 helps us identify the contaminants of concern, we
15 look at how these contaminants might pose a risk to
16 the public and the surrounding environment. Two
17 site-specific risk assessments were conducted for
18 AWI OU2, a human health risk assessment and an
19 ecological or an environmental risk assessment.
20 Anita and I will review these in the
21 upcoming slides.
22 Over to you, Anita.
2 3 MS. SAHA: Thank you, Peter.
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1 Now I will be explaining the results for
2 the risk assessment. Risk assessment results are
3 the driver for a site cleanup. The results for the
4 human health shows no current risk, but noncancer
5 risks are present for workers if the area is to
6 develop into a commercial space in the future.
7 Also, there is a risk for insect-eating birds from
8 the soil and sediments.
9 Now, we are going to talk about the fish
10 sampling data that were part of the remedial
11 investigation. Fish sampling at this area was first
12 conducted during 1996 to 1998 by the U.S. Army Corps
13 of Engineers. During that time, a limited amount of
14 fish were collected and sampled. Unacceptable
15 levels of polychlorinated biphenyl, or PCB, were
16 found in fish. So an extensive fish sampling was
17 conducted during this remedial investigation phase
18 from 2019 to 2020.
19 Two -- 357 fish were collected in three
20 areas shown in the slide. Upstream area shown in
21 yellow, site shown in green, downstream in pink.
22 Now the results show PCBs in fish have declined
23 significantly, approximately 80 percent since the
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1 limited fish sampling was conducted in the late
2 1990s.
3 EPA now advises that the public should
4 avoid only channel catfish and suckerfish from the
5 Rocky Creek downgradient to Houston Road because
6 these two bottom feeder fish had the highest level
7 of PCBs among all the fish sampled.
8 This is the agenda back again. We have
9 completed down to a remedial investigation portion.
10 Now Peter will be describing the feasibility study
11 portion and explaining the cleanup goals and the
12 preferred remedies for SU-7 and the landfills.
13 Off to you, Peter.
14 MR. JOHNSON: Hey, thanks, Anita.
15 This is Peter Johnson again, and I am now
16 going to review the remedial action objectives, or
17 RAOs, at OU2. RAOs are cleanup goals that provide a
18 general description of what a cleanup will
19 accomplish. The figure on the right here shows our
20 areas of focus for this proposed plan. SU-7 is in
21 pink, and the landfills are highlighted in blue and
22 green.
23 So let's now review the remedial
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1 alternatives for the SU-7 sampling unit shown here
2 in pink. So, before we discuss cleanup options, we
3 need to talk about the action areas. SU-7 was
4 divided into three portions, or action areas, based
5 on PCB soil cleanup concentrations. Action Area 3
6 on the right was preferred. Action Area 3 is the
7 biggest of the three action areas and will remove
8 all PCB contaminated soil greater than 25 parts per
9 million. This will lower the risk for insect-eating
10 birds and a future industrial worker.
11 So to better picture this, a part per
12 million is similar to putting one drop of water from
13 an eyedropper into 10 gallons of water. PCBs are
14 reported in SU-7 at concentrations over 900 parts
15 per million, and this cleanup will remove PCBs in
16 soil at concentrations greater than 25 parts per
17 million.
18 So here is a table showing the comparison
19 of the SU-7 remedial alternatives that we reviewed
20 on the previous slide, except for option 1, which is
21 the no-action-taken remedy. We've highlighted in
22 red on the right option 6, the preferred remedy,
23 which reduces risk to acceptable levels and achieves
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1 the remedial action objectives by removing
2 contaminated soils. The cost to implement this
3 cleanup is approximately 3.27 million. However,
4 this is on the lower end of the cost range, so this
5 cleanup may exceed this amount.
6 Because potential risk in SU-7 and the
7 landfills are different, a separate cleanup
8 alternative was needed to address the landfills.
9 These remedial alternatives for the remote and
10 Former Macon Naval Ordnance Landfills, shown here in
11 blue and green, will be discussed in the upcoming
12 slides.
13 Here is a table showing the comparison of
14 the remedial alternatives, or cleanups, for the
15 landfills, except for option 1, which is the
16 no-action-taken option. Our preferred cleanup is
17 option 2, outlined right here in the middle in red,
18 which repairs the existing soil cover. This was
19 selected because it offers protection of human
2 0 health and the environment, it achieves our cleanup
21 objectives, and there would be minimal tree removal
22 with a quicker habitat recovery and potentially less
23 exposure to workers implementing the cleanup. The
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1 option 2 cleanup is estimated to cost approximately
2 4.8 million dollars.
3 So here is a list of criteria that we used
4 when evaluating the cleanup options for SU-7 and the
5 landfills. It is actually required by law that
6 these nine evaluation criteria be used when
7 reviewing and evaluating cleanup options. The
8 analysis of alternatives reflects the scope and
9 complexity of site problems and alternatives being
10 evaluated and considers the relative significance of
11 the factors within each criteria.
12 Please note that under "Modifying
13 Criteria," we see state and community acceptance.
14 So while we are talking about our preferred remedies
15 here in this presentation, the final decision is not
16 made without giving the state and community,
17 you-all, the opportunity to weigh in. So, please,
18 if you have any questions or comments, please submit
19 these to us no later than July 1st.
2 0 In summary, here are the two preferred
21 cleanup alternatives for the SU-7 sampling unit and
22 the landfills and the rationale of why these were
23 selected. For SU-7, the preferred method is option
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1 6, which includes the removal of PCBs in soils at
2 concentrations greater than 25 parts per million,
3 backfilling with clean soil, and implementing
4 institutional controls. Our rationale for this
5 selection is shown here in the bulleted list. Under
6 option 6, cleanup levels will be reduced to
7 ecological and human protective levels and it will
8 be effective long term.
9 For the landfills, the preferred method is
10 option 2, which includes restoring and repairing the
11 existing soil cover, installing fencing, and
12 implementing institutional controls. This
13 alternative also offers a greater protection of the
14 natural habitat that provides better flood and storm
15 hazard reduction and better erosion control. This
16 is also the more sustainable green option over
17 option 3.
18 Again, please reach out to us no later
19 than July 1st of this year with any input or
2 0 feedback that you may have about the cleanup at AWI
21 OU2.
22 And now I will turn it over to Ron.
2 3 Ron?
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1 MR. TOLLIVER: All right. So our next
2 steps. So now that you've heard our proposed plan,
3 now it's time to talk about the next steps. So
4 right now we are in our comment period, and so these
5 are the dates for the comment period from May 3 0th,
6 which is tonight, to July 1st.
7 During this comment period, we want
8 you-all to submit your comments formally. So if you
9 have any questions or comments regarding our
10 proposed plan, the plan that you've just heard
11 about, we want you to officially submit them to us
12 or you can comment here.
13 You can -- during our Q&A session, we can
14 capture your comments or questions on this
15 presentation and during this meeting tonight. That
16 will also go into our responsiveness summary, where
17 we will officially respond to those.
18 Okay. After that period is over, then
19 we'll have a record of decision. So a record of --
20 that record of decision will be -- will be signed
21 after that comment period and after we address your
22 comments. We'll have that signing for that, and
23 that will be our official document to start the next
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1 few steps.
2 And then we'll have a remedial design,
3 which will design the cleanup plan. And then we
4 also will have the remedial action, which is where
5 actually we're going to go out and perform the
6 cleanup. And that's when we will come back to you,
7 and we'll send out fact sheets in the mail. I know
8 some of you probably have gotten your fact sheets in
9 the mail. I got some calls from you.
10 So we'll send out those fact sheets again,
11 and if we need to have another meeting, that's -- we
12 can do that as well. But we'll send the -- we'll
13 definitely send a fact sheet out to let you know
14 what to expect during this remedial action. And
15 those will be our next steps.
16 Okay. Next slide.
17 All right. And that's -- that comes to
18 the end of our presentation portion. Now we'll have
19 our Q&A session, and hopefully you-all gained a lot
2 0 of knowledge and information about EPA's process,
21 Superfund process. I hope you-all know it very
22 well, and hopefully that it was explained to you
2 3 what we're going to be doing in Armstrong down in
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1 Macon.
