Solutia

May 12, 2017

SENT VIA E-MAIL AND FEDERAL EXPRESS

Ms. Pamela J. Langston Scully, P.E.

Remedial Project Manager
United States Environmental Protection Agency, Region IV
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960

Re: Operable Unit 1/OperabIe Unit 2

Comments on the Proposed Plan
Anniston PCB Site (Docket No. l:02-cv-0749-KOB); Anniston, Alabama

Dear Ms. Langston Scully:

This letter provides comments from Pharmacia LLC and Solutia Inc. (P/S), as parties to the Partial Consent
Decree (PCD; August 4, 2003) on the Proposed Plan for the Operable Unit 1/Operable Unit 2 (OU-l/OU-
2) portion of the Anniston PCB Site (the Site). The Proposed Plan was issued for public comment by the
United States Environmental Protection Agency (USEPA) on March 13, 2017. Comments from P/S are
included as a series of Attachments, listed as A through C, as described below:

Attachment A: General comments are provided in this attachment and are organized by the eight
categories of remedial alternatives that were presented in the Proposed Plan. The eight categories of
general eomments include:
Residential properties
Special use properties
Interim measures (IMs)
Dredge spoil piles
Unapproved waste disposal areas (UWDAs)
Nonresidential properties
Groundwater at T-11
Snow Creek Sediment and Creek Banks
Attachment B: Specific comments on the Proposed Plan are provided in this attachment, and many of
these comments are consistent with the themes presented in the general comments. The specific
comments also provide citations to pages within the Proposed Plan to further describe the source(s) of the
comments.
Ms. Pamela J. Langston Scully, P.E.
May 12, 2017 Page 2 of 2

Attachment C: Editorial and consistency comments on the Proposed Plan are provided in this
attachment.

Please contact me if you have any questions.

Sincerely,

E. Gayle Macolly Harris
Manager, Remedial Projects
Solutia Inc.

Attachments

cc: Mr. Chip Crockett (ADEM)

Mr. G. Douglas Jones, Esq.
Mr. Thomas Dahl
Mr. David Reddick, CAG
Mr. Bertrand Thomas, TA
ATTACHMENTA

General Comments on the Proposed Plan

 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

Preamble

This document provides comments from Pharmacia LLC/Solutia Inc. (P/S) as parties to the Partial
Consent Decree (PCD; August 4, 2003) on the Proposed Plan for the Operable Unit 1/Operable 2
(OU-l/OU-2) portion of the Anniston PCB Site (the Site) issued by the United States Environmental
Protection Agency (USEPA) for public comment on March 13, 2017. The comments from P/S include
general comments provided in Attachment A, specific comments in Attachment B, and
editorial/consistency comments in Attachment C. In addition to the Proposed Plan, the USEPA sent
three separate documents to P/S as part of releasing the Proposed Plan for public comments. These
three documents and the associated comments/responses from P/S are listed below and should be part
of the Administrative Record for the Site.

Letter from the USEPA to P/S dated March 7, 2017 with the subject. Residential Properties with
Residual PCBs in Soil, and the associated comments from P/S dated May 12, 2017

Letter from the USEPA dated March 7, 2017 with the subject. Feasibility Study Report Approval
with Comments and the associated responses from P/S dated May 12, 2017

Memorandum from USEPA Region IV dated March 10, 2017 responding to recommendations
from the USEPA National Remedy Review Board (NRRB), and the associated responses from P/S
dated May 12, 2017

The documents from the USEPA listed above include critical information regarding the USEPA's
Proposed Plan and the comments/responses that were submitted by P/S under separate cover require
written responses from the USEPA. These responses are incorporated into these comments as if fully set
forth herein and should be included in the Responsiveness Summary portion of the forthcoming Record
of Decision (ROD) to ensure the completeness of the Administrative Record.

General Comments

Residential Properties

1. The USEPA proposed, in a letter dated March 7, 2017, that P/S assume responsibility for 59 Anniston
Lead Site properties with PCB residuals. These properties do not meet the definition of the Anniston
PCB Site and, therefore, the PCB residuals on these Anniston Lead Site properties are not the
responsibility of P/S. These residential properties were separately addressed by the USEPA and a
group of Responsible Parties (RPs) under a Removal Order (RO) to which P/S are not party. Since P/S
are not the source of contamination on these for the Anniston Lead Site properties, the letter should
not have been addressed to P/S.

2. The USEPA recently issued a Desk Statement Regarding Lead Contamination in Soil (Desk Statement;
USEPA September 2016). The USEPA should consider the implications on the upper threshold
concentration for lead in soil (400 mg/kg) that was used to trigger removal actions for the Anniston

Attachment A page 1 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

Lead Site properties under the RO. Specifically, residential properties with lead concentrations less
than 400 mg/kg may have unacceptable risks, including the 59 properties discussed in general
comment no. 1.

3. While the text and tables of the Proposed Plan are footnoted to explain the number of properties
associated with the Anniston Lead Site and the Anniston PCB Site, the remedial alternatives
presented in the Proposed Plan do not include costs for soil management and long-term operation
and maintenance (O&M) for the Anniston Lead Site properties that the USEPA is attempting to
transfer to P/S.

Special Use Properties

1. The PCB Preliminary Remedial Goal (PRG) for the low activity portions of the special use areas
should be consistent with the PCB PRG used for the other nonresidential potions of OU-l/OU-2
(21 mg/kg). Thus, the selected remedy for the special use properties should be remedial alternative
SU-2, not SU-3. The proposed remediation of low activity portions of the special use areas to
support school/daycare exposures is inconsistent with current land use, the Stipulation and
Agreement (Stipulation) to the PCD, and the human health risk assessment (HHRA) prepared for
OU-l/OU-2 by the USEPA.

2. The comparative analysis presented in Table 20 of the Proposed Plan supports the selection of SU-2,
not SU-3 as recommended in the Proposed Plan. SU-2 and SU-3 are rated the same in the
comparative analysis table with the exception that SU-3 costs significantly more while providing no
additional protectiveness. SU-4 is appropriately noted as having more short-term negative impacts
while providing no additional protectiveness (and costing more).

Interim Measures

1. The recommended remedial alternative presented in the Proposed Plan for the IM areas (IM-4) is
more disruptive to the community than the two other active remedial alternatives (IM-2 and IM-3);
and based on the comparative analysis table in the IM Fact Sheet (Table 3; page 8), both IM-3 and
IM-4 are "effective and permanent." Based on this, IM-3 should be the recommended remedial
alternative, not IM-4.

2. The Proposed Plan Fact Sheet incorrectly lists PRGs for non-Site related constituents for surface and
subsurface soils located in the IM areas (IM Fact Sheet page 5). The list of non-PCB constituents
includes: arsenic, chromium, polycyclic aromatic hydrocarbons (PAHs) as benzo(a)pyrene
equivalents (BaPE), and toxic equivalents (TEQ). As stated in the Proposed Plan (p. 40): 'There is
substantial data to link these contaminants to multiple industrial operations in the area, even some
still operating in the floodplain.

3. Including dioxin-like PCBs (DL-PCBs) with the polychlorinated dibenzo-p-dioxin/ dibenzofuran

(PCDD/DF) component of TEQ is not necessary or appropriate. The cleanup of total PCBs in soils for

Attachment A page 2 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

the IM expansion areas is consistent with the conclusions of the OU-l/OU-2 HHRA prepared by the
USEPA, and there is no need to separately assess the risks from DL-PCBs because there is no
relationship between PCDD/DFs and total PCBs on this Site. If PCDD/DFs are of concern, they should
be addressed separately by other parties.

4. The subsurface soil PRG for PCBs of 97 mg/kg is not directly applicable to the IM expansion areas
(page 56 of the Proposed Plan). This subsurface PRG was developed to protect receptors
(construction and utility workers) whose exposure was evaluated on an OU-wide basis and not an
EU, area or location basis. The OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the subsurface
soil PCB exposure point concentration (EPC) of 99 mg/kg was equivalent to the subsurface PRG
(97 mg/kg) and thus remediation of subsurface soils is not required.

5. The Proposed Plan inconsistently and incorrectly describes how the presence of a Principal Threat
Waste (PTW) in soil is identified. The Proposed Plan (pages 56, 57 and 58) correctly includes the use
of groundwater impacts at concentrations exceeding the maximum contaminant level (MCL) in the
process to identify PTW. However, there are other portions of the Proposed Plan (pages 33 and 34)
that incorrectly refer to a PCB concentration threshold value in soil to define PTW (e.g., 500 mg/kg).
The Proposed Plan is also inconsistent and incorrect in identifying the remedial approach to address
PTW, if present. In many locations (e.g., pages 55 through 58), the Proposed Plan incorrectly
defaults to a removal approach if PTW is present versus the correct approach of assessing a range of
remedial approaches as presented on page 34.

6. The key applicable or relevant and appropriate requirements (ARARs) listed on page 54 of the
Proposed Plan include elements of the Toxic Substances Control Act (TSCA) and incorrectly refer to
remediation wastes. The specific statement of concern is "Regulations at 40 Code of Federal
Regulations (C.F.R.) Part 262.11 (a)-(d) for the "management and disposal of remediation wastes." It
is undisputed that PCB residuals from the Site being addressed within OU-l/OU-2 are associated
with waste placed or releases which occurred prior to 1978. Based on this, the PCBs in OU-l/OU-2
are not subject to TSCA and its implementing regulations except when materials with PCB
concentrations greater than or equal to 50 mg/kg are removed for remediation.

Dredge Spoil Piles

1. Only one of the four dredge spoil piles proposed for removal in the Proposed Plan has PCB
concentrations above the PRG for nonresidential soils. Of the three remaining dredge spoil piles,
one has yet to be sampled for PCBs, and the other two piles have PCB concentrations below the
nonresidential PRG. The Proposed Plan (and ROD) should not require removal of dredge spoil piles
with PCB concentrations below the PRG.

