AW Sate. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

53 2 REGION 4
a is" ATLANTA FEDERAL CENTER
9s 61 STREET

4?41: ?1016?? ATLANTA, GEORGIA 30303?8960

August31, 2017

Lucius E. Elsie C., Jr. Library

ATTN: Amber Halter, Adult Services Librarian
501 Poplar View Parkway

Collierville, TN 38107

SUBJECT: First Five-Year Review Report Smalley-Piper Superfund Site

Dear Ms. Halter:

The US. Environmental Protection Agency, Region 4, is currently working with the Lucius E. 
Elsie C., Jr. Library to house an Information Repository/Administrative Record for the Former
Custom Cleaners Site, Shelby County, Tennessee. Enclosed is a copy of the ?rst Five-Year
Review Report for the Site. Please add this document to the Administrative Record for the Site.

We appreciate your continued effort to support our Agency in housing these documents for
public review. If you have any questions or comments, please call me at (404) 562-8831 or

e-mail 

Sincerely,

Kerisa R. Coleman-
Community Involvement Coordinator

Enclosure: First ive-Year Review Report for
Smalley-Piper Superfund Site, July 2017

cc: Randy Bryant, Remedial Project Manager 

lnternet Address (URL) - 
Recyled/Recyclable - Printed with Vegetable Oil Based Inks on Recycled Paper (Mmimum 30% Postconsumer)

FIRST IVE-YEAR REVIEW REPORT FOR
SMALLEY-PIPER SUPERFUND SITE
SHELBY COUNTY, TENNESSEE

o??n 343%

4t PROTEG

Cg

 

?\?oumms?

4? 

of.

?Jr

JULY 2017

Prepared by

U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia

 

 

 

 


Franklin E. Hill, Director 
Superfund Division 

 



1106791 5

Table of Contents

LIST OF ABBREVIATIONS ACRONYMS iv
I. INTRODUCTION I
Site Background 1
IV E-YEAR REVIEW SUMMARY FORM 2
II. RESPONSE ACTION - 3
Basis for Taking Action 3
Response Actions 4
Status of . 5
Systems Operations/Operation Maintenance 9
PROGRESS SINCE THE 10
IV. IVE-YEAR REVIEW PROCESS 10
Community Noti?cation, Involvement Site Interviews 10
Data Revrew 11
Site Inspection 14
V. TECHNICAL ASSESSMENT l4
QUESTION A: Is the remedy ?mctioning as intended by the decision documents? .14
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action
objectives (RAOs) used at the time of the remedy selection still valid? 15
QUESTION C: Has any other information come to light that could call into question the -
protectiveness of the remedy? 16
VI. 16
OTHER FINDINGS 16
VII. PROTECTIVENESS STATEMENT 17
NEXT REVIEW 17
APPENDIX REFERENCE LIST A-l
APPENDIX CURRENT SITE STATUS.-. 
APPENDIX SITE CHRONOLOGY . C-I
APPENDIX SITE MAPS 
APPENDIX - SITE INSPECTION CHECKLIST E-l'
APPENDIX - PRESS NOTICE 
APPENDIX SITEINSPECTION PHOTOS G-l
APPENDIX INTERVIEW FORMS H?l
APPENDIX I DETAILED ARARs REVIEW TABLES 
APPENDIX HISTORICAL GROUNDWATER DATA J-2
APPENDIX SCREENING LEVEL RISK REVIEW K-l
APPENDIX - RULES AND REGULATIONS OF WELLS IN SHELBY COUNTY L-l
Tables
Table l: COCs, by Media 4
Table 2: Summary of Planned and Implemented Institutional Controls (ICs) 7
Table 3: Costs over the YR Period 10
Table 4: Wells Exceeding Remedial Goals for Total Chromium and Hexavalent Chromium 12
Table C-l: Site Chronology C-l
Table 1?1: ARAR Review . . I -I
Table 1-1: Historical Groundwater Data J-l

Table K?l: Health Evaluation of Groundwater Cleanup Goals K-l
Table Surnn1ary of RSL Calculator Results K-4
Figures

Figure 1: Institutional Control Map 8
Figure 2: Detailed SiteMap 13
Figure D-l: Site Vicinity Map D-l
Figure J-l: Estimation of Hexavalent Chromium in Groundwater April 2016 J-7
Figure 1-2 Estimation of Total Chromium in Groundwater? April 2016 J-8



 

 

LIST OF ABBREVIATIONS ACRONYMS

AOC
ARAR

CERCLA

CFR
000
CRP
EPA
FYR
HQ
IC
ug/L
Ins/kg
MW
NCP
NPL

0U

- PRP
RAO
RCRA

ROD
RSL
TDEC


Administrative Order on Consent 
Applicable or Relevant and Appropriate Requirement
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations

Contaminant of Concern

Chemical Reduction and Precipitation

United States Environmental Protection Agency

ive-Year Review -

Hazard Quotient

Institutional Control

Micrograms per Liter

Milligrams per Kilogram

Monitoring well I

National Contingency Plan

National Priorities List

Operation and Maintenance

Operable Unit 

Potentially Responsible Party

Remedial Action Objective

Resource Conservation and Recovery Act

Remedial Investigation and Feasibility Study

Record of Decision

Regional Screening Level

Tennessee Department of Environment and Conservation
Unlimited Use and Unrestricted Exposure

iv

This page is intentionally blank

 

I. INTRODUCTION

The methods ?ndings and conclusions of reviews are documented in FYR reports such as this one. In
addition, YR reports identify issues found during the review, if any, and document recommendations to
address them.

The US. Environmental Protection Agency is preparing this YR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan Code of Federal Regulations (CFR) Section 
and considering EPA policy.

This is the ?rst YR for the Smalley?Piper Superfund site (the Site). The triggering action for this
statutory review is the on-site construction start date of the remedial action. The YR has been prepared
due to the fact that hazardous substances, pollutants or contaminants remain at the site above levels that
allow for unlimited use and unrestricted exposure 

The Site consists of one operable unit (0U) that will be addressed in this FYR. addresses the entire
site, including contaminated soil and groundwater. 

The EPA led the FYR. Participants included EPA Remedial Project Manager Randy Bryant, EPA
Community Involvement Coordinator Kerisa Coleman, Tennessee Department of Environment and
Conservation (TDEC) representative Jamie Woods, and EPA contractor support staff Johnny
Zimmerman-Ward and Sarah Alfano from Skeo. The review began on 10/18/2016.

Site Background

The 9?acre Site is located on Highway 72 in Collierville, Shelby County, Tennessee. Commercial and
industrial land uses as well as the Norfolk Southern Railroad surround the Site (see Figure D-l 
Residential areas, including single-family homes and a mobile heme park, are located about a quarter
mile southeast (upgradient) of the Site. Surface water draining from the southern boundary of the
property enters the municipal sewer system and connects to the Wolf River drainage basin. Surface
water draining ?-om the Site?s northern and eastern boundaries is directed to Nonconnah Creek, and
subsequently to the Wolf River about 3 miles away, via overland ?ow. The Memphis Sand Aquifer
underlays the Site and is utilized by Collierville for municipal purposes. The aquifer is primarily
recharged in the vicinity of the Site from in?ltration of precipitation. No upper con?ning layer is
present. Gromdwater fin-z: in the Memphis Sand Aquifer is generally to the west-northwest near the

Site.

From 1955 until 1982, Paul Piper, Sr. owned the Site. In 1982, site ownership transferred to Piper
Industries, Inc. In 1985, site ownership transferred to Claudia Piper and Paul Piper, Sr., in Trust. A?er
Paul Piper, Sr., died, the property was distributed to his children and Claudia Piper in Trust with Claudia
Piper as Trustee of all of the Trusts, which currently own the site property.

From the 19505 through the 1980s, the site owner, Paul Piper Sr., leased the site property to various
corporations, including Piper Industries, Inc., Piper Brothers of Collierville and Sweeco, Inc. Piper



Industries, Inc. closed in December 1986, and Piper Brothers of Collierville and Sweeco are now .
defunct. Over the years, these companies made farm tools and also manufactured magnesium battery
casings on site in the 19705. The battery casings went through a production process consisting of several
vats that contained caustic soda, acetic acid, chromic acid and water. Operations sent liquid wastes into
an underground pipe that discharged to two open equalization ponds (East Pend and West Pond, located
just east of the facility buildings). In the ponds, operators treated the spent chromic acid by injecting
liquid sulfur dioxide. Then the treated liquid ?owed into surface water drainage ditches. Facility
operators abandoned the equalization ponds in the 19803 and back?lled them with soil.

From 1992 to 2004, Piper Industrial Coatings, Inc. leased a portion of the property. The company
manufactured tools and used an iron powder containing chromium in its manufacturing process. After
TDEC determined that facility outfall levels of hexavalent chromium did not meet the Tennessee
General Water Quality Criteria for Fish and Aquatic Life, TDEC terminated the company?s National
Pollutant Discharge Elimination System permit. Lund Coating Technologies, Inc. purchased assets and
equipment from Piper Industrial Coatings in 2004 and leased a portion of the property until 2007.

All manufacturing operations at the Site ceased in 2007. Former industrial process buildings remain in .
the central portion of the Site. A wooded area and the groundwater treatment facility are on the west end
of the Site. A vacant paved parking lot abuts the former industrial buildings. The property with the
treatment facility, abandoned industrial buildings and parking lot is fenced and the perimeter is
vegetated. Beyond the fencing, on the east end of the Site, is a self-storage facility and a tire and
automotive store. Refer to Appendix A for additional resources and Appendix for the Site?s
chronology.

FIVE-YEAR REVIEW SUMMARY FORM

Site Name: Smalley-Piper .

