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S O L U T I A

Applied Chemistry, Creative Solutions

Solutia Inc.

702 Clydesdale Avenue

Anniston, Alabama 36201-5328

Tel 256-231-8400

October 8, 2001

SENT VIA FEDERAL EXPRESS

Mr. Steve Spurlin, On Scene CoordinatorU. S. Environmental Protection Agency, Region IVWaste Management DivisionAtlanta Federal Center61 Forsyth Street, S.W.Atlanta, GA 30303

RE: FINAL SUMMARY REPORT OF TECHNICAL REVIEW ANDEVALUATION OF POTENTIAL PCB RELEASESANNISTON PCB SITEANNISTON, ALABAMA

Dear Mr. Spurlin:

Solutia Inc. (Solutia) is in receipt of the Final Summary Report of Technical Review andEvaluation of Potential PCB Releases for the Anniston PCB Site in Anniston, Alabama.We have reviewed the Report and provide the attached comments for your consideration.

Comments are presented in the order in which they occur in the Report to facilitate theirlocation in the Report. The order of presentation does not reflect the relative importanceof the comments. We have not provided any specific comments on the ExecutiveSummary. However, any comments provided on the Report itself apply to the ExecutiveSummary when applicable.

Specific comments are attached to this cover letter, but we would like to provide somegeneral comments regarding the report. First, there are a number of factual errorsregarding the history of the operations at the Anniston facility and the type and amount ofdata collected. We have attempted to correct these errors in the attached comments.

Second, and more significant is the fact that in several cases, it appears data wasselectively chosen to reach conclusions that are not supportable when all data collectedfrom the site are considered. This is particularly true for those conclusions regarding thepotential for ongoing releases via the surface water, air, and groundwater pathways andthe effectiveness of corrective measures that have been completed at the facility. Whereappropriate, we have pointed out these omissions and have referenced the data thatsupport more fundamentally sound conclusions, including the surface water datacollected as part of the NPDES program and groundwater data collected as part of the

RCRA Corrective Action Program. All data discussed in these comments has previouslybeen reported to ADEM and USEPA.

Third, there are other errors suggesting this report received only limited review beforebeing released. Errors in data (see comment to Section 3.1.2, Air subsection), math (seecomment to Section 4.2, fourth paragraph), and site history (see comment to Section 4.2,fourth paragraph) are just three examples where incorrect facts lead to inaccurateconclusions and interpretations of data. Other examples are provided in the specificcomments.

The flaws in the report nullify many of the conclusions presented and minimize theusefulness of the report in determining or evaluating potential future activities inAnniston. Contrary to the erroneous conclusions of the report, Solutia believes that,except for limited exceptions, the site has been fully characterized and, pending approvalof our RCRA Facility Investigation Report by ADEM and USEPA, is ready to undertakea Corrective Measures Study that will evaluate the need for additional correctivemeasures at the facility. Should a need for additional corrective measures be identified inthe corrective measures study, Solutia is prepared to take the actions necessary toimplement these measures. Some corrective measures may include a modification ofSolutia's RCRA Post Closure Permit requiring public review and comment. This is themost appropriate method for conducting an evaluation of data and the need for additionalcorrective measures at the facility.

Should you have any question regarding the enclosed comments please contact me at(256)231-8404.

Sincerely,

Craig R. Brand:Manager, Remedial ProjectsSolutia Inc.

cc: Wm. Gerald Hardy (ADEM)

Solutia Inc. Page 1

Section 1.2, first paragraph: This paragraph states that the Anniston PCB Site 1west of the city of Anniston. The Solutia Inc. facility and adjacent properties fc>^in this report are located within the city of Anniston.

It is also stated that, "In 1997 Monsanto separated its chemical division from the restthe company and the site has since been owned by Solutia Inc. (Solutia)." This statedoes not clearly represent how Solutia came to own the manufacturing facility inAnniston. Specifically, in 1997 Monsanto Company created Solutia Inc. as anindependent publicly held corporation and transferred ownership of certain assets ofchemical division, including the manufacturing facility hi Anniston to Solutia Inc.

This paragraph also states that chemicals have been produced at the facility since 19implying that Monsanto was the producer of the chemicals. In fact, Southern MangaCorporation (SMC) initially owned the site until 1930 when SMC became SwannChemical Company (SCC). Monsanto purchased the site from SCC in 1935.

The following sentence states that, "Aroclor and PCBs were manufactured at the facifrom the 1920s to 1970." This suggests that Aroclor and PCBs were two differentproducts. This is not correct. Aroclor was the Monsanto trade name for polychlorin;polyphenyls, some of which contained PCBs. Additionally, PCBs were manufacturethe facility from 1929 until 1971, not 1970.

Solutia also takes issue with the statement that the landfills were major sources of paPCB releases. There is no evidence to suggest that PCBs in areas outside surface wadrainage features from our facility originated from our facility. In fact, during samplof certain residential and non-residential properties, both within and outside areasassociated with surface water drainage, there is very clear evidence that fill materialhistorical foundry operations are a source of PCBs. This evidence includes findingsblack, gritty material known as foundry sand, slag material that may be associated wfurnace operations at foundries, portions of old drums, valve handles, and other wastmaterials at properties that have been found to be impacted by PCBs. PCBs were usa variety of products including heat transfer and hydraulic fluids that may have beenin foundry operations. Other foundries are known to have used products containingAroclor 1260 or Aroclor 1268 as a binder for casting operations.

In fact, ADEM records indicate that one foundry operation was disposing of foundryin the vicinity of the Highway 21 bridge and Choccolocco Creek. Detailed investigaundertaken at the Highway 21 bridge, Quintard Mall, Oxford Lake Park, and otherlocations where foundry sands and materials have been observed suggest that there r.be other sources of PCBs in the greater Anniston area. Additionally, in approximate1985 ADEM and the Alabama Attorney General's office conducted an investigationTull Chemical Company, which is located along Snow Creek. Tull Chemical was fcto be discharging PCBs into Snow Creek.

Solutia's Anniston facility was only one of many potential contributors to PCB impematerials found in the greater Anniston area.

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Section 1.3: The title of this section is "Assumptions," yet many of the statements madein the bullets that follow appear to be limitations regarding the scope of the investigationas opposed to assumptions made hi the conduct of the investigation. Solutia believes amore appropriate title for this section would be "Limitations."

