'FINAL SUMMARY REPORT OF TECHNICAL REVIEW ...i i i FINAL SUMMARY REPORT OF TECHNICAL REVIEW AND...

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FINAL SUMMARY REPORT OFTECHNICAL REVIEW AND EVALUATION

OF POTENTIAL PCB RELEASES

ANNISTON PCB SITEANNISTON, ALABAMA

MAY 2001

i U.S. EPA Work Assignment No.: 0-179Work Order No.: R1A00179

U.S. EPA Contract No.: 68-C99-223

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TABLE OF CONTENTS

EXECUTIVE SUMMARY iv

1.0 INTRODUCTION 11.1 Objective 11.2 General Information 11.3 Assumptions 11.4 Technical Approach 21.5 Report Organization 2

2.0 BACKGROUND 22.1 Location 22.2 Geologic and Hydrogeologic Settings 3

2.2.1 General 32.2.2 Solutia Property 3

2.3 Surface Water Drainage 42.4 Meteorology 5

3.0 OPERATION HISTORY, PCB CONTAMINATION, AND PAST CORRECTIVE MEASURES . 53.1 Manufacturing Facility 5

3.1.1 Operation History 53.1.2 Reported PCB Contamination 63.1.3 Past Corrective Measures 7

3.2 South Landfill 93.2.1 Operation History 93.2.2 Reported PCB Contamination 93.2.3 Past Corrective Measures 10

3.3 West End Landfill 113.3.1 Operation History 113.3.2 Reported PCB Contamination 113.3.3 Past Corrective Measures 12

4.0 MEDIA RELEASE ANALYSIS 134.1 Soil 134.2 Groundwater 144.3 Surface Water and Sediment 154.4 Air 15

5.0 CONCLUSIONS AND RECOMMENDATIONS 165.1 Conclusions 16

5.1.1 Soil 165.1.2 Groundwater 165.1.3 Surface Water and Sediment 165.1.4 Air 17

5.2 Recommendations 175.2.1 Manufacturing Facility 185.2.2 South Landfill 185.2.3 West End Landfill 18

6.0 REFERENCES 19

APPENDICES

A List of Available Pertinent Documents Reviewed

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LIST OF TABLES

Table 1 Outfall Location and Surface Water Sampling Results

Table 2 Description of Individual Cells at the South Landfill

Table 3 List of SWMUs and AOCs

Table 4 1999 RFI/CS Soil Samples Containing PCBs

Table 5 Detection of PCBs in Groundwater Samples

Table 6 Groundwater Detection Monitoring and Corrective Action Systems

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LIST OF FIGURES

Figure 1 Site Location Map

Figure 2 Site Plan Showing Locations of Select SWMUs, AOCs, WMAs and Groundwater CorrectiveAction Systems

• Figure 3 Stormwater Outfalls

g Figure 4 Soil Sampling and SWMU Locations

Figure 5 Existing Surface Types

• Figure 6 Site Plan Showing Existing Groundwater Well Network

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EXECUTIVE SUMMARY

Background Information

The United States Environmental Protection Agency (U.S. EPA) Region IV has requested the EnvironmentalResponse Team Center to utilize the Response Engineering and Analytical Contract (REAC) as a third party inconducting an independent evaluation of the Anniston PCB Site. The study objective is to assess the completenessof the investigative and remedial work performed to date and to evaluate the potential for on-going releases ofpolychlorinated biphenyls (PCBs) from the site through various environmental pathways. These pathways includesoil, groundwater, surface water and sediment, and air. REAC performed a site reconnaissance, reviewed availabletechnical reports and project files at the U.S. EPA Region IV and the Alabama Department of EnvironmentalManagement (ADEM) offices, and interviewed key project personnel to gather information for this evaluation.

The Anniston PCB Site is located west of the city of Anniston, Calhoun County, Alabama. It belonged toMonsanto Chemical Company (Monsanto) and has been owned by Solutia Inc. (Solatia) since 1997. The siteconsists of an active chemical manufacturing facility and two closed hazardous waste landfills: the South Landfilland the West End Landfill (Solutia property). In addition to many other inorganic and organic chemicals, aroclorand PCBs were manufactured from 1930 to 1971. Various waste streams generated from the manufacturingfacility were disposed of in the two landfills. The South Landfill consists of 10 unlined cells and was in operationfrom 1920s to 1989. The West End Landfill contains a single unlined cell and was active from 1930s to 1960.Process-related wastewater is treated at the on-site wastewater treatment plant (WWTP) prior to discharging tothe City of Anniston Publicly-Owned Treatment Works. Surface runoff generated from the Solutia property isconveyed to 12 outfalls, which are operated by Solutia and ultimately discharge into Snow Creek.

Reported PCB Contamination and Past Corrective Actions

Due to the limited capacity of the historical drainage structures in the area, runoff from the Coldwater Mountainflowed across the landfills and flooded the surrounding area with contaminated surface water. PCB-contaminatedsediments were found in and around drainage ditches, in outfalls, along the median of Highway 202, Snow Creek,and nearby residential properties. Corrective actions taken by Monsanto and Solutia in 1996 and 1997 includedcapping of the South Landfill, diversion of surface runoff, construction of the Upper Diversion Channel and theLower Detention Pond, installation of pipes, collection of surface runoff in the detention pond, and lining of thedrainage ditch along Highway 202 with concrete. The pipes at the manufacturing facility were also cleaned outand encapsulated. Several unused collection sewers that connected to a trunk main were sealed and the trunk mainwas lined.

After the West End Landfill was closed, it was sold to the Alabama Power Company in 1960. However. Monsantobought back the landfill after tar was found seeping from the landfill in December 1993. Subsequent subsurfaceinvestigations in 1994 found PCBs in surficial soil on the landfill and adjacent areas, in sediments along thedrainage ditches, and in groundwater (Well WEL-3). Monsanto then capped the landfill and upgraded thedrainage system at the West End Landfill in 1995.

Contaminated subsurface soil was found during the decommissioning of several chemical production areas in themanufacturing facility. Monsanto excavated the soil at various depths, then backfilled and covered the excavatedareas with asphalt, concrete, gravel, or root mats. Confirmatory sampling was not conducted prior to backfilling.The 1997 Resource Conservation and Recovery Act (RCRA) Facility Investigation/Confirmatory Sampling(RFI/CS) draft results show PCBs in subsurface soil samples collected from some of these excavated areas.

Currently, three groundwater monitoring detection and corrective action systems are in place: the South LandfillCorrective Action System, the Plant Corrective Action System, and the Old Limestone Bed Surface Impoundment(OLBS1) Corrective Action System. Solutia has been collecting groundwater samples for PCB analysis from thesethree systems since 1997. PCBs have been found in the following wells: OW-8A, OW-15, OW-16A, OW-21,OW-22, and OW-24 at the manufacturing facility. The RFI/CS draft results also found PCBs in two deep wellsthat are not part of the on-site groundwater corrective action systems: OWR-5D at the South Landfill and OWR-

7D at the West End Landfill. Extracted groundwater is routed to the on-site WWTP for biological treatment.

Solutia has been sampling ambient air around the perimeter of the manufacturing facility monthly. Analyticalresults show the detection of PCBs. No corrective actions have been required because formal action levels havenot been established for these air samples. The U.S. EPA Region IV also performed ambient air sampling in June2000 in the vicinity of the Solutia property and found PCBs.

Media Release Analysis

Soil

The current approach of isolating the contaminant source is appropriate for the two landfills because removal ofthe buried PCB waste has the potential to generate large amounts of contaminated dust, which could spread overa much larger area. The removal and transportation of PCB waste may present more of a potential for uncontrolledrisk to the community than would leaving the waste in-place under a capping system. However, some cells at theSouth Landfill and contaminated areas adjacent to the West End Landfill have been covered with soil andvegetative cover but without an impervious geosynthetic membrane. These soil and vegetative covers may erodein time, especially if the area is subject to surface water infiltration, flooding, and large volumes of surface waterrunoff. These areas include the area immediately adjacent to the West End Landfill, Cells 1E, 2E, 3E, 4E, 5E, and1W at the South Landfill, and the former catchment basins in the South Landfill.

The existing uppermost soil cover used as the 1998 South Landfill cap upgrade was constructed with native soilfrom a borrow pit located immediately adjacent to and cross-gradient from the South Landfill. According toSolutia, soil samples were collected for geotechnical analysis; however, they were not analyzed for PCBs.

The RFI/CS draft analytical data show that the surficial and subsurface soil in various solid waste managementunits (SWMUs) and areas of concern (AOCs) are contaminated with PCBs. Although surface stabilizationmeasures have been taken in many of these areas, contaminated soil was not completely removed, but was coveredwith either impervious or pervious covers, such as asphalt, concrete, root mat, and gravel. Root mat willdecompose in time and gravel layers contain significant amounts of void spaces. If the areas with pervious coversbecome flooded, contaminated soil particles may migrate via surface water runoff and become airborne afterdrying. These pervious covers do not provide adequate source isolation.

The RFI/CS Work Plan stated that only non-hazardous waste was stored in the Waste Drum Satellite AccumulationArea; however, the highest PCB concentration was detected in a soil sample from this area during the RFI/CS.This shows that previous usage of a SWMU may not be a good indicator of the potential and extent of any PCBcontamination. Using odor as a screening criteria is inadequate and inaccurate. The pervious covers should notbe considered as either an interim or a permanent remedial solution to the existing PCB contamination. The 17surficial and subsurface soil samples collected during the RFI/CS should not be considered as post-excavationconfirmatory samples because the number of samples collected are not representative of the excavated area. Post-excavation confirmatory samples are conventionally collected from each face of the excavation to confirm absenceof contamination prior to backfilling. In addition, no subsurface soil was collected from the area immediatelyadjacent to the West End Landfill.

According to the RCRA Facility Assessment (RFA) report, confirmatory sampling was required for theStormwater Drainage System (Production Area Portion, SWMU 37a), Scrap Yard Waste Oil SatelliteAccumulation Area (SWMU 17), Boiler Feed Tank (SWMU 25), Steam Cleaning Pad (SWMU 31), and ProductStorage Tank (AOC A). However, no surficial or subsurface soil samples were collected from these areas for PCBanalysis during the RFI/CS.

Groundwater

The RFI/CS draft report notes that filtered groundwater samples were collected for PCB analyses. It is not aconventional technique to filter groundwater samples for PCBs and to filter the samples twice using a 0.45- and

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0.1-micron size filter. Furthermore. ADEM does not accept results obtained from filtered samples.

PCB occurrence in groundwater does not appear to have a pattern, based on the locations of the monitoring wellswith PCB detection, and the frequency and level of detection. The RFI/CS draft report does not considergroundwater a pathway for PCB contamination. However, PCBs were detected in groundwater samples from wellOW-21 and OW-22, located north of the railroad tracks on a buy-out property. The detection of PCBs in thesewells may indicate that groundwater contamination has migrated off-site. The corrective action systems for theOLBSI and the South Landfill may not completely capture the groundwater leaving from the Solutia property.The relationship between groundwater flow from the Solutia property and the Jacksonville Fault, which passesjust north of the Solutia property and apparently is a recharge mechanism for Coldwater Spring, is unknown.Coldwater Spring is a major water supply source for Anniston and nearby areas. The effect on groundwater flowof a geologic "discontinuity" underlying the northern boundary of the manufacturing facility, and its relationshipto the Jacksonville Fault, is also poorly understood.

The existing wells in the OLBSI Corrective Action System may not be effectively monitoring the groundwaterquality of the West End Landfill because the wells are not positioned directly downgradient from the landfill. Inaddition, the wells in the West End Landfill are not sampled regularly. The limited amount of PCB data ingroundwater samples collected from the West End Landfill does not adequately define the extent of PCBcontamination in groundwater at the West End Landfill.

Surface Water and Sediment

Sediments in the portion of the drainage ditch located north of the South Landfill along Highway 202 have notbeen sampled since the ditch was concrete-lined. The Lower Detention Pond constructed for the collection ofstorm water runoff from the South Landfill also has not been sampled since its installation. No sediment samplingfor PCBs has been performed after Monsanto upgraded the drainage ditches at the West End Landfill.

Air

The RFI/CS draft report indicates that air was not considered a migration pathway because of the surfacestabilization measures taken at the manufacturing facility, which minimized the potential for airborne dust. Asmentioned above, pervious cover on contaminated soil is inadequate as a source isolation measure.

PCBs have been detected in ambient air samples collected around the manufacturing facility by Solutia and theU.S. EPA Region IV. No air samples have been collected from the two landfills.

Conclusion and Recommendations

Considering the volume of PCB waste disposed of at the South Landfill and the West End Landfill as well as theoperation duration of the two landfills, the amount of analytical data on PCB contamination in soil, groundwater,surface water and sediment, and air for the Solutia property appears to be somewhat limited.

Analytical data shows that PCB-contaminated soil remains in the manufacturing facility, despite the excavationof contaminated soil in many SWMUs and AOCs. The extent of PCB contamination in soil at the manufacturingfacility should be further investigated. Areas with PCB-contaminated soils that have been stabilized usingpervious cover should be subject to either hot-spot removal or covering with impervious material to permanentlyeliminate or completely isolate the source of contamination. To prevent erosion of the clay and vegetative cover,some cells and the former catchment basins at the South Landfill should be covered with a composite geosyntheticcap. An alternative is to diligently maintain the existing clay and vegetative cover at the South Landfill. Hot spotremoval could be a viable option to handle the PCB-contaminated subsurface soil (underneath the existingvegetative cover and general fill) in the adjacent areas surrounding the West End Landfill; otherwise, these areasshould be covered with a geosynthetic membrane. Due to the location of the borrow soil pit relative to that of thewaste in the South Landfill, it may be prudent to collect a representative number of samples from the uppermostsoil cover of the cap to ensure the absence of PCBs. Confirmatory sampling for PCBs should also be performed

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in some required SWMUs that were not done in the past. The vertical extent of PCB contamination in the areaadjacent to the West End Landfill requires delineation. Sediments in the drainage ditches, the sediment pond, andsilt-fenced areas in the West End Landfill should also be collected and analyzed for PCBs.

