Five-Year Review Report Third Five-Year Review Report for T.H. Agriculture and Nutrition Co. (Albany Plant) GAD042101261 Albany Dougherty County, Georgia September 2013


Pive~\ ear Review Report

for

I'll. \t,f iciiltnre and Notrition Co. (Albany Plant)

GAD042101261

Albany
Dougherty Counr\. tknir«Ri

September 2013

United States Environmental Protection Agency
Region 4
Atlanta, ("ieorgia

Director, Superfund Division

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Third Five-Year Review Report
for

T.H. Agriculture and Nutrition Co. (Albany Plant)

1401 Schley Avenue
Albany
Dougherty County, Georgia
List of Acronyms	4

Executive Summary	6

Five-Year Review Summary Form	9

1.0 Introduction	14

2.0 Site Chronology			16

3.0 Background	18

3.1	Physical Characteristics	18

3.2	Land and Resource Use		22

3.3	History of Contamination	22

3.4	Initial Response	23

3.5	Basis for Taking Action	25

4.0 Remedial Actions			27

4.1	Remedy Selection		27

4.2	Remedy Implementation	30

4.3	Operation and Maintenance (O&M)	33

5.0 Progress Since the Last Five-Year Review	34

5.1	New Ground Water Remedies or Remedy Optimization	!	37

5.2	Bioremediation Report	37

5.3	OU2 Subsurface Soil Acting as a Significant Continuing Source	37

5.4	Annual Ground Water Monitoring	37

5.5	OU2 Ground Water Institutional Controls	37

5.6	OU1 and OU2 Soil Institutional Controls	37

5.7	Well Survey	38

5.8	Toxaphene Degradation Products	38

6.0 Five-Year Review Process	39

6.1	Administrative Components	39

6.2	Community Involvement	39

6.3	Document Review	39

6.4	Data Review	44

6.5	Site Inspection			51

6.6'	Interviews	52

7.0 Technical Assessment	55

7.1	Question A: Is the remedy functioning as intended by the decision

documents?	55

7.2	Question B: Are the exposure assumptions, toxicity data, cleanup levels and

remedial action objectives (RAOs) used at the time of remedy selection
still valid?			57

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7.3 Question C: Has any other information come to light that could call into

QUESTION THE PROTECTIVENESS OF THE REMEDY?	59

7.4 Technical Assessment Summary	59

8.0 Issues	61

9.0 Recommendations and Follow-up Actions			62

10.0 Protectiveness Statements	64

11.0 Next Review			65

Appendix A: List of Documents Reviewed	A-l

Appendix B: Press Notice	B-l

Appendix C: Interview Forms	C-l

Appendix D: Site Inspection Checklist			D-l

Appendix E: Photographs from Site Inspection Visit	E-l

Appendix F: Screening-Level Vapor Intrusion and Toxicity Value Evaluation	F-l

Appendix G: Deed Documents Containing Institutional Controls	G-l

Appendix H: 1992 Removal Action Excavated Areas	H-l

Appendix I: 2013 EPA Ground Water Data Analysis	1-1

Tables

Table 1: Chronology of Site Events	16

Table 2: 1984 OU1 Removal Action Cleanup Goals for Surface Soil	24

Table 3: 1992 OU1 Removal Action Cleanup Goals for Surface Soil	25

Table 4: Summary of OU1 Ground Water Treatment Standards	28

Table 5: Summary of OU2 Soil Cleanup Goals	30

Table 6: Progress on Recommendations from the 2012 Addendum to the 2008 FYR	34

Table 7: Previous and Current ARARs for Ground Water COCs	41

Table 8: Deed Documents from Dougherty County Public Records Office	42

Table 9: Institutional Control (IC) Summary Table	42

Table 10: Current Site Issues	61

Table 11: Recommendations to Address Current Site Issues	62

Table F-l: Comparison of 2012 Ground Water Concentrations to VISLs	F-l

Table F-2: Assumptions Used in the JEM Model for Ground Water	F-2

Table F-3: Evaluation of Vapor Intrusion Using EPA's Screening Ground Water JEM	F-3

Table F-4: Evaluation of Toxicity Value Changes on Health-Based Cleanup Goals for Ground

Water	F-4

Table F-5: Evaluation of Toxicity Value Changes on Health-Based Cleanup Goals for OU1

Surface Soil	F-5

Table F-6: Evaluation of Toxicity Value Changes on Health-Based Cleanup Goals for OU2

Surface Soil	F-6

Table F-7: Toxicity Value Comparison Table	F-8

Figures

Figure 1: Site Location Map	20

Figure 2: Site Detail Map	21

Figure 3: Institutional Control Base Map			43

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Figure 4: Ground Water Monitoring Well Locations	45

Figure 5: EDB Concentrations, 2008-2012	46

Figure 6: Toxaphene Concentrations on the THAN Parcel, 2008-2012	47

Figure 7: Toxaphene Concentrations on the Jones Parcel, 2008-2012	48

Figure 8: Beta-BHC Concentrations, 2008-2012			49

Figure 9: DDT Concentrations, 2008-2012	 50

Figure 10: Total Xylene Concentrations, 2008-2012 	 51

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List of Acronyms

alpha-BHC

Alpha-hexachloroethane

ARAR

Applicable or Relevant and Appropriate Requirement

beta-BHC

Beta-hexachloroethane

BRA

Baseline Risk Assessment

CERCLA

Comprehensive Environmental Response, Compensation and Liability Act

CFR

Code of Federal Regulations

CIC

Community Involvement Coordinator

COC

Contaminant of Concern

COPC

Contaminant of Potential Concern

CSF

Oral Cancer Slope Factor

DDT

Dichloro-diphenyl-trichloroethane

EDB

1,2-dibromoethane

EPD

Georgia Environmental Protection Division

EPA

United States Environmental Protection Agency

ESD

Explanation of Significant Differences

FYR

Five-Year Review

GAC

Granulated Activated Carbon

gpm

Gallons per Minute

HI

Hazard Index

IC

Institutional Control

IUR

Inhalation Unit Risk Factor

JEM

Johnson and Ettinger Model

LTTD

Low Temperature Thermal Desorption

MCL

Maximum Contaminant Level

mg/kg

Milligram per Kilogram

M-g/L

Microgram per Liter

NAPL

Nonaqueous Phase Liquid

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OCP

Organochlorine Pesticide

OU

Operable Unit

PCE

T etrachloroethylene

PRG

Preliminary Remediation Goal

PRP

Potentially Responsible Party

RAO

Remedial Action Objective

RfC

Reference Concentration

RfD

Reference Dose

RI/FS

Remedial Investigation/Feasibility Study

ROD

Record of Decision

ROST

Rapid Optical Screening Tool

RPM

Remedial Project Manager

RSL

Regional Screening Level

THAN

T. H. Agriculture & Nutrition, LLC (formerly T. H. Agriculture & Nutrition



Company, Co.)

UAO

Unilateral Administrative Order

4

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VISL	Vapor Intrusion Screening Level

VOC	Volatile Organic Compound

WCC	Woodward-Clyde Consultants

5

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Executive Summary
Introduction

The 12-acre T.H. Agriculture and Nutrition Co. (Albany Plant) Superfund site (the Site) is
located in Albany, Dougherty County, Georgia. Past activities at the Site included formulation
and packaging of agricultural chemicals, fertilizer blending, and retail fertilizer and pesticide
sales. These activities used pesticides, herbicides and solvents that resulted in ground water and
soil contamination at the Site.

The Site includes two parcels of land, the western 7-acre T.H. Agriculture & Nutrition Company,
Co., or THAN, Parcel, and the eastern 5-acre Jones Parcel. A 10-to- 12-foot vegetated utility
easement extends between the two parcels. In 1984, under Georgia Environmental Protection
Division (EPD) oversight, THAN conducted extensive removal activities on the 7-acre THAN
Parcel. Based on contamination discovered during the response actions and investigations, the
United States Environmental Protection Agency placed the entire 12-acre Site on the National
Priorities List (NPL) in 1989.

EPA defined two operable units (OUs) for the Site to better address the contamination and
cleanup of the different site media. OU1 addressed the soil contamination on the western parcel
(the THAN Parcel) and sitewide ground water and associated nonaqueous phase liquid (NAPL).
OU2 addressed the soil contamination on the eastern parcel (the Jones Parcel). EPA selected a
remedy for OU1 in the Site's 1993 Record of Decision (ROD). The remedy required treatment of
ground water and determined that a 1992 removal action had fully addressed the threat posed by
contaminated soils. In 1995, EPA issued an Explanation of Significant Differences (ESD) to
update the ground water treatment technology, disposal method and the treatment process to
address NAPL. EPA selected the OU2 remedy in the Site's 1996 ROD. The remedy required
excavation and treatment of contaminated soil, confirmatory sampling and air monitoring.

The triggering action for this five-year review (FYR) was the signing of the previous FYR on
September 9, 2008.

Remedy Selection

The 1993 OU1 ROD stated that the goal of the remedial action is to restore the ground water in
the Residuum and upper Ocala aquifers to its beneficial use (as drinking water) at the Site. The
1996 ROD for OU2 selected a remedy to reduce risks of industrial worker exposure to surface
soil to a 1 x 10-5 risk level and prevent ground water impacts from migration of organic
compounds in subsurface soil.

Technical Assessment

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contaminant trends and plume migration and determined that the ground water plumes are not
migrating laterally off site despite fluctuations in concentrations within source areas;
contaminant concentrations have decreased or remained stable in the boundary wells; and
localized areas of elevated ground water contamination remain within the THAN Parcel.
Although these localized areas may continue to act as a possible continuing sources, this
migration pathway may not be significant as evidenced by boundary well concentrations. The
ground water remedy has not been effective because 2012 ground water data indicate that
toxaphene and xylene have fluctuated significantly during this FYR review period. Using PRP
provided cross-sections and data, EPA performed a data analysis on 21 years of analytical data.
The results of that analysis indicate that concentrations are moving downward in the central part
of the Site. In addition, toxaphene and beta-hexachloroethane (beta-BHC) concentrations remain
stable but above cleanup goals at two northern property boundary wells of the THAN Parcel.
EPA is currently discussing whether optimizations to the ground water remedy or new remedial
alternatives should be considered with Site's PRPs and EPD.

Institutional controls restricting ground water use as required by the OU1 ROD have been put in
place at the THAN Parcel but have not been put in place for ground water at the Jones Parcel or
the easement. Although the 1993 OU1 ROD did not include a soil component remedy, it did
indicate that the 1992 removal action completely addressed soil on the THAN Parcel. An
evaluation of the Site's institutional controls found that additional institutional controls are
needed to help ensure protectiveness at the Site. Subsurface soil contaminant concentrations on
the THAN and Jones Parcels exceed the industrial-based cleanup goals and potentially are not
within the cumulative acceptable risk range for industrial use. Institutional controls restricting
disturbance of subsurface soil during activities such as excavation/construction should be put in
place for the THAN and Jones Parcels.

Exposure assumptions used during remedy selection remain valid. The Site remains in continued
industrial use. Jones Welding and Industrial Supply operates on the Jones Parcel. Human health
risks associated with the vapor intrusion exposure pathway in on-site buildings had not been
previously quantified. Vapor intrusion exposure at the Site pertains to 1,2-dibromoethane (EDB)
and xylene. The results of the screening-level vapor intrusion evaluation indicate that the EDB
and xylene in ground water do not pose an indoor air concern for the on-site buildings on the
Jones Parcel.

Ground water cleanup goals are slightly less stringent than tap water regional screening levels
(RSLs). Removal action cleanup goals for surface soil at OU1 and cleanup goals for surface soil
at OU2 remain valid. Contaminant concentrations remain in subsurface soil above the
established industrial risk-based cleanup goals. While toxicity factors for a number of the COCs
have changed since EPA issued the Site's RODs, the cleanup levels remain valid. Ground water
monitoring has indicated that xylene exceeds the federal MCL and EPA Region 4's
recommended value of 3,500 jag/L on site but continues to be below criteria at the boundary
wells. Toxaphene parlars have been detected in ground water above the Region 4 preliminary
remediation goal (PRG). However, only recently has EPA approved an analytical method for
toxaphene parlars. Further evaluation of toxaphene parlars and impacts to remedy protectiveness
cannot be determined until EPA has established toxicity values for toxaphene parlars and
commercial laboratories are certified in toxaphene parlar analysis. The ground water remedy
remains protective in the short term because the active business on the Jones Parcel obtains
potable water from the public water supply and ground water use restrictions are in place at the
THAN Parcel.

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Conclusion

The remedy at OU1 currently protects human health and the environment in the short term
because exposure pathways that could result in unacceptable risks are being controlled. The
removal action addressed surface soil contamination to meet industrial-based cleanup goals,
institutional controls restricting residential use are in place, and there are no potable ground
water uses at the Site. However, the ground water remedy has not been effective to date in
significantly reducing contaminant concentrations below cleanup goals. In order for the remedy
to be protective in the long term, the following actions need to be taken to ensure protectiveness.

• Develop ground water remediation alternatives to address ground water exceedances.

• Address the need for additional remedial action for the remaining subsurface soil
contamination at OU1 using the EPA decision-making process.

• Perform a well survey.

• Implement ground water institutional controls for ground water at the Jones Parcel and
the easement area.

• Include toxaphene parlars in future monitoring once EPA has established toxicity criteria
and commercial laboratories are available that are certified in toxaphene parlar analysis.

• Optimize future monitoring by submitting high concentration range samples as separate
laboratory batches from low concentration range samples.

The remedy at OU2 currently protects human health and the environment in the short term
because exposure pathways that could result in unacceptable risks are being controlled. The
remedy addressed surface soil contamination and institutional controls restricting residential use
are in place. However, in order for the remedy to be protective in the long term, the following
action needs to be taken to ensure protectiveness.

• Address the need for additional remedial action for the remaining subsurface soil
contamination at OU2 using the EPA decision-making process.

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Five-Year Review Summary Form

Lead agency: EPA

If "Other Federal Agency" selected above, enter Agency name: Click here to enter text.

Author name: Lynette Wysocki and Claire Marcussen (Reviewed by EPA)
Author affiliation: Skeo Solutions

Review period: March 2013 - September 2013
Date of site inspection: 04/30/2013
Type of review: Statutory
Review number: 3

Triggering action date: 09/09/2008

Due date (five years after triggering action date): 09/09/2013

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Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:
None

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1

Issue Category: Remedy Performance

Issue: The ground water remedy has not been effective to date in
significantly reducing contaminant concentrations below cleanup goals.

Recommendation: Develop ground water remediation alternatives to
address continuing ground water exceedances.

Affect Current
Protectiveness

Affect Future
Protectiveness

Implementing
Party

Oversight
Party

Milestone Date

No

Yes

PRPs

EPA

09/30/2014

OU(s): 1

Issue Category: Remedy Performance

Issue: COCs have been detected above cleanup goals in two wells at the
northern boundary of the THAN parcel.

Recommendation: Perform a well survey to determine contaminant
migration and to create a record of well locations and number of nearby
municipal and domestic wells.

Affect Current
Protectiveness

Affect Future
Protectiveness

Implementing
Party

Oversight
Party

Milestone Date

No

Yes

EPA

EPA

09/30/2014

OU(s): 1

Issue Category: Institutional Controls

Issue: Institutional controls required in the OU1 ROD restricting sitewide
ground water use have not been implemented at the Jones Parcel or the
easement.

Recommendation: Work with EPA, PRPs and property owners to
implement ground water institutional controls.

Affect Current
Protectiveness

Affect Future
Protectiveness

Implementing
Party

Oversight
Party

Milestone Date

No

Yes

Other: PRPs,
Property Owners

EPA

09/30/2014

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OU(s): 1 , 2

Issue Category: Remedy Performance

Issue: Contaminant concentrations remain in subsurface soil at the Site
above the established industrial risk-based cleanup goals.

Recommendation: Address the need for additional remedial action for
the remaining subsurface soil contamination at the Site using the EPA
decision-making process.

Affect Current
Protectiveness

Affect Future
Protectiveness

Implementing
Party

Oversight
Party

Milestone Date

No

Yes

EPA

EPA

09/30/2014

OU(s): 1

Issue Category: Remedy Performance

Issue: Weathered toxaphene results in the formation of degradation
products, known as toxaphene parlars. Depending on the distribution of
toxaphene parlars, their presence and concentration may impact future
remedies at the Site.

Recommendation: Include toxaphene parlars in future monitoring once
EPA has established toxicity criteria and commercial laboratories are
available that are certified in toxaphene parlar analysis.

Affect Current
Protectiveness

Affect Future
Protectiveness

Implementing
Party

Oversight
Party

Milestone Date

No

Yes

EPA

EPA

09/30/2014

OU(s): 1

Issue Category: Monitoring

Issue: Ground water analysis reporting limits for EDB are too high to
detect EDB at concentrations at the MCL in boundary wells.

Recommendation: Optimize future monitoring by submitting high
concentration range samples as separate laboratory batches from low
concentration range samples.

Affect Current
Protectiveness

Affect Future
Protectiveness

Implementing
Party

Oversight
Party

Milestone Date

No

Yes

PRP

EPA

09/30/2014

Protectiveness Statement(s)

]

Operable Unit:	Protectiveness Determination:	Addendum Due Date

1	Short-term Protective	(if applicable):

Click here to enter date.

Protectiveness Statement:

The remedy at OU1 currently protects human health and the environment in the short term
because exposure pathways that could result in unacceptable risks are being controlled. The

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removal action addressed surface soil contamination to meet industrial-based cleanup goals,
institutional controls restricting residential use are in place, and there are no potable ground
water uses at the Site. However, the ground water remedy has not been effective to date in
significantly reducing contaminant concentrations below cleanup goals. In order for the
remedy to be protective in the long term, the following actions need to be taken to ensure
protectiveness.

• Develop ground water remediation alternatives to address ground water exceedances.

• Address the need for additional remedial action for the remaining subsurface soil
contamination at OU1 using the EPA decision-making process.

• Perform a well survey.

• Implement ground water institutional controls for ground water at the Jones Parcel and the
easement area.

• Include toxaphene parlars in future monitoring once EPA has established toxicity criteria
and commercial laboratories are available that are certified in toxaphene parlar analysis.

• Optimize future monitoring by submitting high concentration range samples as separate
laboratory batches from low concentration range samples.

Operable Unit:
2

Protectiveness Determination:
Short-term Protective

Addendum Due Date

(if applicable):

Click here to enter date.

Protectiveness Statement:

The remedy at OU2 currently protects human health and the environment in the short term
because exposure pathways that could result in unacceptable risks are being controlled. The
remedy addressed surface soil contamination and institutional controls restricting residential
use are in place. However, in order for the remedy to be protective in the long term, the
following action needs to be taken to ensure protectiveness.

• Address the need for additional remedial action for the remaining subsurface soil
contamination at OU2 using the EPA decision-making process.

Sitewide Protectiveness Statement (if applicable)

For sites that have achieved construction completion, enter a sitewide protectiveness
determination and statement.

Protectiveness Determination
Choose an item.

Protectiveness Statement:

Not Applicable

Addendum Due Date (if applicable):
Click here to enter date.

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Five-Year Review Summary Form (continued)

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Third Five-Year Review Report
for

T.H. Agriculture and Nutrition Co. (Albany Plant) Superfund Site
1.0 Introduction

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a
remedy in order to determine if the remedy will continue to be protective of human health and
the environment. FYR reports document FYR methods, findings and conclusions. In addition,
FYR Reports identify issues found during the review, if any, and document recommendations to
address them.

The United States Environmental Protection Agency prepares FYRs pursuant to the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section
121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
CERCLA Section 121 states:

If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often than each 5 years after the initiation of such remedial action to assure
that human health and the environment are being protected by the remedial action being
implemented. In addition, if upon such review it is the judgment of the President that
action is appropriate at such site in accordance with section [104] or [106], the President
shall take or require such action. The President shall report to the Congress a list of
facilities for which such review is required, the results of all such reviews, and any
actions taken as a result of such reviews.

EPA interpreted this requirement further in the NCP, 40 Code of Federal Regulations (CFR)
Section 300.430(f)(4)(ii), which states:

If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after initiation of the selected remedial action.

Skeo Solutions, an EPA Region 4 contractor, conducted the FYR and prepared this report
regarding the remedy implemented at the T.H. Agriculture and Nutrition Co. (Albany Plant)
Superfund site (the Site) in Albany, Dougherty County, Georgia. EPA's contractor conducted
this FYR from March to September 2013. EPA is the lead agency for developing and
implementing the remedy for the potentially responsible party (PRP)-financed cleanup at the
Site. The Georgia Environmental Protection Division (EPD), as the support agency representing
the State of Georgia, has reviewed all supporting documentation and provided input to EPA
during the FYR process.

This is the third FYR for the Site. The triggering action for this statutory review is the previous
FYR. The FYR is required due to the fact that hazardous substances, pollutants or contaminants

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remain at the Site above levels that allow for unlimited use and unrestricted exposure. The Site
consists of two operable units (OUs). This FYR Report addresses all site OUs.

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2.0 Site Chronology

Table 1 lists the dates of important events for the Site.

Table 1: Chronology of Site Events

Event

Date

Agricultural chemicals formulated and packaged on T.H. Agriculture and
Nutrition Co. (THAN) Parcel

1950s-1982

Agricultural chemicals formulated and packaged on Jones Parcel

1964-1973

Thompson-Hayward Chemical Company (later renamed T.H. Agriculture &
Nutrition Co.) purchased THAN Parcel from Planters Chemical Company

1967

Gold Kist, Inc. operated fertilizer blending and retail fertilizer and pesticide
operations on Jones Parcel

1973-1981

THAN ceased pesticide formulation operations on THAN Parcel

1982

Site PRPs initiated site inspection, investigation and preliminary cleanup to
include removal of residual product materials such as containers and related
items on THAN Parcel

December 1982

Applied Engineering and Science completed initial site activities on THAN
Parcel

April 1983

Site PRPs began removal action on THAN Parcel

July 23, 1984

EPD performed preliminary assessment on THAN Parcel

August 1, 1984

Site PRPs completed removal action on THAN Parcel

September 26, 1984

Sun Kist, Inc. sold Jones Parcel to Larry Jones

Jones Welding and Industrial Supply, Inc. began operations on Jones Parcel

1985

EPA conducted site inspection

September 17, 1985

EPA proposed Site to National Priorities List (NPL)

June 24, 1988

EPA finalized Site on NPL

March 31, 1989

EPA issued Administrative Order on Consent for OUI

Site PRPs initiated Site's remedial investigation/feasibility study (Rl/FS) for

OUI

July 6, 1990

Site PRPs completed baseline risk assessment

February 15, 1992

Site PRPs began removal action at OU1

March 23, 1992

EPA issued Unilateral Administrative Order (UAO) for OU 1

March 30, 1992

Site PRPs began RI/FS for OU2

January 20, 1993

Site PRPs completed RJ/FS for OU 1

EPA issued Record of Decision (ROD) for OUI

May 21, 1993

EPA issued UAO for OU2

October 25, 1993

Site PRPs began remedial design for OU 1

November 1, 1993

Site PRPs completed OUI removal action

December 31,1993

Site PRPs completed remedial design and began remedial action for OU 1

November 29, 1995

EPA issued Explanation of Significant Differences (ESD) for OU 1

December 1995

Site PRPs completed OU2 RJ/FS
EPA issued ROD for OU2

April 26, 1996

Site PRPs began construction of OU 1 remedy

April 29, 1996

Site PRPs completed construction of OU 1 remedy

April 2, 1997

EPA and site PRPs signed Consent Decree for OU2

March 25, 1997

Site PRPs began remedial design for OU2

June 19, 1997

Site owner filed restrictive covenant with Dougherty County

November 3, 1997

Site PRPs completed OU2 remedial design
Site PRPs began remedial action for OU2

September 29, 1998

Site PRPs began construction of OU2 remedy

August 9, 1999

Site PRPs completed construction of OU2 remedy

January 3, 2000

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Event

Date

EPA identified laboratory irregularities for OU2 soil samples

February 2000

Site PRPs conducted additional confirmatory soil sampling

Summer 2000

EPA and site PRPs signed Consent Decree for OU1

May 28, 2002

Site PRPs discontinued use of ground water treatment system

2003

EPA signed first FYR for OU 1

September 4, 2003

Site PRPs began ground water bioremediation pilot treatability study

October 2003

EPA issued Administrative Order on Consent

October 2, 2003

EPA issued Administrative Order on Consent

July 28, 2004

EPA signed first FYR for OU2

January 31, 2006

Site PRPs completed study reviewing OU2 contaminated subsurface soils

March 2006

Site PRPs completed ground water bioremediation pilot treatability study and
submitted report to EPA

November 2007

EPA signed first sitewide FYR

September 9, 2008

EPA signed Addendum to 2008 FYR

September 28,2012

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3.0 Background

3.1 Physical Characteristics

The 12-acre Site is located in Albany, Dougherty County, Georgia (Figure 1). It includes
two parcels and a utility easement. T. H. Agriculture & Nutrition, LLC (formerly T. H.
Agriculture & Nutrition Company, Co., or THAN) owns the western 7 acres of the Site,
which are located at 1401 Schley Avenue (the THAN Parcel). The THAN Parcel is
Dougherty County property parcel #000MM/00006/009. The THAN Parcel is fenced and
has a locked gate. Jones Family Properties, LLC owns the eastern 5 acres (the Jones
Parcel), located at 1359 Schley Avenue. The Jones Parcel is Dougherty County property
parcel #000MM/00006/01(). An unpaved but vegetated utility easement about 10 to 12
feet wide separates the two parcels.