Section 1.3, bullet 1: This bullet states that only certain, specific areas were consideredin this evaluation, yet section 1.1 states that the objective of the Report is to "...evaluatethe potential for on-going releases of polychlorinated biphenyls (PCBs) from theAnniston PCB Site." While the report focuses on the Solutia facility, Section IV. A of theAdministrative Order on Consent (AOC) between the USEPA and Solutia defines theAnniston PCB Site as ".. .residential, commercial, and public properties located in andaround Anniston, Calhoun County, Alabama'that contain or may contain polychlorinatedbiphenyl (PCB) impacted soils." Thus, Solutia does not believe the stated objective ofthe report can be met given the limited area of investigation and the failure to consider orinvestigate other potential sources for PCBs in the area defined by the AOC..

Section .1.3, bullet 3: This bullet states that other contaminants have been detected onSolutia property. While this statement is true, it would be more accurate to state thatwhile other contaminants have been detected on Solutia's property, none have beenidentified as leaving the site at levels of concern. As a result, only PCBs have beenidentified as a constituent of potential concern (COPC) in off-site areas.

This bullet also states that evaluation of risk assessments was not included in EPA'sstudy, yet the study draws conclusions regarding the implementation of potentialremedies. Solutia does not believe that any conclusions regarding potential correctivemeasures can be reached without evaluating factors such as land use, receptors, andCOPCs as part of an overall evaluation of potential risks.

Section 1.3, bullet 4: This paragraph states that REAC ".. .reviewed project files thatwere made available by the U.S. EPA Region IV and ADEM." Solutia also cooperatedfully in this investigation and in fact assisted in the investigation by providing copies ofdocuments that were specifically requested by the REAC team, and making available alldocuments associated with past and present remedial activities for the teams reviewduring the teams site visit.

Section 1.3, bullet 6: The report fails to note that the fine-grained nature of the soils atthe Solutia facility as defined in the report result in a situation where: 1) fine-grainedparticles are carried in suspension in the water, and 2) low yields from the soil formationlimit the ability to develop the groundwater wells and remove suspended sediments. Theability to produce non-turbid water is a challenge at the Anniston facility. Some wellsdevelop properly and produce non-turbid water, while other wells will produce turbidwater regardless of the amount of effort put into well development. Filtering is thereforenecessary to provide representative samples of the quality of groundwater moving withinthe clay residuum.

For these reasons Solutia has concluded that filtered samples are more representative ofgroundwater-transport conditions. The report's failure to address the absence of PCBs in

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filtered samples raises significant questions regarding the report's conclusions regardingthe presence and migration of PCBs via groundwater.

Section 2.1, first sentence: This sentence incorrectly states that Solutia is located at 700Clydesdale Avenue. Solutia's correct address is 702 Clydesdale Avenue.

Section 2.1, parenthetical after the eleventh sentence: The statement that there is aresidential development underway on properties immediately east of the South Landfill isnot correct. There is currently no residential development occurring in this area. Basedon discussions with the owner of this property, there are no current plans for residentialdevelopment in this area.

Section 2.2.1, second paragraph: While Solutia agrees with the last sentence of thisparagraph that states lie relationship of groundwater discharge from the Solutia property,particularly in the bedrock, to the fault recharge area is unknown, we believe that it isimportant to note that Solutia has installed three primary groundwater collection systemsat the perimeter of our facility that are monitored in accordance with the requirements ofour RCRA Post Closure Permit. Solutia believes that the data collected as part of thisprogram demonstrates that no COPCs, including PCBs, are leaving the Solutia facility atlevels of concern. Therefore, the relationship between groundwater discharge to anypotential fault recharge area is not material to the evaluation.

Section 2.2.2, second paragraph: The last sentence of this paragraph also implies adownward migration potential exists based on vertical gradients. However, the findingsin the January, 1999, RFI/CS report that the residuum becomes more dense with depthmaking the lower residuum an effective unit that inhibits downward migration. Inaddition, downward movement is not supported by a preponderance of the data. In mostareas of the site, where deep residuum wells were sampled, the wells did not showimpacts to groundwater. Impacted groundwater, where present, was generally limited tothe shallow residuum monitoring wells. Therefore, the data demonstrate that suchmigration is not significant.

Section 2.2.2, third paragraph: The second sentence states "the discontinuity ischaracterized by a residuum that is at least 540-foot thick." This statement is incorrect.The deeper bedrock provides evidence of the discontinuity, it does not characterize it.The discontinuity can be characterized as a formational contact between the ShadyDolomite and the Rome Formations. The concluding two sentences of the paragraphreport on slickenslides that were reported in some of the site borings. What thecommentator fails to mention is that slickenslides were always noted in residuum soils,not rock, and there was no discernable pattern evident with the reported slickenslides.For example, slickenslides were noted at a depth of approximately 32.5 feet in the boringfor OWR-1D, but were not detected in the corresponding shallow well (OWR-1S) boringdown to 35 feet. Elsewhere around the site, slickenslides were noted in some boring logs,but not in others. In no cases where slickenslides were detected were they also detectedin the next closest boring. As mentioned in the RFI/CS Report "the degree ofinterconnection between these secondary permeability features varies widely across thesite." They do not form a conduit for groundwater movement.


Section.2.2.2, fourth paragraph: It is apparent that in the residuum, there are soils withlow hydraulic conductivity on both sides of the discontinuity. The soils on the north sideof the discontinuity appear to have slightly lower hydraulic conductivity than those on thesouth side of the discontinuity; however, the difference is not enough to create an .effective barrier. In addition, the soils on both sides of the discontinuity are clayey innature and, as such, likely did not develop highly permeable brecciated zones that mightbe present in competent bedrock situations. Consequently, it is highly unlikely that thediscontinuity represents a transmissive pathway for groundwater movement. In addition,water level data do not suggest the discontinuity acts as a barrier. If anything, thepotentiometric data shown in Figures 28 and 29 of the RPI/CS report indicate that thediscontinuity has little impact on groundwater flow in the residuum soils. In addition, asstated previously, except for a few isolated instances (many of which seem dubious), anyimpacts to groundwater occur in the shallow residuum soils. The deep residuum soilswere found to be more dense and are an effective barrier to prevent downward migrationof chemicals.

