5 ... 9 ooooo;,;: RECORD OF DECISION 7" Remedial Alternative Selection " ' '" JU Amni c o 1 a Dump S :i. te Chattanooga, Termessee This decision document present s the selected remedial action for the Amnicola Dump site, Chattanooga , Tennessee, developed in accordance with CERCLA, as amended by SARA, and, to the extent practicable „ the National Contingency Plan „ The following documents form the basis for selection of the remedial actions Remedial Investigation Report, Amnicola Dump Site Feasibility Study Report, Amnicola Dump Site Summary of Remedial Alternative Selection Responsiveness Summary Staff Recommendations and Reviews The function of this remedy is to reduce the risks associated with exposure to contaminated, on-site surface soils. The major components of the selected remedy include! Surface Soil Excavation of contaminated surface soil and debris Screening of debris from the soil Treatment of contaminated, soil by solidification/ fixation Restoration of the ground surface to its original condition General Imposition of ground water use restrictions within a reasonable distance from the site Imposition of.land use restrictions on the site Quarterly ground water monitoring for four years Public Health Assessment conducted five years following remedial action
Transcript
5 ... 9 ooooo;,;:RECORD OF DECISION
7"Remedial Alternative Selection " ' '"JU
Amn i c o 1 a Dum p S :i. t eChattanooga, Termessee
This decision document present s the selected remedial action forthe Amnicola Dump site, Chattanooga , Tennessee, developed inaccordance with CERCLA, as amended by SARA, and, to the extentpracticable „ the National Contingency Plan „ The followingdocuments form the basis for selection of the remedial actions
Remedial Investigation Report, Amnicola Dump SiteFeasibility Study Report, Amnicola Dump SiteSummary of Remedial Alternative SelectionResponsiveness SummaryStaff Recommendations and Reviews
The function of this remedy is to reduce the risks associatedwith exposure to contaminated, on-site surface soils.
The major components of the selected remedy include!
Surface Soil
Excavation of contaminated surface soil and debrisScreening of debris from the soilTreatment of contaminated, soil by solidification/fixationRestoration of the ground surface to its originalcondition
General
Imposition of ground water use restrictions within areasonable distance from the siteImposition of. land use restrictions on the siteQuarterly ground water monitoring for four yearsPublic Health Assessment conducted five years followingremedial action
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The selected remedy is protective of human health and theenvironment„ attains Federal and State requirements that areapplicable or relevant and appropriate to the remedial action,and is cost-effective,, This remedy satisfies the statutorypreference for remedies that employ treatment that reducestoxicity, mobility,, or volume as a principal element andutilizes permanent solutions and alternative treatmentteclinoilogi.es to the maximum extent practicable., However,because treatment of contaminated ground water was not. found tobe necessary, hazardous substances will remain in the groundwater above" health-based levels. The absence of ground waterusers at or downgradient of the Amnicola Dump site,, and the factthat discharge of ground water to the Tennessee River will notresult in a significant increase of contaminants in that surfacewater body, precludes the need for ground water remediation.Therefore, Alternate Concentration Limits (ACLs) have beenestablished for the site.
Because; this remedy will result in hazardous substancesremaining on-site above health-based levels,, a review will beconducted within five years after commencement of remedialaction to ensure that the remedy continues to provide adequateprotection of human health and the environment.
Date -T<-Cu'j,..yt., Greer C. Tidwell' Regional Administrator
5 . 9
RECORD OF DECISIONREMEDIAL ALTERNATIVE SELECTION
AMNICOLA DUMP SITECHATTANOOGA,, TENNESSEE
PREPARED BY *U . S .. ENVIRONMENTAL PROTECTION AGENCY
5.0 ALTERNATIVES EVALUATION ~ ——— - ——————————— - ————————— 20Al t er na t ive 1 - No Ac t i on ————————————————————————— 2 2Alternative 2 ••• Low Permeability Cover ————————————— 23Alternative 3 ••• Solidification/Fixation ———————————— 26Al tern at ive 4 - 0 £ I: ••• S i t e I nc i . ner a t ion —————————————— 2 9Al tern at ive 5 ••• 0 f f ••• S i t e D i spo s a 1 - ——— ••• ——— ••• ——— ——— ••• — 3 2
<:i . 0 RECOMMENDE D ALTE RMAT I VE ————————————————————————————— 3 46 . 1 Description of Recommended Alternative •••••• ——— ——— - 346 . 2 Operation and Maintenance ••• ——— ••• ——— ••• ——— — ——— ——— 406 .3 Cost of Recommended Alternative ——— - ——— ——— ——— 406 A C1 1'*> In tm. {"1 11 11 1 j"a» . .. ... ... . .. ... .. ... ... .... ..» «• ... .» .... .... ... ... .... .... »» 4l if ll41 "( tmj '.• JL Jk'II* \A LJL JL. "55. '""" *""' "" ""' '"" '"" « • ' « • • • • . • *|ij ^jp
.APPENDIX A - SOIL CLEANUP GOAL CALCULATIONSAPPENDIX B - ALTERNATE CONCENTRATION LIMIT CALCULATIONSAPPENDIX C ™ LISTED THREATENED AMD ENDANGERED SPECIESAPPENDIX D ™ HISTORICAL/ARCHAELOGICAL DATAAPPENDIX E - ADMINISTRATIVE RECORD INDEX
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RECORD OF DECISIONSUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MINI COLA DUMP SITEHAMILTON COUNTY , TENNESSEE
1 • 0
The Amnicola Dump site was included on the National PrioritiesList (NPL) in September 1983 and has been the subject of aRemedial investigation ( RI ) and Feasibility Study ( FS ) performedby the U.S. Environmental Protection Agency (EPA), Region IV,The RI Report, which examines the quality of air, soil, surfacewater, sediment,, and ground water at. the site, was issued to thepublic in January 1989., The FS Report, which develops andexamines alternatives for site remediation,, was also issued indraft form to the public information repository in January 1989.
This Record of Decision has been prepared to summarize theremedial alternative selection process and to present therecommended remedial alternative,,
1 . 1 Site Location and Description
The Amnicola Dump site is an 18-acre inactive constructiondebris disposal site located in Chattanooga ., Tennessee (Figure1). The site is located at latitude 35° 03 '04" and longitude85° 16 '35" along the Tennessee River,, The site isapproximately 0 . 5 miles upstream of the intake for theTenn.es see-American Water Company which i s the primary waterdrinking water source for the City of Chattanooga.,
The site is bordered on the south by Syn-Air Research (anindustrial, research facility) , on the west by the TennesseeRiver, on the north by dense vegetation and vegetation -covereddebris (scrap metal , railroad ties, etc,),, and on the east bythe Amnicola Highway. A berm,, which extends 15 to 25 feet inheight, separates the river from the landfill, Two breaks havebeen noted in the berm. An on.~si.te pond, located in thenorthwestern corner of the s ite , occupies approximately fouracres between the landfill and the berm (Figure 2). Locatedlargely within the 100-year floodplain, the' site drains westerlytowards the river with a slope of approximately three to fivepercent. .
Amnicola Equipment fii Materials Sales,, a salvage businessoperating on the surface of the landfill, is located on anupland area,. This area, which is relatively flat (less thanone percent slope), is approximately 30 to 35 feet above the
1.2 Site History
SIT IE L 0 C A TII0 NA M N I C Q L A ID 1,1 NIP
Fisrure N;:
1-1
-etoew
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During the 19 30 "fit the Amnicola Dump site was reportedly used forclay mining operations. These operation.!-; resulted in severalwater-filled pits along the western boundary of the site in thepresent-day pond area. During the period 1957-1964,construction debris and other unidentified wastes wereoccasionally disposed in many of the open pits. This resultedin a large portion of the pits being filled.
During 1964 to 1970 the area was re vegetated (it is not knownwhether this revegetation occurred naturally) . The Amnicolasite was operated as a dump from mid- 19 70 to September 1973 bythe City of Chattanooga. Construction debris ,, with 25 percentor less household- type waste, was disposed on-site during thisperiod. A substantial portion of wood waste brought on-site wasincinerated by an air •-curtain destructor., The ashes were thendisposed on-site. Approximately 12 acres of the 18-acre sitewere eventually filled ,,
Consolidated Latex, Inc., formerly located on the south borderof the site,, allegedly disposed oil latex waste in the southwestcorner of Amnicola Dump. in 1971, the Tennessee-American WaterCompany noted the dumping of the latex waste at the site as wellas the presence of a strong styrene-like odor during oneleachate sampling event.. Concern arose because of the proximityof the water company's intake, 0.5 miles downstream,, to thisleachate stream and latex dumping location. Latex waste is theonly industrial waste reportedly disposed at the site.
On June 2, 1971, the Tennessee Department of Solid WasteManagement (DSWM) recommended closure of the dump.. Therecommendation was based on unauthorized wastes from garbagetrucks being dumped in the water- filled pits.
In May 1972, EPA provided the City with recommended actionsrequired to eliminate the discharge of leachate from the siteinto the Tennessee River., Elevated levels of iron, manganese,total Kjeldahl nitrogen,, and total organic carbon were detectedin the leachate stream. EPA recommended closure of the site.During the summer of 1973,, the City final iaied closure whichincluded covering, grading slopes,, filling depressions, drainingstanding water ,, applying r i p- rap along the western perimeter ,construction of drainage ditches, and seeding the entiresurface area of the fill .
From 1971 through 19 76 , the Tennessee -American Water Companyconducted weekly leachate tests for inorganic analysis on theatornib-watar runoff entering the river at Miwer Mile 465., 1:1.Jlknalyisies iiic:Iuded haavy aetals ,, ]nianguieseir iron, and specificconductance . Little ox no pattern in the paranitiirterconcentrations was apparent . Conductivity values mime elevated ;some metals were detected but not elevated significantly abovebac kgro und 1 eve Is „
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In July 1979, EPA, Tennessee Department of Health andEnvironment (TDHE) personnel and local officials conducted asite visit at the Amnicola Dump. According to the trip report,,the overall condition of the site was good, However, there wassome discoloration of water observed in the drainage ditch,, EPArecommended an evaluation of historial water data and furtherwater sampling,,
In May 1982,. MCI /Consult. ing Engineers was tasked by the TDHE toconduct a study of the leachate originating from the AmnicolaDump site. The sampling point was the combined leachate stream,less than 20 feet from the confluence with the Tennessee Riverat River Mile 465.8. The results showed trichloroethylene,vinyl chloride , and 1 , 2 trans-dichloroethylene .
The Amnicola Dump site was proposed for inclusion on theRational Priorities List (NPL) in December 1982. The site wasfinalized on the NPL in September 1963, The primary factorcontributing to this score was the proximity of the site toTennessee -American Water Company ' s water intake „ which supplieswater to the majority of Chattanooga.
In December 1986,, EPA Region IV noted that site conditionsvaried from previous site reports. EPA Region IV reported thatthe site was being used as a storage area for heavy equipment,railroad ties, scrap metal, and several large dumpsters. Thecap had been cleared of vegetation, much of the rip-rap alongthe bank had been removed, and discolored water (leachate} wasnoted in the southwest corner of the site.
In January 1987,, EPA Region IV, Environmental Services Division(BSD) sampled leachate and surface drainage at the site. Theanalytical, results indicated that the leachate streams containedelevated levels of 10 inorganic compounds (barium,, strontium,titani.mil, zinc, chromium., manganese, calcium,, magnesium, iron,and sodium) „ Although several trace organic compounds werefound, the only major organic contaminants were bis(2-ethylhexyl)' phthalate at 82 ug/1 and. chloroform, at 7.4 ug/1.ESD concluded that, based on the 'results of the finished watersample collected from the Tennessee -American Water treatmentplant, no impact on the Chattanooga water supply from theAmnicola Dump site was evident.
EPA Region IV personnel initiated the RI/FS of the Amnicola Dumpsite in July 1987; the field investigation portion of the RI wasperformed between January and March 1988,. Both the RI and FSReports ware Jinabmitted in draft form to the public Infomation3i:«:|:icuiiiltoi:i[:y ia Cil]untt:Lnixioog[a<r TIN! IB JuuuiLrf 1JSIBS.