2. PRGs for constituents other than PCBs (Dredge Spoil Piles Fact Sheet, page 5) should not be applied
to the dredge spoil piles. These non-PCB constituents include arsenic, chromium, PAHs (as BaPE) and
PCDD/DF TEQ, and are associated with naturally occurring background conditions or non-P/S

Attachment A page 3 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

industrial sources. As stated in the Proposed Plan (page 40): "There is substantial data to link these
contaminants to multiple industrial operations in the area, even some still operating in the
floodplain. In addition, the locations and footprints of the four dredge spoil piles were established
based on field surveys, and additional delineation of the dredge spoil piles for non-Site related
constituents is not necessary or applicable."

3. The subsurface soil PRG for PCBs of 97 mg/kg (Table 6 of the Proposed Plan and page 5 of the
Dredge Spoil Piles Fact Sheet) is not applicable to the dredge spoil piles as these features were
constructed above the existing ground surface. If the dredge spoil piles are removed as part of the
OU-l/OU-2 remedy, then post-removal surface soil conditions in the footprint of the dredge spoil
pile will be considered as part of evaluating nonresidential surface soil conditions in the respective
EU. The subsurface soil PRG for PCBs was developed to protect receptors (construction and utility
workers) whose exposure was considered on an OU-wide basis and not an EU, area or location basis.
The OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the subsurface soil PCB EPC of 99 mg/kg
was equivalent to the subsurface PRG (97 mg/kg) and thus, remediation of subsurface soils is not
required.

4. USEPA has chosen off-site disposal instead of on-site disposal with little discussion about the
rationale behind that decision. Although in some cases the USEPA cites concerns expressed by local
residents, it is not clear that the USEPA has fully evaluated the balances between the primary
balancing criteria and modifying criteria. On-site disposal would be easier to implement, have fewer
short-term negative impacts to local residents than off-site disposal, and be a significantly lower
cost.

5. The key ARARs listed on page 58 of the Proposed Plan include elements of TSCA and incorrectly
refer to remediation wastes. The specific statement of concern is "Regulations at 40 Code of Federal
Regulations (C.F.R.) Part 262.11 (a)-(d) for the "management and disposal of remediation wastes." It
is undisputed that PCB residuals from the Site being addressed within OU-l/OU-2 are associated
with waste placed or releases which occurred prior to 1978. Based on this, the PCBs in OU-l/OU-2
are not subject to TSCA and its implementing regulations except when materials containing PCBs
with concentrations greater than or equal to 50 mg/kg are removed for remediation.

Unapproved Waste Disposal Areas

1. The responsibility for implementing remedial cleanup actions at the unapproved waste disposal
areas (U WDAs) rests with parties other than P/S. The UWDAs should not be included in the ROD for
OU-l/OU-2. The UWDAs are not part of the Site based on the definition of the Site presented in the
PCD which establishes specific conditions that must be present for an area to be considered part of

Attachment A page 4 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

the Site. If the UWDAs are included in the ROD, the USEPA should pursue parties other than P/S for
the implementation of that portion of the remedy.

2. Although not included in the Proposed Plan, a third UWDA was identified in the OU-l/OU-2 Rl. This
third UWDA is located west of EUl and land ownership records for this property clearly identify it as
dump site for a local industry (MeadWestvaco).

3. Given that the UWDAs are former disposal areas that were constructed with no regulatory
approvals, there is uncertainty regarding the materials (beyond auto fluff) that may be present in
these three areas. Based on this, it is speculative to identify the list of constituents (UWDA Fact
Sheet page 5) that could be applicable recognizing that remedial responsibility for these areas falls
to parties other than P/S.

4. The subsurface soil PRG for PCBs of 97 mg/kg (UWDA fact Sheet page 5) is not applicable to the
UWDAs. The subsurface soil PRG for PCBs was developed to protect receptors (construction and
utility workers) whose exposure was evaluated on an OU-wide basis and not an EU, area or location
basis. The OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the subsurface soil PCB EPC of
99 mg/kg was equivalent to the subsurface PRG (97 mg/kg) and thus, remediation of subsurface
soils is not required.

5. The key ARARs listed on page 63 of the Proposed Plan include elements of TSCA and incorrectly
refer to remediation wastes. The specific statement of concern is "Regulations at 40 Code of Federal
Regulations (C.F.R.) Part 262.11 (a)-(d) for the "management and disposal of remediation wastes." It
is undisputed that PCB residuals from the Site being addressed within OU-l/OU-2 are associated
with waste placed or releases which occurred prior to 1978. Based on this, the PCBs in OU-l/OU-2
are not subject to TSCA and its implementing regulations except when materials with PCBs
concentrations greater than or equal to 50 mg/kg are removed for remediation.

Nonresidential Soils

1. PRGs for constituents other than PCBs should not be applied to the nonresidential soils (page 66 of
the Proposed Plan). These non-PCB constituents including arsenic, chromium, PAHs (as BaPE) and
PCDD/DF TEQ, which are associated with naturally occurring background conditions or non-P/S
industrial sources. As stated in the Proposed Plan (page 40): "There is substantial data to link these
contaminants to multiple industrial operations in the area, even some still operating in the
floodplain. Appendix G in the OU-l/OU-2 Feasibility Study (OU-l/OU-2 FS) includes an exhaustive
review of data compared to background concentrations and geographic distribution. The end result
is a determination that the Facility is not likely the only or even primary contributor to the
concentrations detected in 0U1/0U2."

2. There are inconsistencies regarding proposed cleanup of nonresidential soil with PCDD/DF and
DL-PCBs in the Proposed Plan. The OU-l/OU-2 HHRA previously determined that further assessment
and cleanup of DL-PCBs was not necessary and while the PRG was lowered slightly by the USEPA

Attachment A page 5 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

from 1 M-g/kg to 0.73 jig/kg since the OU-l/OU-2 HHRA was approved, this change does not support
a change in approach to now include DL-PCBs as part of TEQ. In addition, the one location where
TEQ based on PCDD/DF exceeded the PRG is a former industrial area where the total PCB
concentrations are very low (0.062 mg/kg). An additional consideration is that since the publication
of the current toxicity equivalent factors (TEFs) in 2006, there has been considerable research in this
area that supports lowering the human-TEF for PCB126 by a factor of 30.

3. The subsurface soil PRG for PCBs of 97 mg/kg (page 68 of the Proposed Plan) is not applicable to the
nonresidential portions of OU-l/OU-2. The subsurface soil PRG for PCBs was developed to protect
receptors (construction and utility workers) whose exposure was evaluated on an OU-wide basis and
not an EU, area or location basis. The OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the
subsurface soil PCB EPC of 99 mg/kg was equivalent to the subsurface PRG (97 mg/kg) and, thus,
remediation of subsurface soils is not required.

4. USEPA has chosen off-site disposal instead of on-site disposal with little discussion about the
rationale behind that decision. Although in some cases the USEPA cites concerns expressed by local
residents, it is not clear that the USEPA has fully evaluated the balances between the primary
balancing criteria and modifying criteria. On-site disposal would be easier to implement, have fewer
short-term negative impacts to local residents than off-site disposal, and be a significantly lower
cost.

5. The Proposed Plan (page 37) identifies the potential for additional remediation of the floodplain
following the completion of the baseline ecological risk assessment (BERA) for the OU-4 portion of
the Site. The ecological risk assessments prepared for OU-l/OU-2 documented that cleanup of
terrestrial habitat in OU-l/OU-2 was not necessary due to habitat limitations. In addition, the OU-4
BERA and its conclusions will have no bearing on terrestrial or aquatic habitat conditions in
OU-l/OU-2.

6. The key ARARs listed on page 67 of the Proposed Plan include elements of TSCA and incorrectly
refer to remediation wastes. The specific statement of concern is "Regulations at 40 Code of Federal
Regulations (C.F.R.) Part 262.11 (a)-(d) for the "management and disposal of remediation wastes." It
is undisputed that PCB residuals from the Site being addressed within OU-l/OU-2 are associated
with waste placed or releases which occurred prior to 1978. Based on this, the PCBs in OU-l/OU-2
are not subject to TSCA and its implementing regulations except when materials with PCB
concentrations greater than or equal to 50 mg/kg are removed for remediation.

Groundwater at T-11

1. The subsurface soil PRG for PCBs of 97 mg/kg is not applicable to the T-11 area (page 74 of the
Proposed Plan). The subsurface soil PRG for PCBs was developed to protect receptors (construction
and utility workers) whose exposure was evaluated on an OU-wide basis and not an EU, area or
location basis. The OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the subsurface soil PCB

Attachment A page 6 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

EPC of 99 mg/kg was equivalent to the subsurface PRG (97 mg/kg) and thus, remediation of
subsurface soils is not required.

2. The comparative analysis table for the groundwater at T-11 (Table 24) inconsistently and incorrectly
evaluates the long-term effectiveness and permanence of the active remedial alternatives (GW-2
through G W-4). The cap system used for all three of these alternatives has been proven effective
over the long-term and if there are concerns in this regard (as indicated for GW-2 and GW-3 on the
table), these concerns would also apply to G W-4. If the cap systems are considered comparable in
effectiveness for each alternative, then the only difference between the alternatives would be cost,
and the results of evaluation support GW-2 as the appropriate remedial alternative.

3. PRGs for constituents other than PCBs should not be applied to groundwater at T-11 with the
possible exception of discharge criteria for the treatment system (groundwater at T-11 Fact Sheet
page 5). These non-PCB constituents including arsenic, chromium, PAHs (as BaPE) and PCDD/DF TEQ
are associated with naturally occurring background conditions or non-P/S industrial sources. As
stated in the Proposed Plan (page 40): "There is substantial data to link these contaminants to
multiple industrial operations in the area, even some still operating in the floodplain. Appendix G in
the OU-l/OU-2 Feasibility Study (OU-l/OU-2 FS) includes an exhaustive review of data compared to
background concentrations and geographic distribution. The end result is a determination that the
Facility is not likely the only or even primary contributor to the concentrations detected in
0U1/0U2."

