RECORD OF DECISION, INTERIM REMEDIAL ACTION ...11.1.4 Reduction of Toxicity, Mobility, or Volume of...

RECORD OF DECISION

INTERIM REMEDIAL ACTION

NATIONAL FIREWORKS SUPERFUND SITE

OPERABLE UNIT 2

CORDOVA, SHELBY COUNTY, TENNESSEE

PREPARED BY:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 4

ATLANTA, GEORGIA

September 2014

PART 1: THE DECLARATION

Site Name and Location i

Statement of Basis and Purpose i

Assessment of Site i

Description of Selected Remedy ii

Statutory Determinations iii

Data Certification Checklist iv

Authorizing Signature iv

PART 2: THE DECISION SUMMARY

1.0 SITE NAME, LOCATION, AND DESCRIPTION 1

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2

2.1 Operational and Regulatory History 2

3.0 COMMUNITY PARTICIPATION 3

4.0 SCOPE AND ROLE OF THE ACTION AT OPERABLE UNIT 1 WITHIN

THE SITE STRATEGY 4

5.0 SITE CHARACTERISTICS 6

5.1 Physical Characteristics of the Site 6

5.2 Topography and Drainage 7

5.3 Regional and Site Specific Geology and Hydrogeology 8

5.3.1 Site Geology 10

5.3.1.1 Structural High in Jackson Formation Clay Unit 11

5.3.2 Site Hydrology 11

5.4 Conceptual Site Model 12

6.0 NATURE AND EXTENT OF CONTAMINATION 13

6.1 Subsurface Soil 15

6.2 Groundwater 16

6.3 Sediment and Surface Water 17

6.4 Time Critical Removal Action 17

7.0 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 18

7.1 Physical Characteristics and Surrounding Land Use 18

7.1.1 Current and Future Land Use 18

7.1.2 Groundwater Use 19

8.0 SUMMARY OF SITE RISKS 19 8.1 Identification of Chemicals of Potential Concern 20

8.2 Exposure Assessment 20

8.2.1 Identification of Exposure Pathways 21

8.2.1.1 Soil 22

8.2.1.2 Groundwater 22

8.2.2 Exposure Point Concentrations 22

8.3 Toxicity Assessment 23

8.3.1 Non-Carcinogenic Effects 24

8.3.2 Carcinogenic Effects 25

8.3.2.1 Dermal Toxicity Factors 26

8.3.2.2 Toxicological Profiles 27

8.4 Risk Characterization 27

8.4.1 Summary of Risks Associated with the Construction Worker 28

8.4.1.1 Surface Soil (Onsite and Offsite) 28

8.4.1.2 Subsurface Soil 28


8.4.2 Summary of Risks Associated with Future Adult Resident 29




8.4.3 Summary of Risks Associated with Future Adult and Child

Resident 30




8.4.4 Summary of Risks Associated with a Recreational Trespasser 31

8.4.4.1 Surface Soil (Onsite and Offsite 31


8.5 Contaminants of Concern 32

8.6 Uncertainties 33

8.6.1 Uncertainties Related to Exposure Assessment 33

8.6.2 Uncertainties Related to Toxicity Information 34

8.6.3 Uncertainties Related to the Risk Characterization 35

8.7 Results of the Ecological Risk Assessment 35

9.0 REMEDIAL ACTION OBJECTIVES 36

9.1 Remedial Action Objectives 36

9.2 Cleanup Goals 37

10.0 DESCRIPTION OF REMEDIAL ALTERNATIVES 37

10.1 Common Elements to Alternatives 38

10.1.1 Applicable or Relevant and Appropriate Requirements (ARARs) 38

10.1.2 Institutional Controls 38

10.1.3 Long Term Monitoring 39

10.1.4 Five-Year Reviews 39

10.2 Detailed Description of Alternatives 39

10.2.1 Alternative 1: No Action 39

10.2.2 Alternative 2: In-Situ Treatment of Groundwater and Subsurface

Soil at Plumes C, D, and E with Long-Term Monitoring and

Institutional Controls 40

10.2.3 Alternative 3: Limited Injections/In-Situ Treatment of Groundwater

and Subsurface Soil at Plumes C, D, and E with Long-Term

Monitoring and Institutional Controls 41

10.2.4 Alternative 4: Phytoremediation of Groundwater and Subsurface


Institutional Controls 42

10.2.5 Alternative 5: Combination of In-Situ Treatment and

Phytoremediation of Groundwater and Subsurface Soil at Plumes

C, D, and E with Long-Term Monitoring and Institutional

Controls 44

11.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 45

11.1 The NCP Criteria 46

11.1.1 Overall Protection of Human Health and the Environment 46

11.1.2 Compliance with ARARs 46

11.1.3 Long-Term Effectiveness and Permanence 48

11.1.4 Reduction of Toxicity, Mobility, or Volume of Contaminants

through Treatment 49

11.1.5 Short Term Effectiveness 50

11.1.6 Implementability 51

11.1.7 Costs 53

11.1.8 State / Support Agency Acceptance 53

11.1.9 Community Acceptance 53

12.0 PRINCIPAL THREAT WASTE 54

13.0 SELECTED REMEDY 54

13.1 Rationale for the Selected Remedy 54

13.2 Description of the Selected Remedy 55

13.2.1 Institutional Controls 57

13.2.2 Five-Year Reviews 58

13.2.3 Summary of the Estimated Remedy Costs 58

13.2.4 Expected Outcomes of the Selected Remedy 58

13.2.4.1 Expected Land Use 58

13.2.4.2 Groundwater Use 59

14.0 STATUTORY DETERMINATIONS 59

14.1 Protection of Human Health and the Environment 59

14.2 Compliance with ARARs 60

14.3 Cost Effectiveness 60

14.4 Utilization of Permanent Solutions and Alternative Treatment

Technologies or Resource Recovery Technologies to the Maximum

Extent Practicable 60

14.5 Preference for Treatment as a Principal Element 61

14.6 Five-Year Review Requirement 61

14.7 Document of Significant Changes 61

REFERENCES

LIST OF FIGURES

Figure 1. Site Location Map

Figure 2. Site Layout

Figure 3. General Stratigraphy of the Site

Figure 4a. Hydrogeologic Cross Section A-A’ and B-B’

Figure 4b. Hydrogeologic Cross Section C-C’ and D-D’

Figure 5. Risk Assessment Conceptual Site Model

Figure 6. 3-Dimensional Site Conceptual Model

Figure 7. Extent of Tetrochloroethene Plume in Groundwater

Figure 8. Extent of Trichloroethene Plume in Groundwater

Figure 9. Treatment Areas that Require Phytoremediation

LIST OF TABLES

Table 1. Summary of Chemicals of Concern and Medium Specific Exposure Point

Concentrations

Table 2. Toxicity Data Summary – Carcinogens

Table 3. Toxicity Data Summary – Non-Carcinogens

Table 4. Risk Characterization Summary – Carcinogens

Table 5. Risk Characterization Summary – Non-Carcinogens

Table 6. Subsurface Soil Cleanup Levels for Protection of Groundwater

Table 7. Cleanup Levels for Groundwater

Table 8. Comparison of Remedial Alternatives Costs for OU2

Table 9. Estimated Remedy Capital Costs and Present Value Costs for Selected Remedy

at OU2

Table 10. Chemical Specific ARARs

Table 11. Action Specific ARARs

LIST OF APPENDICES

Appendix A Responsiveness Summary

Appendix B Proposed Plan Fact Sheet

Appendix C State Concurrence Letter

ACRONYMS AND ABBREVIATIONS

AR Administrative Record

ADD Average Daily Dose

AOC Administrative Settlement Agreement and Order on Consent

ARARs applicable or relevant and appropriate requirements

ATSDR Agency for Toxic Substances and Disease Registry

bgs below ground surface

bls below land surface

CDI chronic daily intake

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CERCLIS Comprehensive Environmental Response, Compensation, and Liability

Information System

CFR Code of Federal Regulations

cfs cubic feet per second

COCs Contaminants of concern

COPCs Contaminants of potential concern

CSFs Cancer slope factors

CSM Conceptual Site Model

CVOCs Chlorinated Volatile Organic Compounds

DPT direct push technology

EPA U.S. Environmental Protection Agency

EPC Exposure Point Concentrations

ERA Ecological Risk Assessment

ESI Expanded Site Inspection

EU Exposure unit

FS Feasibility Study

HHRA Human Health Risk Assessment

HI Hazard index

HQ Hazard quotient

HSA Hollow Stem Auger

ICs Institutional Controls

IR Information Repository

IRIS Integrated Risk Information System

IROD Interim Record of Decision

ISB In-situ bioremediation


ISCR In-situ Chemical Reduction

LADD Lifetime Average Daily Dose

LOAEL lowest observed adverse effect levels

LTM Long-Term Monitoring

MCL Maximum Contaminant Level

ug/kg micrograms per kilogram

ug/L micrograms per liter

MNA Monitored Natural Attenuation

MRLs Minimal Risk Levels

ng/L nanograms per liter

NCEA National Center for Environmental Assessment

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NOAEL no observed adverse effects levels

NPL National Priorities List

O&M Operation and Maintenance

OUs Operable Units

OSWER Office of Solid Waste and Emergency Response

PA Preliminary Assessment

PAHs Polynuclear aromatic hydrocarbons

PCE Tetrachloroethene

PPRTVs Provisional Peer-Reviewed Toxicity Values

ppb parts per billion

PRGs Preliminary Remedial Goal

PRPs Potentially Responsible Parties

RAOs Remedial Action Objectives

RCRA Resource Conservation and Recovery Act

RD Remedial Design

RfDs Reference doses

RME Reasonable maximum exposure

RI/FS Remedial Investigation/Feasibility Study

RME Reasonable Maximum Exposure

ROD Record of Decision

SARA Superfund Amendments and Reauthorization Act

SAS Superfund Alternative Site

SEMS Superfund Enterprise Management System


SI Site Inspection

SSI Security Signals Inc.

SSLs Soil Screening Levels

SVOCs Semi-volatile organic compounds

TBC To Be Considered

TCE Trichloroethene

TDEC Tennessee Department of Environment and Conservation

TCRA Time Critical Removal Action

UCL Upper Confidence Limit

VI Vapor Intrusion

VOCs volatile organic compounds

WWC wet weather conveyance

ZVI zero valent iron

i

DECLARATION FOR THE INTERIM RECORD OF DECISION

FOR THE NATIONAL FIREWORKS SUPERFUND SITE, OPERABLE UNIT 2

SITE NAME AND LOCATION

Site Name: National Fireworks Superfund Site, Operable Unit 2

Location: 9509 Macon Road

Cordova, Shelby County, Tennessee 38018

EPA Site

Identification Number: TNSFN0407047

The United States Environmental Protection Agency is the lead agency for the Comprehensive

Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) regulatory

response. The Tennessee Department of Environment and Conservation is the support agency.

The National Fireworks Superfund Site is not listed on the National Priorities List (NPL). The

site is being managed as a Superfund Alternative Site (SAS). A Potentially Responsible Party

(PRP) has been identified to conduct the work at Operable Unit 2.

STATEMENT OF BASIS AND PURPOSE

This decision document presents the Selected Interim Remedy for The National Fireworks

Superfund Site (Site), Operable Unit 2 in Cordova,

Shelby County, Tennessee, selected in accordance with the CERCLA of 1980, as amended by

the Superfund Amendments and Reauthorization Act (SARA) of 1986 and, to the extent

practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This

decision is based on the Administrative Record for the National Fireworks Superfund Site,

Operable Unit 2. EPA has organized the planned work into two separate operable units (OUs).

The selected interim remedy addresses the groundwater and subsurface soil contamination on the

north-central portion of the Site. The State of Tennessee, as represented by the TDEC, has been

the support agency during the remedial investigation / feasibility study (RI/FS) process for the

Site. In accordance with 40 CFR 300.430, as the support agency, TDEC has provided input

during this process. The State of Tennessee concurs with the Selected Remedy.

ASSESSMENT OF THE SITE

The response action selected in this Interim Record of Decision (ROD) for OU2 is necessary to

protect the public health or welfare, or the environment from actual or threatened releases of

hazardous substances, pollutants, or contaminants from this Site which may present an imminent

and substantial endangerment to public health or welfare, or the environment.

ii

DESCRIPTION OF THE SELECTED REMEDY

The selected interim remedy addresses contamination in both subsurface soil and

groundwater. The objectives of the remedy will be to prevent exposure to groundwater that

contains levels of site related contaminants exceeding levels that are protective of potable

uses through the use of institutional controls, and remove mass from the contaminated plume:

to minimize lateral migration of contaminated groundwater, to minimize migration of

contaminated groundwater discharging to surface water above ambient surface water quality

criteria, to minimize threats to the underlying Memphis Sand aquifer, and to reduce the long-

term leachability of contaminants from site subsurface soils into the groundwater.

The primary technology to be implemented in this selected remedy is installation of an

engineered phytoremediation network that will remove and degrade volatile organic

compounds (VOCs) in subsurface soil and groundwater. Trees woll be installed within the

footprint of Plume C, Plume D, and Plume E. The dechlorination of the chlorinated VOCs

occurs in both the root zone and in the leaves. Most of the absorbed VOCs will be transferred

in the water uptake to the leaves through the xylem (the primary vascular tissue of trees).

Patented technologies exist that promote aggressive root development to depths up to 30 feet

or more. These engineered phytoremediation systems involve developing a borehole to the

depth desired, inserting a sleeve or liner to direct root growth, then backfilling the borehole

with soil and planting the selected tree species. Within Plumes C and D, the saturated zone is

16 to 30 feet below ground services (bgs) and the soil contamination extends upward from

the top of the aquifer approximately 4 to 12 feet. Within Plume E, the saturated zone is 22 to

45 feet bgs. Trees will be planted in grids with spacing from 10 to 20 feet, with alternating

targeted root depths to fully intercept contaminant distribution in the aquifer. Similarly, trees

may also be planted in trenches to achieve desired depths. Construction techniques given the

semi-confined alluvial aquifer will need to be refined during the remedial design.

The phytoremediation remedy will require an extended period (approximately 5 years) to

achieve maturity, and during that time the phytoremediation network will be sensitive to

external stressors such as weather extremes, drought, etc. Monitoring will assess the stand’s

health over the first several years. The actual duration of monitoring necessary will be

determined during remedial design/remedial action (RD/RA) work planning.

Remedy elements include installation of the phytoremediation network, as well as ancillary

support structures (e.g., irrigation system). Preliminary treatment areas and planting densities

will be resolved during predesign activities. An estimated number of trees are given for each

of the treatment areas. The actual number of trees may increase or decrease based on the

RD. The approximate treatment areas and number of trees are described as:

Plume C — 9,900 square feet (roughly 90 feet by 110 feet) may require

approximately 100 trees

Plume D — 12,800 square feet (roughly 80 feet by 160 feet) may require


iii

Plume E — 10,000 square feet (roughly 50 feet by 200 feet may require


Long-term monitoring (LTM) of the groundwater for VOCs and monitored natural

attenuation (MNA) parameters are included as a remedial component. LTM of the surface

water will also be included as a component of this interim action. LTM of the groundwater

and surface water. Institutional controls (ICs) would be implemented to limit disturbance of

subsurface soil on portions of the property and ensure that the contaminated surficial aquifer

is not used for drinking water. Five Year Reviews will be required as a part of an interim

remedial action until the final remedy is in place. ICs (for onsite groundwater use and offsite

groundwater use), the five year review report cycle, and monitoring activities in support of

the five year review report are critical components of this remedy.

The selected remedy will protect human health and the environment through contaminant

mass removal by installation of an engineered phytoremediation network to remove and

degrade VOCs in subsurface soil and groundwater. Effectiveness of this remedy depends on

(1) access to contaminated media (below ground) and (2) efficiency of the treatment

(reductive dechlorination through phytoremediation) technologies.

STATUTORY DETERMINATIONS

The selected interim remedial action is protective of human health and the environment, and

complies with federal and state requirements that are applicable or relevant and appropriate

to the remedial action. The remedy is cost effective, and utilizes permanent solutions to the

maximum extent practicable.

This remedy satisfies the statutory preference for treatment as a principal element of the

remedy (i.e., it does reduce the toxicity, mobility, or volume of hazardous substances as a

principal element through treatment). The selected interim remedy is an engineered

phytoremediation network that will remove and degrade VOCs in subsurface soil and

groundwater.

Because this remedy will result in hazardous substances, pollutants, or contaminants

remaining on-site above levels that allow for unlimited use and unrestricted exposure, a

statutory review will be conducted within five years after initiation of remedial action to

ensure that the remedy is, or will be protective of human health and the environment.

ROD DATA CERTIFICATION CHECKLIST

1

Chemicals of Concern and Their Respective Concentrations (Table 1)

Section 8.0

2

Baseline Risk Represented by the Chemicals of Concern (Tables 4 and 5)

Section 8.4

3

Cleanup Levels Established for Chemicals of Concern and the Basis for

the Levels (Tables 6 and 7)

Section 9.2

3

4

5

6

7

Cleanup Levels Established for Chemicals of Concern and the Basis for Section 9.2 the Levels (Tables 6 and 7)

Current and Reasonably Anticipated Future Land and Groundwater Use Section 7.0 Assumptions Used in the Baseline Risk Assessment and the Interim Record of Decision

Potential Land and Groundwater Use that Will be Available at the Site as a Section 7.0 Result of the Selected Remedy

Estimated Capital, Operation and Maintenance, and Total Present Worth Section 10.0 Costs; Discount Rate; and the Number of Years Over Which the Remedy Cost Estimates are Projected (Table 1 0)