2 . 0The Amnicola Dump site was included on. the .National Priorities
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List (NPL) in September 1983,, Potentially Responsible Parties(PRPs) were notified of the commencement of the Amnicola DumpRI/FS in 1987. The PRPa declined to participate in the RI/FSand ISPA assumed the lead at that time.The majority of PEPs identified at the Amnicola Dump site wereassociated with the alleged disposal of latex wastes at thesite. The Remedial. Investigation did not detect latex wasteconstituents in any of the media sampled. The Rl did, however,detect polyaromatic hydrocarbons (PAHs) in surface soil. ThePublic Health Evaluation concluded that the risks associatedwith ingestion of surface soils contaminated with PfAHs at theAmnicola Dump site exceed the Agency's 10" to 10'"' riskrange. Thus, remediation of surface soils is required. ThePAHs in surface soil were not responsible for the site'splacement on the NPL. The primary factor contibuting to thesite's placement, on the NPL was the proximity of Amnicola Dumpto the water intake for the Tennessee American Water Company andthe alleged disposal of latex waste at the site,. PAHs insurface soils at the Amnicola Dump site have been attributed tothe burning, storage and handling of creosoted railroad tieson™site by the current site owner and operator,, Southern Foundryand Amnicola Equipment and Materials Sales,, respectively.The RI also detected the presence of chromium at 89 ppb (39 ppbabove the Maximum Concentration Limit of 50 ppb) andbis(2-ethylhexyl)phthalate at 370 ppb (70 ppb" above the ID"'4risk level of 300 ppb). Both compounds were detected in onemonitoring well during one sampling event and are attributed tothe contents of the landfill. The recommended alternativeprovides for the monitoring of ground water for a period of fouryears following remedial, action completion. This monitoringwill allow for the development of a sufficient ground water database upon which a public health assessment will, be performedfive years following remedial action completion,. AlternateConcentration Limits (ACLs) have been established at the siteand reflect the low levels of contaminants that enter theTennessee River on a sporadic basis., No ground waterremediation is required; however, if ACLs are exceeded duringthe four year period of monitoring, a need for remediation, maybe identified during the subsequent public health assessment„In summary,, remediation at the Amnicola Dump site is required asa result of contaminants introduced subsequent to the site'splacement on the NPL. Monitoring of ground water is requireddue to low levels of contaminants attributed to the dump. Thus,iRaniedial Iteiii jjipi./ temedial Ac tion (BD/RA) notice letters will tesent to t.he PBPs i:ipoB selection of tliim reinadhj.. Preliminarydiscussions with Southern Foundry and the City of Chattanooga anRI/FS completion and RD/RA activities coiinmenced i.n March 191:19.,
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3.0 £HBBfiHI_SHE_STAIHS3. 1 Environmental Setting
3.1,1 Beg£0jgk
The bedrock unit beneath the site is the Murfreesboro limestone,an Ordovician-age limestone of the Stones River Group.. Bedrockwas encountered at an average depth oil 34 feet below groundsurface. Depth to bedrock decreases from northeast tosouthwest, ranging from 64 feet at the east end of the site to32 feet adjacent to the Tennessee River,,
The uppermost portion of the Murfreesboro limestone is aweathered rock with numerous clay™filled fractures. Thisuppermost unit is approximately 10 feet thick., Rock coring intothe limestone bedrock allowed visual observation of theMurfreesboro limestone and determination of weathered zonethickness. The limestone is medium-gray to grayish-brown, hard,and contains numerous fractures,.
Although there are many geologic faults with surface tracespresent in Hamilton County•/ ail are considered geologicallyinactive, thereby posing no seismic risk, The seismic activitypresent in Hamilton County is the result of periodic releases ofstress in rocks at great depth.
3.1.2 Soils
Unconsolidated sediments (soils) overlying limestone bedrock inthe general site vicinity include silts, clays, and sands ofQuarternary Age. These sediments were deposited in a fluvialenvironment directly related to the meandering of the TennesseeRiver.
These sediments can be categorised into two fairly distinctunits: the uppermost unit (Unit 1 which is 15 - 30 feet thick)consisting primarily of sandy clayey silts and the unitimmediately overlying the limestone bedrock (Unit 2 which is 2 •••22 feet thick) consisting of sandy,, clayey silts and silty sandswith interbedded sand lenses,
3 .1., 3 Ground Water
Hydro 1 o g I. c c h ar a c t er i s t i.c s o f t he s lib sur f ac e we re i n ve s t1 ga tedby analysis of information obtained during the RI. Theunconfined alluvial formation (shallow aguifer) underlyingJlaunLicola Duutip i=i:i.ta cannpriis4»s the grouadl water of priHiarj'concern,, Ground water of the alliararlal aquifer teineath the siteflows primarilj tJliLrough Unit 2, wrhich consistiii of sandy clayey
overlying the limestone bedrock. Depth to ground water averages34 feet.
Ground water of the alluvial formation flows primarily inresponse to the major hydrologic feature near the site, theTennessee River. Ground water flows westerly towards theTennessee River and under the waste material, intersecting itonly briefly at the on-site pond,. Ground water recharges thepond, maintaining its level within ± 2 feet.
Ground water for municipal, industrial and commercial purposesis available from the alluvium, -colluvium and residuum aquifersin the Hamilton County area; however,, the majority ofChattanooga, is serviced by the Tennessee-American Hater Works(TAWW) . TAWW supplies drinking water to approximately (50,000customers and the water supply for this system is located 0.5miles downstream front the Amnicola Dump on the Tennessee River.
Wells were identified at two of the fifty-one industries andbusinesses located within a one-half mile radius of the siteeast of the river;: both wells are used exclusively forindustrial purposes and do not provide a route of exposure tothe occupants of the building. Furthermore,, the two industrialwells are cased into bedrock and do not draw a substantialportion of water from the contaminated alluvial aquifer beneaththe Amnicola Dump site. A review of TAWW's records indicated noknown private wells in the area.. Personal, communications withinTDHE indicate that few, if any, residents within the survey areahave wells on their property,.
3 .1,. 4 Surface Water
The Amnicola Dump site is bounded on the west by the TennesseeRiver near river mile 466, Historically, Nick-A-Jack Reservoir(Tennessee River) levels are regulated by the Tennessee ValleyAuthority to control flooding. Hurricanes or other significantrainfall events can, however, disrupt the usual rainfall,patterns and, subsequently, the reservoir levels. The 10™, 50-,and 100-year flood elevations for the Tennessee River at thesite have been calculated by TVA to be 655,.3, 657.1/r and 658,1feet above mean sea level (msl), respectively. The occurrenceof a 100-year flood would cause approximately one-half of thesite (western half) to become submerged., The area of the100-year floodplain is shown in Figure 3.
3.2 Surface Soil Contamination
Siiunt invMfcigatlon* „ conductad prior to tJh» initiation of tte IIfield p>:rogramir InditMhted that preisieB-l:.,, md perhaps pest,,activities on the landfill cap 'may have resulted in surface soil
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cont.wni.Eat ion. To determine what contaminants may have been,present or introduced, twenty five surf ace soil samples werecollected on and adjacent to the landfill cap.
There were numerous organic contaminants associated with thesurface soil samples collected from the site. The majority ofthe compounds were extrac table organics that most likelyoriginated from the creosote railroad ties that were stored andburned on™ site by the present owner; approximately 100extractable organic compounds were detected in the surface soilsamples, Table 1 lists the maximum concentration ofcontaminants of concern in stir face '/subsurface soil samples ., Themajority of compounds detected were polynuclear aromatichydrocarbons (PAHs) and are associated with coal tar or creosoteproducts (i.e.. railroad ties)., Concentrations ranged, from anestimated 150 ug/kg of acenaphthylene to 46,000 ug/kg offluoranthene. The PAHs were detected in all surface soil.samples collected from the site; however,, the highestconcentrations were detected in areas where railroad ties werestored (before and during the RI) and in areas where railroadties were once burned. Data on carcinogenic PAH compoundsdetected in. surface soil samples is given in Table 2 . It shouldalso be noted that the use of front-end loaders and other heavyequipment has probably resulted, in the spreading of PAHcontamination over the entire surface of the site. This isapparent from the analytical results of the random samplescollected from the grid system., The origin of thepesticides/PCBs detected in several, of the surface soil samplesis unknown,. The highest PCB concentration was detected at aconcentration of 17,000 ug/kg. However, the exposure risk levelhas been determined to be in the acceptable 10" * to 10" 'range ,
The creosote wood products brought on™ site by Amnicola Equipment!« Material Sales is the apparent source of PAHs detected insurficial soil samples, A target population of workers andvisitors to the site could pose a complete pathway of exposurethrough ingestion of contaminated soil ,. Activities using heavyequipment with considerable traffic across the contaminated sitewould create high airborne particulate levels . Additionally, afuture use scenario could include residential development of thelandfill area, allowing exposure of children through the soilingestion. pathway ., Respiratory absorption through inhalat ion ordermal absorption by skin exposure are thought to beinsignificant relative to the much more important ingestionroute .
Using thiii! mean PAH soil level, the ;plaiui:ilila and aa"'•xporaxe •cenaxios yialded risk levels of 2.8 x 10"' J> «nd 1.6 :n:
10~4 , respectively/ under the current-use .scenarios. Thefuture-use residential development scenario yielded an upper
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TABU! 1
MAXIMUM CONCENTRATION OF CONTAMINANTS OF CONCERN
IN SURFACE/SUBSURFACE SOIL SAMPLES
Sample ' Concentrat ion Concentration
Chemical Location No., in Test Sample in Control Sample
AriEienic:
Cadmium
Chromium
PAH8b
Lead
Mercury
Cyanide
Heptachlor
6amma-DHK ( Lincane }
Dieldrin
DDTC
PCS
Chlordane
mg/kg mg/kg
AD-006/007 12 .. ND*
AD-059 2. MA
AD-020 58. 29.00
AD-014 123. ND
AD-078 460.. 35.00
AD- 02 4 ..62 .15
AD-057 .41 NA
AD -05 7 .0024 ND
AD-057 .013 ND
AD-006 .059 ND
AD-OS 7 1.49 ND
AD-015 17. ND
AD-057 .63 NA
a - ND = Not detected
b - 'lt'J\.Kl wnlunt iJii mum of the detected a:u»€<iKixl:xfliti.o:nfl! of eiiircinDCiiEiaic
CARCIMOGEN 1C PAH COMPOUNDS DETECTED IN SURFACE SOIL SAMPLESAMNICOLA BUMP SITE
Control(Background)
Frequencyof
Chemical Detection
BeniKo ( a ) anthraceneChryseneBenzo(b and/or k) f luorantheneBenzo-a-pyreneXdeno i[ 1 , 2 , 3 , -cd } pyreneDibenzo( a, h) anthracene
14/1514/1514/1514/1513/158/15
Kin. - Max.. (ug/kg)
310J -360J -•360J •-300J •-290J -200J •-
260024002400250093001900
Mean Concentration(ug/kg) (ug/kg)
23 91277827782 2 5 51125307
NDNDNDNDNDND
NOTES: (I) Frequency of detection i.a the number oil iiampleti in which thechemical wan detected over the total number o£ eiamplee.
{2} Geometric inaaniEi are calculated u<=;ing one-half the miniiniuneiEitimated aactiple concentration for n.on-detect laampleconcentrations.
J - eutiroated value
ND - not detected
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bound risk of 2.2 x 10~4. The calculated upper bound risksare outside the Agency's acceptable risk range of 10""4 to10"" , thus, remediation of surface soil is required.
3.3 Ground Water Contamination
Organics and inorganics were detected in monitoring wellsamples. Table 3 lists those compounds detected in ground waterat the Amnicola Dump site., Four contaminants are regulated byMCLs under the Safe Drinking Water Act. Compared to theappropriate ARARs (MCLs) , chromium exceeded the level consideredsafe for lifetime exposure t'hrough drinking water. The 0.09 ppmdetected is approximately two times the MCL standard.Bis (2-ethylhexyl)phthalate (maximum concentration observed was370 ppb) exceeded the 10"''* excess cancer risk level of 300 ppbin one monitoring well on one occasion. The trihalomethanesidentified in same of the wells can be attributed to monitoringwell installation procedures.
No ground water users are located on or downgradient of thesite. The low concentrations o:l! contaminants discharging intothe River are diluted below human health and aquatic protectionstandards. Recreational use of the river adjacent to thelandfill would not be expected to produce exposure to thesecontaminants at levels of concern., Based upon the establishmentof Alternate Concentration Limits (See Section 4.2), the currentlevels of ground water contaminants will not result: in adverseimpacts to human health or the environment; thus, no remediationof ground water is required.
3.4 Subsurface Soil
Subsurface soil samples were collected, to determine if anycontaminants could be detected at the cap-fill, interface.Subsurface soil samples were also collected during the track-hoeexcavation work and at selected monitoring wells to identifywhat, contaminants may have and, may still be migrating fronn thesite in the surficial ground water.