2 And if you have any input from your
3 perspective on what you saw, at this time, we would
4 ask that you would comment now. You can use your
5 raise-your-hand function on your -- on your tray,
6 your icon tray at the bottom, and then we can
7 acknowledge you, or if you'd like to type in the
8 chat, if you have any comments or questions. The
9 website here is on the page as well, along with
10 Peter and Anita's contact information. So if you
11 have any questions or concerns after this meeting,
12 you can also contact us, and we can address your
13 comments or concerns. Okay?
14 So at this time, we'll have our Q&A
15 session. Those of you on the phone -- I don't know
16 if anyone has called on -- called in, but if you are
17 on the phone, you press star 6 to unmute and star 9
18 to do the raise-your-hand function.
19 Okay. And with that being said, we will
20 go to any comments. So this is the time, those of
21 you who are -- have a comment or question about
22 anything we presented tonight, you can do so at this
23 time. All right.
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1 MS. LEWIS: Ron, I'm not seeing anything
2 or any --
3 MR. TOLLIVER: Don't see anything, okay.
4 All right, Zariah. Thank you.
5 So I guess that means we did a good job,
6 Peter and Anita.
7 MS. LEWIS: We do have a raised hand.
8 MR. TOLLIVER: Oh, there we go. Okay.
9 Ms. Redmond, we'll acknowledge you now.
10 MS. REDMOND: Now?
11 MS. REDMOND'S DAUGHTER: Yes, ma'am.
12 MS. REDMOND: Give my name?
13 MS. REDMOND'S DAUGHTER: Yes, ma'am, they
14 know you. They know who you are.
15 MR. TOLLIVER: Yes, we know you,
16 Ms. Redmond.
17 MS. REDMOND: All right. I want to say,
18 how far you-all going to come up and cleaning up out
19 there in Lynmore Estate?
2 0 MR. TOLLIVER: Can you repeat that again,
21 so we can . . .
22 MS. REDMOND: How far you-all going to be
23 cleaning up out there in Lynmore Estate?
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1 MR. TOLLIVER: Oh, as -- are you talking
2 about the area? How far? How much we're --
3 MS. REDMOND: Yes.
4 MR. TOLLIVER: -- going to cover?
5 MS. REDMOND: Yes.
6 MR. TOLLIVER: Okay, okay.
7 Do you want to go back to that slide,
8 Peter or Anita? And you can kind of explain where
9 the boundaries of where we're going to clean up.
10 Can y'all do that for Ms. Redmond?
11 MR. JOHNSON: Yeah. Hey, Ms. Redmond.
12 Thanks -- thanks for the question.
13 We've got a couple of slides here that I
14 think will be helpful. If you can see -- can you
15 see the figure on the screen now that highlights the
16 SU-7, the orange there, the green, and the blue?
17 MS. REDMOND: Yeah, but I couldn't tell
18 too much what -- what -- let me ask you this.
19 MR. JOHNSON: Yeah.
2 0 MS. REDMOND: Up there at 4221 Trammell
21 Avenue, okay, up there, that house up there, which I
22 done got rid of it, there --we had a lot of damage
23 up in there in the ground part of that.
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1 And you can see -- I mean you can smell
2 the -- in the air and up in there. There's a lot of
3 health hazards up in that area.
4 MR. TOLLIVER: Okay. Okay, okay. Thank
5 you for submitting that, Ms. Redmond. If you could
6 give me that address, and then we --
7 MS. REDMOND: 4221.
8 MR. TOLLIVER: Okay, okay. 4221? 4221?
9 MS. REDMOND: Um-hum.
10 MR. TOLLIVER: Okay.
11 MS. REDMOND'S DAUGHTER: 4221 Trammell
12 Avenue.
13 MR. TOLLIVER: Okay. 4221 Trammell.
14 MR. JOHNSON: Okay.
15 MR. TOLLIVER: Okay, we'll take a look at
16 it.
17 MR. JOHNSON: Yeah, thank you.
18 MR. TOLLIVER: Thank you.
19 MS. REDMOND: I don't live there now.
2 0 MR. TOLLIVER: Okay.
21 MS. REDMOND: I don't live there now.
22 MR. TOLLIVER: You just want us to take a
23 look at it, though?
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Page 28
1 MS. REDMOND: Yes.
2 MR. TOLLIVER: Okay. Yes, ma'am.
3 MS. REDMOND: It needs to be -- it needs
4 to be tended to. I don't know how it is out there
5 now because I haven't lived out there in over a year
6 now.
7 MR. TOLLIVER: Okay. Okay. All right.
8 MS. REDMOND: Because there's a lot of
9 problems, a lot of health problems out in that area,
10 right in that area in there.
11 MR. TOLLIVER: Yes, ma'am, yes, ma'am.
12 We'll take a look at it.
13 MS. REDMOND: Okay.
14 MR. TOLLIVER: Okay.
15 MR. JOHNSON: Okay. Thank you.
16 MS. REDMOND'S DAUGHTER: Do you-all know
17 of any health issues that -- that could be -- that
18 people in that area should be concerned about?
19 MR. TOLLIVER: So -- so what -- so the way
2 0 that we do it is, we work with -- you know, the
21 Department of Public Health, they do a lot of
22 studies. They do studies on health trends in
23 neighborhoods, and so they would be more likely to
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Page 29
1 be able to answer that question. But what we're
2 doing now, we're really kind of focusing in on this
3 particular cleanup.
4 You know, so the Department of Public
5 Health, I did have their contact information if you
6 have -- there on that first slide that we had. So
7 they could -- they could let you know about any --
8 you know, any trends and health trends going on in
9 the area. So they'll be the ones to contact about
10 that.
11 MS. REDMOND'S DAUGHTER: But you don't
12 know if the -- the cleanup that you-all are working
13 on, you don't know if it affect that area, then, I
14 guess?
15 MR. TOLLIVER: If it affects the --
16 outside the area that we just showed? Is that what
17 you're asking?
18 MS. REDMOND'S DAUGHTER: Right. Because I
19 can't really -- really tell whether the area is in
2 0 Lynmore Estate or not.
21 MR. TOLLIVER: Okay.
22 MS. REDMOND'S DAUGHTER: So, based on your
23 drawing and what we could actually see because it's
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Page 30
1 really small, she can't --
2 MR. TOLLIVER: Okay.
3 MS. REDMOND'S DAUGHTER: -- really tell
4 whether it affect -- how far it really affects.
5 And a lot of people out there has like,
6 you know, fruit trees and --
7 MR. TOLLIVER: Um-hum.
8 MS. REDMOND'S DAUGHTER: -- pecan trees
9 and stuff like that, so, if it's anything in the
10 ground, that could be causing issues, you know --
11 MR. TOLLIVER: Okay.
12 MS. REDMOND'S DAUGHTER: -- because --
13 like Mom had a lot of pecan trees out there, tons of
14 pear trees, and so, you know, with everybody out
15 there picking up those things, there could be
16 issues.
17 MR. TOLLIVER: Okay, okay. So we can look
18 into how those are being impacted, those --
19 MS. REDMOND'S DAUGHTER: Right.
2 0 MR. TOLLIVER: -- those trees? Okay. And
21 do you have like some addresses, the addresses of
22 those? We can -- if you want to put those in the
2 3 chat or . . .
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Page 31
1 MS. REDMOND'S DAUGHTER: I know -- all I
2 know is Mom -- where Mom was, and so anything around
3 the area, the one that she just gave you, 42- --
4 MR. TOLLIVER: Okay.
5 MS. REDMOND'S DAUGHTER: And I can try to
6 put it in the chat here in a second.
7 MR. TOLLIVER: Okay, okay. All right. We
8 can take a look at it. All right.
9 MR. FARRIER: Okay. Let me turn my camera
10 on. I don't --
11 MR. TOLLIVER: Brian -- do you have
12 something to say about that, Brian?
13 MR. FARRIER: Yeah, I would like to talk
14 to Carrie Redmond because --my name is Brian
15 Farrier. I'm one of the three project managers
16 working on this for EPA. I was the project manager
17 back in 2011.