Groundwater does not appear to be a major pathway for PCB transport, however, PCB contamination has beenfound in two wells located on the buy-out property across the railroad tracks from the manufacturing facility. Inparticular, the shallow bedrock flow system and discharge locations for groundwater leaving the Solutia propertyare not well understood. The relationship of the hydrogeology at the Solutia property to the nearby JacksonvilleFault and Coldwater Spring is also unknown.

The mechanism of PCB releases from the manufacturing facility and the two landfills in the past was stormwaterrunoff. Prior to capping the two landfills and upgrading the drainage systems in the vicinity of the Solutia propertyas well as the limited capacities of drainage structures, runoff from Coldwater Mountain flowing across the twolandfills was in contact with the waste and flooded the surrounding area. After the flooded areas dry, PCB-contaminated particulates remained in the surficial soils and drainage ditches. Many corrective actions have beentaken by Monsanto and Solutia to control the migration of, and exposure to, PCB-contaminated materials, but theair pathway remains a major concern. PCB-contaminated particulates can become airborne easily and the nearbyresidents can be exposed to PCB-entrained particulates through inhalation; this can be considered an on-going PCBrelease. Although the drainage structures in the surrounding area have been upgraded, recent photographicdocumentation shows that some areas near the Solutia property are still subject to flooding.

To determine if PCBs are released to the air from the Solutia property, it will be necessary to conduct high-volumeambient air sampling at the two landfills and at the manufacturing facility. The sampling methodology to be usedis approved by the U.S. EPA for PCBs and the results can be compared with conventional regulatory action levels.However, this method cannot distinguish between airborne particulates or vapor. To determine whether thelandfills are emanating vapor, an air flux study on the landfills is recommended. Although there are no U.S. EPA-approved flux sampling methodology for PCBs, and no action levels have been established for comparison, theair flux study can, at least, determine the presence or absence of PCBs in any vapor emanating from the landfills.By performing both an ambient air sampling and air flux study, one can determine if the landfills are giving offPCB-containing vapor, as well as the concentrations of PCBs in the ambient air at and around the two landfillsand the manufacturing facility.

Based on the above evaluation, REAC recommends the following general site activities:

• Continue the operation of the groundwater corrective action systems;• Refine information on groundwater elevations and flow paths at and near the northern end of the Solutia

property. Because of logistical problems on the Solutia property, this would ideally involve installationof additional monitoring wells off-site to obtain the necessary spatial coverage;

• Verify groundwater elevations and apparent flow directions in the shallow bedrock by additionalgroundwater measurements in existing wells;

• Using both existing data and any new data developed after the release of the RFI/CS draft report,determine a probable range of groundwater travel times from the South Landfill to the northern edge ofthe Solutia property since the installation of the landfill; and

• Perform both ambient air sampling and an air flux study at the manufacturing facility and at each of thetwo landfills to determine whether the structure is giving off PCB-containing vapor and theconcentrations of PCBs in the ambient air around the Solutia property.

Additional recommendations for each individual component of the Solutia Property are listed below:

Manufacturing Facility

• Until a permanent remedial alternative is identified, cover the following areas with impervious materials,such as asphalt or concrete, to minimize the potential of PCB-contaminated particulates residing in void

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spaces and migrating off-site:- Former Parathion Area (SWMU 41);- Former Phosphorus Pentasulfide Production Area (SWMU 43);- Former Holding Tanks, Aeration Basins, and Clarifiers (SWMU 46);- Phosphate Landfill (SWMU 6);- Santotar® Pit (SWMU 7);- Phosphoric Acid Basins (SWMU 12);- Waste Drum Satellite Accumulation Area (SWMU 44);Collect surficial and subsurface soil samples in Stormwater Drainage System (Production Area Portion,SWMU 37a), Scrap Yard Waste Oil Satellite Accumulation Area (SWMU 17), Boiler Feed Tank(SWMU 25), Steam Cleaning Pad (SWMU 31), and Product Storage Tank (AOC A) for PCB analysissince confirmatory sampling is required for these areas;Delineate the horizontal and vertical extent of PCB-contaminated soil at the manufacturing facility todetermine the estimated volume of contaminated soil to be remediated; andInstall additional monitoring wells further north of wells OW-21 and OW-22 to determine if thegroundwater contamination has migrated further off-site to the north.

South Landfill

Cover Cells IE, 2E, 3E, 4E, 5E, and 1W and the former catchment basins at the South Landfill withgeosynthetic membrane to prevent erosion; otherwise, provide regular maintenance on vegetation cover;Collect a representative number of soil samples from the uppermost topsoil cover of the South Landfillfor PCB analysis to ensure the absence of PCBs in the topsoil cover;Remediate the concrete-lined drainage ditch along Highway 202 and subsequently perform sedimentsampling for PCBs on a regular basis to determine any on-going releases from the South Landfill aftercapping; andCollect sediment samples from the Lower Detention Pond to determine if the South Landfill is an on-going source of PCB release since the landfill was capped.

West End Landfill

Remove PCB-contaminated subsurface soil (underneath the existing vegetative cover and general fill)in the adjacent areas surrounding the West End Landfill to eliminate the contamination and to preventcontaminated soil from becoming mobile; otherwise, cover the adjacent areas with geosyntheticmembrane;Install monitoring wells along the northwestern perimeter of the Solutia property to monitor thedowngradient area of the West End Landfill;Further assess the extent of groundwater contamination in the deep residuum because the only deep wellinstalled in the West End Landfill, OWR-7D and in the South Landfill, OWR-5D, contained PCBs;Include the five monitoring wells in the West End Landfill in the semi-annual groundwater detectionmonitoring and corrective action program to collect PCB in groundwater data on the West End Landfill.

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1.0 INTRODUCTION

1.1 Objective

The purpose of this Work Assignment is to provide technical assistance to the United States EnvironmentalProtection Agency (U.S. EPA)/Environmental Response Team Center (ERTC) in conducting an independentevaluation for the Anniston PCB Site. The objective of the evaluation is to assess the completeness of theinvestigative and remedial work performed to date and to evaluate the potential for on-going releases ofpolychlorinated biphenyls (PCBs) from the Anniston PCB Site. This evaluation includes a review of availabletechnical reports and project files and interviews with key project personnel. Various environmental pathways,including soil, groundwater, surface water and sediment, and air, were considered in this evaluation.

1.2 General Information

The Anniston PCB Site is located west of the City of Anniston, Alabama. It is comprised of an active chemicalmanufacturing facility and two nearby closed hazardous waste landfills: the South Landfill and the West EndLandfill. The site was formerly owned by Monsanto Chemical Company (Monsanto). In 1997, Monsantoseparated its chemical division from the rest of the company and the site has since been owned by Solutia Inc.(Solutia). Chemicals have been produced at the facility since 1917. Aroclor and PCBs were manufactured fromthe 1920s to 1970. Various types of waste generated by the manufacturing facility were disposed of in the twohazardous waste landfills. These two landfills have been closed, but the local residents consider them to be pastand on-going sources of PCB contamination. The U.S. EPA Region IV and the Alabama Department ofEnvironmental Management (ADEM) believe that these landfills were major sources of past PCB releases;however, the question of on-going PCB releases is currently under investigation by ADEM through their ResourceConservation and Recovery Act (RCRA) Program.

As part of its oversight of the ADEM RCRA Program, the U.S. EPA Region IV RCRA and ComprehensiveEnvironmental Response and Compensation Liability Act (CERCLA) Programs determined that it was necessaryto further evaluate the effectiveness of previous PCB removal and containment activities at the site. At a meetingwith community leaders on August 21, 2000, the U.S. EPA Region IV agreed to perform an independentevaluation to determine if the manufacturing facility and the two closed landfills are on-going sources of PCBcontamination. The U.S. EPA Region IV has requested the ERTC to utilize the Response Engineering andAnalytical Contract (REAC) as a third party in conducting the independent evaluation of the work performed bythe U.S. EPA Region IV, ADEM, and Solutia (U.S. EPA, 2000b).

1.3 Assumptions

The following assumptions were made in this independent evaluation:

• The areas evaluated include the manufacturing facility, the South Landfill, and the West End Landfill.Its entirety is referred to as the Solutia property in this report. Properties that were previously residentialand have been purchased by Solutia are not within the scope of work and were excluded from theevaluation. Investigative and remedial work activities performed outside the Solutia property were alsonot considered.

• Information contained in work plans submitted by Monsanto and Solutia was reviewed, but proposedwork activities were not considered to be actual work.

• Although there have been other contaminants detected at the Solutia property, REAC was tasked toevaluate only the potential for PCB releases through various environmental pathways. Evaluation of riskassessments was also not included in this study.

• REAC interviewed available key project personnel and reviewed project files that were made availableby the U.S. EPA Region IV and ADEM. REAC does not guarantee the completeness and accuracy ofthe information contained in documents prepared by other parties or given by the interviewees.

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• Because the Solutia property was previously owned by Monsanto and is now Solutia, both names arereferenced in this report to reflect the ownership of the site at the time of the event.

• Because ADEM does not accept the practice of filtering groundwater samples for PCB analysis, onlyunfiltered groundwater sample results were considered in this independent evaluation.

1.4 Technical Approach

The following tasks were completed from October 2000 to February 2001 to gather information for theindependent evaluation:

• A vehicular reconnaissance and/or walk-through of the exterior of the manufacturing facility, the SouthLandfill, and the West End Landfill;

• A review and evaluation of project documents that were made available to REAC at the U. S. EPARegion IV office in Atlanta, Georgia, and the ADEM office in Montgomery, Alabama.

• A review and evaluation of the public documents in the local government repository at the AnnistonPublic Library in Anniston, Alabama;

• A review and evaluation of correspondence from the community at the U.S. EPA CommunityRelationship Center in Anniston, Alabama; and

• An interview of available key project personnel from the U.S. EPA Region IV, ADEM, and Solutia.

1.5 Report Organization

This report summarizes the work performed to date for the Solutia property on the basis of the informationgathered. It also documents REAC's evaluation and conclusions regarding the completeness of the work and thepotential for on-going PCB releases. Section 1.0 of this report introduces the objective of the project as well asthe technical assumptions and approaches used. Background environmental information on the Solutia propertyis provided in Section 2.0. Section 3.0 contains the operation history, reported PCB contamination, and pastcorrective measures taken on each of the three components of the Solutia property. Section 4.0 presents REAC'sevaluation of the potential for on-going PCB releases via the soil, groundwater, surface water and sediment, andair (vapor and paniculate) pathways. Conclusions of the independent evaluation and recommendations foradditional work activities are provided in Section 5.0. Section 6.0 lists the references used in this report. Severalfigures presented in this report were adapted from previous technical reports prepared for Monsanto and Solutia.Appendix A is a list of pertinent documents available and reviewed for this evaluation.

2.0 BACKGROUND

2.1 Location .

The Solutia property is located at 700 Clydesdale Avenue (formerly 300 Birmingham Highway), Anniston,Calhoun County, Alabama (Figure 1). The site is comprised of four tracts of land and occupies 530 acres (U.S.EPA, 1991). The Solutia property consists of three main components: an active chemical manufacturing facilityand two closed hazardous waste landfills: the South Landfill and the West End Landfill (Figure 2). Land use inthe vicinity of the Solutia property is mainly residential with some industrial and commercial establishments.Private residential houses and some commercial businesses and industrial facilities are located to the north, east,and west of the manufacturing facility. Historically, numerous foundries were located in and around the City ofAnniston. The chemical manufacturing facility occupies approximately 70 acres of land. It is bounded on thesouth by Highway 202 (formerly Birmingham Highway), on the east by Clydesdale Avenue, on the west by FirstAvenue, and on the north by the Norfolk Southern and Erie Railroads. The South Landfill sits at the lowernorthwestern slope of Coldwater Mountain, across Highway 202 from the manufacturing facility. It occupiesapproximately 45 acres of land and consists of 10 cells. Except for some residential homes immediately to thewest of the landfill and Highway 202 to the north, the South Landfill is surrounded by undeveloped land to thesouth and east. (Properties to the east were under development for residential use at the time of the site visit.) TheWest End Landfill adjoins the manufacturing facility to the west and is situated along the northern toe of

Coldwater Mountain. The landfill was constructed as a single cell and occupies approximately six acres of land(25 acres including the surrounding undeveloped land). A substation and a regional switching station, both ownedby the Alabama Power Company, are located at the southern end of the landfill. Approximately 75 percent of thelandfill is occupied by high voltage power lines (Colder Associates, 1999).

2.2 Geologic and Hydrogeologic Settings

2.2.1 General

Anniston is located near the eastern edge of the Valley and Ridge physiographic province, which is characterizedby northeast-southwest trending valleys and ridges. Valley floors range from an altitude of 500 to 900 feet abovemean sea level (msl) and are generally underlain by carbonate rocks. The ridges range from 1,000 to 2,100 feetabove msl and are usually underlain by more resistant sandstone or quartzite units (Colder Associates, 1999).Rocks of the area are extensively folded and faulted, producing complex geologic structures. Locally, theAnniston area is underlain by sedimentary and weakly metamorphosed rocks of Paleozoic age consisting of avariety of lithologies, including shale, sandstone, siltstone, carbonates (limestones and dolomites), and quartzites.