This paragraph also alludes to cross section A - A' showing groundwater flow in thebedrock moving south. While this may be true on the south side of the site and in thedeeper portion of the aquifer, cross section A - A' shows groundwater movement to thenorth on the north side of the site in the shallow bedrock,

Section 2.3, first paragraph: This paragraph states that Snow Creek merges intoChoccolocco Creek and joins Lake Logan Martin on the Coosa River. This is not correct.Snow Creek discharges into Choccolocco Creek, which is a tributary separate and distinctfrom Snow Creek. Choccolocco Creek then flows into Lake Logan Martin.

This paragraph also states that stormwater from the twelve outfalls at the Solutia facilitydischarges to Snow Creek via a discharge structure on West 10th Street. This is notcorrect. Outfalls DSN 001, DSN 007, DSN 008, DSN 009, DSN 010, and DSN 011discharge to Snow Creek via a discharge structure on West 10th Street that is designatedas DSN 012. Outfalls DSN 002, DSN 003, DSN 004, DSN 005, and DSN 006 alldischarge to a drainage ditch located north of the Solutia facility which flows into SnowCreek.

Section 2.3, second paragraph: This paragraph states that surface water from the SouthLandfill flowed beneath 8th Street through a culvert by the Mars Hill Missionary BaptistChurch. This is not correct. The name of the church was Bethel Missionary BaptistChurch. Further, stormwater from the median of the portion of Highway 202 referred toin this paragraph is not conveyed to the Lower Detention Pond, it is conveyed to thedischarge structure on 10th Street. The stormwater from the paved ditch is conveyed tothe Lower Detention Pond, but not in a pipe. Finally, the water from the Upper DiversionChannel is conveyed in a pipe to the 10 Street discharge structure, not to the LowerDetention Pond.

Section 2.3, third paragraph: This paragraph states that surface water from ColdwaterMountain flows across the West End Landfill. This is not correct. Roadside ditchesintercept surface water flow from Coldwater Mountain across Highway 202 before itflows onto Solutia property. Even if surface water flow were to reach the West End

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Landfill, the landfill is at least fifteen feet above the surrounding ground surface andwould therefore not be affected by surface water flow from the mountain.

Section 2.3, fourth paragraph: Solutia strongly disagrees with the implication hi thisparagraph that surface water runoff from our facility continues to cause flooding in thevicinity of our manufacturing facility. Solutia has undertaken extensive measures tocontrol surface water runoff from our facility including the construction of four retentionponds, two east of our facility, one south of our facility, and one north of our facility.The combined capacity of these ponds is over 30,000,000 gallons and all are designed tofunction as stormwater routing ponds. As a result of interim measures taken by Solutia,peak storm water runoff from a 100-year, 24 hour storm event has been reduced by over30% as it enters the 11th Street Ditch upstream of Snow Creek. Therefore, any floodingthat occurs hi the vicinity of our facility is not associated with runoff from our site.

Additionally, Solutia has and will continue to coordinate closely with the City ofAnniston and Calhoun County regarding the need to perform maintenance of drainageditches that receive surface water runoff from our facility to ensure no potentiallyimpacted drainages ditches are disturbed that might result in the mobilization of PCBimpacted materials. Based on our experience with the City of Anniston and CalhounCounty, Solutia does not agree with the implication that drainage ditches that receivesurface water runoff from our facility require frequent maintenance.

Section 2.3, fifth paragraph: Solutia does not understand what is meant by the term"anecdotal map." Use of this term suggests the map may have been based on rumor andhearsay rather than sound technical data and is therefore not appropriate for use in adocument of this nature.

Section 3.1.1, first paragraph: This paragraph first states that PCB production began atthe facility in 1927. Later in the paragraph it is stated that PCB production began in1960. Neither of these statements is correct. PCB production began at the Annistonfacility in 1929.

Additionally, this paragraph interchanges the use of the terms Aroclor and PCB. It is notappropriate to use the terms Aroclor and PCBs interchangeably. Aroclor was theMonsanto trade name for polychlorinated polyphenyls, some of which contained PCBs.Solutia recommends using the term PCBs consistently throughout the document.

Section 3.1.1, second paragraph: This paragraph incorrectly states that one of the twophosphoric acid basins is still in operation. Both phosphoric acid basins have beenbackfilled and are no longer in operation. Additionally, this paragraph does not mentionmonitoring for PCBs that is conducted in accordance with the facility's NPDES Permit atoutfalls DSN 012 and DSN 006.

Section 3.1.2, Soil subsection: Solutia believes this paragraph misleads the reader byspecifically pointing out the highest concentration of PCBs detected during the RFI/CS.This paragraph fails to note that the soil sampling program presented in the RFI/CS WorkPlan, which was reviewed and approved by ADEM and USEPA, was intentionallydesigned to take into account over 17 years worth of historic sampling data. Surface soil


samples were purposely collected in areas that, based on site characteristics such asSWMU locations, topography, and previously collected data, would provide data to assistin identifying any chemical, including PCBs, which may have been released from aspecific SWMU. By presenting only the highest concentration detected, the reader maybe led to believe that this data point is representative of what was found hi other areas ofthe facility, which is not the case. In fact, out of all the sampling conducted, the samplereferenced in this section was the only sample which exceeded the risk-based SiteSpecific Target Level, or level of concern, in high contact areas of the plant. Only oneother soil sample exceeded the risk-based level of concern.

This section also fails to mention that the sample location where the highestconcentration was found has since been remediated by paving the area with concrete.

Section 3.1.2, Groundwater subsection: Solutia believes that it is important to note thatall PCB detections referenced in this section were found in unfiltered samples and thatPCBs were not detected in any filtered samples from these monitoring wells. Again, thereport's failure to consider that the detection of PCBs in groundwater samples is a resultof the presence of suspended particles calls into question the report's conclusions!

See comment on Section 1.4, Bullet 6.

Section 3.1.2, Air subsection, first paragraph: In Section 1,1, Objectives, it is clear thatthe purpose of this report is to evaluate the potential for on-going releases of PCBs fromthe site. Solutia believes it is important to note that the issue regarding odor from the on^site WWTP is in no way associated with PCBs or potential releases of PCBs from ourfacility. Solutia believes the paragraph is immaterial to the stated objectives of thisreport.

Section 3.1.2, Air subsection, second paragraph: The data presented in this paragraph isincorrect. For the July, 2000, air monitoring event PCBs were detected at levels between0.0021 ug/m3 and 0.0774 ug/m3. For the August, 2000 air monitoring event PCBs weredetected at levels between 0.0057 ug/m3 and 0.0369 ug/m3.