Decisive Factors that Led to Selecting the Remedy Sections 11.0 & 13.0

AUTHORIZING SIGNATURE

This Interim Record of Decision documents the selected interim remedy for Operable Unit 2 at the National Fireworks Superfund Site. This remedy was selected by the Environmental Protection Agency with concurrence of Tennessee Department of Environment and Conservation.

~~~h Superfund 1vision

Date

U.S. Environmental Protection Agency, Region 4

•

lV

DECISION SUMMARY

FOR THE

IRECORD OF DECISION

INTERIM ACTION

NATIONAL FIREWORKS SUPERFUND SITE

OPERABLE UNIT 2

Cordova, Shelby County, Tennessee

PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION 4

ATLANTA, GEORGIA

September 2014

Interim Record of Decision

National Fireworks Superfund Site September 2014

Operable Unit 2

1

RECORD OF DECISION

INTERIM ACTION

FOR THE NATIONAL FIREWORKS SUPERFUND SITE

OPERABLE UNIT 2

DECISION SUMMARY

1.0 SITE NAME, LOCATION, AND DESCRIPTION

The National Fireworks Superfund Site (Site) is located at 9509 Macon Road, in Cordova, Shelby

County, Tennessee. The Site is identified in the Superfund Enterprise Management System (SEMS)

as TNSFN0407047. The Interim Record of Decision (IROD) is issued by the U.S. Environmental

Protection Agency (EPA), the lead agency for site activities, with the concurrence of the Tennessee

Department of Environment and Conservation (TDEC), the support agency. EPA has identified

Security Signals Inc. (SSI) as the potentially responsible party who is responsible to conduct the

remediation at operable unit (OU) 2. Thus, EPA is currently handling the Site as an enforcement

lead action. Figure 1 is a site location map.

The Site is currently referred to as the Cordova Industrial Park, which has subdivided industrial lots

with numerous property owners. The industrial park encompasses an area of about 260 acres of

subdivided land. Portions of the industrial park are still under development. Dirt and paved roads

provide access throughout the industrial park. Most of the businesses currently operating at the

industrial park consist of distributors, office spaces, sales, storage space, repair facilities, and

production facilities.

The Site is located off Macon Road in Cordova, Shelby County, Tennessee. Cordova is located east

of Memphis. The Site is zoned for industrial use. The general use of the parcels surrounding the

Site are zoned for industrial, commercial, agricultural, and residential uses. The geographic

coordinates at the western entrance to the Site are latitude 35' 09' 27.06" north and longitude 89' 45'

41.63" west.

The Site is bounded on the north by Macon Road, on the east by Grays Creek Drainage Canal, on the

west by a Tennessee Valley Authority easement, and on the northwest by former CSX railroad

tracks, now owned by Shelby County for future recreational use. To the south is forested property,

which abuts a residential community.



Operable Unit 2

2

The Site has been organized into operable units (OUs) as illustrated in Figure 1. OU1 addresses the

former burn pit located on the southwestern portion of the Site. The burn pit was used to burn

materials of unknown composition. OU2 addresses the groundwater and subsurface soil

contamination on the north-central portion of the Site. OU2, is in the north-central portion of the

Site and consists of approximately 22 acres and is located south of Macon Road in Cordova,

Tennessee as illustrated in Figure 2. OU2 consists of multiple production buildings of varied

construction (cinder block, fiberboard, sheet metal) on both slab and conventional foundations. Both

asphalt and gravel drives provide access across OU2. Unpaved areas are typically grass or gravel

and are maintained. Ditches are present across this portion of the Site to ensure drainage. Multiple

unused production buildings are also present. Some buildings are used for storage and other

buildings are being refurbished. Both the southern and western portions of OU2 remain

undeveloped. Additional details regarding historical use and former property owners are provided in

the Remedial Investigation Report and the Remedial Investigation Report Addendum.

Potential future land use at OU2 is anticipated to remain as commercial/industrial. The closest

residential parcels are approximately 0.25-mile to the south, beyond the Cordova Industrial Park

development. Figure 2 is a current site layout of OU2.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.1 Operational and Regulatory History

The history of the National Fireworks Inc. (NFI) facility including OU2 dates back to World War II

when the NFI facility produced ammunition, incendiary bombs, flares and signals, smoke pots, and

blast caps/grenades. NFI was active on a 260-acre tract from February 1942 to August 1945. During

operations from 1942 to 1945, NFI buildings were spaced throughout the Site because of the

explosive nature of the products. Former employees of the former NFI facility confirmed that NFI

produced smoke pots and incendiary bombs for the Army and loaded 20 millimeter (mm) and 55 mm

shells for the Navy. Historical documents indicated that the following activities were conducted in

these identified areas on or adjacent to OU2:

Chemicals used in the manufacture of munitions were unloaded in an area around the former

NFI railroad tracks in the northern portion of the Site.

NFI buildings currently located in the northern portion of the Site were used for warehouses

and office for plant operations.



Operable Unit 2

3

NFI buildings in the north-central portion of the Site (currently owned by SSI) were used to

manufacture ammunition.

Cordova Industrial Development Company purchased the 260-acre property from NFI in 1946. SSI

leased a 20-acre tract of Site in 1948 to manufacture fuses, ignition cartridges, and other pyrotechnic

devices. In 1952, NFI leased back four of approximately sixty buildings to resume operations for the

Korean War.

SSI was established in 1948 to manufacture fuses, ignition cartridges, and other pyrotechnic devices.

After NFI vacated the Site the second time, SSI purchased approximately 11 acres from Cordova

Industrial Development on or about June 14, 1955. SSI purchased an additional acre February 18,

1969. SSI purchased approximately 10 additional acres on April 23, 1993. SSI currently owns a

total of 22 acres; however, their site operations are still limited to the eastern portion of OU2.

In 1968, SSI expanded operations in the OU2 area, to include a screw machine, parts and metal

fabrication. Since 1996, recent SSI operations have included manufacture of machined metal

products, including automotive valves, and air conditioning compressor parts from raw material bar

stock. The machined metal parts are produced in screw machines, using cutting oil as a coolant. No

pyrotechnic products have been manufactured in the OU2 area since 1997.

Tetra Tech conducted a Site Inspection (SI) in 2003 and an Expanded Site Inspection (ESI) in 2005

on the entire Site. The results from the SI and ESI identified volatile organic compounds (VOCs),

semivolatile organic compounds (SVOCs), pesticides, explosives, and inorganic constituents in soil

and groundwater at various locations across the Site. Samples collected at OU2 identified VOCs,

SVOCs (specifically polynuclear aromatic hydrocarbons [PAHs]), pesticides, and inorganics. Both

the SI and ESI reports recommended that the contamination onsite be further evaluated.

EPA entered into an Administrative Settlement Agreement and Order on Consent (AOC) with SSI

on May 18, 2007, to complete the RI/FS activities for OU2. All Remedial Investigation/Feasibility

Study (RI/FS) activities have been performed in accordance with the AOC.

3.0 COMMUNITY PARTICIPATION

Since the RI/FS activities have been ongoing at OU2, EPA has engaged in community involvement

activities to notify the public of Site activities. A public notice was published in the Commercial

Appeal notifying the public of the start of a time-critical removal action (TCRA) and notification that



Operable Unit 2

4

the Administrative Record was available on November 12, 2010. A comment period was held from

November 12, 2010 to December 13, 2010.

The Remedial Investigation/Feasibility Study (RI/FS) Report and Proposed Plan for the Site were

made available to the public August 20, 2014. Those documents along with other documents

included in the Administrative Record file are maintained in the EPA Docket Room located at EPA

Region 4 in Atlanta, Georgia, and at the Cordova Library in Cordova, Tennessee. The notice of

availability of the Proposed Plan was published in the Commercial Appeal on August 14, 2014. A

public comment period was held from August 20, 2014 to September 18, 2014. The Proposed Plan

for the remedial action at the Site was presented at the public meeting held on August 21, 2014. The

public meeting was held at the Cordova Community Center. At this meeting, representatives from

the EPA and TDEC answered questions about OU2 and the remedial alternatives.

After the public comment period ended, EPA reviewed comments received from the community as

part of the process of selecting a decision on the most appropriate remedial alternative, or

combination of alternatives, to address contamination found at the National Fireworks OU2 Site.

The comments documented in the responsiveness summary indicate that overall the community

supports the selected remedy. The public meeting had a small turnout but the attendees did ask

questions during the meeting. After the meeting, EPA also received questions from one resident via

email. All of the questions as well as EPA’s response to the comments received at the public

meeting, the public meeting’s transcript, and comments received during the public comment period

are included in the Responsiveness Summary as Appendix A in this IROD.

4.0 SCOPE AND ROLE OF THE ACTION AT OPERABLE UNIT 2 WITHIN THE

SITE STRATEGY

As with many Superfund sites, the problems are complex at the Site. EPA has organized the planned

work into two separate OUs:

OU1 addresses the former burn pit (the burn pit was used to burn materials of unknown

composition) located on the southwestern portion of the Site and other areas that may be identified in

the planned investigation. Actions, if needed, to address unacceptable risks associated with OU 1

will be selected in future decision documents.

OU2 addresses groundwater and subsurface soil contamination on the north-central portion of the

Site. The remedy selected in this document is an interim remedy for OU2.



Operable Unit 2

5

The response action for OU2 will be an interim action for the contaminated groundwater and

subsurface soil at the site. The scope of the selected remedy is intended to address only the

contaminated groundwater of Plumes C, D, and E as identified in the RI. Plumes A and B are

hydraulically upgradient of the degreaser and Plumes C, D, and E. A determination of the source of

the contamination associated with Plumes A and B could not be made based on the proximity of the

Plumes A and B to the OU2 property boundary. Additional characterization will be performed in

order to determine the origin of the contamination in the areas of Plumes A and B. Therefore, the

selected interim remedy does not address the contaminated groundwater in Plumes A and B.

In addition, the scope of this selected interim remedy addresses contaminated subsurface soil that is

present and can leach into the groundwater. The limited scope of the OU2 action is an interim action to

treat the contaminated groundwater and subsurface soil. The remaining portions of the Site will

be addressed separately under a separate response action that will be selected in future decision

documents. A final remedy to address all the groundwater plumes will be required in the future.

As described in the Human Health Risk Assessment, contact with the Contaminants of Concern

(COCs) present in the groundwater in specific areas of the Site pose an unacceptable risk to human

health because concentrations of contaminants are present in media (groundwater and subsurface

soil) above the 1x10-6 cancer risk or a hazard index of 1 and above federal and state groundwater

standards. The Selected Interim Remedy for OU2 is necessary to protect public health or welfare or

the environment from actual or threatened releases of hazardous substances into the environment.

The results of the groundwater sampling indicate that chlorinated volatile organic compounds

(CVOCs) are present in groundwater at concentrations that indicate that the vapor intrusion may be a

pathway of potential concern. Vapor intrusion (VI) may be a concern near Plumes C, D, and E,

given subsurface soil contamination. VI will be fully evaluated as a separate investigation under

the existing AOC at OU2. Actions to address unacceptable risks associated with soil vapor

intrusion, if needed, will be selected in a future decision document.

Results of a fate and transport empirical model indicated that several constituents exhibit the

potential to leach and migrate between subsurface soil and groundwater. The levels of contaminants in

the subsurface soil pose a threat to the groundwater and can act as a source of contamination to leach

into the groundwater resulting in groundwater concentrations exceeding the federal and state MCLs.

T he primary constituents which pose a threat to multiple media are the CVOCs, as the potential exists

for multiple cross-media transfers between parent products tetrachloroethylene (PCE) and subsequent



Operable Unit 2

6

degradation products. Therefore, soil screening levels (SSLs) of subsurface contaminants for

protection of groundwater were calculated.

As discussed in the Ecological risk assessment (ERA), no unacceptable risk was indicated for aquatic

flora and fauna based on comparisons of contaminant concentrations in surface water and sediment to

media-specific screening values. No unacceptable risk was indicated for upper trophic level

aquatic receptors (mammals and birds) based on the lack of bioaccumulative chemicals in surface

water and sediment. Finally, no unacceptable site-related risk was indicated for upper trophic level

terrestrial receptors (mammals and birds) based on the refined food web evaluation. More detailed

discussion of the ERA and risk calculations are found in Section 7.0 of the RI.

Site-specific remedial action objectives (RAOs) have been developed to address unacceptable risks at

this Site, and discuss which exposure routes are to be addressed through the remedial action in order

to prevent exposure to site contaminants. The RAOs are further described in detail in Section 9.1 of

this ROD.

5.0 SITE CHARACTERISTICS

5.1 Physical Characteristics of the Site

The Site is currently called the Cordova Industrial Park, which has subdivided industrial lots with

numerous property owners. The industrial park encompasses an area of about 260 acres of






of Memphis. The 260 acres that make up the site are all zoned for industrial use. The general use of

the parcels surrounding the Site are zoned for industrial, commercial, agricultural, and residential

uses. The Site is bounded on the north by Macon Road, on the east by Grays Creek Drainage Canal,

on the west by a Tennessee Valley Authority easement, and on the northwest by former CSX railroad



The portion of the Site referred to as OU2 is owned and operated by SSI and is located in the north



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7

central part of the Site as illustrated in Figure 2. OU2 consists of multiple production buildings of

varied construction (cinder block, fiberboard, sheet metal) on both slab and conventional

foundations. Both asphalt and gravel drives provide access across OU2. Unpaved areas are typically

grass or gravel and are maintained. Ditches are present across this portion of the Site to ensure

drainage. Multiple unused production buildings are also present. Some buildings are used for storage

and other buildings are being refurbished. Both the southern and western portions of OU2 remain

undeveloped.



development.

5.2 Topography and Drainage

The Site is bordered to the east by Grays Creek. The topography of OU2 is flat; however, the former

NFI facility consisted of rolling hills. Since operations began in the 1940s, most of the facility has

been leveled for redevelopment. A Memphis Press-Scimitar article dated March 16, 1961, indicated

“dozers… leveled off the hilly countryside, moving the fresh earth into low spots.”

The eastern portion of the Site, which includes OU2, appears to have been constructed along the

floodplain of Grays Creek Drainage Canal. Storm water drainage has been a recurrent problem at

OU2, as it historically received overland flow from the west and northwest. Drainage is managed via

drainage ditches/wet weather conveyances (WWCs) across the newly developed areas of the Site and

appears to be channeled to storm sewers immediately behind the screw machine building and at the

southeast corner of the OU2 area. Grays Creek Drainage Canal flows north northwest and turns

south to southwest before reaching its confluence with the Wolf River, which is approximately 4

miles downstream of Macon Road.

Surface water discharges from the Site occur in three ways:

Onsite, via WWCs on OU2, and then via culverts to Grays Creek Drainage Canal. The

WWCs/culverts which drain the developed portions of the OU2/SSI property flow due east:

one along the southern edge of Macon Road, and one generally east of the degreaser

building/screw machine building. WWCs on OU2 are maintained to ensure drainage to the

culverts. Overland flow from undeveloped portions of OU2 is expected to be minimal, given

vegetation and topography.



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Via groundwater-to-surface water discharge, as interpolated from subsurface lithology. The

alluvial/fluvial water bearing units increase in thickness to the east, towards Grays Creek

Drainage Canal. A comparison of stream bed elevations and top of clay elevations suggests

that the alluvial/fluvial unit discharges into Grays Creek Drainage Canal.

Offsite via networks of storm drains (along Big Orange Road and Cordova Park Road) and

drainage ditches along the southern property boundary.

5.3 Regional and Site Specific Geology and Hydrogeology

The site is in the north-central part of the Mississippi Embayment, a broad structural trough or

syncline that plunges southward along an axis approximating the Mississippi River (Cushing et. al.

1964). This syncline is filled with a few thousand feet of unconsolidated sediments that make up

formations of Cretaceous, Tertiary, and Quaternary age. The sediments consist primarily of sand,

clay, gravel, silt, and some lignite. These formations dip gently westward into the embayment and

southward down the axis. Overlying the Cretaceous and Tertiary formations in many areas are the

fluvial deposits (terrace deposits), loess, and alluvium of Tertiary and Quaternary age.

Discussions of the area hydrogeology are restricted to post-Wilcox strata because the Memphis

aquifer is confined regionally at its base by the Flour Island Formation, the uppermost formation in

the Wilcox Group. This confining unit, which generally consists of fine-grained sediments, decreases

the vulnerability of deeper zones to contamination from above. Figure 3 illustrates the relationships

between the various major hydrogeologic units.

The alluvium of the Mississippi Alluvial Plain and alluvial plains of streams that drain the Gulf

Coastal Plain consists primarily of fine sand, silt, and clay in the upper portion, and sand and gravel

in the lower portion. The alluvium ranges from 0 to 175 feet thick, and is commonly 100 to 150 feet

thick beneath the Mississippi Alluvial Plain and less than 50 feet thick beneath the alluvial plains of

major streams draining the Gulf Coastal Plain. The alluvium supplies water to many domestic, farm,

industrial, and irrigation wells in the Mississippi Alluvial Plain. Where present, the alluvium is part

of the surficial aquifer.

Loess, eolian in origin, consists of a blanket-type silt deposit draped over Loess, eolian in origin,

consists of a blanket-type silt deposit draped over existing topography developed on underlying units.

Loess is characterized by very fine angular particles of uniform composition. Loess has a

characteristic vertical grain that promotes steep bluffs. The upper three loess units correlate with the

Peoria, Farmdale, and Loveland loess sheets of Illinois. A fourth unit that underlies the others is a



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thin clayey and darker deposit classified as pre-Loveland. The loess is underlain by fluvial deposits

that occur locally near the study area, typically characterized by a red or brown sand and gravel.

Some of the sandy and argillaceous silt on the lower slopes is reworked and could be included in

fluvial deposits, but no practical distinction can be made for geologic mapping purposes. Loess is

locally thin or absent where eroded and uncommonly thick where accumulated. The loess is a

significant impediment to the downward migration of water due to its massive structure of tight

interbedded silts and clays.

The fluvial deposits, which are beneath the uplands and valley slopes of the Gulf Coastal Plain,

consist primarily of sand, gravel, and minor clay lenses. Locally, the sand and gravel is cemented

with iron oxide to form thin layers of ferruginous sandstone or conglomerate generally in the lower

or basal parts of the units. The fluvial deposits range up to 100 feet thick in the Memphis area.

Thickness varies because of erosional surfaces at both the tops and bases of the units. The fluvial

deposits provide water to many domestic and farm wells in rural areas of the Gulf Coastal Plain.

The Jackson Formation, once thought to constitute most of the thickness of the confining unit

separating the surficial aquifers from the Memphis aquifer, occurs only beneath the higher hills and

ridges in the northern part of the Memphis area. The Jackson Formation is included here in the

descriptions of the Jackson-Upper Claiborne confining unit. The Cockfield Formation occurs in the

subsurface in most of the western part of the Memphis area, and extends eastward to the limits of the

Jackson-Upper Claiborne confining unit. The Cockfield Formation consists of interfingering fine

sand, silt, clay, and local lenses of lignite. The unit ranges up to 250 feet thick. In most of the

Memphis area, the Cockfield Formation is an erosional remnant, and the original thickness is

preserved only beneath the higher hills and ridges of Shelby County. The discontinuous and

interconnected sands of the Cockfield Formation constitute a regional aquifer in some parts of the

area of occurrence in Tennessee, Kentucky, Missouri, Arkansas, Louisiana, Texas, and Mississippi.

In the Memphis area, the Cockfield Formation generally is dominated by fine sediments, but may

contain thicker, coarser sands in some areas. Consequently, the formation has been included in the

Jackson-Upper Claiborne confining unit for work conducted by the U.S. Geological Survey in the

Memphis area. A few domestic wells in the Memphis area are screened in sands in the Cockfield

Formation. The Cook Mountain Formation occurs in the subsurface of most of the Memphis area,

extending eastward to the approximate eastern limits of the Jackson-Upper Claiborne confining unit.

The Cook Mountain Formation consists primarily of clay, but locally it contains varying amounts of

fine sand. The formation ranges from approximately 30 to 150 feet thick in the Memphis area, but it

is commonly approximately 60 to 70 feet thick. The Cook Mountain Formation is a regional



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10

confining unit overlying the Memphis Sand in Tennessee, Missouri, and northeastern Arkansas and

the Sparta Sand in Kentucky, southern Arkansas, Louisiana, and Mississippi. The Site’s regional

stratigraphy is shown in Figure 3.

5.3.1 Site Geology

Site-specific geologic information was obtained from subsurface exploration using direct push

technology (DPT) and during monitoring well installation using a hollow stem auger (HSA) during

the RI. Lithologic logging performed during these investigations extended to a maximum depth of

15 feet into the clay unit. Boring logs are provided as Appendix E of the RI.

Yellowish-brown clayey silt was encountered from ground surface to a depth of between 12 to 28

feet bgs across the Site and is typical of reworked loess in the Memphis area. A transition zone

consisting of clayey silt with sand is encountered below the reworked loess, ranging from

approximately 2 to 7 feet in thickness. This transition zone is encountered site wide except for areas

around monitoring wells SS-GW-02 and SS-GW-03 and temporary monitoring well TW-10. The

transition zone is underlain by an intermittent water bearing clayey sand and/or silty sand unit. These

two units are not present sitewide and vary in thickness from 0 to 8 feet. A water-bearing sand/silty

sand with some gravel unit was encountered beneath the clayey sand and/or silty sand. As shown in

Figures 3-2 and 3-3, the sand/silty sand with some gravel unit varies in thickness across the Site from

zero feet in the northwest section of the Site to ten feet thick east of the Site along Grays Creek

Drainage Canal. Beneath this unit is an intermittent water-bearing gravel with clayey sand unit in the

northwest section of the Site ranging in thickness from 2 to 4 feet and a water-bearing sand and

gravel unit to the south/southeast of the Site ranging in thickness from 3 to 4 feet. In general, water-

bearing sands and gravels are not present in the west/northwest section of the Site. Thickness of the

water-bearing units increases on the east side of the Site and towards Grays Creek Drainage Canal.

The sand and gravel units have an abrupt contact with the underlying clay unit, suspected to be the

upper portion of the Jackson Formation/Upper Claiborne. Elevation data show the clay generally

dipping to the east. The clay was encountered at all locations that penetrated to the base of the sand

and gravel units.

Borings for monitoring wells MW-5, MW-6, and MW-7 were advanced 15 feet into the Jackson

Clay to verify a minimum thickness and competency of the clay. This was done to ensure the clay

unit was providing adequate protection of the underlying Memphis Sand (regional aquifer) from any

downward contaminant migration. During the SI, another boring for monitoring well SS-GW-22,

was also advanced 15 feet into the Jackson Clay. Borings for monitoring wells MW-5, MW-6, MW-

7, and SS-GW-22 confirmed a thickness of at least 15 feet for the unit beneath the Site. The unit was



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11

not penetrated at any location during boring advancement to prevent any potential pathways into the

underlying Memphis Sand.

Twenty-one additional borings have also been advanced across the Site which “tagged” the top of the

Jackson Clay. These borings were advanced to various depths within the unit based on site geology

and drilling techniques. Given the number of locations where the clay was encountered, the spatial

distribution of the locations, and the minimum thickness of 15 feet, the data suggest that the clay is a

continuous confining unit beneath the Site and surrounding area. There does not appear to be any

breaches/pathways to the underlying Memphis Sand. These findings, as well as a more detailed

summary of the regional extent of the Jackson Clay, were summarized in the Jackson Clay Confining

Unit Memorandum date August 2012, and are included in Appendix K of the RI.

5.3.1.1 Structural High in Jackson Formation Clay Unit

The upper clay contact appears to show a structural high feature trending across the western portion

of the Site which may impact groundwater and contaminant migration; orientation of the structural

high appears to be approximately north/northeast-south/southeast and dipping to the east/southeast

through the western/central portion of the SSI property. In general, the structural high feature

coincides with the absence of water-bearing sand and gravels underlying this portion of the Site.

Two sets of geologic cross sections were created A-A’ and B-B’ and C-C’ and D-D’. A map view

of these cross sections are presented as Figure 4a and 4b. The A-A’ and B-B’ cross section, Figure

4a generally runs east-west across the Site and the C-C’ and D-D’ cross section, Figure 4b generally

runs northeast-southwest across the Site.

5.3.2 Site Hydrology

The Memphis Sand aquifer supplies approximately 95 percent of the water used in the Memphis area

for municipal and industrial water supplies. The drinking water in the area is provided by municipal

wells served by Memphis Light Gas and Water. The closest municipal well field is the Shaw well

field located approximately 1 – 2 miles from the Site. The aquifer is encountered approximately 120

feet below ground surface (bgs) in Cordova, Tennessee. In the site vicinity, groundwater flow in the

Memphis Sand aquifer is greatly influenced by cones of depression created by the surrounding

municipal wellfields. Recharge to the aquifer generally occurs from precipitation along the outcrop

belt, where it is at or near the surface or where the Jackson-Upper Claiborne confining unit is thin or

absent, thereby allowing downward infiltration to occur. Where the aquifer is confined and head

differences are favorable, a recharge component locally enters the Memphis Sand aquifer by

downward leakage from the surficial aquifer or the Jackson-Upper Claiborne confining unit.



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According to the Rules set forth in TDEC and the Tennessee Water Quality Control Board, General

Water Quality Criteria, Chapter 1200-04-03-.07, titled Groundwater Classification, specifically

Section, 1200-04-03-.07(4)(b) states the following,

“Except for groundwater in areas that have been designated as Special Source Water, Site

Specific Impaired Groundwater, or meet the definition of Unusable Groundwater, all groundwater is

designated General Use Groundwater.” The rule further states in Section 1200-04-03-.08(2),

“Except for naturally occurring levels, General Use Groundwater: (a) shall not contain

constituents that exceed those levels specified in Rules 1200-04-03-.03(1)(j) and (k); and (b) shall

contain no other constituents at levels and conditions which pose an unreasonable risk to the public

health or the environment.”

Therefore, based on the state of Tennessee’s groundwater classification all aquifers not otherwise

characterized are “general use” and should be maintained for their most stringent use, which is

drinking water use. This general use groundwater determination is applicable to the contaminated

surficial aquifer.

5.4 Conceptual Site Model

The conceptual site model (CSM) for the Site incorporates information on the potential chemical

sources, affected media, release mechanisms, routes of migration, and known or potential human

receptors. The purpose of the CSM is to provide a framework with which to identify potential

exposure pathways occurring at the Site. Information observed during the site visit and presented in

the RI Report was used to identify potential receptors and exposure pathways at the Site. The CSM

for the Site is presented in Figure 5. As shown in the CSM, human receptors include future

residents, industrial workers, construction workers, and recreational users. Based on current zoning,

intended land use, and other site-specific conditions, many of these scenarios are unlikely. Potential

releases at the site are expected to be surface spills or through the septic fields. Contaminants could

possibly migrate through the subsurface soil and impact groundwater, and shallow groundwater may

eventually discharge to Grays Creek Drainage Canal. The exposure assessment is detailed below.

Contaminant sources, releases mechanisms, and migration pathways are also presented in the CSM

diagram in Figure 5.

An exposure pathway consists of four elements: (1) a source and mechanism of chemical release; (2)

a retention or transport medium (or media in cases involving media transfer of chemicals); (3) a

point of potential human contact with the contaminated medium; and (4) an exposure route (e.g.,



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13

ingestion) at the contact point (EPA, 1989). When all of these elements are present, the pathway is

considered complete. The assessment of pathways by which human receptors may be exposed to

Contaminants of Potential Concern (COPCs) includes an examination of existing migration

pathways (i.e. soil) and exposure routes (i.e., ingestion, inhalation, and / or dermal absorption), as

well as migration pathways that may be reasonably expected in the future.

As shown in the CSM, human receptors at OU2 include current and future SSI employees (industrial

workers), as well as hypothetical construction workers. No groundwater exposure has been identified

at this time. However, groundwater exposure pathways were included in this risk assessment to

document potential future risks. Residential land use was included to document whether potential for

unacceptable risks will exist in the future. Current and anticipated future receptors evaluated

included children and adults using the area for recreational purposes. Based on the understanding of

the fate and transport of contaminants and the potential for human contact, the following media /

receptors were examined in the risk assessment and are addressed in this IROD:

Future Residents,

Current and Future industrial workers,

Future Construction workers, and

Recreational users.

Potentially complete exposure pathways examined in the risk assessment that are addressed in this

IROD include:

Dermal contact with subsurface soil,

Incidental ingestion of subsurface soil,

Inhalation of dust associated with subsurface soil,

Ingestion of groundwater,

Dermal contact with groundwater, and

Inhalation of volatiles, released from groundwater while showering.

6.0 NATURE AND EXTENT OF CONTAMINATION

The RI was conducted The RI was conducted from 2008 to 2013. The RI identified types, quantities,

and locations of contaminants and the FS developed alternatives to address the contamination. The

sampling events were grouped into phases based on the dates samples were collected.



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14

Phase I Investigation, 2008

Phase II Investigation, 2009

Time Critical Removal Action, 2010 through 2011

Phase III Investigation, 2011

Supplemental Sampling 2012


Phase I activities focused on identifying the nature of contamination across five areas of potential

concern. The Phase I investigation identified five areas of potential concern, and confirmed that

VOCs were the contaminants of potential concern. Subsequent phases of the RI (Phase II and Phase

III) were focused investigations which targeted the five areas. The site conceptual model (SCM)

identifies three areas on the SSI parcel where chlorinated solvents appear to have been released

(Plume C, Plume D, and Plume E). The sources of contamination depicted in the SCM for Plume A,

B1, and B2, have not been identified. Full characterization of the contamination will be completed

in order to fully determine the source of the contamination. All of the plumes are identified in Figure

6, 3-Dimensional Site Conceptual Model.

Plume A — trichloroethylene (TCE) in groundwater; source of contamination is unknown;

the location is upgradient relative to main SSI operations area Monitoring Well (MW) -7

Plume B — TCE in groundwater; source of contamination is unknown; the location is

upgradient relative to main SSI operations area (MW-1)

Plume C is near the former degreaser on the eastern portion of OU2. Deep soil and

groundwater contamination immediately to the east of this plume suggests the possibility of

overland flow of chlorinated solvents along a ditch (Plume D). Tetrachloroethene (PCE)

and degradation products in soil and groundwater from former degreaser area at SSI

operations area

Concentrations in groundwater near Plume D are within the same order of magnitude as

concentrations near MW-04 (adjacent to Plume C, near the degreaser). Detected

concentrations along the ditch decrease to the east. PCE and degradation products, and

1,1,1-trichloroethane (TCA) degradation products exist in soil and groundwater underlying

the ditch east of degreaser building



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15

Concentrations in Plume E are slightly lower than at the concentrations associated with

Plumes C and D, and may represent a source area unique to Building SSI-15, although no

soil source has been found. PCE source near former Building 15 concrete foundation pad

6.1 Subsurface Soil

Subsurface soil samples were collected from borings advanced using hand auger, DPT, or HSA

sampling techniques between 2008 and 2013. Subsurface soil contamination is generally attributed

to the degreaser source area (Plume C). Residual subsurface soil contamination is typically

encountered at depth of 16 feet bgs on the order of 1 to 5 mg/kg (total VOCs), with higher

concentrations immediately above the water bearing alluvial unit encountered approximately 20 to

25 feet bgs. Contamination within the degreaser area is present within the entire soil column.

Residual subsurface soil contamination has not been identified on the OU2 property except for the

area of VOC-contaminated soil at depth near the former degreaser associated with Plumes C and D.

An empirical fate and transport evaluation was conducted on the subsurface soil-to-groundwater

pathway. The evaluation indicated that empirically, several constituents exhibit the potential to leach

and migrate between subsurface soil and groundwater. However, the primary constituents which

pose a threat to multiple media are the CVOCs, as the potential exists for multiple cross-media

transfers between parent products (PCE) and subsequent degradation products. Therefore, SSLs of

subsurface contaminants for protection of groundwater were calculated. A more detailed discussion

of the subsurface soil cleanup levels for protection groundwater are given in Section 9.2 of the

IROD.

6.2 Groundwater

The groundwater collected during Phase I, II, and III investigations indicate the presence of multiple

groundwater contamination plumes. TCE and PCE are the two primary contaminants on the OU2

property with the daughter products cis-1,2-DCE, 1,1-dichloroethene (1,1-DCE), and vinyl chloride

also present above their federal MCLs. The MCL is a federal standard and the maximum

permissible level of a contaminant in water which is delivered to any user of a public water system.

The source of the PCE and TCE groundwater contamination for Plumes C, D, and E results from the

use of both solvents to clean parts onsite. Machined metal parts were cleaned to remove residual

cutting oils using a vapor degreasing unit (degreaser) containing TCE or reclaimed TCE from 1986

to 2006. The degreaser was attached to a distillation unit used to reclaim spent TCE. The use of other

solvents, including PCE, is documented in the RI Report.



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The former degreaser is located in the area of Plume C. Plume C sits along the base of the structural

high observed in the top of the Jackson Clay. This feature has a general north/south orientation. PCE

contamination appears to move to the east and south/southeast away from this source area.

Movement of the PCE contamination from the degreaser to the east appears to have been influenced

by the WWC, area (Plume D). Historical flooding of the degreaser building also carried

contaminants away from the source (degreaser) to the east along the ditch. The following

summarizes the results from the most recent groundwater sampling events conducted in 2012 and

2013:

PCE

PCE exceeded its federal MCL (5 ug/L) in five of the nine monitoring wells. Exceedances ranged

from 46.4 μg/L in monitoring well MW-5 in the southeastern portion of OU2 to 9,440 μg/L in

monitoring well MW-4 near the former degreaser (Plume C).

TCE

TCE exceeded its federal MCL (5 ug/L) seven of the nine monitoring wells. Exceedances ranged

from 14.5 μg/L in monitoring well SS-GW-02 in the central portion of OU2 to 645 μg/L in

monitoring well MW-7 at the westernmost OU2 property boundary (Plume A).

Cis-1,2-DCE

Cis-1,2-DCE exceeded its federal MCL (70 ug/L) in two of the nine monitoring wells. Exceedances

ranged from 236 μg/L in monitoring well MW-4 near the former degreaser to 1,240 μg/L in

monitoring well SS-GW-01 in the northwestern portion of OU2 (Plume B2).

1,1-DCE

1,1-DCE exceeded its federal MCL (7 ug/L) in one of the nine monitoring wells, monitoring well

MW-5 at 46.7 μg/L in the southeastern portion of OU2 (downgradient from Plume E).

Vinyl chloride

Vinyl chloride did not exceed its federal MCL (2 ug/L) in any of the onsite monitoring wells during

the August 2013 event. However, vinyl chloride exceeded its MCL in two of the eight monitoring

wells during the August 2012 sampling event. Vinyl chloride was detected at 70 μg/L in monitoring

well MW-1 in the northwestern portion of OU2 (Plume B2) and at 22 μg/L in monitoring well MW-

4 near the former degreaser (Plume C).



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6.3 Sediment and Surface Water

Eight locations were selected in Grays Creek Drainage Canal and in the ditch to the south of the

Cordova Industrial Park for sediment and surface water samples. TCE was detected in three of the

eight sediment samples. All of these detections are in the ditch to the south of the Site.

Concentrations ranged from 0.0018 mg/kg to 0.041 mg/kg. Cis-1,2-DCE was also detected in two

samples at 0.00078 mg/kg (GC03) and 0.0023 mg/kg (GC08).

Surface water samples collected at the same locations as the sediment samples did contain VOCs,

some above water quality criteria. Specifically, TCE exceeded TDEC surface water criteria (25 ug/L)

at three locations, ranging from 42 μg/L to 230 μg/L in the ditch south of the industrial park. PCE

exceeded TDEC surface water criteria (6.9 ug/L) in one sample at 15 ug/L.

6.4 Time Critical Removal Action

As part of the Phase I investigation, a geophysical investigation was completed in Screening Area

A, the grassy area south of Building 10. The survey identified five anomalies (L1, Al, B1, B2, and

Cl). After Phase II of the RI, a TCRA was performed in 2010 and 2011 at Anomalies B1 and B2.

The objective of TCRA was to excavate contaminated soil and debris (Anomaly B1) and live pin

flares (Anomaly B2) and send offsite for disposal.

Anomaly B1 was determined to be an area of waste disposal. The debris included stainless steel pipe

and other metals products. Visual and olfactory evidence of contamination was identified as the

trench exposed the waste area. Various metals, SVOCs, and pesticides were detected in soil. A

removal action was recommended to address this waste disposal area. The dimensions of the

excavation at Anomaly B1 were 43 feet by 31 feet by 11 feet. Approximately, 745 tons of soil and

debris were excavated from Anomaly B1. The disturbed area was restored to its original condition on

February 15, 2011.

Anomaly B2 was determined to be buried live pin flares. The pin flares were observed to be in good

condition. One soil sample was collected beneath the flares. SVOCs and pesticides were detected in

soil. A removal action was recommended to address this waste disposal area. The pin flare removal

action was conducted in two phases, at Anomaly B2. The initial phase began December 2010 and

the second phase was completed July 2011. The approximate excavation dimensions were 625

square feet by 4 feet. The excavated area was backfilled with sifted soil from the excavation on

August 4, 2011, and restored to original conditions. Based on evidence discovered from the

excavation with the pin flares the labels on the pin flares indicated three lots, with each lot typically

containing 2,500 flares. An approximate 7,500 pin flares were packaged and shipped according to



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DOT requirements and transported offsite for disposal.

7.0 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES

The Site is currently called the Cordova Industrial Park, which has subdivided industrial lots with


subdivided land. Portions of the industrial park are still under development. Most of the businesses

currently operating at the industrial park consist of distributors, office spaces, sales, storage space,

repair facilities, and production facilities.

7.1 Physical Characteristics and Surrounding Land Use

The site property is zoned for industrial use. The general use of the parcels surrounding the Site are

zoned for industrial, commercial, agricultural, and residential uses. The Site is bounded on the north

by Macon Road, on the east by Grays Creek Drainage Canal, on the west by a Tennessee Valley

Authority easement, and on the northwest by former CSX railroad tracks, now owned by Shelby

County for future recreational use. To the south is forested property, which abuts a residential

community.

The portion of the Site that is referred to as OU2 and owned and operated by SSI and is located in the

north central part of the Site as illustrated in Figure 2. OU2 consists of multiple production buildings

of varied construction (cinder block, fiberboard, sheet metal) on both slab and conventional

foundations. Both asphalt and gravel drives provide access across OU2. Unpaved areas are typically

grass or gravel and are maintained. Ditches are present across this portion of the Site to ensure

drainage. Multiple unused production buildings are also present. Some buildings are used for storage

and other buildings are being refurbished. Both the southern and western portions of OU2 remain

undeveloped. Additional details regarding historical use and former property owners are provided in

the Remedial Investigation Report and the Remedial Investigation Report Addendum.

7.1.1 Current and Future Land Use

The Site is zoned as industrial. Cordova appears to be a relatively prosperous community with

significant new commercial and residential construction completed and underway. Potential future

land use at OU2 is anticipated to remain as commercial/industrial. The closest residential parcels are

approximately 0.25-mile to the south, beyond the Cordova Industrial Park development.



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7.1.2 Groundwater Use

The Memphis Sand aquifer supplies approximately 95 percent of the water used in the Memphis area

for municipal and industrial water supplies. The drinking water in the area is provided by municipal

wells served by Memphis Light Gas and Water. The closest municipal well field is the Shaw well

field located approximately 1 – 2 miles from the Site. The aquifer is encountered approximately 120

feet bgs in Cordova, Tennessee. In the site vicinity, groundwater flow in the Memphis Sand aquifer

is greatly influenced by cones of depression created by the surrounding municipal wellfields.

Recharge to the aquifer generally occurs from precipitation along the outcrop belt, where it is at or

near the surface or where the Jackson-Upper Claiborne confining unit is thin or absent, thereby

allowing downward infiltration to occur. Where the aquifer is confined and head differences are

favorable, a recharge component locally enters the Memphis Sand aquifer by downward leakage

from the surficial aquifer or the Jackson-Upper Claiborne confining unit.



Section, 1200-04-03-.07(4)(b) states the following,

“Except for groundwater in areas that have been designated as Special Source Water, Site

Specific Impaired Groundwater, or meet the definition of Unusable Groundwater, all groundwater is

designated General Use Groundwater.” The rule further states in Section 1200-04-03-.08(2),

“Except for naturally occurring levels, General Use Groundwater: (a) shall not contain

constituents that exceed those levels specified in Rules 1200-04-03-.03(1)(j) and (k); and (b) shall

contain no other constituents at levels and conditions which pose an unreasonable risk to the public

health or the environment.”

Therefore, based on the state of Tennessee’s groundwater classification all aquifers not otherwise

characterized are “general use” and should be maintained for their most stringent use, which is

drinking water use. This general use groundwater determination is applicable to the contaminated

aquifers.

8.0 SUMMARY OF SITE RISKS

As part of the RI, a human health risk assessment (HHRA) and ecological risk assessment (ERA)

were prepared for the OU2 portion of the Site. The risk assessments evaluated risks to human and

ecological populations who may be exposed to chemicals present in the surface soil, subsurface soil,



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groundwater, sediment, and surface water under current and future conditions. The risk evaluation

involved consideration of the future residential land use scenario, the current land use (which is

industrial), and recreational use. Receptors evaluated included resident, industrial worker,

construction worker, and trespasser.

The HHRA and ERA estimate what risks the Site poses if no action is taken. The risk assessment

provides the basis for taking action and identifies the contaminants and exposure pathways that need

to be addressed by the remedial action.

The risk assessments provide the basis for taking action and identify the contaminants and exposure

pathways that should be addressed by the selected remedy. Although, the risks have been quantified

for all the contaminated media (subsurface soil, groundwater, sediment, and surface water), this

ROD will only address unacceptable risks associated with subsurface soil that pose a threat to

groundwater due to leachability and unacceptable risks to groundwater. This section of the IROD

summarizes the results of the HHRA for this Site.

8.1 Identification of Chemicals of Potential Concern

Carcinogenic and non-carcinogenic COCs are a subset of the site-related chemicals that were carried

through the risk assessment. COCs are COPCs that significantly contribute to a pathway in a use

scenario for a receptor that exceeds a 10-4 total carcinogenic risk or exceeds a hazard index (HI) of 1.

The carcinogen trigger represents the summed risks to a receptor considering all pathways, media,

and routes per land use scenario. The HI represents the total of the Hazard Quotients (HQs) of all

COPCs in all pathways, media, and routes to which the receptor is exposed. Chemicals are not

considered as significant contributors to risk, and therefore not identified as COCs, if their individual

carcinogenic risk contribution is less than 1x10-6 and their non-carcinogenic HQ is less than 0.1.

The risk assessment discussion in Section 8.0 of the IROD is limited to the receptors and media of

concern addressed in OU2, which includes industrial worker exposed to groundwater and child and

adult residents exposed to groundwater. The media and the exposure routes associated with these

receptors result in the greatest potential risk.

8.2 Exposure Assessment

An exposure assessment identifies pathways whereby receptors may be exposed to site contaminants

and estimates the frequency, duration, and magnitude of such exposures. The exposure assessment

process involves four main steps:



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Characterization of the exposure setting,

Identification of the exposure pathways,

Quantification of the exposure, and

Identification of uncertainties in the exposure assessment.

8.2.1 Identification of Exposure Pathways

An exposure pathway links a source or contaminated medium to an exposed individual or receptor.

Exposure pathways are identified based on the location and nature of the contaminated media and the

types and patterns of human activity. To complete a pathway, a source, affected medium, point of

contact, and effective exposure route all must exist. An exposure pathway consists of four

elements: (1) a source and mechanism of chemical release; (2) a retention or transport medium (or

media in cases involving media transfer of chemicals); (3) a point of potential human contact

with the contaminated medium; and (4) an exposure route (e.g., ingestion) at the contact point.

When all of these elements are present, the pathway is considered complete. The assessment of

pathways by which human receptors may be exposed to COCs includes an examination of existing

migration pathways (i.e. soil) and exposure routes (i.e., ingestion, inhalation, and / or dermal

absorption), as well as migration pathways that may be reasonably expected in the future. The

sources of contamination at SSI are discussed in Section 6 of the IROD. For the HHRA, it was

assumed that some exposure pathways will be incomplete.

Figure 5 shows the CSM for the Site. As shown in the CSM, human receptors at OU2 include current

and future SSI employees (industrial workers), as well as hypothetical construction workers. No

groundwater exposure has been identified at this time. However, groundwater exposure pathways

were included in this HHRA to document potential future risks and that there is an expectation that

groundwater should be restored to beneficial use, in this case drinking water purposes. Residential

land use was included to document potential for unacceptable risks in the future, based on

Tennessee’s regulation that all water is “general use” water and should be maintained for their most

stringent use. Current and anticipated future receptors evaluated included children and adults using

the area for recreational purposes. The only risks and hazards presented in this IROD are those

posed by media that will be addressed by the selected interim remedy for OU2. These potential risks

and hazards result from current or future exposure to onsite and offsite surface soils, onsite

subsurface soils, and groundwater. Potentially exposed receptors include:

Adult and Child Residents,

Industrial workers,

Construction workers, and



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Recreational trespassers.

8.2.1.1 Soil

Soil types screened includes onsite surface soil, onsite subsurface soil, offsite surface soil, and offsite

subsurface soil. As previously discussed, no COPCs were identified in offsite subsurface soil.

Consequently, the soil exposure routes apply to onsite surface soil, onsite subsurface soil, and offsite

surface soil, which were evaluated as separate exposure units. HHRA exposure routes generally

consist of ingestion, dermal contact, and inhalation. Exposure routes evaluated in the HHRA

included the following:

Incidental ingestion of COPCs in soil,

Dermal contact with COPCs in soil, and

Inhalation of COPCs in particulates from soil sources.

8.2.1.2 Groundwater

In accordance with Section 4.01 of Rules and Regulations of Wells in Shelby County, wells for

consumption cannot be installed where an adequate water supply exists. Shelby County water is

readily available in Cordova, which is served by Memphis Light Gas and Water, so an adequate

water supply exists. Regardless, hypothetical site residents and hypothetical Site workers were

assumed to use Site groundwater as drinking water for the purpose of documenting and prioritizing

risks through ingestion and the combined inhalation and dermal contact while showering pathways.

Construction workers were assumed to contact groundwater during excavation activities.

Recreational Site users would not be expected to contact groundwater onsite during normal

activities.

The risks and hazards associated with the other current and future receptors and media combinations

are discussed in detail in Section 6.0, the Risk Assessment section of the RI report. The results of

the groundwater sampling indicate that VOCs are present in groundwater at concentrations that

indicate that the VI may be a pathway of potential concern. VI may be a concern near Plumes C, D,

and E, given subsurface soil contamination. VI will be fully evaluated as a separate investigation

under the existing AOC at OU2. Actions to address unacceptable risks associated with soil vapor

intrusion, if needed, will be selected in a future decision document.

8.2.2 Exposure Point Concentrations

The concentration term used in the intake equations is an upper bound estimate of the arithmetic

average concentration for a COC based on a set of Site sampling results. Ideally, the exposure point



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concentration (EPC) should be the true average concentration within an exposure unit. The

concentration term in each exposure chronic daily intake (CDI) equation is intended to represent

contact over the exposure duration and exposure area. Due to the uncertainties associated with these

estimates, the upper confidence limit (UCL) of the mean is most commonly used as the Exposure

Point Concentration (EPC) for Reasonable Maximum Exposure (RME) estimates. For the HHRA,

EPA’s ProUCL was used to estimate EPCs. ProUCL uses the ‘W test’ (n ≤ 50) or Lilliefors test (n

> 50) statistics to test for normal and lognormal data distributions. If the data do not fit the

conventional distributions, it also tests for the gamma distribution, which is often used to evaluate

positively skewed environmental data by ProUCL using the Anderson-Darling or Kolmogorov-

Smirnov test.

UCL mean concentrations were estimated using various parametric and non-parametric methods.

Depending upon the results of the normality testing, ProUCL recommends a particular UCL estimate

as most appropriate given the data distribution for a parameter. The recommended UCL estimate was

used as the EPC to estimate exposure. Table 1 summarize groundwater EPCs and corresponding

ProUCL documentation. ProUCL version 4.1 was originally used to estimate UCLs. Samples

collected in 2013 have been incorporated into the calculations, which affect UCLs for onsite

subsurface soil and groundwater. When new data were available, new UCLs were calculated to

integrate the data into the HHRA using ProUCL version 5.0 (U.S. EPA 2013).

8.3 Toxicity Assessment

The toxicity assessment is a two-step process whereby the potential hazards associated with route-

specific exposure to a given chemical are: (1) identified by reviewing relevant human and animal

studies, and (2) quantified through analysis of dose response relationships. The toxicity

assessment will identify and define the toxicity values for the evaluation of COCs at the Site. These

toxicity values are applied to the estimated exposure doses in order to calculate potential cancer risks

and non-cancer hazard quotients.

EPA Toxicity assessments and the resultant toxicity values were used in the baseline evaluation

to determine both carcinogenic and non-carcinogenic risks associated with each COC and route

of exposure. EPA toxicity values that were used in this assessment include:

Reference dose (RfD) values for non-carcinogenic effects, and

Cancer slope factors (CSFs) for carcinogenic effects



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Toxicity values were obtained from the following hierarchy of sources in accordance with the EPA

Office of Superfund Remediation and Technology Innovation (OSRTI):

Tier 1 - Integrated Risk Information System (IRIS)

Tier 2 - Provisional Peer-Reviewed Toxicity Values (PPRTVs)

Tier 3 - Other (Peer Reviewed) Values, including: ATSDR, Minimal Risk Levels (MRLs);

California Environmental Protection Agency (CalEPA) values; and Health Effects Assessment

Summary Tables (HEAST).

Tables 2 and 3 summarize the toxicity values for carcinogenic COCs and toxicity values for non-

carcinogenic COCs. Toxicological profiles of the COCs may be found in an Appendix W of the RI

Report.

8.3.1 Non-Carcinogenic Effects

Non-cancer effects include all health effects that are not cancer related. For most non carcinogens,

the human body is capable of detoxifying or otherwise protecting itself against the potential harmful

effect. A threshold level typically exists above which these mechanisms are no longer able to protect

the exposed individual. Common effects are organ toxicity (kidney, liver, and heart), blood disorders,

central nervous system disorders (permanent damage or transient impairment), reproductive toxicity

and developmental effects (retarded growth, defects). The threshold concept has been rejected in

some instances citing the difficulty of empirically distinguishing a true threshold from a dose-

response curve that is nonlinear at low doses (U.S. EPA 1996b and 1998b).

Reference doses (RfD) are derived based on experimental no observed adverse effects levels

(NOAELs) or lowest observed adverse effect levels (LOAELs). Ideally, experiments would be based

on human subjects under chronic exposure conditions with a well-defined lower limit of toxic

response (NOAEL) identified. However, very few such studies of adequate quality have been

performed. As a result, most toxicological data used to derive RfDs have been obtained from

chronic (or acute) animal studies. To account for uncertainties related to sub-chronic experimental

exposure, failure to identify an NOAEL/use of an LOAEL, extrapolation from animal species to

humans, and sensitive human populations, RfDs typically reflect a series of uncertainty (or safety)

factors ranging from 1 to 10. A modifying factor may also be applied to reflect the weaknesses or

strengths of the associated toxicological database. The RfD is calculated as the NOAEL (or LOAEL)

divided by the product of all applicable uncertainty and modifying factors. Although sub-chronic (2

weeks to 7 years) and acute (less than 2 weeks) RfDs have been developed for some chemicals, only



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chronic RfDs (in units of milligrams per kilogram-day[mg/kg-day]) were considered for the HHRA

based upon the proposed risk characterization approach.

The reference concentration (RfC) is an estimate (with uncertainty spanning perhaps an order of

magnitude) of a continuous inhalation exposure to the human population (including sensitive

subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime

(U.S. EPA IRIS 2012). The RfC considers both toxic effects of the respiratory system

(portal‑ of‑ entry) and effects peripheral to the respiratory system (extra-respiratory effects EPA

IRIS 2012). The inhalation RfC (generally expressed in units of milligrams per cubic meter) is

analogous to the oral RfD and is similarly intended for use in risk assessments for health effects

known or assumed to be produced through a nonlinear (presumed threshold) mode of action (EPA

IRIS 2012). Non-carcinogenic toxicological information was obtained from U.S. EPA’s online

resources and is integrated with CDI and other calculations. Toxicological information is

summarized in Appendix W.

8.3.2 Carcinogenic Effects

Carcinogenic slope factors (SF) and inhalation unit risks (IUR), along with the accompanying

weight-of-evidence (WOE) determination, are the toxicity data most commonly used to evaluate

potential human carcinogenic risks. The basic methods U.S. EPA uses to derive these values are

outlined as follows. Additional detail is in Guidelines for Carcinogen Risk Assessment (U .S. EPA

1994 and 2005). In general, estimates of carcinogenicity are not based on a threshold assumption.

Exposure at any magnitude is thought to present some potential for carcinogenesis. A WOE

classification has historically been assigned based upon the strength of supporting human and/or

animal data available for a chemical. The following classifications were defined by U.S. EPA (1986):

Group A: Known human carcinogen

Group B: Probable human carcinogen

Group B1: Limited evidence/data regarding carcinogenicity in humans

Group B2: Sufficient evidence in animals and inadequate or no evidence in humans

Group C: Possible human carcinogen

Group D: Not classifiable as to human carcinogenicity

Group E: Evidence of noncarcinogenicity for humans

For chemicals in Groups A, B, and sometimes C, SFs and IURs are derived using mathematical

models to extrapolate from responses in high dose animal studies to responses anticipated at

relatively low dose human environmental exposures. The values represent the 95% UCL of the slope



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of the dose-response curve for a specific exposure route (oral or inhalation). EPA has traditionally

used the linearized multistage model for this application, which has been shown to be conservative

(i.e., predicts higher cancer potency) than other available models. SFs are expressed in units of

(mg/kg-day)-1 to allow for estimation of potential carcinogenicity based on chronic daily intake (or

exposure) via oral routes. IURs are expressed in units of (micrograms per cubic meter)-1 [(μg/m3)-1]

and represent the risk (unitless) per μg/m3 of the contaminant in inhaled air.

In 2005, EPA issued updated guidelines on carcinogen risk assessment (EPA 2005b). The highlights

of the changes are: Consideration of all potentially relevant biological information. In addition to

tumor data, data indicating other responses are to be used and modeled if they may be a measure of

carcinogenic risk. Mode of action is emphasized to ensure the mechanisms and uncertainties

associated with a chemical’s likelihood to cause harm are considered in the dose-response approach.

The alphanumeric WOE classification has been replaced by a WOE narrative. Five standardized

hazard descriptors are recommended: Carcinogenic to Humans, Likely to be Carcinogenic to

Humans, Suggestive Evidence of Carcinogenic Potential, Inadequate Information to Assess

Carcinogenic Potential, and Not Likely to be Carcinogenic to Humans. The narrative also

summarizes hazard assessment results and provides a conclusion regarding the human carcinogenic

potential on a route-specific basis. The types of evidence considered and how it was used to draw

conclusions are discussed. The significant issues/strengths/limitations of data and conclusions and

the mode of action information are summarized to support the dose-response approach. Various

dose-response assessment options are provided. Extrapolation is based on extension of a

biologically-based model if supported by substantial data. Otherwise, default approaches can be

applied that are consistent with current understanding of mode(s) of action of the agent, including

approaches that assume linearity or nonlinearity of the dose-response relationship, or both. Oral SFs

and IURs for were obtained from EPA’s online resources and are integrated with CDI and other

calculations. Alphanumeric WOE classifications are also presented. Currently, the revised WOE

guidelines are not reflected in the primary toxicological information sources for many chemicals.

8.3.2.1 Dermal Toxicity Values

Dermal exposures related to solids and water are calculated based on absorbed dose. Dermal toxicity

values must be derived because they are not provided as part of EPA’s toxicity value hierarchy. As a

result, oral toxicity values must be modified to reflect absorbed rather than administered dose. In

accordance with RAGS Part E, oral SFs are adjusted to represent absorbed dose as: Oral

SF/Gastrointestinal Absorption Factor = Dermal SF (mg/kg-day)-1. Absorption factors and dermal

toxicity values used in the HHRA, as per RAGS Part E (U.S. EPA 2004a), are integrated with CDI

and other calculations as previously discussed.



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8.3.2.2 Toxicological Profiles

Basic toxicological profiles for COPCs were obtained from Oak Ridge National Laboratory RAIS

online database service in January 2013 (USDOE 2013). They were reviewed and supplemented with

information from the National Library of Medicine, Hazardous Substances Databank to reflect

project-specific assumptions and/or updated toxicological or chemical characteristic data and are

summarized in Appendix W.

8.4 Risk Characterization

The final step of the HHRA is the risk characterization. Human intakes for each exposure pathway

are integrated with EPA reference toxicity values to characterize risk. To characterize the overall

potential for non-carcinogenic effects associated with exposure to multiple chemicals, the EPA uses

a HI approach. This approach assumes that simultaneous sub-threshold chronic exposures to

multiple chemicals that affect the same target organ are additive and could result in an adverse health

effect. The HI is calculated as follows:

HI = ADD1/RfD1 + ADD2/RfD2 + ADDi/RfDi

Where:

ADDi – Average Daily Dose for the ith toxicant

RfDi = RfD for the ith toxicant

ith represents an infinite number of toxicants that are summed; using the arithmetic operation of

summing or calculating the sum of two or more numbers

The term ADDi / RfDi is referred to as the HQ.

Calculation of an HI in excess of unity (1) indicates the potential for adverse health effects. An HI

greater than one will be generated anytime intake for any of the COCs exceeds its RfD. However,

given a sufficient number of chemicals, it is possible to generate an HI greater than one even if none

of the individual chemical intakes exceeds its respective RfD.

Carcinogenic risk is expressed as a probability of developing cancer as a result of lifetime exposure.

For a given chemical and route of exposure, excess lifetime cancer risk is calculated as follows:

Risk = LADD x CSF

These risks are probabilities that are generally expressed in scientific notation (e.g., 1x10-6). An

incremental lifetime cancer risk of 1x10-6 indicates that, as a plausible upper-bound, an

individual has a one-in-one-million chance of developing cancer as a result of site-related



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exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions at the Site.

For exposures to multiple carcinogens, the EPA assumes that the risk associated with multiple

exposures is equivalent to the sum of their individual risks.

8.4.1 Summary of Risks Associated with the Future Construction Worker

This scenario evaluates excavation activities performed by a construction worker occurring at the

site. Media included in this exposure scenario include onsite surface soil, onsite subsurface soil,

offsite surface soil, and groundwater. Contact with groundwater during excavation activities was

assumed to occur to evaluate this scenario. Use of groundwater as drinking water was not included

based on the assumption that excavation workers would obtain drinking water from other sources.

The corresponding risk characterization tables for onsite and offsite surface soil are Tables 6-19,

6-20 and 6-21 of the RI.

8.4.1.1 Surface Soil (Onsite and Offsite)

The onsite surface soil HI was estimated to be 1.98 due to perchlorate concentrations. Consequently,

perchlorate was initially identified as a COC for onsite surface soil and is discussed further in

Section 8.6 of the IROD. Cancer risk was estimated to be 6.3xE-8. The risk estimate is less than the

lower bound of EPA’s acceptable risk range of 1xE-6 to 1xE-4, so no COCs were identified based on

cancer risk for a construction worker exposed to onsite surface soil. Offsite surface soil COPCs

include only PAHs, so HIs are not applicable. No COCs were identified for a construction worker

exposed to offsite surface soil based on the HI. Cancer risk was estimated to be 1.8xE-8 for this

scenario. The risk estimate is less than the lower bound of EPA’s acceptable risk range of 1xE-6 to

1xE-4, so no COCs were identified based on cancer risk for construction worker exposed to offsite

surface soil.

8.4.1.2 Subsurface Soil

The onsite subsurface soil HI was estimated to be 0.029. Consequently, no COCs were identified for

onsite subsurface soil. Cancer risk was estimated to be 8.2xE-8 for this scenario due to the

contribution from arsenic. The risk estimate is less than the lower bound of EPA’s acceptable risk

range of 1xE-6 to 1xE-4, so no COCs were identified based on cancer risk for a construction worker

exposed to onsite subsurface soil.

8.4.1.3 Groundwater

The groundwater HI was estimated to be 9.7 for this scenario. The primary contributor to the HI was

TCE, with minor contributions from PCE and 1,1,2-TCA. TCE was identified as a COC for a

construction worker coming into direct contact with groundwater based on the HI. Cancer risk was



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estimated to be 1.4xE-6 for this scenario due to TCE. The risk estimate is within EPA’s acceptable

risk range of 1xE-6 to 1xE-4, no COCs were identified based on cancer risk for this exposure medium

and scenario.

8.4.2 Summary of Risks Associated with the Industrial Worker

This scenario includes both current and future land use. Exposure media include onsite surface soil,

onsite subsurface soil, and offsite surface soil. The corresponding risk characterization tables for

onsite and offsite surface soil are Tables 6-16, 6-17 and 6-18 of the RI. Groundwater as drinking

water is not likely to occur under current land use but exposure pathway was included to document

risks.


The onsite surface soil HI was estimated to be 3.8 due to perchlorate concentrations. Consequently,

perchlorate was initially identified as a COC for surface soil and is discussed further in Section 8.6 of

this IROD. Cancer risk was estimated to be 2.8xE-6 for this scenario due to the contribution from

arsenic. The risk estimate is within EPA’s acceptable risk range of 1xE-6 to 1xE-4, so no COCs were

identified based on cancer risk for onsite surface soil. Offsite surface soil COPCs include only

PAHs, so HIs are not applicable. COCs were identified for offsite surface soil based on the HI.

Cancer risk was estimated to be 6.2xE-7 for this scenario due to contributions from PAHs. The risk

estimate is less than the lower bound of EPA’s acceptable risk range of 1xE-6 to 1xE-4, so no COCs

were identified based on cancer risk for onsite surface soil.

8.4.2.2 Subsurface Soil

The onsite subsurface soil HI was estimated to be 0.07. Consequently, no COCs were identified for

subsurface soil based on the HI. Cancer risk was estimated to be 3.4x E-6 for this scenario due to the

contribution from arsenic. The risk estimate is within EPA’s acceptable risk range of 1xE-6 to 1xE-4,

so no COCs were identified based on cancer risk for this exposure medium and scenario.

8.4.2.3 Groundwater

The corresponding risk characterization tables are included as Tables 4 and 5 of the IROD. The HI

was estimated to be 179. The primary contributor to the HI was TCE, with secondary contributions

from 1,1-DCE, cis-1,2-DCE, PCE, and 1,1,2-TCA. Other contributors include 1,1-DCA, iron,

manganese, and vinyl chloride. Consequently, TCE, 1,1-DCE, cis-1,2-DCE, PCE, 1,1,2-TCA, 1,1-

DCA, iron, manganese, and vinyl chloride were identified as COCs for an industrial worker scenario

exposed to groundwater based on the HI. Cancer risk was estimated to be 9.69xE-4 for this scenario

due to contributions from TCE, with secondary contributions from 1,1-DCA, PCE and vinyl



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chloride. Other contributors included 1,4-dioxane and 1,1,2-TCA. The risk estimate exceeds EPA’s

acceptable risk range of 1xE-6 to 1xE-4, so 1,1-DCA, TCE, PCE, vinyl chloride, 1,4-dioxane and

1,1,2-TCA were identified as COCs based on cancer risk for an industrial worker exposed to

groundwater.

8.4.3 Summary of Risks Associated with the Future Adult and Child Resident

As previously discussed, the future residential land use scenario is not likely to occur and was

included to document risks for onsite surface soil, onsite subsurface soil, offsite surface soil, and

groundwater. This scenario includes evaluation of the child, adult, and lifetime weighted average

receptors. The corresponding risk characterization tables for onsite and offsite surface soil are

Tables 6-13, 6-14 and 6-15 of the RI.


The corresponding risk characterization tables for onsite and offsite surface soil are Tables 6-13 and

6-14 of the RI. The onsite surface soil HI for the child was estimated to be 98, and the HI for the

adult was estimated to be 10 due to perchlorate concentrations. Consequently, perchlorate was

initially identified as a COC for soil. The incidence of perchlorate detected in surface soil was

isolated to one sample and not in the corresponding duplicate. A detailed discussion regarding the

perchlorate is given in Section 8.6 of the IROD. Cancer risk was estimated to be 4xE-5 for this

scenario due to contributions from arsenic, hexavalent chromium, benzo(a)pyrene, and TCE. The

risk estimate is within EPA’s acceptable risk range of 1xE-6 to 1xE-4.

Offsite surface soil COPCs include only PAHs, so HIs are not applicable. No COCs were identified

for offsite surface soil based on the HI of less than 1. Cancer risk was estimated to be 3.3E-5 for this

scenario due to contributions from benzo(a)pyrene, with secondary contributions from other PAHs.

The risk estimate is within EPA’s acceptable risk range of 1xE-6 to 1xE-4, so no COCs were

identified based on cancer risk for offsite surface soil. Therefore, no COCs were identified based on

cancer risk for both onsite and offsite surface soil.

8.4.3.2 Subsurface soil

The corresponding risk characterization table is Table 6-13 of the RI. The onsite subsurface soil HI

for the child was estimated to be 1.4, and the HI for the adult was estimated to be 0.2. No COCs

were identified for subsurface based on the HI. Cancer risk was estimated to be 6.7xE-5 for this

scenario due to contributions from arsenic and benzo(a)pyrene, with secondary contributions from

other PAHs. The risk estimate is within EPA’s acceptable risk range of 1xE-6 to 1xE-4, so no COCs

were identified based on cancer risk for onsite subsurface soil.



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8.4.3.3 Groundwater

The corresponding risk characterization tables are included as Tables 4 and 5 of the IROD. The

results yielded an HI of 838 for the child receptor and an HI of 642 for the adult receptor. The

primary contributors to the HI were TCE and PCE, with secondary contributions from 1,1-DCA, 1,1-

DCE, iron, manganese, cis-1,2-DCE, and 1,1,2-TCA. Consequently, these compounds were

identified as COCs for an adult and child receptor exposed to groundwater based on the HI. Cancer

risk was estimated to be 1xE-2 for lifetime weighted average due to contributions from TCE and

vinyl chloride, with secondary contributions from 1,1-DCA and PCE. Other contributors included

bis(2-ethylhexyl)phthalate, 1,4-dioxane, and 1,1,2-TCA. The risk estimate exceeds EPA’s acceptable

risk range of 1xE-6 to 1xE-4, so TCE, vinyl chloride, 1,1-DCA, bis(2-ethylhexyl)phthalate, 1,4-

dioxane, and 1,1,2-TCA were identified as COCs based on cancer risk for a residential receptor

exposed to groundwater.

8.4.4 Summary of Risks Associated with a Recreational Trespasser

The hypothetical recreational land use scenario was included to document risks for onsite surface

soil, onsite subsurface soil, and offsite surface soil. This scenario includes evaluation of the child,

adult, and lifetime weighted average receptors. Ingestion, inhalation, and dermal contact with

groundwater are not a completed pathways to this scenario because recreational users were assumed

to obtain drinking water from other sources. The corresponding risk characterization tables for onsite

and offsite surface soil are Tables 6-22 and 6-23 of the RI.

8.4.4.1 Surface soil (Onsite and Offsite)

The onsite surface soil HI for the child was estimated to be 21, and the HI for the adult was estimated

to be 2.2, primarily due to perchlorate concentrations. Consequently, perchlorate was initially

identified as a COC for a trespasser exposed surface soil and was discussed further in Section 8.6 of

the IROD. Cancer risk was estimated to be 8.6xE-6 for this scenario due to contributions from

arsenic, hexavalent chromium, and benzo(a)pyrene. The risk estimate is within EPA’s acceptable

risk range of 1xE-6 to 1xE-4, so no COCs were identified based on cancer risk for a trespasser

exposed to surface soil. The offsite surface soil COPCs include only PAHs, so HIs are not

applicable. No COCs were identified for a trespasser exposed to subsurface soil based on the HI.

Cancer risk was estimated to be 7.0xE-6 for this scenario due to contributions from benzo(a)pyrene,

with secondary contributions from other PAHs. The risk estimate is within EPA’s acceptable risk

range of 1xE-6 to 1xE-4, so no COCs were identified based on cancer risk for a trespasser exposed to

surface soil.



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8.4.2.2 Subsurface soil

The onsite subsurface soil HI for the child was estimated to be 0.29, and the HI for the adult was

estimated to be 0.032. Consequently, no COCs were identified for a trespasser exposed to subsurface

soil based on the HI. Cancer risk was estimated to be 1.4xE-5 for this scenario due to contributions

from arsenic, benzo(a)pyrene, and benzo(b)fluoranthene. The risk estimate is within EPA’s

acceptable risk range of 1xE-6 to 1xE-4, so no COCs were identified based on cancer risk for a

trespasser exposed to subsurface soil.

8.5 Contaminants of Concern

As described in the HHRA, to develop the cleanup levels at the site, EPA first identified the COPCs,

which are the chemicals whose data are of sufficient quality for use in the quantitative risk

assessment, are potentially site-related, are above background concentrations at the site, and

represent the most significant contaminants in terms of potential health risks to humans.

A list of COCs was then derived from the COPCs identified for the Site. The HHRA assessed the

total cancer and non-cancer risks for each COC for all human health pathways for each type of

human receptor (i.e., receptors with separate exposure pathways).

Under the NCP, EPA’s goal is to reduce the excess cancer risk to the range of 1x10-4 to 1x10-6 for

the expected future land use at the site. Upon consideration of a variety of site-specific factors, EPA

determined that the acceptable target carcinogenic risk at this site is 1x10-6 risk and acceptable target

non-carcinogenic risk at an HI of 1.

The HHRA then calculated cleanup levels for each COC by combining the intake levels of each

COC from all appropriate exposure routes for a particular medium and rearranging the risk equations to

solve for the concentration term (i.e., the cleanup levels). Cleanup levels are chemical

concentrations which provide FS and remedial design (RD) staff with long-term targets to use during

development, analysis and selection of remedial alternatives. Ideally, such level if achieved are

protective and comply with ARARs and result in residual risks that fully satisfy NCP requirements

for the protection of human health and the environment.

The cleanup levels calculated in the HHRA were developed specifically to protect human health and to

address the risk identified in the HHRA. These goals are based on available information, standards

such as ARARs and the risk-based levels established in the HHRA. Cleanup levels at the Site were

developed by using the more stringent of the COC concentrations which indicate a 1x10-6 cancer risk

or a non-cancer HI of 1 for groundwater at the Site, except for the subsurface soil cleanup levels



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protective of groundwater, which are based on levels that prevent further migration of contaminants

from soil to groundwater. The selected cleanup levels are discussed later in Section 9.2.

8.6 Uncertainties

The uncertainty analysis provides decision makers with a summary of those factors that

significantly influence results and discusses the underlying assumptions that most significantly

influence risk. This section discusses the assumptions that may contribute to overestimating or

underestimating risk.

8.6.1 Uncertainties Related to Exposure Assessment

It was assumed that recreational users could be exposed to surface soils (direct and indirect)

throughout the entire Site. Given the vegetation present onsite and use of default particulate

emission factors, estimates of inhalation exposure via fugitive dust generation and direct soil contact

are likely biased high. Hypothetical construction projects typically do not include long-term

exposure to depths greater than 10 feet bgs. Groundwater depths are greater than 20 feet, and

dewatering techniques would be used to minimize exposure to groundwater, so contact with

groundwater during hypothetical construction activities would be minimal. Consequently, the

hypothetical construction worker scenario may overstate risk for groundwater.

During the exposure frequency, it was assumed that 100 percent of the daily soil ingestion would

take place onsite. The assumed exposure pattern and frequency are expected to overestimate chronic

exposure given site characteristics and local climatic factors. Perchlorate was detected in two of 76

samples, the maximum reported perchlorate concentration in soil was reported in sample SE-SSB02,

perchlorate was not detected in the corresponding field duplicate sample collected at the same

location, and it was not detected in any other samples collected along the WWC (SE-SSB12 through

SE-SSB16) along the northern border of the SSI property. These data suggest the concentration

reported at SE-SSB02 was anomalous, which limits the potential for long-term exposure due to the

limited extent of contamination. The potential direct and indirect contributions of sediment to

overall exposure were not evaluated. Given that sediment is permanently inundated, this is not

expected to significantly affect exposure estimates via direct routes.

The facility is zoned for industrial use and is surrounded by land zoned for industrial, residential,

agricultural, and commercial uses. Consequently, future residential land use is unlikely to occur, and

corresponding risk estimates would overstate risk. The alluvial aquifer appears to be discontinuous

and is unlikely to be a source of drinking water because ordinances are in place restricting wells for

consumption from being installed where an adequate water supply exists. Shelby County water is



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readily available in Cordova, which is served by Memphis Light Gas and Water, so an adequate

water supply exists. Future use of groundwater as drinking water is unlikely to occur, and

corresponding risk estimates would overstate risk. Field duplicate data were used to validate data

and were collected only for QC evaluation purposes. Duplicate data were not used during screening

or exposure estimates, which could over- or under-estimate exposure.

The exposure scenarios contribute a considerable degree of uncertainty to the risk assessment

because they assume conditions that are unlikely to occur. The exposure assumptions directly

influence the calculated doses (daily intakes), and ultimately the risk calculations. For the most

part, site-specific data were not available for the risk assessment; therefore, conservative

default exposure assumptions were used in calculating exposure doses such as the selection of

exposure routes and exposure factors (e.g. contact rate). In most cases, this uncertainty may

overestimate the most probable realistic exposures and, therefore, may overestimate risk. This is

appropriate when performing risk assessments of this type so that the risk may not be

underestimated, and so that risk assessments for different locations and scenarios can be compared.

8.6.2 Uncertainties Related to Toxicity Information

For a risk to exist, both significant exposure to the COCs and toxicity at the predicted exposure

levels must exist. The toxicological uncertainties primarily relate to the methodology by which

carcinogenic and non-carcinogenic criteria (i.e., cancer slope factors and reference doses) are

developed. In general, the methodology currently used to develop cancer slope factors and reference

doses is very conservative and likely results in overestimation of human toxicity.

When available, subchronic oral RfDs and inhalation RfCs were used in calculating hazard quotients

for the construction worker. No Tier 1 subchronic values were available for any of the COCs at the

Site, so available Tier 2 and Tier 3 subchronic values were used. Tier 2 and Tier 3 subchronic values

are not IRIS-verified and are subject to revision. When subchronic toxicity values were not

available, chronic values were used in calculating hazard quotients for the construction worker. The

use of chronic RfDs to evaluate short-term exposures for the construction worker is conservative and

will result in overestimation of risk. Chronic RfDs are developed assuming a lifetime daily

exposure. Subchronic RfDs are calculated assuming an exposure duration of 2 weeks to 7 years,

generally tend to be higher than chronic RfDs and result in a lower hazard quotient and index.

In addition, a number of toxicity values were obtained from Tier 3 sources (HEAST, ATSDR-MRLs

and CalEPA values). These values are also not IRIS-verified and are thus subject to revision. There

is a higher level of uncertainty associated with Tier 3 sources as opposed to sources considered Tier



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35

1 and Tier 2 values.

8.6.3 Uncertainties Related to the Risk Characterization

Each complete exposure pathway concerns more than one contaminant. Uncertainties associated

with summing risks or hazard quotients for multiple substances are of concern in the risk

characterization step. The assumption ignores the possibility of synergistic or antagonistic activities

in the metabolism of the contaminants. This could result in over-or under-estimation of risk.

The Site was evaluated for the following receptors: adult and child residents, industrial site workers,

construction workers, and trespassers as described in the exposure assessment based on the CSM. In

accordance with the NCP and EPA OSWER Directive 9355.0-30, excess risk between the ranges of

1xE-6 and 1xE-4 is within EPA’s acceptable excess risk range and generally does not warrant further

action as well as an HQ of 1.0 for non-cancer effects. Chemicals detected in samples resulted in risk

estimates greater than the EPA acceptable cancer risk range or an HQ of 1.0 were identified as COCs

in the HHRA. Risk estimates are summarized in Table 6-24 and COCs are summarized in Table 6-

25 of the RI.

Perchlorate was eliminated as a COC because it was detected in two of 76 samples, the maximum

perchlorate concentration in soil was reported in sample SE-SSB02 and it was not detected in the

corresponding field duplicate collected from the same location. Further, perchlorate was not detected

in any other samples collected along the WWC (SE-SSB12 through SE-SSB16), which suggests that

the concentration reported at SE-SSB02 was anomalous.

8.7 Results of the Ecological Risk Assessment

An ERA was conducted at the OU2 portion of the Site during the RI activities, in accordance with

the 8-step process “Ecological Risk Assessment Guidance for Superfund: Process for Designing and

Conducting Ecological Risk Assessments”

This section summarizes the results of the ERA. The Screening-Level Ecological Risk Assessment

evaluated potential risk to aquatic plants and invertebrates, and terrestrial and aquatic upper trophic

level receptors from exposure to surface soil, surface water, and sediment associated with OU2. It is

noted that analytical data for surface water and sediment was limited to VOCs, as these were the

contaminants of interest at the Site based on historical investigations. No unacceptable risk was

indicated for aquatic flora and fauna based on comparisons of contaminant concentrations in surface

water and sediment to media-specific calculated risk screening values. No unacceptable risk was

indicated for upper trophic level aquatic receptors (mammals and birds) based on the lack of

bioaccumulative chemicals in surface water and sediment. Finally, no unacceptable site-related risk



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was indicated for upper trophic level terrestrial receptors (mammals and birds) based on the refined

food web evaluation.

9.0 REMEDIAL ACTION OBJECTIVES

9.1 Remedial Action Objectives

CERCLA and the NCP define RAOs that are applicable to all Superfund sites. Site specific RAOs

relate to potential exposure routes and specific contaminated media, such as soil, and are used to

identify target areas of remediation and contaminant concentrations, ARARs and statutory

requirements. They require an understanding of the contaminants in their respective media and are

based upon the evaluation of risk to human health and the environment, protection of groundwater,

applicable guidance documents and directives, and state and federal applicable or relevant

appropriate requirements. RAOs provide a general description of what the remedial action will

accomplish. The RAOs for this decision were developed to address the contaminated subsurface soil

and groundwater.

The RAOs developed for contaminated groundwater are:

• Prevent human exposure (dermal contact, ingestion, and inhalation) of groundwater that

contain concentrations of COCs exceeding levels that are protective of potable uses through

the use of institutional controls.

• Minimize lateral migration of contaminated groundwater by removing contaminant mass

from the plume.

• Minimize migration of contaminated groundwater discharging to surface water above

ambient surface water quality criteria by removing contaminant mass from the plume.

• Minimize threats to the underlying Memphis Sand aquifer by removing contaminant mass in

the surficial aquifer.

The RAO developed for contaminated subsurface soil is:

• Reduce or eliminate the long-term leachability of contaminants from site subsurface soils to

the groundwater to levels.

The NCP sets forth an expectation that groundwater be restored to beneficial use, at this site is

potable use. The action selected in the ROD will not restore the contaminated groundwater to levels

that are protective for potable use. The groundwater restoration, is an objective for the Site but may

not be achieved solely by the selected remedy. Therefore, the selected remedy is considered to be an



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interim action, but is necessary to move the Site towards a final site-wide ROD which will address

any residual contamination at the Site and restore groundwater.

9.2 Cleanup levels

Cleanup levels for both subsurface soil and groundwater are presented in Table 7 and Table 8. The

basis for the cleanup levels in both media are presented in both tables. Groundwater cleanup levels

are based on the MCL established under the Safe Drinking Water Act. In the absence of an MCL,

the groundwater PRG was calculated from the HHRA based on a total HI greater than 1, or a

cumulative excess lifetime cancer risk greater than 1x10-6. Cleanup levels were selected that would

both reduce the risk associated with exposure to groundwater contaminants to an acceptable level,

and ensure minimal migration of contaminants into the groundwater. The cleanup levels for

groundwater are based on residential exposure assumptions.

The cleanup levels for subsurface soil are based on soil screening levels for protection of

groundwater. Results of a fate and transport empirical model indicated that several constituents

exhibit the potential to leach and migrate between subsurface soil and groundwater. The levels of

contaminants in the subsurface soil pose a threat to the groundwater and can act as a source of

contamination to leach into the groundwater resulting in groundwater concentrations exceeding the

MCL. The primary constituents which pose a threat to multiple media are the CVOCs, as the

potential exists for multiple cross-media transfers between parent products (PCE) and subsequent

degradation products.

10.0 DESCRIPTION OF ALTERNATIVES

As required in the NCP, remedial alternatives were developed and remedial technologies were

screened for effectiveness, implementability and cost. After screening, the remedial alternatives

described in this section were retained for evaluation. More details about the alternatives and

evaluation process are described in the FS report. The FS evaluated remedial alternatives from a

technical, environmental, and cost-effectiveness perspective. The FS also provided for each

alternative (where possible) the estimated time for implementation, capital costs, total operation &

maintenance (O&M) costs over the life of the cleanup, and total present worth costs. Where

applicable, the total present worth was developed for a period of 30 years with a discount rate of

approximately 4 percent. For a “Detailed Analysis of Alternatives”, please refer to Section 5.0 of the

FS document. The FS report is part of the administrative record for the Site.



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10.1 Common Elements to Alternatives

10.1.1 Applicable or Relevant and Appropriate Requirements (ARARs)

Chemical-specific ARARs include Safe Drinking Water Act MCLs for COCs and serve as the basis

for cleanup levels for restoration of contaminated groundwater to its beneficial use as a potential

drinking water supply. CERCLA and NCP require that remedial alternatives comply with the

ARARs as a threshold criteria. Under 40 CFR 300.430(e)(9)(iii)(B), remedial alternatives are

assessed to evaluate whether they attain ARARs or provide grounds for invoking a waiver.

However, the proposed alternatives for this action will not be able to achieve the chemical-specific

ARARs (MCLs) for TCE, PCE, cis- 1,2-DCE, 1,1-DCE, and vinyl chloride, which are the basis for

groundwater cleanup levels, and therefore are waived under CERCLA 121(d)(4)(A). However,

since this action OU2 is an interim action and is part of the total remedial action which will attain

such levels when completed.

10.1.2 Institutional Controls

All of the alternatives include institutional controls (ICs) 1) to limit disturbance on portions of the

property; and 2) to ensure that the groundwater from the contaminated surficial aquifer is not used

for drinking water purposes until MCLs are achieved or there are no unacceptable risks associated

with the Site. The type of restriction and enforceability of the institutional control will need to be

determined for the selected remedy in the IROD. Consistent with expectations set out in the

Superfund regulations, none of the remedies rely exclusively on ICs to achieve protectiveness. ICs

are a component of each alternative except the No Action alternative.

Specific to the restriction “to ensure that the groundwater from the contaminated surficial aquifer is

not used for drinking water purposes until MCLs are achieved or there are no unacceptable risks

associated with the Site,” an existing legal control exists in Shelby County that may prevent the use

of the contaminated groundwater in the surficial aquifer. In accordance with Section 4.01(C) of

Rules and Regulations of Wells in Shelby County, which states,

“A water well cannot be sited or placed in service within a half-mile of the designated boundaries

of a listed federal or State Superfund site or Resource Conservation and Recovery Act corrective

action site, unless the well owner can make a demonstration that the well will not enhance the

movement of contaminated groundwater or materials into the shallow or deep aquifer.”

The Shelby County legal control may offer some protection from installation of wells within a half-

mile of the Site but ultimately to ensure protectiveness an institutional (proprietary) control will be



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necessary on properties that the plume has migrated until the surficial aquifer has been restored to its

beneficial use.

10.1.3 Long Term Monitoring

Each remedial alternative includes long-term monitoring (LTM) of the groundwater. LTM of the

groundwater for site related COCs and monitored natural attenuation (MNA) parameters will help

determine whether MNA will be a viable long-term remedial alternative as a final action following

the interim action. LTM of the surface water will also be included as a component of this interim

action. The groundwater-to-surface water pathway is considered a valid pathway for contaminant

migration. Continued sampling of the groundwater at the surface water interface will be necessary

for establishing the expected rate of change of the concentration, the groundwater velocity and a data

set for an MNA evaluation. A sampling program designed to monitor the groundwater concentration

before it enters Grey’s Creek and the adjacent surface water concentration will be included in the

LTM program.

10.1.4 Five-Year Reviews

Five Year Reviews will be required for this action until the final remedy is selected and implemented.

Section 121 of CERCLA, as amended by SARA, requires that remedial actions which result in any

hazardous substances, pollutants, or contaminants remaining at the site be subject to a five-year

review. The NCP further provides that remedial actions which result in any hazardous substances,

pollutants, or contaminants remaining at the site above levels that allow for unlimited use and

unrestricted exposure be reviewed every five years to ensure protection of human health and the

environment. The Five-Year Review requirement applies to all remedial actions selected under

CERCLA §121.

The remedial alternatives for the Site are presented below. The alternatives are numbered

to correspond with the numbers in the FS document.

10.2 Detailed Description of Alternatives

10.2.1 Alternative 1: No Action

Estimated Cost: $0

The No Action scenario is required under NCP as a reference scenario against which other remedial

alternatives can be compared. It allows evaluation of future adverse environmental impacts and

risk/hazard resulting from not taking an action to address the existing contamination at OU2. Under



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this alternative no action would be taken to address the subsurface soil and groundwater

contamination, as such contaminated groundwater would continue to migrate and pose unacceptable

risks to human health and the environment. This alternative achieves none of the RAOs developed

for OU2 because no remedial actions are implemented.

10.2.2 Alternative 2: In-Situ Treatment of Groundwater and Subsurface Soil at Plume C, D, and

E, Long-term Monitoring and Institutional Controls

Estimated Capital Cost: $2,700,000

Estimated Annual O&M Cost: $1,500,000

Estimated Present Worth Cost: $4,000,000*

*Net present worth is based on 30 years

Estimated Construction Timeframe: 6-12 months for injection(s)

Estimated Timeframe to achieve RAOs: 2 -3 years to achieve RAOs

In this alternative, engineered amendments would be injected into the shallow surficial aquifer in

Plumes C, D and E, as depicted in Figure 5. Injections would be implemented and optimized for

mass removal of contaminants. The remedial design would evaluate DPT versus continuous

injections, top-down versus bottom up, injection substrates, and establish performance metrics.

In-situ Bioremediation (ISB) and In-situ Chemical Reduction (ISCR) would be integrated as

appropriate and, as determined during the remedial design, as a means of destroying CVOC

contaminant mass that is a source of ongoing groundwater contamination. ISB is commonly applied

technology that degrades target compounds by naturally-occurring bacteria in soil and groundwater.

In the case of CVOCs, this is usually by reductive metabolic pathways enhanced by adding carbon

substrate and amendments (e.g., nutrients). ISCR is a reductive dechlorination process that treats

organic contaminants in groundwater. A reactive liquid or solid is delivered to the water-bearing

zone, most commonly via DPT injections, and the material quickly reacts with contaminants. The

hydrogen for the reaction is provided by a reductant. A widely used reductant is zero valent iron

(ZVI). When ZVI in introduced in an aquifer, it corrodes, and the resulting geochemical reactions

catalyze and promote rapid CVOC destruction (much quicker than biological reactions).

Following remedial design activities to refine design parameters in each area/plume, multiple

injections would occur in a phased sequence over several years. The source areas would be

monitored, and each sequential injection would be optimized in response to performance data

collected.



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41

Field optimization will involve collection of VOC and geochemical data from the contaminated

areas. The data would then be used to optimize the injection protocol and to determine if follow-up

injections were required to enhance mass removal. For Alternative 2, up to three injections have been

estimated for costing purposes, but the actual number of injections would be determined based on the

results from the design phase and additional sampling of monitoring wells in Plumes C, D, and E to

refine treatment areas and post-injection performance monitoring, with the goal of removing as much

mass as practicable from Plumes C, D, and E.

LTM of the groundwater for VOCs and MNA parameters are included as a remedial component.

LTM of the surface water will also be included as a component of this interim action. ICs would be

implemented to limit disturbance of subsurface soil on portions of the property and ensure that the

contaminated surficial aquifer is not used for drinking water. Five Year Reviews will be required as

a part of an ongoing remedial action until the final remedy is in place.

Remedial activities would need to comply with the substantive Underground Injection Control

(UIC) permitting requirements, as well as local well installation standards. Any wastes generated onsite

during remedial activities would be characterized and managed in accordance with appropriate

hazardous and solid waste regulations. MCLs will not be attained but since this action is an interim

action, they are being waived as specified in CERCLA 121(d)(4)(A).

10.2.3 Alternative 3: Limited Injections/In-Situ Treatment of Groundwater and Subsurface Soil

at Plumes C, D, and E, with Monitored Natural Attenuation (MNA) and Institutional Controls






Estimated Timeframe to achieve RAOs: 2-3 years to achieve RAOs

Engineered amendments would be identical to those described in Alternative 2, however this

alternative considers the potential that field limitations (e.g., substrate delivery, heterogeneity, back

diffusion) may constrain the expected effectiveness of follow-on injections. Treatment would be

suspended once optimization indicated that mass removal efforts were no longer effective. Initial

injections would be based on results from the design phase and additional sampling of monitoring

wells in Plumes C, D, and E to refine treatment.



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42

Data would be used to develop a long-term MNA protocol for OU2, with the assumption that MNA

would continue based on (a) residual substrates injected at the source, and (b) positive findings of the

predesign MNA evaluation. One injection has been estimated for costing purposes, but the actual

number of injections will be determined based on field results.

MNA evaluations would include on- and offsite sampling for geochemical parameters. Conceptually,

for costing purposes, this assumes a 14-well network (up to 6 wells in the source areas, and up to 8

additional wells selected during predesign from the east/southeast quadrant downgradient of Plumes

C, D, and E). LTM of the groundwater for VOCs and MNA parameters are included as a remedial

component. ICs would be implemented to limit disturbance of subsurface soil on portions of the

property and ensure that the contaminated surficial aquifer is not used for drinking water. Five Year

Reviews will be required as a part of an ongoing remedial action until the final remedy is in place.

Similar to Alternative 3, remedial activities would need to comply with UIC permitting

requirements, as well as local ARARs associated with well permitting. Any wastes generated onsite


hazardous and solid waste regulations. MCLs will not be attained but since this action is an interim

action, they are being waived as specified in CERCLA 121(d)(4)(A).

10.2.4 Alternative 4: Phytoremediation of Groundwater and Subsurface Soil at Plumes C, D, and

E with Long Term Monitoring and Institutional Controls





Estimated Construction Timeframe: 3-6 months to plant trees

Estimated Timeframe to achieve RAOs: up to five years to monitor phytoremediation network and

achieve RAOs

This alternative includes installation of an engineered phytoremediation network to remove and

degrade VOCs in soil and groundwater. Trees are installed within the footprints of Plume C, Plume

D, and Plume E to remove contaminants as shown in Figure 5. To successfully remove contaminants

from groundwater, tree roots must extend far enough to physically reach the contaminants. At Plume

C and Plume D, the saturated zone is 16 to 30 feet bgs. There is also limited soil contamination that

extends upward from the top of the aquifer approximately 4 to 12 feet. At Plume E, the saturated

zone is approximately 22 to 45 feet bgs.



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43

Patented technologies exist that promote aggressive root development to depths up to 30 feet or

more. These engineered phytoremediation systems involve developing a borehole to the depth

desired, inserting a sleeve or liner to direct root growth, then backfilling the borehole with soil and

planting the selected tree species. Trees can be planted in grids with spacing from 10 to 20 feet, with

alternating targeted root depths to fully intercept contaminant distribution in the aquifer.

Similarly, trees can be planted in trenches to achieve desired depths. Construction techniques given

the semi-confined alluvial aquifer will need to be refined during RD.

The phytoremediation remedy would require an extended period (approximately 5 years) to achieve

maturity, and during that time will be sensitive to external stressors such as weather extremes and

drought. Monitoring will assess the tree’s health over the first several years. The actual duration of

monitoring would be determined during RD/RA work planning.

Remedy elements include installation of the phytoremediation network, as well as ancillary support

structures (e.g., irrigation system). Preliminary treatment areas and planting densities would be

resolved during predesign activities. An approximate number of trees are given for each of the

treatment areas. The actual number of trees may increase or decrease based on the RD. The

approximate treatment areas and number of trees are described as:

Plume C — 9,900 square feet (roughly 90 feet by 110 feet) may require approximately

100 trees

Plume D — 12,800 square feet (roughly 80 feet by 160 feet) may require approximately

130 trees

Plume E — 10,000 square feet (roughly 50 feet by 200 feet) may require approximately

100 trees





a part of an ongoing remedial action until unlimited use and unrestricted exposure is achieved.



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Phytoremediation offers a multi-component treatment approach (mass removal, hydraulic control,

and reduced infiltration) can be designed to accelerate compliance with ARARs, relative to natural

attenuation processes. Remedial activities would need to consider local standards associated with well

installation since the trees would be installed similarly to monitoring well installation. Any wastes

generated onsite during remedial activities would be characterized and managed in accordance with

appropriate hazardous and solid waste regulations. MCLs will not be attained but since this action

is an interim action, they are being waived as specified in CERCLA 121(d)(4)(A).

10.2.5 Alternative 5: Combination of In-Situ Treatment of Groundwater and Subsurface Soil at

Plumes C, D, and E and Phytoremediation, Long-term Monitoring and Institutional Controls and

Phytoremediation Estimated Capital Cost: $2,500,000


Estimated Present Worth Cost: $4,200,000 *Net present worth is based on 30 years

Estimated Construction Timeframe: 3-6 months to plant trees and 6-12 month for injection(s)

Estimated Timeframe to achieve RAOs: up to five years to monitor phytoremediation network and

achieve RAOs

Alternative 5 includes components of the in-situ and phytoremediation alternatives (2,3, and 4). In

this alternative active in-situ treatment of groundwater and soil remediation occurs at Plumes C, D,

and E as shown in Figure 5. Injections of engineered substrates would be identical to those described

in Alternative 2, however this alternative is designed to provide a single, one-time mass reduction

event in the treatment area. Any residuals not affected during injections would then be treated as

groundwater flows through a phytoremediation system located immediately downgradient of each

treatment zone. Phytoremediation would function as a long-term barrier treatment option for plumes

emanating from Plumes C, D, and E. LTM associated with phytoremediation plots are comparable to

those identified in Alternative 4.

A combination of an injection/barrier treatment approach achieves mass removal and reduces mass

flux of OU2 over the long term. High concentration effects on trees are minimized due to treatment

as well as their placement at the downgradient edge of the plume areas.

Remedy elements include:

1. The one-time injection from the design phase and additional sampling of monitoring wells in

Plumes C, D and E to refine treatment areas and install additional monitoring locations. In



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this scenario, no follow-up injections would be performed in favor of the phytoremediation

installation.

2. Phytoremediation would be installed downgradient of the contaminated zones near the SSI

property line, roughly 200 feet long by 50 feet wide in each location.

The plantings would require more aggressive monitoring during the first several years to ensure

growth, consistent with Alternative 4. A long timeframe for the phytoremediation effectiveness can

be expected (tree lifespan should be 20 to 30 years) and will thus be a lasting barrier to contaminant

migration away from the contaminated zones, even if remedial objectives are not met at the treatment

areas immediately after injections.





a part of an ongoing remedial action until unlimited use and unrestricted exposure is achieved.

A multi-component treatment approach using both injections and phytoremediation (which

incorporates treatment, hydraulic control, and reduced infiltration) would be designed to accelerate

compliance with ARARs relative to natural attenuation processes. Alternative 5 meets EPA’s

programmatic preference for sustainable remediation. Remedial activities would need to comply

with the substantive UIC permitting requirements, as well as local well installation standards. Any

wastes generated onsite during remedial activities would be characterized and managed in

accordance with appropriate hazardous and solid waste regulations. MCLs will not be attained but

since this action is an interim action, they are being waived as specified in CERCLA 121(d)(4)(A).

11.0 COMPARATIVE ANALYSIS OF ALTERNATIVES

In this section, each alternative is assessed using nine evaluation criteria required under the (NCP

§300.430 (f)(5)(i)). Comparison of the alternatives with respect to these evaluation criteria is

presented in summary form in the text of this section. The required nine evaluation criteria serve as

the basis for conducting a comparative detailed analysis and selecting the remedy. The comparison

is summarized by evaluation criteria in the next paragraphs.



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The comparative analysis of the remedial alternatives is based on the threshold and balancing

evaluation criteria. The first two criteria, the threshold criteria, are requirements that each alternative

must meet in order to be considered in the evaluation. The next five criteria are the primary

balancing criteria and are used to weigh major trade-offs among alternatives.

11.1 The NCP Criteria

Each alternative is evaluated using the nine criteria below:

1. Overall protection of human health and the environment

2. Compliance with Applicable or Relevant and Appropriate Requirements

3. Long-term effectiveness and permanence

4. Reduction of toxicity, mobility, or volume through treatment

5. Short-term effectiveness

6. Implementability

7. Cost

8. State/support agency acceptance

9. Community acceptance

11.1.1 Overall Protection of Human Health and the Environment

Overall protection of human health and the environment addresses whether each alternative

provides adequate protection of human health and the environment and describes how risks posed

through each exposure pathway are eliminated, reduced, or controlled through treatment,

engineering controls, and/or institutional controls.

Assuming in-situ treatment and phytoremediation are effective at destroying contaminants in

subsurface soil and groundwater, Alternatives 2, 3, 4, and 5 will be protective because it eliminates

contaminants from groundwater and subsurface soil at OU2. Furthermore, in the short term there is

no immediate risk to human health because the groundwater is not currently being used.

11.1.2 Compliance with ARARs

Section 121(d) of CERCLA and NCP section § 300.430(f)(1)(ii)(B) require that remedial actions at

CERCLA sites at least attain legally applicable or relevant and appropriate Federal and State

requirements, standards, criteria, and limitations, which are collectively referred to as “ARARs,”

unless such ARARs are waived under CERCLA section 121(d)(4).

Applicable requirements are those cleanup levels, standards of control, and other substantive

requirements, criteria, or limitations promulgated under Federal or state environmental laws or



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facility citing laws that specifically address a hazardous substance, pollutant, contaminant, remedial

action, location, or other circumstance(s) found at a Superfund Site. Relevant and appropriate

requirements are those cleanup standards, standards of control, and other substantive requirements,

criteria, or limitations promulgated under Federal environmental or State environmental or facility

siting laws that, while not “applicable” to a hazardous substance, pollutant, contaminant, remedial

action, location, or other circumstance at a CERCLA site, address problems or situations sufficiently

similar to those encountered at the CERCLA site that their use is well-suited to the particular site.

Pursuant to 40 CFR § 300.400(g)(5), only those state standards that are promulgated, identified in a

timely manner, and more stringent than federal requirements may be applicable or relevant and

appropriate. For purposes of identification and notification of promulgated state standards, the term

promulgated means that the standards are of general applicability and are legally enforceable. State

standards are considered more stringent where there is no corresponding federal standard, the state

standard provides a more stringent concentration of a contaminant, or the state standard is broader in

scope than a federal requirement.

In addition to ARARs, the lead and support agencies may, as appropriate, identify other advisories,

criteria, or guidance to be considered for a particular release. The “to-be-considered” (TBC)

category consists of advisories, criteria, or guidance that were developed by EPA, other federal

agencies, or states that may be useful in developing CERCLA remedies. See 40 CFR. §

300.400(g)(3). TBCs are not considered legally enforceable and, therefore, are not considered to be

applicable for a site, but are evaluated along with ARARs as part of the risk assessment to set

protective cleanup levels. TBCs can be used in the absence of ARARs, when ARARs are

insufficient to develop cleanup levels, or when multiple contaminants may be posing a cumulative

risk. See EPA, OSWER Directive No. 9234.0-05, Interim Guidance on Compliance with Applicable

or Relevant and Appropriate Requirements (July 9, 1987).

There are three different categories of potential ARARs:

Chemical–specific requirements include those laws and regulations governing the release of

materials possessing certain chemical or physical characteristics, or containing specified chemical

compounds. Chemical-specific requirements set health or risk based concentration limits or ranges

in various environmental media for specific hazardous substances, contaminants, and pollutants.

Action-specific requirements are technology based or establish performance, design, or other similar

action-specific controls or regulations for the activities related to the management of hazardous

substances or pollutants. Action-specific ARARs are triggered by the types of remedial activities

and types of wastes that are generated, stored, treated, disposed, emitted, discharged, or otherwise

managed. Location-specific requirements are design requirements or activity restrictions based on



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the geographic or physical position of the Site and its surrounding area. Location-specific

requirements set restrictions on the types of remedial activities that can be performed based on site-

specific characteristics or location.

Compliance with ARARs is a threshold criteria and a remedy must meet ARARs or be waived. Remedial

alternatives’ compliance with ARARs is the most challenging criterion to evaluate because of the

number and multiple types of ARARs that can apply to a site. In general, chemical-specific ARARS

can be met most effectively by removing (as by excavation) or reducing (as by treatment)

contaminant mass from a site. Treatment occurs in subsurface soil and groundwater in Alternatives

2, 3, 4, and 5. The alternatives vary in terms of implementation aggressiveness (with Alternative 2

and Alternative 5 being relatively more aggressive, and Alternative 3 being the least aggressive).



drinking water supply. CERCLA and the NCP require that remedial alternatives comply with the

ARARs as a threshold criteria. Under 40 CFR 300.430(e)(9)(iii)(B), remedial alternatives were

assessed to evaluate whether they attain ARARs or provide grounds for invoking a waiver. However,

the selected remedy will not be able to achieve the chemical-specific ARARs (MCLs) for TCE, PCE,

cis- 1,2-DCE, 1,1-DCE, and vinyl chloride, which are the basis for groundwater cleanup levels, and

therefore are waived under CERCLA 121(d)(4)(A). The remedial action to be implemented for OU2

is an interim action that is only part of the total remedial action for the contaminated groundwater at

the Site which will attain such levels when completed.

For all alternatives except Alternative 1, remedial activities include boring that can be implemented

in accordance with local standards associated with well installation. Any wastes generated onsite


hazardous and solid waste regulations. Additionally, Alternative 2, Alternative 3, and Alternative 5

would need to comply with the substantive UIC permitting requirements. Alternative 4 and

Alternative 5 meet EPA’s programmatic preference for green remediation. Action-specific criteria

relate to limitations or parameters by which a particular remedial action is to be implemented. As

such, all four treatment alternatives would achieve their specific action-specific criteria to the same

degree.

11.1.3 Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy

to maintain reliable protection of human health and the environment over time, once clean-up levels



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have been met. This criterion includes the consideration of residual risk that will remain on site

following remediation and the adequacy and reliability of controls. Long-term effectiveness is

evaluated based on the following three factors:

Magnitude of the risk remaining from untreated waste or treatment residuals at the end of

the remedial activities;

Adequacy of controls used to manage the treatment residuals or untreated wastes that

remain at the Site; and

Reliability of the controls to provide protection from the treatment residuals or untreated

