5 9 0001

RECORD OF DECISION (ROD)FOR THE

CHEMET COMPANY SITEMOSCOW, TENNESSEE

MAY 1996

PREPAREDBY

U. S. ENVIRONMENTAL PROTECTION AGENCYREGION IV

-V

Record Of Decision (ROD) 59 0002

___________Table of Contents__________'Description Page

DECLARATION FOR THE RECORD OF DECISION . . . . . . . . . . . ill

DECISION SUMMARY . . . . . . . . . . . . . . . . . . . . . . 1

1.0 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . 11.1 Site Location . . . . . . . . . . . . . . . . . . . 11.2 Site Description Before Removal Activities . . . . 11.3 Site History and Enforcement Actions . . . . . . . . 4

2.0 COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . 9

3.0 SITE CHARACTERISTICS . . . . . . . . . . . . . . . . . . 103.1.1 Type of Facility and Operational Status ... 103.1.2 Site Topography . . . . . . . . . . . . . . . 103.1.3 Population and Land Use . . . . . . . . . . . 113.1.4 Sensitive Ecosystems . . . . . . . . . . . . 113.1.5 Meteorology . . . . . . . . . . . . . . . . . 11

3.2 SOURCE, NATURE, AND EXTENT OF CONTAMINATION . . . . 113.2.1 Sample Locations . . . . . . . . . . . . . . 113.2.2 Analytical Results of Sample Collection . . 12

3.3 CONFIRMATION SAMPLE RESULTS . . . . . . . . . . . . 12

4.0 SUMMARY OF REMOVAL ACTIVITIES . . . . . . . . . . . . . 13

RESPONSIVENBSS SUMMARY . . . . . . . . . . . . . . . . . . . 17

Record Of Decision (ROD) 59 Q Q 0 3

___________Table of Contents___________Description Page

Figure 1 Site Location Map . . . . . . . . . . . . . . 2Figure 2 Site Layout . . . . . . . . . . . . . . . . . 3Figure 3 Distribution of Lead . . . . . . . . . . . . . 6Figure 4 Distribution of Arsenic . . . . . . . . . . . 7Figure 5 Distribution of Antimony . . . . . . . . . . . 8Figure 6 Clean Up Confirmation Grid . . . . . . . . . . 15Table 1 Summary of Hauled Waste . . . . . . . . . . . 16

11

g fl H 0 1 Record of DecisionJ . U U J -+ Chemet Company Site

DECLARATION FOR THE RECORD OF DECISION

Site Name and LocationChemet Company SiteRoute 3 Box 90Moscow, TN 38057

Statement of Basis and Purpose

This Record of Decision (ROD) presents the selected remedial actionfor the Chemet Company Site, located in Moscow, Fayette County,Tennessee. The remedial action selected conforms with requirements ofthe Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980 (CERCLA), as amended by the Superfund Amendments andReauthorization Act of 1986 (SARA), and the National Oil and HazardousSubstances Pollution Contingency Plan (NCP). This decision documentis based on the information contained in the Chemet CompanyAdministrative Record. EPA has determined that its response at thisSite is completed. Therefore, the Site now qualifies for inclusion onthe Construction Completion List.

The State of Tennessee Department of Environment and Conservation(TDEC) concurs on the selected remedy.

Description of the Selected Remedy

The Removal Activities conducted by EPA at the Site from August 29,1994 to March 23, 1995 have eliminated the need to conduct additionalremedial actions. Based upon the data collected in the confirmationsampling (Section 3.3), EPA is recommending that no further action isnecessary at this Site to provide protection to human health and theenvironment. Furthermore, no Five-year review is necessary for thisSite because hazardous substances, pollutants, or contaminants are atacceptable levels at the Chemet Company Site.

During the removal activities, 731 truck loads (over 20,000 tons) ofnonhazardous soil were excavated and disposed of in the South ShelbyLandfill, Memphis, TN. Additionally, 28 truck loads (over 600 tons)of hazardous soil were disposed of by the Laidlaw EnvironmentalServices, Pinewood, SC. Based on the Streamlined Risk Assessment andconfirmation samples taken during the removal activities to verifysoil concentration levels, the Chemet Site does not pose a threat topublic health, welfare or the environment.

