United States 

Environmental Protection 1200 Pennsylvania Avenue, N.W. 

Agency Washington, D.C. 20460 0D\ 2013 

Office of Solid Waste and Emergency Response 

Support Document for the 

Revised National Priorities List 

Final Rule – Macon Naval Ordnance Plant
Support Document for the 

Revised National Priorities List 

Final Rule 

Macon Naval Ordnance Plant 

May 2013 

Site Assessment and Remedy Decisions Branch 

Office of Superfund Remediation and Technology Innovation 

Office of Solid Waste and Emergency Response 

U.S. Environmental Protection Agency 

Washington, DC 20460 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Table of Contents

Executive Summary ................................................................................................................................... iv

Introduction ................................................................................................................................................ iv

Background of the NPL ........................................................................................................................... iv

Development of the NPL ......................................................................................................................... iv

Hazard Ranking System ........................................................................................................................... v

Other Mechanisms for Listing ................................................................................................................. vi

Organization of this Document................................................................................................................ vi

Glossary .................................................................................................................................................. vii

1. List of Commenters and Correspondence ........................................................................................ 1

2. Site Description ................................................................................................................................... 1

3. Summary of Comments ..................................................................................................................... 2

3.1 Support for Listing and Other Non-opposition Comments ........................................................... 5

3.2 Consistency with HRS .................................................................................................................. 5

3.2.1 Consistency with Guidance ................................................................................................................. 6

3.3 Site Name ..................................................................................................................................... 7

3.4 Liability ........................................................................................................................................ 7

3.5 Criteria for Listing ........................................................................................................................ 8

3.6 Data Quality Issues ....................................................................................................................... 8

3.7 Data Selection - Use of Previous Sampling Data .......................................................................... 9

3.8 Site Definition ............................................................................................................................. 10

3.9 Source 1 ...................................................................................................................................... 11

3.9.1 Representativeness of the Background Sample ................................................................................. 13

3.9.2 Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source Sample . 15

3.9.3 Documenting Mercury Contamination in the Source Sample ........................................................... 17

3.10 Observed Release – Background ................................................................................................ 18

3.10.1 Adequacy of Background Sample - Observed Release ..................................................................... 20

3.10.2 Sample Similarity .............................................................................................................................. 21

3.10.3 Number of Background Samples Used to Identify an Observed Release .......................................... 22

3.11 Observed Release - Attribution ................................................................................................... 23

3.11.1 Possible Mercury Releases from Alternative Sites ............................................................................ 25

3.11.1.1 Wastewater Discharges from GP and the Southern Wood Piedmont Company via the RCWRF 27

3.11.1.2 GP Air Emissions ......................................................................................................................... 29

3.11.1.3 Contribution of Sources West and North of Source 1 ................................................................... 30

3.11.2 Contaminant Concentration Gradient in Drainage Ditch #4.............................................................. 30

3.11.3 Contaminant Concentration Downgradient of the RCWRF .............................................................. 32

3.11.4 Other Data Sets ................................................................................................................................. 34

3.12 Characterization of PPE 1 ........................................................................................................... 36

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

iii 

4. Conclusion ......................................................................................................................................... 37

Attachment 1: Macon Water Authority, Rocky Creek Effluent Sample Results, Various Dates 

Attachment 2: Macon Water Authority, Rocky Creek Biosolids Mercury Data, Undated 

Attachment 3: Macon Water Authority, Status of MWA lines to Ocmulgee River from Rocky 

Creek POTW, January 24, 2003
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Executive Summary 

Section 105(a)(8)(B) of CERCLA, as amended by SARA, requires that the EPA prepare a list of national 

priorities among the known releases or threatened releases of hazardous substances, pollutants, or 

contaminants throughout the United States. An original National Priorities List (NPL) was promulgated 

on September 8, 1983 (48 FR 40658). CERCLA requires that the EPA update the list at least annually. 

This document provides responses to public comments received on the Macon Naval Ordnance Plant, 

proposed on March 15, 2012 (77 FR 15344). This site is being added to the NPL based on an evaluation 

under the EPA’s Hazard Ranking System (HRS) in a final rule published in the Federal Register in May 

2013. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Introduction 

This document explains the rationale for adding the Macon Naval Ordnance Plant site in Macon, Georgia, to the 

National Priorities List (NPL) of uncontrolled hazardous waste sites and also provides the responses to public 

comments received on this site. The EPA proposed this site on March 15, 2012 (77 FR 15344). This site is being 

added to the NPL based on an evaluation under the Hazard Ranking System (HRS) in a final rule published in the 

Federal Register in May 2013. 

Background of the NPL 

In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), 42 U.S.C. Sections 9601 et seq. in response to the dangers of uncontrolled hazardous waste sites. 

CERCLA was amended on October 17, 1986, by the Superfund Amendments and Reauthorization Act (SARA), 

Public Law No. 99-499, stat., 1613 et seq. To implement CERCLA, the EPA promulgated the revised National 

Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on July 16, 1982 (47 FR 

31180), pursuant to CERCLA Section 105 and Executive Order 12316 (46 FR 42237, August 20, 1981). The 

NCP, further revised by the EPA on September 16, 1985 (50 FR 37624) and November 20, 1985 (50 FR 47912), 

sets forth guidelines and procedures needed to respond under CERCLA to releases and threatened releases of 

hazardous substances, pollutants, or contaminants. On March 8, 1990 (55 FR 8666), the EPA further revised the 

NCP in response to SARA. 

Section 105(a)(8)(A) of CERCLA, as amended by SARA, requires that the NCP include 

criteria for determining priorities among releases or threatened releases throughout the United 

States for the purpose of taking remedial action and, to the extent practicable, take into account 

the potential urgency of such action, for the purpose of taking removal action. 

Removal action involves cleanup or other actions that are taken in response to emergency conditions or on a 

short-term or temporary basis (CERCLA Section 101). Remedial action is generally long-term in nature and 

involves response actions that are consistent with a permanent remedy for a release (CERCLA Section 101). 

Criteria for placing sites on the NPL, which makes them eligible for remedial actions financed by the Trust Fund 

established under CERCLA, were included in the HRS. The EPA promulgated the HRS as Appendix A of the 

NCP (47 FR 31219, July 16, 1982). On December 14, 1990 (56 FR 51532), the EPA promulgated revisions to the 

HRS in response to SARA, and established the effective date for the HRS revisions as March 15, 1991. 

Section 105(a)(8)(B) of CERCLA, as amended, requires that the statutory criteria provided by the HRS be used to 

prepare a list of national priorities among the known releases or threatened releases of hazardous substances, 

pollutants, or contaminants throughout the United States. The list, which is Appendix B of the NCP, is the NPL. 

An original NPL of 406 sites was promulgated on September 8, 1983 (48 FR 40658). At that time, an HRS score 

of 28.50 was established as the cutoff for listing because it yielded an initial NPL of at least 400 sites, as 

suggested by CERCLA. The NPL has been expanded several times since then, most recently on September 18, 

2012 (77 FR 57546). The Agency also has published a number of proposed rulemakings to add sites to the NPL. 

The most recent proposal was on September 18, 2012 (77 FR 57546). 

Development of the NPL 

The primary purpose of the NPL is stat ed in the legi slative history of CERCLA (Report of the Committ ee on 

Environment and Public Works, Senate Report No. 96-848, 96th Cong., 2d Sess. 60 [1980]). 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

The priority list serves primarily informational purposes, identifying for the States and the public 

those facilities and sites or other releases which appear to warrant remedial actions. Inclusion of a 

facility or site on the list does not in itself reflect a judgment of the activities of its owner or 

operator, it does not require those persons to undertake any action, nor does it assign liability to 

any person. Subsequent government actions will be necessary in order to do so, and these actions 

will be attended by all appropriate procedural safeguards. 

The NPL, therefore, is primarily an informational and management tool. The identification of a site for the NPL is 

intended primarily to guide the EPA in determining which sites warrant further investigation to assess the nature 

and extent of the human health and environmental risks associated with the site and to determine what CERCLAfinanced remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites the EPA 

believes warrant further investigation. Finally, listing a site may, to the extent potentially responsible parties are 

identifiable at the time of listing, serve as notice to such parties that the Agency may initiate CERCLA-financed 

remedial action. 

CERCLA Section 105(a)(8)(B) directs the EPA to list priority sites among the known releases or threatened 

release of hazardous substances, pollutants, or contaminants, and Section 105(a)(8)(A) directs the EPA to 

consider certain enumerated and other appropriate factors in doing so. Thus, as a matter of policy, the EPA has 

the discretion not to use CERCLA to respond to certain types of releases. Where other authorities exist, placing 

sites on the NPL for possible remedial action under CERCLA may not be appropriate. Therefore, the EPA has 

chosen not to place certain types of sites on the NPL even though CERCLA does not exclude such action. If, 

however, the Agency later determines that sites not listed as a matter of policy are not being properly responded 

to, the Agency may consider placing them on the NPL. 

Hazard Ranking System 

The HRS is the principle mechanism the EPA uses to place uncontrolled waste sites on the NPL. It is a 

numerically based screening system that uses information from initial, limited investigations -- the preliminary 

assessment and site inspection -- to assess the relative potential of sites to pose a threat to human health or the 

environment. HRS scores, however, do not determine the sequence in which the EPA funds remedial response 

actions, because the information collected to develop HRS scores is not sufficient in itself to determine either the 

extent of contamination or the appropriate response for a particular site. Moreover, the sites with the highest 

scores do not necessarily come to the Agency's attention first, so that addressing sites strictly on the basis of 

ranking would in some cases require stopping work at sites where it was already underway. Thus, the EPA relies 

on further, more detailed studies in the remedial investigation/feasibility study that typically follows listing. 

The HRS uses a structured value analysis approach to scoring sites. This approach assigns numerical values to 

factors that relate to or indicate risk, based on conditions at the site. The factors are grouped into three categories. 

Each category has a maximum value. The categories are: 

• likelihood that a site has released or has the potential to release hazardous substances into the 

environment; 

• characteristics of the waste (toxicity and waste quantity); and 

• people or sensitive environments (targets) affected by the release. 

Under the HRS, four pathways can be scored for one or more threats as identified below: 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

• Ground Water Migration (Sgw) 

- drinking water 

• Surface Water Migration (Ssw) 

The following threats are evaluated for two separate migration components, overland/flood migration and 

ground water to surface water. 

- drinking water 

- human food chain 

- sensitive environments 

• Soil Exposure (Ss) 

- resident population 

- nearby population 

- sensitive environments 

• Air Migration (Sa) 

- population 

- sensitive environments 

After scores are calculated for one or more pathways according to prescribed guidelines, they are combined using 

the following root-mean-square equation to determine the overall site score (S), which ranges from 0 to 100: 

4

S + S + S + S = S

2

a

2

s

2

sw

2

gw

If all pathway scores are low, the HRS score is low. However, the HRS score can be relatively high even if only 

one pathway score is high. This is an important requirement for HRS scoring because some extremely dangerous 

sites pose threats through only one pathway. For example, buried leaking drums of hazardous substances can 

contaminate drinking water wells, but -- if the drums are buried deep enough and the substances not very volatile 

-- not surface water or air. 

Other Mechanisms for Listing 

There are two mechanisms other than the HRS by which sites can be placed on the NPL. The first of these 

mechanisms, authorized by the NCP at 40 CFR 300.425(c)(2), allows each State and Territory to designate one 

site as its highest priority regardless of score. The last mechanism, authorized by the NCP at 40 CFR 

300.425(c)(3), allows listing a site if it meets the following three requirements: 

• Agency for Toxic Substances and Dis ease R egistry (ATSDR) o f the U.S. P ublic Health Service ha s 

issued a health advisory that recommends dissociation of individuals from the release; 

• EPA determines the site poses a significant threat to public health; and 

• EPA anticipates it will be m ore cost-effective to us e its remedial authorit y than to use it s emergency 

removal authority to respond to the site. 

Organization of this Document 

The following section contains the EPA responses to site-specific public comments received on the proposal of 

the Macon Naval Ordnance Plant site on March 15, 2012 (77 FR 15344). The site discussion begins with a list of 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

commenters, followed by a site description, a summary of comments, and Agency responses to each comment. A 

concluding statement indicates the effect of the comments on the HRS score for the site. 

Glossary 

The following acronyms and abbreviations are used throughout the text: 

Agency U.S. Environmental Protection Agency 

AIP Allied Industrial Park 

APA Administrative Procedure Act 

AWI Armstrong World Industries 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 

U.S.C. Sections 9601 et seq., also known as Superfund 

CFR Code of Federal Regulations 

D.C. Cir U.S. Court of Appeals for the District of Columbia Circuit 

DoD Department of Defense 

EPA U.S. Environmental Protection Agency, also USEPA 

FMNOL Former Macon Naval Ordnance Landfill 

FR Federal Register

GP Graphic Packaging 

HRS Hazard Ranking System, Appendix A of the NCP 

HRS score Overall site score calculated using the Hazard Ranking System; ranges from 0 to 100 

MCL Maximum contaminant level 

μg/kg Micrograms per kilogram 

μg/L Micrograms per liter 

MNOP Macon Naval Ordnance Plant 

MWA Macon Water Authority 

NCP National Oil and Hazardous Substances Pollution Contingency Plan, 40 C.F.R. Part 300 

NPDES National Pollution Discharge Elimination System 

NPL National Priorities List, Appendix B of the NCP 

NWI National Wetlands Inventory 

OR Observed release 

OSWER USEPA’s Office of Solid Waste and Emergency Response 

PA Preliminary assessment 

PCE Tetrachloroethene or tetrachloroethylene 

PRP Potentially responsible party 

PSA Pre-CERCLIS screening assessment 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

viii 

QAPP Quality assurance project plan 

QA/QC Quality assurance/quality control 

RCRA Resource Conservation and Recovery Act 

RCWRF Rocky Creek Water Reclamation Facility 

RI Remedial investigation 

ROD Record of decision 

SARA Superfund Amendments and Reauthorization Act 

SCDM Superfund Chemical Data Matrix 

SESD Science and Ecosystem Support Division

SI Site inspection

SWPC Southern Wood Piedmont Company

TCE Trichloroethene or trichloroethylene 

USACE United States Army Corps of Engineers

USGS United States Geological Survey 

VOC Volatile organic compound 

 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

1. List of Commenters and Correspondence 

EPA-HQ-SFUND-2012-0064-0004 State Concurrence Letter – Macon Naval Ordnance Plant 

submitted by F. Allen Barnes, Director, Georgia Department of 

Natural Resources 

EPA-HQ-SFUND-2012-0064-0005 Comment and attachment submitted by Peter J. Fontaine of 

Cozen O’Conner 

 EPA-HQ-SF UND-2012-0064-0006 Comment and attachment submitted by Maureen 

EPA-HQ-SFUND-2012-0064-0008 Sullivan, Director, Environmental Management, on behalf of the 

Department of Defense (DoD)

EPA-HQ-SFUND-2012-0064-0007 Comment and attachment submitted by Peter J. Fontaine of 

Cozen O’Conner on behalf of Unimax Corporation 

 EPA-HQ-SFUND-2012-0064-0009 Comment and attachment submitted by Michael W. Steinberg, 

Counsel, Morgan, Lewis & Bockius LLP 

 EPA-HQ-SFUND-2012-0071-0005 Comment and attachment submitted by Emily Hinchman, 

Rutgers University School of Law – Camden 

2. Site Description 

The Macon Naval Ordnance Plant (MNOP) site (the Site), located in Macon, Georgia, is composed of the release 

of mercury from the former MNOP facility to Drainage Ditch #4 and into Rocky Creek. Land uses at the facility 

are predominantly commercial and heavy industrial. The MNOP facility was constructed and operated by the 

Reynolds Corporation before World War II for production of ordnance. In 1941, the U.S. Navy assumed 

operation of the plant and continued to manufacture ordnance there until 1965. Ordnance manufactured at the 

MNOP included flares, small primers, detonators, and other triggering mechanisms. Several industrial businesses 

such as Maxson Electronics Corporation, Allied Chemical Corporation, and Macon-Bibb County Industrial 

Authority have owned and operated at the location of the MNOP facility since the Department of Defense (DoD) 

operations ceased in 1965. 

The MNOP facility property is bordered to the north by Guy Paine Road; to the east by Mead Road and the 

Norfolk Southern railroad tracks; to the southeast by Graphic Packaging; to the south by the Macon Water 

Authority (MWA) Rocky Creek Water Reclamation Facility (RCWRF), the Armstrong World Industries (AWI) 

remote landfill, the former Macon Naval Ordnance Landfill (FMNOL), and Rocky Creek; and to the west by the 

AWI plant property (see Figure 1). 

The Site for HRS scoring purposes includes one source (Source 1) -- contaminated soil on the eastern section of 

the MNOP property near Building 109, and the associated releases from the Site to drainage ditch #4. Source 1 

consists of contaminated soil surrounding Building 109 which was a primary explosives production area. Soil 

samples collected from this area during the U.S. Army Corps of Engineer’s (USACE) 1996 site investigation 

contained mercury. Mercury has also been detected at significant levels in sediments collected in wetlands that 

receive runoff from Source 1 via Drainage Ditch #4 on the east side of the facility, indicating that a release has 

occurred to the surface water migration pathway. The HRS Site score is based on the release of mercury to the 

surface water migration pathway and the resulting risk to nearby wetlands and a human food chain fishery. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

2 

Several investigations have been conducted at MNOP between 1989 and 2011. Mercury has been associated with 

the MNOP site. The most recent investigation was a June 2011 Supplemental Sampling Event (shown in Figure 1 

below) and while all available data was used in the site evaluation and included as references to the HRS 

documentation record at proposal, the June 2011 data was the basis for the HRS evaluation as it is the most 

current data and is focused on contamination in Drainage Ditch #4. Source background samples were taken on the 

northern portion of the MNOP property (MNOP-01-SF shown in Figure 1 below) and an observed release 

background level was based on a sample taken from southwest of the MNOP property located in the same 

wetland as the observed release sample (MNOP-W-01-SD shown on Figure 3 of the HRS documentation record 

at proposal). 

3. Summary of Comments 

Two commenters, Michael W. Steinberg, on behalf of Counsel, Morgan, Lewis and Bockius LLP, and Emily 

Hinchman, from Rutgers University School of Law, each submitted a comment regarding all sites proposed for 

listing in March 2012, which include the former Macon Naval Ordnance Plant. These comments applicable to 

multiple sites are addressed in the preamble of the first Final Rule promulgating sites that were proposed for 

listing in March 2012 (77 FR 57498-57500, September 18, 2012). 

The Director of the Georgia Department of Natural Resources, F. Allen Barnes, supported the placement of the 

former Macon Naval Ordnance Site on the National Priorities List (NPL) and commented that the listing will help 

compel responsible parties to plan remedial action that is needed at the Site. 

Three commenters submitted comments in opposition to placing the former Macon Naval Ordnance Plant on the 

NPL. Peter J. Fontaine of Cozen O’Conner (Cozen) submitted a set of preliminary comments and later submitted 

additional comments on behalf of the Unimax Corporation (Unimax). Maureen Sullivan, Director of 

Environmental Management, submitted comments on behalf of DoD. Cozen, Unimax, and DoD raised both site 

eligibility policy and technical HRS scoring issues. 