waste.

Alternatives that treat or remove contaminants from the site media provide the most protection for

the longest period of time (i.e., site contaminants do not return to the site after remediation is

complete). Alternatives 2, 3, 4, and 5 all rely on treatment to achieve RAOs over the long term, and

use ICs to prevent exposures to CVOCs. ICs would be implemented to limit disturbance of

subsurface soil on portions of the property and ensure that the contaminated surficial aquifer is not

used for drinking water; annual site evaluations (monitoring) of the ICs to determine whether ICs are

reliable controls will be conducted. The LTM program would assess treatment effectiveness and

groundwater plume status on a periodic basis. Data would be used to detect changes in plume

conditions, determine the need for remedy modifications (if any), and make recommendations for

changes in monitoring; inspections and monitoring can also be used to determine whether replanting

is required for the phytoremediation remedies (Alternatives 4 and 5). Five-year reviews would be

completed to assess ongoing protectiveness; Five-year reviews are reliable mechanisms to assess site

status.

Risk at OU2 is minimal because the alluvial aquifer is not being used, and because drinking water is

available. In addition, RI studies indicated that the Jackson Clay is competent beneath OU2, and

protects the underlying Memphis Sand aquifer. Therefore, the overall risk of vertical migration of

contaminants from the alluvial aquifer into the Memphis sand is negligible. Alternatives 2, 3, 4, and

5 use active remedial measures to treat the groundwater plumes, and all are expected to effectively

reduce the magnitude of residual risk due to residual mass to very low and certainly protective level.

11.1.4 Reduction of Toxicity, Mobility, or Volume of Contaminants Through Treatment

Reduction of T/M/V refers to the anticipated performance of the treatment technologies that may be

included as part of the remedy. This criterion addresses the statutory preference for selecting

remedial action that permanently and significantly reduces the T/M/V of the COCs. The ability of a



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remedial alternative to reduce the T/M/V of the COCs is evaluated based on the following five

factors:

The treatment processes, the remedies employed and the materials they treat;

The amount (mass and or volume) of hazardous materials that will be destroyed or treated

by the remedial alternative, including how the principal threat(s) will be addressed;

The degree of expected reduction in the T/M/V of COCs, measured as a percentage of

reduction or order of magnate;

The degree to which the treatment is irreversible; and

The type and quantity of treatment residuals would remain following the treatment.

Alternative 1 does not provide any reduction in toxicity, mobility, or volume. Alternatives 2, 3, 4,

and 5 use treatment as a primary remedy activity for subsurface soil and groundwater. Alternatives

2, 3, 5 use injections for mass removal: biotic and abiotic processes would be irreversible. However,

Alternative 3 proposes MNA as a follow-on to injections, and MNA has not been confirmed to be

effective at the OU2 at this time; further studies are necessary in order to verify that attenuation is

occurring with multiple lines of evidence.

Alternatives 4 and 5 use phytoremediation to remove CVOCs through evapotranspiration and biotic

means, and also exert control over infiltration and groundwater hydraulics. Phytoremediation

techniques will be more tolerant of lithologic heterogeneity than the injections, although the

reduction in volume of mass may not be materially affected in any case; in Alternative 5, combining

treatment with injections with phyto-treatment may be just as effective as the multiple injections that

comprise Alternative 2.

11.1.5 Short Term Effectiveness

Short term effectiveness refers to the period of time needed to implement the remedy and any adverse

impacts that may be posed to workers, the community, and the environment during construction and

operation of the remedy until cleanup levels are achieved.

Protection of the community during the remedial action. This addresses any risk that results

from the implementation of the remedial action (i.e. dust from an excavation) that may affect

human health;

Protection of workers during the remedial action. This addresses threats that may affect

workers and the effectiveness and reliability of protective measures that may be taken;

Environmental impacts. This addresses the potential adverse environmental impact from the

implementation of the remedial alternative and evaluates how the impact could be mitigated,



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prevented, or reduced; and

The amount of time required until the RAOs are achieved. This includes an estimate of the

time required to achieve RAOs for the entire Site or for individual elements associated with

specific areas or threats.

The short-term effectiveness of remedial alternatives relates to the implementation impacts of the

remedial action, how long it will take to implement the remedy and how long the remedial action

will take to attain cleanup levels and achieve RAOs. The No Action alternative is the best approach

for minimizing added exposure or risk to receptors in the short-term. The effectiveness of remedial

actions at ensuring short-term protection during implementation of a remedial action depends on the

care and attention to detail exhibited by the remediation personnel. In some cases, implementation

of the alternative could temporarily increase risk and exposure pathways to receptors.

The risk of exposure to site workers and community impacts are minimal for all alternatives. The

environmental impacts are negligible, and worker protection and community monitoring protocols

defined during remedial design and health and safety planning would be sufficiently protective.

There is no significant difference among alternatives regarding this criterion. Physical hazards

associated with the deep emplacement of tree roots are manageable.

The interim treatment actions implemented by Alternatives 2, 3, 4, and 5 would all significantly

accelerate achieving RAOs relative to the No Action alternative. The expected time to achieve the

RAOs varies by alternative. Alternatives 2, 3, 4, and 5 would achieve some degree of treatment

within a few years after injections. Alternatives 4 and 5 would require approximately 5 years to

develop a mature stand of trees, but would be partially effective in the interim, and possibly more

effective relative to injection because it would provide hydraulic control. Alternative 2 is the most

aggressive in terms of contemplated treatment area injections; effectiveness in preventing offsite

migration of contaminants may not differ significantly from the other alternatives. The time to

achieve RAOs is expected to be longest for Alternative 3, given that the other alternatives are either

more aggressive in terms of injection or more active in terms of preventing migration.

11.1.6 Implementability

Implementability addresses the technical and administrative feasibility of the remedy from design to

construction and operation. Factors such as the relative availability of services and materials,

administrative feasibility, and coordination with other government entities are also considered. The

implementability of a given remedial alternative is evaluated based on the following factors:



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Technical feasibility

Construction and operation. This consideration relates to the technical difficulties and

unknown aspects associate with a given technology;

Reliability of a technology. This consideration focuses on the ability of a technology to

meet specified process efficiencies and performance goals, i`ncluding whether technical

problems may lead to schedule delay;

Ease of undertaking additional remedial actions. This consideration includes a

discussion of what, if any, future remedial actions may need to occur and how difficult it

would be to implement them; and

Monitoring considerations. This consideration addresses the ability to monitor the

effectiveness of the remedial actions and includes an evaluation of the risks of exposure if

monitoring is determined to be insufficient to detect a system failure.

Administrative Feasibility

Both the ability and time required to coordinate with other offices and regulatory agencies

(i.e., obtaining permits for offsite activities or rights-of-way for construction activities).

Availability of services and materials/ supplies;

Availability of adequate offsite treatment, storage capacity and disposal services;

Availability of necessary equipment, specialists and provisions to ensure any necessary

resources;

Timing of the availability of each technology; and

Availability of services and materials, and the potential for obtaining competitive bids,

especially for innovative technologies.

Alternative 1, No Action, can be implemented immediately. It is the simplest and quickest to

implement, but it does not achieve remedial objectives. Alternatives 2, 3, and 5 would require

injection of substrates within the target zones; injection vendors and substrates, however, are readily

available. Multiple injections are expected to be required for Alternative 2.

Alternatives 4 and 5 may require proprietary phytoremediation installation techniques that involve

excavation to emplace tree roots in close proximity to the target depth of treatment; alternative

techniques would be explored during remedial design. Installation to the top of the alluvial aquifer

carriers a finite but manageable risk of encountering difficult subsurface conditions (e.g., running

sands). This risk would be minimized through careful remedial design and construction techniques.

The phytoremediation remedies would require an extended period (approximately 5 years) to achieve

maturity and maximum effect. Also during that time, the trees would be relatively more sensitive to



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external stressors such as weather extremes, and drought. These uncertainties in technology

application can be managed and additional trees can be planted as needed based on inspections of the

tree stands.

11.1.7 Costs

Include estimated capital and O&M costs, as well as present worth cost. Present worth cost is the

total cost of an alternative over time in terms of today's dollar value. A discount rate of 4 % was

assumed for O&M cost.

Alternatives 2 and 5 would incur the most upfront capital costs ($2.7M and $2.5M, respectively).

Similarly, the capital costs associated with Alternatives 3 and 4 are very close ($1.6M and $1.8M,

respectively). The LTM costs are all based on a 30-year monitoring period and range from $1.5M to

$1.9M which is approximately $58,000 annually in monitoring costs. Table 8 provides a summary

of the net present worth of each of the remedial alternatives. A detailed breakdown of remedial costs

and cost assumptions are included in Appendix E of the FS.

11.1.8 State/Support Agency Acceptance

Considers whether the State agrees with the EPA's analyses and recommendations, as described

in the RI/FS and Proposed Plan.

TDEC supports the selected remedy. A copy of TDEC’s concurrence with the IROD is given in

Appendix C.

11.1.9 Community Acceptance

Considers whether the local community agrees with EPA’s analyses and preferred alternative.

Comments received on the Proposed Plan are an important indicator of community acceptance.

The RI/FS Report and Proposed Plan for the Site were made available to the public August 20, 2014.

Those documents along with other documents included in the Administrative Record file are

maintained in the EPA Docket Room located at EPA Region 4 in Atlanta, Georgia, and at the

Cordova Library in Cordova, Tennessee. The notice of availability of the Proposed Plan was

published in the Commercial Appeal on August 14, 2014. A public comment period was held from

August 20, 2014 to September 18, 2014. The Proposed Plan for the remedial action at the Site was

presented at the public meeting held on August 21, 2014. The public meeting was held at the

Cordova Community Center. At this meeting, representatives from the EPA and TDEC answered

questions about OU2 and the remedial alternatives.



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After the public comment period ended, EPA reviewed comments received from the community as

part of the process of reaching a final decision on the most appropriate remedial alternative, or

combination of alternatives, to address contamination found at the Site. The comments documented

in the responsiveness summary indicate that overall the community supports the selected remedy.

The public meeting had a small turnout but the attendees did ask questions during the meeting. After

the meeting, EPA also received questions from one resident via email. All of the questions as well as

EPA’s response to the comments received at the public meeting, the public meeting’s transcript, and

comments received during the public comment period are included in the Responsiveness Summary

as Appendix A in this IROD.

12.0 PRINCIPAL THREAT WASTE

The NCP establishes an expectation that EPA will use treatment to address principal threats posed by

a site wherever practicable (NCP §300.430(a)(1)(iii)(A)). A principal threat concept is applied to

the characterization of “source material” at a Superfund site. Source material includes or contains

hazardous substances, pollutants, or contaminants that act as a reservoir for migration of

contamination to groundwater, surface water, or air, or acts as a source for direct exposure. EPA has

defined principal threat wastes as those source materials considered to be highly toxic or highly

mobile, and generally cannot be reliably contained or would present a significant risk to human

health or the environment. There have not been any materials identified during the RI as principal

threat waste.

13.0 SELECTED REMEDY

13.1 Rationale for the Selected Remedy

Phytoremediation of the groundwater and subsurface soil is recommended as the preferred remedial

alternative for OU2. This alternative is recommended because it will achieve a substantial risk

reduction by treating the groundwater and subsurface soil and achieve the RAOs. Alternative 4 also

provides protection of human health and the environment, reduction of toxicity/mobility/volume

through treatment, and short-term effectiveness. Costs associated with this alternative are moderate.

Phytoremediation is a sustainable alternative to remediating the contamination. An evaluation of all

the alternatives indicated that Phytoremediation is consistent with the Superfund Green Remediation

Strategy. Phytoremediation will reduce the overall environmental footprint. Furthermore,

Phytoremediation supports the Five Principles of Greener Cleanups:



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Minimize Total Energy Use,

Minimize Air Pollutants and Greenhouse Gas Emissions,

Minimize Water Use and Impacts to Water Resources,

Reduce, Reuse, and Recycle Material and Waste, and

Protect Land and Ecosystems.

Based on information currently available, the EPA believes the selected interim remedy meets the

threshold criteria and provides the best balance of tradeoffs among the other alternatives with the

respect to the balancing and modifying criteria. The EPA expects the selected remedy to satisfy the

following statutory requirements of CERCLA 121(b): (1) be protective of human health and the

environment; (2) comply with ARARs; (3) be cost effective; (4) utilize permanent solutions and

alternative treatment technologies or resource recovery technologies to the maximum extent

practicable; and (5) satisfy the preference for treatment as a principal element. TDEC supports the

selected remedy.

13.2 Description of the Selected Remedy

The selected remedy is an engineered phytoremediation network that would remove and degrade

VOCs in soil and groundwater. Trees would be installed within the footprint of Plume C, Plume D,

and Plume E. The dechlorination of the CVOCs occurs in both the root zone and in the leaves. Most

of the absorbed VOCs will be transferred in the water up to the leaves through the xylem (the

primary vascular tissue of trees). Patented technologies exist that promote aggressive root development to depths down to 30 feet or



planting the selected tree species. Within Plumes C and D, the saturated zone is 16 to 30 feet bgs

and the soil contamination extends upward from the top of the aquifer approximately 4 to 12 feet.

Within Plume E, the saturated zone is 22 to 45 feet bgs. Trees can be planted in grids with spacing

from 10 to 20 feet, with alternating targeted root depths to fully intercept contaminant distribution in

the aquifer. Similarly, trees may also be planted in trenches to achieve desired depths. Construction

techniques given the semi-confined alluvial aquifer will need to be refined during design.


maturity, and during that time the phytoremediation network will be sensitive to external stressors

such as weather extremes and drought. Monitoring will assess the stand’s health over the first several

years. The actual duration of monitoring necessary would be determined during RD/RA work



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planning.

Remedy elements include installation of the phytoremediation network, as well as ancillary support

structures (e.g., irrigation system). Preliminary treatment areas and planting densities would be

resolved during predesign activities. An estimated number of trees are given for each of the

treatment areas. The actual number of trees may increase or decrease based on the RD. The

approximate treatment areas and number of trees are described as:

Plume C — 9,900 square feet (roughly 90 feet by 110 feet) may require approximately

100 trees

Plume D — 12,800 square feet (roughly 80 feet by 160 feet) may require approximately

130 trees

Plume E — 10,000 square feet (roughly 50 feet by 200 feet) may require approximately

100 trees


LTM of the surface water will also be included as a component of this interim action. LTM of the

groundwater and surface water will continue through the start of the Remedial Action phase of the

final Site-wide ROD. ICs would be implemented to limit disturbance of subsurface soil on portions

of the property and ensure that the contaminated surficial aquifer is not used for drinking water. Five

Year Reviews will be required as a part of an ongoing interim action until unlimited use and

unrestricted exposure is achieved at the site. The components of this remedy may require

preparation, submittal, and approval of corresponding work plans and health and safety plans. The

selected remedy will require minor pre-remedy site work, such as soil grading or disassembling of

existing equipment or buildings. No major soil moving operations or use ex-situ treatment facilities

are anticipated for this alternative. Monitoring wells would be installed within the available space

onsite. ICs (for subsurface soil, onsite groundwater use, and offsite groundwater use), the five year

review report cycle, and monitoring activities in support of the five year review report are critical

components of this alternative.

The selected interim remedy will protect human health and the environment by a combination of

exposure pathway disruption and contaminant mass removal by in-situ treatment to both subsurface

soil and groundwater. Effectiveness of this alternative’s remedial strategy depends on (1) access to



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contaminated media (below ground; onsite and offsite) and (2) efficiency of treatment (chemical

oxidation) technologies.

13.2.1 Institutional Controls

ICs are required as part of the selected interim remedy. ICs 1) to limit disturbance on portions of the

property; and 2) to ensure that the groundwater from the contaminated surficial aquifer is not used

for drinking water purposes until MCLs and cleanup levels are achieved and there are no

unacceptable risks associated with the Site. Consistent with expectations set out in the Superfund

regulations, the selected interim remedy does not rely exclusively on ICs to achieve protectiveness.


not used for drinking water purposes until drinking water standards are achieved or there are no

unacceptable risks associated with the Site,” an existing legal control exists in Shelby County that

may prevent the use of the contaminated groundwater in the surficial aquifer. In accordance with

Section 4.01(C) of Rules and Regulations of Wells in Shelby County, which states,

“A water well cannot be sited or placed in service within a half-mile of the designated boundaries

of a listed federal or State Superfund site or Resource Conservation and Recovery Act corrective

action site, unless the well owner can make a demonstration that the well will not enhance the

movement of contaminated groundwater or materials into the shallow or deep aquifer.”

The Shelby County legal control may offer some protection from installation of wells within a half-

mile of the Site but ultimately to ensure protectiveness an institutional (proprietary) control will be

necessary on properties that the plume has migrated beneath until the surficial aquifer has been

restored to its beneficial use.

A Final Institutional Controls Implementation Plan will be developed during the remedial design and

will identify the specific ICs necessary to implement the above-mentioned restrictions. Potential ICs

may include, but are not limited to, the following:

Restrictive covenants, deed notices, or other proprietary controls to limit disturbance of

subsurface soil on portions of the property, and

Restrictive covenants, deed notices, or other proprietary controls to ensure that the

groundwater from the contaminated surficial aquifer is not used for drinking water purposes

until drinking water standards are achieved or there are no unacceptable risks associated



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with the Site by restricting installation of monitoring wells within the groundwater plume

both onsite and offsite.

13.2.2 Five-Year Reviews

Five-year Reviews will be conducted to evaluate the implementation and performance of the

Selected Remedy, and in order to determine if the remedy continues to be protective of human health

and the environment. Five year reviews will be conducted as required under CERCLA.

13.2.3 Summary of the Estimated Remedy Costs

The cost information is based on the best available information regarding anticipated scope of the

selected remedy. Changes in cost elements are likely to occur as a result of new information and

data collected during the engineering design of the selected remedy. Changes will be documented in

the form of a memorandum in the Administrative Record file, an Explanation of Significant

Differences, or a ROD amendment. The estimated present worth cost is an order-of-magnitude

engineering cost estimate that is expected to be within +50 and -30 percent of the actual project cost.

See Table 9 for a detailed description of the cost estimate summary table for the selected remedy. A

summary of the estimated costs of the selected remedy is provided:



Estimated Present Worth Cost: $3,400,000

13.2.4 Expected Outcomes of the Selected Remedy

The outcome of the remedy is to meet the objectives which have been set forth: to prevent exposure

to groundwater that contains levels of site related contaminants exceeding levels that are protective

of potable uses through the use of institutional controls. Also, remove mass from the contaminated

plume: to minimize lateral migration of contaminated groundwater, to minimize migration of

contaminated groundwater discharging to surface water above ambient surface water quality criteria,

to minimize threats to the underlying Memphis Sand aquifer, and to reduce the long-term leachability

of contaminants from site subsurface soils into the groundwater.

13.2.4.1 Expected Land Use

The soil component of the remedy will only address the subsurface soil. The surface soil present at

the site does not pose an unacceptable risk. It is anticipated that once remedies have been implemented

at both OUs, the property’s land use will remain commercial / industrial.



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13.2.4.2 Groundwater Use

The objective of this interim action is to aid in the restoration of the groundwater in the surficial

aquifer. It is expected that once actions at both OUs are implemented the groundwater will be

suitable as a general use water without restrictions.

14.0 STATUTATORY DETERMINATIONS

The Selected Remedy satisfies the requirement of Section 121 of CERCLA, 42 U.S.C. § 9621, and to

the extent practicable, the NCP § 300.430, 40 Code of Federal Regulations (CFR) § 300.430. The

EPA must select remedies that are protective of human health and the environment, comply with

ARARs (unless a statutory waiver is justified), must be cost-effective, and utilize permanent

solutions to the extent practicable. In addition, CERCLA includes a preference for remedies that

employ treatment that permanently and significantly reduces the T/M/V of hazardous wastes as a

principal element. The following sections discuss how the selected remedy meets these statutory

requirements.

14.1 Protection of Human Health and the Environment

The selected remedy will protect human health and the environment by:

Prevent human exposure (dermal contact, ingestion, and inhalation) of groundwater that



Minimize lateral migration of contaminated groundwater by removing contaminant mass

from the plume.

Minimize migration of contaminated groundwater discharging to surface water above

ambient surface water quality criteria by removing contaminant mass from the plume.

Minimize threats to the underlying Memphis Sand aquifer by removing contaminant mass

present in the fluvial zone.

Reduce the long-term leachability of contaminants from site subsurface soils into the

groundwater.

The Selected Interim Remedy will not restore the contaminated groundwater to levels that are

protective for potable use. The groundwater restoration is an objective for the Site but may not be

achieved solely by the Selected Interim Remedy. Therefore, the action is considered to be interim,

but is necessary to move the Site towards a final site-wide ROD which will address any residual

contamination at the Site and restore groundwater.



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14.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)



drinking water supply. CERCLA and NCP require that remedial alternatives comply with ARARs as

a threshold criteria. Under 40 CFR 300.430(e)(9)(iii)(B), remedial alternative. The interim action y

will not be able to achieve the chemical-specific ARARs (MCLs) for TCE, PCE, cis- 1,2-DCE, 1,1-

DCE, and vinyl chloride. Due to the interim status of this action ARARs are waived under CERCLA

121(d)(4)(A). The remedial action to be implemented for OU2 is an interim action that is only part

of the total remedial action for the contaminated groundwater at the Site which will attain such levels

when completed. A summary of the chemical specific ARARs are listed in Table 10.

This interim action is expected to comply with local standards associated with well installation since

the trees would be installed similarly to monitoring well installation. Any wastes generated onsite


hazardous and solid waste regulations.

Table 11 identifies the action-specific ARARs for the selected remedy, which include requirements

for the control of stormwater runoff and fugitive dust. The selected remedy will attain all action-

specific ARARs. There have not been any location specific ARARs that have been identified for the

selected remedy.

14.3 Cost Effectiveness

A cost-effective remedy is one whose “costs are proportional to its overall effectiveness.” The

overall effectiveness was determined by evaluating the four of the five balancing criteria used in the

detailed analysis of alternatives: (1) long-term effectiveness and permanence; (2) Reduction in

toxicity, mobility, and volume treatment; (3) short-term effectiveness; and (4) Implementability. The

selected remedy is considered cost effective because it is an interim action toward a permanent

solution that reduces contaminant mass in the groundwater plume. Furthermore, the selected remedy

meets four of the five balancing criteria at a reasonable cost. Detailed cost estimates for the selected

remedy may be found in Table 9.

14.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or

Resource Recovery Technologies to the Maximum Extent Practicable

The EPA and TDEC have determined that the Selected Interim Remedy represents the maximum

extent to which permanent solutions and treatment technologies can be utilized in a cost-effective

manner, given the specific conditions at the Site. The EPA and TDEC have determined that the



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Selected Interim Remedy provides the best balance of trade-offs in terms of long-term effectiveness

and permanence, reduction of toxicity, mobility, or volume, short-term effectiveness,

implementability, and cost, while also considering State and community acceptance. The interim

remedy will require specific institutional controls over the short-term to remain effective.

14.5 Preference for Treatment as a Principal Element

The NCP establishes an expectation that EPA will use treatment to address the principal threats

posed by a site wherever practicable (NCP §300.430(a)(1)(iii)(A)). The “principal threat” concept is

applied to the characterization of “source materials” at a Superfund site. A source material is

material that includes or contains hazardous substances, pollutants or contaminants that act as a

reservoir for migration of contamination to groundwater, surface water, or air, or acts as a source for

direct exposure. Principal threat wastes are those source materials considered to be highly toxic or

highly mobile that generally cannot be reliably contained, or would present a significant risk to

human health or the environment should exposure occur. There have not been any materials

identified during the RI as principal threat waste. However, in-situ treatment and phytoremediation

are components of the interim remedy and therefore satisfies the preference for treatment.

14.6 Five-Year Review Requirement

NCP §300.430(f)(4)(ii) requires a five-year review if a remedial action results in hazardous

substances, pollutants, or contaminants remaining onsite above levels that allow for unlimited use

and unrestricted exposure. Five Year Reviews will be required as a part of an ongoing remedial

action until unlimited use and unrestricted exposure is achieved. Section 121 of CERCLA, as

amended by SARA, requires that remedial actions which result in any hazardous substances,

pollutants, or contaminants remaining at the site be subject to a five-year review. The NCP further

provides that remedial actions which result in any hazardous substances, pollutants, or contaminants

remaining at the site above levels that allow for unlimited use and unrestricted exposure be reviewed

every five years to ensure protection of human health and the environment. Five-year reviews will

be completed to assess ongoing protectiveness; five-year reviews are reliable mechanisms to assess

site status.

14.7 Document of Significant Changes

Pursuant to CERCLA 117(b) and NCP § 300.430(f)(3)(ii), the IROD must document any significant

changes made to the Preferred Alternative discussed in the Proposed Plan. There have been no

significant changes to the Preferred Alternative discussed and presented in the Proposed Plan.



Operable Unit 2

REFERENCES

Bouwer, H. and R.C. Rice, 1976. A slug test method for determining hydraulic conductivity of

unconfined aquifers with completely or partially penetrating wells, Water Resources Research,

vol.12, no. 3, pp. 423-428.

Buchman, M. F., 2008. NOAA Screening Quick Reference Tables, NOAA OR&R Report 08-1,

Seattle WA, Office of Response and Restoration Division, National Oceanic and Atmospheric

Administration.

EnSafe, 2006. Monitoring Well Installation and Groundwater Sampling Report for Security

Signals, Inc.

EnSafe, 2006. Report of Findings, Passive Soil Gas Survey. Security Signals, Inc.

EnSafe, 2007. Report of Findings, Passive Soil Gas Survey. Security Signals, Inc.

EnSafe, 2007. Final Remedial Investigation/Feasibility Study Work Plan, Security Signals, Inc.

Operable Unit 2, National Fireworks, Inc.

EnSafe, 2007. Final Remedial Investigation/Feasibility Study Sampling and Analysis Plan,

Security Signals, Inc. Operable Unit 2, National Fireworks, Inc.

EnSafe, 2007. Phase I Field Investigation Findings, Security Signals, Inc.

EnSafe 2010. Phase II Field Investigation, Security Signals, Inc.

EnSafe, 2012. Time-Critical Removal Action Work Plan for Security Signals, Inc., Operable Unit

2, National Fireworks, Inc.

EnSafe, 2012. Phase III Field Investigation Results, Security Signals, Inc., 9509 Macon Road,

Cordova, Tennessee 38016.

EPA, 1989. Guidelines for Carcinogen Risk Assessment. Risk Assessment Forum. Federal

Register 51(185):33992-34003.



Operable Unit 2

EPA, 1989. RAGS, Volume I: Human Health Evaluation Manual (Part A), Interim Final, Office

of Emergency and Remedial Response, Washington, DC, EPA/540/1-89/002, 1989.

EPA, 1991. Risk Assessment Guidance for Superfund Volume I —Human Health Evaluation

Manual (Part A) Interim Final. EPA/540/1-89/002.

EPA, 1992. Role of the Baseline Risk Assessment in Superfund Remedy Selections. OSWER Directive

9355.0-30. (1991c, December). Risk Assessment Guidance for Superfund Volume I — Human Health

Evaluation Manual (Part B — Development of Risk-Based Preliminary Remediation Goals) Interim.

EPA/540/R092/003.

EPA, 1992. Calculating the Concentration Term- Supplemental Guidance to RAGS. OSWER #

PB92-963373.

EPA, 1998. Guidelines for Ecological Risk Assessment (EPA/630/R-95/002F).

EPA, 2000. Supplemental Guidance to RAGS: Region 4 Bulletins, Human Health Risk

Assessment Bulletins. EPA Region 4, Website version last updated May 2000.

http://www.epa.gov/Region4/waste/ots/healtbul.htm

EPA, 2004. Risk Assessment Guidance for Superfund Volume I — Human Health Evaluation

Manual (Part E — Supplemental Guidance for Dermal Risk Assessment)

Final. EPA/540/R/99/005.

EPA, 2004. Expanded Site Inspection Report for National Fireworks, Cordova, Shelby County,

Tennessee.

EPA, 2006. Guidance for Developing Ecological Soil Screening Levels. (OSWER Directive

9285.7-55).

EPA, 2009. Risk Assessment Guidance for Superfund Volume I — Human Health Evaluation

Manual (Part F, Supplemental Guidance for Inhalation Risk Assessment) Final. EPA-540-R-070-

002 OSWER 9285.7-82.

Fisher and Arnold Environmental, Inc., 2010. Indoor Air Sampling Study Report. M&F Business

Credit, Inc., Property, Macon Road and Big Orange Road, Memphis, Tennessee. Fisher and

http://www.epa.gov/Region4/waste/ots/healtbul.htm



Operable Unit 2

Arnold, Inc., Memphis, Tennessee. Hazardous Substances Databank.

http://toxnet.nlm.nih.gov/Hosman, R.L. (1988).

Geohydrologic framework of the Gulf Coastal Plain: U.S. Hydrologic Atlas HA-695, 2 sheets.

Parks, W.S., 1990. Hydrogeology and Preliminary Assessment of the Potential for Contamination

of the Memphis Aquifer in the Memphis Area, Tennessee: (U.S. Geological Survey, Water

Resources Investigation Report, 90-4092, 37 p., illus.)

Shelby County, 1999. Rules and Regulations of Wells in Shelby County Tennessee Department of

Environment and Conservation.

Tetra Tech EM, 2003. Preliminary Assessment Narrative Report, NF, Memphis, Shelby County,

Tennessee. Division of Superfund. Tennessee Department of Environment and Conservation

(2011, May Revised).

Tetra Tech EM, 2005. Site Inspection Report for National Fireworks, Cordova, Shelby County,

Tennessee.

Tennessee Water Quality Control Board, Division of Water Pollution Control. General Water

Quality Criteria. Chapter 1200-04-03. http://www.tn.gov/sos/rules/1200/1200-04/1200-04-

03.20110531.pdf

Weidemeier, T.H., M. Swanson, D. Montoux, E.K. Gordon, J. Wilson, B. Wilson, D.H. Kampbell

,

P.E. Haas, R.N. Miller, J.E. Hansen, and F.H. Chapelle. (1998): Technical Protocol for Evaluating

Natural Attenuation of Chlorinated Solvents in Ground Water. National Risk Management

Research Laboratory, Office of Research and Development, U.S. EPA.

http://www.tn.gov/sos/rules/1200/1200-04/1200-04-03.20110531.pdf

http://www.tn.gov/sos/rules/1200/1200-04/1200-04-03.20110531.pdf

FIGURES

\

\

0

A-2

LEGEND - Existing Parcels

- Former Site

- Industrial Park Boundary

_,___ Railroad Tracks

- Surface Water

C3 Burn Pit Outline

300 600

Feet

1:7.200

A

e l.:p:t Unit..t su:es

PA Environmental Proteccion Agency

NATIONAL FIREWORKS CORDOVA,

SHELBY COUNTY, TENNESSEE

TDD No.TTEMI-05-003-0050

FIGURE 1

SITE LAYOUT

1"11:: I TETRA TECH

I i ' , • i ~ ~ ~

~ f • ~ ! ., • ' ~

' ' ~ ~ ~ ~ !

t ' < i ! i • • ~

~ 1 ! ~

~ ~ • •

c:J Security Signals Property Boundary

X Struct1ures no Longer Present

0 200 400 800

Figure 2 Site Location Map

National Fireworks OU2 9509 Macon Road

Cordova, TN

Figure 3 General Stratigraphy of the Site


Cordova, TN

A co ~:!:

8 305

295

285

275

265

255

245 NOT TO SCALE

2.35 - '--------------------------------------l 235

Le end

~ - Clayey Silt D - Silty Sand • - Sand And Gravel

~ - Clayey Sili With Sand . ~ - Sand [gj - Grovel With Clayey Sand 200 0 200

D - Clayey Sand fill - Sand/Silty Sand With Some Grovel D - Cloy (Jackson) Feet Hori zontal Scale

Vertical Scale: 1" 20'

\ \ E,dotooet\cod\CAIJ PROJECTS\45Sl SECURilY SIG~AL'l\Pioos\4563_9001_CROSS SEC_SECURITY SIGNAL.Llll.dwg

305

295

285

27!)

265

255

245

235

Figure 4a Hydroge<Jiogic Cross Secfion A·A' and B·B'

Na)Onal Fireworks OU2 9509 Maoon Road

Cordova, TN

REQUESTED BY: HODSKINS ORAVIN BY:

EN SliFE

2€6

255

245

235

e D 1£

2. D' J 05 JIJ5

295 295

28S 285

275 275

265 265

255 255

245 2q5

235 2l5

200 0

Horizontal Scale

Vertical Scale: 1" 20'

200

Feet

E2J - Clayey Silt With Sand

D - Clayey So nd

0 - Sil ly Sand

~ - Sand

~ - Sand/ Silty Sond With Sorne Gravel

• - Sand And Grovel

rn -Grovel With Clayey Sand

D - Cloy (Jackson)

Ft;rll'e4b Hydr<>Jeclogio ero.. s.if.on C·C' an<l D· 0'

Ne-..ora Fre.A'Orks OU2 9509M"-""'Rcad

C<lrdOva, TN

ENSAFE REOUESTEO BY: HODSKINS OR.IWU BY: BRONSCtl

OWG DAlE: 02/25/14 DWG 1¥.>: 4563....8001

,.....,.$ido:l~

(800) )~~7)62: ~v;an ~~~. .. w ... w.: n)Cik.ct>:n

Figure 5

Risk Assessment Conceptual Site Model

Figure 6 3D Site Conceptual Model National Fireworks OU2

9509 Macon Road Cordova, TN

• Exceeds MCL and Tap Water RSL (2013)

• Exceeds MCL only (2013)

• Exceeds Tap Water RSL only (2013)

o No Exceeclance (2013)

• Non-Detect (2013)

~--- Contour Interval (dashed where inferred)

Note: all units are in !Jg/l

• - indicate MW sample locations

MCL= Maximum Contaminant l evel

RSL= Regional Screening Level

Figure 7 Tetrach loroethene in Groundwater

August 2013 Security Signals Inc. 9509 Macon Road

Cordova, Tennessee

EN SliFE

Service l ayer Credls: Source: Esri, Dig1131Giobe, GeoEye. i--cubed, Earthst:ar Geographies, CNES/Airbus OS. USDA. USGS, AEX. Getmappng. Aefogrid. tGN.. IGP. SW:Sstopo. and the GIS User Commuity

• Exceeds MCL and Tap Water RSL (2013)

• Exceeds MCL only (2013)

• Exceeds Tap Water RSL only (2013)

o No Exceedance (2013)

• Non-Detect (2013)

- contour Interval (dashed where inferred)

Note: all units are in ~g/L

• - indicate MW sample locations

MCL= Maximum Contaminant Level

RSL= Regional Screening Level

FigureS Trichloroethene in Groundwater

August2013 Security Signals Inc. 9509 Macon Road

Tennessee

EN SliFE UUJO.-SBiJ.-1961

W'NW.t:NSAf£.00/.1

Service l ayer Credis: Source: Esti, Digital Globe. GeoEye., i-<Ubed, Earthstar Geographies, CNES/Ai'bus OS. USDA. USGS, AEX, Getmappftg. Aeiogrid, fGN., IGP. swisstopo, and the GIS User Commm.'ty

• Monitoring Well Sample Location

• Proposed Monitoring Well Location

• Proposed Surface Water Sample Location

1"77/'1 Phytoremediation Barrier (To Be Finalized in Remedial ~Design)

r-1 Source/Plume Area (To Be Finalized in Remedial ~Design)

0

Note: Source/Plume areas are approximate.

125 250

Treatment Areas that Require Phytoremediation


Cordova, TN

EN SliFE

Service layer Cred'ts: Source: Esri. ~itJIGiobe, GeoEye, i<Ubed, Earthstar Geographies. CNES/Ai'bus OS. USDA. USGS. AEX. Getrnappi'lg. Aerogrid, tGN. IGP. swlsstopo. and the GIS User Comi'I'M.rity

TABLES

Table 1

Summary of Chemicals of Concern and

Medium-Specific Exposure Point Concentrations

National Fireworks OU2


Scenario Timeframe: Future

Medium: Groundwater

Exposure Medium: Groundwater

Exposure

Point Chemical of Concern Units

Detection

Frequency

Exposure Point

Concentration

Exposure Point

Concentration

Units

Statistical

Measure

Site 1,1,1-Trichloroethane 0.039 J 1500 ppb 25/76 124 ppb UCL

Site 1,1,2-Trichloroethane 0.12 J 25 J ppb 15/76 2.71 ppb UCL

Site 1,1-Dichloroethane 0.23 J 13000 ppb 45/76 1060 ppb UCL

Site 1,1-Dichloroethene 0.44 J 23000 ppb 45/76 1980 ppb UCL

Site 1,4-Dioxane 9.2 J 99 J ppb 5/32 21.5 ppb UCL

Site cis-1,2-Dichloroethene 0.048 J 1900 ppb 57/76 400 ppb UCL

Site Methylene chloride 4 J 75 J ppb 6/76 3.38 ppb UCL

Site Tetrachloroethene 0.15 J 9500 ppb 51/76 2450 ppb UCL

Site Trichloroethene 0.18 J 15000 ppb 67/76 1880 ppb UCL

Site Vinyl chloride 0.18 J 230 ppb 24/76 26.4 ppb UCL

Site bis(2-Ethylhexyl)phthalate 3.2 J 8.1 ppb 3/8 810 ppb UCL

Site Iron 122 48600 ppb 8/8 31600 ppb UCL

Site Manganese 22.6 3730 ppb 8/8 1280 ppb UCL

Notes

ppb = parts per billion

UCL = Upper Confidence Limit

J = Estimated value

Minimum

Concentration

Detected

Maximum

Concentration

Detected

Table 2

Cancer Toxicity Data Summary



Pathway: Ingestion, Dermal

Chemical of Concern

Oral Cancer Slope

Factor

Dermal Cancer

Slope Factor

Slope Factor

Units

Weight of Evidence /

Cancer Guideline

Description Source

Tetrachloroethene (PCE) 2.10E-03 2.10E-03 (mg/kg-day) B1 IRIS

Trichloroethene (TCE) 4.60E-02 4.60E-02 (mg/kg-day) A IRIS

cis- 1,2-Dichloroethene (DCE) -- -- -- unknown --

Vinyl chloride 7.20E-01 7.20E-01 (mg/kg-day) A IRIS

1,1,1-Trichloroethane -- -- -- D --

1,1-Dichloroethane (DCA) 5.70E-03 5.70E-03 (mg/kg-day) C CALEPA

1,1-Dichloroethene (DCE) -- -- -- C IRIS

1,4-Dioxane 1.00E-01 1.00E-01 (mg/kg-day) B2 IRIS

bis(2-Ethylhexyl)phthalate 1.40E-02 1.40E-02 (mg/kg-day) -- CALEPA

Iron -- -- -- -- --

Manganese -- -- -- D --

Methylene chloride 2.00E-03 2.00E-03 (mg/kg-day) B IRIS

1,1,2-Trichloroethane 5.70E-02 5.70E-02 (mg/kg-day) C IRIS

Pathway: Inhalataion

Chemical of Concern Unit Risk Units

Inhalation

Cancer Slope

Factor Units

Weight of Evidence /

Cancer Guideline

Description Source

Date (MM/DD/

YYYY)

Tetrachloroethene (PCE) 2.60E-07 (ug/m3)

-12.10E-02 (mg/kg-day)

-1B1 IRIS 2/10/2012

Trichloroethene (TCE) 4.10E-06 (ug/m3)

-17.00E-03 (mg/kg-day)

-1A IRIS 9/28/2011

cis- 1,2-Dichloroethene (DCE) -- -- -- -- unknown -- 9/30/2010

Vinyl chloride 4.40E-06 (ug/m3)

-11.50E-02 (mg/kg-day)

-1A IRIS 8/7/2000

1,1,1-Trichloroethane -- -- -- -- unknown -- 9/28/2001

1,1-Dichloroethane (DCA) 1.60E-06 (ug/m3)

-1-- -- C CALEPA/IRIS 1/1/2000

1,1-Dichloroethene (DCE) -- -- -- -- C IRIS 8/3/2002

1,4-Dioxane 5.00E-06 (ug/m3)

-1-- (mg/kg-day)

-1B2 IRIS 9/20/2013

bis(2-Ethylhexyl)phthalate 2.40E-06 (ug/m3)

-1-- IRIS -- CALEPA 1999

Iron -- -- -- -- -- -- --

Manganese -- -- -- -- D IRIS 12/1/1996

Methylene chloride 1.00E-08 (ug/m3)

-1-- IRIS B IRIS 11/18/2011

1,1,2-Trichloroethane 1.60E-05 (ug/m3)

-1-- IRIS C IRIS 2/1/1994

Units Weight of Evidence Description

kg = kilogram

mg = miligram

ug = microgram

m3 = cubic meter

--

9/20/2013

Date (MM/DD/YYYY)

2/10/2012

9/28/2011

9/30/2010

8/7/2000

9/28/2001

1/1/2000

8/3/2002

11/18/2011

2/1/1994

12/1/1996

1999





Group B1: Limited evidence/data regarding

carcinogenicity in humans

Group B2: Sufficient evidence in animals and

inadequate or no evidence in humans


Table 3

Non-Cancer Toxicity Data Summary



Pathway: Ingestion, Dermal

Chemical of Concern

Chronic/

Subchronic

Oral RfD

Value Oral RfD Units

Dermal

RfD

Dermal RfD

Units

Primary Target

Organ

Combined

Uncertainty/

Modifying

Factors

Sources of

RfD: Target

Organ

Dates of RfD:

Target Organ

(MM/DD/YY

YY)

Tetrachloroethene (PCE) Chronic 6.00E-03 mg/kg-day 6.00E-03 mg/kg-day Neurotoxicity 10/1 IRIS 2/10/2012

Trichloroethene (TCE) Chronic 5.00E-04 mg/kg-day 5.00E-04 mg/kg-day heart 100/1 IRIS 9/28/2011

cis- 1,2-Dichloroethene

(DCE) Chronic 2.00E-03 mg/kg-day 2.00E-03 mg/kg-day kidney 300 IRIS 9/30/2010

Vinyl chloride Chronic 3.00E-03 mg/kg-day 3.00E-03 mg/kg-day liver 30/1 IRIS 8/7/2000

1,1,1-Trichloroethane Chronic 2.00 mg/kg-day 2.00 mg/kg-day liver 1000/1 IRIS 9/28/2001

1,1-Dichloroethane (DCA)Chronic 2.00E-01 mg/kg-day 2.00E-01 mg/kg-day unknown -- PPRTV C 1/1/2000

1,1-Dichloroethene (DCE)Chronic 5.00E-02 mg/kg-day 5.00E-02 mg/kg-day liver 100/1 IRIS 8/3/2002

1,4-Dioxane Chronic 3.00E-02 mg/kg-day 3.00E-02 mg/kg-day liver and kidney 300/1 IRIS 9/20/2013

bis(2-Ethylhexyl)phthalate 2.00E-02 mg/kg-day 2.00E-02 mg/kg-day -- -- -- --

Iron 7.00E-01 mg/kg-day 7.00E-01 mg/kg-day -- -- -- --

Manganese 2.40E-02 mg/kg-day 2.40E-02 mg/kg-day CNS 10 IRIS 12/1/1993

Methylene chloride 6.00E-03 mg/kg-day 6.00E-03 mg/kg-day liver 30 IRIS 11/18/2011

1,1,2-Trichloroethane 4.00E-02 mg/kg-day 4.00E-02 mg/kg-day liver, CNS 10 IRIS 2/1/1995

Pathway: Inhalataion

Chemical of Concern

Chronic/

Subchronic

Inhalation

RfC Value

Inhalation

RfC Units

Inhalation

RfD

Inhalation RfD

Units

Primary Target

Organ

Combined

Uncertainty/

Modifying

Factors

Sources of

RfD: Target

Organ

Dates of RfD:

Target Organ

(MM/DD/YY

YY)

Tetrachloroethene (PCE) Chronic 4.00E-02 mg/m3

-- -- Neurotoxicity 10/1 IRIS 2/10/2012

Trichloroethene (TCE) Chronic 2.00E-03 mg/m3

-- -- heart 100/1 IRIS 9/28/2011

cis- 1,2-Dichloroethene

(DCE) -- -- -- -- -- -- 3000 -- 9/30/2010

Vinyl chloride Chronic 1.00E-01 mg/m3

2.90E-02 -- liver 30/1 IRIS 8/7/2000

1,1,1-Trichloroethane Chronic 5.00 mg/m3

-- -- liver 1000/1 IRIS 9/28/2001

1,1-Dichloroethane (DCA)Chronic 5.00E-01 mg/m

3-- -- unknown -- HEAST 1/1/2000

1,1-Dichloroethene (DCE)Chronic 2.00E-01 mg/m

3-- -- liver 100/1 IRIS 8/3/2002

1,4-Dioxane Chronic 3.00E-02 mg/m3

-- -- liver and kidney 300/1 IRIS 9/20/2013

bis(2-Ethylhexyl)phthalate -- -- -- -- -- -- -- -- --

Iron -- -- -- -- -- -- -- -- --

Manganese Chronic 5.00E-05 mg/m3

-- -- CNS 10 IRIS 12/1/1993

Methylene chloride Chronic 6.00E-01 mg/m3

-- -- liver 30 IRIS 11/18/2011

1,1,2-Trichloroethane Chronic 2.00E-04 mg/m3

-- -- liver, CNS 10 IRIS 2/1/1995

Notes

IRIS = Integrated Risk Information System

HEAST = Health Effects Assessment Summary Tables

Table 4

Risk Characterization Summary - Carcinogens




Receptor Population: Resident (Lifetime weighted average)

Chemical of Concern Ingestion Inhalation Dermal Exposure Routes Total

Onsite (Plumes C, D, and E) 1,1,1-Trichloroethane - - - -

Onsite (Plumes C, D, and E) 1,1,2-Trichloroethane 2.30E-06 8.92E-06 1.62E-07 1.14E-05

Onsite (Plumes C, D, and E) 1,1-Dichloroethane 9.00E-05 3.49E-04 6.82E-06 4.46E-04

Onsite (Plumes C, D, and E) 1,1-Dichloroethene - - - -

Onsite (Plumes C, D, and E) 1,4-Dioxane 3.20E-05 - 1.11E-07 3.21E-05

Onsite (Plumes C, D, and E) cis-1,2-Dichloroethene - - - -

Onsite (Plumes C, D, and E) Methylene chloride 3.14E-07 1.76E-08 1.05E-08 3.42E-07

Onsite (Plumes C, D, and E) Tetrachloroethene 7.64E-05 1.31E-04 4.41E-05 2.52E-04

Onsite (Plumes C, D, and E) Trichloroethene 4.02E-03 4.02E-03 5.95E-04 8.64E-03

Onsite (Plumes C, D, and E) Vinyl chloride 1.55E-03 8.21E-05 9.19E-05 1.72E-03

Onsite (Plumes C, D, and E) bis(2-Ethylhexyl)phthalate 1.69E-06 - - 1.69E-06

Onsite (Plumes C, D, and E) Iron - - - -

Onsite (Plumes C, D, and E) Manganese - - - -

Total Risk 5.77E-03 4.59E-03 7.38E-04 1.11E-02

Carcinogen Risk

Medium Exposure Medium Exposure Point

Groundwater Groundwater

Table 4

Risk Characterization Summary - Carcinogens




Receptor Population: Industrial Worker

Receptor Age: Adult

Chemical of Concern Ingestion Inhalation Dermal Exposure Routes Total

Onsite (Plumes C, D, and E) 1,1,1-Trichloroethane -- -- -- --


Onsite (Plumes C, D, and E) 1,1-Dichloroethane 2.12E-05 6.93E-05 3.32E-06 9.38E-05

Onsite (Plumes C, D, and E) 1,1-Dichloroethene -- -- -- --

Onsite (Plumes C, D, and E) 1,4-Dioxane -- -- 5.42E-08 5.42E-08

Onsite (Plumes C, D, and E) cis-1,2-Dichloroethene -- -- -- --


Onsite (Plumes C, D, and E) Tetrachloroethene 1.80E-05 2.59E-05 2.14E-05 6.53E-05

Onsite (Plumes C, D, and E) Trichloroethene 3.02E-04 3.15E-04 1.01E-04 7.18E-04

Onsite (Plumes C, D, and E) Vinyl chloride 6.65E-05 4.74E-06 1.05E-05 8.17E-05

Onsite (Plumes C, D, and E) bis (2-Ethylhexyl)phthalate 3.96E-07 -- 3.96E-07

Onsite (Plumes C, D, and E) Iron 7.52E-06 -- -- 7.52E-06

Onsite (Plumes C, D, and E) Manganese -- -- -- --

Total Risk 4.16E-04 4.17E-04 1.36E-04 9.69E-04


Carcinogen Risk


Table 5

Risk Characterization Summary - Non-Carcinogens




Receptor Population: Resident

Receptor Age: Child

Ingestion Inhalation Dermal Exposure Routes Total

Onsite (Plumes C, D, and E) 1,1,1-Trichloroethane liver 3.95E-03 1.18E-02 6.96E-04 1.64E-02

Onsite (Plumes C, D, and E) 1,1,2-Trichloroethane liver, CNS 4.34E-02 6.51E+00 3.06E-03 6.56E+00

Onsite (Plumes C, D, and E) 1,1-Dichloroethane unknown 3.39E-01 1.02E+00 2.64E-02 1.39E+00

Onsite (Plumes C, D, and E) 1,1-Dichloroethene liver 2.53E+00 4.75E+00 3.37E-01 7.62E+00

Onsite (Plumes C, D, and E) 1,4-Dioxane liver and kidney 4.59E-02 -- 1.66E-04 4.61E-02

Onsite (Plumes C, D, and E) cis-1,2-Dichloroethene kidney 1.28E+01 -- 1.60E+00 1.44E+01

Onsite (Plumes C, D, and E) Methylene chloride liver 3.60E-02 2.70E-03 1.37E-03 4.01E-02

Onsite (Plumes C, D, and E) Tetrachloroethene Neurotoxicity 2.61E+01 2.93E+01 1.50E+01 7.04E+01

Onsite (Plumes C, D, and E) Trichloroethene heart 2.41E+02 4.51E+02 3.85E+01 7.31E+02

Onsite (Plumes C, D, and E) Vinyl chloride liver 5.63E-01 1.27E-01 4.54E-02 7.35E-01

Onsite (Plumes C, D, and E) bis(2-Ethylhexyl)phthalate -- 2.59E-02 -- -- 2.59E-02

Onsite (Plumes C, D, and E) Iron -- 2.88E+00 -- 1.90E-02 2.90E+00

Onsite (Plumes C, D, and E) Manganese CNS 3.40E+00 -- 5.62E-01 3.96E+00

Total Risk 2.90E+02 4.93E+02 5.61E+01 8.39E+02


Exposure Point

Non-Carcinogenic Hazard Quotient

Primary Target OrganMedium Exposure Medium Chemical of Concern

Table 5





Receptor Population: Resident

Receptor Age: Adult


Onsite (Plumes C, D, and E) 1,1,1-Trichloroethane -- 1.18E-02 -- 1.18E-02

Onsite (Plumes C, D, and E) 1,1,2-Trichloroethane liver, CNS -- 6.51E+00 -- 6.51E+00

Onsite (Plumes C, D, and E) 1,1-Dichloroethane (DCA) kidney, CNS 1.45E-01 1.02E+00 1.14E-02 1.18E+00

Onsite (Plumes C, D, and E) 1,1-Dichloroethene (DCE) liver, kidney, CNS 1.09E+00 4.75E+00 1.46E-01 5.99E+00

Onsite (Plumes C, D, and E) 1,4-Dioxane liver, kidney 1.97E-02 -- 7.08E-05 1.98E-02

Onsite (Plumes C, D, and E) cis-1,2-Dichloroethene (DCE) -- 5.49E+00 -- 6.93E-01 6.18E+00

Onsite (Plumes C, D, and E) Methylene chloride liver 1.54E-02 2.70E-03 5.81E-04 1.87E-02

Onsite (Plumes C, D, and E) Tetrachloroethene (PCE) kidney, liver, Neurotoxicity 1.12E+01 2.93E+01 6.68E+00 4.72E+01

Onsite (Plumes C, D, and E) Trichloroethene (TCE) liver, lung, CNS 1.03E+02 4.51E+02 1.71E+01 5.71E+02


Onsite (Plumes C, D, and E) bis(2-Ethylhexyl)phthalate -- 1.11E-02 -- -- 1.11E-02

Onsite (Plumes C, D, and E) Iron -- 1.24E+00 -- 6.45E-03 1.25E+00

Onsite (Plumes C, D, and E) Manganese CNS 1.46E+00 -- 1.90E-01 1.65E+00

Total Risk 1.24E+02 4.93E+02 2.48E+01 6.41E+02

Chemical of Concern Primary Target Organ




Table 5





Receptor Population: Industrial Worker

Receptor Age: Adult



Onsite (Plumes C, D, and E) 1,1,2-Trichloroethane liver 6.64E-03 1.55E+00 9.72E-04 1.56E+00

Onsite (Plumes C, D, and E) 1,1-Dichloroethane (DCA) kidney, CNS 5.20E-02 2.42E-01 8.16E-03 3.02E-01

Onsite (Plumes C, D, and E) 1,1-Dichloroethene (DCE) liver, kidney, CNS 3.88E-01 1.13E+00 1.04E-01 1.62E+00

Onsite (Plumes C, D, and E) 1,4-Dioxane liver, kidney 7.02E-03 -- 5.05E-05 7.07E-03

Onsite (Plumes C, D, and E) cis-1,2-Dichloroethene (DCE) -- 1.96E+00 -- 4.95E-01 2.46E+00


Onsite (Plumes C, D, and E) Tetrachloroethene (PCE) kidney, liver, Neurotoxicity 3.99E+00 6.98E+00 4.77E+00 1.57E+01

Onsite (Plumes C, D, and E) Trichloroethene (TCE) liver, lung, CNS 3.68E+01 1.07E+02 1.22E+01 1.56E+02


Onsite (Plumes C, D, and E) bis(2-Ethylhexyl)phthalate 3.96E-03 -- -- --

Onsite (Plumes C, D, and E) Iron 4.42E-01 -- 4.61E-03 4.47E-01

Onsite (Plumes C, D, and E) Manganese 5.21E-01 -- 1.36E-01 6.57E-01

Total Risk 4.43E+01 1.17E+02 1.77E+01 1.79E+02

Chemical of Concern Primary Target Organ




Table 6

Subsurface Soil Cleanup Levels

for Protection of Groundwater



Media: Subsurface soil

Site Area: Plumes C, D

Available Use: Current/Future expected to remain industrial

Controls to Ensure Restricted Use: ICs will be components of the selected remedy

Chemical of Concern

Cleanup Level

(ug/kg) Basis for Cleanup

Tetrachloroethene (PCE) 16 ug/kg Calculated SSL Protective of Groundwater

Trichloroethene (TCE) 16 ug/kg Calculated SSL Protective of Groundwater

cis- 1,2-Dichloroethene (DCE) 226 ug/kg Calculated SSL Protective of Groundwater

Vinyl chloride 647 ug/kg Calculated SSL Protective of Groundwater

1,1,1-Trichloroethane 8 ug/kg Calculated SSL Protective of Groundwater

1,1-Dichloroethane (DCA) 23 ug/kg Calculated SSL Protective of Groundwater

1,1-Dichloroethene (DCE) 2 ug/kg Calculated SSL Protective of Groundwater

1,4 -Dioxane 16 ug/kg Calculated SSL Protective of Groundwater

Abbreviations

ug/kg - microgram per kilogram

*Soil Screening Levels (SSLs) for Subsurface Soil Protective of Groundwater

Table 7

Cleanup Levels for Groundwater



Media: Groundwater

Site Area: Plumes C, D, and E

Available Use: Current/Future expected to remain industrial

Controls to Ensure Restricted Use: ICs will be components of the selected remedy

Chemical of Concern

Cleanup Level

(ug/L) Basis for Cleanup Risk at Cleanup level1

Tetrachloroethene (PCE) 5 MCL2

--

Trichloroethene (TCE) 5 MCL2

--

cis- 1,2-Dichloroethene (DCE) 70 MCL2

--

Vinyl chloride 2 MCL2

--

1,1,1-Trichloroethane 200 MCL2

--

1,1-Dichloroethane (DCA) 2.4 Human health risk based level 10-6

Excess cancer risk

1,1-Dichloroethene (DCE) 7 MCL2

--

1,4-Dioxane 0.67 Human health risk based level 10-6

Excess cancer risk

Abbreviations

ug/L microgram per liter

MCL Federal Maximum Contaminant Levels

Notes

1 Cleanup levels and residual risk information prsented in this table are based on the risk associated with exprosure to contamination through ingestion,

dermal contact, and inhaltion of VOCs whild showering by future child and adult residents.

2 The MCLs, which are considered chemical-specific ARARs for groundwater restoration, may not be attained for this Interim Action and are waived under

CERCLA Section 121(d)(4)(A). The remedy selected in this Interim Action ROD is only part of the total remedial action to be implemented at the Site and

under a Final ROD for the Site all ARARs , including MCLs, to be attained when completed.

Table 8

Cost Comparison for Remedial Alternatives

National Fireworks, OU2


Alternatives Description of Alternative Net Present Value Costs

Alternative 1 No action $0

Alternative 2

In-Situ Treatment of Groundwater and Subsurface Soil at

Plumes C, D, and E with Long-Term Monitoring and

Institutional Controls $4.0M

Alternative 3

Limited Injections/In-Situ Treatment of Groundwater

and Subsurface Soil at Plumes C, D, and E with Long-Term

Monitoring and Institutional Controls

$3.3M

Alternative 4

Phytoremediation of Groundwater and Subsurface


Institutional Controls $3.4M

Alternative 5

Combination of In-Situ Treatment and Phytoremediation of

Groundwater and Subsurface Soil at Plumes C, D, and E with

Long-Term Monitoring and Institutional Controls $4.1M

Notes:

Inflation rate 1.5%, based on CPI (all items), accessed 2-10-14, NSA since Dec 2012 (http://www.bls.gov/cpi/).

Discount rate 3.67%, based on 30-year T-bill yields, accessed 2-10-14, http://www.treasury.gov/resource-center/data-chart-center/interest-rates/Pages/TextView.aspx?data=yield

Table 9

Cost Estimate Summary of Selected Remedy



Components of Selected Remedy

Description

Predesign Activities 1 LS 498,000$ 498,000$

Phytoremediation

Vendor Support 1 LS 20,000$ 20,000$

Vendor Support 2 LS 40,000$ 80,000$

Clearing and Grading 1 LS 10,000$ 10,000$

Storm water controls 1 LS 5,000$ 5,000$

Phytoremediation - Implementation 327 trees 2,125$ 694,875$

Oversight 540 hours 200$ 108,000$

Equipment 19 days 500$ 9,500$

Mileage 950 miles 1$ 523$

Soil characterization 327 holes 120/sample 39,240$

Soil disposal (hazardous) 102.25 CY 300$ 30,675$

Soil disposal (non-hazardous) 306.75 CY 150$ 46,013$

Irrigation and Oversight 1 LS 15,000$ 15,000$

Contracts 40 hours 83/hour 3,320$

RACR 1 LS 15,000$ 15,000$

PM 40 hours 190/hour 7,600$

1,084,745$

Phytoremediation Operation and Maintenance

Tree monitoring/assessment 416 hours 200$ 83,200$

Annual reporting 16 hours 137$ 2,192$

24 hours 115$ 2,760$

8 hours 83$ 664$

8 hours 45$ 360$

4 hours 156$ 624$

4 hours 190$ 760$

90,560$

Pruning/cleanuout every 5 years

Tree subcontractor 1 LS 10,000$ 10,000$

Oversight 5 days 1300/day 6,500$

Milieage 125 miles 0.55/mile 69$

PM 4 hours 190/hour 760$

17,329$

Sampling - Initial LTM Event

Labor 136 200/hour 27,200$ 27,200$

Equipment 6 500/day 3,000$ 3,000$

Mileage 150 0.55 mile 83$ 83$

VOCs Analysis 41 110/each 4,510$ 4,510$

Shipping 6 100/each 600$ 600$

Contracts 4 83/hour 332$ 332$

Project Manager 8 190 hour 1,520$ 1,520$

Notes 37,245$

LS = lump sum

CY = cubic yard

Quantity Unit Unit Cost Cost

Table 9

Cost Estimate Summary of Selected Remedy



Components of Selected Remedy

Description

Annual Geochemical Sampling - per event

Additional Labor 6 hours 200/hour 1,200$

Geochemcial parameters 6 samples 400/sample 2,400$

Shipping 6 coolers 100/cooler 600$

Equipment 1 LS 1,000$ 1,000$

5,200$

Sampling - First LTM Optimization

Labor 48 hours 200/hour 9,600$

Equipment 3 days 500/day 1,500$

Mileage 75 miles 0.55/mile 41$

VOCs Analysis 21 samples 110/each 2,310$

Shipping 3 coolers 100/each 300$

Contracts 4 hours 83/hour 332$

PM 8 hours 190/hour 1,520$

15,603$

Sampling - Second LTM Optimization

Labor 41 hours 200/hour 8,200$

Equipment 3 days 500/day 1,500$


VOCs Analysis 16 samples 110/each 1,760$

Shipping 3 coolers 100/each 300$

Contracts 4 hours 83/hour 332$

Project Manager 8 hours 190/hour 1,520$

13,653$

Reporting

Data review/validation 16 hours 137/hour 2,192$

Report preparation 24 hours 115/hour 2,760$

GIS/CAD 8 hours 83/hour 664$

Administrative 8 hours 45/hour 360$

SME review 4 hours 156/hour 624$

Project Manager review 4 hours 190/hour 760$

7,360$

IC Support 40 LS 200/hour 8,000$

Annual VI Inspections 1 LS 4400 4,400$

Periodic VI Inspections and monitoring 1 LS 1200 1,200$

13,600$

Annual IC Inspection Monitoring

Site Inspection 4 hours 137/hour 548$


Letter report 4 hours 137/hour 548$

Administrative 1 hours 45/hour 45$

Project Manager Review 1 hours 190/hour 190$

1,345$

Five-year Review Costs 1 LS 40,000$ 40,000$

Notes

LS = lump sum Total Capital Costs 1,285,295$

CY = cubic yard

Quantity Unit Unit Cost Cost

Table 10

Potential Chemical -Specific ARARs and TBC Guidance



* The Interim Remedy selected in this Record of Decision is part of a larger final remedy to be completed at a later time. Restoration of ground water will not be

a remedial action objective, and therefore and ARAR, until the final remedy Record of Decision.

** MCLs which are considered chemical-specific ARARs are not expected to be fully attained as part of the Interim Action and will be waived under CERCLA

Section 121(d)(4).

Action/Media Requirements Prerequisite Citation(s)

Classification of

ground water Except for ground water in areas that have been

designated as Special Source Water, Site Specific

Impaired Ground Water, or meet the definition of

Unusable Ground Water, all Tennessee ground

water is designated General Use (GU) Ground

Water.

Groundwater classification in the

State of Tennessee – applicable

TDEC 0400-40-03-

.07(4)(b)

Restoration of

ground water as a

potential drinking

water source*

General Use Ground Water:

(a) shall not contain constituents that exceed those

levels specified in subparagraphs (1)(j) and (k) of

TDEC 0400-40-03-.03, including Primary Drinking

Water Regulations (Maximum Contaminant

Levels); and

(b) shall contain no other constituents at levels and

conditions which pose an unreasonable risk to the

public health or the environment.

Ground water classified as Class

GU under TDEC 0400-40-03-.07

requiring restoration - relevant

and appropriate

TDEC 0400-40-03-.08(2)

Maximum

Contaminant

Levels**

Tetrachloroethene (PCE) 5 ug/L

Trichloroethene (TCE) 5 ug/L

cis- 1,2-Dichloroethance

(DCE)

70 ug/L

Vinyl chloride 2 ug/L

1,1,1-Trichloroethane 200 ug/L

1,1-Dichloroethene (DCE) 7 ug/L

TDEC-0400-45-01-.25.

40 CFR 141.61(a) and (c).

Table 11

Potential Action-Specific ARARs and TBC Guidance



ARAR = applicable or relevant and appropriate requirement

CFR = Code of Federal Regulations

CWA = Clean Water Act of 1972

NPDES = National Pollutant Discharge Elimination System

DOT = U.S. Department of Transportation

EPA = U.S. Environmental Protection Agency

RCRA = Resource Conservation and Recovery Act of 1976

HMR = Hazardous Materials Regulations

HMTA = Hazardous Materials Transportation Act

TBC = to be considered

TCA = Tennessee Code Annotated

TDEC = Rules of theTennessee Department of Environment and Conservation, Chapter noted

UTS = Universal Treatment Standard

Action Requirements Prerequisite Citation(s)

General construction standards—all land-disturbing activities (i.e., excavation, tree planting, etc.)

Activities causing

fugitive dust emissions

Shall take reasonable precautions to prevent particulate

matter from becoming airborne; reasonable precautions

shall include, but are not limited to, the following:

Fugitive emissions from demolition,