Richard D. Green DateActing Director

Waste Management Division

n ̂ n c Record of DecisionU U U b Chemet Company Site

DECISION SUMMARY

1.0 BACKGROUND

1.1 Site Location

The Chemet Company Site is located in Moscow, Fayette County,Tennessee. The Site is located west of the LaGrange-MoscowElementary School on Tennessee State Road 57 approximately 1.2miles east of State Road 76 intersection (figure 1). The mailingaddress is Route 3, Box 90, Moscow, Tennessee, 38057. Thegeographic coordinates are latitude 35° 03' 30.52" north andlongitude 89° 22' 24.22" west.

The facility covers five acres situated between the LaGrange-Moscow Elementary School to the east and proposed MoscowIndustrial Park to the west. The LaGrange-Moscow ElementarySchool is immediately adjacent to the Site. Entrances to theschool building are approximately 100 yards away. Three housesare located across State Road 57 to the south. A railroad islocated approximately 3300 feet north of the most northernproperty boundary.

The Site is in a rural area of Fayette County, TN, situated 1.2miles east of Moscow. The population of Moscow is approximately517. The population in a four-mile radius of the Site isapproximately 1,553.- There are three schools in the 4-mileradius area of concern. The nearest school is the adjacentLaGrange-Moscow Elementary School. There are no day care centersknown to be located in the area of concern. The land use isprimarily agricultural; however, there are several smallbusinesses located along State Road 57.

The nearest home is approximately 200 feet south of the Siteacross State Road 57. This is also the location of the nearestoff-site private potable well. This well is used by threehouseholds and is owned by J.D. and Sally Miller. Through asampling inspection in 1992, the State of Tennessee determinedthat the Miller's well water was not contaminated. The City ofMoscow municipal well is located approximately 1.3 miles west ofthe Site.

1.2 Site Description Before Removal Activities

The Chemet Site was an antimony processing facility (figure 2).Lead laden ore was processed at the facility to yield antimony.Antimony is commonly used as a fire retardant and plasticsstrengthener.

to

72 \_Germantown57

ROY F. WESTON Region IV TATACTIVITY DESCRIPTION: Site Location Map-Not To Scale

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TDD NO.: 04-041O0025

24 May 1906

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Moscow LaGrange Elementary School

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«14

59 0008 Record of DecisionChemet Company Site

During the years of operation, slag from the furnaces wassystematically stored in unsecured stockpiles on the property.Bins, containers, and barrels of slag and other waste materialswere also stored inside buildings, pending secondary treatmentfor disposal.

Surface soils on-site are a silty clay with non-native gravel inthe driveway area. The Site and surrounding area are gentlyrolling terrain with mixed vegetation. The low lying areas aregrassy. The meadows and knolls are covered in grasses and trees.The immediate Site has a mixture of young pine and hardwood treeswith blackberry thickets and tall grasses.

Three metal buildings existed on-site before the removalactivities were conducted. Buildings #2 and #3 were parallel toeach other in an east/west orientation. Building #3 containedfurnaces, a forklift and miscellaneous items. These twobuildings had a common concrete slab floor. Building #2 hadcontaminated soil that had been removed from the Site by theowner/operator. The contaminated soil filled the building fromend to end in a prismatic pile to a height of approximately 12feet (approximately 550 cubic yards). Building #1 was smaller(30 feet by 60 feet) and contained a drying furnace, between 25and 50 drums of slag and trash, raw ore in wooden crates,discarded automobile and industrial batteries, householdfurniture, and miscellaneous items. Two 40-forty foot semi-trailers were located north of the buildings. One trailer wasempty and the other held machinery and miscellaneous parts.

1.3 Site History and Enforcement Actions

During the construction of the elementary school, local residentsexpressed concerns regarding the safety of small childrenattending a school next to an operating metal processingfacility. These concerns were forwarded to the TennesseeDivision of Superfund (TDSF). Through sampling surveys, TDSFinspectors determined that hazardous level of inorganics existedin the slag piles, barrels, soil and sediment. The Site wasadded to the State's List of Inactive Hazardous Waste Sites onDecember 6, 1989. A Commissioner's Order was issued on March 19,1990 that directed the owner/operator to remove the hazardouswastes from the Site and dispose of the waste according to theTennessee Solid Waste Management Division Rules.