Section 3.1.3, Soil subsection: The reference in the RFI/CS Work Plan for using soilodor as a screening tool for parathion impacts was in the context of installing piezometersto evaluate the effectiveness of the OLBSI Corrective Action System. This observationwas not used in any quantitative way, since the piezometers were only used to observewater levels in the vicinity of the system. Groundwater quality was determined bysampling wells adjacent to the system. Thus, the inference suggested by the report thatodor was used a as quantitative screening tool to determine the extent of contaminatedsoil during the decommissioning of the SWMUs and AOCs is not correct.

Section 3.1.3, Groundwater subsection: See comment on Section 1.4, Bullet 6. Thissection also states that PCBs were found at a concentration of 600 micrograms per liter(ug/L) in well OW-8A. This is incorrect. The highest concentration ever detected inOW-8A is 22 ug/L. In 1997 a sample taken from well OW-8 was reported to have anunfiltered PCB concentration of 600 ug/L. However, a filtered sample found a PCBconcentration of only 79 ug/L suggesting the 600 ug/L result was a result of PCB


sediments being present in the sample. Well OW-8 was decommissioned with theapproval of ADEM and replaced with well OW-8 A. The PCB concentration in unfilteredsamples from well OW-8A has since decreased to below the detection limit with theexception of one sample in the second half of 2000 which was reported to contain PCBsat a concentration of 22 ug/L. PCBs have not been detected in any of the filtered samplesfrom this well.

Solutia also believes it is important to note that PCBs have not been detected in eitherfiltered or unfiltered samples from wells OW-15, OW-22, and OW-24 since early 1999,and that PCBs have never been detected in filtered samples from any of the wells listed inthis paragraph. PCB detections in groundwater can be attributed to PCB impactedsediments in the unfiltered groundwater samples and NOT the presence of dissolvedphase PCBs in groundwater.

This section also incorrectly states that well DW-1 was installed in 1997. The well wasinstalled in 1991.

Section 3.1.3, Air subsection: Subsequent to the release of this report a meeting was heldon August 22,2001 among Solutia, ADEM, and USEPA to discuss alternatives forevaluating the air pathway for Solutia's Anniston facility. At this meeting Solutia agreedto prepare a new RFI/CS Work Plan for further evaluating the air pathway. All partiesalso agreed that previously submitted work plans, including those referenced in thissection, would be withdrawn from consideration by the agencies. This was confirmed byADEM in a letter which has been attached to these comments.

Section 3.2.1, first paragraph: The opening sentence in this paragraph states that theSouth Landfill was in operation from the 1920s to 1989. This is not correct. The SouthLandfill was opened in approximately 1960.

Section 3.2.2, Soil subsection: This section states that there is no analytical data for anysoil samples collected from the South Landfill. This statement is not correct. Soilsampling conducted on the South Landfill in 1996 identified the presence of PCBs insurface soils on the South Landfill. It was this sampling that established the basis forInterim Measures completed on the landfill in the late 1990s.

Section 3.2.2, Groundwater subsection: This section notes that PCBs were detected at210 ug/L in well OWR-5D. It is important to note that this well is located within thecapture zone of the South Landfill Corrective Action System, and that this result is froman unfiltered sample of the groundwater. PCBs were not detected in the filtered result forthe same sample. See comment on Section 1.3, bullet 6.

Section 3.2.2, Surface Water and Sediment subsection: This section suggests that surfacewater flowing from Coldwater Mountain across the South Landfill was the sole source ofsurface water responsible for flooding that occurred in some areas of west Anniston.This is not an accurate portrayal of the sources of water that may have caused flooding.The area of the South Landfill covers only a small portion of Coldwater Mountain, andonly a small portion of surface water flowing from Coldwater Mountain would actuallycross the South Landfill. Additionally, there is a significant amount of property between


Coldwater Mountain and areas that were historically prone to flooding that would havealso contributed surface water volume to flooding events.

Additionally, this paragraph states that certain areas flooded often. Use of the term"often" is relative in nature and does not give an accurate portrayal of the frequency offlooding events. Solutia is aware of no information that would suggest flooding hi thearea of our facility occurred often, although flooding was known to have occurredperiodically.

Section 3.2.2, Air subsection: This section states that no air data has been collected fromthe South Landfill. This is not correct. Two air monitors have been placed on the southlandfill for over three years. Data has been provided to ADEM on a bi-monthly basissince January 1999. The ambient air data from the South Landfill have rarely exceeded0.010ug/m3

Section 3.2.3, Surface Water and Sediment subsection, first paragraph: This paragraphdoes not accurately describe the purpose of the Lower Detention Pond. The LowerDetention Pond serves to reduce the peak runoff from surface water flowing from theSouth Landfill to reduce the potential of flooding in the vicinity of 10th Street, notClydesdale Avenue.

Section 3.2.3, Surface Water and Sediment subsection, second paragraph: This sectiondoes not correctly describe the flow of surface water from the remediated areas of theSouth Landfill. Surface water flows from the upper diversion channel to the southwestwhere it is transported through an HOPE piping system under Highway 202 to thedischarge structure on 10th street. Surface water from the South Landfill flows to aconcrete lined ditch along the south side of Highway 202, is routed under the highway,and is captured in the Lower Detention Pond.

Section 3.3.1: This section contains several inaccuracies. In the first place, there wasnever a hog farm on the West End Landfill. In the early 1970s, Monsanto became awarethat some hogs were on Monsanto property just north of the South Landfill. Monsantopurchased the hogs from the residents, disposed of the hogs, and secured the area. Withregard to the disposition of the West End Landfill, Alabama Power Company acquiredthe area in a land swap; the land was not sold. In 1993, Monsanto reacquired, but did notbuy back, the property from Alabama Power Company to facilitate management andcontrol of the PCB-impacted materials. Finally, the second sentence of the section isgrammatically incorrect.

Section 3.3.2, Groundwater subsection: This section does not provide a completesummary of PCB data in groundwater collected from monitoring wells in the vicinity ofthe West End Landfill. Specifically, samples were also taken from monitoring wellsWEL-01, WEL-02, WEL-03, and WEL-04 in 1998. PCBs were not detected in anysamples collected from these wells. Additionally, following the sampling of WEL-03referenced in this paragraph, WEL-03 was redeveloped and sampled. PCBs were notdetected in this sample.