The Site contains 50 monitoring wells, two extraction wells and five injection wells.
Figure 2 shows the on-site features. OU1 includes soil contamination on the THAN
Parcel and sitewide ground water. The source contamination on the Jones Parcel is
referred to as OU2. Former activities on both of the Site's parcels, including formulation
and packaging of agricultural chemicals, fertilizer blending, and retail fertilizer and
pesticide sales, resulted in ground water and soil contamination at the Site.

Schley Avenue borders the Site to the south. A property occupied by Interstate Leasing, a
trucking company, borders the Site to the north. The Seaboard Coastline Railway line
runs along the western edge of the THAN Parcel. Lightly populated residential areas are
located to west and southwest of the Site. A commercial area and a few residences border
the Jones Parcel to the east. There is an elevated expressway about 300 feet south of the
Site and a large commercial section of Albany further south. The 2011 Census estimated
that 77,683 people live in the City of Albany.

The area surrounding the Site is drained by the Flint River and Kinchafoonee Creek
systems. Kinchafoonee Creek, located about 0.4 miles east of the Site, is the nearest
natural body of surface water. However, there are no swales, drainage ditches or
intermittent streams that act as completed surface water pathways from the Site to these
surface waters. The sedimentary units outcropping in Dougherty County range from
Quaternary to Cretaceous in age. Only the uppermost geologic units consisting of the
Residuum, the Ocala Limestone, the Claiborne Group and the Wilcox Group are pertinent
to the Site. The Residuum is typically comprised of silty-clay with minor varying
amounts of sand, limestone fragments and lignite. It has an average thickness on site of
about 26 feet and thickens to the northwest. The Residuum overlies the Ocala Limestone.
The Ocala consists of medium- to fine-grained highly weathered, fossiliferous limestone
with some silt and sand.

The 1993 OU1 Record of Decision (ROD) reported no known critical habitats or
endangered species affected by site contaminants. The water table is relatively close to
the land surface. Infiltration of rainfall through the surficial sediments and the upper
limestones is the major source of recharge to the aquifers. Laboratory permeability and

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slug tests within the upper 30 feet of Residuum and limestone show that the actual
physical movement of water (vertically or horizontally) is very small. Except for the
existence of some paths of preferential ground water flow in the more brittle and
permeable sections of the limestone, the volume of ground water flowing laterally
through the Site is relatively small.

19

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0 skeo

T.H. Agriculture and Nutrition (Albany) Superfund Site
Albany. Dougherty County, Georgia

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for
informational purposes only regarding EPA's response actions at the Site.



Albany

T.H. Agriculture and
Nutrition (Albany)
Superfund Site

* t*
Area

20

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Figure 2: Site Detail Map

250 500

1,000
Hi Feet

Legend

— -¦ Site Boundary

T.H. Agriculture and Nutrition (Albany) Superfund Site

Albany, Dougherty County, Georgia	/

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for
informational purposes only regarding HPA's response actions at the Site.

21

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3.2	Land and Resource Use

Beginning in the 1950s, a formulation and packaging plant for agricultural chemicals
operated on the THAN Parcel. Currently, the parcel contains a warehouse that houses the
ground water treatment system; the remainder of the parcel is vacant. The current
landowners do not have any plans to lease or redevelop the parcel in the near future.

From 1964 until 1981, a formulation and packaging plant for agricultural chemicals also
operated on the Jones Parcel facility. Fertilizer blending as well as retail fertilizer and
pesticide activities also took place on the Jones Parcel. Since 1985, the Jones family has
operated a welding supply facility and associated office space on the parcel. There is no
anticipated change in land use or ownership for this property in the near term. Both
parcels are zoned for light industrial use. Restrictive covenants have been put in place to
prevent residential use of either parcel.

Industrial and commercial land areas surround the Site. A brick manufacturing facility
originally occupied the property immediately north of the THAN Parcel. Later, the
Spillman Company used the property immediately north of the THAN Parcel to produce
aggregate and asphalt. Interstate Leasing, a trucking company, now occupies the property
immediately north of the THAN Parcel. Residential areas are located within a mile of the
Site. Residential growth in these areas is expected to continue.

There are 19 City of Albany municipal wells located within 3 miles of the Site. Many of
these public supply wells are deep wells, with total depths ranging from 700 to 800 feet
below ground surface. However, the shallowest open portion of these wells is 260 feet
below ground surface. Woodward-Clyde Consultants (WCC) conducted a residential well
survey to identify any private wells within a 3-mile radius of the Site in 1992. WCC
identified a number of private wells in both Dougherty and Lee counties. Most residents
of Dougherty County used the city's public water supply as the sole source of drinking
water, while residents of Lee County (about 0.5 mile north of the Site) use private wells.

The well survey did not identify private wells within a half-mile of the Site, although it is
possible that unrecorded wells may exist. The 1992 remedial investigation (RI) for OU1
determined that private residential wells surrounding the Site were not affected by site-
related contamination. However, an updated confirmatory well survey has not been
conducted since then. The aquifer under the Site is a Class 2A water resource. According
to EPD records, non-municipal public supply wells exist just outside the half-mile radius
of the Site. The 2012 FYR Addendum concluded that there is no apparent migration of
contamination in ground water horizontally at the Site.

3.3	History of Contamination

From the 1950s until 1982, a formulation and packaging plant for agricultural chemicals
operated on the THAN Parcel. The Thompson-Hayward Chemical Company (later
renamed T.H. Agriculture & Nutrition Co.) purchased the THAN Parcel from Planters
Chemical Company in 1967. Year-end inventory records for the Thompson-Hayward
Chemical Company date to 1973. They indicate that insecticides handled on site included

22

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lindane, 4,4-dichlorodiphenyl, dichlorodiphenyltrichloroethane, toxaphene, methyl
parathion, malathion and parathion. Herbicides handled on site included 2,4-
dichlorophenoxybutyric acid, amine and dinitrobutylphenol. Solvents used on site
included 1,1,1-trichloroethane.

Storage and distribution of these chemicals took place in a small warehouse formerly
located on the THAN Parcel. In the 1960s and 1970s, dry product formulation occurred
in another former building on the THAN property. The contiguous storage area to the
west of the dry product formulation building was used to house materials prior to their
use in dry formulations. Trucks carrying dry products were routinely swept out in the
yard adjacent to the warehouse. Liquid pesticide formulation occurred on the THAN
Parcel from about 1973 until 1978. During liquid formulation operations, operators rinsed
the blending tank between batches with xylene and then discharged it into a drainage
ditch. The drainage ditch ran east to west across the THAN Parcel, from behind the liquid
formulations building to the low-lying area in the southwestern portion of the parcel.

Very little pesticide formulating took place after 1978. Business operations on the THAN
Parcel ended in 1982.

From 1964 into the 1970s, a formulation and packaging plant for agricultural chemicals
also operated on the Jones Parcel. Handling of agricultural chemicals likely started on the
Jones Parcel when the Southeastern Liquid Fertilizer Company, Inc. purchased the
. property in 1964. A succession of owners conducted dry and liquid pesticide formulation
operations. In 1973, Gold Kist, Inc. purchased the Jones Parcel and pesticide formulation
activities on the property ceased. Fertilizer blending and retail fertilizer and pesticide
activities continued until 1981. In 1985, Gold Kist sold the property to the late Mr. Larry
Jones.

The initial discovery of site contamination occurred in 1982 during a site visit conducted
by EPD officials. EPA began its involvement at the Site in 1983.

3.4 Initial Response

THAN contracted with Applied Engineering and Science in late 1982 to evaluate the
nature and extent of potential chemical residues from prior facility operations. These
activities included an inspection of suspected contaminated areas, preliminary cleanup of
residual product materials (containers and related items), and a subsequent investigation
into pesticides and solvents in soil and ground water. Applied Engineering and Science
performed these activities between December 1982 and April 1983.

Under EPD oversight, THAN conducted extensive removal activities on the THAN
Parcel from July 23, 1984, through September 26, 1984/THAN removed surficial soils in
accordance with a cleanup plan approved by EPD, which identified areas of soil
exceeding state cleanup criteria. Major removal activities included the demolition of
several buildings, excavation of selected surface soil and subsurface disposal areas,
installation of a perimeter fence, and establishment of a vegetative cover.

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THAN disposed of the excavated soil and debris off site in a permitted hazardous waste
landfill. During removal, about 10,400 tons of soil was excavated to meet EPD standards.
Cleanup activities also included the removal of an underground storage tank on the east
side of the Site. Analysis of surface soil samples collected during and following
excavation activities confirmed compliance of the surface soil with the state soil cleanup
criteria summarized in Table 2. Soil cleanup criteria are based on the protection of
ground water.

Table 2: 1984 OU1 Removal Action Cleanup Goals for Surface Soil

Leachability-based

Contaminant

Cleanup Level

(mg/kg)a'b

Dichloro-diphenyl-trichloroethane (DDT)

Lindane

Toxaphene

Notes:

a. As cited in the Removal Action Work Plan prepared by WCC,

March 31, 1992.

b. Cleanup criteria established by EPD based on leachable

organochlorine pesticide (OCP) concentrations as measured using

the Extraction Procedure Toxicity test method.

In March 1986, Applied Engineering and Science requested that another contractor
review existing site data and present the findings to THAN. Subsequent to the review and
in response to a request from EPD, contractors prepared a proposal to conduct additional
site studies to further characterize the ground water and explore potential remedial
options. Between 1986 and 1989, field activities included chemical analyses on selected
soil, ground water and surface water samples, and samples obtained from facility
structures.

Upon discovery of nonaqueous phase liquid (NAPL) in several monitoring wells, THAN
and EPD determined that additional fieldwork would be required. The scope of the
additional fieldwork included a ground water hydraulic study, a receptor survey, design
of a conceptual NAPL recovery system, and additional ground water sampling. Results
from preliminary NAPL recovery tests led to the installation of five 8-inch stainless steel
recovery wells, designated PR-1, PR-2, PR-3, PR-6 and PR-7, to evaluate the hydraulic
characteristics of the NAPL. Drilling and installation of the five recovery wells started on
January 9, 1988.

Following these initial response actions, and based on contamination discovered during
the response actions and investigations, EPA placed the Site on the National Priorities
List (NPL) on March 31, 1989. Pursuant to the Site's 1990 Administrative Order on
Consent, THAN, the OU1 PRP, agreed to conduct the remedial investigation/feasibility
study (RI/FS) at OU1. During RI activities conducted between July 1990 and May 1993,
a pit containing pure product and high levels of contamination under the former wet mix
building were identified. As a result, THAN conducted a second removal action in March
1992 under a Unilateral Administrative Order (UAO) from EPA.

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The removal action included demolition and removal of several on-site structures and
excavation and removal of the first foot of surface soil in areas of contamination. The
removal action excavated and removed contaminated subsurface soil and debris to 100
milligrams per kilogram (mg/kg) for total pesticides to prevent the leaching of pesticides
to ground water. The removal action removed over 24,700 tons of soil and shipped it to a
permitted hazardous waste landfill. THAN conducted on-site thermal desorption of
approximately 3,000 tons of excavated soil that could not be landfilled because it
contained greater than 1,000 mg/kg of total pesticides. THAN backfilled excavated areas
and established a vegetative cover. According to the March 31, 1992 Removal Action
Work Plan, removal action cleanup goals for surface soil were developed to achieve a 10"
6 risk level for industrial workers as summarized in Table 3.

Table 3: 1992 OU1 Removal Action Cleanup Goals for Surface Soil

Contaminant

Cleanup Level Based on
1 x 10"6 Industrial Risk
(mg/kg)a

DDT

7.2

Toxaphene

2.2

alpha-Hexachloroethane (alpha-BHC)

0.39

beta-Hexachloroethane (beta-BHC)

1.4

Notes:

a. Values from Removal Action Work Plan prepared by WCC,
March 31, 1992.

Post-removal confirmation samples from the THAN Parcel show that levels of
contamination in the in-situ soils on the western parcel have been decreased from greater
than 1,000 mg/kg of total pesticides to levels of less than 20 mg/kg total pesticides. In
addition, the top foot of soil was removed at approximately six of the seven acres on the
THAN Parcel with specific areas being excavated up to seven feet below land surface, as
shown in Appendix H.

3.5 Basis for Taking Action

Sampling during the OU1 RI established a ground water contamination plume that
extended underneath the Jones Parcel and a significant contamination source on the Jones
Parcel. RI results determined that organochlorine pesticides (OCPs) were the primary
contaminants of concern (COCs) in surface soil, subsurface soils and ground water at the
Site. The solvent xylene was also discovered at both pesticide formulation facilities. The
primary risk associated with the contamination discovered at the Site was from the lens of
NAPL floating on the surficial aquifer, which contained solvents that could facilitate the
release of the minimally soluble pesticides into the ground water. Floating NAPL has
been observed in monitoring wells located on the east-central portion of the THAN
Parcel and has been measured to be over 4 feet in thickness at some locations on the
THAN Parcel.

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EPA divided the Site into two OUs to better address the contamination and cleanup of the
different site media. OU1 addresses soil contamination on the western parcel (the THAN
Parcel) as well as ground water contamination and associated NAPL for the entire Site.
OU2 addresses soil contamination on the eastern parcel (the Jones Parcel).

The Site's February 1992 Baseline Risk Assessment (BRA) determined that surface soils
and surface water contained primarily herbicides and pesticides, while ground water
contained herbicides, pesticides and volatile organic compounds (VOCs). This is
consistent with the fate and transport characteristics of VOCs, since these compounds
would volatilize from surface soil and water over an extended period. In general,
chemical concentrations in soil and ground water were greatest in the parts of the Site
where pesticide formulation activities had occurred in the past (i.e., the eastern portion of
the Site), with a NAPL found underlying this area.

Generally, the presence of COCs in ground water appears localized in areas where NAPL
is present on the water table. The highest levels of COCs in ground water were found in
monitoring wells in the Upper Floridan Aquifer. This is also the zone where the NAPL is
predominantly found. Site characterization data indicate that concentrations of pesticides
in ground water samples decrease by an order of magnitude from the upper to the lower
water bearing zones of the Upper Floridan Aquifer.

The BRA evaluated potential human exposure to ground water, surface water and surface
soils for the incidental ingestion and dermal contact exposure routes. Also, individuals on
site or near the Site could be exposed to chemicals in contaminated ground water if a
shallow drinking water well was installed in this area. Potential exposure to fugitive dusts
at the Site was determined to be low and was not quantified. Although some of the
contaminants are volatile, vapor intrusion was not evaluated in the BRA. An evaluation
of off-site seeps, in conjunction with monitoring well data, indicated that seeps were not a
potential source for chemical exposure. The results of the BRA concluded that the
cumulative risks associated with ingestion exposure of on-site ground water were well
above EPA's upper bound of the acceptable risk range of 1 x 10~6 to 1 x 10"4 for both
residential and worker exposure. The noncancer hazard index of 1.0 was also exceeded
for both receptor groups. The BRA also concluded that direct ingestion and dermal
exposure to soil exceeded the upper bound of EPA's acceptable risk range and the
noncancer hazard index of 1.0 for both residential and worker exposures and the hazard
index of 1.0 for soils at OU1 and OU2. Surface water risks were well below 1 x 10"6, the
lower end of EPA risk range, and the noncancer hazard indices were well below the
threshold of 1.0.

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4.0 Remedial Actions

In accordance with CERC-LA and the NCP, the overriding goals for any remedial action are
protection of human health and the environment and compliance with applicable or relevant and
appropriate requirements (ARARs). A number of remedial alternatives were considered for the
Site, and final selection was made based on an evaluation of each alternative against nine
evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria
are:

1. Overall Protection of Human Health and the Environment

2. Compliance with ARARs

3. Long-Term Effectiveness and Permanence

4. Reduction of Toxicity, Mobility or Volume through Treatment

5. Short-Term Effectiveness

6. Implementability

7. Cost

8. State Acceptance

9. Community Acceptance

4.1 Remedy Selection

EPA divided the Site into two OUs. OU1 addresses soil contamination on the THAN
Parcel and sitewide ground water contamination. OU2 addresses soil contamination on
the Jones Parcel.

QUI: THAN Parcel Soil and Sitewide Ground Water

EPA selected the OU1 remedy for soils on the THAN Parcel of the Site and the ground
water and associated NAPL under the entire Site in the May 21, 1993 ROD. The selected
remedy indicated that cleanup objectives for OU1 were based on public health and
environmental concerns and were consistent with the NCP, EPA guidance, and state and
local regulations. The 1993 OU1 ROD stated that the goal of the remedial action is to
restore the ground water in the Residuum and upper Ocala aquifers to its beneficial use
(as drinking water) at the Site.

The selected remedy included the following components:

• Fencing of the Site and treatment facility.

• Extraction and on-site treatment of ground water by ultraviolet/oxidation
treatment with granular activated carbon (GAC) adsorption as a polishing step if
needed.

• Extraction and off-site incineration of NAPL.

• Drainage controls to divert runoff from the Site.

• Maintenance of the vegetative cover installed by the removal action.

• Institutional controls such as deed and land use restrictions.

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Cleanup objectives for OU1 soils were not specified because, according to the 1993
ROD, the 1992 removal action had fully addressed the threat posed by contaminated soils
by cleaning up soils to residential-based levels equivalent to a 1 x 10"6 risk. However,
according to the Removal Action Work Plan for OU1, soil was remediated to levels for
industrial worker exposure and a 1 x 10"6 risk.

The 1993 ROD stated that the pumping and treatment of ground water must continue
until treatment standards are met, followed by compliance monitoring of ground water
and soil for at least five years after ceasing treatment to ensure acceptable limits are
maintained. The 1993 ROD indicated if ground water compliance monitoring indicates
that the treatment standards are exceeded at any time after pumping has been
discontinued, extraction and treatment of the ground water will recommence until the
performance standards are once again achieved. Cleanup objectives for OU1 soils were
not specified because the 1992 removal action had fully addressed the threat posed by
contaminated surface soil. However, the 1993 ROD did specify that if monitoring of the
treated soil indicates treatment standards have been exceeded, the effectiveness of the
source control component will be reevaluated.

Table 4 provides a summary of the ground water treatment standards in the 1993 RQD.
According to the 1993 ROD, the contaminants presented in Table 4 were chosen based
on toxicity, mobility and frequency of detection throughout the Site. The 1993 ROD
stated that the COCs for which treatment standards were chosen for are not the only
contaminants at the Site. The ROD anticipated that contaminants at the Site that do not
have numerical cleanup levels presented will be reduced to acceptable levels when
cleanup levels are met for the most toxic and most mobile contaminants for which
cleanup levels have been established.

Table 4: Summary of OU1 Ground Water Treatment Standards

Contaminant

Treatment Standard

(Hg/L)a

Dibromoethane, 1,2-(EDB)

0.05"

Aldrin

0.54c

Dieldrin

0.57c

DDT

IT

alpha-BHC

4.r

beta-BHC

5.r

Toxaphene

3.0"

Notes:



a. According to the 1993 ROD, these standards are to be attained at the wells

designated by EPA as compliance points,
b. Maximum contaminant level (MCL).



c. 1 x lO"* risk-based cleanup goals, as MCLs have not been established for

these chemicals.



The 1993 ROD also provided for the implementation of contingency measures and goals,
if the selected remedy cannot meet specified remediation goals at any or all of the
monitoring points during implementation. The 1993 ROD indicated that the objectives of
the contingency measures are to:

28

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•	Prevent further migration of the plume.

•	Prevent exposure to the ground water and NAPL.

The key components of contingency measures are to:

•	Discontinue pumping at individual wells where cleanup goals have been attained.

•	Alternate pumping at wells to eliminate stagnation points.

•	Use pulse pumping to allow aquifer equilibration and encourage adsorbed
contaminants to partition into ground water.

•	Install additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.

In 1995, EPA issued an Explanation of Significant Differences (ESD) to update the
ground water treatment technology, disposal method, and treatment process for NAPL.
The 1995 ESD included the following changes:

•	Ground water treatment technology changed to the use of GAC alone;
ultraviolet/oxidation to be used only as a backup.

•	Ground water disposal method changed from using an infiltration gallery to the
use of infiltration wells and discharge to the Albany Wastewater Treatment
Facility for engineering reasons. If too much treated ground water is produced for
the wells, excess treated water will be discharged to the facility through the sewer
line under Schley Avenue.

•	Three dual-phase vacuum extraction wells will be used to extract ground water
and soil gas to remove NAPL more quickly. NAPL will continue to be taken off
site for incineration while soil gas will be treated with activated carbon, if
necessary.

OU2: Jones Parcel Soils

EPA selected the OU2 remedy for contaminated soil on the Jones Parcel in the Site's
April 26, 1996 ROD. The 1996 ROD for OU2 selected a remedy to reduce risks of
industrial worker exposure to surface soil to a 1 x 10-5 risk level and prevent ground
water impacts from migration of organic compounds in subsurface soil.

The selected remedy consisted of the following components:

•	Excavation of contaminated surface and subsurface soils.

•	Staging and preconditioning of soil for low temperature thermal desorption
(LTTD).

® Treatment of excavated soil by LTTD.

•	Placement of treated decontaminated soil back on the Site.

•	Periodic sampling of treated soil during the treatment process to verify the
effectiveness of the remedy.

•	Air monitoring to ensure safety of nearby residents and workers.

29

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• Ground water monitoring to ensure that metals contamination remaining in the
subsurface soil will not result in contaminated ground water migrating off site in
concentrations exceeding ground water protection standards. Institutional controls
such as deed restrictions to prevent ground water use were part of the OU1
remedy.

• Deed restrictions to prevent residential use of the property.

The surface soil cleanup levels for OU2 ensure treatment of contaminated soil to a health-
based cleanup level using a 1 x 10"5 risk level for carcinogenic contaminants and a hazard
quotient level of 1.0 for non-carcinogenic contaminants based on an industrial worker
exposure. A 1 x 10"5 risk level was chosen because it fell within EPA's acceptable risk
range of 1 x 10"4 and 1 x 10~6 and because it resulted in a significantly more cost-effective
remedy than the 1 x 10~6 risk level. The cleanup levels for contaminated subsurface soil
were based on protection of ground water. Table 5 summarizes the cleanup goals for
OU2 COCs.

Table 5: Summary of OU2 Soil Cleanup Goals

coc

Surface Soil

Subsurface Soil

(mg/kg)"'b

(mg/kg)ac

Manganese

337

4, 4-DDT

Ethylene dibromide

0.006

Methyl parathion

Toxaphene

Notes:

a. Values source: Table 8 of the 1996 ROD forOU2.

b. Based on an industrial worker exposure and a 1 x 10"5 cancer

risk or non-cancer hazard index of 1.0.

c. Based on protection of ground water.
NA: Not applicable

4.2 Remedy Implementation

Remedy implementation at the Site has been a complex undertaking. Remedial activities
are still underway in an effort to achieve performance goals established in the Site's
RODs.

QUI: THAN Parcel Soil and Sitewide Ground Water
Soil

No action was taken to further remediate the soils on the THAN Parcel.

Ground Water

EPA issued UAOs to six PRPs (Boise Cascade Corporation (now OfficeMax), Air
Products and Chemicals Inc., Hercules Inc., Gold Kist Inc., THAN and Philips
Electronics North America Corporation) associated with the Site, directing the companies

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to conduct remedial design and remedial action for site ground water. In 1993, the PRPs
began remedial design and initiated a treatability study consisting of four pilot tests that
continued for several years. The pilot tests evaluated the effectiveness of the dual-phase
extraction technology and three different ground water treatment options - GAC,
ultraviolet oxidation and air stripping. These tests were done to obtain operational
parameters for the design of the ground water treatment system. The pilot test for the
dual-phase vacuum extraction was ineffective.

The PRPs completed the remedial design and began the remedial action in November
1995. The PRPs began construction of the ground water extraction system in April 1996.
The system consisted of two extraction wells (EW-101 and EW-102) located on the Jones
Parcel, 80 to 100 feet east of the THAN Parcel. The wells were screened to remove water
from the upper 20 feet of the Ocala Limestone. The ground water extraction system
removed between one and seven gallons per minute (gpm), with an average of about one
gpm. The system's major components included a NAPL separator, a microfilter and
GAC. Treatability studies showed that microfiltration was necessary to remove
contaminants adsorbed to suspended solids.

By 2003, an estimated 3.5 million gallons of ground water had been recovered and
treated. However, COC concentrations remained largely unchanged within the plume
during this period. Due to the low recovery rate for the targeted COCs, operation of the
ground water treatment system ceased in 2003.

Following the discontinuation of the ground water treatment systems in 2003, a pilot
study evaluated bioremediation as a potential innovative technology and an alternative to
the ineffective original treatment strategy. The bioremediation pilot study was designed
to reduce concentrations of OCPs in the Site's subsurface soils to minimize the potential
for leaching to ground water. The pilot study focused on two hot spots in the Ocala
Limestone covering an area of about 2,000 square feet; the hot spots were identified
through the use of the Rapid Optical Screening Tool (ROST).