18 And where do you live, Mr. Redmond? You
19 gave -- you gave us your address. Are you in
2 0 Lynmore Estates, by any -- by any chance?
21 MS. REDMOND: Yes, sir.
22 MS. REDMOND'S DAUGHTER: Yes, that's
23 Lynmore Estate.
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Page 32
1
MS. REDMOND: Um-hum.
2
MR. FARRIER: Okay. Lynmore Estates.
3
What I want to point out to you is that if
4 you -- if you look at this map here, the Armstrong
5 facility, and at the very top to the north is Guy
6 Paine. And that little grassy area -- yeah, go up a
7 little bit north. Yeah, right there. That grassy
8 area next to the -- no, a little bit more to the
9 east. A little bit more to the east. Right there,
10 that grassy area, we had concerns about PCBs, and we
11 sampled --we sampled PCBs along that area because
12 we were concerned about whether PCBs were going
13 further north into the Lynmore Estates Subdivision,
14 and we did not detect any PCBs.
15 The other thing I would like to point out
16 is that, you know, with Rocky Creek to the south of
17 Armstrong and Macon Naval Ordnance Plant, when it
18 rains, if there's water runoff runs towards the
19 creek, away from the residential areas. So we don't
20 think that the site has impacted Lynmore Estates or
21 the other residential areas, and we have samples we
22 got to document that. So I hope that helps you
23 understand.
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Page 33
1 MS. REDMOND'S DAUGHTER: So you're saying
2 they did samples out there in Lynmore Estate and you
3 didn't see anything? Is that what you're saying?
4 MR. FARRIER: We sampled along Guy Paine
5 Road to the north to make sure that PCBs had not
6 moved into Lynmore Estates, correct.
7 MS. REDMOND: I don't see -- you know, we
8 got a lot of health hazards out there in that area.
9 So, you know, they got -- now they done put a
10 landfill out there, over there by the paper company
11 back over in there.
12 And then too, they're saying they're going
13 to open up now another landfill over there where
14 they dumping over there somewhere over there off of
15 the street you just called a few minutes ago.
16 MS. REDMOND'S DAUGHTER: It's supposed to
17 be out there near the . . .
18 MS. REDMOND: So all that needs to be
19 taken care of, because a lot of people ain't saying
2 0 nothing. They don't know what and -- what to say.
21 MR. TOLLIVER: Okay.
22 MS. REDMOND: So all that needs to be
23 taken care of, the whole area, because people having
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PROPOSED PLAN FOR REMEDIAL ACTION
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Page 34
1 a problem out there, but they don't know what to
2 say. They don't know what -- you know how some
3 people is; they just don't know. They're
4 ignorant --
5 MR. TOLLIVER: Right.
6 MS. REDMOND: -- too.
7 MR. TOLLIVER: Right, right, right. Okay.
8 MS. REDMOND: And I wish you-all would
9 check that out.
10 MR. TOLLIVER: Yes, ma'am.
11 MS. REDMOND: I was out there for
12 70-something years, and I'm over the whole place out
13 there. And I seen a lot of issues out there, and it
14 still is in the ground part. They said they didn't
15 find nothing, but I believe they found something,
16 but they just don't want to admit it. I might be
17 wrong. If I am, y'all forgive me, but I just -- I
18 still believe y'all -- they found something.
19 MR. TOLLIVER: Okay. Okay, okay. Well,
2 0 thank you.
21 MS. REDMOND: There's a lot of health
22 problems.
2 3 MR. TOLLIVER: Yes, ma'am.
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PROPOSED PLAN FOR REMEDIAL ACTION
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1
Page 35
MS. REDMOND: A lot of (indiscernible) and
2 everything out in that area.
3
MR. FARRIER: Thank you, Ms. Redmond.
4
MR. JOHNSON: Yes, ma'am.
5
MS. REDMOND: Thank you.
6
MR. TOLLIVER: Thank you for your input.
7
MR. JOHNSON: And, Ms. Redmond, if -- you
8 should have my email address and Brian's email
9 address and Anita's. Please, please reach out to us
10 with -- you know, I think I wrote down the 4221,
11 but, you know, it'd be good to get the details of
12 all the other locations that you're talking about.
13 That would be -- that would be good to have.
14 MS. REDMOND: (Indiscernible)
15 MS. REDMOND'S DAUGHTER: Yes, ma'am. He
16 was saying if you -- all the other locations, like
17 the landfill and everything you're talking about.
18 MS. REDMOND: Um-hum.
19 MS. REDMOND'S DAUGHTER: So if you have a
2 0 location of where they're talking -- what you're
21 talking about, then we can send that to them as
22 well.
2 3 MS. REDMOND: All right, then.
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PROPOSED PLAN FOR REMEDIAL ACTION
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Page 36
1 MR. TOLLIVER: Okay.
2 MS. REDMOND: I appreciate it if y'all
3 would take care of it.
4 MR. TOLLIVER: Yes, ma'am. Yes, ma'am.
5 Thank you --
6 MR. JOHNSON: Thank you. Thank you.
7 MR. TOLLIVER: -- thank you for
8 participating tonight. It's good hearing from you.
9 MS. REDMOND: Thank you.
10 MR. TOLLIVER: Okay. All right. Any
11 other -- any other questions, comments, concerns?
12 (NO RESPONSE)
13 MR. TOLLIVER: Okay.
14 All right. Zariah, do we have anything in
15 the chat?
16 MS. LEWIS: No, your chat is empty, and I
17 don't see any more raised hands.
18 MR. TOLLIVER: No more raised hands.
19 Okay.
20 All right. Well, I guess we'll -- since
21 everyone is --
22 MR. JOHNSON: Hey, Ron, can I -- could I
2 3 say one --
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PROPOSED PLAN FOR REMEDIAL ACTION
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Page 37
1 MR. TOLLIVER: Sure.
2 MR. JOHNSON: -- one more thing before we
3 adjourn. And I know you mentioned this, but I
4 wanted to point out the site's webpage right there.
5 I'd recommend writing that down or you could simply
6 Google "Armstrong World Industries EPA" and that --
7 that would show up. But we have uploaded countless
8 documents on that website, and you can -- you can
9 view the site history. You can review a lot of, if
10 not all of, the information that we just presented.
11 We threw a lot at you tonight, so I'd
12 recommend writing that email address down and going
13 to that website to find some additional documents.
14 But, if you can't find what you want, feel free to
15 email me or call me directly, and we'll talk about
16 how to best answer your questions.
17 MR. TOLLIVER: Yeah, absolutely,
18 absolutely. So definitely go to that website. We
19 will -- like I said, during the remedial action
20 part, we will send out another fact sheet to you-all
21 to kind of let you-all know what's going on, so you
22 know what to expect after we go through all your
2 3 comments and concerns. And we're going to -- we
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PROPOSED PLAN FOR REMEDIAL ACTION
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Page 38
1 will build that -- our decision-making -- decision
2 document called the "Record of Decision." And then
3 we will reach back out to you-all when we get to
4 that, when we get ready to do the remedial action,
5 so that will be the next time we reach out to
6 you-all.
7 But if you-all have any -- like I said, if
8 you have any questions or concerns, you know, our
9 information is here. Please feel free to reach out.
10 You-all should have my phone number, email address.
11 All of it's on the website as well, so feel free to
12 reach out to us with any other questions.
13 We will -- and we also have another site
14 close to there too that we will be -- we will be
15 reaching out to you-all for another meeting soon.
16 So you-all stay in touch. If you want to be on our
17 contact list if you haven't, or if you know someone
18 that wants to be on the contact list, please
19 submit -- send me their contact information. I can
2 0 put them on our contact list, so that we can make
21 sure that they get informed on our decisions and the
22 things related to our work that we're doing in your
2 3 community. Okay?
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
1
Page 39
All right. Thank you-all so much.
2
Anita, you can -- you can stop presenting,
3
and we will adjourn for the evening. No other
4
questions. Thanks -- thank everyone for coming out
5
to our meeting. This will end our proposed plan
6
meeting for Armstrong World Industries 0U1 and 0U2,
7
Superfund site in Macon, Georgia. Thank you again.