4. The key ARARs listed on page 73 of the Proposed Plan include elements of TSCA and incorrectly
refer to remediation wastes. The specific statement of concern is "Regulations at 40 Code of Federal
Regulations (C.F.R.) Part 262.11 (a)-(d) for the "management and disposal of remediation wastes." It
is undisputed that PCB residuals from the Site being addressed within OU-l/OU-2 are associated
with waste placed or releases which occurred prior to 1978. Based on this, the PCBs in OU-l/OU-2
are not subject to TSCA and its implementing regulations except when materials with PCB
concentrations greater than or equal to 50 mg/kg are removed for remediation.

Snow Creek Sediment and Creek Bank Soils

1. PRGs for constituents other than PCBs should not be applied to sediment and creek bank areas.
These non-PCB constituents are identified on Table 6 of the Proposed Plan (page 44) and include
barium, chromium, cobalt, lead, manganese, mercury, nickel, and vanadium. These constituents are
associated with non-P/S industrial sources located in the Snow Creek watershed. As stated in the
Proposed Plan (page 40): "There is substantial data to link these contaminants to multiple industrial
operations in the area, even some still operating in the floodplain."

2. PRGs for chromium II, chromium VI and lead in surface water are associated with parties other than
P/S. These constituents are associated with non-P/S industrial sources located in the Snow Creek
watershed. As stated in the Proposed Plan (page 40): 'There is substantial data to link these

Attachment A page 7 of 8
 Attachment A
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. General Comments on the Proposed Plan

contaminants to multiple industrial operations in the area, even some still operating in the
floodplain."

3. USEPA has chosen off-site disposal instead of on-site disposal with little discussion about the
rationale behind that decision. Although in some cases, the USEPA cites concerns expressed by local
residents, it is not clear that the USEPA has fully evaluated the balances between the primary
balancing criteria and modifying criteria. On-site disposal would be easier to implement, have fewer
short-term negative impacts to local residents than off-site disposal, and be significantly lower cost.

4. The key ARARs listed on page 78 of the Proposed Plan include elements of TSCA and incorrectly
refer to remediation wastes. The specific statement of concern is "Regulations at 40 Code of Federal
Regulations (C.F.R.) Part 262.11 (a)-(d) for the "management and disposal of remediation wastes." It
is undisputed that PCB residuals from the Site being addressed within OU-l/OU-2 are associated
with waste placed or releases which occurred prior to 1978. Based on this, the PCBs in OU-l/OU-2
are not subject to TSCA and its implementing regulations except when materials with PCB
concentrations greater than or equal 50 mg/kg are removed for remediation.

Attachment A page 8 of 8
ATTACHMENT B

Specific Comments on the Proposed Plan

 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

Bl. Page 8: Air dispersion is not a main pathway for past or present migration of constituents from
OU-3 to OU-l/OU-2 or to OU-4. Concentrations of RGBs in air have been investigated and found to
be below concentrations that would pose unacceptable risks in OU-3 and in OU-l/OU-2. The
distribution of RGBs in OU-l/OU-2 soils surrounding OU-3 does not support the air pathway as
being a significant historical source. The distribution of PCBs in OU-l/OU-2 soils is not consistent
with the predominant direction of winds in this portion of the Anniston area. To the extent that
the USERA claims that RGBs from the operations of P/S' predecessors have "volatilized" and
"spread" through the Anniston area, that claim is insufficient as a matter of law to hold P/S as a
potentially responsible party under CERCLA. See Pakootas v. Teck Cominco Metals, No. 15-35228,
2016 WL 4011196 (9"' Gir. July 27, 2016). In the Pakootas case, the 9"' Circuit Court of Appeals
rejected a similar "aerial deposition' theory." 2016 WL 401196 at *5. The Court noted that an
earlier interpretation of the term "deposit" as used in CERCLA held there was nothing in the
statute suggesting "'that Congress meant to include chemical or geologic processes or passive
migration, i.e., the gradual spread of contaminants without human intervention.'" Id. (quoting
Carson Harbor Vill., Ltd. v. Unocal Corp., 270 F.3d 863, 879 & n.7 (9"' Cir. 2001)).

B2. Rage 10, Table 1 and Table 9 footnotes: The number of properties that fall into the different
categories (with or without structures and with RGBs or no PCBs at depth) are not the same on the
two tables. Recognizing that these numbers change as the properties are addressed, the numbers
on the applicable tables should be the same and should reference a date and source document for
the information.

B3. Rage 15, Soil: The Proposed Plan does not clarify that the special use properties included high and
low activity areas and that the Stipulation treated the high activity portions of the special use
areas as residential for the purposes of surface and subsurface RGB removals.

B4. Rage 15, Residential Soil: The USERA should consider the recently issued Desk Statement
Regarding Lead Contamination in Soil (Desk Statement; USERA September 2016). The Desk
Statement discusses recent data for lead toxicity that may impact the 400 mg/kg action level that
was used to address the Anniston Lead Site properties under the RO. Specifically, there may be
unacceptable risks for residential properties with lead concentrations less than 400 mg/kg.
including properties that were cleaned up under the Anniston Lead Site Removal Order by other
RRRs. Since the mid-1990s, the USERA has relied on the Integrated Exposure, Uptake, and
Biokinetic (lEUBK) model for lead to establish "safe" lead levels in various environmental media.
The model is applied to exposures to both adult and children. Epidemiological data have
suggested that neurodevelopmental effects in young children are the most sensitive toxic
endpoint for lead, and the lEUBK model has been used to estimate exposures in soil and water
that are protective of these receptors. More than 25 years ago, the Centers for Disease Control
and Rrevention (CDCR) established a guideline of 10 micrograms of lead per deciliter (pg Rb/dL)
blood in preschool children, "which is believed to prevent or minimize lead-associated cognitive
deficits". Using the lEUBK model, the USERA determined that residential exposure to lead at a
concentration of 400 milligrams per kilogram (mg/kg) in soil would prevent 90% of the exposed

Attachment B page 1of 16

 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

population from having lead blood levels in excess of 10 pg Pb/dL The Desk Statement discusses
the current science and states that the USEPA Office of Research and Development reviewed the
health effects evidence for lead in the 2013 Integrated Science Assessment for Lead and identified
several studies that have observed cognitive impairments in children ages 4 to 11 with blood-lead
levels between 2 and 8 pg/dL. In 2012, the National Toxicology Program (NTP) published a report,
Monograph on Health Effects of Low-Level Lead (NTP June 2012), that "found sufficient evidence
of delayed puberty, reduced post-natal growth, and decreased hearing for young children with
blood-lead levels below 10 pg/dL, and adverse effects on academic achievement, IQ, attention-
related behaviors, problem behaviors and other cognitive measures at blood-lead levels below
5 pg/dL." Since the lEUBK model is relatively linear in terms of exposure and predicted blood lead
levels, lowering the threshold from 10 pg/dL to 5 pg/dL may require a reduction for the "safe"
level of lead in soil (currently concentrations below 400 mg/kg). The impacts of this recently
published information may require additional remediation of residential properties previously
sampled and/or remediated as part of the Anniston Lead Site to which: P/S are not the source of
lead.

B5. Page 15 and p. 19: Although not included in the Proposed Plan, a third UWDA was identified in the
OU-l/OU-2 Rl. This third UWDA is located west of EUl and land ownership records for this
property clearly identify it as dump site for a local industry (MeadWestvaco). The presence of this
third UWDA is documented in publicly available records for parcel (PPIN 32695) and indicates that
the property was owned by the Anniston Foundry Company (recorded in the Calhoun County at
Deed Book 1097, Page 931-938) and used as a dumping operation by Anniston Foundry Company
from 1957 forward. See Affidavit of H. Worth Little, dated March 9, 1961. The property was
conveyed by Anniston Foundry Company to Woodward Iron Company (as the sole shareholder of
Anniston Foundry Company) in 1963, Calhoun County, Alabama, Deed Book 1263, Page 528; and
that the Mead Corporation acquired the property by merger from Woodward Iron Company in
1977, Calhoun County, Alabama, Deed Book 1445, Page 764. The UWDAs should not be included
in the ROD for OU-l/OU-2 as the areas are not part of the Anniston PCB Site. If they are included
in the ROD, the USEPA should pursue parties other than P/S for the implementation of that
portion of the remedy.

B6. Page 15, Residential Soil: Stating that PCB residuals on properties that were addressed under the
Anniston Lead Site are now part of the Anniston PCB Site equates to a transfer in liability. The
Anniston Lead Site properties were separately addressed by the USEPA and a group of PRPs under
a Removal Order to which P/S are not party. The responsibility for PCB residuals at these
properties rests with these other parties and not P/S.

B7. Page 19, UWDAs: The responsibility for implementing remedial cleanup actions at the UWDAs
rests with parties other than P/S. The UWDAs should not be included in the ROD for OU-l/OU-2 as
the areas are not part of the Anniston PCB Site. If the UWDAs are included in the ROD, the USEPA
should pursue parties other than P/S for the implementation of that portion of the remedy. The
UWDAs are not part of the Anniston PCB Site based on the definition of the Site presented in the

Attachment B page 2 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

PCD which establishes specific conditions that must be present for an area to be considered part
of the Site: "the Anniston RGB Site consists of the area where hazardous substances, including
RGBs associated with releases or discharges as a result of the operations, including waste disposal,
of the Anniston plant by Solutia Inc., Monsanto Company, and their predecessors have come to be
located." In a letter to P/S dated February 25, 2016, the USERA, in discussing the U WDAs, indicates
that "Based on the thousands of parcels sampled and the volume of data reviewed, the ERA has a
solid understanding that the Site contamination is either fill material containing RGBs and/or lead
or fill material that contains auto fluff." The past use of the U WDAs by parties other than P/S is
recognized by the USERA in the Proposed Plan when describing the UWDAs..."Investigations
conducted in these areas have shown that the UWDAs contain or may contain auto fluff that was
deposited overtime."