After testing various reagents, Daramend® Injection was selected as the one most likely
to reduce the concentrations of the OCPs. Daramend® is a proprietary reagent consisting
of organic material and zero-valent iron, which together stimulate anoxic bioremediation
by indigenous microorganisms. The Daramend® Injection study concluded that
bioremediation is ineffective at reducing contaminant concentrations given site
conditions. EPA confirmed this conclusion in November 2009.

The 2008 FYR recommended that site PRPs evaluate other options for the treatment of
the Site's ground water, and if necessary, consider implementing the 1993 ROD's
containment contingency. In 2012, EPA evaluated ground water contaminant trends and
plume migration and determined that the ground water plumes are not migrating laterally
despite fluctuations in concentrations within source areas; contaminant concentrations
have decreased or remained stable in the boundary wells; and localized areas of elevated
ground water contamination remain within the THAN Parcel. Although these localized
areas may continue to act as a possible continuing sources, this migration pathway may

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not be significant as evidenced by boundary well concentrations. EPA is currently
evaluating and discussing potential remedy optimizations and other alternatives with the
PRPs and EPD because ground water concentrations, while declining, still remain above
the treatment standards.

Removal of NAPL

No NAPL was observed in the NAPL separator during more than two years of operation
of the ground water treatment system. Therefore, the NAPL removal was considered
ineffective and the NAPL separator was bypassed in November 1998 in accordance with
a work plan submitted to EPA in February 1998.

Institutional Controls

Institutional controls restricting residential use and use of ground water at the THAN
Parcel have been implemented. Additional details regarding institutional controls at the
Site are discussed in Section 6.3 of this FYR Report.

Maintenance of the Cover

A local contractor maintains the vegetative cover on OU1 soils on an as-needed basis.

OU2: Jones Parcel Soils

Soil

A Consent Decree signed on March 25, 1997, directed Boise Cascade Corporation (now
OfficeMax), the lead PRP for OU2, to conduct the remedial design and remedial action
for surface and subsurface soil at OU2. Boise Cascade Corporation began the remedial
design in June 1997 and completed it in September 1998. The soil remedy required:
excavation of contaminated surface and subsurface soils; staging and preconditioning of
the soil; treatment of the soil by LTTD; placement of treated soil back on the Site;
periodic sampling of treated soil during the treatment process to verify the effectiveness
of the remedy; and air monitoring to ensure the safety of nearby residents and workers.
About 5,000 tons of soil were treated and placed back on the OU2 property. The remedial
action was completed in January 2000.

In February 2000, EPA Region 4 was notified that Intertek Testing Services, one of the
laboratories used by the PRP's contractor, had experienced potential problems during
analyses of the delineation samples collected during the remedial design. EPA Region 4
verbally notified the PRP of its discovery on March 15, 2000, concerning possible
inaccuracies in laboratory data collected for the remedial design. In the summer of 2000,
Boise Cascade Corporation and EPA Region 4 conducted independent sampling to
determine if contaminated soil remained at OU2. The analytical data indicated that an
estimated 2,800 tons of contaminated soil remains buried at a depth of between 12 and 16
feet in the formerly excavated area. The contaminated soil exceeds the leachability-based
cleanup goal of 0.006 mg/kg for 1,2-dibromoethane (EDB).

Institutional Controls

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An institutional control restricting residential use at the Jones Parcel has been put in
place. Additional details regarding institutional controls at the Site are discussed in
Section 6.3 of this FYR Report.

Ground Water Monitoring

Although the OU1 sitewide ground water remedy addressed ground water plumes
containing pesticides, it did not address metal contamination moving from soils at the
Jones Parcel into ground water. Therefore, a component of the selected remedy in the
Site's 1996 ROD called for annual ground water monitoring to ensure that metal
contamination remaining in the subsurface soil will not result in contaminated ground
water migrating off site at concentrations exceeding ground water protection standards.
Ground water sampling and monitoring has occurred at least annually, and often more
frequently, over the past five years. The last five years of monitoring data are discussed
in Section 6.4 of this FYR Report.

Operation and Maintenance (O&M)

THAN developed an O&M Plan in March 1997. The plan described system operating
procedures, inspection and maintenance procedures, and monitoring and sampling
activities for the Site. The 1993 ROD estimated that the total cost to implement the
selected remedy for OU1 would be $4.1 million. However, the 1993 ROD did not specify
estimated O&M costs associated with the OU1 remedy. The 1996 ROD estimated that the
total cost to implement the selected remedy for OU2 would be $2.5 million, with
$500,000 designated as the estimated O&M cost for the OU2 remedy.

The O&M contractor for the THAN Parcel does not consider O&M costs to be publicly-
available information. There is not an O&M presence at the Jones Parcel. O&M costs for
the Site are not included in this FYR Report.

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5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2012 Addendum to the 2008 FYR for the Site stated:

The remedy for OU1 currently protects human health and the environment in the short-term
because surface soils on the site have been excavated, and the exposure from direct soil contact
has been eliminated. Contaminated soils remain in the subsurface but the contaminated
ground water plume remains -within the property boundary and does not affect the municipal
drinking water wells, which are within a 3 mile radius from the site, or nearby private wells that
are upgradient of the Site. In order for the remedy to be protective in the long term, a well
survey will need to be completed, toxaphene parlars will need to be sampled for, and ICs will
need to be implemented on the Jones Parcel, restricting ground water usage.

The remedy for OU2 currently protects human health and the environment in the short-term and
long-term because surface soils on the site have been thermally treated and the exposure from
direct soil contact has been eliminated. Contaminated soils remain in the subsurface but the
contaminated ground water plume remains within the property boundary and does not affect the
municipal drinking water wells, which are within a 3 mile radius from the site, or nearby private
wells that are upgradient of the Site.

The 2012 Addendum to the 2008 FYR included actions taken and outcomes for the eight issues
and recommendations identified in the 2008 FYR. Table 6 summarizes the status of these issues
and recommendations.

Table 6: Progress on Recommendations from the 2012 Addendum to the 2008 FYR

Section

Recommendations
from 2008 FYR

Party
Responsible

Milestone
Date

Action Taken during
2012 Addendum and
Outcome

Date of
Action8

5.1

Explore/evaluate other
options for the treatment
of the Site's ground
water. If necessary,
consider implementing
the 1993 ROD'S
containment
contingency.

PRP

12/31/2009

EPA performed an
analysis of existing
ground water data and
concluded that the
contaminant plume is not
migrating horizontally,
and exhibits decreasing
trends in contaminant
concentrations across the
Site in a majority of wells
sampled. EPA is currently
evaluating and discussing
potential remedy
alternatives with the PRPs
and EPD.

April 2012b

34

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Section

Recommendations
from 2008 FYR

Party
Responsible

Milestone
Date

Action Taken during
2012 Addendum and
Outcome

Date of
Action'

5.2

Complete Agency
review of the
Daramend® Injection
for In-Situ

Bioremediation Report
and evaluate other
alternatives.

EPA

12/30/2010

The Daramend® Injection
for In-situ Bioremediation
Report was published in
November 2007. The
study concluded that the
use of Daramend® for
bioremediation is
ineffective at reducing
contaminant

concentrations given site
conditions.

November
2009

5.3

Perform necessary
studies in order to
determine whether the
OU2 subsurface soil
acts as a significant
continuing source and
whether additional
remediation may be
necessary.

EPA

12/30/2009

EPA Region 4 has
conducted an analysis of
the existing monitoring
well data at the Site and
determined that while
there are localized areas
of elevated ground water
contaminations within the
THAN Parcel, these areas
do not appear to act as
significant continuing
sources of contamination.
This conclusion is
supported by the lack of
lateral migration of the
ground water plume off
site and the stable or
decreasing concentrations
at site boundaries.

April 2012b

5.4

Continue annual
monitoring of ground
water contamination,
with special emphasis
on intermediate and
deep wells. Install
additional deep wells as
appropriate, if the
current deep wells do
not adequately monitor
the deep zone.

PRP

October
2008

Annual ground water
monitoring at the Site is
ongoing. Based on a
review of existing data,
there is no apparent
migration of ground water
contamination
horizontally at the Site.
However, concentrations
on site remain above
ground water cleanup
goals.

October 2008b

35

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Section

Recommendations
from 2008 FYR

Party
Responsible

Milestone
Date

Action Taken during
2012 Addendum and
Outcome

Date of
Action"

5.5

Work with Jones Parcel
and neighboring
property owners to
implement ground water
use restrictions.

PRPs

12/31/2009

Institutional controls
restricting ground water
use have not been
implemented on the Jones
Parcel. The parcel is
currently being leased by
Office Max and there are
no potable wells there.
EPA continues to work
with the owners of the
Jones property to
implement institutional
controls for ground water
use.c

Ongoing

5.6

Work with both
property owners to
implement

excavation/construction
institutional controls.

PRP

12/31/2009

Institutional controls
addressing excavation and
construction were
addressed at the time of
the 2008 FYR. As such,
they have been
implemented on both
properties, addressing
excavation/construction.d

September
2008d

5.7

Conduct well survey to
update locations and
number of nearby
municipal and domestic
wells. If wells are found
within a half-mile of the
Site, incrementally
sample for COCs.

PRPs

12/31/2009

A well survey has not
been conducted at the
Site.

Incomplete

5.8

Include toxaphene
degradation products
(parlars) as part of the
analytical suite.

PRPs

12/31/2009

A method for the analysis
of toxaphene degradation
products was approved by
EPA in September 2012.
As such, parlar analysis
has not yet been included
in the analytical suite at
the Site as currently a
commercial laboratory
that is certified to perform
the new method has not
been located.

April 2012b

a. Dates provided in Month/Year format in the 2012 Addendum to the 2008 FYR.

b. Date from the 2012 Addendum to the 2008 FYR; this recommendation remains ongoing.

c. This FYR confirmed that OfficeMax does not lease or own the Jones Parcel at the Site. OfficeMax
(formerly Boise Cascade) is the PRP for the Jones Parcel.

d. This FYR confirmed that excavation/construction institutional controls have not been implemented on
either parcel at the Site. This action is incomplete.

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5.1 New Ground Water Remedies or Remedy Optimization

EPA completed an analysis of the Site's ground water data in April 2012. EPA
determined that contaminant concentrations at a majority of monitoring wells across the
Site were decreasing. Concentrations were also decreasing at site boundaries. EPA
concluded that the plume was not migrating horizontally. EPA is currently evaluating
next steps regarding the Site's ground water remedy.

5.2 Bioremediation Report

The bioremediation pilot study using injection of the Daramend® compound began in
October 2003. Implementation was completed by November 2007. The final report on the
pilot study concluded that the injection of Daramend® did not enhance the preexisting
conditions or accelerate the processes already occurring at the Site sufficiently to justify
the expansion of the pilot study site wide. EPA reviewed the final report and concluded in
November 2009 that, given site conditions, the bioremediation is ineffective at further
reducing contaminant concentrations.

5.3 OU2 Subsurface Soil Acting as a Significant Continuing Source

Although the issue and recommendation from the 2008 FYR aimed to address subsurface
soils as a potential source at OU2 (the Jones Parcel), EPA's April 2012 evaluation
concluded that the plumes were not migrating laterally off site as evidenced by
decreasing concentrations at the site boundaries. However, this issue and
recommendation remains incomplete with respect to vertical migration of ground water
as EPA is currently evaluating concentrations trends across the intermediate and deeper
wells on site to determine the significance of this contaminant migration pathway..

5.4 Annual Ground Water Monitoring

Since October 2008, annual ground water monitoring at the Site has been ongoing. Based
on a review of existing data, EPA has concluded that there is no apparent contaminant
migration horizontally at the Site.

5.5 OU2 Ground Water Institutional Controls

Institutional controls restricting ground water use have not been put in place on the Jones
Parcel. The parcel operates as a welding facility and associated office space. OfficeMax
(formerly Boise Cascade) is the PRP for the Jones Parcel. EPA continues to work with
the owners of the Jones Parcel to put institutional controls restricting ground water use in
place on the Jones Parcel.

5.6 OU1 and OU2 Soil Institutional Controls

The 2012 Addendum to the 2008 FYR indicated that institutional controls addressing
excavation and construction were put in place at the completion of the 2008 FYR.

-------
However, this FYR confirmed that institutional controls have not been put in place for
either of the site parcels. As such, this recommendation is incomplete.

5.7	Well Survey

The 2008 FYR recommendation to conduct a well survey has not yet been implemented.
The recommendation was made due to the expansion of residential areas north and south
of the Site and because a determination had not been made on whether public water
supplies could be affected in the future by vertical migration of ground water
contamination. The 2012 FYR Addendum concluded that there is no apparent vertical or
horizontal migration of contamination in ground water at the Site. However, a well
survey should be performed to create a record of well locations and the number of nearby
municipal and domestic wells.

5.8	Toxaphene Degradation Products

The 2008 FYR recommended analysis of toxaphene degradation products, known as
parlars, as part of the analytical suite. At that time, an approved EPA method was not
available. According to the 2012 FYR Addendum, EPA approved an analytical method
for parlars in September 2012. However, to date, a commercial laboratory certified in
conducting toxaphene parlar analysis has not been located that can perform the analysis.
Until commercial laboratories are certified to perform the analysis, this issue and
recommendation will remain ongoing.

38

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6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in March 2013 and scheduled its completion for
September 2013. EPA's remedial project manager (RPM) James Hou led the EPA site
review team, which also included EPA hydrologist Ben Bentkowski, EPA community
involvement coordinator (CIC) L'Tonya Spencer, and contractor support provided to
EPA by Skeo Solutions. In June 2013, EPA held a scoping call with the review team to
discuss the Site and items of interest as they related to the protectiveness of the remedy
currently in place. The review schedule established consisted of the following activities:

• Community notification.

• Document review.

• Data collection and review.

• Site inspection.

• Local interviews.

• FYR Report development and review.

6.2 Community Involvement

In April 2013, EPA published a public notice in The Albany Herald newspaper
announcing the commencement of the FYR process for the Site, providing contact
information for RPM James Hou and CIC L'Tonya Spencer, and inviting community
participation. The press notice is available in Appendix B. No one contacted EPA as a
result of the advertisement.

EPA will make the final FYR Report available to the public. Upon completion of the
FYR, EPA will place copies of the document in the designated site repository: Dougherty
County Public Library, located at 300 Pine Avenue, Albany, Georgia 31701.

6.3 Document Review

This FYR included a review of relevant, site-related documents, including the ROD,
remedial action reports and recent monitoring data. Appendix A includes a complete list
of the documents reviewed.

ARARs Review

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of
cleanup of hazardous substance, pollutants, and contaminants released into the
environment and of control of further release at a minimum which assures protection of
human health and the environment." The remedial action must achieve a level of cleanup
that at least attains those requirements that are legally applicable or relevant and
appropriate.

-------
•	Applicable requirements are 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, remedial action, location or other circumstance
found at a CERCLA site.

•	Relevant and appropriate requirements are those standards that, while not
"applicable," address problems or situations sufficiently similar to those
encountered at the CERCLA site that their use is well suited to the particular site.
Only those state standards that are more stringent than federal requirements may
be applicable or relevant and appropriate.

•	To-Be-Considered criteria are non-promulgated advisories and guidance that are
not legally binding, but should be considered in determining the necessary
remedial action. For example, To-Be-Considered criteria may be particularly
useful in determining health-based levels where no ARARs exist or in developing
the appropriate method for conducting a remedial action.

Chemical-specific ARARs are health- or risk-based numerical values or methodologies
which, when applied to site-specific conditions, result in the establishment of numerical
values. These values establish an acceptable amount or concentration of a chemical that
may remain in, or discharged to, the ambient environment. Examples of chemical-
specific ARARs include MCLs under the federal Safe Drinking Water Act and ambient
water quality criteria enumerated under the federal Clean Water Act.

Action-specific ARARs are technology- or activity-based requirements or limits on
actions taken with respect to a particular hazardous substance. These requirements are
triggered by a particular remedial activity, such as discharge of contaminated ground
water or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances or the conduct of the
response activities solely based on their location in a special geographic area. Examples
include restrictions on activities in wetlands, sensitive habitats and historic places.

Remedial actions are required to comply with the chemical-specific ARARs identified'in
the ROD. In performing the FYR for compliance with ARARs, only those ARARs that
address the protectiveness of the remedy are reviewed.

Ground Water ARARs

The 1993 ROD established chemical-specific ARARs for two of the seven ground water
COCs based on the National Primary Drinking Water Standards (40 CFR Part 141). This
ARAR review examined current federal standards (federal drinking water MCLs) for any
changes in ARARs established by the 1993 ROD. As shown in Table 7, drinking water
standards have not changed for EDB or toxaphene. MCLs have not been established for
the remaining COCs, so the 1993 ROD used health-based values. These health-based
values are further discussed in Section 7.2 of this FYR Report.

40

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Table 7: Previous and Current ARARs for Ground Water COCs

COCs*

1993 ARARsc
(Hg/L)

Current
ARARs'1
(Hg/L)

ARAR
Change

EDBb

0.05

None

Toxaphene

None

alpha-BHC

NAe

beta-BHC

NA1

4, 4"-DDT

NAg

Aldrin

NAh

Dieldrin

NA'

Notes:

a. COCs from 1993 ROD.

b. Also known as ethylene dibromide.

c. The 1993 ROD listed the ARARs as cleanup goals for ground water COCs to include the federal
drinking water MCL for EDB and toxaphene. Cleanup goals for COCs without established MCLs
were health-based criteria (lxl0"4 risk level for carcinogens).

d. Based on federal MCLs. Federal primary MCLs are available at
httD://water.et>a.eov/drink/contaminants/index.cfm (last accessed 4/1/2013").

e. There is no MCL for alpha-BHC. Cleanup goal of 4.1 |ig/L based on health-based criteria (1 x
10"4 risk level for carcinogens)

f. There is no MCL for beta-BHC. Cleanup goal of 5.1 ng/L based on health-based criteria (1 x 10"4
risk level for carcinogens)

g. There is no MCL for 4, 4'-DDT. Cleanup goal of 27 |ig/L based on health-based criteria (1 x 10"4
risk level for carcinogens)

h. There is no MCL for aldrin. Cleanup goal of 0.54 |ug/L based on health-based criteria (lxl 0"4
risk level for carcinogens)

i. There is no MCL for dieldrin. Cleanup goal of 0.57 |ig/L based on health-based criteria (1 x 10"4
risk level for carcinogens)

NA: Not applicable

Soil ARARs

There are no chemical-specific soil ARARs for the Site identified in the decision
documents for either OU1 or OU2. The OU1 1993 ROD and the OU2 1996 ROD
identified cleanup goals for soil that were based on a soil risk assessment and the results
of a soil leachability model. They were not based on promulgated levels set in federal or
state regulations.

Institutional Controls Review

On April 30, 2013, contractor staff conducted research at the Dougherty County Public
Records Office and found deed information pertaining to the Site. There are three
restrictions filed with the Dougherty County Public Records, which act as institutional
controls for the Site, as shown in Table 8. The deed documents recording these
institutional controls are included in Appendix G. The institutional control base map for
the Site is included as Figure 3. Institutional controls restricting sitewide ground water

-------
use, as required in the 0U1 ROD, need to be put in place for the Jones Parcel and the
easement area.

Table 8: Deed Documents from Dougherty County Public Records Office

Date

Type of Document

Description

Book#

Page #

09/29/1997

Notice of Consent
Decree, Declaration of
Restrictive Covenant
and Grant of Access

Restricts residential land use at the Jones
Parcel (000MM/00006/010) and grants a
right of access to the Jones Parcel for the
purposes of conducting any activity related
to the Consent Decree

1741

163

11/17/1997

Declaration of
Restriction

Restricts use of ground water at the THAN
Parcel (000MM/00006/009)

1757

065

02/05/2002

First Amendment to
Declaration of
Restriction

Adds residential land use restriction for the
THAN Parcel (000MM/00006/009) to the
1997 Declaration of Restriction

1757

065

Table 9 lists the institutional controls associated with areas of interest at the Site.
Table 9: Institutional Control (IC) Summary Table

Media

ICs
Needed

ICs Called for
in the Decision
Documents

IC

Objective

Instrument in Place

Easement

Ground
Water

Yes

Yes

Restrict use of
ground water

None

Area of Interest - THAN Parcel 0001MM/00006/009

Ground
Water

Yes

Yes

Restrict use of
ground water

1997 Declaration of Restriction

Soil

Yes

Yes

Prohibit
residential use

2002 First Amendment to the
1997 Declaration of Restriction

Subsurface
Soil

Yes

No

Restrict
disturbance of
subsurface soil

None

Area of Interest-Jones Parcel 000MIV1/00006/010

Ground
Water

Yes

Yes

Restrict use of
ground water

None

Soil

Yes

Yes

Prohibit
residential use

1997 Notice of Consent Decree,

Declaration of Restrictive
Covenants and Grant of Access

Subsurface
Soil

Yes

No

Restrict
disturbance of
subsurface soil

None

42

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Figure 3: Institutional Control Base Map

Site Boundary

Parcel Boundary

8

CM

S?

o

500



Schley Ave

Institutional Controls

OOOMM/00006/009: 1997 Declaration of Re-Unction (restricts ground water use) and 2002 First Amendment
to Declaration of Restriction (no residential use)

QOOMM/0O0O6/010: 1997 Notice of Consent Decree. Declaration of Restrictive Covenant and Grant of
Access (no residential use and grants access for activities relating to the Consent
Decreet

T.H. Agriculture and Nutrition (Albany) Superfund Site

Albany, Dougherty County, Georgia

J

Disclaimer. This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response
actions at the Site.

43

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6.4 Data Review

0U1

Ground Water

According to the 2012 Addendum to the 2008 FYR, EPA evaluated ground water
contaminant trends and plume migration and determined that the ground water plumes
are not migrating despite fluctuations in concentrations within source areas; contaminant
concentrations have decreased or remained stable in the boundary wells; and localized
areas of elevated ground water contamination remain within the THAN Parcel. Although
these localized areas may continue to act as a possible continuing sources, this migration
pathway may not be significant as evidenced by boundary well concentrations. However,
because ground water remedies have not been effective to date in reducing ground water
contaminant concentrations below cleanup goals, EPA is currently evaluating and
discussing potential remedy alternatives with site PRPs and EPD.

To interpret ground water monitoring results during this FYR period, it is important to
understand how the leachability of the various pesticides at the Site determines the trends
observed for the different types of pesticides. Generally, EDB, alpha-BHC and dieldrin
leach more readily than beta-BHC, aldrin and toxaphene. DDT leaches the slowest of all.
Based on a review of the last four years of data, EDB was evaluated to represent the
highly leachable pesticides, as the concentrations for alpha-BHC and dieldrin were either
below detection or the detection limits were well below the cleanup goal. Toxaphene and
beta-BHC were evaluated to represent the moderately leachable grouping. Toxaphene
was routinely detected with concentrations well above cleanup goals. Beta-BHC was
generally below detection or below the cleanup goal, except along the northern boundary
of the THAN Parcel where concentrations are above the cleanup goal. Aldrin was not
included in the evaluation because it was either below detection or the detection limits
were well below the cleanup goal. DDT was evaluated to represent the slowest leaching
COC. Xylene was also considered because ground water monitoring has shown that its
concentrations have consistently exceeded the federal primary drinking water standards.
Also, it is a compound known to have been used at the Site during former operations.
Figure 4 shows monitoring well locations at the Site.

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Figure 4: Ground Water Monitoring Well Locations

125 250

500
|F»tt

Legend

Monitoring well
Property boundary

¦»

'

Site boundary

T.H. Agriculture and Nutrition (Albany) Superfund Site

Albany. Dougherty County, Georgia

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for
informational purposes only regarding EPA's response actions at the Site.

45

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EDB

From 2008 to 2012, EDB was below detection in all wells at the property boundary of the
THAN and Jones Parcels. EDB concentrations within the THAN Parcel were below
detection limits. However, EDB concentrations were above the cleanup goal of 0.05 (ig/L
in MW-39U on the Jones Parcel. Concentrations in MW-39U ranged from 0.38 ng/L to
0.63 |ag/L. From 2008 to 2012, the highest concentrations were observed in GB-3D, the
deep well at the western edge of the Jones Parcel. The highest concentration detected in
GB-3D was 200 (j.g/L in 2009, decreasing to 61 |ig/L in 2012. The intermediate well GB-
31 appears to be decreasing in concentrations while the deeper zone monitored in GB-3D
is increasing slightly. This may indicate that the contaminants may be migrating
vertically however additional evaluation over time is warranted as monitoring continues.
MW-UR2 is located between GB-3D and MW-39U. The highest concentration detected
in MW-33UR2 was 41 |ig/L in 2008, decreasing to 24 |ig/L in 2012 (Figure 5). As shown
in Figure 5, data were not obtained in 2011 for GB-3D or MW-39U, or for MW-33UR2
in 2009. The data collected during this FYR period indicated that most of the detection
limits for EDB were above the cleanup goal due to the need for diluting samples
containing high range VOCs results Resulting in a majority of the detection limits
exceeding 1 (j.g/L or higher. Based on these findings, it is recommended that future
monitoring activities consider submitting samples expected to contain high range VOCs
as a separate batch from samples expected to contain low range VOCs for laboratory
analysis in order to avoid elevated detection limits in low range samples.