Unimax commented that the EPA did not correctly follow the HRS or HRS guidance in placing the Site on the 

NPL. Unimax also commented that the data used in the HRS documentation record was not of known and 

documented quality, was from unreliable previous sampling events, and used qualified data that should not be 

used in an HRS evaluation. 

DoD commented that the Site should be renamed “Allied Industrial Park,” since DoD activities have ceased and 

the property is now commonly known as such. DoD, Cozen, and Unimax also commented that the property has 

been owned and operated by several different businesses and the EPA fails to discuss these other potentially 

responsible parties (PRPs), as well as failing to discuss possible sources such as the Rocky Creek Water 

Reclamation Facility (RCWRF), Graphic Packaging (GP), and an adjacent NPL site that is currently being 

remediated. 

DoD, Unimax, and Cozen commented that Source 1 has not been properly established and that the background 

sample used for Source 1 is insufficient to show that contamination is non-ubiquitous. Unimax and Cozen 

commented that a single source soil background sample is suspect also because it is a qualified value and merely 

an estimate. 
Macon Naval Ordnance Plant NPL Listing Support Document 

3 

Figure 1 – Map of the Macon Naval Ordnance Plant area showing the property boundaries, drainage ditches, wetlands, 
Macon Naval Ordnance Plant NPL Listing Support Document 

4 

Figure 2 – Large-scale map of the Macon Naval Ordnance Plant area showing the neighboring facilities of Graphic Pac

Armstrong World Industries, and location of the background wetland sediment sample used to establish the observed r#4. 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Cozen and Unimax commented that only one background sediment sample used to establish an observed release 

is insufficient and not defensible to establish background conditions, account for background variability, and 

attribute contamination to the former Macon Naval Ordnance Plant. Additionally, Unimax and Cozen commented 

that this background sample (the observed release background sample) was not taken from the same media as the 

observed release sample and is therefore insufficient to show sample similarity. 

Unimax and Cozen commented that the mercury contaminant concentration gradient in Drainage Ditch #4 does 

not support MNOP being the source of mercury contamination. Unimax commented that the HRS documentation 

record only obtained a small set of data focused around Building 109 and Drainage Ditch #4, and commented that 

a large volume of spatially extensive, high-quality, relevant data has been ignored. Unimax and Cozen 

commented that there are other sources of mercury in the area and that mercury discharges from GP and the 

Southern Wood Piedmont Company (SWPC) to the RCWRF had not been considered in attributing the mercury 

contamination to the MNOP site. Unimax also identified that the GP released mercury to the air and that GP 

should also be considered a possible source of the mercury. 

Finally, Unimax commented that the probable point of entry (PPE) is located within a settling basin of the 

RCWRF in which the National Wetlands Inventory (NWI) characterizes the location as Emergent Wetland 

“PEM1Fx,” which is depicted as part of the RCWRF. 

3.1 Support for Listing and Other Non-opposition Comments 

Comment: F. Allen Barnes, Director of the Georgia Department of Natural Resources, expressed support for the 

placement of the Macon Naval Ordnance Plant site on the National Priorities List (NPL). Mr. Barnes stated that 

“[t]he NPL listing will help compel the PRPs to move forward with the investigation and remedial action that is 

needed at the Site.” 

Response: The Macon Naval Ordnance site is being added to the NPL. Listing makes a site eligible for remedial 

action funding under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 

and the EPA will examine the Site to determine the appropriate response action(s). Actual funding may not 

necessarily be undertaken in the precise order of HRS scores. In addition, upon more detailed investigation may 

not be necessary at all in some cases. The need for using Superfund monies for remedial activities will be 

determined on a site-by-site basis, taking into account the NPL ranking, State priorities, further site investigation, 

other response alternatives, and other factors as appropriate. 

3.2 Consistency with HRS 

Comment: Unimax commented that the EPA failed to follow the HRS in placing this site on the NPL, and as a 

result the placement of the Site on the NPL is arbitrary and capricious. Unimax asserted that the EPA should 

withdraw its proposed listing of the Site. 

Response: The HRS evaluation of the Site is consistent with the HRS regulation and the Administrative Procedure 

Act (APA); EPA’s decision to add the Site to the NPL based on the HRS evaluation is therefore neither arbitrary 

nor capricious. The HRS documentation record at proposal and this support document clearly document that EPA 

has complied with the HRS regulation; this support document addresses all comments on the proposed listing of 

this site, including those comments that challenge compliance with the HRS, and shows that HRS requirements 

have been met in every aspect of the Site evaluation. 

Section 553 of the APA authorizes “informal” rulemaking. The informal rulemaking process encourages and 

relies on the participation of the public, including PRPs. The public can comment during the comment period 

(typically 60 days) after a site is proposed for listing and also during the time the Agency is evaluating and 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

selecting a remedy (the Agency may also hold a public hearing during the latter decision-making period). If 

private parties conduct remedial action under a Consent Decree between the EPA and the parties, the decree is 

also subject to public comment. The Agency believes that the above process offers the public sufficient 

opportunity to present facts and opinions germane to its decision-making in a timely manner. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.2.1 Consistency with Guidance 

Comment: Unimax asserted that the EPA failed to follow its own guidance in the HRS evaluation of the Site. 

Unimax specifically commented that the HRS Guidance Manual [The Hazard Ranking System Guidance Manual; 

Interim Final, November 1992 (NTIS PB92-963377, EPA 9345.1-07)] was not followed when determining 

background concentrations and attributing mercury contamination to the MNOP facility, concluding that “the 

background determination is arbitrary...” Unimax made the following statements regarding the EPA’s use of the 

HRS Guidance Manual: 

• EPA’s failure to explain why the off-site mercury impacts in Ditch #4 are not derived from the Rocky 

Creek Water Reclamation Facility (RCWRF) and the Graphic Packaging (GP) facilities is contrary to 

EPA’s HRS guidance. 

• EPA’s failure to consider the RCWRF and the GP facilities as sources of the mercury impacts detected in 

Drainage Ditch #4 and at the so-called “source area” on the former MNOP is contrary to EPA’s HRS 

guidance. 

• According to EPA HRS Guidance, there is no source of mercury on the MNOP property. 

Unimax asserted that these inconsistencies with guidance render the HRS evaluation arbitrary and capricious. 

Response: The EPA followed the HRS regulation to list the Site. Furthermore, the HRS Guidance Manual was 

also applied appropriately in the HRS evaluation based on the facts and circumstances presented for this site. The 

responses presented in this support document demonstrate that the HRS evaluation was consistent with EPA 

guidance. The technical aspects of this comment are addressed in this support document in sections 3.9, Source 1; 

3.10, Observed Release – Background; and 3.11, Observed Release – Attribution. 

Unlike the HRS regulation itself, the HRS Guidance Manual is not a regulation and imposes no mandatory 

requirements on the agency. The HRS Guidance Manual states that: 

[t]he procedures set forth in this document are intended as guidance to employees of the U.S. 

Environmental Protection Agency (EPA), States, and other government agencies. EPA officials 

may decide to follow the guidance provided in this directive, or to act at variance with it, based 

on analysis of specific site circumstances. 

In evaluating whether a site merits NPL listing, the EPA complies with the HRS regulation in the HRS evaluation 

and uses the HRS Guidance Manual as guidance to determine how best to perform the evaluation based on the 

facts or circumstances presented at each site. The HRS Guidance Manual is consistent with the HRS (this was not 

challenged by Unimax). As shown in this support document, the EPA has followed the HRS in scoring the Site 

and applied the HRS Guidance Manual as appropriate to the Site situation. EPA is therefore neither arbitrary nor 

capricious in the decision to list this site on the NPL. 

 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

3.3 Site Name 

Comment: The DoD commented that the Site should be renamed “Allied Industrial Park,” as several industrial 

businesses have owned and operated the property since the DoD activities have ceased and the property is now 

commonly known as Allied Industrial Park (AIP). 

Response: The Site name has not been revised. While neither CERCLA nor the NCP establishes a required 

procedure for assigning a site name to a proposed listing, in this case it is reasonable to have named the site the 

Macon Naval Ordnance Plant site. Since the primary purpose of an NPL listing is to inform the public that the site 

warrants further investigation, the attempt is made to select the name that most clearly informs the public as to the 

location of the site, what appears to be the primary source(s) of the problems at the site, and/or considers 

assigning a geographic name. The attempt is also made to select names that do not offend local sensitivities (see 

RSR Corporation v. EPA, 102 F.3d 1266 (D.C. Cir. 1997)). The EPA chose to name the Site Macon Naval 

Ordinance Plant, as that site name is expected to have some degree of name-association to the public. 

The site was named after the Macon Naval Ordnance Plant, which was constructed and operated by the Reynolds 

Corporation before World War II for production of ordnance. The U.S. Navy assumed operations in 1941 and 

continued to manufacture ordnance at the MNOP until 1965. Ordnance manufactured at the MNOP included 

flares, small primers, detonators, and other triggering mechanisms. Page 13 of the HRS Documentation record at 

proposal states: 

Explosive compounds were either handled or stored at many areas throughout the MNOP 

property, including numerous small dryer buildings, ordnance magazines, and blending and 

weighing houses (Ref. 13, pp. 11, 12, 54) (see Figure 2 of this HRS documentation record). 

According to a technical manual prepared by the Department of the Army, military explosives, 

such as those that were manufactured at the MNOP, contained mercury compounds as initiating 

agents, including mercury fulminate (Ref. 23, pp. 7-5, 7-8). Building 109, located in the eastern 

portion of the MNOP, was a primary explosives production site (Ref. 13, pp. 11, 12, 54) 

Importantly, the name of the Site does not in any way restrict the evaluation of the Site, its sources, its releases, or 

extent of contamination to only the practices of the Macon Naval Ordnance Plant. Any and all areas of 

contamination associated with the Site will be explored during further investigation activities. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.4 Liability 

Comment: The DoD and Unimax commented that the MNOP property has been owned and operated by several 

different industrial businesses since DoD activity and operations have ceased. The DoD stated that “the current 

narrative...fails to discuss the other potentially responsible parties whose operations appear to be associated with 

the areas evaluated for this proposed listing.” 

Response: Inasmuch as this comment addresses the owners and operators of the property on which the Site source 

is located, liability for site contamination is not considered when evaluating a site under the HRS, nor is liability 

established or apportioned based on the decision to place a site on the NPL. The NPL serves primarily as an 

informational tool for use by the EPA in identifying those sites that appear to present a significant risk to public 

health or the environment. It does not reflect a judgment on the activities of the owner(s) or operator(s) of a site. It 

does not require those persons to undertake any action, nor does it assign any liability to any person. This 

position, stated in the legislative history of CERCLA, has been explained more fully in the Federal Register (48 

FR 40759, September 8, 1983 and 53 FR 23988, June 24, 1988). See Kent County v. EPA, 963 F.2d 391 (D.C. 

Cir. 1992). 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.5 Criteria for Listing 

Comment: The DoD commented that the Site Narrative should identify and include one or more listing criteria as 

set forth in the NCP and stated that “[i]n this case, the applicable criterion appears to be the HRS score.” The DoD 

also asserted that the Site may not need listing because contamination may originate from a source area on an 

adjacent NPL site that is currently being remediated. 

Response: The listing criteria are provided in the administrative record for this rulemaking, which includes the 

HRS documentation record and supporting materials, including this support document. For prospective sites under 

consideration for listing on the NPL, the EPA follows NCP procedures by conducting a preliminary assessment 

(PA) of the site. Depending on the results, the PA may be followed up by a site inspection report (SI), which 

involves gathering more information about the site by contacting the state and interested parties on and around the 

site. When a site is proposed to the NPL, the EPA provides its detailed rationale, including consideration of 

information gathered in the PA and SI, along with other site-related information in documents (i.e., the HRS 

documentation record and supporting materials) made publicly available at the EPA Headquarters in Washington, 

DC, in the Regional offices, and by electronic access at htpp://www.regulations.gov. In this case, the MNOP site 

qualifies for listing on the NPL; the Site has received an HRS score of greater than 28.50 and has met CERCLA 

and NCP listing criteria. Furthermore, the State concurred with the listing and stated that remedial action was 

needed at the Site. The purpose of NPL listing is explained in the Final Rule, National Priorities List for 

Uncontrolled Hazardous Waste Sites, published February 21, 1990 (55 FR 6154), excerpted below. 

The purpose of the NPL, therefore, is primarily to serve as an informational and management 

tool. The initial identification of a site for the NPL is intended primarily to guide EPA in 

determining which sites warrant further investigation to assess the nature and extent of the public 

health and environmental risks associated with the site and to determine what CERCLA-financed 

remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites 

EPA believes warrant further investigation. 

While remediation may be occurring on an adjacent NPL site, the source (Source 1) identified in the HRS 

documentation record at proposal warrants further investigation and there have been no efforts or plans to 

remediate the source as part of any other site. Furthermore, the HRS evaluation of the MNOP site yielded a site 

score of 48.97; this score is substantially above the 28.50 score that qualifies a site for listing and is sufficient, in 

and of itself, to place the Site on the NPL. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.6 Data Quality Issues 

Comment: Unimax commented that the Tetra Tech 2011 data used in the HRS documentation record at proposal 

was not of “known and documented quality.” Specifically, Unimax commented that data validations and QA/QC 

procedures were not provided in the HRS documentation package for the 2011 assessment. Unimax concluded 

that “until evidence that QA/QC procedures were correctly followed, the data from Tetra Tech, 2011 is not 

reliable.” Unimax also noted that the data used in the HRS documentation record at proposal contained qualified 

data that “is merely an estimate (denoted by the ‘J-Value’)” and asserted that qualified data should not be used in 

the HRS evaluation. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Response: The data used in the HRS evaluation were properly validated according to documented validation and 

QA/QC procedures, and are of known and documented quality. In addition, qualified data was used appropriately 

in this HRS evaluation. The analytical data used in the HRS scoring of this site came from a June 2011 

supplemental sampling event that was performed in accordance with the EPA Quality Assurance Project Plan 

(QAPP) for the sampling event, dated June 20, 2011. Soil samples collected in this event were collected in 

accordance with the EPA Region 4 Science and Ecosystem Support Division (SESD) Field Branches Quality 

System and Technical Procedure for Soil Sampling, November 2007 (SESDPROC-300-R1) (Reference 24 to the 

HRS documentation record at proposal) and sediment samples were collected in accordance with the EPA Region 

4 SESD Field Branches Quality System and Technical Procedure for Sediment Sampling, September 2010 

(SESDPROC-200-R2) (Reference 25 to the HRS documentation record at proposal). 

Regarding data validation, the June 2011 analytical data was reviewed, and validated in accordance with EPA 

procedures; therefore the data are of known and documented quality. Page 17 of the HRS documentation record 

at proposal states that “EPA Region 4 [Science and Ecosystem Support Division] SESD reviewed all data 

according to the laboratory contract statement of work (SOW) and EPA guidelines (Refs. 28; 11, p. 1).” 

Reference 28 of the HRS documentation record at proposal, provides a description of how data review, 

validation, and verification is conducted in the EPA SESD program. Data validation reports and the QA/QC 

procedures for the June 2011 sampling event are provided in References 10, 11, 26, 27, and 28 of the HRS 

documentation record at proposal. 

Regarding the use of qualified data in the HRS evaluation, the U.S. Court of Appeals for the D.C. Circuit has 

specifically ruled on the use of analytical data in the scoring of a site using the HRS when there are possible 

weaknesses in the laboratory analysis. In the case of Board of Regents of the University of Washington v. EPA, 86 

F.3d 1214 (DC Cir. 1996), the Court, in response to the petitioner's challenge regarding the quality of the data 

used in an HRS evaluation—specifically, when there were issues dealing with the analysis—stated that “EPA 

does not face a standard of absolute perfection. . . . Rather, it is statutorily required to ‘assure to the maximum 

extent feasible,’ that it ‘accurately assesses the relative degree of risk,’” [emphasis in original] and that “[i]t would 

hardly make sense for the courts to respond to the resulting evidence by treating a lab’s findings as fatally 

defective whenever it comes up short in any way.” Also in this decision, the Court repeated a statement in an 

earlier NPL HRS case (Eagle–Picher Indus., Inc. v. EPA, 759 F.2d. 905, 921, D.C. Cir. 1985) that explained the 

Agency has met its obligations when “[t]he EPA has thus ‘examined [the] relevant data and . . . articulated a 

rational explanation for its action.’” [addition of “the” in original] 

Therefore, the data used in the HRS evaluation are of known and documented quality and are appropriate for use 

in the HRS evaluation consistent with the intent of the HRS and court rulings. 

See also section 3.9.2, Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source 

Sample, of this support document, which addresses the technical aspects of this comment regarding the use of 

analytical data and data quality. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.7 Data Selection - Use of Previous Sampling Data 

Comment: Unimax commented that other previous data sets (i.e., 2009 Region 4 SESD data completed by 

TetraTech and 1998 Rust data) are available for the Site that were not included in the HRS documentation record 

at proposal. Unimax commented that a large volume of spatially extensive, relevant data has been ignored and 

that these other data sets show that the Site conditions were not adequately represented in the HRS documentation 

record at proposal. Unimax noted that the only data used in the HRS documentation record to justify NPL listing 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

was obtained in a small sampling event in 2011, which shows “an arbitrary selectivity in the use of the data.” 

Unimax claimed, “EPA’s failure to attempt to explain this contradictory data is arbitrary and capricious.” 

Response: Contrary to Unimax’s assertions, all of the data sets that the commenter mentioned (2009 Region 4 

SESD data completed by TetraTech, 1998 Rust data, and June 2011 Supplemental Sampling Event data) were 

relied upon in the evaluation of the MNOP site and were included in the HRS documentation record at proposal as 

references to the HRS documentation record. However, none of the data from the previous sampling events 

impacted the scoring of the MNOP site, so the most recent data (June 2011 Supplemental Sampling Event) was 

used in the HRS documentation record to most accurately represent the current conditions at the MNOP site. 

While all of the data from all prior sampling events were considered in the evaluation of the MNOP site and are 

referenced in the HRS documentation record at proposal, the June 2011 Supplemental Sampling Event data was 

used to score the Site because this data is most recent and best represents current Site conditions. The 2009 

Region 4 SESD data (referred to by Unimax as 2009 TetraTech data) are included as References 7, 34 and 35 of 

the HRS documentation record at proposal and the 1998 Rust Report is included as Reference 13 of the HRS 

documentation record at proposal; the results from the prior sampling events are consistent with the results from 

the June 2011 Supplemental Sampling Event and the HRS documentation record characterization of the Site, 

source, or observed releases. 

The HRS documentation record at proposal uses the most current data (June 2011) to establish the presence of 

mercury in Source 1 and an observed release of mercury downgradient in Drainage Ditch #4. The HRS 

requirements for identifying sources and the hazardous substances associated with the source as well as the HRS 

requirements for establishing an observed release by chemical analysis have been met. All previous studies and 

additional data would be considered in performing other stages of the Superfund process after listing. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.8 Site Definition 

Comment: Unimax and Cozen made several comments using the term “onsite” to refer to the MNOP property and 

using the term “offsite” to refer to areas other than the MNOP property. Examples of these comments include: 

• Unimax commented that elevated mercury samples “onsite,” as well as samples within Drainage Ditch 

#4, may have migrated from “offsite” sources. 

• Sediment samples in Drainage Ditch #4 that are consistently low in mercury, while “onsite” and exhibit 

elevated concentrations only in “offsite” portions of the ditch. 