8
Have a good night.
9
10
(THE PROCEEDINGS CONCLUDED AT 5:43 P.M.)
11
12
13
14
15
16
17
18
19
20
21
22
23
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PROPOSED PLAN FOR REMEDIAL ACTION
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Page 40
1
CERTIFICATE
2 STATE OF ALABAMA )
3 WALKER COUNTY
4
I hereby certify that the above and
5 foregoing proceeding was taken down by me by
6 stenographic means, and that the questions and
7 answers therein were produced in transcript form by
8 computer aid, and that the foregoing represents a
9 true and correct transcript of the proceedings
10 occurring on said date.
11 I further certify that I am not of
12 counsel, nor related to any of the parties to this
13 action; nor am I in anywise interested in the result
14 of said cause.
15 Witness my signature and seal this the
16 11th day of June 2024.
17
18
19
SUZANNE LEE, CCR
Certified Court Reporter
ACCR No.: 476
Expires: 09/30/24
20
21
Notary Public, State of Alabama at Large
22 My commission expires January 5, 2025
23
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: L.ahead
activity
1
3
9
13 : 15
1 4:718:20
3 18:5,6
9 6:6 24 : 17
actual 10:18
19 : 15
21 : 17
900 18:14
additional
10 18:13
3.27 19:3
37 : 13
180 9:5
30th 22:5
A
address 8:6,
1948 12:2
357 16:19
absolutely
17 15:4
19:8 22:21
1960s 12:7
37:17,18
24 : 12 27:6
1977 12:11
4
acceptable
31 : 19
15 : 11
1990s 17:2
4.8 20:2
42- 31:3
18 : 23
acceptance
35:8,9
37 : 12
3 8-10
1996 16:12
1998 16:12
1st 2 0:19
21:19 22:6
4221 26:20
27:7,8,11,
13 35:10
20 : 13
access 6 :1
9:2,7,15
accomplish
addressed
7:17 12:14
addresses
30:21
addressing
14 : 8
5
17 : 19
2
5:43 39:10
achieves
18 : 23
2 4:710:9
19 : 20
adj ourn 3 7:3
19:17 20:1
6
acknowledge
39:3
21 : 10
6 6:4,5
5:19 6 : 14
administrative
2011 12:21
18 : 22
7:4 9:17
8 : 21
31 : 17
21:1,6
24 : 7 25:9
admit 34:16
2016 12:23
24 : 17
acknowledged
advises 17:3
5:17 7:8
8:4
2019 10:7
16 : 18
7
affect 2 9:13
30:4
2020 16:18
2023 10:10
7 0-something
34 : 12
action 4 : 8
10 : 20
17 : 16
affects
29 : 15 30:4
21 15:3
8
18:3,4,5,
agency 5 : 1
6,7 19:1
23:4,14
37:19 38:4
25 18:8,16
21 : 2
80 16:23
agenda 17:8
ahead 4 : 2
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Index: air.xare
air 2 7:2
alternative
19:8 21:13
alternatives
18:1,19
19:9,14
20:8,9,21
amount 16:13
19 : 5
analysis
20 : 8
Anita 5 : 8
11:2,6,8
14 :3
15 : 20,22
17 : 14 25:6
26:8 39:2
Anita1s
24 : 10 35:9
approximately
16:23 19:3
20 : 1
area 13:21
14 : 11
16:5,11,20
18:5,6
26:2 27:3
28:9,10,18
29:9,13,
16,19 31:3
32:6,8,10,
11 33:8,23
35 : 2
areas 13:10
15:3 16:20
17 : 20
18:3,4,7
32 : 19,21
Armstrong
4:6 9:1
12:3 23:23
32:4,17
37:6 39:6
Army 16:12
assess 14:22
assessing
10 : 13
assessment
15:18,19
16 : 2
assessments
15 : 17
assigned
11 : 8
atop 15:11
audio 6:16,
17, 19
Avenue 9 : 6
26:21
27 : 12
avoid 17:4
AWI 12:3,4
13:9 15:18
21:20
B
back 17:8
23 : 6 26:7
31 : 17
33:11 38:3
backfilling
21:3
bark 12:6
barrier
13 : 12
based 11:5
18 :4 29:22
began 10:8
12 : 4
begin 9:11,
19 11:17
begins 8:11
biggest 18:7
biphenyl
13:3 16:15
birds 16:7
18 : 10
bit 11:19
32:7,8,9
blue 17:21
19 : 11
26 : 16
border 13:19
bottom 6:9,
12 17:6
24 : 6
boundaries
26 : 9
Brian 5:7,8
31 : 11,12,
14
Brian1s 3 5:8
build 3 8:1
bulleted
21 : 5
cadmium 13:3
call 8:21
10 : 19
37 : 15
called 8:19
9:23 13 : 10
24 : 16
33 : 15 38:2
calling 6 : 5
calls 23 : 9
camera 5 : 7
31 : 9
cap 12:15
13:13,15
capped 12:22
captioning
6 : 21,23
capture
7 : 19,23
22 : 14
capturing
7 : 14
care 3 3:19,
23 36:3
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: Carrie.xoordinator
Carrie 31:14
catfish 17:4
causing
30:10
ceiling 12:4
CERCLA 9:23
chance 31:20
channel 17:4
characterize
14 : 21
chat 5:18
7:5 9:15
24:8 30 : 23
31 : 6
36 : 15,16
check 34:9
chosen 10:15
clay 12:15
clean 21:3
26 : 9
cleaning
25:18,23
cleanup 4:18
5:2,4 8:14
10:5,15,19
11:4,11
13:4,6,8,9
16:3
17:11,17,
18 18:2,5,
15 19:3,5,
7,16,20,23
20:1,4,7,
21 21:6,20
23 :3, 6
29:3,12
cleanups
19 : 14
close 3 8:14
closed 6:21,
22 12:12
collected
16:14,19
collects
14 : 21
comment
7:10,16
8:7,9,10,
12 10:22
22:4,5,7,
12, 21
24:4,21
comments
7:5,15
8:1,3,6,17
9:16 20:18
22:8,9,14,
22 24 : 8,
13, 20
36 : 11
37 : 23
commercial
16 : 6
communities
8 :13
community
4:3 5:5
9 : 20
20 : 13,16
38 : 23
company
33 : 10
comparison
18 : 18
19 : 13
completed
12 : 16 17:9
completing
10 : 6
complexity
20 : 9
concentrations
18 :5,14,16
21 : 2
concern 13:2
15 : 14
concerned
28 : 18
32 : 12
concerns 9 : 9
15 : 6
24:11,13
32 : 10
36 : 11
37:23 38:8
CONCLUDED
39:10
conditions
14 : 22
conduct
10 : 18
conducted
12 : 23
15 : 17
16 : 12,17
17 : 1
connect 6:19
considered
15 : 1
considers
20 : 10
construction
12 : 10
contact
24 : 10,12
29:5,9
38:17,18,
19,20
contacts
4 : 22
contaminants
13 : 1
15 : 14,15
contaminated
18:8 19:2
contamination
10:13 15:4
control
13 : 17
21 : 15
controls
21 :4,12
coordinator
4:4 5:6
9 : 20
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: copper..empty
copper 13:3
DAUGHTER
17 : 10
32 : 22 38:2
Corps 16:12
25:11,13
description
documents
27 : 11
17 : 18
8:18,23
correct 33:6
correctly
28 : 16
29:11,18,
design 10 :
18
9:8 37:8,
13
7 : 22
22 30:3,8,
23 :2,3
cost 19:2,4
12, 19
detail 11 :
3
dollars 2 0:2
31:1,5,22
details
dot 14 : 9
20:1
33:1,16
35 : 11
costs 14:23
35:15,19
downgradient
countless
detect 3 2 :
14
17 : 5
debris 12:10
37 : 7
determined
downstream
couple 2 6:13
decision
10 : 16
12 : 18
16 : 21
cover 13:13
20 : 15
develop 16
: 6
drawing
29 : 23
15 : 10
22 : 19,20
developed
19 : 18
38:1,2
10 : 6
driver 16:3
21:11 26:4
decision-
directly
drop 18:12
covers 12:13
8 :18
37 : 15
dumping
creek 13:21