construction operations, grading, or the

clearing of land —applicable

TDEC 1200-3-8-.01(1)

use, where possible, of water or chemicals for control

of dust, and

TDEC 1200-3-8-.01(1)(a)

application of asphalt, oil, water, or suitable chemicals

on dirt roads, materials stock piles, and other surfaces

which can create airborne dusts;

TDEC 1200-3-8-.01(1)(b)

Shall not cause or allow fugitive dust to be emitted in such

a manner as to exceed 5 minute/hour or 20 minute/day

beyond property boundary lines on which emission

originates.

TDEC 1200-3-8-.01(2)

Activities causing

storm water runoff

(e.g., clearing, grading,

excavation)

Implement good construction management techniques

(including sediment and erosion controls, vegetative

controls, and structural controls) in accordance with the

substantive requirements of General Permit No.

TNR100000 to ensure that storm water discharge:

Dewatering or storm water runoff

discharges from land disturbed by

construction activity disturbance of 1

acre of total land applicable

TCA 69-3-108(j)

TDEC 0400-40-10-.03(2)

does not violate water quality criteria as stated in

TDEC 1200-4-3-.03 including but not limited to

prevention of discharges that causes a condition in

which visible solids, bottom deposits, or turbidity

impairs the usefulness of waters of the state for any of

the designated uses for that water body by TDEC

1200-4-4

Storm water discharges from

construction activities –TBC

General Permit No. TNR100000

Section 5.3.1(a)

does not contain distinctly visible floating scum, oil,

or other matter;


Section 5.3.1(b)

Table 11


















does not cause an objectionable color contrast in the

receiving stream; and


Section 5.3.1(c)

results in no materials in concentrations sufficient to

be hazardous or otherwise detrimental to humans,

livestock, wildlife, plant life, or fish and aquatic life in

the receiving stream.


Section 5.3.1(d)

Monitoring well installation, operation, and abandonment

Well construction-

local regulations

All wells shall be constructed in a manner that will guard

against contamination of the groundwater aquifers

underlying Shelby County. No person shall construct,

repair, modify, or abandon or cause to be constructed,

repaired, modified, or abandoned any well contrary to the

provisions of these Rules and Regulations.

All materials, components, parts, etc., used in the

installation of a monitoring or recovery well, such as the

casing, screen, pumping equipment, pressure tank, wiring,

pipe and other such components, must comply with the

standards as established in the TDEC Rule 1200-4-10

entitled “Well Construction and Abandonment Standards.”

Well construction, maintenance, and

abandonment - TBC

Shelby County Well Construction Code, Section 6.01

and 7

Section 6.04

Construction of

groundwater

monitoring well

All monitoring wells must be cased in a manner that

maintains the integrity of the monitoring well bore hole;

this casing must be screened or perforated and packed with

gravel or sand, where necessary, to enable collection of

groundwater samples; the annular space above the sampling

depth must be sealed to prevent contamination of

groundwater and samples.

Construction of RCRA groundwater

monitoring well—relevant and

appropriate

40 CFR 264.97(c)

TDEC 0400-12-01-.06(6)(h)(3)

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Abandonment of

groundwater

monitoring well

Cased wells shall be grouted and sealed in accordance with

subparagraphs 2(b) and 2(c) of TDEC 0400-45-09-.16

Permanent plugging and abandonment of a well—

relevant and appropriate

TDEC 0400-45-09-.16(2)

Should a well be abandoned for any reason, the well shall

be filled in a manner prescribed by Section 9 of the [Shelby

County Well Construction] Rules and Regulations.

Permanent plugging and abandonment of a well –

TBC

Shelby County Well Construction Code,

Section 9.01

Observation and monitoring wells being actively used for

the investigation or management of groundwater by federal,

state or local governmental agencies or research

organizations may be classified as temporarily abandoned

and shall be covered with a secure cap such that the cover

is water tight and cannot be removed except with the aid of

equipment or the use of tools.

Temporary abandonment of a monitoring well - TBC Section 9.01.F

Underground injection well installation abandonment

Waste characterization and storage—primary and secondary waste streams (e.g., IDW, soils from well borings/tree plantings, purge water, etc.)

Characterization of

solid waste

Must determine if solid waste is excluded from regulation

under 40 CFR 261.4(b); and

Generation of solid waste as defined in 40 CFR

261.2 and which is not excluded under 40 CFR

261.4(a) —applicable

40 CFR 262.11(a)

TDEC 0400-12-01-.03(1)(b)(1)

Must determine if waste is listed as hazardous waste under

40 CFR Part 261; or

Generation of solid waste which is not excluded

under 40 CFR 261.4(a)—applicable

40 CFR 262.11(b)

TDEC 0400-12-01-.03(1)(b)(2)

Table 11


















Must determine whether the waste is (characteristic waste)

identified in subpart C of 40 CFR part 261by either:

(1) Testing the waste according to the methods set forth

in subpart C of 40 CFR part 261, or according to an

equivalent method approved by the Administrator under 40

CFR 260.21; or

(2) Applying knowledge of the hazard characteristic of

the waste in light of the materials or the processes used.

40 CFR 262.11(c)

TDEC 0400-12-01-.03(1)(b)(3)

Must refer to Parts 261, 262, 264, 265, 266, 268, and 273

of Chapter 40 for possible exclusions or restrictions

pertaining to management of the specific waste

Generation of solid waste which is determined to be

hazardous – applicable

40 CFR 262.11(d);

TDEC 0400-12-01-.03(1)(b)(4)

Characterization of

hazardous waste (all

primary and secondary

wastes)

Must obtain a detailed chemical and physical analysis on a

representative sample of the waste(s), which at a minimum

contains all the information that must be known to treat,

store, or dispose of the waste in accordance with pertinent

sections of 40 CFR 264 and 268.

Generation of RCRA-hazardous waste for storage,

treatment or disposal – applicable

40 CFR 264.13(a)(1)

Determinations for

management of

hazardous waste

Must determine each EPA Hazardous Waste Number

(waste code) applicable to the waste in order to determine

the applicable treatment standards under 40 CFR 268 et

seq..

Note: This determination may be made concurrently with

the hazardous waste determination required in Sec. 262.11

of this chapter.

Generation of RCRA hazardous waste for storage,

treatment or disposal – applicable

40 CFR 268.9(a)

TDEC 0400-12-01-.10(1)(i)(1)

Must determine the underlying hazardous constituents [as

defined in 40 CFR 268.2(i)] in the characteristic waste.

Generation of RCRA characteristic hazardous waste

(and is not D001 non-wastewaters treated by

CMBST, RORGS, or POLYM of Section 268.42

Table 1) for storage, treatment or disposal –

applicable

40 CFR 268.9(a)

TDEC 0400-12-01-.10(1)(i)(1)

Table 11


















Must determine if the hazardous waste meets the treatment

standards in 40 CFR 268.40, 268.45, or 268.49 by testing

in accordance with prescribed methods or use of generator

knowledge of waste.

Note: This determination can be made concurrently with

the hazardous waste determination required in 40 CFR

262.11.

Generation of hazardous waste for storage, treatment

or disposal – applicable

40 CFR 268.7(a)

TDEC 0400-12-01-.10(1)(g)(1)(i)

Temporary storage of

hazardous waste in

containers

A generator may accumulate hazardous waste at the facility

provided that:

waste is placed in containers that comply with 40 CFR

265.171-173; and

Accumulation of RCRA hazardous waste on site as

defined in 40 CFR 260.10—applicable 40 CFR 262.34(a);

TDEC 0400-12-01-.03(4)(e)

40 CFR 262.34(a)(1)(i);

TDEC 0400-12-01-.03(4)(e)(2)(i)(I)

the date upon which accumulation begins is clearly

marked and visible for inspection on each container

40 CFR 262.34(a)(2);

TDEC 0400-12-01-.03(4)(e)(2)(ii)

container is marked with the words “hazardous waste”

or

40 CFR 264.34(a)(3)

TDEC 0400-12-01-.03(4)(e)(2)(iii)

container may be marked with other words that

identify the contents

Accumulation of 55 gal. or less of RCRA hazardous

waste at or near any point of generation—applicable

40 CFR 262.34(c)(1)

TDEC 0400-12-01-.03(4)(e)(5)(i)(II)

Use and management

of hazardous waste in

containers

If container is not in good condition (e.g. severe rusting,

structural defects) or if it begins to leak, must transfer waste

into container in good condition.

Storage of RCRA hazardous waste in containers—

applicable

40 CFR 265.171

TDEC 0400-12-01-.05(9)(b)

Use container made or lined with materials compatible with

waste to be stored so that the ability of the container is not

impaired.

40 CFR 265.172

TDEC 0400-12-01-.05(9)(c)

Keep containers closed during storage, except to

add/remove waste.

40 CFR 265.173(a)

TDEC 0400-12-01-.05(9)(d)(1)

Table 11


















Open, handle and store containers in a manner that will not

cause containers to rupture or leak.

40 CFR 265.173(b)

TDEC 0400-12-01-.05(9)(d)(2)

Storage of hazardous

waste in container area

Area must have a containment system designed and

operated in accordance with 40 CFR 264.175(b).

Storage of RCRA-hazardous waste in containers with

free liquidsapplicable

40 CFR 264.175(a)

TDEC 0400-12-01-.06(9)(f)(1)

Area must be sloped or otherwise designed and operated to

drain liquid from precipitation, or

Containers must be elevated or otherwise protected from

contact with accumulated liquid.

Storage of RCRA-hazardous waste in containers that

do not contain free liquids —applicable

40 CFR 264.175(c)

TDEC 0400-12-01-.06(9)(f)(3)

Treatment/disposal of wastes— primary and secondary wastes (e.g., IDW, soils from well borings/tree plantings, purge water, etc.)

Disposal of non-

hazardous solid waste

All solid waste managed as non-hazardous Solid Waste must be disposed of at permitted facility

under TDEC 0400-11-01-.02(b)

TDEC 0400-11-01

Disposal of RCRA-

hazardous waste in a

land-based unit

May be land disposed if it meets the requirements in the

table “Treatment Standards for Hazardous Waste” at 40

CFR 268.40 before land disposal.

Land disposal, as defined in 40 CFR 268.2, of

restricted RCRA waste—applicable

40 CFR 268.40(a)

TDEC 0400-12-01-.10(3)(a)

Must be treated according to the alternative treatment

standards of 40 CFR 268.49(c) or according to the UTSs

[specified in 40 CFR 268.48 Table UTS] applicable to the

listed and/or characteristic waste contaminating the soil

prior to land disposal.

Land disposal, as defined in 40 CFR 268.2, of

restricted hazardous soils—applicable

40 CFR 268.49(b)

TDEC 0400-12-01-.10(3)(j)(2)

Table 11


















Disposal of RCRA

wastewaters into CWA

wastewater treatment

unit

Waste otherwise restricted under TDEC 0400-12-01-.10 are

not prohibited from land disposal if the waste meet any of

the following criteria, unless the wastes are subject to a

specified method of treatment other than DEACT in 40

CFR 268.40, or are D003 reactive cyanide:

(I) The wastes are managed in a treatment system which

subsequently discharges to waters of the U.S. pursuant to a

permit issued under section 402 of the Clean Water Act; or

(II) The wastes are treated for purposes of the pretreatment

requirements of section 307 of the Clean Water Act; or

(III) The wastes are managed in a zero discharge system

engaged in Clean Water Act-equivalent treatment as

defined in part (2)(h)1 of this rule; or

(IV) The wastes no longer exhibit a prohibited

characteristic at the point of land disposal.

Restricted RCRA characteristic hazardous

wastewaters managed in a wastewater treatment

system applicable

40 CFR 268.1(c)(4)(iv)

TDEC 0400-12-01-.10(1) (a)(3)(iv)

Pretreatment standards

for discharges into

POTW

General prohibitions:

A user may not introduce into a POTW any pollutants

which cause pass through or interference, as defined in 40

CFR 403.3 (TDEC 0400-40-14.03).

Discharge of pollutants into or transported by truck

or rail or otherwise introduced into POTW, as

defined in 40 CFR 403.3 (TDEC 0400-40-14-.03),

by industrial user—applicable

40 CFR 403.5(a)(1)

TDEC 0400-40-14.05(1)(a)

Table 11


















Specific prohibitions. The following pollutants shall not be

introduced into a POTW:

(1) pollutants which create a fire or explosion hazard,

including, wastestreams with a closed cup flashpoint of <

140 °F or 60 °C, using test methods specified in 40 §CFR

261.21;

(2) pollutants which will cause corrosive structural

damage, but in no case discharges with pH < 5.0, unless

POTW is designed to accommodate such discharges;

(3) solid or viscous pollutants in amounts which will

cause obstruction to flow resulting in interference;

(4) any pollutant, including oxygen demanding pollutants

(BOD) released in a discharge at flow rate and/or pollutant

concentration which will cause interference;

(5) heat in amounts which will inhibit biological activity

resulting in interference, but in no case heat in quantities

causing temperature at POTW to exceed 40°C (104°F)

unless alternate temperature limits approved by POTW;

(6) petroleum oil, nonbiodegradable cutting oil, or

products of mineral oil origin in amounts that will cause

interference or pass through;

(7) pollutants which result in presence of toxic gases,

vapors, or fumes within POTW in quantity that may cause

acute worker health and safety problems; and

(8) any trucked or hauled pollutants, except at discharge

points designated by the POTW.

40 CFR 403.5(b)(1)-(8)

TDEC 0400-40-14.05(2)(a)-(h)

Transportation of Wastes

Table 11


















Transportation of

hazardous materials

Shall be subject to and must comply with all applicable

provisions of the HMTA and HMR at 49 CFR 171-180.

Any person who, under contract with a department or

agency of the federal government, transports “in

commerce,” or causes to be transported or shipped, a

hazardous material

—applicable

49 CFR 171.1(c)

Transportation of

hazardous waste off

site

Must comply with the generator requirements of 40 CFR

262.20–23 for manifesting, Sect. 262.30 for packaging,

Sect. 262.31 for labeling, Sect. 262.32 for marking, Sect.

262.33 for placarding and Sect. 262.40, 262.41(a) for

record keeping requirements and Sect. 262.12 to obtain

EPA ID number.

Preparation and initiation of shipment of RCRA

hazardous waste off-site—applicable

40 CFR 262.10(h)

TDEC 0400-12-01-.03(1)(a)(8)

Transportation of

hazardous waste on-

site

The generator manifesting requirements of 40 CFR

262.20262.32(b) do not apply. Generator or transporter

must comply with the requirements set forth in 40 CFR

263.30 and 263.31 in the event of a discharge of hazardous

waste on a private or public right-of-way.

Transportation of hazardous wastes on a public or

private right-of-way within or along the border of

contiguous property under the control of the same

person, even if such contiguous property is divided

by a public or private right-of-way – applicable

40 CFR 262.20(f)

Management of

samples (i.e.

contaminated soils and

wastewaters)

Are not subject to any requirements of 40 CFR Parts 261

through 268 or 270 when:

Generation of samples of hazardous waste for

purpose of conducting testing to determine its

characteristics or composition---applicable

40 CFR 261.4(d)(1)

The sample is being transported to a laboratory for

the purpose of testing;

40 CFR 261.4(d)(1)((i)

The sample is being transported back to the

sample collector after testing; and

40 CFR 261.4(d)(1)(ii)

Table 11


















The sample collector ships samples to a

laboratory in compliance with U.S. Department

of Transportation, U.S. Postal Service, or any other

applicable shipping requirements, including packing

the sample so that it does not leak, spill or vaporize

from its packaging.

40 CFR 261.4(d)(2)

Institutional Controls

Waste left in place Institutional controls are required and shall include, at a

minimum, deed restrictions for sale and use of property,

and securing the area to prevent human contact with

hazardous substances which pose or may pose a threat to

human health or safety.

Hazardous substances left in place that may pose an

unreasonable threat to public health, safety, or the

environment-----relevant and appropriate

TDEC 0400-15-01-.08(10)

APPENDIX A

Responsiveness Summary

National Fireworks Superfund Site

Operable Unit 2


RESPONSIVENESS SUMAMRY

The following presents a summary of all the questions received either during the public meeting

on August 21, 20014 or during the public comment period from August 21, 2014 through

September 18, 2014. By the conclusion of the public comment period on September 18th, EPA

received one email from a resident that contained eight questions. Additionally, questions from

the transcript from the public meeting were extracted. The questions and answers have been

summarized in the following Responsiveness Summary.

1. Has the rate of lateral movement of the contaminants in the groundwater been

determined? (Is it known how fast the contaminants are leaving the site?)

Yes, calculations have been performed. However, a complex and more accurate

groundwater fate and transport model has not been prepared. The contaminants are

dissolved in the groundwater and move at approximately the same velocity as the

groundwater. There are exceptions to this rule but they are not important to addressing

this question. The velocity of the groundwater depends upon three factors, hydraulic

conductivity of the aquifer material, porosity of the aquifer material and the hydraulic

gradient of the aquifer. The hydraulic conductivity is a measure of ease with which water

passes through the aquifer. For the fluvial aquifer at the National Fireworks site, the more

sand there is in an aquifer, the higher the hydraulic conductivity. Conversely, the more silt

or clay in the aquifer material, the lower the hydraulic conductivity. The amount of sand,

silt or clay varies across the site and therefore the hydraulic conductivity varies across the

site.

The amount of porosity in the fluvial aquifer materials depends upon the percentages of

sand, silt and clay. Clay sediments have relatively more porosity but that porosity is poorly

connected. It has a lower hydraulic conductivity. Sand sediments have relatively lower

porosity but a higher hydraulic conductivity. The groundwater will want to flow through

the higher porosity and higher hydraulic conductivity sediments. That means the coarser

grained sand sediments is where most of the groundwater will flow. Grain size

measurements were made in the field by the field geologist. The sandy materials of the

aquifer were estimated to have 30% porosity.

The hydraulic gradient is determined by the slope of the top of the water elevation surface.

The steeper the surface, the greater the hydraulic gradient. Hydraulic gradients are

calculated by subtracting the difference in the water table elevation for two different

measuring points (likely monitoring wells) and dividing that number by the distance

between the measurement points. For this site the hydraulic gradient is calculated to be

o.oo6 feet/foot. This low gradient is reasonable for this setting.


Operable Unit 2


The variation in the three factors results in a range of groundwater velocity for the site. As

stated in the Remedial Investigation report in Section 3.5, Hydrogeology, starting on page

3-11, the groundwater velocity for the fluvial aquifer ranges from 17.76 feet/year to 86.87

feet/year. That would also be the range of rate of lateral movement of the contaminants in

the groundwater.

2. I live at the Lakeview at Woodland Hills Subdivision - are there contaminants in the

groundwater underneath this property?

No. Based on what has been defined as the lateral (horizontal extent of the plume), there

is not any analytical results that suggest that site related contaminants in the

groundwater underneath the Woodland Hills Subdivision.

3. Have air quality studies been done at the site?

No. Air quality studies have not been conducted within the existing buildings at the

Security Signals facility. Because of the levels of site related contaminants or contaminants

of concern (COCs) present in the groundwater beneath the footprint of the groundwater

plume, Vapor Intrusion is concern. Security Signals is aware of the potential for vapor

intrusion and will evaluate whether or not there is a completed exposure pathway and

perform the necessary studies/evaluations in order to determine if an unacceptable risk to

vapor from groundwater contaminants exists for industrial workers.

There were several questions (both during the public meeting and after) that dealt with

whether the drinking water was safe, what were the increased cancer risks due to exposure

to ground water, and what were the health concerns associated with site related

contaminants. The bold questions summarize the exact manner in which the questions

were asked. The italicized response provides a complete response to all the questions

regarding

4. What are the increased cancer risks for someone living within a mile of the site? -

There was mention of 1xE-2 and 1xE-3 for future resident (not sure what this means)?

The groundwater contamination that is of concern that has the potential to increase the

cancer risks to 1.11 x E-2 (or a 1 in 100 increase in the chance of developing cancer) is

located in the surficial aquifer and is located at a depth of 15-25 feet below ground surface

within the footprint of the groundwater plume. The cancer risks from exposure to

groundwater (mentioned during the public meeting and in the Proposed Plan) was

evaluated in our risk assessment process under a future exposure scenario and not a

current exposure scenario. Although the cancer risk of 1.11xE-2 is quantified, there is no

completed exposure pathway that will allow for any current receptors to be exposed to the

groundwater.


Operable Unit 2


In a hypothetical scenario or in the future, if the property’s land use changed to residential

and the groundwater was used for drinking water, exposure to the contaminated

groundwater could result in a cancer risk of 1.11xE-2.

There are not any increased cancer risks for current residents living within a mile of the

site from the ingestion, inhalation, or dermal contact to the contaminated surficial aquifer.

The drinking water in the area is provided by municipal wells served by Memphis Light

Gas and Water. The Memphis Sand aquifer supplies approximately 95 percent of the water

used in the Memphis area for municipal and industrial water supplies. The Memphis Sand

aquifer is encountered approximately 120 feet below ground surface in Cordova,

Tennessee. The depths at which the drinking water is pulled from the Memphis Sand

aquifer is significantly deeper than the contaminated groundwater in the surficial aquifer.

Furthermore, the contaminated surficial aquifer is separated from the Memphis Sand

Aquifer by a confining unit called the Jackson Formation. It is believed that the hydraulic

conductivity that clay in the Jackson Formation is impermeable and will not allow

contaminants to migrate through the clay. Therefore, the groundwater within the Memphis

Sand aquifer would not be impacted by contamination in the upper surficial aquifer.

5. What are the health concerns due to exposure to Tetrachloroethene (PCE) and

Trichloroethene (TCE)

Specifically, if an exposure pathway exists through either ingestion, inhalation, and/or

dermal contact and receptors such as residents or industrial workers are exposed to the

contaminated groundwater there is the potential for harmful health risks. Weight-of-

evidence (WOE) determination, are the toxicity data most commonly used to evaluate

potential human carcinogenic risks. The basic methods EPA uses to derive these values

are outlined as follows. Additional detail is in Guidelines for Carcinogen Risk Assessment

(EPA 1994 and 2005). In general, estimates of carcinogenicity are not based on a

threshold assumption. Exposure at any magnitude is thought to present some potential for

carcinogenesis. A WOE classification has historically been assigned based upon the

strength of supporting human and/or animal data available for a chemical. The following

classifications were defined by EPA in 1986:



Group B1: Limited evidence/data regarding carcinogenicity in humans

Group B2: Sufficient evidence in animals and inadequate or no evidence in

humans





Operable Unit 2


For contaminants in Groups A, B, and sometimes C, are derived using mathematical

models to extrapolate from responses in high dose animal studies to responses anticipated

at relatively low dose human environmental exposures. The values represent the 95%

Upper Confidence Limit of the slope of the dose-response curve for a specific exposure

route (oral or inhalation). Specifically, the following contaminants of concern have been

summarized as having health effects on the following target organs/systems and have been

further categorized as having WOE to classify carcinogen risks.

Contaminants of Concern

Primary Target

Organ

Weight-of-Evidence /

Cancer Guideline

Description

Tetrachloroethene (PCE) kidney, liver,

Neurotoxicity

Group B2 – probable

human carcinogen

Trichloroethene (TCE) liver, lung, CNS

Group B2 – probable

human carcinogen

Vinyl chloride liver

Group A –

human carcinogen

1,1-Dichloroethane (DCA) kidney, CNS

Group C – possible

human carcinogen

1,1-Dichloroethene (DCE) liver, kidney, CNS

Group C – possible

human carcinogen

1,4-Dioxane liver, kidney Group B2 – probable

human carcinogen

6. Why was there not any information regarding the health issues from exposure to site

related contaminants provided during the Proposed Plan presentation or at the public

meeting?

Inclusion of health effects on target organs/systems as well as the Weight of Evidence

information has been added to the responsiveness to address the concerns raised by a

resident during the public meeting. In addition, Toxicological Frequently Asked Questions

or ToxFAQs/ fact sheets developed by the Agency for Toxic Substances and Disease

Registry (ATSDR) have also been attached as a part of the Responsiveness Summary.

EPA’s intent during the meeting was to engage the community to determine what their

concerns were regarding the Site. EPA has determined that members of the community

were interested in receiving more information regarding the health effects of site related

contaminants despite the fact that there is not a current completed pathway for exposure

to groundwater. EPA has addressed this concern by the responses given in the

Responsiveness Summary and by providing the attached toxicological FAQs.


Operable Unit 2


7. Will implementing a remedial alternative re-introduce contaminants to the surface?

No. The selected remedy is phytoremediation. Phytoremediation occurs through a

reductive dechlorination process. The main contaminants which are chlorinated solvents

(Tetrachloroethene and Trichloroethene) degrade over time into by products or

degradation products. Phytoremediation which will involve planting a specific type of tree

grown for the purpose of extracting contaminants from the groundwater will not introduce

contaminants into the subsurface soil or groundwater.

8. If the contaminants will naturally degrade and there are not any immediate health

concerns, why is the remediation necessary?

According to the Rules set forth in The Tennessee Department of Environment and

Conservation (TDEC) and the Tennessee Water Quality Control Board, General Water

Quality Criteria, Chapter 1200-04-03-.07, titled Groundwater Classification, specifically

Section, 1200-04-03-.07(4)(b) states the following, “Except for groundwater in areas that

have been designated as Special Source Water, Site Specific Impaired Groundwater, or

meet the definition of Unusable Groundwater, all groundwater is designated General Use

Groundwater.” The rule further states in Section 1200-04-03-.08(2), “Except for

naturally occurring levels, General Use Groundwater: (a) shall not contain constituents

that exceed those levels specified in Rules 1200-04-03-.03(1)(j) and (k); and (b) shall

contain no other constituents at levels and conditions which pose an unreasonable risk to

the public health or the environment.” Therefore, based on the state of Tennessee’s

groundwater classification all aquifers not otherwise characterized are “general use” and

should be maintained for their most stringent use. This general use groundwater

determination is applicable to the contaminated surficial aquifer.

Furthermore, TDEC believes in using a balanced approach in accessing contamination in

the surficial aquifer. Although there is a confining unit or impermeable clay layer in the

area of the National Fireworks Site, there are other areas where contamination has

migrated to areas where there is not a competent clay or confining unit. If TDEC does not

take aggressive action by not allowing contaminants to linger in the surficial aquifer, then

there is a potential for long-term problems and threats to the drinking water source, the

Memphis Sand Aquifer.

9. Will the remedial alternative halt the movement of the contaminants? If so, how

long will it take to halt the movement?

Yes, it will but it will not be immediate. The selected remedy will provide hydraulic capture

of the contamination source zone and hydraulic capture would be expected to occur within

two years of remedy implementation. Groundwater contamination plumes result when

high concentration materials are released into an aquifer, become mixed with groundwater

and become more dilute (lower in concentration) the further away (down gradient) from

the release location. It is a basic practice of groundwater remediation to remediate the


Operable Unit 2


highest concentrations (the source or release area) and the remaining contamination will

decrease due to the natural attenuation process of dilution.

The selected groundwater remedy is phytoremediation which will act as a biological

capture system that will capture the contaminated groundwater in its roots and transfer it

through the leaves to the atmosphere to be photo-degraded and diluted. Upon an estimated

five years to maturity, a poplar tree will extract approximately 40 gallons of water from

the ground. Estimated calculations were made using the porosity and thickness of the

aquifer in the three main source areas to determine the amount of groundwater available

within the treatment zones. At maturity, a poplar tree will extract approximately 3.5 times

the groundwater (contamination) available on a per unit basis. Within the root zone of

each tree, it will effective capture all the groundwater in the immediate area and draw

more (cleaner) groundwater from beyond the source zone. It is reasonable to assume

that a less mature tree will capture less water and the proposed trees are installed with an

already developed root mass of approximately 10 feet in length. More detailed and complex

calculations about expected groundwater contamination capture will be performed during

the remedial design phase of the project. To answer these specific questions, the selected

remedy will provide hydraulic capture of the contamination source zone and hydraulic

capture would be expected to occur within two years.

10. How old is the initial contamination?

Security Signals has operated at the site from the mid-fifties until now. At some point

during their operation of the degreaser contaminants were released into the groundwater.

It is not possible to place a specific date on the release because there was not a one-time

climatic event. It is believed that the contamination occurred over time, may have been

attributed to migration along a former wet weather conveyance, and it is also believed that

the contaminants migrated as a result of overland flooding during small and large flood

events in the area.

11. What would happen if the creek overflowed?

Eight sediment and surface water collocated samples were collected in the Grays Creek

Drainage Canal. Site related contaminants were detected in both sediment and surface

water samples. Although site related contaminants were detected in some of the samples

above screening levels, the ecological risk assessment indicated that there was not an

unacceptable risk for upper trophic level aquatic receptors (mammals and birds) based on

the lack of bioaccumulative chemicals in surface water and sediment. Finally, no

unacceptable site-related risk was indicated for upper trophic level terrestrial receptors

(mammals and birds) based on the refined food web evaluation. The risk of ecological

exposures to the creek are within an acceptable risk range. Therefore if the creek

overflowed, there would not be an exposure for unacceptable risks.


Operable Unit 2


12. What about our fruit trees, will they be affected?

There is not any evidence that indicates contaminants have migrated offsite from Security

Signals into any of the nearby subdivisions (Woodland Hills or Glenridge). Therefore,

fruit trees in residential subdivisions will not be impacted by groundwater contamination.

1,1-DICHLOROETHANE

CAS # 75-34-3

Division of Toxicology and Human Health Sciences ToxFAQsTM June 2013

This fact sheet answers the most frequently asked health questions (FAQs) about 1,1-dichloroethane. For more information, call the ATSDR Information Center at 1-800-232-4636. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It is important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

HIGHLIGHTS: Exposure to 1,1-dichloroethane occurs mainly from eating contaminated food, but may also occur from skin contact, breathing

contaminated air, or drinking contam inated water. 1,1-Dichloroethane affects the function of the nervous system. 1,1-Dichloroethane has been

found in at least 673 of the 1,699 National Priorities List sites identified by the Environmental Protection A gency (EPA).

What is 1,1-dichloroethane? 1,1-Dichloroethane is a colorless, oily liquid with a sweet odor. It evaporates easily at room temperature and burns easily. It does not occur naturally in the environment. 1,1-Dichloroethane is used mostly as an intermediate in the manufacture of 1,1,1-trichloroethane, and to a lesser extent, vinyl chloride and high vacuum rubber. In the past, it was used as a surgical anesthetic. What happens to 1,1-dichloroethane when it enters the environment? □ 1,1-Dichloroethane breaks down slowly in air and has

the potential for long-range transport. □ 1,1-Dichloroethane does not dissolve easily in water. □ 1,1-Dichloroethane is not expected to rapidly break

down in water. It can evaporate from the water into the air.

□ 1,1-Dichloroethane does not bind strongly to soil particles, unless the organic content of the soil is high.

□ Small amounts of 1,1-dichloroethane released to soil can evaporate into the air or move into ground water.

□ 1,1-Dichloroethane is not expected to build up in the body tissues of animals.

How might I be exposed to 1,1-dichloroethane? □ Breathing air containing 1,1-dichloroethane from

industrial releases or hazardous waste sites. □ Drinking contaminated water if you live near industrial

facilities or hazardous waste sites. □ Touching contaminated soil, but little will enter the body

due to 1,1-dichloroethane’s high volatility. How can 1,1-dichloroethane affect my health? High levels of 1,1-dichloroethane that cause anesthesia can cause irregular heartbeats, which is why its use as a surgical anesthetic was discontinued. Kidney effects have been observed in cats exposed to 1,1-dichloroethane in air for long periods. However, kidney effects have not been observed in other animal species following long-term inhalation or oral exposure. How likely is 1,1-dichloroethane to cause cancer? A study in rats and mice found suggestive evidence that 1,1-dichloroethane may cause cancer. However, the study had several flaws and the results are not conclusive. Another long-term study in mice drinking water containing 1,1-dichloroethane did not find cancer.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, Public Health Service Agency for Toxic Substances and Disease Registry

1,1-DICHLOROETHANE

CAS # 75-34-3

ToxFAQsTM Internet address is http://www.atsdr.cdc.gov/toxfaqs/index.asp

The Department of Health and Human Services (DHHS), the International Agency for Research on Cancer (IARC) have not evaluated the carcinogenic potential of 1,1-dichloroethane. The EPA has determined that 1,1-dichloroethane is a possible human carcinogen. How can 1,1-dichloroethane affect children? There are no data that describe the effects of exposure to 1,1-dichloroethane on children or young animals. Although it is likely that children would show the same health effects as adults, we don’t know whether children are more susceptible than are adults to 1,1-dichloroethane effects. We do not know whether 1,1-dichloroethane can produce birth defects in humans. Minor skeletal problems were observed in the fetuses of rats breathing 1,1-dichloro-ethane; decreases in body weight were also observed in the mothers. How can families reduce the risk of exposure to 1,1-dichloroethane? □ Prevent children from playing in soil contaminated with

1,1-dichloroethane, as it may occur near a hazardous waste site that contains this substance.

□ If you use drinking well water and live near a hazardous site, it may be a good idea to have the water tested for 1,1-dichloroethane and other contaminants.

□ If you use bottled water, you should contact the bottler with specific questions on potential contaminants. Bottled water may be less subject to 1,1-dichloroethane contamination than tap water.

Is there a medical test to determine whether I’ve been exposed to 1,1-dichloroethane? 1,1-Dichloroethane and its breakdown products (metabolites) can be measured in blood and urine. But the detection of 1,1-dichoroethane or its metabolites cannot predict the kind of health effects that might develop from that exposure. Because 1,1-dichloroethane and its metabolites leave the body fairly rapidly, the tests need to be conducted within days after exposure. These tests are not available at most doctors’ offices, but can be done at a special laboratory. Has the federal government made recommendations to protect human health? The EPA has included 1,1-dichloroethane as a priority contaminant in the drinking water program. The Occupational Safety and Health Administration (OSHA) set a legal limit of 100 ppm 1,1-dichloroethane in air averaged over an 8-hour workday. The National Institute for Occupational Safety and Health (NIOSH) recommends a limit of 100 ppm 1,1-dichloro-ethane in air averaged over a 10-hour work day. References Agency for Toxic Substances and Disease Registry (ATSDR). 2013. Toxicological Profile for 1,1-Dichloroethane (Draft for Public Comment). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.

Where can I get more information? For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology and Human Health Sciences, 1600 Clifton Road NE, Mailstop F-57, Atlanta, GA 30333. Phone: 1-800-232-4636, FAX: 770-488-4178. ToxFAQs Internet address via WWW is http://www.atsdr.cdc.gov/toxfaqs/index.asp. ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questions or concerns.

Federal Recycling Program Printed on Recycled Paper

1,1-DICHLOROETHENE CAS # 75-35-4

Agency for Toxic Substances and Disease Registry ToxFAQs September 1995

SUMMARY: Exposure to 1,1-dichloroethene occurs mainly in the workplace.

Breathing high levels of 1,1-dichloroethene can affect the liver, kidney, and central

nervous system. This chemical has been found in at least 515 of 1,416 National Priorities

List sites identified by the Environmental Protection Agency.

This fact sheet answers the most frequently asked health questions (FAQs) about 1,1-dichloroethene. For more information, call the ATSDR Information Center at 1-888-422-8737. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It’s important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

What is 1,1-dichloroethene? (Pronounced 1,1-dI'k1ôr'o eth'en)

1,1-Dichloroethene is an industrial chemical that is not found naturally in the environment. It is a colorless liquid with a mild, sweet smell. It is also called vinylidene chloride.

1,1-Dichloroethene is used to make certain plastics, such as flexible films like food wrap, and in packaging materials. It is also used to make flame retardant coatings for fiber and carpet backings, and in piping, coating for steel pipes, and in adhesive applications.

What happens to 1,1-dichloroethene when it enters the environment? � 1,1-Dichloroethene enters the environment from indus

tries that make or use it.

� 1,1-Dichloroethene evaporates very quickly from water and soil to the air.

� In the air, it takes about 4 days for it to break down.

� 1,1-Dichloroethene breaks down very slowly in water.

� It does not accumulate very much in fish or birds.

� In soil, 1,1-dichloroethene is slowly transformed to other less harmful chemicals.

How might I be exposed to 1,1-dichloroethene? � Workers may be exposed in industries that make or use

1,1-dichloroethene (these industries are mainly in Texas and Louisiana).

� Food that is wrapped in plastic wrap may contain very low levels of 1,1-dichloroethene. The government controls these levels to prevent harm to your health.

� A small percentage (3%) of the drinking water supplies may contain very low levels of 1,1-dichloroethene.

� Air near factories that make or use 1,1-dichloroethene and air near hazardous waste sites may contain low levels of it.

How can 1,1-dichloroethene affect my health?

The main effect from breathing high levels of 1,1dichloroethene is on the central nervous system. Some people lost their breath and fainted after breathing high levels of the chemical.

Breathing lower levels of 1,1-dichloroethene in air for a long time may damage your nervous system, liver, and lungs. Workers exposed to 1,1-dichloroethene have reported a loss in liver function, but other chemicals were present.



Where can I get more information? For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology, 1600 Clifton Road NE, Mailstop F-32, Atlanta, GA 30333. Phone:1-888-422-8737, FAX: 770-488-4178. ToxFAQs Internet address via WWW is http://www.atsdr.cdc.gov/toxfaq.html ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questions or concerns.

ATSDR Internet home page via WWW is http://www.atsdr.cdc.gov/toxfaq.html

Animals that breathed high levels of 1,1-dichloroethene had damaged livers, kidneys, and lungs. The offspring of some of the animals had a higher number of birth defects. We do not know if birth defects occur when people are exposed to 1,1-dichloroethene.

Animals that ingested high levels of 1,1-dichloroethene had damaged livers, kidneys, and lungs. There were no birth defects in animals that ingested the chemical.

Spilling 1,1-dichloroethene on your skin or in your eyes can cause irritation.

How likely is 1,1-dichloroethene to cause cancer?

The Environmental Protection Agency (EPA) has determined that 1,1-dichloroethene is a possible human carcinogen.

Studies on workers who breathed 1,1-dichloroethene have not shown an increase in cancer. These studies, however, are not conclusive because of the small numbers of workers and the short time studied.

Animal studies have shown mixed results. Several studies reported an increase in tumors in rats and mice, and other studies reported no such effects.

Is there a medical test to show whether I’ve been exposed to 1,1-dichloroethene?

Tests are available to measure levels of 1,1-dichloroethene in breath, urine, and body tissues. These tests are not usually available in your doctor’s office. However, a sample taken in your doctor’s office can be sent to a special laboratory if necessary.

Because 1,1-dichloroethene leaves the body fairly quickly, these methods are useful only for finding exposures that have occurred within the last few days. These tests can't tell you if adverse health effects will occur from exposure to 1,1-dichloroethene.

Has the federal government made recommendations to protect human health?

The EPA has set a limit in drinking water of 0.007 parts of 1,1-dichloroethene per million parts of drinking water (0.007 ppm). EPA requires that discharges or spills into the environment of 5,000 pounds or more of 1,1-dichloroethene be reported.

The Occupational Safety and Health Administration (OSHA) has set an occupational exposure limit of 1 ppm of 1,1-dichloroethene in workplace air for an 8-hour workday, 40-hour workweek.

The National Institute for Occupational Safety and Health (NIOSH) currently recommends that workers breathe as little 1,1-dichloroethene as possible.

Glossary Carcinogen: A substance that can cause cancer. CAS: Chemical Abstracts Service. Ingesting: Taking food or drink into your body. ppm: Parts per million. Tumor: An abnormal mass of tissue.

References Agency for Toxic Substances and Disease Registry (ATSDR). 1994. Toxicological profile for 1,1-dichloroethene. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.

1,1-DICHLOROETHENE CAS # 75-35-4

CS249955-R

1,4-Dioxane - ToxFAQs™ CAS # 123-91-1

This fact sheet answers the most frequently asked health questions (FAQs) about 1,4-dioxane. For more information, call the CDC Information Center at 1-800-232-4636. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It is important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

HIGHLIGHTS: Exposure to 1,4-dioxane occurs from breathing contaminated air, ingestion of contaminated food and drinking water, and dermal contact with products such as cosmetics that may contain small amounts of 1,4-dioxane. Exposure to high levels of 1,4-dioxane in the air can result in nasal cavity, liver, and kidney damage. Ingestion or dermal contact with high levels of 1,4-dioxane can result in liver and kidney damage. 1,4-Dioxane has been found in at least 31 of 1,689 National Priorities List (NPL) sites identified by the Environmental Protection Agency (EPA).

What is 1,4-dioxane?1,4-Dioxane is a clear liquid that easily dissolves in water. It is used primarily as a solvent in the manufacture of chemicals and as a laboratory reagent. 1,4-Dioxane is a trace contaminant of some chemicals used in cosmetics, detergents, and shampoos. However, manufacturers now reduce 1,4-dioxane from these chemicals to low levels before these chemicals are made into products used in the home.

What happens to 1,4-dioxane when it enters the environment?

• 1,4-Dioxane can be released into the air, water, and soil at places where it is produced or used as a solvent.

• In air, 1,4-dioxane rapidly breaks down into different compounds.

• In water, 1,4-dioxane is stable and does not break down.

• In soil, 1,4-dioxane does not stick to soil particles, so it can move from soil into groundwater.

• Fish and plants will not accumulate 1,4-dioxane in their tissues.

How might I be exposed to 1,4-dioxane? • Breathing air, drinking water, or eating foods that

contain 1,4-dioxane. During showering, bathing, or laundering, 1,4-dioxane in tap water may volatilize and you can be exposed to 1,4-dioxane vapors.

• Your skin may contact 1,4-dioxane when you use cosmetics, detergents, bubble baths, and shampoos containing 1,4-dioxane.

How can 1,4-dioxane affect my health?Few studies are available that provide information about the effects of 1,4-dioxane in humans. Exposure to very high levels of 1,4-dioxane can result in liver and kidney damage and death. Eye and nose irritation was reported by people inhaling low levels of 1,4-dioxane vapors for short periods (minutes to hours).

Studies in animals have shown that breathing vapors of 1,4-dioxane affects mainly the nasal cavity, liver, and kidneys. Ingesting 1,4-dioxane or having skin contact with 1,4-dioxane also affects the liver and kidneys.

How likely is 1,4-dioxane to cause cancer? The limited number of studies available does not show whether 1,4-dioxane causes cancer in humans. Laboratory rats that breathed vapors of 1,4-dioxane during most of their lives developed cancer inside the nose and abdominal cavity. Laboratory rats and mice that drank water containing 1,4-dioxane during most of their lives developed liver cancer; the rats also developed cancer inside the nose. Scientists are debating the degree to which the findings in rats and mice apply to exposure situations commonly encountered by people.

The (DHHS) U.S. Department of Health and Human Services considers 1,4-dioxane as reasonably anticipated to be a human carcinogen.

Agency for Toxic Substances and Disease RegistryDivision of Toxicology and Health Human Sciences

of 2April 2012

1,4-Dioxane CAS # 123-91-1

How can 1,4-dioxane affect children?There are no studies of children exposed to 1,4-dioxane. However, children might experience health problems similar to those in adults if they were exposed to high concentrations of 1,4-dioxane.

Scientists do not know whether exposure of pregnant women to 1,4-dioxane can harm the unborn child.

How can families reduce the risk of exposure to 1,4-dioxane?1,4-Dioxane may be a contaminant in cosmetics, detergents, bath products, shampoos, and some pharmaceuticals. 1,4-Dioxane is not intentionally added, but may occur as an unintentional byproduct in some ingredients that may be listed on the product label, including: PEG, polyethylene, polyethylene glycol, polyethoxyethylene,-eth or -oxynol . Many products on the market today (foods, pharmaceuticals, cosmetic products, detergents, etc.) contain 1,4-dioxane in very small amounts. However, some cosmetics, detergents, and shampoos may contain 1,4-dioxane at levels higher than recommended by the FDA for other products. Families wishing to avoid cosmetics containing the ingredients listed above may do so by reviewing the ingredient statement that is required to appear on the outer container label of cosmetics offered for retail sale.

1,4-Dioxane has been detected in some drinking water supplies. Bottled water may be less likely to be contaminated with 1,4-dioxane, and consumers should contact the bottler with specific questions on potential contaminants.

Is there a medical test to determine whether I’ve been exposed to 1,4-dioxane?1,4-Dioxane and its breakdown products can be measured in your blood and urine, and positive results indicate you have been exposed to 1,4-dioxane. These tests do not predict whether exposure to 1,4-dioxane will produce harmful health effects. The tests are not routinely available at your doctor’s office because they require special equipment, but the doctor can collect the samples and send them to a special laboratory. The tests need to be conducted within days after the exposure because 1,4-dioxane and its breakdown products leave the body fairly rapidly.

Has the federal government made recommendations to protect human health?EPA has determined that exposure to 1,4-dioxane in drinking water at concentrations of 4 milligrams per liter (4 mg/L) for one day or 0.4 mg/L for 10 days is not expected to cause any adverse effects in children.

The Occupational Safety and Health Administration (OSHA) has set a limit for of 100 parts 1,4-dioxane per 1 million parts of air (100 ppm) in the workplace.

ReferencesAgency for Toxic Substances and Disease Registry (ATSDR). 2012. Toxicological Profile for 1,4-Dioxane. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.

Where can I get more information?For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology and Human Health Sciences, 1600 Clifton Road NE, Mailstop F-57, Atlanta, GA 30333.

Phone: 1-800-232-4636

ToxFAQsTM Internet address via WWW is http://www.atsdr.cdc.gov/toxfaqs/index.asp.

ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questions or concerns.

CS249955-AH

Tetrachloroethylene - ToxFAQs™ CAS # 127-18-4

This fact sheet answers the most frequently asked health questions (FAQs) about tetrachloroethylene. For more information, call the CDC Information Center at 1-800-232-4636. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It’s important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

HIGHLIGHTS: Tetrachloroethylene is a manufactured chemical used for dry cleaning and metal degreasing. Exposure to very high concentrations of tetrachloroethylene can cause dizziness, headaches, sleepiness, confusion, nausea, difficulty in speaking and walking, unconsciousness, and death. Tetrachloroethylene has been found in at least 771 of the 1,430 National Priorities List (NPL) sites identified by the Environmental Protection Agency (EPA).

What is tetrachloroethylene? (Pronounced tĕt’rә -klôr’ ō-ĕth’ә -lēn’)

Tetrachloroethylene is a manufactured chemical that is widely used for dry cleaning of fabrics and for metal-degreasing. It is also used to make other chemicals and is used in some consumer products.

Other names for tetrachloroethylene include perchloroethylene(PERC), PCE, and tetrachloroethene. It is a nonflammable liquid at room temperature. It evaporates easily into the air and has a sharp, sweet odor. Most people can smell tetra chloroethylene when it is present in the air at a level of 1 part tetrachloroethylene per million parts of air (1 ppm) or more, although some can smell it at even lower levels.

What happens to tetrachloroethylene when it enters the environment?

• Much of the tetrachloroethylene that gets into water or soil evaporates into the air.

• Microorganisms can break down some of the tetrachloro ethylene in soil or underground water.

• In the air, it is broken down by sunlight into other chemicals or brought back to the soil and water by rain.

• It does not appear to collect in fish or other animals that live in water.

How might I be exposed to tetrachloroethylene?

• When you bring clothes from the dry cleaners, they will release small amounts of tetrachloroethylene into the air.

• When you drink water containing tetrachloroethylene, you are exposed to it.

How can tetrachloroethylene affect my health? High concentrations of tetrachloroethylene (particularly in closed, poorly ventilated areas) can cause dizziness, headache, sleepiness, confusion, nausea, difficulty in speaking and walking, unconsciousness, and death.

Irritation may result from repeated or extended skin contact with it. These symptoms occur almost entirely in work (or hobby) environments when people have been accidentally exposed to high concentrations or have intentionally used tetrachloroethylene to get a “high.”

In industry, most workers are exposed to levels lower than those causing obvious nervous system effects. The health effects of breathing in air or drinking water with low levels of tetrachloroethylene are not known.

Results from some studies suggest that women who work in dry cleaning industries where exposures to tetrachloroethylene can be quite high may have more menstrual problems and spontaneous abortions than women who are not exposed. However, it is not known if tetrachloroethylene was responsible for these problems because other possible causes were not considered.


of 2September 1997

Tetrachloroethylene CAS # 127-18-4

Results of animal studies, conducted with amounts much higher than those that most people are exposed to, show that tetrachloroethylene can cause liver and kidney damage. Exposure to very high levels of tetrachloroethylene can be toxic to the unborn pups of pregnant rats and mice. Changes in behavior were observed in the offspring of rats that breathed high levels of the chemical while they were pregnant.

How likely is tetrachloroethylene to cause cancer?The Department of Health and Human Services (DHHS) has determined that tetrachloroethylene may reasonably be anticipated to be a carcinogen. Tetrachloroethylene has been shown to cause liver tumors in mice and kidney tumors in male rats.

Is there a medical test to show whether I’ve been exposed to tetrachloroethylene? One way of testing for tetrachloroethylene exposure is to measure the amount of the chemical in the breath, much the same way breath-alcohol measurements are used to determine the amount of alcohol in the blood.

Because it is stored in the body’s fat and slowly released into the bloodstream, tetrachloroethylene can be detected in the breath for weeks following a heavy exposure.

Tetrachloroethylene and trichloroacetic acid (TCA), a breakdown product of tetrachloroethylene, can be detected in the blood. These tests are relatively simple to perform. These tests aren’t available at most doctors’ offices, but can be per formed at special laboratories that have the right equipment.

Because exposure to other chemicals can produce the same breakdown products in the urine and blood, the tests for breakdown products cannot determine if you have been exposed to tetrachloroethylene or the other chemicals.

Has the federal government made recommendations to protect human health?The EPA maximum contaminant level for the amount of tetrachloroethylene that can be in drinking water is 0.005 milligrams tetrachloroethylene per liter of water (0.005 mg/L).

The Occupational Safety and Health Administration (OSHA) has set a limit of 100 ppm for an 8-hour workday over a 40-hour workweek.

The National Institute for Occupational Safety and Health (NIOSH) recommends that tetrachloroethylene be handled as a potential carcinogen and recommends that levels in workplace air should be as low as possible.

GlossaryCarcinogenicity: The ability of a substance to cause cancer.

CAS: Chemical Abstracts Service.

Milligram (mg): One thousandth of a gram.

Nonflammable: Will not burn.

ReferencesThis ToxFAQs™ information is taken from the 1997 Toxicological Profile for Tetrachloroethylene (update) produced by the Agency for Toxic Substances and Disease Registry, Public Health Service, U.S. Department of Health and Human Services, Public Health Service in Atlanta, GA.


Phone: 1-800-232-4636.



http://www.atsdr.cdc.gov/toxfaqs/index.asp

1,1,1-TRICHLOROETHANE CAS # 71-55-6

Division of Toxicology and Environmental Medicine ToxFAQsTM July 2006

This fact sheet answers the most frequently asked health questions (FAQs) about 1,1,1-trichloroethane. For more information, call the ATSDR Information Center at 1-888-422-8737. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It is important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

HIGHLIGHTS: Exposure to 1,1,1-trichloroethane usually occurs by breathing contaminated air. It is found in building materials, cleaning products, paints, and metal degreasing agents. You are not likely to be exposed to large enough amounts to cause adverse health effects. Inhaling high levels of 1,1,1-trichloroethane can cause you to become dizzy and lightheaded. Exposure to much higher levels can cause unconsciousness and other effects. This substance has been found in at least 823 of the 1,662 National Priorities List sites identified by the Environmental Protection Agency (EPA).

What is 1,1,1-trichloroethane? 1,1,1-Trichloroethane is a synthetic chemical that does not occur naturally in the environment. It also is known as methylchloroform, methyltrichloromethane, trichloromethylmethane, and α−trichloromethane. Its registered trade names are chloroethene NU® and Aerothene TT® . No 1,1,1-trichloroethane is supposed to be manufactured for domestic use in the United States after January 1, 2002 because it affects the ozone layer. 1,1,1-Trichloroethane had many industrial and household uses, including use as a solvent to dissolve other substances, such as glues and paints; to remove oil or grease from manufactured metal parts; and as an ingredient of household products such as spot cleaners, glues, and aerosol sprays. What happens to 1,1,1-trichloroethane when it enters the environment? ‘ Most of the 1,1,1-trichloroethane released into the environment enters the air, where it lasts for about 6 years. ‘ Once in the air, it can travel to the ozone layer where sunlight can break it down into chemicals that may reduce the ozone layer. ‘ Contaminated water from landfills and hazardous waste sites can contaminate surrounding soil and nearby surface water or groundwater. ‘ From lakes and rivers, most of the 1,1,1-trichloroethane evaporates quickly into the air.

‘ Water can carry 1,1,1-trichloroethane through the soil and into the groundwater where it can evaporate and pass through the soil as a gas, then be released to the air. ‘ Organisms living in soil or water may also break down 1,1,1trichloroethane. ‘ It will not build up in plants or animals. How might I be exposed to 1,1,1-trichloroethane? ‘ Breathing 1,1,1-trichloroethane in contaminated outdoor and indoor air. Because 1,1,1-trichloroethane was used so frequently in home and office products, you are likely to be exposed to higher levels indoors than outdoors or near hazardous waste sites. However, since 2002, 1,1,1-trichloroethane is not expected to be commonly used, and therefore, the likelihood of being exposed to it is remote. ‘ In the workplace, you could have been exposed to 1,1,1trichloroethane while using some metal degreasing agents, paints, glues, and cleaning products. ‘ Ingesting contaminated drinking water and food. How can 1,1,1-trichloroethane affect my health? If you breathe air containing high levels of 1,1,1-trichloroethane for a short time, you may become dizzy and lightheaded and possibly lose your coordination. These effects rapidly disappear after you stop breathing contaminated air. If you breathe in much higher levels, you may become unconscious, your blood pressure may decrease, and your heart may stop beating. Whether breathing low levels of 1,1,1-trichloroethane for a long



ToxFAQsTM Internet address is http://www.atsdr.cdc.gov/toxfaq.html

Where can I get more information? For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology and Environmental Medicine, 1600 Clifton Road NE, Mailstop F-32, Atlanta, GA 30333. Phone: 1-888-422-8737, FAX: 770-488-4178. ToxFAQs Internet address via WWW is http://www.atsdr.cdc.gov/toxfaq.html. ATSDR can tell you where to find occupational and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questions or concerns.