• Most “onsite” sediment concentrations are lower than those found in the most upgradient portions of 

Rocky Creek. 

Response: In their comments, Cozen and Unimax incorrectly equated “site” with the MNOP property; whereas, as 

defined in the HRS, “site” refers to an area where a hazardous substance has been deposited, stored, disposed, or 

placed, or has otherwise come to be located, and is not restricted by or defined by property boundaries. This 

response describes the meaning of “site” as used in the HRS documentation record and in this support document, 

and clarifies that the HRS defines the term “site” to encompass a different physical area than Cozen and Unimax 

referred to in their comments. The technical aspects of their comments are addressed in this support document in 

sections 3.9, Source 1; 3.10, Observed Release – Background, and 3.11; Observed Release – Attribution. 

HRS Section 1.1, Definitions, provides the definition for the term “site”: 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Site: Area(s) where a hazardous substance has been deposited, stored, disposed, or placed, or has 

otherwise come to be located. Such areas may include multiple sources and may include the area 

between sources. 

Page 15346 of NPL Proposed Rule No. 56, published March 15, 2012 (77 FR 15344) clarifies that: 

the NPL site is not necessarily coextensive with the boundaries of the installation or plant, and the 

boundaries of the installation or plant are not necessarily the ‘‘boundaries’’ of the site. Rather, the 

site consists of all contaminated areas within the area used to identify the site, as well as any other 

location where that contamination has come to be located or from where that contamination came.

The HRS documentation record at proposal states that “[f]or HRS scoring, the site consists of one source and 

associated releases.” Source 1 is contaminated soil on the eastern section of the MNOP property, which contains 

elevated concentrations of mercury over background levels (see section 3.9, Source 1, of this support document). 

An associated release of mercury has also been detected at significant levels in sediments collected in wetlands 

outside of the MNOP property boundaries that receive runoff from Source 1 via Drainage Ditch 4. 

Therefore, a site is not associated with property or facility boundaries and the MNOP site is not confined to the 

MNOP property boundaries.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.9 Source 1 

Comment: The DoD, Unimax, and Cozen commented that Source 1 has not been properly established. These 

commenters asserted that the former MNOP is not the source of mercury contamination found at the Site and that 

Source 1 does not contain mercury contamination above levels found in the local environment. 

Unimax commented that the HRS Site score should be 0 because the MNOP does not contain a source of mercury 

that contributes to the observed release. Unimax stated that “there appears to be no credible basis to assume that 

its [the EPA’s] ‘Source No. 1’ somewhere near Building 109 exists.” Unimax commented that other available 

data shows low levels of mercury contamination present on the western portion of the property “thousands of feet 

west of Drainage Ditch #4” and no mercury contamination on the eastern portion of the property where Source 1 

is located. Unimax asserted that since the western portion of the property is not a plausible source of the mercury 

contamination found in the Drainage Ditch #4 samples, the Source sample “is not representative of site 

conditions...” and therefore Source 1 was not properly established. 

Response: The HRS documentation record at proposal correctly identifies Source 1 as a contaminated soil source 

on the MNOP property. Mercury contamination has been documented to be present at levels above background at 

the facility surrounding Building 109 as determined by sampling and documented in the HRS documentation 

record at proposal1

. 

 

1

 This section of the support document deals exclusively with samples that are used to establish Source 1. Background 

samples discussed in this section are not the same as the background sample that is used to establish the observed release 

sample (see Figures 1 and 2). While background samples are not required to establish site sources, as explained in section 

3.9.1, Representativeness of the Background Sample, of this support document, Source 1 background samples were used 

solely to demonstrate that mercury contamination in Source 1 is elevated over natural mercury concentrations in the local 

environment. The commenters’ concerns about the observed release samples, including the background sample used to 

establish an observed release, are discussed in section 3.10, Observed Release – Background, of this support document. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

The HRS defines a site as “[a]ny area where a hazardous substance has been deposited, stored, disposed, or 

placed, plus those soils that have become contaminated from migration of a hazardous substance.” 

The HRS directs the scorer to identify sources at each site. HRS Section 2.2.1, Identify sources, states: 

For the three migration pathways, identify the sources at the site that contain hazardous 

substances. Identify the migration pathway(s) to which each source applies. For the soil exposure 

pathway, identify areas of observed contamination at the site (see section 5.0.1). 

HRS Section 2.2.2, Identify hazardous substances associated with a source, states: 

For each of the three migration pathways, consider those hazardous substances documented in a 

source (for example, by sampling, labels, manifests, oral or written statements) to be associated 

with that source when evaluating each pathway. 

The HRS documentation record at proposal documents that the soil on the eastern portion of the MNOP property 

(specifically around Building 109) is contaminated with mercury. The HRS documentation record at proposal 

states on page 15: 

Source No. 1 consists of contaminated soil on the eastern portion of the MNOP property (Refs. 9, 

p. 3; 11, p. 8) (see Figure 3 of this HRS documentation record). MNOP operated as an ordnance 

manufacturing facility from before World War II until 1973 (Ref. 12, p. 1-1, 1-7). Ordnance 

manufactured at MNOP included flares, small primers, detonators, and other triggering 

mechanisms (Ref. 13, p. 2). 

According to a technical manual prepared by the Department of the Army, military explosives, 

such as those that were manufactured at the MNOP, contained mercury compounds as initiating 

agents, including mercury fulminate (Ref. 23, pp. 7-5, 7-8). Explosive compounds were either 

handled or stored in many areas throughout the MNOP property, including numerous small dryer 

buildings, ordnance magazines, and blending and weighing houses. Specifically, Building 109, 

located in the eastern portion of the MNOP near Source No. 1, was a primary explosives 

production site (Ref. 13, pp. 11, 12, 54) (see Figures 2 and 3 of this HRS documentation record). 

Soil samples collected from this area during the U.S. Army Corps of Engineers (USACE) 1996 

site investigation and the EPA June 2011 supplemental sampling event contained mercury (Refs. 

9, p. 1; 11, p. 8; 13, pp. 58, 83, 84). 

The HRS documentation record at proposal presents the analytical results for Source 1 and the background 

sample on page 17: 

 

TABLE 3: Analytical Results for Background and Source No. 1 Samples – June 2011

Sample 

Designation Sample ID HazardousSubstance

Hazardous

Substance 

Concentration

MRL References

Background MNOP-01-SF Mercury 0.073J (0.13) 

mg/kg 

0.050 mg/kg 11, pp. 4, 5; 31 

Source No. 1 MNOP-04-SF Mercury 0.40 mg/kg 0.050 mg/kg 11, p. 8 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

As presented above, the HRS documentation record at proposal establishes Source 1 as an area of soil that has 

come to be contaminated by mercury, a hazardous substance. Analytical data presented show that contaminated 

soil is present at the facility surrounding Building 109 above naturally occurring levels. Additionally, historical 

operations in Building 109 have been documented in the HRS documentation record at proposal to include 

explosives production, which is known to have used mercury compounds as initiating agents. The contaminated 

soil, as shown in the above table, has been documented to contain mercury at concentrations that are above 

background levels (mercury levels that would be naturally present, or ubiquitous) in the area surrounding 

Building 109 (see section 3.9.1, Representativeness of the Background Sample, of this support document). Thus, 

the contaminated soil surrounding Building 109 (Source 1) is present as a result of hazardous substance migration 

from the historical operations in Building 109 and Source 1 was properly established in the HRS documentation 

record at proposal. 

The HRS documentation record at proposal demonstrates that mercury concentrations in Source 1 are elevated 

over natural conditions by taking background samples at locations near Source 1 (see Figure 1) and comparing the 

source samples to these background samples. Source 1 mercury concentrations were documented to be greater 

than the highest recorded background samples; thus, the HRS documentation record at proposal correctly 

established Source 1 as contaminated soil near Building 109. 

Specific comments related to the Site source are addressed in the following subsections: 

• 3.9.1 Representativeness of the Background Sample 

• 3.9.2 Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source Sample 

• 3.9.3 Documenting Mercury Contamination in the Source Sample 

 

3.9.1 Representativeness of the Background Sample 

Comment: Unimax and Cozen commented that the background sample used for Source 1 is insufficient to show 

that contamination is non-ubiquitous in the area and due to former MNOP facility operations. Unimax asserted 

that without a sufficient number of background samples, a source cannot be determined at the Site. Unimax 

commented that GP has deposited low levels of contamination throughout the property and asserted GP’s air 

emissions may be the cause of the contamination at Source 1 and not the former MNOP facility operations. 

Response: The HRS documentation record at proposal correctly presented background concentrations to show 

that contamination is non-ubiquitous in the local environment and established Source 1 as contaminated soil near 

Building 109. The background sample used in the HRS documentation record at proposal to establish Source 1 as 

containing mercury concentrations above natural levels (MNOP-01-SF) contained a detected mercury 

concentration of 0.073 mg/Kg. Source 1 was determined to have 0.40 mg/Kg mercury which is above the 

background sample and was correctly established in the HRS documentation record at proposal. 

The HRS does not require background samples be taken to establish the presence of source contamination, rather, 

the HRS requires that the scorer identify sources at each site as stated in Section 2.2.1, Identify sources: 

For the three migration pathways, identify the sources at the site that contain hazardous 

substances. Identify the migration pathway(s) to which each source applies. For the soil exposure 

pathway, identify areas of observed contamination at the site (see section 5.0.1). 

The HRS defines a source to be “[a]ny area where a hazardous substance has been deposited, stored, disposed, or 

placed, plus those soils that have become contaminated from migration of a hazardous substance.” 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

The HRS documentation record at proposal includes source background samples to establish that mercury 

contamination in Source 1 is elevated over naturally occurring mercury levels in the local environment. Pages 16 

and 17 of the HRS documentation record at proposal state: 

The background and source soil samples listed in Table 2 were collected during the EPA June 

2011 supplemental sampling event (Refs. 9, pp. 1, 3, 7, 9; 11, p. 3). The background soil sample 

was collected from the north-central portion of the MNOP property where no site-related 

activities have been known to occur (Refs. 8; 9, pp. 1, 3; 17, pp. 11, 17, 21, 25, 29, 33, 37, 41, 

45). The source soil sample was collected from the eastern portion of the MNOP property where 

mercury has been previously detected, near where facility operations were known to have 

occurred and where explosives were handled and stored (Refs. 7, Appendix A, p. A-4; 9, p. 3; 13, 

pp. 11, 12, 54). The background and source surface soil samples were collected at a depth of 0 to 

6 inches bgs (Refs. 9, p. 1; 10, Appendix B, p. B-1). 

Background and Source No. 1 surface soil samples were collected during the same sampling 

event, from the same type of soil (sandy loam), and in accordance with the same sampling 

procedures (Refs. 9, pp. 1, 6, 9; 10, p. 4; 30, pp. 1, 3). Surface soil samples were collected in 

accordance with the EPA Region 4 SESD Field Branch Quality System and Technical Procedures 

for Soil Sampling, SESDPROC-300-R1 (Refs. 9, p. 6; 10, p. 4; 24). 

... 

Background and Source No. 1 samples listed in Table 3 were analyzed for mercury in accordance 

with EPA Method 245.5 and the EPA Region 4 Analytical Support Branch (ASB) Laboratory 

Operations and Quality Assurance Manual (LOQAM), January 2011 (Refs. 9, p. 1; 11, p. 1; 27). 

EPA Region 4 SESD reviewed all data according to the contract statement of work (SOW) and 

EPA guidelines (Refs. 28; 11, p. 1). The minimum reporting limits (MRL) are listed on the 

analytical data sheets in Reference 11. Each MRL is sample-specific and corresponds to the 

lowest quantitative point on the calibration curve; it is adjusted for the amount of sample prepared 

and any dilutions performed, as well as for percent moisture. The MRLs are equivalent to sample 

quantitation limits (SQL) (Ref. 29). 

While the HRS does not require background samples to establish the presence of hazardous substances in sources, 

a background sample was used at this Site to establish elevated mercury concentrations in the source sample over 

naturally occurring levels of mercury in the local environment. Unimax correctly stated that an observed release 

determined by chemical analysis is established when the contaminant concentration in the observed release 

sample is three times or more above the background concentration; however, this criteria does not apply to 

identifying sources. As established in the HRS documentation record at proposal, the background sample shows 

that mercury is not ubiquitous in the local soil and that Source 1 contains mercury at elevated levels compared to 

background concentrations. 

The background sample identified in the HRS documentation record at proposal contained a mercury 

concentration of 0.073 J (0.13) mg/Kg. The most accurate estimate of the true value of mercury in the background 

sample (MNOP-01-SF) is 0.073 mg/Kg mercury; however, in order to adjust for possible bias in the sample, or 

sample analysis, the sample concentration was adjusted. As a result, the HRS documentation record at proposal 

considers the background sample MNOP-01-SF to contain 0.13 mg/Kg mercury to account for possible bias (see 

section 3.9.2, Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source Sample, of 

this support document for using qualified data). Thus, the contaminated soil surrounding Building 109 has been 

established as containing contaminated soil related to Site activities. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Even if the adjusted background sample concentration of mercury were 0.1336 mg/Kg as Unimax suggested, 

instead of 0.13 mg/Kg as in the HRS documentation record at proposal, this would have no effect on the 

identification of Source 1. The mercury concentration of 0.40 mg/Kg found in Source 1 is elevated above those 

values found to be present in the soil surrounding Source 1. While an argument could be made that natural levels 

of mercury in the local soil could be as high as 0.1336 mg/Kg, the natural levels of mercury were not found to be 

ubiquitous at the mercury concentrations found in Source 1. Further, the commenter has not shown that the 

natural levels of mercury in the soil surrounding the Site contain concentrations of mercury above this established 

background level. Therefore, the background sample was correctly identified in the HRS documentation record at 

proposal and Source 1 was correctly established. 

Regarding aerial deposition from the nearby GP facility, the HRS documentation record at proposal documents 

elevated concentrations of mercury surrounding Building 109 on the MNOP property relative to background 

samples that were taken in nearby soils. While GP may have released mercury through air emissions that have 

settled throughout the MNOP property, the contaminated soil scored as Source 1 has been compared to 

background samples to determine that the contaminated soil is due to local deposits of mercury surrounding 

Building 109 on the MNOP property. Furthermore, if the mercury contamination is found to be more extensive 

than the existing preliminary sampling has indicated, then this will be considered in later stages of the Superfund 

process. 

Finally, the commenters’ assertion that the HRS documentation record at proposal includes an insufficient number 

of background samples to establish Source 1 is incorrect. While only one background sample is listed in the HRS 

documentation record at proposal, other soil samples were taken from nearby locations and also show that 

mercury is not a ubiquitous hazardous substance in the local environment near Source 1. Four other soil samples 

were collected as part of the 2011 Supplemental Sampling Event (see Reference 9 of the HRS documentation 

record at proposal) near Source 1 and none of the samples contained mercury at a concentration higher than the 

sample reported as the background sample (MNOP-01-SF). 

Therefore, the background sample used in the HRS documentation record at proposal is representative of the Site 

conditions and natural levels of mercury in the soil and was properly used to show that Source 1 contains elevated 

concentrations of mercury over natural levels. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.9.2 Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source 

Sample 

Comment: Unimax and Cozen challenged the association of mercury with Source 1. Unimax and Cozen asserted 

that the concentration of mercury in the source sample was not three times the concentration in the source 

background sample. The commenters argued that the mercury concentration in the source sample was not three 

times the concentration in the background sample after the background concentration is adjusted upward to 

account for issues in the analysis of the sample. 

Unimax and Cozen commented that the single source soil background sample is suspect because it is merely an 

estimate, denoted by the “J” value. Cozen stated that “there is significant doubt as to the utility of this soil 

sample” particularly when the difference between the source soil sample and background sample is 0.01 mg/Kg. 

Unimax stated “[w]hen analytical results are flagged by "J" ("estimated") qualifiers, the attendant uncertainty 

creates a problem in determining whether a release may have occurred.” Unimax further commented that “[t]he 

calculation of the background value is incorrect due to an arithmetic error” and when computed correctly, Unimax 

asserted that the soil sample contamination does not exceed three times background level. Unimax commented 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

that although the correct analyte and medium-specific factor for mercury in soil was used (1.83), “sufficient 

numerical precision” was not used. 

Response: The use of qualified data and the possible bias associated with this analytical sampling data was 

accounted for in the association of mercury with Source 1. The mercury concentration in the source sample is 

sufficiently higher than in the background sample to document that the soil in Source 1 is contaminated with 

mercury. Thus, mercury is correctly associated with the source. The HRS does not require that the increase 

between the background and source sample contamination be three times the background level (i.e., observed 

release criteria) to demonstrate that a source is contaminated with a hazardous substance. The HRS only requires 

the contaminant be present at the source. 

HRS Section 2.2.2, Identify hazardous substances associated with a source, states how to associate hazardous 

substances with a source: 

For each of the three migration pathways, consider those hazardous substances documented in a 

source (for example, by sampling, labels, manifests, oral or written statements) to be associated 

with that source when evaluating each pathway. 

The HRS documentation record at proposal presents the analytical results for Source 1 and the background 

sample on page 17: 

 

TABLE 3: Analytical Results for Background and Source No. 1 Samples – June 2011

Sample 

Designation Sample ID Hazardous Substance

Hazardous 

Substance 

Concentration

MRL References

Background MNOP-01-SF Mercury 0.073J (0.13) 

mg/kg 

0.050 mg/kg 11, pp. 4, 5; 31 

Source No. 1 MNOP-04-SF Mercury 0.40 mg/kg 0.050 mg/kg 11, p. 8 

As shown in Table 3, the mercury level in the background sample (MNOP-01-SF) was reported as 0.073 mg/kg 

and assigned a data quality qualifier of a J (in this case, a J qualifier means that the identification of the analyte is 

acceptable, but the reported value is an estimate due to laboratory issues). The addition of a qualifier to the data 

does not mean the reported data value is incorrect, rather, the addition of a qualifier to the data only cautions the 

user that the reported value might be slightly inexact due to possible bias. However, the reported (qualified) value 

is the best estimate of the true value of mercury in the surrounding soils and the adjusted value (0.13 mg/kg) is an 

estimate of the highest concentration that could have been present in the sample if the sample were biased low2

. 

The HRS documentation record at proposal uses the adjusted value of 0.13 mg/Kg mercury to establish the 

natural levels of mercury concentrations and thus provides a reasoned estimate of mercury background 

concentrations in the soil surrounding Source 1 (see section 3.6, Data Quality Issues, of this support document, 

regarding the use of qualified data in the HRS evaluation). 