decision-
discuss 18
: 2
33 : 14
17 : 5
32 : 16,19
making 8:18
10:2,23
38 : 1
discussed
19 : 11
E
criteria
20:3,6,11,
decisions
disposal
12 : 9
earlier 14:4
13
38:21
east 3 2:9
current 4:17
declined
disposing
12 : 4
ecological
16:4
16 : 22
15:19 21:7
defines
disturb
effective
D
10 : 12
13 : 15
21 : 8
damage 2 6:22
demolition
divided
efficiently
13 : 21
13:9,10
15 :4
dashed 13:19
15:3 18:4
email 3 5:8
Department
Division
data 14:21
5 :12 28:21
37 : 12,15
16 : 10
29:4
12 : 12
38 : 10
dates 22:5
describing
14 : 15
document
22 : 23
empty 3 6:16
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: end..focus
end 7:2 8:4
19:4 23:18
39:5
engineered
13 : 12
Engineers
16 : 13
entire 11:17
environment
10 : 14
12 : 19
14:18,23
15 : 16
19 : 20
environmental
12 : 11
15 : 19
EPA 4:23
5:3 7:3
11:8,11
12 : 22
13:1,13
14:5,21
17:3 31:16
37 : 6
EPA1s 11:1
23 : 20
EPD 12:14,
17
equipment
12 : 5
eroded 15:12
erosion
21 : 15
Estate
25:19,23
29:20
31 : 23 33:2
Estates
31:20
32 :2,13,20
33 : 6
estimated
20 : 1
evaluate
14 : 23
evaluated
20:10
evaluating
20:4,7
evaluation
12 : 17 20:6
evening 3 9:3
exceed 19:5
excess 12:6
existing
19 : 18
21 : 11
expect 23:14
37:22
explain
11:3,16
13:8,23
26 : 8
explained
23 : 22
explaining
16:1 17:11
explosive
13 : 21
exposure
19 : 23
extensive
16 : 16
extent 10:13
eyedropper
18 : 13
F
facilitate
7 : 2
facility
32 : 5
fact 23:7,
8,10,13
37:20
factors
20 : 11
Faith 5 : 13
Farrier 5 : 7
31:9,13,15
32:2 33 :4
35:3
feasibility
10:9,11
17 : 10
feature 9:15
feedback
10 : 22
21 : 20
feeder 17:6
feel 9 : 9
37 : 14
38:9,11
fencing
21 : 11
figure 15:6,
8 17:19
26 : 15
final 2 0:15
finalize
10 : 16
finalized
8:22 10:10
find 34:15
37:13,14
fish 13:21
14 : 18
16:9,11,
14,16,19,
22 17:1,6,
7
Flack-walker
5 : 13
flood 21:14
flooding
14 : 13
FMNOL 12:8
fo- 7 : 9
focus 13:19
17 : 20
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: focusing..ID
focusing
general 12:5
guess 25:5
helps 15:14
29 : 2
17 : 18
29 : 14
32 : 22
follow-up
Georgia 4 : 9
36:20
Hey 17:14
7 : 10
5:11,12
Guy 3 2:5
26 : 11
forgive
9:4,6
33 : 4
36:22
34 : 17
12:11,14,
highest 15:9
17 39:7
H
17:6
formally
give 25:12
7:17 8:1,
habitat
highlighted
2,6,16,17
2 7:6
19 : 22
10:4 17:21
22 : 8
giving 2 0:16
21 : 14
18 : 21
found 13:1
goals 17:11,
hand 6 : 6
highlights
16 : 16
17
25 : 7
26 : 15
34 : 15,18
good 14:11
hands 7:11
history
Franklin
25 : 5
36 : 17,18
11:23 37:9
5 : 13
35:11,13
home 9 : 2
hazard 21:15
free 9 : 9
36:8 39:8
hazards 2 7:3
hope 23:21
37 : 14
Google 3 7:6
33 : 8
32 : 22
38:9,11
grassy 3 2:6,
health 5:13
house 2 6:21
frequent
7, 10
14 : 13
greater
10:14
Houston 17:5
12 : 19
fruit 3 0:6
18:8,16
14:17,22
hover 6:11
function
21:2,13
15:18 16:4
human 10:14
6:8,14 7:7
green 14:9
19:20 27:3
12 : 19
24:5,18
16 : 21
28:9,17,
14 : 17,22
17 : 22
19 : 11
21,22
15:18 16:4
future 4:18
29:5,8
19:19 21:7
16:6 18:10
21:16
33:8 34:21
I
G
2 6:16
heard 2 2:2,
ground 2 6:23
10
IC 13:17
gained 23:19
gallons
30:10
34 : 14
hearing 3 6:8
heavily
icon 6:8,
11,12,23
18 : 13
groundwater
14 : 11
24 : 6
gave 31:3,
13 : 14
helpful
ID 7:21
19
26 : 14
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Huseby Global Litigation
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Index: identify..listed
identify
15 : 14
ignorant
34 : 4
image 14:9
impacted
8:14 30:18
32 : 20
implement
19 : 2
implementing
19 : 23
21:3,12
important
8:9 10:22
11:10,14
includes
13 : 20
14 : 17
21:1,10
indiscernible
35:1,14
industrial
12:5 18:10
Industries
4:7 12 :3
37:6 39:6
Industries 1
9 : 1
information
5:18 7 : 23
8:2 9:3
11:4 23 :20
24:10 29:5
37:10
38:9,19
informed
38:21
input 8:12
10 : 16
21:19 24:2
35 : 6
insect-eating
16:7 18:9
installing
21 : 11
institutional
13 : 17
21 :4,12
instructions
5:23
Internet 9 : 7
introduce
4 :16
introductions
4 :13
investigation
10:8,11
13 : 6
14 : 16,20
15:2,13
16:11,17
17 : 9
investigative
13 : 1
involvement
4:3 5:5
9:20
issues 11:19
28 : 17
30:10,16
34 : 13
j ob 2 5:5
Johnson 5 : 8
11:2 14 :3,
5 17:14,15
26 : 11,19
27 : 14,17
28 : 15
35:4,7
36:6,22
37 : 2
join 6:17,
19
July 2 0:19
21:19 22:6
K
kind 13:16
26:8 29:2
37:21
knowledge
23 : 20
land 13:14
landfill
12:6,7,8,
13,14,23
13:12,20
33:10,13
35 : 17
landfills
12 : 12
14 : 10
15 : 7,11
17 : 12,21
19:7,8,10,
15 20:5,22
21 : 9
late 10:10
17 : 1
law 9:23
20 : 5
lead 5 : 1
13 : 3
left 15:6,8
level 17:6
levels 15:9
16 : 15
18 : 23
21:6,7
LEWIS 25:1,7
36 : 16
Library 9 : 5
limited
16:13 17:1
list 14:19
20:3 21:5
38 : 17,18,
20
listed 12:20
14 : 19
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Index: listing..open
listing
12 : 20
live 2 7: 19,
21 31:18
lived 2 8:5
located 4 : 8
9:4 14:13
15 : 7
location
35 : 20
locations
35 : 12,16
long 21:8
lot 23:19
26:22 27:2
28:8,9,21
30:5,13
33:8,19
34:13,21
35:1 37:9,
11
lower 14:8
18:9 19:4
Lynmore
25:19,23
29:20
31 : 20,23
32 :2,13,20
33 :2,6
M
Macon 4 : 8
9:6 12:7
19:10 24:1
32:17 39:7
made 2 0:16
mail 23:7,9
make 5:23
6:18 7:20,
21 33:5
38:20
manager 11:9
31 : 16
managers
5:3,6 11:2
14:6 31:15
manufactured
12 :4
map 3 2:4
means 2 5:5
meeting 4 : 5
5:23 6:1,
3,18,20
7:15 8:4,
10 10:21
22 : 15
23 : 11
24 : 11
38 : 15
39:5,6
mentioned
11:9 14:4
37:3
method 2 0:23
21 : 9
middle 9 : 4
19 : 17
milestone
11 : 10
milestones
10:1,6
million
18:9,12,
15,17 19:3
20:2 21:2
minimal
19 : 21
minutes
33 : 15
Modifying
20 : 12
Mom 3 0:13
31 : 2
mouse 6:11
moved 3 3:6
munition
12 : 9
mute 6 : 5
muted 7 : 7
N
national
12 : 20
14 : 19
natural
21 : 14
nature 10:12
Naval 12:7
19 : 10
32 : 17
needed
12:17,18
19 : 8
neighborhoods
28 : 23
night 3 9:8
no-action-
taken 18:21
19 : 16
noncancer
16:4
north 3 2:5,
7,13 33:5
note 2 0:12