EPA 78

 

 

 

City/County: Collierville/Shelby

 

NPL Status: Final

Multiple Has the site achieved construction completion?
No No

    

Lead agency: EPA
Author name: Randy Bryant (EPA) and Sarah Alfano (Skeo)

Author af?liation: EPA and Skeo

 

 

 

 

 

 

 

 

Review period: 10/18/2016 - 5/ 14/2017
Date of site inspection: 10/20/2016
Type of review; Statutory

 

 

 

Review number: I
Triggering action date: 5/14/20] 2
Due date (?ve years a?er triggering action date): 5/14/2017

 

 

 

 

 

ir. RESPONSE ACTION SUMMARY

Basis for Taking Action

In August 2001, sampling at two Town of Collierville public drinking water wells about one-half mile
west of the Site showed low levels of total chromium and hexavalcnt chromium. The on-site and Town
of Collierville wells were screened in the Memphis Sand Aquifer. Due to the presence of chromium in
the near-site samples, the State of Tennessee has required that the Town of Collierville periodically
monitor Wmimmeem?nv??gamm -
determine the nature and extent of contamination and health risks posed by the Site, starting in 2002. In
December 2003, the Town of Collierville shut down the production of the two wells closest to the Site to

make sure there is no chromium present in the water it distributes for public use.

Additional investigations found that site soils, groundwater and surface runoff contained elevated levels
of metals. On October 4, 2004, the EPA entered into an Administrative Order on Consent (AOC) for
Remedial Investigation and Feasibility Study with the Estate and Claudia B. Piper, as Trustee of
the Trusts, whereby the Estate and the Trusts agreed to perform the and reimburse the EPA's
oversight costs. Thereafter, the Estateand the Trusts commenced performance of the RI with
oversight ?'om the EPA. The EPA placed the Site on the Superfund National Prio?ties List (NPL) in
April 2005. The parties began the Site?s in 2006. The parties identi?ed the most signi?cant-
groundwater contamination in samples near the historic equalization ponds. In addition, soil
contamination was generally con?ned to the former equalization pond areas; levels of chromium were
highest in the l6.5-to-20.5-foot depth interval. The EPA assumed performance of the completion of the
upon receipt of?notice from the Estate and the Trusts on February 1, 2008, that they had ceased
implementation of the Work.

Based on the results of the Site?s ecological risk assessment, contaminated surface runoff does not pose
a threat to the nearby Nonconnah Creek, which is used for recreational ?shing. The assessment
concluded that no remediation for ecological concerns was necessary.

Investigative studies from 2001 to 2008 included ?eld data acquisition and laboratory analyses to
evaluate the nature and extent of site contamination, including assessments of human health risks based
on current/future on-site and off-site residents and future construction workers on site. Studies identi?ed
contaminants of concern (COCs) in soil and groundwater. Hexavalent chromium was the only?COC
identi?ed in soil. Antimony, hexavalent chromium, total chromium and iron were identi?ed as the Site?s
groundwater COCs (see Table 

Response Actions

The EPA selected the Site?s ?nal remedy in the Site?s 2008 Record of Decision (ROD) to address soil
and groundwater contamination. The remedial. action objectives (RAOs) listed in the ROD include:

0 Prevent or minimize human exposure to contaminated subsurface soil at concentrations above
the cleanup levels.

- Prevent or minimize human exposure to contaminated groundwater at concentrations above the
cleanup levels.

- Prevent ?nther migration of the contaminated groundwater plumes.

- Restore groundwater to the cleanup levels and bene?cial use.

The selected remedy included the following remedial activities:

- Excavation of contaminated soil, to the extent practicable.1

- Chemical stabilization and solidi?cation of contaminated soil.
- Off-site disposal of stabilized soil.

- Recovery of contaminated groundwater.

- Ex-situ treatment of contaminated groundwater.

- Disposal of treated water.

- In-situ soil ?ushing.

- Implementation of institutional controls for groundwater.

ROD soil and groundwater cleanup goals are listed in Table 1.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table l: COCs, by Media
cm: I Media ROD Cleanup Goal Cleanup Goal Basis
LHexavalent chromium I groundwater 47 pg/L I noncancer HQ for child resident
I
Total chromium groundwater 100 rig/L MCLs
Antimony groundwater 6 ug/L MCLs 
Iron groundwater 4,693 ug/L noncancer HQ for child resident"
- . . noncancer HQ for ?iture ?1
Hexavalent chromium 5011 876 mg/kg construction worker
Notes:
HQ hazard quotient
MCL maximum contaminant level established under the Safe Drinking Water Act.
ug/L micrograms per liter 
milligrams per kilogram . .

 

 

 

 

The 2008 ROD anticipated that excavation of contaminated subsurface soil would address the most contaminated soil at the
Site, found between 16.5 feet below ground surface and 20.5 feet below ground surface and deeper excavation would be
limited by equipment capabilities the length of the backhoe arm).

4

 

Status of Implementation

While a past and ?iture response cost settlement was reached with the Trusts to the extent they were able
to pay, the EPA has ?mded the design and construction of the remedy with assistance from TDEC. The
Site?s and 2010 remedial design investigations evaluated the extent of soil contamination in the
historic equalization ponds. The contractor conducted an additional subsurface soil investigation

in November 201 l.

The 2010 remedial design investigation veri?ed groundwater results. Samples from monitoring
well (MW) 07 and 1 exceeded 100,000 micrograms per liter (pg/L) for total chromium in the
vicinity of the historic ponds. The total chromium concentrations ranged from 140,000 rig/L to 180,000
ug/L. The source plume is focused in the top 20 feet of the saturated portion of the Memphis Sand

Aquifer on the site property.

The contractor conducted the remedial action for soil from May 2012 to September 2012. The
soil cleanup included:

0 Excavation of contaminated soil from the former wastewater pond area. Excavation depths
varied within the target area with a maximum depth of about 23 feet

- Chemical stabilization of excavated soil into a non-hazardous solid matrix.

- Transportation and disposal of the stabilized soil to a non?hazardous waste facility.

. Construction of an in?ltration gallery at the base of excavation in the former wastewater pond
area.

- Back?ll of the excavated area with clean soil.

The Soil cleanup achieved the goals established in the ROD. Approximately 6,618 tons of soil were
excavated, treated as necessary, and disposed'at the offsite facility. Less contaminated soil may remain
at depths below practical excavation limits in the former wastewater pond area. Such soil is addressed
by the soil ?ushing component of the groundwater remedy noted below.

The remedial action for groundwater will take place in phases: Phase 1A, Phase 13, Phase 2 and Phase
3. Phase 1A was constructed between September 2014 to August 2015. The Phase 1A remedy has been
operational since December 2015 and includes:

a Four shallow groundwater recovery wells to remove contaminated groundwater.
0 A source area groundwater treatment facility using conventional chemical reduction and
precipitation (CRP) and~ion exchange with a treatment capacity of 100, gallons per minute.
- DeWatering and off-site disposal of the chemical treatment residue.
. - Installation of four reinjection wells near in?ltration gallery
- Discharge of treated groundwater to the in?ltration gallery and reinjection wells to enhance the
?ushing of any remaining contaminated subsurface soil.

The subsequent phases, if implemented, may be structured as follows:

Phase IB would add four intermediate depth groundwater recovery wells (versus shallow for Phase 1A)
and use the existing groundwater treatment facility.

Phase 2 would add four more recovery wells and additional groundwater treatment capacity to address
contaminated groundwater downgradient from the Site.

Phase 3 would add four additional groundwater recovery wells and additional groundwater treatment
capacity to address contaminated groundwater ?rrther downgradient ?om the Site.

During 2017-2018, the EPA and TDEC plan to evaluate options for the downgradient portion of the
plume. The agencies will evaluate the potential for in?situ chemical or biological reduction/precipitation
methods for the plume versus the installation of off-site recovery wells and increased on-site treatment

capacity.
Institutional Control Review

The 2008 ROD requires institutional controls for groundwater and notes the need for institutional
controls for soil as per state regulation. Tennessee law requires that a property owner prepare and record
a "Notice of Land Use Restrictions" where land use restrictions are part of a remedial action on the
property. These restrictions must include information about the type, location and quantity of regulated
hazardous substances and regulated substances known to exist on the Site and speci?c restrictions on its
current or ?xture use. The Site?s 2012 Soil Remedial Action Report notes that the EPA will pursue a
restrictive covenant with the present landowner to limit on-site land use activities to those that are
consistent with the remedy. The goal is to protect the long-term integrity of the in?ltration gallery and
reinjection wells and to prohibit excavation and disturbance within the former wastewater pond area.
These institutional controls are not in place yet. However, the portion of the Site addressed by these
future institutional controls is not currently in use so there is no current means of exposure or planned
excavation in the wastewater pondarea.

In January 2001, the Shelby County Groundwater Control Board updated the Rules and Regulations of
Wells in Shelby County.2 Under these rules (Regulation 4.01C), water wells are de?ned as wells
developed for the primary purpose of producing a supply of water, regardless of the intended use of the
water supply. The rules prohibit water wells within one-half mile of the designated boundaries of a listed
federal or state CERCLA site or Resource Conservation and Recovery Act (RCRA) correCtive action
site (see Figure 1), unless the owner can demonstrate that movement of contaminated groundwater or
materials into adjoining aquifers will not be enhanced by the well. Similar location restrictions are not
Speci?ed for any other type of well. These rules allow the Shelby County Health Department to reject a
permit application for a proposed well if it will be harmful or potentially hannful to Shelby County?s
water resources.

The current inferred plume area is within the half-mile radius of the property. However, current
contaminant levels in the westernmost well and downgradient from the source exceed cleanup standards
and there may be contaminated groundwater beyond the reach of implemented institutional controls. 
This well is located in a commercial area and there are no known users of groundwater in the area. As of
January 2005, 140 wells were recorded within 1 mile of the Site. Only one of these wells was a private
water supply well and it was located northeast and upgradient of the Site. This area of Collierville has
had municipal drinking water available for over 15 years. No residents within 1 mile and downgradient
of the' Site are thought to be drinking water from a private well.