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Section 3.3.2, Surface Water and Sediment subsection: This section implies that surface,water runoff from the West End Landfill can be monitored at DSN 001. This is notcorrect. DSN 001 has never received surface water runoff from the West End Landfill.Therefore, the data presented is immaterial. A more appropriate indicator of surfacewater runoff from the West End Landfill would be data collected from DSN 006. Thisoutfall was sampled hi 1998 as part of the RFI/CS program. PCBs were not detectedduring this sampling event. Additionally, PCBs are analyzed for under Solutia's NPDES.Permit on a quarterly basis at DSN 006. PCBs have not been detected at this outfall inover three years.

Section 3.3.2, Air subsection: This section states that no air data has been collected fromthe West End Landfill. This is not correct. One air monitor has been placed on the WestEnd Landfill for over three years. An additional air monitor was colocated on the WestEnd Landfill for approximately two years. Data has been provided to ADEM on a bi-monthly basis since January, 1999. The ambient air monitoring data from the West EndLandfill stations usually report total PCBs at less that 0.010 ug/m3.

Section 4.1, second paragraph: Solutia agrees with the reports conclusion that the SouthLandfill is unlikely to be affected by large volume surface water runoff due to the upperdiversion channel. Solutia also believes it is important to note that a vegetative layer ismaintained on the South Landfill to further minimize the potential for erosion. The SouthLandfill is also inspected on a weekly basis to ensure no erosion is occurring. To date,these inspections have demonstrated the validity of EPA's conclusion on both the SouthLandfill and the West End Landfill. Solutia also believes that the report failed toconsider the existing operation and maintenance work plan establishing the schedule forperiodic inspections and describing the nature of such inspections.

Solutia does not agree with the conclusion that areas adjacent to the West End Landfillcan be affected by flooding. These areas are capped with a geofabric marker layer that iscovered by a minimum of eighteen inches of clean soil and a vegetative layer.Inspections of the West End Landfill and its adjacent areas are completed on a quarterlybasis. Given the flat topography in this area, it is very unlikely that eighteen inches ofsoil could erode within the period between inspections. However, in the unlikely eventthis were to occur, the geofabric marker layer would quickly identify the fact thatsignificant erosion had occurred allowing repairs to be made hi a timely manner. Thegeofabric would also provide an additional barrier to further erosion.

Section 4.1, fourth paragraph: Solutia strongly disagrees with the conclusion reached inthis paragraph that pervious covers do not provide adequate source isolation. Thisconclusion is based on speculation and completely ignores data that demonstratescorrective measures taken to date have, in fact, been effective at preventing migration ofPCBs from our facility.

The logic presented hi this paragraph is flawed. The largest potential source of surfacewater runoff in the vicinity of the facility is Coldwater Mountain. However, as noted inthis report, surface water runoff from Coldwater Mountain is not directed to themanufacturing facility. It is directed to the discharge structure at 10th Street and thelower detention pond, thereby ensuring that even in large storm events, it is not likely that


enough surface water flow could be generated to create washout of in-place pervious capsthat could result in the mobilization of PCBs. This is demonstrated by the fact that noevidence of erosion of the capped areas in the plant has been observed even though someof these caps have .been in place for over 15 years. Additionally, surface water that isdeposited on the manufacturing facility itself will tend to percolate down through thepervious cover and create a downward gradient, not an upward gradient, thereby ensuringany impacted materials will not rise to the surface. Solutia does not believe that it ispossible for impacted materials to move through a gravel cover against a downwardgradient and become mobilized via surface water flow. Furthermore, the gravel willreduce the flow velocity to the extent that erosion of the underlying soils is unlikely.

Additionally, sampling of surface soils in 1998 supports a conclusion that perviouscovers are in fact preventing migration of PCBs. Soil samples taken at sampling pointsSSR-07 and SSR-09 found PCBs in surface soils at 230 ppm and 280 ppm respectively.However, samples taken immediately downgradient from these points found PCBconcentrations of 0.034 ppm at SSR-08, and 9.3 ppm at SSR-06. Sampling points furtherdowngradient show PCB concentrations at six out of seven sampling points to be below 1ppm. Clearly this demonstrates that PCB migration is not occurring as suggested by theReport.

The conclusions reached in this paragraph also ignore the technical approach forconducting the RFI/CS program that was approved by ADEM and USEPA in the RFI/CSWork Plan dated November, 1997. Specifically, section 1.3, Technical Approach, statesthe following:

"The facility will be viewed as a single potential release source for the purposes of theRFL In addition, CS will be conducted at those SWMUs andAOCs identified in thePermit. Emphasis will be placed on potential off-site migration of constituents to assessperimeter control."

This section.goes on to state that, "The perimeter control assessment will be used toevaluate the effectiveness of the existing remedial systems." Additionally, Section4.2.3.1 of the Work Plan states that, "The potential for mobilization and off-site transportof surface soils from the SWMUs will be evaluated by monitoring the nearest surface-water outfalls, primarily in association with the NPDES program." Given this approvedapproach to conducting the facility RFI, Solutia believes that comments in the Reportsuch as those presented in this paragraph are important only to the extent that impacts atthe perimeter of the facility are being observed.

Based on this technical approach it is also important to note that Solutia is required tomonitor surface water runoff from our facility in accordance with an NPDES Permit andto report the results of our monitoring to ADEM on a quarterly basis. Sinceimplementation of corrective measures, including the placement of pervious covers,samples taken have shown a marked decline in PCB levels in surface water.

Section 4.1, fifth paragraph: Solutia does not agree with the conclusion that previousSWMU usage may not be a good indicator of the potential and extent of PCBcontamination. It is important to note that SWMU 44 was located immediately adjacent


the PCB manufacturing facility and that some runoff from the PCB manufacturingprocess was routed through a sump that is located near SWMU 44. It was for this reasonthat PCBs were analyzed for in this soil sample. Given the level of PCBs found at thislocation, Solutia does not believe that PCBs found in SWMU 44 are a result of migration,but are more likely the result of a historic release at this location. Additionally, surfacesoil data collected from other areas of the facility clearly suggest that previous SWMUusage is in fact a very good indicator of where PCBs are likely to be deposited.

