August 10, 2016 Mr. Terry Stilman On-Scene Coordinator U.S. Environmental Protection Agency, Region 4 61 Forsyth Street, SW, 11th Floor Atlanta, Georgia 30303 Subject: Final Removal Investigation Letter Report Middle Georgia Speedway Sand Blaster EPA Contract No. EP-S4-14-03 Technical Direction Document No. TT-02-022 Dear Mr. Stilman: The Tetra Tech Superfund Technical Assessment and Response Team (START) is submitting this letter report summarizing soil screening and sampling conducted on June 9, 2016 at the Middle Georgia Speedway Sand Blaster (MGS) site in Byron, Peach County, Georgia. This report includes five enclosures and one attachment. Enclosure 1 contains figures illustrating the site location, site layout, and sampling locations. Enclosure 2 contains tables summarizing X-ray fluorescence (XRF) screening and analytical results. Enclosure 3 provides a photographic log of sampling activities. Enclosure 4 contains a copy of the Tetra Tech START logbook notes. Enclosure 5 contains a copy of the Tetra Tech START data validation report. Attachment 1 contains the laboratory data package. BACKGROUND The MGS site, formerly known as Old Byron Motor Speedway, is located at 4015 Highway 41 North, Byron, Peach County, Georgia (see Figure 1 in Enclosure 1). Please note, the TDD incorrectly states the county as Douglas; however, the site is located in Peach County. According to Tim Thornton, the property owner and responsible party (RP), sand blasting media was transported from U.S. Technology Aerospace Engineering, in Byron, Georgia, in bags or barrels to U.S. Technology in Macon, Georgia. The sand blasting media was removed from the containers and placed into dumpsters, which were transported back to Peach County and spread on roads as filler at the MGS site. Mr. Thornton explained the material was spread between three main roadways around the outside of the Middle Georgia Speedway racetrack. It was also used in 55-gallon drums as barriers for the infield pit area. According to Mr. Thornton, screening results for the material did not exceed the May 2016 U.S. Environmental Protection Agency (EPA) Regional Screening Levels (RSL). The site was reported to the EPA for suspected improper dispersion of lead-based sand blast media. EPA tasked Tetra Tech START to conduct an investigation of metals compared to respective industrial RSLs to determine if a removal is warranted. Tetra Tech START is not aware of any previous investigations at the site and no historical data of the sand blasting media was available for review. REMOVAL INVESTIGATION ACTIVITIES On June 9, 2016, EPA On-Scene Coordinators (OSC) Terry Stilman and Christopher Tripp and Tetra Tech START, arrived on site to conduct XRF field screening of surface soils and collect surface soil samples. Tetra Tech START used a XRF to screen locations in situ to gauge concentrations of existing metals present in the sand blasting material. Observed levels were lower than anticipated (below both industrial 1955 Evergreen Blvd., Suite 300, Duluth, GA 30096 Tel 678.775.3080 Fax 678.775.3138 www.tetratech.com Mr. Terry Stilman August 10, 2016 Removal Management Levels [RML] and RSLs); therefore, the EPA OSC elected to conduct in situ soil screening in general accordance with the EPA Region 4 Science and Ecosystem Support Division (SESD) Field Branches Quality System Technical Procedures (FBQSTP) for Field X-Ray Fluorescence Measurement (SESDPROC-107-R3), dated December 2015. This deviated from the Sampling and Analysis Plan (SAP) and Quality Assurance Project Plant (QAPP) dated June 7, 2016. The EPA OSC approved this deviation based on the observed low concentrations, thus reducing the scope and time spent for this investigation. Tetra Tech START divided the MGS site into three areas (Road 1 [R1], Road 2 [R2], and Road 3 [R3]) based on criteria of sand blast media placed on three roadways, as shown in Figure 2 of Enclosure 1. The primary metals of concern were arsenic, cadmium, chromium, and lead. Tetra Tech START used a XRF manufactured by Niton to screen for sampling locations. A brief summary of the XRF screening procedure is outlined