NPL 14:19
number 14:9
38 : 10
objectives
17 : 16
19:1,21
obtain 9 : 8
offers 19:19
21 : 13
official
22 : 23
officially
8 : 11
22 : 11,17
open 3 3:13
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: operable..portions
operable 4 : 7
10:8 13:11
opportunity
20 : 17
option
18 : 20,22
19:15,16,
17 20:1,23
21:6,10,
16,17
options
11:11 13:5
18 :2 20:4,
7
orange 2 6:16
order 7:11,
12
Ordnance
12:8 19:10
32 : 17
organizations
4:17 5:15
OU 13:11
14 : 7
OU1 13:11
39:6
OU2 13:5,
18, 20,23
14 : 13
15:2,18
17 : 17
21:21 39:6
outlined
19 : 17
oversee 5 : 1
oversight
5:3
P.M. 39:10
paid 13:6
Paine 3 2:6
33:4
paper 3 3:10
part 8 : 9
16 : 10
18 : 11
26 : 23
34 : 14
37:20
participating
36 : 8
parties
10:7,17
13 : 7
parties1 5:2
parts 11:14
12:9 18:8,
14,16 21:2
PCB 13:2
16 : 15
18:5,8
PCBS 15:8
16:22 17:7
18:13,15
21 : 1
32:10,11,
12,14 33 :5
pear 3 0:14
pecan 3 0:8,
13
people 28:18
30:5
33 : 19,23
34:3
percent
16 : 23
perform 23:5
performed
14 : 20
period 8:7,
9,10,12
22:4,5,7,
18,21
personnel
4 : 23 5:11
7:4
perspective
8:15 24 :3
Peter 5 : 8
11:2 13:23
14 :2,4
15 : 23
17 : 10,13 ,
15 24:10
25:6 26:8
phase 11:13
14 : 21
16 : 17
phone 6:3,5
24 : 15,17
38 : 10
photos 14:7,
12
picking
30 : 15
picture
18 : 11
pink 16:21
17:21 18:2
place 34:12
placing
13 : 13
plan 4 : 7
8:14 10:4,
5 11:4,10,
13 , 15
13 : 20 14 : 8
17 : 20
22:2,10
23 :3 39:5
Plant 12:23
32 : 17
point 3 2:3,
15 37:4
polychlorinate
d 13 : 2
16 : 15
portion 7:10
14:16 15 : 8
17:9,11
23 : 18
portions
18:4
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: pose..receive
pose 15:15
14 : 19
21 : 13
14, 16
potential
priority
protective
20:18
19 : 6
12 : 20
21 : 7
22 : 9,14
24:8,11
potentially
problem 34:1
provide
36 : 11
5:1 19:22
problems
17 : 17
37 : 16
preferred
20:9 28:9
public 4 : 5
38 : 8,12
11:12 13:5
34 : 22
5 : 13
39:4
17 : 12
PROCEEDINGS
10 : 21,22
quicker
18:6,22
39:10
15:16 17:3
19 : 22
19 : 16
28:21 29:4
process 9:22
20:14,20,
purpose 8:12
23 21:9
10:2,12,23
R
11:11,17
put 5:18
rains 32:18
present 5:16
23 : 20,21
8:20 30:22
12:2 13 :4
16 : 5
project 5:3,
31:6 33:9
raise 6 : 6
6 11 :2, 9
38:20
raise-your-
presentation
14 : 5
putting
hand 6:8,14
4:13,14,19
31:15,16
12 : 15
7:6 24:5,
9:12,14,
17,19
prone 14:13
18 : 12
18
raised 7:12
14:16
proper 6 : 2
Q
25 : 7
20 : 15
proposed 4 : 7
36 : 17,18
22 : 15
10:4,5
Q&a 6:15
range 19:4
23 : 18
11:4,10,
7:1,3
presented
13, 15
9:13,18
RAOS 17:17
24 : 22
13 : 20 14 : 8
22 : 13
rationale
37:10
17 : 20
23 : 19
20 :22 21:4
presenting
22:2,10
24 : 14
reach 9 : 9
10:15 39:2
3 9:5
question
21:18 35:9
press 6:4,5
proposes
4:15,19
3 8:3,5,9,
24 : 17
11 : 11
7:10,16
24 : 21
12
previous
protect
26 : 12 29:1
reaching
10:6 18:20
12 : 19
38 : 15
protection
questions
ready 3 8:4
primary 15:6
7:4,15
12 : 11
receive 8:12
Priorities
19:19
8:3,6 9:9,
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: received..Ron
received 8 : 7
recommend
37 : 5,12
record 8:21
22 : 19,20
38 : 2
recovery
19 : 22
red 10:4
18 : 22
19 : 17
Redmond
25:9,10,
12,16,17,
22 26:3,5,
10,11,17,
20 27:5,7,
9,19,21
28:1,3,8,
13 31:14,
18,21 32:1
33:7,18,22
34:6,8,11,
21 35:1,3,
5,7,14,18,
23 36:2,9
REDMOND 1S
25:11,13
27 : 11
28 : 16
29:11,18,
22 30:3,8,
12, 19
31:1,5,22
33:1,16
35 : 15,19
reduced 21:6
reduces
18 : 23
reduction
21 : 15
reflects
20 : 8
Regional 9 : 5
relate 11:16
related
38:22
relative
20:10
remedial 4 : 8
5:6 10:8,
11,18,19
14:5,15,20
15:2,13
16:10,17
17:9,16,23
18 : 19
19:1,9,14
23:2,4,14
37:19 38:4
remedies
11:5,12
13:5 17:12
20 : 14
remedy 10:15
18:21,22
remote 12:6
19 : 9
removal
19:21 21:1
remove 18:7,
15
removing
19 : 1
repairing
21 : 10
repairs
19 : 18
repeat 25:20
report 8 : 5
reported
15:7,9
18 : 14
repository
9:3,4
required
9:22 20:5
residential
32 : 19,21
resources
12 : 18
respond 8:1,
2 22:17
RESPONSE
36 : 12
responsible
5:2 10:7,
17 13 : 7
responsiveness
8:19 22:16
restoring
21 : 10
restriction
13 : 14,16
results
14 : 17
16:1,2,3,
22
review 15:20
17 : 16,23
37 : 9
reviewed
18 : 19
reviewing
20 : 7
rid 2 6:22
risk 14:22
15:15,17,
18,19
16:2,4,7
18 : 9,23
19 : 6
risks 10:13
14 : 17 16:5
Road 17:5
33 : 5
Rocky 13:21
17:5 32:16
role 5:2,3
roles 9:21
Ron 4:3 5:5
11:7,9
14 : 4
21 :22,23
25:1 36:22
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
Index: runoff..start
runoff 3 2:18
runs 3 2:18
Saha 5 : 8
11:2,7,22
12:2 15:23
sampled
16:14 17:7
32:11 33:4
samples
32:21 33:2
sampling
13 : 22
14:17,18
15 :3, 5
16:10,11,
16 17:1
18:1 20:21
Sanchez 5:14
scope 2 0:8
scrap 12:6
screen 6:9,
12 26:15
sediments
16 : 8
select 6:13
selected
19 : 19
20 : 23
selection
21 : 5
send 23:7,
10,12,13
35:21
37:20
38:19
sense 14:11
separate
19 : 7
session
4 :15,20
6:15 7:1,3
9:13,18
22 : 13
23 : 19
24 : 15
setting 14 : 1
sheet 23:13
37:20
sheets 23:7,
8,10
short 12:3,8
13 : 11
show 16:22
37 : 7
showed 2 9:16
showing
18 : 18
19 : 13
shown 13:18
15 : 5
16:20,21
18:1 19:10
21 : 5
shows 9:23
11:14 14:9
16:4 17:19
signed 22:20
significance
20:10
significantly
16 : 23
signing
22 : 22
similar
18 : 12
simply 3 7:5
sir 31:21
site 4:4,8,
18,22,23
9:1,3 10:8
11:9,23
12:3,20
13:2,6, 9,
23 14:6,
18,20,22
16 :3,21
20:9 32:20
37:9 38:13
39:7
site 1s 3 7:4
site-specific
15 : 17
sizes 14:10
slide 4:11,
21 9:23
10:7 11:14
16 : 20
18 : 20
23 : 16 26:7
29 : 6
slides 15:21
19 : 12
26 : 13
small 3 0:1
smaller 15:3
smell 2 7:1
soil 12:13
13 : 13
15 : 9,10
16:8 18:5,
8,16 19:18
21:3,11
soils 19:2
21 : 1
solid 12:9
south 32:16
southwest
15 : 10
space 16:6
speakers
6 : 20
spell 7:18
spelled 7:22
stage 10:4
star 6:4,5,
6 24 : 17
start 4:12
11 : 22
22 : 23
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Huseby Global Litigation
800-333-2082