Figure 5: EDB Concentrations, 2008-2012

Toxaphene

From 2008 to 2012, toxaphene was below detection in all of the boundary wells on the
Jones Parcel. However, it exceeded the cleanup goal of 3 (ig/L at the two northern
boundary wells on the THAN Parcel, MW-19U (12 |ig/L) and MW-36U (12 ng/L), in

46

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2012. These data indicate that concentrations of toxaphene are likely migrating to or
present at the northern boundary of the THAN Parcel. From 2008 to 2012, the highest
concentrations observed were in MW-N2, located on the eastern boundary of the THAN
Parcel on the east side of the warehouse. Concentrations ranged from 2.6 ng/L in 2008 to
a maximum of 29,000 |ig/L during the most recent sampling event in 2012 (Figure 6).
Concentrations at GB-02, located north of MW-N2 on the east side of the bioremediation
pilot project, were much lower. Concentrations at GB-02 ranged from a high of 220 (_ig/L
in 2008 to a low of 130 fig/L in 2012. The second highest concentrations were in MW-
81R and MW-8D, located at the southwest corner of the Jones Parcel. Concentrations
ranged from a low of 45 |_ig/L in MW-8D in 2008 to a high of 530 |j.g/L in both wells in
2012 (Figure 7). The concentrations gradually decrease going north, as indicated by GB-
31, and east, as indicated by MW-34UR and MW-39U, however, the potential may exist
that contamination is migrating vertically from the intermediate zone to the deeper zone
as indicated by increasing concentrations between GB-3I and GB-3D.

Figure 6: Toxaphene Concentrations on the THAN Parcel, 2008-2012

47

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Figure 7: Toxaphene Concentrations on the Jones Parcel, 2008-2012

600

MW-34UR

MW-39U

GB-3I

GB-8D

GB-8IR

Oct-08

Oct-09

Oct-10
Date

Oct-11

Oct-12

Beta-BHC

Beta-BHC was below detection in most of the wells at the property boundary of the
THAN and Jones Parcels, except for along the north boundary of the THAN Parcel in
wells MW-19U and MW-36U. Concentrations in these two wells from 2008 to 2012 were
similar, ranging from 20 to 25 jug/L in both wells. The highest concentrations detected at
the Site were in MW-23U, located on the THAN Parcel. Concentrations in MW-23U
were approximately twice that of the concentrations in the northern two boundary wells
(Figure 8). These data indicate that concentrations of beta-BHC are likely migrating to or
present at the northern boundary of the THAN Parcel.

48

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Figure 8: Beta-BHC Concentrations, 2008-2012

60

50

J

~o2)
E

40

KJ
±3
C
0>

o
S
o
U
U
X
CD

u

m

30

20

10

•MW-19U
•MW-23U
MW-36U

Cleanup Goal
= 5.1 mg/L

Oct-08 Oct-09 Oct-10 Oct-11

Date

Oct-12

DDT

DDT was below detection in all wells at the property boundary of the THAN and Jones
Parcels in 2012. Most wells within the THAN and Jones Parcels were also below
detection or below the cleanup goal of 27 ng/L. The highest concentrations during this
FYR period were observed in MW-N2, located at the easternmost property boundary of
the THAN Parcel. The concentrations fluctuated in MW-N2 from 2008 to 2012.
Concentrations ranged from below detection in 2008 (detection limit 0.05 (Jg/L) to a high
of 2,300 jig/L in 2010, then decreased to 270 |ig/L in 2011, and increased to 1,900 fig/L
in 2012 (Figure 9). The second highest concentrations were observed in well GB-02.

Well GB-02 is also located at the easternmost property boundary of the THAN parcel,
due south of MW-N2. Concentrations in GB-02 ranged from a high of 26 |ig/L in 2011 to
a low of 8.4 ng/L in 2012. These concentrations are below the cleanup goal of 27 |ng/L.
Further east on the Jones Parcel, the concentrations were well below the cleanup goal in
MW-33UR2, GB-3IR, GB-3D, GB-8IR and GB-8D.

49

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Figure 9: DDT Concentrations, 2008-2012

Date

Xylene

Xylene was below detection in all wells at the property boundary of the THAN and Jones
Parcels in 2012. The highest concentrations were in wells located near the warehouse on
the THAN Parcel. Concentrations exceeding the MCL of 10,000 |_ig/L were routinely
detected in a number of wells. These wells include MW-21U, located on the west side of
the warehouse on the THAN Parcel, and GB-9I, MW-22U, MW-N2 and GB-2, located
on the east side of the warehouse on the THAN Parcel. Xylene was also detected on the
Jones Parcel at concentrations above 10,000 (ig/L in wells GB-3D and MW-34UR
(Figure 10). Concentrations then drop significantly to below 1 (ig/L in MW-39, a well
located in the center of the Jones property and downgradient of the THAN parcel.

50

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Figure 10: Total Xylene Concentrations, 2008-2012

cs
s

o
f-

Oct-08 Oct-09 Oct-10 Oct-11 Oct-12

QUI and OU2
Soil

Soil data have not been collected. The OU1 soil removal action was completed in 1992
and confirmatory samples were collected in 2000 following OU2 soil remediation.
Therefore, this FYR did not evaluate soil data.

6.5 Site Inspection

On April 30, 2013, James Hou (EPA), Ben Bentkowski (EPA), Rick Hardy (Georgia
EPD), Matthew Wilson (URS), Allan Gebhard (Barr Engineering), Treat Suomi (Skeo
Solutions) and Lynette Wysocki (Skeo Solutions) met at the site entrance, located at 1401
Schley Avenue in Albany, Georgia, to participate in the site inspection. Site inspection
participants discussed the contaminated ground water plume, the stability of the plume,
regional ground water flow, and monitoring well sampling frequency and data.
Participants also discussed the current status of institutional controls at the Site. EPA and
the PRP for OU1 had recently discussed the Site's institutional controls and the possible
need for excavation/construction institutional controls for the Site.

Participants inspected the THAN Parcel, identifying the ground water monitoring wells,
checking whether the wells were maintained and secured, and examining the parcel's
vegetated cover. The PRP and O&M contractor for OU1 showed participants the area of
the parcel with underlying NAPL and explained the types of wells at the Site. White PVC
pipes were identified as the temporary wells used for the pilot project in 2003. These
wells are no longer regularly sampled but are used occasionally to measure water levels.

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The majority of the wells observed were well maintained and locked. Several wells,
including MW25U and MW25L, were unlocked or without locks.

Fencing surrounding the THAN Parcel was in good condition. Some areas of the fence,
while still functional, could be repaired to fix damage to the fence caused by vegetation
overgrowth. Participants identified numerous anthills across the THAN Parcel, especially
near the monitoring well slabs. Participants toured the remaining building on the THAN
Parcel. The building houses the ground water treatment system, which is currently not in
operation. The PRP and O&M contractor for OU1 explained that the ground water
treatment system is not functional and would require repair and maintenance prior to
operating it. Participants viewed original soil borings taken during the early site
investigations, which are stored in the building.

Site inspection participants identified a city easement between the THAN Parcel and the
Jones Parcel. Surveying and flagging of the utilities in the easement area were evident.
The PRP and O&M contractor for OU 1 were not aware of whether the city has plans for
construction in this easement area. Participants then inspected the Jones Parcel and
identified the ground water monitoring wells. Active industrial operations are ongoing on
the Jones Parcel and the gate to the parcel remains open during business hours.
Participants were unable to locate one of the monitoring wells. The PRP and O&M
contractor for OU1 explained that this well had been included in recent ground water
monitoring reports. Participants also identified off-site monitoring wells south and east of
the Site. The site inspection checklist is included in Appendix D.

Contractor staff took photographs of site features, the remaining building on the THAN
Parcel, ongoing industrial operations at the Jones Parcel, the surveyed easement area,
perimeter fencing and ground water monitoring wells. Photographs are included in
Appendix E.

Also on April 30, 2013, Treat Suomi and Lynette Wysocki (Skeo Solutions) visited the
information repository for the Site at the Dougherty County Public Library, located at
300 Pine Avenue, Albany Georgia 31701. The library is temporarily located across the
street from this address, as the library is undergoing renovations. The librarian that
manages the materials indicated that the library no longer has copies of site information.
The library would like to receive paper copies or discs of the necessary site documents.

6.6 Interviews

The FYR process included interviews with parties affected by the Site, including the
current landowners and regulatory agencies involved in site activities or aware of the
Site. The purpose was to document the perceived status of the Site and any perceived
problems or successes with the phases of the remedy implemented to date. All of the
interviews took place after the site inspection. The interviews are summarized below.
Appendix C provides the complete interviews.

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James W. Smith: Mr. James W. Smith is the Director of Environmental Projects at
Project Realty LLC, the PRP representative for T. H. Agriculture & Nutrition, LLC. Mr.
Smith feels well informed regarding site activities and is not aware of any effects on or
complaints from the surrounding community. Mr. Smith explained that most of the active
remediation at the Site was performed some time ago. Currently, activities include
maintenance of the soil cap and vegetative cover, upkeep of ground water monitoring
wells, and annual ground water monitoring and reporting. Mr. Smith stated that the OU1
remedy continues to protect human health and the environment. However, current O&M
and remedial activities may not reflect those originally anticipated in the OU1 ROD. Mr.
Smith believes that it may be prudent to review and amend the ROD to more accurately
reflect current site activities, which do not include use of the ground water treatment
system.

Matthew E. Wilson: Mr. Matthew E. Wilson is a Project Manager at URS Corp., the
O&M Contractor for OU1. Mr. Wilson stated that potential or actual exposures are under
control and COCs are not migrating into ground water. He believes that current site
conditions indicate that human health and the environment are being protected. However,
the remedy described in the OU1 ROD does not reflect that long-term monitoring is
sufficient to ensure protectiveness. The ROD should be amended to reflect this. Mr.
Wilson explained that there is a general decreasing trend of contaminant levels over the
past 23 years of monitoring. Mr. Wilson feels that, given the extremely low cleanup
goals, it is unlikely that most interior wells will be below those goals in the next five
years. "Hot spot" treatment would not reduce concentrations in interior monitoring wells
to below the goals within a reasonable timeframe based on previously piloted,
technologically-feasible treatments at the Site.

Mr. Wilson stated that there should be an opportunity to reduce the number of interior
wells sampled and/or the frequency of sampling beyond the provisions in the O&M
Manual. Mr. Wilson believes that the analytical results from the interior wells do not
affect protectiveness and will not change decisions made at the Site until all analytical
results are below cleanup goals, which is not anticipated in the next five years. He stated
that the Site's protectiveness is assessed by the annual sampling of the perimeter wells.
Mr. Wilson also explained that cap maintenance is done by a local contractor and that
there have not been any significant O&M changes in the last five years. In 2009, upkeep
work was done on the monitoring wells. Optimization for monitoring has been
implemented using provisions in the O&M Manual for removing non-perimeter wells
from sampling following five years of concentrations below cleanup goals.

Allan Gebhard/Dennis Radocha: Mr. Dennis Radocha is the OfficeMax PRP
representative. Mr. Allan Gebhard is a contractor for OfficeMax from Barr Engineering
Co. Mr. Radocha and Mr. Gebhard stated that OfficeMax has no knowledge of the most
recent remedial activities at the OU1 portion of the Site. OfficeMax has not visited the
Site or been involved in any site-related discussions (other than FYR interviews) for the
last 10 years. They believe that the past remedial activities at OU2 went well and that the
OU2 remedy continues to perform well based on their understanding. They explained the
history of the OU2 cleanup activities, indicating that the laboratory inaccuracies were not

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the reason that there is contamination remaining in soils but that the inaccuracies
triggered additional investigations that found soils exceeding the cleanup level for EDB.
Mr. Radocha and Mr. Gebhard think that it will be very difficult to achieve MCLs in the
ground water below the OU2 excavation area due to past releases from OU1. They stated
that soil at OU2 is considered to be at most a minimal contributor to the existing ground
water contamination. They indicated that it was a challenge to not have to demolish the
welding facility during the 1999 excavation activities. However, they stated that the
completion of the OU2 remedy has allowed welding operations to continue and the
business is an asset to the community. OfficeMax is not a property owner at the Site and
cannot place institutional controls on the property parcel. OfficeMax is not aware of any
complaints or inquiries about the Site. Mr. Radocha and Mr. Gebhard have not heard
anything about the progress of the OU1 remedy and indicated that may be helpful to
receive technical information about OU1 as it becomes available. They suggested that
because of possible free product on the water table under the THAN Parcel and the
western portion of the Jones Parcel, the cleanup of the ground water to the MCLs is not
reasonable in the foreseeable future and there should have been more appropriate goals
established.

Rick Hardy: Mr. Rick Hardy is the representative for the Site from EPD. Mr. Hardy
stated that monitoring wells need maintenance as missing or broken bolts, ponded water
in flush mount wells and piezometers, unlocked wells, broken concrete pads, ant
infestations and unmarked wells were observed during the site inspection. He also noted
that several wells on the Jones property could not be located. Mr. Hardy stated that well
maintenance issues can provide conduits that may accommodate surface to subsurface
contaminant migration even in unused or dormant wells. Mr. Hardy believes that the soil
remedy has provided protection for exposure to site soils. However, ground water
remediation on the THAN Parcel has been ineffective. While lateral ground water
contaminant migration appears nominal, vertical contaminant migration is observable.
Mr. Hardy stated that contaminant source areas continue to impact ground water and
unless these areas are address, ground water is not expected to be returned to beneficial
use. EPD has not received any inquires about the site and has maintained communication
with EPA. Mr. Hardy is not aware of any state laws that would affect protectiveness at
the Site or any changes in projected land uses at the Site. Mr. Hardy stated that
restrictions should be considered for both parcels to protect future construction and utility
workers. He also stated that EPA and EPD are evaluating remedial progress to date to see
if the remedy needs to be updated.

James Hou: Mr. James Hou is the EPA RPM for the Site. Mr. Hou stated that the
remedial activities at the Site do not appear to be effective in reducing contaminant
concentrations in ground water. However, there does not appear to be horizontal
migration of the ground water plume, thereby restricting exposure. He stated that EPA's
analysis of ground water data does indicate that vertical migration is occurring, which
contradicts the conclusions of the Site's 2012 FYR Addendum. Mr. Hou has not received
any complaints or inquiries from the community and is not aware of any effects of the
Site on the surrounding community. Mr. Hou stated that there are institutional control
issues that need to be addressed at the Site.

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7.0 Teclmkal Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents?
OU1

Sitewide Ground Water

The ground water remedy for OU1 is not functioning as designed. NAPL recovery and
the pumping and treatment of ground water have not functioned as intended in the 1993
ROD. A follow-up bioremediation pilot study was completed in November 2007. EPA
Region 4 reviewed the bioremediation study in November 2009 and concluded that,
given site conditions, bioremediation is ineffective at reducing contaminant
concentrations.

In 2012, EPA evaluated ground water contaminant trends and plume migration and
determined that the ground water plumes are not migrating laterally off site despite
fluctuations in concentrations within source areas; contaminant concentrations have
decreased or remained stable in the boundary wells; and localized areas of elevated
ground water contamination remain within the THAN Parcel. Although these localized
areas may continue to act as a possible continuing sources, this migration pathway may
not be significant as evidenced by boundary well concentrations. EPA has concluded that
ground water remedies have not been effective to date in significantly reducing
contaminant concentrations below cleanup goals. Further, the most recent data collected
in 2012 indicate that toxaphene and xylene concentrations in ground water have
fluctuated significantly during this FYR period. Using PRP provided cross-sections and
data, EPA performed a data analysis on 21 years of analytical data. The results of that
analysis indicate that concentrations are moving downward in the central part of the Site.
This analysis is included as Appendix I. Toxaphene and beta-BHC concentrations remain
stable but above cleanup goals at two northern boundary wells of the THAN property.
Therefore, EPA is currently evaluating and discussing with site PRPs and EPD whether
new remedial alternatives should be considered or whether there are possible
optimizations to prior remedies to improve overall site remediation of ground water
contamination.

The 1993 OU1 ROD requires institutional controls restricting sitewide ground water use.
Additionally, the 1996 OU2 ROD indicates that institutional controls to prevent use of
ground water were addressed under the OU1 remedy. Institutional controls restricting
ground water use have been put in place on the THAN Parcel. Institutional controls
restricting ground water use have not yet been put in place on the Jones Parcel or the
easement. EPA continues to work with the Site's PRPs and property owners to record
institutional controls restricting ground water use at the Jones Parcel and the easement.

Finally, the 2008 FYR raised an issue regarding the formation of toxaphene degradation
products, known as parlars, and whether parlars should be characterized because their
presence may impact future remedies at the Site. Although EPA established an approved
method for the analysis of toxaphene degradation products in September 2012, a

-------
commercial laboratory with the ability to perform such analysis has not yet been
identified. EPA may consider this issue as part of evaluating other remedial alternatives
or optimizations for the Site's ground water remedy.

QUI and OU2

Soil

The remedy for OU1 did not include a soil component. The 1993 OU1 ROD indicated
that the 1992 removal action completely addressed soil on the THAN Parcel.

The 2012 Addendum to the 2008 FYR indicated that institutional controls addressing
excavation and construction were put in place at the completion of the 2008 FYR. In
April 2013, a review of restrictions filed with Dougherty County found that institutional
controls restricting disturbance of subsurface soil during activities such as
excavation/construction have not been put in place at the Site. This FYR conducted a
review of historic documents containing subsurface soil contamination concentrations to
determine the necessity for institutional controls restricting disturbance of subsurface
soil. For subsurface soils at the THAN Parcel, the review determined that subsurface soils
for some of the COCs (DDT, toxaphene and BHCs) exceed the industrial cleanup goals
for 1 x 10"6 risk. For example, confirmatory samples collected following the 1992
removal action indicate that alpha-BHC has been detected as high as 20 mg/kg in
subsurface soil, which is higher than the revised 1 x 10"6 risk-based industrial cleanup
goal (based on current toxicity values as presented in Section 7.2 of this FYR Report) of
0.27 mg/kg. This concentration is equivalent to 7 x 10° industrial risk. The COCs DDT
and toxaphene were detected as high as 12 mg/kg and 20 mg/kg, respectively, versus the
revised lxl 0~6 industrial cleanup goals presented in the March 31, 1992 Removal Action
Work Plan of 7.2 mg/kg and 2.2 mg/kg, respectively. Based on more current toxicity
values, the risks associated with the soil COCs will be even higher, as discussed in
Section 7.2 of this FYR Report.

For subsurface soil on the Jones Parcel, historic documents indicated that subsurface soil
remediation did not address DDT and toxaphene because it was concluded that the
concentrations were not a concern with respect to impacting ground water. According to
the OU2 ROD, the surface soil remedy remediated DDT and toxaphene to achieve 1x10"
5 risk-based cleanup goals for industrial use. DDT and toxaphene in subsurface soil were
not considered for potential future exposure if they were disturbed. Remediation
addressing manganese, methyl parathion and EDB in subsurface soils was done to
achieve cleanup goals protective of ground water. The 2001 confirmatory sampling on
the Jones Parcel only analyzed for EDB. The 1995 RI report reported concentrations of
DDT and toxaphene up to 210 mg/kg and 1,800 mg/kg, respectively. These
concentrations exceed the revised 1 x 10"5 risk-based industrial cleanup goals (based on
current toxicity values as presented in Section 7.2 of this FYR Report) of 70 mg/kg and
16 mg/kg, respectively. Further, the maximum concentrations of DDT and toxaphene
correspond to industrial risks of 3 x 10"5and 1 x 10"3 respectively.

Based on the above evaluation, subsurface soil on the THAN and Jones Parcels exceed
the industrial-based cleanup goals and potentially are not within the cumulative

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acceptable risk range for industrial use. Therefore, additional institutional controls are
needed to help ensure protectiveness at the Site. Institutional controls restricting
disturbance of subsurface soil during activities such as excavation/construction should be
put in place for the THAN and Jones Parcels. This does not impact short-term
protectiveness, as construction/excavation at the Site is not planned in the near term.

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and

remedial action objectives (RAOs) used at the time of remedy selection still valid?

The exposure assumptions used at the time of remedy selection remain valid and the site
use remains industrial. However, human health risks associated with the vapor intrusion
exposure pathway in on-site buildings had not been previously quantified. Since the
signing of both RODs, risk assessment guidance has become available for evaluating the
vapor intrusion exposure pathway. Vapor intrusion exposure pertains to chemicals,
including EDB and xylene, which are considered sufficiently toxic and volatile.

This FYR conducted a screening-level vapor intrusion evaluation in a tiered approach to
assess the protectiveness of the remedy using EPA's Vapor Intrusion Screening Levels
(VISLs)1 followed by the use of a vapor intrusion model using the most recent ground
water monitoring data collected from the shallow ground water zone on site. The results
of the screening-level vapor intrusion evaluation indicate that EDB and total xylene
concentrations exceed VISLs. However, further site-specific modeling suggests that the
EDB and xylene in ground water do not pose an indoor air concern for the on-site
occupiable buildings that exist at the Jones Parcel. The screening-level vapor intrusion
evaluation is provided in Appendix F.

The ground water cleanup goals identified for the COCs were the MCLs for EDB and
toxaphene, and 1 x 10"4 risk-based levels for alpha- and beta-BHC, DDT, aldrin and
dieldrin. The MCLs for EDB and toxaphene remain unchanged. To evaluate whether the
risk-based cleanup goals remain valid for alpha- and beta-BHC, DDT, aldrin and dieldrin,
the cleanup goals were compared to EPA's tap water regional screening levels (RSLs)
adjusted to a 1 x 10"4 risk level. These comparisons are presented in Appendix F. The
comparison indicates that the cleanup goals are slightly less stringent than the tap water
RSLs. Although the cleanup goals are less stringent, the remedy remains protective for
the short term. The active business on site obtains potable water from the public water
supply. Ground water use restrictions are in place at the THAN Parcel. EPA continues to
work with the property owners of the Jones Parcel and the easement to implement ground
water use restrictions.

The OU1 ROD identified health-based cleanup goals for soil based on residential
exposure and a 1 x 10"6 cancer risk. To evaluate if the cleanup goals remain valid for
surface soil at OU1, the values listed in the Removal Action Work Plan were compared to
EPA RSLs for soil, based on industrial exposure. The comparison shows that the cleanup
goals from the 1992 removal action are slightly more stringent but within EPA's

' EPA's Vapor Intrusion Screening Level Calculator is available at

http://www.eDa.gov/oswer/vaDorintrusion/guidance.html.

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acceptable risk range of 1 x 10"6 to 1 x 10~4 and support that the industrial land use-based
cleanup goals remain valid. However, as presented in Section 7.1 of this FYR Report,
concentrations remain in the subsurface soil of the THAN Parcel that exceed the
industrial risk-based cleanup goals.

The OU2 ROD identified health-based cleanup goals for soil that were based on
industrial exposure and a 1 x 10° cancer risk. To evaluate if the cleanup goals remain
valid for surface soil at OU2, the values listed in the 1996 ROD were compared to EPA
RSLs for soil based on industrial exposure. The comparison shows that the 1996 ROD
soil cleanup goals are more stringent but remain within EPA's acceptable risk range of 1
x 10'6 to 1 x 10"4 and support that the industrial land use-based cleanup goals remain valid
for OU2. However, as presented in Section 7.1 of this FYR Report, concentrations
remain in the subsurface soil of the Jones Parcel that exceed the industrial risk-based
cleanup goals.

Toxicity factors for a number of site COCs have changed since EPA issued the OU1 and
OU2 RODs. A summary of the toxicity factors available from the human health risk
assessment compared with current toxicity values is presented in Appendix F. Based on
an evaluation of the changes in the toxicity values, the cleanup levels remain valid; the
information to support this conclusion is provided in Appendix F.

According to the 2008 FYR, ground water monitoring detected xylene at levels well
above the MCL. Further, due to a change in the EPA noncancer oral reference dose (RfD)
and inhalation reference concentrations (RfCs), the promulgated MCL of 10,000 (ig/L is
no longer considered protective. EPA has developed a health protective level of 3,500
|ig/L based on the current toxicity assessment and standard drinking water exposure
assumptions (including EPA Region 4 assumptions for showering exposure to volatilized
chemicals). Although the site data exceed the current federal MCL and EPA Region 4's
recommended value of 3,500 ^g/L, the remedy remains protective. There are no potables
uses of ground water at the Site because the active on-site business gets potable water
from the public water supply and vapor intrusion under the industrial land use scenario is
not a pathway of concern. Ground water use restrictions are in place for the THAN
Parcel. EPA continues to work with the owners of the Jones Parcel to implement ground
water use restrictions.

Recently, new analytical methods and toxicity criteria have been developed to
characterize degradation products of toxaphene, known as parlars. Based on a
preliminary analysis conducted in the 2008 FYR, toxaphene parlars were identified in
four wells exceeding a health-based preliminary remediation goal (PRG) of 0.03 |ag/L.
Depending on the distribution of toxaphene parlars, their presence and concentration may
impact future remedies at the Site. However, further evaluation of toxaphene parlars and
impacts to remedy protectiveness cannot be determined until EPA has established
toxicity values for toxaphene parlars and commercial laboratories are certified in
toxaphene parlar analysis.

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7.3 Question C: Has any other information come to light that could call into question
the protectiveness of the remedy?

During the April 30, 2013 site inspection, participants observed utility work in the
easement separating the THAN Parcel from the Jones Parcel. This raised a concern
regarding whether the easement area had been included in the prior OU1 removal action
or OU2 soil remediation. Based on a review of the 1998 final removal action
confirmatory sampling results, concentrations of COCs in surface soil in the easement
area were below the lxl 0"6 risk-based industrial use remedial goals for the soil COCs.
Ground water institutional controls, as required in the OU1 ROD, should be put in place
for this area.