 

2 

6

 

an 

Table 2: Summary of Planned and Implemented Institutional Controls (ICs)

 

Media, Engineered

 

 

 

 

 

 

 

 

 

 

. ICs Called Title of IC
gzgg's?ngutg? ICs for in the Impacted 1c Instrument
Needed Decision Parcel(s) Objective Implemented and
based on Documents Date (or lanned)
Current Conditions 
Protect integrity of the
in?ltration gallery A
C0244A00430 constructed within the . .
Soil Yes Yes west Pond excavation and Re?mer?nwl?enam
(3024400355 prohibit excavation and ace
within the area of the
former West Pond.
I Groundwater
All site parcels . Quality Control

and off-site area Prevent human exposure to Board for Shelby

potentially contaminated groundwater County, Tennessee?s
Groundwater Yes Yes impacted by at concentrations above the Rules and

contaminated 'cleanup levels. Regulations of Wells

groundwater in Shelby County

(updated January

2001)

 

 

 

Figure 1: Institutional Control Map

 

0024400356

Ha- .. .. - 
0 0.2 0.4 0.8 Liam!
Miles

a Approximate Site Boundary .Haxavalant Chmmium
- . . lmconcenlralion Contours
swissfopo,'ANQ Tale Atlas, Firsmmarfcan, UNEP-WCMC, uses, the mm" 

. 5.0m mil.
618 User Community, 2008 R00, 2016 Remedial-Action Report, Black mi). Groundwater Flow ?7 tin-?1
Watch and Sheiby County, TN.

(Dashed Miminhmd)
. - Smalle -Pi er Superfund Site
(skeo 0 

NORTH Town of Collierville, Shelby County. Tennessee

 

 

-- Historic Ponds

 

 

 

 

 

 

 

 

Systems Operations/Operation Maintenance

contractor performs site inspections daily while on site for groundwater treatment. Per the
Site?s 2015 operation and maintenance plan (sourced in Appendix A), required operations
include:

Inspection of asth pavement for cracks, settling or other damage.

Collection of periodic groundwater samples. 

InSpeetion of the planted grass to verify the growth of the vegetation.

Inspection of the constructed slopes and drainage ditches for signs of erosion.

Operation of four shallow recovery wells.

Operation of lOO-gaIIOn-per-minute chemical reduction and precipitation and ion exchange
treatment modules. .

- Operation of required ancillary water and waste treatment system facilities.

- Operation of treated water discharge facilities. 

The EPA has completed the on?site construction phase of the groundwater remedy (known as Phase IA),
which includes the installation of additional monitoring wells, in?ltration gallery, reinjection wells,
shallow recovery wells, construction of the groundwater treatment plant, completion of baseline .
groundwater sampling, and startup of the on-site groundwater treatment system. An manual was
prepared for the Phase 1A groundwater remediation system (Winter Systems, 2015). It is anticipated that
manual requirements will be updated over time as operational conditions and experience dictate.

The groundwater treatment system has been operational for just over a year, so rather than
annual, costs are included below. Higher costs in January represent the initial start of the system. The
higher costs in May re?ect the start of full-scale operation a?er the installation of reinjection wells to
add discharge capacity to supplement the in?ltration gallery. The estimate for annual in the ROD
is $524,106. However, given the limited time the remedial components have been operating and the
ongoing groundwater remedy considerations, the annual average cost of should be reconsidered
once the ?ill remedy is in place and functioning.

Table 3: Costs over the FYR Period

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

22:11:,- Total Cost (rounded to the nearest $1,000)
January $187,000
February $119,000
March $100,000
April $122,000
May $221,000
June $172,000
July $171,000
August $133,000
September $143,000
October $157,000
November 316?090 
December - $255,528*
January $104385?
February $240,627?
*Did not include typical costs due to change in subcontractors
Operating the plant; resulted in delay of twice] invoices.

 

 

PROGRESS SINCE THE LAST REVIEW
This is the ?rst FYR for the Site. I

IV. FIVE-YEAR REVIEW PROCESS

Communig Noti?cation, Involvement Site Interviews

A public notice was made available by a newspaper posting, Collier-ville Herald, on December 8, 2016,
stating that there was a FYR and inviting the public to submit any comments to the EPA. The results of
the review and the FYR report will be made available at the Site?s information repository, Lucius E. 
Elsie C., Jr. Library, located at 501 Poplar View Parkway, Collierville, Tennessee 381-07.

During the YR process, interviews were conducted to document any perceived problems or successes
with the remedy that has been implemented to date. Interviews were completed during the site
inspection with project manager and a representative from the Town of Collierville?s Public
Works Department; Complete interviews are included in Appendix H. Overall, the interviewees believe
the remedy is effective and protective of human health and the environment. The remedy is?performing
as intended and there have been no complaints and few inquiries in the last ?ve years. project
manager noted that a few residents and local consultants have asked about the condition of the Site. The
Public Works Department representative stated that it would be beneficial for the EPA to hold consistent
remediation status meetings for public and local elected o?icials, to sample monitoring wells
immediately of the Site to see if groundwater quality is showing improvement near the Site,

10

 



and to provide a summary report of groundwater treatment plant operations. It is noted that the Public
Works Department receives weekly meeting minutes regarding ongoing operations at the Site.

Data Review

 

Phase 1a of the groundwater remedy has been operational since December 2015. Long-term trends
between baseline conditions and post-startup are limited since only data from one post-startup event was
available for analysis (April 2016) to compare to the baseline groundwater sampling event (December
2014).

A total of 21 active monitoring wells are associated with the Site (Figure 2). Of these 21 wells, 10 are
located signi?cantly north and northwest of the site boundary (off site), spanning almost one-half mile
northwest of the Site, in the direction of groundwater ?ow (downgradient) (Figure 2). Wells have been
installed to monitor groundwater quality in the shallow, intermediate and deep portions of the Memphis
Sand Aquifer. The contractor sampled a total of 18 monitoring wells in December 2014 to obtain
a baseline dataset of groundwater conditions at the Site prior to implementation of Phase 1A. Three of
the 21 monitoring wells (MW03, MW04, and MW12) were not sampled during the 2014 baseline
sampling event due to access limitations. The contractor sampled a total of 20 monitoring wells
in April 2016 and 21 monitoring wells in November 2016 to assess current groundwater conditions at
the Site following Phase 1A startup.

The samples included both un?ltered and'?ltered samples. The un?ltered samples represent
groundwater where suspended particulates remain in the sample while a ?ltered sample removes the
suspended particulates and represents the dissolved metal concentration in groundwater. The
concentrations in the ?ltered samples generally remained the same or lower than in the
un?ltered samples at the Site, indicating that the metals contamination is primarily in dissolved form.
All December 2014 and April 2016 samples were below the 2008 ROD remedial goals for un?ltered and
?ltered antimony and ?ltered iron. Un?ltered iron only exceeded the remedial goal in one well, 
which was not sampled in 2014 but increased from 480 ug/L in April 2010 to 160,000 ug/L in April
2016 and decreased to 3,000 pig/L in November 2016. It was noted in the Remedial Action Report that
in April 2016, the sample ?'om MW12 was turbid. The ?ltered result (480 rig/L) Was below the remedial
goal. A summary of the wells that exceeded remedial goals for un?ltered and ?ltered total chromium
and hexavalent chromium are presented in Table 4 along with a comparison to the December 2014

results.

Table 4 shows the three groundwater sampling events during 2014-2016. A comparison of the 2016

events indicates showeda assassin hararalsatsadiatal shaman inningwella handing six great: 
?wwells (MW04, MWOS, 1, MW12 and MW 15) and three off-site wells (MWZO, MW24S

andMW24I). Increases in hexavalent and total chromium were observed in three o?lsite wells MW 1 8,
MW21 and MW27D), while the remaining wells show a mixed decrease and increase in hexavalent and
total chromium. These results demonstrate the need to continue regular groundwater monitoring and to
plan appropriate actions for the downgradient portion of the plume. Appendix 1 includes a detailed
listing of analytical results for each well and ?gures depicting the interpreted plumes for both hexavalent
and total chromium. The footprint of the total chromium plume appears to fall within the larger
hexavalent plume (Appendix 1.). -

11

 

Table 4: Sampling Results for Total Chromium and Hexavalent Chromium

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Total Chromium Hexavalent Chromium
(remedial goal= 100 ngIL) (remedial goal 47 ugiL)
Well Un?ltered Filtered Un?ltered Filtered
Dec Apr Nov Dec Apr Nov Dec Apr Nov Dec Apr Nov
2014 2016 2016 2014 2016 2016 2014 2016 2016 2014 2016 2016
Ou-site Wells
- -MWMWMw-MW-Off-site Wells

MW-MW-MW-24S 34Notes:

2010 data used asbaseline since the remedial action construction prevented sampling this well in

2014.

result exceeds the remedial goal.

- result is below the remedial goal.

1 Decrease from previous event.

Increase from previous event.

 

Unchanged since previous event.

 

 

 

 

12-

 



Figure 2: Detailed Site Map

 

9?
Tu

 

900

1 800

Feet -.
Eartmtar Geographies,

 

Leienci 
Approximate Site Boundary 
- Groundwater Treatment Building
Former Facility Buildings

Sources: Esnf, OrbitaIGlobe, Gamma, GooEye,
CNESfAirbus DS, USDA, AEX, Getmapping, Aerogrid, IGN. (GP, 
swisstopo, Taia Atlas, First American; USGS. the
GIS User Communim 2008 R00, 2016 Remedial Action Report and

Deep Monitoring Wei]
Injection Welt

Recovery Wall

Shelton Monitoring Well

0


and

?Automotive-?g 
Store 

 

Groundwater Flow
Historic Ponds

Norfulk Southern Railroad

 



 

smalley-Piper Superfund Site
Tom of Colliervilie. Shelby County. Tennessee

 

kgskeo 

 

 

 

 

I 0 l. 9 I
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 infomational pumoscs only regarding the Elm1
the Site. 

