FIVE YEAR REVIEW · TCE target indoor air levels used is more stringent than the current...

Five-Year Review Report

Fourth Five-Year Review Report for

Mallory Capacitor Company TND075453688

Waynesboro Wayne County, Tennessee

June 2013

United States Environmental Protection Agency Region 4

Atlanta, Georgia

~~ JA ~ V '- Franklin E. Hill Director, Superfund Division

llllllllllllllllllllllllllllllllllllllllllllllllll 10923796


Mallory Capacitor Company Belew Circle Waynesboro

Wayne County, Tennessee

List of Acronyn1s ........................................................................................................................... 3

Executive Summary ...................................................................................................................... 5

Five-Year Review Summary Forni.............................................................................................. 7

1.0 Introduction ........................................................................................................................... 10

2.0 Site Chronology ..................................................................................................................... 12

3.0 Background ........................................................................................................................... 13

3.1 PHYSICAL CHARACTERISTICS ........................................................................................ 13

3.2 LAND AND RESOURCE USE···························································································· 16 3.3 HISTORY OF CONTAMlNATION ....................................................................................... 17

3.4 INITIAL RESPONSE ····················'···················································································· 17 3.5 BASIS FOR TAKING ACTION··························································································· 18

4.0 Remedial Actions .................................................................................................................. 19

4.1 REMEDY SELECTION······································································································ 19 4.2 REMEDY IMPLEMENTATION ........................................................................................... 21 4.3 OPERATION AND MAlNTENANCE (O&M) ....................................................................... 24

5.0 Progress Since the Last Five-Year Review ......................................................................... 26

5.1 OPERATE AND MONITOR THE GROUND WATER EXTRACTION AND TREATMENT SYSTEM

····································································································································· 27 5.2 COMPLETE NOTICE OF LAND USE RESTRICTION ............................................................ 27 5.3 MONTHLY HYDRAULIC MONITORING ............................................................................ 28

6.0 Five-Year .Review Process .................................................................................................... 30

6.1 ADMlNISTRATIVE COMPONENTS .................................................................................... 30 6.2 COMMUNITY INVOLVE MENT .......................................................................................... 30 6.3 DOCUMENT REVIEW ················································· ..................................................... 30

6.4 OATA REVIEW ·························································· ····················································· 36 6.5 SITE INSPECTION············································································································ 43 6.6 INTERVIEWS ................................................................................................................... 44

7.0 Technical Assessment ........................................................................................................... 46

7.1 QUESTION A: ls THE REMEDY FUNCTIONlNG AS lNTENDED BY THE DECISION

DOCUMENTS? ............................................................................................................... 46 7.2 QUESTION 8: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND

RAOS USED AT THE TIME OF REMEDY SELECTION STILL VALID? .................................. 46

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? .................. · .................................... 47

7.4 TECHNICAL ASSESSMENT SUMMARY ............................................................................. 47

8.0 Issues ...................................................................................................................................... 48

9.0 Recommendations and Follow-up Actions ......................................................................... 49

10.0 Protectiveness Statements .................................................................................................. 50

11.0 Next Review ......................................................................................................................... 51

Appendix A: List of Documents Reviewed ............................................................................. A-1

Appendix B: Press Notice ......................................................................................................... B-1

Appendix C: Illustration of Ground Water and Surface Water Monitoring Network ...... C-1

Appendix D: Interview Forms ................................................................................................. D-1

Appendix E: Site Inspection Checklist .................................................................................... E-1

Appendix F: Photographs from Site Inspection Visit .............................................................F-1

Appendix G: Toxicity Value Evaluation ................................................................................. G-1

Tables Table 1: Chronology of Site Events .............................................................................................. 12 Table 2: Summary of 1991 ROD Remediation Goals for Ground Water..................................... 20 Table 3: Summary of 1991 ROD Remediation Goals for Surface Water..................................... 21 Table 4: Summary of O&M Costs (2008 through 2012) .............................................................. 25 Table 5: Progress on Recommendations from the 2009 Addendum to the Third FYR ................ 27 Table 6: Previous and Current ARARs for Ground Water COCs ................................................ 32 Table 7: Previous and Current ARARs for Surface Water COCs ................................................ 33 Table 8: Institutional Control Summary Table ............................................................................. 34 Table 9: Summary of Sediment PCB Concentrations at Outfall to Green River.......................... 41 Table 10: Summary of Mass Removal Estimates Since the 2008 FYR ....................................... 42 Table 11: C.urrent Site Issues ........................................................................................................ 48 Table 12: Recommendations to Address Current Site Issues ....................................................... 49 Table G-1. Toxicity Value Comparisons .................................................................................... G-3

Figures Figure 1: Site Location Map ......................................................................................................... 14 Figure 2: Detailed Site Map .......................................................................................................... 15 Figure 3: Location of Off-site Plume Area ................................................................................... 35 Figure 4: Concentration Trends of TCE in Ground Water ........................................................... 38 Figure 5: Concentration Trends of PCBs in Shallow Bedrock Ground Water ............................. 38 Figure 6: Concentration Trends of PCBs in Deep Bedrock Ground Water.. ................................ 39 Figure 7: Concentration Trends of PCBs in Deeper Bedrock Ground Water. .............................. 40

2

List of Acronyms

ARAR AWQC BHHRA BPI Cal EPA CERCLA CFR CIC cisDCE coc COPC CRA CSF cVOC EPA EW FYR HHRA IC IUR MCLs MNA MOU NCP NPL O&M OMMP OU PCBs PQL PRP RA RAO RCRA RD RfC RID RG RVFS ROD RPM svoc TBC TCE

Applicable or Relevant and Appropriate Requirement Ambient Water Quality Criteria Baseline Human Health Risk Assessment Battery Properties Incorporated California Environmental Protection Agency Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations Community Involvement Coordinator cis-1,2-Dichloroethene Contaminant of Concern Contaminants of Potential Concern Conestoga-Rovers & Associates Cancer Slope Factor Chlorinated Volatile Organic Compound United States Environmental Protection Agency Extraction Well Five-Year Review Human Health Risk Assessment Institutional Control Inhalation Unit Risk Factor Maximum Contaminant Levels Monitored Natural Attenuation Memorandum of Understanding National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List Operation and Maintenance Operations, Maintenance and Monitoring Plan Operable Unit Polychlorinated Biphenyls Practical Quantitation Limit Potentially Responsible Party Remedial Action Remedial Action Objective Resource Conservation and Recovery Act Remedial Design Inhalation Reference Concentration Oral Reference Dose Remedial Goal Rem~dial Investigation/Feasibility Study Record of Decision Remedial Project Manager Semi-Volatile Organic Compound To-Be-Considered Trichloroethylene

3

VI

TDEC TDHE transDCE TWRA vc

VISL voe 12DCE

Tennessee Department of Environment and Conservation Tennessee Department of Health and Environment trans-1,2-Dichloroethene Tennessee Wildlife Resources Agency Vinyl Chloride Vapor Intrusion Vapor Intrusion Screening Level Volatile Organic Compound 1,2-Dichloroethene

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Executive Summary

Introduction The Mallory Capacitor Company Superfund Site (the Site) is an 8.6-acre abandoned facility that manufactured electrical capacitors from 1969 until 1984. The Site is located in the City of Waynesboro, Tennessee, situated on the western bank of the Green River. The manufacturing process for the capacitors occurred in the plant area and involved impregnating the capacitors with dielectric fluid containing polychlorinated biphenyls (PCBs) or dioctyl phthalate. The unused dielectric fluid was drained from the impregnation chambers, treated to remove impurities and then recycled for reuse. The impregnated capacitors then underwent a degreasing process using trichloroethylene (TCE). The manufacturing facility ceased operations in July 1984, and remained abandoned with little maintenance effort until the plant was disassembled and removed during removal actions that occurred in 1988 and 1989.

Contaminants were released to the environment as a result of spills and discharges during the removal of the fluid-filled capacitors from the impregnation chambers. Spilled dielectric fluid was collected in troughs in the floor and transferred to a 4,000-gallon underground storage tank, which later leaked. Other sources of contamination included leaking drums of liquids and sludge stored in the below-grade storage room at the Site. The media impacted from site releases include facility structures, soil, ground water, surface water and sediment. Primary contaminants of concern include PCBs and volatile organic compounds. The United States Environmental Protection Agency placed the Site on the National Priorities List (NPL) on October 4, 1989.

The Site is comprised of a single site-wide operable unit that addresses soil, sediment, surface water, and ground water contamination at the Site. The 1991 Record of Decision (ROD) selected a remedy to address contamination remaining in soil and ground water on-site and off-site using hydraulic containment of the ground water plume with extraction and treatment, institutional controls and monitoring. The triggering action for this five-year review (FYR) was the signing of the previous FYR on June 27, 2008.

Remedial Action Objectives The remedial action objectives established in the 1991 feasibility study and ROD were to prevent human exposure to ground water contaminated with chlorinated volatile organic compounds and PCBs; prevent or mitigate the migration of site-related contaminated ground water, both on-site and hydraulically down gradient from the Site; and monitor ground water and surface water in a manner to verify the effectiveness of remedial measures.

Technical Assessment The review of decision documents, applicable or relevant and appropriate requirements (ARARs) and the results of the site inspection indicate that parts of the remedy are functioning as intended by the ROD. Contaminated soils south of the plant were excavated and removed to the depth of bedrock, leaving concentrations of PCBs in bedrock above the industrial cleanup gqal; however, the area was backfilled with up to ten feet of Site soil meeting the cleanup goal of 10 mg/kg. In addition, contaminated sediments on site and off site have been excavated and removed. Land use controls, as called for in the ROD, are in place to prevent unrestricted exposure to soil and ground water on-site. Adequate ground water institutional controls have not been implemented at

5

off-site locations where ground water contamination has migrated. However, the EPA is currently working with the City of Waynesboro to establish an ordinance to prohibit the installation of wells and use of ground water impacted by the Site.

The 2005 vapor intrusion (VI) evaluation determined that VI did not pose unacceptable risks for on-site and off-site human receptors. As the TCE toxicity assessment was finalized on the EPA Integrated Risk Information System since the completion of the 2005 YI evaluation, the EPA reviewed the 2005 VI evaluation for current protectiveness. The EPA detennined that the 2005 evaluation remains protective, as exposure assumptions remain valid, and as the lower of the two TCE target indoor air levels used is more stringent than the current residential air Regional Screening Level for TCE. Although TCE in the shallow aquifer has fluctuated in the last five years due to the pump and treat system, the EPA has determined that these fluctuations would not impact the VI pathway because the vadose zone conditions have not changed. Although it does not affect protectiveness, the VI assessment should be updated when the EPA VI Guidance has been finalized.

Due to the presence of TCE at the Site, the potential exists that the chlorinated solvent stabilizer 1,4-dioxane may be present. The EPA has identified 1,4-dioxane as an emerging contaminant. This probable human carcinogen readily dissolves in water, and as a result, can migrate much further than a chlorinated solvent plume. While there is no risk of public exposure to site ground water, future analysis for 1,4-dioxane in some ground water samples should be considered.

Conclusion The remedy at the Site currently protects human health and the environment in the short-tem1 for the following reasons: contaminated soils and sediments have been excavated and removed down to bedrock from the Site, land use controls are in place to restrict. on-site activities to industrial use only, land use controls prohibit the disturbance of site soils and remediation equipment, and contaminated ground water is not in use. However, in order for the remedy to be protective in the long-term, the following action should be taken to ensure protectiveness: institutional controls should be implemented to restrict ground water use at off-site areas impacted by the Site.

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lFive-Year !Review Summary form

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Site Name:

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EPA ID: TND075453688

NPL Status: Final

Multiple OUs? Has the site achieved construction completion?

No Yes ,., ,.,..... . ' ' ~- ·~,fr~

REVIEW STATUS . . : ~ t •.:t ·'J.t

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Lead agency: EPA If "Other Federal Agency" selected above, enter Agency name:

Author name: Johnny Zimmerman-Ward and Claire Marcussen (Reviewed by EPA)

, Author affiliation: Skeo Solutions

Review period: January 8, 2013 - June 27, 2013

Date of site inspection: February 14, 2013

Type of review: Statutory

Review number: 4

Triggering action date: June 27, 2008

Due date (five years after triggering action date): June 27, 2013

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Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

None

Issues and Recommendations Identified in the Five-Year Review:

OU(s): OUOO Issue Category: Institutional Controls

Issue: Adequate ground water use restrictions, as called for in the 1991 ROD, have not been implemented for the portion of plume that has migrated off site. EPA is currently working with the City of Waynesboro to implement this institutional control.

Recommendation: Establish an ordinance with the City of Waynesboro to prevent access to contaminated ground water until it is fully remediated.

Affect Current Affect Future Implementing Oversight Milestone Date Protectiveness Protectiveness Party Party

No Yes EPA and City of EPA 6/01/2014 Waynesboro

Protectiveness Statement(s)

Operable Unit: Protectiveness Determination: Addendum Due Date ouoo Short-term Protective (if applicable):

Protectiveness Statement: The remedy at the Site currently protects human health and the environment in the short-term for the following reasons: contaminated soils and sediments have been excavated and removed down to bedrock from the Site, land use controls are in place to restrict on-site activities to industrial use only, land use controls prohibit the disturbance of site soils and remediation equipment, and contaminated ground water is not in use. However, in order for the remedy to be protective in the long-term, the following action should be taken to ensure protectiveness: institutional controls should be implemented to restrict ground water use at off-site areas impacted by the Site.

8

. ''

Environmental Indicators . .

- Current human exposures at the Site are under control. - EPA is working to ensure that contaminated ground water migration is under control.

. . _..,

Are Necessary Institutional Controls in Place?

D All ~ Some D None The Site needs additional ground water use restrictions.

..

D Yes~ No

as the Site Been Put into Reuse. . .

9


Mallory Capacitor Company Superfund Site

1.0 Introduction

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

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

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

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

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

Skeo Solutions, an EPA Region 4 contractor, conducted the FYR and prepared this report regarding the remedy implemented at the Mallory Capacitor Company Superfund site (the Site) in Waynesboro, Wayne County, Tennessee. The EPA's contractor conducted this FYR from January to June 2013. The EPA is the lead agency for developing and implementing the remedy for the Potentially Responsible Party (PRP)-financed cleanup at the Site. The Tennessee Department of Environment and Conservation (TDEC), as the support agency representing the State of Tennessee, has reviewed all supporting documentation and provided input to the EPA during the FYR process.