7.4 Technical Assessment Summary

The remedy for OU1 is not functioning as designed. When pumping and treatment of
ground water proved less effective than predicted in the Site's decision documents,
operation of the ground water treatment system ceased in 2003 and a bioremediation pilot
study was initiated and completed in 2007. In 2009, EPA evaluated the study and
concluded that bioremediation is ineffective, at which time site PRPs continued to
evaluate other options for the treatment of the Site's ground water. In 2012, EPA
evaluated ground water contaminant trends and plume migration and determined that the
ground water plumes are not migrating laterally off site despite fluctuations in
concentrations within source areas; contaminant concentrations have decreased or
remained stable in the boundary wells; and localized areas of elevated ground water
contamination remain within the THAN Parcel. Although these localized areas may
continue to act as a possible continuing sources, this migration pathway may not be
significant as evidenced by boundary well concentrations. The ground water remedy has
not been effective because 2012 ground water data indicate that toxaphene and xylene
have fluctuated significantly during this FYR review period. Using PRP provided cross-
sections and data, EPA performed a data analysis on 21 years of analytical data. The
results of that analysis indicate that concentrations are moving downward in the central
part of the Site. In addition, toxaphene and beta-BHC concentrations remain stable but
above cleanup goals at two northern property boundary wells of the THAN Parcel. EPA
is currently discussing whether optimizations to the ground water remedy or new
remedial alternatives should be considered with Site's PRPs and EPD.

Institutional controls restricting ground water use as required by the OU1 ROD have been
put in place at the THAN Parcel but have not been put in place for ground water at the
Jones Parcel or the easement. Although the 1993 OU1 ROD did not include a soil
component remedy, it did indicated that the 1992 removal action completely addressed
soil on the THAN Parcel. An evaluation of the Site's institutional controls found that
additional institutional controls are needed to help ensure protectiveness at the Site.
Subsurface soil contaminant concentrations on the THAN and Jones Parcels exceed the
industrial-based cleanup goals and potentially are not within the cumulative acceptable
risk range for industrial use. Institutional controls restricting disturbance of subsurface

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soil during activities such as excavation/construction should be put in place for the
THAN and Jones Parcels.

Exposure assumptions used during remedy selection remain valid. The Site remains in
continued industrial use. Jones Welding and Industrial Supply operates on the Jones
Parcel. Human health risks associated with the vapor intrusion exposure pathway in on-
site buildings had not been previously quantified. Vapor intrusion exposure at the Site
pertains to EDB and xylene. The results of the screening-level vapor intrusion evaluation
indicate that the EDB and xylene in ground water do not pose an indoor air concern for
the on-site buildings on the Jones Parcel.

Ground water cleanup goals are slightly less stringent than tap water RSLs. Removal
action cleanup goals for surface soil at OU1 and cleanup goals for surface soil at OU2
remain valid. Contaminant concentrations remain in subsurface soil above the established
industrial risk-based cleanup goals. While toxicity factors for a number of the COCs have
changed since EPA issued the Site's RODs, the cleanup levels remain valid. Ground
water monitoring has indicated that xylene exceeds the federal MCL and EPA Region 4's
recommended value of 3,500 (J.g/L on site but continues to be below criteria at the
boundary wells. Toxaphene parlars have been detected in ground water above the Region
4 PRG. However, only recently has EPA approved an analytical method for toxaphene
parlars. Further evaluation of toxaphene parlars and impacts to remedy protectiveness
cannot be determined until EPA has established toxicity values for toxaphene parlars and
commercial laboratories are certified in toxaphene parlar analysis. The ground water
remedy remains protective in the short term because the active business on the Jones
Parcel obtains potable water from the public water supply and ground water use
restrictions are in place at the THAN Parcel.

60

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8.0 Issues

Table 10 summarizes the current site issues.

Table 10: Current Site Issues

Issue

Affects Current
Protectiveness?

(Yes or No)

Affects Future
Protectiveness?
(Yes or No)

The ground water remedy has not been effective to
date in significantly reducing contaminant
concentrations below cleanup goals.

No

Yes

COCs have been detected above cleanup goals in two
wells at the northern boundary of the THAN parcel.

No

Yes

Institutional controls required in the OU1 ROD
restricting sitewide ground water use have not been
implemented at the Jones Parcel or the easement.

No

Yes

Contaminant concentrations remain in subsurface soil
at the Site above the established industrial risk-based
cleanup goals.

No

Yes

Weathered toxaphene results in the formation of
degradation products, known as toxaphene parlars.
Depending on the distribution of toxaphene parlars,
their presence and concentration may impact future
remedies at the Site.

No

Yes

Ground water analysis reporting limits for EDB are
too high to detect EDB at concentrations at the MCL
in boundary wells.

No

Yes

61

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9.0 Recommendations and Follow-up Actions

Table 11 provides recommendations to address the current site issues.

Table 11: Recommendations to Address Current Site Issues

Issue

Recommendation /
Follow-Up Action

Party
Responsible

Oversight
Agency

Milestone
Date

Affects
Protectiveness?
(Yes or No)

Current

Future

The ground water
remedy has not been
effective to date in
significantly reducing
contaminant
concentrations below
cleanup goals.

Develop ground water
remediation alternatives
to address continuing
ground water
exceedances.

PRPs

EPA

09/30/2014

No

Yes

COCs have been
detected above cleanup
goals in two wells at the
northern boundary of the
THAN parcel.

Perform a well survey
to determine
contaminant migration
and to create a record of
well locations and
number of nearby
municipal and domestic
wells.

PRP

EPA

09/30/2014

No

Yes

Institutional controls
required in the OU1
ROD restricting sitewide
ground water use have
not been implemented at
the Jones Parcel or the
easement.

Work with EPA, PRPs
and property owners to
implement ground
water institutional
controls.

PRPs,
Property
Owner

EPA

09/30/2014

No

Yes

Contaminant
concentrations remain in
subsurface soil at the
Site above the
established industrial
risk-based cleanup goals.

Address the need for
additional remedial
action for the remaining
subsurface soil
contamination at the
Site using the EPA
decision-making
process.

EPA

EPA

09/30/2014

No

Yes

Weathered toxaphene
results in the formation
of degradation products,
known as toxaphene
parlars. Depending on
the distribution of
toxaphene parlars, their
presence and
concentration may
impact future remedies
at the Site.

Include toxaphene
parlars in future
monitoring once EPA
has established toxicity
criteria and commercial
laboratories are
available that are
certified in toxaphene
parlar analysis.

EPA

EPA

09/30/2014

No

Yes

Ground water analysis
reporting limits for EDB
are too high to detect

Optimize future
monitoring by
submitting high

PRP

EPA

09/30/2014

No

Yes

62

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Issue

Recommendation /
Follow-Up Action

Party
Responsible

Oversight
Agency

Milestone
Date

Affects
Protectiveness?
(Yes or No)

Current

Future

EDB at concentrations at
the MCL in boundary
wells.

concentration range
samples as separate
laboratory batches from
low concentration range
samples.











The following additional items, though not expected to affect protectiveness, warrant additional
follow up:

•	The 1993 OU1 ROD states that the removal action remediated on-site soils to 1 x 10"6
residential risk-based levels, but the Removal Action Work Plan indicates that the levels
were actually remediated to lxl 0"6 industrial risk-based levels. However, the 1993 OU1
ROD included institutional controls to prevent residential exposure. EPA should clarify
the cleanup levels for surface soil.

•	Continue the ground water monitoring program and include deeper interior monitoring
wells for the purpose of identifying if contaminants migrate deeper than the current
intermediate depths.

•	The site repository at the Dougherty County Public Library should be updated with the
Site's administrative record.

•	Monitoring wells should be checked to ensure they are properly locked and secured.

63

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10.0 Protectiveness Statements

• Develop ground water remediation alternatives to address ground water exceedances.

• Address the need for additional remedial action for the remaining subsurface soil
contamination at OU1 using the EPA decision-making process.

• Perform a well survey.

• Implement ground water institutional controls for ground water at the Jones Parcel and
the easement area.

• Include toxaphene parlars in future monitoring once EPA has established toxicity criteria
and commercial laboratories are available that are certified in toxaphene parlar analysis.

• Optimize future monitoring by submitting high concentration range samples as separate
laboratory batches from low concentration range samples.

• Address the need for additional remedial action for the remaining subsurface soil
contamination at OU2 using the EPA decision-making process.

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11.0 Next Review

The next FYR will be due within five years of the signature/approval date of this FYR.

65

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Appendix A: List of Documents Reviewed

Addendum to T.H. Agriculture and Nutrition (Albany) Five-Year Review Report, Dated
September 9, 2008. United States Environmental Protection Agency Region 4. September 28,
2012.

Alternatives Analysis Report. Post-Remedial Action Conditions. T.H. Agriculture & Nutrition
Site. Operable Unit 2. Albany, GA. Submitted by Boise Cascade Corporation. Submitted to EPA
Region 4. May 2001.

Annual Progress Report, January-December 2011. T.H. Agriculture & Nutrition L.L.C., Albany,
Georgia. Prepared by URS Corporation. Prepared for United States EPA Waste Division.

January 3, 2012.

Baseline Risk Assessment for the T.H. Agriculture & Nutrition Site, Albany, Georgia. Prepared
by Woodward-Clyde Consultants. Prepared for T.H. Agriculture & Nutrition Company, Inc.
February 1992.

Draft Remedial Action Report. T.H. Agriculture & Nutrition Site, Operable Unit 2, Albany, GA.
Prepared by Focus Environmental. Prepared for Boise Cascade Corporation. Submitted to EPA
Region 4. February 24, 2000.

Explanation of Significant Differences. U.S. Environmental Protection Agency-Region 4.
December 1995.

Feasibility Study Report. T.H. Agriculture & Nutrition Company Inc., Albany, Georgia Site.
Prepared by Woodward-Clyde Consultants. Prepared for T.H. Agriculture & Nutrition Company,
Inc. February 1992.

Final Construction Report. Volumes 1 & 2. Prepared by Woodward-Clyde Consultants. Prepared
for: TH Agriculture & Nutrition Company, Inc. May 1997.

Final Report. Daramend® Injection for In-Situ Bioremediation. T.H. Agriculture & Nutrition
Site, Albany, Georgia. Prepared by URS Corporation. November 2007.

Five-Year Review Report for T.H. Agriculture & Nutrition. Operable Unit 1. Albany, Dougherty
County, Georgia. Prepared by United States Environmental Protection Agency Region 4. March
2003. Signed September 4, 2003.

Five-Year Review Report for T.H. Agriculture & Nutrition. Operable Unit 2. Albany, Dougherty
County, Georgia. Prepared by United States Environmental Protection Agency Region 4. January
31,2006.

Five-Year Review Report for T.H. Agriculture & Nutrition. Sitewide. Albany, Dougherty
County, Georgia. Prepared by E2 Inc. Prepared for United States Environmental Protection
Agency Region 4. September 9, 2008.

A-l

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Preliminary Remedial Investigation Report. T.H. Agriculture & Nutrition Company Facility.
Albany, Georgia. Prepared by Woodward-Clyde Consultants. Prepared for T.H. Agriculture &
Nutrition Company, Inc. April 25, 1990.

Record of Decision. Summary of Remedial Alternative Selection. T.H. Agriculture & Nutrition
Site. Operable Unit One. Albany, Dougherty County, Georgia. Prepared by U.S. Environmental
Protection Agency, Region 4. May 21, 1993.

Record of Decision. T.H. Agriculture & Nutrition Co. (Albany Plant). EPA ID: GAD042101261.
OU2. Albany, GA. April 26, 1996.

Remedial Investigation Report. Jones Property Site. Albany, Georgia. U.S. Environmental
Protection Agency, Region 4, Environmental Services Division. February 1995.

Removal Action Work Plan. Prepared by Woodward-Clyde Consultants. Prepared for T.H.
Agriculture & Nutrition Company, Inc. March 1992.

Removal Action Report - Thermal Desorption. T.H. Agriculture & Nutrition Co. Facility,

Albany, GA. Focus Project No. 069206. Prepared by Focus Environment, Inc. Prepared for T.H.
Agriculture & Nutrition Company, Inc. February 1994.

Review of Ground Water and Soil Contamination at the T.H. Agriculture and Nutrition Site,
Albany, Georgia. Prepared by North Wind, Inc. February 2006.

Summary of Pre-Final Construction Inspection. T.H. Agriculture & Nutrition Company, Inc.,
Albany, Georgia. Sent from Woodward-Clyde Consultants. Sent to U.S. Environmental
Protection Agency, Region 4. September 3, 1996.

Technical Memorandum. Exposure Assessment and Documentation. Prepared by Woodward-
Clyde Consultants. Prepared for T.H. Agriculture & Nutrition Company, Inc. June 1991.

Technical Memorandum. Industrial Use Scenario for the THAN-Albany, Georgia Facility.
Prepared by Woodward-Clyde Consultants. Prepared for T.H. Agriculture & Nutrition Company,
Inc. November 1991.

Technical Memorandum. Preliminary Remedial Action Objectives. Prepared by Woodward-
Clyde Consultants. Prepared for T.H. Agriculture & Nutrition Company, Inc. January 1992.

Treatability Study and ROST Investigation Results. T.H. Agriculture & Nutrition Site, Albany,
Georgia. Prepared by URS Corporation. Prepared for T.H. Agriculture & Nutrition, L.L.C.

March 21, 2003.

Work Plan for Enhanced In-Situ Bioremediation Treatment Pilot Test. T.H. Agriculture &
Nutrition, L.L.C., Albany, Georgia. Prepared by URS Corporation. Prepared for USEPA Waste
Division. August 7, 2003.

A-2

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Appendix B: Press Notice

The U.S. Environ mortal Proteoton Agency,
Region 4Announce* the Fourth Rve-Yeer
Review lor the

T.H. Agriculture & Nutrition Co. (AJbeny
Plant) Superfund SttaAtoany. Dougherty
County Geortaie

		 Y	u fi

_ cy (EPA) la conducting ¦
Flve-Yaar Review of the remedy for the T.H.
Agriculture & Nutrtton Co. (Albany Ptent)
8upertund alte (the 8Me) in Albany, Oeorgie.
The purpose ot the Flv*-\%ar Review la to

make eure the ssleated cleanup action#
effectively prelect human health and the

SHe Background: The 12-acre ake Incfudee
two propertiea in an Industrial and reelden-
ttel area of Atoany, Oeorgie. The weetem 7
scree of the Ske are located at 1401 Schley
Avenue. The area, known as (he THAN
property, is owned by T. H Agriculture &
Nutrition, LLC (formerly T. H. Agriculture &
Nutrition Company, Inc.). The eaatam 5
acres are located at 1359 Schlev Avenue.
Jones Family Propertiea. LLC

the 1950b to 1982, two peetickte formute-
tlon facilities operated at the Site. The
facilities handled, blended, packaged and

¦old agricultural
Operations and

resulted In sol and ground weier contami-
nation. The EPA diacovared contamination
at the Site In 1983. T. H. AgricuSure &
Nutrition Company, Inc. oonducted cleanup
activities mclutflng demolition of several
buildings, excavation of sod and dhpoaal
areas, installation of a perimeter tenoe, and
eatabNehment of a vegetative cover, under
the supervision of the Georgia Environmen-
tal Protection DMslon In 1984. The EPA
proposed the Site for Inclusion on the
National Priorltlea List (NPL) in 1988: the
EPA finalized the Sits on the NPL h 1989
Major contaminants at the Ske Included
pesticides such aa methyl parathion,
dlrttoro^henyt-trichloroethane (DOT),
ethylene tiDbromide, loxaphene and xylene
In soil end around water.

Cieenup Actions: The ERA designated two
operable units (OUs) to address the Ske"*
aofl and ground water contamination. The
ERA signed the Site7* 0U1 Record oi
Decision in Mey 1993, selecting a remedy
to beat soil contamination at the THAN
property and the Site** ground water
contamination. The selected remedy tor
OU1 included no action tor soil due to
previoua cleanup activities, pumping and
treatment of contaminated ground water,
pumping and off-sMe incineration of Ight
non-equeous phase liquids, ptecemem oi
instttutionel controls on ths property, and
maintenance of the property's vegetattvi
oover. The EPA signed an Explanation oi
Significant Differences for 0U1 in
December 1995. aeiectina chanoee lor the
ground water treatment technology, dis-
posal methods tor treeled ground water,
and the treatment proemfar light non-
aqueous phase liquids. The EPA signed the
8fte»s OU2 ROD In April 1090. selecting ¦
remedy to treat aoll contamination at the
Jones property. The selected remedy tor
0U2 Included excavebon of contaminated
aoll, treatment of contaminated aoH,
placement of treated soil on alts, confir-
matory sampling of treated soli, air
monitoring, confirmatory ground water
monitoring, and placement of Institutional
controls on ths orooeitv.

Five-Year Review Schedule: The Natlonel
Contingency Plan requires review of reme-
dial actions that result In any hazardous
substances, pollutants or contaminants re-
maining at ths Site ebove levels that alow
tor unHmked uee and unraatricted exposure

human health and the environment.
The EPA w« complete the fourth of the
Pive->frar Reviews (the second site-wide
Flve-Yeer Review) for the Site by Septem-
ber 2013.The EPA Invftee Community
Participation in the Five-Year Review Proc-
ess: The ERA Is conducting this Five-Year
Review to evaluate the effectiveness of the
Sfts*s remedy and to ensure that the rem
edy remain# protective of human health and
the environment. Aa part of the Five-Year
Review process, EPA staff member* are
sva*ebte to anewer any questions about ths
Site. Community members who have ques-
tions about ths Ste or the Five-Year Review
process, or who would Ike to participate In
a oommunlty interview, are asked to con-
tact:

James Hou, EPA Remedial Project Man-

Sow 1404*582.8965
Email: hou.lamesOepa.gov

LATbnya Spencer, EPA Community in-
volvement Coordinator

(404)882-8463 / (877)718-3752

(toll-free)
Email: ai

aoencer.letonveOeoaoov

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Appendix C: Interview Forms

T.H. Agriculture & Nutrition Co. (Albany Five-Year Review Interview Form

Plant) Superfund Site

Site Name: T.H. Agriculture & Nutrition EPA ID No.: GAD042101261
Co. (Albany Plant)

Interviewer Name: Lynette Wysocki Affiliation: Skeo Solutions

Subject Name: James W. Smith Affiliation: PRP Representative

Project Realty LLC

Subject Contact Information: James W. Smith, Director, Environmental Projects

Project Realty LLC, 15313 W. 95th Street, Lenexa, KS
66219

Time: NA Date: May 7,2013

Interview Location: NA

Interview Format (circle one): In Person Phone Mail Other: Email X

Interview Category: Potentially Responsible Parties (PRPs)

1. What is your overall impression of the remedial activities at the Site?

This is the second five-year review and most of the active remediation was performed quite
some time ago. Most of the remedial activities now consist of maintenance of the site soil cap
and its vegetative cover (installed during the removal action), upkeep of the ground water
monitoring wells, and annual ground water monitoring and reporting.

2. What have been the effects of the Site on the surrounding community, if any?

None of which I am aware during the review period.

3. What is your assessment of the current performance of the remedy in place at the Site?

The approved remedy for OU1, per the ROD, is still effective in its protection of human
health and the environment as being currently implemented. However, current site activities
may not reflect those originally anticipated under the ROD.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial
action from residents since implementation of the cleanup?

No.

5. Do you feel well informed regarding the Site's activities and remedial progress? If not, how
might EPA convey site-related information in the future?

Since we are the PRP representative who employs the remedial contractor/consultant (URS
Corporation), we are well informed regarding the site.

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6. Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy?

The approved ROD for OU1 as currently implemented is still protective of human health and
the environment. However, current remedial activities may differ from those anticipated
under the original ROD. Much work had been performed to review various alternatives to
address site remedial measures since the original ROD was issued. Therefore, it may be
prudent to review and amend the ROD to reflect current site activities more accurately.

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Site Name: T.H. Agriculture & Nutrition EPA ID No.: GAD042101261
Co. (Albany Plant)

Interviewer Name: Lvnette Wvsocki Affiliation: Skeo Solutions

Subject Name: Matthew Wilson Affiliation: O&M Contractor

URS Corp.

Subject Contact Information: Matthew E. Wilson, Project Manager, URS Corp.

500 Enterprise Dr., Suite 3B, Rocky Hill, CT 06067
Time: NA Date: May 9,2013

Interview Location: NA

Interview Format (circle one): In Person Phone Mail Other: Email X
Interview Category: O&M Contractor

1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)?

Potential or actual exposures are under control, and COCs are not migrating in ground water.

2. What is your assessment of the current performance of the remedy in place at the Site?

Current conditions at the Site indicate that human health and the environment are being
protected. However, the remedy as described in the ROD does not reflect that long-term
monitoring is sufficient to ensure protectiveness. The ROD should be amended to reflect this.

3. What are the findings from the monitoring data? What are the key trends in contaminant
levels that are being documented over time at the Site?

Environmental data is highly variable from year to year, and statistical analysis does not
always demonstrate that trends are statistically significant depending on the confidence level
used. General trends, however, can be discerned over 23 years of monitoring. An overall
decreasing slope can be discerned in most wells that might have no statistically significant
trend. The key trend in the concentrations of COCs is that they are decreasing in the order
predicted by their respective retardation coefficients. EDB with the lowest retardation
coefficient has been decreasing in a majority of wells since the mid-1990s. The isomers
alpha-BHC and beta-BHC have been declining since the late-1990s. Dieldrin, which has a
higher retardation coefficient than the BHC isomers, appears to have been decreasing in most
wells since the middle of the last decade. Aldrin and toxaphene, which have higher
retardation coefficients than Dieldrin, appear to have begun decreasing in most wells since
the last five-year review.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and
activities. Alternatively, please describe staff responsibilities and the frequency of site
inspections and activities if there is not a continuous on-site O&M presence.

The O&M presence at the site consists of cap maintenance by a local contractor, Todd
Washington. Annual sampling is conducted in October by ProTech, which is based in Baton
Rouge, Louisiana, and which has personnel in Atlanta, Georgia. URS Corporation oversees

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these site activities, evaluates the annual monitoring data, and submits the annual monitoring
report to EPA on behalf of THAN.

5. Have there been any significant changes in site O&M requirements, maintenance schedules
or sampling routines since start-up or in the last five years? If so, do they affect the
protectiveness or effectiveness of the remedy? Please describe changes and impacts.

There have been no significant changes in site O&M requirements in the last five years.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last
five years? If so, please provide details.

Flush-mounted monitoring well protectors on the Jones Parcel are occasionally covered in
dirt or gravel, requiring a metal detector to locate. ProTech performed the following
monitoring well repairs the week of February 9-13, 2009:

• Replaced well locks.

• Painted well protectors.

• Painted well numbers on protectors or pads.

• Replaced compression plugs on flush-mounted wells.

• Replaced bolts and washers on flush-mounted wells.

• Repaired well protectors at MW-13 and MW-25U.

• Replaced pads and flush mounted protectors at GB-3I, MW-35U and MW-39U.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please
describe changes and any resulting or desired cost savings or improved efficiencies.

Optimization has been implemented using provisions in the O&M Manual for removing non-
perimeter wells from the sampling list following five years of concentrations below site
RAOs. This involves analyzing VOC samples in candidate wells by method 504.1 to obtain a
method detection limit below 0.05 |ig/L for EDB.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and
schedules at the Site?

Given the extremely low RAOs in the parts per trillion range (e.g., Aldrin, Dieldrin) or parts
per quadrillion range (e.g., EDB), it is unlikely that most interior wells will be below RAOs
in the next five years. "Hot spot" treatment would not reduce concentrations in interior
monitoring wells to below RAOs within a reasonable timeframe based on technologically
feasible treatments that have previously been examined and/or piloted at the Site. There
should be an opportunity to reduce the number of interior wells sampled and/or the frequency
of sampling beyond the provisions in the O&M Manual. The analytical results from the
interior wells do not affect protectiveness, and will not change the decisions made at the Site
until all of them are below RAOs, which is not anticipated in the next five years.
Protectiveness at the Site is assessed by the annual sampling of the perimeter wells. Annual
sampling of the perimeter wells is sufficient for achieving data quality objectives and
ensuring protectiveness.

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Site.Name: T.H. Agriculture & Nutrition Co. EPA ID GAD042101261

(Albany Plant) No.:

Interviewer Name: NA Affiliation: NA

SubjectName: Allan Gebhard/Dennis Radocha Affiliation: RP Representatives
Subject Contact Information: Barr Engineering Co - Minneapolis. MN: OfficeMax - Boise. ID
Time: Date: 6/25/2013

Interview Location: NA

Interview Format (circle one): In Person Phone (frforiP) Other:

Interview Category: Potentially Responsible Parties (PRPs)

1. What is your overall impression of the remedial activities at the Site?

¦ OfficeMax has no knowledge of the most recent remedial activities at the OU1 portion of the site.
Overall we believe the remedial activities at OU2 went well. In 1999. Boise Cascade (now
OfficeMax) completed a RA involving excavation and low temperature thermal desorption of the
soils in OU2 as described in the ROD for OU2 and in the approved RA Work Plan. At the end of the
RA we thought we had finished with the site. The lab we used for the analysis of some of the RA
samples came to the attention of the EPA with allegations of fraudulent analyses. Additional soil
borings were completed at the request of EPA to follow-up and they showed EDB above the ROD-
based PRO deeper in some of the soil borings. The original RD sampling protocol used 5-point
composites to classify the soil into one of two types - soil that exceeded PRGs and soil that did not,
Excavation occurred along neat excavation lines as described in the RA Work Plan with the two types
of soil placed in separate stockpiles. The soil that was classified as not exceeding PRGs was put back
into the bottom of the excavation and the soil that was classified as exceeding PRGs was treated and
then put back into the excavation on top of the soil that was considered to meet PRGs. The follow-up
soil sampling showed that a portion of the soil that was thought to meet PRGs actually exceeded the
cleanup level for EDB. An early FYR did not present this accurately - the lab fraud issue was not the
reason there is contamination remaining in the soils. The lab fraud issue triggered additional
investigations that found soils that exceeded cleanup levels.