Groundwater yields in the carbonates rocks are generally sufficient for both domestic and commercial use.However, yields in other rock types may only be sufficient for domestic use. Anniston and several other areas inCalhoun County obtain their water supply from Coldwater Spring, located approximately five miles southwestof Anniston. The spring discharge, approximately 31.2 million gallons per day, is one of the largest in Alabama(Scott et al., 1987). The high flow rate is apparently closely related to the location of the Jacksonville Fault, amajor regional thrust fault, that extends from Coldwater Spring northeast through Anniston to northeasternCalhoun County. Movement on the fault has placed older rocks of the Chilhowee Group and Shady DolomiteFormation against younger, normally overlying, carbonates, thus hydraulically connecting a number of rock units.The minimum recharge area for the spring, as mapped by Scott et al. (1987), includes the Anniston area and thenorthern slope of Coldwater Mountain. The manufacturing facility of the Solutia property lies just within thisminimum recharge area, but the relationship of groundwater discharge from the Solutia property, particularly inthe bedrock, to the fault recharge area is unknown.

2.2.2 Solutia Property

The area of investigation is immediately underlain by a residuum, approximately 100-foot thick, composed of siltyto sandy clay, probably derived from the underlying Shady Dolomite Formation. The Shady Dolomite Formationis a major groundwater source throughout most of Calhoun County. The 1999 RF1/CS draft report indicates that,based upon the weathering profile, the residuum has been divided into a shallow unit (surface to 45 feet belowground surface [bgs]) and a deeper unit (45 feet bgs to the top of weathered bedrock) (Golder Associates, 1999).The shallow unit of the residuum comprises the water-table aquifer, in which groundwater below themanufacturing facility flows generally north, reflecting the slope of the local topography. In the northeasternportion of the manufacturing facility, groundwater appears to have a northeasterly flow component. In the vicinityof the West End Landfill, shallow groundwater flows to the northwest. Portions of the groundwater regime arealtered by the corrective action systems as discussed in Section3.0.

The average hydraulic conductivity of both the shallow and deep residuum is estimated to be approximately 8 x10 "2 feet per day based on aquifer pumping and slug tests. Horizontal groundwater flow in the shallow residuum,determined from the average hydraulic conductivity and groundwater gradients, varies from approximately 44 feetper year (ft/yr) at the South Landfill to 4 ft/yr across flatter portions of the manufacturing facility. Groundwaterlevels, as measured in monitoring wells, indicate a downward vertical gradient between the shallow and deepresiduum and between the residuum and the underlying Shady Dolomite Formation. Because hydraulicconductivities are highest in the horizontal direction, most groundwater flow off-site is probably horizontal.However, the downward vertical gradient implies the potential for migration of groundwater from shallow todeeper zones.

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The 1999 RFI/CS draft report identifies a geologic "discontinuity" underlying the area just north of themanufacturing facility (Colder Associates, 1999). The discontinuity is characterized by a residuum that is at least540-foot thick, the depth of the deepest borehole penetrating this unusually thick weathered section. Althoughoriginally thought to be a sinkhole, the feature is more likely a fault. Laminated weathered shale lenses, ratherthan carbonate rocks, were found in boreholes penetrating the section. Geologic cross-sections in the 1999 RFI/CSdraft report assigns the shale to the Rome Formation, which has apparently been juxtaposed against the youngerShady Dolomite Formation beneath the northern side of the manufacturing facility (Colder Associates, 1999).The 1999 RFI/CS draft report also indicates that slickenslides were observed during the boring investigation atthe Solutia property, although no specific locations are given (Colder Associates, 1999). Slickenslides areindicative of rock movement.

The discontinuity appears to be a barrier to northerly groundwater flow in the shallow bedrock and possibly thelower portion of the overlying deep residuum. Limited water level data from bedrock monitoring wells indicatethat water levels in the bedrock next to the discontinuity are higher than levels in the bedrock underlying thesouthern portion of the Solutia property. The difference in water levels and relatively low permeability of thediscontinuity suggest that little groundwater flows across the structure. Moreover, Cross section A-A' in the 1999RFI\CS Draft Report indicates that groundwater in the shallow bedrock may flow south, toward ColdwaterMountain, although the gradient is relatively flat. This conclusion is based on limited data because groundwaterlevel maps for the shallow bedrock have not been developed. However, Cross Section A-A depicts a steepnortherly dipping contact between the Shady Dolomite Formation and the Weisner Formation, a quartziticsandstone underlying the northern slope of Coldwater Mountain. The contact may be a bedrock groundwater flowpath, carrying relatively shallow groundwater to deeper portions of the bedrock. Data are not sufficient todetermine the specific relationship of groundwater flow at the Solutia property to the recharge area of theJackonsville Fault.

2.3 Surface Water Drainage

The ditches around the manufacturing facility drain towards Snow Creek. This creek eventually merges intoChoccolocco Creek and joins Lake Logan Martin on the Coosa River. The Solutia property is not located withinthe 100 year floodplain (Colder Associates, 1999). Eleven stormwater outfalls and one on-site storm waterdischarge point are operated by Solutia (Figure 3). Table 1 lists the location, receiving area, and discharge pointof these 12 outfalls. All stormwater from each of the 12 outfalls eventually discharges into Snow Creek via adischarge structure on West 10th Street.

Prior to the construction of Highway 202 approximately 20 years ago, surface water runoff from the South Landfillflowed north across Birmingham Highway (which was part of the existing Highway 202) via three points towardClydesdale Avenue and 6th Street. A 24-inch diameter culvert carried flow beneath 8th Street by the Mars HillMissionary Baptist Church. Because of the limited capacity of the culvert, flooding often occurred in the vicinityof the Solutia property. During the active phase of Cells 4E and 5E in the South Landfill, two surface watercatchment basins, located immediately downgradient of Cells 2 W, 4E, and 5E, collected stormwater runoff behindearthen dams at the base of the South Landfill (Monsanto, 1996). Monsanto covered the catchment basins witha layer of clay and vegetation when the landfill was closed. In addition, corrective measures were subsequentlytaken by Solutia in 1997. Sediment in the ditches along the portion of Highway 202 located north of the SouthLandfill was excavated and the ditches were lined with concrete. Stormwater from this portion of Highway 202is conveyed to the Lower Detention Pond in a 36-inch pipe. An earth berm, the Upper Division Channel, wasconstructed along the southeastern perimeter of the South Landfill to divert surface water runoff from the landfill.The runoff is collected behind the berm and conveyed to the Lower Detention Pond through a network of pipesand outfalls.

Historically, an unlined drainage ditch from Coldwater Mountain intersected an unlined ditch located downslopefrom the West End Landfill, along its southern, western, and northern perimeters. Stormwater runoff fromColdwater Mountain also flowed across the West End Landfill. The limited capacity of the culvert causedflooding in the area. Because PCB-contaminated sediments were found in the drainage ditches, Solutia

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reconfigured the ditches on the West End Landfill. Stormwater is now collected on the northern side of the railroadtracks in a 42-inch diameter pipe and conveyed to an existing culvert on West 10th Street.

Many surface water drainage structures in the vicinity of the Solutia property have been upgraded since 1997;However, based on a review of photographic documentation collected by the U. S. EPA Region IV personnel inAugust 2000, flooding still occurs in the area around the manufacturing facility. According to U.S. EPA RegionIV personnel, the ditches in the area require frequent clean-out after rainfall events.

An anecdotal drainage map shown by the U.S. EPA Region IV personnel indicates that a number of springsdischarged at or near the northern slope of Coldwater Mountain. Some of the discharge may have been interceptedor redirected by the construction of the South Landfill and West End Landfill. The discharge from one springappeared to flow northward through the present location of the West End Landfill. The construction of the WestEnd Landfill now precludes any surface water flow through the area, but the presence of, or possibility for, re-establishment of subsurface flow is unknown.

2.4 Meteorology

The climate of the Anniston area is characterized by long, moderately hot summers and mild winters. The averagesummer and winter temperature is 78.9 and 44.9 degrees in Fahrenheit, respectively. The average annualprecipitation is approximately 54 inches with March being the wettest month and October the driest (ColderAssociates, 1999). According to Solutia and U.S. EPA Region IV personnel, the Anniston area has beenexperiencing a drought condition for the past 1.5 years. The prevailing wind direction is to the east-northeastapproximately 30 percent of the year and to the west-southwest approximately 15 percent of the year. The averagewind speed ranges from 11 to 16 miles per hour (Colder Associates, 1999).

3.0 OPERATION HISTORY, PCB CONTAMINATION, AND PAST CORRECTIVE MEASURES

The following sections briefly summarize the operation history, the previous investigations performed in each ofthe three components of the Solutia property, the detection of PCB contamination in various environmental media,and previous corrective measures taken to mitigate the contamination.

3.1 Manufacturing Facility

3.1.1 Operation History

At the turn of the century, iron ore was mined in and around the manufacturing facility. Operations at themanufacturing facility began in 1917 with the formation of the Southern Manganese Corporation. The companyinitially manufactured ferro-manganese, ferro-silicon, and ferro-phosphorus, and later phosphoric acid. In 1927,the corporation began producing a variety of inorganic and organic chemicals, such as aroclor and phosphoric acid.In 1930, Southern Manganese become Swarm Chemical Company and in 1935, the Phosphate Division ofMonsanto purchased the Swann Chemical Company. The manufacturing facility served as the divisionheadquarters until 1954, when it was transferred to the Organic Division. Parathion and methyl parathionoperations began in 1954 and the production of PCBs was started in 1960. Paranitrophenol (PNP) was thenmanufactured five years later. In 1971, the production of aroclor ceased and the PCB production unit wasdemolished in 1972. In the early 1970s, the Solutia property was transferred to the Monsanto Agricultural ProductsCompany. Production of parathion was halted in June 1986 and the Solutia property was subsequently transferredto the Monsanto Chemical Company. In 1997, Monsanto separated its chemical division and the Solutia propertyhas been operated by Solutia. PNP and polyphenyls are being produced now (U.S. EPA, 1991).All process-related water generated at the manufacturing facility is diverted to the on-site wastewater treatmentplant (WWTP) for treatment prior to discharging to the City of Anniston Publicly-Owned Treatment Works(POTW). The on-site WWTP was constructed in 1961 to biologically treat corrosive wastewater derived frommanufacturing processes and laboratory tests. The capacity of the WWTP was expanded twice in the 1970s tohandle increased wastewater flows. However, the capacity was decreased after the production of parathion ceased

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in 1986 and the wastewater flows was reduced. Until 1988, the WWTP received discharges from the Old and NewLimestone Bed Surface Impoundments, which were used to neutralize incoming wastewater. A lagoon was alsooperated as a surge basin in the mid 1960s until it was replaced by an additional holding tank. This former lagoonarea was then used for the New Limestone Bed Surface Impoundment. The manufacturing facility also operatedtwo phosphoric acid basins, which were designed to neutralize corrosive wastewater prior to direct dischargethrough Outfall DSN 001 located on Clydesdale Avenue. Although one of the basins was backfilled, the otheris still being used for neutralization. Facility wastewater is currently transferred from the production areas to theWWTP mostly in overhead piping and some underground piping. The manufacturing facility formerly had sixpermitted outfalls (DNS 001 through DSN 006). Some of the outfalls have been taken out of service, but theactive outfalls are monitored for pH, chemical oxygen demand, biological oxygen demand, total suspended solids,parathion, PNP, and total phosphate. Biological sludges generated from the WWTP during 1960 to 1983 weredisposed of in the South Landfill. Since then, the sludge has been transported for off-site disposal at a localsanitary landfill (U.S. EPA, 1991). Currently, extracted groundwater from interceptor wells of the three on-sitegroundwater corrective action systems is piped to the WWTP for biological treatment.

3.1.2 Reported PCB Contam ination

Monsanto conducted a hydrogeologic investigation in the vicinity of Waste Management Area (WMA) II, locatedin the northwestern portion of the manufacturing facility, in September and October 1981 (Colder Associates,1997). WMA II consists of the New Limestone Bed Surface Impoundment, storage areas, and a sump. Fourborings were installed, three of which were converted into monitoring wells. Additional monitoring wells weresubsequently installed in WMA II in October and November 1985 and June 1986. Analysis of PCBs was notdocumented in any of these sampling events. In 1997, Solutia was required to monitor PCBs in the site-widegroundwater detection monitoring and corrective action programs. Soil, groundwater, and outfall samples werealso collected for PCB analysis during the 1999 RF1/CS event.

In 1991, a RCRA Facility Assessment (RFA) of the Solutia property was conducted by a U.S. EPA contractor.The assessment identified 46 solid waste management units (SWMUs) and three Areas of Concern (AOCs).Figure 2 shows the locations of the various SWMUs and AOCs and Table 2 describes the location of the SWMUsand AOCs.

Soil

Draft analytical results for the RFI/CS show detection of PCBs in surficial and subsurface soil samples collectedfrom various SWMUs and AOCs, including previously decommissioned chemical production areas, at themanufacturing facility. Table 4 presents the soil sampling location and depth, sample number, and reported PCBconcentration. The highest PCB concentration (estimated at 16,620 milligram per kilogram [mg/kg]) was foundin a soil sample collected at 3 to 6 inches below the gravel surface in the Waste Drum Satellite Accumulation Area.