This paragraph also states that the use of odor as a screening criteria is inadequate andinaccurate, as well as a health and safety concern. See our response to Section 3.1.3, Soilsubsection. It is also important to note that Solutia could not use odor as a screeningcriterion for PCBs, as they have no characteristic odor. Finally, Solutia does notunderstand what relation this statement has to the subject of this paragraph, specificallyPCB levels located at SWMU 44, and suggests it be deleted.

An incorrect statement is also made regarding interim measures at SWMU 44.Specifically, this area has been capped with concrete as recommended in Section 9.1 ofthe Draft On-Site RFI/CS Report dated January, 1999. It is not covered with a pervioussurface as described in the ERT Report.

Solutia also disagrees with the statement that pervious surfaces should not be consideredas either an interim or permanent remedial solution to existing PCB contamination. Seeresponse to section 4.1, fourth paragraph.

Section 4.1, sixth paragraph: Soil sampling activities undertaken'as part of the RFI werenot intended to provide any information regarding the effectiveness of any. excavationconducted at the manufacturing facility. As stated hi Section 4.2.3.1 of the RFI/CS WorkPlan, soil sampling was taken to evaluate the potential for off-site migration of impactedmaterials.

Section 4.1, seventh paragraph: Section 4.2.3 of the RFI/CS Work Plan, which wasreviewed and approved by ADEM and USEPA, provides the reason why samples werenot obtained for PCB analysis at SWMUs 17,25, and 31. Stormwater sampling is carriedout on a quarterly basis under the facility NPDES Permit. As presented in Section 4.2.4of the Work Plan, this data was used in the RFI/CS.

Section 4.2, first paragraph: Solutia strongly disagrees with the conclusion that availableanalytical data for PCBs in groundwater are insufficient. The report provides noexplanation for this statement, nor does it cite any regulations, guidance, or data tosupport this conclusion. In accordance with the approved technical approach forconducting the RFI/CS (see response to Section 4.1, fourth paragraph) groundwater ismonitored for and, where necessary, captured at the perimeter of the facility. Samplesare collected on a semi-annual basis to evaluate the effectiveness of our groundwatercollection systems, and this data is submitted to ADEM and USEPA for their review.The groundwater management systems are effective, and the data collected to date clearlydemonstrate that no constituents of potential concern, including PCBs, are migratingoutside the perimeter of our facility.

Solatia Inc. Page 12 10/5/01

Section 4.2, second paragraph: See response to Section 1.4, bullet 6. It is also importantto note that ADEM has agreed that the results of filtered samples can be reported inperiodic groundwater quality reports along with the results of unfiltered samples.

Section 4.2, third paragraph: As discussed in the comment to Section 2.2 of the ERTReport-, slickenslided features were only found sporadically around the site. There is noevidence that would suggest these features form a conduit for groundwater flow, otherthan in localized and highly discrete areas. In addition, where slickenslides wereobserved, they were generally in the shallow residuum. As mentioned in the RFI/CSreport, the deep residuum was more dense and acted as a barrier to prevent groundwaterflow moving into the shallow bedrock. The paragraph also alludes that the configurationof the shallow bedrock was unknown because of the limited depth of the investigation.As reported, the depth of the investigation was sufficient to characterize the nature andextent of groundwater impacts. The investigation was not undertaken to great depthsbecause non-spurious impacts were limited to the shallow residuum.

Section 4.2, fourth paragraph: Solutia does not understand the basis for the hypotheticalexercise conducted in this paragraph. The paragraph begins by stating that the SouthLandfill groundwater corrective action system is effective, yet continues to conduct ananalysis as if the system is not effective. Additionally the analysis draws conclusionsbased on the hypothetical scenario that PCBs have been migrating from the SouthLandfill without being captured by the in place corrective action system from 1920 untilthe present. This logic is flawed for numerous reasons. First, PCBs were notmanufactured at the Anniston facility until 1929. Additionally, the South Landfill wasfirst operational in approximately 1960, a full forty years after the analysis in thisparagraph assumes PCBs were placed in the South Landfill. Also, the groundwatercorrective action system has been operating since 1983, collecting any potentiallyimpacted groundwater. This fact is also ignored in the analysis. In addition, the analysisfails to account for simple groundwater transport parameters such as retardation. Even ifgroundwater travels at 11 ft/yr or 4 fVyr, contaminants in groundwater are affected bynumerous processes that nearly always result in slower movement. PCBs are immobilein groundwater and would move substantially slower than groundwater. Even if theseissues were not considered, the analysis makes no sense mathematically. The analysisindicates the plume would have moved 1,100 feet in 25 years (1920 to 1945) moving at arate of 11 ft/yr. To move 1,100 feet at a rate of 11 ft/yr would require 100 years, not 25years. Finally, as stated previously, groundwater data collected at the Solutia facilitydemonstrates that PCBs are not migrating in groundwater outside the perimeter of ourfacility. For these reasons Solutia believes that all conclusions and implications drawn inthis analysis are of no value.

Section 4.2, sixth paragraph: Solutia disagrees that detection of PCBs in samples takenfrom monitoring wells OW-21 and OW-22 are an indication of PCBs migrating off-site.It is first important to note that both wells are located on Solutia owned property.Therefore, these wells are not off-site as stated in the Report. It is also important to notethat PCBs have been detected in well OW-22 only once in early 1999. The concentrationof PCBs detected was 1.2 parts per billion (ppb). When this sample was filtered, PCBswere not detected. Based on this data, Solutia does not believe that PCBs are migratingoff-site in the vicinity of OW-22.


Solutia also believes that PCBs detected in OW-21 raise questions regarding the integrityof the well. OW-21 is an older well, installed in the late 1980s. It was also installed inan area where PCBs were later discovered to be present in surface soils at elevatedconcentrations. Well construction diagrams indicate that the well was installed without asurface casing. Consequently, it seems likely that PCBs were dragged down the boringwhen the well was drilled. This conclusion is supported by the fact that when samplesfrom OW-21 are filtered, PCBs are not detected.

Section 4.2, seventh paragraph: A preponderance of the data collected during the 19,99RFI/CS program suggests that groundwater in the vicinity of the West End Landfill is notimpacted by PCBs, contrary to statements made in the Report.

Section 4.3, first paragraph: See response to Section 2.3, fourth paragraph.

Section 4.4, first paragraph: See response to Section 4.1, fourth paragraph.