The OU2 ROD cleanup goals for EDB and methyl parathion in soil are based on maintaining MCLs
in the groundwater so that the soils would not lead to contamination of the ground water above
MCLs. It seems that it will be very difficult to achieve MCLs in the groundwater below the OU2
excavation area due to releases from OU1 that occurred many years ago

OfficeMax has furnished EPA with estimated costs as well as identified issues associated with re-
excavation of the soil at OU2. It was a challenge to not have to demolish the. Jones commercial
building during the 1999 RA excavation.

2. What have been the effects of this Site on the surrounding community, if any?

When the OU2 remedy described above s complete, the site was safe to use by the Jones Welding
Company's operations. Jones's business is an asset to the community.

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3. What is your assessment of the current performance of the remedy in place at the Site?

OfficeMax has not visited the site or been involved in any site-related discussions (other than FYR
interviews) for the last 10 years. Based on what we understand, the OU2 remedy is performing well.
Some residual contamination remains at the bottom of the excavation, but the top 7-8 feet of soil is
clean. There were high concentrations of pesticides in the groundwater below OU2 front releases
associated with OU1. The soil on OU2 is considered to be at most a diminimis contributor to the
existing groundwater contamination. The remedy at OU2 is believed to be protective of human
health and the environment. OfficeMax is not a property owner and has no ability to place ICs on the
property.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action
from residents since implementation of the cleanup?

5. Do you feel well-informed regarding the Site's activities and remedial progress? [f not, how might
EPA convey site-related information in the future?

At one time we were kept informed by the EPA regarding OU1 activities. Perhaps there has not been
much activity recently at OU1, but we have not heard anything about OU1 in the last few years
except for what we read in the periodic FYR documents. We prepare a progress report every six
months for EPA and other stakeholders. It may be helpful to receive technical information about
OU1 as it becomes available.

6. Do you have any comments, suggestions or recommendations regarding the management or operation
of the Site's remedy?

The remedy at OU2 is protective of human health and the environment from the information we have
available. There remains a disconnection between the PRGs in the OU2 ROD and the existing
situation. There was (perhaps still is) free product on the water table under OU1 and the western
portion of OU2 and cleanup of the ground water to the MCLs beneath OU2 is not reasonable in the
foreseeable future. There should have been more appropriate PRGs established for OU2 than the
groundwater pathway PRGs that are in the ROD.

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at -

Site Name: T.H. Agriculture & Nutrition
Co. (Albany Plant)

EPA ID No.: GAD042101261

Interviewer Name:
Lynette Wysocki
Subject Name:
Rick Hardy
Subject Contact
Information:

Time:

Date:
8/26/2013

Affiliation:
SKEO Solutions
Affiliation:
GAEPD

Interview
Location:

Interview Format (circle In Person Phone
one);

Mail X Other:

Interview
Category:

State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)? Monitoring wells need some attention to maintenance. During
the site visit, missing or broken bolts and ponded water were noted in flush mount
wells/piezometers. Some wells were not locked. Broken concrete pads and ant infestations
were also noted. These can provide conduits which may accommodate surface to subsurface
contaminant migration even in unused or dormant wells. Many wells were not clearly labeled
and several wells on the Jones property could not be located.

2. What is your assessment of the current performance of the remedy in place at the Site? The
soil remedy (soil removals and clay capping) has provided protection for exposure to site
soils. Lateral groundwater contaminant transport appears to be nominal, however vertical
contaminant migration is still observable. Groundwater source remedial attempts (Daramend
injections, DVE/NAPL extraction, pump and treat) on the THAN property have been
ineffective. Contaminant source areas continue to impact groundwater, and unless they are
addressed, groundwater is not expected to be returned to its most beneficial use.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or
remedial activities from residents in the past five years? Public concerns about this site have
not been reported to EPD.

4. Has your office conducted any site-related activities or communications in the past five
years? If so, please describe the purpose and results of these activities. EPD stays in
communication with EPA and has attended meetings with technical support personnel
evaluating the site's remedial progress and the potential effectiveness of additional remedial
actions.

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Five Year Review Interview

Page 2

5.	Are you aware of any changes to state laws that might affect the protectiveness of the Site's
remedy? No.

6.	Are you comfortable with the status of the institutional controls at the Site? If not, what are
the associated outstanding issues? Groundwater use restrictions should be extended to cover
the Jones Property. Dig restrictions should also be considered for both properties to protect
future construction and utility workers.

7.	Are you aware of any changes in projected land use(s) at the Site? No

8.	Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy? EPD and EPA are evaluating the current remedy in light of
remedial progress to date, to see if the remedy needs to be updated.

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Site Name: T.H. Agriculture & Nutrition EPA ID No.: GAD042101261

Co. (Albany Plant)

Interviewer Name: NA Affiliation: NA

Subject Name: James Hou Affiliation: EPA

Subject Contact Information: hou.iames@epa.gov
Time: NA Date: NA

Interview Location: NA

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: EPA Remedial Project Manager

1. What is your overall impression of the project, including cleanup, maintenance and reuse
activities (as appropriate)?

The remedial activities at this Site do not appear to be effective at reducing contaminant
concentrations in ground water. This appears to be partially a function of the subsurface
permeability, but also a function of the fact that source material appears to be left on the Site.
Fortunately, the subsurface permeability has hindered horizontal migration of the ground
water plume, thereby restricting exposure. Based on an analysis of historical ground water
data, it also appears that vertical migration is occurring, which directly contradicts the
statements made in the 2012 Second FYR Addendum.

2. What have been the effects of this Site on the surrounding community, if any?

I am not aware of any effects on the surrounding community, as a consequence of this Site.
Fortunately, the ground water plume is contained within the site boundaries, and impacts to
residential wells do not appear to be occurring.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or
remedial activities since the implementation of the cleanup?

I am not aware of any effects on the surrounding community, as a consequence of this site.
Fortunately, the ground water plume is contained within the site boundaries, and impacts to
residential wells do not appear to be occurring.

4. What is your assessment of the current performance of the remedy in place at the Site?

The remedy, as prescribed in the ROD, does not appear to be effective. The discontinuation
of the use pump and treat system has not been supplemented with any additional remedial
alternative. Further evaluation of the Site's remedy performance is warranted

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5.	Are you comfortable with the status of the institutional controls at the Site? If not, what are
the associated outstanding issues?

There are still some remaining institutional control issues remaining at the Site, specifically
as it relates to the ground water at on the Jones parcel and the utility easement. These will
need to be addressed.

6.	Are you aware of any community concerns regarding the Site or the operation and
management of its remedy? If so, please provide details.

I am not aware of any complaints or inquiries regarding environmental issues or the remedial
action from residents since implementation of the cleanup.

7.	Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy?

I do not have any additional comments, suggestions, or recommendations regarding the
management or operation of the Site's remedy.

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Appendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: T.H. Agriculture & Nutrition Co.
(Albany Plant)

Date of Inspection: 04/30/2013

Location and Region: Albany, GA, Region 4

EPA ID: GAD042101261

Agency, Office or Company Leading the Five-Year
Review: EPA

Weather/Temperature: Sunny, Warm 75°F

Remedy Includes: (Check all that apply)
I~1 Landfill cover/containment
E3 Access controls
^ Institutional controls
E3 Ground water pump and treatment
I~1 Surface water collection and treatment
~ Other:	

~ Monitored natural attenuation
I I Ground water containment
I~1 Vertical barrier walls

Attachments: ^ Inspection team roster attached

[~1 Site map attached

II. INTERVIEWS (check all that apply)

Owner of Facility

Name

Interviewed Q at site Q at office Q by phone
Problems, suggestions |~1 Report attached:

Title
Phone:

mm/dd/wvv
Date

2. O&M Staff

Interviewed ~ at site
Problems/suggestions [

Matthew E. Wilson
Name

Project Manager. URS Corp.
(contractor for PRP representative
for T. H. Agriculture & Nutrition.
LLC)

Title

05/09/2013
Date

3 at office Q by phone Phone: (860) 990-6784
Report attached: Yes	

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3.

Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.

Agency Georgia EPD
Contact

Ricky Hardy, P.G.
Name

Geologist
Title

Problems/suggestions ^ Report attached: Yes

Agency.

Contact

Name

Problems/suggestions ~ Report attached:.

08/26/2013
Date

(404)651-7524
Phone No.

Title

Date

Phone No.

Agency.

Contact

Name

Problems/suggestions Q Report attached:.

Title

Date

Phone No.

Agency
Contact

Name

Problems/suggestions Q Report attached:

Agency.
Contact

Title

Date

Phone No.

Name

Problems/suggestions |~1 Report attached:.

Title

Date

Phone No.

4.

Other Interviews (optional) N/A O Report attached: Yes

James Hou. EPA Remedial Project Manager, hou.iames@epa.gov

James W. Smith. Director of Environmental Projects, Project Realty LLC fPRP representative for T. H.
Agriculture & Nutrition. LLC). 05/07/2013. (913) 538-2357

Allan Gebhard. Senior Vice President. Barr Engineering Co. (contractor for PRP OfficeMax). 06/25/2013. (952)
832-2725: Dennis Radocha. OfficeMax. 06/25/2013. dennisradocha@officemax.com

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&IM Documents











1 1 O&M manual

~ Readily available

~ Up to date

|g] N/A





~ As-built drawings

[~l Readily available

Q] Up to date

13 N/A





I""! Maintenance logs

1 I Readily available

~ Up to date

13 N/A





Remarks:









2.

Site-Specific Health and Safety Plan

I"! Readily available

I~1 Up to date [X

|n/a



I~1 Contingency plan/emergency response plan

l~~l Readily available

~ Up to date E

I N/A



Remarks:









3.

O&M and OSHA Training Records

~ Readily available

~ Up to date E

I N/A



Remarks:









D-2

-------
4. Permits and Service Agreements

I~1 Air discharge permit
l~l Effluent discharge
f~| Waste disposal, POTW
n Other permits:

Remarks:

I~1 Readily available
~ Readily available
f~~1 Readily available
I~1 Readily available

~	Up to date

~	Up to date

~	Up to date

~	Up to date

IEIn/a
E<]n/a

^N/A
I^N/A

5. Gas Generation Records

Remarks:

n Readily available

Q Up to date

13 N/A

6. Settlement Monument Records

Remarks:

[~l Readily available

~ Up to date

IE] n/a

7. Ground Water Monitoring Records ^ Readily available
Remarks: The PRP contractor submits annual reports to EPA.

^ Up to date

~ n/a

8. Leachate Extraction Records

Remarks:

l~~l Readily available

~ Up to date

[El n/a

9. Discharge Compliance Records

Q Air O Readily available Q Up to date
~ Water (effluent) ~ Readily available ~ Up to date
Remarks:

El
E

n/a
n/a

10. Daily Access/Security Logs

Remarks:

I~1 Readily available

~ Up to date

13 N/a

IV.

O&M COSTS





1. O&M Organization

~ State in-house
1 1 PRP in-house
[~1 Federal facility in-house

n

1 1 Contractor for state
[X] Contractor for PRP
1 1 Contractor for Federal facility



D-3

-------
2. O&M Cost Records





1 1 Readily available

ED Up to date



[U Funding mechanism/agreement in place ^ Unavailable (PRP did not provide costs for OU1

remedy; no O&M activities or costs for OU2)



Original O&M cost estimate: Not SDecified for OU 1 remedv. Estimated at $500,000 for OU2 remedv.

~ Breakdown attached





Total annual cost by year for review period if available

From: mm/dd/wvv

To: mm/dd/wvv

1 1 Breakdown attached

Date

Date Total cost



From: mm/dd/wvv

To: mm/dd/wvv

1 1 Breakdown attached

Date

Date Total cost



From: mm/dd/wvv

To: mm/dd/wvv

O Breakdown attached

Date

Date Total cost



From: mm/dd/wvv

To: mm/dd/wvv

1 1 Breakdown attached

Date

Date Total cost



From: mm/dd/wvv

To: mm/dd/wvv

1 1 Breakdown attached

Date

Date Total cost



3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: N/A



V. ACCESS AND INSTITUTIONAL CONTROLS

^ Applicable Q N/A

A. Fencing

1. Fencing Damaged

1 I Location shown on site map ^

Gates secured Q N/A

Remarks: Perimeter fencing surrounds the THAN Parcel. Portions of the fencing around the THAN

Parcel need maintenance due to vegetation growth surrounding the DroDertv. Gates to the THAN Parcel

were locked and secured.Fencing surrounds most of the Jones Parcel. Gates at the Jones Parcel remain

open to allow access to the business operating on the parcel.

B. Other Access Restrictions

1. Signs and Other Security Measures Q Location shown on site map ^ N/A

Remarks:





C. Institutional Controls (ICs)

D-4

-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented EH Yes ^ No D N/A

Site conditions imply ICs not being fully enforced ~ Yes ^ No I~1 N/A

Type of monitoring (e.g., self-reporting, drive by): self-reporting

Frequency: Jones Parcel has daily on-site presence due to the business operating on the parcel. PRP
contractors regularly visit the THAN Parcel.

Responsible party/agency: URS/additional contractors

Contact Matthew Wilson

Principle
Hvdrogeologist/
Project Manager

04/30/201

(860) 990-
6784

Name

Title

Date

Phone no.

Reporting is up to date

1X1 Yes

N/A

Reports are verified by the lead agency

^ Yes

~ n/a

Specific requirements in deed or decision documents have been met

H] Yes

~ N/A

Violations have been reported .

1 1 Yes

~ N/A

Other problems or suggestions: Q Report attached

Adequacy Q ICs are adequate ^ ICs are inadequate Q N/A

Remarks: Institutional controls to restrict ground water use and residential use on the THAN Parcel have
been put in place. Institutional controls to restrict residential land use on the Jones Parcel have been put in
place. Institutional controls should be put in place to restrict disturbance of remaining subsurface soil
contamination at the Site. Institutional controls restricting sitewide around water use as required in the
OU1 ROD need to be put in place at the Jones Parcel.

General

Vandalism/Trespassing Q Location shown on site map ^ No vandalism evident

Remarks:

Land Use Changes On Site Q N/A

Remarks: The city-owned easement between the THAN Parcel and the Jones Parcel is marked indicating
that excavation mav occur in the near future. The Jones Parcel remains in industrial use. The THAN
Parcel and on-site building remain vacant.

Land Use Changes Off Site [X] N/A

Remarks:

VI. GENERAL SITE CONDITIONS

Roads Q Applicable ^ N/A

Roads Damaged Q Location shown on site map ~ Roads adequate ^ N/A

Remarks:

Other Site Conditions

Remarks:

D-5

-------
VII. LANDFILL COVERS ~ Applicable ^ N/A

A.

Landfill Surface





1.

Settlement (low spots)

|~1 Location shown on site map

1 1 Settlement not evident



Arial extent:



Depth:



Remarks:





2

Cracks

1 1 Location shown on site map

I~1 Cracking not evident



Lengths:

Widths:

Depths:



Remarks:





3.

Erosion

1 1 Location shown on site map

1 1 Erosion not evident



Arial extent:



Depth:



Remarks:





4.

Holes

1 I Location shown on site map

1 I Holes not evident



Arial extent:



Depth:



Remarks:





5.

Vegetative Cover

1 1 Grass

l~~l Cover properly established



C] No signs of stress

1 1 Trees/shrubs (indicate size and locations on a diagram)



Remarks:





6.

Alternative Cover (e.g..

armored rock, concrete)

~ N/A



Remarks:





7.

Bulges

|~1 Location shown on site map

[~1 Bulges not evident



Arial extent:



Height:



Remarks:





8.

Wet Areas/Water Damage ~ Wet areas/water damage not

evident



1 1 Wet areas

[~1 Location shown on site map

Arial extent:



1 1 Ponding

I~1 Location shown on site map

Arial extent:



1 1 Seeps

1 1 Location shown on site map

Arial extent:



[~l Soft subgrade

1 1 Location shown on site map

Arial extent:



Remarks:





9.

Slope Instability

1 1 Slides

l~l Location shown on site map



I"! No evidence of slope instability





Arial extent:







Remarks:





B.

Benches ~ Applicable O N/A





(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in



order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

D-6

-------
1.

Flows Bypass Bench

1 1 Location shown on site map

[~1 N/A or okay



Remarks:





2.

Bench Breached

Remarks:

1 1 Location shown on site map

I~1 N/A or okay

3.

Bench Overtopped

Remarks:

1 1 Location shown on site map

I~1 N/A or okay

C.

Letdown Channels

~ Applicable Q N/A





(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)

1.

Settlement (Low spots)

I~1 Location shown on site map

I~1 No evidence of settlement



Arial extent:



Depth:



Remarks:





2.

Material Degradation

Material tvpe:

I~1 Location shown on site map

l~l No evidence of degradation
Arial extent:



Remarks:





3.

Erosion

Arial extent:
Remarks:

~ Location shown on site map

I~1 No evidence of erosion
Depth:

4.

Undercutting

Arial extent:
Remarks:

~ Location shown on site map

PI No evidence of undercutting
Depth:

5.

Obstructions

Type:

l~1 No obstructions



PI I-ocation shown on site map Arial extent:





Size:







Remarks:





6.

Excessive Vegetative Growth Type:
|~~1 No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
|~~1 Location shown on site map Arial extent:





Remarks:





D.

Cover Penetrations

I~1 Applicable ~ N/A



D-7

-------
1.

Gas Vents ~ Active

~ Passive



1 1 Properly secured/locked Q Functioning

1 1 Routinely sampled

1 1 Good condition



1 1 Evidence of leakage at penetration

I~1 Needs maintenance

IKI N/A



Remarks:





2.

Gas Monitoring Probes







1 1 Properly secured/locked Q Functioning

1 1 Routinely sampled

1 1 Good condition



1 1 Evidence of leakage at penetration

1 1 Needs maintenance

~ n/a



Remarks:





3.

Monitoring Wells (within surface area of landfill)







1 1 Properly secured/locked O Functioning

1 1 Routinely sampled

~ Good condition



1 1 Evidence of leakage at penetration

1 1 Needs maintenance

~ N/A



Remarks:





4.

Extraction Wells Leachate







1 1 Properly secured/locked Q Functioning

[~1 Routinely sampled

1 1 Good condition



1 1 Evidence of leakage at penetration

l~~l Needs maintenance

~ N/A



Remarks:





5.

Settlement Monuments Q Located
Remarks:

1 1 Routinely surveyed

~ n/a

E.

Gas Collection and Treatment Q Applicable

~ n/a



1.

Gas Treatment Facilities







1 1 Flaring Q Thermal destruction

1 1 Collection for reuse



1 1 Good condition O Needs maintenance





Remarks:





2.

Gas Collection Wells, Manifolds and Piping







[~1 Good condition Q Needs maintenance





Remarks:





3.

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)



1 1 Good condition Q Needs maintenance Q N/A





Remarks:





F.

Cover Drainage Layer Q Applicable

~ N/A



1.

Outlet Pipes Inspected O Functioning

~ N/A





Remarks:





2.

Outlet Rock Inspected Q Functioning
Remarks:

~ n/a



D-8

-------
G. Detention/Sedimentation Ponds ~ Applicable

~ N/A

1. Siltation Area extent: Depth:

~ n/a

1 1 Siltation not evident



Remarks:



2. Erosion Area extent: Depth:



I~1 Erosion not evident



Remarks:



3. Outlet Works Q Functioning

~ N/A

Remarks:



4. Dam ~ Functioning

~ n/a

Remarks:



H. Retaining Walls ~ Applicable O N/A

1. Deformations GI Location shown on site map

[~1 Deformation not evident

Horizontal displacement: Vertical displacement:

Rotational displacement:



Remarks:

•

2. Degradation Q Location shown on site map

f~l Degradation not evident

Remarks:



1. Perimeter Ditches/Off-Site Discharge ~ Applicable

~ n/a

1. Siltation Q Location shown on site map

1 1 Siltation not evident

Area extent:

Depth:

Remarks:



2. Vegetative Growth ~ Location shown on site map

~ n/a

1 1 Vegetation does not impede flow



Area extent:

Type:

Remarks:



3. Erosion Q Location shown on site map

1 1 Erosion not evident

Area extent:

DeDth:

Remarks:



4. Discharge Structure O Functioning

~ N/A

Remarks:



VIII. VERTICAL BARRIER WALLS ~ Applicable

13 N/A

D-9

-------
1.

Settlement EH Location shown on site map [H Settlement not evident

Area extent: Depth:

Remarks:

Performance Monitoring Tvpe of monitoring:

1 1 Performance not monitored

Freguencv: 1 1 Evidence of breaching

Head differential:

Remarks:

IX.

GROUND WATER/SURFACE WATER REMEDIES ^Applicable ~ N/A

Ground Water Extraction Wells, Pumps and Pipelines ^ Applicable Q N/A

Pumps, Wellhead Plumbing and Electrical

Q Good condition Q All required wells properly operating ^ Needs maintenance I~1 N/A

Remarks: The around water treatment svstem is located within the building on the THAN Parcel. Use of

the svstem has been discountinued and the svstem would not be operational without significant

maintenance activity.

Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

|~~1 Good condition ^ Needs maintenance

Remarks: The around water svstem will need maintenance if it is Dut back into use.

Spare Parts and Equipment

~ Readily available ~ Good condition ^ Requires upgrade ^ Needs to be provided

Remarks: The around water svstem will need maintenance if it is put back into use.

B. Surface Water Collection Structures, Pumps and Pipelines Q Applicable ^ N/A

Collection Structures, Pumps and Electrical

l~~l Good condition n Needs maintenance

Remarks:

Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

1 1 Good condition HH Needs maintenance

Remarks:

Spare Parts and Equipment

1 1 Readily available dH Good condition O Requires upgrade Q Needs to be provided

Remarks:

Treatment System ^ Applicable |~~1 N/A

D-IO

-------
1.	Treatment Train (check components that apply)

I 1 Metals removal	[] Oil/water separation	Q Bioremediation

1 | Air stripping ^ Carbon adsorbers
I I Filters:	

Q Additive (e.g., chelation agent, flocculent):	

I I Others: The 1993 QUI ROD called for oxidation/ultraviolet and carbon treatment. The 1995 ESP
changed the remedy to carbon treatment only.

I I Good condition	Q Needs maintenance

l~l Sampling ports properly marked and functional

Q Sampling/maintenance log displayed and up to date

~	Equipment properly identified

n Quantity of ground water treated annually:	

I~l Quantity of surface water treated annually:	

Remarks: The PRP has discontinued use of the ground water treatment system. The system is currently
not in operating condition.

2.'	Electrical Enclosures and Panels (properly rated and functional)

~	N/A I I Good condition	^ Needs maintenance
Remarks:	

3.	Tanks, Vaults, Storage Vessels

~	N/A I~1 Good condition Q Proper secondary containment [3 Needs maintenance
Remarks:	

4.	Discharge Structure and Appurtenances

l~l N/A O Good condition	^ Needs maintenance

Remarks:	

5.	Treatment Building(s)

I I N/A	Good condition (esp. roof and doorways)	^ Needs repair

I I Chemicals and equipment properly stored

Remarks: There is a hole in one of the skylights in the roof.

6.	Monitoring Wells (pump and treatment remedy)

~	Properly secured/locked ^ Functioning ^ Routinely sampled ~ Good condition

n All required wells located ^ Needs maintenance	O N/A

Remarks: Most ground water monitoring wells were found locked and secured. Several well were found
unlocked or without locks on the THAN Parcel. Wells identified on both parcels were in functioning
condition but could use maintenance. Several wells on the Jones Parcel, as well as off-site perimeter
wells, were unable to be located. The PRP contractor indicated that although site inspection participants
could not locate some of the wells, the wells had been included in the 2012 annual ground water .
sampling.

D-l I

-------
D. Monitoring Data

1. Monitoring Data

153 Is routinely submitted on time

[X] Is of acceptable quality

2. Monitoring Data Suggests:

153 Ground water plume is effectively contained

l~~l Contaminant concentrations are declining

E. Monitored Natural Attenuation

Monitoring Wells (natural attenuation remedy)

I I Properly secured/locked Q Functioning Q Routinely sampled HH Good condition

I I All required wells located Q Needs maintenance ^ N/A

Remarks:

X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical

nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).

