State Environmental Protection Division publishes update on Crown Lake site

Mar. 1—The Georgia Environmental Protection Division published a mammoth 1,000-page-plus compliance status report pertaining to the W.F. Taylor LLC property in Dalton last month.

The report, prepared by Alpharetta-based Environmental International Corp. (EIC), details a voluntary investigation and remediation plan, or VIRP, for the roughly 3.18-acre site at 209 Crown Lake Drive Southeast.

"Before implementing the VIRP, the environmental impairments were addressed under a corrective action plan that led Taylor into a perpetual remedial program with minimal progress," the report states. "As such, Taylor retained Environmental International Corp. to obtain EPD approval for implementing a more practical approach with defined regulatory remedial endpoints under the VRP (voluntary remediation program)."

Volatile organic compounds, also known as VOCs, were identified at the site in 2007.

"Although the actual source(s) contributory to the soil and groundwater impacts remained undefined, Taylor LLC submitted a hazardous site response act notification to the EPD in September 2007," the report reads. "On Dec. 18, 2007, EPD listed the site under the hazardous site inventory."

A corrective action plan, or CAP, was approved by the EPD in June 2010.

"The CAP specified soil excavation in the vadose zone and in-situ enhanced biological treatment as remedies to treat the impacted soil and groundwater," the report states. "After initiating CAP activities, groundwater impacts remained persistent at the site for over a decade."

The report indicates that additional soil and groundwater contamination was identified in a small area within the initial VOC footprint.

A meeting between the EPD and Taylor representatives took place on March 10, 2021. A subsequent VIRP was approved by the EPD on Dec. 22, 2021.

The report indicates the site is currently used for the processing and manufacturing of industrial adhesives, with no changes anticipated for the property's use.

Per the report, trichloroethylene (TCE) was stored at the site in an above-ground storage tank.

"Although soil and groundwater impacts were found at the Taylor site, no records of solvent releases were available from Taylor's historic operations," the report reads. "As result, the potential source(s) of release in this area remain undefined."

According to the report, human and ecological receptor exposure via soil and groundwater is "unlikely" at the site.

"EIC determined that the residual soil was confined to one area known as AOC-3 and the site monitoring data indicated that the groundwater plume was attenuating," the report states. "EIC demonstrated that vapor intrusion was not a concern at the Taylor property or the hydraulically downgradient VRP qualifying properties."

To address soil impacts at the site, the report indicates that a paved restricted use zone was designated at the property.

"To address the groundwater impacts, EIC prepared uniform environmental covenants for Taylor and the other qualifying properties as an institutional control to prevent groundwater use at all qualifying properties," the report adds. "On behalf of Taylor, EIC submitted a requisite maintenance and monitoring plan which outlines methods to maintain engineering and institutional controls to prevent future exposure."

The report indicates Taylor will also prepare a contractor health and safety awareness plan to "inform each property owner of the limitations associated with disturbing and/or stockpiling contaminated soil and with recovering contaminated groundwater."

That plan, the report continues, will identify the footprint of "constituents of concern" in soil and groundwater at the property.

"The plan will also stipulate that any stockpiled soil should be properly managed to prevent leaching and erosion and that any extracted groundwater should be properly contained and not be discharged into the stormwater system or surface waters."

The report explicitly notes that groundwater extraction from the Taylor property will be prohibited.

"If any future development of the properties is planned with enclosed structures in the area covered by the restricted use zone, a vapor intrusion evaluation will be required and appropriate vapor mitigation measures will be required," the documents read. "As Taylor has demonstrated that vapor intrusion from the underlying groundwater plume is not a concern for the existing buildings on those properties, no additional vapor intrusion studies are required for any future developments above the water table."

A 30-day public comment period regarding the compliance status report opened on Feb. 26.

"EPD is currently reviewing the compliance status report to determine if corrective action is needed for regulated substances that have been released at this site," a public notice reads. "Before EPD decides whether corrective action is needed, the public has the opportunity to review the compliance status report and provide comments to EPD about the report."

A copy of the full report can be viewed online via the EPD's public inquiry portal at epd.georgia.gov.