time causes harmful effects is not known. Studies in animals show that breathing air that contains very high levels of 1,1,1trichloroethane damages the breathing passages and causes mild effects in the liver, in addition to affecting the nervous system. There are no studies in humans that determine whether eating food or drinking water contaminated with 1,1,1-trichloroethane could harm health. Placing large amounts of 1,1,1-trichloroethane in the stomachs of animals has caused effects on the nervous system, mild liver damage, unconsciousness, and even death. If your skin contacts 1,1,1-trichloroethane, you might feel some irritation. Studies in animals suggest that repeated exposure of the skin might affect the liver and that very large amounts may cause death. These effects occurred only when evaporation was prevented. How likely is 1,1,1-trichloroethane to cause cancer? Available information does not indicate that 1,1,1-trichloroethane causes cancer. The International Agency for Research on Cancer (IARC) and the EPA have determined that 1,1,1-trichloroethane is not classifiable as to its carcinogenicity in humans. How can 1,1,1-trichloroethane affect children? Children exposed to large amounts of 1,1,1-trichloroethane probably would be affected in the same manner as adults. In animals, it has been shown that 1,1,1-trichloroethane can pass from the mother’s blood into a fetus. When pregnant mice were exposed to high levels of 1,1,1-trichloroethane in air, their babies developed more slowly than normal and had some behavioral problems. However, whether similar effects occur in humans has not been demonstrated. How can families reduce the risk of exposure to 1,1,1-trichloroethane? Children can be exposed to 1,1,1-trichloroethane in household products, such as adhesives and cleaners. Parents should store household chemicals out of reach of young children to prevent accidental poisonings or skin irritation. Always store household chemicals in their original labeled containers. Never store household chemicals in containers that children would find attractive to eat or drink from, such as old soda bottles. Keep your Poison Control Center’s number near the phone.

Sometimes older children sniff household chemicals in an attempt to get high. Your children may be exposed to 1,1,1-trichloroethane by inhaling products containing it. Talk with your children about the dangers of sniffing chemicals. Is there a medical test to show whether I’ve been exposed to 1,1,1-trichloroethane? Samples of your breath, blood, and urine can be tested to determine if you have recently been exposed to 1,1,1trichloroethane. In some cases, these tests can estimate how much 1,1,1-trichloroethane has entered your body. To be of any value, samples of your breath or blood have to be taken within hours after exposure, and samples of urine have to be taken within 2 days after exposure. However, these tests will not tell you whether your health will be affected by exposure to 1,1,1trichloroethane. The exposure tests are not routinely available in hospitals and clinics because they require special analytical equipment. Has the federal government made recommendations to protect human health? EPA regulates the levels of 1,1,1-trichloroethane that are allowable in drinking water. The highest level of 1,1,1-trichloroethane allowed in drinking water is 0.2 parts 1,1,1,-trichloroethane per 1 million parts of water (0.2 ppm). The Occupational Safety and Health Administration (OSHA) has set a limit of 350 parts 1,1,1-trichloroethane per 1 million parts of air (350 ppm) in the workplace. Reference Agency for Toxic Substances and Disease Registry (ATSDR). 2006. Toxicological Profile for 1,1,1-Trichloroethane (Update). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.

1,1,1-TRICHLOROETHANE CAS # 71-55-6

CS249955-AI

Trichloroethylene - ToxFAQs™ CAS # 79-01-6

This fact sheet answers the most frequently asked health questions (FAQs) about trichloroethylene. For more information, call the CDC Information Center at 1-800-232-4636. This fact sheet is one in a series of summaries about hazardous substances and their health effects. This information is important because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

HIGHLIGHTS: Trichloroethylene is a colorless liquid which is used as a solvent for cleaning metal parts. Drinking or breathing high levels of trichloroethylene may cause nervous system effects, liver and lung damage, abnormal heartbeat, coma, and possibly death. Trichloroethylene has been found in at least 852 of the 1,430 National Priorities List (NPL) sites identified by the Environmental Protection Agency (EPA).

What is trichloroethylene? Trichloroethylene (TCE) is a nonflammable, colorless liquid with a somewhat sweet odor and a sweet, burning taste. It is used mainly as a solvent to remove grease from metal parts, but it is also an ingredient in adhesives, paint removers, typewriter correction fluids, and spot removers.

Trichloroethylene is not thought to occur naturally in the environment. However, it has been found in underground water sources and many surface waters as a result of the manufacture, use, and disposal of the chemical.

What happens to trichloroethylene when it enters the environment?

• Trichloroethylene dissolves a little in water, but it can remain in ground water for a long time.

• Trichloroethylene quickly evaporates from surface water, so it is commonly found as a vapor in the air.

• Trichloroethylene evaporates less easily from the soil than from surface water. It may stick to particles and remain for a long time.

• Trichloroethylene may stick to particles in water, which will cause it to eventually settle to the bottom sediment.

• Trichloroethylene does not build up significantly in plants and animals.

How might I be exposed to trichloroethylene?

• Breathing air in and around the home which has been contaminated with trichloroethylene vapors from shower water or household products such as spot removers and typewriter correction fluid.

• Drinking, swimming, or showering in water that has been contaminated with trichloroethylene.

• Contact with soil contaminated with trichloroethylene, such as near a hazardous waste site.

• Contact with the skin or breathing contaminated air while manufacturing trichloroethylene or using it at work to wash paint or grease from skin or equipment.

How can trichloroethylene affect my health? Breathing small amounts may cause headaches, lung irritation, dizziness, poor coordination, and difficulty concentrating.

Breathing large amounts of trichloroethylene may cause impaired heart function, unconsciousness, and death. Breathing it for long periods may cause nerve, kidney, and liver damage.

Drinking large amounts of trichloroethylene may cause nausea, liver damage, unconsciousness, impaired heart function, or death.

Drinking small amounts of trichloroethylene for long periods may cause liver and kidney damage, impaired immune system function, and impaired fetal development in pregnant women, although the extent of some of these effects is not yet clear.

Skin contact with trichloroethylene for short periods may cause skin rashes.


of 2July 2003

Trichloroethylene CAS # 79-01-6

How likely is trichloroethylene to cause cancer?Some studies with mice and rats have suggested that high levels of trichloroethylene may cause liver, kidney, or lung cancer. Some studies of people exposed over long periods to high levels of trichloroethylene in drinking water or in workplace air have found evidence of increased cancer. Although, there are some concerns about the studies of people who were exposed to trichloroethylene, some of the effects found in people were similar to effects in animals.

In its 9th Report on Carcinogens, the National Toxicology Program (NTP) determined that trichloroethylene is “reasonably anticipated to be a human carcinogen.” The International Agency for Research on Cancer (IARC) has determined that trichloroethylene is “probably carcinogenic to humans.”

Is there a medical test to show whether I’ve been exposed to trichloroethylene? If you have recently been exposed to trichloroethylene, it can be detected in your breath, blood, or urine. The breath test, if it is performed soon after exposure, can tell if you have been exposed to even a small amount of trichloroethylene.

Exposure to larger amounts is assessed by blood and urine tests, which can detect trichloroethylene and many of its breakdown products for up to a week after exposure. However, exposure to other similar chemicals can produce the same breakdown products, so their detection is not absolute proof of exposure to trichloroethylene. This test isn’t available at most doctors’ offices, but can be done at special laboratories that have the right equipment.

Has the federal government made recommendations to protect human health?The EPA has set a maximum contaminant level for trichloroethylene in drinking water at 0.005 milligrams per liter (0.005 mg/L) or 5 parts of TCE per billion parts water.

The EPA has also developed regulations for the handling and disposal of trichloroethylene.

The Occupational Safety and Health Administration (OSHA) has set an exposure limit of 100 parts of trichloroethylene per million parts of air (100 ppm) for an 8-hour workday, 40-hour workweek.

GlossaryCarcinogenicity: The ability of a substance to cause cancer.

CAS: Chemical Abstracts Service.

Evaporate: To change into a vapor or gas.

Milligram (mg): One thousandth of a gram.

Nonflammable: Will not burn.

ppm: Parts per million.

Sediment: Mud and debris that have settled to the bottom of a body of water.

Solvent: A chemical that dissolves other substances.

ReferencesThis ToxFAQs™ information is taken from the 1997 Toxicological Profile for Trichloroethylene (update) produced by the Agency for Toxic Substances and Disease Registry, Public Health Service, U.S. Department of Health and Human Services, Public Health Service in Atlanta, GA.


Phone: 1-800-232-4636.




CS249955-AL

Vinyl Chloride - ToxFAQs™ CAS # 75-01-4

This fact sheet answers the most frequently asked health questions (FAQs) about vinyl chloride. For more information, call the CDC Information Center at 1-800-232-4636. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It is important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, how you are exposed, personal traits and habits, and whether other chemicals are present.

HIGHLIGHTS: Exposure to vinyl chloride occurs mainly in the workplace. Breathing high levels of vinyl chloride for short periods of time can cause dizziness, sleepiness, unconsciousness, and at extremely high levels can cause death. Breathing vinyl chloride for long periods of time can result in permanent liver damage, immune reactions, nerve damage, and liver cancer. This substance has been found in at least 616 of the 1,662 National Priority List (NPL) sites identified by the Environmental Protection Agency (EPA).

What is vinyl chloride? Vinyl chloride is a colorless gas. It burns easily and it is not stable at high temperatures. It has a mild, sweet odor. It is a manufactured substance that does not occur naturally. It can be formed when other substances such as trichloroethane, trichloroethylene, and tetrachloroethylene are broken down. Vinyl chloride is used to make polyvinyl chloride (PVC). PVC is used to make a variety of plastic products, including pipes, wire and cable coatings, and packaging materials.

Vinyl chloride is also known as chloroethene, chloroethylene, and ethylene monochloride.

What happens to vinyl chloride when it enters the environment?

• Liquid vinyl chloride evaporates easily. Vinyl chloride in water or soil evaporates rapidly if it is near the surface.

• Vinyl chloride in the air breaks down in a few days to other substances, some of which can be harmful.

• Small amounts of vinyl chloride can dissolve in water.

• Vinyl chloride is unlikely to build up in plants or animals that you might eat.

How might I be exposed to vinyl chloride?

• Breathing vinyl chloride that has been released from plastics industries, hazardous waste sites, and landfills.

• Breathing vinyl chloride in air or during contact with your skin or eyes in the workplace.

• Drinking water from contaminated wells.

How can vinyl chloride affect my health? Breathing high levels of vinyl chloride can cause you to feel dizzy or sleepy. Breathing very high levels can cause you to pass out, and breathing extremely high levels can cause death.

Some people who have breathed vinyl chloride for several years have changes in the structure of their livers. People are more likely to develop these changes if they breathe high levels of vinyl chloride. Some people who work with vinyl chloride have nerve damage and develop immune reactions. The lowest levels that produce liver changes, nerve damage, and immune reaction in people are not known. Some workers exposed to very high levels of vinyl chloride have problems with the blood flow in their hands. Their fingers turn white and hurt when they go into the cold.

The effects of drinking high levels of vinyl chloride are unknown. If you spill vinyl chloride on your skin, it will cause numbness, redness, and blisters.

Animal studies have shown that long-term exposure to vinyl chloride can damage the sperm and testes.


of 2July 2006

Vinyl Chloride CAS # 75-01-4

How likely is vinyl chloride to cause cancer?The U.S. Department of Health and Human Services (DHHS) has determined that vinyl chloride is a known carcinogen. Studies in workers who have breathed vinyl chloride over many years showed an increased risk of liver, brain, lung cancer, and some cancers of the blood have also been observed in workers.

How can vinyl chloride affect children?It has not been proven that vinyl chloride causes birth defects in humans, but studies in animals suggest that vinyl chloride might affect growth and development. Animal studies also suggest that infants and young children might be more susceptible than adults to vinyl chloride-induced cancer.

How can families reduce the risk of exposure to vinyl chloride?

Tobacco smoke contains low levels of vinyl chloride, so limiting your family’s exposure to cigarette or cigar smoke may help reduce their exposure to vinyl chloride.

Is there a medical test to determine whether I’ve been exposed to vinyl chloride? The results of several tests can sometimes show if you have been exposed to vinyl chloride. Vinyl chloride can be measured in your breath, but the test must be done shortly after exposure. This is not helpful for measuring very low levels of vinyl chloride.

The amount of the major breakdown product of vinyl chloride, thiodiglycolic acid, in the urine may give some information about exposure. However, this test must be done shortly after exposure and does not reliably indicate the level of exposure.

Has the federal government made recommendations to protect human health?Vinyl chloride is regulated in drinking water, food, and air. The EPA requires that the amount of vinyl chloride in drinking water not exceed 0.002 milligrams per liter (mg/L) of water.

The Occupational Safety and Health Administration (OSHA) has set a limit of 1 part vinyl chloride per 1 million parts of air (1 ppm) in the workplace.

The Food and Drug Administration (FDA) regulates the vinyl chloride content of various plastics. These include plastics that carry liquids and plastics that contact food. The limits for vinyl chloride content vary depending on the nature of the plastic and its use.

ReferencesAgency for Toxic Substances and Disease Registry (ATSDR). 2006. Toxicological Profile for Vinyl Chloride (Update). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service.


Phone: 1-800-232-4636.




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10· · · ·NATIONAL FIREWORKS, OPERABLE UNIT 2

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12· · · · · SUPERFUND PROPOSED PLAN MEETING13

14· · · · · · ·AUGUST 21, 2014, 7:01 p.m.15

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http://www.huseby.com

·1· · · · · · · A P P E A R A N C E S

·2· ·For the Environmental Protection Agency:

·3· · · · · · ·MS. KERIEMA SMITH NEWMAN

·4· · · · · · ·61 Forsyth Street, SW

·5· · · · · · ·Atlanta, Georgia 30303

·6· · · · · · ·404-562-8859

·7· · · · · · ·[email protected]

·8· · · · · · ·MR. BEN BENTOWSKI

·9· · · · · · ·61 Forsyth Street, SW

10· · · · · · ·Atlanta, Georgia 30303

11· · · · · · ·404-562-8507

12· · · · · · ·[email protected]

13· · · · · · ·MS. SHERRYL A. LANE

14· · · · · · ·61 Forsyth Street, SW

15· · · · · · ·Atlanta, Georgia 30303

16· · · · · · ·404-562-8611

17· · · · · · ·[email protected]

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20· ·For the State of Tennessee

21· ·Department of Environment and Conservation

22· ·Division of Remediation:

23· · · · · · ·MR. JORDAN ENGLISH· · · · · · · ·8363 Wolf Lake Drive24· · · · · · ·Bartlett, Tennessee 38133· · · · · · · ·901-371-300025· · · · · · ·[email protected]


·1· · · · · · ·MR. JERREL MOORE

·2· · · · · · ·8363 Wolf Lake Drive

·3· · · · · · ·Bartlett, Tennessee 38133

·4· · · · · · ·901-371-3000

·5· · · · · · ·[email protected]

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10· · · · · · MS. NEWMAN:· Tonight, we're going to have

11· ·the proposed plan meeting for National Fireworks

12· ·Superfund site.· It's located in the Cordova area,

13· ·which is in Shelby County.· Let me introduce myself.

14· ·I'm Keriema Newman.· My title with the site is

15· ·remedial project manager, which means I have

16· ·overseen -- I've had oversight over this

17· ·investigation thus far for the past six or seven

18· ·years.

19· · · · · · Along with me today I brought Ben

20· ·Bentowski.· Ben is a hydro -- or a hydrologist in

21· ·Atlanta with the EPA.· He's also been my technical

22· ·backup, I think, pretty much as long as I've been

23· ·with the site.· I think I've only been around a year

24· ·longer than Ben.· So he has shared the history of

25· ·the site with me as well.


·1· · · · · · I also brought Sherryl Lane.· Sherryl is a

·2· ·community involvement coordinator in our region, and

·3· ·Sherryl's role with the site is really to engage the

·4· ·community and find out what the pulse of the

·5· ·community is, find out if the community has any

·6· ·needs in relation to the Superfund site.· She can

·7· ·also be available when I'm not.· So Sherryl's a

·8· ·resource who can basically channel questions to me

·9· ·or field questions to me if you can't get to me,

10· ·because I do travel quite a bit.

11· · · · · · Also, we have TDEC here.· We have Jerrel

12· ·Moore and Jordan English.· And they're with the

13· ·Tennessee Department of Environment and

14· ·Conservation.· And what they are, they are the local

15· ·environmental force in Tennessee.· We are federal.

16· ·They're on the state level.· And they've been around

17· ·even longer than I have with this site.· So how long

18· ·have you been involved with this site, Jordan?

19· · · · · · MR. ENGLISH:· My gosh --

20· · · · · · MS. NEWMAN:· Since the PA was 2001.

21· · · · · · MR. ENGLISH:· I don't want to say.

22· · · · · · MS. NEWMAN:· Okay.· And you would say the

23· ·same amount of time, Jerrel?

24· · · · · · MR. MOORE:· Yeah.

25· · · · · · MS. NEWMAN:· So they also are here.


·1· ·They're local.· They're Bartlett.· They're in the

·2· ·Memphis field office.· So if you all have questions

·3· ·that you want to get answered on the ground in real

·4· ·time without coming directly to Atlanta, they are

·5· ·also a resource that you can use to field questions

·6· ·through.

·7· · · · · · Also, I'd like to introduce to you all

·8· ·Susan Lee.· Susan Lee is the owner of Security

·9· ·Signals, the property at 9509 Macon Road that we're

10· ·here to talk about.· And we're also talking about

11· ·the whole entire National Fireworks site as well.

12· ·So with that, we can go ahead and get starred.

13· · · · · · So what this slide shows here is

14· ·historically the National Fireworks site that

15· ·operated.· National Fireworks operated from 1942 to

16· ·roughly the mid-Fifties.· What they did was they

17· ·were basically a contractor to the Army and Navy

18· ·when the Army and Navy used them during war time.

19· · · · · · So during World War II and during the

20· ·Korean War, they manufactured different bombs and

21· ·munitions and those types of materials for the Army

22· ·and the Navy during that time, as well as the

23· ·chemical warfare services.

24· · · · · · Right here, the smaller picture here that's

25· ·outlined in red shows the Security Signals property


·1· ·in relation to this whole area.· This whole area has

·2· ·been reworked and redeveloped and it's currently

·3· ·referred to as the Cordova Industrial Park.· So this

·4· ·really just gives you an idea of what that whole

·5· ·entire 260 acres looked like when it operated, but

·6· ·tonight, we're only here to discuss the Security

·7· ·Signals property, which is basically in the north

·8· ·central part of this whole entire 260 acres, if that

·9· ·makes sense to everyone.

10· · · · · · This is also just aerial photography, an

11· ·aerial map that shows the site itself.· I mean, this

12· ·area, like I said, is an industrial park and it's

13· ·industrialized with a lot of different -- I mean, if

14· ·you look here, you see Granite Products, Memphis

15· ·Cheer and Dance.· There are a lot of different type

16· ·of commercial businesses that are housed in this

17· ·industrial park.· And this is Security Signals.

18· · · · · · Security Signals now, currently, they make

19· ·more type of machined metal parts, automotive

20· ·valves, things of that nature, but historically,

21· ·after National Fireworks operated, when they started

22· ·operating in the early Sixties, they made similar

23· ·types of products that were also made at National

24· ·Fireworks, so fuses, cartridges, pin flares,

25· ·munitions, those types of things, historically.


·1· · · · · · Let's move on to the next slide.· In this

·2· ·figure -- if anyone is interested in seeing this

·3· ·later, find out more about this, all of this

·4· ·presentation can be emailed if you provide your

·5· ·email.· So I know it's hard to see where you may be

·6· ·sitting now, but this figure right here really just

·7· ·shows historically what -- in that whole first

·8· ·picture I showed, which showed the whole 260 acres,

·9· ·but this picture just kind of highlights from this

10· ·historical information what we know about the site,

11· ·what we believe was manufactured here, and in what

12· ·areas of the property they manufactured these

13· ·products.

14· · · · · · So over here you can see that historically

15· ·this is where they cleaned rail cars.· The black

16· ·line, of course, is the Security Signals area.· And

17· ·historically, within the Security Signals area here,

18· ·rocket fuses were made when National Fireworks

19· ·operated.· Here was where the pin flares were

20· ·produced, bombs over here.· So like I said, this

21· ·presentation, if you're interested, can be provided

22· ·if you email me and you've signed in and I have your

23· ·contact information if you want to look at it later.

24· · · · · · I just wanted everyone to kind of get a

25· ·feel of the historical area, what was there in the


·1· ·early Forties and Fifties, how the area has changed

·2· ·now, and how it looks today, what it looks like to

·3· ·you all now, and what Security Signals still does on

·4· ·the property now, how they operate.

·5· · · · · · So I kind of talked through this without --

·6· ·with having the slides up, so we talked about them

·7· ·beginning the production in 1942 and them being a

·8· ·contractor for the Army and Navy and chemical

·9· ·warfare services and the types of things that were

10· ·manufactured there, flares, grenades, rounds, bombs,

11· ·those types of things.

12· · · · · · They did close in '46, and then they wound

13· ·up coming back and renting or leasing the property

14· ·in the Fifties during the Korean War, but Security

15· ·Signals actually over time purchased what I showed

16· ·you in the black, the area outlined in black.· They

17· ·wound up purchasing about 22 acres, so Security

18· ·Signals -- the slide's wrong.· It's 22.· I thought I

19· ·fixed it, but I didn't.· Sorry.· But it's 22.

20· · · · · · So I guess what's important here is just to

21· ·make the point that since 1997, Security Signals has

22· ·not manufactured any pyrotechnic devices.· And

23· ·specifically the contamination that we're here to

24· ·talk about tonight is two main contaminants.· One of

25· ·them is called tetrachloroethylene and the other


·1· ·trichloroethylene.· And it's believed that that

·2· ·contamination -- the source of that contamination is

·3· ·a former degreaser.· And for products like machine

·4· ·metal parts, those two chemicals are common

·5· ·degreasers that you would use in those type of

·6· ·industrial applications.

·7· · · · · · So there are probably several different

·8· ·explanations to how the contaminants got into the

·9· ·groundwater.· It could have been a result of just

10· ·bad housekeeping.· The degreaser area, we know, did

11· ·get flooded at some point in the Nineties.· It could

12· ·have been spills, but what we do know, which is

13· ·important, is that the groundwater at a certain

14· ·depth on the property and where the groundwater has

15· ·migrated, the contamination has migrated, it has

16· ·gotten into the groundwater.

17· · · · · · So just to give you a background of the

18· ·site itself, TDEC got involved with this site in

19· ·2001, and they did what we call a site inspection.

20· ·And this is a part of our CERCLA process.· And I'll

21· ·kind of get into the CERCLA process in a couple of

22· ·minutes, but the SI and ESI, an expanded site

23· ·inspections were performed in the early 2000s.

24· · · · · · Based on those results, it was recommended

25· ·that something else needed to be done because of a


·1· ·contamination that exists, Security Signals was

·2· ·identified as a potentially responsible party.· They

·3· ·were willing -- there are other potentially

·4· ·responsible parties, too, the Army and Navy and

·5· ·National Coatings, which is a corporate successor of

·6· ·National Fireworks.· So we identified them all as

·7· ·PRPs.· But at that time, Security Signals was

·8· ·willing to enter into an agreement with EPA to

·9· ·investigate the contamination that they believed

10· ·that was on their property.

11· · · · · · So we entered into an enforcement agreement

12· ·with Security Signals for them to do what we call a

13· ·remedial investigation and a feasibility study.· And

14· ·we signed an order with them.· There was something

15· ·else I wanted you to know, but I can't remember what

16· ·it is.· When it comes back to me, I'll tell you all

17· ·what it was.· Oh, the site is not on our national

18· ·priorities list.

19· · · · · · The national priorities list is a mechanism

20· ·that we have in place as a result of the regulation

21· ·that we have, which is CERCLA.· And we decided at

22· ·some point in the process that this site wouldn't be

23· ·listed on the national priorities list, but this

24· ·site is what we call a national priorities list

25· ·caliber site, meaning that if we decided to list it


·1· ·on the NPL, we would list it, but because we had a

·2· ·PRP, potentially responsible party, who was willing

·3· ·to do the work, we did not list it at that time.

·4· · · · · · So just to kind of back up, I've given you

·5· ·the history of the site and where we are in terms of

·6· ·why we're sitting here tonight talking.· I just

·7· ·wanted to give you all a flavor for what this

·8· ·remedial investigation is and feasibility study is.

·9· · · · · · In our Superfund process, Superfund is a

10· ·program I work with in Atlanta.· We are a program

11· ·that was birthed from the regulation from the

12· ·statute CERCLA.· That is our regulation.

13· · · · · · Our objective when we have a site that's

14· ·NPL caliber or an NPL site, the objective is to

15· ·determine the nature and extent of the

16· ·contamination, determine if there's a risk to human

17· ·health and to ecological receptors, and to also

18· ·develop remedial alternatives.· And that's really

19· ·what this meeting is about tonight, it is to talk to

20· ·you all about the alternatives that we all looked

21· ·at, meaning myself, Ben, TDEC, Susan, that we've all

22· ·evaluated and determined are the best alternatives

23· ·to take care of this groundwater contamination, and

24· ·to also talk to you about what the recommended

25· ·alternative is.


·1· · · · · · So we're just coming out of this remedial

·2· ·investigation feasibility study phase, and now we

·3· ·are at the proposed plan stage.· So I'm here to

·4· ·present to you what those alternatives are so that I

·5· ·can eventually issue what's called a Record of

·6· ·Decision.· And that Record of Decision will become

·7· ·the memorialization, I guess, of this contamination

·8· ·and how we're going to clean it up.· So that Record

·9· ·of Decision is what we say and outline will be our

10· ·path for Security Signals cleaning up this site.

11· ·You're here because -- yes, ma'am.

12· · · · · · UNIDENTIFIED SPEAKER:· Before you go into

13· ·the proposed plan, can you tell us if the water that

14· ·we're drinking is safe?

15· · · · · · MS. NEWMAN:· Yes.· So let's talk about that

16· ·and -- we can definitely talk about that.· And Ben

17· ·may chime in, too, as well.· Our understanding is

18· ·that you all's water is provided by MGLW.· Is that

19· ·right?· Memphis Gas, Light and Water.· And based on

20· ·the research that we've done on their municipal

21· ·wells, those wells are screened in the Memphis Sand

22· ·Aquifer, which is drawing water at depth ranges -- I

23· ·think I've seen from, like, 500 feet to 800 feet

24· ·below ground surface.· This contamination is only --

25· ·this contamination ranges from, like, 16 feet below


·1· ·ground surface to 25 feet.· So as you can see,

·2· ·that's a significant difference in depth.

·3· · · · · · In addition to that, this aquifer that is

·4· ·contaminated is considered a surficial aquifer, and

·5· ·the Alluvium is the consolidation, it's referred to

·6· ·as, and there are confining units, is the term that

·7· ·we use, but basically, thick beds of clay that have

·8· ·high hydraulic conductivity.

·9· · · · · · I know these are a lot of terms to get to

10· ·ultimately what you're looking -- with what you want

11· ·me to say, but I just want to make sure for the

12· ·record that I'm stating that.· But there are beds of

13· ·clay that have hydraulic conductivities that are

14· ·impermeable, that don't allow contamination to

15· ·migrate from the surficial aquifer to the aquifer

16· ·that the groundwater is flowing from.· So it is

17· ·based on a lot of science, what we know about

18· ·aquifers, we believe that those aquifers are not

19· ·connected and that your water is protected, the

20· ·Memphis Sand Aquifer is protected by this clay and

21· ·that the contaminants are not migrating from there

22· ·so that you are drinking safe water.

23· · · · · · UNIDENTIFIED SPEAKER:· So what was in the

24· ·ground, that the clay is not harming our pets or

25· ·anything?


·1· · · · · · MS. NEWMAN:· The clay is at a depth way

·2· ·deeper than the surface, so I'm not talking about

·3· ·like -- I don't know, is your clay like a green --

·4· · · · · · UNIDENTIFIED SPEAKER:· We can't dig in our

·5· ·yard because of the clay, so --

·6· · · · · · MS. NEWMAN:· That's a different clay layer

·7· ·than the clay layers that I'm referring to.· But I

·8· ·went around and around to get the answer, but the

·9· ·Memphis Sand Aquifer is where your water is being

10· ·pulled from and it's a confined aquifer and a

11· ·protected aquifer and the contaminants are not

12· ·migrating.

13· · · · · · Is there another question?· Okay.· You all

14· ·are here because of the proposed plan, and I wanted

15· ·to let you all know that we do have copies of the

16· ·proposed plan here which you may have seen in the

17· ·newspaper and in the library with just a short type

18· ·of fact sheet that was there to make sure that you

19· ·all knew to come out here.· But we do have copies of

20· ·the proposed plan here.· If you want to read through

21· ·the 37-page document, it's here.

22· · · · · · I think based on the number of people I

23· ·have here tonight, everyone can get one.· If we run

24· ·out, if you could provide me with your address,

25· ·which I think you have, or an email address, I can


·1· ·send it to you.· And if anyone else asks you about

·2· ·it, because you came out to the meeting, you can

·3· ·refer them to the Cordova library.· There is a copy

·4· ·there along with other documents that are related to

·5· ·the site.

·6· · · · · · So we talked a little bit about this

·7· ·already, but the Record of Decision, the ROD

·8· ·basically will be, like I said, just this living

·9· ·document that will summarize -- it's similar to the

10· ·proposed plan, but the ROD actually has in it the

11· ·remedy that we select, where the proposed plan is

12· ·just telling you what the preference is and

13· ·recommendations made.· The ROD will tell you all

14· ·what the selected remedy is.

15· · · · · · So the purpose here is for you all to

16· ·listen to the alternatives.· And if you are

17· ·interested in providing comments or you want to

18· ·write back to us or call me or email me, there is a

19· ·30-day comment period from the time the comment

20· ·period started, it started yesterday, so it started

21· ·on August 21st, and it will end on September 18th.

22· ·So after the comment period ends, if there's

23· ·significant comments that need to be addressed, they

24· ·are all addressed in the ROD in the part of the ROD

25· ·called the Responsiveness Summary.


·1· · · · · · So if after this meeting there are things

·2· ·that you all want to make sure get into the record

·3· ·or ROD, please, feel free to call me or email me or

·4· ·send me comments to the alternatives, if you have

·5· ·some.

·6· · · · · · So once we get this ROD signed and we get

·7· ·it in place, the next phase would be to -- and see,

·8· ·I have a typo -- the next phase would be to start

·9· ·dialog with us and the responsible party to come up

10· ·with a path forward on how we get to the remedial

11· ·design, which is the next phase in the remedial

12· ·action.

13· · · · · · So what we do is we design a remedy.· We

14· ·design a remedy based on what we selected.· So we

15· ·design some type of way to implement the action.· So

16· ·we go through an aggressive design to come up with

17· ·how we're going to do it, and then the next phase is

18· ·the remedial action.

19· · · · · · So now we can talk about the contaminants

20· ·in more detail.· From 2008 to 2013, Security

21· ·Signals' consultant investigated the property and

22· ·took several samples in groundwater, in soil, in

23· ·surface water and in sediment.· So we're going to

24· ·talk about that a little bit more.· The alternatives

25· ·that we're discussing here tonight are limited to


·1· ·plumes that have been defined in our documents as

·2· ·Plume C, Plume D, and Plume E.· The remaining

·3· ·groundwater contamination identified in the remedial

·4· ·investigation which we referred to as Plumes A and

·5· ·Plumes B are going to be addressed under a separate

·6· ·response action at another time.

·7· · · · · · There is evidence that exists that tells us

·8· ·that those plumes need to be characterized more and

·9· ·we need to conduct some additional investigation.

10· ·So those aren't being addressed under this response

11· ·action, only C, D, and E.· We can move on.

12· · · · · · So just to kind of highlight what the areas

13· ·are, so what you see here, this is within the

14· ·footprint of the Security Signals property, the

15· ·property that I showed you several slides back that

16· ·was outlined in black.· So this is a model of the

17· ·contamination.

18· · · · · · And I think I talked already about the

19· ·degreaser that was there.· So the degreaser was in

20· ·this area in here, right in here.· And the

21· ·contaminants migrated from the degreaser along the

22· ·southeastern pathway and they've moved this way.· So

23· ·what you see here is just an area of what we

24· ·consider the contaminated groundwater from the

25· ·site-related contaminants.


·1· · · · · · And this is also this more in 3-D, but what

·2· ·you see here is what we talked about, the

·3· ·underground surface, and I talked about the clay

·4· ·layer in the surficial aquifer.· This is the

·5· ·surficial aquifer here.· And just to kind of give

·6· ·you an idea, this is 300 -- this is 300 feet, I

·7· ·guess, above ground surface and this is sea level.

·8· · · · · · Thank you, Ben.

·9· · · · · · That's why I bring him with me.· He makes

10· ·me sound good.· This is 300 feet above sea level.

11· ·And then you see here this is about 270.· So that's

12· ·a difference of about 30 feet.· So this is the area

13· ·that we're concerned about.· This is the area of the

14· ·surficial aquifer where we know the contaminants

15· ·have migrated.· This doesn't show the whole

16· ·depiction of the hydrogeologic unit, but this does

17· ·show Jackson clay which is one of the defining

18· ·units.· And as I mentioned, there are several units

19· ·that separate this surficial aquifer from the

20· ·Memphis Sand Aquifer.

21· · · · · · So what I was trying to illustrate or talk

22· ·about having this model earlier is there are these

23· ·clay layers that prevent the groundwater

24· ·contaminants from migrating down.· And once again,

25· ·these are the areas that we're concerned with.· This


·1· ·was the former degreaser area, so here, here, and

·2· ·here.· I mentioned A and B and, like I said before,

·3· ·there's going to be a separate response action to

·4· ·deal with those areas, but right now Security

·5· ·Signals is addressing these areas here.

·6· · · · · · MR. BENTKOWSKI:· Can I add, Keriema, there

·7· ·was a boring done on site and the Jackson clay was

·8· ·at least 100 feet thick.· So that's pretty good

·9· ·protection from the contamination that's in this

10· ·sand and gravel aquifer you see here, which is

11· ·about -- the sandy part of it is about 10 to -- 5 to

12· ·10 feet thick.· And then you've got at least 100

13· ·feet of clay before you get to the Memphis Sand

14· ·Aquifer, which is pretty good.

15· · · · · · UNIDENTIFIED SPEAKER:· According to that

16· ·chart, some contaminants will come up, right?

17· · · · · · MR. BENTKOWSKI:· No.· They go -- they were

18· ·released at the surface and have filtered through

19· ·that silty clay that's called the loase and then

20· ·down into this thin sandy zone which is the

21· ·surficial aquifer.· So they start from the top with

22· ·releases and then migrate down to that first

23· ·aquifer, but not any lower because that clay is so

24· ·thick and so impermeable that the contamination

25· ·doesn't go through it at any -- hardly at any


·1· ·negligible rate.

·2· · · · · · MS. NEWMAN:· Okay.· Moving on.· So one

·3· ·other point to make here is that there is some

·4· ·subsurface soil contamination that is consistent

·5· ·with the groundwater contamination in the area of

·6· ·the degreaser.· So this slide just really talks

·7· ·about where we've encountered that subsurface soil

·8· ·contamination.

·9· · · · · · And there are different depths that we've

10· ·seen.· It was first encountered at 16 feet and then

11· ·again at 20 to 25 feet.· And it's 1 to 5 milligrams

12· ·per kilogram.· And I know that that term might not

13· ·mean a lot to you, what's 1 to 5 milligrams per

14· ·kilogram, but if you have some questions about a

15· ·milligram to a kilogram and you want to talk about

16· ·that, I can talk to you all about that after the

17· ·meeting if you want more information about how a

18· ·sample was analyzed and how we're able to determine

19· ·what the concentration of the units are.

20· · · · · · But what we do is -- and when I say "we," I

21· ·just mean generally in the environmental field, when

22· ·I say "we," but generally soil is collected, either

23· ·at the surface or at the subsurface at some depth

24· ·and then sent off to be analyzed.· And usually some

25· ·type of mass spec -- and I know this is probably


·1· ·more than you want to know, but anyway, there's a

·2· ·method to how to determine the contaminants in soil,

·3· ·in groundwater and in sediment and in surface

·4· ·water.· And it's very scientific and really it's the

·5· ·basis for how we make decisions.· We make our

·6· ·decisions on this laboratory data.

·7· · · · · · MR. BENTKOWSKI:· Very precise and rigid

·8· ·procedures both in collecting the samples and in

·9· ·analyzing the samples.· Is that it?

10· · · · · · MS. NEWMAN:· Yes.· So in terms of what type

11· ·of contamination was detected on site, this slide

12· ·really just shows you the tetrachloroethylene.

13· ·Which is interesting if you get the proposed plan

14· ·and you read about this, PCE is just a short term

15· ·that we use.· It stands for perchloroethylene.· Most

16· ·of these contaminants or chemicals have common names

17· ·and then they have, you know, a chemical name.· So

18· ·we use PCE sometimes, we say perchloroethylene, and

19· ·then some days we say tetrachloride, it just

20· ·depends.· And the same for the TCE.· This one is

21· ·trichloroethene.

22· · · · · · The one thing that I left out is that these

23· ·contaminants do naturally degrade over time.

24· ·There's a degradation process.· So when you find

25· ·perchloroethylene or tri, you'll find the daughter


·1· ·products, and the degradation products are

·2· ·consistent with those chemicals because they degrade

·3· ·over time.· So these are --

·4· · · · · · UNIDENTIFIED SPEAKER:· How long does it

·5· ·take?

·6· · · · · · MR. BENTKOWSKI:· That's the $54,000

·7· ·question.· It really just depends on the chemistry

·8· ·of the site, the microbial population, because

·9· ·there's certain bacteria that break down these

10· ·chemicals.· In some places it doesn't break down.

11· ·There's just too much oxygen for the bacteria to

12· ·survive, and so you can monkey with the chemistry in

13· ·order to encourage that to happen.· So it depends.

14· ·But usually, it takes tens of years.· And we're

15· ·trying to -- we're going to try to encourage that to

16· ·happen faster with our remedy.

17· · · · · · MS. NEWMAN:· Okay.· So I guess what's

18· ·important here is just to highlight, these are the

19· ·type of contaminants that we have and these are the

20· ·ranges.· Once again, you're seeing another unit that

21· ·you might not be familiar with, micrograms per

22· ·liter.· I don't mind talking to you about that.· If

23· ·you want a little chemistry class about a microgram

24· ·and a liter, we can do that.· And it will get me

25· ·ready for -- my son is taking chemistry next year,


·1· ·so maybe I won't be so dusty when he asks me a

·2· ·question next year.

·3· · · · · · So I guess the only other thing here to

·4· ·kind of highlight, which I just showed you all what

·5· ·were the range of chemicals in a tabular form in

·6· ·that table.· This is another way we use to

·7· ·demonstrate contaminants.· And we call this a plume

·8· ·map or an isoconcentration map, but this is also a

·9· ·way that we can show where the source of the

10· ·contamination starts.

11· · · · · · And what happens is you have a source area,

12· ·so the contaminants really migrate two ways.· They

13· ·can migrate vertically, and we've already talked

14· ·about how they move in the surface through that sand

15· ·and gravel aquifer.· We talked about that, but they

16· ·also can migrate laterally as well.· So they move in

17· ·real time and in real space, is what they do.

18· · · · · · So in this picture, this picture really

19· ·shows that source area that we know.· And I'm sorry,

20· ·I can't remember if this one is tri or tetra.

21· · · · · · MR. BENTKOWSKI:· That's the tetra.

22· · · · · · MS. NEWMAN:· This one is the tetra.· This

23· ·is the tetrachloroethylene.· So here what we do in

24· ·our line of work or in our line of business is we're

25· ·able through calculation -- I guess calculation


·1· ·really isn't the best way to describe this.

·2· · · · · · MR. BENTKOWSKI:· It's a graphic technique.

·3· · · · · · MS. NEWMAN:· A graphic technique, and Ben

·4· ·is really good at it.· We're able to depict the

·5· ·concentration in terms of the concentration levels.

·6· ·So here, this line right here represents 5,000

·7· ·micrograms per liter.· So what that means is that

·8· ·the contamination inside this line is greater than

·9· ·5,000.

10· · · · · · So then the next line is 500 micrograms per

11· ·liter.· So that means that the contaminants outside

12· ·of here are greater than 500 but less than 5,000.

13· ·Does that make sense?

14· · · · · · And then you keep going outward.· So for

15· ·us -- these are very easy for us to read, and this

16· ·tells a really good story for us.· It might not make

17· ·that much sense to you all.· The tables probably

18· ·make more sense, but I did want to just display this

19· ·so you could get an idea of the fact that

20· ·contaminants move vertically and they move

21· ·horizontally.

22· · · · · · MR. BENTKOWSKI:· So, Keriema, I'll use my

23· ·pointer.· All right.· So this is where the degreaser

24· ·was -- is, I think.· And then there's a surface

25· ·water pathway that went that way.· So some of the


·1· ·release happened in this area and then along that

·2· ·drainage pathway, and that's how come that high spot

·3· ·is there.

·4· · · · · · The other suspected release location is

·5· ·over here, this kind of bulge in the contours.· And

·6· ·all this -- this on the elevation, this is high and

·7· ·this is low.· This is that Gray's Creek drainage

·8· ·canal on this east side of the site.· So the

·9· ·groundwater will flow this way.· And as it flows

10· ·that way, it takes the contamination with it towards

11· ·the creek.· And you can see that also -- that same

12· ·basic pattern in the TCE map on this figure here.

13· · · · · · And here you can see again this is where

14· ·the degreaser was.· And along this surface water

15· ·pathway, this is that other source area E, and this

16· ·is A and B, these two other -- that are right near

17· ·the side of -- the edge of the site, the upgrading,

18· ·up dip side of the site.· And that's -- we think

19· ·there might be some off site issues with that, not

20· ·related to the Security Signals operation.· So

21· ·that's why that's not covered in what we're

22· ·recommending to you today.

23· · · · · · MS. NEWMAN:· Awesome.· Any questions about

24· ·that?· Okay.

25· · · · · · UNIDENTIFIED SPEAKER:· What would happen if


·1· ·that creek ever overflowed?

·2· · · · · · MR. BENTKOWSKI:· Well, we actually have

·3· ·analytical data from the sediment and the surface

·4· ·water of the creek.· There is some of these solvents

·5· ·detected but at very low levels, so low that when we

·6· ·run them through a human health and ecological risk

·7· ·assessment, that it did not show -- it's kind of a

·8· ·funny phrase, but it did not show unacceptable risk.

·9· ·There's risk in anything you do.

10· · · · · · UNIDENTIFIED SPEAKER:· That creek runs

11· ·right past, you know, the back of our house.

12· · · · · · MS. NEWMAN:· What subdivision do you live

13· ·in?

14· · · · · · UNIDENTIFIED SPEAKER:· Over here, Glen

15· ·Ridge.

16· · · · · · MS. NEWMAN:· Glen Ridge, okay.

17· · · · · · MR. BENTKOWSKI:· Do you live north of here

18· ·or south of here?

19· · · · · · MS. NEWMAN:· Glen Ridge is the one

20· ·that's --

21· · · · · · MR. BENTKOWSKI:· South of there, okay.· But

22· ·we've got this last -- this number five sample, I

23· ·think, right here -- no, it's a little further

24· ·south, the number five surface water sample was

25· ·non-detected.· So what little bit there is is coming


·1· ·out from this plume and discharging into the creek

·2· ·is evaporated into the atmosphere and gone by the

·3· ·time it gets down to where your subdivision is.

·4· · · · · · UNIDENTIFIED SPEAKER:· Okay.

·5· · · · · · MS. NEWMAN:· And that's also important to

·6· ·us.· So when we -- I think we have a slide about the

·7· ·monitoring of the surface water that's also going to

·8· ·be included in our path forward, that the surface

·9· ·water continue to be monitored to make sure that it

10· ·is not discharging -- the contaminants are not

11· ·discharging into the surface water that will cause,

12· ·like, the term "unacceptable risk."· We have a slide

13· ·about that and we'll get to that in a minute.

14· · · · · · Where are we now?· So this slide right here

15· ·talks about -- we do two different types of risk

16· ·assessments.· We do one on human receptors, which

17· ·are in an industrial setting like this, we would

18· ·consider industrial workers.· We would consider the

19· ·potential that the site might become residential in

20· ·the future, so we consider residents.· We consider

21· ·construction workers.· And we also consider just

22· ·trespassers, someone who might come on the site and

23· ·is not supposed to be on the site.· So we evaluate

24· ·these things in this very complex -- it's called

25· ·risk assessment, is the term.


·1· · · · · · And I actually used to do it in a former

·2· ·life.· I don't do it anymore, but it's a series of

·3· ·calculations and assumptions where you consider this

·4· ·person having this level of exposure for this many

·5· ·hours over this period of time over a year.· You

·6· ·consider their lifespan.· You consider all of these

·7· ·things into this calculation.· And it spits out a

·8· ·risk number for those contaminants that we talked

·9· ·about.

10· · · · · · So when we did that calculation and we

11· ·assumed a residential scenario -- and we had to

12· ·assume a residential scenario because of the fact

13· ·that in Tennessee, because that Memphis Sand Aquifer

14· ·is so important to you all, Tennessee considers that

15· ·water that's contaminated general use water.· It may

16· ·never be used as a drinking water aquifer, but that

17· ·scenario has to be considered.· And Tennessee has

18· ·its own state statute that says that water could be

19· ·used, and if it is considered general use water, it

20· ·can't have contaminants in it.

21· · · · · · So in our decision-making process we had to

22· ·consider that.· And as a result of that, the risk

23· ·yielded that there was an unacceptable risk if

24· ·someone drank that water, which we know you all are

25· ·not because we already talked about the fact that


·1· ·that water is not being used, but that scenario

·2· ·yielded an unacceptable risk for a resident and also

·3· ·for an industrial worker.

·4· · · · · · So the point is that at some sites you may

·5· ·find that you have contaminants.· And when you run

·6· ·this risk calculation, there may be an acceptable

·7· ·risk where the calculation shows that the

·8· ·contaminants are not high enough that yields a risk,

·9· ·so you won't take an action.· But in this particular

10· ·case the contaminants were high enough, we ran the

11· ·risk calculations, and they yielded that this

12· ·groundwater needs to be remediated.· And that's why

13· ·we're here.

14· · · · · · And we've already talked the Memphis Sand

15· ·Aquifer, and we talked about where you all get your

16· ·water from, so we can move on.· So like we

17· ·mentioned, we do sample the sediment and the surface

18· ·water.· And in sampling the sediment and the surface

19· ·water, we also do a similar risk calculation on the

20· ·ecological receptors and the terrestrial receptors.

21· ·And based on the ecological risk assessment, it was

22· ·determined that based on the concentrations that

23· ·showed up in the surface water bodies and the

24· ·sediment concentrations that showed up, there isn't

25· ·an unacceptable risk to fauna, to terrestrial


·1· ·receptors, and to aqua receptors.· But like I

·2· ·mentioned, we will continue to require that the

·3· ·surface water is monitored to make sure that the

·4· ·contaminants are acceptable and that there won't be

·5· ·a risk.

·6· · · · · · So I think now you all have a good idea of

·7· ·what's out there, why we're here, and we're very

·8· ·close to talking about the remedies.· We're getting

·9· ·there.· But if you are interested, the contaminants

10· ·that are found at the site, for the most part, all

11· ·of them except for these two have what's called a

12· ·maximum contaminant level or an MCL.· And that is a

13· ·federal standard and it's called a safe drinking

14· ·water standard.· So these are the levels that if you

15· ·have contaminants that exceed these levels in the

16· ·ground, then it is not safe.· So that's also the

17· ·basis of why we're here because, like I showed you

18· ·in the slide, we have contaminants that exceed these

19· ·concentrations.

20· · · · · · For these two contaminants, when I

21· ·explained to you about the risk calculation, when we

22· ·performed the risk calculation, these were the

23· ·levels that were unacceptable.· So at this

24· ·concentration based on that risk value, these are an

25· ·unacceptable risk, and we could talk about that for


·1· ·hours, risk assessments.

·2· · · · · · MR. BENTKOWSKI:· But we won't.

·3· · · · · · MS. NEWMAN:· But we won't.· I think I

·4· ·already mentioned that there are issues with the

·5· ·subsurface soil that are -- there are areas within

·6· ·the subsurface in the degreaser area where you see

·7· ·groundwater contamination, you see subsurface soil

·8· ·contamination.· So what happens is that when that

·9· ·soil is in the groundwater, it's there and it can

10· ·leach from the soil into the groundwater and it's

11· ·basically contributing to the contamination over

12· ·time.· So it's important to also remediate the

13· ·subsurface soil and eliminate that leaching pathway

14· ·to the groundwater.· So these are also calculated

15· ·values.

16· · · · · · And so at these levels, if you had

17· ·contaminants in the subsurface at these levels, the

18· ·groundwater would be protected.· But if you have

19· ·subsurface soil above these contaminant levels for

20· ·each of these, they could leach into the groundwater

21· ·and yield unacceptable groundwater concentrations.

22· · · · · · So we have what we call remedial action

23· ·objectives.· All right.· We're going to get through

24· ·this.· I know you all want to get to the

25· ·alternatives.· I'm hoping I'm almost there.


·1· · · · · · We have these remedial action objectives

·2· ·that are things that we are trying to accomplish

·3· ·with these alternatives.· And the first one is we

·4· ·want to prevent human exposure or dermal contact,

·5· ·touching the skin, ingestion, or inhalation of the

·6· ·groundwater.· And there's one other thing I didn't

·7· ·mention, it's an institutional control.· And in

·8· ·addition to us talking about the Memphis Sand

·9· ·Aquifer being protected, there is also a Shelby

10· ·County ordinance that is in place that does not

11· ·allow people to install a well without permission

12· ·and application to the groundwater pollution control

13· ·board.· So that's another layer of protection that

14· ·we believe is in place that would prevent someone

15· ·from coming on to the Security Signals property or

16· ·anywhere where the contaminants have migrated and

17· ·installing a well.

18· · · · · · The next thing we would like to do is the

19· ·remedies that we have in place are going to -- or

20· ·the remedies that we're suggesting to put into place

21· ·are going to treat the groundwater and hopefully

22· ·remove the contaminants from the plume.· So we

23· ·talked about how the plume moves laterally, so that

24· ·is also in our objective, is we want to prevent that

25· ·plume from continuing to migrate by treating the


·1· ·source.

·2· · · · · · Next, we would like to -- we already talked

·3· ·about how the surface water is important to us and

·4· ·how we want to prevent or minimize contaminants from

·5· ·discharging into the surface water, so that's also

·6· ·an objective.

·7· · · · · · Next would be the Memphis Sand Aquifer is

·8· ·very important to us, so we want to make sure that

·9· ·that surficial aquifer is treated and we remove mass

10· ·amounts from the aquifer just to make sure that it

11· ·will never be there to impact the Memphis Sand

12· ·Aquifer.· So that's important.

13· · · · · · And finally, we want to -- we talked -- I

14· ·just finished talking about the leachability.· We

15· ·want to reduce or eliminate that subsurface soil

16· ·contamination from leaching into the deeper aquifer.

17· ·So we want to remediate those subsurface soils.

18· · · · · · The main point here to make is that this is

19· ·just an interim action.· There is going to be a

20· ·long-term -- long-term action for the site.· So

21· ·really here our objective is to just do the things

22· ·that we just talked about, but long term the aquifer

23· ·will have to be restored to those maximum

24· ·contaminant levels that I mentioned for all the

25· ·contaminants.


·1· · · · · · MR. BENTKOWSKI:· This is normally part of

·2· ·any ROD, Record of Decision, that we put in, but

·3· ·since this is an interim action, we're not going to

·4· ·meet this normal objective.· It will be part of the

·5· ·future Record of Decision.

·6· · · · · · MS. NEWMAN:· So now we're here to talk

·7· ·about the technologies we considered in this

·8· ·feasibility study or that Susan's consultants

·9· ·considered.· The first one is called in-situ

10· ·treatment.· And typically because of how

11· ·groundwater -- the nature of groundwater, it being

12· ·underground and it being dynamic, we like to try to

13· ·treat groundwater in-situ, meaning in place.· If it

14· ·was soil contamination and it was at a depth where

15· ·we could just dig it up and haul it and take it

16· ·away, that's how we would treat soil contamination,

17· ·but groundwater is a little bit different.· We want

18· ·to try to treat it in place.

19· · · · · · The first one I want to describe to you is

20· ·one that was considered and it's considered

21· ·reductive dechlorination.· The solvent that we

22· ·talked about, the perchloroethylene and the

23· ·trichloroethylene, are a group of contaminants

24· ·called chlorinated solvents.· So a way to remediate

25· ·those solvents and to degrade them would be to


·1· ·either use a substrate, like a carbon substrate, and

·2· ·what you would do is you would inject it into the

·3· ·ground.· And I think Ben already talked a little bit

·4· ·about these bugs that are in the ground.· So these

·5· ·bugs are naturally occurring in the ground, so you

·6· ·would either try to enhance the bugs by giving them

·7· ·nutrients to eat and they just go crazy and they eat

·8· ·up the contamination.

·9· · · · · · MR. BENTKOWSKI:· They make more of them and

10· ·then they actually consume the solvent and break one

11· ·of the chlorines off of it and then expel the

12· ·byproduct.· And so we start with four chlorines and

13· ·then it breaks it apart, and then you get three

14· ·chlorines.· And the next step has two chlorines, the

15· ·last step has one chlorine, and then it goes down to

16· ·ethane and ethene and methane.· So the bacteria, you

17· ·want to try to encourage that activity.· And that is

18· ·existing here already because we do have vinyl

19· ·chloride.· We show the complete breakdown process.

20· · · · · · MS. NEWMAN:· And you saw that in the list

21· ·of contaminants.· So the fact that we have the

22· ·degradation contaminants already in the groundwater,

23· ·we know that the groundwater has a reducing

24· ·condition.· So we know that some of it is already

25· ·going on, but this first alternative would just


·1· ·basically enhance what's happening hydrogeologically

·2· ·and would degrade the contaminant.· So that's what

·3· ·we would consider the in-situ treatment.

·4· · · · · · Another way of doing that would be --

·5· ·another way of reducing the chlorines is through

·6· ·zero valent iron.· And the iron acts as -- it

·7· ·donates the hydrogen, and the hydrogen is then --

·8· · · · · · Ben, help me out here.

·9· · · · · · MR. BENTKOWSKI:· It's in-situ chemical

10· ·reduction.· It donates the hydrogen, and that causes

11· ·a low oxygen environment which encourages the

12· ·bacteria to then proceed to break down the solvents.

13· ·And both of those are a type of in-situ treatment.

14· · · · · · MS. NEWMAN:· So that was one option.· The

15· ·second option would be to not -- so you do that

16· ·through an injection.· What you have are -- you

17· ·design a remedy where you select strategic points

18· ·where you inject either the carbon into the ground

19· ·or the zero valent iron.· And that's what we mean

20· ·when we say treatment.· We treat it through an

21· ·injection.

22· · · · · · And what you would do is you would inject,

23· ·and then you would collect samples, and you would

24· ·see how the concentrations responded to the

25· ·samples.· And you would wait some period for it to


·1· ·actually happen.· And then based on what the

·2· ·concentrations were, you would maybe inject again

·3· ·and see how the concentrations degrade.

·4· · · · · · So you would have several rounds of

·5· ·injection to determine how the concentrations were

·6· ·degrading over time, over some span of time.· And

·7· ·that would all be designed in remedial design.· So

·8· ·this is really just in general terms.

·9· · · · · · We talked already about the fact that

10· ·degradation is already occurring.· So another option

11· ·would be to not inject as many times, but maybe do

12· ·an injection one time.· And because we know we have

13· ·reducing conditions and we know it's degrading,

14· ·inject once and then just monitor the groundwater.

15· ·And over time it will eventually continue to

16· ·degrade.· And we would have the sample results on

17· ·some sampling schedule where we would know the

18· ·contaminants are degrading.· So that is what the

19· ·next alternative describes.

20· · · · · · The third alternative is also a treatment

21· ·alternative and it's called phytoremediation.· And

22· ·it is basically an engineered phytoremediation

23· ·network.· So an engineered network of trees are

24· ·planted in the ground.· And I'm going to let Ben do

25· ·this.


·1· · · · · · MR. BENTOWSKI:· Okay.

·2· · · · · · MS. NEWMAN:· We're closing in on this,