Groundwater

Analytical results for groundwater samples collected from monitoring wells installed in the manufacturing facilityduring 1997 to 2000 show detection of PCBs in the following wells: OW-8A, OW-15, OW-16A, O W-21, OW-22,and OW-24. Table 5 presents the sampling date, well location, and detected PCB concentrations.


Enforcement records indicate that PCBs were discharged from the manufacturing facility into Snow Creek priorto the enforcement of RCRA Program. Analytical results of sediment samples collected from nine drainage areasaround the manufacturing facility on February 6, 1995 by Monsanto reveal the presence of PCBs. Theconcentration ranges from none detected to 990 parts per million. The highest concentration was found in an arealocated 500 feet south of Outfalls DSN 009, DSN 010, and DSN 011 (Monsanto, 1995).

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ilOn April 5, 1995, Monsanto entered into a Consent Order with ADEM to sample sediment in the stormwaterdrainage system outside the immediate areas of the manufacturing facility. Sediment sampling results detectedPCBs in the samples collected from and around the drainage ditches in areas east and north of the manufacturingfacility. On March 8, 1996, Monsanto entered into another Consent Order with ADEM to identify and sampleadditional areas for PCBs and to continue relocating residents east of the manufacturing facility.

Air

Based on a review of various correspondence files at ADEM, odor problems associated with the on-site WWTPwere reported by nearby residents from 1972 to 1985. After several inspections were performed by the ADEMrepresentatives, it was determined that the odor was caused by the presence of excessive waste material and thelack of oxygen in the wastewater, which resulted in bacteria die-off and foul-smelling emission.

Monthly ambient air sampling around the perimeter of the manufacturing facility shows the detection of PCBs atconcentrations ranging from 0.21 to 7.74 microgram per cubic meter (ug/m3) in the July 2000 monitoring eventand 0.57 to 3.69 ug/m3 in the August 2000 monitoring event. The highest detection in both events was found insamples collected from the vacant buy-out property located north of the railroad track (Sample No. Site 4-North).

3.1.3 Past Corrective Measures

Soil

Soil corrective measures were implemented at many S WMUs and AOCs in the manufacturing facility after certainchemical production activities ceased. The following summarizes the decommissioning activities in these areas.Figure 2 shows the locations of the SWMUs described below and Figure 5 shows the existing surface type of theSolutia property:

• Former Phosphate Landfill (SWMU 6): no information is available on the closure of this unit, but it wascovered with gravel.

• Santotar® Pit (SWMU 7): the area was excavated, then backfilled and covered with gravel. Excavatedmaterials were placed in the South Landfill.

• Old Limestone Bed (SWMU 8): the area was closed in 1982 and six interceptor wells were installed aspart of the Old Limestone Bed Surface impoundment (OLBSI) Corrective Action System in 1988. Thewells are used to intercept and recover groundwater from the New and Old Limestone Bed SurfaceImpoundments.

• Lagoon (SWMU 9): the lagoon sludge and liner were excavated and placed in the South Landfill in themid 1970s. The New Limestone Bed Surface Impoundment was constructed in this area in 1977.

• New Limestone Bed Surface Impoundment (SWMU 11): the area was closed as a landfill in 1988.Contaminated soil was excavated from the New Limestone Bed and the storage areas. A groundwaterrecovery program was implemented to reduce orthophosphate and PNP in groundwater.

• Phosphoric Acid Basins (SWMU 12): contaminated soils were excavated in the South Basin to a depthof approximately 10 to 12 feet bgs and disposed of in Cell 5E at the South Landfill. It was thenbackfilled with clean clay. The North Basin was closed in-place and the limestone bed materials from3 to 10 feet bgs were also left in-place.

• Boiler Feed Tank (SWMU 25): the leaking flange connection was repaired and the tank was dismantledin 1995. The area was covered with gravel.

• Santotar Tank (SWMU 27): the area surrounding the tank was covered with gravel.• Steam Cleaning Pad (SWMU 31): the ground surface was covered with gravel.• Old Boiler Scrap Yard (SWMU 34): the ground surface was covered with gravel.• Former Parathion Production Area (SWMU 41): in 1986, contaminated soils were excavated and

removed to a depth of 20 feet bgs. Excavated area was backfilled and covered with gravel. Structureswere dismantled and disposed of in Cell 5E at the South Landfill.

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• Former PCB Production Area (SWMU42): the production facility was dismantled in 1972 and disposedof in the South Landfill; however, the concrete floor was left in-place. The area, including the concretefloor, was covered with asphalt in the mid 1980s.

• Former Phosphorus Pentasulfide Production Area (S WMU 43): the production area was decommissionedin 1988. The production facility and equipment were decommissioned and disposed of in the SouthLandfill. The existing concrete slab was left in-place and other areas were covered with gravel.

• Waste Drum Satellite Accumulation Area (SWMU 44): the unit was closed and a concrete slab was leftin-place.

• Former Holding Tanks, Aeration Basins, and Clarifiers (SWMU 46): the units were cleaned, demolished,and left in-place. The area was covered with gravel.

• Production Storage Tank (AOC A): stained gravels were removed and a concrete floor was added in thecontainment structure. The secondary level control circuitry on the tank was upgraded.

• Underground Storage Tanks (AOC C): three underground storage tanks of unknown condition wereremoved in the mid 1980s.

There is no documentation of the screening method and criteria used to determine the extent of contaminated soilexcavated during the decommissioning of the SWMUs and AOCs. However, the 1997 RFI/CS Work Plan statedthat soil odor was used as a screening consideration and the absence of odor in soil was an indication ofuncontaminated soil (Solutia, 1997).

Groundwater

Two groundwater corrective action systems are installed at the manufacturing facility: the Plant Site GroundwaterExtraction System and the OLBSI Corrective Action System. The Plant Site Groundwater Extraction System wasinstalled and in operation since 1988 and is comprised of a shallow interceptor well, IW-14, and three observationwells, OW-6, OW-8A, and OW-16A. The OLBSI Corrective Action System consists of six shallow interceptorwells (IW-16, IW-17, IW-18, IW-19, IW-20, and IW-21), one deep interceptor well (DW-1), four point ofcompliance wells (MW-1B [also serves a background well], MW-15, MW-16A, and MW-20A), and 10observation wells (MW-8, MW-9, MW-15, MW-16A, MW-20A, OW-19,0W-21, OW-22, OW-24, and SBP-5).Except for well DW-1, which was installed in 1997, the remaining wells were installed in 1988. Prior to 1997,groundwater samples collected from these corrective action systems were not analyzed for PCBs. Since 1997,PCB analysis has been done semi-annually. PCBs have been detected in groundwater samples collected fromwells OW-8A, OW-15, OW-16A, OW-24, and two off-site wells, OW-21 and OW-22. The highest PCBconcentration detected in well samples collected from the manufacturing facility is 600 microgram per liter (ug/L),which was from well OW-8A. Groundwater from the corrective action systems is routed to the WWTP at themanufacturing facility before being discharged to the local POTW (Colder Associates, 1999). Figure 6 shows thelocations of the monitoring wells for these two groundwater corrective action systems. Table 6 presents theinstallation dates, the monitoring area, and the interceptor and observation wells installed under these correctivesystems.


As part of the upgrade work for the surface water drainage structure in the manufacturing facility, the pipes werecleaned out and then encapsulated in 1997. Solutia sealed several unused collection sewers that connected to atrunk main, which discharged to Outfall DSN 001. The trunk main was also lined with an epoxy resinimpregnated felt liner (Golder Associates, 1999).

Air

• Currently, there is no formal PCB cleanup action level developed for Solutia's ambient air samples and no* corrective actions are required. Under ADEM and U.S. EPA oversight, the air release pathway is currently under

further investigation by Solutia. ADEM requested that Solutia perform an air flux study and Solutia submitted aI work plan in March 2000. Comments from the U. S. EPA were issued and Solutia submitted responses to the

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comments in April 2000 (U.S. EPA, 2000c).

3.2 South Landfill


The South Landfill was in operation from the 1920s to 1989. It consists of 10 cells and is divided into twoportions: the southwestern and southeastern portions. The southwestern portion has five closed waste disposalunits (Cells 1W, 2W, 2WA, 3W, and 4W). The southeastern portion includes three closed waste disposal units(Cells 1E, 2E, and 3E) and a closed, permitted RCRA cell, WMAI (Cells 4E and 5E). With the exception of Cell5E, which was lined with compacted clay and crushed sandstone, the remaining cells were constructed on naturalclay. The landfill received general plant refuse, construction debris from the demolition of various buildings andstructures, laboratory wastes, and processing wastes. The waste was collected in dumpsters then hauled to thelandfill for disposal. Waste material was disposed of in a cell and then covered with a six-inch thick layer of clay.A clay cap of unknown thickness and a vegetative cover were applied when a cell was closed. A leachatecollection system was installed on the downward slope of the South Landfill in 1980. The leachate collected inthe french drains flows by gravity through a pipe network into the on-site WWTP. While the WMA-I was cappedwith a RCRA-compliant cap in 1989, the remaining cells were capped prior to the enforcement of RCRA in 1976.

Based on the information presented in the 1991 RFA Report, Cells I E, 2E, and 3E were covered with an unknownthickness of clay and vegetative cover and Cell 1W was covered with geotextile, 12 inches of compacted fill, andvegetative cover. Cells 4E and 5E were covered with 24 inches of compacted clay, 12 inches of sand, geotextilefabric, 24 inches of topsoil, and vegetative cover. The March 1998 South Landfill Construction CompletionReport indicates that Cells 2W, 2WA, 3W, and 4W were covered with six inches of fill, geomembrane,geocomposite drain net, 18 inches of compacted soil cover, six inches of topsoil, and vegetative cover. Table 3lists the operation year, the type of wastes disposed, the liner and capping system of each cell at the South Landfill.Please note that mere is a discrepancy in which cells at the South Landfill received PCB waste. Contrary to the1991 RFA Report, the RCRA Part B Post-Closure Permit Application indicates that the only known cell to receivePCB waste was Cell 3E. The permit also states that it is possible for PCB waste to be disposed of in Cells 1E and2E. None of the western landfill cells received PCB waste (Monsanto, 1996).

Monsanto operated a trash incinerator at the South Landfill to burn office trash in 1963. The incinerator wasphased out in 1973 due to stricter regulatory air emission standards (U.S. EPA, 1991).

3.2.2 Reported PCB Contamination

Reviews of available project files showed that the first subsurface investigation of the Solutia property wasconducted in 1973 (Law Engineering, 1973), but it did not include PCB sampling. Monsanto performed ahydrogeologic investigation of the South Landfill from July through October 1980 (Colder Associates, 1997).The investigation consisted of drilling 35 soil borings. Of the 35 borings, 15 of which were converted into casedborings and six into monitoring wells. There is no documentation indicating that soil and groundwater sampleswere collected for PCB analysis. Subsequently, a water level and quality monitoring program was initiated in1981 and additional monitoring wells were installed in the following seven years to delineate the extent of PNPand organophosphorous pesticides contamination in groundwater; however, no analysis was done for PCBs.

Soil

According to a 1979 U.S. EPA Potential Hazardous Waste Site Identification Form, approximately 10 millionpounds of PCBs were disposed of in the South Landfill (U.S. EPA, 1979). There is no documentation of soilcontamination at the South Landfill because eight of the 10 cells at this landfill were operated and closed prior tothe enforcement of RCRA, and monitoring of PCB releases was not required. There is also no PCB analytical datafor any soil samples collected from the South Landfill.

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Groundwater

Draft groundwater sampling results for the 1999 RF1/CS show the detection of PCBs at a concentration of 210ug/L in well OWR-5D. This is a deep well located along the northern perimeter of the South Landfill.


Due to the limited capacity of the historical drainage structures, stormwater runoff originating from ColdwaterMountain flowed across the South Landfill and often flooded the surrounding area. Sampling results showed thatPCB contamination was generally found along the drainage paths. PCBs were also detected along the median ofHighway 202.

ADEM files indicate that PCBs were detected in stormwater runoff samples collected from a drainage ditch nearthe South Landfill during three sampling events in 1994. On February 10, 1994, the total PCB concentrations ina grab and composite surface water sample were 8.3 and 6.3 ug/L, respectively. On July 12,1994, a grab samplecontained 1.3 ug/L of PCBs. On December 10, 1994, a grab and a composite sample contained 6.8 and 4.7 ug/Lof PCBs. Another grab sample collected from a ditch north of Highway 202 containing stormwater from thewestern side of the South Landfill had 4.9 ug/L of PCBs.

A National Pollutant Discharge Elimination System Stormwater Permit application at ADEM indicates that afterthe closure of Cells 4E and 5E, a stormwater sample collected from Outfall DSN 009 was found to contain PCBsat an unknown concentration.

Air

No air sampling has been performed at the South Landfill and no air analytical data are available.


Soil

Cells 4E and 5E of the South Landfill were capped in 1989, prior to the enforcement of RCRA, and Cells 2W,2 WA, 3 W, and 4 W were capped between 1997 and 1998. The 1997-1998 capping activities consisted of installinga geosynthetic cap over the closed cells and a soil cover over adjacent areas. The soil cover is comprised of ageotextile secured with compacted soil. A soil cover was installed on approximately 11 acres adjacent to the cap.The cap contains a high-density polyethylene (HDPE) geomembrane, a geocomposite drainage net, topsoil, anda vegetative cover. It was installed on approximately 14 acres, which covered the horizontal limits of the cells,including side slopes. Cells IE, 2E, and 3E were capped with a clay layer of unknown thickness and a vegetationcover (Woodward Clyde, 1998). Table 3 lists the type of capping system installed in each cell of the SouthLandfill.