By visual inspection, the State of Tennessee determined thecleanup efforts by the owner did not meet the requirements of theCommissioner's Order.. Instead of conducting a cleanup, the ownerscraped soils from the Site and stored it in Building #2. Afterthe owner's unsuccessful attempts to meet the requirements set

Pi n 0 Q Record of DecisionU U U:? Chemet Company Site

forth in the Commissioner's Order, the Site was referred to EPAin May 1990. The Site Investigation (SI) conducted by TDSF staffin 1992, verified that heavy metals were present because ofprocessing antimony. A Hazardous Ranking System (HRS) packagewas prepared and submitted to EPA Headquarters in Washington,D.C.. From the HRS package, EPA determined that the Site posed asignificant threat to human health and the environment. In May1993, the Site was referred to the EPA, Region IV, NorthSuperfund Remedial Branch (NSRB). After a thorough review ofSite information, NSRB staff concluded the Site was a candidatefor cleanup under Superfund Accelerated Cleanup Model (SACM)Guidelines. Concurrently, the Site was proposed for the NationalPriority List (NPL), January 1994. The Site was finalized on theNPL in May 1994.

Subsequent sampling surveys, conducted by EPA EnvironmentalServices Division (ESD), Hazardous Waste Section (HWS), confirmedthe soil was contaminated with elevated levels of lead, arsenicand antimony. Additionally, the poorly secured waste piles posedan increased risk of direct exposure to the highly concentratedlead waste. EPA Waste Division staff determined that a Non-TimeCritical Removal under SACM, would be an effective method toaccomplish the remediation.

The Field Investigation (FI) was developed to gather sufficientinformation to: 1) characterize the Site, 2) define contaminantsof concern and extent of contamination, 3) determine the actualor potential threat, if any, the Site poses to human healthand/or the environment, and 4) aid in the development ofremoval/cleanup remedies that may be necessary to address anythreat identified.

Soil samples were collected for the Engineering Evaluation/CostAnalysis (EE/CA) on January 25 and 26, 1994. Additional sampleswere collected by ESD on March 23, 1994, for Toxic CharacteristicLeaching Procedure (TCLP) analysis to determine appropriateremediation/disposal of contaminated soils at the Site.Sampling, conducted by ESD, verified the soil on-site wascontaminated with lead, arsenic and antimony {Figure 3,4,5).

•<„>

5 9 0010LEGEND>

Q- —• ;> INTERMrTTENT STREAM

\TREESFENCE- CRATES- SOU/SEDIMENT- WATER

• - GRID NUMBER- SURF. SOIL/SURF. WATER PPMr- SUBSURFTSOI/SED. PPM

U - DETECTION UMfrJ - ESTIMATED VALUE

NA - NOT ANALYZED

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FIGURE 3DISTRIBUTION 01- LEAD

CHEMETMOSCOW, TENNESSEE

APPROXIMATE SCALEtoo e

< IN FEET >I inch * 100 ft

&EPA SR 57

5 9 0011

11J >4413J

LEGEND£ INTERMITTENT STREAM

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- CRATES

- SOIL/SEDIMENT- WATER

• - GRO NUMBERI - SURF. SOOySURF. WATER PPMT- suBsixtFYsoft/sED. PPM

U - DETECTION LIMITJ - ESTNMIEO VALUE

NA - NOT ANALYZED

•35

•30

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11 •17

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FIGURE 4DISTRIBUTION OF ARSENIC

CHEMETMOSCOW.TENNESSEE

APPROXIMATE SCALEtoo • so 100

< IN FEET )1 Inch = 100 ft

SR 57

' 0012LEGEND ——

-"—" J£ INTERMITTENT STREAM

• - GRD NUMBER- SURF. SOL/SURF. WATER PPMF- SUBSUR l̂otySEO. PPM

U - DETECTION LIMITJ - ESTIMATED VALUE

NA - NOT ANALYZED

., ^^ 2.700J. s88J

* " FENCE- CRATES- SOIL/SEDIMENT- WATER

FIGURE 5DISTRIBUTION OF ANTIMONY

CHEMETMOSCOW, TENNESSEE

APPROXIMATE SCALEso

< IN FEET )1 Inch « 100 ft

&EPA SR 57

H n 1 ̂ Record of DecisionU U I O Chemet Company Site

2.0 COMMUNITY PARTICIPATION

In accordance with the requirements of CERCLA §113(k)(2)(B) and§117, a Community Relations Plan (CRP) was developed to establisha framework for community relations activities at the ChemetCompany Site. The CRP was finalized January 1994, andimplemented throughout the EE/CA, Action Memorandum and RemovalActivities.