below:    Area R1 – R1 is approximately 440 feet long, oriented to the north/south and located west of the racetrack. Tetra Tech START screened R1 every 20 feet using the XRF with a clear plastic bag protecting the screening window from cross contamination. XRF screening results revealed that several locations, evenly dispersed across R1, contained arsenic exceeding the industrial EPA RSL of 3 milligrams per kilogram (mg/kg); therefore, grab soil samples were collected at approximately 60-foot intervals across R1. Neither cadmium nor lead exceeded their industrial EPA RSLs of 980 mg/kg and 800 mg/kg, respectively. XRF screening results are summarized below: o Chromium ranged from below the instrument detection level (10 parts per million [ppm]) to 322 ppm. o Cadmium ranged from below the instrument detection level (8 ppm) to 48 ppm. o Lead ranged from below the instrument detection level (3 ppm) to 393 ppm. o Arsenic ranged from below the instrument detection level (7 ppm) to 17 ppm. Area R2 – R2 is approximately 700 feet long, oriented to the east/west, and located south of the racetrack. Tetra Tech START and the EPA OSC determined the screening interval could be extended to 50 feet without compromising data quality. XRF screening results indicated several areas containing the highest chromium concentrations observed across the site; therefore, Tetra Tech START collected grab soil samples at approximately 100-foot intervals. A brief summary of XRF screening results is provided below: o Chromium ranged from 202 ppm to 5,129 ppm. o Cadmium ranged from below the instrument detection level (6 ppm) to 74 ppm. o Lead ranged from 12 ppm to 112 ppm. o Arsenic ranged from below the instrument detection level (6 ppm) to 11 ppm. Area R3 – R3 is approximately 950 feet long, oriented to the east/west, and located north of the racetrack. Tetra Tech START collected in situ XRF readings every 50 feet and only arsenic was observed above industrial EPA RSLs. Tetra Tech START collected grab soil samples in approximately 50-foot intervals. A brief summary of XRF screening results is provided below: o Chromium ranged from 86 ppm to 812 ppm. o Cadmium ranged from below the instrument detection level (6 ppm) to 269 ppm. o Lead ranged from 30 ppm to 322 ppm. 2 TDD No. TT-02-022 Middle Georgia Speedway Sand Blaster Mr. Terry Stilman August 10, 2016 o Arsenic ranged from below the instrument detection level (8 ppm) to 19 ppm. Figure 3 in Enclosure 1 depicts the three roads (R1, R2, and R3) where Tetra Tech START used the XRF to screen in situ surface soils and Table 1 in Enclosure 2 provides XRF screening results. Tetra Tech START collected grab soil samples from 28 locations along the three areas of interest. Soil samples were collected from 0 to 3 inches below ground surface in general accordance with EPA Region 4 SESD FBQSTP for Soil Sampling (SESDPROC-300-R3), dated August 2014. Below is a brief summary of soil sampling procedures:  Tetra Tech START used clean, dedicated stainless steel spoons to obtain the soil, which was placed and homogenized in an aluminum pan, and then containerized in laboratory-supplied containers.  Tetra Tech START immediately placed the samples on ice inside of a cooler maintained by Tetra Tech START until relinquished to the analytical laboratory. ANALYTICAL RESULTS Tetra Tech START procured and submitted soil samples to Gulf Coast Analytical Laboratories, (GCAL), located in Atlanta, Georgia. GCAL analyzed samples for metals using the EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846) Method 6020A, Inductively Coupled Plasma-Mass Spectrometry; EPA SW-846 Method 7471B, Mercury in Solid or Semisolid Waste (Manual Cold-Vapor Technique); and EPA SW-846 Method 7470A Mercury in Liquid Waste (Manual ColdVapor Technique). Tetra Tech START performed a Stage 2A validation of the laboratory data package in accordance with the Environmental Protection Agency (EPA) Guidance for Labeling Externally Validated Laboratory Analytical Data for Superfund Use (January 2009). Analytical data was evaluated in general accordance with the EPA National Functional Guidelines (NFG) for Inorganic