Section 4.4, second paragraph: The conclusions reached in this paragraph are speculativein nature and should not be made without supporting data. There are many factors thatcan impact concentrations of PCBs in air that are completely disregarded in this analysisincluding, but not limited to, temperature, wind speed, and wind direction. Additionally,the Report points out another limiting factor in that this analysis assumes all PCBsdetected are of a particulate form, yet no data are available to support this conclusion.This is important because if PCBs are in a vapor phase, then the mechanisms creatingmobilization of PCBs assumed in this report are immaterial. In fact soil and airmonitoring data collected by Solutia and submitted to ADEM show that PCBs detected inair have been lower chlorinated PCBs while PCBs detected in soils have been the higherchlorinated PCBs suggesting that PCBs detected in air are not a result of dust and soilsparticles being blown into the air.

Section 5.1: Solutia disagrees with the conclusion that the amount of PCB data in soil,groundwater, surface water, sediment, and air are limited. Given the stated technicalobjective of the RFI/CS program (see responses to Section 4.1, fourth paragraph, andSection 4.2, first paragraph), Solutia believes adequate amounts of data have beencollected to evaluate title potential for PCB migration from the site.

Section 5.1.1, first paragraph: Solutia believes the existing soil data at the plant sitelargely satisfies the stated technical objectives of the RFI/CS Work Plan. The need foradditional soil data is only warranted where well-defined data gaps are identified. In thiscontext we have already agreed to a supplemental soil investigation to evaluate soilconditions at SWMU 12.

Additionally, Solutia does not agree that pervious surfaces are not effective. (Seeresponse to Section 4.1, fourth paragraph).

Section 5.1.1, third paragraph: The report provides no basis for conducting furthersampling to identify the vertical extent of PCBs in areas adjacent to the West End


Landfill. As stated in Section 3.3.3 of the Report, areas adjacent to the West End Landfillhave been capped with a geofabric material, a minimum of eighteen inches of cleanmaterial, and a vegetative layer. Groundwater data from wells in the vicinity of the WestEnd Landfill also support a conclusion that the vertical extent of PCBs has no bearing onthe possibility of off-site migration.

Section 5.1.2: While Solutia has agreed to consider only unfiltered groundwater hi theanalysis of PCS impacts to groundwater as part of the RFI/CS process, Solutia maintainsthat the report should note the fine-grained nature of the soils at the Solutia facility asdefined in the report result in a situation where: 1) fine-grained particles can be found incollected samples, and 2)'-low yields from the soil formation limit the ability to properlydevelop the groundwater wells and remove suspended sediments. Our substantialexperience at the Anniston facility demonstrates that the ability to produce non-turbidwater is problematic. Some wells develop properly and produce non-turbid water, whileother wells will produce turbid water regardless of the effort put into well development.Filtering is' therefore necessary to provide representative samples of the quality ofgroundwater moving within the clay residuum.

For these reasons Solutia believes that filtered samples are more representative ofgroundwater transport conditions, and that any conclusions drawn that ignore this arequestionable. •

The report fails to mention that PCBs were not detected hi any of the groundwatersamples collected from the shallow residuum in the vicinity of the West End Landfill, norwere they detected in the filtered sample from OWR-7D. Solutia believes this datasupport a conclusion that groundwater in the vicinity of the West End Landfill is notimpacted by PCBs. However, as part of the ongoing RFI process, Solutia has agreed tocollect additional groundwater samples in the vicinity of the West End Landfill for twoyears to confirm these findings, pending issuance of a permit modification by AD EM.

Solutia does not agree with the statement that data from OW-22 support a need foradditional monitoring in the vicinity of this well. Solutia also believes that PCBsdetected in well OW-21 are a result of the well installation process (see response toSection 4.2 paragraph 6). However, as part of the RFI/CS program Solutia has agreed toinstall a new well in the vicinity of well 0W-21.

Groundwater data collected as part of the ongoing RFI/CS process support a conclusionthat potentially impacted groundwater is being captured on-site and is not migratingoutside our facility. We therefore disagree with the statement that further study isrequired to determine groundwater discharge points from the Solutia property.

Section 5.1.3: Solutia does not agree that ongoing releases of PCBs at a significant levelvia surface water runoff are occurring. This conclusion is supported by data collected inaccordance with an ongoing NPDES program. Therefore, no further evaluation of thesurface water pathway is required other than ongoing monitoring conducted inaccordance with the NPDES program.

Solutialnc. Page 15 , 10/5/01

Solatia also does not understand the basis for the statement that,"... selected samplinglocations should be identified and cleaned up." Until data is available from a specificlocation and is properly evaluated in accordance with regulatory guidance, there is nobasis for concluding any type of remediation is required, and if it is required, of whatnature the remediation should be.

The soil used for installing the cap and cover system on the South Landfill was excavatedfrom native soils from an area sidegradient to the South Landfill. .Soils were excavatedfrom a depth of over 30 feet. For this reason, there is no basis to speculate that PCBs arepresent in the cap of the South Landfill and thus no logical basis upon which to concludethat sampling of the concrete ditch along Highway 202 or the Lower Detention Pond isappropriate. The ditch along Highway 202 was lined with concrete after the completionof the cap and cover system. Therefore, there is no reason to speculate that there are anyimpacted sediments in this ditch. Surface water sampling from the Lower DetentionPond revealed no PCBs above the detection limit further supporting a conclusion that ,sampling of the Lower Detention Pond is not necessary.

Section 5.1.4: Solutia disagrees with the statement that the air pathway remains a majorsource of concern. During the development of the RFI/CS Work Plan, all potentialpathways by which constituents of potential concern (COPC), including PCBs, couldenter the environment were examined. The air pathway was eliminated as a potentialpathway during the RFI because COPCs were primarily semi-volatile organic compoundswith low vapor pressures. This decision is supported by Region 9 PRGs which suggestthat, "volatile chemicals [are] defined as those chemicals having a Henry's Law constantgreater than 10"5 (atm-m3 /mol) and a molecular weight less that 200 g/mole..." Whilethere are Henry's Law constants for PCB mixtures published in scientific literature thatexceed 10"5 (atm-m3/mol), the molecular weight of all the major Aroclor mixturesexceeds 200 g/mole. Similarly, the USEPA's 1996 Soil Screening Guidance: TechnicalBackground Document does not contain an SSL value for the "Inhalation volatiles"pathway, while the 2001 Draft of the SSL guidance document does not include any valuefor PCBs. Thus, these two primary sources for risk-based values do not considervolatilization of PCBs from soil a significant exposure pathway.