Groundwater

The South Landfill Corrective Action System, which consists of the Western and Northern Landfill CorrectiveAction Systems, was installed in 1988 to intercept and recover shallow groundwater from the downgradientportion of the landfill. The South Landfill Corrective Action System consists of 10 active interceptor wells (IW-2,IW-5, IW-6, IW-7, IW-8, IW-9, IW-10, IW-11, IW-12, and IW-13), four point of compliance wells (MW-1B,MW-11A, MW-12A, and MW-13A), and seven effectiveness wells (OW-2, OW-4, OW-6, OW-7, OW-8A, OW-15, and OW-16A). Table 6 presents the installation dates, the monitoring area, and the interceptor and observationwells installed under the South Landfill Corrective Action System.

Extracted groundwater from the South Landfill Corrective Action System is temporarily stored in a collection tankand then routed through piping to the WWTP at the manufacturing facility before being discharged to the local

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POTW.


In 1996, the Lower Detention Pond was constructed to control flooding in the Clydesdale Avenue drainage areaand to mitigate the potential migration of contaminated soil and sediment from the South Landfill. However, thesurface water and sediments in the Lower Detention Pond have not been dredged or sampled since its construction.

Since 1998, the South Landfill has been covered with a capping system to control surface water infiltration. Inaddition, a large soil berm, the Upper Diversion Channel, was constructed along the southeastern perimeter of theSouth Landfill. This portion was then capped with a series of natural and synthetic liners and topsoil. The currentdrainage flows from the Upper Diversion Channel around the southeastern portion of the South Landfill, then overthe capped properties to the east of the manufacturing facility through culverts and pipes.

After the South Landfill was capped, Monsanto removed unknown amounts of sediment in the portion of thedrainage ditch along Highway 202 located north of South Landfill. The ditch was then concrete-lined; however,there is no documentation indicating that confirmatory sampling was performed after the removal activities.

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The South Landfill has been closed and covered with a capping system to control paniculate emission from thelandfill.

3.3 West End Landfill


The West End Landfill was operated from the mid to late 1930s to early 1960. Although there is nodocumentation on the type of wastes that were disposed of at the West End Landfill, but wastes probably includedparathion, polyphenyl, and PCB processing waste because these compounds were produced during the active lifeof this landfill. The West End Landfill was sold to the Alabama Power Company in 1960, after it was closed.According to ADEM, there was a hog farm on the West End Landfill after it was closed; however, the exact natureand duration of the farming operation is unknown. In December 1993, Monsanto bought back the landfill fromthe Alabama Power Company after a seep was found in one of the faces. Subsequently, Monsanto leased a portionof the West End Landfill to the Alabama Power Company for the construction and operation of a substation anda regional switching station at the northern toe of the landfill. Approximately 75 percent of the landfill area isoccupied by high voltage power lines (Golder Associates, 1999). In 1995, Monsanto capped the West EndLandfill with a composite capping system.

3.3.2 Reported PCB Contamination

Following the detection of a seepage in one of the faces of the West End Landfill by the Alabama Power Companyin December 1993, a site investigation consisting of soil, groundwater, and sediment sampling was performed byMonsanto in May 1994 for the West End Landfill (Geraghty and Miller, 1994).

Soil

Based on reviews of available project files at the U.S. EPA Region IV and ADEM offices, there is nodocumentation relating to the volume and disposal procedure of PCB-contaminated waste at the West EndLandfill. Analytical results of the May 1994 site investigation indicate the presence of PCBs in all eight surficialcomposite soil samples (0 to 1 inch bgs) collected from the landfill and adjacent areas at concentrations rangingfrom 18 to 798 mg/kg. A composite sample of the tar found across the landfill surface contained PCBs at aconcentration of 33,000 mg/kg. Nine of the 10 surficial soil samples collected along the western fence line on

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First Avenue contained PCBs at concentrations ranging from 2.56 to 92.9 mg/kg. However, PCBs were notdetected in any of the soil samples collected at 12 inches bgs along the western fence line. No soil samples werecollected at 12 inches bgs in the landfill and adjacent areas. Based on the analytical results, it was concluded thatPCBs were detected in surficial soil (0 to 1 inch bgs) throughout the landfill, adjacent areas, and along the westernfence line. The highest concentrations were found in the adjacent areas immediately west of the landfill and thewestern half of the landfill. The overall concentrations were higher at the locations closest to the landfill andgenerally decreased downslope from the landfill.

Groundwater

A groundwater sample collected in 1994 from a shallow well, WEL-3, and in 1998 from a deep well, OWR-7D,contained PCBs at concentrations of 6.8 and 2.2 ug/L, respectively.


Seven sediment samples and one composite sediment sample collected along the drainage ditch originated fromthe West End Landfill to the railroad track during the 1994 site investigation contained PCBs. The PCBconcentrations range from 41 to 508 mg/kg. A surface water sample collected at Outfall DSN 001 was also foundto contain PCBs at concentration of 8.3 ug/L.

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No air sampling has been performed on the West End Landfill and therefore, there is no analytical data availableto evaluate the potential PCB release via this air pathway.


Soil

Under the March 8, 1996 Consent Order with ADEM, Monsanto capped the West End Landfill, including the ditchfrom the West End Landfill to the railroad, with a series of liners and topsoil. The components of the compositecapping liner, starting from the lowermost layer, include a six-inch thick (minimum) layer of compacted structuralfill, a 60-mil thick textured HDPE geomembrane, a non-woven geotextile, geosynthetic drainage layer strips at50-foot intervals, and a 18-inch thick layer of topsoil with vegetation. In addition, adjacent areas around thelandfill were regraded and covered with 12 inches of general fill and six inches of topsoil and vegetative growth(Golder Associates, 1995).

Groundwater

Groundwater recovery/monitoring wells were installed along the northern perimeter of the manufacturing facilityand along the railroad tracks. According to the 1999 RFI/CS draft report, the OLBS1 Corrective Action Systemis also used to monitor the downgradient area of the West End Landfill (Golder Associates, 1999). Table 6 liststhe wells in the OLBSI Corrective Action System and Figure 2 shows the locations of these wells.


In addition to the capping system to control surface water infiltration into the landfill, several stormwater runoffdrainage improvements were also made at the West End Landfill. These corrective measures included:

• The diversion of runoff from the upgradient area through a new channel and culverts along the toe of thelandfill;

• The installation of a drop inlet to drain the Alabama Power Company switch yard area;• The construction of new channels along the perimeter of the landfill slope;

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• The construction of a channel to carry runoff from adjacent areas to the landfill and around the switchyard pad into a sediment pond, located in an area northeast of the switch yard, to capture and attenuatethe runoff and capture sediment from the landfill and adjacent areas; and

• The installation of a silt fence in area downgradient of the West End Landfill.

Air

The West End Landfill was closed and capped to control any participate emission from the landfill via air.

4.0 MEDIA RELEASE ANALYSIS

4.1 Soil

Generally, the most permanent solution to environmental contamination is source removal. However, this optionis not considered feasible for the buried PCS waste at the South Landfill and West End Landfill. Removal activityhas the potential to generate large amounts of contaminated dust, which could spread over a much larger area. Theremoval and transportation of PCB waste may present more of a potential for uncontrolled risk to the communitythan would leaving the waste in-place under a capping system. The current approach of isolating the contaminantsource is appropriate for the two landfills. The capping system installed at the South Landfill and West EndLandfill utilizes conventional composite layers of impervious geosynthetic membranes, compacted clay, andvegetative covers. These systems can be sufficient as a source control measure.

Some cells and contaminated areas (such as the area immediately adjacent to the West End Landfill, Cells IE,2E, 3E, 4E, 5E, and 1W at the South Landfill, and the former landfill catchment basins in the South Landfill) thathave been covered with clay and vegetative cover, but without an impervious geosynthetic membrane may erodein time, especially if the area is subject to infiltration, flooding, and large volume of surface water runoff. Whilethe South Landfill is less likely to be affected by flooding because of its elevation and the presence of the UpperDiversion Channel, the areas adjacent to the West End Landfill can be affected by flooding due to its lowerelevation and flat topography.

The soil cover used as a part of the South Landfill cap was constructed with native soil borrowed from an areaimmediately adjacent to and located cross-gradient from the South Landfill. Although the borrow soil was subjectto geotechnical testing, no PCB analysis was performed.

The vertical extent of the PCB contamination in soil at the manufacturing facility has not been fully characterizedby previous sampling. Based on the analytical data for soil samples collected during the RFI/CS at themanufacturing facility, the surficial and subsurface soil in various SWMUs and AOCs are contaminated withPCBs. Although corrective measures have been taken in many of these areas, contaminated soil was notcompletely removed, but was covered with either impervious or pervious covers, such as asphalt, concrete, rootmat, and gravel. The impervious cover can be effective in reducing infiltration to the underlying contaminatedsoil. Root mat will decompose in time and gravel layers contain significant amounts of void spaces. If the areaswith pervious covers become flooded, contaminated soil particles may migrate via surface water runoff andbecome airborne after drying. Therefore, these pervious covers do not provide adequate source isolation.

According to the 1997 RFI/CS Work Plan, the Waste Drum Satellite Accumulation Area was used solely forstoring non-hazardous waste drums and no further action was recommended for this area (Solutia, 1997). The1999 RFFCS draft analytical data show that the surficial soil sample collected beneath the existing gravel layerat this S WMU contained the highest level of PCBs, compared to the remaining 16 soil samples collected elsewhere(Colder Associates, 1999). Based on this evidence, previous usage of a SWMU may not be a good indicator ofthe potential and extent of any PCB contamination. Using odor as a screening criteria is inadequate and inaccurate,as well as a health and safety concern. The surface stabilization measures using pervious caps and covers, suchas the gravel cover in the Waste Drum Satellite Accumulation Area, should also not be considered as either aninterim or a permanent remedial solution to the existing PCB contamination.

13

IIIIIIIIIIIIIIIIIII

The 17 surficial and subsurface soil samples collected from various S WMUs and AOCs across the manufacturingfacility during the RFI/CS should not be considered as post-excavation confirmatory samples because the numberof samples collected are not representative of the excavated area. Post-excavation confirmatory samples areconventionally collected from each face of the excavation to confirm absence of contamination.

According to the 1991 UFA report, confirmatory sampling was required for the Stormvvater Drainage System(Production Area Portion, SWMU 37a), Scrap Yard Waste Oil Satellite Accumulation Area (SWMU 17), BoilerFeed Tank (SWMU 25), Steam Cleaning Pad (SWMU 31), and Product Storage Tank (AOC A). However, nosurficial and subsurface soil samples were collected from these areas for PCB analysis during the RFI/CS.

The 1994 West End Landfill Site Investigation concluded that only the surficial soil in the landfill, adjacent area,and western fence line along First Avenue was impacted by PCBs. However, no subsurface soil was collectedfrom the area immediately adjacent to the West End Landfill.

4.2 Groundwater

According to a potential hazardous waste site identification form submitted by Monsanto to ADEM in the ADEMfiles, approximately 10 million pounds of PCBs were disposed of in the South Landfill (U.S. EPA, 1979).However, approved permits for the manufacturing facility did not include sampling of PCBs in groundvvater until1997. Available analytical PCB data in groundwater at the Solutia property is insufficient, considering the volumeof PCB waste disposed of in the South Landfill and the unknown volume of PCB waste in the West End Landfill.

The RFI/CS draft report notes that filtered groundwater samples were collected for PCB analysis. It is not aconventional technique to collect filtered samples for PCBs and to filter the samples twice using a 0.45- and 0.1-micron size filter. Furthermore, ADEM does not accept results obtained from the filtered samples (ADEM, 1998).Therefore, only the results of unfiltered groundwater samples should be used in the 1999 RFI/CS draft report.

The RFI/CS draft report does not consider groundwater a pathway for PCBs; however, the report indicates thatthe residuum underlying the Solutia property contains slickenslided, wetted fractures that serve as conduits forgroundwater flow. Information is not sufficient to determine the continuity of these features from the residuuminto the shallow bedrock. The configuration of the shallow bedrock is also poorly known because of the depthsrequired for investigation. Existing data suggests that a geologic "discontinuity" limits northerly groundwater flowin the deep residuum and shallow bedrock. Groundwater in the shallow bedrock may flow towards a postulated,steep, northerly dipping geologic contact underlying the southern portion of the Solutia property and the northernslope of Coldwater Mountain.

The groundwater corrective action system for the South Landfill appears to be functioning properly and capturingmuch of the shallow groundwater flowing through or under the South Landfill. However, assuming a PCB plumemigrated from the southern perimeter of Cell 4W (the southern most point) at the South Landfill since 1920, andusing the calculated horizontal groundwater flow velocity of 11 ft/yr for the South Landfill and 4 ft/yr for themanufacturing facility (Golder Associates, 1999), the assumed plume would have moved approximately 1,100feet and reached the southern boundary of the manufacturing facility in 1945. By 2001, the plume would havemigrated another 224 feet into the manufacturing facility. Based on this exercise, it is possible that groundwaterreleases from at least the South Landfill, either before or after capping, may have just passed the southernboundary of the manufacturing facility and may not yet have reached the northern boundary of the manufacturingfacility. Likewise, some portions of both the shallow and deep groundwater flowing northwesterly within theresiduum appear to be captured by the OLBSI Corrective Action System, but piezometric maps in both the 1996Post-Closure Permit Application and the RFI/CS draft report suggest that a northerly flow component is leavingthe Solutia property. The discharge point for this flow may be Snow Creek, but neither the deep or shallowgroundwater flow configuration north of the Solutia property can be determined with existing information.