 

The commenters incorrectly calculated and asserted that the difference between the background sample and 

source sample is 0.01 mg/Kg. To reach this number, the commenters adjusted the background sample 

 

2

 Biased low means that the true concentration of the hazardous substance in the sample, if no quality control issues were 

identified, might be greater than the measured laboratory value. Thus, the adjusted value represents the maximum 

concentration of that substance that could be present in the sample. However, the adjusted value does not necessarily 

represent a more accurate value or the true value. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

concentration (0.13 mg/kg), multiplying it by 3 for a total of 0.39 mg/kg, then compared the adjusted background 

sample concentration (0.39 mg/kg) to the Source 1 sample concentration (0.40 mg/kg) to calculate the difference 

of 0.01 mg/kg. Multiplying the background sample concentration by 3 is incorrect when determining the natural 

levels of a contaminant in the local environment for the purpose of establishing a source during an HRS 

evaluation (see sections 3.9, Source 1; and 3.9.3, Documenting Mercury Contamination in the Source Sample, of 

this support document). The HRS does not require source samples to be 3 times the background concentration to 

establish natural levels of a contaminant in the local environment. The HRS only requires that a source be an area 

where hazardous substances have been “deposited, stored, disposed, or placed...” and that the site source contain 

a hazardous substance(s) available to a pathway (at this site, the surface water pathway). The HRS documentation 

record at proposal uses the background concentration value (0.13 mg/Kg) to determine the natural levels of 

mercury in the local environment; therefore, Source 1 was properly established as containing mercury 

contamination above background levels and contains contamination due to Site-related activities. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.9.3 Documenting Mercury Contamination in the Source Sample 

Comment: The DoD, Unimax, and Cozen commented that the number of source samples and background source 

samples raises uncertainty about the identification of Source 1. Unimax stated that “[t]he proposed listing is based 

on comparing one background surface soil sample to a single soil sample obtained at the Site in 2011.” Unimax 

further stated that comparing one background soil sample to only one other soil sample is “an insufficient quantity 

of samples to establish a background concentration and therefore the data does not indicate a release.” Unimax 

asserted that without a sufficient number of background samples, a source cannot be determined at the Site. 

Response: The HRS documentation record at proposal correctly establishes Source 1 contaminated soil as 

containing a hazardous substance at concentrations above background levels. Background samples are used to 

show that soil contamination in a source is above natural levels in the local environment. The HRS does not 

require that multiple samples be taken to identify a source or to determine background concentrations, and Source 

1 was correctly established in the HRS documentation record at proposal as containing contaminated soil above 

background concentrations. 

As quoted in section 3.9, Source 1, of this support document, the HRS directs the scorer to “identify the sources at 

the site that contain hazardous substances.” Source 1 was correctly identified and established in the HRS 

documentation record at proposal as being contaminated soil near Building 109. 

While the HRS does not require background samples (or multiple background samples) for source soil samples, 

and the HRS documentation record at proposal only lists one background sample under Source 1, other soil 

samples were taken from nearby locations (see Reference 9, June 2011 Supplemental Sampling Event, of the HRS 

documentation record at proposal). These other samples show that mercury is not a ubiquitous hazardous 

substance near Source 1 (see Figure 1 of this support document, and page 3 of Reference 9 of the HRS 

documentation record at proposal). None of the four other soil samples that were collected as part of the 2011 

Supplemental Sampling Event contained mercury at a concentration higher than the background sample (MNOP01-SF) used in establishing Source 1. 

Therefore, the background sample used in the HRS documentation record at proposal in establishing Source 1 is 

representative of the Site conditions, and was properly used to show that Source 1 contains elevated 

concentrations of mercury over the natural levels present in the surrounding soil. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

3.10 Observed Release – Background 

Comment: Unimax and Cozen commented that the background sample used to establish an observed release was 

determined incorrectly, contained an insufficient number of background samples, and was not of the same media 

as the observed release sample. 

Response: A single valid background sample for mercury in surface water is sufficient to identify that a 

significant increase in the mercury concentration in the release sample (used to establish an observed release to 

surface water) has been documented. While the background level assigned is based on a single sample, this level 

is supported by other samples taken in the vicinity of the site. The background sample (MNOP-W-01-SD; see 

Figure 2) is located west and upgradient of Drainage Ditch #4 in the same watershed and same wetland as the 

observed release sample and from the same medium, without the potential influence from the MNOP facility (see 

Figure 2 of this support document and Figure 3 of the HRS documentation record at proposal). 

The HRS addresses background in the context of identifying an observed release of a hazardous substance to the 

environment by chemical analysis. HRS Section 4.1.2.1.1, Observed release, states in relevant part: 

Establish an observed release to surface water for a watershed by demonstrating that the site has 

released a hazardous substance to the surface water in the watershed. Base this demonstration on 

either: 

• Direct observation: . . . 

• Chemical analysis: 

- Analysis of surface water, benthic, or sediment samples indicates that the 

concentration of hazardous substance(s) has increased significantly above the 

background concentration for the site for that type of sample (see section 2.3) 

- Limit comparisons to similar types of samples and background 

concentrations—for example, compare surface water samples to surface 

water background concentrations. 

- ... 

• Some portion of the significant increase must be attributable to the site to establish the 

observed release, except: when the site itself consists of contaminated sediments with no 

identified source, no separate attribution is required. 

If an observed release can be established for a watershed, assign an observed release factor value 

of 550 to that watershed, enter this value in Table 4-1, and proceed to section 4.1.2.1.3... 

In establishing whether a hazardous substance is significantly above background concentrations, HRS Section 

4.1.2.1.1 refers the scorer to HRS Section 2.3 for requirements for establishing significant increases in hazardous 

substance concentrations. HRS Section 2.3, Likelihood of release, specifies that the scorer is to “[u]se the criteria 

in Table 2-3 as the standard for determining analytical significance.” HRS Table 2-3 states: 

An observed release is established as follows: 

• If the background concentration is not detected (or is less than the detection limit), an 

observed release is established when the sample measurement equals or exceeds the 

sample quantitation limit. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

• If the background concentration equals or exceeds the detection limit, an observed release 

is established when the sample measurement is 3 times or more above the background 

concentration. 

Based on HRS Table 2-3, the purpose of the background sample is to establish a background level (the 

concentration of a hazardous substance) for the Site that provides a reference point to evaluate whether a release 

has occurred. 

HRS Section 4.1.2.1.1, Observed Release, in part states that samples should be compared to similar types of 

samples: 

... 

• Chemical analysis: 

... 

–Limit comparisons to similar types of samples and background concentrations—for 

example, compare surface water samples to surface water background concentrations... 

Thus, a background sample should be located in the same media as the release samples being evaluated and 

outside of any potential impacts from facility operations. Background samples are used to demonstrate an increase 

in hazardous contamination due to facility operations and provide a reference point for contamination that may be 

naturally present in the local environment 

The HRS documentation record at proposal on page 22 explains the rationale for the establishment of a 

background level at the MNOP site: 

During the EPA June 2011 supplemental sampling event, one background sediment sample, 

MNOP-W-01-SD, was collected from HRS-eligible palustrine forested wetlands west of and 

upgradient from Drainage Ditch 4. Contaminated sediment sample MNOP-D4-W-09-SD was 

collected from Drainage Ditch 4 within HRS-eligible palustrine forested wetlands downstream of 

the PPE. Background and contaminated sediment samples were collected from HRS-eligible 

palustrine forested wetlands at depths ranging from 0 to 3 inches bgs (Refs. 9, pp. 1, 3, 8, 9; 36, 

Map 1). 

The sediment samples were collected in accordance with the EPA Region 4 SESD Field Branches 

Quality System and Technical Procedures for Sediment Sampling, SESDPROC-200-R2 (Refs. 9, 

pp. 1, 6; 10, p. 4; 25)... 

The background and contaminated sediment samples were collected during the same sampling 

event, in accordance with the same sampling procedures, and from the same type of HRS-eligible 

wetland (palustrine forested).(Refs. 9, pp. 1, 3, 6;36) (see Figure 3 of this HRS documentation 

record). 

Table 7 from page 23 of the HRS documentation record at proposal, provides the background and observed 

release samples as follows: 

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TABLE 7: Analytical Results for Background and Contaminated Sediment Samples – June 2011

Sample

Description Sample ID

Hazardous

Substance Concentration MRL References

Background MNOP-W-01-SD Mercury 0.16J (0.29) 

mg/kg 

0.050 mg/kg 11, pp. 4, 22; 31; 32, 

pp. 8, 18 

Release MNOP-D4-W-09-SD Mercury 1.1 mg/kg 0.050 mg/kg 11, p. 21 

The commenters’ specific issues with this background level determination are addressed in the following 

subsections: 

• 3.10.1 Adequacy of Background Sample – Observed Release 

• 3.10.2 Sample Similarity 

• 3.10.3 Number of Samples used to Identify an Observed Release 

3.10.1 Adequacy of Background Sample - Observed Release 

Comment: Cozen and Unimax commented that the single observed release background sample, which is intended 

to provide a defensible reference to evaluate whether a release from the site has occurred, is insufficient to 

determine attribution of mercury in Drainage Ditch #4 to the former MNOP. Cozen and Unimax added that 

observed release samples must be significantly greater than the background concentration. Unimax asserted that 

the determination of the observed release sample (MNOP-D4-W-09-SD) to be significantly greater than 

background contamination levels is incorrect. 

Unimax commented that the sediment samples found in the upper portions of Drainage Ditch #4 contain lower 

concentrations of mercury than in the background sample, and that in 2009 TetraTech considered the upper 

portion of Drainage Ditch #4 to be background. Unimax stated that for the sample to be considered a release, the 

concentration must exceed three times the background; which “strongly suggests the background determination 

[in the HRS evaluation] is arbitrary and contradicted by the additional data contained in the HRS references.” 

Response: The background level established in the HRS documentation record at proposal, based on the single 

observed release background sample, is sufficient for identification of a significant increase in mercury 

concentrations consistent with the HRS. The background sample was taken from the same palustrine forested 

wetland and upgradient of any release from Source 1. However, this background sample was not the only sample 

used to establish the background level. 

Other samples considered in establishing the background level include those samples taken from Drainage Ditch 

#4 upgradient of the observed release sample in Drainage Ditch #4. These samples in the upper portions of 

Drainage Ditch #4 showed mercury concentrations ranging from non-detect (0.050 mg/kg in samples MNOP-D4-

01-SD, MNOP-D4-02-SD-DUP, MNOP-D4-03-SD, MNOP-D4-05-SD, and MNOP-D4-06-SD) to 0.083 mg/kg 

in sample MNOP-D4-04-SD. 

These samples show that the background mercury level in the vicinity of the Site is no more than the background 

concentration of the designated mercury background sample. These samples are located upgradient of the release 

sample location but were not considered for background samples as they are part of the contaminant migration 

pathway from Building 109 at the MNOP site. However, as discussed in section 3.11.2, Contaminant 

Concentration Gradient in Drainage Ditch #4, of this support document, these samples contain different 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

streambed morphologies and thus may not have elevated mercury concentrations due to this difference, but the 

absence of mercury contamination in these upgradient samples indicates that mercury is not ubiquitous. 

In addition to the 2011 Supplemental Sampling Event samples, Reference 7 of the HRS documentation record at 

proposal includes analytical data from an Expanded Site Inspection that includes samples taken from Rocky 

Creek upgradient of the confluence with Drainage Ditch #1 (and upgradient of Drainage Ditch #4). Samples RC400-SD, RC-401-SD, RC-402-SD and RC-403-SD (sample locations are shown in Figure 4 on page A-4 of 

Reference 7 of the HRS documentation record at proposal) of the Expanded Site Inspection all contain mercury 

levels that are below the detection limit and less than the concentration identified in background sample MNOPW-01-SD (see page B-110 of Reference 7 of the HRS documentation record at proposal). 

However, background sample MNOP-W-01-SD was collected from the same HRS-eligible wetland west of the 

observed release sample (MNOP-D4-W-09-SD) which had similar background conditions as the release sample 

location and was collected during the same sampling event; therefore this sample is sufficient for identifying a 

significant increase in mercury concentrations in Drainage Ditch #4.

Insomuch as this comment addresses the attribution of mercury at the Site, section 3.11, Observed Release – 

Attribution, of this support document further addresses the attribution component of establishing a release by 

chemical analysis to the Site. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.10.2 Sample Similarity 

Comment: Cozen commented that the EPA failed to explain why a sample obtained from palustrine forested 

wetlands, west of Drainage Ditch #4, was used for the background concentration to establish an observed release 

by chemical analysis. Cozen asserted that the background sample was “apparently not [collected] from sediments 

in a stream and/or drainage ditch” and is not in the same media as the observed release sample (i.e., sediment to 

sediment). Cozen and Unimax commented that samples used for comparison purposes must be from the same 

media. 

Response: The background level was correctly established consistent with the HRS. The background sample was 

collected in a similar environment and in the same media as the release sample. The background sample was 

taken upgradient of the release samples in Drainage Ditch #4, in the same palustrine wetland, using the same 

sampling procedures, and at the same time the release samples were collected (see Figure 3 of the HRS 

documentation record at proposal). For HRS purposes, the sample similarity of background sample (MNOP-W01-SD), collected in palustrine forested wetlands and considered a surface water sample, is correctly compared to 

the surface water observed release sample (MNOP-D4-W-09-SD), collected from Drainage Ditch #4, as they are 

both surface water samples. 

As defined by HRS Section 4.0.2, Surface water categories, surface water is defined in part as follows: 

For HRS purposes, classify surface water into four categories: rivers, lakes, oceans, and coastal 

tidal waters. 

 -Rivers include: 

• Perennially flowing waters from point of origin to the ocean or to coastal tidal 

waters, whichever comes first, and wetlands contiguous to these flowing waters. 

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HRS Section 4.1.2.1.1, Observed Release, in part states that samples should be compared to similar types of 

samples: 

... 

• Chemical analysis: 

... 

–Limit comparisons to similar types of samples and background concentrations—for 

example, compare surface water samples to surface water background concentrations... 

Thus, the purpose of a background sample is to establish a background level in the medium of concern for the site 

to determine whether or not a release from the site has occurred. Background samples should be taken from the 

same media (surface water, sediment, soil, etc.) and should be sufficiently similar to release samples to ensure the 

increase in contamination between the background level and the release sample is due to a release and not due to 

differences in the samples or the analysis. 

Page 22 of the HRS documentation record at proposal identifies that the background and release samples were 

collected from the same surface water body: 

The background and contaminated sediment samples were collected during the same sampling 

event, in accordance with the same sampling procedures, and from the same type of HRS-eligible 

wetland (palustrine forested) (Refs. 9, pp. 1, 3, 6; 36). 

Hence, both background and observed release sediment samples were collected from the same HRS-eligible3

palustrine forested wetlands, within the same watershed and are thus considered taken from the same media. 

Additionally, as stated in the HRS documentation record at proposal, the background sample was taken during the 

same sampling event, under the same physical conditions (i.e., weather, season, etc.), and used the same sampling, 

handling, and analytical procedures as the release samples. Therefore, the similarities of the background and 

release samples at this Site are considered sufficiently similar to ensure the significant increase is not simply due 

to difference in the sample media or to differences in sampling and analysis procedures, and the significant 

increase criteria for establishing an observed release have been met. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.10.3 Number of Background Samples Used to Identify an Observed Release 

Comment: Cozen and Unimax commented that only one background sediment sample used to establish an 

observed release is insufficient and not defensible to establish background conditions, account for background 

variability, and attribute contamination to the former Macon Naval Ordnance Plant. 

Response: The background level is sufficiently supported to establish a significant increase in the mercury level in 

the release sample consistent with the HRS. In establishing an observed release, a background concentration is 

used to show that contamination in the release sample is significantly above those levels that occur naturally in 

the local environment or significantly above those levels that are present due to other nearby facilities. The HRS 

does not require that multiple samples be taken to identify an observed release or to determine background 

 

3

 Wetlands are considered HRS-eligible if they meet the criteria defined in 40 CFR Section 230.3. Generally this definition 

includes areas that are inundated by surface or ground water at a frequency and duration sufficient to support a prevalence of 

vegetation typically adapted for life in saturated soil conditions. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

concentrations, rather, the background level is used to show that observed release contamination is significantly 

above background levels. 

HRS Section 4.1.2.1.1, Observed release, states in relevant part: 

Establish an observed release to surface water for a watershed by demonstrating that the site has 

released a hazardous substance to the surface water in the watershed. 

The HRS does not require multiple background samples to establish an observed release by chemical analysis. 

However, as noted in section 3.10.1, Adequacy of Background Sample - Observed Release, of this support 

document, Reference 7 of the HRS documentation record at proposal contains additional samples from Rocky 

Creek upgradient of the release sample that contain mercury concentrations below the background level 

established by sample MNOP-W-01-SD in the HRS documentation record at proposal (see Figure 4 and page B110 of Reference 7 of the HRS documentation record at proposal). Nevertheless, the observed release was 

established based on a significant increase in the concentration of mercury in sample MNOP-D4-W-09-SD (1.1 

mg/kg) as compared to background sample MNOP-W-01-SD (0.29 mg/kg). Mercury is not naturally occurring at 

the levels found in the release sample and therefore the background sample is sufficient and consistent with the 

HRS. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.11 Observed Release - Attribution 

Comment: Unimax commented that the attribution of mercury contamination to the former MNOP site was not 

properly established and that the EPA had not considered that the mercury could have come from alternative sites. 

Unimax commented that although low levels of mercury are present on the MNOP property, the property is not 

the source of any downstream contamination. Unimax asserted that the additional data contained in the HRS 

documentation package contradicts the determination of attribution to the MNOP site due to faulty analysis and 

the failure to consider alternative sources. 

Response: The significant increase of mercury contamination in Drainage Ditch #4 was correctly attributed to the 

MNOP site consistent with the HRS. 

HRS Section 2.3, Likelihood of release, presents the basic requirements for establishing an observed release 

including attribution to the site in relevant part: 

Establish an observed release either by direct observation of the release of a hazardous substance 

into the media being evaluated (for example, surface water) or by chemical analysis of samples 

appropriate to the pathway being evaluated (see sections 3, 4, and 6). The minimum standard to 

establish an observed release by chemical analysis is analytical evidence of a hazardous substance 

in the media significantly above the background level. Further, some portion of the release 

must be attributable to the site. [emphasis added] 

HRS Section 4.1.2.1.1, Observed release, contains specific instructions on establishing observed releases to 

surface water, and states in relevant part: 

Establish an observed release to surface water for a watershed by demonstrating that the site has 

released a hazardous substance to the surface water in the watershed. Base this demonstration on 

either: 

• Direct observation: . . . 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

• Chemical analysis: 

- Analysis of surface water, benthic, or sediment samples indicates that the 

concentration of hazardous substance(s) has increased significantly above the 

background concentration for the site for that type of sample (see section 2.3) 

- Limit comparisons to similar types of samples and background 

concentrations—for example, compare surface water samples to surface 

water background concentrations. 

- ... 

- Some portion of the significant increase must be attributable to the site to 

establish the observed release, except: when the site itself consists of 

contaminated sediments with no identified source, no separate attribution is 

required. [emphasis added] 

Thus, there are two parts to establishing an observed release by chemical analysis for the ground water migration 

pathway: first, establishing a significant increase in contaminant concentrations, and second, attributing at least 

part of the increase to the site. 

Attribution of a release to a site is also established in two steps. First it is documented that the released 

substance(s) is associated with sources at the site and that containment for the HRS component or pathway is not 

such that the release could not occur. Second, it is shown that not all of the significant increase in the released 

hazardous substances could have come from other sites (i.e., that part of the increase came from the site). 

As discussed in section 3.10, Observed Release – Background, of this support document, the background 

hazardous substance (mercury) level was correctly established in the HRS documentation record at proposal. The 

background level allows for a significant increase of a hazardous substance in a release sample to be identified. A 

significant increase in the concentration of mercury was established in sample MNOP-D4-W-09-SD as detailed in 

section 4.1.2.1.1, Observed Release, of the HRS documentation record at proposal (see Figure 1) and the 

commenters did not challenge that the mercury contamination in this established background sample can also 

support the attribution of the release to the Site. 