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

IO

remain at the Site above levels that allow for unlimited use and unrestricted exposure. The Site consists of one sitewide operable unit (OUOO).

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2.0 Site Chronology

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

Table 1: Chronology of Site Events

Event Date Site Discovery August 1, 1980 Tennessee Department of Health and Environment (TDHE)completed the August I, 1984 Preliminary Assessment TDHE' completed the Site Inspection November 15, 1985 TDHE completed the Hazard Ranking System Package March 14, 1986 The EPA proposed the Site for listing on the National Priorities List January 22, 1987 (NPL) Administrative Order on Consent filed; remedial investigation/feasibility February 18, 1988 study (Rl/FS) initiated The EPA started first removal action of equipment and stock within the July 26, 1988 plant The EPA completed first removal action September 19, 1988 The EPA started second removal action of part of plant and impacted October 1988 soils The EPA completed second removal action January 1989 The EPA finalized the Site on NPL October 4, 1989 Potentially Responsible Party (PRP) completed RI/FS and the EPA August 29, 1991 signed Record of Decision (ROD) Unilateral Administrative Order signed March 16, 1992 PRP started remedial design March 30, 1992 PRP completed remedial design and PRP started Phase I of the remedial June 8, 1993 action PRP completed Phase I remedial action February 1995 PRP started Phase II remedial action October 9, 1995 PRP completed Phase II remedial action August 1996 PRP started Modifications to the Phase II remedial action September 4, 1996 Preliminary Close-out Report (PCOR) completed September 24, 1996 PRP started a karst hydrogeologic assessment March 6, 1998 The EPA approved the karst hydrogeologic assessment May 1, 1998 The EPA approved initiation of a dye tracer study May 11, 1998 The EPA issued first FYR July 1, 1998 PRP completed the dye tracer study October 23, 1998 Consent Decree September 4, 2001 The EPA issued the second FYR July I, 2003 The EPA issued the third FYR June 27, 2008 The EPA issued an Addendum to the third FYR June 24, 2009 PRP filed notice ofland use restriction recorded in the Wayne County August 17, 2011 Register of Deeds Office

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3.0 Background

3.1 Physical Characteristics

The Site is located on Belew Circle in the City of Waynesboro, Tennessee. The Site is located adjacent to the floodplain of the Green River, which fom1s the eastern boundary of the Site. Highway I 3 passes west of the Site (Figures I and 2). A facility on the 8.6acre Site (Parcel: 077G F 001.00) manufactured electrical capacitors from I 969 until 1984, resulting in leaks and spills of dielectric fluid and solvents. The contaminants of concern associated with past activities include polychlorinated biphenyls (PCBs) and chlorinated solvents trichloroethylene (TCE), cis-1,2-dichloroethene (cis I 2DCE), transl ,2-dichloroethene (trans 12DCE) and vinyl chloride (VC). Following a series ofremoval actions, contaminated media still remained, including soil in and around the Site's former manufacturing facility, and ground water on site and off site.

The geology of the Site as interpreted from surface and subsurface features consists of three stratigraphic units, the alluvial deposits, residual soils and bedrock, with all three units varying in depth across the Site. The alluvial deposits consist of red to brown silts and sands with some clay and gravel and range in depth from eight feet on the west side of the Site to zero feet where they fan out at the edge of the Green River. The residual soils consist of brown to tan mottled clay silts up to eight feet thick. The bedrock unit, Fort Payne Formation, consists of three distinct subunits of fractured dolomitic limestone; numerous domestic water supplies are derived from the Fort Payne Formation in the Waynesboro area. However, a well survey was completed in February 2009, and no potable water wells were identified down-gradient from the Site. Further, potable water is provided on-site as well as to off-site residences from the Waynesboro municipal supply, which obtains potable water from surface water resources up-gradient from the Site. General ground water flow direction is northeasterly toward the Green River and is disrupted by fractures and lenses.

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Figure 1: Site Location Map

[Ji.Waynesboro, V

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Mallory Capacitor Co. Superfund Site

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Mallory Capacitor Co. Superfund Site City of Waynesboro, Wayne County, Tennessee

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

14

Figure 2: Detailed Site Map

Property Boundary

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This map was created using site data provided by the PRP contractors, Conestoga-Rovers & Associates.

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

15

3.2 Land and Resource Use

The Site, originally developed in the late 1940s as a shoe factory, was purchased in 1968 by P.R. Mallory & Co., Inc. Commencing in 1969, the company, then known as Mallory Capacitor Company (Mallory), began to manufacture electrical capacitors. In early 1979, Dart Industries Inc. acquired Mallory and sold the facility to Emhart Industries Inc. As part of the sales agreement with Emhart, certain PCB wastes were removed from the Site. In 1980, Mallory changed its name to Duracell International Incorporated (Duracell). Litigation ensued, between Emhart and Duracell from 1985 to 1988 over PCB liability. In 1988, Duracell's parent corporation formed a separate subsidiary, ~attery Properties Inc. (BPI), to assume ownership of the Site with all associated liability. The Site is currently occupied only by the secured former warehouse that houses the ground water extraction and containment system, and various extraction and monitoring wells. It is grassed and well maintained.

The Site is located in a residential/commercial/industrial/business area in the eastern section of Waynesboro. The properties surrounding the Site are primarily residential interspersed with some commercial establishments such as a dry cleaning business and a woodcraft shop to the north of the Site. The land use surrounding the Site has not changed appreciably since the 1991 ROD. The Green River forms the eastern boundary of the property.

Following the 1988/1989 removal actions, all areas of the Site became freely accessible to the public with the exception of the secured warehouse. It has been reported during the site inspection conducted on February 14, 2013, that golf balls have been found as evidence of incidental use of the open grassed area of the Site between the warehouse and the Green River. The Green River itself, although too shallow for recreational activities such as boating or swimming, has reportedly supported occasional recreational fishing by local residents. However, as presented in the 1991 Remedial Investigation/Feasibility Study (Rl/FS) and the June 2009 Addendum to Third Five Year Review, the aquatic

. habitat of the Green River adjacent to the Site is not suitable to support recreational fishtaking.

Residential properties in the immediate vicinity of the Site are serviced by municipal water supplied by the City of Waynesboro, which obtains the water from surface water resources upstream of the Site. An inventory of domestic water supplies within a 1-mile radius of the Site was completed as part of the hydrogeologic investigation conducted by Conestoga-Rovers & Associates (CRA) in 1987. The inventory identified 54 private water sources that draw water from the Fort Payne Fonnation, consisting of 27 drilled wells, 19 dug wells and eight springs. One private well (DWI 8) and two springs (S2 and SJ) were located down gradient from the Site. The well and springs reportedly were utilized for drinking water sources. The two springs are located closest to the Site and were sampled in 1987 by CRA. No site-related impact was detected at these two spring locations. In 2002, CRA conducted a private water well survey resulting in the identification of three private wells (18108023, 18108024 and 18109037) located down gradient from the Site. Well 18108024 has been abandoned, while wells OW 18,

16

18108023 and 18109037 and springs S2 and S3 were not in use. In February 2009, CRA contacted the property owners of the identified down gradient wells and springs to confirm that their uses had not changed since the 2002 water well search. Therefore, the results of the previous water well searches have been confirmed, as no potable water wells were identified down gradient from the Site. Additionally, a small spring is located on an adjacent property west of the Site which discharges into Cold Water Creek and is not in use as a drinking water source. A 2006 sample from the spring indicated that site contaminants are not present.

There are no wetlands, endangered species or critical habitats that are impacted by the Site. There are also no historical landmarks or agricultural lands that have been or are being impacted by the Site.

3.3 History of Contamination

From 1969 until 1978, the facility at the Site manufactured electrical capacitors that were impregnated with a dielectric fluid containing PCBs; in 1978, PCBs were replaced with dioctyl phthalate as a dielectric fluid. After impregnation, the capacitors were sent through a degreasing process using TCE to remove dielectric fluid adhering to the outside of the capacitors. During removal of the fluid-filled capacitors from the impregnation chambers, some dielectric fluid typically dripped or spilled off the capacitors and from the chambers onto the floor. The spilled dielectric fluid was collected in troughs in the floor and transferred to an underground holding tank, adjacent to the south wall of the plant, as waste fluid. The capacitor manufacturing operations ceased on July 27, 1984.

3.4 Initial Response

As part of the sales agreement between Duracell and Emhart, certain PCB wastes were removed from the Site between 1976 and 1980. The following activities were conducted:

• Disposal of still bottoms containing PCBs • Drainage of vacuum pumps • Disposal of pump oils containing PCBs • Implementation of a pilot program for cleaning plant equipment • Removal of 80 drums of liquids and sludge from a below-grade storage room,

followed by backfilling the storage room with cherty-clay to within 1 foot of the ceiling and then capping with a concrete slab.

• Removal of a 4,000-gallon underground storage tank used for storing wastes from the capacitor manufacturing process

• Excavation of contaminated soils adjacent to the leaking tank, followed by lining, backfilling and capping with concrete the entire former tank area.

Duracell completed the following removal activities in January 1989 after signing the Administrative Order on Consent on February 18, 1988:

17

• Cleaning and disposal of equipment within the plant, exclusive of equipment located within the impregnation room of the plant

• Cleaning and disposal of stock within the plant • Demolition and removal of the impregnation room of the plant, including

annexed buildings and all equipment contained therein, and the plant's air handling systems

• Excavation and disposal of soils south of the plant to the depth of bedrock contaminated with PCBs at concentrations of greater than 10 milligrams per kilogram (mg/kg)

• Cleaning of floor, wall, ceiling and overhead surfaces within the remaining portions

• Restoration of the Site by backfilling all excavations, placing topsoil and seeding

• Regrading soils beneath the fom1er plant satisfying the removal criterion of 10 mg/kg for PCBs and using them as backfill.

• Excavation backfilling was completed with clean imported soils • Removal of soi I containing PCBs at concentrations in excess of 10 mg/kg at

one isolated location in the grass area adjacent to the Green River • Removal of sediments containing PCBs in one sanitary sewer manhole located

on site.

Confirmatory soil samples showed concentrations of PCBs ranging from 12 to 270 mg/kg in the vicinity of the former boiler and impregnation rooms of the plant and south of the southeast comer of the plant, exceeding the on-site removal action criterion of 10 mg/kg. However, since this contamination at bedrock was below the water table present in the excavation and/or overlain by as much as 10 feet of clean soils, the contaminated bedrock soils were left in place, as reported in a letter to the EPA from CRA dated December 28, 1988.

Following a site inspection conducted by the TDHE and the completion of a Hazard Ranking System (HRS) scoring package, the Site was listed on the NPL on October 4, 1989.

3.5 Basis for Taking Action

A number of removal actions conducted at the Site prior to NPL listing demonstrated that the Site has been impacted with PCBs and solvent wastes. A remedial investigation (RI) was initiated in February 1988 and completed in August 1991 to characterize the nature and extent of human and environmental health risks associated with residual contamination present in soil, ground water, surface water and sediment. The results of the RI indicated that ground water in both the shallow and deep bedrock aquifers required remedial action due to unacceptable human health risks associated with potable use of the ground water. The contaminants of concern include PCBs, TCE and 1,2-dichloroethene (12DCE), which includes two isomers: cis-1,2-dichloroethene (cisDCE) and trans-1,2dichloroethene (transDCE).

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4.0 Remedial Actions

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

1. Overall Protection of Human Health and the Environment 2. Compliance with ARARs 3. Long-Term Effectiveness and Permanence 4. Reduction of Toxicity, Mobility or Volume through Treatment 5. Short-Term Effectiveness 6. Implementability 7. Cost 8. State Acceptance 9. Community Acceptance

4.1 Remedy Selection

The EPA signed the ROD on August 29, 1991, to address contamination on site and off site in the shallow and deep bedrock aquifers. The remedial action objectives listed in the 1991 FS and in the ROD were:

• Prevent human exposure to ground water contaminated with chlorinated volatile organic compounds (VOCs) and PCBs

• Prevent or mitigate the migration of site-related contaminated ground water, both on site and hydraulically down gradient from the Site

• Monitor ground water and surface water in a manner to verify the effectiveness of remedial measures

The remedy components included in the 1991 ROD were:

• Installation of ground water extraction wells in a phased approach (e.g., initially install approximately five wells at hot spots on site, followed in one year by the installation of approximately nine additional wells at the outer edge of the contaminant plume for containment and additional removal)

• Pumping collected water for on-site treatment of TCE and TCE degradation products using air stripping/bag filtration/carbon adsorption

e Discharge of treated ground water to the Green River or the local water treatment plant

• Investigations to better determine northern extent of off-site ground water contamination

• Investigations to determine possible impacts to Cold Water Creek

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• Placing deed restrictions on the Site property title to identify the presence of PCBs, I 2DCE and TCE and prevent the installation of ground water extraction wells on properties within the zone of ground.water contamination

• Effectiveness monitoring • Contingency measures: if it is determined that certain portions of the aquifer

cannot be restored to beneficial use for any one of the contaminants of concern (COCs), then all of the following measures involving long-term management may

1occur:

• Engineering controls such as physical barriers or long-tenn gradient control by low-level pumping

• Waiver of chemical-specific ARARs for those portions of the aquifer based on the technical impracticability of achieving further contaminant reduction

• Institutional controls to restrict access to those portions of the aquifer that remain above remediation goals for any of the COCs

• Continued monitoring of specific wells • Periodic re-evaluation of remedial technologies for ground water

restoration

Table 2 summarizes the remediation goals to be attained for ground water. Table 3 summarizes the remediation goals to be attained for surface water.