Previous groundwater sampling conducted between 1994 and 2000 for the Solutia property detected PCBs in

14

samples collected from the following shallow and deep monitoring wells: OW-8A, OW-15, OW-16A, OW-21,OW-22, OW-24, OWR-5D, OWR-7D, and WEL-3 (Colder Associates, 2000a&b). Based on the locations of themonitoring wells with PCB detection as well as the frequency and level of detection, PCB occurrence ingroundwater does not appear to have a pattern. Although the RFI/CS draft report indicates that groundwater isnot a pathway because PCBs are not soluble, an explanation is needed for the detection of PCBs in thegroundwater samples obtained in both shallow and deep wells at the Solutia property. In the report, Solutia statedthat the detection of PCBs in groundwater were due to the drag-down effect of contaminated surficial soil duringwell installation. This point can be proven if future wells are installed in a location after the surficial soil has beenremoved and sampled to ensure the absence of PCBs.

The RFI/CS draft report states that there is no off-site migration of PCBs; however, wells OW-21 and OW-22 arelocated across the railroad track on a buy-out property, not on the manufacturing facility. According to the U.S.EPA Region IV personnel, this property was once occupied by the Alabama Soil and Pipe Company. If there wasno manufacturing of PCBs in this area and PCBs did not exist in the groundwater at this property, the detectionof PCBs in these two wells may indicate that groundwater contamination has migrated off-site.

The RFI/CS draft report also indicates that one of the functions of the existing wells in the OLBSI GroundwaterDetection Monitoring and Corrective Action System is to monitor the groundwater quality in the areadowngradient of the West End Landfill. However, these wells are not positioned directly downgradient from theWest End Landfill. In addition, the four shallow wells and one deep well in the West End Landfill have beenexcluded from the site-wide groundwater detection and corrective action systems and are not sampled regularly.The limited amount of PCB data in groundwater samples collected from the West End Landfill does not adequatelydefine the extent of PCB contamination in groundwater at the West End Landfill.

4.3 Surface Water and Sediment

Although the drainage structure in the surrounding area has been upgraded, recent photographic documentationshows that some areas near the Solutia property still subject to flooding. The PCB-contaminated particulates leftin previously flooded areas can still be spread to other areas through flooding.

The sediment in the drainage ditches along Highway 202 has not been sampled since the ditch was concrete-lined.The Lower Detention Pond constructed for the collection of stormwater runoff from the South Landfill also hasnot been sampled since its construction. Sediments in the drainage ditches, the sediment pond, and silt-fencedareas in the West End Landfill have not been sampled for PCBs since the drainage features at the landfill wereupgraded.

4.4 Air

The RFI/CS draft report indicates that air was not considered a migration pathway because of the surfacestabilization measures taken at the manufacturing facility, which minimized the potential for airborne dust.However, as mentioned above, pervious covers on contaminated soil are not adequate as a source isolationmeasure. The contaminated soil particles underneath the gravel layers can still migrate to the surface if floodingoccurs. After the flooded area becomes dry, PCB-contaminated particulates can be airborne easily.

PCBs have been detected in ambient air samples collected from selected areas around the perimeter of themanufacturing facility by Solutia (Solutia, 2000a and b). In addition, the analytical results of the June 2000ambient a'ir sampling event conducted by the U.S. EPA Region IV indicate that the PCB concentrations in thesamples collected after a heavy rainfall in all sampling locations were higher than those collected before rainfallat all but one sampling location (U.S. EPA, 2000a). This can be interpreted that PCBs were attached to the soilparticles and were agitated by the rainfall. The PCBs in the ambient air samples are likely to have originated fromcontaminated sediment and dust, which can easily become airborne. PCBs can also exist in a vapor form.However, there is no PCB vapor data available for evaluation.

15

IIIIIiit§iiiiiiii§i

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 Conclusions

Considering the volume of PCB waste disposed of at the South Landfill and the duration of operations of the twolandfills, the amount of analytical data on PCB contamination in soil, groundwater, surface water and sediment,and air appears to be somewhat limited.

5.1.1 Soil

Analytical data shows that PCB-contaminated soil remains in the manufacturing facility, despite the excavationof contaminated soil in many SWMUs and AOCs. The extent of PCB contamination in soil at the manufacturingfacility should also be further investigated. Areas with PCB-contaminated soils that have been stabilized usingpervious cover should be subject to either hot-spot removal or covered with impervious material to permanentlyeliminate or completely isolate the source of contamination.

Because it is not practicable to remove the waste from the South Landfill, Cells IE, 2E, 3E, 4E, 5E, and 1W andthe former catchment basins should be covered with a composite geosynthetic cap. An alternative is to diligentlymaintain the present clay and vegetative cover at the South Landfill. Due to the location of the borrow soil pitrelative to that of the waste in the South Landfill, it may be prudent to collect a representative number of samplesfrom the uppermost soil cover of the South Landfill cap to ensure the absence of PCBs.

The vertical extent of PCB contamination in areas adjacent to the West End Landfill requires delineation. Afterdelineation, hot spot removal could be a viable option to handle the PCB-contaminated surficial soil in the adjacentareas surrounding the West End Landfill; otherwise, these areas should be covered with a geosynthetic membrane.

5.1.2 Groundwater

ADEM does not accept filtered groundwater sample results for PCBs. Therefore, evaluation of PCB data ingroundwater should only be performed using unfiltered groundwater sample results. Because of the limitedamount of analytical data available for PCBs in groundwater at the Solutia property, the three on-goinggroundwater detection monitoring and corrective action systems should be continued. Results should be evaluatedto assess the vertical and horizontal extent and movement of groundwater contamination in both the shallow anddeeper residuum. Monitoring wells should be installed further downgradient of the existing wells along thenorthwestern perimeter of the Solutia property for regular sampling and PCB analysis. Based on the limitedanalytical data, the extent of groundwater contamination in the deep residuum should be further assessed becausesamples from the only deep well installed in the West End Landfill, OWR-7D, contained PCBs. The fivemonitoring wells in the West End Landfill should also be included in the on-going groundwater monitoring andsampling program. Additional monitoring wells should be installed north of wells OW-21 and OW-22 todetermine if the groundwater contamination has migrated further off-site to the north. This is in keeping with anApril 24, 2000 letter from Solutia to ADEM outlining an off-site groundwater study. Integration of sitegroundwater patterns with off-site information and regional groundwater flow directions is necessary to determineprobable groundwater discharge points from the Solutia property.

5.1.3 Surface Water and Sediment

Due to the relatively immobile nature of PCBs in the subsurface environment, it is difficult to determine the timingof PCB releases in the various environmental pathways. To effectively evaluate the possibility of any on-goingreleases from the Solutia property, selected sampling locations should be identified and cleaned up. Regularmonitoring including sample collection and analysis of PCBs should follow as soon as these selected areas areremediated. Some areas, such as the drainage ditches along Highway 202 and the Lower Detention Pond, havenot been sampled or dredged since the capping of the South Landfill. It is recommended that these areas beremediated and then regularly sampled to determine if on-going PCB releases occurred after the South Landfill

16

was capped.

5.1.4 Air

Based on reviews of available technical reports and project files for the Anniston PCB site, the major mechanismof PCB releases from the manufacturing facility and the two landfills in the past was stormwater runoff. Priorto the capping of the South Landfill and the West End Landfill and the upgrade of the drainage systems in thevicinity of the Solutia property, surface water from Coldwater Mountain flowed across the two landfills in contactwith the waste. The contaminated runoff then flooded the surrounding area due to the limited capacities ofdrainage structures. After the flooded area became dry, PCB-contaminated particulates remained in the surficialsoil and in drainage ditch sediments. Because PCB-contaminated particulates can become airborne easily andthe nearby receptors can be exposed to PCB-entrained particulates through inhalation, this can be considered asan on-going PCB release. Many corrective actions, such as hot spot removal and capping, have been taken byMonsanto and Solutia to control the migration of and exposure to PCB-contaminated material, but the air pathwayremains a major concern.

To determine if PCBs are released through the air from the Solutia property, it is necessary to conduct high-volume ambient air sampling at the two landfills and at the manufacturing facility. The methodology of this high-volume air sampling is approved by the U.S. EPA for PCBs and the results can be compared with conventionalregulatory action levels. However, the method cannot distinguish between airborne particulates or vapor.

The ambient air sampling program for the source areas should contain a sufficient number of samples in upwind,downwind, and background locations at each of the landfills and the manufacturing facility. It is imperative duringan extended sampling event utilizing high volume PCB sampling that background, upwind, and downwindlocations remain consistent. Therefore, sampling pumps should only be running when the wind direction isrelatively constant in order to determine if the Solutia property is the sole source of PCBs, or if other sources existupwind of the background and upwind samplers.

To determine if the landfills are emanating vapor, it is recommended that an air flux study be performed on thelandfills. Although there is no U.S. EPA-approved flux sampling methodology for PCBs and no action levelestablished for comparison, an air flux study would, at least, determine the presence or absence of PCBs in anyvapor emanating from the two landfills. The U.S. EPA and ADEM have requested that Solutia perform such astudy to determine if vapor containing PCBs are released from the landfill.

By performing both ambient air sampling and air flux study, one can determine if the landfills are giving off PCB-containing vapor, as well as the concentrations of PCBs in the ambient air at and around the two landfills and themanufacturing facility.

5.2 Recommendations

Based on the media release analysis presented in Section 4.0, REAC recommends the following general siteactivities:

• Continue the operation of the groundwater corrective action systems;• Refine information on groundwater elevations and flow paths at and near the northern end of the Solutia

property. Because of logistical problems on the Solutia property, this would ideally involve installationof additional monitoring wells off-site to obtain the necessary spatial coverage. This recommendationcan be integrated with a similar one included in Section 5.2.3;

• Verify groundwater elevations and apparent flow directions in the shallow bedrock by additionalgroundwater measurements in existing wells;

• Using both existing data and any new data developed after the release of the RFI/CS draft report,determine a probable range of groundwater travel times from the South Landfill to the northern edge ofthe Solutia property since the installation of the landfill; and

17

• Perform both ambient air sampling and an air flux study at the manufacturing facility and at each of thetwo landfills to determine whether the structure is giving off PCB-containing vapor and theconcentrations of PCBs in the ambient air around the Solutia property.

Additional recommendations for each individual component of the Solutia Property are listed below:

5.2.1 Manufacturing Facility

• Cover the following areas with impervious materials, such as asphalt or concrete, to minimize thepotential of PCB-contaminated particulates residing in void spaces and migrating off-site until apermanent remedial alternative is identified:- Former Parathion Area (SWMU 41);- Former Phosphorus Pentasulfide Production Area (SWMU 43);- Former Holding Tanks, Aeration Basins, and Clarifiers (SWMU 46);- Phosphate Landfill (SWMU 6);- Santotar® Pit (SWMU 7);- Phosphoric Acid Basins (SWMU 12);- Waste Drum Satellite Accumulation Area (SWMU 44);

• Collect surficial and subsurface soil samples in Stormwater Drainage System (Production Area Portion,SWMU 37a), Scrap Yard Waste Oil Satellite Accumulation Area (SWMU 17), Boiler Feed Tank(SWMU 25), Steam Cleaning Pad (SWMU 31), and Product Storage Tank (AOC A) for PCB analysissince confirmatory sampling is required for these areas;

• Delineate the horizontal and vertical extent of PCB-contaminated soil at the manufacturing facility sinceit is not defined currently; and

• Install additional monitoring wells further north of wells OW-21 and OW-22 to determine if thegroundwater contamination has migrated further off-site to the north.

5.2.2 South Landfill

• Cover Cells IE, 2E, 3E, 4E, 5E, and 1 Wat the South Landfill with geosynthetic membrane because theexisting soil cover can erode; otherwise, provide maintenance on vegetation cover;

• Collect a representative number of soil samples from the uppermost topsoil cover of the South Landfillfor PCB analysis to ensure the absence of PCBs in the topsoil cover;

• Further assess the extent of groundwater contamination in the deep residuum because the only deep wellinstalled in the South Landfill, OWR-5D, contained PCBs

• Remediate the concrete-lined drainage ditch along Highway 202 and subsequently perform sedimentsampling for PCBs on a regular basis to determine any on-going releases from the South Landfill; and

• Collect sediment samples from the Lower Detention Pond to determine if the South Landfill is an on-going source of PCB release since the landfill was capped.

5.2.3 West End Landfill

• Remove PCB-contaminated subsurface soil (underneath the existing vegetative cover and general fill)in the adjacent areas surrounding the West End Landfill to prevent contaminated soil becoming mobilebecause the existing soil cover can erode; otherwise, cover the adjacent areas with geosyntheticmembrane;

• Install monitoring wells along the northwestern perimeter of the Solutia property to monitor thedowngradient area of the West End Landfill;

• Further assess the extent of groundwater contamination in the deep residuum because the only deep wellinstalled in the West End Landfill, OWR-7D, contained PCBs; and

• Include the five monitoring wells in the West End Landfill in the semi-annual groundwater detectionmonitoring and corrective action program. Groundwater samples from these wells should be analyzedfor PCBs.

18

6.0 REFERENCES

ADEM. July 8, 1998. Correspondence to Solutia Inc. (Solutia) - Review of June 11, 1998 Letter RegardingRFUCS Monitoring Well Location Changes (Revision 3 of RFI/CS Work Plan).