B8. Rage 23: The information provided by the USERA on this page of the Proposed Plan for non-RGB
constituents including arsenic, RAHs, chromium and RCDD/DFs in soils documents that these
constituents are not associated with the Anniston RGB Site. The distribution of these non-RGB
constituents is consistent with the presence of other industrial sources in the Anniston area, or in
the case of arsenic, is consistent with naturally occurring conditions based on a comparison of
background data from a study conducted at Fort McGlellan.

B9. Rages 23, 36, 41 and 66: There are inconsistencies regarding proposed cleanup of nonresidential
soil with RGDD/DF and DL-RGBs in the Proposed Plan and the Proposed Plan Fact Sheet. For
example, page 66 of the Proposed Plan indicates that there is "one location where one sample
result exceeds the RGDD/DF RRG of 0.6 pg/kg (Exposure Unit [EU]25)." This statement is
inconsistent with the information provided on page 41 of the Proposed Plan that indicates "two
locations (2,200 ng/kg in EU25 and 2000 ng/kg in EUlO) do not fit the data... ." In reviewing the
nonresidential surface soil results for RGDD/DF and DL-RGBs in OU-l/OU-2, there are a total of
three sample locations where the RRG forTEQ inclusive of RGDD/DF and DL-RGBs (0.73 pg/kg) is
exceeded. The corresponding total RGB concentrations for each of these three sample locations
are low. Additional information is provided below for the two locations where remedial actions
are not needed to reduce risks associated with RGBs in surface soils. Information is also provided
below for the single sample location where the possible presence of RGDD/DFs is not the
responsibility of P/S.

a. The TEQ RRG exceedance for two of the three locations are driven by the DL-RGB
component of TEQ. One of the RRG exceedances is associated with a surface soil sample
collected in EUll, and the second exceedance is associated with a surface soil sample
collected in EU15/16. Both of these EUs are characterized by low RGB concentrations,
and the Proposed Plan does not identify remediation for either of these EUs based on
the presence of total RGBs. The average surface soil RGB concentrations in EUll and
EU15/16 are 1.3 mg/kg and 0.84 mg/kg, respectively. The DL-RGB concentrations for
these two sample results are discussed in the GDM September 29, 2010 memorandum
addendum to the HHRA. This memorandum concluded that the DL-RGB component of

Attachment B page 3 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

TEQ for these two locations is attributed to PCB 126, and that the reported
concentrations of PCB 126 are likely false positives or are falsely biased high. The
memorandum also concludes that total PCB concentrations based on the sum of
detected Aroclors is consistent with total PCB homologues and, thus, subsequent risk-
based decisions based on PCB Aroclors results can be made with confidence.
b. An additional consideration is that since the publication of the current toxicity
equivalent factors (TEFs) in 2006, there has been considerable research in this area, and
several papers have been published demonstrating the flaws in the published 2006 PCB
TEFs. The lead author of the 2006 TEF publication (Martin van den Berg) recently
published research that concludes that the "current TEF concept overestimates [aryl
hydrocarbon receptor] AHR-mediated risk of DL-PCBs in humans." In particular, "the
human-TEF for PCB126 should probably be around 0.003 for AHR-mediated effects" or
30 times lower than the current TEF. If, based on these new data, TEFs were lowered to
reflect actual toxicity, DL-PCBs would not make a measurable contribution to the
calculated total TEQ.
c. The third TEQ above 0.73 pg/kg is in a former industrial area (US Pipe) located in EU25.
The TEQ concentration at this location is driven by the concentration of PCDD/DFs and
not DL-PCBs, as the total PCB concentration is 0.062 mg/kg. Since the TEQ concentration
is driven by a group of constituents that are not associated with the Anniston PCB Site
(i.e., PCDD/DFs), and given that the PCB concentrations at this location do not pose
unacceptable risks, there is no need to address the area as part of the Anniston PCB
Site. If the risks associated with the PCDD/DF component of TEQ at this single location
are unacceptable, then the responsibility to address this portion of EU25 shifts to parties
other than P/S.

BIO. Page 24, PCDD/DF TEQ: This section accurately describes a single sample with a concentration of
2.2 pg/kg PCDD/DF TEQ as an outlier relative to the remainder of the OU-l/OU-2 data set. The
lack of correlation between TEQ and PCB concentrations indicates that PCDD/DFs and PCBs are
not from the same source. It is not appropriate to combine the results for PCDD/DF with DL-PCBs
for the purposes of remediation decisions, as the OU-l/OU-2 HHRA determined that risks
associated with total PCBs sufficiently addressed risks associated with DL-PCBs. Furthermore, the
OU-l/OU-2 HHRA determined that the two sample locations where the total TEQ was driven by
the detection of PCB 126 are attributed to potentially false positive or falsely high results for
PCB 126.

Attachment B page 4 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

Bll. Page 24, metals in sediment: Because metals found in the sediment deposits of Snow Creek are
associated with a wide range of industries in the watershed and/or are naturally occurring
elements, they should not be used to develop PRGs for Snow Creek. Remediating sediment
deposits in Snow Creek for these metals would be difficult to maintain over the long-term given
the past and continued use of these constituents by non-P/S entities. If risks associated with the
isolated occurrences of metals in sediment are deemed unacceptable by USEPA, then the
responsibility to address these sediment deposits would fall to others, recognizing the challenges
to meet the PRGs over the long-term.

B12. Page 33, PTW: The definition of PTW in the Proposed Plan is inconsistent and in some cases
incorrect. The USEPA's Proposed Plan (page 56, 57, and 58) correctly identifies PTW as locations
where high PCB concentration soils have impacted groundwater at concentrations exceeding the
maximum contaminant level (MCL) of 0.5 pg/L While the description of PTW is correct in the
locations referred to above, the text included on page 34 incorrectly indicates that "principal
threats will generally include material contaminated at concentrations exceeding ICQ ppm for
sites in residential areas and concentration exceeding 500 ppm for sites in industrial areas." The
inconsistent manner in which PTW is defined in the Proposed Plan should be corrected in the ROD
to reflect that impacts to groundwater must be exist for PTW to be present. The inference is that a
default PCB concentration of 500 mg/kg defines PTW is a one-size-fits-all approach without
technical justification. The USEPA's guidance documents (A Guidance on Remedial Actions at
Superfund Sites with PCB Contamination [OSWER Directive No. 9355.4-OlFS, August 1990] and A
Guide to Principal Threat and Low Level Threat Wastes [OSWER Directive No. 9380.3-06FS,
November 1991]) allow for a site-specific determination of what constitutes PTW and should be
determined as part of the ongoing RI/FS process. The information presented in the Proposed Plan
should be corrected in the ROD to reflect a correct and consistent approach for defining PTW.

B13. Page 34, The proposed Plan is inconsistent in the approach to address PTW, if identified. For
example, if predesign investigations conducted for the Eastside Properties IM identify the
presence of PTW through impacts to groundwater, then some of the text on page 34 of the
Proposed Plan correctly states that "excavation of PTW may be required". The text presented on
pages 55 through 58 of the Proposed Plan conflicts with this approach by indicating that..."If PCB
impacts to groundwater are greater than the MCL, excavation of the PCB impacted subsurface soil
within the IM or at PB-RR-37 will be required as determined in the design." The advance decision
to excavate PTW presented on these pages of the Proposed Plan is in direct conflict with the
language presented on page 34 of the Proposed Plan including "When PTWs are not practicable to
treat or remove, reliable and effective long-term containment options can be considered..."

B14. Page 35: Air is not a future exposure pathway of concern once the remedial action is implemented
for OU-l/OU-2. Both the remedial investigation (OU-l/OU-2 Rl) and OU-l/OU-2 FS recognize that
additional air sampling may be needed to support construction activities if soils are disturbed
during construction. At the present time, with no intrusive activity, there are no concerns
regarding PCB concentrations in ambient air. Based on the lack of risks associated with ambient air

Attachment B page 5 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

exposure, additional ambient air monitoring following implementation of the remedy for
OU-l/OU-2 is not necessary.

B15. Page 35,full paragraph, last sentence: "... and impacted areas further downstream." This
sentence should be deleted as OU-4 is not the subject of this Proposed Plan. In addition, there has
been no decision to assess the potential for Site-related impacts downstream of OU-4 and the
sentence as currently written, presumes that impacts are present downstream of OU-4.

B16. Page 36: The PCB concentration value for the MCL is incorrect. It should be 0.5 pg/L and not
5 pg/L.

B17. Pages 36 and 37, Dioxins v. PCBs: The heading and associated text are poorly worded, sometimes
incorrect and misleading. The term "dioxin" is used interchangeably to refer to both PCDD/DF TEQ
and DL-PCB TEQ. Although the guidance documents include provisions for calculating a total
PCDD/DF/DL-PCB TEQ using both PCDD/DF and PCB data, the data from the Anniston Site indicate
that the PCDD/DF compounds are not related to PCBs. It is, therefore, incorrect to include them in
an additive calculation. The text should be clear when discussing dioxins and furans (PCDD/DFs),
PCBs or calculated TEQ values. Also, there is no relationship between PCDD/DFs and PCBs for this
Site based on the data collected for OU-l/OU-2 and OU-4.

B18. Page 36, last paragraph: "used to provide information about total dioxins (PCDD/DF/DL-PCB) in
lower concentrations of PCBs, like what might be present in a residential setting." Furans and DL-
PCBs are not dioxins and should not be referred to as dioxins in this context. The conclusion
presented on the top of page 37 that "PCB remedial goals are protective ... " is essentially correct,
although it would be more appropriately worded as: "PCB remedial goals are protective of the
risks calculated for DL-PCBTEQs."