13

law



5 response actions at

Site Inslgec?on

The site inspection took place on October 20,- 2016. Site inspection participants included Randy Bryant
from the EPA, Jamie Woods from TDEC, and Sarah Alfano and Johnny Zimmerman-Ward from Skeo.
The completed site inspection checklist is available in Appendix E. Site inspection photographs are

available in Appendix G. The purpose of the inspection was to assess the protectiveness of the remedy.

Site inspection participants met near the historic equalization pond area to observe the surface of the
in?ltration gallery. The area is graveled. Piezometer wells and one monitoring well are located within
the graveled area. Recovery wells, monitoring wells and injections wells are located nearby. One
piezometer well was damaged and had an orange cone next to it to ?ag it. Site inspection participants
then walked through the abandoned historic buildings, observing recovery wells, drums holding soils
and water ?'om previous sampling events, and dilapidated former facility buildings. Participants
observed the groundwater treatment building and walked through the treatment process. The
groundwater pumping and treatment system is fenced and staff is on site at all times. The property is
fenced; vegetation borders most of the Site. The Site is in good condition. No issues were observed

during the site inspection.

Skeo staff visited the Site?s information repository and found no site-related documents. The EPA
mailed two copies of the administrative record on compact disc to the repository during November 2016.

V. TECHNICAL ASSESSMENT

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

Question A Summag:

The selected remedy is excavation and ex-situ stabilization/solidi?cation of contaminated source area
soil as well as an in-situ in?ltration gallery to remediate soil contamination beyond depths of safe
excavation, disposal of treated soil at a non-hazardous waste disposal facility, and long-term on- and
offsite groundwater recovery and treatment. The soil portion of the remedy has been completed. Phase
la of the groundwater/soil ?ushing portion of the remedy is in operation. Phase 1a of the groundwater
remedy is achieving its intended function of reducing the high contaminant concentrations in
groundwater onsite. However, additional actions may be necessary to address the offsite portion of the
plume. The remedy components completed to date are functioning as intended.

Throughout 2017, the EPA and TDEC will monitor system performance to determine if groundwater
treatment system can be simpli?ed bypassing either the CRP or ion exchange modules to treat
groundwater) During 2017-2018, the EPA and TDEC will also evaluate appropriate methods, to address
the downgradient portion of the plume.

Long-term monitoring began in April 2016 for the ?rst phase (1A) of the four-phase groundwater
remedy. The monitoring wells were sampled in April 2016 and November 2016. The data from these
two events were comparedto contaminant concentrations ?-om December 2014, which represent
baseline conditions. Long-term contaminant trends are limited given that just two sampling events have
occurred since remedy startup. A comparison of the 2016 events indicates showed a decrease in
hexavalent and total chromium in nine wells, including six on-site wells (MW 04, MW05, MW08,
1, MW12 and MWIS) and three off-site wells (MWZO, MW24S and MW24I). Increases in

14

 

 

hexavalent and total chromium were observed in three off-site wells (MW18, MW21 and MW27D). The
remaining wells show a mixed decrease and increase in hexavalent and total chromium. MW27D is the
well closest to the edge of Shelby County Regulation 4.01C boundary (see Figure 1) and has high levels
of hexavalent chromium (un?ltered samples increased from 633 pig/L in 2014 to 827 rig/L in November
2016 and ?ltered samples increased from.591 rig/L in 2014 to 869 ug/L. Total chromium (un?ltered
samples increased from 680 rig/L in 2014 to 860 rig/L in November 2016 and ?ltered samples increased
from 630 rig/L in 2014 to 860 rig/L) (Table 1-1). Though the plume is not fully de?ned to determine
whether the Shelby County Regulation 4.01C boundary around the Site covers all contaminated
groundwater, there are no current exposures as per the most recent well survey in 2005. The Site is
located in a commercial area where municipal water has been offered for many years. These results
demonstrate the need for continuing regular groundwater monitoring and consideration of appropriate
methods to address the off-site portion of the plume.

costs, daily site inspections and monitoring, and remedial action reports for soil and the ?rst
two phases of groundwater remediation do not indicate any current or future problems with remedy
performance. As more time elapses ?'om the startup of the on-site groundwater treatment facility, a more
detailed assessment of the remedy?s functionality will be possible.

The EPA and TDEC have not yet implemented all the institutional controls required by the 2008 ROD.
The 2008 ROD requires institutional controls for groundwater, which are partially in place through a
Shelby County regulation restricting well installation within one-halfmile of the Site. However, off-site
groundwater contamination has not been fully delineated and may extend beyond the current boundary
of the regulated area.

The 2008 ROD notes, as per Tennessee law, the need for institutional controls for soil. They are not yet
in place. However, the soil cleanup has been completed. Also, given the daily presence of the treatment
plant stall and limited site access, such controls may not be necessary in the short term. In the long term,
consideration should be given to site conditions after completion of the remedy and whether institutional

controls are still necessary.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action
objectives (RAOs) used at the time of the remedy selection still valid?

Question Summary" 

Since the 2008 ROD, there have not been any changes to the maximum contaminant levels (MCL) for

Site COCs (Appendix I). For groundwater COCs without MCLs, the EPA selected health-based values

as goals. The reviewed (Appendix K) to detsnniae if the
values remain valid based on changes in toxicity values.

The EPA completed an update of standard default exposure factors in 2014. However, the revised
exposure factors in most cases lower the risk and thus does not affect the protectiveness of the remedy.
In addition, there have been no changes in site conditions. that would suggest the presence of new

exposure pathways.

The RAOs for soil have been met; the remedy has prevented human exposure to contaminated
subsurface soil at concentrations above cleanup levels. The groundwater remedy is being implemented

15

in phases and Phase 1a is in operation. Expected progress toward meeting the RAOs for groundwater
will be evaluated once all phases of the groundwater remedy are in place.

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

No other information calls the protectiveness of the remedy into question.

VI. 

tin ns

 

 

 

Issues and Recommendations Identi?ed in the FYR:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Issue Category: Institutional Controls
(Sitew'de) Issue: Institutional controls are not in place to protect the soil remedy.
Recommendation: Evaluate if institutional controls are still necessary to
protect the soil remedy in the long term and implement if necessary.
'Affeet Current Affect Future Party I Oversight Milestone Date
Protectiveness Protectiveness Responsible Party 
No Yes EPA/State EPA/State 12/31/2018
Issue Category: Remedy Performance
(Sitewide) Issue: Groundwater contamination may extend beyond area of institutional
controls.
Recommendation: Update supply well survey, install additional
groundwater monitoring wells as necessary, and implement protective
measures, if required.
Affect Current Affect Future Party Oversight Milestone Date
Protectiveness Protectiveness Responsible Party
No Yes EPA/State EPA/State 3/30/2019
OTHER FINDINGS

During 2017-2018, the EPA and TDEC plan to evaluate options for the downgradient portion of the
plume. The agencies will evaluate the potential for in-situ chemical or biological reduction/precipitation

16

methods for the plume versus the installation of off-site recovery wells and increased on?site treatment
capacity.

VII. PROTECTIVENESS STATEMENT

Sitcu'idc Statement

  

Protectiveness Determination:
Will be Protective

Protectiveness Statement: 

The remedy at the Site is expected to be protective of human health and the environment upon
completion. In the interim, remedial activities completed to date have adequately addressed all
exposure pathways that could result in unacceptable risks in these areas. The Site is secured,
some institutional controls are in place, contaminated soil has been treated and disposed of off-
site,? and the on-site groundwater monitoring and treatment system is in place and functional
while groundwater monitoring continues northwest of the Site.

i

 

 

 

 

 

NEXT REVIEW

The next YR Report for the Smalley-Piper Superfund site is required ?ve years from the completion
date of this review.

17



 

APPENDIX A REFERENCE LIST

Baseline Risk Assessment, Volume 1, Smalley-Piper Super?md Site, Collierville, Tennessee. Prepared
by Black Veatch Special Projects Corp. for EPA Region 4. July 2008.

Baseline Risk Assessment, Volume 2, Smalley-Piper Superfund Site, Collierville, Tennessee. Prepared
by Black Veatch Special Projects Corp. for EPA Region 4. July 2008.

Draft Operations andMaintenance Manual: Operating and Maintenance Instructions for the Phase 1A
Ground Watet Recovery Treatment System Revision 3. Prepared by Fisher Arnold for Winters
Systems. December 2015.

Groundwater Implementation Status Report, Smalley?Piper Super?md Site, Collierville, Tennessee.
Prepared by Black Veatch for EPA Region 4. December 2014.

Groundwater Implementation Status Report, Smalley-Piper Superfund Site, Collierville, Tennessee.
Prepared by Black Veatch for EPA Region 4. January 2017.

Public Health Assessment for Smalley-Piper, Collierville, Shelby County, Tennessee. Prepared by U.S.
Department-of Health and Human Services Public Health Services Agency for Toxic Substances and
Disease Registry. May 2006.

Record of Decision, Smalley-Piper Superfund Site, Collierville, Tennessee. EPA Region 4. September
2008.

Remedial Action Report, Phase 1 (Soil Remediation), Smalley-Piper Superfund Site, Collierville,
Tennessee. Prepared by Black Veatch Special Project Corp. for EPA Region 4. September 2012.

Remedial Action Report, Phase la (Groundwater Remediation), Smalley-Piper Super?md Site,
Collierville, Tennessee. Prepared by Black Veatch Special Project Corp. for EPA Region 4.
November 201 6.

Rules and Regulations of Wells in Shelby County. Shelby County. Accessed December 2016.


 

 

 

 

 

APPENDIX CURRENT SITE STATUS

lim'irnnmentnl

- Current human exposures at the Site are under 

- There is insu??icient data to determine groundwater status.

 
 
 

Indicators

antral.

 
 

Are Necessnr} Institutional Controls in Place?