Pages 25 and 26 of the HRS documentation record at proposal establish that some portion of the observed release 

is attributable to the Site, stating: 

The MNOP was constructed before World War II and was operated as an ordnance 

manufacturing facility until 1973 (Refs. 12, p. 1-1; 13, p. 2)... 

Explosive compounds were either handled or stored in many areas throughout the MNOP 

property, including numerous small dryer buildings, ordnance magazines, and blending and 

mixing houses (Ref. 13, pp. 11, 12, 54). According to a technical manual prepared by the 

Department of the Army, military explosives, such as those that were manufactured at the 

MNOP, contained mercury compounds as initiating agents, including mercury fulminate (Ref. 23, 

pp. 7-1, 7-5, 7-8). Building 109, located in the eastern portion of the MNOP near Source No. 1, 

was a primary explosives production site (Ref. 13, pp. 11, 12, 54) (see Figures 2 and 3 of this 

HRS documentation record). Soil samples collected from this area during the USACE 1996 site 

investigation and EPA June 2011 supplemental sampling event contained mercury (Refs. 9, p. 3; 

13, pp. 58, 83, 84). 

... 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

The HRS documentation record at proposal continues by discussing association of mercury contamination 

with the Site source: 

The source sample collected from Source No. 1 (contaminated soil on the eastern portion of 

MNOP) during the EPA June 2011 supplemental sampling event contained mercury (Refs. 9, p. 

3; 11, p. 8) (see Table 3 in Section 2.2.2 for Source No. 1 of this HRS documentation record). 

Sediment samples collected from Drainage Ditch 4, which receives runoff from Source No. 1, 

also contained mercury. The presence of mercury in Drainage Ditch 4 documents the migration of 

releases from Source No. 1 at the MNOP (Refs. 9, p. 3; 11, pp. 13, 16, 19, 20, 21) (also see 

Tables 6 and 7 in Section 4.1.2.1.1, Observed Release, of this HRS documentation record). 

Furthermore, an observed release of mercury has been documented in HRS-eligible wetlands 

along Drainage Ditch 4 (Refs. 9, p. 3; 11, p. 21; 36). 

Mercury has been documented in Source No. 1, in Drainage Ditch 4 and in palustrine forested 

wetlands indicating migration of hazardous substances from the MNOP property (see Table 3 in 

Section 2.2.2 for Source No. 1, and Table 7 in Section 4.1.2.1.1, Observed Release, of this HRS 

documentation record). 

The following subsections address specific comments regarding the attribution of the significant increase in 

mercury to the MNOP site: 

 

• 3.11.1 Possible Mercury Releases from Alternative Sites 

• 3.11.2 Contaminant Concentration Gradient in Drainage Ditch #4 

• 3.11.3 Contaminant Concentration Downgradient of the RCWRF 

• 3.11.4 Other Data Sets 

3.11.1 Possible Mercury Releases from Alternative Sites 

Comment: Unimax and Cozen commented that the mercury contamination found in the observed release sample 

cannot be attributed to the former MNOP and the EPA has failed to consider other sites which may be causing the 

mercury contamination. 

Unimax commented that the following possible contributors of mercury to Drainage Ditch #4 were not 

investigated in establishing attribution of the mercury in the release samples to the MNOP site: 

• Rocky Creek Water Reclamation Facility (RCWRF) 

• Graphic Packaging International, Inc. (GP) 

• Southern Wood Piedmont Company 

• “Off-site source areas north of the site” 

Unimax commented that the mercury contamination in the release sample is due to operations at facilities other 

than the MNOP facility. Unimax asserted that while mercury contamination may be present in the area, it is not 

due to operations at the MNOP facility and the significant increase found in the release sample in Drainage Ditch 

#4 is due to releases from the RCWRF. Unimax stated that the “EPA’s failure to explain why the off-site mercury 

impacts to Ditch #4 are not derived from the RCWRF and the GP facilities is contrary to EPA’s HRS guidance.” 

Unimax concluded its comment by stating that since the former MNOP is not the source of contamination in 

Drainage Ditch #4, the HRS Site score should be 0. 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Response: The significant increase in mercury concentration found in the release sample (MNOP-D4-W-09-SD) 

in Drainage Ditch #4 is correctly attributed to the MNOP site and not to any alternative sites. Other alternative 

facilities that could impact the level of mercury contamination in the release sample were considered and 

described in the HRS documentation record at proposal and, at that time, were found not to be the source of the 

mercury in the observed release in Drainage Ditch #4. 

The HRS documentation record at proposal on pages 25-26 discusses other nearby facilities and their possible 

contributions to the mercury contamination, stating: 

Other facilities in the area include the MBCIA, which renamed the MNOP property the Allied 

Industrial Park and currently leases or sells buildings as office and warehouse space to various 

industrial and commercial businesses on the AIP property (Refs. 7, Appendix A, p. A-3; 13, pp. 

1, 2, 3; 14, p. 2-9; 15). Politex U S Inc. (Politex) is the only manufacturing business that is 

currently located at the AIP. Politex is a textile manufacturing firm that produces roofing 

membranes, clothing and furniture padding, and building materials (Ref. 15). Politex is located on 

the western portion of the MNOP property (Refs. 6, pp. 42 through 49; 7, Appendix A, p. A-3). 

Runoff and drainage originating from Politex does not enter Drainage Ditch 4 (Ref. 7, Appendix 

A, pp. A-2, A-3) (see Figure 3 of this HRS documentation record). The property where Source 

No. 1 soil sample MNOP-04-SF was collected is owned by the City of Macon and is operated as 

a recreational park that includes baseball fields (Refs. 6, pp. 7, 8; 7, Appendix A, pp. A-2, A-3; 9, 

p. 3). 

Possible off-site sources also include the FMNOL, AWI, and the Rocky Creek water reclamation 

facility (RC WRF). AWI and FMNOL are currently listed on the EPA NPL under CERCLIS ID 

No. GAN000410033 at docket number EPA-HQ-SFUND-2010-0640-0002 (Ref. 47). Runoff 

from FMNOL and AWI flows into Rocky Creek via a drainage easement. The drainage easement 

enters Rocky Creek west and upstream of Source No. 1 soil sample MNOP-04-SF and Drainage 

Ditch 4. Drainage Ditch 4 is located just west of the RC WRF (Ref. 7, Appendix A, p. A-2). 

 

The FMNOL was reportedly used for disposal of solid wastes and ordnance throughout the 

operational history (1941 to 1974) of the MNOP (Refs. 8; 17, pp. 42, 43, 46, 47; 18, p. 2). The 

landfill was also used for disposal of used parts and construction debris (Refs. 14, p. 2-11; 18, p. 

2). During the EPA May 2009 ESI, mercury was detected in soil samples collected from the 

FMNOL at concentrations ranging from 0.47 mg/kg (FML-303-SF) to 4.7 mg/kg (FML-304-SB) 

(Ref. 35, pp. 130, 132). 

Since 1948, AWI has operated an acoustic ceiling tile manufacturing plant on 130 acres of land 

west of the MNOP property (Ref. 19, p. 3). In 1980, AWI notified the Georgia Environmental 

Protection Division (GAEPD) that it was a generator of hazardous waste and AWI was classified 

as a conditionally exempt small quantity generator under the Resource Conservation and 

Recovery Act (RCRA). PCBs are the primary hazardous substance of concern for this facility, not 

metals (Ref. 19, pp. 5, 6). 

The RC WRF, located southeast of and downstream from MNOP, provides wastewater treatment 

for the southern and western portions of the City of Macon. Treated wastewater from this facility 

is discharged into the Ocmulgee River; however, RC WRF maintains a National Pollutant 

Discharge Elimination System (NPDES)-permitted discharge point at the southern property 

boundary (Refs. 9, p. 3; 45, pp. 2, 3; 46, pp. 1, 8). The NPDES permit requires RC WRF to 

monitor outfall discharges for biochemical oxygen demand, total suspended solids, pH, chlorine, 

fecal coliform, nitrogen, dissolved oxygen, PCBs, and phosphorus (Ref. 46, pp. 6, 7). There are 

currently no documented releases of mercury at this location (Refs. 9, p. 3; 46, pp. 6, 7). 

26 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

27 

All nearby facilities were considered in the evaluation of possible contributors of contamination at the Site; 

however, the evaluation has not documented any evidence of these other off-site facilities contributing to the 

significant increase of mercury in the observed release sample. The evaluation also does not negate EPA’s 

determination that some portion of the significant increase in mercury levels is attributable to the Site. The 

following subsections address the specific off-site facilities that Unimax asserted may be potentially contributing 

to the mercury contamination at the Site: 

• 3.11.1.1 Wastewater Discharges from GP and the Southern Wood Piedmont Company via the 

RCWRF 

• 3.11.1.2 GP Air Emissions 

• 3.11.1.3 Contribution of Sources West and North of Source 1 

3.11.1.1 Wastewater Discharges from GP and the Southern Wood Piedmont Company via the RCWRF 

Comment: Unimax commented that mercury discharges from GP and SWPC to the RCWRF had not been 

considered in attributing the mercury release to the MNOP site. Unimax commented that both GP and SWPC 

have been documented to historically send wastewater containing mercury to the RCWRF. Unimax commented 

that the RCWRF has treated wastewater containing mercury since its construction and that the RCWRF has 

historically been in non-compliance with its National Pollution Discharge Elimination System (NPDES) permit 

for discharge of organic waste. Further, Unimax commented that the HRS documentation record appears to 

conclude that since the RCWRF does not currently monitor for mercury it cannot be a current or historic source of 

the mercury contamination found in Drainage Ditch #4. Unimax asserted that RCWRF discharge into Drainage 

Ditch #4 is responsible for the increase in mercury in the observed release sample. 

Response: The possibility of mercury being discharged from the RCWRF due to the inputs of discharge from GP 

and SWPC to the RCWRF was considered as a possible contributor to the increase in mercury contamination in 

the observed release sample in Drainage Ditch #4. However, discharges from the RCWRF were found not to be 

contributing to the mercury contamination to Drainage Ditch #4. The historic effluent outfall from the RCWRF 

(from 1975 to 1991) was directly to the wetlands located to the south of the RCWRF facility as shown in Figure 3 

below, and in fact, RCWRF effluent has never been directly discharged to Drainage Ditch #4 (see Attachment 3, 

and Section 3.11.3, Contaminant Concentration Downgradient of the RCWRF, of this support document for 

additional information regarding the RCWRF effluent outfall). Furthermore, no evidence could be found to 

document that the RCWRF has ever released mercury into Drainage Ditch #4. In fact, the discharge from the 

RCWRF does not contain mercury (see Attachment 1 to this support document). Additionally, aside from general 

allegations, Unimax did not present any data to show that mercury contamination is associated with the effluent 

from the RCWRF, nor did it provide evidence that the RCWRF has historically discharged effluent to Drainage 

Ditch #4, that could contribute to the significant increase in the observed release sample. 

Contrary to Unimax’s assertions, the HRS documentation record at proposal does not conclude that the RCWRF 

is not contributing mercury contamination to Drainage Ditch #4 because the RCWRF discharge is not being 

monitored; rather, the HRS documentation record at proposal identifies the facility to be a potential off-site 

contributor. However, as discussed above and shown in Figure 3, the historical RCWRF discharge point is 

downgradient of the release sample location (MNOP-D4-W-09-SD, shown above in Figure 3 and in Figure 2 of 

this support document; also, see Reference 3 of the HRS documentation record at proposal for a topographical 

map) and thus it is unlikely that RCWRF discharge contributed to the mercury contamination levels in the release 

sample. 
Macon Naval Ordnance Plant NPL Listing Support Document 

28 

Figure 3. Aerial image of the Rocky Creek Water Reclamation Facility indicating the location of the historical effluent o

approximate locations of PPE-1 and the observed release sample MNOP-D4-W-09-SD (see figure 2 for the exact sample 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

Even if the RCWRF effluent had been discharged to Drainage Ditch #4, there is no evidence suggesting that 

mercury would have been present in the discharge. The RCWRF currently monitors its discharge for mercury as 

required by its NPDES permit and performs annual effluent testing with results dating back to 1996 (presented in 

Attachment 1 of this support document). The attached sampling results (Attachment 1) show that mercury has 

never been documented to be present in the effluent leaving the facility for this time period. Based on the 

information available at the time of the HRS evaluation, no evidence exists to suggest that the RCWRF effluent is 

a contributor to the mercury contamination found in the observed release sample in Drainage Ditch #4. 

Insomuch as any mercury in the discharges from the GP and Southern Wood Piedmont Company would have to 

pass through the RCWRF, no indication of a release of mercury from the RCWRF to the wetlands east of 

Drainage Ditch #4 can be found (see section 3.11.3, Contaminant Concentration Downgradient of the RCWRF, of 

this support document for further explanation of the RCWRF treatment facility processes). Water discharges from 

GP and the Southern Wood Piedmont Company cannot be said to have contributed to the significant increase in 

the observed release. However, these properties may be considered at a later stage in the Superfund process. 

For additional information, see section 3.11.3, Contaminant Concentration Downgradient of the RCWRF, of this 

support document, which addresses the concentration gradient in Drainage Ditch #4 as it relates to the RCWRF 

discharge 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.11.1.2 GP Air Emissions 

Comment: Unimax commented that the GP released mercury to the air and that GP should be considered a 

possible source of the mercury contamination in the vicinity of the Site. Unimax specifically commented that the 

mercury will settle out on nearby soils and plants. Unimax asserted that GP air emissions are also a plausible 

source of the low levels of mercury found in surface soils throughout the Site and in the background samples. 

Response: Contamination originating from GP air emissions is not a likely source of the mercury either in Source 

1 or in the observed Release sample in Drainage Ditch #4. The HRS documentation record at proposal includes 

samples in the vicinity of the Site that show that widespread mercury contamination is not present, as would be 

expected if significant dispersion of mercury resulting from air emissions. 

If aerial deposition were the source of contamination at the Site as Unimax asserts, the contamination would be 

widespread throughout the MNOP property. The HRS documentation record at proposal contains six soil and 

sediment samples from the July 2011 Supplemental Sampling Event that are located throughout the sampling area 

on the MNOP property and in Drainage Ditch #4 that do not indicate widespread mercury contamination 

(depicted in Figure 1 of this support document and Figure 3 of the HRS documentation record at proposal). 

Additionally, the 2009 Region 4 SESD (performed by TetraTech) data (these data sets were identified by 

Unimax) are included as References 7, 34 and 35 of the HRS documentation record at proposal; and, as Unimax 

commented, only 6 of the 43 surface soil samples show detectable mercury levels in the 2009 Region 4 SESD 

data. These findings support that mercury is not ubiquitous or widespread throughout the MNOP property except 

for the mercury contamination as identified in the HRS documentation record at proposal as Source 1 near 

Building 109. Furthermore, Unimax presented no data to support that widespread mercury contamination on the 

MNOP property exists that would be consistent with aerial depositions from the GP facility. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

29 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

3.11.1.3 Contribution of Sources West and North of Source 1 

Comment: Unimax asserted that the mercury contamination in the release sample in Drainage Ditch #4 did not 

come from MNOP or from contamination caused by MNOP. Unimax commented that the mercury contamination 

in the western portion of the MNOP property did not cause the mercury contamination in the release in Drainage 

Ditch #4 and that the contamination in the northern area of the MNOP property did not originate from MNOP. 

Unimax also commented that other data sets indicate that mercury contamination may be present on the western 

portion of the MNOP property but Unimax concluded that the western portion of the property does not affect 

Drainage Ditch #4. 

Response: Mercury contamination in the release sample has been documented to have originated from the MNOP 

site, not from sources west and north of Source 1. Mercury in the contaminated soils on the northern portion of 

the Site came from the MNOP facility (Source 1), not other off-site sources; this area of mercury contaminated 

soil, which drains to Drainage Ditch #4, is the only identified mercury source documented to enter Drainage Ditch 

#4. As discussed in section 3.9, Source 1, of this support document, multiple soil samples collected throughout the 

MNOP property show that the mercury contamination in Source 1 is not originating from off-site sources, 

including those areas north or west of the Site. 

Regarding the possible northern sources, as shown in Figure 1 of this support document, multiple soil samples 

were taken throughout the MNOP property in the June 2011 Supplemental Sampling Event. These samples 

include locations to the north (MNOP-02-SF) and west (MNOP-05-SF) of Source 1. These sample locations are 

south of the northern source area pointed to by the Unimax and are thus located between the northern area and 

both Source 1 and Drainage Ditch #4. These samples contain mercury at levels that are not detectible or below the 

concentration in the background sample (MNOP-01-SF) and show that contamination in Source 1 is not 

originating from off-site sources to the north or west of Source 1. If mercury contamination were reaching Source 

1 from these areas, the mercury in samples from between the areas should be detectible and at similar levels as 

found in Source 1. 

Regarding contamination in the western portion of the Site; while some mercury contamination may be present on 

the western portions of the MNOP property, the western portion of the MNOP property drains into Drainage 

Ditch #1 and does not impact the eastern portion of the MNOP property or Drainage Ditch #4. The HRS 

documentation record at proposal lists the western portion of the property as a possible source of contamination, 

but states that it does not drain to Drainage Ditch #4. Unimax agreed in their comments that the western portions 

of the property do not affect the contamination found in Drainage Ditch #4. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.11.2 Contaminant Concentration Gradient in Drainage Ditch #4 

Comment: Unimax challenged the attribution of mercury contamination to the MNOP by claiming the sampling 

in the intermittent ditch (Drainage Ditch #4) between the Site source and the observed release sample did not 

indicate the mercury migrated to the release sample via that route. Unimax and Cozen commented that the 

contaminant concentration gradient in Drainage Ditch #4 is not supportive of MNOP being the upgradient source 

of mercury contamination and provided the following comments: 

• Unimax commented that “[t]he hypothesized transport pathway [used in the HRS evaluation] through 

Drainage Ditch #4 is not supported by the data.” 

• Unimax commented that the lowest mercury concentrations in sediment occur near the MNOP facility 

and in the upstream reaches of Rocky Creek. 

30 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

• Unimax stated that the mercury concentrations in the ditches on the MNOP property tend to decrease as 

they travel downgradient on the property. 

• Cozen commented that the EPA background sediment sample is an order of magnitude higher than the 

sediment samples taken from Drainage Ditch #4 on MNOP property. 

Unimax stated that the “EPA’s failure to consider the concentration gradient, which reveals very low or non 

detectable levels of mercury in Ditch #4 at the southern site boundary and north of the RCWRF and the highest 

levels of mercury immediately downgradient of the RCWRF, is arbitrary and capricious.” Unimax commented 

that by plotting the mercury concentration gradient in Drainage Ditch #4 it becomes clear that the MNOP is not a 

“likely or material” contributor to the higher mercury concentrations at and downgradient of the RCWRF. 

Further, the low mercury concentrations found in sediment samples in Drainage Ditch #4 on the MNOP property 

provide “evidence of no source of mercury upgradient of their locations.” 

Response: The contaminant concentration gradient in Drainage Ditch #4 is supportive of an upgradient source of 

mercury contamination and the significant increase in mercury contamination found in the release sample 

(MNOP-D4-W-09-SD) is attributed to the Site. While the mercury concentration gradient is not at a constant 

concentration or a slowly decreasing concentration with distance from Source 1, this is most likely due to the 

streambed morphology. 