·3· ·guys.· We're almost there.· We're in the home

·4· ·stretch, but I think you all are really enjoying

·5· ·this.· I am.

·6· · · · · · UNIDENTIFIED SPEAKER:· We can leave if we

·7· ·don't like it.

·8· · · · · · MR. BENTOWSKI:· Okay.· The third option is

·9· ·phytoremediation.· The design -- the preliminary

10· ·design shows a network of over 400 trees.· The trees

11· ·are actually grown in a very specific way so that

12· ·you have a plot that's about two feet in diameter

13· ·but about 10 feet long.· So when you plant these

14· ·trees, they already have a well-established root

15· ·system and they get down to where the contamination

16· ·is.

17· · · · · · Part of the design will go through and mix

18· ·up the soil below where the roots are, between there

19· ·and the sandy zone of the alluvial aquifer, and that

20· ·will allow the contaminated water to come up near

21· ·the root zone.· And then through an

22· ·evapotranspiration process the volitiles that are in

23· ·the groundwater will come up through the trees, go

24· ·up through the vascular tissue of the trees and out

25· ·in the pores of the leaves where the sunlight


·1· ·degrades the chemicals.

·2· · · · · · We're planting enough trees in that a

·3· ·full-grown tree will produce -- will draw about 40

·4· ·gallons of water a day.· And this zone of aquifer is

·5· ·really fairly thin, about 10 -- 5 to 10 feet thick.

·6· ·And it might actually -- I haven't run the numbers

·7· ·yet, but I think it might actually provide hydraulic

·8· ·control to keep all the contamination there so that

·9· ·the trees can then draw it up through their roots

10· ·and into the vascular tissue.

11· · · · · · We have this -- we ran these ideas past one

12· ·of our research engineers in our lab in Cincinnati,

13· ·and he agreed that the concept looks good.· And so

14· ·that's the fourth element -- or the third element of

15· ·our alternatives here.

16· · · · · · And then the fourth element is actually a

17· ·combination of the in-situ treatment and the

18· ·phytoremediation.

19· · · · · · MS. NEWMAN:· Any questions about that?

20· · · · · · UNIDENTIFIED SPEAKER:· What about our fruit

21· ·trees, will they be affected?

22· · · · · · MR. BENTOWSKI:· No, ma'am, because where

23· ·you live -- you remember the map that showed just

24· ·the contamination was near the site, it's not near

25· ·your house.· And we'll plant these trees in the


·1· ·areas that have the highest concentration with

·2· ·contaminants.· And these contaminants are about 10

·3· ·times smaller than the maximum levels that these

·4· ·Poplar trees can stand.


·6· · · · · · MR. BENTOWSKI:· So none of this should

·7· ·affect anything that's in your yard at all.


·9· · · · · · MS. NEWMAN:· So we've kind of given you the

10· ·technology that we considered, the in-situ treatment

11· ·and the phyto and the combination remedies.· So

12· ·these next couple of slides are just going to talk

13· ·about how much it would cost to do those.· So the

14· ·first remedy would be -- or alternative would be no

15· ·action and, of course, that would cost nothing.

16· · · · · · The next alternative was the treatment

17· ·alternative and the monitoring once you inject.

18· ·What you have here is you have just a display of how

19· ·much the capital cost is to initially do the

20· ·injections and do the treatment versus how long it

21· ·will -- or how much it will cost to monitor it over

22· ·a 30-year period.· So basically the second

23· ·alternative will cost $4 million to implement.

24· · · · · · The next one, which is the limited

25· ·injections and the in-situ treatment, and we've


·1· ·talked about that one, that's the MNA where we just

·2· ·monitor it over time.· That one will cost $3.3

·3· ·million.

·4· · · · · · The fourth one is the phytoremediation, and

·5· ·that one will cost $3.4 million.· And like I said,

·6· ·these costs are the initial capital costs, plus the

·7· ·costs associated with monitoring the groundwater

·8· ·over time.

·9· · · · · · The final one is the combination of

10· ·treatment and phyto and that one is $4.3 million.

11· ·And the next slide just shows how the costs are

12· ·compared to each other.· There's a range of about

13· ·$700,000 in between all of the remedies that were

14· ·considered.· And, you know, here just to point out

15· ·the -- this one was the most expensive, the combo,

16· ·and then the one with the limited injections and the

17· ·MNA was the least expensive.

18· · · · · · MR. BENTOWSKI:· But not by much.

19· · · · · · MS. NEWMAN:· But not by much.· So when we

20· ·consider all of the alternatives, CERCLA, our

21· ·regulation, has these wonderful things called

22· ·criteria.· We have threshold criteria, modifying

23· ·criteria, and balancing criteria.· This part, when I

24· ·say boring, this is just really boring stuff, but

25· ·we've got to get through it.


·1· · · · · · MR. BENTOWSKI:· Get through it.

·2· · · · · · MS. NEWMAN:· But the first thing we

·3· ·consider when we're considering an alternative is

·4· ·the overall protectiveness of human health and the

·5· ·environment.· So when we're looking at an

·6· ·alternative, threshold criteria, the first two

·7· ·things it has to do is it has to protect human

·8· ·health and environment and it has to meet ARARs,

·9· ·which is an acronym.· So basically, an ARAR is some

10· ·established -- it could be an MCL, the maximum

11· ·contaminant level, like, a remedy would have to meet

12· ·those cleanup levels.· That would be an example of

13· ·an ARAR.

14· · · · · · MR. BENTOWSKI:· It's the laws and the

15· ·regulation that define what you have to do, what

16· ·you're required to do in order to do a remedy.

17· · · · · · MS. NEWMAN:· So we wouldn't even consider a

18· ·remedy that wouldn't meet those laws or that

19· ·wouldn't protect human health and environment.· So

20· ·that's basically the threshold.· So once we get

21· ·through the threshold, the next set of criteria are

22· ·balancing criteria and the long-term effectiveness

23· ·and permanence of an alternative.· So it's the

24· ·ability to protect the human health and environment

25· ·over time, will that remedy continue to operate the


·1· ·way that it should to protect human health and the

·2· ·environment.

·3· · · · · · The next one is, does that remedy reduce

·4· ·toxicity, mobility, volume, and -- is there

·5· ·something else?· It's just toxicity, mobility, and

·6· ·volume of contaminants.· So treatment for EPA is our

·7· ·preference.· We would like to always install a

·8· ·remedy or have our responsible party install a

·9· ·remedy that is a treatment remedy, so that's always

10· ·our preference.· We want to reduce contaminants and

11· ·the mobility of them and reduce the volume of

12· ·contaminants.· So we always really want to try to go

13· ·really hard at a remedy and treat contaminants.

14· · · · · · Next is balancing criteria.· And short-term

15· ·effectiveness is important, too, because if you're

16· ·implementing a remedy that may introduce dust into

17· ·the community or there are a lot of trucks coming

18· ·through a residential community, what's the short-

19· ·term effectiveness of that remedy, is that remedy

20· ·inherently going to really provide -- or not

21· ·provide, but is that remedy going to disrupt the

22· ·community where you implement it.

23· · · · · · So what's the short-term effectiveness, you

24· ·have to balance.· Are having those heavy trucks in

25· ·the neighborhood worth it because they're only going


·1· ·to be there for a month and you've really got to dig

·2· ·up this dirt and get it out.· So that's another

·3· ·criteria that we balance.· We think about that when

·4· ·we're selecting the remedy.

·5· · · · · · Is the remedy implementable, can it really

·6· ·be implemented, can you get to -- like, the trees,

·7· ·can we really find these trees, are they out there,

·8· ·is it just an idea, does it really exist, can you

·9· ·really implement this.

10· · · · · · And cost, do we want the PRP or does the

11· ·Federal Government want to pay for a remedy that

12· ·costs $50 million.· You've got to balance that, is

13· ·the cost worth it, or is it better to seek a

14· ·different remedy that costs less but may take

15· ·longer.· So cost also plays into how we balance

16· ·whether or not we select a remedy.

17· · · · · · And finally, the State, Jordan and Jerrel,

18· ·they have a role in this.· Do they accept the remedy

19· ·that's preferred and selected as a good one.· So

20· ·they have a role in here.· What they think is also

21· ·important.

22· · · · · · And most important, of course, are you, the

23· ·community, do you like the idea of what we are

24· ·putting forth out here, what we are recommending?

25· ·Do you think it's a good thing for the community and


·1· ·is it -- should it be selected?· So is that --

·2· ·that's a huge, important thing to us.

·3· · · · · · So finally, our preferred remedy, and I

·4· ·think you all may have already seen this if you saw

·5· ·the notice in the newspaper or if you received the

·6· ·flyer is the phytoremediation, the planting of the

·7· ·trees.· Ben did a great job of explaining to you

·8· ·that this process is going to be very similar to

·9· ·what we explained in the treatment.· It's also

10· ·creating this reducing condition.· It's

11· ·dechlorinating.· It's breaking down the tetra and

12· ·the trichloroethylene and the products.· It's

13· ·started degrading.

14· · · · · · He explained about how the contaminants

15· ·move through -- what is that thing called -- the

16· ·vascular tissue and comes out of the leaves through

17· ·the xylem.· And these trees would be installed in

18· ·Plumes C, D, and E.· And we believe that the trees

19· ·will effectively reduce the groundwater

20· ·contaminants.

21· · · · · · And this is just another example of this

22· ·tree, that they are -- Security Signals and their

23· ·consultants are looking at.· It's a patented

24· ·technology, so it's proprietary.· The company that

25· ·does this, the way they've been explained, I guess


·1· ·they've had -- they have several applications of

·2· ·this in the United States, where it's worked other

·3· ·places, that company that they are considering --

·4· ·and there are other companies out there who have

·5· ·similar technologies, but basically, what Ben

·6· ·described would be how the technology will work.

·7· · · · · · I guess the big thing here is that we are

·8· ·not going to be able to just plant trees in the

·9· ·ground and then walk away.· The trees are going to

10· ·have to be monitored to make sure that the tree

11· ·stands mature over time.· There's definitely

12· ·environmental stressors that, you know, we have to

13· ·be concerned about, winter and things like that.· So

14· ·the maturity of the tree stand, we believe it will

15· ·be at least five years before you know that that

16· ·tree's going to survive and it's there and it's

17· ·going to continue to flourish, is the time frame

18· ·that we think it will take.

19· · · · · · MR. BENTOWSKI:· And these are expected to

20· ·be Poplar trees which is a very common tree in this

21· ·part of the world.· I drove around Poplar Avenue a

22· ·couple of times when I was here last and you have a

23· ·fairly long growing season.· You have a fair amount

24· ·of rainfall.· When I first saw this site four or

25· ·five years ago, I thought that this might be a


·1· ·likely type -- a likely application for this type of

·2· ·technology.· And I think it has great promise to be

·3· ·effective.

·4· · · · · · And one of the things about it is we try to

·5· ·have more what we call green remediation where --

·6· ·that is, they have a lower carbon footprint.· It's

·7· ·actually less of an engineered solution or a

·8· ·mechanical solution, more of a natural solution.

·9· ·And I contend that planting trees to help reduce the

10· ·contamination is probably about as green a remedy as

11· ·we'll find.

12· · · · · · MS. NEWMAN:· So this just kind of gives you

13· ·an idea.· I know you all have already seen something

14· ·similar, but these will be the three areas that the

15· ·trees will need to be planted on the Security

16· ·Signals property.· The area of Plume C is about

17· ·10,000 square feet.· Plume D is about 13,000 square

18· ·feet.· And Plume E is also about 10,000 square feet.

19· ·And also on here, I think we've already talked about

20· ·this, we talked about where the zones are -- the

21· ·contaminants are below the ground surface.

22· · · · · · Ben has already alluded to this, the fact

23· ·why we're so passionate about the phytoremediation,

24· ·the fact that it is greener remediation, it will

25· ·reduce the overall carbon footprint.· In our agency,


·1· ·that's why we're here.· We're here to protect human

·2· ·health and environment.· And we want to promote the

·3· ·type of cleanups that are of a greener strategy.

·4· · · · · · This remedy supports our preference for

·5· ·treatment because EPA also always wants to

·6· ·aggressively seek treatment.· It will achieve our

·7· ·remedial action objectives.· It will protect human

·8· ·health and the environment.· It will, like I said,

·9· ·reduce toxicity, mobility, and volume.· And it is --

10· ·what's the fourth, moderate cost.· The fifth, the

11· ·moderate cost.· So this is our recommendation

12· ·tonight that we wanted to present to you.

13· · · · · · In the meantime, there are some other

14· ·things that we would want to have in place to make

15· ·sure that the environment is being protected while

16· ·we are making sure that the phyto is working.· So

17· ·that's Security Signals' property, that area, but it

18· ·would need to be restricted to land use and to

19· ·commercial use, which is not a problem because we do

20· ·believe that that area will remain industrial.

21· · · · · · We would also want to have a control in

22· ·place that will prevent the subsurface soil from

23· ·being disturbed while the remedy is being achieved,

24· ·because we already talked about the fact that

25· ·there's that soil -- that contaminated soil from 16


·1· ·to 25 feet deep.· We also talked about this, the

·2· ·fact that that aquifer should not be used for

·3· ·drinking water.· So we would want to prevent that

·4· ·aquifer from being used for drinking water.· So no

·5· ·one would use the surficial aquifer or install a

·6· ·well.

·7· · · · · · And finally, this is something that's very

·8· ·important, in this industrialized area you always

·9· ·want to make sure that potential property owners,

10· ·future property owners are notified that there is

11· ·residual contamination.· If Security Signals was to

12· ·sell the property to someone else, that would be a

13· ·part of the institutional control, that they notify

14· ·a future property owner if there's contamination

15· ·until it's cleaned up.

16· · · · · · And of course, the monitoring, so we

17· ·already talked about the fact that the groundwater

18· ·will have to be monitored.· The surface water will

19· ·have to be monitored.· And the fact sometimes when

20· ·you have these high concentrations in the

21· ·groundwater, there is a vapor intrusion pathway.

22· ·And what it is is that these concentrations can --

23· ·when they're in the groundwater, they can come up

24· ·through the slab or through whatever, the

25· ·crawl space.· In this case, I think it's all slab.


·1· ·At Security Signals, everything is on a slab.

·2· · · · · · And the indoor air, the vapors can come up

·3· ·through the soil and through the groundwater and

·4· ·pose a risk to indoor air.· So that would also be

·5· ·important.· That until the concentrations are

·6· ·cleaned up, that that indoor air is safe for the

·7· ·workers of Security Signals.· So that would also be

·8· ·important.

·9· · · · · · MR. DRAPER:· What are the health concerns

10· ·of these contaminants?· Are there any?

11· · · · · · MS. NEWMAN:· I am not -- but I'm pretty

12· ·sure that PCE -- I didn't have that in here.

13· · · · · · MR. DRAPER:· Why would we not have that

14· ·information?

15· · · · · · MS. NEWMAN:· I meant I don't have a slide

16· ·on it.

17· · · · · · MR. DRAPER:· Okay.· But why would --

18· ·shouldn't that be part of this?· That's the whole

19· ·reason --

20· · · · · · MS. NEWMAN:· Ben and I can talk about it,

21· ·but I'm just saying I don't have a slide.

22· · · · · · MR. DRAPER:· I don't understand why it

23· ·would not be part of the presentation.

24· · · · · · MS. NEWMAN:· Well, I talked about it in

25· ·terms of the fact that there's an unacceptable risk


·1· ·to that.

·2· · · · · · MR. DRAPER:· To what?

·3· · · · · · MS. NEWMAN:· To the PCE and to the TCE, but

·4· ·no one is drinking it.

·5· · · · · · MR. DRAPER:· But I mean --

·6· · · · · · MR. BENTOWSKI:· What are the health effects

·7· ·of excess PCE?

·8· · · · · · MR. DRAPER:· Yes.

·9· · · · · · MR. BENTKOWSKI:· Okay.· I believe for PCE,

10· ·it causes liver problems, liver cancer.

11· · · · · · MR. DRAPER:· Okay.

12· · · · · · MR. BENTOWSKI:· Now --

13· · · · · · MR. DRAPER:· So this stuff naturally

14· ·degrades but over a long period of time, so within,

15· ·like, 100 years?

16· · · · · · MR. BENTOWSKI:· Yeah.· I know some places

17· ·it is thousands of years, yes.

18· · · · · · MR. DRAPER:· So the primary health concern

19· ·is liver cancer, but no one is drinking the water

20· ·and no one is using the land for commercial use.· We

21· ·feel it's necessary to clean it up why?

22· · · · · · MS. NEWMAN:· Because of the fact of the --

23· ·and I'm going to let Jordan or Jerrel talk about

24· ·this, but TDEC, meaning Tennessee, and the

25· ·Tennessee -- I forget what the regulation is.· TDEC


·1· ·and who else is on the legislation?

·2· · · · · · MR. ENGLISH:· Well, it's TDEC.

·3· · · · · · MS. NEWMAN:· But there's someone else on

·4· ·that regulation.

·5· · · · · · MR. ENGLISH:· The State of Tennessee

·6· ·believes that any water of the state should be used

·7· ·for its most restrictive use and most pristine use,

·8· ·I guess.· And groundwater is expected to be usable

·9· ·for drinking water, whether it's actually used or

10· ·not, so --

11· · · · · · MR. DRAPER:· I understand that, but I just

12· ·think that the health concerns of that water, if for

13· ·some reason it was used, you even mentioned on there

14· ·just in case someone trespasses, but yet, you don't

15· ·even explain the risk.

16· · · · · · MR. ENGLISH:· You would have to find a

17· ·mechanism to get to that water to use it.· And there

18· ·are going to be restrictions about well use.· You

19· ·won't be able to install a well, so there would be

20· ·no access to that water for drinking.

21· · · · · · MS. NEWMAN:· But I can elaborate on what

22· ·you're asking.· You're asking me that in a

23· ·hypothetical situation, if the groundwater --

24· · · · · · MR. DRAPER:· That's the whole point of

25· ·this.


·1· · · · · · MS. NEWMAN:· The risk would be -- and it's

·2· ·in the proposed plan, I can give you a copy of it,

·3· ·but it's an unacceptable risk.· And the risk would

·4· ·be 1 times 10 to negative 3, I believe, is what the

·5· ·number is.· So that would be 1 in 10,000.

·6· · · · · · MR. BENTOWSKI:· No, one in --

·7· · · · · · MS. NEWMAN:· One in 1,000, I'm sorry.· One

·8· ·in 1,000.

·9· · · · · · MR. BENTOWSKI:· Chances of getting cancer.

10· · · · · · MS. NEWMAN:· Would be 1 in 1,000, is how we

11· ·-- that's how we think of risk and how we calculate

12· ·it.· So does that make sense to you?

13· · · · · · MR. DRAPER:· No.· I understand there's a

14· ·risk.· If there is -- if someone is exposed to it,

15· ·there's a certain risk of certain health issues.

16· · · · · · MS. NEWMAN:· Right.

17· · · · · · MR. DRAPER:· What bothers me is that those

18· ·health issues are not even a part of this

19· ·presentation.· That is the whole point that we're

20· ·concerned about, that chemical being in the

21· ·groundwater, but yet, its effect or what it could

22· ·cause, we're supposed to just kind of guess at it.

23· · · · · · MS. NEWMAN:· Well, I mean --

24· · · · · · MR. DRAPER:· It almost seems like you're

25· ·leaving it to us to figure out.


·1· · · · · · MS. NEWMAN:· No.· This is an opportunity

·2· ·for us to engage and find out what your concern is.

·3· ·So you've made it clear in your statement, in your

·4· ·question what your concern is.· This is an open

·5· ·dialog and an open conversation that will continue

·6· ·through the cleanup process.· So that means if I

·7· ·haven't met your need tonight, then there's follow-

·8· ·up action.· I provide you with IRIS, which is our

·9· ·database where we talk about toxicity and how

10· ·toxicity is an issue.· There are toxicity values on

11· ·IRIS, and I can walk you through the risk

12· ·calculations.

13· · · · · · In addition to that, we have a daughter

14· ·agency called ATSDR where we have fact sheets on

15· ·each of those contaminants.· And those fact sheets

16· ·tell you what the risks are.· So it might not just

17· ·be to the liver.· It may be other organs that TCE or

18· ·perchloroethylene cause a risk to.· So I can provide

19· ·those things to you.

20· · · · · · MR. DRAPER:· And is there any data on what

21· ·levels are in our drinking water?· I know it's not

22· ·connected, but naturally found just because of

23· ·widespread -- you know, wherever the water comes

24· ·from and over time.· I'm sure there's parts per

25· ·million or something of these contaminants already


·1· ·in our water but at acceptable levels; is that

·2· ·correct?

·3· · · · · · MS. NEWMAN:· That's what the maximum

·4· ·contaminant level is.

·5· · · · · · MR. DRAPER:· So they're already there,

·6· ·possibly?

·7· · · · · · MS. NEWMAN:· I wouldn't go on record saying

·8· ·that without having seen what Shelby County -- I

·9· ·would have to look at -- I'm sure that Shelby County

10· ·has some annual period samples there that are

11· ·collected by --

12· · · · · · MR. DRAPER:· I'm assuming that whenever you

13· ·calculate this stuff, you would have the control.

14· · · · · · MS. NEWMAN:· The control is the maximum

15· ·contaminant level.· That does not mean that that

16· ·level is in your groundwater.

17· · · · · · MR. DRAPER:· Right.

18· · · · · · MS. NEWMAN:· That means that if it exceeds

19· ·that level, then it's a risk, an unacceptable risk.

20· ·So I think that what I would need to provide you

21· ·with are those ATSDR fact sheets for the

22· ·contaminants that are site related and also maybe

23· ·have another discussion with you either after the

24· ·meeting or over the phone about any other concerns

25· ·that you have specifically.· But I think I


·1· ·understand what you're asking me now and what I

·2· ·should provide you.

·3· · · · · · MR. DRAPER:· Because I'm guessing the

·4· ·employees of Security Signals have been provided

·5· ·this type of information.

·6· · · · · · MS. NEWMAN:· Well, you know, Susan can

·7· ·elaborate on that, but they have a different set of

·8· ·standards that they have to follow operating in an

·9· ·industrial environment, OSHA standards that they

10· ·need to meet.

11· · · · · · MR. DRAPER:· Okay.· Is there any -- I know

12· ·they are considered the responsible party.· Is there

13· ·any responsibility placed on the manufacturer of the

14· ·degreaser?

15· · · · · · MS. NEWMAN:· Not at this time, no.

16· · · · · · MR. DRAPER:· So there was a warning label

17· ·saying this stuff gets into the water?

18· · · · · · MS. NEWMAN:· I can't comment on that at

19· ·all.· I have no idea if there was a warning label on

20· ·the degreaser.

21· · · · · · Susan, do you know?

22· · · · · · MS. LEE:· We haven't used that degreaser

23· ·for years and I could not tell you that there was,

24· ·but I will tell you this, we don't use that

25· ·material.· We have an enclosed system in a building


·1· ·that we use for parts.

·2· · · · · · I just found out, by the way, when this

·3· ·problem was identified, this was one of the first

·4· ·things we did.· We had a flood situation that we

·5· ·feel caused it when that industrial park was

·6· ·developed.· After the flood and then the testing

·7· ·began, we moved to, as I say, an enclosed cleaning

·8· ·system that's based on something entirely

·9· ·different.· And it's -- and it's contained within a

10· ·building so that we don't think that -- I mean,

11· ·there's absolutely no spill hazard on that.

12· · · · · · And we don't use that type of material.· So

13· ·we haven't been using that for quite some time.· The

14· ·employees are not exposed to it; however, employees

15· ·do have access to MSDS on the shop floor.

16· · · · · · MR. DRAPER:· But you guys are still open

17· ·and functional?

18· · · · · · MS. LEE:· And we don't have anybody with

19· ·cancer.

20· · · · · · MR. DRAPER:· Exactly.· So if they're still

21· ·working and functioning on the property and this

22· ·stuff will naturally degrade on its own, why spend

23· ·$4 million if there's no -- if it's not hurting

24· ·anybody?· Because my concern is -- I know that you

25· ·said the Federal Government, that means we pay for


·1· ·it.· And if the Federal Government doesn't pay for

·2· ·it, we're going to pay for it also.

·3· · · · · · MS. LEE:· We're paying for it.

·4· · · · · · MR. DRAPER:· So that's messed up, because

·5· ·if there is no immediate health concern, the

·6· ·employees are not at risk, why are we even here

·7· ·talking about this?· It will naturally degrade

·8· ·for -- I think the treatments are great, but at

·9· ·$4,500 a tree, it seems a little ridiculous.

10· · · · · · MR. BENTOWSKI:· Only $100.

11· · · · · · MR. DRAPER:· $1.8 million was the initial

12· ·cost, you said 400 trees.

13· · · · · · MR. BENTOWSKI:· There's also the design and

14· ·the installation of the trees.

15· · · · · · MR. DRAPER:· Which the total --

16· · · · · · MR. BENTOWSKI:· We're talking about $2,100.

17· · · · · · MR. DRAPER:· I understand.· I was factoring

18· ·in all these costs per tree.

19· · · · · · MS. NEWMAN:· I think the point that you're

20· ·making is well taken.· I think ultimately what it

21· ·boils down to is there is CERCLA and there are the

22· ·TDEC regs.· And because of CERCLA and what Tennessee

23· ·has in place and what their rules are about their

24· ·aquifer and the use of it and the beneficial use,

25· ·that's really what it boils down to.


·1· · · · · · And Susan is a good corporate citizen and

·2· ·she realizes that there's a problem out there.· And

·3· ·she has actively engaged in the cleaning up -- well,

·4· ·investigating and ultimately in the cleaning up of

·5· ·the groundwater.· And that's really what it boils

·6· ·down to.

·7· · · · · · MR. ENGLISH:· TDEC likes to take a balanced

·8· ·approach to dealing with environmental matters.

·9· ·Over most of Memphis there is a fairly good

10· ·confining layer.· And in most places, even though

11· ·the surficial aquifer may be contaminated, that's

12· ·fine for those locations where there's a clay layer.

13· ·There are places where there's not.· And when the

14· ·contamination migrates to an area where there is no

15· ·confining layer, then you have the ability for that

16· ·contamination to move down into the Memphis Sand and

17· ·become a part of the water we drink.

18· · · · · · We have places where we have windows, and

19· ·right now we have sites where we have big concerns

20· ·about those.· And we're more aggressively working on

21· ·those sites to try to solve those problems.· But if

22· ·we allow the surficial aquifer to just absorb and

23· ·collect and continue to not try to manage the

24· ·contamination in the surficial aquifer, we could be

25· ·setting ourselves up for long-term problems for our


·1· ·drinking water in the Memphis Sand.

·2· · · · · · MR. DRAPER:· But in this situation, if we

·3· ·would have left it alone, the only way it could get

·4· ·to the groundwater would be through the 100-foot

·5· ·boring hole that you guys put through to see how

·6· ·deep the clay was.· Other than that, it wouldn't

·7· ·have had a shot.· You guys punctured it and gave it

·8· ·a pathway.· So had you just left it alone, there

·9· ·would have been no shot of getting to it.

10· · · · · · MR. ENGLISH:· Those borings weren't done

11· ·with blinders on.· Those borings were done -- any

12· ·borings like that are always done with a mechanism

13· ·where when we do that, we determine the thickness of

14· ·that and we grout that up.· We do not leave an open

15· ·hole.· It's just not done.

16· · · · · · MR. DRAPER:· Okay.

17· · · · · · MR. ENGLISH:· I understand what you're

18· ·saying, and I agree with you to some extent, that

19· ·it's a very expensive endeavor to clean up an

20· ·aquifer that might not ever be used, but the State

21· ·of Tennessee's position is that aquifer might be

22· ·needed one day.

23· · · · · · MR. DRAPER:· I feel like it would be

24· ·cheaper to purchase the water.

25· · · · · · MR. ENGLISH:· Pardon?


·1· · · · · · MR. DRAPER:· Is there any way to purchase

·2· ·the water rights for the ground?· Would it be

·3· ·cheaper for them for their property?

·4· · · · · · MR. ENGLISH:· Everything that is water --

·5· · · · · · MR. DRAPER:· I know, but I'm looking at

·6· ·your diagrams and how it's spread out and we've got

·7· ·it confined to this small, tiny, little area, I just

·8· ·don't understand.

·9· · · · · · UNIDENTIFIED SPEAKER:· It's not actually

10· ·confined, it can migrate and it can leach.

11· · · · · · MR. DRAPER:· But we found that when it does

12· ·migrate out into the creek, it actually disappears.

13· · · · · · MR. ENGLISH:· It does now.

14· · · · · · UNIDENTIFIED SPEAKER:· Eventually.· To

15· ·anyone with liver cancer, it will make a difference.

16· · · · · · MR. DRAPER:· That's where workmen's comp

17· ·comes in.

18· · · · · · UNIDENTIFIED SPEAKER:· Eventually they're

19· ·going to put this on the ballot for us to vote on

20· ·how many trees to plant.

21· · · · · · MS. NEWMAN:· Well, a design will come out.

22· ·A design will be put forth once the remedy is

23· ·selected.· Like, really this is your opportunity --

24· ·I'm sorry, I didn't get your name for the record.

25· · · · · · MR. DRAPER:· Jonathan Draper.


·1· · · · · · MS. NEWMAN:· Like he's basically told us --

·2· ·and his comment is on record about what he feels

·3· ·about the remedy.· And you all have an opportunity

·4· ·right now to also make statements that will go in

·5· ·the record.· Or if you want to write them, if

·6· ·there's some concern that you have about the number

·7· ·of trees or about the -- you can write that up and

·8· ·give it to me before you leave.· So that is what

·9· ·this dialog is for, for any concern that you have,

10· ·to get it on the record and to formalize your

11· ·comment.

12· · · · · · But there won't be a ballot.· It will be --

13· ·if we don't receive significant comments that make

14· ·us think that this is not the remedy that we want to

15· ·select, then we will move forward with this remedy

16· ·in the Record of Decision.· If there are significant

17· ·comments, then we have to address them in our

18· ·Responsiveness Summary and figure out the path

19· ·forward.· And still continuing to have dialog,

20· ·figure out how we can all reach a common ground.

21· · · · · · MR. BENTOWSKI:· Mr. Draper, I have found in

22· ·the remedial investigation document in one of the

23· ·later appendices the details about the cancer-

24· ·causing effects of the various chemicals.· It's

25· ·about four or five pages long.· You're welcome to


·1· ·come up here, if you want me to show you -- walk you

·2· ·through it, I'll be glad to.

·3· · · · · · But it's basically cancer causing for

·4· ·liver, kidneys, and problems with the reproductive

·5· ·systems.· Anyway, so it's -- I'll be glad to walk

·6· ·you through it, a geologist talking about

·7· ·epidemiology and toxicology, but I can show you

·8· ·where it is in the report.

·9· · · · · · MS. NEWMAN:· And you know, like I said, if

10· ·you want to have some more discussion about this off

11· ·line, we can.

12· · · · · · MR. DRAPER:· I just think it's odd that our

13· ·main concern about contamination is health and how

14· ·it would affect people, but yet, that information is

15· ·not presented.· That's absurd.

16· · · · · · MS. NEWMAN:· You know, our position is that

17· ·we have definitely verbally discussed with you that

18· ·there is an unacceptable risk.· I've given you what

19· ·that cancer risk number is.· It's 1 times 10 to

20· ·negative 3.· It's in the proposed plan that we have

21· ·multiple copies here.· It's also in the library.

22· ·The only thing in addition to that I could have done

23· ·tonight was also provide the ATSDR fact sheets,

24· ·which I don't have, but I will follow up with those

25· ·in the mail or email.


·1· · · · · · UNIDENTIFIED SPEAKER:· I have a question.

·2· ·Did you say the initial contamination was over 50

·3· ·years ago?

·4· · · · · · MS. NEWMAN:· Well, that's the problem.

·5· ·Specifically, you know, Susan and I had some

·6· ·conversations about that earlier.· We know when

·7· ·Security Signals started its operation.· We know

·8· ·what years they used the degreaser.· But when that

·9· ·actual release occurred into the groundwater, like,

10· ·Susan mentioned a flood that happened in the

11· ·Nineties, she thinks could have been a major

12· ·contributor to the contamination, it could have just

13· ·been over time through the operation.

14· · · · · · We also know when she stopped using the

15· ·degreaser and she went to the different closed

16· ·system.· So we have an approximate time frame, but

17· ·it's really hard in an industrial setting to date

18· ·unless you have -- we do have sites where we know a

19· ·big release occurred because it was a catastrophic

20· ·release, a tank burst or a tank ruptured, but we

21· ·know that here that is not the case.

22· · · · · · But there's a chance that it could be -- it

23· ·could date back from the Fifties, you know, it could

24· ·be 50 years or it could be 30 years.· I just can't

25· ·tell you.


·1· · · · · · This really talks about the schedule.· We

·2· ·put the public notice last week in The Commercial

·3· ·Appeal.· The start of the comment period was

·4· ·yesterday.· Tonight is the meeting.· The end of the

·5· ·comment period is September 18th.· And the Record of

·6· ·Decision, we hope, will be issued before the end of

·7· ·the fiscal year, which is September 30th.

·8· · · · · · We have an administrative record in Atlanta

·9· ·that all the files that are site related we have in

10· ·our office in Atlanta.· And all of these things have

11· ·also been sent and they're housed in the Cordova

12· ·branch library.· They've agreed to let it stay

13· ·there.· So as long as we're here and Security

14· ·Signals is here and the cleanup is ongoing, those

15· ·documents will be on display in the Cordova library.

16· · · · · · Once again, I think I already made this

17· ·statement, you can contact me by mail.· Anyone who

18· ·wants a copy of the proposed plan, there's a sheet

19· ·on there that you can send back in, you can write

20· ·your comments and mail it back.· You can email it.

21· ·You can email your comments to me in email.· My

22· ·email address is provided.· Fax it or you can stay a

23· ·couple of minutes and write down what you'd like

24· ·today after the meeting is over.

25· · · · · · And like I mentioned, I'm Keriema, this is


·1· ·my contact information.· Or if you can't reach me,

·2· ·Sherryl, of course, is another resource.· And I

·3· ·think that concludes it.· And anyone else who wants

·4· ·to talk to me or Ben or Jordan or Jerrel or Susan,

·5· ·we're available to you all that would like to talk.

·6· · · · · · END OF PROCEEDINGS

·7· · · · · · ·August 21, 2014, 8:28 p.m.

·8

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·1· ·C E R T I F I C A T E

·2

·3· · · · · · I, KELLY N. STEPHENS, RPR, TN LCR #477,

·4· ·hereby certify that the foregoing proceedings

·5· ·were taken before me at the time and place

·6· ·specified.

·7· · · · · · I further certify that the proceedings

·8· ·were taken down in stenograph by myself

·9· ·and thereafter transcribed and reduced to

10· ·typewriting and constitutes a full, true, and

11· ·correct record of the foregoing proceedings.

12· · · · · · I further certify that I am not agent,

13· ·attorney, or counsel for any of the parties, and

14· ·that I am in no way interested in the event of the

15· ·cause named.

16· · · · · · IN WITNESS WHEREOF, I have hereunto set

17· ·my hand the 2nd day of September, 2014.

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19· · · · _________________________________________

20· · · ·KELLY N. STEPHENS, RPR, TN LCR #477

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APPENDIX B

Proposed Plan Fact Sheet

1

INTRODUCTION

This Proposed Plan identifies the Preferred Remedial Alternative for remediating the contaminated

subsurface soil and groundwater within Operable Unit (OU) 2 at the National Fireworks,

Superfund Site (Site). In addition, the Proposed Plan includes summaries of other cleanup

alternatives evaluated for use at the OU2 portion of the Site. The Proposed Plan is issued by the

U.S. Environmental Protection Agency (EPA), the lead agency for site activities, and the Tennessee

Department of Environment and Conservation (TDEC), the support agency. The EPA, in

consultation with TDEC, will select a final remedy for OU2 after reviewing and considering all

information submitted during the 30-day comment period from August 20, 2014 through September

18, 2014. The EPA will accept written comments on this Proposed Plan during the public comment

period.

A public meeting is scheduled on August 21, 2014. The meeting will be held at Cordova

Community Center, 1017 N. Sanga Road, Cordova, Tennessee 38018 at 7:00 pm. The EPA will

hold a public meeting to explain this Proposed Plan. Oral and written comments will also be

accepted at the meeting. For more information regarding the Site, see the Administrative Record at

the following locations: U.S. EPA Records Center, 61 Forsyth Street, S.W., Atlanta, GA 30303,

404-562-8946; Hours: Mon. – Fri. 8:30am – 4:30pm and Cordova Branch Library, 8457 Trinity

Road, Cordova, TN 38010, 901-415-2764; Hours: Mon.- Thur. 10am -7pm, Fri..- Sat. 10am-5pm.

The EPA, in consultation with TDEC, may modify the Preferred Alternative or select another

remedial alternative presented in this Proposed Plan based on new information or public comments.

Therefore, the public is encouraged to review and comment on all the alternatives presented in this

Proposed Plan. The EPA’s final decision will be announced in the Record of Decision (ROD) with

inclusion of a Responsiveness Summary addressing public comments.

The EPA is issuing this Proposed Plan as part of its public participation responsibilities under the

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 117(a)

and Section 300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency

Plan (NCP).

The Site has been organized into operable units (OUs) as illustrated in Figure 1. OU1 addresses

the former burn pit located on the southwestern portion of the Site. The burn pit was used to burn

materials of unknown composition. OU2 addresses the groundwater and subsurface soil

contamination on the north-central portion of the Site. This Proposed Plan is written to address

OU2, only. OU2, is in the north-central portion of the Site and consists of approximately 22 acres

and is located south of Macon Road in Cordova, Tennessee. The remedial alternatives presented in

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 4

NATIONAL FIREWORKS, OPERABLE UNIT 2 SUPERFUND PROPOSED PLAN

Cordova, Shelby County, Tennessee August 2014

2

this Proposed Plan address the contaminated groundwater and subsurface soil located at OU2

portion of the Site which is currently owned and operated by Security Signals Inc. (SSI) and

properties where contaminated groundwater have migrated. The scope of the OU2 Proposed Plan

is limited to addressing contaminated groundwater and contaminated subsurface soil that is present

and can leach into the groundwater. In addition, this action is an interim action, until a final

groundwater remedy is selected. The remaining portions of the Site will be addressed separately

under a separate response action.

The OU2 Proposed Plan summarizes information that can be found in greater detail in the

Remedial Investigation / Feasibility Study (RI/FS) Report and other documents contained in the

Administrative Record (AR) for OU2. EPA and TDEQ encourage the public to review these

documents to gain a more comprehensive understanding of OU2 and the Superfund activities that

have been conducted at the entire Site including OU2. These documents are available for public

review at the Information Repository located at the Cordova Branch Library in Cordova, TN.

Figure 1. Former National Fireworks Facility Layout

3

SITE BACKGROUND Historical Operations The history of the National Fireworks Inc. (NFI) facility including OU2 dates back to World War II

when the NFI facility produced ammunition, incendiary bombs, flares and signals, smoke pots, and

blast caps/grenades. NFI was active on a 260-acre tract from February 1942 to August 1945.

During operations from 1942 to 1945, NFI buildings were spaced throughout the Site because of the

explosive nature of the products. Former employees of the former NFI facility confirmed that NFI

produced smoke pots and incendiary bombs for the Army and loaded 20 millimeter (mm) and 55

mm shells for the Navy. Historical documents indicated that the following activities were

conducted in these identified areas on or adjacent to OU2:

Chemicals used in the manufacture of munitions were unloaded in an area around the former

NFI railroad tracks in the northern portion of the Site.

NFI buildings currently located in the northern portion of the Site were used for warehouses

and office for plant operations.

NFI buildings in the north-central portion of the Site (currently owned by SSI) were used to

manufacture ammunition.

Cordova Industrial Development Company purchased the 260-acre property from NFI in 1946. SSI

leased a 20-acre tract of Site in 1948 to manufacture fuses, ignition cartridges, and other

pyrotechnic devices. In 1952, NFI leased back four of approximately sixty buildings to resume

operations for the Korean War. SSI was established in 1948 to manufacture fuses, ignition cartridges, and other pyrotechnic

devices. After NFI vacated the Site the second time, SSI purchased approximately 11 acres from

Cordova Industrial Development on or about June 14, 1955. SSI purchased an additional acre

February 18, 1969. SSI purchased approximately 10 additional acres on April 23, 1993. SSI

currently owns a total of 22 acres; however, their site operations are still limited to the eastern

portion of OU2.

In 1968, SSI expanded operations in the OU2 area, to include a screw machine, parts and metal

fabrication. Since 1996, recent SSI operations have included manufacture of machined metal

products, including automotive valves, air conditioning compressor parts, etc., from raw material

bar stock. The machined metal parts are produced in screw machines, using cutting oil as a coolant.

No pyrotechnic products have been manufactured in the OU2 area since 1997.

4

Pre-Remedial Activities Tetra Tech conducted a Site Inspection (SI) in 2003 and an Expanded Site Inspection (ESI) in

2005 on the entire Site. The results from the SI and ESI identified volatile organic compounds

(VOCs), semivolatile organic compounds (SVOCs), pesticides, explosives, and inorganic

constituents in soil and groundwater at various locations across the Site. Samples collected at OU2

identified VOCs, SVOCs (specifically polynuclear aromatic hydrocarbons [PAHs]), pesticides,

and inorganics. Both the SI and ESI reports recommended that the contamination onsite be further

evaluated.

Enforcement Activities EPA entered into an Administrative Settlement Agreement and Order on Consent (AOC) with

SSI on May 18, 2007, to complete the RI/FS activities for OU2. All RI/FS activities have been

performed in accordance with the AOC.

SITE CHARACTERISTICS

Physical Characteristics and Land Use The Site is currently called the Cordova Industrial Park, which has subdivided industrial lots with







of Memphis. The parcel is zoned for industrial use. The general use of the parcels surrounding the

Site are zoned for industrial, commercial, agricultural, and residential uses. The geographic

coordinates at the western entrance to the Site are latitude 35' 09' 27.06" north and longitude 89' 45'

41.63" west.

The Site is bounded on the north by Macon Road, on the east by Grays Creek Drainage Canal, on

the west by a Tennessee Valley Authority easement, and on the northwest by former CSX railroad



The portion of the Site that is referred to as OU2 and owned and operated by SSI and is located in

the north central part of the Site as illustrated in Figure 2. OU2 consists of multiple production

buildings of varied construction (cinder block, fiberboard, sheet metal) on both slab and

conventional foundations. Both asphalt and gravel drives provide access across OU2. Unpaved

areas are typically grass or gravel and are maintained. Ditches are present across this portion of the

Site to ensure drainage. Multiple unused production buildings are also present. Some buildings are

used for storage and other buildings are being refurbished. Both the southern and western portions

of OU2 remain undeveloped. Additional details regarding historical use and former property

owners are provided in the Remedial Investigation Report and the Remedial Investigation Report

Addendum.

5



development.

Figure 2. Property Boundary of OU2 (Security Signals Inc.) within the Site

Topography and Drainage The topography of OU2 is flat; however, the former NFI facility consisted of rolling hills. Since

operations began in the 1940s, most of the facility has been leveled for redevelopment. A Memphis

Press-Scimitar article dated March 16, 1961, indicated “dozers… leveled off the hilly countryside,

moving the fresh earth into low spots.”

The eastern portion of the Site, which includes OU2, appears to have been constructed along the

floodplain of Grays Creek Drainage Canal. Storm water drainage has been a recurrent problem at

OU2, as it historically received overland flow from the west and northwest. Drainage is managed

via drainage ditches/wet weather conveyances (WWCs) across the newly developed areas of the

Site and appears to be channeled to storm sewers immediately behind the screw machine building

and at the southeast corner of the OU2 area. Grays Creek Drainage Canal flows north northwest

6

and turns south to southwest before reaching its confluence with the Wolf River, which is

approximately 4 miles downstream of Macon Road.

Surface water discharges from the Site occur in three ways:

Onsite, via WWCs on OU2, and then via culverts to Grays Creek Drainage Canal. The

WWCs/culverts which drain the developed portions of the OU2/SSI property flow due east:

one along the southern edge of Macon Road, and one generally east of the degreaser

building/screw machine building. WWCs on OU2 are maintained to ensure drainage to the

culverts. Overland flow from undeveloped portions of OU2 is expected to be minimal, given

vegetation and topography.

Via groundwater-to-surface water discharge, as interpolated from subsurface lithology. The

alluvial/fluvial water bearing units increase in thickness to the east, towards Grays Creek

Drainage Canal. A comparison of stream bed elevations and top of clay elevations suggests

that the alluvial/fluvial unit discharges into Grays Creek Drainage Canal.

Offsite via networks of storm drains (along Big Orange Road and Cordova Park Road) and

drainage ditches along the southern property boundary.

Site Hydrogeology The alluvium of the Mississippi Alluvial Plain and alluvial plains of streams that drain the Gulf

Coastal Plain consists primarily of fine sand, silt, and clay in the upper portion, and sand and gravel

in the lower. The alluvium ranges from 0 to 175 feet thick, and is commonly 100 to 150 feet thick

beneath the Mississippi Alluvial Plain and less than 50 feet thick beneath the alluvial plains of

major streams draining the Gulf Coastal Plain. The alluvium supplies water to many domestic,

farm, industrial, and irrigation wells in the Mississippi Alluvial Plain. Where present, the alluvium

is part of the surficial aquifer.

Loess, eolian in origin, consists of a blanket-type silt deposit draped over existing topography

developed on underlying units. Loess is characterized by very fine angular particles of uniform

composition. Loess has a characteristic vertical grain that promotes steep bluffs. The upper three

loess units correlate with the Peoria, Farmdale, and Loveland loess sheets of Illinois. A fourth unit

that underlies the others is a thin clayey and darker deposit classified as pre-Loveland. The loess is

underlain by fluvial deposits that occur locally near the study area, typically characterized by a red

or brown sand and gravel. Some of the sandy and argillaceous silt on the lower slopes is reworked

and could be included in fluvial deposits, but no practical distinction can be made for geologic

mapping purposes. Loess is locally thin or absent where eroded and uncommonly thick where

accumulated. The loess is a significant impediment to the downward migration of water due to its

massive structure of tight interbedded silts and clays.

The fluvial deposits, which are beneath the uplands and valley slopes of the Gulf Coastal Plain,

consist primarily of sand, gravel, and minor clay lenses. Locally, the sand and gravel is cemented

with iron oxide to form thin layers of ferruginous sandstone or conglomerate generally in the lower

or basal parts of the units. The fluvial deposits range up to 100 feet thick in the Memphis area.

7

Thickness varies because of erosional surfaces at both the tops and bases of the units. The fluvial

deposits provide water to many domestic and farm wells in rural areas of the Gulf Coastal Plain.

The Jackson Formation, once thought to constitute most of the thickness of the confining unit

separating the surficial aquifers from the Memphis aquifer, occurs only beneath the higher hills and

ridges in the northern part of the Memphis area. The Jackson Formation is included here in the

descriptions of the Jackson-Upper Claiborne confining unit. The Cockfield Formation occurs in the

subsurface in most of the western part of the Memphis area, and extends eastward to the limits of

the Jackson-Upper Claiborne confining unit. The Cockfield Formation consists of interfingering

fine sand, silt, clay, and local lenses of lignite. The unit ranges up to 250 feet thick. In most of the

Memphis area, the Cockfield Formation is an erosional remnant, and the original thickness is

preserved only beneath the higher hills and ridges of Shelby County. The discontinuous and

interconnected sands of the Cockfield Formation constitute a regional aquifer in some parts of the

area of occurrence in Tennessee, Kentucky, Missouri, Arkansas, Louisiana, Texas, and Mississippi.

In the Memphis area, the Cockfield Formation generally is dominated by fine sediments, but may

contain thicker, coarser sands in some areas. Consequently, the formation has been included in the

Jackson-Upper Claiborne confining unit for work conducted by the U.S. Geological Survey in the

Memphis area. A few domestic wells in the Memphis area are screened in sands in the Cockfield

Formation. The Cook Mountain Formation occurs in the subsurface of most of the Memphis area,

extending eastward to the approximate eastern limits of the Jackson-Upper Claiborne confining

unit. The Cook Mountain Formation consists primarily of clay, but locally it contains varying

amounts of fine sand. The formation ranges from approximately 30 to 150 feet thick in the

Memphis area, but it is commonly approximately 60 to 70 feet thick. The Cook Mountain

Formation is a regional confining unit overlying the Memphis Sand in Tennessee, Missouri, and

northeastern Arkansas and the Sparta Sand in Kentucky, southern Arkansas, Louisiana, and

Mississippi.

The Memphis Sand aquifer supplies approximately 95 percent of the water used in the Memphis

area for municipal and industrial water supplies. The aquifer is encountered approximately 120 feet

below ground surface (bgs) in Cordova, Tennessee. In the site vicinity, groundwater flow in the

Memphis Sand aquifer is greatly influenced by cones of depression created by the surrounding

municipal wellfields. Recharge to the aquifer generally occurs from precipitation along the outcrop

belt, where it is at or near the surface or where the Jackson-Upper Claiborne confining unit is thin

or absent, thereby allowing downward infiltration to occur. Where the aquifer is confined and head

differences are favorable, a recharge component locally enters the Memphis Sand aquifer by

downward leakage from the surficial aquifer or the Jackson-Upper Claiborne confining unit.



Section, 1200-04-03-.07(4)(b) states the following, “Except for groundwater in areas that have been

designated as Special Source Water, Site Specific Impaired Groundwater, or meet the definition of

Unusable Groundwater, all groundwater is designated General Use Groundwater.” The rule

further states in Section 1200-04-03-.08(2), “Except for naturally occurring levels, General Use

Groundwater: (a) shall not contain constituents that exceed those levels specified in Rules 1200-04-

03-.03(1)(j) and (k); and (b) shall contain no other constituents at levels and conditions which pose

8

an unreasonable risk to the public health or the environment.” Therefore, based on the state of

Tennessee’s groundwater classification all aquifers not otherwise characterized are “general use”

and should be maintained for their most stringent use. This general use determination is applicable

to the contaminated surficial aquifer.

Water Supply The drinking water in the area is provided by municipal wells served by Memphis Light Gas and

Water. The closest municipal well field is the Shaw well field located approximately 1 – 2 miles

from the Site.

Remedial Investigation Summary The RI was conducted during 2008 to 2013. The RI identified types, quantities, and locations of

contaminants and the FS developed alternatives to address the contamination. The sampling events

were grouped into phases based on the dates samples were collected.

Phase I Investigation, 2008

Phase II Investigation, 2009

Time Critical Removal Action, 2010 through 2011

Phase III Investigation, 2011



Phase I activities focused on identifying the nature of contamination across five areas of potential

concern. The Phase I investigation identified five areas of potential concern, and confirmed that

VOCs were the contaminants of potential concern. Subsequent phases of the RI (Phase II and Phase

III) were focused investigations which targeted the five areas as follows and illustrated in Figure 3:

Plume A — trichloroethylene (TCE) in groundwater; source of contamination is unknown;

the location is upgradient relative to main SSI operations area Monitoring Well (MW) -7

Plume B — TCE in groundwater; source of contamination is unknown; the location is

upgradient relative to main SSI operations area (MW-1)

Plume C — tetrachloroethene (PCE) and degradation products in soil and groundwater from

former degreaser area at SSI operations area

Plume D — PCE and degradation products, and 1,1,1-trichloroethane (TCA) degradation

products in soil and groundwater underlying ditch east of degreaser building

Plume E — PCE source near former Building 15 concrete foundation pad

Site Conceptual Model The site conceptual model (SCM) identifies three areas on the SSI parcel where chlorinated

solvents appear to have been released (Plume C, Plume D, and Plume E). The sources of

9

contamination depicted in the SCM for Plume A, B1, and B2, have not been identified. Full

characterization of the contamination will be completed in order to fully determine the source of the

contamination.

Plume C is near the former degreaser on the eastern portion of OU2. Deep soil and

groundwater contamination immediately to the east of this plume suggests the possibility of

overland flow of chlorinated solvents along a ditch (Plume D).

Concentrations in groundwater near Plume D are within the same order of magnitude as

concentrations near MW-04 (adjacent to Plume C, near the degreaser). Detected

concentrations along the ditch decrease to the east.

Concentrations in Plume E are slightly lower than at the concentrations associated with

Plumes C and D, and may represent a source area unique to Building SSI-15, although no

soil source has been found.

Figure 3: Site Conceptual Model

10

Nature and Extent of Contamination Groundwater The groundwater collected during Phase I, II, and III investigations indicate the presence of

multiple groundwater contamination plumes. TCE and PCE are the two primary contaminants on

the OU2 property with the daughter products cis-1,2-DCE, 1,1-dichloroethene (1,1-DCE), and vinyl

chloride also present above their federal Maximum Contaminant Levels (MCLs). The MCL is a

federal standard and the maximum permissible level of a contaminant in water which is delivered to

any user of a public water system.

The source of the PCE and TCE groundwater contamination for Plumes C, D, and E results from

the use of both solvents to clean parts onsite. Machined metal parts were cleaned to remove

residual cutting oils using a vapor degreasing unit (degreaser) containing TCE or reclaimed TCE

from 1986 to 2006. The degreaser was attached to a distillation unit used to reclaim spent TCE. The

use of other solvents, including PCE, is documented in the Remedial Investigation Report.

The former degreaser is located in the area of Plume C. Plume C sits along the base of the

structural high observed in the top of the Jackson Clay. This feature has a general north/south

orientation. PCE contamination appears to move to the east and south/southeast away from this

source area.

Movement of the PCE contamination from the degreaser to the east appears to have been influenced

by the WWC, area (Plume D). Historical flooding of the degreaser building also carried

contaminants away from the source (degreaser) to the east along the ditch. The following

summarizes the results from the most recent groundwater sampling events conducted in 2012 and

2013:

PCE

PCE exceeded its MCL (5 ug/L) in five of the nine monitoring wells. Exceedances ranged from

46.4 μg/L in monitoring well MW-5 in the southeastern portion of OU2 to 9,440 μg/L in monitoring

well MW-4 near the former degreaser (Plume C).

TCE

TCE exceeded its MCL (5 ug/L) seven of the nine monitoring wells. Exceedances ranged from

14.5 μg/L in monitoring well SS-GW-02 in the central portion of OU2 to 645 μg/L in monitoring

well MW-7 at the westernmost OU2 property boundary (Plume A).

Cis-1,2-DCE

Cis-1,2-DCE exceeded its MCL (70 ug/L) in two of the nine monitoring wells. Exceedances ranged

from 236 μg/L in monitoring well MW-4 near the former degreaser to 1,240 μg/L in monitoring

well SS-GW-01 in the northwestern portion of OU2 (Plume B2).

1,1-DCE

1,1-DCE exceeded its MCL (7 ug/L) in one of the nine monitoring wells, monitoring well MW-5 at

46.7 μg/L in the southeastern portion of OU2 (downgradient from Plume E).

11

Vinyl chloride

Vinyl chloride did not exceed its MCL (2 ug/L) in any of the onsite monitoring wells during the

August 2013 event. However, vinyl chloride exceeded its MCL in two of the eight monitoring

wells during the August 2012 sampling event. Vinyl chloride was detected at 70 μg/L in

monitoring well MW-1 in the northwestern portion of OU2 (Plume B2) and at 22 μg/L in

monitoring well MW-4 near the former degreaser (Plume C).

Figure 4a. Tetrachloroethene Concentrations in Groundwater

Subsurface Soil Subsurface soil samples were collected from borings advanced using hand auger, direct push

technology (DPT), or Hollow Stem Auger (HSA) sampling techniques between 2008 and 2013.

Subsurface soil contamination is generally attributed to the degreaser source area (Plume C).

Residual subsurface soil contamination is typically encountered at depth of 16 feet bgs on the order

of 1 to 5 mg/kg, with higher concentrations immediately above the water bearing alluvial unit

encountered approximately 20 to 25 feet bgs. Contamination within the degreaser area is present

within the entire soil column. Residual subsurface soil contamination has not been identified on the

Figure 4b. Trichloroethene Detections in Groundwater

12

OU2 property except for the area of VOC-contaminated soil at depth near the former degreaser

associated with Plumes C and D.

An empirical fate and transport evaluation was conducted on the subsurface soil-to-groundwater

pathway. The evaluation indicated that empirically, several constituents exhibit the potential to

leach and migrate between subsurface soil and groundwater. However, the primary constituents

which pose a threat to multiple media are the chlorinated VOCs (CVOCs), as the potential exists for

multiple cross-media transfers between parent products (PCE) and subsequent degradation products

(TCE, cis-1,2-DCE). Therefore, soil screening levels (SSLs) of subsurface contaminants for

protection of groundwater were calculated. The following table represents the calculated SSLs.

Table 1. Soil Screening Levels for Subsurface Soil Protective of Groundwater

Sediment and Surface Water Eight locations were selected in Grays Creek Drainage Canal and in the ditch to the south of the

Cordova Industrial Park for sediment and surface water samples. TCE was detected in three of the

eight sediment samples. All of these detections are in the ditch to the south of the Site.

Concentrations ranged from 0.0018 mg/kg to 0.041 mg/kg. Cis-1,2-DCE was also detected in two

samples at 0.00078 mg/kg (GC03) and 0.0023 mg/kg (GC08).

Surface water samples collected at the same locations as the sediment samples did contain VOCs,

some above water quality criteria. Specifically, TCE exceeded TDEC surface water criteria (25