All Some None

 

Through "city regulations, institutional controls are in place to restrict well placement within
one-half mile of the Site. Additional assessment maybe needed to ensure groundwater

restrictions are in place for the full extent of site-

are not yet in place.

related contamination. Land use restrictions

 

 

Ilns El? Designated the Site :15 Site?

DYes ENO

 
 

itiL? Read) for .rXIltieipnted Use?

Has the Site Been Put into Reuse?

Yes No (Eastern portion of the Site is in commercial reuse)



B-l

 

 SITE CHRONOLOGY

Table C-l: Site Chronology

 

 

Event

1

Date

 

Site leased to several co orations for various manufacturin operations

issos-zo?

 

Additional testing of Collierville public drink water wells detected
hexavalent chromium contamination

 

August 2001-January 2002

 

 

 

 

 

 

 

 

 

 

wide Record of Decision (ROD)

The EPA conducted a site investigation and discovered additional July 

contaminants; the EPA installed three monitorin wells on site

The EPA issued notice letters to potentially responsible parties (PRPs), March 12, 2004
. informing them of their potential liability at the Site 

The EPA proposed the Site for listing on the Super?md National September 23, 2004

Priorities List (N PL)

The EPA and PRPs entered into an Administrative Order on Consent October 4, 2004

(AOC) to perform the Site?s remedial investigation and feasibility study

(RIIF S) and reimburse the EPA for its oversight costs; PRPs began the

The EPA ?nalized the Site on the NPL April 27, 2005

completed the RIIFS under EPA oversight and EPA issued the site- September 30, 2008

 

 

The EPA initiated the Site?s remedial design

 

August 19, 2009

 

 

The EPA and PRPs entered into a second AOC

February 10, 2010

 

 

 

 

 

The EPA ?nalized the Site?s remedial design September 20&_
The EPA initiated the Site?s remedial action for soil Ma)? 12. 201.2
The EPA completed remedial construction for the Site?s soil remedy September 29, 2012
The EPA initiated construction of on-site groundwater treatment facilities September 13, 2014
December 7, 2015

 

 

 

The EPA completed construction of the on-site gromdwater treatment
Lfacilities and facility startup

 

 

 

APPENDIX SITE MAPS
Figure D-l: Site Vicinity Map

Kr

 

 

 

come?mne. TN ff

 

. . 

I. 2-:2 (?amalgam
?npegfqund Site






 

 

 

 

 

 

a Ill!
Feet gLegepd
Sources: Em; swam, DeLomIe, Gensye, Earmstar Geographies. APP'rOXimate Site. Emma?!

as. usm, AEX, Getmapping, Aaragrid, swisstopo. - -
AND. Tale A?as, mem, UNEP-WCMC. uses, the GIS User N?rf?lk Southern Radroad

1543A3m7 BOD

 

Cambium and Bgack a. V?s-am,

 

 

 

 

?keo sma'hV-Piper Sunerfund Site

r: a . NORTH Town of Collierville, Shelby County, Tennessee

i

 

 

 



 

Disclaimer. 

are approximate and subject to change. The map is not a survey. The map is for infannational
purposes only regarding the actions at the Site.

D-I

 

 

APPENDIX SITE INSPECTION CHECKLIST

 

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

 

 

 

I. SITEINFORMATION

 

 

Site Name: Smiley-Piper Date or Inspection: 10/20/2016
Location and Region: Collierville, Tennessee 4 EPA ID: TNN000407378

 

 

353:3: gig? or Company Leading the Five-Year Weather/Temperature: 705 and [1351}: cloudy

 

Remedy Includes: (Check all that apply)

Land?ll cover/containment Monitored natural attenuation
Access controls Groundwater containment
Institutional controls Vertical barrier walls

Groundwater pump and treatment
Surface water collection and treatment
Other: contaminated soil removal

Attachments: inspection team roster attached Site map attached

 

 

n. INTERVIEWS (check all that apply)

 

I. Site Manager

 

 

- Name Title Date
Interviewed at site at of?ce by phone Phone:
Problems, suggestions Report attached:

 

 

Name Title Date
Interviewed at site at of?ce by phone Phone:
Problems/suggestions Report attached:

2. Gail? Sta?'

 

 

 

 

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

Agency TDEC
Contact Jamie Woods 11/301?2016 901-371?3041
Name Remediation Date Phone No.

Title
Problems/suggestions Report attached: see interview form

Agency Collier-ville

Contact 'Ttm? othy OverlyName Qtilities 11/15/2016 toverlg@ci.collierville
Director Date .tn.us
Title Email

Problems/suggestions Report attached: see interview fom

Agency
Contact

 

 

 

Name Title Date Phone No.
Ptoblems/suggestions Report attached:

Agency
Contact

 

 

 

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

 

 

 

 

 

 

 

  
 
 

Agency
Contact

 

Name Title Date

Problems/suggestions Report attached:

Phone No.

 

 

Other Interviews (optional) Report attached:

 

 

 

 

444$

 

 

 

 

DOCUMENTS AND RECORDS (check all that apply)

 

 

 

 

 

 

 
 
 
 
  
  

 

 

 

 

 

 

 

 

 

 

 

Documents
manual Readily available Up to date 
As-built drawings Readily available Up to date 
Maintenance logs Readily available Up to date 
Remarks: Manual has been revised and is in the process of being ?nalized.

2. Site-Speci?c Health and Safety Plan Readily available Up to date El 
Contingency plan/emergency response Readily available Up to date 
an
Remarks: 

3. and OSHA Training Records Readily available Up to date 
Remarks: 

4. Permits and Service Agreements .
Air discharge permit Readily available [3 Up to date 
Ef?uent discharge Readily available Up to date 
Waste disposal, POTW Readily available Up to date 
Readily available Up to date 
Remarks: Regan" ements are met for off-site disposal of contamination.

5. Gas Generation Records [3 Readily available [3 Up to date 
Remarks: 
Settlement Monument Records Readily available Up to date 3
Remarks: 
Groundwater Monitoring Records Readily available Up to date 
Remarks: 
Leachate Extraction Records Readily available Up to date 8 
Remarks: 7
Discharge Compliance Records
[1 Air 1] Readily available 1] Up to date El 
Water (ef?uent) Readily available Up to date 
Remarks: 

b0. Daily Access/Security Logs Readily available Up to date 3

 

E-2

 

Remarks: 

 

1V. COSTS

 

 

1. Organization 
State in-house Contractor for state
PRP in-house Contractor for PRP
Federal facility in?house Contractor for Federal facility

2. Cost Records
Readily available Up to date
Funding mechanism/agreement in place Unavailable

Original cost estimate: $524,106 per year Breakdown attached

Total cost for review period if available

 

tam 2016' $187,255
Date Total cost
Febru_2112016 $119,432
Date Total cost
March 2'oi6 599,703
Date Total cost
April 2015' 5121.765
Date Total cost
Ha?z?016' 5220.551
Date Total cost
June 2016 $171,662
Date Total cost
July 2016' 5171,30
Date Total cost
132 562
Date Total cost
Sep' 'uhbg 2016 5143.172
Date Total cost
October 2016 $157,350
Date Total cost
3. Unanticipated or Unusually High Costs during Review Period
Describe costs and reasons: I

 

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable 

 

A. Fencing

 

 

l. Fencing Damaged

Location shown on site map Gates secured



 



 

 

 

Remarks: Fencing around the gmundwater pumping and treatment building is secure but there mav he
breaks in the fencing around the entire site bounm.

 

B. Other Access Restrictions

 

1. Signs and Other Security Measures Location shown on site map 
Remarks:

 

C. Institutional Controls (1C5)

 

I. Implementation and Enforcement
Site conditions imply ICs not properly implemented El Yes No MA
Site conditions imply ICs not being fully enforced Yes No 

Type of monitoring self-reporting, drive by):
Frequency:
Responsible party/agency:

 

 

Contact 

Name Title Date Phone no.
Reporting is up to date Yes No 
Reports are veri?ed by the lead agency Yes No 
Speci?c requirements in deed or decision documents have been met Yes No NIA
Violations have been reported Yes No 

Other problems or suggestions: Report attached

 

2. Adequacy
Remarks: lash-titmion controls are lace to 

restrig- ions are not yet in place;

ICs are adequate [Cs are inadequate 
"ctwell'l 

 

   

 

D. General

 

l. Location shown on site map No vandalism evident

Remarks: There has been no-recent vandalism since gaundwater pumpm' and treating bega_n. Some
vandalism and equipment was stolen when remediation DEE.

 

 

 

 

 

2. Land Use Changes On Site NIA
Remarks:
3. Land Use Changes Off Site 
Remarks: 
VI. GENERAL SITE CONDITIONS
A, Roads Applicable 
1. Roads Damaged Location shown on site map Roads adequate 
Remarks:

 

B. Other Site Conditions

 

Remarks: Dilanidated buildings and old machingy remain on site.

 

vn. LANDFILL COVERS [3 Applicable IZI NIA

 

 

VERTICAL BARRIER WALLS El Applicable 

 

 

E-4

 

 

IX. WATER REMEDIES Applicable NIA

 

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable [3 

 

1.

Pumps, Wellhead Plumbing and Electrical
Good condition All required wells properly operating El Needs maintenance 

Remarks:

 

Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
Good condition Needs maintenance
Remarks:

 

Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks: I

 

B. Surface Water Collection Structures, Pumps and Pipeline: Applicable 

 

1.