The CRP contains information gathered from community interviewsconducted in the Fall 1993. Some of the information included inthe document dealt with the community's knowledge of the Site,perception of the Site and other issues related to the Site.

Before the start of the EE/CA, EPA held a Public Meeting onJanuary 27, 1994, to describe the Superfund process and theplanned EE/CA activities. The public meeting provided thefollowing opportunities for the public: (1) to participate earlyin the Superfund decision process, and (2) provide theopportunity for community groups to receive a TechnicalAssistance Grant (TAG) to closely monitor the technical progressof the investigation. Notice of the meeting was disseminatedthrough fact sheets and local newspapers. Many concernedcitizens, local and state officials, and local media personnelwere present. Most of the people there strongly supported thestreamlined activities proposed by EPA. EPA also established andcontinues to maintain an information repository andAdministrative Record (AR) at the LaGrange-Moscow ElementarySchool in Moscow, Tennessee. The AR includes all documents andinformation EPA used as a basis for developing the final action.

On May 24, 1994, EPA held a Public Meeting to describe theSuperfund Proposed Removal Plan, present the results of theEE/CA, and the Streamline Risk Assessment. A court recorder waspresent at the meeting to record the minutes. Additionally, afact sheet was developed to describe EPA's proposed removalaction for the Site and announce the public comment period. Thefact sheet was sent to the residents, officials, and the media.The public comment period began on May 16, 1994, and ended onJune 16, 1994. All comments received during the comment periodstrongly supported the EPA preferred alternative.

A fact sheet was internally prepared and disseminated by EPAstaff August 1994, to inform the public that the ActionMemorandum had been signed and the removal activities would beginin late August 1994. The fact sheet outlined the schedule ofevents to take place and contact numbers of EPA staff members.The fact sheet was printed in two local newspapers. Furthermore,the project manager held a media conference with local officials

5 9 0014 Record of DecisionChemet Company Site

and the media to entertain questions about the impending removalactivities. All-involved strongly supported EPA's presence andthe planned removal activities.

3.0 SITE CHARACTERISTICS

3.1.1 Type of Facility and Operational Status

The owner/operator began operation at the Site in 1980 as anantimony oxide processing facility. Ore mined in China wasprocessed at the facility to yield antimony (antimony is used asa fire retardant and plastics strengthener). During the years ofoperation, slag from the furnaces was stored uncovered on thenortheast portion of the property pending secondary treatment ordisposal. Barrels of slag and other waste materials were storedinside the buildings.

During the construction of the elementary school in 1988,concerns for exposure to the Site from the public were expressedand forwarded to the Tennessee Division of Superfund (TDSF). In1989, the owner reduced operations to one antimony oxidationfurnace. Before the EPA removal action, the owner had left theState of Tennessee and abandoned the Site.

3.1.2 Site Topography

The facility covers five acres situated between the LaGrange-Moscow Elementary School to the east and proposed MoscowIndustrial Park to the west. Three houses are located acrossState Road 57 to the south. To the North of the Site isfarmland. A railroad is located approximately 3300 feet north ofthe most northern property boundary. The Wolf River is locatedapproximately 2 miles to the west and flows north.

Surface soils on-site are a silty clay with non-native gravel inthe driveway area. The Site and surrounding area are gentlyrolling terrain with mixed vegetation. The low lying areas aregrassy. The meadows and knolls are covered in grasses and trees.The immediate Site has a mixture of young pine and hardwood treeswith blackberry thickets and tall grasses.

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P. p. y. f- Record of DecisionU U I 0 Chemet Company Site

3.1.3 Population and Land Use

The Site is in a rural area of Fayette County, TN, situated 1.2miles east of Moscow. The population of Moscow is approximately517. The population in a four-mile radius of the Site isapproximately 1,553. There are three schools in the four-mileradius area of concern. The nearest school is the adjacentLaGrange-Moscow Elementary School. There are no day care centersknown to be located in the area of concern.

Within one-half mile of the Site the land use is primarilyagricultural. However, there are several small businesseslocated along State Road 57. The nearest home (J.D. and SallyMiller) is approximately 200 feet south of the Site across StateRoad 57. Their private potable well was sample by TDSF in 1992,and TDSF determined that the well was not contaminated.