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024 Index: started..treatment
started 4:2,
10 5:21
state 5:11
7 : 18
20 : 13,16
stay 7 : 7
38 : 16
steps 22:2,3
23:1,15
s top 3 9:2
storm 21:14
strategy
10 : 5
street 33:15
studies 13 : 1
28 : 22
s tudy 10:9,
12 17:10
stuff 3 0:9
SU-7 15:7,
9,10
17 : 12,20
18:1,3,14,
19 19:6
20:4,21,23
26 : 16
Subdivision
32 : 13
submit 9:16
20 : 18
22:8,11
38:19
submitting
27 : 5
suckerfish
17 : 4
summarize
11 : 15
summary 8:19
20:20
22 : 16
Superfund
9:1,22
10 : 1
11:11,17
23 : 21 39:7
support
4:17,23
5 :10
supposed
33 : 16
surrounding
15 : 16
SUS 15:5
sustainable
21 : 16
T
table 18:18
19 : 13
Tahsin 5:11
talk 4 : 6
8:8 13:18
16:9 18:3
22:3 31:13
37 : 15
talking
20 : 14 26:1
35 : 12,17,
20.21
technical
11 : 19
technologies
15 : 1
tended 2 8:4
term 21:8
thing 3 2:15
37 : 2
things 8:15
30 : 15
38:22
threw 3 7:11
tiles 12:4
time 5:17,
19 16:13
22:3 24 :3,
14,20,23
38 : 5
Today 13:4
today1s
11 : 15
Tolliver
4:1,3 5:5
11:20 12 : 1
22:1 25:3,
8,15,20
26:1,4,6
27:4,8,10,
13,15,18,
20.22
28:2,7,11,
14, 19
29 : 15,21
30:2,7,11,
17,20
31:4,7,11
33 : 21
34:5,7,10,
19,23 35:6
36:1,4,7,
10,13,18
37:1,17
tonight 4 : 5
5:16 8:11
22 : 6,15
24 : 22 36:8
37 : 11
tonight1s
10 : 21
tons 3 0:13
top 3 2:5
topics 11:16
touch 3 8:16
Trammel1
26 : 20
27:11,13
transcriptioni
st 7:14,19,
22 8:5
trash 12:5
tray 6:8,
11,12,23
24:5,6
treatment
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PROPOSED PLAN FOR REMEDIAL ACTION
Public Hearing on 05/30/2024
12 : 23
14 : 23
tree 19:21
trees 14:10
3 0:6,8,13,
14, 20
trends 2 8:22
29 : 8
turn 7 : 8
11:1 21:22
31 : 9
type 24:7
U
U.S. 16:12
Um-hum 2 7:9
30:7 32:1
35 : 18
Unacceptable
16 : 14
understand
9:21 32 : 23
unit 10:9
13:11 18:1
20:21
units 4 : 7
15 :4, 5
unmute 6 : 6
7:9 24:17
upcoming
15 : 21
19 : 11
uploaded
37 : 7
upper 15:8
Upstream
16 : 20
utilize 6 : 7
V
view 3 7:9
viewing 6 : 2
W
wall 13:12,
15
wanted 3 7:4
Washington
9:5
waste 12:9
Wastewater
12 : 22
water 18:12,
13 32:18
waving 5 : 9
webpage 3 7:4
website 8:23
9:2 24 : 9
37:8,13,18
38 : 11
weigh 2 0:17
wetlands
14 : 14
wood 12:6
wooded 14:11
Woodyard
12 : 13
word 5:20
work 4:18
13:9 14 : 6
28 : 20
38:22
worker 18:10
workers 16:5
19 : 23
working
29 : 12
31 : 16
World 4 : 6
9:1 12 :3
37:6 39:6
writing
37 : 5,12
wrong 3 4:17
wrote 3 5:10
Y
y1 all 2 6:10
34:17,18
36 : 2
year 21:19
28 : 5
years 34:12
yellow 13:19
16 : 21
Index: tree..Zoom
you-all 7 : 7
8:13 20:17
22 : 8
23 : 19,21
25 : 18,22
28 : 16
29 : 12 34:8
37:20,21
3 8:3,6,7,
10,15,16
39:1
Z
Zahid 5:12
Zariah 2 5:4
36 : 14
Zoom 6:10
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Huseby Global Litigation
800-333-2082
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Armstrong World Industries, Macon-Bibb County, Georgia, OU1 and OU2
Record of Decision
July 2024
APPENDIX C
COMMENTS RECEIVED ON BEHALF OF THE PRP
RESPONDENTS
C-l
-------
AA MONTROSE
W 1 ENVIRONMENTAL
Comments on the Proposed Plan
for Armstrong World Industries Superfund Site, Operable Unit 2
The following comments to the Proposed Remedial Action Plan ("PRAP") are submitted on behalf of the
Respondents to the AOC for the Armstrong World Industries Site, Docket No. CERCLA - 04-2018-3759.
Bolding indicates the portions of the text of the PRAP subject to the comments.
Page 2, Paragraph 3: "For the SU-3 and SU-5 sampling units, active remediation is not being proposed
at this time. However, as part of the first Five Year Review for the Site, additional sampling will be
conducted in the SU-3 and SU-5 sampling units, with environmental risks re-evaluated based on the
sampling results. Plans to remediate the SU-3 and SU-5 sampling units will also be re-evaluated if
environmental risks do not decrease."
Page 16, Paragraph 2: "For the SU-3 and SU-5 sampling units, ecological risk estimates shown in
Table 2 range from 1.2 to 2.7, representing a modest exceedance of an environmental risk criterion of
1.0. These risk estimates are based on modestly conservative exposure assumptions. In addition, the
benefit from reducing these relatively modest ecological risk estimates may be offset by remedial action
that disrupts ecological habitat. Therefore, active remediation of sampling units SU-3 and SU-5 is not
being proposed at this time. However, as part of the first Five Year Review for the Site, additional
sampling will be conducted in the SU-3 and SU-5 sampling units, with environmental risks re-evaluated
based on the sampling results. Plans to remediate the SU-3 and SU-5 sampling units will also be re-
evaluated if environmental risks do not decrease."
• EPA establishes the following remedial action objectives (RAOs) (pg. 17) related to soil:
1. Reduce risks to the insectivorous bird population from exposure to PCBs in surficial soil within
SU-7 to acceptable levels (HQ of 1 or less).
2. Prevent future exposure for industrial workers to PCB contaminated soil with post-cleanup average
concentrations greater than 15 ppm.
• EPA establishes a preliminary remedial goal (PRG) of 15 mg/kg for protection of human health under
an industrial land use scenario. A remedial action level (RAL) of 25 mg/kg PCB (pg. 17) based on
TSCA clean-up levels for low occupancy areas (TSCA was identified as an ARAR), is established to
meet the PRG. TSCA's clean-up levels are, in fact, risk-based thresholds for protection of human
health. However, EPA's PRG is not based on the same exposure factors described for low occupancy
areas. Had EPA considered consistent exposure factors for low occupancy, the resultant PRG would
be higher than what is reflected in the PRAP.