Collection Structures, Pumps and Electrical
Good condition [3 Needs maintenance
Remarks:

 

 

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

 

 

 

 

 

 

2.
Good condition Needs maintenance
Remarks: 

3. Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks: 

C. Treatment System Applicable [3 

1. Treatment Train (check'components that apply)
Metals removal [1 Oil/water separation Bioremediation
Air stripping Carbon adsorbers 
Filters: bag ?lters, mlishing with resin

Additive chelation agent, ?occulent): 

chem 77777 
8 Good condition Needs maintenance
Sampling ports properly marked and ?lnctional
Sampling/maintenance log displayed and up to date
Equipment properly identi?ed
Quantity of groundwater neared annually: my 2016 November 2016 869 570 gallons}
Quantity ofsurface water treated annually: 
Remarks: 

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

 

 

E-5

 

 

ran-?w

 

Good condition Needs maintenance

Remarks:

 

3. Tanks, Vaults, Storage Vessels
Good condition Proper secondary containment Needs maintenance

Remarks: 

 

4. Discharge Structure and Apportcnances

 

Good condition Needs maintenance
Remarks: 
5. Treatment Building(s)
Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored
Remarks:

 

6. Monitoring Wells (pump and treatment remedy)
Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Needs maintenance 

Remarks: One iezometer well in the area of the soil removal was damn ed and marked with an oran 
cone. -

 

D. Monitoring Data 

 

1. Monitoring Data
Is routinely submitted on time Is of acceptable quality

 

2. Monitoring Data Suggests: .
Groundwater plume is e?'ectively contained Contaminant concentrations are declining

 

E. Monitored Natural Attenuation

 

1. Monitoring Wells (natmal attenuation remedy)

Properly secured/locked CI Functioning Routinely sampled Good condition
All required wells located Needs maintenance 
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 ?mctioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish to contain contaminant
- plume, minimize in?ltration and gas emissions).

The remedy included excavation. treatment and off-site disposal of chromium-contaminated ppils;

put?oping and treatment of chromium-contaminated pzoundwater and reiniectipn to ?ush remaining
chromium in area of former egualization ponds; and institutional controls. The rem?y has not been ?illy:
igplemented get but so far 323813 to be ?mctioning as desiged.

 

B. Adequacy of 

 

Describe issues and observations related to the implementation and scope of procedures. in
particular, discuss their relationship to the current and long-term protectiveness of the remedy.

The Plan is being ligated as adjustments are made to the gxoundwater pumping and treatment

svstep-p

 

 

 

E-6

 

C. Early Indicators of Potential Remedy Problems

 

Describe issues and observations such as unexpected changes in the cost or scope of or a high

?'equency 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 optimimtion in monitoring tasks or the operation of the remedy.


Site Inm?on Participants:
Randy Bryant, EPA
Jamie Woods, TDEC
Sarah Alfano, Skeo
Johnny Zimmerman?Ward, Skeo

 

 

APPENDIX PRESS NOTICE

The U.S. Environmental Protection Agency, Region 4
?7 EPA Announces the First Five-Year Review for
. The Smalley-Piper Superfund Site,
Collierville, Shelby County, Tennessee

Purpose/Objective: The EPA is conducting a Five-Year Review of the remedy for the Smalley-Piper Superfund site (the
Site) in Collierville, Tennessee. The purpose of the Five-Year Review is to?make sure the selected cleanup actions e?'ectively

protect human health and the environment.

Site Background: In the 19705, site operations included battery casing manufacturing and treatment. Operations sent liquid
wastes into an underground pipe that discharged to open retention ponds. The ponds treated the wastes and allowed the liquid
to ?ow into surface water drainage ditches. Facility operations later abandoned the ponds and back?lled them with soil.
Contamination resulted from facility Operations. In 2005, the EPA listed the 9-acre site on the NFL.

Cleanup Actions: The site?s long-term remedy, selected in 2008, included digging up contaminated soil, treating
contaminated soils with chemicals and disposing of them off site, extracting, treating and disposing of groundwater on. site,
and placing institutional controls on the site property. The soil cleanup was ?nished in September 2012. The initial
groundwater treatment system was constructed during 2015 .

environment. As part of the Five-Year Review process, EPA sta?? is available to answer any questions about the Site.
Community members who have questions about the Site or the Five-Year Review process, or who would like to participate in
a community interview, are asked to contact:

Randy Bryant, EPA Remedial Project Manager Kerisa Coleman, EPA Community Involvement Coordinator
Phone: (404) 562-8794 Phone: (404) 562-8831

Email: bmt.randy@epa.gov Email: coleman.kerisa@epa.gov

Mailing Address: U.S. EPA Region 4, 6i Street, S.W., lith Floor, Atlanta, GA 30303-8960

Additional information is available at the Site?s local document repository, located at the Lucius E. Elsie 0., Jr. Library,
50! Poplar View Parkway, Collierville, TN 38107, and online at: a. ov/su erfund/smalle - i er. .



ur-

mm at?



mm?w r:



APPENDIX SITE INSPECTION PHOTOS





1

I I .
. ?9
ran-2mg?

. 95"?"35-
. 

    

Gated entrance at the east end of the Site.

 

Old battery casing facility and sampling barrels on site.

G-l

 

 

Piezom ter open and unloced in gallery area.

     

G-2



cum





 

 

.-
'h



an: 1- ?112m?!

 

Groundwater treatment building on west end of the Site.

G-3

 

 

 

Outdoor groundwater treatment facilities, including ion exchange components.

 



. . Whl??a'!
. .

.

wag-?pm W??1k?m?rw 

mgr:

 

E:

5*
a:
5?1

 

Off-site monitoring well MW27D.

 

Off-site monitoring wells MW24I and MW24S.

 

mm.? "uh

APPENDIX INTERVIEW FORMS

 

Smalley-Piper Superfund Site Five-Year Review Interview Form
Site Name: Smallest-Piper EPA ID No.: TNN000407378
Interviewer Name: Sarah Alfano Af?liation: ?og

Subject Name: Timothy Over? Af?liation: Town of Collierville
Subject Contact 

Information:

Time: 7:20 a.m. Date: 1111512016

Interview Collierville Public Works Department of?ces, located at 500
Location: Keough Road, Collierville, TN

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

 

Interview Category: Local Government

. Are you aware of the former environmental issues at the Site and the cleanup activities that have
taken place to date? Yes.

. Do you feel well-informed regarding the Site?s activities and remedial progress? If not, how might
EPA convey site-related information in the future? Yes.

. Have ?1ere been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing? No.

. Are you aware of any changes to state law's or.local regulations that might affect the protectiveness
of the Site?s remedy? No. 

. Are you aware of any changes in projected land use(s) at the Site? No.

. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? Yes.
Collierville receives weekly operational reports on the remediation process.

7. How can EPA best provide site-related information in the ?sture? At some point, EPA should
consider holding a remediation status meeting for the public and local elected o??icials.

. Do you have any comments, suggestions or recommendations regarding the project? Based on the
information in the weekly operations report, the remediation appears to be progressing fairly well.
Since the remediation has been going along for most of the year, sampling of the monitoring wells
immediately of the site might be good to determine if groundwater quality is showing
improvement near the Site. In addition to the monitoring, a summary report of the plant operations
would be bene?cial.

Smalley-Piper Superfund Site Five-Year Review Interview Form

 

 

 

 

 

 

Site Name: Smaller-Finer EPA ID 0.: 
Interviewer Name: Johnny Zimmerman- Af?liation: Skeo
Ward
Subject Name: Jamie Woods . Affiliation: TDEC Remediation
a 
Subject Contact 901-371-3041
Information:
Time: 11:47 am Date: 11/30/2016
Interview Format (circle one): In Person Phone Mail Other: Email

 

Interview Category: State Agency

Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial
activities ?'om residents in the past five years? I have not received any complaints, but there have
been a few inquiries from Callierville residents and local consultants as to what is going on at the
Site. One of these was ?om the Shelby County Land Bank, which expressed a desire to get the
property back on local tax rolls. 

4. Has your of?ce conducted any site-related activities or communications in the past ?ve years? If so,
please describe the purpose and results of these activities. Yes, we have assisted the EPA with local
oversight, attended construction meetings, in site walk-throughs, and provided
Callierville Public Works Department with site status and progress updates, as requested

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site?s remedy?
No, I am not aware of any current or pending changes to state laws that Would impact the project.?

6. Are you comfortable with the status of the institutional controls at the Site? If not, What are the
associated outstanding issues? Yes, I am comfortable with them and have no issues. Water Plant #2
has been o?line since December 2003 and the Site is more secure now than ever (since plant
operations ceased).

7. Are you aware of any changes in projected land use(s) at the Site? I ?m not aware of any changes,
currently.

H-2

 

8. Do you have any comments, suggestions or recommendations regarding the management or
Operation of the Site?s remedy? No-

comments or suggestions that 1 haven already provided as the
state-level Site Project Manager.

H-3

Smalley-Piper Superfund Site Five-Year Reviewlnterview Form

 

 

Site Name: Smalley-Piper EPA ID No.: 
Interviewer Name: Affiliation: 
Subject Name: Randy Bgant Af?liation: EPA
Subject Contact 

or 404/562-8794
Time: Date: 05/123017
Interview Location:
Interview Format (circle one): In Phone Mail Other: email
Person
Interview Category: EPA Remedial Project Manager
1. What is your overall impression of the project, including cleanup, maintenance and reuse

activities (as appropriate)? Overall, I am satis?ed that with the site cleanup and operation of the
treatment system. We have had a few introductory calls with two pe0ple interested in some reuse of the
Site, but their interest has waned .

2. What have been the effects of this Site on the surrounding community, if any? A narrow plume
of groundwater contamination extends about 7/10 of a mile northwest of the Site. However, there are no
water supply wells in the area of the plume.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or
remedial activities since the implementation of the cleanup? There have been afew'inquiries which
related to the potential reuse of the Site or the periodic groundwater sampling.

4. What is your assessment of the current performance of the remedy in place at the Site? The soil
component of the remedy was completed in 2012. The first phase of the groundwater remedy is in
operation and is performing as intended

5. Are yOu comfortable with the status of the institutional controls at the Site? If not, what are the
associated outstanding issues? I am comfortable with the county ordinance that prevents the installation
of water supply wells in the vicinity of a Superfund site.

6. Are you aware of any community concerns regarding the Site or the operation and management
of its remedy? If so, please provide details. I am not aware of any community concerns regarding the
Site.

7. Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site?s remedy? We continue to monitor contaminant concentrations in the groundwater
in?uent to the treatment plant. As the concentrations drop, we may be able to simplify: some steps in the
treatment process resulting in reduced costs while still improving overall groundwater quality. Also, we
are going to evaluate potential insitu treatment methods to address the o?site portion 0f the
groundwater plume instead of expanding the recovery well network and the treatment plant. Insitu

H-4

 

methods may be more e?t?c

tent and cost e??ective, particular-{vfor the lower concentration portion of the
plume that extends o?fs?ite. 

APPENDIX I DETAILED ARARs REVIEW TABLES

Applicable or Relevant and Appropriate Requirements (AMRs) Review

- CERCLA Section 121(d)(l) requires that Super?rnd remedial actions attain ?a degree of cleanup of
hazardous substances, pollutants, and contaminants released into the environment and of control of
?rrther 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

Sail ARARS
Chemical-speci?c ARARs were not established for soil. Cleanup goals were risk-based.

Groundwater: ARARs 
The 2008 ROD selected National Primary Drinking Water Standard MCLs as chemical-speci?c ARARs

for groundwater. This FYR compared the relevant MCLs used in the 2008 ROD against the current
relevant MCLs for the groundwater COCs. MCLs used in the 2008 ROD have not changed. In the
absence of an MCL, the EPA developed a risk-based cleanup level as a cleanup goal.

Table 1-1: ARAR Review 

 

  
  
  
 

 

 

 

 

 

Groundwater coc zoos ROD ARAR (my 2016 MCL m) i ARAR Chan 
]_Hexavalent chromium I NA NA NA
Lrotal chromium 100 100 - I no Chan 

Antimony 6 I 6 no chan 

 

 

 

 

[iron NA NA NA
Notes:

MCLs accessed at 
water-contaminants in December 20l6.

NA MCLs have not been established for these COCs.
per liter 

 

I-l

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

I I cos 0001 000'? We: 00010: 000':: ?90 Nisan!
I 005 005 001'05 00005 000'? 000?? 00'! mist/to
I 0 00's? 0 005 00m 03?: 000's: 000'? we 06 Trimm?
"m 00: on one'u ooe'u 000'09 005?69 000?09 0 Ia ammo
00: not warm 00519 00610 000'59 00099 1- 59 
00! 005 000'09 tot-as 0:090:90
006'65 002'" :0
000m: 006'? E: 00/01! 5?
05: 005'? mm: 50 50191190
m: llama IFM
5500 rn 911' as 000?er 00059! noo?ss: 00019: 00th 000'09: 9 a atlozho
0'9 a 000m 000'00: 000'621 00mm 000'an 000m: 1 as
as .0009: 000'?! 000'?: 00020: 000051 0001151 (dun 01/01/00
0 rn 9'6 In St 00010: 000'?! 000??! 000'151 000'051 9? 9? otlozho
003' 005 000%: .0001?: 9551 (deer 
0 00: 00025: 0: ammo
00010: 000'001 :0
00019! 000'!? 64 90mm
000m 000??! - 06 90mm
on?: 0001-00 00029: 50 9011:1400
?9mm:
3""de panama mu "am Jim 0mm 9:0:nt
panama unu um u: norm some
0100: mist/00
0 5'0 :90'0 res 0 501-: mm
?6 90/9tlso
9300mm IBM
001': M's 60
001': 90mm mm
00 an: 000's 000's - 9: Emma
1? 1: 00: n?o? 0! or In 9mm1011? 910nm]:?
Manama95'0 l- 2'8 mm?
:01 06675? I ?it 50mm
I 9 96 Wot?so
n: (annular/90
- :0 0010:}qu
um 
9 :m 00: 00: Wil'lom 
a I I I
(no: war)

uodau uoymuawolduq .mumpunmg) 11101} 0100 paymsg? JO KJ-uulul-ns :I-f anal
VLVCI 1? 

 

Z'f

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

I: :10: NEW 1
In am 08101:15:!?
m?gjo I l' 0'95 I 
9'0 
I rs wt BOISIISD
I I 001 0065 0001 0005 0001: 000"! 00 9t arm
I I 00? 00000! as It 009's - guano
mum on Taiwan 1PM - no:
0 rn L?s. I000 000'? 00:11 000's! 000?? 06 ?my?
0 0 not In I9 000'? I- 90 MIN
0 be: 000's: 000'.? 5 101-19 60180190
I art's 00m 66
095's 0625': as 
005's 009's: am he memo
I I 000: 00: our? 001?s: 000:: 000:: 000 
I I 0 mm 005 005%: 0002: 0001: 000:: ?00 grim0001' 001's! 00929 00095 0000: on (WIN/belt
I I 000I 000I 00"99 005?19 00005 000:5 ov'I sIlozho
I 000 000: 005's: 002?: 000:: 00009 05': 56 (?in?rm/z:
I I 009 000: 000's:? 00m: 000.19 012'! 56 mean:
0 9: In (I 00030: 000's" 000's? 000?sat 000100000'001 :0I-sa atlsmo 
00: not 000??: mu'nI 0001091 0000? I 66
In Iv's In at 000'!? 000's.? [000'03 0 :6 nun/to
In a In 0000:: 000'06 I 000'03 50
I 5'0 0059.: 00:21 I 663'er Marisa/W90
I 0 ms: I on 6 mm" 6:060:90
000'?: 0000:: 66
000'er 58 solarlso
0901 I 000109 0000!? :6 gum/I0
I I ?I?n 00: o?r 00: oas'u 000?s: 000's: noo?u Iamar 001's: 009':9 000'55 00019 69': atlazhn
I I 000 000I 000's: 000's: 000w 000?69 W5 06 within
0090?: 009'0: oos'o: 000%: 0000: I 000?: 0 ?6
In In IvI'o In W. In :5 WW: 009?0: 000'0: 00:1: 0001: I 000's: 50 aria/Io
In Ira In 09 0091: can: 000?: 0001:: 000?: I 000?: {mum f?mlar?zI?I-a
In 0500 In 0 not an ana'I: oos'I: 005?" 0002: I 000:: 55-00 Mist/m 00mm
In 90 I m'ls I (as 505: Warren
I mm 000'? 56 90mm
I 00m: 009?): as gala/90
I oot?oz 90mm
an 002:1 009:: 58 (Mm/glen
an: 000 I 005 50:5: 0
0:1 
II: 0m min-mo F09 

 

 

-. mun-80?. 1.81 as: our. 3511 stistlbo 
an: 95-0 SII 
I I cos cos can; own 000%! Sn 
I I cm on own 086's ma'a ooI'I 50"6 
I I no: 0091: ozo?g uIs?s Don's oas's om IIfsoizI
a 
not or; am ooe'v mm: 6 3:3? ammo
II am on one-'5: car's: 009's: uoz'st mo'gI mo'gt or as . 8mm
_n0'z n'O [9 01.9 ono'eI nos'II m?st 005's: ano?uI or 
osz?t and? com 51 Ell-Bl salsa/so
9 6'8 {dunno/mitt
osz's 059's 
[095 um 
065?! me? 06 
nou'055 unoI or In 0! as as 26's stizzho
69': on vI/volzI
9H: at I: 0309 was a In In ?gm? UIISZIW
. . . 1mm
SIM. mica/90

61: am 
81 05 90mm
001?- um :61061) 
I I on one 009'; ou's oos's 009?s ow 
sImemo
rn 5'0 I 911.: [Iran 5 
(II
out salsa/so
Map} Wee/so
II): ?9 more:
[ml on plant mac. plan-mall?
9 ?591 u- m: not no Wilma
l?ield A tron

Antillrrony
in 2010. 2016}
(NT?ll . lug/ll tug/ll (Ila/ll

. Unfiltered Filtered Un?ltered - Filtered Unfiltered Filtered Unfilteted Filtered Un?ltered Filtered

Sample") . (?Hem?m . Deplh . I'urhidtlv. l' 201? 201? . {A'Nf?n UP) lAllNon .2016}
Date 

 

   

?amedlal Goal Obiec?ve:
Tartan: 0f Wt? screen being 120 It by

130 119 170 127
04/23!? 170122 2.5 14164 2.71 5 
ml? 178 3.2 1 11.6 
06/00/09 105-164 1 5 10 213 2.31
04/26/2600 100 2.0 2.0 
04/29/2.0 2.0 
2014 RA Construction Adivtues Prat/awed Sampling 
04/20/16 21 10 5 10 10 2000 100 1 1 
11/10/207
05/11/06 111 246
124 149
124
mwos 0511210511211?) 137 126

06/09/09 60-1119 4 42.2 1 120 051 
04/19/6.2 0.21 01 0.17 01

136 30 190 150 2_10 151 141 150 1.6001 100 0.11 2.0 11
12/03/14 135 5.04/21/16 0.11/10/16 0.04/26/05 175 5.080
166 2.5 6.91

152 2.5 9.6 1
05/12/05 166 2.5 6.2 1
#180 2.5 5 11
111111106 06/09/09 156-195 2 31.41 10 0.51
04/25/0.095 111 2.0 

12/02/14 161 1.04/21/16 1.1y09/16 0. 