3.1.4 Sensitive Ecosystems

There is a wetland area approximately 1.5 miles northwest of theSite formed by the North Fork and Wolf rivers. The State ofTennessee considers both rivers and wetlands area as a sensitiveenvironment. There are no endangered species or wildlifemanagement areas in the area of concern. There are threeintermittent streams near the Site. Two are located to the easton the elementary school property and the other is west of theSite on city property. At the time of the FI, January 1994, allintermittent streams contained water. The streams do not reachthe wetlands and are not considered a threat to the area.

3.1.5 Meteorology

Net precipitation near the Site is 52 inches per year, with anone year 24-hour rainfall event of 3.4 inches. Above averagerainfall is characteristic of winter months with summer monthsbeing relatively dry. The average wind speed is six to ten milesper hour from the south. Annual mean maximum and minimumtemperatures associated with this area are 70°F and 53°Frespectively.

3.2 SOURCE, NATURE, AND EXTENT OF CONTAMINATION

3.2.1 Sample Locations

The EE/CA Field Investigation was conducted at the Chemet Site onJanuary 25 and 26, 1994. The investigation included thecollection of surface water, sediment, surface soil, andsubsurface soil samples.

11•"

r Q 0 n 1 < Record of DecisionJ 7 U U I o Chemet Company Site

Samples were collected from locations on and off Site using a100-foot grid system. Composite surface soil and compositesubsurface soil samples were collected from each grid exceptwhere the grid contained a surface water feature. Surface waterand sediment samples were collected from areas that included theon-site settling ponds, an intermittent stream to the west, andtwo intermittent streams to the east. Soil samples werecollected in a 45°, 135°, 225°, and 315° angle with respect tonorth.

3.2.2 Analytical Results of Sample Collection

Before the removal activities, lead was detected in the surfacesoil and in the subsurface soil on-site. Concentration levelsranged from 250 mg/kg (ppm)(part per million ppm) to 3300 mg/kg(ppm) in the surface soils/sediments and 25 mg/kg (ppm) to 650mg/kg (ppm) in the subsurface soils.

The distribution of arsenic and lead was very similar throughoutthe study area. Arsenic was detected in surface soils on-site atconcentrations ranging from 6 mg/kg (ppm) to 440 mg/kg (ppm) .Arsenic was detected in subsurface soils on-site atconcentrations that ranged from 8.1 mg/kg (ppm) to 95 mg/kg(ppm).

Antimony was detected in approximately 80% of the samplescollected. The areal distribution of antimony followstopographical reliefs leading away from the site.The only area unaffected by antimony was north of the bleachersand baseball field. Antimony levels in soils to a depth of 12inches ranged from a detection level of 11 mg/kg (ppm) to a levelof 12,000 mg/kg (ppm), except the removed soils stored inBuilding #2 that contained antimony at 25,000 mg/kg (ppm).

3.3 CONFIRMATION SAMPLE RESULTS

The primary contaminant at the Chemet Site was lead. EPAguidance recommends a screening level for lead in soil forresidential land use of 500 mg/kg (ppm) . Screening levels arenot cleanup goals; rather, screening levels may be used as atool to determine which sites require further study. EPAguidance further states those levels of contamination above thescreening level would not automatically require a removal action,nor designate a site as contaminated. In the case of this Site,a cleanup goal for lead was established at 500 mg/kg (ppm) . Theremoval activities of lead have also reduced the arsenic andantimony levels to health protection concentrations.

LEAD - EPA recommends that residential areas have lead levels

12

5 9 0017 Record of DecisionChemet Company Site

in surface soil less than 500 mg/kg (ppm) . The confirmationsamples taken after the removal activities verified the leadlevels in the exposed surface areas averaged 42.9 mg/kg (ppm) forthe Site. The samples ranged from 15 mg/kg - 110 mg/kg.

ARSENIC - Surface soil health-based screening values inresidential areas for arsenic are 23 mg/kg (ppm) and 610 mg/kg(ppm) for industrial areas. The confirmation samples taken afterthe removal activities verified the arsenic levels exposedsurface areas averaged 20.2 mg/kg (ppm) for the Site. Thesamples ranged from 6 mg/kg - 51 mg/kg (ppm) .

ANTIMONY - Surface soil health-based screening values inresidential areas for antimony are 31 mg/kg (ppm) and 820 mg/kg(ppm) for industrial areas. The confirmation samples taken afterthe removal activities verified the antimony levels exposedsurface areas averaged 107.1 mg/kg (ppm) for the Site. Thesamples ranged from 5 mg/kg - 330 mg/kg (ppm) .