B19. Page 37, 2'"' paragraph: The sentence: "The highest PCB value evaluated for non-residential
surface soil is 21 mg/kg." appears to be out of context.

B20. Page 37, 3"' paragraph: "The results of the study provided a relationship between total dioxin (i.e.,
PCDD/DF and DL-PCB TEQ) and total PCBs." This sentence is incorrect. Although there is a
relationship between total PCBs and DL-PCB TEQ, as the latter is calculated from the former, there
is no relationship between total PCBs and PCDD/DFs on this Site. The statement provided to the
National Remedy Review Board by the USEPA Region IV is correct: "The distribution of
concentrations of PCDD/DFs is random with no evident pattern to the sporadic higher
concentrations in the Snow Creek floodplain."

B21. Page 37, 4"' paragraph: As noted in comment no. B9, there are three locations in OU-l/OU-2
where the total PCDD/DF/DL-PCB TEQ is greater than the PRG.

B22. Page 37, 5"' paragraph: The phrase "total dioxin" should be replaced with "DL-PCB TEQ" in two
instances.

Attachment B page 6 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

B23. Page 37: The statement in the Proposed Plan indicating "If after the Baseline Ecological Risk
Assessment for 0U4 is complete, it is determined that additional terrestrial cleanup should be
conducted in certain areas to address ecological risk, an amendment to the decision document
will be considered." is not relevant. It is not clear why (or how) the results of the OU-4 BERA
would be back-applied to OU-specific decisions that have already been made for OU-l/OU-2. The
ecological risks assessments conducted for OU-l/OU-2 included the 2005 Screening Level
Ecological Risk Assessment (SLERA) and the Streamlined Ecological Risk Assessment (SERA) that
was finalized in the OU-l/OU-2 Rl (ENVIRON 2015). The SLERA and SERA for OU-l/OU-2 were both
approved by the USEPA. The OU-4 BERA is focused on areas located downstream of OU-l/OU-2
and its conclusions will have no bearing on terrestrial conditions in OU-l/OU-2. This statement
should be corrected to reflect document approvals already in-place, and information regarding
studies that are not applicable to OU-l/OU-2 should be deleted.

B24. Page 41, 5"' paragraph: The statement regarding the random distribution of PCDD/DFs with no
pattern similar to the PCB distribution pattern is correct. Therefore, it is inappropriate to combine
PCDD/DFs and DL-PCBs in a single equation to represent toxicity (TEQ). See General Comment No.
2 for nonresidential soils in Attachment A for an accurate description of the three sample
locations with calculated total TEQ values above 0.73 pg/kg. It is also inappropriate to develop a
PRG to address "data outliers" especially, in this case, where the outliers appear to be the result of
uncertainties in the data set.

B25. Page 41, last sentence regarding arsenic, chromium, PAHs and PCDD/DFs: "Confirmation samples
will be needed to demonstrate whether subsurface soil need to be remediated." The data from
the Rl demonstrate that P/S and the Facility are "not likely the only or even the primary
contributor" for these four constituents in soils. Furthermore, the risk assessments evaluated
these constituents on an OU-wide basis and found that their presence and concentrations did not
constitute an OU-wide risk. Therefore, these constituents should not be evaluated as part of the
Site, and any sampling and subsequent data analysis required to further delineate the nature,
extent, and risks from these constituents would be the responsibility of others.

B26. Pages 41, 66, and Table 6 on page 44: Since the OU-l/OU-2 HHRA was approved in 2012, the
USEPA has updated the cancer slope factor (CSF) that should be used to update the PRG for PAHs.
The USEPA has also published a reference dose (RfD) that can be used to estimate non-cancer
risks for benzo(a)pyrene (USEPA IRIS database:
https://cfpub.epa.gov/ncea/iris2/chemica I Land ing.cfm?substance_nmbr=l 36, accessed May
2017). Using the most recent toxicity information, the PRG in soil for PAHs (as BaPE) associated
with a cancer risk of 1 x lO"'' would be 153 mg/kg, and the non-cancer PRG for an HQ of 1 would
be 186 mg/kg.

B27. Page 44, Table 6: Subsurface has a footnote reference, but no footnote is included with this table.

B28. Page 44, Table 6, nonresidential soils: The non-PCB PRGs should not be applied to nonresidential
soils. This includes the IM areas, dredge spoil piles, UWDAs, nonresidential floodplain soils, and

Attachment B page 7 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

soils at the T-11 area. These non-PCB constituents include arsenic, chromium, PAHs (as BaPE) and
PCDD/DF TEQ, and are associated with naturally occurring background conditions or non-P/S
industrial sources. As stated in the Proposed Plan (page 40): "There is substantial data to link
these contaminants to multiple industrial operations in the area, even some still operating in the
floodplain. Appendix G in the FS includes an exhaustive review of data compared to background
concentrations and geographic distribution. The end result is a determination that the Facility is
not likely the only or even primary contributor to the concentrations detected in 0U1/0U2."
Based on this statement and all the supporting data, non-PCB constituents should not be
considered for the Anniston PCB Site. If these constituents are included in the ROD, the USEPA
should pursue parties other than P/S for the implementation of that portion of the remedy.

B29. Page 44, Table 6, sediment: The non-PCB PRGs should not be applied to sediment and creek bank
areas. These non-PCB constituents include chromium, cobalt, manganese, mercury, nickel, and
vanadium. These constituents are associated with non-P/S industrial sources located in the Snow
Creek watershed. As stated in the Proposed Plan (page 40): "There is substantial data to link these
contaminants to multiple industrial operations in the area, even some still operating in the
floodplain. Appendix G in the FS includes an exhaustive review of data compared to background
concentrations and geographic distribution. The end result is a determination that the Facility is
not likely the only or even primary contributor to the concentrations detected in 0U1/0U2."
Based on this statement and all the supporting data, non-PCB constituents should not be
considered to identify remedial areas along Snow Creek or the creek bank areas. If these
constituents are included in the ROD, the USEPA should pursue parties other than P/S for the
implementation of that portion of the remedy.

B30. Page 44, Table 6, surface water: The non-PCB PRGs should not be applied to surface water. This
includes chromium III, chromium VI and lead that are associated with other industrial discharges
located in the watershed, and not P/S. This is underscored for lead where responsibility for
remediating lead was assigned to a separate group of PRPs by the USEPA as part of the Anniston
Lead Site. If these non-PCB constituents are included in the ROD, the USEPA should pursue parties
other than P/S for the implementation of that portion of the remedy.

B31. Page 45,paragraph: "... risks to contamination..." should be rephrased in a manner similar to
"risks due to contamination".

B32. Pages 47 and 48, Deed Notices: Deed notices for residential properties with PCB residuals are not
necessary as these properties will be tracked through the soil management program that will be
implemented for OU-l/OU-2. A key component of the soil management program will be regular
written outreach with the property owners and tenants to remind them of the procedures to
follow if they plan to disturb soils with PCB residuals and/or remove structures or paving from
areas where the PCB concentrations may exceed the residential PRG of 1 mg/kg. These conditions
must be disclosed to prospective buyers by the landowner and/or real estate professional. Even

Attachment B page 8 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

though the State of Alabama has a "caveat emptor" provision for real estate transactions, items
that present a health or safety concern must be disclosed to prospective buyers.

B33. Pages 48 (RS-2) and 49 (RS-3): last bullets: "Re-vegetate the property as close to original
conditions as possible." Given that overgrown properties with limited physical access has been
one of the difficulties with the residential cleanups to date, it is unlikely that restoration will be to
original conditions. In some cases, the original conditions include multiple invasive species which
may return on their own, but will not be planted as part of restoration activities.

B34. Page 49, Special Use Properties, sentence: "Special Use Properties ... were partially cleaned..."
The term "partially" should be deleted and this sentence should be reworded to recognize that all
of the special use properties have been addressed in accordance with the Stipulation. The
Stipulation includes the definition of high activity and low activity areas and only required
residential cleanup activities for the high activity areas. Where high activity areas required cleanup
to reach residential cleanup goals, these cleanups have been completed with the exception of
areas with structures or paved areas that prevent direct contact with soils.

B35. Page 50, SU-1: " ...the health of current visitors and workers at low activity areas on special use
properties may be at risk." This sentence, when used in this context, implies that there may be a
different or greater risk than what was evaluated in the OU-l/OU-2 HHRA. The OU-l/OU-HHRA
prepared by COM on behalf of the USEPA fully evaluated the risks to visitors and workers (and
residential receptors) and developed PRGs that are protective of those receptors.

B36. Page 52, SU-3: The PRG for the low activity portions of the special use areas should be consistent
with the PRG used for the other nonresidential portions of OU-l/OU-2 (21 mg/kg) and, thus, the
selected remedy for the special use properties should be remedial alternative SU-2, not SU-3. The
proposed remediation of low activity portions of the special use areas to support school and
daycare under SU-3 is inconsistent with current land use, the Stipulation, the OU-l/OU-2 HHRA
prepared by the USEPA. In both of these documents, the USEPA considered the low activity
portions of the special use areas to be nonresidential and not used for school or daycare activities.
The high activity portions of the special use areas (e.g., schools, daycare, churches, playgrounds)
were addressed under the Stipulation based on the different characterization of such properties in
the Anniston Lead Site Removal Order (presumably based on an assumption of children having
direct contact with soils on a regular basis in these areas) and P/S' agreement to address these
areas as part of the Non-Time Critical Removal Order rather than wait until the OU-l/OU-2 RI/FS
process on these properties, which are classified as nonresidential properties under the PCD, was
completed. As defined in the Stipulation, low activity areas do not present the same exposure as
the high activity areas and it is not appropriate for the USEPA to apply a PRG from a
school/daycare exposure scenario to areas that are not used in this way. If land use changes from
low to high activity, the high activity removal requirements would apply and remedial activities for
the area would be implemented consistent with the requirements of the Stipulation (1 mg/kg for
surface soils and 10 mg/kg for subsurface soils). To be consistent with the OU-l/OU-2 HHRA and

Attachment B page 9 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

the Stipulation, the low activity special use areas should be evaluated as part of the broader EUs
that they are located in, where a nonresidential PRG of 21 mg/kg would apply. As presented in the
OU-l/OU-2 FS, alternative SU-2 would implement a soil management plan that would
communicate land use issues with the property owner(s) and would ensure that appropriate
remediation actions would be taken if the land use changed to high activity (i.e., school/daycare)
or residential.