The remedy was designed to remove contamination from both soil and ground water and has not been
effective at achieving the cleanup goals established in the Site's decision documents. For QUI, soil
contamination has been addressed through two removal actions. Ground water treatment was selected to
address ground water contamination. The treatment system proved ineffective and operation of the system
ended in 2003. The PRP conducted a bioremediation pilot project to address ground water contamination
through injections instead of ground water extraction and treatment. The pilot project concluded the
bioremediation was ineffective. Ground water will require an additional remedy if it is to achieve selected
cleanup goals. The vegetated clay cap over the OU1 parcel is functioning and well maintained. For OU2.
the selected remedy included excavation and treatment of contaminated soil through low temperature
thermal desorption. Soils were treated to industrial use cleanup levels and placed back on site. Cleanup
did not address all contamination at OU2 due to its location beneath the building on the Jones Parcel. It
was determined that leaving the soil contamination in place would not impact the QUI ground water

Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
None

Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.

None

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
The OU1 remedy for around water should be updated to effectively address ground water contamination.

Site inspection participants:
James Hou, EPA Region 4
Ben Bentkowski, EPA Region 4
Rick Hardy, Georgia EPD

D-12

-------
James Smith, Project Realty LLC (PRP representative)
Matthew Wilson, URS (O&M contractor)

Treat Suomi, Skeo Solutions
Lynette Wysocki, Skeo Solutions

D-13

-------
Appendix E: Photographs from Site Inspection Visit

Gated entrance to the THAN Parcel

Entrance to the building and perimeter fencing at the THAN Parcel

E-l

-------
View of flush mounted wells, yellow monitoring wells and white PVC temporary wells on the
eastern portion of the THAN Parcel near the fence line with the Jones Parcel

View (facing west) of the vegetated cap over the THAN Parcel

E-2

-------
E-3

-------
Fencing in need of maintenance along the northern boundary of the THAN Parcel

View (facing northwest) of the THAN Parcel

E-4

-------
Soil borings stored inside of the building on the THAN Parcel

Water treatment system (not in operation) inside of the building on the THAN Parcel

E-5

-------
City of Albany surveying flags for possible construction in easement between the THAN Parcel

and the Jones Parcel

E-6

-------
Entrance to the Jones Parcel

Jones Welding & Industrial Supply business located on the Jones Parcel

E-7

-------
Off-site perimeter wells located on property east of the Jones Parcel

E-8

-------
Appendix F: Screening-Level Vapor Intrusion and Toxicity Value Evaluation

A screening-level vapor intrusion evaluation was performed following a tiered approach. First,
site ground water concentrations were compared to conservative screening levels for vapor
intrusion, VISLs. As shown in Table F-l below, the results of the screening indicate that EDB
exceeds the industrial VISLs based on a 1 x 10"6 and 1 x 10° risk, but the maximum detected
concentration is below the 1 x 10"4 risk level. Under a future residential land use scenario,
concentrations of EDB exceed the VISLs for all three risk levels. Further, the maximum
concentration of total xylene exceeds the non-cancer-based VISL for both industrial and
residential land uses based on a target hazard index (HI) of 1.0 for both parcels. Both parcels are
restricted from residential development. The THAN Parcel does not have current full-time
industrial workers conducting work activities within the warehouse, but the Jones Parcel does
include such activity at the welding supply facility and associated office space. Although there is
likely significant air circulation and use of large open doors within the welding facility, there is
also an associated office building on site. Additional vapor intrusion evaluation was conducted
for the Jones Parcel using a screening-level vapor intrusion model.

Table F-l: Comparison of 2012 Ground Water Concentrations to VISLs

COCs

Maximum
Concentration3
(Mg/L)

2013 <

Ground Water VISLb (ng/L)

Industrial

Risk
lO^/lO^/lO"4

Residential

Risk
10 VlO^/lO"4

Industrial
HI=1.0

Residential
HI=1.0

EDB

61

i.i / ii mo

0.2/2.1/21

ND

ND

Xylenes

17,000

ND

ND

2,900

680

Notes:

a.	Based on maximum 2012 concentration detected in shallow wells screened across the
water table. Well GB-3D for EDB (no well with elevated levels screened across the
top of water, therefore selected GB-3D, which is the current maximum) and well MW-
N2 for xylene (screen interval is 10 to 35 feet below ground surface versus top of
water at 24 feet below ground surface)

b.	EPA VISLs for ground water based on the average temperature for shallow ground
water of 67 degrees Fahrenheit or 19.4 degrees Celsius (from EPA, 2004) and cancer
risk of 1 x 10"6 and 1 x 10"4 for EDB and a non-cancer HI of 1.0 for xylene obtained
at: http://www.epa.gov/reg3hwmd/risk/human/rb-

concentration table/Generic Tables/index.htm (accessed 4/17/13)

HI: Non-cancer hazard index

Bold italicized value: Maximum ground water concentration exceeds the risk- or Hi-based
VISL

ND: Value not determined

Because both properties are restricted from residential development, only xylene was evaluated
further using EPA's version of the Johnson and Ettinger model (JEM) for ground water (GW-
SCREEN-Feb04.xls). EPA's spreadsheet model replicates the implementation that EPA Office
of Solid Waste and Emergency Response used in developing its draft vapor intrusion guidance
(EPA 2002), but includes a number of inputs that are facilitated by the spreadsheet: ground water

F-l

-------
temperature, soil type, depth to ground water, and building construction. EPA's online version
of the JEM, also known as the JEMlite, was not used because this model does not allow for input
of a silty clay soil type. Therefore, EPA's screening level JEM spreadsheet was used to evaluate
xylene as the primary COC using the assumptions in Table F-2 below.

Table F-2: Assumptions Used in the JEM Model for Ground Water

Model Parameter

Assumption

Notes

Temperature of
ground water

19.4 degrees
Celsius

Obtained from EPA's JEM user's guide for
Georgia2

Building
construction

slab-on-grade
construction

Building at site is slab-on-grade

Soil type

silty clay

Soil type for the upper Residuum as described in
the RIs for both OU1 and OU2. Used JEM
default soil properties for silty clay

Receptor well

MW-34UR
24,000 ng/L

Well with highest xylene concentration adjacent
to the current building on the Jones Parcel

Depth to water

22 feet (670
centimeters)

Well is 45 feet in total depth with the screen at
35 to 45 feet below ground surface with the top
of water measured at 22 to 23 feet below ground
surface during 2008 to 2012. Nearly all the
monitoring wells not screened at the top of
water; therefore, this imparts some uncertainty in
the modeling.

Average vapor flow
rate into building

5 liters per
minute

Model default

The JEM model was only used to predict the indoor air concentration. Because the model has
three options for evaluating xylene, all three isomers were evaluated to include the ortho-, meta,
and para- isomer. The predicted indoor air concentration was compared to EPA's industrial RSL
for indoor air to estimate the industrial non-cancer health hazard for xylene at the Site. As shown
in Table F-3, the non-cancer HI for all three isomers of xylene assuming each isomer is at a
maximum concentration of 24,000 jag/L is well below the target level of 1.0, which suggests that
the elevated concentrations of xylene in ground water do not pose an indoor air concern on the
Jones Parcel

2 EPA, 2004. User's Guide for Evaluating Subsurface Vapor Intrusion into Buildings.
http://www.eDa.gov/oswer/riskassessment/airmodel/Ddf/2004 0222 3phase users guide.pdf

F-2

-------
Table F-3: Evaluation of Vapor Intrusion Using EPA's Screening Ground Water JEM

Maximum

Modeled

Industrial RSL for

Modeled VI

Contaminant

Ground Water

Indoor Air

Indoor Air (ju.g/m3)

Evaluation

Concentration
(f*g/L)

Concentration

Og/m3)a

Non-Cancer
HI = 1

Non-Cancer HIb

Industrial Exposure

Xylene, m-

24,000

49.1

2.900

0.02

Xylene, o-

24,000

48.4

2,900

0.02

Xylene p-

24,000

55.4

2,900

0.02

Notes:

a. EPA JEM spreadsheet used:

httD://www.eDa.eov/oswer/riskassessment/airmodel/iohnson ettinger.htm

b. Non-cancer His were calculated as follows:

HI = Modeled indoor air level + Industrial Non-Cancer RSLAir

HI: Non-cancer HI

The ground water cleanup goals identified for the COCs were the MCLs for EDB and toxaphene,
and 1 x 10"4 risk-based levels for alpha- and beta-BHC, DDT, aldrin and dieldrin. The MCLs for
EDB and toxaphene remain unchanged. To evaluate whether the risk-based cleanup goals remain
valid for alpha- and beta-BHC, DDT, aldrin and dieldrin, the cleanup goals were compared to
EPA's tap water RSLs adjusted to a 1 x 1 (T4 risk level. As shown in Table F-4, the cleanup goals
are slightly less stringent than the tap water RSLs. Although the cleanup goals are less stringent,
the remedy remains protective for the short term. The active business on site obtains potable
water from the public water supply. Ground water use restrictions are in place at the THAN
Parcel. EPA continues to work with the owners of the Jones Parcel to implement ground water
use restrictions.

F-3

-------
Table F-4: Evaluation of Toxicity Value Changes on Health-Based Cleanup Goals for
Ground Water



Health-Based







COCs8

Cleanup Goal

from 1993
RODb (ng/L)

EPA Tap Water
RSLC (ng/L)

Change

Equivalent
Risk Leveld

1,2-Dibromoethane (EDB)

NAe

NA

None

NA

Toxaphene

NAe

NA

None

NA

Alpha-BHC

4.1

0.62

More stringent

6.6 x 10"4

Beta-BHC

5.1

2.2

More stringent

2.3 x 10"4

4, 4'-DDT (DDT)

27

20

More stringent

1.4 x 10*4

Aldrin

0.54

0.4

More stringent

1.4 x 10"4

Dieldrin

0.57

0.15

More stringent

3.8 x 10"4

Notes:

a.	COCs from 1993 ROD

b.	Cleanup goals for COCs without established MCLs were residential health-based criteria
(1 x 10"4 risk level for carcinogens)

c.	EPA November 2012 RSLs for tap water adjusted for a 1 x 10"4 risk level for carcinogens
obtained at: http://www.epa.gov/reg3hwmd/risk/human/rb-

concentration table/Generic Tables/index.htm (accessed 4/17/13)

d.	The cancer risks were calculated using the following equation, based on the fact that
RSLs are derived based on 1 x 10"6 risk:

Cancer risk = (1993 ROD Cleanup Level tap water ground water cancer RSL) x 1CT4

e.	Based on federal MCL

NA: Not applicable	

The OU1 ROD identified health-based cleanup goals for soil based on residential exposure and
a 1 x 10"6 cancer risk. However, numerical cleanup goals were not presented in the OU1 ROD
because the cleanup goals had already been met by the 1992 removal action. The 1992 Removal
Action Work Plan prepared by WCC states that "surface soil will be excavated to achieve the
removal action objectives, based on industrial worker scenario with a 10"6 target cancer
risk... submitted to EPA and conditionally approved on January 31, 1992." To evaluate if the
cleanup goals remain valid for surface soil at OU1, the values listed in the Removal Action
Work Plan were compared to EPA RSLs for soil, based on industrial exposure. As shown in
Table F-5, the cleanup goals from the 1992 removal action are slightly more stringent but within
EPA's acceptable risk range of 1 x 10"6 to 1 x 10"4 and support that the industrial land use-based
cleanup goals remain valid. However, as presented in Section 7.1 of this FYR Report,
concentrations remain in the subsurface soil of the THAN Parcel that exceed the industrial risk-
based cleanup goals.

F-4

-------
Table F-5: Evaluation of Toxicity Value Changes on Health-Based Cleanup Goals for OU1
Surface Soil

COCs"

Health-Based
Cleanup Goal from
the OU1 1992
Removal Action
Work Plan2 (iug/kg)

EPA
Soil RSLb
(mg/kg)

Change

Equivalent
Risk Levelc

Alpha-BHC

0.39

0.27

More stringent

1.4 x 10"6

Beta-BHC

1.4

0.96

More stringent

1.5 x 10"6

4, 4'-DDT

7.2

7.0

More stringent

1.0 x 10"b

Toxaphene

2.2

1.6

More stringent

1.4 x 10"b

Notes:

a.	COCs from Removal Action Work Plan. Health-based criteria (1 x 10"6 risk level for
carcinogens assuming an industrial worker exposure)

b.	EPA November 2012 RSLs for soil based on a 1 x 10"6 risk level for carcinogens and
industrial exposure obtained at: httD://www.eDa.eov/ree3hwmd/risk/human/rb-
concentration table/Generic Tables/index.htm (accessed 4/17/13)

c.	The cancer risks were calculated using the following equation, based on the fact that
RSLs are derived based on 1 x 10~6 risk:

Cancer risk = (1992 Cleanup Goal + Industrial Soil Cancer RSL) x 10"6

The OU2 ROD identified health-based cleanup goals for soil that were based on industrial
exposure and a 1 x 10"? cancer risk. To evaluate if the cleanup goals remain valid for surface soil
at OU2, the values listed in the 1996 ROD were compared to EPA RSLs for soil based on
industrial exposure. As shown in Table F-6, the 1996 ROD soil cleanup goals are more stringent
but remain within EPA's acceptable risk range of 1 x 10~6 to 1 x 10"4 and support that the
industrial land use-based cleanup goals remain valid for OU2. However, as presented in Section
7.1 of this F YR Report, concentrations remain in the subsurface soil of the Jones Parcel that
exceed the industrial risk-based cleanup goals.

F-5

-------
Table F-6: Evaluation of Toxicity Value Changes on Health-Based Cleanup Goals for OU2
Surface Soil

COCsa

Health-Based Cleanup
Goal from the OU2
1996 ROD" (mg/kg)

EPA Soil RSL
(mg/kg)

Change

Equivalent Risk
Levelc

4, 4'-DDT

More stringent

1.3 x 10

1.8 x 10"s

Toxaphene

More stringent

Notes:

a. COCs from OU2 ROD based on a 1 x 10"5 risk level for carcinogens assuming an industrial
worker exposure

b. EPA November 2012 RSLs for soil adjusted to a 1 x lO "1 risk level for carcinogens and
industrial exposure obtained at: http://www.epa.gov/reg3hwmd/risk/human/rb-
concentration table/Generic Tables/index.htm (accessed 4/17/13)

c. The cancer risks were calculated using the following equation, based on the fact that RSLs
are derived based on 10~6 risk:

Cancer risk = (1996 ROD Cleanup Goal Industrial Soil Cancer RSL) * 10"5

According to the 2008 FYR, ground water monitoring detected xylene at levels well above the
MCL. Further, due to a change in EPA non-cancer oral RfD and inhalation RfCs, the
promulgated MCL of 10,000 (ig/L for xylene is no longer considered protective. EPA has
developed a health protective level of 3,500 j_tg/L based on the current toxicity assessment and
standard drinking water exposure assumptions (including EPA Region 4 assumptions for
showering exposure to volatilized chemicals).

EPA Region 4 recommends using a concentration of 3,500 fig/L as a health protective remedial
level for total xylenes in ground water. Although the site data exceed the current federal MCL
and EPA Region 4's recommended value of 3,500 |ig/L, the remedy remains protective. There
are no potables uses of ground water at the Site because the active on-site business gets potable
water from the public water supply and vapor intrusion under the industrial land use scenario is
not a pathway of concern. Ground water use restrictions are in place for the THAN Parcel. EPA
continues to work with the owners of the Jones Parcel to implement ground water use
restrictions.

Finally, EPA Office of Inspector General issued two reports in 2005 J'4 recommending that new
analytical methods and toxicity criteria should be developed to identify and evaluate toxaphene
contamination. Weathered toxaphene results in the formation of degradation products (parlars),
which have been found to have a much higher toxicity than toxaphene itself.3 As an initial effort

3 "More Information is Needed on Toxaphene Degradation Products" EPA Office of the Inspector General. Report
No. 2006-P-00007, December 16, 2005.

4 "Appropriate Testing and Timely Reporting Are Needed at the Hercules 009 Landfill Superfund Site" EPA Office
of Inspector General. September 26, 2005.

? Simon, Ted and Manning, Randall, "Development of a reference dose for the persistent congeners of weathered
toxaphene based on in vivo and in vitro effects related to tumor promotion" (2006). U.S. Environmental Protection
Agency Papers. Paper 178

F-6

-------
to characterize the toxaphene degradation products present in a subset of the Site's monitoring
wells, six wells were sampled in May 2008 (MW-26L, GB-9D, MW-20U, MW-N2, GB-03I and
MW-33UR) and analyzed using a gas chromatograph-negative ion mass spectrometry method.
EPA Region 4 developed a PRG of 0.03 (ig/L in 2006 for the sum of three of the toxaphene
degradation products for which toxicity information is available. Based on this preliminary
analysis, four of the six wells were found to exceed the PRG of 0.03 (ig/L. Depending on the
distribution of the parlars, their presence and concentration may impact future remedies at the
Site. However, further evaluation of toxaphene parlars and impacts to remedy protectiveness
cannot be determined until EPA has established toxicity values for toxaphene parlars and
commercial laboratories are certified in toxaphene parlar analysis.

Changes in toxicity values were evaluated for all contaminants of potential concern (COPCs)
evaluated in the 1992 BRA. Table F-7 lists the toxicity values used in the 1992 risk assessment
for OU1. Toxicity values for COPCs for OU2 were obtained from the 1996 ROD. Oral cancer
slope factors (CSFs) and inhalation unit risk factors (IURs) are used for evaluating cancer risks
while oral RfDs and inhalation RfCs are used for evaluating non-cancer hazards. As shown in
Table F-7, many of the values have not changed or have become less stringent with a few
exceptions. The CSFs for atrazine, benzene, and trichloroethene are slightly higher (e.g., less
than one order of magnitude), which translate to slightly higher risks than originally calculated.
The increase in cancer potency for atrazine, benzene and trichloroethene is not expected to result
in additional COCs identified for cleanup because the toxicity changes are less than an order of
magnitude.

Oral RfD and inhalation RfC values are the toxicity values used to evaluate non-cancer effects.
An increase in an RfD or RfC indicates that the non-cancer effects are less severe while a
decrease in these values would indicate that the chemical is more toxic. According to the OU1
and OU2 RODs, a number of chemicals were initially identified as COCs. However, following
the cumulative risk analysis, the COC list was reduced to a subset of chemicals that were the risk
or hazard index drivers. Several OU1 COCs now have more stringent non-cancer toxicity values
to include gamma-BHC, cyanide, tetrachloroethylene (PCE) and xylene. Similarly, in the OU2
ROD, beryllium, manganese and vanadium were identified as preliminary COCs in soil. Only
manganese was retained as a final soil COC. These changes do not impact the protectiveness of
the ground water remedy. Potable ground water is provided from a public water supply and
ground water use restrictions are in place.

F-7

-------
Table F-7: Toxicity Value Comparison Table

Contaminant

Carcinogenic toxicity changes

Non-carcinogenic toxicity changes

C
(m

)ral CSF
>/kg-day)-l

-------
Toxaphene'

1.1E+00

1.1E+00

None

NE

3.2E-04

NE

ND

ND

NA

NE

ND

NE

Metals

Aluminum'

ND

ND

None

NE

ND

NE

1.0E+00

1.0E+00

None

NE

5.0E-03

NE

Arsenic'

1.75E+00

1.5

Less
stringent

4.3 E-03

4.3 E-03

None

3.0E-04

3.0E-04

None

ND

1.5E-05

NE

Beryllium'

4.3+00

ND

NA

2.4E-03

2.4E-03

None

5.0E-03

2.0E-03

More
stringent

ND

2.0E-05

NE

Cadmium'

ND

ND

NA

I.8E-03

I.8E-03

None

1.0E-03

I.0E-03

None

ND

2.0E-05



Hexavalent
chromium'

ND

ND

None

I.2E-02

I.2E-02

None

5.0E-03

3.0E-03

None

1.0E-04

1.0E-04



Cyanide

ND

ND

None

NE

ND

NE

2.0E-02

6.0E-04

More
stringent

NE

8.0E-04

NE

Iron'

ND

ND

None

ND

ND

None

3.0E-0I

7.0E-0I

Less
stringent

ND

ND



Lead'

ND

ND

None

ND

ND

None

ND

ND

None

ND

ND



Manganese"

ND

ND

None

NE

ND

NE

I.4E-0I

2.4E-02

More
stringent

NE

5.0E-05

NE

Vanadium'

ND

ND

None

ND

ND

None

7.0E-03

5.0E-03

More
stringent

ND

ND



Organic Compounds

Benzene

2.9E-02

5.5E-02

More
stringent

NE

7.8E-06

NE

ND

4.0E-03

New

NE

3.0E-02

NE

Benzo(a)pyrenec

7.3E+00

7.3E+00

None

8.8E-04

1.1 E-03

More
stringent

ND

ND

None

ND

ND

None

Benzo(b)fluoranthene'

7.3E+00

7.3E-01

Less
Stringent

ND

1.1E-04

New

ND

ND

None

ND

ND

None

Chlorobenzene

ND

ND

None

NE

ND

NE

2.0E-02

2.0E-02

None

NE

5.0E-02

NE

Chloroform

3.1E-02

3.1E-02

None

NE

2.3E-05

NE

1.0E-02

1.0E-02

None

NE

9.8E-02

NE

Dichlorobenzene, 1,4-

5.4E-03

5.4E-03

None

NE

I.IE-05

NE

ND

7.0E-02

New

NE

8E-01

NE

Dichloropropane, 1,2-

6.8E-02

3.6E-02

Less
stringent

NE

1.0E-05

NE

ND

9.0E-02

New

NE

4.0E-03

NE

Indeno (1,2,3)pyrenec

7.3E+00

7.3E-01

Less
Stringent

ND

1.1 E-04

New

ND

'ND

None

ND

ND



Methylnaphthalene, 2-

ND

ND

None

NE

ND

NE

ND

4.0E-03

New

NE

ND

NE

Naphthalene

ND

ND

None

NE

3.4E-05'

NE

4.0E-03

2.0E-02

Less
stringent

NE

3.0E-03

NE

Tetrachloroethene

5.IE-02

2.1 E-03

Less
stringent

NE

2.6E-07

NE

1.0E-02

6.0E-03

More
stringent

NE

4.0E-02

NE

F-9

-------
Trichloroethcne

l.IE-02

4.6E-02

More
stringent

NE

4.1E-06

NE

ND

5E-04

New

NE

2.0E-03

NE

Trichlorobenzene-
1,2,4-

ND

2.9E-02

New

NE

ND

NE

1.3E-03

2.0E-03

Less
stringent

NE

2.0E-03

NE

2,4,5-

T richlorophenoxyaceti
c acid (2,4,5-T)

ND

ND

None

NE

ND

NE

1.0E-02

1.0E-02

None

NE

ND

NE

Xylenes

ND

ND

None

NE

ND

NE

2.0E+00

2.0E-01

More
stringent

NE

1.0E-01

NE

Notes:

a. Toxicity values from BRA for the T.H. Agriculture and Nutrition Site, Albany, Georgia, Prepared by Woodward-Clyde Consultants, February 1992
b Values available for comparison from HPA's November 2012 Regional Screening Table (httn://www eoa.20v/re23hwmd/risk/human/rb-
concentration table/Generic Tables/Ddfmaster si table run NOV2012.Ddfl







c.	Toxicity values from 1996 ROD for OU2

d.	Contaminant also known as 1,2-Dibromoethane and EDB

e.	Contaminant information based on diet-based RSL value because manganese was a COC in soil only
New: New value: no toxicity value previously available

ND: Not determined

NE: Inhalation exposure not evaluated in the 1992 BRA; therefore, a direct comparison to values could not be conducted











F-10

-------
Appendix G: Deed Documents Containing Institutional Controls

tlXfcSC JWTCJW THIS tOCOMBfT IDs
sdbfln Wlllluwi ^

Run-ton 4

¦»tiaa«fiank Iliti - Salt* 4100

9 wnl757i-sLt065

(OO FMehtTM Street, U.S.

a*of,u "MOfttaUHL

THIS DECLARATION OF RESTRICTION ((Us 'Declaration'), nude anil catered

into u of the 3rd day of Wn»«»b«T	. 1997. by T H AGRICULTURE A

NUTRITION COMPANY, INC. ("THAN"):

WHEREAS. THAN 0 (he CWTCSI owner of rrrtaizi property (Ibe 'Property') touted
ai 1401 Schley Avenue. Albany. Dougherty County. Georgia. said Property being more
particularly described u fiat certain tract or parcel of lend dcsiiailtd and lawn as Lot 25
in Subdivision "C" of Misyn Pecan Groves Subdrvtsiao being pan of the original Land Lra
369 is die First District of Doegheny County, Georgia. and shown on t plat of said Land
Lot 369 recorded in the Office of the Clerk of die Superior Coon of Dougherty County.
Geetgia in Phu Boole 1, Page 15. such Property being 11m same as that described in dial
certain Warranty Deed dated December 29, 1967 tad recorded is Deed Boole 394, hge 16],
aforesaid records: and

WHEREAS, ike United State* Environmental Protection Agency, Region IV (the
"EPA"), hu directed THAN id execiBa and record a deed restncaoo with respect lo (be
Property in accordance with die EPA's Record of Decision foe (be T H Agrieulnm A
Nutrition Company. lac. Site. Operable Unit One. Albany. Dougherty County, Georgia,
dared May 21. 1993 (the "Record of Decision'}.