Lead was detected in several subsurface soil samples atconcentrations from 100 nig/kg to 460 mg/kg. Numerousextract able organic compounds were detected in the subs u r facesoil samples collected from the site. The concentration ofcompounds detected, in the samples ranged from presumptiveevidence of ben:!;anthracenone detected at an estimatedconcentration of 1C) 0 ug/kg to di-n,-butyIphthalate detected at51 .,000 ug/kg,. Th* majority of organic' coiiKpoutdiii detactad war*polynuclear aromatic hydrocarbona" (;PAHs),. 'Ttese compounds wereIdentified in the shallow subsuxface soil sunipl.es collected witithand augers. The majority of compounds detected in five of the
5 ... 9TABLE 3
Caprolactum
Diethyl tetrahydro fur an
Chloroform '
Bromodichloromethane
Ethyl Ether
Chromium
Bis ( 2-ethylhexyl ) phthalate
Bis ( dijne thyl ethyl ) inethy Iphenol
Concentraltion
2 . 0
3 0 . 0
8 . 6
4 ., 6
5 . 0
189.0
370 . 0
10 ., 0
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ten trench sample!:! were also PAHs., No PAH compounds weredetected in the split spoon samples collected from the perimeterof the site during monitoring well installation,
Shallow subsurface soil sample:® collected with hand augers fromthe cap-fill interface had the greatest number of extractableorganic compounds identified and at the highest concentrations.The cap-fill interface was not well defined, and thecontamination at these shallow depths may have resulted from theoperation of heavy equipment on the site by Amnicola Equipment &Materials Sales personnel.., ,The extractable organic:contamination identified in the trench samples probably resultedfrom the material, disposed at the site,
Remediation o£ subsurface soils, however, is not necessary dueto the incomplete exposure pathway associated with these soils,
3.5 Surface Water, Sediment and Leachate41
The Tennessee River and the pond on the dump site are consideredClass III waters by the State of Tennessee and are to beprotected as a habitat for fish and aquatic life. Surfacewater, sediment and leachate samples were collected during theRI to identify any contaminants that may pose an environmentaland/or human health hazard on-site or by migrating from the sitevia surface water and leachate drainage., Samples were collectedfrom the Tennessee River and on-site from the pond,, drainageditches and leachate points.
Numerous organic and inorganic contaminants were detected inseveral of the leachate samples and soil samples contaminated byleachate collected during the RI. However, the majority of thecontaminants detected in the sediment samples can probably beattributed to the railroad ties that were stored on the site.The analysis of an upstream--downstream pair (relative to thedump site) of river water samples showed almost identicalcontaminant results., The findings were indicative of backgroundlevels and showed no indication of river water degradation bythe dump site,
One surface water sample contained significant levels ofinorganic compounds. A ditch sample taken near the southwesterncorner of the site contained barium,, chromium and lead at 820ppb, 150 ppb,, and 660 ppb, respectively. This sample alsocontained a PAH compound at 1.4 ppb.
Of the four pond water snipies, two contained significant level IBof a carcinogen,, bis | 2-«thylh«qrl) phtbal«t«, A. llf mK&ms rexposure for humans (through accidental ingestion) of 4 :n; IIP1"(within the acceptable risk range) would toe associated with
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these pond concentrations . The concentration ofbis ( 2 -ethylhexyl) phthalate is higher than the fresh waterquality criteria limit for phthalate esters. Phthalates werenot detected in the other two pond water samples and were notdetected in any of the four pond sediment samples .. The sourceof this compound is not known, A bioassay with daphnids usingundiluted water from the pond drainage ditch did not detecttoxic ity. Additional sampling of the pond water will beperformed during remedial design to resolve this unusual, patternof phthalate findings in two pond samples in the absence ofsediment detection .
Chromium,, nickel and lead occurred in most samples atapproximately three times the background level . There is noreasonably likely scenario that would result in ingestion of thequantities of sediment required at the site to exceed theacceptable daily intake .,
Complete pathways of human exposure to pond water and sedimentsand leachate do not appear to exist since these waters are notused for drinking , recreation or fishing ; therefore remediationof these media Is not required. However, a decision regardingremediation of surface waters , based on environmental concerns ,will be determined using analytical, data collected duringremedial design ,
4 • 0The extent of contamination was defined in Section 3.0,
This section establishes health-based c leanupgoals for surface soil contaminants at Amnicola Dump as wel asdefining Alternate Concentration Limits ( ACLs ) for ground water .
4.1 Surface Soil Cleanup Criteria
Health-based surface soil cleanup goals have been based oncurrent and potential future site use scenarios.
Current-use scenarios cons idered inc lude :mi Direct contact with on-site soil by part-time outdoor
workers and frequent visitors to the site.
mi Direct, contact with on-site soil by full-time outdoorworkers.
Dixed contact with on-site soil by fitictare i:m-»s Iibiisresidents.
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Soil cleanup goals were developed for both practical andworst-case scenarios.. The sum of seven carcinogenic PAHspresent in surface soil was used to calculate a GDI and cleanupgoal for both scenarios.
Soil PAH (total carcinogenic) cleanup levels for adultpractical, adult worst case, and child resident exposurescenarios were calculated; the results are presented in AppendixA. The assumptions for each of the scenarios can be found Inthe Public Health Assessment section o:l! the Amnicola Dump RIReport., The equation used towards calculating risk related soilcleanup goals is also presented, in Appendix A.
Due to the limited and conflicting data available relating toabsorption rates after oral exposure, two "acceptable" soilcleanup goals were calculated based on 100% and 25% absorption.,
In light of the conflicting literature available on absorptionrates, and in keeping with the position of using conservativeassumptions when in doubt, soil cleanup goals which incorporatea 100% absorption rate were used. Finally, the established soilcleanup goal was based, upon the following considerations::
<n> Amnicola Dump is located in an industrial setting.Although considered in the Public Health Evaluation, thelikelihood of future development of the site forresidential purposes appears to be remote. Therefore,child resident values were not considered further.
in In light, of the conservative positions taken during thePublic Hea1th Evaluation, aduit practical valueswere selected.
in A comparison was made of CERCLA sites within and outsideof Region IV to determine the cleanup levels that wereselected at sites exhibiting similar land use and.types of contaminants (creosote compounds)., A cleanupgoal of 100 ppm was the most consistently used,
Thus, a soil cleanup goal of 100 ppm has been established forthe Amnicola Dump site.
4.2 Alternate Concentration Limits
Although ground water is only slightly contaminated at theAmnicola Dump site, Alternate Concentration Limits (ACLs) wereiguE);iu»bliBhiiid to addreiitnt thiit ]pot:<i:u;i;l:..Lin.;i. .impact of iKJLLutQNlClt4lllIIIJi.IUifc.li.On,..
Section 121(d) of the Saperfund JkHMMteentfl andi MaauthorizAtionAct (SARA) requires that the selected remedial action establish
5.9 OOOUi
-18-
a level or standard of control which complies with all ARARs.
At the Amnicola Dump site!, ground water discharges into theTennessee River and,, therefore, beyond the boundaries of thesite. Applicable statutory language concerning cleanupstandards"under CERCLA is found"in'Section 12l' (d)(2) (13) (ii) ofSARA. SARA does not allow any increase in contaminants inoff-site surface water,, Since cleanup goals must be based onsome finite number, the reduction calculation presented inAppendix B reflects the large dilution factor in the TennesseeRiver.
To relate health-based standards for contaminant concentrationsto potential receptors, a current-use scenario was employed,Under an evaluation of the current-use scenario, there are nodirect receptors of ground water at or downgradient of thesite. Rather, the closest potential receptors are associatedwith surface water use at a location where affected ground waterdischarges to the Tennessee River.
To calculate probable ACLs for the various contaminants in theground water system, a relatively straight-forward mass-balanceapproach was used. The analysis involves an initial assumptionthat observed levels of contaminants will remain constant asground water flows from the source area to a discharge zone atthe Tennessee River.
A second assumption is that ground water enters the surfacewater regime in the Tennessee River and undergoes a process ofdilution in a mixing zone. Mixing of the two sources of wateris assumed to occur instantaneously throughout the entire volumeof the mixing zone (one-quarter of the cross-sectional flow ofthe Tennessee River), resulting in an output flow andconcentration that can be calculated based on a continuity, ormass balance approach..
The average reservoir flow rate over 65 years is reported to beon the order of 30,030 cubic feet, per second (cfs) ,. The flowrate through one quarter of the reservoir was used to estimatethe diluted concentration of contaminants in the TennesseeRiver. The point of exposure is the property boundary where thesite meets the Tennessee River.
The recommended ACLs are presented in Table 4 and represent aone order-of-magnitude increase in maximum detectedconcentrations of contaminants in ground water.. The resultingdiluted concentrations in the Tennessee River due to this oneozder-of-ougnitade increase mould still be aoadvtactohle.,purpose of the on*' order-of~nagnit:ud0 iBCxsnisint ini to pnvvntuirmecessary remedial action in. ground water d.ue to seuounlfluctuations in ground water quality,.
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TABLE 4
RECOMMENDED ALTERNATE CONCENTRATION LIMITS (A.CI.S)FOR THE AMNICOLA DUMP SITE
Maximum DetectedC o nc e n t r a t i o n i nGround Water
The key to obtaining .ACLs at the Amnicola Dump site is todevelop an enforceable restriction on ground water use within areasonable distance of the site. The exact distance and methodfor the restriction will be developed during the Remedial.Design.
A quarterly monitoring program will be conducted for only thoseconstituents detected in ground water during the RI. Thisprogram will continue for 4 years so that an adequate groundwater data base is available for the public health assessmentthat will be conducted 5 years following remedial actionimplementation.
5.0
The principal remedial, action objective at the Amnicola Dumpsite is control or treatment, of contaminated soil to mitigatethe current and potential future pathways of exposure.
Even though PAH-contaminated soil was introduced subsequent tothe ranking and placement of the Amnicola Duimp site on theNational Priorities List (NPL), it has been Agency policy toidentify all hazardous wastes present at NPL sites,, determine ifthe concentrations pose, or could pose, a human health threateither now or in the future, and to evaluate potential.ecological effects of site™related contaminants. It is,therefore, insignificant that PAHs were not initiallyresponsible for the site's placement on the NPL.
Furthermore, once treatment or control, measures are implementedat the site, assurances are necessary to prevent re-introductionof additional contaminants. Institutional controls, such asdeed or land use restrictions should be applied to the site toprovide for its long-term integrity.
An additional remedial action objective is to provide for themonitoring of ground water quality in order to develop a groundwater data base as well as imposition of ground water userestrictions within a reasonable distance of the site.,
The following five remedial action alternatives were considered:
Alternative 1: no Monitoring of surface water and ground water(No Action) quality for 30 years
in Fencing of the area of contaminationin Imposition of land and ground water use
restrictions<n> Public iliiaaltli JhsiiiwiuiKiinmt nmrasrir £*«•in Cost $ 1,100,, ODD
5 ,9 000023
Alternative 2:(Clay Cap)
Alternative 3:(Solidifica-tion/Fixation)
Alternative 4(Off--SiteIncineration)
Alternative 5(Off-SiteDisposal)
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ii) Placement of clay and topsoil over area ofcontamination
in> Construction of drainage divers ion ditchesaround the cap
(in Fencing of the capped areami Imposition of land and ground water use
restrictionsin Monitoring of ground water quarterly for four
years and send-annually thereafter for 26years
in Public Health Assessment conducted five yearsfollowing remedial action
in> Cost $ 900,000
mi Excavation and screening of contaminatedsoil/debris
in Treatment of contaminated soil on-sitein Debris disposal off-site if contaminated;
allowed to remain on-site if samplingconfirms it is clean
in Imposition of land and ground water userestrictions
in Monitoring of ground water quarterly for fouryears
on Public Health Assessment conducted five years:(: o 11 owi nq rerne d i a 1 a c t i o n
<ni Cost «; 640,000
in Excavation and screening of contaminatedsoil/debris
in Transportation of soil off-site forincineration
in Debris disposed off-site if contaminated;allowed to remain on-site if samplingconfirms it is clean
<ni Monitoring of ground water quarterly for fouryears
in Public Health Assessment conducted five yearsfollowing remedial action
in Cost $ 1~, 100,000
mi Excav ation of contaminated soil /'debris<m Transportation of soil/debris to RCRA
landfillw Monitoring of ground water quarterly for four
yearson Public Health Assessment conducted five years
following r«iM-idi.aI a« CoiEit: $ 610,000
pj w 9 000023
-22-
ALTERNATIVE NO. 1 - NO ACTION
The no action alternative implies leaving the site in Itspresent, condition without disturbing contaminated surfacesoils, Associated with the no action alternative would becontinued monitoring of surface water and ground water qualityat the site, allowing identification of any changes in siteconditions which could include the migration of contaminantsoff -site. Should changes be discovered which increase the risksassociated with the site,, this alternative could foe reassessedand r if necessary , alternat ive ac tions-i taken .