Table 2: Summary of 1991 ROD Remediation Goals for Ground Water

Remediation G-Oal (micrograms per liter; Chemical of Concern 11!!/L)"

Dichloroethene, cis-1,2- ( cisDCE) 70 Dichloroethene, trans-1,2- (transDCE) 100 Polychlorinated biphenyls (PCB) 0.5* Trichloroethylene (TCE) 5 a. Safe Drinking Water Act (SDWA) 40 C.F.R. 141. Primary Drinking Water standards listed in the EPA 1991 ROD. *According to the 1991 ROD. because of the infeasibility of removing sufficient amounts of PCBs from the aquifer for treatment. none of the alternatives are estimated to comply with the Primary Drinking Water standard for PCBs.

1 According to the 1991 ROD, if any of the contingency measures are warranted, an Explanation of Significant Differences (ESD) or a ROD Amendment will be required.

20

Table 3: Summary of 1991 ROD Remediation Goals for Surface Water

Remediation Goal (µg!L)"

Discharge Pipe Effluent Limits Green RiverChemical of Concern Maximum Continuous Ingestion of fish and Allowable Dischani:e drinkin2 river water

Total Dichloroethenes,- l ,2-(12DCE) 3,030 303 0.057

(sum of cisDCE and transDCE) Polychlorinated biphenyls (PCB) 0.2 0.014 7.9E-04 Trichloroethylene (TCE) NA NA 2.7 a. The EPA Ambient Water Quality Criteria for PCBs, TCE and cis and trans I 2DCE as listed in the 1991 ROD. NA - not available as criteri~ not established at the time ROD was published in 1991.

4.2· Remedy Implementation

The remedial design (RD) was conducted in phases to include Phase I and Phase II. Under the Unilateral Administrative Order (UAO) issued by the EPA on March 16, 1992, BPI undertook ground water remediation at the Site. BPI started the RD for Phase I on March 30, 1992, and completed it on June 8, 1993. Remedial action (RA) activities included:

• Installation and operation of five on-site ground water extraction wells • Construction and operation of an on-site ground water treatment facility with

effluent discharged to the Green River • Implementation of an effectiveness monitoring program consisting of hydraulic

and ground water quality monitoring in the shallow, deep and deeper bedrock aquifers; and surface water quality monitoring in the Green River and Cold Water Creek.

Following one year of collecting hydraulic and analytical data, in February 1995 BPI recommended maximizing the on-site extraction system and increasing the ground water treatment system pump rate. The EPA approved the modifications with additional recommendations on March 13, 1995. The Phase II RA construction began on October 9, 1995. Startup of the revised systems occurred on December 7, 1995, to include:

• Maximizing the pumping rates of all five on-site extraction wells • Increasing the capacity of the on-site ground water treatment system • Providing pretreatment to ground water extracted from extraction well (EW) 5 to

address elevated PCB concentrations attributed to the dense non-aqueous phase liquid (DNAPL) present in the well during Phase I RA

• Deepen EW-2 from 35 feet to 100 feet below ground surface (bgs) to increase drawdown at this well due to increased pumping rate

• Installation of two additional off-site shallow bedrock piezometers north of the Site to define hydraulic containment in this region

In August 1996, BPI recommended modifications to the system following a 6-month data collection period. BPI identified that the hydraulic head differentials from the deeper

21

bedrock to the deep bedrock that existed under non-pumping conditions, were reversed during pumping, likely causing the increased concentrations of site-related contaminants observed in the deeper bedrock. The EPA approved the modifications on August 16, 1996. The modifications occurred in a two-stage process. Stage I was conducted from September 1996 to mid-February 1997 to include:

• Temporarily sealing the bottoms of EW-2, EW-3 and EW-5 with inflatable packers

• Pemrnnently grouting the bottom portions of these extraction wells • Optimizing the extraction well pumping rates to reduce, or reverse, the downward

vertical hydraulic gradients from the deep to the deeper bedrock

Stage II was conducted from mid-February to September 1997 to include:

• Temporarily sealing the bottoms of EW-1 and EW-4 with inflatable packers • Permanently grouting the bottom portions of EW-1 and EW-4 • Optimizing the extraction well pumping rates to reduce, or reverse, the downward

vertical hydraulic gradients from the deep to the deeper bedrock

The EPA completed the Preliminary Close-out Report (PCOR) on September 24, 1996, verifying that the physical construction of the remedy had been completed.

In September 1997, the EPA and the TD EC raised concerns that: 1) karst features in the bedrock beneath the Site may influence ground water flow and contaminant migration at the Site; and 2) delineation of contamination north of the Site in the deep and deeper bedrock aquifers was warranted. The EPA and TDEC approved the Phase II modifications on March 11, 1998, with the following conditions:

• Conduct a karst hydrogeologic assessment within the Site vicinity to include a dye tracer study

• Defer the recommendation to install monitoring wells OW68, in the deep bedrock, and OW69, in the deeper bedrock, until the completion of the karst hydrogeologic assessment

• Initiate confinnatory ground water quality sampling at the time of the karst hydrogeologic assessment to evaluate the need for additional monitoring wells.

BPI completed the karst investigation on May 1, 1998, and concluded that significant karst features were not identified in the immediate Site vicinity; however, it could not be concluded with certainty that karst features did not influence ground water flow beneath the Site. As a result, BPI proposed on May 11, 1998, to conduct a dye tracer study, which was subsequently approved by the EPA and TDEC. BPI completed the tracer study on October 23, 1998, concluding that bedrock beneath the Site is not highly karstic and that karst features may not significantly influence ground water flow.

Due to the observed presence of non-aqueous phase liquids (NAPL) in the sampling port of extraction well EW-3 and the detected PCB concentrations in water samples collected

22

from extraction well EW-4, BPI modified the treatment system in September 2000. BPI connected EW-3 and EW-4 to the PCB stream (ground water that is directed through the PCB pre-treatment process), and added two additional primary resin filtration units and two secondary resin filtration units to the PCB Stream.

The EPA requested that BPI install six additional monitoring wells north of the Site (OW68-01, OW69-01, OW70-01, OW71-01, OW72-01 and OW73-01); this work occurred from September 7, 2001, until October 1, 2001. On January 9, 2002, North Wind Environmental conducted an independent performance review of the monitoring results of the new well installations and provided recommendations to include:

• Adding additional existing monitoring wells to the ground water quality monitoring network

• Installing a new off-site shallow/deep/deeper bedrock monitoring well nest approximately mid-way between existing shallow bedrock wells OW58-90 and OW59-90.

BPI completed an assessment of the monitoring network from 2003 to 2004, resulting in the addition of deep bedrock monitoring wells OW26-89 and OW52-89 to the annual monitoring event to monitor the extent of PCBs and VOCs in ground water to the east and north of the Site. Sampling on a five-year frequency of the shallow bedrock monitoring well OW50-89 and the deep bedrock monitoring well OW42-89 was also recommended to better evaluate on-site source area concentration.

CRA completed a vapor intrusion (VI) evaluation at the Site in 2004 to 2005 at the request of the EPA. On-site soil gas samples were collected where the maximum VOC concentrations were detected in shallow ground water. In April 2005, the EPA approved the VI evaluation, which concluded that potential health risks on site due to VI would not occur above acceptable levels under a residential setting. Since VOC concentrations in shallow ground water decrease down gradient from the Site, the VI evaluation also reached the same conclusion regarding VI exposure to off-site soil gas.

In November 2007, CRA installed three additional off-site ground water monitoring wells north of the Site to further define the extent of the aqueous phase PCBs and VOCs., including one shallow bedrock monitoring well (OW74-07), one deep bedrock monitoring well (OW75-07) and one deeper bedrock monitoring well (OW76-07).

In April 2008, CRA submitted a Monitored Natural Attenuation (MNA) Evaluation report to the EPA and demonstrated that naturally occurring attenuation processes, and in particular biodegradation, are active at the Site and are facilitating some reduction in the COC concentrations in ground water both on Site and down gradient from the Site.

On September 19, 2008, the EPA requested that three additional Green River surface water sampling locations be added to the surface water monitoring program, including two down-gradient from monitoring wells OW27-89 and OW59-90, and the third opposite monitoring well OW65-92, for a total of six surface water sampling locations

23

(G 1 through G6) to assess high water table conditions. Since the last FYR, the surface sampling results indicate that COCs remain at or below the limits of detection.

On June 24, 2009, the EPA prepared an Addendum to the 2008 FYR (FYR Addendum), because a protectiveness statement was deferred in 2008 until the EPA comments related to the exposure assumptions, PCBs toxicity data and exposure point concentration calculation methodology were addressed. The FYR Addendum indicated that the remedy was protective in the short tenn; however, additional actions were warranted to ensure the ground water remedy would be protective in the long term including implementation of institutional controls (ICs) and collection of additional ground water data to verify longterm protectiveness. CRA is currently conducting annual surface water and ground water sampling and analysis at the Site.

On August 17, 2011, the notice ofland use restrictions was recorded on the deed to prevent unrestricted use of the Site. Restrictions prohibit potable use of ground water and prohibit disturbance of the Site and associated remedial equipment.

4.3 Operation and Maintenance (O&M)

The Operations, Maintenance and Monitoring Plan (OMMP) was approved by the EPA on June 7, 1996. Remedial construction activities at the Site to date have resulted in the construction and commissioning of three main systems: ground water extraction system; ground water treatment system and treated water discharge system.

The ground water is divided into two treatment process streams, which are treated either: 1) by air stripping, oil/water separation, bag filtration, polymeric resin adsorption and activated carbon adsorption (PCB Stream); or 2) air stripping, bag filtration and activated carbon adsorption (General Stream). The off-gas emissions from the air strippers are treated by activated carbon adsorption prior to being released to the atmosphere. "The treated water continues to be discharged to the Green River located along the eastern Site boundary.

The annual system operations and O&M costs for this review period are summarized in Table 4. As shown in Table 4, the costs in 2008 and 2009 were higher due to the preparation of the third FYR and addendum to the third FYR, respectively. The ROD forecasted O&M costs of $80,000 per year and monitoring of $60,000 per year for a total of $140,000 per year. As shown in Table 4, the O&M costs are substantially more than proposed in the ROD, because the ROD cost estimate was based on the initial ground water extraction and treatment system, which anticipated a much lower ground water recovery rate of five gallons per minute (gpm). The extraction and treatment systems were upgraded to match the actual, much higher ground water extraction rate which for the period of 2008 to 2012, averaged 33 gpm, therefore resulting in higher O&M costs. Additionally, the monitoring network (monitoring wells and surface water locations) has been expanded a number of times (from 24 locations to 44 locations), thus increasing the monitoring costs over those contemplated in the ROD.

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Table 4: Summary of O&M Costs (2008 through 2012)

Dates From To

Total Cost

January 2008 December 2008 $478,000 January 2009 December 2009 $455,000 January 20 I 0 December 20 I 0 $377,000 January 2011 December 2011 $397,000 January 2012 December 2012 $359,000

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5.0 I?rng1ress Since tllle Last !Five-Yeat" Review

The protectiveness statements from the 2009 FYR Addendum for the Site stated the following:

"The rernedy at the Malloty Capacitor Site currently protects human health and the enviromnent in the short term.

0 The groundivater extraction and treatment system continues to remain functional and ivell maintailled. Additionally, tlze system continues to provide effective source colltrol alld fullctions as an effective contamillallt rnass removal system.

0 The Green River adjacent to the Site does not support a sign(ficalltfish population for consumption, since it is shallovv. relative(v fast-flowing. and the rhier bed consists of either exposed bedrock or bedrock covered by gravel/small stones, and there are no quiescent pools ofdeep water. Additional(v. interviews conducted in March 2009 with Tim Aston. Wayne County-Tennessee Wildlife Resources Agency [TWRA} Officer, stated the nearest location for edible.fish habitat is approxirnately 5,000feet downstreamfi·om the Site.

0 The results ofthe previous i-vater vvell searches have been c01~firmed; no potable ivater wells i.vere ident(fied dott'll-gradientfrom the Site.

0 The results .from the humall health risk assessment [HHRA} indicate the potential risk and hazard to a construction worker.from e:>..posure to PCBs in Site soil are within acceptable levels. The evaluation for the collstruction worker presellted in the HHRA ivas conservative cornpared with currellt methodologies and the collcfusions regarding the construction worker scenario are still valid.

All exposure pathways that could result ill unacceptable risks at the Site are current(v under control

However. in order/or the remedy to be protective ill the long-term, the.followillg actions need to be taken:

0 Institutional colltrols need to be implernented at the Site. A Notice ofLand Use Restriction is current(y being negotiated.for the Site.

Long-term protectivelless ofthe rernedial action will be ver(fied by obtaining additional ground water sarnples to fidly evaluate potential migration ofthe contaminant plume down-gradient.from the treatrnent area and towards the river. QuarterZv groundwater sampling and ana(ysis will continue at the Site. Current mollitoring data indicate the remedy isfimctioning as required to achieve groundwater cleanup goals."

The 2009 FYR Addendum included three issues and recommendations. Table 5 below summarizes each recommendation and its current status.

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- ---- -- - -- - --------- -·-

Table 5: Progress on Recommendations from the 2009 Addendum to the Third FYR

Party Milestone Action Taken andSection Recommendation Date of Action

Responsible Date Outcome Continue to operate and Progress reports from monitor the ground water 2007 through 2012 extraction and treatment indicate that the

5.1 system at the Site as a Site Owners Ongoing system should Ongoing source control and mass co_ntinue to operate to removal mechanism maintain hydraulic

control. Notice of Land Use

Complete the Notice of Restriction filed at the

Land Use Restriction Wayne County

pursuant I 0 Tennessee Register of the Deeds.

state law TC.A. Section Includes an

68-212-225 of the Institutional Control to

Hazardous Waste prevent the placement

Management Act of 1985 of ground water

for the Site property and EPA/TDEC/5.2 July 2013 extraction/drinking 08/17/2011

develop an Institutional Site Owners water wells on the

Control to prevent the Site. Does not include

placement of ground water restriction of ground

extraction/drinking water water extraction/

wells on properties within drinking water wells

the zone of ground water within the off-site

contamination. zone of ground water contamination.

Monthly hydraulic monitoring events continue

As approved in email to July 2009, followed by

correspondence from reassessment of the

EPA dated potential for shallow

February 4, 2011, the bedrock ground water

5.3 Site Owner July 2009 hydraulic monitoring 02/04/2011discharge to surface water,

frequency has been and an evaluation of

reduced from a potentially reducing

monthly to quarterly hydraulic monitoring

basis.conducted at the Site from monthly to quarterly.