As cited in section 3.11, Observed Release - Attribution, of this support document, the HRS requires that for an 

observed release by chemical analysis to be identified, at least part of the significant increase in a hazardous 

substance in a release sample be attributable to a release from the site. The HRS documentation record at proposal 

on pages 25 and 26 establishes that at least some portion of the mercury contamination found in the release 

sample (MNOP-D4-W-09-SD) is due to the Site as addressed in section 3.11, Observed Release - Attribution, of 

this support document. 

The contaminant concentration gradient observed in Drainage Ditch #4 (presented in Figure 1 of this support 

document) is supportive of an upgradient source of mercury on the MNOP property. The physical characteristics 

of the drainage ditch support the mercury contamination concentration gradient seen in the data presented in the 

HRS documentation record at proposal. These physical characteristics include the intermittent nature and the 

streambed gradient of Drainage Ditch #4. These two characteristics explain how the data collected in the Ditch 

support contamination originating from the MNOP site source. 

Drainage Ditch #4 is an intermittent stream as shown in Reference 3 of the HRS documentation record at 

proposal. In addition to having intermittent flow, the streambed gradient4 of Drainage Ditch #4 from the MNOP 

property to PPE-15 in the palustrine forested wetland is approximately 75 ft/mile (gradient of 1.5%). The 

streambed gradient after PPE-1 (once the Ditch reaches the palustrine forested wetlands) is less than 10 ft/mile 

(streambed gradient of 0.2%) (see Reference 3 of the HRS documentation record at proposal).6 The streambed 

gradient suggests that water flowing in the ditch exhibits two different flow regimes. The first flow regime occurs 

in the water in the portion upgradient of PPE-1. The upper portion of Drainage Ditch #4 flows at a high velocity 

 

4

 Streambed gradient is calculated by dividing the change in elevation by the lateral distance covered. The gradient is then 

multiplied by 100 to attain a percent gradient. 

5

 PPE-1 is located along Drainage Ditch #4 at the point where the ditch enters HRS-eligible wetlands (at this site, Palustrine 

forested wetlands) and does not correspond to a sample location. 

6

 This gradient value was calculated using the topographical map for the area presented in the HRS Documentation Record at 

proposal (Reference 3 of the HRS documentation record at proposal). The upstream portion of Drainage Ditch #4 drops 30 

feet in elevation from the southern boundary of the MNOP property to PPE-1 (which is approximately 2000 ft. downgradient 

of the property). The downgradient portion, below PPE-1, does not show an elevation change on the topographical map 

within one mile of PPE-1, therefore an estimation of 10 feet was used as the elevation change could not be greater than 10 

feet if it does not cross a topographical contour line. 

31 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

(high streambed gradient) and carries water, and any contamination, away from the MNOP facility with little to 

no deposition within Drainage Ditch #4. The second flow regime occurs as the water enters the palustrine forested 

wetlands at PPE-1. The lower portion of Drainage Ditch #4, after the ditch enters the wetland, flows at a low 

velocity (lower streambed gradient) and is supportive of sediment (and contaminant) deposition. 

The flow regime in the upper portions of Drainage Ditch #4 (upgradient of PPE-1) retard the settling of particles 

(including those containing or associated with contamination) in the ditch following precipitation events. The 

sediments and contamination in the water will travel at a higher velocity upgradient of PPE-1 and will have less 

time to settle (if at all) in this portion of the streambed of Drainage Ditch #4 where the upgradient sediment 

samples were taken. After the flow enters the palustrine forested wetlands (at PPE-1), the flow regime changes. 

The streambed gradient lowers to 0.2% and the velocity of the water slows to allow for increased amounts of 

suspended sediments to settle out in the streambed of Drainage Ditch #4. This area is where samples MNOP-D4-

W-08-SD and MNOP-D4-W-09-SD were taken. 

Therefore, it is expected that upgradient streambed sediment samples in the area of the first, higher velocity flow 

regime would have lower contamination than sediment samples downgradient of PPE-1 as the contamination 

from Source 1 would have more time to settle into the sediment in the drainage ditch in the area of the second 

flow regime, which slows in the palustrine forested wetlands. Thus, the concentration gradient of mercury 

contamination observed in Drainage Ditch #4 is supportive of an upgradient source of mercury consistent with the 

MNOP facility. The possibility of the mercury originating from other possible facility sources is discussed further 

in Section 3.11.1, Possible Mercury Releases from Alternative Sites, of this support document. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.11.3 Contaminant Concentration Downgradient of the RCWRF 

Comment: Unimax argued that because the concentration of mercury is higher downstream of the RCWRF 

facility, the source of the mercury was not Source 1 at the Site. Unimax commented that the highest mercury 

concentrations occur downgradient of the RCWRF discharge, suggesting that the source of the mercury in the 

release samples is the discharge from the RCWRF. Unimax stated that the “EPA’s failure to consider the 

concentration gradient, which reveals very low or nondetectable levels of mercury in Ditch #4 at the southern site 

boundary and north of the RCWRF and the highest levels of mercury immediately downgradient of the RCWRF, 

is arbitrary and capricious.” Unimax further commented that the attribution of an observed release to the former 

MNOP is not supported by the data; instead, the data indicate the RCWRF and its industrial user, GP, as the 

responsible parties for the mercury contamination found in the observed release sample. Unimax asserted that the 

RCWRF has historically received mercury-containing wastewater from the GP facility and other industrial 

facilities. 

Response: The significant increase in mercury concentration in Drainage Ditch #4 downgradient of the RCWRF 

location (i.e., the increased concentration gradient) was correctly attributed to the MNOP site and not to 

discharges from the RCWRF. While the concentration of mercury in Drainage Ditch #4 is higher in a sample 

downgradient of the RCWRF facility location, as explained in section 3.11.1, Possible Mercury Releases from 

Alternative Sites, of this support document, the location of the sample used to establish an observed release is 

upgradient of the location of the historical discharge outfall from the RCWRF. Furthermore, the RCWRF 

discharge does not contain mercury. Therefore discharge from the RCWRF is not likely the cause of the 

significant increase in mercury contamination in the observed release sample (see Section 3.11.1.1, Wastewater 

Discharges from GP and SWPC via the RCWRF, of this support document). 

Based on information collected in responding to this comment (see Attachment 1 and Figure 3 of this support 

document), the discharge from this wastewater treatment facility contained no mercury and the historical outfall 

32 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

from the RCWRF was discharged directly into the wetland south of the treatment facility and not to Drainage 

Ditch #4; Unimax did not identify any information documenting releases of mercury from the RCWRF. 

As described in 3.11.2, Contaminant Concentration Gradient in Drainage Ditch #4, of this support document, the 

possible causes of the contaminant concentration gradient in Drainage Ditch #4 were evaluated and it was 

determined that the gradient is consistent with an upgradient source such as Source 1 on the MNOP property. 

Potential mercury discharges from the RCWRF were considered when establishing attribution of the mercury 

release to the Site. No evidence was identified (nor did the commenters present any evidence) to suggest that the 

RCWRF ever discharged mercury into Drainage Ditch #4 (see section 3.11.1.1, Wastewater Discharges from GP 

and the Southern Wood Piedmont Company via the RCWRF, of this support document). 

Pages 25 and 26 of the HRS documentation record at proposal discuss the attribution of mercury contamination 

found at the Site and considered the RCWRF as a potential contributor to the contamination in Drainage Ditch #4 

as follows: 

Possible off-site sources also include the FMNOL, AWI, and the Rocky Creek water reclamation 

facility (RC WRF). AWI and FMNOL are currently listed on the EPA NPL under CERCLIS ID 

No. GAN000410033 at docket number EPA-HQ-SFUND-2010-0640-0002 (Ref. 47). Runoff 

from FMNOL and AWI flows into Rocky Creek via a drainage easement. The drainage easement 

enters Rocky Creek west and upstream of Source No. 1 soil sample MNOP-04-SF and Drainage 

Ditch 4. Drainage Ditch 4 is located just west of the RC WRF (Ref. 7, Appendix A, p. A-2). 

... 

The RC WRF, located southeast of and downstream from MNOP, provides wastewater treatment 

for the southern and western portions of the City of Macon. Treated wastewater from this facility 

is discharged into the Ocmulgee River; however, RC WRF maintains a National Pollutant 

Discharge Elimination System (NPDES)-permitted discharge point at the southern property 

boundary (Refs. 9, p. 3; 45, pp. 2, 3; 46, pp. 1, 8). The NPDES permit requires RC WRF to 

monitor outfall discharges for biochemical oxygen demand, total suspended solids, pH, chlorine, 

fecal coliform, nitrogen, dissolved oxygen, PCBs, and phosphorus (Ref. 46, pp. 6, 7). There are 

currently no documented releases of mercury at this location (Refs. 9, p. 3; 46, pp. 6, 7). 

The RCWRF was built as a joint treatment facility with the Macon Kraft Company, now called GP, and provides 

wastewater treatment for the GP facility. Mercury may be a possible constituent in the waste water from GP that 

is discharged to the RCWRF for treatment. While the RCWRF may have received mercury-containing waste 

water from GP, the RCWRF was designed to treat effluent delivered to the facility. The RCWRF plant is an 

advanced secondary wastewater treatment facility that includes activated sludge aeration basins, clarifiers, 

conventional filtration, as well as disinfectants before its effluent is discharged into the Ocmulgee River 

(http://maconwater.org/water-reclamation-facilities). As shown in Attachment 2 to this support document, 

mercury is one of the metals known to be captured by the extended aeration activated sludge process and is found 

in the biosolids7

 that are removed from the wastewater. These processes combined effectively treat the mercury in 

the effluent, and there has been no documented mercury in the discharge from the RCWRF. 

The RCWRF historically discharged to the wetlands east of Drainage Ditch #4 from the time it began operation in 

1971 to the mid 1980’s when the discharge was re-routed to the Ocmulgee River. The RCWRF currently 

discharges to the Ocmulgee River which is approximately 2 miles east of the facility (see Reference 3 of the HRS 

 

7

 Biosolids is a term used to describe municipal treatment plant solids that result from the treatment of wastewater. Biosolids 

are processed wastewater solids that have met specific criteria and are suitable for land application. Specifically, the RCWRF 

biosolids have been tested for mercury, and the results are presented in Attachment 2 of this support document. 

33 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

documentation record at proposal). Although the RCWRF has discharged effluent to the wetlands east of 

Drainage Ditch #4, no evidence or data supports a release of mercury from the RCWRF facility. Attachment 1 of 

this support document presents annual monitoring data (which dates back to 1996) for the effluent of the RCWRF 

and shows no mercury in the facility effluent. While the discharge point for the RCWRF has been repositioned, 

no information was found or was presented by the commenter, to indicate that the conditions at the RCWRF 

significantly changed. The treatment system at the RCWRF is essentially the same as before 1996 and there is no 

evidence to suggest that discharge prior to 1996 might contain mercury. Therefore, no evidence suggests that the 

RCWRF effluent is a contributor to the mercury contamination found in the release sample in Drainage Ditch #4 

For additional information, see section 3.11.1, Wastewater Discharges from GP and the Southern Wood Piedmont 

Company via the RCWRF, which addresses the possible contaminant contributions of GP and SWPC via the 

RCWRF. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.11.4 Other Data Sets 

Comment: Unimax commented that a large volume of “spatially extensive, high-quality, relevant data” has been 

ignored and stated that “[t]he HRS documentation record shows an arbitrary selectivity in use of the data.” 

Unimax asserted that the failure to present or analyze these data is a fundamental mistake because they help to 

explain the Site conditions. Unimax stated that “[E]PA guidance recommends using existing analytical data when 

they are of sufficient quality.” 

Unimax commented that the HRS documentation record only obtained a small set of data focused around 

Building 109 and Drainage Ditch #4 and only used these data samples to show mercury contamination at the 

facility even though previous investigations found “no significantly elevated mercury concentrations.” Unimax 

stated that the “EPA’s failure to attempt to explain this contradictory data is arbitrary and capricious.” 

Unimax commented that both Rust and TetraTech obtained usable mercury measurements of more than 100 

surface soil and sediment samples and found that low levels of mercury are pervasive in surface soils throughout 

the area and are not unique to the MNOP facility. Unimax further stated that “[t]hese data present a convincing 

picture of the absence of any material source of mercury to Drainage Ditch #4.” Unimax asserted that these 

additional data sets contradict the establishment of a source of mercury on the MNOP facility. 

Unimax concluded that these other data sets show that mercury contamination on the MNOP facility cannot be 

contributing to the contamination in the observed release sample downgradient in Drainage Ditch #4. 

Response: The June 2011 Supplemental Sampling Event provided sufficient analytical data to document and 

attribute the significant increase in mercury contamination in the observed release to migration from Source 1 on 

the MNOP property, and best represents the current Site conditions. While the other data sets were not used for 

scoring purposes in the HRS evaluation, these other data sets were made available as references in the HRS 

documentation record at proposal and show mercury contamination that is consistent with the sampling results in 

the June 2011 Supplemental Sampling Event. 

The HRS documentation record at proposal did not fail to present or analyze additional available data; rather, the 

HRS documentation record at proposal included the additional data referred to by Unimax (see References 7, 12, 

13, 14, 21, 34 and 35 of the HRS documentation record at proposal) which support the findings in the June 2011 

Supplemental Sampling Event data. The HRS documentation record at proposal lists and provides references that 

contain the results of six other investigations that were performed at the Site prior to the June 2011 Supplemental 

Sampling Event. Table 1 on pages 13 and 14 of the HRS documentation record at proposal summarizes these 

previous investigations: 

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Macon Naval Ordnance Plant NPL Listing Support Document May 2013

TABLE 1: Summary of Previous Investigations

Company/

Agency Investigation Date Samples Collected

Hazardous 

Substances 

Detected

References

Beaver 

Engineering 

Environmental 

Assessment 

1989 Soil Metals 13, p. 3 

Environmental 

Science and 

Engineering 

Confirmation 

Study of the 

Former Macon 

Naval Ordnance 

Plant 

1990 Soil, ground 

water, and 

sediment 

Arsenic 

Cadmium 

Chromium 

Lead 

TCE 

14, pp. I, 2-1, 3-

4, 3-6, 3-9, 3-

11, 4-2, 4-3, 4-

11, 4-12 

USACE, 

Savannah 

District 

Site 

Investigation 

1996 Soil, ground 

water, surface 

water, and 

sediment 

Cadmium 

Chromium 

Lead 

Mercury 

13, pp. vi, 1, 13, 

20, 27, 28, 55 

through 60, 63, 

71 through 92, 

94 through 104, 

106, 107 

USACE, 

Savannah 

District 

Hazardous Site 

Response Act 

(HSRA) 

Compliance 

Status Report 

1998 to 2000 Soil, ground 

water, surface 

water, and 

sediment 

Arsenic 

Cadmium 

Chromium 

Lead 

Zinc 

TCE 

PCE 

Benzo(a)pyrene 

12, pp. i, ii,1-1, 

1-10, 2-9, 2-19, 

2-33, Appendix 

O, pp. O15 

through O53 

USACE, 

Savannah 

District 

Post-Test 

Groundwater 

Sampling 

2004 Ground water DCE 

TCE 

PCE 

Vinyl Chloride 

21, pp. 1, 2, 5, 

11 

EPA Expanded Site 

Inspection 

May 2009 Soil, ground 

water, surface 

water, and 

sediment 

Cadmium 

Chromium 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

PCBs 

Pesticides 

SVOCs 

VOCs 

7, pp. 1, 6, 7, 

Appendix B, pp. 

B-12 through B69, B-71 

through B-75, 

B-77 through B113 

EPA Supplemental 

Sampling Event 

June 2011 Soil and 

sediment 

Mercury 9, pp. 1, 3; 11, 

pp. 5, 8, 19, 21 

The HRS documentation record did not fail to present or analyze additional data sets available for the Site. 

Rather, in June 2011 a supplemental sampling event was completed and included samples located on the MNOP 

property and in Drainage Ditch #4. The HRS documentation record at proposal scored the Site on this June 2011 

Supplemental Sampling Event because it is the most current data that is available for the Site. As presented in the 

HRS documentation record at proposal, the June 2011 Supplemental Sampling Event included multiple surface 

soil samples and sediment samples located in Drainage Ditch #4 (see Figure 1). These samples, as presented in 

35 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

the HRS documentation record at proposal, provide sufficient data to score the Site as discussed in this support 

document in sections 3.9, Source 1; 3.10, Observed Release – Background; and 3.11, Observed Release – 

Attribution. 

The additional data sets noted by the commenter do not contradict the establishment of Source 1 or the observed 

release of mercury in Drainage Ditch #4. These additional data sets do support Unimax’s assertion that mercury 

contamination is not ubiquitous throughout the property, however, it is not true that there are no “elevated 

mercury concentrations” identified in these data sets. For example, in the 2009 Expanded Site Assessment alone, 

mercury is not detected in the background sample located on the north east portion of the MNOP property and at 

least two soil samples located near Building 109 are detected at concentrations above the sample quantitation 

limit as required by the HRS and explained in section 3.9, Source 1, of this support document. 

The contamination found in the June 2011 Supplemental Sampling Event is supported by the additional data sets 

that the commenters mention and are provided as references to the HRS documentation record at proposal as 

shown in Table 1 above. However, the June 2011 data set is sufficient to document attribution, at least in part, to 

Source 1 on the MNOP property. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

3.12 Characterization of PPE 1 

Comment: Unimax commented that PPE 1 is located within a settling basin of the RCWRF in which the National 

Wetlands Inventory (NWI) characterizes the location as Emergent Wetland “PEM1Fx”. Unimax asserts that this 

is a man-made, or excavated basin or channel and according to topographic quadrangle maps this area is depicted 

as part of the RCWRF. 

Response: The HRS documentation record at proposal correctly identifies the probable point of entry to Drainage 

Ditch #4 from Source 1 (see Figure 2). PPE-1 was identified at the point at which Drainage Ditch #4 intersects an 

eligible surface water body; specifically, the eligible surface water body at this site is the HRS eligible wetland: 

Freshwater Palustrine Forested/Shrub Wetland (see Figure 1 of this support document). The HRS documentation 

record at proposal does not identify PPE-1 as being located within a settling basin of the RCWRF labeled an 

emergent wetland “PEM1Fx.” 

HRS Section 4.0.2, Surface water categories, defines what is considered a surface water body for HRS 

purposes as follows: 

For HRS purposes, classify surface water into four categories: rivers, lakes, oceans, and coastal 

tidal waters. 

 -Rivers include: 

... 

• Perennially flowing waters from point of origin to the ocean or to coastal tidal 

waters, whichever comes first, and wetlands contiguous to these flowing waters. 

HRS Section 4.1, Overland/flood migration component, establishes how to identify a probable point of entry for a 

source. It states to “[u]se the overland/flood migration component to evaluate surface water threats that result 

from overland migration of hazardous substances from a source at the site to surface water.” 

Page 21 of the HRS documentation record at proposal explains the establishment of PPE 1, stating: 

36 
Macon Naval Ordnance Plant NPL Listing Support Document May 2013

37 

The hazardous substance migration pathway includes both the overland segment and the in-water 

segment that hazardous substances would take as they migrate away from sources. The overland 

segment begins at the source and proceeds downgradient to the probable point of entry (PPE) to 

surface water. The in-water segment at the PPE continues in the direction of flow (Ref. 1, Section 

4.1.1.1). 