B37. Pages 51, 52, and 53, deed notices for special use properties: Deed notices for special use
properties with PCB residuals are not necessary as these properties will be tracked through the
soil management program that will be implemented for OU-l/OU-2. A key component of the soil
management program will be regular written outreach with the property owners and tenants to
remind them of the procedures to follow if they plan to disturb soils with PCB residuals and/or
remove structures or paving from areas where the PCB concentrations may exceed the residential
PRG of 1 mg/kg. These conditions must be disclosed to prospective buyers by the landowner
and/or real estate professional. Even though the State of Alabama has a "caveat emptor"
provision for real estate transactions, items that present a health or safety concern must be
disclosed to prospective buyers.

B38. Pages 51 (SU-2), 53 (SU-3), and 4 (SU-4), last bullets: "Re-vegetate the property as close to original
conditions as possible." Given that this is in reference to low activity areas that may be heavily
wooded or overgrown, achieving original conditions may not be feasible. In some cases, the
original conditions include multiple invasive species which may return on their own, but will not
be planted as part of restoration activities.

B39. Pages 49 through 54: Remedial alternatives to address the low activity portions of special use
properties are not necessary as these areas should be addressed as part of the nonresidential soil
alternatives. This would include these areas as part of the EUs where the nonresidential PRG for
PCBs (21 mg/kg) would be applied. See General Comment No. 1 for special use properties
presented in Attachment A.

B40. Pages 54, 58, 63, 67, 73 and 78: Pages 56, The key ARARs listed on these pages of the Proposed
Plan include elements of TSCA and incorrectly refer to remediation wastes. The specific statement
of concern is "Regulations at 40 Code of Federal Regulations (C.F.R.) Part 262.11 (a)-(d) for the
"management and disposal of remediation wastes." It is undisputed that PCB residuals from the
Site being addressed within OU-l/OU-2 are associated with waste placed or releases which
occurred prior to 1978. Section 761.50(b)(3)(i) of the PCB Mega Rule (Applicability) provides that
PCBs "placed in a land disposal facility, spilled, or otherwise released into the environment prior to
April 18, 1978, regardless of the concentration of the spill or release" are "presumed not to
present an unreasonable risk of injury to health or the environment from PCBs at the site." See 40
C.F.R. 761.50 (b)(3)(i)(A); see also Rogers Corp. v. Environmental Protection Agency, 275 F.3d
1096,1102 (D.C. 2002). Thus, there is a presumption that there is no unreasonable risk or injury to
health or the environment at the site regarding PCBs at levels below 50 mg/kg. See 40 C.F.R.

Attachment B page 10 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

761.50 (b)(3)(i)(A). On March 10, 2009, the USEPA issued an email correspondence to P/S
expressly indicating that the "Mega Rule" was not a chemical specific ARAR for OU-3, since a risk
assessment was performed for the Site (March 10, 2009 Email Correspondence from the USEPA's
Remedial Manager for the Anniston PCB Site). The same logic applies to OU-l/OU-2. See also
June 10,1997 Letter from Wm. Gerald Hardy ("It is my understanding that correspondence will be
issued from Mr. Perry indicating whether or not the proposed activity will be a TSCA issue");
August 12, 1997 Letter from Alfreda F. Freeman ('The soil and sediments from this drainage ditch
are pre-Toxic Substance Control Act (TSCA) materials generated from historic operations at the
facility prior to 1972, and contain less than 50 parts per million of Polychlorinated Biphenyls (PCB)
. .. We have reviewed the information that was submitted, and concur with the proposal to place
the soil in the south landfill as part of upgrading the cover on the south landfill since the soil is
considered to be pre-TSCA"), July 16,1998 Letter from Wm. Gerald Hardy ("The soil to be
removed is reportedly considered pre-Toxic Substances Control Act (TSCA) material and
furthermore is contaminated with PCBs at levels significantly less than 50 mg/kg"). This position is
also confirmed by the USEPA's PCB Q&A Manual (June 2014), pp. 46-48. Among other things, the
PCB Q&A Manual confirms that "[the PCB Rules do not apply to waste disposed of prior to April
18, 1978, that is currently < 50 ppm, regardless of the concentration of the original spill,"
"[d]isposal of pre-'78 wastes at PCB concentrations < 50 ppm are not regulated under TSCA,"
"[t]he PCB disposal rules do not apply to waste that is currently < 50 ppm that was disposed of,
spilled, or otherwise released into the environment prior to April 18,1978," and "[u]nder
761.50(b)(3)(i)(A), the Regional Administrator can require cleanup based on a finding of
unreasonable risk only if the PCB concentration [from a pre-78 release] as found at the Site is > 50
ppm." As a result, the PCBs in OU-l/OU-2 are not subject to TSCA and its implementing
regulations except when materials containing PCBs greater than or equal to 50 mg/kg are
removed for remediation.

B41. Page 56: The subsurface soil PRG for PCBs of 97 mg/kg is not directly applicable to the IM
expansion areas. This subsurface PRG was developed to protect receptors (construction and utility
workers) whose exposure is evaluated on an OU-wide basis and not an EU, area or location basis.
The OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the subsurface soil PCB exposure point
concentration (EPC) of 99 mg/kg was equivalent to the subsurface PRG (97 mg/kg) and thus
remediation of subsurface soils is not required.

B42. Pages 56, 57, and 58: Additional deed restrictions are not needed for properties that are owned by
P/S and have IMs. P/S are not planning to divest these properties and access to most of these
properties is controlled through fencing. For properties that are owned by P/S with deed notices
already in place, these deed notices will remain in effect. Additional institutional controls for IMs
on properties that are not owned by P/S will be evaluated during the remedial design process for
the selected remedy.

Attachment B page 11 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

B43. Pages 56 and 57 (last paragraph on each page): "Further evaluation of potential PCB discharges to
groundwater..." should be reworded, suggest: "Further evaluation of the potential presence (and
concentration) of PCBs in groundwater..."

B44. Page 58: Only one of the four dredge spoil piles proposed for removal in the Proposed Plan has
PCB concentrations above the PRG for nonresidential soils. Of the three remaining dredge spoil
piles, one has yet to be sampled for PCBs, and the other two piles have PCB concentrations below
the nonresidential PRG. The two dredge spoil piles with PCB concentrations less than the PRG do
not pose an unacceptable risk, are located well away from the creek, and have been stabilized
with a vegetative cover. Based on these collective findings, there is no need to remove these two
dredge spoil piles. Since the dredge spoil pile that has not been characterized is located away from
the creek and has been stabilized with vegetation, the correct technical approach would be to
evaluate the dredge spoil pile for PCBs. If the USEPA requires the removal of all four dredge spoil
piles, institutional controls (ICs) would not be applicable

B45. Page 58, dredge spoil piles: "... to prevent future erosion back into the creek or residential use of
the soil in the piles as fill." Based on the most recent evaluation of the dredge spoil piles, all of the
dredge spoil piles with the exception of SC-8 (that exceeds the nonresidential PRG) are located
away from the creek and stable with well-established cover. Based on this, the other dredge spoil
piles that have been sampled have PCB concentrations below the PRG and are not susceptible to
erosion. All of the dredge spoil piles are located in heavily vegetated areas and well away from
areas that could be used for residential-type activities.

B46. Page 60, 7"' bullet, DSP-3 and DSP-4, and all references to in-place sampling to determine waste
disposal options: Initial waste disposal decisions will be made based on in-place total PCB
concentrations. However, if excavated materials are sampled from stockpiles, as is often required
by the disposal facility, disposal decisions may be altered based on those results. Disposal
decisions would always be made based on the highest concentrations identified from any of the
sampling events. For example, if in-place sampling indicates that material is less than 50 mg/kg
PCB and stockpile sampling indicates that material is greater than 50 mg/kg PCB, material will be
disposed of as greater than 50 mg/kg PCB material at an approved off-site facility.

B47. Page 63: The UWDAs should not be included in the ROD for OU-l/OU-2 as the areas are not part
of the Site. If they are included in the ROD, the USEPA should pursue parties other than P/S for the
implementation of that portion of the remedy. The UWDAs are not part of the Site based on its
definition presented in the PCD which establishes specific conditions that must be present for an
area to be considered part of the Site. While not included in the Proposed Plan, a third U WDA was
identified in the OU-l/OU-2 Rl.

B48. Page. 65, 1^' paragraph: "... a more stringent RCRA Subtitle D cap is appropriate for waste disposal
areas." This is a declarative statement rather than a conclusion from the OU-l/OU-2 FS process.
The Proposed Plan text and Table 23 indicate that each of the UWDA alternatives, except for
UWDA-1, would comply with ARARs. As stated, the Proposed Plan does recognize that the

Attachment B page 12 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

source(s) for these waste materials are not P/S and, therefore, these UWDAs should not be
included as a part of the Anniston PCB Site.

B49. Page 66: There are inconsistencies for the TEQ PRG in this section for nonresidential soils.
Sometimes the TEQ PRG is listed as 0.73 pg/kg, and other times it is listed as 0.6 pg/kg. The use of
TEQ should be clarified to only include PCDD/DF based on the OU-l/OU-2 HHRA. If DL-PCBs are
included in the calculation of TEQ, there are three sample locations where the total TEQ PRG of
0.73 pg/kg is exceeded.