5.1 Operate and Monitor the Ground Water Extraction and Treatment System

The third FYR recommended continued operation of the ground water extraction and treatment systems at the Site as a source control and mass removal mechanism. Since the third FYR, the ground water extraction and treatment systems have operated continuously with the exception of short down times to complete maintenance activities.

5.2 Complete Notice of Land Use Restriction

The notice of land use restrictions was completed on July 11, 2011, and recorded on the deed on August 17, 2011. The notice implements the following:

27

• Prohibits activities to include, but not limited to, any activity that would disturb wells or other equipment used to perform the remedy, or that would limit access to wells and equipment.

• Prohibits use of the property for non-industrial purpose, including but not limited to use as a residence, domicile, daycare, school, church, elder care facility, playground, recreational facility or fann, unless prior written notice is given to the EPA; demonstration is made to the satisfaction of TDEC that such proposed use will not pose an unacceptable risk to public health, safety or the environment; and written approval is obtained from TDEC before proceeding with the proposed use.

• Prohibits any land-disturbing activity on the property, without a forty-five (45) day written notice to TDEC and the EPA of the location of the proposed disturbance; and unless neither TDEC nor the EPA provides written objection within forty-five (45) days after its receipt of notice.

• Prohibits installation of potable ground water wells and the access, extraction or use of ground water from the Site for any reason, except for the installation of those wells installed as a part of the ongoing remediation of the property

• Requires notification of TDEC within no more than thirty (30) days after any conveyance of any ownership interest or any conveyance of any leasehold interest of all or substantially all of the property (excluding mortgages, liens and other non-possessory encumbrances or conveyances).

The land use restriction currently does not address institutional controls to restrict ground water extraction/drinking water wells within the zone of ground water contamination on off-site properties. The EPA is working with the City of Waynesboro to put in place a city ordinance to restrict ground water use in the relevant area of the plume.

5.3 Monthly Hydraulic Monitoring

An assessment of high water table conditions is ongoing at the Site to address whether this situation may result in site-related impacts to shallow ground water discharging to the Green River. The assessment has indicated that shallow ground water from the Site could periodically discharge to the Green River, based on surface water quality monitoring at one location within the river. The 2008 FYR recommended the comparison of ground water and surface water elevations be repeated, since the previous conclusion regarding discharge to the Green River were based on only one surface water elevation gauge in the northeast comer of the Site and a one-time survey of the surface water elevation change from the location of the gauge upstream (opposite OW 19-85) and downstream (opposite OW70-01 ). On September 19, 2008, the EPA requested that three additional Green River surface water sampling locations be added to the surface water monitoring program to assess high water table conditions including two down gradient from monitoring wells OW27-89 and OW59-90, and the third opposite monitoring well OW65-92, for a total of six surface water sampling locations (Gl through G6). A

28

summary of the hydraulic monitoring conducted at these six locations is provided in Section 6.4.

29

6.0 Five-Year Review Process

6.1 Administrative Components

The EPA Region 4 initiated the FYR in January 2013 and scheduled its completion for June 2013. EPA remedial project manager (RPM) Loften Carr led the EPA site review team, which also included the EPA community involvement coordinator (CIC) Neema Atashi and contractor support provided to the EPA by Skeo Solutions. In January 2013, the EPA held a scoping call with the review team to discuss the Site and items of interest as they relate to the protectiveness of the remedy currently in place. The review schedule established consisted of the following activities:

• Community notification • Document review • Data collection and review • Site inspection • Local interviews • FYR report development and review

6.2 Community Involvement

In March 2013, the EPA published a public notice in the Wayne County Ne-vvs newspaper announcing the commencement of the FYR process for the Site, providing contact information for Loften Carr and Neema Atashi and inviting community participation. The press notice is available in Appendix B.

The EPA will make the final FYR Report available to the public. The EPA will place copies of the document in the designated site repository: Wayne County Public Library, located at US 64 East, Waynesboro, TN 38485.

6.3 Document Review

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

ARARs Review

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

30

o Applicable requirements are those cleanup standards, standards of control and other substantive requirements, criteria or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, remedial action, location or other circumstance found at a CERCLA site.

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

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

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

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

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

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

Ground Water ARARs

The 1991 ROD established chemical-specific ARA Rs for the four COCs in ground water, based on the National Primary Drinking Water Regulations at 40 C.F.R. §141.TDEC has revised criteria for water uses under Rule 1200-04-03-.03 which are equivalent to the National Primary Drinking Water Regulations. This review confirmed that the MCLs for PCBs, cis-1,2-dichloroethene, trans-1,2-dichloroethene and TCE have not changed since

31

the selection of the remedy, as summarized in Table 6. It should be noted that vinyl chloride (VC) was not identified in the ROD as a COC; however, it is included in the monitoring reports since VC is a TCE degradation product.

Table 6: Previous and Current ARARs for Ground Water COCs

1991 ROD Current Federal and ARARs Chemical of Concern ARARs State

<ue:IL)" ARARs (ue:/L)b,c Change

Polychlorinated biphenyls (PCBs) 0.5 0.510.5 None

Dichloroethene, cis-1,2- ( cisDCE) 70 70170 None

Dichloroethene, trans-1,2- (transDCE) 100 100/ 100 None

Trichloroethylene (TCE) 5 515 None

a. COCs as listed in Table 7.2 from 1991 ROD. b. Federal Primary MCLs and MCL goals (MCLGs) are available at http://water.epa.gov/drink/contaminants/index.cfin (last

accessed 11/28/2012).

c. TDEC Rule 1200-04-03-.03 Criteria for Water uses http://tn.gov/sos/rules/1200/1200-04/1200-04-03.20110531.pdf (last accessed 6/6/2013)

Since the 2008 FYR, TDEC revised ground water quality criteria under Chapter 1200-04-03 in May 2011. Specifically TDEC established ground water ARARs under Rule 1200-04-03-.10 to addresses the remediation of ground water and perched ground water. This rule authorizes the commissioner under a number of statutes to cause remediation of the water when ground water contamination does not meet ground water criteria. The statutes include the Solid Waste Disposal Control Act, T.C.A. §§ 68-211-101 et seq., the Hazardous Waste Management Act, parts 1and2, T.C.A. §§ 68-212-101 et seq., and§§ 68-212-201 et seq., the Petroleum Underground Storage Tank Act, T.C.A. §§68-215-101 et seq., and the Drycleaner Environmental Response Act, T.C.A. §§ 68-217- 101 et seq. According to Rule 1200-04-03-.10, the goals of all such remediation actions are:

(a) to return waters to meeting standards when practicable by such methods as source removal, bioremediation, pump and treat, and natural attenuation; and

(b) to protect the public from exposure to water that does not meet standards through such methods as physical and institutional controls.

Surface Water ARARs

Surface water ARARs were identified as applicable to the discharge of the treated ground water to the Green River. The 1991 ROD identified the EPA's Ambient Water Quality Criteria (AWQC) for PCBs, TCE and total DCE (cis- and trans- isomers) promulgated in October 1980. 2 This review confirmed that the A WQC for protection of ingestion from fish and water is more stringent for PCBs and TCE, while the A WQC for transDCE is less stringent as summarized in Table 7. The more stringent values do not affect the

2 1980 Water Quality Criteria obtained at http://water.epa.gov/ sci tech/ swguidance/ standards/criteria/ ambientwgc index. cfin

32

protectiveness of the remedy, since none of COCs were detected in surface water samples since the 2008 FYR.

Table 7: Previous and Current ARARs for Surface Water COCs

Chemical of 1991 ROD ARARs (µg!Ll Current Federal ARARs ARARs Concern (11e/L)b Change

Max. Cont. Protection Max. Cont. Protection Allow. for Fish and Allow. for Fish and

Water Water Ineestion Ineestion

PCBs 0.2 0.014 7.9E-04 ND 0.014 6.9E-05 More

(6.9E-04)0 stringent

cisDCE 3,030 303 5.7E-02 ND ND ND ND

3,030 303 5.7E-02 ND ND 140 Less

transDCE stringent

ND ND 2.7 ND ND 2.5 More

TCE {25)0 stringent a. I 99l ROD Page 8-1 b. National Recommended Water Quality Criteria http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm

(accessed 1/3/13) c. Values in parentheses are the Tennessee Ambient Water Quality Criteria accessed at htm://www.tn.gov/sos/rules/1200/1200-

04/1200-04-03.20110531.pdf; the values are based on a 1 E-05 cancer risk.

Max allow - maximum allowable concentration in one day Cont - concentration based on a continuous discharge ND- The EPA has not established a value for this chemical.

Institutional Controls Review

Table 8 lists the institutional controls associated with the Site (Parcel 0770 F 001.00). The notice ofland use restriction, which was ' signed on July 11, 2011, and filed in the Wayne County Register of Deeds office on August 17, 2011, prevents unrestricted use of the Site, prohibits installation of potable wells and use of site ground water and prohibits land disturbing activities and activities that would disturb remediation systems in place. There are no institutional controls in place on off-site properties above the contaminated ground water plume; however, the EPA is currently working with the City of Waynesboro to put an ordinance in place that prevents installation of wells in the off-site contaminant plume. Figure 3 illustrates the location of the plumes, as delineated by COCs exceeding MCLs, and potentially impacted properties which should be addressed by the ordinance.

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Table 8: Institutional Control Summary Table

Areas of Interest: Site Parcel 077G F 001.00 and Off-site Properties Above Ground Water Contaminant Plume

Media I Cs

Needed?

ICs Called for in the Decision

Documents?

Impacted Parcel(s)

IC Objective

Prohibits installation of potable ground water wells, and the access, extraction or use

On-site of ground water Ground Yes Yes 077G F 001.00 from the Site for Water any reason

except for the installation of those wells installed as a part of the ongoing remediation

Prevent the installation of

Off-site Ground Water

Yes Yes Multiple parcels

wells and use of ground water at off-site properties impacted by the Site

Prohibits

Soil Yes Yes 077G F 001.00 unrestricted use of Site.

Instrument in Place"

Land use Restriction signed on July 11, 2011, and recorded in the deed office on August 17, 2011

None

Land use Restriction signed on July 11, 2011,and filed on August 17, 2011

Notes

Also prohibits any activity that would disturb wells or other equipment used to perform the remedy

The EPA is currently working with the City of Waynesboro on an ordinance to prevent installation of wells and use of · ground water

Land disturbing activity cam10t occur without TDEC and EPA approval

a. All infonnation recorded in a Notice of Land Use Restrictions. recorded by Ruth Butler. Register Wayne County Tennessee signed on July 11. 2011. recorded on August 17. 20 I I. Instrument #59151. Record book 139. pages 518 to 536.

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Figure 3: Location of Off-site Plume Area

® c I J 0778 D 007

0778 0005

0778 0778 0003 0001

1IIJJ I 0770 0778 077C i F016 0002 A042

0

o11ofo110 077G ~i FO)t F018 F019 077G

I F021

I I 0770 0110 / I 0770 f 013 F 013.0/ 0770

/ 0770 f 009

F012 0770

I I F011 F 010

I •"- I

ct..0"' ' r .. - .. ,.1- .. - .. w0\e~ I . \ ··-··-··-··-cold - •• - •• ., -

I ' =' 1 0770 f 007

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-;::R~Mariva ~treet ~n......___~, , i ··--··- •• ;m

I 125 250 500 -

-I -I

••c:::==-•••• Feet ••••• Shallow Bedrock Ground Water Plume (PeBs and VOCs > MeLs)

Interpreted Extent of Shallow Bedrock Ground Water Plume

Legend Site Property Boundary Property Boundaries

n NORTH

, .... Deep Bedrock Ground Water Plume (PeBs and Voes > MeLs) Interpreted Extent of Deep Bedrock Ground Water Plume Deeper Bedrock Ground Water Plume (PeBs and voes> MeLs) Interpreted Extent of Deeper Bedrock Ground Water Plume


This map was created using site data provided by the PRP contractors, Conestoga-Rovers & Associates.

07 03 .14

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

35

6.4 Data Review

Significant monitoring activities have been conducted at the Site to evaluate the performance of the ground water extraction and treatment systems. These activities involve the following monitoring programs:

• Ground Water Extraction and Treatment Systems Operation, Maintenance and Monitoring

• Ground Water Effectiveness Monitoring • Sediment Monitoring

A review of the data collected during these monitoring activities and documented in quarterly and annual reports since the 2008 FYR is summarized in the following subsections.

Ground Water Extraction and Treatment Systems Monitoring

Monitoring activities of the ground water extraction and treatment system (system) entail monitoring the system's operating data to ensure the system is operating within the design parameters for each of the process components. Extraction well flow rates are monitored and alterations made to the system to accommodate equipment maintenance (e.g., filter change out). The system has operated continuously with the exception of short down times to complete maintenance activities.

Treated Water and Treatment System Components: Samples are collected for the treated water and treatment system components and analyzed for PCBs, TCE, cisDCE, transDCE and VC to determine if the system is operating effectively. Based on a review of the quarterly reports, CRA addressed any breakthrough of chemicals in the system by changing out the carbon in the adsorption unit and resin infiltration unit to ensure complianc~ with the monitoring plan.

Extraction Well Monitoring: Chemical analyses were conducted on ground water extraction wells EW-1, EW-2, EW-3, EW-4 and EW-5 on a monthly basis to monitor the. concentrations of PCBs, TCE, cisDCE, transDCE and VC as well as field measurements of conductivity, pH and temperature. In all monitoring conducted since the 2008 FYR, the predominant contaminants detected were TCE and PCBs. PCBs were detected at the highest concentrations in EW-3 and EW-4. TCE was consistently detected at the highest concentrations in EW-4, with a few exceptions in which it was detected at higher concentrations in EW-1.

Vapor-phase carbon air emissions quality monitoring: The results of the monitoring are reported in the quarterly progress reports. The vapor-phase carbon emissions monitoring consists of collecting TCE air emission measurements using a Sensidyne® detector tube system at locations before, between and after the two vapor-phase carbon units. Since the 2008 FYR, these results indicate that the vapor-phase carbon is effective in the removal of the TCE from the off-gas of both air strippers, and that the final air emissions are

36

meeting the allowable discharge. In addition, monthly visual checks are made for the presence of non-aqueous phase liquid (NAPL) in the sump of air stripper No. 2; since the 2008 FYR, no NAPL was observed in the sump during any of the monitoring events.