After the confirmation samples were taken, further risk reductionwas achieved by applying six-inches of clean fill dirt to theentire excavation area. The clean soil was stabilized by theapplication of grass seed and fertilizer.

4.0 SUMMARY OF REMOVAL ACTIVITIES

The signing of the Action Memorandum by EPA on August 18, 1994,authorized the spending of Federal Superfund monies to cleanupthe Chemet Site. EPA assigned OHM Corporation to perform theremoval actions. Removal activities were initiated on August29, 1994 at the Site. These activities are described below:

* Phase I of the removal activities consisted of excavating,segregating, and categorizing the contaminated soil over theentire Site. The contaminated areas that reached the ball fieldof the LaGrange-Moscow Elementary School were the first areasaddressed (figure 6, areas BFN & BFS) in the removal activities.A minimum of six-inches of soil was excavated from the entireSite. Those areas closes to the ball field were then sampledfirst, and the confirmation samples verified the areas meetcleanup goals. Approximately six-inches or more of clean filldirt was place on the entire areas of BFN & BFS. Finally, thoseareas (BFN/BFS) were seeded with tall fescue grass.

Samples from the stockpiles on-site were sent to the laboratoryfor determination of proper disposal methods. The results of thelaboratory analysis verified that most of the contaminated soilcould be disposed of in a licensed solid waste landfill.Contaminated soil previously stored in an on-site building,

13

5 9 0018Record of DecisionChemet Company Site

needed to be disposed of in a licensed hazardous waste landfillbecause of a higher concentration of heavy metals. The twoabandoned tractor trailers were pressured washed and removed fromthe Site.

* Phase II of the removal activities consisted of the disposalof over 20,000 tons of nonhazardous contaminated soil in theSouth Shelby Landfill, Memphis, TN (table 1). An additional 600tons of hazardous soil were disposed of by the LaidlawEnvironmental Services, Pinewood, SC. Laboratory chemicals on-site were inventoried, segregated into compatible groups, labpacked, and disposed of properly. Approximately 4800 tons ofcontaminated metal were pressured washed and recycled by alicensed vendor. Over 120 drums of slag and 37 boxes of raw orewere categorized and disposed of properly. The on-site buildingswere demolished, pressured washed, and disposed. The on-siteprivate well was closed according to State regulations.

After the contaminated soil had been disposed of and confirmationsampling verified that on-site soil were below cleanup levels,the entire Site was backfilled with a six-inch layer of cleansoil. Finally, the Site was seeded with tall fescue grass andthe damaged areas of the perimeter fence were repaired. Theremoval activities were completed March 23, 1995. The total costof cleanup was 1.3 million dollars.

EPA recommends that no further Federal cleanup action be taken atthe Chemet Company Site. The Removal Activities and subsequentsampling of the surface soil confirmed that no hazardoussubstances, pollutants, or contaminants remain on-site exceedingconcentrations that will restrict unlimited use of the Site orthreaten human health through unlimited exposure. Sampling showsthat the groundwater is not contaminated. Furthermore, since EPAhas removed the contaminated soil, it no longer poses a threat togroundwater. The additions of clean soil and planting of grasshave reduced the risk of human intake or exposure to contaminatedsoil through direct contact with the soil or wind blown dust.EPA has determined that the response at this Site is complete.Therefore, the Site now qualifies for inclusion on theConstruction Complete List.

14

PBt PBII

Confirmation SumptoR«tuNimg/Kg

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Grid*BFNBFSFBIPBIIHRNW1HRCNB2WRHRCSMRS

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i WE8TON TAT ACTIVITY: Sampling Qrlda

5

CHEMETSITE_Nonhazardous Wi

9 0020 TABLE 1

32Dec9413 Dec 9414 Dec 9415 Dec 9419 Dec 9420 Dec 94|21Dec944 Jan 955Jan959 Jan 9510 Jan 9511 Jan 95^12 Jan 9517 Jan 9520 Jan 9523 Jan 9524 Jan 9525 Jan 9526 Jan 9522Feb9523Feb9524Feb951 Mar 952 Mar 959 Mar 9510 Mar 95

Arnold TruckingArnold TrackingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TrackingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TrackingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TruckingArnold TrackingArnold TruckingArnold Tracking

South Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby Landfill, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby Landfia, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby 1-amJRH, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD. Memphis. TNSouth Shelby LandfiD, Memphis, TNSouth Shelby Landfill, Memphis. TNSouth Shelby LandfiD. Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby Landfin, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby Landfill, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD, Memphis, TNSouth Shelby LandfiD. Memphis, TNSouth Shelby Landfin, Memphis, TN