Also included in this alternative is the installation of a fencearound the perimeter of the 7 ,500 square feet area of surfacesoil contamination located at the northeast corner of theon-site pond. Warning signs would be posted on the fence andland use restrictions would be imposed on the site owner/operator to prevent the accumulation of additional areas ofcontamination exceeding the surface soil cleanup goals as aresult of the continuous handling,, storage or burning ofcreosoted railroad ties .
A public health assessment would be performed every five yearsto evaluate potential changes in risk associated with no actionat the site. Monitoring will be assumed to continue for 30years,, which is the minimal design life for an EPA remedialaction .
No additional risk: to public health or the environment wouldresult from implementation of this alternative. Theinstallation of a fence would require approximately two weeks
Little in the way of risk reduction would occur with thisalternative.. The potential for trespass in the area ofcontamination would remain; thus , the ingest ion exposure pathwaywould remain.. This alternative does not meet SARA'S preferencefor permanence and treatment .,
This alternative provides no treatment or reduction inor Mroiuinuit of iDE;iM:a]iiuLBfli.tad inutf.aoni st>iliii ..
5 ... 9 oooo,;:: o-23-
Institutional controls such as land use restrictions could beimplemented within the current Federal , State and localregulatory framework.
Fence construction could be implemented in a straightforwardmanner requiring no research or engineering and requiring aslittle as two weeks for fence construction,
Existing wells at the site would be used for the monitoring ofground water quality., In 10 ''to 15 years,, well casings andscreens may need to be replaced.
The total present worth cost for this alternative is estimatedto be $ 1,100,000, the vast majority of which consists of 0 & M.
This alternative is not the least expensive alternative, Atmost Super fund sites, the costs of monitoring are significantlyless than the costs for site remediation. However, at theAmnicola Dump site, the volume of contaminated soil is so smallthat several of the more detailed remediation alternatives areless expensive than the less detailed no action alternativewhich includes long-term monitoring of ground and surfacewater. In addition to monitoring ground and surface water for30 years, the no action alternative includes conducting a publichealth assessment every 5 years for 30 years.
This alternative does not comply with CERCLA requirements ;: ARARswould not be achieved since the exposure pathway of soilingest ion would remain .
3![:!£
The Public Health Evaluation concludes that ingestion ofcontaminated surface soils is the greatest concern at theAmnicola Dump site.. Ingestion of soils above the establishedcleanup goal is not acceptable and the no action alternativewould not provide an effective, long-term barrier to theinges t ion exposure pathway .
M» prete»Qoin for this alt.eiXBat.rira MIIIB crcninmicat^ed to EPA byeitter State personnel or the 'coanunity.
ALTERNATIVE NO. 2 ••• LOW PERMEABILITY COVER
5 .9-24-
Construction of a low permeability (clay) cover at the AmnicolaDump i-iite would involve the placement of clay and topi-soil overareas of contaminated surface soil that exceed the establishedsoil cleanup goals,.
Due to the absence of "clean" clay fill on-site, approximately600 cubic yards of clay would be hauled to the site and placedover the area of surface soil contamination. Approximately twofeet of this low' hydraulic conductivity material would beplaced, compacted, and then covered with a one-foot layer ofvegetative fill. Again, due to the absence of acceptabletopsoil material on-site, approximately 300 cubic yards of thismaterial would be hauled to the site,,Little in the way of re-contouring of the current ground surfacewould be required prior to construction of the cap, The current.surface of the area of concern slopes one to two percent to thewest (towards the on-site pond and Nick-a-Jack Reservoir). Thecap contour would match the current slope, resulting in adequatedrainage of precipitation, Drainage diversion ditches would beconstructed around three sides oil the capped area to promoterunon of surface water towards the on-site pond and away fromthe capped area. These drainage ditches would be lined withrip-rap to control erosion.
Once constructed, the capped area would be fenced to helpprotect its long™terra integrity.
Land use restrictions would be Imposed on the site to preventthe accumulation of additional areas of contamination thatexceed the established surface soil cleanup goals as a result ofthe handlingj, storage or burning of creosoted railroad ties.
Monitoring of ground water quality of the site would beperformed quarterly for a period of four years and semi-annuallyfor 26 years thereafter. A public health assessment would beconducted by EPA five years after implementation of the remedialaction to evaluate potential changes in risk associated with thesite.
Ground water use restrictions would be imposed within areasonable distance from the site in keeping with theestablishment of ACLs.
A low permeability cover is a reliable„ .low maintenanceprocedure for Uniting infiltration and reducing the nobility of
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contaminants . The soil exposure pathway would be immediatelybroken and risk from the site would be within the acceptable"risk range,Minimal risk would be associated with the construction of thisremedy ;: erosion control measures would be Implemented duringconstruction to prevent excessive sediment loading of theadjacent on-site pond and Nick -a- Jack Reservoir ..
This alternative would provide a continued , ef f ect ive reductionof risk posed by ingest ion of contaminated surface soils. A lowpermeability cover would minimize infiltration of surface water irthereby significantly reducing the migration potential ofcontaminants ., The potential for downward migration ofcontaminants would remain ;: however , the relatively immobilenature of PAHs, along with the minimization of surface waterinfiltration,, should prevent the formation of additionalexposure pathways.,
Periodic maintenance of the cap would enhance the long-termreliability of this alternative . Maintenance would consist ofrepairing any areas of erosion and maintaining a healthyvegetative cover .
Approximately one-half of the Amnicola Dump site lies within the100-year f loodplain of the Tennessee River ( Nick-a- JackReservoir);: all of the contaminated area of concern lies withinthis f loodplain. Although river elevations are regulated by theTennes see Val ley Authority , extremely heavy rainfall events overa short duration could cause flooding of portions of theAmnicola Dump site, specifically,, the capped area,, therebycompromising the long-term integrity of the cap.
^
This alternative would provide no treatment which wouldsignificantly reduce the toxicity, mobility or volume of thecontaminants. Preventing surface water infiltration wouldreduce the migration potential of contaminants .
Implementation of this alternative would involve the use ofstandard earth moving and compacting equipment. Site accesswould Jbe obtained with little difficulty; no temporary roads orpermits would be xeqoised for on-site activities .. Only minorclear log and grading operations mould ibe required prior to capconstruction. Labor and materials for this alternative arereadily available and would be obtained locally.,
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Institutional controls such as land use restriction.!-; could beimplemented within the current Federal , State and localregulatory framework .
Implementation time can be expected to take approximate ly twomonths.. Existing wells at the site would be used for themonitoring of ground water quality. In 10 to 15 years, wellcasings and screens may need to he replaced,,
The total present worth cost of this alternative is estimated tobe $ 900,000 which includes $ 684,, 000 for 0 !i« M.
Capping of the gn£ire Amnicola Dump landfill surface was notconsidered because i) Amnicola Dump was used as a constructiondebris disposal site and never as a permitted Solid WasteDisposal facility; and 2) levels of contaminants exceeding soil.cleanup goals were confined to one isolated area of the site,Thus, closure of the entire dump in accordance with Subtitle DSolid Waste regulations is neither applicable nor relevant andappropriate.
Land Disposal Restrictions would not be triggered becausecontaminants would be capped in-place; no placement ofcontaminants would occur .
This alternative does not comply with SARA'S preference fortreatment,
Q:£!iy;;jLLLJThis alternative would effectively break the soil ingestionexposure pathway,.
No preference for or objections to this alternative werecommunicated to EPA by either State personnel or the community.
ALTERNATIVE NO, 3 - SOLIDIFICATION/FIXATION
Sol idi. f icat ion/Fixation of contaminated surface soils wouldinitially involve the excavation of approximately 600 cubicyards of contundBated soils arid debris. Sampling will bepert oxiDBd during the remedial iitesic to conf lan actual. lateraland vertical extent of soil
Numerous debris in the subsoil of the contaminated area wouldrequire on»?s ite materials hand! ing prior .to .solid! f ication
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-27-
processes. This debris, such as bricks, broken concrete, scrapmetal.!, and wood, may require off -site disposal, at a permitteddisposal facility . Land Disposal Restrictions for CERCLA debrismay not foe in effect at the time of construction and the debriscould be disposed of at a permitted landfill without priortreatment. However, the levels of contaminants on the debrismay not exceed cleanup goals (or Land Disposal Restrictionrequirements if they are in effect), thereby allowing the debristo remain on-site.
Once debris has been removed, approximately 400 cubic yards ofsoil, would require treatment.
Mixing of the soil with stabilizing agents would be performedon-site and above-grade. The mixed material, would be placedback in the excavated area and covered with a 12 -inch thicklayer of vegetated topsoil. Due to the lack of acceptabletopsoil on- site,, approximately 300 cubic yards of material wouldbe hauled to the site. The finished ground surface would matchthe existing ground contour ,
Treatability or bench scale studies would be necessary todetermine which solidification agents are most effective for theAmnicola Dump waste .
Land use restrictions would be imposed on the site to prevent.the accumulation of contamination that exceed the surface soilcleanup goals as a result of the handling, storage or burning ofcreosoted railroad ties. Ground water use restrictions would beimposed within a reasonable distance of the site in keeping withthe establishment of ACLs .
A quarterly monitoring program to analyze for those ground waterconstituents of concern would foe implemented for a period offour years. A public health assessment would be conducted byEPA five years after remedial, action implementation ,, Followingthis assessment , monitoring activities would foe terminated ,.provided that the public health assessment does not identify aneed for further remedial action or monitoring.
Solidification o £ contaminants would immediately break theingest ion exposure pathway . This alternative would involveminimal risk to workers during construction with the exceptionof potential exposure of site workers to contaminated dustduring excavation . Exposure risks would foe minimized through•the uiiie of wetting agents or wnter .. Continuous airiioould be pBriiormuad to «nuinure mitfflt worker safinrty..
Erosion control measures would be implemented ituxing
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activitiee to prevent sediment mid contaminant loading of theGUI-site: pond and Nick-a-Jack Reservoir.
All contaminated soil exceeding the established cleanup goalswould be immobilized and the soil ingest ion exposure pathwaybroken, Solidification would produce a monolithic block ofwaste with high structural integrity . Stabilizing agents shouldmechanically lock up the PAH coinpoundi-i within a solidifiedmatrix resulting in reduced surface area and negligiblecontaminant loss over a long period of time, Leaching testshave shown that solidification is an effective means toprevention o f contaminant migration .
The organic compounds at Amnicola Dump (sum of six carcinogeniccompounds-; was less than 125 ppm in the area of concern) shouldnot interfere with the setting,, curing,, and performance of thes o 1 id i f i ed ma t er ia 1 .
Long-term management and monitoring would not be required withthis alternative .,
Sol id i f ic at ion would s igni f ic ant ly reduce the mobility ofcontaminants and comply with SARA'8 preference for treatment,.
Implementation of this alternative would involve the use ofstandard earth moving and cement mixing equipment,, Special.equipment would be required, however ,, to separate debris fromthe waste prior to solidif ication processes. Site access wouldbe obtained with little difficulty; no temporary roads orpermits would be required for these on™ site activities. Minorclearing operations would be required prior to excavationactivities . Labor and materials (assuming Portland cement orlime-based poxzolan is used) are readily available and could beobtained locally.,Institutional controls such as land use restrictions could beimplemented within the current Federal, State and localregulatory framework.
An implementation time of approximately two months can beeaqiected following ramedlal deiiiigmi which weald* include <intxMtability or tench-sctl* study xaqairiag up to tJla:i»e vonthBto complete ,
5 .9 000036
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The total present worth cost for this alternative is estimatedto be $ 6 40 ,,000 which includes $ 384,000 for 0 !< H.
This alternative achieves SARA.' s preference for treatment and,,as demonstrated by the MIL calculations,, is protective of humanhealth and the environment .
£!YJI[jlLLLJi!£sI
This alternative is protective of human health and theenvironment since all contaminants exceeding the establishedsoil cleanup goal will be immobilized and the soil ingestionexposure pathway broken .
J ^The State accepts this alternative for achieving the remedialaction objectives ; however , the State has withheld concurrencepending a further review of Tennessee "s Alternate ConcentrationLimit policy and its applicability to ground water contaminantsat the Amnicola Dump site. Only one comment from the communitywas received during the public comment period. This residentfelt too much money was being spent on site remediation.
ALTERNATIVE NO. 4 - OFF --SITE INCINERATION
This al ternat ive involve s the of f -s ite inc inerat ion ofcontaminated soils and o f f - s ite disposal of inc inerat ionresiduals .