NOW. THEREFORE. THAN hereby declare* that (he Property a and thai! be held,
transferred, told tad conveyed auhjeci to the rsstnettoe hereinafter tat forth, luck restriction
being binding on all parties having and acquiring any rigid, tick or (merest m (he Property or
any part thereof,

Any and all groundwater withdrawn from die Property shall not be used for any
reason or purpose males*, prior to such use, (be groundwater meets the Remedial Acsiot^

RE5TB1CHQM

Objectives set forth in the Record of Decision.

5

P

G-l

-------
.1757«n06i

IN WITNESS WHEREOF, THAN bis caused this Declaration 10 tie executed by its
duly authorized officers the day and year First above written.

Signed, sealed and delivered
in die presence of:



dL

My Commission Expires'.

fyti, ( /f, J'Ct
[AFFIX NOTARIAL SEAL|

T H AGRICULTURE & NUTRITION
COMPANY. INC

By	^		

Title: Tici Praaldant. ttanaser of Plnanca
*04 Op«r*tlofl<

-------
\lter recording- mum to

i. ;»v-FUtctcncr

£d»vi VUltamMJO. tjq
Hmtmt X lllianu
nK." Peacbtret Street. N L
vjtw-1100

\llnnu. I"Morgia "O30i-1216

DecJ Buo» I7JT.
Paft bi. I Kiughenv (_cunr>.

Oeonu* Records

nRST VMENDMENT TO DECLARaTIOV W RESTRK HQS

THIS HRST \MEN"DMENT TO DECLARATION OF RESTRICTION illr

\irciJmCTi: ? is triad* and entered We m of cbe i** ^a> ul tehn«ar\ JlOti*. In T H
MrRiCl tr.'Kt  Dougherty Count}. ijeoritia. »asd Proper.', bemj more
paflmicK ^escribed »¦ thai terrain iract or pmcei of land designated nm! known is [ <>1
C.' ir. Suhdti'WOn "C of Pairesm Peon	Suhdnmon being pan of the inunai

i jjid Lu'l sC4 is lite Firnt District o: Dougherty Count* Oeorsia. and >himn 011 a plat of
•aid Land (nperty being the same at thai tie sen bed
in rhar certain Wannir Deed dated December .9. 196' and rwrrded in Dee-' Boo* 39«,
Paife lt»! JwresaUi records: .mc

ftHERf.AS. pursuant an ord*i 01 the Cnned -Stales Emiri'nmental ?-flection
ieenci Region IV rtPA' i imrterrentir-t EPA s Record «>l Dcttsmn lor the T H
Upvalue £ Nutri-jon C.««rparr. Inc >i«r. Operable (..'nit One. Uban'. L)out(hen>
•unii 1 -e^rea jawd May - I I ua>. THA* etecuteJ thai cetuun CteianctMl ut
«te trwjim JjmJ is •»! N"s«nt*r 5 l1*** '•vhjcii wax recorded a) !krt Boot !'J". Page
• : • 1 :he records 01 the Clert oi Vjper.or Conn ot Doujfteny Countv Oeotga itfx
Dee Pinion" >. jtic

G-3

-------
WHEREAS. THAN intends to enter into • Consent Decree with EPA. pursuant to
which THAN wli continue to perform certain response actions at the Property. .Among
other thing;)., this Consent Decree requires that as additional restriction be added to the
Declaration, and

fcHERf-AS. THAN wishes to amend the Declaration. as more particularly sei
lorth herein, in order to comply with the rtomremenu 01 the Consent Decree

N'OH THEREFORE. THAN hereby amends the Declaration as follows

I Vdditiiimil Restriction. immediaielv foltowtng the "Restriction
raragraph contained m the Der:irsiioo. the following paragraph is hereby added to the
Declaration "The Property shall not be used for residential purposes. In furtherance of
and noi in iirruutiion of the foregoing, no stnxnaes shall be constructed or placed on the
Property for the purpose of providing a dwelling or other habiratii>n for my prrsan or
persons, nor shall the Property, to fact, be inhabited by any person or persons or used by
any pertnn or persons as a dwelling or other habitaooc."

Z. Restriction! Ran wiifa the Land. The restrictions contained in the
Declaration and this Amendment are and shall be covenants running with the title to the
Property and shall bsnd THAN and its successors in title 10 ihe Property

3 Miscellaneous. Except as otherwise provided herein, the Declaration
shall remain in full force and effect according to its terms.

TN WITNESS WHEREOF. THAN has caused this Amendment to he executed
and delivered as of the das and vear ftm above wntttn.

THAN:

Signed sealed and delivered in the T H \GRIClrt..Tl"RE St WTRJTION. L L.C.

presence of

By.

¦a

iwfKeial W nans



Name

Title:

Jpwbti l. m*s Jtv
Vio President	

[CORPORATE SEAL!

My CinamsssionExpires	,-A

, \FF1\ NOTARY SEAL)

(' Y'V^. -T.

G-4

-------
«>~# 		

vv/v-'	S3reS555B»*

IM w Pmtom to* t» Jttl

Nonet or conskct mm nkxaiutjom o* motuctivk

COVXNAXTS AMD CRATCr 0* I

THIS NOtJCl OP C0MI1NT DKCMB. DECLARATION OF RESTRICTIVE
COVENANTS and ORANT Of ACCESS (dtit *NJ bcitfa *7 nftsKt «b* 'km* hiifwrf'), U*

WHBRKaS. 1m lam* Pmptry M lt» in of fonarr t|ricai«jnl (teoiotl fomnUnlon
ml ilnrlMJo* rKUbq. uA wraia tpltuAimi ctwmtaM fu>« haw ttmmt La At mi on
M f»i*» »r*9*fry, irt

WWBMtAJ, « Cot»«rl Dwnt ku t>M mmI Uim b» Luty Joatt, (,AI*

C»wc CmcmI*) (5oU Kla. Air
—«—1 ie « n* 'Stnlkf

> wd md Cm CWim tui btta oftead hy ¦%)
United Sunt DUafct CMR fw tba MkUK Dinner ofdtorfi* AAwv'AoMdcui Clvtataa aa

AiiflU 14, IWI I* fltoWftU
CM* Off. J«.. airflelif Cm
Dnt hi MBttica «Mk

' tf H» Uaatd (

tot mi un * * <

Utility Act, *1 USX. I< MM, <

v iJUTfUw. Mr Pndum ami

Cmi As&oaNo, lyT-CV-TVI «h* -0mm*
m by At UoM StUM »* hthtlf of tka
I taMOlM A**? ("IfA") pu*M«i •

k«ty«f *•



r- '*

G-5

-------
NalHlnKsl&t

WBDBUtAi d* Qxmm Dacaa* tafiStn Owm Seato* rw»~«— « ^
Dwg*wjr Couaqr. a b patriot tcoc*
—too Ac laaa Propenj » peas* tg^mrrmcVii of «a aaaaavml Esatnii «*! to *t
paipot* of coodueasg »y aefrttjr [dated b He Cocsew Decree; and

WHEREAS. 0*wr Setfijoj DrfcotU* detfeac Aat tta Nairn tad DaetKttta ta
wwM ta *c re«l ert*» »conH of Dcwgiystr Cwey, Qeorpa ia aoJfx as comety- iritfc g»
M^janSMSB of Ok Cocscsr Dean

NOW. THEREFORE. QvwSea&agDc&adattfcBtbygcuiu, dGmiadtekuMilw
ft* lorn fropartr «kili be hrid. owaad. aoM. iyyrfmwl, mnirnVysd. land. iepcovad,
oetapkd. ud eStervot nmveytd or daposed of Sfcjati nd subcrtiaws » a* amHdocu.
woBBtta. wBrcbaa*, agfcttttd o*U|«>a«B gruuea. goad. rmhbihrd. dcHwd Of atarwjg
IK (*nk teton

L. PnwxMt af Notice ind Oerimricc. Tfc» Noccc lad twriaivfc* B bc*g aaita
aid desired by Owner Scaling ftfcwa ia eider b oomftf with tbe rsrincajao 4/ tte
cmmDm.

X CnnmirlVntt Tbe Jdsti I'mpcty is satyact » tt Cause* Deem wtnek k
¦mflHM* h—gia it BririEk JW' »ftfi iaeeraogted	tav idm. Any Wtjwqfuta; . dta Scalioj CeftsdiBS, «sd die
wannnn of fce UssBd Sots ud be SoOiiOg Oefeadiaq (coBectuwet* hMeisnfkr Kfea<< V
u ibe *Ltoes«aa') aii{M of aOKU «id HeoB a*(tr^oa. >crea. drMfb md under dK Joaec
Pwp«ty ft* die ywipcan of cottiucnag aey letmty calued » fte Cimetu D«3*». Uoqiee*
dtafl x ail icaMBikk tiMkne leaea to <6* looet Ptapery 
a a» of
dfc foet» Property to ity eod kU piupsaea rtici do am uanavjai&ly Istcrfeie «t the dglu

udgriafed berets

G-6

-------
®w1741mu165

J r.iirrligii:* wgi tj* Tie »«fc to be
Dcleadim shall be perisrairi ji «inpLi« wiifc

6 fip-nrat:.^ fttieo £?A pnrcdec 4* ScoUot Oefc
aS R-sedai Acticc tat Wrk tivc bcra coapfeted x Mxoriiace *nl Ac Csomx Own*.
Owner Seticj DcfitadEE '>->.1 u*e the zfli to umaKc tat rtnert vJ terra nfSo
acsxd a Sec=on « of th-i Scax ui DevUnaaa. Is otte 10 . Jnrel aid *ccoc ngbc. Oner
.Cwiirj Deiettliet «*•¦»' 30U0 ts CciBed S'jat of neb uacrCtaea md rccorl ud
cn»0*aoQ ffl ±e Dcujherrf C:uorr rnl oatc moett, The rgactfon ifmat ircvVrttiif me
cooa-.ooC j) Secaoa lifis Noaue ion Declaration. start aoc irgvhxr or ct?ee i
eoSJ Oww Socio* Ofefti»r.» xaava wriiKm »ajcat fram EPA.

7. Smice- Any book wjuatsd or pumucd Herwaaier b rtikfi* jrvea.
if tft wfttiif tad iebverai penoaaJ'y o? wot by avmtfo ouii« HiUgci SUai.
at fottowv

(1} If to Owner or Owner S«sCnsgDcft3d»x w:

hoa F»sily Prcp«tie«. L LC.
os lorry R If a. Opena* Mings

P=k 0(fa Be* C(

A-fcirty. C-ctju. J:70«

«£ :ptro« citS ltt-3917
ce'-ecqpier: <»12> M-W)

witt*oopy«»

lobe C Sfxnti E»q
ArttQ Getoea Jk Gregory
Oae At'nric Cwer
1201 *'ot Pcactate Seen
Alicia. C"=crpj 1QJ09-J450

~ *!e?So* (40«rj-S66«	

{4W> S73-4K7

ft) If a be I sjtsi Sim. to

Cfcxf. EtAnxreml Ezlcxaom Uahn
Ssvgcaaec] ud Njftial Rctoum DrriccB
US r*?irac* it fra«*=

PO Bet 7SU
Sea Ff«sJdSa S**am

, D C. 2000*

Ogj-

G-7

-------
mirn^rn

vttliqprb:

Dirattrf, Wt» MittfttOUB

DbrWoft

Viited to Eavitwangtal PiJtfctiua Ayacy	-—¦

BejJon TV

Aflaau Mnt Cam
100 Alabama Street. SW
AtUna. Gectjia JftMl

9. Ai«ng»>ii« r .w itii Nwfct ud Dorltrnina OmB be jovecmt by w
It >"nriirrr ~Wti fflr Hi nf iftr Tttt nf tnn|f-

»	Bnanlwr WW. TV !«¦«» the pnrttioa* of tim. No** uA

Dtdamfe* tie imuMed to ckm coteeeim nmninf wiA tad wfehis 4m	of

O.C.O.A. {<4-5-60. eremnbenn* the Jcoee Piopeny, ud blading upon Owner Settling
Ddtaieat. All of the Janet Property than be heid, told, uied tad oo«*sy<*J subject ® die
Mtriedooi tod toceu rigiw oomataed in Bui Notice ud Ded«r«i« which tlukU cua wits tic
H|W to ill of (J* Jones Property, This Notice ud Declaration (ball bo bifldinj upon «U pencw
having tor flCht. Q»e or aatexe* Is O font* Property, or »ny part thereof, or any property
which ouy be nude wbjea to ihit Kooce ud Declantioo ta the Man, and the hrirr,
fwxeMon. (oecasKn in otic ami t£si{u Omof. iochtdtaj, without liraimioe, aay tnortpfee
acquiring aa iangrttt la uv portofi of the Property b> rtatoa of foracimuia. deed or assignment
in lieu of fonxlorne or pvieluw « breclonae ult, umUuidj occupuu of my portion
Of the foots Property and their fwat* aad Inviiees.

IN WITNESS WHEREOF, the undersigned has caused (Mil Nodec tad Dcctenbcn 14
be litped and aeaiGd on (he day aad year tat above wrtttee..

Owner Seating Deftodiat;

ift the preside* of'	--

(^^loTnorijpd (js&j.z-*

Si|S«l. waded and delivered
1ft the prWMM of

KotarV Public

My Cnuitfioi

iflP

*' M #fV (IMU ||F1 % Ml

G-8

-------
we* 1741 mis 1R7

EXHIBIT "A"

isf.Ai nKsnrrrmfi pv	pgomnv

Ail that tact or pucel of UttJ lying aod bestf in Lai Lor 349. Ftra Diitrks m tf» CSw
of AJbwy, Duagbcrty Camay, Oorju. «*J boat a ore ptniealarlT	u *17 op

LOT 2*?ALMYRA PECAU OSOVES SUBDUVISIOK "C'. ice«£og n 4 nap arpbi of aid
«Mj»i»»on recorded in Pl»t Book l.jageiJ, iajJ* Office of 0»Cteckof cte Srawior Court
«f DonchcrQr Couaj, Gcocgik. tod mnainiag S e», owe or Hi

BdQg tbc use propatg> conveyed by deed from	<**—»«—» Cixpondco ®

MnilhC CWWlrtW(wfchWIHtiiaBitii Qgrial ftiiMiiwiMil 1—1 i» jaco
AM totrecord Aptfi22, 19®, Mdrf k Deed Book AcTtZtZt. in e*W'^

G-9

-------
G-10

-------


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Appendix H: 1992 Removal Action Excavated Areas

Figure 3

Map Showing Extent of 1992 Removal Action
(Excavated Areas are Shaded)

H-l

-------
Appendix I: 2013 EPA Ground Water Data Analysis

United States Environmental Protection Agency

Region 4
Atlanta Federal Center
61 Forsyth St SW. Atlanta, Georgia 30305-8960

September 17, 2013

4SSD-TSS

MEMORANDUM

SUBJECT: Data analysis in support of the Five Year Review
T. H. Agricultural and Nutrition Co. Site
Albany, GA

FROM: Ben Bentkowski, P. G., Hydrologist,

Technical Services Section
Superfund Division

THROUGH: Glenn Adams, Chief

Technical Services Section
Superfund Division

TO:	James Hou,

Remedial Project Manager
Superfund Division

In support of the Five Year Review (FYR) process for the T. H. Agricultural and Nutrition Co. site in
Albany, GA, I have reviewed the draft five year review document, reviewed historical files, attended
the site visit for the FYR and performed a data analysis on hydrogeologic and historical analytical
data. This memorandum will focus on the data analysis and will provide three suggested
recommendations for inclusion with the FYR report. Please consult the FYR report for historical
details and background information as this memorandum is limited in scope to the items described in
this paragraph.

During the FYR site visit, in consultation with the responsible party's representatives and the Georgia
Environmental Protection Division's representative, it was decided that the responsible party's
representatives would prepare hydrogeologic cross sections that accurately portrayed the

1

1-1

-------
Comments on the Five Year Review
T.H. Agricultural and Nutrition Co. Site, Albany, GA
September 17, 2013

relationship of selected groundwater monitoring wells to the locations of the two main release
locations; the THAN property on the west and the Jones property on the east. Tine cross sections were
used as working figures to determine which monitoring wells were of the greatest concern. As
working figures, they are not attached to this memorandum but will be retained in the file. That
analysis determined a subset of wells to be investigated further. Two well pairs, GB-31/GB-3D and
GB81/GB8D, which were selected see if the general downward groundwater gradient at the site had
taken compounds deeper into the aquifer. The five other locations; MW-21U, MW-22U, MW-34U/UR,
well GB2 and MW-N2, were selected to indicate the historical movement of the contaminants over
time. Well MW-N2 is shallower than MW-21U and MW-22U and the hypothesis is that
concentrations in MW-N2 may have contributed to concentrations at the slightly deeper, nearby wells
MW-21U and MW-22U. MW-34U/UR and well GB2 were not on the line of the cross sections but did
indicate generally elevated concentrations. The well locations are shown on the figure on Page 8 of
this memorandum. The well construction details are included on Page 9 of this memorandum. Wells
MW-N2, MW-31, MW8I and GB-02 are the shallower wells with screen elevations ranging from 200 to
180 feet in elevation. The deeper w.ells are GB-8D, GB-8D, MW-21U, MW-22U and MW-34U are the
deeper wells with screen elevations range from 174 to 151 feet in elevation. The deepest wells in the
central portion of the site have their screen elevations at 110 feet in elevation.

The responsible party's representatives had previously provided an ACCESS database of all available
analytical data which was mimed and queried to produce monitoring well specific, compound
specific data sets which were used to produce time series graphs. Analytical data was available from
1991 until 2012. To limit the data to be processed, data for the years 1991,1995, 2000, 2005, 2008 and
2013 were selected to provide representative points over the 20+ year history of groundwater
monitoring at the site. The compounds evaluated were the seven compounds which were listed in the
Record of Decision as having cleanup standards (also known as treatability standards (TS) and xylene
which has an MCL but was not included as one of the compounds to be remediated by the site's
remedial action. Additionally, because xylene was used as a carrier liquid for many pesticides, it was
included to see if it perhaps its movement facilitated transport of the site's pesticides.

GROUNDWATER CLEANUP STANDARDS
THAN ALBANY SITE

1,2-Dibromoethane (EDB)

0.05 Mg/L

Beta BHC

5.10 MS/L

4,4'-DDT

27 MS/L

Dieldrin

0.57 |.ig/L

Aldrin

0.54 fjg/L

Toxaphene

3.0 pg/L

Alpha-BHC

4.10 ng/L

Xylene

10,000 |Jg/L

1-2

-------
C«M>iw> u": th# Flv# Vnr Rpvw*
TH Agricultural .*rd SJsirrtMnr.Co •*!•>. Alh>ry, OA
SffHHmfeer 1 ?. IOT-3

GB-3I/G8-3D

GBiltCB r«x^rtfarnor'.

-fWMlll I*il

///

Well GB-JD fcDS Cooceotfallocs

/ y s y

"T500S urA

- R." ill

EDB concentrations in the shallow well arc going down while the EDB concentrations in the deeper
well are going up.

GB-3D Toxjphene Concentrations

	n3u&'L

	%SUlU*t

/ / ./ ./

Toxaphene concentrations in fallow well CB-3I are holding a steady concentration well above the
treatment standard while the to xaphene concentrations inwell GB-3D appear tv> be trending upward
slightly.

6B<3I Xylene Concentrations

loooooo -
ioooik
10000

1000

too

-Vwitt uf/l

/////

GB-?GX*l«w Cantcrnralion'.

1! 111111

10.002 t»fA
-*Uru*H uk/1

Xylene concentrations in GB-31 have definitely gone down while correspondingly, xylene
concentrations m GB-3D have gone up. This may be the source of the EDB transport mechanism.

1-3

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Cronnrwnoe mi rue- h\r Year Kmcpw
TJi Agriculturaland Nutrition Co. Site. Albany, CA
SepmrJwr 17,2013

GB-8I/GB-8D

GB 81 To>jphcre Concentration*

1000.00
100.00
10.00
100

-re3«A.
-Result

mr«-C r-«m»Ar^o —

§>n?C' SoSoo
?$SSSS!SSS

G3-SD Toxapliane CDncentratcns

190COO
100.00
10.00
1X0



>—^



/

^ /





	TS3 uftil

—Rpiull

/ / / /

Toxaphene concentrations in GB-81 have increased over the monitoring period and are not- two orders
ot magnitude above the treatment standard. Over the same time period the toxaphene
concentrations in GB-8D have increased to nearly the same concentrations as found in the shallower
well. This indicates that the toxaphene has migrated downward.

GB-BD Aldrin

GB- 80 Aldr i n Cone en [rations

-T&0.S4 ug/1
-Result

000

1/1/00 1/1/05 1/1/10

There are four data points on this graph and all are either U or N qualified. With the detection limits
so near the tratment standard, it make it difficult to make a completely clean determinate that this
location does have or does not have an exceedence for Aldrin.

1-4

-------
Comment* on #•* Fiw Review
T JHL Af^evbaai and Nidc&on Ct> bete. AJbju .v, GA
SepHwrJun 17,2013

MW-N2, MW-21U & MYV22U

ORAM

In the area of MW-N2, toxaphene conentrations have increased signicantly over the monitoring
period. MWs -21U and -22U are nearby and are screened at a lower depth. Both of these wells have
shown a general increase over the monitoring period. This is indicative ol a continuing and migrating
secondary source of toxaphene in this area andd would be an indication of the need for a remedial
action for this compound in this area.

UmiwKx



» Jk









„l





mm m

m mm mi

m j&gi

—Wl«l

In the area of MW-N2, alpha-BHC conciliations have increased signicantly over the monitoring
period. MWs 21U and 22U are near by and are screened at a lower depth. Both of these wells have
shown a general increase over the monitoring period. This is indicative of a continuing and migrating
seoodary source of toxaphene in this area andd would be an indication of the need for a remedial
action for this compound in this area.

MW-N2 4/-DDT Concur I rations

• Ti2: Jg/'L
-Rciull

1/1/JOTII

4,4-DDT concentrations have mcreaspd in recent years of the monitoring period. The reason for this
increase is unclear. The 4,4-DDT concentrations in MW-21U and MW22U show no increase above the

1-5

-------
loimnnnb on Jhe Fiv« "r ear Review
T H Agf cultafiit v t N«f» > wt ¦" '¦ . Albar.y. GA
JepteTrber ]?, 3032

detection limits so far. Given the patern of downward migration for tosaphene and alpha-BHC, this
bears watching tn the future.

P/Y» M.: Xvtmr Cancratrrvm

zf

tut f

UWm in pm

WVt 2111 **lene Cartwvauofe



/////



Though there is not a ROD specified treatment standard for xylene, all three wells do exceed the MCL
for Xylene. White there does not appear to be significant migration, all three monitoring wells have
shown relatively steady, non-attenuating concentrations through the 30 year monitoring period.

GB2

Sample_Date

TS
0.05

WA

Result

Qualifier

Units

2/10/1991

0.05

880

J

Pg/l

8/30/1901

0.05

200



UtfL

6/20/1995

0.05

270

J

Vtfl-

8/28/2000

0.05

1000

U

ik/l

1/13/2005

0.05

670

u



5/12/2005

0,05

800

u

ag/i

8/25/2005

0.05

270

u

Ufft.

10/27/2005

0.05

250

u

ut/l

10/7/2010

0,05

3.6

u

t&l

10/3/2012

0.05

50

u

we/t

Gtt2 tl>t CarterIr .mans

-iva.t* j§n
-fe* i

^ /¦ ^

At first glance, this graph appears to tw» heading in the correct direction. Upon closer inspection it
becomes apparent that the graph shows a decreasing trend in detection limits, not a decreasing trend
in actual EDB concentrations. With the treatment standard at the low value of 0.05 tig/L, detection
limits in the 100r» of ug/L provide no useful information. The effort and expense of sampling this
well, analyzing the sample and reporting the results have been a wasted effort. There are mum' wells
in the THAN Albany monitoring program and contaminant concentrations can vary widely. It is a
subtle point but it is recommended that the batched groundwater samples submitted for analysis be
grouped so that historically low concentration wells are analyzed with other samples of expected low
concentrations. This is a step that may provide more useful unqualified data in the future.

1-6

-------
Comments on fee Ftv« 'ssr Rv.iew
T H Agrt :ultu.
-------
C ocnornr.1« on Ow Fir#'1 &ix
TH AjncuMeral and Nutciuon Co. Sit*. Alfcacy, Q*
S«p14xc.bc 37, 201c-

This figure shows the layout of the central part of the site with the THA N property em the west and
the Jones property on the east. The lines on the figure are from the proposed croass section? and the
final cross section allignments. The wells covered in this memo are GB-3I, GE30, GB-8l(R), GB-8D,
MW-N2, MW-21U MW-22U, GB-2and MW-34DR. (not to scaie)



1-8

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W1' i \. K i SI RUCTION Dt'l



J !







¦i „ |

_..1 :







(=S2,V ;



1 i"~



.'Ml

,2'.i7



207,v0 ,

GI1-8I J

181,2? [



! 7ii,2~

25.0

V.,! |

2!«.

'57 ;

!

i. ;

ri i. V



i .j-i ~S



tJhi hii.O j

2tfc



2:)hM'

YHV \2 :

>





iit.il

>

210

oi> .

sSWJX'

MW-21U |

i<».V; ;



i T-.. Vi

40,(1



2' i":

I

n  :

21117 I

V!V\' ''.41 ;

17).It.



)(/! .!<•>



•tv i .1:

20h

;

207.M

, I V -

U'ts.-i"1 :





"!2.<".

i;

2!2

-n!

212.67 ;

-------