Ground Water Effectiveness Monitoring

The effectiveness monitoring program consists of monthly hydraulic monitoring (ground water levels beneath and in the vicinity of the Site and surface water levels in the Green River) and annual ground water and surface water quality monitoring.

Hydraulic Monitoring: Hydraulic monitoring is conducted at the Site to determine if impacted ground water could reach down-gradient surface water. Hydraulic monitoring occurred on a monthly basis up until February 2011, at which time the EPA agreed that the monitoring could be reduced to quarterly basis. The hydraulic monitoring consists of measuring ground water elevations at the wells included in the hydraulic monitoring network, as illustrated in Appendix C.

Sw:fhce Water Quality Monitoring: The annual surface water samples were analyzed for PCBs and the VOCs TCE, cisDCE, transDCE and VC to detennine if ground water is impacting the Green River and Cold Water Creek. Surface water samples were collected at three locations along Cold Water Creek and six locations along the Green River, which includes the three new locations G4, GS and G6 as requested by the EPA on September 19, 2008. The sampling events conducted in October 2008 through October 2012 indicate that PCBs and VOCs are not present in surface water at or above laboratory detection limits.

Ground Water Quality Monitoring: Ground water samples were obtained from the monitoring network on an annual basis. The monitoring network is illustrated in Appendix C, along with figures showing the most current depiction of the PCB and chlorinated solvent plumes in the shallow, deep, and deeper bedrock zones. The network consists of two overburden/bedrock interface wells, 15 shallow bedrock wells, 13 deep bedrock wells and five deeper bedrock wells. A summary of the ground water results was obtained from the annual sampling reports for samples collected in October 2008 through October 2012, which concludes that the extent of site-related ground water impact in the shallow, deep and deeper bedrock essentially has remained similar to that which existed following completion of the Phase II Remedial Action Modifications. The results provide further definition of the impacted ground water and confinn that the extent of the ground water impact remains as previously estimated.

Shallow Bedrock: The highest concentrations of PCB and TCE (greater than 1,000 µg/L) in the shallow bedrock wells occur north of the fonner plant area in well OW37-89, as well as in the former impregnation area of the plant in OW 50-89. In addition, high concentrations (greater than 1,000 µg/L) of TCE are detected off-site consistently in OW67-95, which is located about 150 feet north of the fonner plant. TCE and its degradation products ( cisDCE, transDCE and VC) are at much lower concentrations down gradient and towards the Green River. As shown in Figure 4, the concentrations

37

near the source areas remain high, as represented by OW37-89 and OWS0-89. Concentrations in OW37-89 have declined, however, the concentrations have increased slightly at OWS0-89 where the former impregnation area was located. As shown in Figure 5, a similar trend is observed for the concentrations of PCBs at both source area wells.

Figure 4: Concentration Trends of TCE in Ground Water

1000000

100000

10000

~ ..... ~ 1000 w u ....

100

10

1

Cleanup level = 5 µg/L

2008 2009 2010 2011 2012

~OW37-89-S

- OWS0-89-5

OW38-89-Dl

-++o-OW76-07-D2

S =shallow bedrock Dl = deep bedrock 02 = deeper bedrock

Figure 5: Concentration Trends of PCBs in Shallow Bedrock Ground Water

1000

100

10

2008

Shallow Bedrock PCBs (µg/L)

2009 2010 2011 2012

38

~OW37-89

- OWS0-89

Deep Bedrock: The highest concentrations of PCB and TCE in the deep bedrock wells occur north of the former plant area in well OW38-89 while high concentrations ofTCE and its degradation products are also detected at OW52-89, off site and northeast of the Site approximately 150 feet from the western bank of the Green River. As shown in Figure 4, the TCE concentrations have fluctuated significantly over time in OW38-89, while PCBs appear to have increased between 2008 and 2010 and then declined from 2010 to 2012 (Figure 6).

Figure 6: Concentration Trends of PCBs in Deep Bedrock Ground Water

Deep Bedrock PCBs (µg/L)

-+-OW38-89 100 +--------------------

10 +--------------------

1 +----~----ir-----r----....----.,

2008 2009 2010 2011 2012

Deeper Bedrock: The highest concentrations in the deeper bedrock are not as high as the concentrations observed in the shallow or deep bedrock wells, with the highest concentrations of TCE and its degradation products consistently detected on site in OW62-90, which is located on the eastern side of the former plant, and off-site in OW60-90 adjacent to the Green River. The highest detections of PCBs are detected in off-site well OW76-07 approximately 300 feet north of the former plant area. As shown in Figure 4, TCE concentrations in OW76-07 range from 10 µg/L to 330 µg/L and have fluctuated between 2008 and 2012 while PCBs have generally declined in concentration since 2008 (Figure 7).

39

Figure 7: Concentration Trends of PCBs in Deeper Bedrock Ground Water

Deeper Bedrock PCBs (µg/L)

-+-OW76-07

2008 2009 2010 2011 2012

The conclusions of each annual report since the 2008 FYR include the recommendation that the ground water extraction and treatment systems remain in operation at the Site.

Sediment Monitoring of the Green River: Sediment samples were collected on a monthly basis from the Green River at former sediment sample location 272 near the outfall from the treatment system, and analyzed for PCBs (Table 9). According to the progress reports, the bottom of the Green River predominantly consists of exposed bedrock, and it is often difficult to collect sufficient sediment to permit analyses.

40

Table 9: Summary of Sediment PCB Concentrations at Outfall to Green River

Pt>riod PCB (mg/kg) 2008

January - March 0.35 to 0.84 April- June 0.54 to 0.86 October-December 0.15 to 3

2009 January - March 0.085 to 0.12 April- June <O.l133 July- September <0.033 October-December <0.033

2010 January - March <0.033 April- June 0.043 to 0.14 July- September 1.2 to 4.6 October-December 0.042 to 0.13

2011 January - March <0.033 to 0.063 April - June <0.033 to 0.059 July- September 0.11 to 0.33 October-December 0.49 to 0.57

2012 January - March <0.039 April - June <0.039 July - September 0.095 to 0.22 October-December 0.09 to 0.23

Extraction Well Contaminant Mass Removal Estimates: The contaminant mass removal achieved by the extraction wells is estimated on an annual basis using the average annual contaminant concentrations detected in extraction well influent samples and the average annual extraction well flow rates. Mass removal estimates are conducted for PCBs and TCE.

The monthly hydraulic monitoring conducted at the Site in accordance with the OMMP includes the collection of influent samples from each extraction well and the measurement of the extraction well flow rates. The results of the monthly extraction well influent sampling and extraction well flow rate measurements are presented in the quarterly monitoring reports prepared for the Site and submitted to the EPA.

The average of the PCB and TCE concentrations detected in the monthly extraction well influent samples and the average of the monthly extraction well flow rates were applied to estimate the PCB and TCE mass removal achieved by the extraction wells from 2008 through 2012, as presented in Table 10.

41

Tabie 10: Summary of Mass Removal Estimates Since the 2008 FYR

Average Extraction Well Average PCB Average TCE

Estimated PCBs Mass

Estimated TCE Mass

Extraction Pumping Rate Concentration Concentration Removed(I) Removed(I)

Well (GPM) lu11:/L) (u!!:/L) (lbs) (lbs)

2008 (December 29, 2007 to January 2, 2009) EW-1 0.10 18.0 5,558 0.008 2.5 EW-2 19.4 32.3 1,346 2.8 116

EW-3 7.3 9,286 9,600 302.2 312 EW-4 0.04 6,592 22,467 1.18 4.0

EW-5 6.9 3.8 43 0.12 1.3

Estimated Total Mass Removed 306 437

2009 (January 3, 2009 to January 1, 2010) EW-1 0.10 7.9 9,455 0.003 4.1 EW-2 19.8 48.6 1,267 4.2 109.4 EW-3 7.7 3,574 6,609 120.0 222.0 EW-4 0.07 3,043 17,125 0.93 5.2

EW-5 7.4 4.3 52 0.14 1.7


2010 (January 2, 2010 to December 31, 2010) EW-1 0.12 35.5 10,467 0.019 5.5

EW-2 19.0 60.3 1,172 5.0 97.1

EW-3 8.3 3,446 4,533 124.8 164.1 EW-4 0.08 358 13,533 0.12 4.7 EW-5 8.1 24.2 40 0.86 1.4


2011(January1, 2011 to December 30, 2011) EW-1 0.10 16.4 5,900 0.007 2.6

EW-2 18.3 45.4 1, 175 3.6 94.1 EW-3 7.3 4,565 4,545 145.8 145.1

EW-4 0.08 235 14,483 0.08 5.1 EW-5 7.3 2.3 32.1 0.07 1.0


2012 (December 31, 2011 to December 28, 2012) EW-1 0.10 4.5 5,033 0.002 2.2

EW-2 18.5 128.7 938 10.4 75.9 EW-3 6.4 3,001 4,344 84.0 121.6 EW-4 0.05 104 14,500 0.02 3.2 EW-5 5.5 3.0 48.4 0.07 1.2


Estimated Total Mass Removed Since 2008 FYR 807 1,504 GPM - gallons per minute lbs - pounds

As presented in Table 10, CRA has estimated that approximately 807 pounds of PCBs and 1,504 pounds of TCE have been removed from ground water beneath the Site from

42

December 2007 to December 2012. Also, Table 10 illustrates that the most productive EW is EW-3 for extraction of both PCBs and TCE from the ground water. It is also noted that EW-2 exhibited a significant increase in the average PCB concentration in 2012 compared to the previous four years. The mass removal estimates during this FYR are significantly lower than the mass removal estimates during the 2008 FYR, as approximately 2,710 pounds of PCBs and 14,620 pounds ofTCE were removed between 2002 and 2007.

6.5 Site Inspection

The site inspection was held on February 14, 2013. In attendance were Loften Carr, the EPA RPM; David Hill and Seth Roberts, CRA; Mark Hatcher, TDEC; and Johnny Zimmerman-Ward and Claire Marcussen, Skeo Solutions. For a full list of site inspection activities, see the Site Inspection Checklist in Appendix E. For photographs of the Site, see Appendix F.

The purpose of the site inspection was to observe site conditions and interview, where appropriate, PRPs, state government personnel and other people associated with the Site. All site inspection participants met at the project office at the Site, located in the warehouse structure housing the remediation system. Mr. Carr provided an overview of the scope and objectives of the FYR process, followed by Mr. Hill providing a summary of the ground water remediation system components and an overview of the ground water and surface water monitoring network.

Mr. Hill led the site tour, starting with a more detailed description of the ground water extraction and treatment system, which includes the extraction well lines into the treatment system where the extracted ground water is treated by air stripping, bag filtration, carbon adsorption (includes both liquid and vapor phase carbon adsorption units) and the liquid phase resin adsorption units to treat PCBs. The tour continued outdoors to include observation of the extraction wells and monitor wells, both on the Site property as well as off site. The location of the treated effluent discharge to the Green River was observed, and the residential areas located down gradient of the Site and north of Belew Circle Drive were observed, including the Cold Water Creek that flows through the residential area eventually discharging to the Green River.

The Site is not fenced, since the impacted soils have been removed to bedrock and replaced with fill and vegetative cover that is well-maintained with routine mowing. All monitoring and extraction wells were in good condition and were locked. Mr. Hill indicated vandalism has not occurred. The Site and treatment system is monitored on Monday through Friday, according to the logbook maintained in the warehouse office.

Following the site inspection, Skeo staff and Mr. Carr interviewed an adjacent business owner. They also visited the Waynesboro Public Library (located at US 64 East, Waynesboro, Tennessee), the designated repository for the Site's documents, to verify that information about the Site was publicly available. All hard copies had recently been moved to the county file room because the library was informed by the EPA that compact

43

disks (CDs) of the administrative record and all FYRs would be provided. The EPA delivered several copies of the CDs to the library, indicating that at leasl one copy should be maintained as a Reference Copy and available at all times to the public. The EPA and Skeo staff concluded the site inspection by visiting the Wayne County Register of Deeds office, where Ms. Ruth Butler, Register of Deeds, furnished Skeo staff with a copy of the Notice of Land Use Restrictions filed on August 17, 2011.

6.6 fot:erviews

The FYR process included interviews with parties affected by the Site, including regulatory agencies involved in Site activities, adjacent residents and former employees of the plant. The purpose was to document the perceived status of the Site and any perceived problems or successes with the phases of the remedy implemented to date. Some of the interviews took place during the site inspection, and some were received following the Site visit via email. The interviews are summarized below. Appendix D provides the complete interviews.

Loften Carr: Loften Carr is the EPA RPM for the Site, and indicated that the remedy is performing as planned. Having the Site monitored on a daily basis has helped with maintaining the Site. Mr. Carr indicated that he is comfortable with the institutional controls in place on the Site and anticipates that the ordinance with the City of Waynesboro will be finalized in the near future to prohibit the installation of wells and use of off-site ground water that has been impacted by the Site.

Mark Hatcher: Mark Hatcher is the TDEC project manager, and believes the remedy is working efficiently and that the O&M contractor is doing a fine job in the cleanup aspects of the Site. Mr. Hatcher indicated that TD EC conducts inspections of institutional controls on a regular basis.

Resident 1: Resident 1 is aware of the enviromnental issues at the Site and believes that the cleanup is successful. Resident 1 was pleased to know that information about the Site and associated cleanup activities is available at the public library. Resident 1 was concerned, however, that the Site activities have impacted real estate values, as Resident l was unable to sell property near the Site due to buyer concef!IS regarding contamination and children.

Business Owner: Business Owner is aware of the environmental issues at the Site and believes that the cleanup has been successful. However, a concern was raised by Business Owner that contractors installing a well near the business were wearing protective gear, yet Business Owner was not asked to wear any protective gear. Business Owner would like to be informed of ongoing Site activities by updates being published in the local newspaper.