Superfund Data Review (August 2014) data validation guidance document, as well as the above referenced methods (see Enclosure 5 and Attachment 1). Overall, most of the data can be used as reported. Rejection of data was required for one selenium result in sample MGS-BKGD. The rejected selenium result is due to no recovery in the matrix spike/matrix spike duplicate (MS/MSD) and possibility of matrix interference. Tetra Tech START believes this does not affect the other samples due to the heterogeneity of site soils. This investigation focused on sampling areas with observed sand blasting material; however, the rejected data is from the background sample, which did not contain sand blasting material. Furthermore, no other quality control issues were noted in the data. Some results are qualified due to exceedances in field blanks and MS/MSDs. The Stage 2A data validation report is provided in Enclosure 5. Please note, the laboratory reported results in micrograms (ug/kg). A review of laboratory analytical results indicate that metals concentrations did not exceed their respective EPA RML therefore EPA RSLs were used as comparison criteria. Cadmium and lead concentrations in the 28 soil samples did not exceed their EPA RSLs of 980 mg/kg and 800 mg/kg, respectively, for industrial soil. There is no established industrial RSL for chromium. Laboratory analytical results revealed two samples, MGS-R1-K and MGS-R2-B Dup, contained arsenic above the EPA RSL of 3 mg/kg for industrial soil. Analytical results exceeding EPA RSLs for industrial soil are summarized below: 3 TDD No. TT-02-022 Middle Georgia Speedway Sand Blaster Mr. Terry Stilman August 10, 2016  Sample MGS-R1-K contained arsenic at a concentration of 3.730 mg/kg.  Sample MGS-R2-B-Dup contained arsenic at a concentration of 3.590 mg/kg. The original sample, MGS-R2-B contained arsenic at a concentration of 2.830 mg/kg. A brief summary laboratory analytical results for each area is summarized below:    Area R1 – Tetra Tech START collected seven grab soil samples, approximately every 60 feet, across R1. Laboratory analytical results identified one sample, MGS-R1-K, as having arsenic exceeding its industrial EPA RSL of 3 mg/kg. Below are laboratory analytical concentration ranges in Area R1 for the four primary contaminants of concern at the MGS site: o Chromium ranged from 50.4 mg/kg to 139 mg/kg. o Cadmium ranged from 2.49 mg/kg to 40.2 mg/kg. o Lead ranged from 7.35 mg/kg to 280 mg/kg. o Arsenic ranged from 1.71 mg/kg to 3.73 mg/kg. Area R2 - Tetra Tech START collected 10 grab soil samples, approximately every 100 feet, across R2. Laboratory analytical results identified one sample, MGS-R2-B-Dup, as having arsenic exceeding its industrial EPA RSL of 3 mg/kg. Below are laboratory analytical concentration ranges in Area R2 for the four primary contaminants of concern at the MGS site: o Chromium ranged from 40.6 mg/kg to 236 mg/kg. o Cadmium ranged from 5.38 mg/kg to 82.6 mg/kg. o Lead ranged from 16.0 mg/kg to 204 mg/kg. o Arsenic ranged from 1.20 mg/kg to 3.59 mg/kg. Note the duplicate sample for MGS-R2B contained the elevated concentration of arsenic. The original sample contained arsenic at a concentration of 2.83 mg/kg. Area R3 - Tetra Tech START collected 10 grab soil samples, approximately every 100 feet, across R3. Laboratory analytical results did not identify any contaminant concentrations above EPA RSLs for industrial soil. Below are laboratory analytical concentration ranges in Area R3 for the four primary contaminants of concern at the MGS site: o Chromium ranged from 32.2 mg/kg to 137 mg/kg. o Cadmium ranged from 12.6 mg/kg to 279 mg/kg. o Lead ranged from 29.5 mg/kg to 196 mg/kg. o Arsenic ranged from 0.569 mg/kg to 1.19 mg/kg. Additionally, the RP requested that EPA provide split samples for all sampling locations. Tetra Tech START relinquished split samples to Georgia Environmental Management, the RP’s environmental consultant. Figure 3 in Enclosure 1 depicts soil sampling locations and Table 2 in Enclosure 2 provides a summary of laboratory analytical results. 4 TDD No. TT-02-022 Middle Georgia Speedway Sand Blaster