Approximately 600 cubic yards of contaminated soil would beexcavated to a depth of two feet below ground, surface. Samplingwill be performed during remedial design to confirm the actual.lateral and vertical, extent of contamination .,
Numerous debris in the subsoil of the contaminated area wouldrequire on-site materials handling prior to shipment of thewaste off -Bite. For estimation purposes, it was assumed that50% of the excavated material consists of debris. This debris(approximately 325 cable yards), such as wood, scrap metal,concrete blocks , etc., may require off -site disposal at apermitted landfill or allowed to remain on-site, Off-sitedisposal would be necessary if sampling indicates the. debriseontainiii ct>n£»rail:xatixms of contaminants anseeddng the cleanupgoals. Hoiwewer,, if Land Disposal ReiEttrictioBS axe ift «f feet mi!:the time of remedial action implementation, disposal at amoff-site location will foe necessary if contaminants exceed LDRtrea tmen t .s tandards .
oo oo;:;; 7-30-
Subsoil debris would undergo o.n-site materials handlingprocesses such as screening to remove debris and reduce particlesize to two inches or less, depending upon the incinerationfacility used. Once debris has been removed,, and assuming a 20%volume expansion of soil during excavation,, approximately 350 -400 cubic yards of soil. would remain to be treated.
All feed material would be containerized in 30-gallon fiber orpolyethylene drums or 55-gallon steel drums prior totransportation . All transportation loads would be manifestedand carried by licensed hazardous waste haulers. Permits forthe incineration facility would be verified prior to initiatingthe process .
Once excavation activities have been completed , the excavatedarea would be backfilled with clean fill hauled in from anoff -site location and the ground restored to its originalcontour.
Land use restrictions) would be imposed on the site to preventthe accumulation of additional areas of cont.ajrn.inat ion thatexceed the surface soil cleanup goals as a result of thehandling , storage or burning of creosoted railroad ties. Groundwater use restrictions would be imposed witihin a reasonabledistance from the site in keeping with the establishment ofACLs.
A quarterly monitoring program, to analyze for those ground waterconstituents of concern would foe implemented for a period offour years. A public health assessment would be conducted byEPA five years after remedial action .implementation „ Followingthis assessment. ,- monitoring activities would be terminated ,provided that the public health assessment does not identify aneed for further remedial, action or monitoring.
Incineration of contaminated soils would immediately break thesoil ingestion exposure pathway „
This alternative would involve minimal risk with the exceptionof short term exposure to site workers., These potential impactscan be reduced by implement at ion of a site-specific health andsafety plan including the use of wetting agents duringexcavation activities . Continuous air monitoring would beperformed to ensure site worker safety. In addition, there issome risk to the general population associated with
of than mi.ter.Li»ls .,
Eros ion control nmiEmres would be inpleBanted during wccava t ionactivities to prevent sediment, and contaminant, loading of theadjacent on-site pond and Nick-a-Jack Reservoir .
5 ... 9fink"•-' •«..•
nk
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All contaminated soil exceeding the eatabl ished cleanup goalswould be detoxified and delis ted. The soil ingestion exposurepathway would be broken,. Removal, of contaminated soil willeliminate the need for installation o£ any long-term treatmentor containment technologies .
Implementation of this alternative will result in totalreduction of toxic ity, mobility and volume of site contaminants.
Implementation of this alternative would involve the use ofstandard earth moving and hauling equipment ,. Special equipmentwould be required, however, to separate debris from the wasteprior to transportation .
Site access would be obtained with little difficulty;: notemporary roads would be required for on-site activities, Laborand resources are readily available and could be obtainedlocally ., Transportation loads would require manifests andtransportation by licensed hazardous waste haulers ,. Permits forthe incineration facility would require verification;verification of the unit's ability to accept waste within therequired time frame would be necessary ..
The greatest difficulty with this alternative would be locatinga facility to accept the screened •••out debris,, For costingpurposes, it is assumed that the debris would be transported tothe Chemical Haste Management Inc. RCRA facility in Erne lie,,Alabama and that Land Disposal Restrictions for CERCLA debrisare not in effect at the time of remedy implementation..However, these restrictions for CERCLA, debris may not be ineffect at, the time of construction and the debris could bedisposed at a permitted landfill without prior treatment,. Ifsampling indicates that the levels of contaminants on the debrisdo not exceed cleanup goals (or Land Disposal Restrictionrequirements if they are in effect),, the debris may remainon-site .
Total implementation time is estimated to take no longer thansix weeks.
laBtit-utional controls such as land use restrictions could heiAplaiiented wii±J.a Hunt currant Federal ir Sfcatwi ainid localregu 1 at ory framework .
5 - 9 000033
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The total present worth cost of this alternative is estimated tobe $ 1,100' 000 which includes $ 384,000 for 0 & M.
HI omp 1 i a nc e Hi£h
This alternative would comply with SARA'!-! preference fortreatment and,- as demonstrated by the ACL calculations, isprotective of human health and the environment.
Transportation of all contaminated soil would be in accordancewith appropriate, Federal and State regulations . The treatmentand disposal facility receiving .the contaminated soil would bein compliance with all ARARs.
QYM yJ:..
This alternative is protective of human health and theenvironment since all contaminants exceeding the establishedsoil cleanup goal would be removed from the site, detoxified,and delisted. The soil ingest ion exposure pathway would bebroken .
No preference for or objection to this alternative wascommunicated to EPA by either State personnel or the community.
ALTERNATIVE NO. 5 - OFF-SITE DISPOSAL
Of £ -site disposal would involve the excavation of approximately(500 cubic yards of contaminated soils down to two feet belowground surface. This material contains numerous debris such aswood, scrap metal, broken concrete,, etc. that were identifiedduring the HI field sampling program. Actual extent and depthof contaminated material to be excavated will be determinedduring remedial design .
Excavated wastes would be stockpiled in a staging area thatwould serve as a place for loading and decontamination. Wastesshould not require stockpiling for more than two or three days;:thus, no special pads or drainage devices would be required.
The wastes would be manifested by a licensed hazardous wastehauler and transported to an approved RCRA Subtitle C hazardouswaste landfill.
<«xcavatJ.on activit les have tarai completed <r the excavatedarea would be backfilled with clean material hauled in from anoff- site location arid the giro and surface restored to itsoriginal contour .
5 , 9 OQCKKQ-33-
Lanci use restr let Ions would be imposed on the site to preventthe accumulation of additional areas of contamination thatexceed the surface soil cleanup goals as a result of thehandling , storage or burning of creosoted railroad ties.. Groundwater use restrictions would be imposed within a reasonabledistance from the site in keeping with the establishment ofACLs .
A quarterly monitoring program to analyze for those ground waterconstituents of concern would, be implemented for four years. Apublic health assessment would be conducted by EPA five yearsafter remedial action implementation. Following thisas ses sment , monitoring ac t ivit ies would be terminated , providedthat the public health assessment does not identify a need forfurther remedial action or monitoring .
Off -•site disposal of contaminants exceeding the established soilcleanup goals would immediately break the ingestion exposurepathway.
This alternative would involve minimal risk with the except ionof short-term exposure to site workers. These potential, impactscan be reduced by implementation of a site-specific health andsafety plan and the use of wetting agents during excavationactivities . Continuous air monitoring would be performed toensure site worker safety.. In addition,, there is some risk tothe general population associated with transportation of thematerials,.
Eros ion control measures would be implemented during excavationactivities to prevent sediment and. contaminant loading of theadjacent on-site pond and Nick-a-Jack Reservoir ,,
Al I contaminated soils exceed ing the established soi 1 c leanupgoals would be removed form the site; however,, risk from thesesoils would be transferred from the Amnicola Dump site toanother location.. No long-term monitoring or 0 lit M requirementsare anticipated .
This alternative provides no reduction of toxic ity, mobility orvolume of contaminated soils .
Implementation of this altar native would involve the. use ofstandard earth moving and hauling equipment ,.
5 .9 OOOQ<il
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Site access would be obtained with little difficulty; notemporary roads would be required for on- site activities. Laborand resources axe readily available and could be obtained1 oc a 1 1 y . Trams port at ion 1 oads won. Id r equ i re man i £ e s t s andtransportation by licensed hazardous waste haulers .
The greatest difficulty with this alternative would be locatinga facility to accept the waste. For costing purposes, it isassumed that the waste would be transported to the ChemicalHaste Management Inc. RCRA facility in Erne lie, Alabama.,
Land Disposal Restrictions, however, may take effect before thisalternative could be implemented in which case the soil/debrismay require treatment prior to disposal . For cost estimationpurposes , it is assumed that Land Disposal. Restrictions are notin effect at the time of remedy implementation,, If samplingindicates that the levels of contaminants on the debris, do notexceed cleanup goals ( or Land Disposal. Restriction requirementsif they are in effect), the debris may remain on-site.
Implementation time , including excavation, hauling, and siterestoration is estimated to take no longer than three weeks .
Cost.
The total present worth cost for this alternative is estimatedto be $ 610, 000 which includes $ 384,000 for 0 & M.
This alternative would not comply with SARA'S preference fortreatment.
Transportation of all. contaminated soil would be in accordancewith appropriate Federal and State regulations . The disposalfacility would be in compliance with all. ARARs .
Qz:=o;jLLOThis alternative is only partially protective of human healthand the environment since all risk would be removed from, theAmnicola Dump site but transferred to another location..
No preference for or objection to this alternative wascommunicated to EPA by the community., The State commented thattills Of f -Sit* Di.iii;pi:)ii»ai would alma iiint .111:1:1 aoDiapUiihle alternative .,
6.06... 1. . Description of Recommended Alternative
5 - 9 0000*42
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The recommended alternative, Alternative I 3, for remediation ofcontamination at the Amnicola Dump site, includes the Hollowingcomponents:
w Excavation and screening of contaminated soil/debrisin Treatment of contaminated soil on-sitein Debris disposed off-site if contaminated; allowed, to
remain on-site if (sampling confirms it is cleanin Placement of solidified mass on-site, above the ground.
water table, and outside the 100-year floodplainn» Monitoring of ground water quality for four yearson Public health assessment conducted five years after
remedial action
Contaminated soil/debris would be excavated from a location inthe northwest corner of the Amnicola Dump site (Figure 4). PAHsat this location were detected, at a concentration of 123 ppm, 23ppm above the 100 ppm cleanup goal that has been established forPAHs at the Amnicola Dump site. While the levels of PAHs abovethis cleanup goal of 100 ppm are believed to be confined to thisone location,, biased sampling in the area of concern., as well asrandom site-wide sampling, will be conducted during remedialdesign to determine if heavy equipment traffic on-site hasdistributed contaminants elsewhere on-site.
Additionally, surface water samples would be collected, from theon-site pond during the remedial design., Additional samples arenecessary in light of the conflicting data obtained during theRI concerning the presence of bis (2-ethylhexyl)phth.al.ate in twopond water samples. Should bis(2-ethylhexyl)phthalate bedetected, at significant concentrations during the rem.edi.aldesign sampling, the Record of Decision would be re-evaluatedand appropriate actions taken to mitigate the threat orpotential threat to aquatic: life, if necessary.
Following remedial design, an estimated 1500 cubic yards ofsoil/debris would be excavated and the debris (wood, metal,concrete,, etc.) screened. Approximately 400 cubic yards ofcontaminated soil, would remain to be treated. Sampling of thedebris will be performed during remedial action to determine ifthe debris contains concentrations of contaminants exceedingeither the cleanup goal or Land Disposal Restrictionrequirements (if LDRs are in effect at the time of remedyimplementation), whichever is more stringent. 1:1: samplingindicates that the debris does not contain concentrations ofcontaminants above the applicable standard, the debris will ber«- diiipos.it iiid on- IB!te.
•lacing of ticw contaBinatMl moll vith ctalbllicing iiiq-iiriTlMii innnicin aimceiDiient, kiln dust,, etc. would be performed on-site andabove-grade.
ۥ033*0
DUMP RiTSSNESStt
U.S. E-P.A. BESS" SVt^SURFACE SOIL RBOMATION TO 100
roNTAMIHRTIOM HAVINGEXCECDING CLEANUP «o«,.
5„9 000044
...')[ 1...*J' V
Solidification/fixation of contaminated soil should facilitate achemical or physical reduction of the mobility of contaminants.A. bench-scale treatability test would be conducted to select theproper additives and their ratios and to determine the curingtime required to set the waste adequately. Leaching tests andcoppressive strength tests would also be conducted to determinethe'integrity of the solid end product.
Actual attainment of cleanup goals, like any other remedial.alternative, using the solidification/fixation technology willnot be known until remedial action has been completed. However,,creosote type wastes have been successfully treated bysolidification/fixation and it is very reasonable to assume thatat least a 19% reduction in the concentration of PAHs from theleachate that may migrate from the solidified mass can beachieved.. A 19% reduction would reduce the concentration ofcontaminants to the cleanup goal of 100 ppm.