Geraghty and Miller, Inc. August 1994. West End Landfill Site Investigation Plan, prepared for Monsanto.

Colder Associates. May 17, 1995. Detailed Design of West End Landfill Cover Revisions at the MonsantoAnniston Plant, Alabama, prepared for Monsanto.

Colder Associates. November 1997. RFI/CS Work Plan for the Anniston, Alabama Facility, prepared for Solutia.

Colder Associates. January 1999. RFI/CS Draft Report, Volumes I, II, and III, prepared for Solutia.

Colder Associates. February 2000a. Second 1999 Semi-Annual and 1999 Annual Ground\vater DetectionMonitoring and Corrective Action Effectiveness Report, prepared for Solutia.

Colder Associates. August 2000b. First 2000 Semi-Annual Grouna\vater Detection Monitoring and CorrectiveAction Effectiveness Report, prepared for Solutia.

Law Engineering. 1973. Subsurface Investigation.

Monsanto. March 7, 1995. Correspondence to ADEM.

Monsanto. April 1996. RCRA Part B Post-Closure Permit Application.

Scott, J. C., Harris, W. F. and R. Cobb. 1987. Geohydrology and Susceptibility of Cola\vater Spring andJacksonville Fault Areas to Surface Contamination in Calhoun Count)', Alabama: U. S. Geological Survey Water-Resources Investigation Report 87-4031. 29 pp.

Solutia. November 25, 1997. RFI/CS Work Plan.

Solutia. February 28, 2000a. Correspondence to ADEM - Bimonthly Submittal of Air Monitoring Data.

Solutia. October 20, 2000b. Correspondence to ADEM - Bimonthly Submittal of Air Monitoring Data.

U.S. EPA. Decembers, 1979. Potential Hazardous Waste Site Identification and Preliminary Assessment.

U.S. EPA. September 13, 1991. Region IV, RCRA and Federal Facilities Branch, Waste Management Division.RFA-RCRA Facility Assessment Report.

U.S. EPA. August 10, 2000a. Region IV, Science and Ecosystem Support Division. Results of June 2000Poly chlorinated Biphenyl Ambient A ir Study.

U.S. EPA. September 15, 2000b. Region IV, Emergency Response and Removal Branch, Removal OperationsSection. Correspondence to Environmental Response Team - Request for Technical Assistance at the AnnistonPCB Site, Anniston, Alabama, CERCLA Account No. 04S9.

U. S. EPA. October 2,2000c. Region IV, Office of Technical Services. Comments Submitted by ADEM: RFI/CSDraft Report, Solutia Inc., Anniston, Alabama- On-Site Activities.

Woodward-Clyde International-Americas. March 1998. Completion Report: South Landfill Construction,Anniston, Alabama, prepared for Solutia

19

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Table 2List of SWMUs and AOCs

Anniston PCB SiteAnniston, Alabama

I

SWMU No. Location1 Landfill2 Landfill Catchment Basins3 Western Landfill Corrective

ActionSystem

4 Leachate Storage Tank5 Northern Landfill Corrective

ActionSystem

6 Phosphate Landfill7 Santotar Pit8 Old Limestone Bed9 Lagoon10 Limestone Bed Corrective Action

System11 New Limestone Bed12 Phosphoric Acid Basins13 Closed Container Storage Area14 Hazardous Materials Storage

Area15 Spent Nickel Catalyst Storage

Area16 Laboratory Satellite

Accumulation Area17 Scrap Yard Waste Oil Satellite

Accumulation Area18 Benzene Satellite Accumulation

Area19 Trash Incinerator20 Sulfur Incinerator21 Former Boiler22 Present Boiler23 Satellite Accumulation Area for

Compress Oil24 Boiler Satellite Accumulation

Area25 Boiler Feed Tank

SWMU No.262728293031

32333435363738394041

4243

44

4546

AOCABC

LocationBlending TankSantotar TankTherminol® Ends TankWastewater Treatment FacilityPlant Corrective Action SystemSteam Cleaning PadDrum CrusherSouth Scrap YardOld Boiler Scrap YardAcetone Recovery ColumnCarbon Towers (3)Storm water Drainage SystemDumpstersLoading/Unloading AreaFire Training AreaFormer Parathion ProductionAreaFormer PCB Production AreaFormer Phosphorus ProductionAreaWaste Drum SatelliteAccumulation AreaHydrogen Sulfide FlareFormer Holding Tanks, AerationBasins, and Clarifiers

LocationLeaking Product Storage TankSnow Creek Contamination AreaProduct Underground StorageTanks

II

I

Table 3Description of Individual Cells at the South Landfill


CellNo.

IE

2E

3E

4E

5E

1W

2W

2WA

3W

4W

Years ofOperation

1 920s to thelate 1950s/early 1960s

1920s to thelate 1950s/early 1960s

1980s

Late 1970sto 1988

1980- 1989

1960s to1975

1960s to1975

1960s to1975

1960s to1975

1973 to1983

Liner System(from bottom totop)

Natural Clay

Natural Clay

Natural Clay

Natural Clay

24-inchCompactedclay, 12- to 18-inch crushedsandrock, 18- to24-inchcompact clay

Natural Clay

Natural Clay

Natural Clay

Natural Clay

Natural Clay

Waste Type

Phosphorous, Aroclor, and chlorineprocessing wastes

Phosphorous, Aroclor, and chlorineprocessing wastes

Non-hazardous chemical wastes

Flammable waste, methyl parathion,parathion, acetone, benzene,cumene, mcthylene chloride,methanol, PNP, and xylcneprocessing wastes

Flammable waste, methyl parathion,parathion, acetone, benzene,cumene, methylene chloride,methanol, PNP, and xylencprocessing wastes, spent limestone,limestone, clay, acid brick, andconcrete rubble

Parathion, methyl parathion, PCBs.asbestos, and Paranitrophenolprocessing waste, biological solids,and trash

Parathion, methyl parathion, PCBs,asbestos, and Paranitrophenolprocessing waste, biological solids,and trash

Parathion, methyl parathion, PCBs,asbestos, and Paranitrophenolprocessing wastes, biological solids,and trash

Parathion, methyl parathion, PCBs,asbestos, and Paranitrophenolprocessing wastes, biological solids,and trash

Organophosphate contaminatedsulfur, parathion, methyl parathion,PCBs, asbestos, PNP processingwastes, biological solids, and trash

Capping System (from bottom totop)

Clay and vegetation cover(Unknown thickness)



24-inch Compacted clay, 12-inchsand, geotextile fabric, 24-inchtopsoil, and vegetation cover

24-inch Compacted clay, 12-inchsand, geotextile fabric, 24-inchtopsoil, and vegetation cover

Geotextile, 12-inch compactedborrow fill, vegetation cover

6-inch Fill, geomembrane.geocomposite drain net, 18-inchcompacted soil cover, 6-inchtopsoil, vegetation cover

6-inch Fill, geomembrane,geocomposite drain net, 1 8-inchcompacted soil cover, 6-inchtopsoil, vegetation cover

6-inch Fill, geomembrane,geocomposite drain net, 1 8-inchcompacted soil cover, 6-inchtopsoil, vegetation cover

6-inch Fill , geomembrane,geocomposite drain net. 18-inchcompacted soil cover, 6-inchtopsoil, vegetation cover

Table 41999 RFI/CS Soil Samples Containing PCBs


Sampling Location

Phosphate Landfill (SWMU 6)

Santotar Pit (SWMU 7)

Phosphoric Acid Basins (SWMU 12)

Old Boiler Scrap Yard (SWMU 34)

Former Parathion Production Area (SWMU41)

Former PCB Production Area (SWMU 42)

Former Phosphorus Pentasulfide ProductionArea (SWMU 43)

Waste Drum Satellite Accumulation Area(SWMU 44)

Former Holding Tanks, Aeration Basins andClarifiers (SWMU 46)

Undersround Product Storage Tanks (AOCC)

Sampling Depth

2 feet below the base ofexisting gravel cover

2 feet below the base ofexisting gravel cover

surface

6 to 10 feet below grade

surface beneath the existinggravel cover

surface

19 to 21 feet below grade

6 to 1 0 feet below grade

6 to 8 feet below grade (2feet below the base ofasphalt cover)

2 feet below the cover

3 to 6 inches below thegravel surface

1.25 to 3. 5 feet below thecover

1 0 to 12 feet below grade

SampleNo.

SSR-6

SSR-7

SSR-8

SSR-9

SSR-3

SSR-5

SSR-4

SSR-15

SSR-21

SSR-2

SSR-10

SSR-11

SSR-12

SSR-13

SSR-19

SSR-18

SSR-17

SSR-14

PCBConcentration(rag/kg)

9.3

229

0.034

282

2.17

106

104

65 E

0.559 E

11.2

0.339 E

0.204

0.67

16

0.507 E

1 6,620 E

0.205

6.4

Note:mg/kg - milligram per kilogram.E indicates estimated concentration.

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Table 5Detection of PCBs Ln Groundwater Samples


Well No.

OW-08A

OW-15

OW-16A

OW-21

OW-22

OW-24

OWR-05D

OWR-07D

WEL-3

Location

South of SWMU 12

Near Plant

South of SWMU 25

Across Railroad Tracks from OldLimestone Bed

Across Railroad Tracks from OldLimestone Bed

Old Limestone Bed

Northern Perimeter of SouthLandfill

Downgradient of West End Landfill

Downgradient of West End Landfill

Sampling Date

1997(1" Half)

1997 (2nd Half)

1998

1999

1998

1999

1997 (1st Half)

1 997 (2nli Half)

1998 (1s1 Half)

1998 (2nd Half)

1999 (1st Half)

1999 (2nd Half)

2000

1998

1999

1999

1998

1999

1998

1998

1994

Total PCBs Concentration inug/L (Unfiltered)

600

17.4

320

7.9

4.2

2.5

80

260

73

110

155.8

290

114

7.3

97

1.2

1.5E

2.8

210

2.2

6.8

Note:ug/L - microgram per liter.E indicates estimated concentration.

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Site Location Map

On-Site RFI/CS ProgramSdufla Inc., Anniston. Alabamat=i '*'

&$M Military Reservation

A/ Property LineO Alabama Power

Solute Inc.

/\/ Highway/Major Road,\s Minor Road

Lakes

/V* Intermittent StreamA/ Perennial Stream

V. On-sfte boundary/VRpenne/•I '' V PowerDns

/> Railroad - Active-' '•/ Raflroad - Abandoned

MAP PROJECTION

Appned Chnriitn% Qeativc Solmi

IIaiiiiiiiiiiii

Jt ^/^/W^Qf5^3

^ rV* W^ %^©-=<!/ ^xi I ,, \. f/Jra CX357D aim a s

/ ' ^WSOE/ /xrl^^P

,^r Y&w^P&fiS'•' i; v. =• .eK« "-"sririn ///'"•OurtSB

LAMJFU.CCmECTlVE ACTION 8Y8TBI

• ij— 'Uf-vln' ' ~ I>--^r-. r-, 'ii=3 L-'ip-a? « j!

n '.i;;i- a-tl-p j3 ' " ^

••^H' jf ^te • <%J*=!!0 .- o ;!- r"»-v,-n «Vi!

MONSANTORR/CS WORKPLAN

APRIL, 1997

RCRA POttHT REC«»lfcCNDS CONFIRMATORY SAUPLINC

RCRA PERMIT RECOMMENDS AODITIOMAI. RF1

GRC3UNDWATCR CORRECTIVE ACTION SYSTEM

WASTE MANAGEMENT AREA

ADDITIONAL SVMU NOT INCLUDED IN RCRA PERMITRECOMMEMJATIONS

INTERCEPTOR WELL LOCATION

< SWMU 37A IS NOT SHOWN DUE TOVARIOUS LOCATIONS THROUGHOUT FAdUTY.

2. AOC C NOT SHOWN DUE TO UNKNOWNLOCATIONS OF FOUR USTa

3. SWMU 2 NOT SHOWN DUE TO UNKNOWNLOCATIONS WITHIN WMA I AND SWMU 1.

4. RCRA PERMIT REQUIRES FURTHERACTION FOR SWMU 2. SWMU 37 A ANDAOC C AS FOLLOWS:

«U 2

rfU 37A

BS""*»

C C

RCRA PERMIT REQUIRESADDITIONAL RFI

RCRA PERMIT REQUIRESCONFIRMATORY SAMPLING

RCRA PERMIT REQUIRESCONFIRMATORY SAMPLING

5 ONLY THE PORTION OF AOC B ADJACENTTO THE SITE IS SHOWN.

6. OTHER SWMU's NOT REQUIRING FURTHERINVESTIGATION ARE NOT SHOWN.

— f -

Storm Water Outfalls

On-Srte RFI/CS ProgramSolatia Inc., Annteton, Alabama

Major Roads•' /\/ Minor Roads

;/vA/ Property Line

BuildingsAlabama PowerSolutia Inc.Paved

Afabama East 101

MAP PROJECTION

LOCATION MAP

% • ' AppBni Chcmmts (i^

PRODUCED BY

Old Limestone Be

SWMU-08,

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Soil Sampling and SWMU Locations

On-Slte RFI/CS ProgramSolute Inc., Anniston, Alabama

Major Roads

-•|V Minor Roads

/*\/ Drainage Basin

, . Railroads

A/ Property Una

Buildings

mm Paved

S Subsurface Soil Sample© Surface (or near surface)

Soil Sample

RR/CS Actions

Confirmatory Sampling

GroundwaterCorrective Action

Additional RR

Waste Management Area

SOURCEGaidar Associates (on-site base map)USGS 13400 Quad Maps

US State Plane

DATUM

NAD83

ve Soiurion:

PROJECT/FILE No:

QA-Mfl-gisMfMiase-apr

RGURE No:

4

Annteton, Alabam

/\y Major Roads

Minor RoadsDrainage Basin

RaflroadsProperly Une

I I Buildings

SOURCEGoldsr Associates (on-ste base map)USGS 1:2400 Quad MapsAlabama East 101

MAP PROJECTION

\ ------m

0 -P Q LOCATION MAP

Associates''.•.. . 'AppSai Cbvoixty. O«iveSolurioni

SCALE

200 400 600 Feet

INTERCEPTOR WEUL LOCATIONOBSERVATION WELL LOCATIONMONITORING WELL LOCATIONRESIDUUM PIEZOMETER LOCATIONCASED BORING LOCATION

'NOTES: • ; •

1. THE FOLLOWING WELLS ARE SCREENED IN BEDROCK:BR-i, BR-2, BR-3, BRT4, BR-5, MW-11A, MW-12A,MW-13A. SBP-1, SBP-;2l SBP-3, SBP-4, SBP-5,AND DW-1.