• EPA acknowledges that TSCA does not apply to the wetlands in SU-5 (and presumably SU-3, which
is also wetland area) (pg. 16, para. 3). Therefore, RAO #2 does not apply to SU-3 and SU-5, and the
clean-up level (i.e., RAL) to achieve an HQ of 1 (RAO #1) remains open to interpretation.
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• MNR is not viable in low-energy setting with nominal sediment accretion, so eco risk is expected to
remain stable over the next 5 years.
• The risk results presented in Table 2 match what was presented in EPA's subsequent ecological risk
calculations presented as comments to the BERA. However,
a. The HQ is calculated to one significant figure (this is not reflected in EPA's table).
Therefore, the PCB condition in SU-5 (1 instead of 1.2) meets RAO #1.
b. The PCB ISM data in SU-3 is highly skewed. EPA acknowledges in the footnote of Table
2 that the high-end HQ of 2.7 based on the 95% UCL has the most uncertainty.
c. EPA does not mention that the risk estimates for SU-3 and SU-5 do not include the effects
of flood inundation from Rocky Creek. The flood study showed 12% and 17% inundation
(as cumulative acre-day inundation / total number of acre-days during the study period) of
SU-3 and SU-5, respectively.
d. The risk calculations performed in the BERA and by EPA conservatively use the 95% UCL
as the Exposure Point Concentration (EPC). However, in determining ecological-based
remedial action it is common to use the average concentration instead of 95% UCL. Using
the average concentrations results in the following HQs for PCBs:
AREA
coc
HQ using 95% UCL
HQ using Average
SU-3
PCB
2.7
1
Cd
2.6
2
SU-5
PCB
1.2
1
• Thus, based on the average concentrations and rounding to one significant digit,
SU-3 and SU-5 meet the HQ of 1 for PCB, thus meeting RAO#l.
• The HQ for cadmium in SU-3 is above 1; however, this does not account for the
effects of flood inundation. As stated in the BERA: "Avian response to flooding
varies based on the extent and duration of flood events and species ecology.
Prolonged flooding has been shown to cause changes in population density,
occupancy, and community structure of ground foraging birds (Knopf and
Sedgwick, 1987; Knutson and Klaas, 1997). Additionally, flooding can induce
habitat alteration and impact the availability of avian food resources (Chiavacci et
al., 2014). For example, flooding generally has a negative impact on earthworm
abundance (Ausden etal., 2001; Ivask etal., 2007; Plum and Filser, 2005), which
represent a significant portion of the modeled diet of the cotton mouse and
insectivorous bird and a key pathway for exposure to soil COPECs (as discussed in
Section 4.4.2.1). In summary, the flood study suggests that this risk assessment
over-estimates risk to nonarboreal small mammals and certain avail species in
inundated areas."
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• Additionally, as mentioned in the Proposed Plan, the inputs into the risk
calculations are "modestly conservative exposure assumptions." Using exposure
assumptions that we feel are more realistic (as presented in the BERA), the resulting
HQ for avian exposure to cadmium at SU-3 is 0.6.
• Based on all the points above, additional sampling at SU-3 and SU-5 is not warranted as these areas
do not pose an unreasonable ecological risk. Additionally, it is likely that the concentrations will
remain stable over the next 5 years and, more importantly, using average concentrations in SU-3 and
SU-5 results in acceptable HQ values (considering flood inundation) indicating that there is not an
unacceptable ecological risk.
a. If the risk estimates of 1.2 to 2.7 for these areas don't warrant remedial action today, there
is no basis to conclude that the same concentrations will warrant a remediation in 5 years.
b. It is notable that the highest HQ (2.7) is based on a "statistical estimate" - not a measured
concentration or the representative exposure concentration for these areas. Excluding this
estimate, the HQs associated with PCBs are 1.2 and 1.4 (both of which round to 1).
c. Finally, the reduction in risk from maximum of 2.6 to less than 1 is insignificant compared
to the recognized damage that would occur to the ecological habitat from implementing an
intrusive remedy - the risk reduction achieved by an active remedy does not justify an
intrusive remedy. In the event that any reevaluation is performed at the Five Year Review,
we suggest rewording the penultimate sentence above to allow for the concept of a potential
NEB A evaluation. "However, as part of the first Five Year Review for the Site ... to the
extent that environmental risks are re-evaluated... the evaluation may incorporate net
environmental benefit analysis concepts. "
Page 14, Paragraph 3: The HHBRA found that the fish tissue does not pose an unacceptable risk
(Cancer Risk of 6x10-6 and HI of 0.6)
The cancer risk should be 3 x 10-6, not 6 x 10-6. (Note: EPA used results for the Adolescent Angler in
this table.)
Page 14, Last Paragraph: By removing SU-7 soils with total PCBs above 25 ppm the human health
risk is reducedfrom a hazard quotient of 7.3 to 0.3.
It is unclear how the EPA derived an HQ of 0.3. Per the Feasibility Study, the post-action EPC in SU-7
is 3 mg/kg, which results in a HQ of 0.2 for the Composite Worker using the EPA RSL Calculator. (Note:
the values shown in Table 1 that were calculated by the EPA were based on the Composite Worker.)
Page 15, Table 1
Noted several errors in this table, as indicated below. (Note that it looks like CTE values were entered
into the table for the Trespasser instead of the RME values that were used for the other receptors.)
The table should indicate that these values are based on the RME scenario and thus represent an elevated
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potential risk.
The summary of risk for the industrial worker indicates the estimates are "future risks" potentially
implying risks post-remediation. As noted above, the post-remediation HQ would be 0.2. The table should
indicate more clearly that the risk estimates are pertinent to a hypothetical future industrial land use
scenario if remediation is not conducted and not reflective of the post-remediation condition.
Table 1: Human Health Risks at OU2 and SU-7
Current Risks for the OU2 Site Inspector, Trespasser, and Angler
Site Inspector
Exposure
Medium
Soil
Contaminant
PCBs
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Carcinogenic Risks
{Ingestion, Dermal, Inhalation)
lxlO"06
lxicr
3xl0"°s
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
0.01
1x10-6
Total = 2x10
0.0004
Total = 0.01
Trespasser
Exposure
Medium
Soil
Contaminant
5x10-7
PCBs
Benzo(a)pyre
3:arcii
ion.
arcinogenic Risks
Dermal, IrH—*-
1x10-8
Dibenzo(a,h)anthracene
^^•3x10
6x1c09
-^^lxlO"0
6x10-8
Non-Carcinogenic Ha
(Ingestion, Dermal,
0.01
6x10-7
Total = SxlO"08
0.0003
0.09
0.001
Total = 0.01
0.09
Angler
Exposure
Medium
Surface Water
Fish
Contaminant
PCBs
PCBs
Mercury
Carcinogenic Risk
(Ingestion, Dermal, Inhalation)
6x10^
3X10"06
Total = 3x10^
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
0.5
0.1
Total = 0.6-
Future Risks for SU-7 Sampling Unit
0.5 max by
target organ
Industrial Worker
Exposure
Medium
Soil
Contaminant
PCBs
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Carcinogenic Risk
(Ingestion, Dermal, Inhalation)
lxlO"01
3 xlO"06
5x10-7
3 xicr07
Non-Carcinogenic Hazard Quotient
(Ingestion, Dermal, Inhalation)
7.23
7 (one sig fig)
0.0257
0.03 (one sig
Total = 1x10
Total = 7.3-
7 (one sig fig)
Page 16, Paragraph 4: "By removing SU-7 soils with total PCBs above 25 ppm the ecological risk is
reduced from a hazard quotient of 19 to 0. 7.
It is unclear how the EPA derived a post-action HQ of 0.7. Per the Feasibility Study, the post-action EPC
in SU-7 is 3 mg/kg, which results in a HQ for the robin of 0.1 - 0.5 as presented in Appendix D of the
Feasibility Study.
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