The solidified mass would be placed in an area of the site abovethe ground water table and outside the 100-year floodplain. A12-inch thick layer of topsoil would then be placed over thesolidified mass and the ground surface restored to its originalcondition.
Land use restrictions would be imposed on the site to preventthe accumulation of contamination that exceed the surface soilcleanup goals as a result of the handling, storage, or burningof creosoted railroad ties.
SARA Section 121(d)(2 )(b)(ii) provides for the establishment ofAlternate Concentration Limits (ACLs) under certaincircumstances. One of the criteria for establishment of ACLs isthe existence of institutional controls that preclude humanexposure to the contaminated ground water at any point betweenthe site boundary and all known and projected points of entry ofsuch ground water into surface water,. The point of entry forthe Amnicola Dump site is the property boundary where the sitemeets the Tennessee River. Therefore,, the key to obtaining ACLsat the Amnicola Dump site is to develop enforceable restrictionson ground water use within a reasonable distance of the site.The exact distance and method for the restriction would bedeveloped, during the remedial design phase.
A. quarterly monitoring program to analyze for those ground waterconstituents of concern would be implemented for a. period offour years. A public health assessment would be conducted byHPill five years after remedial action implementation. Followingthis aii(einisiEiw!!Bt monituaring activities would be tumixiatad,,provided that the public health asseiEiranent. does mot. identify aneed for further remedial action or.monitoring.
5 ,9... 3 9...
All of the alternatives, with the exception of the No Actionalternative„ would immediately break the soil ingestion exposurepathway. Minimal risk is associated with remedy"constructionfor each alternative;; however, solidification, off-siteincineration, and off-site disposal would require additionalprecautionary measures to ensure the safety of workers,,Off-site Disposal and Off-Site Incineration add a slight risk tothe general public due to hauling activities. Given therelative immobility of site contaminants and media they arecontained in (soil), this risk would be minimal in, the event ofan accident,,
All alternatives, with the exception of the No Actionalternative, would require temporary erosion control measures toprevent impact to the adjacent on-site pond and Nick-a-JackReservoir during remedial action.,
Alternatives 2 through 5 provide an equal degree of short-termeffectiveness,.
Solidification and Off-Site Incineration provide the greatestdegree of long-term elimination of risk posed by contaminants atthe Amnicola bump site.
The Low Permeability Cover Alternative would also providelong-term protection to public health and the environment butthe potential exists for rare, but nonetheless possible,, floodevents which could compromise the integrity of the cap,,
Off-Site Disposal merely transfers the risk to another locationbut would offer some protection by proper disposal in apermitted hazardous waste facility. Fencing (No Action)provides little in the way of prevention of long-term exposureto site contaminants,
By detoxifying contaminants, the Off-Site Incinerationalternative offers maximum reduction of toxicity, mobility, andvolume and is thereby the most effective in achieving thiscriteria. Solidification would provide a significant reductionof contaminant mobility.,
Alternatives 1 and 2 offer no or minimal reduction in toxicity,mobility or volume of contaminants at the Amnicola Dump site.
The fence construction, monitoring and land use restrictioncomponents of Alternative 1 would mato tills -alternative toeLnianit. difficult to. :i.iiii]:xl.'i=i:iii«i[|[!.:t:..The Low :i E:!riEeal:tIl.Itf Cover would present feuer difficulties thanAlternatives 3 through 5 because no permits would foe required
5•9-39-
and all activities could be performed with standard,, readilyavailable equipment and resources „
01: 1: -Site Disposal would require licensed hazardous waste haulersand location of an approved RCRA facility to accept the waste..Standard, readily available equipment could also be used.
Both Solidification/Fixation and Of f -Site Incinerationalternatives require licensed hazardous waste haulers ( debrisonly for the Solidification/Fixation alternative) and the use ofspecial equipment for screening of: debris from the waste,,However,, Off -Site Incineration involves the location of alicensed incineration unit that would accept the waste withinthe required timeframe. Solidification/Fixation would require atreatability or bench- scale study but this could be performedduring the remedial design with minimal impact to projectschedule.,
Off -Site Incineration is estimated to be the most expensivetreatment alternative . The Sol idif icat ion/Fixation and Of f -SiteDisposal, alternative are similar in cost and are the leastexpensive alternatives . The alternatives which included themost limited remediation alternatives , No Action and Capping ,are not the least expensive alternatives. This is due to theextens ive long-term monitoring requirements not inc luded in theother al ternat ives .
Cost es t imates for Sol idi f i.c ation/Fixat ion are perhaps the leastaccurate. This is due to the large variability in unit costsattributable to difficulty in estimating operating parametersbefore completion of treatability studies, and the very smallvolume of soils to be remediated.
All alternatives, with the exception of the No Actionalternative, are protective of human health and the environment;however , only So 1 idi :!: ic at i o n / F ixat ion and 0 f f ••• S i. te Inc i ner at ioncomply with SARA' s preference for treatment ,.
Off -Site Icineration and Of f -Site Disposal involve compliancewith additional ARARs associated with the transportation ofhazardous materials ., Alternatives 4 and 5 involve incinerationand disposal, respectively , at approved, facilities only.
Of f -Site Incineration and Solid! feat ion/Fixation alternativesboth offer the greatest degree of overall protection of humanhealth and the environment . Off -Site Incineration involvesalightly gram-tar zisk due. to the transportation xequixwients.No Action providn the least protection while Capping andOff -Site Disposal fall somewhere in the middle,.
5 .. 9-40-
Thus, EPA believes that Alternative 3 presents the best balanceamong the effectiveness , inplementability, and cost factors forthis "site. Further, this remedy meets all applicable federaland state standards .
6 . 2 Operation and Maintenance
Overall implementation of this remedy is estimated to take 1month following remedial design. Ground water monitoring willbe performed for four years following remedial action. A publichealth assessment will be conducted within 5 years of remedialaction. Monitoring activities would be terminated, after the4 -year monitoring period, provided that the public healthassessment does not identify a need for further monitoring orremedial action .
6 .3 Cost of Recommended Alternative
The present worth cost of this remedy is estimated to be$ 640,000. The capital cost would be approximately $ 256,, 000,,The total present worth of the 0 & M costs is estimated to be$ 384 ,000,.
6 .4 Schedule
The planned schedule for remedial activities at the AmnicolaDump site is as follows:
April 1989 Initiation of Remedial DesignSeptember 1989 Initiation of Remedial ActionOctober 19 89 Remedial Action Completed/
0 £> M Initiated
Motes This schedule assumes that EPA will conduct the RemedialDesign/Remedial. Action. Should the Potentially ResponsibleParties accept EPA's offer to conduct the RD/RA, this schedulewill not apply and a new schedule would be negotiated through aConsent Decree .
6 ,. 5 Future Action
Following completion of remedial action, 0 & M activities willbe initiated. 0 lit M activities are estimated to take 4 yearsHollowed by a public health assessment within 5 years ofremedial action implementation „ Currently,, there are no knownstate or federal regulations or guidelines that, restrict the useof a sita CDitttaiaxwji solidified waste. A&\ long as the groundrater and l.i!i:n,i:l luise restrictions are «Mlbi>!rniii:ll to', site use will itoadictated try the site owner,During Remedial Design, soil samples will be collected at the
5 ,. 9-41-
Amnicola Dump site.. Sampling will include random, site-widesurface soil as well a si biased sampling in the area of concern.Biassed sampling will be conducted to gain a more accuratevertical and lateral extent of contamination for use in designconsiderations „ Random,, site-wide (sampling will be conducted todetermine i:l! site conditions have changed since the 1986 sitesampling .
Should sampling indicate that soil contamination is no longerpresent (e.g. traffic: over the site by the on-site salvagebusiness has dispersed contaminants ) , surface soil remediationmay not be required. Site- wide sampling may indicate thatadditional hot spots are present on-site.. If additional areascontaining concentrations of contaminants above 100 ppm arediscovered during remedial design, the scope of soil remediationwill be expanded to include these areas. if soil contaminationabove 100 ppm in the area of concern is no longer present,, or ifadditional areas are discovered, the remedy will bere-evaluated. This re •••evaluation may result in a change in theselected alternative or the decision to take no action at thesite., Such actions would be public-noticed and a comment periodheld prior to implementation of these actions.,
6 .6 Consistency With Other Environmental Laws
!!IlJE::<!l!:!j;LJ!iL!:L!!Ul!;Ll!;:!iLs - Section 1 2 1 governs"ground water ceanup standards and allows the establishment
of ACLs provided, that there is no significant increase incontaminants in off-site surf ace water,. Section 121 alsospecifies that the point of human exposure may not bebeyond the boundaries of the site when establishing ACLsunless;:
- There are known and projected points of entry ofcontaminated ground water into surface water ;
-•• There will be no measured or projected increase ofcontaminants from the ground water in the surface waterat the point of entry, and;
- There are institutional controls that preclude humanexposure to ground water ,.
Institutional controls will be put in place within areasonable distance of the Aiiinicola Dump site to precludehuman consumption of ground water., There are currently:no ground water users on or domitgradiant of the site,,Sfeonld tto conoentrat Ion of ctiriTt.Htnii.Li in-nt.iii i»i ground imaton:meet or slightly exceed the established l£:i.sir tJneresult .ing C(:mc«itntzatio>n of tJHiise .contaminants < 'in theTennessee River will still, be non-detectable. Thus,,
5 .9 00004,9-42-
there will be no significant increase of contaminants insurface water ..
"• Requires adequateprotecton of fish and wildlife if any 3 1 ream or otherbody of water is modified.. Additionally, actions infloodplains are required to avoid, adverse effects,,minimize potential harm,, and restore and preserve naturaland beneficial value!-: .
Actions such as silt fencing will be undertaken duringremedial action to avoid sediment and/or contaminantloading of the Tennessee River or on- site pond.
!;!JL;i£Jl<;!J!L!;;!i-'<;L.J:L!;!!:-!.<;;J:J:!::L.j£:!;: - Requires action to conserveendangered or threatened species for activities incritical habitats upon which these species depend.
Those species identified by the U.S. Department ofInterior - Fish and Wildlife Service (See Appendix C) asfederally listed endangered (E) and/or threatened (T) whichmay occur in the area of influence of remedial action atAmnicola Dump include ::
Snail Darter (T), Orange- footed pearly mussel (E), andPink mucket pearly mussel (E). Remedial action atAmnicola Dump will be implemented in a manner resultingin no impact to threatened and endangered species orsurface water quality of the Nick- a •••Jack;reservoir.,
Mil! t :ionaj .. ...Hi jtojc ca,l__Preservation_ ci. - Re qu i re s t ha taction be taken to preserve or recover historical orarchaeological data which might be destroyed as a resultof site activities .
There is no information to indicate that the Amnicola Dumpsite contains any sites which may be considered to be ofhistoric or archaeological significance! (Appendix D) ..
Establshes criteria for monitoring ground water qualitywhen contaminants have been detected., This involvesdevelopment of a ground water quality data base sufficientenough to characterise seasonal fluctuations in groundwater quality at the site.
applicable to~the waist'e 'on"--'s it'e if the soils are excavatedKind removed or excavated aad treated. In alternativeswhere the LDRs are applicable, the soil must be treated to
5.9 OOOQSO
-43-
t he interim treatment levels prior to land disposal. .,LDRs for CERCLA soil and debris will be adhered to if theyare in effect at the time of remedial action. Should LDRsbe in effect at the time of remedial action,, and if thecone en tr at ion of contaminants on. the excavated debrisexceeds LDR standards „ the debris will be treated prior todisposal,,
7 • 0Community relations act ivit ies have remained an important, aspectthroughout the RI/FS. On December 15, 1987,, a publicinformation meeting was held at the Chattanooga Hamilton CountyBicentennial Library in Chattanooga, TN to inform the communityof EPA's activities during the RI/FS process. Prior to theDecember 15 meeting, public notices, fact sheets , and pressreleases ware issued .
On January 30, 1989,, the final draft RI and FS reports weresubmitted to the public information repository in Chattanooga .,A public meeting was held at the Chattanooga Hamilton CountyBicentennial Library in Chattanooga on February 13, 19139 topresent the findings of the RI and EPA's preferred remedial.alternative. Prior to the February 13 meeting, EPA issued pressreleases, public notices, fact sheets, and a proposed plan.Following the February 13 meeting, a public comment period washeld for 21 days, ending on March 5, 1989.
Comments and EPA responses are included in the ResponsivenessSummary portion of this Record of Decision. The Record ofDecision will be placed in the public information repository anda public notice will be issued stating the basis and purpose oil-the selected alternative. When EPA approves the design for theselected alternative,, a fact sheet will be issued explaining thefinal engineering design. A fact sheet will be issued againbefore construction of the design begins.