Former Employee: Former Employee worked at the Mallory Capacitor Company prior to I 985 and is aware of the environmental issues at the Site and believes the cleanup has been good and well maintained.

44

O&M Contractor: Mr. David Hill is overseeing the O&M of the site and believes the cleanup is progressing as anticipated, as shown by the on-going removal of contaminant mass from the subsurface. Mr. Hill indicates that the monitoring data show that the extent of Site-related ground water impacts are stable and has remained essentially unchanged following completion of the Phase II remedial action modifications completed in 1996. Mr. Hill also indicated that the O&M activities are closely monitored five days a week by a local subcontractor who records various system readings to monitor system performance; in addition, a local contractor conducts inspections of the treatment system and conduct minor maintenance activities three days of week. Further, Mr. Hill indicates that every six months the treatment system is disassembled, cleaned and inspected to ensure proper operation. Minor O&M optimization may occur to improve system performance, which is all documented and reported on a quarterly basis.

45

7.0 Technical Assessment

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

The review of decision documents, ARARs and the results of the site inspection indicate the remedy is functioning as intended by the ROD. Contaminated soils and sediments have been excavated down to bedrock and removed from the Site. Land use controls, as called for in the ROD, are in place to restrict on-site activities to industrial use only and to prohibit the disturbance of site soils and remediation equipment. In addition, I Cs are in place that prohibit installation of potable ground water wells on the Site, as well as prohibiting the extraction or use of ground water on site; however, adequate ground water ICs have not been implemented for areas where the plumes have migrated off-site. Although the monitoring indicates that the plume is contained, the EPA is currently working with the City of Waynesboro to establish an ordinance to prohibit the installation of wells and use of ground water impacted by the Site.

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of remedy selection still valid?

Exposure assumptions, RA Os and ARARs used at the time of the remedy selection are still valid. The ground water ARARs have not changed for any of the COCs since the 2008 FYR. The A WQCs for PCBs and TCE established as NPDES criteria for the ground water treatment and subsequent discharge to the Green River are more stringent with respect to the criteria based on human ingestion of surface water and fish. According to the 2009 Addendum to the 2008 FYR (2009 Addendum), multiple lines of evidence were presented to support the conclusion that human exposure through fish ingestion was considered a negligible exposure pathway.

The 2005 VI evaluation determined that VI did not pose unacceptable risks for on-site and off-site human receptors. As the TCE toxicity assessment was finalized on the EPA Integrated Risk Information System since the completion of the 2005 VI evaluation, the EPA reviewed the 2005 VI evaluation for current protectiveness. The EPA determined that the 2005 evaluation remains protective as exposure assumptions remain valid, and as the lower of the two TCE target indoor air levels used is more stringent than the current residential air Regional Screening Level for TCE. Although TCE in the shallow aquifer has fluctuated in the last five years due to the pump and treat system, the EPA has determined that these fluctuations would not impact the VI pathway because the vadose zone conditions have not changed. Although it does not affect protectiveness, the VI assessment should be updated when the EPA VI Guidance has been finalized.

Due to the presence of TCE at the Site, the potential exists that the chlorinated solvent stabilizer 1,4-dioxane may be present. The EPA has identified 1,4-dioxane as an emerging contaminant. This probable human carcinogen readily dissolves in water, and as a result, can migrate much further than a chlorinated solvent plume.3 (See Appendix

31,4-Dioxane Overview. EPA's Contaminated Site Cleanup Information. http://cluin.org/contaminantfocus/default.focus/sec/ l %2C4-Dioxane/cat/Overview

46

G.) While there is no risk of public exposure to site ground water, analysis for 1,4dioxane in some ground water samples should be considered.

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

No new information has come to light that would call into question the protectiveness of the remedy.

7.4 Technical Assessment Summary

The review of decision documents, applicable or relevant and appropriate requirements and the results of the site inspection indicate that parts of the remedy are functioning as intended by the ROD. Contaminated soils south of the plant were excavated and removed to the depth of bedrock leaving concentrations of PCBs in bedrock above the industrial cleanup goal. However, the area was backfilled with up to ten feet of Site soil meeting the cleanup goal of 10 mg/kg. In addition, contaminated sediments on site and off site have been excavated and removed. Land use controls, as called for in the ROD, are in place to prevent unrestricted exposure to soil and ground water on-site. Adequate ground water institutional controls have not been implemented at off-site locations where ground water contamination has migrated. However, the EPA is currently working with the City of Waynesboro to establish an ordinance to prohibit the installation of wells and use of ground water impacted by the Site.

The 2005 vapor intrusion evaluation determined that VI did not pose unacceptable risks for on-site and off-site human receptors. As the TCE toxicity assessment was finalized on the EPA Integrated Risk Information System since the completion of the 2005 VI evaluation, the EPA reviewed the 2005 VI evaluation for current protectiveness. The EPA detennined that the 2005 evaluation remains protective as exposure assumptions remain valid, and as the lower of the two TCE target indoor air levels used is more stringent than the current residential air Regional Screening Level for TCE. Although TCE in the shallow aquifer has fluctuated in the last five years due to the pump and treat system, the EPA has determined that these fluctuations would not impact the VI pathway because the vadose zone conditions have not changed. Although it does not affect protectiveness, the VI assessment should be updated when the EPA VI Guidance has been finalized.

Due to the presence of TCE at the Site, the potential exists that the chlorinated solvent stabilizer 1,4-dioxane may be present. The EPA has identified 1,4-dioxane as an emerging contaminant. This probable human carcinogen readily dissolves in water, and as a result, can migrate much further than a chlorinated solvent plume. While there is no risk of public exposure to site ground water, future analysis for 1,4-dioxane in some ground water samples should be considered.

47

8.0 Issues

Table 11 summarizes the current site issues.

Table 11: Current Site Issues

Issue

Adequate ground water use restrictions, as called for in the 1991 ROD, have not been implemented for the portion of plume that has migrated off site. EPA is currently working with the City of Waynesboro to implement this institutional control.

Affects Current Protectiveness?

No

Affects Future Protectiveness?

Yes

48

9.0 Recommendations and Follow-up Actions

Table 12 provides recommendations to address the current site issues.

Table 12: Recommendations to Address Current Site Issues

Issue Recommendation I Follow-Up Action

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness?

Current Future Adequate ground Establish an ordinance water use with the City of restrictions, as Waynesboro to prevent called for in the access to contaminated 1991 ROD, have not ground water until it is been implemented for the portion of plume that has migrated off site.

fully remediated. EPA and City of

Waynesboro EPA 06/01/2014 No Yes

EPA is currently working with the. City of Waynesboro to implement this institutional control.

49

10.0 Protectiveness Statements

The remedy at the Site currently protects human health and the environment in the short-term for the following reasons: contaminated soils and sediments have been excavated and removed down to bedrock from the Site, land use controls are in place to restrict on-site activities to industrial use only, land use controls prohibit the disturbance of site soils and remediation equipment, and contaminated ground water is not in use. However, in order for the remedy to be protective in the long-term, the following action should be taken to ensure protectiveness: institutional controls should be implemented to restrict ground water use at off-site areas impacted by the Site.

50

11.0 Next Review

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

51

Appendix A: List of Documents Reviewed

Conestoga-Rovers and Associates (CRA). Annual Groundwater and Surface Water Sampling Results Mallory Capacitor Co. Site. Waynesboro, Tennessee, dated March 20, 2009; March 23, 2010; March 25, 2011; March 27, 2012; January 30, 2013.

CRA. Quarterly Progress Reports, Mallory Capacitor Co. Site, Waynesboro, Tennessee, from 2008 through 2012.

CRA. Final Remedial Investigation Report, Mallory Capacitor Co. Site. January 1991

CRA. Final Feasibility Study Report, Mallory Capacitor Co. Site. May 1991

CRA. Final Vapor Intrusion Pathway Assessment, Mallory Capacitor Co. Site. February 2005.

CERCLA Information System Site Information accessed from website http://www.epa.gov/region4/superfund/sites/npl/tennessee/mallcaptn.html. Accessed January 2013.

EPA. Third Five-Year Review Report - Addendum, Mallory Capacitor Co., Waynesboro, Wayne County, Tennessee, TND075453688. June 2009

EPA. Third Five-Year Review Report, Mallory Capacitor Co., Waynesboro, Wayne County, Tennessee, TND075453688. June 2008

EPA. Second Five-Year Review Report, Mallory Capacitor Co., Waynesboro, Wayne County, Tennessee, TND075453688. June 2003

EPA, Trichloroethylene Health Risk Assessment: Synthesis and Characterization - External Review Draft, Office of Research and Development, EP N600/P-Ol/002A, August 2001. (http://cfuub2.eoa.gov/ncea/cfrn/recordisplay.cfrn?deid=23249#Download)

EPA. First Five-Year Review Report, Mallory Capacitor Co., Waynesboro, Wayne County, Tennessee, TND075453688. June 1998.

EPA (U.S. Environmental Protection Agency). 1994. Method I 613, Tetra-Through Octa-Chlorinated Dioxins and Furans by Isotope Dilution HRGSIHRMS, Revision B. Environmental Protection Agency, Office of Water, Washington D.C. [Online] Available: http://www.epa.gov/ost/methods/1613.html. October.

EPA Record of Decision: Mallory Capacitor Superfund Site. EPNROD/R04-91/083. August 29, 1991.

EPA Integrated Risk Information System (IRIS). Cancer slope factor and Inhalation unit risk factor withdrawn in 1989.

A-1

Wayne County Property Appraiser accessed from website http://www.assessment.state.tn. us/SelectCounty.asp?map=true&SelectCountv=091. Accessed February 4, 2013

A-2

Appendix B: Press Notice

Free PPACA Informational Seminar Be Held March 12

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-cea-Fourtll "'- -Yetorllevlew for tlM ... llory C.1>11dtor Company Site, ... ,,,_bore, way,.. Coun1y, T.,.n_

The U.S. Environmental Prol9cllon Agency (EPA) Is conducting the fourth Five-Year Review of the cleanup 1Ctlvltl11 at lh• Mallory Capacitor Company Superfund Sia loeated in Waynesboro, Wayne County, Tenn•-· The purpose of lhe Five Year Review Is to monitor lhe performance of the rlllllldy iq>lemented mt Iii• Site in on:ler to ensure lhe Sita rem1in1 protective of human health and lhe environment. The remedies Implemented mt the Site included toll uc.vation/otfllte dilponl, grounM!er exlrlctlon/trellment dlte:harge and monitoring.

When completed, 1 copy of the review report win be pllcad in lh• lnfonMlion Repolltory Ill• locited in lhe EPA Record <Anter, 11 Iii Floor, 61 Forsyth Slrlel, S.W. Alianta, GA 30303, and the Wayne County Public Library, US 64 East, Wayn•boro, TN 38485. EPA will alto conduct 1 number of lllephone Interviews with ne1rby busln111•, re11dents, local ofllclals, state officials, and others to obtain their opin011 on the cleanup proceu.

Th• community can contribute during thl• review by providing comments or qullllona. The flv•y.ar review Is scheduled to be comp!N by July 2013. If you would fike to speak with 1111 1bout this Sia, plu .. Clll N•m11 Atalhl, EPA Community lnvolv• ment Coon:llnltor at (404) 317·9885. If you have any technical qu11tlon1, pl-contact Loften Carr, EPA Remedial Project Manager mt (404) 562-8804.

B-1

Appendix C: Illustration of Ground Water and Surface Water Monitoring Network

C-1

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figure 1

SITE PLAN AND MONITORING LOCATIONS MALLORY CAPACITOR CO. SITE

Waynesboro, Tennesset1

Appendix D: Interview Forms

D-1

Mallory Capacitor Company Site Site Name: Mallory Capacitor Company Site Interviewer Name: Skeo Solutions Subject Name: Loften Carr Subject Contact Information: Time: Interview Location:

Interview Format (circle one): In Person

Five-Year Review Interview Form EPA ID No.: TND 07-545-3688 Affiliation: Affiliation: EPA Region4

Date: February 19, 2013

Phone Mail Other • Email

Interview Category: EPA Remedial Project Manager

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

2. What effects has this Site had on the surrounding community, if any? The community is aware of the Site.

3. How well do you believe the remedy currently in place is performing? The remedy is performing well. Do you believe the monitoring data shows the remedy's effectiveness? Yes

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? No

5. Are you comfortable with the status of the institutional controls at the Site? Yes because a notice ofland use controls are in place on the Site and in the recent near future an ordinance will be established with the city of Waynesboro to prohibit the installation of wells and use of ground water in areas impacted by the Site. If not, what are the associated outstanding issues?

6. Are you aware of any changes in projected land use at or near the Site? No

7. Do you feel well informed about the Site's activities and progress? Yes

8. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy? No. It is expected that a ROD Amendment will be warranted to memorialize the remedy endpoints.

D-2

Mallory Capacitor Company Site Site Name: Mallory Capacitor Company Site Interviewer Name: Skeo Solutions Subject Name: Mark Hatcher Subject Contact Information: Time: Interview Location:

Interview Format (circle one): In Person

Interview Category: State Agency

Five-Year Review Interview Form EPA ID No.: TND 07-545-3688 Affiliation: Affiliation: TDEC Project Manager

Date:

Phone Mail Other: Email

1. What is your overall impression of the project? The management and consulting work of the O&M is doing a fine job in the cleanup aspect of the Site.

2. How well do you believe the remedy currently in place is performing? Efficiently.

3. Are you comfortable with the institutional controls required for the Site and their current status of implementation? Yes.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents in the last five years? No.

5. Has your office conducted any site-related activities or communications in the last five years? If so, please give purpose and results of these activities. Other than report reviews and IC/EC inspections, No.

6. Are you aware of any changes to state laws that might affect the protectiveness of the remedy? Are you aware of any changes in projected land use at the Site? Not at this time.

7. Do you feel well informed about the site's activities and progress? Yes.

8. Do you have any comments, suggestions, or recommendations regarding the Site's management or operation? Not at this time.

D-3

Mallory Capacitor Company Site Five-Year Review Interview Form Site Name: Mallory Capacitor Company EPA ID No.: TND 07-545-3688

Site Interviewer Name: Affiliation: Subject Name: David S. Hill Affiliation: Subject Contact Information: 209 Gothic Court, Suite 109

Franklin, Tennessee 37067 (615) 778-2535 [email protected]

Conestoga-Rovers & Assoc.