It was also concluded in the RFI Work Plan that the surface stabilization measuresconstructed around the facility since 1971, when PCB production was discontinued, hadreduced the potential for airborne dust, and this pathway was eliminated as a pathway ofconcern. This evaluation was accepted by ADEM, and the Work Plan was approved byADEM on April 21,1998.

Currently, air sampling devices are mounted at five locations, and 24 hour samples arebeing collected twice per month. The results of this program confirm that PCB migrationvia an air pathway is not a source of concern in that concentration are typically in therange of 0.1 to 50 nanograms per cubic meter (ng/m3). All of the air levels detected bySolutia, plaintiffs attorneys, and by EPA have been orders of magnitude below theOSHA PEL for Aroclor 1242, which is 1,000,000 ng/m3-. The OSHA PEL is strictlyapplicable only to occupational exposures, which are considered to be 40 hours per week.Even if the OSHA PEL is divided by four to adjust for a worst case, 168 hours per weekexposure scenario, the levels at the Anniston facility are still orders of magnitude lower


than the PEL. They are also well below the 1,000 ng/m3 recommended by NIOSH, alevel which was based on analytical considerations and is not a risk-based value.Additionally, at PCB operating landfills in other areas of the country notification levelsare in the range of 100 to 300 ng/m3 and work stoppage levels are greater than 1000ng/m3. Solutia believes that this clearly supports a conclusion that the air pathway is nota source of concern in Anniston.

Solutia has agreed to work with ADEM and USEPA to further evaluate the air pathwayto better understand the reason for the observed levels of PCBs in air. There are,however, more effective alternatives for conducting this investigation than thoseproposed in the Report. Subsequent to the release of this report a meeting was held onAugust 22, 2001 between Solutia, ADEM, and USEPA to discuss alternatives forevaluating the air pathway for Solutia's Anniston facility. At this meeting Solutia agreedto prepare a new RFI/CS Work Plan for further evaluating the air pathway.

Section 5.2: Solutia believes it is important to point out that the RFI/CS program at theAnniston facility is far from complete. An RFI/CS Report was submitted to ADEM inJanuary, 1999. Solutia has received comments on this report and has recently submitted aresponse to these comments to. ADEM. Upon approval of the RFI/CS Report aCorrective Measures Study will be performed to evaluate the need for correctivemeasures at the site. If corrective measures are required, a modification will be made toSolutia's RCRA Post Closure Permit and made available for public notice. Solutiabelieves that this is the most appropriate process to address corrective measures at theAnniston site, and that any recommendation regarding corrective measures in the Reportshould only be considered in the context of the RFI process.

Solutia also believes that recommendations regarding corrective measures are clearlyoutside the objective of this report as stated in Section 1.1, which specifically states, "Theobjective of the evaluation is to assess the completeness of the investigative and remedialwork performed to date and to evaluate the potential for on-going releases ofpolychlorinated biphenyls (PCBs) from the Site." Nowhere in this section does it statethat an objective of the report is to provide recommendations for corrective measures.Additionally, as presented in the above comments, there are a number of inaccuracies inthe evaluation of data within this report. Therefore, Solutia does not consider itappropriate to comment on any specific recommendations for corrective measures untilall investigation activities and a corrective measures study is completed in the context ofthe RFI/CS process.

Solutia interprets the following recommendations to fall in this category:

• Section 5.2.1, first bullet• Section 5.2.2, first bullet• Section 5.2.3, first bullet

Comments will only be made on those recommendations that meet the objectives of theReport.


Section 5.2, second bullet: In response to comments on the RFI report, Solutia agreed toinstall an additional well to help define the completeness and accuracy of data obtainedfrom well OW-21. We also proposed to prepare an interim measures work plan toevaluate the need to improve the performance of the Old Limestone Bed CorrectiveAction System.

Section 5.2, third bullet: Solutia does not agree that additional investigation should beundertaken in the bedrock. Sufficient investigations of the bedrock and interface betweenthe bedrock and the residuum have been completed..

In addition, the focus on the bedrock is unfounded. The report appears to suggest that theSolutia site may potentially impact Coldwater Spring. However, water qualitymonitoring of Coldwater Spring consistently finds that PCBs are not present.

Section 5.2, fourth bullet: Although it is not clearly stated, Solutia believes the logic usedto develop this recommendation is presented in Section 4.2, fourth paragraph. As statedin our comment to this section, the logic used to develop this recommendation is flawed.Solutia does not agree that there is any need to conduct the analysis recommended. Thecalculation would be meaningless, as water is captured by the in-place corrective actionsystems.

Section 5.2, fifth bullet: See comment on Section 5.1.4.

Section 5.2.1, second bullet: Solutia does not believe additional surface soil data isrequired at the site. See comment on Section 4.1, fourth and seventh paragraphs.

Section 5.2.1, third bullet: See comment on Section 4.1, fourth paragraph.

Section 5.2.1, fourth bullet: See comment on Section 4.2, paragraph 6.

Section 5.2.2, third bullet: Solutia does not believe there is a need to further evaluate thedeep residuum based on a single sample from OWR-5D. It is important to note thatPCBs were not detected in the filtered sample from OWR-5D (see comment on Section5.1.2, paragraphs 1 and 2). Additionally, OWR-5D is located within the capture zone ofthe SWMU 1 Corrective Action System.

Section 5.2.2, fourth bullet: See comment on Section 5.1.3, first paragraph.

Section 5.2.2, fifth bullet: See comment on Section 5.1.3, first paragraph. Additionally,because there is no reason to believe the soils used to cap the South Landfill are impactedby PCBs, there is no reason to expect impacts to the Detention Pond from ongoing runofffrom the South Landfill.

Section 5.2.3, second bullet: Five monitoring well are installed northwest of the WestEnd Landfill. Solutia believes these wells provide adequate coverage for monitoringgroundwater that may migrate from the vicinity of the West End Landfill. See fourthparagraph of comment on Section 5.1.2.


Section 5.2.3, third bullet: See fourth paragraph of comment on Section 5.1.2.

Section 5.2.3, fourth bullet: See fourth paragraph of comment on Section 5.1.2.

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