8 . 0As required by CERCLA,, Section 104 (C), the State must assurepayment of ten percent of all costs of remedial action.Remedial, action has been defined in SARA as including allconstruction and implementation activities until siteremediation is completed . Activities required to maintain theeffectiveness of the remedy following completion of the remedialaction IB considered operation and maintenance (0 fti M). If•ur£ ace water or ground water ±xaataent is put: of tne :»MII»IHIII%Wonly the first ten years of such treataent will be considered amxenugsdial action;; the remaining period of. treatment will be apart of 0 & M activities . This State is required to pay 100
5 .9 oooosi...44-
percent of all 0 & M following completion of the remedialaction, EPA and the State may enter into an agreement:, wherebyEPA would fund 90 percent of 0 & M costs,, for a period not toexceed one year, until the remedy is determined to beoperational and functional.
A summary of State cost-sharing obligations for the recommendedalternative at the Amnicola Dump site is shown in Table 5 . TheState of Tennessee 's cost-sharing responsibility is estimated tobe $ 25 r 3 00 for remedial action and $'297,600 for 0 & M.
9.0CERCLA section 117 (b) requires that the final remedial actionplan (i.e., ROD) be accompanied by a discussion of anysignificant changes (and the reasons for such changes) in theproposed plan and a response to each of the significantcomments, critic isms, and new data submitted [on the RI/FSreport and the Proposed Plan].
If significant changes are made to the Proposed Flan,, EPA mustdocument the significant changes , and the reasons for thesignificant changes, in the ROD. EPA also must make thedetermination if the significant changes could have beenreasonably anticipated based on the RI/FS Reports and theProposed Plan. Where such changes could not reasonably havebeen anticipated by the public, EPA must, provide an additionalopportunity for public comment .
A significant change was incorporated to the recommendedalternative ( Sol. Idi f cation /Fixation) subsequent to the publicmeeting and release of the Proposed Plan. The cost, for therecommended alternative was presented at the Public Meeting andin the Proposed Plan as $ 415,500, which included $ 127, 500 forOperations and Maintenance (0 <!< M) . Revised cost estimates werereceived on all alternatives evaluated in the Feasibility Studysubsequent to the issuance of the Proposed Plan. As presentedin this ROD, the estimated cost for Solidification/Fixation isnow $ 637,000, which includes $ 3 8 4 ,,000 for 0 & M.
Ground water monitoring was added to the treatment alternativessubsequent to EPA's peer review of the draft Feasibility StudyReport, The additional costs associated with this new componentwas underestimated . The contractor preparing the revised costestimates could not provide final costs prior to the publicmeeting and issuance of the Proposed Plan. The public meetingdate was already established when the roieed fox revised costest:i:iutfflis «i».s identified,. Thus,, a algalf leant ehaaga tin fetecost, of the recommended a Iternative resulted ..
5.9 OOOQS2
-45-
The estimated cost of the recommended alternative increased by$ 221,,500 and could have been reasonably anticipated by thepublic. On page 5-12 of the Peasibilty Study report that wassent to the public information repository, the followingstatement was made: "Revised cost estimates will be preparedand included in the Final FS Report, following the public commentperiod.." It was also noted on page 5-12 that the addition ofground water monitoring to the treatment alternatives was thereason for cost uncertainty.,
Therefore, the estimated cost for the recommended alternativeincreased significantly (53%) as a result of the addition ofground water monitoring to the treatment alternatives just priorto the public meeting. This increase could have been reasonablyanticipated by the public based on the information in the FSReport. Subsequently, there is no need for an additional publiccomment period.
5 . 9 OOQQS3
TABLE 5
STATE COST-SHARIN6 OBLIGATIONSMINI:COLA DUMP SITE
ACTIVITY
CONSTRUCTIONCAPITAL COSTS
FIRST YEAR 0 !, M
REMAINING 0 fit H
TOTAL
EPA
$ 227,700
66,400
0
314,000
STATE
$ 25,300
9,600
268,000
322/900
TOTAL
$ 253,000
9 6 ,000
2813,000
6. 37 ,QQO
5 .9 oooosiRESPONSIVENESS SUMMARY
AMNICOLA DUMP SITE, CHATTANOOGA, TENNESSEE
This community relations responsiveness summary is divided into theHollowing sections::
SECTION I. QvejryjLew: This section discusses EPA's recommendedalternative for remedial action and public reaction to thisalternative.
SECTION II. li!!£kgrpj: Thissection provides a brief history of community interest and concernsraised during remedial planning activities at the Axnnicola Dump site.
s ECT i ON 1 1 1 . SyM!!iy;::L j;> ^£!2ME!!=-L![ Both the commentand EPA's response are provided".
SECT ION IV ,. R mjairiing_ oncerris : This sec t ion describes remainingcommunity concerns that EPA should be aware of in conducting theremedial design, and remedial action at the Amnicola Dump site.
I • OVEBV££W
With the issuance of the Proposed Plan to the public in February1989 , EPA presented its preferred alternative. This alternativeaddresses surface soil and ground water contamination at the site.The recommended alternative specified in the Record of Decision (ROD)includes :: solidification/ fixation of contaminated surface soils ,imposition of land and ground water use restrictions, and themonitoring of ground water ,,
Only three sets of comments were received during the public commentperiod; two from residents, and the third from one of the PotentiallyResponsible Parties.. Therefore , it is difficult to assess thecommunity's preference for remediation of the site. One of theresidents did, however, feel that the alternative cost, too much andthat no action was more appropriate ..
II- IMIlliilfiMThe Amnicola Dump site is located in an industrial area of the cityof Chattanooga. The nearest resident is located approximately oneBiile l:.o the. northeast of the site., CoaBuunity interest.. at theAndcola Damp Bite is low as «u indicated toy participation at theDecember IS 1:17 and February 19B9 public neat ings „ the lour mmber ofinquiries received throughout the RI/FS, and the low number ofcomments received during the public comment period,.
5 .9 000053„.;;>....
There are no active environmental or citizen groups following theprogress of the site. This can probably be attributed to thelocation of the site in an industrial surrounding and the fact thatthe Remedial Investigation,, as well, as numerous sampling events priorto the RI , concluded that the site was having no negative impact onthe surface water quality of the Tennessee River,.
in ,. SUMMARY pj py£Li£_pQ!Q£Nj;£_iiiECEIVE£! J;0=!1I!*P THE PUBLIC
1... A comment was made that remediation costs for the recommendedalternative were too high, that EPA must stop putting millions into"non-dangers". An article in the Chattanooga News -Free Press, datedFebruary 15, 1989, on the Amnicola Dump site was referenced in thecomment. This article stated that "...the [Super fund] emphasis[should] be put on major problems while simply fencing and postingwarning signs might foe sufficient to avoid any danger from those[Amnicola Dump] of less magnitude.""
The Public Health Evaluation, using Agency guidelines and policy fordetermining site risks,, identified an unacceptable level of risk tosite workers, site visitors, and potential future on-site residentsif soil was ingested in the area of concern, over a number of years.Fencing and warnings signs around the area of concern might deteringestion of soil in that area; however, it is Agency policy tomonitor a site for 30 years if contaminants are left in place abovehealth-based levels,, Therefore, fencing the area (No Action) wouldcost more than treatment of waste and not meet Super fund's preferencefor treatment. Solidification/Fixation represents the mostc o s t -e f f ec t i ve a 1 1 e r na t i ve f o r s i t e de 1 e t ion f r om t he Nat iona 1Priorities List.
2,. A comment was made that EPA should reconsider bioremediation as atreatment alternative . The following questions were also raised:(1) Was the sampling technique accurate and clean enough that PAHswere not introduced to greater depths of soil;
(2) Is it not likely that contamination is actually in the first 15"horizon;
(3) Was EPA 's concern over clay soil from the standpoint of capintegrity breach;;
(4) Did your bioraiioiediation option consider tilling La compostedorgaB.ii:: material fluid tunning a cauple of times;;; and,,,l[5]l Your risk assessment assumed that: the PAH levels assmed thai: tinPAH levels remained constant over 30 years, Will they not likelydegrade before 30 years is up,,
5 .9 oooo.;.;;s
(1 ) Surface soil samp ling at the Amnicola Dump site Was conducted inaccordance with U.S. EPA Region IV Standard Operating Procedures.Sample ADO 14, collected in the area requiring remediation, wascollected from the top six inches of soil., PAHs were not introducedto greater depths during this sampling.
(2) Yes. It is likely that the PAHs of concern are in the top six totwelve inches, However, for the purposes of estimating volume ofsoil requiring cleanup, it was assumed that soil contaroi.nati.on abovethe cleanup goal existed at depths of up to two feet below groundsurface. Traffic from the salvage business on-site may have forcedthe PAHs to greater depths than would have occurred naturally. Thus,a two foot depth was assumed, Sampling in the area of concern willbe conducted during remedial design to get a more accurate verticaland... lateral, extent of contamination .
(3) This question is not understood. The concern over clay arosebecause of clay's impact on the feasibility and implement ability ofbio remediation. Bioremediation is most effective on sandy soils ..Bio remediation was eliminated from further consideration during thescreening of alternatives because of implementability andeffectiveness concerns in light of the other more effective treatmenttechnologies ..
(4) Yes. Bioremediation was also screened out because it was feltthat the large number of debris (scrap metal,, concrete,, bricks,, etc.)in the surface and subsurface soil would inhibit the implement abilityof this technology. Tilling of the soil would, require screening ofthe soil/debris mixture first .
(5) It is possible that the PAH compounds will degrade over 30years,. But there are no assurances that, if degradation isoccurring, it will, reduce the concentration of PAHs below the soilcleanup goal,. Natural degradation is not a treatment technology,
3, A request to re- rank the site was made,, It was felt that, giventhe results of the Remedial Investigation, the site would not receivea high enough score to be on the National Prior ities List (NPL)., Anadditional statement was made that the original factors used in themodel to rank the site were flawed and the model should be refiguredusing the correct data.,
To lit imply re-rank the site every tiime additional information .iiiigathered' on a ait* is neither the most ef £ iciant aae of Af eacyresources nor im it the appropriate Method for site deletion, ironNPL. It is irrelevant that the PAHs that are driving Elite cleanupwere not initially responsible for the site's placement on the NPL,
5 . 9 000057
An unacceptable level, of risk Is associated with the potential.ingest. ion of contaminated surface soil at the Amnicola Dump site;remediation of the defined area of concern is therefore justified andrequired.,
Ranking oil the site used information available at that time,, alongwith assumptions as to the landfill's potential content!:!. Someassumptions , in the absence of extensive technical informationgathered during a remedial investigation, are necessary to assess asite's potential risk to human health or the environment ., To haveassumed, during the ranking process, that the landfill did notcontain hazardous wastes (in light of reports of hazardous wastedisposal at the site and sample analyses of leachate streams), wouldhave been irresponsible. The absence of latex wastes at the site canbe explained as follows: (1) Either the reports concerning thedisposal of latex waste at the site were false and the leachatesample analyses that indicated latex constituents present were notrepresentative of site conditions, or (2) the latex wastes wereflushed from, the site and diluted in the Tennessee River belowdetectable quant iti.es .
4. A comment was made that the site poses no hazard to thepopulation. The following statements were used in an attempt toj u s t i f y t h I, s c 1 a im :
(1) Only one soil sample from the site showed contamination in excessof EPA guidance on acceptable levels ., Even that sample wasmarginally above acceptable limits. It was only by the assumption ofan unrealistic level of contact with FAHs at the site that action wasindicated under the "reasonable worst case" .
(2) The study assumed that the PAHs were composed of 100% of the mostdangerous of the PAHs, even though this substance comprised 20% orless of the total PAHs found on the site.
The site does pose an unacceptable level of risk to Bite workers,site visitors, and potential future site residents due to potentialIngestion of contaminated surface soils ,.
(1) True, only one sample, ADO 14, contained a total carcinogenic PAHconcentration above the .soil cleanup goal. However, every surfacesoil sample collected, with the exception of the control sample,contained PAHs; thereby indicating that sample ADO 14 isrepresentative of site conditions. It is irrelevant that theconciimtraLtioB of PAHs was only marginally above the cleanup goal .Whether tte soil riintaitinp goal" was liwiitMhiiwiliiid by only 23 ppm (am in -thecase at itonlcola Xhmp) or 'by 230CI ppiiii, raniiidlnitloB is stillrequired. The soil cleanup goals at the site ranged from 1,2 ppn to122 ppm. It is felt that 'the cleanup goal selected, 100 ppm, is
5 . 9 OOOG58
appropriate for the waste type and industrial setting of AmnicolaDump. An "unrealistic" level of contact, was not used. The publichealth evaluation followed standard Agency guidance, 'as outlined inthe Superfund Public Health Evaluation manual, in calculating siterisk.