B50. Page 68, last full paragraph, page 69, last paragraph, page 70, last paragraph: The potential
application of "... deed notices or environmental easements/covenants..." As presented in the
OU-l/OU-2 FS, the soil management plan will include regular outreach provisions to notify
nonresidential landowners and tenants if PCB residuals are present on their property. The soil
management plan will also include notice and handling procedures to prevent inadvertent contact
with and/or the migration of PCB-containing soils. These provisions of the soil management plan
will more than satisfy the intent of deed restrictions and be much more practical to implement for
the number of properties that will be involved.

B51. Page 69, first bullet, page 70, first and fourth bullets: The nonresidential remedial alternatives
should be focused on the remediation of PCBs, not non-PCB constituents unrelated to P/S. If
remedial alternatives based on non-PCB constituents are included in the ROD, the USEPA should
pursue parties other than P/S for the implementation of that portion of the remedy.

B52. Page 73, Groundwater, 2'"' paragraph, last sentence: "... a separate set of alternatives were
considered for this area." It is not clear what is intended by this sentence, separate from the other
OU-l/OU-2 alternatives or separate from the OU-3 alternatives? Is an additional statement
needed to clarify this?

B53. Page 74: The subsurface soil PRG for PCBs of 97 mg/kg is not applicable to the T-11 area. The
subsurface soil PRG for PCBs was developed to protect receptors (construction and utility workers)
whose exposure is evaluated on an OU-wide basis and not an EU, area or location basis. The
OU-l/OU-2 Rl and OU-l/OU-2 HHRA documented that the subsurface soil PCB EPC of 99 mg/kg
was equivalent to the subsurface PRG (97 mg/kg) and, thus, remediation of subsurface soils at
T-11 (other than in the PTW area) is not required. In addition, the subsurface PRG was developed
to protect construction workers who may contact subsurface soils. Under the proposed remedy,
the entire T-11 area will be capped with an impermeable liner that will limit excavation activities
and be owned by P/S. If after completion of the remedy, excavation of subsurface soils in the T-11
area is necessary for O&M purposes, this work will be performed by trained workers wearing the
appropriate personnel protective equipment (PPE) to prevent exposure to subsurface soils.

B54. Pages 75, 76 and 77: The remedy proposed by the USEPA for the T-11 area is protective of direct
contact with soils. In addition, the parcel where groundwater well T-11 is located is owned by P/S
and there are no plans to divest the property. Also, the local community receives their potable

Attachment B page 13 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

water from a public water supply and, thus, there is no need for an IC to prevent groundwater
extraction. Based on the protective nature of the proposed remedy, land ownership by P/S, and
the availability of a public water supply, deed restrictions on the T-11 property are not necessary.

855. Page 77, 2'"' paragraph: "... chromium, cobalt, manganese, mercury, nickel, and vanadium ..."
should not be included as these constituents are not the responsibility of P/S.

856. Page 80, top of page: it is not clear why the Proposed Plan chose the SED alternatives as the first
place to mention energy usage and carbon footprints. This information was also developed for the
other remedial alternatives and should be used consistently.

B57. Page 89: The recommended remedial alternative presented in the Proposed Plan for the IM areas
(IM-4) is more disruptive to the community than the two other active remedial alternatives (IM-2
and IM-3); and based on the comparative analysis table in the IM Fact Sheet (Table 3; page 8),
both IM-3 and IM-4 are "effective and permanent". Based on this, IM-3 should be the
recommended remedial alternative and not IM-4. The Proposed Plan (page 89) differentiates IM-4
from IM-2 and IM-3 by asserting that "IM-4 would provide higher long-term effectiveness and
permanence through soil removal." Since capping has been and continues to be effective at the
Site and other sites, the basis for stating that removal provides a higher degree of effectiveness
and permanence is not supported by the information provided by the USEPA.

858. Pages 89 through 91: It is unclear why the USEPA chose DSP- 4 as the preferred alternative. The
other active alternatives are similar for each of the evaluation criteria and meet the PRGs. DSP-4
and DSP-5 would be more difficult to implement and DSP-4 would cost significantly more than the
other alternatives.

859. Pages 95 and 96: Each of the active GW alternatives is expected to achieve MCLs over time and
GW-4 reduces the "expected time" to achieve MCLs. The increase in cost (almost $1M) for GW-4
above GW-3 do not appear warranted given the limited geography of the impacted groundwater,
Anniston is served by a public water supply, and the increased implementability challenges due to
its location next to Snow Creek and an active railway line.

860. Page. 97, 4"' paragraph: Sediment removal for metals and the acknowledgement that "the
contribution of multiple historical and ongoing sources to Snow Creek." It does not make sense to
implement removal actions for these non-PCB constituents based on the historical and ongoing
sources and the non-PCB PRGs should not be included with the remedial alternative for sediment.
If these non-PCB constituents are included in the ROD, the USEPA should pursue parties other
than P/S for the implementation of that portion of the remedy.

861. Page 98, 2'"' full paragraph: "Sediments in Snow Creek upstream of the 11 Street Ditch and in the
9"' Street Ditch would need to be remediated to 1 mg/kg to protect the remedy downstream,
further increasing the cost of the remedy." Although it is implied that these would increase the
costs above the $4.1M and $4.5M cited, the volume of additional sediment and the additional
costs are not clear.

Attachment 8 page 14 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

B62. Page 99, 2'"' paragraph and 3"' bullet: Although it is correct that the chosen alternatives include
off-site disposal, the use of on-site disposal, where appropriate, is not mentioned in this list of
preferred alternatives.

B63. Page 100, last bullet: "Community concerns about PCBs in air is not increased by selection of
onsite treatment." This bullet should be re-worded to recognize the community's concerns and
state that off-site alternatives eliminate the possibility of increased PCBs in air from on-site
treatment systems.

B64. Table 11 Remedial Alternatives Comparison for table Interim Measures, Treatment: typo: "PWT",
the statement regarding "effectively contained" does not belong under treatment, none of the IM
alternatives include treatment.

B65. Table 11 Remedial Alternatives Comparison Table for Interim Measures: The OU-l/OU-2 FS
assumed that 100% of the excavated soils (4,200 cubic yards (cy), 6,200 tons) for IM-4 would be
disposed of off-site as >50 mg/kg (not 20%).

B66. Table 12 Remedial Alternatives Comparison Table for UWDAs: The OU-l/OU-2 FS assumed that
the entire excavation under UWDA-4 would be backfilled to natural grade (100,100 cy) and that
excavated materials would be disposed of as > 50 mg/kg and < 50 mg/kg in 51%/49% proportions,
respectively.

B67. Table 15 Remedial Alternatives Comparison Table for Nonresidential Soil: The estimated costs for
NRS-5 and NRS-6 for the 9 mg/kg goal should be as follows:

NRS-5: $46,200,000
NRS-6: $36,600,000

B68. Table 20: The comparative analysis presented in Table 20 for the special use properties supports
the selection of SU-2 as opposed to SU-3 that was proposed by the USEPA. In reviewing the
comparative analysis table, alternatives SU-2 and SU-3 are rated the same, with the exception that
SU-3 costs significantly more than SU-2. SU-4 is appropriately noted as having more short-term
negative impacts while providing no additional protectiveness (and costing more). The evaluation
of the special use alternatives is further complicated by the USEPA's selection of a lower
nonresidential PRG for SU-3 (1 mg/kg) in contrast to the nonresidential PRG (21 mg/kg) that is
used for SU-2. This nonresidential PRG (21 mg/kg) is used for all of the nonresidential remedial
alternatives (NRS-2 through NRS-6) and is also appropriately applied for SU-2. The USEPA selected
the lower PRG for SU-3 (and SU-4) based on an assumption that a daycare/school exposure
scenario could potentially occur in the low activity portions of the special use areas. These low
activity areas are not currently used for daycare/school activities and if the land use changed to
high activity, these areas would be remediated in accordance with the requirements of the
Stipulation. This remediation would include the removal of surface soils with PCBs greater than or
equal to 1 mg/kg and the removal of subsurface soils with PCB concentrations greater than or

Attachment B page 15 of 16
 Attachment B
Anniston PCS Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Specific Comments on the Proposed Plan

equal to 10 mg/kg. Based on the comparative analysis table for the special use alternatives, the
proposed remedial alternative for the special use areas should be SU-2.

869. Table 21: The comparative analysis presented in Table 21 does not provide a basis for selecting
IM-4 over IM-3. The table correctly concludes that IM-3 and IM-4 would be similar for each
evaluation criterion except for cost. IM-4 would cost significantly more ($1.7M) than IM-3. The
comparative analysis table correctly identifies IM-3 and IM-4 as being effective and permanent
provided that the caps and covers remain in place and would provide a permanent remedy for the
railroad and McDaniel Street area. The version of the table included with the Proposed Plan does
not have the language from the OU-l/OU-2 FS regarding the difficulty of working adjacent to the
railroad for IM-3. Both IM-3 and IM-4 have similar implementability concerns, recognizing that the
short-term effectiveness would be magnified for IM-4 as compared to IM-3 given the larger
amount of excavation near railways and waterways and the transportation of the excavated soils
to an off-site disposal facility.

B70. Table 22: The comparative analysis presented in Table 22 for the dredge spoil piles does not
support the recommendation of DSP-4. Both DSP-3 and DSP-4 are equally protective and effective
over the long-term, yet DSP-4 has more short-term negative impacts, is less implementable, and
has a higher cost. Given these factors, there is no technical basis to propose DSP-4 over DSP-3. The
primary difference between DSP-3 and DSP-4 is that all dredge soil piles are removed under DSP-4
as opposed to only removing the dredge spoil piles that exceed the nonresidential PRG (21 mg/kg)
under DSP-3. While the USEPA appropriately acknowledges the additional implementability
concerns associated with removing all of the dredge spoil piles under DSP-5, the table incorrectly
omits this implementability concern for DSP-4.