001001-001020 1 19001021 - 001042001043-001063001066-001081001082-001135001136-001180001181-001216001217-001236001237-001276001277-001289001290-001327001328-001338001339-001342001343-001356001357-001370001371-001396001397-001435001436-001461001462-001465001466-001516001517-001573001574-001605001606-001637001638-001687001689-001731001732-001737

20221654453620401338114

14142639264

5157313250436

47256]577.854695437158

1331.741156.059314157037

101756418.71

1105.722723411225382383695376759

1129.62750.0611355

1481.891639.01849.15869.1

1489.75127729

154.6

Hazardous Waste

12 Dec 94 Robbie D. Woods UidlawEnvir. Svs, Pinewood, S.C.13 Dec 94 Robbie D. Woods Laidlaw Envir. SUE, Pinewood, S.C 00006-00017 1016 Jan 95 Robbie D. Woods UkflawEnvir. Svs, Pine wood, S.C 00018-0002417 Jan 95 Robbie D. Woods Laidlaw Envir. Svs, Pinewood. S.C19 Jan 95 Environmental Trans. Laidlaw Envir. Svs, Mfflinf

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5 0021 Record of DecisionChemet Company Site

APPENDIX A

18

5 9 0022V

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 4

345 COURTLAND STREET. N.E.ATLANTA. GEORGIA 30365

January 25, 1996

Trent J. Hancock815 Linwood Dr.Rossville, TN 38066

Dear Mr. Hancock:

Thank you very much for your comments and concerns about theChemet Company Site. Before I answer your questions, I wouldlike to comment on the fast and successful clean up of the Site.We (EPA) are very concerned about the Site's close proximity tothe LaGrange-Moscow Elementary School, so once the Site wasfinalized on the NPL and eligible for Superfund monies, wedecided to clean up the Site through the Superfund AcceleratedClean up Model (SACM). In applying this procedure, Chemet wascleaned up in record time. The support I received from thecommunity, state and local government and the media wastremendous in securing funds from EPA Headquarters andsuccessfully cleaning up the Site.

Question 1

Why was the Chemet plant allowed to operate in such a haphazardmanner for a period of time long enough to cause hazardous levelsof heavy metals to accumulate?The Tennessee Department of Air Pollution Controls issued apermit to the owner/operator of the facility to use his furnaceson the Site. No violations of any regulations were documented.The Tennessee Department of Solid Waste Management issued apermit to the owner/operator to disposed of some of the waste inthe Fayette County Landfill. This permit was withdrawn in June1989 after several samples found regulatory limits exceeded forseveral metals. The State of Tennessee issued a Commissioner'sOrder on March 19, 1990, directing the owner/operator to clean-upthe Site. The owner/operator was unsuccessful in his effort tocomply with the Order. At that time the Site was referred to theU.S. EPA.

Question 2

Why did the EPA allow this company to create an area that wouldeventually cost millions to clean up?

The owner/operator of the site had to have the appropriate

5 9 0023

permits, however, that does not protect the environment 100%.The site (as with most National Priority List (NPL) sites) wasreferred to EPA by the State of Tennessee.

Question 3

Why was the State of Tennessee allowed to build an elementaryschool in such close proximity to a known toxic waste site?

That was decision made by the Fayette county school officials.

Question 4

Why did the BPA wait for such a long time before taking clean upaction at the site?

The site was finalized on 'the NPL in May 1994. Until that timewe could not spend trust fund monies on remedial action at theSite. The Chemet site was cleaned up under a program calledSuperfund Accelerated Clean up Model, and is one of the fastestNPL site to be cleaned up in the country. Clean up of the sitebegan in August 1994 and ended March 1995. The average clean uptime for a NPL site is 7-10 years.

Question 5

How do we know the site is truly safe?

The site was thoroughly sampled and characterized before clean upactions started. Two Public meetings were held before clean upactions started (January 1994 and May 1994) to inform thecommunity of the site, levels of contamination and how the sitewould be cleaned up. Once the clean up actions endedconformations samples were taken and showed that contaminationslevels were below clean up goals. All records are available atthe repository located in the library at the Lagrange-MoscowLibrary.

If you have any further questions, you can contact me at 404-347-3555 Ext. 2033.

Sincere

Robert WestRemedial Project Manager