Time: Date: February 28, 2013 Interview Location:

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

Interview Category: O&M Contractor

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? I have personally been involved at the Site since 1998 have a very favorable impression of the project. The cleanup is progressing as anticipated, as shown by the on-going removal of contaminant mass from the subsurface.

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

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being documented over time at the Site? The monitoring data show that the extent of Site-related groundwater impact is stable and has remained essentially unchanged following completion of the Phase II remedial action modifications completed in 1996.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there is not a continuous on-site O&M presence. Scheduled routine O&M and inspections are performed by a local subcontractor 3 days per week (Monday, Wednesday, and Friday). These activities include bag filter change out, replacement of minor electrical components, etc. For issues that may develop outside of the scheduled O&M visits, the treatment system is equipped with an autodialer that immediately notifies the local O&M subcontractor and CRA by telephone of alarm conditions. Depending on the alarm condition, the treatment system will automatically shut down; if this occurs, manual restart of the system is required. Every 6 months the treatment system is disassembled, cleaned, and inspected to ensure proper operation.

Additionally, 5 days per week (Monday through Friday), a contractor inspects the Site and records various pressure and hour meter readings used to monitor system performance. Any issues identified during these inspections are immediately reported to CRA.

D-4

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

There have been no significant changes in Site O&M requirements or schedules since completion of the Phase II remedial action modifications in 1996. Individual components of the extraction and treatment system are reconditioned or replaced to maintain system performance on an as needed basis. In the last 5 years, the interiors of the liquid-phase carbon adsorption vessels were resurfaced to minimize pitting of the steel walls and some of the bag filtration units were replaced. These maintenance activities were perfonned prior to any component failures to maintain the protectiveness and effectiveness of the remedy.

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

There have been no unexpected O&M difficulties or costs since completion of the Phase II remedial action modifications in 1996.

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

Performance of the extraction and treatment system is continuously monitored. The O&M procedures are routinely evaluated for effectiveness. An example of a minor O&M optimization is that the initial O&M procedures included semi-annual removal and inspection of the extraction well submersible pumps. We observed that most submersible pump failures occurred within a few days of the removal and inspection. Based on this observation, the O&M procedures were optimized to only remove the submersible pumps when warranted by performance issues. This change reduced the costs associated with removing and inspecting the pumps when they were operating properly, and improved system performance by decreasing downtime due to pump failure. We now see extraction well submersible pumps operating within design parameters for years, where prior to the modification, some pumps failed every 6 months.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site? I believe that the O&M activities and schedules implemented at the Site are sufficient and appropriate.

D-5

Mallory Capacitor Company Site Five-Year Review Interview Form

Site Name: Mallory Capacitor Company Site EPA ID No.: TND 07-545-3688 Interviewer Name: Loften Carr Affiliation: EPA RPM Subject Name: Business Owner Affiliation: Subject Contact Information: Time: 11 :OOAM Date: February 14, 2013 Interview Location: Off-site Business

Interview Format (circle one): n Person Phone Mail Other:

Interview Category: Residents

1. Are you aware of the environmental issues at the Site and what cleanup activities have occurred? Not completely, however, aware of the ground water and soil contamination and the ground water treatment system.

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

3. What effect has this Site had on the surrounding community, if any? Concerned that the contractors drilling the well near his building were wearing protective clothing while he was working in his business and he was concerned he was not protected from the dust generated during the well drilling.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing? None

5. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide site-related information in the future? Somewhat. He would like updates published in the local paper.

6. Do you own a private well in addition to accessing city/municipal water supplies? If so, for what purpose(s) is your private well used? No

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? Yes. Be informed when drillers and coming and explain why he does not need to wear protective clothing.

D-6

Mallory Capacitor Company Site Five-Year Review Interview Form Site Name: Mallory Capacitor Company Site EPA ID No.: TND 07-545-3688 Interviewer Name: Claire Marcussen Affiliation: Skeo Solutions Subject Name: Resident 1 Affiliation: Subject Contact Information: Time: 11 :30AM Date: February 14, 2013 Interview Location: Waynesboro Public Library

Phone Mail Other: Interview Format (circle one): m Person ~~~~~~~-----'~~~---'-~~ ~~~~~~~~~~~~~~~~~~~-


1. Are you aware of the environmental issues at the Site and what cleanup activities have occurred? Yes

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

3. What effect has this Site had on the surrounding community, if any? Real estate has been impacted. Unable to sell property as potential buyers concerned of their children being exposed to contamination.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing? None observed.

5. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide site-related information in the future? Yes. CDs in library will be great for reference.

6. Do you own a private well in addition to accessing city/municipal water supplies? If so, for what purpose(s) is your private well used? No

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? None

D-7

Mallory Capacitor Company Site Five-Year Review Interview Form Site Name: Mallory Capacitor Company Site EPA ID No.: TND 07-545-3688 Interviewer Name: Johnny Zimmerman

Ward Affiliation: Skeo Solutions

Subject Name: Former Mallory Employee

Subject Contact Information:

Affiliation:

Time: 11:40 AM Interview Location:

Date: February 14, 2013 Office of the Register of Deeds

Interview Format (circle one): m Person Phone Mail Other:


1. Are you aware of the environmental issues at the Site and what cleanup activities have occurred? Yes, I worked at the Mallory Company until I was laid off in 1985.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? It is a good project and is being well maintained.

3. What effect has this Site had on the surrounding community, if any? I do not hear much about the Site anymore.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing? I am rarely in that part of town, so am unaware of any trespassing.

5. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide site-related information in the future? I have not been involved, but it would be best to receive information via the Wayne County News.

6. Do you own a private well in addition to accessing city/municipal water supplies? If so, for what purpose(s) is your private well used? I am on City Water.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? No

D-8

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Appen11.dlix IE: Site Ilmpectioirn Cllleckllnst

IFilVIE-YIEAIR IRIEVIl!EW §Illr!E IlN§PIEClI'IlON CIHIIECKJLil§lr

I. SITE INFORMATION

Site Name: Mallory Capacitor Company Date of Inspection: February 14, 2013

EPA ID: TND075453688 Location and Region: Wayne County, Tennessee

Agency, Office or Company Leading the Five-Year Weather/Temperature: Breezy, sunny, about 48°F

Review: EPA Region 4

Remedy Includes: (Check all that apply) D landfill cover/containment D Monitored natural attenuation D Access controls D Ground water containment ~ Institutional controls D Vertical barrier walls ~ Ground water pump and .treatment D Surface water collection and treatment D Other:

Attachments: ~ Inspection team roster attached D Site map attached

II. INTERVIEWS (check all that apply)

I. O&M Site Manager David Hill mm/dd/vvvv Name Title Date

Interviewed D at site D at office D by phone Phone: Problems, suggestions D Report attached: __

2. O&M Staff mm/dd/yyyy Name Title Date

Interviewed D at site D at office D by phone Phone: Problems/suggestions D Report attached: __

E-1

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

Agency EPA Contact Loften Carr Remedial

Name Project Date Phone No. Manager Title

Problems/suggestions 0 Report attached: __

Agency TDEC Contact Mark Hatcher Project

Name Manager Date Phone No. Title

Problems/suggestions 0 Report attached: ___

Agency __ Contact

Name Title Date Phone No. Problems/suggestions 0 Report attached: ___

Agency __ Contact

Name Title Date Phone No. Problems/suggestions 0 Report attached: __

Agency __ Contact

Name Title Date Phone No. Problems/suggestions 0 Report attached: ___

4. Other Interviews (optional) ~ Report attached: see Appendix C

Residents

Business Owner

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

I. O&M Documents

~ O&M manual ~ Readily available ~Up to date ON/A

~ As-built drawings ~ Readily available ~Up to date ON/A

~ Maintenance logs ~ Readily available ~Up to date ON/A

Remarks:

2. Site-Specific Health and Safety Plan ~ Readily available ~ Up to date ON/A

~ Contingency plan/emergency response plan ~ Readily available ~ Up to date ON/A

Remarks:

3. O&M and OSHA Training Records ~ Readily available ~Up to date ~NIA.

Remarks: __

E-2

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4. Permits and Service Agreements

0 Air discharge pemlit 0 Readily available 0 Up to date ~NIA

0 Effluent discharge 0 Readily available 0 Up to date ~NIA

0 Waste disposal, POTW 0 Readily available 0 Up to date ~NIA

0 Other permits: __ 0 Readily available 0 Up to date ~NIA

Remarks:

5. Gas Generation Records 0 Readily available 0 Up to date ~NIA

Remarks:

6. Settlement Monument Records 0 Readily available 0 Up to date ~NIA

Remarks:

7. Ground Water Monitoring Records l:8J Readily available l:8J Up to date ON/A

Remarks:

8. Leachate Extraction Records 0 Readily available 0 Up to date ~NIA

Remarks:

9. Discharge Compliance Records

0 Air 0 Readily available 0 Up to date ~NIA

0 Water (effluent) 0 Readily available 0 Up to date ~NIA

Remarks:

10. Daily Access/Security Logs l:8J Readily available l:8J Up to date ON/A

Remarks:

IV. O&M COSTS

I. O&M Organization

0 State in-house 0 Contractor for state

D PRP in-house ~ Contractor for PRP

D Federal facility in-house D Contractor for Federal facility

o_

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2. O&l\1 Cost Records

~ Readily available ~Up to date

0 Funding mechanism/agreement in place 0 Unavailable

Original O&M cost estimate: __ 0 Breakdown attached

Total annual cost by year for review period if available

From: mm/dd/yyyy To: mm/dd/vvvv 0 Breakdown attached

Date Date Total cost

From: rnm/dd/yyyv To: nun/ dd/ vvvv 0 Breakdown attached


From: mm/dd/yyyy To: nun/dd/vvvv 0 Breakdown attached


From: rnm/dd/yyyy To: nun/dd/vvvv 0 Breakdown attached


From: rnm/dd/vvvv To: mm/dd/vvvv 0 Breakdown attached


3. Unanticipated or Unusually High O&l\1 Costs during Review Period

Describe costs and reasons: Costs were high in 2008 and 2009 due to the FYR and subseguent Addendum

V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable ON/A

A. Fencing

I. Fencing Damaged ~ Location shown on site map ~ Gates secured ON/A

Remarks:

B. Other Access Restrictions

I. Signs and Other Security Measures 0 Location shown on site map ON/A

Remarks: Signs 12osted along fence line indicating no tres12assing.

c. Institutional Controls (ICs)

E-4

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1. Implementation and Enforcement

Site conditions imply ICs not properly implemented 0Yes C8] No 0 N/A

Site conditions imply I Cs not being fully enforced 0Yes C8] No 0 N/A

Type of monitoring (e.g., self-reporting, drive by): Personal on site daily

Frequency: M-F

Responsible party/agency: __

Contact mm/dd/vvvv

Name Title Date Phone no.

Reporting is up to date 0 Yes 0No C8l ON/A

Reports are verified by the lead agency 0 Yes 0No C8] NIA

Specific requirements in deed or decision documents have been met 0Yes C8] No ON/A

Violations have been reported 0Yes C8] No ON/A

Other problems or suggestions: 0 Report attached

2. Adequacy 0 ICs are adequate C8] ICs are inadequate ON/A

Remarks: Institutional controls current in 12lace on the 12ro12erty to restrict ina1212ro12riate land use and ground water use. No institutional controls in 12lace on off-site 12ro12erties above contaminated ground water 12lume. The EPA is working the City of Waynesboro to establish an ordinance on the area of the 12lume.

D. General

1. Vandalism/Trespassing 0 Location shown on site map C8J No vandalism evident

Remarks:

2. Land Use Changes On Site ON/A

Remarks:

3. Land Use Changes Off Site ON/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads C8J Applicable ON/A

I. Roads Damaged 0 Location shown on site map C8] Roads adequate ON/A

Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS 0 Applicable C8]N/A

A. Landfill Surface

E-5

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I. Settlement (low spots) 0 Location shown on site map 0 Settlement not evident

Arial extent: -- Depth: __

Remarks: - 2. Cracks 0 Location shown on site map 0 Cracking not evident

Lengths: __ Widths: Depths: __

Remarks: - 3. Erosion 0 Location shown on site map 0 Erosion not evident


Remarks: - 4. Holes 0 Location shown on ~ite map 0 Holes not evident


Remarks: - 5. Vegetative Cover 0 Grass 0 Cover properly established

0 No signs of stress 0 Trees/shrubs (indicate size and locations on a diagram)

Remarks: - 6. Alternative Cover (e.g., annored rock, concrete) ON/A

Remarks: - 7. Bulges 0 Location shown on site map 0 Bulges not evident

Arial extent: -- Height: __

Remarks: - 8. Wet Areas/Water Damage 0 Wet areas/water damage not evident

0 Wet areas 0 Location shown on site map Arial extent:

0 Ponding 0 Location shown on site map Arial extent:

0 Seeps 0 Location shown on site map Arial extent:

0 Soft subgrade 0 Location shown on site map Arial extent:

Remarks: - 9. Slope Instability 0 Slides 0 Location shown on site map

0 No evidence of slope instability

Arial extent: - Remarks: -

8. Benches 0 Applicable ON/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench 0 Location shown on site map 0 N/A or okay

Remarks: -

E-6

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2. Bench Breached 0 Location shown on site map 0 N/A or okay

Remarks:

3. Bench Overtopped 0 Location shovvn on site map 0 N/A or okay

Remarks: -

c. Letdown Channels 0 Applicable ON/A

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

I. Settlement (Low spots) 0 Location shown on site map 0 No evidence of settlement

Arial extent: Depth: __

Remarks: -

2. Material Degradation 0 Location shown on site map 0 No evidence of degradation

Material type: ___ Arial extent:

Remarks: -

3. Erosion 0 Location shown on site map 0 No evidence of erosion

Arial extent: Depth: __

Remarks:

4. Undercutting 0 Location shown on site map 0 No evidence of undercutting


Remarks: -

5. Obstructions Type: __ 0 No obstructions

0 Location shown on site map Arial extent: - Size: -

Remarks:

6. Excessive Vegetative Growth Type: __

-0 No evidence of excessive growth

0 Vegetation in channels does not obstruct flow

0 Location shown on site map ·Arial extent:

Remarks:

D. Cover Penetrations 0 Applicable ON/A

I. Gas Vents 0 Active 0 Passive

0 Properly secured/locked 0 Functioning 0 Routinely sampled 0 Good condition

0 Evidence of leakage at penetration 0 Needs maintenance ON/A

Remarks:

E-7

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2. Gas Monitoring Probes



Remarks: -

3. Monitoring Wells (within surface area of landfill)



Remarks:

4. Extraction Wells Leachate



Remarks:

5. Settlement Monuments 0 Located 0 Routinely surveyed ON/A

Remarks:

E. Gas Collection and Treatment 0 Applicable ON/A

I. Gas Treatment Facilities

0 Flaring 0 Thermal destruction 0 Collection for reuse

0 Good condition 0 Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping

0 Good condition 0 Needs maintenance

Remarks: - 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

0 Good condition 0 Needs maintenance ON/A

Remarks:

F. Cover Drainage Layer 0 Applicable ON/A

I. Outlet Pipes Inspected 0 Functioning ON/A

Remarks:

2. Outlet Rock Inspected 0 Functioning ON/A

Remarks:

G. Detention/Sedimentation Ponds 0 Applicable ON/A

I. Siltation Area extent: Depth: __ ON/A

0 Siltation not evident

Remarks:

E-8

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2. Erosion Area extent: -- Depth: __

0 Erosion not evident

Remarks: - 3. Outlet Works 0 Functioning ON/A

Remarks: - 4. Dam 0 Functioning ON/A

Remarks: - H. Retaining Walls 0 Applicable ON/A

I. Deformations 0 Location shown on site map 0 Deformation not evident

Horizontal displacement: __ Vertical displacement: __

Rotational displacement: __

Remarks: - 2. Degradation 0 Location shown on site map 0 Degradation not evident

Remarks: - I. Perimeter Ditches/Off-Site Discharge 0 Applicable ON/A

I. Siltation 0 Location shown on site map 0 Siltation not evident

Area extent: Depth: __

Remarks: - 2. Vegetative Growth 0 Location shown on site map ON/A

0 Vegetation does not impede flow

Area extent: Type: __

Remarks:

3. Erosion 0 Location shovm on site map 0 Erosion not evident


Remarks: - 4. Discharge Structure 0 Functioning ON/A

Remarks: - VIII. VERTICAL BARRIER WALLS 0 Applicable [8J N/A

I. Settlement 0 Location shown on site map 0 Settlement not evident


Remarks: -

E-9

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2. Performance Monitoring Type of monitoring: __

D Perfonnance not monitored

Frequency: __ D Evidence of breaching

Head differential:

Remarks:

IX. GROUND WATER/SURFACE WATER REMEDIES ~ Applicable 0 NIA

A. Ground Water Extraction Wells, Pumps and Pipelines ~ Applicable ON/A

I. Pumps, Wellhead Plumbing and Electrical

~ Good condition ~ All required wells properly operating D Needs maintenance ON/A

Remarks: - 2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

~ Good condition D Needs maintenance

Remarks: - 3. Spare Parts and Equipment

[gJ Readily available [gJ Good condition D Requires upgrade D Needs to be provided

Remarks: - B. Surface Water Collection Structures, Pumps and Pipelines D Applicable [gj NIA

I. Collection Structures, Pumps and Electrical

D Good condition D Needs maintenance

Remarks:

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

D Good condition D Needs maintenance

Remarks: - 3. Spare Parts and Equipment

D Readily available D Good condition D Requires upgrade D Needs to be provided

Remarks: - c. Treatment System ~ Applicable ON/A

E-10

I. Treatment Train (check components that apply)

D Metals removal [8J Oil/water separation D Bioremediation

[8J Air stripping [8J Carbon adsorbers

C8J Filters: resin

D Additive (e.g., chelation agent, flocculent): __

OOthers: __

l:8J Good condition D Needs maintenance

[8J Sampling ports properly marked and functional

C8J Sampling/maintenance log displayed and up to date

C8J Equipment properly identified

D Quantity of ground water treated annually: __

D Quantity of surface water treated annually: __

Remarks:

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

D N/A C8J Good condition D Needs maintenance

Remarks: __

3. Tanks, Vaults, Storage Vessels

D N/A C8J Good condition C8J Proper secondary containment D Needs maintenance

Remarks:

4. Discharge Structure and Appurtenances

D N/A C8J Good condition D Needs maintenance

Remarks:

5. Treatment Building(s)

D N/A l:8J Good condition (esp. roof and doorways) D Needs repair

C8J Chemicals and equipment properly stored

Remarks: __

6. Monitoring Wells (pump and treatment remedy)

C8J Properly secured/locked [8J Functioning [8J Routinely sampled [8J Good condition

D All required wells located D Needs maintenance ON/A

Remarks:

D. Monitoring Data

1. Monitoring Data

l:8J ls routinely submitted on time [8J Is of acceptable quality

2. Monitoring Data Suggests:

C8J Ground water plume is effectively contained l:8J Contaminant concentrations are declining

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E. Monitored Natural Attenuation

I. Monitoring Wells (natural attenuation remedy)

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

D All required wells located D Needs maintenance ON/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

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

The QU!:QOSe of the remedy is to Qrotect human health and the environment from exQosure to contaminated ground water through direct exQosure. The remedy is effectively fulfilling this QU!:QOSe, although institutional controls are not in Qiace to Qrevent access to the contaminated ground water Qiume off site. Institutional controls are currently in Qlace on the QroQerty to restrict inaQQroQriate land use and ground water use. No institutional controls in Qlace on off-site QroQerties above contaminated ground water Qlume. The EPA is working the City of Waynesboro to establish an ordinance on the area of the Qlume.

B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy.

O&M is adeguate.

c. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. None

D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None

Site Inspection Team: Loften Carr, EPA Johnny Zimmennan-Ward, Skeo Solutions Claire Marcussen, Skeo Solutions David Hill, CRA Seth Roberts, CRA

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Appendix F: Photographs from Site Inspection Visit

PRIVATE PROPERTY

NO TRESPASSING.

Sign at locked entrance of warehouse containing vapor-phase carbon adsorption units.

Looking southwest at warehouse with fenced-in vapor-phase carbon adsorption unit.

F-1

Site warehouse and fenced-in vapor-phase carbon adsorption unit looking west

Air strippers located in warehouse

F-2

Resin adsorption units for removing polychlorinated biphenyls (PCBs)

Liquid-phase carbon adsorption units

F-3

Oil-water separator with extraction well inputs in background

Vapor-phase carbon adsorption units in fenced area on the eastern side of the warehouse

F-4

Extraction Well Number 4 looking north towards Belew Circle Drive

On-site monitor wells along south side of Belew Circle Drive

F-5

Off-site monitor well cluster (OW74-, 75-, and 76-07) in residential area north of Site

Monitor wells OW25-89 and OW26-89 east of Site adjacent to Green River

F-6

Discharge point of treated effluent to the Green River

Green River immediately down gradient of discharge point

F-7

Cold Water Creek looking south from Butler Street

F-8

Appendix G: Toxicity VaRue IEvalL11ation

This appendix provides additional detail to support the evaluation of Technical 7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of remedy selection still valid?

Exposure assumptions, RA Os and ARA Rs used at the time of the remedy selection are still valid. The ground water ARARs have not changed for any of the COCs since the 2008 FYR. However, the AWQCs for PCBs and TCE established as NPDES criteria for the ground water treatment and subsequent discharge to the Green River are more stringent with respect to the.criteria based on human ingestion of surface water and fish. The more stringent A WQS would not impact the remedy at the Site since human exposure to fish impacted by the Site was not identified as a significant exposure pathway. According to the 2009 Addendum to the 2008 FYR (2009 Addendum), human health risks were evaluated for the fish ingestion pathway for the Green River which indicated risk greater than 1 E-04; however, the Addendum concluded this exposure pathway was considered negligible. This conclusion was based on multiple lines of evidence, including the following: the results of surface water quality samples collected from three locations adjacent to the Site which were all below detection limits for PCBS; a supplemental field survey of the Green River undertaken in February 2009 demonstrating that the Green River adjacent to the Site and up to 600 feet down-gradient of the Site cannot support a significant recreational fish population; and March 2009 statements by local personnel from the Tennessee Wildlife Resources Agency (TWRA) that the presence of habitat for edible fish between the Site and the Lawrenceburg Highway bridge is unlikely, and the nearest location for edible fish habitat is probably approximately 5,000 feet downstream from the Site.

Toxicity factors have changed only for TCE since the supplemental risk evaluation was included in the 2009 Addendum, as illustrated in Table G-1. According to the 2009 Addendum, the EPA had requested that the VI-exposure pathway be evaluated since it was not included in the 1991 RVFS. In response to the EPA 's request, the VI risk assessment that was prepared and approved in 2005 was summarized as part of the 2009 Addendum.4 The 2009 Addendum concluded potential human health risks through indoor air inhalation either on site or off site are not present above acceptable levels under a residential setting. That conclusion was based on results from five soil gas probes (GPl-04 to GP5-04) installed on site within overburden soils where VOC concentrations detected in the shallow bedrock ground water were highest.

The 2005 VI risk evaluation calculated risks for TCE based on two sets of toxicity values: the conservative draft provisional TCE toxicity values developed by the EPA 's National Center for Environmental Assessment (NCEA), as well as the TCE toxicity values developed by the EPA but withdrawn from the EPA's Integrated Risk Information System (IRIS) in 1989. Although the more current oral cancer slope factor (CSF) and inhalation unit risk factor (IUR) are more stringent than the 1989 withdrawn values, the 2005 risk assessment also calculated risks based on the NCEA CSF and IUR values, which are significantly more stringent than the current values. The 2005 evaluation demonstrated that using the NCEA toxicity values resulted in risks within the EPA 's risk management range of 1 E-06 to 1 E-04. Since the more current toxicity

4 Conestoga-Rovers & Associates. Final Vapor Intrusion Pathway Assessment, Mallory Capacitor Co. Site, Waynesboro, Tennessee. February 2005.

G-1

values for TCE are less stringent than the NCEA values, the risks would be even lower based on the analysis of data collected in 2004. Although TCE in the shallow aquifer has fluctuated in the last five years due to the pump and treat system, the EPA has determined that these fluctuations would not impact the VI pathway because the vadose zone conditions have not changed. Although it does not affect protectiveness, the VI assessment should be updated when the EPA VI Guidance has been finalized in order to address multiple lines of evidence as required for VI evaluations.

Although 1,4-dioxane was not identified as a COC in site ground water, this compound may potentially be present, since it is often used as a stabilizer in chlorinated solvents, specifically solvents such as TCE and 1, 1, 1-trichloroethane. 5 The EPA has identified 1,4-dioxane as an emerging contaminant, because it is a probable human carcinogen, and the physical and chemical properties and behavior of 1,4-dioxane create challenges for its characterization and treatment. Since 1,4-dioxane readily dissolves in water, it is expected to migrate much further than a chlorinated solvent plume. 6 While there is no risk of public exposure to site ground water, future analysis for 1,4-dioxane in some ground water samples should be considered.

5 White Paper: 1,4-Dioxane and Other Solvent Stabilizers. Santa Clara Valley Water District. June 14, 2001. 61,4-Dioxane Overview. EPA's Contaminated Site Cleanup Information. http://clu-in.org/ contaminantfocus/ default. focus/sec/ 1 %2 C4-Dioxane/ cat/Overview

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Table G-1. Toxicity Value Comparisons

Carcinogenic Toxicity Changes Non-Carcinogenic Toxicity Changes Inhalation Reference Concentration

Oral Cancer Slope Factor (CSF) Inhalation Unit Risk (TUR)" Oral Reference Dose RID)" (RfC)"

2009 2009 2009 2009 2012 Addendum• Addendum" 2012 Oral Addendum"

Addendum' Oral Change Oral 2012 Change Oral RfD RfD Oral RfC 2012 RfC Oral CSF CSP in !UR lUR in Value Value Change in Value Value Change in

Contaminants (mg/kg-davr 1 (mg/kg-davr1 CSF (u!!'/m3r 1 (u!!/m3r 1 !UR (mg/kg-d) (mg/kg-d) RfD (mg/m') (mg/m'l RfC Dichloroethene, cis- More 1,2- (cisDCE) ND ND None ND ND None l.OE-02 2E-03 stringent ND ND None Dichloroethene, trans-1,2- (transDCE) ND ND None ND ND None 2.0E-02 2.0E-02 None 6.0E-02 6.0E-02 None Polychlorinated biphenyls (high-risk) (PCBs) 2.0E+OO 2.0E+OO None 5.7E-04 5.7E-04 None 2.0E-05 2.0E-05 None ND ND None

Slightly more Less Less More

Trichloroethylene 4.0E-02d 4.6E-02 stringent l.IE-04d 4.1 E-06 stringent 3.0E-04d 5E-04 stringent 3.5E-02d 2.0E-03 stringent (TCE)°

More More l.lE-02' 4.6£-02 stringent l.7E-06' 4.lE-06 stringent ND' 5E-04 New ND' 2.0E-03 New

a.Values from 2009 Addendum to the 2008 FYR (2009 Addendum) b.EPA's Integrated Risk Information System (IRIS) (accessed http://www.epa.gov/TRIS 1/13/20 13) . c. 2009 Addendum evaluated cancer risks for trichloroethylene using two sets of toxicity values. d. 2009 Addendum cites the Draft provisional toxicity values from the EPA's provisional toxicity values recommended by the EPA's National Center for Environmental Assessment (NCEA).7

e. 2009 Addendum Superfund Health Risk Technical Support Center, Fact Sheet for Trichloroethylene (TCE) (CASRN 79-01-6), dated Dec. 14, 1992.

7 EPA, Trichloroethylene Health Risk Assessment: Synthesis and Characterization - External Review Draft, Office of Research and Development, EP A/600/P-O l /002A, August 2001. (http://cfpub2.epa.gov/ncea/cfm/recordisplay.cfm?deid=23249#Download)

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