Woolfolk Chemical Works, Inc.

• Site Profile
• Administrative Record Index (PDF): OU1 (37 pp., 3.1 M), OU2 (17 pp., 1.1M),
  OU3 (3 pp., 153K), OU3 AMD (8 pp., 481K), OU4 (5 pp., 276K), OU4 ESD (1 pp., 21K)
• Additional Site Documents including Five Year Reviews, Records of Decisions (ROD) and Explanation of Significant Differences (ESD).
• For documents not available on the website, please contact the Region 4 Freedom of Information Office (http://www.epa.gov/region4/foiapgs/submit.htm).

Site Background:
The Woolfolk Chemical Works Site in Fort Valley, Georgia is a 31-acre site which resulted from the facilities production, formulation, and packaging of pesticides, herbicides, and insecticides since 1910. In the early 1980s, the Georgia Environmental Protection Division investigated the site based on complaints from local citizens. The company was discharging waste products to a drainage corridor heading away from the site. Canadyne-Georgia Corporation (CGC) sold the property to Peach County Properties Inc. and as a part of that agreement began a removal action to remediate a lead-arsenic plant and the surrounding soils. Contamination reports from this removal effort indicated a more extensive problem at the site. The site was put onto the National Priority List in August 1990, CGC entered into an Administrative Order on Consent in April 1990 to implement a Remedial Investigation/Feasibility Study (RI/FS). The RI and the baseline risk assessment indicated that there were 48 contaminants of potential concern, however, that the majority of the risk was being driven by the arsenic contamination.

Cleanup Progress: Actual Construction Underway
The results of the RI indicated that the contamination had spread from the 18-acre facility onto the surrounding residential properties. EPA issued a Unilateral Administrative Order to implement a Removal Action at the site in December 1993. This was followed by a ROD in March 1994 for long term cleanup at the site. This action resulted in the removal of contamination from 26 residential properties, including 22,900 tons of soil and debris. CGC also purchased approximately 17 properties and converted them to commercial use. It was also found that the drainage corridor was significantly contaminated by arsenic and pesticides, therefore, CGC was ordered to complete a removal action in approximately ½ mile of the most effected areas of the corridor. This action resulted in the removal and appropriate disposal of 26,000 tons of arsenic-contaminated soils and debris. Furthermore, CGC was ordered to complete the demolition of a building used to package Silex which contains dioxin. Approximately 45 cubic yards of demolition debris was shipped for incineration in Coffeeville, Kansas. Finally, house dust in eight homes were found to have excessive arsenic levels. The cleanup of these homes was completed in July 1997 with monitoring activities in the home being conducted on a quarterly basis until June 1998.

As a result of the conversion of residential properties to non-residential use, EPA issued a second ROD in September 1995 which integrated the redevelopment of these properties into a library, an adult education center, and a Welcome Center for the City. Construction of the library began in October 1996 and was completed in 1998. The welcome center for the City is currently under renovation. In addition, the installation of the groundwater pump and treat system was conducted in 1998. The system is currently operational and functional.

OU#3 ROD was signed on August 6, 1998 that addressed soils and buildings on the former Woolfolk plant site, the capped area containing materials form earlier site cleanup activities and the stormwater drainage system both on and off the site (Preston Street portion).

PRPs were not in compliance with the OU# 3 UAO. PRPs indicated in writing by letter dated October 19, 1998, that they could not comply with the UAO.(They said they didn't have enough money to implement the ROD. They also indicated that the volume of contaminants to be addressed, duration of remediation and cost of the cleanup are grossly underestimated. The ROD estimated approximately 8,000 cy of material would be excavated for transportation off-site. The PRPs have indicated that the volume could be as high as 35,000 cy.)

EPA called and met with the primary PRPs several times in an attempt to bring them into compliance with the UAO (from late October to December). Our efforts did not bring the PRPs into compliance.

RPM proceeded with a Fund-Lead remedial design using a RACS contractor. In addition, representatives from ESD in Athens, GA and from ORD in Cincinnati, OH were used in collecting and analyzing samples results from the capped area and evaluating innovative technologies to remediate the contaminated material found. The results from the sampling activities indicated that approximately 40,000 cubic yards of material exceed the cleanup levels identified in the ROD (approximately 4 times larger than the ROD estimated). Based on this new information, an Amended Proposed Plan and a ROD Amendment were prepared in 2004 which identified the additional risk resulting from the increase in volume of contaminated material at the site and discussed the alternatives being considered for remediation of that contamination.

The Amended ROD for OU#3 (Former Manufacturing Facility) and ROD addressing OU#4 (Oversight areas 63 attics and 47 residential properties) were signed by the Division Director in 2004. the RODs are currently being implemented under the ERRS contract.

To date all excavation of arsenic exceeding action levels from residential soil is complete. all remediation of arsennic contaminated dust from above action levels from residential attics is complete. The RA report documenting the completion of cleanup activities in OU#4 is expected to be complete by March 30, 2008.

Remediation activities in OU#3 are ongoing. The volume and concentrations found on-site were significantly greater than expected. According to data gathered during the RD, approximately 120,000 cy of contaminated material was expected to be excavated. To date, over 500,000 cy of material has been excavated at the site. Due to increase in volume and concentrations, additional funds will be needed to complete the cleanup. Excavation of contaminated soils in OU#3 is expected to be completed in FY 09 if sufficient funding is available. Site restoration and pavement of areas with restricted use is expected to be completed in FY 2010.

OU#5 which addresses drainage ditch though undeveloped part of the county will focus on Eco and is in the RI stage. Once sampling results from OU5 are available, the RPM will evaluate the data to determine if a hot spot removal of highly contaminated areas of the ditch would allow for an expedited cleanup of the area. The soils that would be removed could be treated with OU3 soils (Former Manufacture Facility) with the current contractor and equipment saving time and money for the Government.

An Alliance group has been formed at the site to provide a forum for all involved to discuss and address cleanup issues, so that the Woolfok site remediation results in a safe place to live, protects the environment and where possible, helps the local economy. The Alliance Group meets every 6-8 weeks at the Fort Valley City Hall. The Alliance group consist of representatives from :The City of Fort Valley, Peach County, Fort Valley Utilities Commission, Woolfolk Citizens Response Group WCRG), local citizens, Businesses (Canadyne-Georgia Corporation, Holcomb Tire Corporation, SureCo Inc.) and Federal and State Agencies (Agency for Toxic Substances and Disease Registry (ATSDR) Georgia Division of Public Health, Georgia Environmental Protection Division (EPD) and Environmental Protection Agency Region 4 (EPA).