B71. Table 23: The comparative analysis table for the UWDAs incorrectly indicates that UWDA-4 is
implementable. Other than being used as disposal areas for auto fluff, there is limited knowledge
regarding other subsurface materials that may have been disposed of by others in the UWDAs.

B72. Table 24: The comparative analysis table for the groundwater at T-11 inconsistently and
incorrectly evaluates the long-term effectiveness and permanence of the active remedial
alternatives (GW-2 through G W-4). The cap system used for all three of these alternatives has
been proven effective over the long-term and if there are concerns in this regard (as indicated for
GW-2 and GW-3 on the table), these concerns would also apply to G W-4. If the cap systems are
considered comparable in effectiveness for each alternative, then the only difference between the
alternatives would be cost, and the results of evaluation would support GW-2 as the proposed
remedial alternative.

Attachment B page 16 of 16
ATTACHMENT C

Editorial/Consistency Comments on the Proposed Plan

 Attachment C
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Editorial/Consistency Comments on the Proposed Plan

CI. Page 6, 2'"' paragraph: 'The EPA negotiated a Partial Consent Decree (PCD) with the with P/S..."

C2. Page 16, 5"' bullet: "... 43 are wooded lots were no....", were should be where.

C3. Pages 15,16 and 19: inconsistent use of capitalization for "auto fluff".

C4. Page 23: "... PCDD/DF data were detected..." should be rephrased, suggest: "PCDD/DFs were
detected."

C5. Page. 24: "Metals were also found in sediment data... " should be rephrased, suggest: "Metals
were also reported for sediment samples."

C6. Page 26, creek banks: "... 3 EUs with average PCB OU-l/OU-2 Feasibility Study Report Anniston
PCB Site concentrations below 1mg/kg." should be rephrased, suggest: "3 EUs with average
PCB concentrations below 1mg/kg."

C7. Global with page 27 as an example: Inconsistent use of superscripts for 11th and 10"\

C8. Page 28: Fourth line under "Groundwater", delete the word "pathways".

C9. Page 28, First paragraph under groundwater, last sentence: should be changed: "... monitoring
wells were installed to..."

CIO. Page 28, Second paragraph under "Groundwater", 3"' sentence: "Soil data was..." should be
changed to "Soil samples were" or Soil data were".

Cll. Page 31, First paragraph under "Air", 5"' line: "Shown" should not be capitalized.

C12. Page 31, First paragraph under "Air", last sentence: "... that are part of the administrative
record."

C13. Page 31, Fourth paragraph under "Air", 3"' line: " ... air ranged from non-detect to...."

C14. Page 31, Last paragraph under "Air": First sentence should be clarified: In 2003 and 2004, Solutia
conducted the most comprehensive of all the ambient air PCB studies for Anniston.

CIS. Page 31, Last paragraph under "Air", 4"' line: "ranging" should be changed to "ranged".

C16. Page. 33, First paragraph, 5"' line: "ranging" should be changed to "ranged".

C17. Page 33, Second paragraph, first sentence: "Request" should be lower case.

C18. Page37, First sentence: The closing punctuation is missing.

C19. Page 37, Second paragraph, 3"' sentence: "... PCB remedial goals... " goal should be singular.

C20. Page 37, 4"' paragraph: " appear to be hot spots that are nor representative... " should be "not"

C21. Page. 39, PRGs for soil, 2'"' paragraph: typo: PCDD/DFs.

Attachment C page 1 of 4
 Attachment C
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Editorial/Consistency Comments on the Proposed Plan

C22. Page 41, 2'"' paragraph: arsenic should be lower case.

C23. Page 42, 2'"' paragraph: For consistency, grebes and muskrats should be plural.

C24. Page 42, 4"' paragraph: "... and all receptors at a NOAEL that spend 50%... " should be
rephrased, suggest: "... a NOAELfor receptors that spend 50%...".

C25. Page 42, 5th paragraph: "...receptors at a NOAEL that spend 50%... " should be rephrased,
suggest: "... a NOAEL for receptors that spend 50%..."

C26. Page. 42, 6th paragraph: "...receptors at a NOAEL that spend 50%... " should be rephrased,
suggest: "... a NOAEL for receptors that spend 50%..." .

C27. Page 42, 7th paragraph: "...receptors at a NOAEL that spend 50%... " should be rephrased,
suggest: "... a NOAEL for receptors that spend 50%...".

C28. Page 43,1^^ paragraph, 3"' line: " ... represents the mean..."

C29. Page 43, 2'"' paragraph: "...receptors at a NOAELthat spend 50%... " should be rephrased,
suggest: "... a NOAEL for receptors that spend 50%...".

C30. Page 43, 3rd paragraph: "...receptors at a NOAEL that spend 50%... " should be rephrased,
suggest: "... a NOAEL for receptors that spend 50%...".

C31. Page 43, 4"' paragraph: "This values are... " singular, plural, verb agreement, "...receptors at a
NOAEL that spend 50%... " should be rephrased suggest: "... a NOAELfor receptors that spend
50%...".

C32. Page 44, Table 6: The use of title case for constituents is not consistent.

C33. Page 46, RS-1: "... cover soil over subsurface soil PCBs remain in place." Should be reworded,
suggest: "... cover soil over subsurface soil where PCBs remain in place."

C34. Page 47,1^^ paragraph: " ... at an approved TSCA offsite disposal facilities." Singular, plural
agreement.

C35. Page 47, 2'"' paragraph: 4"' line "... or paved areas that limits exposure)..." plural, verb
agreement

C36. Page 47, 2'"' paragraph: 9"' line, "protection" should be "protect"

C37. Page.47, 2'"' sub-bullet: "soil are" singular, plural agreement

C38. Page 48, last full paragraph: "(i.e., buildings, sheds, or paved areas that limits exposure)" plural,
verb agreement

C39. Global and illustrated on pages 48 and 49: Consistent use of significant figures and/or decimal
points, e.g., 1.0 mg/kg, 1 mg/kg, 10.0 mg/kg, 10 mg/kg.

Attachment C page 2 of 4
 Attachment C
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Editorial/Consistency Comments on the Proposed Plan

C40. Global: Consistent use of text or symbols for >, <, >, >.

C41. Page 49, Last full paragraph: "... (a sampled... " should be "a sample"

C42. PageSl, 3"' paragraph, last line: "... controls that can..."

C43. Global for the Special Use Properties: Consistent use of capitalization and hyphenation of "low
activity" and "high activity" areas. The Stipulation uses "high activity" with no capitalization or
hyphen.

C44. Page 52, 3"' paragraph, last line: "... controls that can..."

C45. Page 53, SU-4, 3"' paragraph, last line: "... controls that can..."

C46. Page 54, Interim Measures, 1^' paragraph: "... removals actions..."

C47. Page 55, IM-2, 1^' paragraph, 6"' line: "engineering" should be "engineered".

C48. Page 56, IM-3, 1^' paragraph, 8"' line: "engineering" should be "engineered".

C49. Page 60, 8"' bullet: "Evaluated" should be "Evaluate"

C50. Page 61,1'^ bullet: "... PCBs is less th^ the PCB PRG..."

C51. Page 66,1^^ paragraph, 2'"' to last sentence: "... if ICs..." should be "... of ICs.... "

C52. Page 67, NRS-1,1^^ line: chromium should be lower case

C53. Page 73, Introduction to bullet list: "Groundwater" should be lower case.

C54. Page. 74, top of page: "Groundwater" should be lower case.

C55. Page. 74, last paragraph, ll"\ 12 line: "... these impacted soil,..." singular/ plural agreement.

C56. Page 75, GW-3: "... of the a 40-mil..."

C57. Page. 85, 7"' paragraph: " ... where surface soil were... " subject verb agreement

C58. Page 85, 7"' paragraph: "... subsurface soil with PCB concentration between ... " should be "PCB
concentrations... "

C59. Page 86, special use property soil, first sentence: "Surface soil ... have ... " subject verb
agreement

C60. Page 92, last paragraph, middle of paragraph, "... each involves..." subject verb agreement

C61. Page 93, 2'"' paragraph: This text should be clarified to reflect that the paragraph is discussing
ARARs.

C62. Page 93, bottom of page: The sentence: stating..."The lower cleanup goal will approximately
double the volume of soil and increase the short-term impacts on the community." Appears to

Attachment C page 3 of 4
 Attachment C
Anniston PCB Site: Operable Unit 1/Operable Unit 2
Pharmacia LLC/Solutia Inc. Editorial/Consistency Comments on the Proposed Plan

be somewhat out of context and could be re-phrased to clarify that it is a statement regarding
short-term effectiveness. Similarly, the 2'"' to last paragraph and the two one-sentence
paragraphs on page 94 regarding long-term effectiveness, implementability, and costs could be
re-phrased and/or combined to be clearer and easier to follow.

C63. Page.95, second paragraph is unclear and out of context.

C64. Page. 97, 1^' full paragraph: " the expected viability in the overall field construction schedule."
Should be variability.

C65. Page 98, last SED paragraph: costs are incorrect, should be: $3.1M (SED-4), $4.5M (SED-4).

C66. Page98, SU-3: "Excavate of... " should be re-worded, suggest: "Excavation of"

C67. Page 98: NRS-4 the "a)" appears out of context

C68. Page 99,bullet: the "a)" appears out of context

C69. Page. 99, last paragraph: "The soil management plan would extent..." should be changed to
"extend"

C70. Page 100, 1^' paragraph: "... institutional controls are limited to, the following:" delete comma.

C71. Page 100: "Five year reviews ... to determine if the remedies continues ..." subject verb
agreement.

Attachment C page 4 of 4