ug/L) at three locations, ranging from 42 μg/L to 230 μg/L in the ditch south of the industrial park.

PCE exceeded TDEC surface water criteria (6.9 ug/L) in one sample at 15 ug/L.

Time Critical Removal Action After Phase II of the RI, a time-critical removal action (TCRA) was performed in 2010 and 2011

at Anomalies B1 and B2. The objective of TCRA was to excavate contaminated soil and debris

(Anomaly B1) and live pin flares (Anomaly B2) and send offsite for disposal. These anomalies

were identified during a geophysical survey that was conducted during Phase I of the RI. As part of

the Phase I investigation, a geophysical investigation was completed in Screening Area A, the

grassy area south of Building 10. The survey identified five anomalies (L1, Al, B1, B2, and Cl).

Contaminant of Concern Subsurface

Soil Screening

Level

Tetrachloroethane (PCE) 16 ug/kg

Trichloroethane (TCE) 16 ug/kg

cis- 1,2-Dichloroethane (DCE) 226 ug/kg

1,1,1-Trichloroethane 647 ug/kg

1,1-Dichloroethane (DCA) 8 ug/kg

1,1-Dichloroethene (DCE) 23 ug/kg

1,4-Dioxane 2 ug/kg

13

Anomaly B1 was determined to be an area of waste disposal. The debris included stainless steel

pipe and other metals products. Visual and olfactory evidence of contamination was identified as

the trench exposed the waste area. Various metals, SVOCs, and pesticides were detected in soil. A

removal action was recommended to address this waste disposal area. The dimensions of the

excavation at Anomaly B1 were 43 feet by 31 feet by 11 feet. Approximately, 745 tons of soil and

debris were excavated from Anomaly B1. The disturbed area was restored to its original condition

on February 15, 2011.

Anomaly B2 was determined to be buried live pin flares. The pin flares were observed to be in good

condition. One soil sample was collected beneath the flares. SVOCs and pesticides were detected

in soil. A removal action was recommended to address this waste disposal area. The pin flare

removal action was conducted in two phases, at Anomaly B2. The initial phase began December

2010 and the second phase was completed July 2011. The approximate excavation dimensions were

625 square feet by 4 feet. The excavated area was backfilled with sifted soil from the excavation on

August 4, 2011, and restored to original conditions. Based on evidence discovered from the

excavation with the pin flares the labels on the pin flares indicated three lots, with each lot typically

containing 2,500 flares. An approximate 7,500 pin flares were packaged and shipped according to

DOT requirements and transported offsite for disposal.

SCOPE AND ROLE OF PROPOSED REMEDY The response action for OU2 as identified in this Proposed Plan will be an interim action for the

contaminated groundwater at the site. The scope of the proposed remedy is intended to address

only the contaminated subsurface soil and groundwater of Plumes C, D, and E. The results of the

RI indicate that site related COCs exist above MCLs in the area of both Plumes A and B. Plumes A

and B are hydraulically upgradient of the degreaser and Plumes C, D, and E. A determination of

the source of the contamination associated with Plumes A and B could not be made based on the

proximity of the Plumes A and B to the OU2 property boundary. Additional characterization will

be performed in order to determine the origin of the contamination in the areas of Plumes A and B.

Therefore, the alternatives highlighted in this Proposed Plan do not address Plumes A and B.

In addition, the scope of this proposed action addresses contaminated subsurface soil that is present

and can leach into the groundwater. The limited scope of the OU2 action is an interim action to

treat the contaminated groundwater and subsurface soil. The remaining portions of the Site will be

addressed separately under a separate response action that will be selected in future decision

documents. A final remedy to address all the groundwater plumes will be required in the future.

It is the EPA’s current judgment that the Preferred Alternative identified in this Proposed Plan, or

one of the other active measures considered in this Proposed Plan, is necessary to protect public

health or welfare or the environment from actual or threatened releases of hazardous substances into

the environment.

14

SUMMARY OF SITE RISKS As part of the RI, a baseline human health risk assessment (HHRA) and ecological risk

assessment (ERA) were prepared for the OU2 portion of the Site. The risk assessments evaluated

risks to human and ecological populations who may be exposed to chemicals present in the surface

soil, subsurface soil, groundwater, and surface water under current and future conditions. The risk

evaluation involved consideration of the future residential land use scenario, the current land use,

which is industrial, and recreational use. Receptors evaluated included resident, industrial worker,

construction worker, and trespasser.

The risk assessments provide the basis for taking action and identify the contaminants and exposure

pathways that should be addressed by the preferred remedial alternative.

Although, the risks have been quantified for all the contaminated media (subsurface soil,

groundwater, sediment, and surface water, this Proposed Plan will only address unacceptable risks

associated with subsurface soil and groundwater. For detailed information regarding risk, see the

Table: What Is Risk and How Is It Calculated on the following page.

Human Health Risk Assessment (HHRA) The OU2 portion of the Site was evaluated for residential use, industrial site workers,

construction/excavation workers, and recreational scenarios as described in the exposure assessment

given as Section 6.3 of the RI. The results of the HHRA indicate that unacceptable cancer risk for

exposure to groundwater for a future resident (1 x E-2) and a current/future industrial worker (9.69 x

E-4) exists. Chemical concentrations reported in site samples resulted in risk estimates greater than

the EPA acceptable non-cancer risk range or an HQ of 1.0 in groundwater for a future resident (HI

= 642, assuming adult receptor) and for a current/future industrial worker (HI = 179, assuming adult

receptor). Therefore, the contaminants that were identified as significantly contributing to the

unacceptable risks were identified as contaminants of concern.

There is no immediate risk for exposure to contaminated groundwater for future residents and

industrial workers because drinking water for the Cordova area is served by Memphis Light Gas

and Water. Furthermore, the drinking water for the area is provided from the deeper Memphis Sand

Aquifer which is not hydraulically connected to the contaminated fluvial aquifer in the area of

Cordova where the Site is located.

Ecological Risk Assessment (ERA)

An ERA was conducted at the OU2 portion of the Site during the RI activities, in accordance with

the 8-step process “Ecological Risk Assessment Guidance for Superfund: Process for Designing

and Conducting Ecological Risk Assessments”

This section summarizes the results of the ERA. The Screening-Level Ecological Risk Assessment

evaluated potential risk to aquatic plants and invertebrates, and terrestrial and aquatic upper trophic

level receptors from exposure to surface soil, surface water, and sediment associated with OU2. It is

noted that analytical data for surface water and sediment was limited to VOCs, as these were the

contaminants of interest at the Site based on historical investigations. No unacceptable risk was

indicated for aquatic flora and fauna based on comparisons of contaminant concentrations in

15

surface water and sediment to media-specific screening values. No unacceptable risk was indicated

for upper trophic level aquatic receptors (mammals and birds) based on the lack of bioaccumulative

chemicals in surface water and sediment. Finally, no unacceptable site-related risk was indicated for

upper trophic level terrestrial receptors (mammals and birds) based on the refined food web

evaluation.

WHAT IS RISK AND HOW IS IT CALCULATED?

A Superfund human health risk assessment estimates the "baseline risk." This is an estimate of

the likelihood of health problems occurring if no cleanup action were taken at a site. To

estimate the baseline risk at a Superfund site, EPA undertakes a four-step process:

Step 1: Analyze Contamination

Step 2: Estimate Exposure

Step 3: Assess Potential Health Dangers

Step 4: Characterize Site Risk

In Step 1, EPA looks at the concentrations of contaminants found at a site as well as past

scientific studies on the effects these contaminants have had on people (or animals, when

human studies are unavailable). A comparison between site-specific concentrations and health-

based concentrations helps EPA to determine which contaminants are most likely to pose the

greatest threat to human health.

In Step 2, EPA considers the different ways that people might be exposed to the contaminants

identified in Step 1, the concentrations that people might be exposed to, and the potential

frequency and duration of exposure. Using this information, EPA calculates a "reasonable

maximum exposure" (RME) scenario, which portrays the highest level of human exposure that

could reasonably be expected to occur.

In Step 3, EPA uses the information from Step 2 combined with information on the toxicity of

each chemical to assess potential health risks. EPA considers two types of risk: cancer risk and

non-cancer risk. The likelihood of any kind of cancer resulting from a Superfund site is

generally expressed as an upper bound probability; for example, a "1 in 10,000 chance." In

other words, the exposed individual would have an excess cancer risk of one in 10,000 due to

site contaminants. This excess risk would be over and above the existing cancer risk for the

individual. For non-cancer health effects, EPA calculates a "hazard index." The key concept

here is that a "threshold level" (measured usually as a hazard index of less than 1) exists below

which non-cancer health effects are not expected.

In Step 4, EPA determines whether site risks are excessive for people at or near the Superfund

site. The results of the three previous steps are combined, evaluated and summarized. EPA

adds up the potential risks for each receptor.

16

Contaminants of Concern The contaminants of concern (COCs) in groundwater and subsurface soil at the OU2 portion of

the Site are summarized below.

Groundwater: PCE, TCE, cis 1,2- dichloroethene (DCE), 1,1-dichloroethane (DCA), 1,1-

dichloroethene, 1,1,1 - trichloroethane (TCA), and vinyl chloride.

Subsurface Soil: PCE, TCE, cis 1,2- dichloroethene (DCE), 1,1-dichloroethane (DCA), 1,1-

dichloroethene, 1,1,1 - trichloroethane (TCA), and vinyl chloride.

REMEDIAL ACTION OBJECTIVES AND PROPOSED CLEANUP LEVELS

The Remedial Action Objectives (RAOs) for the contaminated subsurface soil and groundwater

developed for this action are as follows:

Prevent human exposure (dermal contact, ingestion, and inhalation) of groundwater that



Prevent lateral migration of contaminated groundwater by removing contaminant mass from

the plume.

Prevent migration of contaminated groundwater discharging to surface water above ambient

surface water quality criteria by removing contaminant mass from the plume.

Minimize threats to the underlying Memphis Sand aquifer by removing contaminant mass

present in the fluvial zone.

Reduce the long-term leachability of contaminants from site subsurface soils into the

groundwater to levels that are protective of drinking water.

The Preferred Alternative will not restore the contaminated groundwater to levels that are protective

for potable use. The groundwater restoration, is an objective for the Site but may not be achieved

solely by the Preferred Alternative presented in the Proposed Plan. Therefore, the Preferred

Alternative is considered to be an interim action, but is necessary to move the Site towards a final

site-wide ROD which will address any residual contamination at the Site and restore groundwater.

The proposed cleanup levels or preliminary remedial goals (PRGs) for contaminated media at the

Site were developed specifically to protect human health and address the unacceptable risks

identified in the HHRA. These goals are based on federal regulatory standards (MCLs), including

Applicable or Relevant and Appropriate Requirements (ARARs), and risk based levels

established in the HHRA.

17

PRGs for groundwater are based on the MCL established under the Safe Drinking Water Act. In

the absence of a MCL, the groundwater PRG was calculated from the HHRA based on a total HI

greater than 1, or a cumulative excess lifetime cancer risk greater than 1x10-6. PRGs were selected

that would both reduce the risk associated with exposure to groundwater contaminants to an

acceptable level, and ensure minimal migration of contaminants into the groundwater. The

proposed cleanup levels for subsurface soil and groundwater COCs are summarized in Table 2.

Table 2. Proposed Subsurface Soil and Groundwater Cleanup Levels

DESCRIPTION OF REMEDIAL ALTERNATIVES

Below is a summary and brief description of the remedial alternatives evaluated in the FS document

for the OU2 portion of the Site. The FS evaluated remedial technologies from a technical,

environmental, and cost-effectiveness perspective. The FS also provided for each alternative

(where possible) the estimated time for implementation, capital costs, total operation &

maintenance (O&M) costs over the life of the cleanup, and total present worth costs. Where

applicable, the total present worth was developed for a period of 30 years with a discount rate of

approximately 4 percent. For a “Detailed Analysis of Alternatives” please refer to the FS

document.

The five alternatives (which include No Action and a four treatment alternatives) were developed

for subsurface soil and groundwater. Each onsite remedy is composed of one or more primary

(active) remedies and one or more remedy support operation(s). The common support elements are

discussed in detail below.

Contaminant of Concern Proposed

Subsurface Soil

Cleanup Levels*

Proposed

Groundwater Cleanup

Levels**

Tetrachloroethene (PCE) 16 ug/kg 5 ug/L

Trichloroethene (TCE) 16 ug/kg 5 ug/L

cis- 1,2-Dichloroethene (DCE) 226 ug/kg 70 ug/L

Vinyl chloride 647 ug/kg 2 ug/L

1,1,1-Trichloroethane 8 ug/kg 200 ug/L

1,1-Dichloroethane (DCA) 23 ug/kg 2.4 ug/L

1,1-Dichloroethene (DCE) 2 ug/kg 7 ug/L

1,4 - Dioxane 16 ug/kg 0.67 ug/L

*Soil Screening Levels (SSLs) for Subsurface Soil Protective of Groundwater

**Federal Drinking water standards (MCLs)

18

Common Elements to Alternatives

Applicable or Relevant and Appropriate Requirements (ARARs) Chemical-specific ARARs include Safe Drinking Water Act MCLs for COCs and serve as the basis





However, the proposed alternatives will not be able to achieve the chemical-specific ARARs

(MCLs) for TCE, PCE, cis- 1,2-DCE, 1,1-DCE, and vinyl chloride, which are the basis for

groundwater cleanup levels, and therefore are waived under CERCLA 121(d)(4)(A). The remedial

action to be implemented for OU2 is an interim action that is only part of the total remedial action

for the contaminated groundwater at the Site which will attain such levels when completed.

Institutional Controls All of the remedies will require institutional controls (ICs) 1) to restrict future land use to

industrial/commercial; 2) to limit disturbance on portions of the property; and 3) to ensure that the

groundwater from the contaminated surficial aquifer is not used for drinking water purposes until

unlimited use conditions are achieved or there are no unacceptable risks associated with the Site.

The type of restriction and enforceability of the institutional control will need to be determined for

the selected remedy in the ROD. Consistent with expectations set out in the Superfund regulations,

none of the remedies rely exclusively on ICs to achieve protectiveness. ICs are a component of

each alternative except the “no action” alternative.


not used for drinking water purposes until unlimited use conditions are achieved or there are no

unacceptable risks associated with the Site,” an existing legal control exists in Shelby County that

may prevent the use of the contaminated groundwater in the surficial aquifer. In accordance with

Section 4.01(C) of Rules and Regulations of Wells in Shelby County, which states “A water well

cannot be sited or placed in service within a half-mile of the designated boundaries of a listed

federal or State Superfund site or Resource Conservation and Recovery Act corrective action site,

unless the well owner can make a demonstration that the well will not enhance the movement of

contaminated groundwater or materials into the shallow or deep aquifer.” The Shelby County legal

control may offer some protection from installation of wells within a half-mile of the Site but

ultimately to ensure protectiveness an institutional (proprietary) control will be necessary on

properties that the plume has migrated until the surficial aquifer has been restored to its beneficial

use.

19

Long Term Monitoring Each remedial alternative includes long-term monitoring (LTM) of the groundwater. LTM of the

groundwater for site related COCs and monitored natural attenuation (MNA) parameters will

help determine whether MNA will be a viable long-term remedial alternative as a final action

following the interim action. LTM of the surface water will also be included as a component of this

interim action. The groundwater-to-surface water pathway is considered a valid pathway for

contaminant migration. Continued sampling of the groundwater at the surface water interface will

be necessary for establishing the expected rate of change of the concentration, the groundwater

velocity and a data set for an MNA evaluation. A sampling program designed to monitor the

groundwater concentration before it enters Grey’s Creek and the adjacent surface water

concentration will be included in the LTM program.

Vapor Intrusion (VI) evaluation and a monitoring program will be included as a remedial

component to assess the vapor intrusion pathway in the buildings. Protocol for performing baseline

sampling of building slabs near Plumes C, D, and E, as well as baseline indoor air sampling, and a

schedule for periodic indoor air sampling events will also be carried forward into each remedial

alternative.

Five Year Reviews will be required as a part of an ongoing remedial action until the final remedy is

in place. Section 121 of CERCLA, as amended by SARA, requires that remedial actions which

result in any hazardous substances, pollutants, or contaminants remaining at the site be subject to a

five-year review. The NCP further provides that remedial actions which result in any hazardous

substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited

use and unrestricted exposure be reviewed every five years to ensure protection of human health

and the environment.

The Five-Year Review requirement applies to all remedial actions selected under CERCLA §121.

Therefore, sites with CERCLA remedial actions may be subject to a five-year review. Consistent

with Executive Order 12580, other Federal agencies are responsible for ensuring that five-year

reviews are conducted at sites where five-year reviews are required or appropriate. Five-year

reviews would be completed to assess ongoing protectiveness; five-year reviews are reliable

mechanisms to assess site status.

Alternative 1: No Action Estimated Cost: $0

The no remedial action scenario is required under NCP as a reference scenario against which other

remedial alternatives can be compared. It allows evaluation of future adverse environmental

impacts and risk/hazard resulting from not taking an action to address the existing contamination at

OU2. Under this alternative no action would be taken to address the subsurface soil and

groundwater contamination, as such contaminated groundwater would continue to migrate and pose

unacceptable risks to human health and the environment. This alternative achieves none of the

RAOs developed for OU2 because no remedial actions are implemented.

20

Figure 5. Areas that Require Treatment

21

Alternative 2: In-Situ Treatment of Groundwater and Subsurface Soil at Plume C, D, and E,

Long-term Monitoring and Institutional Controls Estimated Capital Cost: $2,700,000


Estimated Present Worth Cost: $4,000,000* *Net present worth is based on 30 years


Estimated Timeframe to achieve cleanup levels and RAOs: 2 -3 years to achieve RAOs

In this alternative engineered amendments would be injected into the shallow surficial aquifer in

Plumes C, D and E as depicted in Figure 5. Injections would be implemented and optimized for

mass removal of contaminants. The remedial design would evaluate DPT versus continuous

injections, top-down versus bottom up, injection substrates, and establish performance metrics. In-

situ Bioremediation (ISB) and In-situ Chemical Reduction (ISCR) would be integrated as

appropriate and as determined during the remedial design as a means of destroying CVOC

contaminant mass that is a source of ongoing groundwater contamination. ISB is commonly

applied technology that degrades target compounds by naturally-occurring bacteria in soil and

groundwater. In the case of CVOCs, this is usually by reductive metabolic pathways enhanced by

adding carbon substrate and amendments (e.g., nutrients). ISCR is a reductive dechlorination

process that treats organic contaminants in groundwater. A reactive liquid or solid is delivered to

the water-bearing zone, most commonly via DPT injections, and the material quickly reacts with

contaminants. The hydrogen for the reaction is provided by a reductant. A widely used reductant is

zero valent iron (ZVI). When ZVI is emplaced in an aquifer, it corrodes, and the resulting

geochemical reactions catalyze and promote rapid CVOC destruction (much quicker than biological

reactions).

Following remedial design activities to refine design parameters in each area/plume, multiple

injections would occur in a phased sequence over several years. The source areas would be

monitored, and each sequential injection and would be optimized in response to performance data

collected.

Field optimization will involve collection of VOC and geochemical data from the contaminated

areas. The data would then be used to optimize the injection protocol and to determine if follow-up

injections were required to enhance mass removal. For Alternative 2, up to three injections have

been estimated for costing purposes, but the actual number of injections would be determined based

on the results from the design phase and additional sampling of monitoring wells in Plumes C, D

and E to refine treatment areas and post-injection performance monitoring, with the goal of

removing as much mass as practicable from Plumes C, D, and E.


LTM of the surface water will also be included as a component of this interim action. VI

evaluations/monitoring would be performed to assess the VI pathway. ICs would be implemented

to prevent groundwater use and restrict property for industrial use over the long term. Five Year


22

Remedial activities would need to comply with Underground Injection Control (UIC) permitting




Alternative 3: Limited Injections/In-Situ Treatment of Groundwater and Subsurface Soil at

Plumes C, D, and E, with Monitoring Natural Attenuation (MNA) and Institutional Controls Estimated Capital Cost: $1,600,000




Estimated Timeframe to achieve cleanup levels and RAOs: 2-3 years to achieve RAOs

Engineered amendments would be identical to those described in Alternative 2, however this

alternative considers the potential that field limitations (e.g., substrate delivery, heterogeneity, back

diffusion) may constrain the expected effectiveness of follow-on injections. Treatment would be

suspended once optimization indicated that mass removal efforts were no longer effective. Initial

injections would be based on results from the design phase and additional sampling of monitoring

wells in Plumes C, D, and E to refine treatment.

Data would be used to develop a long-term MNA protocol for OU2, with the assumption that MNA

would continue based on (a) residual substrates injected at the source, and (b) positive findings of

the predesign MNA evaluation. One injection has been estimated for costing purposes, but the

actual number of injections will be determined based on field results.

MNA evaluations would include on- and offsite sampling for geochemical parameters.

Conceptually, for costing purposes, this assumes a 14-well network (up to 6 wells in the source

areas, and up to 8 additional wells selected during predesign from the east/southeast quadrant

downgradient of Plumes C, D, and E). LTM of the groundwater for VOCs and MNA parameters

are included as a remedial component. VI evaluations/monitoring would be performed to assess the

VI pathway. ICs would be implemented to prevent groundwater use and restrict property for

industrial use over the long term. Five Year Reviews will be required as a part of an ongoing

remedial action until the final remedy is in place.

Similar to Alternative 3, remedial activities would need to comply with UIC permitting




23

Alternative 4: Phytoremediation of Groundwater and Subsurface Soil at Plumes C, D, and E with

Long Term Monitoring and Institutional Controls Estimated Capital Cost: $1,800,000



Estimated Construction Timeframe: 3-6 months to plant trees

Estimated Timeframe to achieve cleanup levels and RAOs: up to five years to monitor phytoremediation

network and achieve RAOs

This alternative includes installation of an engineered phytoremediation network to remove and

degrade VOCs in soil and groundwater. Trees are installed within the footprints of Plume C, Plume

D, and Plume E to remove contaminants as shown in Figure 5. To successfully remove

contaminants from groundwater, tree roots must extend far enough to physically reach the

contaminants. At Plume C and Plume D, the saturated zone is 16 to 30 feet bgs. There is also

limited soil contamination that extends upward from the top of the aquifer approximately 4 to 12

feet. At Plume E, the saturated zone is approximately 22 to 45 feet bgs.

Patented technologies exist that promote aggressive root development to depths up to 30 feet or



planting the selected tree species. Trees can be planted in grids with spacing from 10 to 20 feet,

with alternating targeted root depths to fully intercept contaminant distribution in the aquifer.

Similarly, trees can be planted in trenches to achieve desired depths. Construction techniques given

the semi-confined alluvial aquifer will need to be refined during RD.


maturity, and during that time will be sensitive to external stressors such as weather extremes,

drought, etc. Monitoring will assess the stand’s health over the first several years. The actual

duration of monitoring would be determined during RD/RA work planning.


Installation of the phytoremediation network, as well as ancillary support structures (e.g.,

irrigation system). Preliminary treatment areas and planting densities, which would be

resolved during predesign. The approximate treatment areas are:

Plume C — 9,900 square feet (roughly 90 feet by 110 feet) will require approximately 100

trees

Plume D — 12,800 square feet (roughly 80 feet by 160 feet) will require approximately 130

trees

24

Plume E — 10,000 square feet (roughly 50 feet by 200 feet will require approximately 100

trees




to prevent groundwater use and restrict property for industrial use over the long term and ensure

that the remedy is not compromised. Five Year Reviews will be required as a part of an ongoing

remedial action until the final remedy is in place.

Phytoremediation offers a multi-component treatment approach (mass removal, hydraulic control,

and reduced infiltration) can be designed to accelerate compliance with ARARs, relative to natural

attenuation processes. Remedial activities would need to comply with local ARARs associated with

well permitting since the trees would be installed similarly to monitoring well installation. Any


accordance with appropriate hazardous and solid waste regulations.

Alternative 5: Combination of In-Situ Treatment of Groundwater and Subsurface Soil at Plumes

C, D, and E and Phytoremediation, Long-term Monitoring and Institutional Controls and

Phytoremediation Estimated Capital Cost: $2,500,000


Estimated Present Worth Cost: $4,200,000 *Net present worth is based on 30 years

Estimated Construction Timeframe: 3-6 months to plant trees and 6-12 month for injection(s)

Estimated Timeframe to achieve cleanup levels and RAOs: up to five years to monitor phytoremediation

network and achieve RAOs

Alternative 5 includes components of the in-situ and phytoremediation alternatives. In this

alternative active in-situ treatment of groundwater and soil remediation at Plumes C, D, and E as

shown in Figure 5. Injections of engineered substrates would be identical to those described in

Alternative 2, however this alternative is designed to provide a single, one-time mass reduction

event in the treatment area. Any residuals not affected during injections would then be treated as

groundwater flows through a phytoremediation system located immediately downgradient of each

treatment zone. Phytoremediation would function as a long-term barrier treatment option for plumes

emanating from Plumes C, D, and E. LTM associated with phytoremediation plots are comparable

to those identified in Alternative 4.

A combination of an injection/barrier treatment approach achieves mass removal and reduces mass

flux of OU2 over the long term. High concentration effects on trees are minimized due to treatment

as well as their placement at the downgradient edge of the plume areas.


1. The one-time injection from the design phase and additional sampling of monitoring wells

in Plumes C, D and E to refine treatment areas and install additional monitoring locations. In

25

this scenario, no follow-up injections would be performed in favor of the phytoremediation

installation.

2. Phytoremediation would be installed downgradient of the contaminated zones near the SSI

property line, roughly 200 feet long by 50 feet wide in each location.

The plantings would require more aggressive monitoring during the first several years to ensure

growth, consistent with Alternative 4. A long timeframe for the phytoremediation effectiveness can

be expected (tree lifespan should be 20 to 30 years) and will thus be a lasting barrier to contaminant

migration away from the contaminated zones, even if remedial objectives are not met at the

treatment areas immediately after injections.




to prevent groundwater use and restrict property for industrial use over the long term. Five Year


A multi-component treatment approach using both injections and phytoremediation (which

incorporates treatment, hydraulic control, and reduced infiltration) would be designed to accelerate

compliance with ARARs relative to natural attenuation processes. Alternative 5 meets EPA’s

programmatic preference for sustainable remediation. Remedial activities would need to comply

with UIC permitting requirements, as well as local ARARs associated with well permitting. Any


accordance with appropriate hazardous and solid waste regulations.

26

COMPARATIVE ANALYSIS OF ALTERNATIVES This section presents a comparative analysis of

the remedial alternatives based on the threshold

and balancing evaluation criteria. The objective

of this section is to compare and contrast the

remedial alternatives in order to select a

preferred alternative. The first two criteria, the

threshold criteria are requirements that each

alternative must meet in order to be further

considered in the evaluation. The next five

criteria are the primary balancing criteria and

are used to weigh major trade-offs among

alternatives.

Overall Protection of Human Health and the Environment In theory, protection of human health and the

environment is best achieved by removal of

contaminant mass from a CERCLA site. The

next best remedial strategy for protection of

health and environment is treatment to remove

and degrade contaminants, which is a form of

removal for many organic contaminants.

Assuming in-situ treatment and

phytoremediation are effective at destroying

contaminants in subsurface soil and

groundwater, Alternatives 2, 3, 4, and 5 would

be protective because it eliminates

contaminants from media at

OU2. Furthermore, in the short term there is no

immediate risk to human health and the

environment because drinking water is

available.

Compliance with ARARs Remedial alternatives’ compliance with ARARs

is the most challenging criterion to evaluate

because of the number and multiple types of

ARARs that can apply to a site. In general,

chemical-specific ARARS can be met most

effectively by removing (as by excavation) or

reducing (as by treatment) contaminant mass

from a site. Treatment occurs in subsurface soil

and groundwater in Alternatives 2, 3, 4, and 5.

EVALUATION CRITERIA FOR SUPERFUND

REMEDIAL ALTERNATIVES

Overall Protectiveness of Human Health and the

Environment determines whether an alternative

eliminates, reduces, or controls threats to public health

and the environment through institutional controls,

engineering controls, or treatment.

Compliance with ARARs evaluates whether the

alternative meets Federal and State environmental

statutes, regulations, and other requirements that

pertain to the site, or whether a waiver is justified.

Long-term Effectiveness and Permanence considers

the ability of an alternative to maintain protection of

human health and the environment over time.

Reduction of Toxicity, Mobility, or Volume of

Contaminants through Treatment evaluates an

alternative's use of treatment to reduce the harmful

effects of principal contaminants, their ability to move

in the environment, and the amount of contamination

present.

Short-term Effectiveness considers the length of time

needed to implement an alternative and the risks the

alternative poses to workers, residents, and the

environment during implementation.

Implementability considers the technical and

administrative feasibility of implementing the

alternative, including factors such as the relative

availability of goods and services.

Cost includes estimated capital and annual operations

and maintenance costs, as well as present worth cost.

Present worth cost is the total cost of an alternative

over time in terms of today's dollar value. Cost

estimates are expected to be accurate within a range of

+50 to -30 percent.

S State Acceptance considers whether the State agrees

with the EPA's analyses and recommendations, as

described in the RI/FFS and Proposed Plan.

Community Acceptance considers whether the local

community agrees with EPA's analyses and preferred

alternative. Comments received on the Proposed Plan

are an important indicator of community acceptance.

27

The alternatives vary in terms of implementation aggressiveness (with Alternative 2 and Alternative

5 being relatively more aggressive, and Alternative 3 being the least aggressive).






However, the proposed alternatives will not be able to achieve the chemical-specific ARARs

(MCLs) for TCE, PCE, cis- 1,2-DCE, 1,1-DCE, and vinyl chloride, which are the basis for

groundwater cleanup levels, and therefore are waived under CERCLA 121(d)(4)(A). The remedial

action to be implemented for OU2 is an interim action that is only part of the total remedial action

for the contaminated groundwater at the Site which will attain such levels when completed.

For all alternatives except Alternative 1, remedial activities can be implemented so that they would

comply with local action-specific ARARs associated with well permitting. Any wastes generated

onsite during remedial activities would be characterized and managed in accordance with

appropriate hazardous and solid waste regulations. Additionally, Alternative 2, Alternative 3, and

Alternative 5 would need to comply with UIC permitting requirements, which are managed at both

the state and county level. Alternative 4 and Alternative 5 meet EPA’s programmatic preference for

green remediation. Action-specific criteria relate to limitations or parameters by which a particular

remedial action is to be implemented. As such, all four treatment alternatives would achieve their

specific action-specific criteria to the same degree.

Long-Term Effectiveness and Permanence Alternatives that physically remove contaminants from the site media provide the most protection

for the longest period of time (i.e., site contaminants do not return to the site after remediation is

complete). Alternatives 2, 3, 4, and 5 all rely on treatment to achieve RAOs over the long term, and

use ICs to prevent exposures to CVOCs. ICs would restrict property use and ensure that the site

remedy is not disturbed; annual site evaluations (monitoring) of the ICs to determine whether ICs

are reliable controls will be conducted. The LTM program would assess treatment effectiveness and

groundwater plume status on a periodic basis. Data would be used to detect changes in plume

conditions, determine the need for remedy modifications (if any), and make recommendations for

changes in monitoring; Inspections and monitoring can also be used to determine whether

replanting is required for the phytoremediation remedies (Alternatives 4 and 5). Five-year reviews

would be completed to assess ongoing protectiveness; five-year reviews are reliable mechanisms to

assess site status.

Risk at OU2 is minimal because the alluvial aquifer is not being used, because drinking water is

available. In addition, RI studies indicated that the Jackson Clay is competent beneath OU2, and

protects the underlying Memphis Sand aquifer. Therefore, the overall risk of vertical migration of

contaminants from the alluvial aquifer into the Memphis sand is negligible. Alternatives 2, 3, 4,

and 5 use active remedial measures to treat the groundwater plumes, and all are expected to

effectively reduce the magnitude of residual risk due to residual mass to very low and certainly

28

protective level. VI may be a concern near Plumes C, D and E, given subsurface contamination.

Alternatives 2, 3, 4, and 5 address future VI potential through evaluation of VI.

Reduction of Toxicity, Mobility or Volume through Treatment (T/M/V) Alternative 1 does not provide any reduction in toxicity, mobility, or volume. Alternatives 2, 3, 4,

and 5 use treatment as a primary remedy activity for subsurface soil and groundwater. Alternatives

2, 3, 5 use injections for mass removal: biotic and abiotic processes would be irreversible. However,

Alternative 3 proposes MNA as a follow-on to injections, and MNA has not been confirmed to be

effective at the OU2 site at this time; further studies are necessary in order to verify that attenuation

is occurring and multiple lines of evidence verify that MNA is occurring .

Alternatives 4 and 5 use phytoremediation to remove CVOCs through evapotranspiration and biotic

means, and also exert control over infiltration/groundwater hydraulics. Phytoremediation techniques

would be more tolerant of lithologic heterogeneity than the injections, although the reduction in

volume of mass may not be materially affected in any case; in Alternative 5, combining treatment

with injections with phyto-treatment may be just as effective as the multiple injections that

comprise Alternative 2.

Short-Term Effectiveness The short-term effectiveness of remedial alternatives relates to how well human health and the

environment are protected (the first threshold criterion) and how well the remedial action attains

ARARs (the second threshold criterion) during implementation. The No Action alternative is the

best approach for minimizing added exposure or risk to receptors in the short-term. The

effectiveness of remedial actions at ensuring short-term protection during implementation of a

remedial action depends on the care and attention to detail exhibited by the remediation personnel.

In some cases, implementation of the alternative could temporarily increase risk and exposure

pathways to receptors.

The risk of exposure to site workers and community impacts are minimal for all alternatives. The

environmental impacts are negligible, and worker protection and community monitoring protocols

defined during remedial design and health and safety planning would be sufficiently protective.

There is no significant difference among alternatives regarding this criterion. Physical hazards

associated with the deep emplacement of tree roots are manageable.

The interim treatment actions implemented by Alternatives 2, 3, 4, and 5 would all significantly

accelerate achieving RAOs relative to the no action alternative. The expected time to achieve the

RAOs varies by alternative. Alternatives 2, 3, 4, and 5 would achieve some degree of treatment

within a few years after injections. Alternatives 4 and 5 would require approximately 5 years to

develop a mature stand of trees, but would be partially effective in the interim, and possibly more

effective relative to injection because it would provide hydraulic control. Alternative 2 is the most

aggressive in terms of contemplated treatment area injections, effectiveness in preventing offsite

migration of contaminants may not differ significantly from the other alternatives. The time to

achieve RAOs is expected to be slowest for Alternative 3, given that the other alternatives are either

more aggressive in terms of injection or more active in terms of preventing migration.

29

Implementability Implementing remedial alternatives involves design, planning, construction or installation, and

operation of the various mechanical and human components of remedial actions. The efficiency

with which an alternative can be installed and operated impacts how well an alternative achieves its

level of protection (the first threshold criterion) and attains ARARs (the second threshold criterion).

The No Action Alternative is the simplest alternative to implement.

Alternative 1, no action, can be implemented immediately. It is the simplest and quickest to

implement, but it takes the longest time to achieve remedial objectives. Technically, it never

achieves remedial objectives; therefore, the time to achieve them is too long to quantify.

Alternatives 2, 3, and 5 would require UIC permits for injection of substrates within the target

zones; injection vendors and substrates, however, are readily available. Multiple injections are

expected to be required for injection Alternative 2.

Alternatives 4 and 5 may require proprietary phytoremediation installation techniques that involve

excavation to emplace tree roots in close proximity to the target depth of treatment; alternative

techniques would be explored during remedial design. Installation to the top of the alluvial aquifer

carriers a finite but manageable risk of encountering difficult subsurface conditions (e.g., running

sands). This risk would be minimized through careful remedial design and construction techniques.

The phytoremediation remedies would require an extended period (approximately 5 years) to

achieve maturity and maximum effect. Also during that time, the trees would be relatively more

sensitive to external stressors such as weather extremes, drought, etc. These uncertainties in

technology application can be managed and additional trees can be planted as needed based on

inspections of the tree stands.

Cost Alternatives 2 and 5 would incur the most upfront capital costs ($2.7M and $2.5M, respectively).

Similarly, the capital costs associated with Alternatives 3 and 4 are very close ($1.6M and $1.8M,

respectively). The LTM costs are all based on a 30 year monitoring period and range from $1.5M

to $1.9M which is approximately $58,000 annually in monitoring costs. The following table

provides a summary of the net present worth of each of the remedial alternatives. A detailed

breakdown of remedial costs and cost assumptions are included in Appendix E of the FS.

Table 3. Comparative Cost Analysis of Remedial Alternatives

Alternative Description Cost

1 No Action $0

2 In-situ Treatment (ISB or ISCR) $4.0M

3 Limited In-situ Treatment (ISB or ISCR) with MNA $3.3M

4 Phytoremediation $3.4M

5 Combination of In-situ Treatment (ISB or ISCR) and

Phytoremediation

$4.2M

30

All alternatives would require relatively long-term costs associated with developing agreements and

covenants in order to implement treatment areas. There are costs associated with implementation

and monitoring of the institutional controls, minimal costs for access barriers (e.g., fencing and

signage), and laboratory charges with sampling and analysis of media downgradient of treatment

areas. Laboratory charges on a per-sample basis are difficult to quantify without specific sampling

and analysis plan.

Overall the total costs are similar for each of the alternatives with a difference of approximately

$700,000 among the four of alternatives

The final two evaluation criteria are the modifying criteria. The modifying criteria (State and

Community Acceptance) can only be fully considered after the public comment period has ended.

The final balancing of tradeoffs between the alternatives allows for equal importance of the

balancing and modifying criteria when selecting the remedy in the ROD. A Detailed Description of

the nine evaluation criteria is given on the left side of page 25.

State/Support Agency Acceptance TDEC supports the Preferred Alternative.

Community Acceptance Community acceptance of the preferred alternative will be evaluated after the comment period ends

and will be discussed in the ROD.

31

PREFERRED REMEDIAL ALTERNATIVE Alternative 4, Phytoremediation of the groundwater and subsurface soil is recommended as the

preferred remedial alternative for OU2. This alternative is recommended because it will achieve

a substantial risk reduction by treating the groundwater and subsurface soil and achieve the

RAOs. Alternative 4 also provides protection of human health and the environment, reduction of

toxicity/mobility/volume through treatment and short-term effectiveness. Costs associated with

this alternative are moderate. Phytoremediation is a sustainable alternative to remediating the

contamination. An evaluation of all the alternatives indicated that Phytoremediation is consistent

with the Superfund Green Remediation Strategy. Phytoremediation will reduce the overall

environmental footprint. Furthermore, Phytoremediation supports the Five Principles of Greener

Cleanups.

Minimize Total Energy Use

Minimize Air Pollutants and Greenhouse Gas Emissions

Minimize Water Use and Impacts to Water Resources

Reduce, Reuse, and Recycle Material and Waste

Protect Land and Ecosystems

Based on information currently available, the EPA believes the preferred alternative meets the

threshold criteria and provides the best balance of tradeoffs among the other alternatives with the

respect to the balancing and modifying criteria. The EPA expects the Preferred Alternative to satisfy

the following statutory requirements of CERCLA 121(b): (1) be protective of human health and the

environment; (2) be cost effective; (3) utilize permanent solutions and alternative treatment

technologies or resource recovery technologies to the maximum extent practicable; and (5) satisfy the

preference for treatment as a principal element. TDEC supports the preferred alternative. The

preferred alternative is based on current information; therefore, the selected alternative can change in

response to public comment or new information in the final ROD.

Description of Alternative

This alternative represents installation of an engineered phytoremediation network that would

remove and degrade VOCs in soil and groundwater. Trees would be installed within the footprint

of Plume C, Plume D, and Plume E. The dechlorination of the CVOCs occurs in both the root

zone and in the leaves. Most of the absorbed VOCs will be transferred in the water up to the

leaves through the xylem (the primary vascular tissue of trees). Patented technologies exist that promote aggressive root development to depths up to 30 feet or


desired, inserting a sleeve or liner to direct root growth, then backfilling the borehole with soil

and planting the selected tree species. Within Plumes C and D, the saturated zone is 16 to 30 feet

bgs and the soil contamination extends upward from the top of the aquifer approximately 4 to 12

feet. Within Plume E, the saturated zone is 22 to 45 feet bgs. Trees can be planted in grids with

spacing from 10 to 20 feet, with alternating targeted root depths to fully intercept contaminant

distribution in the aquifer. Similarly, trees may also be planted in trenches to achieve desired

depths. Construction techniques given the semi-confined alluvial aquifer will need to be refined

during design.

32

The phytoremediation remedy would require an extended period (approximately 5 years) to

achieve maturity, and during that time the phytoremediation network will be sensitive to external

stressors such as weather extremes, drought, etc. Monitoring will assess the stand’s health over

the first several years. The actual duration of monitoring would be determined during RD/RA

work planning.


Installation of the phytoremediation network, as well as ancillary support structures (e.g.,

irrigation system). Preliminary treatment areas and planting densities, which would be

resolved during predesign. The approximate treatment areas are described as:



evaluations/monitoring would be performed to assess the VI pathway. ICs would be

implemented to prevent groundwater use and restrict property for industrial use over the long

term. Five Year Reviews will be required as a part of an ongoing remedial action until the final

remedy is in place.

Plume C — 9,900 square feet (roughly 90 feet by 110 feet) will require approximately

100 trees

Plume D — 12,800 square feet (roughly 80 feet by 160 feet) will require approximately

130 trees

Plume E — 10,000 square feet (roughly 50 feet by 200 feet will require approximately

100 trees

33

Glossary of Terms

Agreement and Order on Consent (AOC): It is generally a voluntary agreement worked out

between two or more parties to a dispute.

Administrative Record (AR): Material documenting EPA’s selection of cleanup remedies at

Superfund sites, usually placed in the Information Repository near the site.

Applicable or Relevant and Appropriate Requirements (ARARs): Refers to federal and state

requirements a selected remedy must attain which vary from site to site.

Chlorinated Volatile Organic Compounds (CVOCs): Chlorinated chemical compounds that

contain carbon and evaporate at relatively low temperatures.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or

Superfund): A federal law passed in 1980 and amended in 1986 by the Superfund Amendments

and Reauthorization Act (SARA); the Act created a trust fund, known as Superfund, to

investigate and cleanup abandoned or uncontrolled hazardous waste sites.

Contaminants of Concern (COCs): Constituents associated with a site which has been released

into the environment.

Direct Push Technology (DPT): Category of equipment that push or drive steel rods into the

ground. They allow cost-effective, rapid sampling and data collection from unconsolidated soils

and sediments.

Expanded Site Inspection (ESI): Collection of additional samples from contaminated media

necessary to document a Hazard Ranking Score.

Feasibility Study (FS): Study conducted after the Remedial Investigation to determine what

alternatives or technologies could be applicable to address the site specific COCs.

Hollow Stem Auger (HSA): Drilling method uses a series of continuously flighted augers that

are, as the name implies, hollow. The augers are made by welding the flights around steel pipe of

varying diameters (depending on what size auger is desired).

Human Health or Ecological Risk Assessment (HHRA or ERA): A qualitative and

quantitative evaluation performed in an effort to define the risk posed to human health and the

environment and ecological receptors by the presence or potential presence and use of specific

pollutants.

Information Repository: A library or other location where documents and data related to a

Superfund project are placed to allow the public access to the material.

34

Glossary of Terms (continued)

Institutional Controls (ICs): EPA defines ICs as non-engineered instruments, such as

administrative and/or legal controls, that help to minimize the potential for human exposure to

contamination and/or protect the integrity of a remedy. ICs work by limiting land or resource

use and/or by providing information that helps modify or guide human behavior at the site.

Examples of ICs include zoning restrictions, well drilling prohibitions, easements, and

covenants. Engineered controls or physical barriers, such as fences, are not considered ICs by

EPA.

In-Situ Bioremediation (ISB): Remediation technology that degrades target compounds by

naturally occurring bacteria in and groundwater.

In-Situ Chemical Reduction: Reductive dechlorination process that treats organic contaminants

in groundwater.

Long-Term Monitoring: Monitoring of groundwater conditions within defined geologic

environments that can be used to evaluate contaminant trends and geochemical conditions.

Maximum Contaminant Level (MCL): Maximum permissible level of a contaminant in water

which is delivered to any user of a public water system.

Milligram per kilogram (mg/kg): One part per million or defined as ppm.

Microgram per liter (µg/L): One part per billion or defined as ppb.

Monitored Natural Attenuation: Natural attenuation relies on natural processes to decrease or

“attenuate” concentrations of contaminants in soil and groundwater.

Nanograms per liter (ng/L): One part per trillion or defined as ppt.

National Oil and Hazardous Substances Pollution Contingency Plan (NCP): The federal

regulation that guides the Superfund program.

Operable Units (OUs): Different phases or areas of a Remediation Project. Often a Superfund

Site is divided in phases or areas to better address different pathways and areas of contamination.

Operation and Maintenance (O&M): Activities conducted at sites after cleanup remedies have

been constructed to ensure that they are properly functioning.

Parts per billion: One part of solute per one billion parts solvent.

Polynuclear aromatic hydrocarbons (PAHs): Organic compounds containing only carbon and

hydrogen that are composed of multiple aromatic rings in which the electrons are delocalized).

http://en.wikipedia.org/wiki/Organic_compound

http://en.wikipedia.org/wiki/Aromatic_ring

http://en.wikipedia.org/wiki/Delocalization

35


Preliminary Assessment (PA): A review of existing information and an off-site reconnaissance,

if appropriate, to determine if a release may require additional investigation or action.

Preliminary Remedial Goal (PRG): Initial cleanup goals that are (1) protective of human

health and the environment and (2) comply with ARARs. PRGS are developed as a result of the

risk assessments and are used during the analysis of remedial alternatives in the RI/FS phase.

Proposed Plan: Superfund document prepared to promote public participation which

summarizes the preferred remedial alternative, the rationale, and the results of the RI/FS.

Resource Conservation and Recovery Act (RCRA): The Federal act that established a

regulatory system to track hazardous wastes from the time they are generated to their final

disposal. TCRA also provides for safe hazardous waste management practices and imposes

standards for transporting, treating, storing, and disposing of hazardous waste.

Record of Decision (ROD): A public document describing EPA’s rationale for selection of a

Superfund cleanup alternative.

Remedial Action Objectives: Cleanup objectives that specify the level of cleanup, area of

cleanup (area of attainment), and time required to achieve cleanup (restoration time frame).

Remedial Investigation (RI): Part one of a two-part investigation conducted to fully assess the

nature and extent of the release, or threat of release, of hazardous substances, pollutants, or

contaminants, and to identify alternatives for cleanup. The Remedial Investigation gathers the

necessary data to support the corresponding Feasibility Study.

Responsiveness Summary: A summary of oral and written comments received by EPA during a

comment period on key EPA documents and EPA’s responses to those comments. The

Responsiveness Summary is a key part of the ROD, highlighting community concerns for EPA

decision-makers.

Semi-volatile Organic Compounds: An organic compound which has a boiling point higher

than water and which may vaporize when exposed to temperatures above room temperature.

Semivolatile organic compounds include phenols and polynuclear aromatic hydrocarbons (PAH).

Site Conceptual Model: Conceptual relationship between contaminant sources and receptors

through consideration of potential or actual migration and exposure pathways.

Site Inspection (SI): An on-site investigation to determine whether there is a release or potential

release and the nature of the associated threats. The purpose is to augment the data collected in

the preliminary assessment and to generate, if necessary, sampling and other field data to

determine if further action is or investigation is appropriate.

36


Soil Screening Levels (SSLs): Risk-based soil concentrations derived for individual chemicals

of concern from standardized sets of equations. These equations combine EPA chemical toxicity

data with parameters defined by assumed future land uses and exposure scenarios, including

receptor characteristics and potential exposure pathways.

Superfund: The common name used for the Comprehensive Environmental Response,

Compensation and Liability Act of 1980 (CERCLA), the federal law that mandates cleanup of

abandoned hazardous waste sites.

Surficial Aquifer: The geologic term for a saturated, shallow, water bearing unit, usually no

deeper than 50 feet below ground surface.

Time Critical Removal Action: An action that is implemented to address a direct threat to

human health or the environment.

Underground Injection Control: Process for regulating the construction, operation, permitting,

and closure of injection wells that place fluids underground for storage or disposal.

Vapor Intrusion: Vapor-phase migration of volatile organic compounds or volatile inorganic

compounds into occupied buildings from underlying contaminated groundwater or soil.

Volatile Organic Compounds: Organic chemicals that have a high vapor pressure at

ordinary room temperature. Their high vapor pressure results from a low boiling point, which

causes large numbers of molecules to evaporate or sublimate from the liquid or solid form of the

compound and enter the surrounding air.

http://en.wikipedia.org/wiki/Organic_chemicals

http://en.wikipedia.org/wiki/Vapour_pressure

http://en.wikipedia.org/wiki/Room_temperature

http://en.wikipedia.org/wiki/Evaporation

http://en.wikipedia.org/wiki/Sublimation_(phase_transition)

37

FUTURE STEPS

EPA and TDEC provide information regarding the cleanup of the National Fireworks, OU2 Site

to the public through Fact Sheets, public meetings, announcements in the Commercial Appeal,

and the Administrative Record file for the site. EPA and the TDEC encourage the public to gain

a more comprehensive understanding of the Site and the Superfund activities that have been

conducted at the Site. Information regarding the public comment period, public meeting and the

locations of the Administrative Record files, are provided on the front page of this Proposed Plan.

For further information on the National Fireworks OU2 Site, please contact:

Keriema S. Newman

Remedial Project Manager

(404) 562-8859 or (800) 435-9233

e-mail: [email protected]

or

Sherryl Lane

Community Involvement Coordinator

(404) 562-8611 or (800) 435-9233

e-mail: [email protected]

US EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303-8960

mailto:[email protected]

38

USE THIS SPACE TO WRITE YOUR COMMENTS

Your input on this Proposed Plan for the National Fireworks OU2 Site is important to EPA.

Comments provided by the public are valuable in helping EPA select a final cleanup remedy for

the site. You may use the space below to write your comments. Comments must be postmarked

or faxed by September 18, 2014 to 404-562-8788. If you have any questions about the comment

period, please contact Keriema Newman at (404) 562-8859 or through EPA’s toll-free number at

1-800-435-9233. Individuals with electronic communications capabilities may submit their

comments to EPA via Internet at the following e-mail address: [email protected].

Comments may also be mailed to:

Keriema S. Newman

SD-SRSEB

Region 4 U.S. Environmental Protection Agency


Atlanta, GA 30303

Name:

Address:

City: State: Zipcode:

39

Official

Business

Penalty for Private Use

U.S. Environmental Protection Agency Keriema S. Newman, Remedial Project Manager

Superfund Division, 11th Floor Sherryl Lane, Community Involvement Coordinator


Atlanta, GA 30303-8960

APPENDIX C

State Concurrence Letter

STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION

DIVISION OF REMEDIATION

September 26, 2014

Randall Chaffins, Deputy Director Superfund Division US EPA - Region 4 Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303

312 Rosa L. Pnrks Avenue, 14111 Floor NASINIL LE, TENNESSEE 37243

Subject: Interim Action Record of Decision Concurrence Letter National Fireworks Superfund Site, Operable Unit 2 EPA ID # TNSFN0407047 TDEC DOR ID # 79-514

Dear Mr. Chaffins:

The Tennessee Division of Remediation (TDOR) received the National Fireworks Superfund Site (located in Cordova, Tennessee) Interim Action Record of Decision Summary ofRemediation Alternative Selection on September 12, 2014.

The Tennessee Department of Environment and Conservation (TDEC) concurs with EPA's selected remedy (Alternative 4) which includes phytoremediation of groundwater and subsurface soil at plumes C, D, and E with long term monitoring and institutional controls.

If you have any questions, please contact Jordan Engli sh at (901) 371-3039 or [email protected].

Sincerely,

~i:o~t:: Division of Remediation

cc: DORJNCO DOR/MEFO

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