(2) For PAHs, the approach adopted by EPA and used as the basis ofthe risk assessment is to divide the PAHs into two subclasses,carcinogenic and non-carcinogenic PAHs,, and to apply a cancer potencyfactor derived from oral bioassays on benzo(a)pyrene to the subclassof carcinogenic PAHs.. ABO 14 was comprised of 20% benzo(a)pyrene.Six other PAHs comprised the remaining 80%. Their carcinogenicpotency is considered to be less than benzo ( a ) pyrene but thisrelationship cannot be adequately quant it a ted with the limited dataavailable. Considering this uncertainty, it has been Agency policyto apply benzo (a)pyrene cancer potency values to PAH risk assessmentprocedures .
5 . A comment was made that there is inadequate evidence that therailroad ties are a source of the PAHs. The following statementswere used in an attempt to justify this claims
(1) There was no consideration of the concept that burning at thelandfill or the disposing of industrial material containing PAHs wasthe source .
(2) Burning of the type formerly conducted at the site, as well asindustrial and construction wastes such as tar paper, are sources ofPAH contamination.
(3) The fact that PAHs were found throughout the site and nocreosote was found, anywhere on the property should have causedfurther inquiry into their source. The EPA did not fully investigateto determine the source of these PAHs but erroneously madeas sumpt io ns re gardi n.g the ir source .
(1) This statement is not true. All waste disposal practices at theAmnicola Dump site were evaluated during the Remedial. Investigation.EPA is aware of the types of debris disposed at the dump as well asthe practice of burning and disposing of wood wastes during thedump's period of operation, 1970 to 1973. EPA is also aware of thetypes of operations conducted by Amnicola Equipment and MaterialsSales, the salvage operation currently located on the surface of thedump. Photographs and site visits indicated that creosoted railroadtiiiuiit were burned,, stored and handled on-sita. Burn spots wereobiiiaiirwiiitd,, photographed uiyd snplad.. This type of activity aiioflirtlikely resulted in PAH contamination of tlie surface soils. Woodwaste burning and disposal between 1970 and 1973 did result in thedeposit of ashes throughout, the site but in the interior of the dump.
5 . 9 OOOGS9
-6-
The surface soil samples that contained the PAHs were collected inthe top six to twelve inches, either on the bottom of the clay capthat once covered the site or on the surface of the dump. PAHs werealso detected in subsurface soil samples within the dump area. ThesePAHs could possibly be attributed to past wood burning practices orother types of disposal,, but subsurface PAHs axe not drivingremediation of the site. PAHs are often associated with creosote orcoal tar products. Thus,, the source of surface soil contamination byPAHs was attributed to the burning of creosoted railroad ties .
(2) See the above response,,
(3) The fact that PAHs were found throughout the site does notpreclude the railroad ties as a source. The observed traffic at thesite by the on- site operation has spread the PAHs from their burningand storage location to other areas of the site.
6. A comment was made that there is inadequate explanation of howthe Agency came up with the cost figures as many of the costs appearto be overestimated and undocumented .
The comment er is encouraged to review Section 5 of the FeasibilityStudy report, £ogt _AjialY§ii.» an(* Appendix B of the Feasibility StudyReport , Pj:;<[!!!j!iijjL!l!^ ., Al 1 o f theassumptions, general and specific., thai: went in to the calculation ofcosts for site remediation and 0 & M are provided in Appendix B.
I v .
The community's concerns surrounding the Amnicola Dump site should beaddressed through community relations support during the Remedial.Design/Remedial Action ( RD/RA) .
Community relations support during the RD/RA should consist of makingavailable final documents (i.e., Remedial Design Work Plan,, RemedialDesign Report , etc,.) in a timely manner to the public informationrepository and issuance of fact sheets upon selection of a remedy andprior to remedial action. The community should be aware that at anytime during the remedial design or remedial action,, if newinformation is obtained on site conditions, the remedy will bere-evaluated to determine its ef fectiveness in protecting publichealth and the environment. If changes are necessary to the Recordof Decision, these changes will be public noticed prior toimplementation of the changes .,
xvltttions activities stainliiil mmihin a:nt active ojiiipnc't of tlliteBD/IE1A phame of this project,.
5 ,,i 9 ooooco
APPENDIX A
q 0.00061
EQUATION FOR CALCULATINGRISK RELATED SOIL CLEANUP LEVELS
A, ' = absorption factor from oral exposre, (unitless)
I.. = intake by incidental oral ingestion of soil (kg/day)
A == absorption factor from dermal, exposure (unitless)
I_ =:: soil deposition on exposed skin (kg/day)
A. = absorption factor from respiratory exposure (unitless)
!„ == soil dust inhalation exposure (kg/day)
BW == body weigth (kg)
F = Frequency of exposure (days exposed/days lived (70-yrs.)
5 • 9 000062
Soil clean up levels for total carcinogenic PAHs consideringsoil ingestion exposures described in the PHE
Opp'er BoundrisR. level
ID'6
io-5
lo-"4 -
.-Adult practical5
100%
1 ,. 2
12.0
122.0
25%
4 , 9
49.0
490,. 0
Adult Worst Case
absorption level
100% 25%
0 . 2 0 , 8 4
2.0 8. 40
20. 0 84,00
Child Resident
100%
0,02
2.00
20.00
25%
0.87
8,70
87.00
5 . 9 OOOOG
APPENDIX B
OOOOC-'i• *» ATTACHMENT
GROUND-WATER DILUTION ESTIMATE AMD ACLs
Re f e r e n c e : ii!i]2jy:JLyX!!O EP A/ 5 4 0 / 1 - 8 8 / 0 0 1 ,.lJL!2.!!LJ£i!!y US GS & TN De p t .of Conservation, 1965.
1. Estimate ground -water discharge rate across front of landfill intoN i. c k a j a c k R e s e r v o i. r .
QsKiA where Q = ground-water discharge in cfd;K = a v e r a g e h yd r a u 1 it c c o n d u c t i v i. I: y o f u n c o n f i n e d a q u i. £ e r
in ft/d;i = hydraulic: gradient across site (dimensionless).
K = 13 qpd/sq. ft. = l.'?38 ft/d. (see RI 1 .i = (24.0 ft - 22,2 ft)/ 7 00 ft == 0. 00 2 5 7 [MW-3 to MW--5, 3-9 -88].A = 35 ft x 950 ft = 33,250 sq. ft.
2. Estimate flow in affected portion of Nick a jack Reservoir.
R e s e r v o i. r I: 1 o w r a t e = 1 2 0 0 c f s 1 1 o we s t me a n <:1 i. s c h a r g e , i n c f s , o f r e c o r d ] .Consider flow rat e through one-quarter of reservoir [see ACL guidanced o c ume n t , p ,. 6 - 3 , J u 1 y , i. 9 8 7 ] .
Q(reservoir) = 1200 cfs / 4 = 300 cfs.
'=!.. Estimate diluted concentration in one-quarter of cross-sectional flow: N i c k a :i a c k R e s e r v o i r .
C ==: [(Ce)(Qe)]/Qt where C - reservoir concentration (ppb);Ce = contaminant concentration in ground water
( ppb ) ,;Qe = (ground -water discharge (cfs);Qt = total flow (ground-water discharge plus
r e s e r v o i r :f! 1 o w ) i n c f s .
E q u a t i o n r e f e r e n c e ;; p . 5 3 , S u R e r i: u n d E x p> o s u r e_ As s^s^me_nt_Manual. .Dilution factor* == Qe/Qt == o7o6Tf2730oTo0172~^ ~5."7E-06 .The dilution factor multiplied by the contaminant concentration in (groundwater will result in the diluted concentration in one-quarter of thereservoir flow.
C ontaminant ______ _____ Ce_JjE£bj. C.....LE!JEl> 1 ACL_ jj:» j;> bj.Caprolactam 2 ITlE - 0 5 2 0D i e t h y 1 1 e t r a hyd r o f u t a n 3 0 1 ,. 1 B - 0 4 3 0 0C h 1 o r o f o r m 8 ,. 6 4 . 9 E - 0 5 8 6Br omod i eh 1 o r oirne thane 4 . 6 2 . 6E- 0 5 4 6Ethyl ether 5.0 2.9E-05 50Chromiim 89 5. IE-04 890lij.ii!!, c 2-ethylhexyl )phthalatc 370 2. IB-03 3700Bis C dime thylethyl imethylphenol 10 5 .TB-05 100
5 • 9
APPENDIX C
5 .9United States Department of the Interior
FISH AND W I L D L I F E SERVICEENDANGERED SPECIES FIELD OFFICE
100 OT11S STREET, ROOM 224ASHEVILLE, NORTH CAROLINA 28801
>L> A i *; ;;Break:Other:*•••......................
( (o . 1'
June 17, 1987
IN REPLY REFER TOLOG NO. 4-2-87-406
SRRB/RAS
JUN191987U li
Mr. Thomas M. RothRemedial Project ManagerEmergency and Remedial Response BranchU. S. Envi monumental Protection Agency345 Court!and Street.Atlanta, Georgia 30365
Dear Mr. Roth:
Your May 19, 1987, letter regarding the proposed remedial investigation ofthe Amnicola Dump hazardous waste site in Hamilton County, Tennessee, wasreceived May 28, 1987. We have reviewed the project as requested with regardto endangered and threatened species.
The attached page lists the federally listed endangered (E) and/orthreatened (T) and/or species proposed for listing as endangered (PE) orthreatened (PT) which may occur in the area of influence of this action,
The legal responsibilities of a Federal agency under Section 7 of theEndangered Species Act of 1973 (as amended!) were detailed in material sent toyou previously. If you would like another copy of this material, or if youhave questions, please contact us at 704/259-0321 (FTS 672-0321).
Your concern for endangered species is appreciated,, and we look forward toworking with you on endangered species matters in the future.
Sincerely yours,/
ty /(/£•;><:.,:.<:./
Henry "'V. Gary HenryActing Field Supervisor
CC:Mr. Bob Hatcher,, Tennessee Wildlife Resources Agency,, Nashville,, INMr. Dan Eager, Program Administrator, Ecological Services Division, Tennessee
Department of Conservation, 701 Broadway,'Nashville, TH 3/219Field Supervisor. ES. «„ Cookevl 1 He,, Till
5 -i 9 oooOG7Unileii States Department of the Interior
FISH AND W I L D L I F E SERVICEENDANGERED SPECIES FIELD OFFICE
100 OTIS STREET, ROOM 224ASHEVILLE, NORTH CAROLINA 2:8801
STAJJJS REVIEW SPECIES"Status Review'1 (SR) species are not legally protected under the EndangeredSpecies Act, and are not; subject, to any of its provisions,, includingSection 7, until they are formally proposed or listed asendangered/threatened. We are including these species in our response forthe purpose of giving you advance notification. These species may be listedin the future, at which time they w i l l be protected under the EndangeredSpecies Act. In the meantime, we would appreciate anything you might doto avoid impacting them.
II Lb
PLANTS
False foxg love - Aure.pJUria ]>atuj_aC arey' s sax i f r age~~:~SlxiTfIgTTafiy_ana
701 BROADWAY • »™v )••••» ,,:~~s r™, Up ' .»„.»., p.»,,,NASHVILLE. TENNESSEE 37203 f» '' '"' " '' r""' >' !j..iTj H t
615/742-6716 I ——ill!jy. JflN 021986 ' ''
,i..i,..»r""'•.. ;_i L!;;[>'
December 16, 1985
Jack E. RavenEnvironmental Protection Agency, Region IV Ari,,u,T.x, •;;.,..345 Courtland StreetAtlanta, Georgia 30365
Re: Intergovernmental Review , Amnicola Dump Site , Chattanooga ,Hamilton County, CH# 86 -.0477
Dear Mr. Raven:;
The above proposed undertaking has been reviewed with regard to NationalHistoric Preservation Act compliance by the participating federal agencyor its designated representative. Procedures for limp 'lenient ing Section 106of the Act are codified at 36 CFR 800 (44 FR 6068-6081, Jan. 30, 1979).,
Based on the Information available, it is our opinion that due to the location,,scope, and mature of the undertaking the project will have no effect on NationalRegister or eligible properties,, Therefore, unless project plans are changedor National Register eligible properties are discovered during project .f.implementation, no additional action is necessary to comply with the Act.
The applicant or federal agency should keep this letter as evidence of compliancewith' Section 106. Any questions or comments should be directed to Joe Garrison.Your cooperation is appreciated.,
Since rely,
Herbert L. Harper,,Executive Director andDeputy State Historic