 

Field Total 01an Total Chromium Heuiwalent Chromium Iron

Antimony
Sampmm comm" 099th Turbidity lCle 2010.2 6} {Alann-ClPl {12190120102015}
Date tug/L) tug/Ll lug/Ll lug/Ll lug/Ll
Un?ltered Filtered Unfiltered Filtered Un?ltered . Filtered Unfiltered Filtered Unfiltered Filtered
Goal Ohm: 100 4? 4,693 6

Ilnttum of well screen below 120 lmn?nmdl


01/11/06 130 2.4 5,510

155 2.4 7.210
01/111116 (dup) 2.4 6

550110 05109105 129 2.5 5 .
06/05/09 120-159 15.1 731,100 100 U1 2.0 2.0 
00an 2012 RA 

113 491
05111105 127 472
141 457
mwu 05/09/09 103-143 5 757 1 190 0.5 1
04/26/10 113 0 200 200 21.5 19? 189 161 49 U1 100 2.0 
12109114 139 4.04/19/15 0.11/07/16 0.11/29/name 05/09/09 103?132 04/21/3301 5.5 111 2.0 0

12107114 127 2.04/16/16 4.n?12/05/14 165 0.MWIBI 04/20/16 1.11/09/15 1.10/31/06 142 2 .l 5 
154 2.21 7.31

10/11/0501011; 3.1 1 5 
mw19 05/05/09 117-155 7 5.5 54.7 209 10 11
04122110 150 1.5001 11 01 2.0 2.0 11

12/01/14 148 11.04/21/15 7.11/08/16 1.1:02

 

 

 

 

 

 

 

 

 

 

 

2.J-5

9'1?

 

?who mm mm Wink: man: ?qu palm Mammal: om: nun 9M 5002 n! "a?uwu (Slump Hum an: lump-us" as! sums
1mm 31an an 12min tau) mammal Mam?! mm mm Wmmpams um

"summon mm mnm?md Hanna awn (Imam mun-5w} mum mm mm HIM-II mu IN

minimal ll minimum ?1331mm mum mm "mum in - 



9m mum fomz ?Haul alumnus we 1600: mm 5:11:13; - m-uou

Mud Ammqu mum ogs- 

(anus-numm atrium Minn-?Insulin - 1mm

mun! ?my" - 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

mamm-MP
umpouquum
I91 sIfaorII
mama ozzmw
I I on on: I55 on 11?91 120009! 0'11 our 9: u; so It's 99I ??at
I I on: not on? 0:92 009?s M's 90's rmplazamfrr
I I on: M's osu?t oos's 1m?! 90': stream
a I I nor oar on? our: our! new 06" mum/am
_n I I 081?9 con cop's act's O??t stfamo
I an: as: 091's 091's cat's oaz'g 00's (-1an Pill/H
I I no: as: 9969 an ooz?s ooI'9 0001mm
an: Iozz we: as: . OI 9H IZMW
. 981-99!
0 at 5125 not 9 am I ,8 gzI-gm 60190190
09t'9 091.9 9 so: 

5 r91: 89: 9015qu
was L?s35's swan!?
I I am 061: I9 89 It. as we .atiamo
I I on oar: ml to on we Imam
at In em at roosotlozlbo
not our931:1!" 6073?0390
In: 19? 
5n 091: 901mm 0mm
86?. on
see 955 sofas!?
3'58 suite/as: nan:
Hom- mm- uaM' man?on
9 it no: out H-nJl-lqolnanpm

 

 

 

Figure J?l: Estimation of Harmlent Chromium in. Groundwater April 2016



 

a

  

 

 

I
I

i
I

 

mm?

(lacuna 704.20 be?

Momma!?
(mum-a balm? an I199)

mm
W?mmungm
?My
?1-um
I, WWrkau-um
Hanna-?cumin?



um- 

mm
Mama-chm


303$

  



Ea?ma?on of Hlxwalent Chromium In Grounuwmr - April ma
Smaller-Finer SIM . a 2
Shalhy County. Tenn-ne- 

 

    

 

 

 

 

Figure 1?2 Estimation of Total Chromium in Grbundwater -- ?April 2016

. 1 
,r
- I

mm?
[m m-uonhm)



5 numb-mung.)
?ovum
. 
Eli-89W?



Tun! Chum
Count?

45.0mm
svmummamm IntrosRmumnm - - ."Chrorilum In Groundwater - April 2056 II we
mllm-Plp? am '34
Colliervill?a, sham county. TunnelsEstimation GfTotll

 

 

.Wm-nu?hh?un??

 

J-8

APPENDIX SCREENING LEVEL RISK REVIEW

Changes in Standards and To?be?Cansidered Values
Since the ROD, there have not been any changes to the MCLs for site COCs (Appendix I).

Changes in Taxicig: and Other Contaminant Characteristics

MCLs were not established for all groundwater COCs. Therefore, the EPA selected health-based levels
as the remedial goals for hexavalent chromium and iron. To determine if the groundwater remedial goals
and MCLs remain protective for unrestricted use, they were compared to the 2016 regional
screening levels (RSLs) for tap water, since the R815 incorporate current toxicity values and standard
default exposure factors. The screening-level risk evaluation indicates that the remedial goal for
hexavalent chromium may require revision as the cleanup goal is equivalent a carcinogenic risk that
exceeds the upper bound of the risk management range of 10'6 to 1 10" (Table The
cancer-based RSL is considered conservative because the Integrated Risk Information System
still states that for oral exposure, the carcinogenicity ?cannot be determined.? To be conservative, the
EPA has established a cancer-based RSL using an oral carcinogenic toxicity value developed by the
New Jersey Department of Environmental Protection for use in screening risk evaluations.

Table K-l: Health Evaluation of Groundwater Cleanup Goals

 

 

 

 

 

 

 

 

 

 

 

 

I Tap Water I
zoos Remedial (us IL) Cancer
COC Goal 1 10? Risk? Noneancer 
Risk HQ 1-0

Antimony 6 NA 7.8 - 0.7
Hexavalent chromium 47 0.035? 44 1.3 10"1 1.0

Total chromium 100 NA 22,000 - 0.004

Iron 4,693 NA 14,000 -- 0.3
Notes:

a. Current EPA RSLs, dated May 2016, are available at 
screening-table-generic-tables (accessed 1 1/02/2016).

b. The cancer risks were calculated using the following equation, based on the fact that RSLs are
derived based on I 10? risk:

Cancer risk (Cleanup goal Cancer?based RSL) 10?

c. The noncancer HQ was calculated using the following equation:

HQ cleanup goal noncancer based RSL -

d. The EPA has not established oral cancer toxicity criteria for this chemical. However, for screening
purposes, the EPA has adopted the oral toxicity value developed by the New Jersey Department of
Environmental Protection for use in screening level evaluations.

NA toxicity values not established by the EPA.
cancer risk or noncancer HQ could not be calculated due to absence of toxicity value.
Bold cancer risk exceeds 1 10" or the noncancer HQ exceeds 1.0.

micrograms per liter

 

 

 

The 2008 ROD established a health-based remedial goal for hexavalent chromium in subsurface soil of

876 milligrams per kilogram (mg/kg) based on a construction worker exposure. To determine if this

value remains protective, the exposure assumptions from the 2008 baseline risk assessment were entered

into the RSL calculator for an outdoor worker to include exposure duration of one year, exposure
K-l

frequency of 250 days/year, skin surface area of 5,000 centimeters, soil-to?skin adherence factor of 0.1
and RSL defaults for inhalation exposure. The RSL calculator estimated a 1x 10"5 risk-based RSL of
49.1 which was adjusted by a factor of 100 to represent a 10" risk-based RSL of 4,910

mg/kg (Table K-2). The noncancer HQ-based RSL of 1,770 mg/kg was also calculated (Table K-2). The
cleanup goal of 876 rug/kg is more stringent than the calculated RSLs, demonstrating that the 2008 ROD

soil cleanup goal remains valid.

Changes in Risk Assessment Methods

The EPA completed an update of standard default exposure factors in 2014. Thus, many of the exposure
assessment input parameters in the original risk assessment are different than values currently recommended.
Overall, these changes do not have a signi?cant impact on the conclusions of the risk assessment; the revised
exposure assumptions in most cases lower the risk and thus do not affect the protectiveness of the remedy.

Changes in Espasare Pathways
There have been no changes in site conditions that would suggest the presence of new exp05ure

pathways.

Expected Progress Toward Meeting RAOs

The RAOs for soil have been met; the remedy has prevented human exposure to contaminated
subsurface soil at concentrations above cleanup levels. The groundwater remedy is being implemented
in phases; Phase la is in operation. Expected progress toward meeting the RAOs for groundwater will
be evaluated once the complete groundwater remedy is in place.



 

Table K-Z: Summary of RSL Calculator Results

inhuman-Imam

Variable
mummen?shm?e?s
macwgethazardqua?a?uni'as

(mm tummy momma 


Erma)"


?lday

GymtahnaaZonQSelet-im
am;

PEPtpa?cumeenissionbcuIm '?cg
AtPEFDisnen?aannsam
BtPEFDisnem'mCotm
69303935501160an
deegea?vemedu?ess
U. (meanamxamindspeemm
U. 
Knitwndepmuonu jwu?us
Gy?IszwSeiec?m
Adam)




Maulso?pcrusiyn 

,m-?nedso?pomsizyu 

ANFDispetsiuxCa-Iaan?

MM 



0.19.!

68.13
0.005
15

2.65
0.43395

0.15
319935000
11.911

 I 
Site-speci?c
Miran!

mm. ca'mrIcSLdaoxcaSIJ.




ham hm
SF Uni! Suhchm?: Suhdnnic Sum: 
CA5 SFO Hist MD MC RIC
0min! [lumber ?1de Rd (mph, Rel GABS
18540-298 V6 No SIDE-OI 3415-02 5 ENE-03 A 3.00544 A 0025
um Lu Em'ns'nn SI. SI. SI.

Facial Cm mm:- Fm mm mum


Mam?) - 1 - - -- 136E109 4.96101 - 4.965413 4.91901 1.77503
3. SI. 
111M Level

mania1.795406 

K-4

 

APPENDIX - RULES AND REGULATIONS OF WELLS

IN SHELBY COUNTY
Section 4 GENERAL REQUIREMENTS AND PROCEDURES

4.01 Applications

C. A water well cannot be sited or placed in service within a half-mile of the designated
boundaries of a listed federal or State Superfund site or Resource Conservation and
Recovery Act corrective action site, unless the well owner can make a demonstration that
the well will not enhance the movement of contaminated groundwater or materials into
the shallow or deep aquifer.