2. ALL OTHER WELLS ARE SCREENED IN RESIDUUM.

SCAl IN FEET

':'•' "

^400

srre PLAN SHOWING EXISTING GROUNDWATER1 WELL NETWORKAtlanta, Georgia

MONSANTOWORKPLAN-APPENDIX A

APRIL,: 199736418 AS SHOWN

II

1HH Appendix A

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APPENDIX A

LIST OF AVAILABLE PERTINENT DOCUMENTS REVIEWED

ANNISTON PCB SITE

FINAL SUMMARY REPORT

MAY 2001

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Alabama Department of Environmental Management (ADEM). February 25, 1985. Correspondence - InternalMemorandum from F. Mason to B. Cox - Part B Groundvvater Review.

ADEM. October 19, 1987. Correspondence - Internal Memorandum from F. Mason to B. Cox - MonsantoAnniston CME Part II Report.

ADEM. October 20, 1987. Correspondence - Internal Memorandum from F. Mason to B. Cox - Monsanto,Anniston Inspection.

ADEM. May 17, 1988. Correspondence - Internal Memorandum from S. Cobb to B. Cox -Condition ofMonitoring Wells at Monsanto - Anniston.

ADEM. May 18,1988. Correspondence - Internal Memorandum from S. Cobb to B. Cox - Monsanto - Anniston,Closure Certification of Limestone Bed Surface Impoundment.

ADEM. August 19, 1991. Correspondence to Karen Jayne Levinson.

ADEM. February 24, 1995. Correspondence to Monsanto Company (Monsanto).

ADEM. April 13, 1995. Correspondence to Monsanto.

ADEM. July 17, 1995. Correspondence to Monsanto - West End Landfill.

ADEM. November 13, 1995. Correspondence to Monsanto - Soil Placement - West End Landfill.

ADEM. July 18, 1996. Correspondence to City of Anniston and Calhoun County Commission - MonsantoCompany - Anniston Facility.

ADEM. December 13, 1996. Complaint Form dated December 13, 1996.

ADEM. January 7, \997.Hazardous Waste Facility Perm it issued to Monsanto Company, Post-Closure Permit:WMA-1 Closed Hazardous Waste Landfill, WMA-11 Surface Impoundment (closed as a landfill).

ADEM. March 11, 1997. Correspondence to Monsanto - Interim Measures.

ADEM. April 10, 1997. Complaint Form dated April 10, 1997.

ADEM. May 30, 1997. Correspondence to Monsanto - Consent Order No. 96-054-CHW.

ADEM. September 10, 1997. Correspondence to Monsanto - April 7, 1997 Biphenyl Release.

ADEM. June 29, 1998. Correspondence to L. Sims.

ADEM. July 8, 1998. Correspondence to Solutia Inc. (Solutia) - Review of June 11, 1998 Letter RegardingRFI/CS Monitoring Well Location Changes (Revision 3 of RFI/CS Work Plan).

ADEM. July 16, 1998. Correspondence to Solutia-Review of July 2, 1998 Soil Excavation/Placement Letter.

ADEM. May 19, 1999. Correspondence - Internal Memorandum from K. Keller to G. Hardy - Solutia Inc.,Operation and Maintenance Inspection.

ADEM. August 17, 1999. Correspondence - Internal Memorandum from J. Adams to L. Brown - Ambient AirSampling at Solutia Inc. (formerly Monsanto Chemical Company).

ADEM. September 20, 1999. Evaluation of Solutia's Status under the RCR1S Corrective Action.

ADEM. October 27, 1999. Correspondence - Internal Memorandum from K. Keller to S. Cobb.

ADEM. December 20, 1999. Correspondence to Solutia - Review of October 1, 1999 Submittal - First Noticeof Deficiency; Regarding: Request for RCRA Activities Associated with Remote Off-Site Residential Areas.

ADEM. April 18, 2000. Correspondence to United States Environmental Protection Agency (U.S. EPA) -Assistance to Community Against Pollution Regarding RCRA/CERCLA Delineation.

ADEM. June 7, 2000. ADEM, Water Division - Water Supply Program, Chapter 335-7-2, Primary DrinkingWater Standards.

ADEM. June 28, 2000. Correspondence to Solutia - Notice of Deficiency: March 27, 2000 PCB Vapor FluxWork Plan; and Call for Additional Phase of RFI Air Evaluation of Potential Volatile Sources of PCB at Solutia.

ADEM. November 9, 2000. Correspondence to Solutia - Focused Ambient Air Sampling Evaluation.

Angle, Travis and Kathy. November 14, 2000. Correspondence to U.S. EPA.

Brown, Gene. November 18, 2000. Correspondence to U.S. EPA.

Community Against Pollution, Inc. November 27,2000. Correspondence to U.S. EPA: CAP Proposal for LongTerm Superfund Clean Up.

Davidson, Clifford & Harper, Alice. December 5, 2000. Correspondence to U.S. EPA.

ENSR. March27,2000. Work Plan for Estimating PCB Vapor Flux From Solutia Landfillls, prepared for Solutia.

ENSR Corporation. April 2000. Work Plan for Estimating Ambient PCB Levels in the Vicinity of Solutia'sAnniston, Alabama Facility, prepared for Solutia.

Geological Survey of Alabama. January 24, 1980. Correspondence to State of Alabama, Department of PublicHealth, Division of Solid Waste and Vector Control.

Geraghty and Miller. January 1988. Direction and Rate of Ground-Water Flow in the Uppermost Saturated Zoneat the Monsanto Facility in Anniston, Alabama, prepared for Monsanto.

Geraghty and Miller, Inc. August 1994. West End Landfill Site Investigation Plan, prepared for Monsanto.

Geraghty and Miller Inc. June 9, 1995. Correspondence to Monsanto - Soil Sampling Results for Area A,Monsanto Company, Anniston, Alabama.

Golder Associates. May 17, 1995. Detailed Design of West End Landfill Cover Revisions at the MonsantoAnniston Plant, Alabama, prepared for Monsanto.

Golder Associates. April 1997. Interim Measures Work Plan, Monsanto Anniston Facility, Anniston, Alabama,prepared for Solutia.

Golder Associates. November 1997. RFI/CS Work Plan for the Anniston, Alabama Facility, prepared for Solutia.

Golder Associates. January 1999. RFI/CS Draft Report, Volumes 1,11, and 111, prepared for Solutia.

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Colder Associates. February 2000. Second 1999 Semi-Annual and 1999 Annual Ground\vater DetectionMonitoring and Corrective Action Effectiveness Report, prepared for Solutia.

Colder Associates. August 2000. First 2000 Semi-Annual Groundwater Detection Monitoring and CorrectiveAction Effectiveness Report, prepared for Solutia.

Johnson, Charles. November 25, 2000. Correspondence to U.S. EPA.

Kinney, Rufus. November 9,2000. Correspondence to U.S. EPA.

Law Engineering. 1973.

Monsanto. May 21, 1985. Correspondence to U.S. EPA - Monsanto Company.

Monsanto. March 20, 1986. Correspondence to U.S. EPA - Request of Information.



Monsanto. June 29, 1995. Correspondence to ADEM.

Monsanto. July?, 1995. Correspondence to ADEM.

Monsanto. November 3, 1995. Correspondence to ADEM.

Monsanto. April \996.MonsantoCompanyAnnistonPlant, RCRA Part B Post-Closure Permit Application, April1996.

Monsanto. June 6, 1996. Correspondence to ADEM - Draft Permit Modification.

Monsanto. May 13, 1997. Correspondence to ADEM - Biphenyl Release on April 4, 1997.

Monsanto. August 7, 1997. Correspondence to ADEM.

Roux Associates. October 11, 2000. North Railroad Ditch Sediment Sampling Report, Solutia Inc. AnnistonFacility, prepared for Solutia

Roux Associates. October 11,2000. 1 ]'h Street Ditch Sediment Sampling Report, Solutia, Inc., Anniston Facility,prepared for Solutia

Sanders, Harry. November 20, 2000. Correspondence to U.S. EPA.

Scott, J. C., Harris, W. F. and R. Cobb. 1987. Geohydrology and Susceptibility of Coldwater Spring andJacksonville Fault Areas to Surface Contamination in Calhoun County, Alabama: U. 5. Geological Survey Water-Resources Investigation Report S7-4031. 29pp.

Scruggs, Opal. November 6, 2000. Correspondence to U.S. EPA.

Solutia. November 25, 1997. RF1/CS Work Plan.

Solutia. July 2, 1998. Correspondence to ADEM - Soil Excavation Placement.

Solutia. July 24, 1998. Revised Interim Measures Report.

Solutia. July 29, 1998. Correspondence to ADEM.

Solutia. July 20, 1999. Correspondence to ADEM - Action Items for Solutia Under its RCRA Post-ClosurePermit.

Solutia. January 25, 2000. Correspondence to ADEM - Review of October 1, 1999 Submittal - First Notice ofDeficiency; Regarding: Request for RCRA Activities with Remote Off-Site Residential Areas.

Solutia. February 28, 2000. Correspondence to ADEM - Bimonthly Submittal of Air Monitoring Data.

Solutia. April 26, 2000. Comments on Health Consultation Public Comment Release: Evaluation of Soil, Bloodand Air Data from Anniston, Alabama, Monsanto Co., Anniston, Calhoun County, Alabama.

Solutia. May 2, 2000. Correspondence to Agency for Toxic Substances and Disease Registry.

Solutia. October 12, 2000. Correspondence to ADEM - Request for Information on Lead use at Solutia'sAnniston Facility.

Solutia. October 20, 2000. Correspondence to ADEM - Bimonthly Submittal of Air Monitoring Data.

U. S. Dept. of Health and Human Services, Public Health Service, Agency for Toxic Substances and DiseaseRegistry. February 14, 2000. Health Consultation Public Comment Release: Evaluation of Soil, Blood and AirData from Anniston, Alabama..

U. S. Dept. of Health and Human Services, Public Health Service, Agency for Toxic Substances and DiseaseRegistry. October 4, 2000. Health Consultations No. I and No. 2 for the Evaluation of Water Quality in a PrivateWell in Anniston, Alabama.

U.S. EPA. Decembers, 1979. Potential Hazardous Waste Site Identification and Preliminary Assessment.

U.S. EPA, Region IV, RCRA and Federal Facilities Branch, Waste Management Division. September 13, 1991.RFA-RCRA Facility Assessment Report.

U.S. EPA, Environmental Response Team Center. April 6, 2000. Correspondence to U.S. EPA - Review ofENSR PCB Flux Work Plan.

U.S. EPA, Region 4, Emergency Response and Removal Branch , Removal Operations Section. April 19, 2000.Sampling and Analysis; Quality Assurance and Quality Control Work Plan for Phase III at the Anniston PCBSite, Anniston, Alabama; Residential Sampling.

U.S. EPA, Region 4, Science and Ecosystem Support Division. April 19, 2000. Review of Work Plan forEstimating PCB Vapor Flux From Two Landfills.

U.S. EPA, Region 4, Science and Ecosystem Support Division. June 21, 2000. Field Investigation Report,Anniston PCB Site, Anniston, Calhoun County, Alabama.

U.S. EPA, Region 4, Science and Ecosystem Support Division. August 10, 2000. Results of June 2000Poly chlorinated Biphenyl Ambient Air Study.

U.S. EPA, Region 4, Science and Ecosystem Support Division. August 16, 2000. Field Investigation Report:April 2000, Anniston PCB Site, Anniston, Calhoun County, Alabama.

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U.S. EPA, Region 4, Science and Ecosystem Support Division. September 5,2000. Field Investigation Report:June 2000, Anniston PCB Site, Anniston, Calhoun County, Alabama.

U.S. EPA, Region 4, Emergency Response and Removal Branch, Removal Operations Section. September 15,2000. Correspondence to Environmental Response Team - Request for Technical Assistance at the Anniston PCBSite, Anniston, Alabama, CERCLA Account No. 04S9.

U. S. EPA, Region 4, Office of Technical Services. October 2, 2000. Comments Submitted by ADEM: RFI/CSDraft Report, Solutia Inc., Anniston, Alabama - On-Site Activities.

Woodward-Clyde International-Americas. March 1998. Completion Report: South Landfill Construction,Anniston, Alabama, prepared for Solutia.

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