Overland flow from Source No. 1 (contaminated soil in the eastern portion of the MNOP 

property) is directed to Drainage Ditch 4. Drainage Ditch 4 is an intermittent drainage route 

located upgradient of the PPE along the eastern boundary of the MNOP property (Ref. 9, pp. 1, 

3). Surface water runoff from Source No. 1 flows overland about 625 feet and enters Drainage 

Ditch 4. Drainage Ditch 4 flows south for about 3,250 feet and enters HRS-eligible palustrine 

forested wetlands adjacent to Rocky Creek. The point where Drainage Ditch 4 enters the 

palustrine forested wetlands is PPE 1. Drainage Ditch 4 continues south within palustrine forested 

wetlands for about 1,250 feet and enters Rocky Creek (Refs. 3; 36, Map 1) (also see Figure 3 of 

this HRS documentation record). 

The HRS documentation record at proposal establishes PPE-1 as the point at which hazardous substances 

migrating overland via runoff enter an eligible surface water body. The HRS documentation record at proposal 

does not identify PPE-1 as being located within a historical settling basin of the RCWRF, rather, as shown in 

Figure 2 of this support document, PPE-1 is identified at sample location MNOP-D4-W-08-SD, which is the entry 

point of surface runoff in Drainage Ditch #4 to Palustrine Forested, Broad-Leaved Deciduous, Seasonally Flooded 

wetland. As identified by HRS Section 4.0.2, Surface water categories, HRS-eligible wetlands contiguous to 

flowing waters are considered surface water; therefore, PPE-1 is correctly established at this intersection in 

Drainage Ditch #4 where overland flow enters palustrine forested wetlands. 

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL. 

4. Conclusion 

The original HRS score for this site was 48.97. Based on the above responses to comments, the Site score remains 

unchanged. The final scores for the MNOP site are: 

Ground Water Not Scored 

Surface Water 97.94 

Soil Exposure Not Scored 

Air Not Scored 

HRS Site Score 48.97 
Attachment 1: 

Macon Water Authority, Rocky Creek Effluent Sample 

Results, Various Dates 
_____ 

Client Sample Results 

Client: Macon Water Authority 

ProjecUSite: Rocky Creek Effluent Annual PP Scan 

________,_., 

'lient Sample ID: AA32930 Rocky Creek Effluent Pre-CI2 

TestAmerica Job ID: 680-75245-2 

-----......._ 
 Lab Sample ID: 680-75245-3 

....ate Collected: 12/13/11 00:00 

Date Received: 12/14/11 09:43 

Matrix: Water 

Method: 200.8 ·Metals (ICP/MS) 

Analyte 

Antimony 

Arsenic 

Beryllium 

Cadmium 

Chromium 

Copper 

Lead 

Nickel 

Selenium 

Silver 

Thallium 

Zinc 

Result 

<0.0050 

<0.0050 

<0.0010 

<0.00070 

<0.0050 

<0.0050 

<0.0010 

<0.0050 

<0.0050 

<0.0050 

<0.0010 

0.042 

Qualifier RL 

0.0050 

0.0050 

0.0010 

0.00070 

0.0050 

0.0050 

0.0010 

0.0050 

0.0050 

0.0050 

0.0010 

0.010 

MDL Unit 

mg/l 

mgll 

mg/L 

mgll 

mgll 

mg/L 

mg/L 

mg/l 

mg/L 

mg/L 

mg/L 

mg/L 

D Prepared 

12/15/1111:06 

12/15/1111:06 

12/15/1111:06 

1211511111:06 

12/15/1111:06 

12/1511111:06 

12/15!1111:06 

12/15/1111:06 

12/15/1111:06 

1211511111:06 

1211511111:06 

12/15/1111:06 

Analyzed 

12115/1117:37 

12/15/1117:37 

12115/11 17:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

12/15/1117:37 

Oil Fac 

1 ~ 

[Method: 245.1 ·Mercury (CVAA) 

Analyte 

Mercury 

Result 

<0.00050 

Qualifier RL 

0,00050 

MDL Unit 

mg/L 

D Prepared 

12/16/1110:19 

Analyzed 

12/19/1116:01 

Oil Fac 

TestAmerica Savannah 

Page 6 of 29 12/23/2011 
Analytical Data 

Client: Macon Water Authority Job Number: 680-65488-1 

Client Sample ID: AA27826 -Rocky Creek EFF 

Lab Sample ID: 680-65488-1 Dale Sampled: 02108/2011 0000 

Client Matrix: Water Dale Received: 02109/2011 0930 

200.8 Metals (ICPIMS) 

Method: 200.8 Analysis Balch: 680-194263 Instrument ID: ICPMSB 

Preparation: 200.8 Prep Batch: 680-194066 Lab File ID: 194066.chr 

Dilution: 1.0 Initial WeightNolume: 50 mL 

Date Analyzed: 0211112011 1549 Final WeighWolume: 250 mL 

Date Prepared: 02/10/2011 1200 

Analyte Result (mg/L) Qualifier RL 

Antimony <0.0050 0.0050 

Arsenic <0.0050 0.0050 

Beryllium <0.0010 0.0010 

Cadmium <0.00070 0.00070 

Chromium <0.0050 0.0050 

Copper <0.0050 0.0050 

Lead <0.0010 0.0010 

Nickel <0.0050 0.0050 

Selenium <0.0050 0.0050 

Silver <0.0050 0.0050 

Thallium <0.0010 0.0010 

Zinc 0.030 0.010 

245.1 Mercury (CVAA) 

Method: 245.1 Analysis Balch: 680-194712 Instrument ID: LEEMAN! 

Preparatlon: 245.1 Prep Balch: 680-194192 Lab File ID: 021611.chr 

Dilution: 1.0 Initial WeighWolume: 50 ml 

Date Analyzed: 0211612011 1308 Final WeighWolume: 50 ml 

Date Prepared: 02111/2011 1051 

Analyte Result (mg/L) Qualifier RL 

Mercury <0.00050 0.00050 

TestAmerlca Savannah Page 5 of 10 02/17/2011 
Analytical Data 

Client: Macon Water Authority Job Number: 680-44771-2 

Client Sample 10: AA16048 

Lab Sample ID: 680-44771-3 Dale Sampled: 02/15/2009 0000 

Client Matrix: Water Date Received: 02/1712009 0902 

200.8 Metals (ICP/MS) 

Method: 200.8 Analysis Batch: 680-130762 

Preparation: 200.8 Prep Batch: 680-130575 

Dilution: 1.0 

Date Analyzed: 02/1912009 2141 

Date Prepared: 02/19/2009 1116 

Analyte Result (mg/L) 

Antimony <0.0050 

Arsenic <0.0050 

Beryllium <0.0010 

Cadmium <0.00070 

Chromium <0.0050 

Copper 0.0060 

Lead <0.0010 

Nickel <0.0050 

Selenium <0.0050 

Silver <0.0050 

Thallium <0.0010 

Zinc 0.023 

Instrument 10: ICPMS-A 

Lab File ID: NIA 

Initial WeighWolume: 50 mL 

Final WeighWolume: 250 mL 

Qualifier RL 

0.0050 

0.0050 

0.0010 

0.00070 

0.0050 

0.0050 

0.0010 

0.0050 

0.0050 

0.0050 

0.0010 

0.010 

Method: 245.1 

Preparation: 245.1 

Dilution: 1.0 

Date Analyzed: 02/1912009 1532 

Date Prepared: 02118/2009 1208 

Analyte 

Mercury 

245.1 Mercury (CVAA) 

Analysis Batch: 680~130779 

Prep Batch: 680-130453 

Result (mg/L) 

<0.00050 

Instrument ID: 

Lab File ID: 

Initial WeighWolume: 

Final WeighWolume: 

Qualifier 

LEEMAN1 

NIA 

50 mL 

50 mL 

RL 

0.00050 

TestAmerica Savannah Page 11 of 30 
Analytical Data 

Client: Macon Water Authority Job Number: 680-54888-2 

Client Sample ID: Rocky Creek Pre-Chlorinated Effluent (AA21742) 

Lab Sample ID: 680-54888-3 Date Sampled: 02/07/2010 0000 

Client Matrix: Water Date Received: 02/09/2010 1114 

200.8 Metals (ICP/MS) 

Method: 200.8 Analysis Batch: 680-160823 Instrument ID: ICPMSB 

Preparation: 200.8 Prep Batch: 680-160403 Lab File ID: N/A 

Dilution: 1.0 Initial WeighWolume: 50 mL 

Date Analyzed: 02/13/2010 0618 Final WeighWolume: 250 mL 

Date Prepared: 02/10/2010 1122 

Analyte Result (mg/L) Qualifier RL Ari'tlnlO-ny- ,-----­ -- ------~ <o:oo55 0.0050 

Arsenic <0.0050 0.0050 

Cadmium <0.00070 0.00070 

Chromium <0.0050 0.0050 

Copper 0.019 0.0050 

Lead 0.0012 0.0010 

Nickel <0.0050 0.0050 

Selenium <0.0050 0.0050 

Silver <0.0050 0.0050 

Thallium <0.0010 0.0010 

Zinc 0.042 0.010 

Method: 200.8 Analysis Batch: 680-160824 Instrument ID: ICPMSB 

Preparation: 200.8 Prep Batch: 680-160403 Lab File ID: N/A 

Dilution: 1.0 Initial WeighWolume: 50 mL 

Date Analyzed: 02/13/2010 0618 Final WeighWolume: 250 mL 

Date Prepared: 02/10/2010 1122 

Result (mg/L) Qualifier

···· ... ·-····· -·<a:ao10"______ ------------------~ 

245.1 Mercury (CVAA) 

Method: 245.1 Analysis Batch: 680-160775 Instrument ID: LEEMAN1 

Preparation: 245.1 Prep Batch: 680-160393 Lab File ID: N/A 

Dilution: 1.0 Initial WeighWolume: 50 mL 

Date Analyzed: 02/11/2010 1526 Final WeighWolume: 50 mL 

Date Prepared: 02/10/2010 1052 

Analyte 

Mercuiy 

Result (mg/L) 

<6.1lolls6 

Qualifier RL 

o:aoo51l 

TestAmerica Savannah Page 13 of 33 04/05/2010
ANALYTICAL =RJLJ C E S. I N C . IA31I Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX (770) 734-4201 

laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark WyzaJek February 5, 2008 

Report No. 254514-2 

Macon Water Authority 

Sample Description: Wastewafer. Composite, Rocky Creek PPL-GA 129, Rocky Creek Effluent, 01/24/2008, 00:00, received 01/25/2008 

Report. Analytical Preparation Oil. Results Preparation Analytical 


Analyte Result Limit Units Qual. Method Method Factor CAS# Source 10 Batch# Date Time Date Time !nit. 


129 Priority Pollutants~ Georgia 

General Chemistry 

Total Phosphorus (P) 0.37 0.02 mg/L SM 4500-P B.E SM 4500-P B.E 1 7723-14-0 254514-2 148966 1/28/08 1130 1/29/08 1400 YM 

Inorganic Anions 

Nitrate-Nitrite Nitrogen (N) 4.9 0.1 mg/L EPA300.0 1 E-10128 254514-2 149166 2/1/08 1346 LMH 

Metals 

Total Antimony (Sb) ND 5 ug/L EPA200.8 EPA 200.8 1 7440-36-0 254514-2 148689 1/28/08 0840 1/28/08 1829 CKE 

Total Arsenic (As) ND 5 ug/L EPA200.8 EPA200.8 1 7440-38-2 254514-2 148689 1/28/08 0840 1/28/08 1829 CKE 

Total Beryllium (Be) ND 1 ug/L EPA200.8 EPA 200.8 1 7440-41-7 254514-2 148689 1/28108 0840 1/28/08 1829 CKE 

Total Cadmium (Cd) ND 0.7 ug!L EPA200.8 EPA200.8 1 7440-43-9 254514-2 148689 1/28/08 0840 1/28/08 1829 CKE 

Total Chromium (Cr) ND 5 ug/L EPA200.8 EPA200.8 1 7440-47-3 254514-2 148689 1/28/08 0840 1/28/08 1829 CKE 

Total Copper (Cu) 6 5 ug/L EPA200.8 EPA200.8 1 7440-50-8 254514-2 148689 1/28/08 0840 1/28108 1829 CKE 

Total Lead (Pb) ND 1 ug!L EPA200.8 EPA200.8 1 7439-92-1 254514-2 148689 1/28/08 0840 1/28108 1829 CKE 

Total Mercury (Hg) ND 0.5 ug/L EPA 245.1 EPA245.1 1 7439-97-6 254514-2 148917 1/29/08 0940 1/29/08 1650 csw 

Total Nickel (Ni) ND 5 ug/L EPA200.8 EPA200.8 1 7440-02-0 254514-2 148689 1/28/08 0840 1/28108 1829 CKE 

Total Selenium (Se) ND 5 ug/L EPA 200.8 EPA200.8 1 7782-49-2 254514-2 148689 1/28/08 0840 1/28/08 1829 CKE 

Total Silver (Ag) ND 5 ug/L EPA200.8 EPA200.8 1 7440-22-4 254514-2 148689 1/28/08 0840 1/28108 1829 CKE 

Total Thallium (TI) ND 1 ug/L EPA200.8 EPA200.8 1 7440-28-0 254514-2 148689 1/28108 0840 1/28/08 1829 CKE 

Total Zinc (Zn) 19 10 ug!L EPA200.8 EPA200.8 1 7440-66-6 254514-2 148689 1/28/08 0840 1/28/08 1829 CKE 

Paae 1 of 1 
ANALYUCAL E R_V I C E S. I N C . 

IJ~stl Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA30092 

(770) 734-4200 FAX (770) 734-4201 

laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek July 18. 2006 

Report No. 230497-1 

Macon Water Authority 

Sample Description: Wastewater, Composite, Rocky Creek PPL, RC Effluent, 06/28-06/29/2006, 00:00- 00:00, received 06/30/2006 

Report. Analytical Preparation Oil. Results Preparation Analytical 

Analyte Result Limit Units Qual. Method Method Factor CAS# Source ID Batch# Date Time Date Time Init. 

129 Priority Pollutants- Georgia 

General Chemistry 

Total Cyanide (CN) 

Total Phosphorus (P) 

NO 

0.56 

20 

0.02 

ug/L 

mg/L 

EPA335.2 

SM 4500-P B ,E 

EPA335.2 

SM 4500-P B,E 

1 

1 

57-12-5 

7723-14-0 

230497-1 

230497-1 

130401 

130429 

7/3/06 

7/5/06 

1830 

1800 

7/5/06 

7/6/06 

1845 

2330 

OMB 

OMB 

Inorganic Anions 

Nitrate-Nitrite Nitrogen (N) 2.7 0.1 mg/L EPA300.0 1 E-10128 230497-1 130469 7/4/06 0800 HE 

Metals 

Total Antimony (Sb) NO 5 ug/L EPA200.8 EPA200.8 1 7440-36-0 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Arsenic (As) NO 5 ug/L EPA200.8 EPA200.8 1 7440-38-2 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Beryllium (Be) NO 1 ug/L EPA200.8 EPA200.8 1 7440-41-7 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Cadmium (Cd) NO 0.7 ug/L EPA200.8 EPA200.8 1 7440-43-9 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Chromium (Cr) NO 5 ug/L EPA200.8 EPA200.8 1 7440-47-3 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Copper (Cu) 6 5 ugll EPA200.8 EPA200.8 1 7440-50-8 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Lead (Pb) ND 1 ug/L EPA200.8 EPA200.8 1 7439-92-1 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Mercury (Hg) NO 0.5 ug/L EPA245.1 EPA245.1 1 7439-97-6 230497-1 129730 713106 0535 7/3/06 1534 MCJ 

Total Nickel (Ni) NO 5 ugll EPA200.8 EPA200.8 1 7440-02-0 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Selenium (Se) NO 5 ug/L EPA200.8 EPA200.8 1 7782-49-2 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Silver (Ag) ND 5 ug/L EPA200.8 EPA200.8 1 7440-22-4 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Thallium (TI) NO 1 ug/L EPA200.8 EPA200.8 1 7440-28-0 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

Total Zinc (Zn) 33 10 ug/L EPA200.8 EPA200.8 1 7440-66-6 230497-1 130298 7/3/06 0625 7/5/06 1902 MCJ 

D ............. -I ....&-< 

IAAsII A N A L y T I c A L s E R v I GE s, I N c --------~E~n~vi~ro~n~1n~e~n~t~a~IM~o~n~ito-r~in~g-&~L-a~bo_r_a~to-~~A-n~a~ly-s~is_________ 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX (770) 734-4201 

Laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No. 224948-1 March 8, 2006 

Sample Description 

Macon Water Authority 

Wastewater, Composite, Rocky Creek PPL, RC Effluent, 02/22-02/23/2006, 06:5(-06:57, received 02/24/2006 

Analytical 

Methoct. Analyte _ Resl!lt Detection. Umit Units 

129 Priority Pollutants- Georgia 

General Chemistry 

EPA 335.2 Total Cyanide (CN) BDL 20 ug/L 

SM 4500-P B,E Total Phosphorus (P) 1.3 . 0.2 mg/L 

Inorganic Anions 

EPA300.0 Nitrate-Nitrit.e Nitrogen (N) 4.1 0.1 mg/L 

Metals 

EPA200.8 Total Antimony (Sb) BDL 5 ug/L 

EPA200.8 Total Arsenic (As) BDL 5 ug/L 

EPA200.8 Total Beryllium (Be) BDL 1 ug/L 

EPA200.8 Total Cadmium (Cd) BDL 0.7 ug/L 

EPA200.8 Total Chromium (Cr) BDL 5 ug/L 

EPA200.8 Total Copper (Cu) 6 5 ug/L 

EPA 200.8 Total Lead (Pb) BDL 1 ug/L 

EPA 245.1 Total Mercury (Hg) BDL 0.5 ug/L 

EPA200.8 Total Nickel (Ni) BDL 5 ug/L 

EPA200.8 Total Selenium (Se) BDL 5 ug/L 

EPA200.8 Total Silver (Ag) BDL 5 ug/L 

EPA 200.8 Total Thallium (TI) BDL 1 ug/L 

EPA 200.8 Total Zinc (Zn) 33 10 ug/L 

SOL - Below Detection Limit Page 1 of 1 
A N A L Y T I C A L S E R V I C E S, I N C Sl Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX (770) 734-4201 

Laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Marl< Wyzalek 

Report No ..219930·1 November 14, 2005 

Sample Description 

Macon Water Authority 

Wastewater, Composite, Rocky Creek PPL, RC Effluent, 11/01-11/02/2005, 06:00- 06:00, received 11/03/2005 

Analytical 

Method Analyte Result Detection Limit Units 

Priority Pollutant Metals 

Metals 

EPA200.7 Total Antimony (Sb) BDL 0.005 mg/L 

EPA200.8 Total Arsenic (As) BDL 0.005 mg/L 

EPA200.7 Total Beryllium (Be) BDL 0.001 mg/L 

EPA200.8 Total Cadmium (Cd) BDL 0.0007 mg/L 

EPA200.7 Total Chromium (Cr) BDL 0.005 mg/L 

EPA200.7 Total Copper (Cu) 0.006 0.005 mg/L 

EPA200.8 Total Lead (Pb) 0.001 0.001 mg/L 

EPA245.1 Total Mercury (Hg) BDL 0.0005 mg/L 

EPA200.7 Total Nickel (Ni) · BDL 0.005 mg/L 

EPA200.8 Total Selenium (Se) BDL 0.005 mg/L 

EPA200.7 Total Silver (Ag) BDL 0.005 mg/L 

EPA200.8 Total Thallium (TI) BDL 0.001 mg/L 

EPA200.7 Total Zinc (Zn) 0.04 0.01 mg/L 

BDL - Below Detection Limit Page 1 of 1 
As~ A N A l y T I c A l s E R v , c E s, I N c . I ~~~~~E~n~v~ir~o~n~m~e-n~ta~I~M~o-n~ito~rin-g~&~L~a~b~o~ra~t~o~ry~A-n~a~ly-s~is~~~~~ 1 1 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX (770) 734-4201 

Laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No. 206502-3 January 27, 2005 

Sample Description 

Macon Water Authority 

Wastewater, Composite, PPL GA 129, Rocky Creek Effluent, 01/11-01/12/2005, 11:50, received 01/13/2005 

Analytical 

Method 

EPA 200.7 

EPA206.2 

EPA 200.7 

EPA 213.2 

EPA200.7 

EPA 200.7 

EPA239.2 

EPA 245.1 

EPA200.7 

EPA270.2 

EPA 200.7 

EPA279.2 

EPA200.7 

Analyte Result Detection Limit Units 

Metals 


Total Antimony (Sb) 


Total Arsenic (As) 


Total Beryllium (Be) 


Total Cadmium (Cd) 


Total Chromium (Cr) 


Total Copper (Cu) 


Total Lead (Pb) 


Total Mercury (Hg) 


Total Nickel (Ni) 


Total Selenium (Se) 


Total Silver (Ag) 


Total Thallium (TI) 


Total Zinc (Zn) 


129 Priority Pollutants -Georgia 

BDL 5 

BDL 5 

BDL 1 

BDL 0.7 

BDL 5 

BDL 5 

BDL 1 

BDL 0.5 

BDL 5 

BDL 5 

BDL 5 

BDL 1 

29 10 

ug/L 

ug/L 

ug/L 

ug/L 

ug/L 

ug/L 

ug/L 

ug/l 

ug/L 

ug/L 

ug/L 

ug/L 

ug/L 

BDL- Below Detection Limit Page 1 of 1 
A N A L Y T I C A L S E R V I C E S, I N C . Sl Environmental Monitoring & Laboratory Analysis 


110 Technology Parkway Norcross, GA 30092 


{770) 734-4200 FAX (770) 734-4201 


Laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No. 188691·1 February 3, 2004 


Sample Description 


Macon Water Aulhority 


Wastewaler, Composile, PPL GA 129, Rocky Creek Effluent, 01/20-01/21/2004, 13:02, received 01/22/2004 


Analytical 

Method Analyte Result Detection Limit Units 

EPA 200.7 

EPA206.2 

EPA200.7 

EPA 213.2 

EPA 200.7 

EPA200.7 

EPA239.2 

EPA 245.1 

EPA200.7 

EPA270.2 

EPA200.7 

EPA279.2 

EPA200.7 

Metals 

Total Antimony {Sb) 

Total Arsenic {As) 

Total Beryllium (Be) 

Total Cadmium {Cd) 

Total Chromium {Cr) 

Total Copper (Cu) 

Total Lead {Pb) 

Total Mercury (Hg) 

Total Nickel (Ni) 

Total Selenium (Se) 

Total Silver (Ag) 

Total Thallium (TI) 

Total Zinc (Zn) 

Priority Pollutant Metals 

BDL 

BDL 

BDL 

BDL 

BDL 

0.005 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

0.04 

0.005 mg/L 

0.005 mg/L 

0.001 mg/L 

0.0007 mg/L 

0.005 mg/L 

0.005 mg/L 

0.001 mg/L 

0.0005 mg/L 

0.005 mg/L 

0.005 mg/L 

0.005 mg/L 

0.001 mg/L 

0.01 mg/L 

BDL • Below Detection Limit Page 1 of 1 
A N A L Y T I C A L S E R V I C E S, I N C 

Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA 30092 

Sl 

(770) 734-4200 FAX (770) 734-4201 

Laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No. 169451-1 January 30, 2003 

Sample Description 

Macon Water Authority 

Wastewater, Composite, PPL GA 129, Rocky Creek Effluent, 01/13-01/14/2003, 09:44, received 01/15/2003 

Analytical 

Method Analyte Result Detection Limit Units 

EPA 204.2 

EPA206.2 

EPA 200.7 

EPA 213.2 

:PA 200.7 

EPA 200.7 

EPA 239.2 

EPA 245.1 

EPA 200.7 

EPA270.2 

EPA 200.7 

EPA279.2 

EPA 200.7 

Metals 


Total Antimony (Sb) 


Total Arsenic (As) 


Total Beryllium (Be) 


Total Cadmium (Cd) 


Total Chromium (Cr) 


Total Copper (Cu) 


Total Lead (Pb) 


Total Mercury (Hg) 


Total Nickel (Ni) 


Total Selenium (Se) 


Total Silver (Ag) 


Total Thallium (TI) 


Total Zinc (Zn) 


Priority Pollutant Metals 

BDL 

BDL 

BDL 

BDL 

BDL 

0.009 

BDL 

BDL 

BDL 

BOL 

BDL 

BDL 

0.05 

0.005 mg/L 

0.005 mg/L 

0.001 mg/L 

0.0007 mg/L 

0.005 mg/L 

0.005 mg/L 

0.001 mg/L 

0.0005 mg/L 

0.005 mg/L 

0.005 mg/L 

0.005 mg/L 

0.001 mg/L 

0.01 mg/L 

BDL - Below Detection Limit Page 1 of 1 
A N A l Y T I C A l S E R V I C E S, I N C Sl Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX (770) 734-4201 

Laboratory Report 

Macon Water Authority 

PO Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No. 150600-1 March 12, 2002 

Sample Description 

Macon Water Authority 

Wastewater, Composite, Priority Pollutants GA 129, Rocky Creek Eff., 01/22-01/23/2002, 10:49, received 01/24/2002 

Analytical 

Method Ana lyle Result Detection Limit Units 

EPA204.2 

EPA 206.2 

oPA 200.7 

EPA 213.2 

EPA 200.7 

EPA200.7 

EPA239.2 

EPA 245.1 

EPA 200.7 

EPA 270.2 

EPA 200.7 

EPA 279.2 

EPA 200.7 

Metals 

Total Antimony (Sb) 

Total Arsenic (As) 

Total Beryllium (Be) 

Total Cadmium (Cd} 

Total Chromium (Cr) 

Total Copper (Cu) 

Total Lead (Pb} 

Total Mercury (Hg) 

Total Nickel (Ni) 

Total Selenium (Se) 

Total Silver (Ag) 

Total Thallium (TI} 

Total Zinc (Zn) 

Priority Pollutant Metals 

BDL 

BDL 

BDL 

BDL 

BDL 

0.013 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

0.05 

0.005 

0.005 

0.001 

0.0007 

0.005 

0.005 

0.001 

0.0005 

0.005 

0.005 

0.005 

0.001 

0.01 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

BDL - Below Detection Limit Page 1 of 1 
A N A L Y T I C A L S E R V I C E S, I N C 51 Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX {770) 734-4201 

Laboratory Report 

Macon Water Authority 

P.O. Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No.131164-1 January 15, 20 

Sample Description 

Macon Water Authority 

Wastewater, composite, Rocky Creek Effluent, 12/12-13/2000, 12:50pm, received 12/15/2000 

Analytical 

Method 

EPA200.7 

EPA 200.7 

EPA 200.7 

EPA 200.7 

EPA 200.7 

EPA 200.7 

EPA 200.7 

EPA 245.1 

EPA 200.7 

EPA 200.7 

EPA 200.7 

EPA 200.7 

EPA 200.7 

Analyte 

Metals 

Total Antimony {Sb) 

Total Arsenic (As) 

Total Beryllium (Be) 

Total Cadmium (Cd) 

Total Chromium (Cr) 

Total Copper (Cu) 

Total Lead (Pb) 

Total Mercury (Hg) 

Total Nickel (Ni) 

Total Selenium (Se) 

Total Silver (Ag) 

Total Thallium (TI) 

Total Zinc (Zn) 

Result 

Priority Pollutant Metals 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

0.04 

Detection Limit 

0.05 

0.03 

0.01 

0.01 

0.01 

0.02 

0.025 

0.0005 

0.02 

0.04 

0.01 

0.05 

0.02 

Units 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

BDL - Below Detection Limit Page 1 of 1 
A N A L Y T I C A l S E R V I C E S, ! N C Sl Environmental Monitoring & Laboratory Analysis 

110 Technology Parkway Norcross, GA 30092 

(770) 734-4200 FAX (770) 734-4201 

Laboratory Report 

Macon Water Authority 

P.O. Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Report No. 117078-1 February 1, 2000 

Sample Description 

Macon Water Authority 

Wastewater, composite, EPD 129 PP, RC Effluent, 01/12-13/2000, 13:29-13:36, received 01/14/2000 

Analytical 

Method Analyte Result Detection Limit Units 

129 Priority Pollutants- Georgia 

General Chemistry 

SM 3500-Cr D Hexavalent Chromium (Cr ' 6

) BDL 10 ug/L 

Metals 

EPA 200.7 Total Antimony (Sb) BDL 50 ug/L 

EPA200.7 Total Arsenic {As) BDL 30 ug/L 

EPA 200.7 Total Beryllium (Be) BDL 10 ug/L 

EPA 200.7 Total Cadmium (Cd) BDL 10 ug/L 

EPA 200.7 Total Chromium (Cr) BDL 10 ug/L 

EPA 200.7 Total Copper (Cu) BDL 20 ug/L 

EPA 200.7 Total Lead {Pb) BDL 25 ug/L 

EPA 245.1 Total Mercury (Hg) BDL 0.5 ug/L 

EPA 200.7 Total Nickel (Ni) BDL 20 ug/L 

EPA 200.7 Total Selenium (Se) BDL 40 ug/L 

EPA 200.7 Total Silver (Ag) BDL 10 ug/L 

EPA 200.7 Total Thallium {TI) BDL 50 ug/L 

EPA 200.7 Total Zinc (Zn) 110 20 ug/L 

BDL - Below Detection Limit Page 1 of 1 
Sl 
 ANALYTICAL SERVICES, INC, 


ENVIRONMENTAL MONITORING & LABORATORY ANALYSIS 

110 TECHNOLOGY PARKWAY • NORCROSS, GA 30092 

(770) 734·4200 • FAX (770) 734-4201 

LABORATORY REPORT 

Macon Water Authority March 3, 1999 

P. 0. Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek Report No. 104553-1 

Sample Description 

Water, composite, Rocky Creek, 02/09-10/99, 3:10-3:10, received 02/11/99 

RESULTS 

129 Priority Pollutants - Georgia 

Result 

Detection 

Limit 

Metals (ug/1) (ug/1) 

Total Antimony (Sb) (EPA 200. 7) .............. . 

Total Arsenic (As) (EPA 200.7) ............... . 

Total Beryllium (Be) (EPA 200. 7) ............. . 

Total Cadmium (Cd) (EPA 200.7) ............... . 

Total Chromium (Cr) (EPA 200. 7) .............. . 

Total Copper (Cu) (EPA 200. 7) ................ . 

Total Lead (Pb) (EPA 200. 7) .................. . 

Total Mercury (Hg) (EPA 245 .1) ............... . 

Total Nickel (Ni) (EPA 200. 7) ................ . 

Total Selenium (Se) (EPA 200. 7) .............. . 

Total Silver (Ag) (EPA 200.7) ................ . 

Total Thallium (Tl) (EPA 200. 7) .............. . 

Total Zinc (Zn) (EPA 200.7) .................. . 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

BDL 

100 

50 

30 

10 

10 

10 

20 

25 

0.5 

20 

40 

10 

50 

20 

BDL - Below Detection Limit 

-

A Unit of American Analytical Services, Inc. 
I ANALYTICAL SERVICES, INC. 

ENVIRONMENTAL MONITORING & LABORATORY ANALYSIS 

110 TECHNOLOGY PARKWAY • NORCROSS, GA 30092 

(770) 734-4200 • FAX (770) 734-4201 

LABORATORY REPORT 

Macon Water Authority 

P.O. Box 108 

Macon, GA 31202 

Attention: Mr. Mark Wyzalek 

Sample Description 

Wastewater, composite, RC 129PP, Final Effluent, 

received 02/27/98 

RESULTS 

Priority Pollutant Metals 

Metals 

Total Antimony (Sb) (EPA 200.7) .............. . 


Total Arsenic (As) (EPA 200. 7) ............... . 


Total Beryllium (Be) (EPA 200. 7) ............. . 


Total Cadmium (Cd) (EPA 200. 7) ............... . 


Total Chromium (Cr) (EPA 200. 7) .............. . 


Total Copper (Cu) (EPA 200. 7) ................ . 


Total Lead (Pb) (EPA 200.7) .................. . 


Total Mercury (Hg) (EPA 245.1) ............... . 


Total Nickel (Ni) (EPA 200. 7) ................ . 


Total Selenium (Se) (EPA 200. 7) .............. . 


Total Silver (Ag) (EPA 200.7) ................ . 


Total Thallium (Tl) (EPA 200. 7) .............. . 


Total Zinc (Zn) (EPA 200.7) .................. . 


March 16, 

Report No. 

02/25-26/98, 

Result 

(ug/1) 

BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


BDL 


1998 

92392-1 

12:50-12:46, 

Detection 

Limit 

(ug/1) 

50 


30 


10 


10 


10 


20 


25 


0.5 

20 

40 

10 

50 

20 

BDL - Below Detection Limit 

A Unit of American Analytical Services, Inc. 
HARBOR BRANCH ENVIRONMENTAL LABORATORY 

Trace Metals Analysis 

-

Client: Macon Water Authority Station ID: Rocky Creek Effluent Comp. 

Project!HPN NO.: Priority Pollutant Scan/62195 HSN ID: 62195003 

HRS Certification No.: E96080 and 96230 Work Order No.: 2195 

Sampled: [ 0/09/96 Received: I 0/10/96 

Data Released By: N. Myron Gunsalus Matrix: Enviromental Water 

Metal Method Date 

Digested 

Date 

Analyzed 

Results 

(mg/L) 

Qualil1e1· Detection Limit 

(mg/L) 

Antimony 200.7 I 0/16/96 10/17/96 ND 0.050 v 

Arsenic 200.7 I 0/16/96 10117/96 ND 0.030 ../ 

Beryllium 200.7 10/16/96 10/17/96 ND 0.010 _, 

Cadmium 200.7 I 0/16/96 10/17/96 ND 0.010 ./ 

Chromium 200.7 10/16/96 10/17/96 ND 0.010 " 

Copper 200.7 I 0/16/96 10/17/96 ND 0.020 ./ 

Lead 200.7 10/16/96 10117/96 ND 0.025 o/ 

Mercury 245.1 10/14/96 I 0/15/96 ND 0.00050 J 

Nickel 200.7 10/16/96 10/17/96 ND 0.020 ..J 

Selenium 200.7 10/16/96 10/17/96 ND 0.040 ..; 

Silver 200.7 10/16/96 10/17/96 ND 0.010 v 

Thallium 279.2 I 0/16/96 I 0/17/96 ND 0.050 1/ 

Zinc 200.7 10/16/96 10/17/96 0.074 0.020 ;/ 

ND - Not Detectable 
Attachment 2: 

Macon Water Authority, Rocky Creek Biosolids Mercury 

Data, Undated
0

0.5

1

1.5

2

2.5

3

3.5

4

Mercury (total) Biosolids RC_BIOSOLIDS Plot 1 of 1

MWA's Rocky Creek WRF analyses; mercury is one Units are mg/kg dry weighthe metals known to be caextended aeration activatedata submitted annually to US EPA in annual biosolidrequirements of 40 CFR 5
Attachment 3: 

Macon Water Authority, Status of MWA lines to Ocmulgee 

River from Rocky Creek POTW, January 24, 2003
AN AFFIRMATIVE ACTION/EQUAL OPPORTUNITY EMPLOYER

Macon Water Authority

790 Second Street – P.O. Box 108

Macon, GA 31202-0108

(478) 464-5620

Members

Frank C. Amerson Jr., Chair

Javors J. Lucas, Vice-Chair

Dorothy “Dot” C. Black

Joe Allen

Barbara Knight

Charles W. Bishop

Henry C. Ficklin

R.A. “Tony” Rojas

Executive Director

January 24, 2003 

VIA MAIL & FAX 404 362-2691 

Jeff Larson 

Program Manager 

Georgia EPD 

4220 International Parkway 

Suite 101 

Atlanta GA, 30354 

Dear Mr. Larson: 

Subject: Status of MWA lines to Ocmulgee River from Rocky Creek POTW 

This letter is being submitted as per your request concerning the status of MWA lines to the 

Ocmulgee River from Rocky Creek POTW. 

1. Until 1975 a MWA 30” gravity sewer line discharged to the Ocmulgee River. 

a. The MWA 30” line closely parallels two lines owned by Riverwood International 

along the service road from Riverwood International to the Ocmulgee. The MWA 

30” line lies south of the two Riverwood lines and terminates in the Ocmulgee 

River next to Riverwood’s discharge line and it is north of the current Rocky 

Creek NPDES discharge point by about 100 ft. 

b. When the Rocky Creek POTW came into service in 1975 the 30” line was 

abandoned and made inactive. A small MWA lift station was built to service only 

the sanitary sewer from Macon Kraft (now Riverwood International) and what 

was the Inland Container company; the lift station discharges into the force main 

from Riverwood International to Rocky Creek POTW. The 30” sewer line was 

terminated in the wet well of the lift station and bricked in so that no sewer 

discharge could flow to the Ocmulgee River. The first manhole just downstream 

of the lift station was filled with grout to further ensure no sewer discharge could 

occur through the abandoned line. 

c. Inspections of this 30” line confirm that it is abandoned and inactive. A break in 

the line near a creek crossing has been observed, at times of higher groundwater 

level due to higher Ocmulgee River level, to discharge groundwater inflow and 

infiltration. Inspection of the broken line on January 23, when the groundwater 

and Ocmulgee river level was lower showed no water in the line. Today (January 

24), when collection system personnel were going to repair the break for aesthetic
Page 2 of 2 January 24, 2003 

reasons, groundwater was found to be discharging due to higher river and 

groundwater levels. Collection system personnel will repair the break using brick 

and grout on the first day that the pipe is again dry. 

2. From 1975 to 1991 Rocky Creek POTW discharged to an area immediately adjacent to 

the facility. 

3. In 1991 a 54” line was put into service that conveys the Rocky Creek facility’s discharge 

to the Ocmulgee. This 54” line for most of its length parallels the abandoned 30” MWA 

line and lies south of it. Inspections of this line showed no discharge except for the 

permitted NPDES discharge.

It is my understanding that Riverwood International will be submitting their own information to 

you concerning the water line and discharge line owned by them. 

If any further information is required concerning this matter please do not hesitate to contact me. 

Sincerely, 

Mark Wyzalek 

Manager, Laboratory & Industrial Monitoring Services 

Office 478 464-5678, fax 478 745-9531 

cc: Tony Rojas, Terry Forrest, Frank Sanders, and Winton Evans - MWA 

 Marion Bard - Riverwood International, via mail and fax 784-4444