The former National Smelting and Refining Site consists of approximately 3 acres located near midtown Atlanta in an area known for its heavy industrial operations over the last century. The site was home to a secondary lead smelting facility that processed lead-acid batteries and lead-bearing scrap that operated from 1914 until 1984 when the facility went inactive. The site remained inactive and in disrepair until a site investigation conducted by the EPA in 1999 incited a Release Notification. In 2001 the US EPA released an Administrative Order of Consent demanding additional subsurface soil, sediment, and groundwater sampling and analysis for contaminants of concern (COCs) by the identified responsible parties.
In 2005-2006 a prospective purchaser became interested in redeveloping the property as a possible mid-to high-rise mixed-use development under the Georgia Brownfields Redevelopment Program. As consultant for the prospective purchaser, KEMRON supplemented former assessment activities at the site by conducting systematic surface and subsurface sampling of soil to accurately define volumes and extents of contaminated media. The assessment activities performed by KEMRON determined that soil at the site was extensively affected by releases from secondary smelting operations and burial of metal-containing materials. Petroleum affected groundwater and soil were present in the area of the former underground tanks on the southeast part of the property. The main Chemicals of Concern (COCs) detected at the site were metals, but VOCs, PCBs, and PAHs were also detected at notification concentrations.
Impacted soils span the subject site and extend into the water table at approximately 10 ft below ground surface (bgs) in various locations. During delineation activities a solid lead core was encountered at approximately 7 ft bgs in the north central portion of the site. Slag material was also encountered in the property’s southwestern quadrant and north central portion. The distribution of lead impacted soil is somewhat erratic and impact concentrations do not convey vertical trends. Due to the sporadic nature of the lead impacted soils, it was determined that segregating soils and spot digging “problem areas” would not be effective during a removal action. The erratic vertical and horizontal distribution of lead contamination across the site and extremely high concentrations known to be located at 10 ft below ground surface (bgs) would require a site-wide removal action to at least 10 ft bgs for the purpose of remediating the majority of the site to applicable remediation goals. Various areas could require removal to 15 ft bgs or more. The total estimated weight of material for removal and disposal in a Subtitle D and/or Subtitle C could be as much as 82,000 tons. This amount of soil removal and disposal would ultimately make the cost of conducting a full scale removal action not financially feasible in that it would significantly exceed the market value of the property.
The potential high cost of remediating this property has kept it unappealing to investors for over 20 years and could cause the property to remain an unusable eyesore; even as the surrounding properties are redeveloped into economically viable communities (Atlantic Station is adjacent to the property). As an alternative to a continued struggle between the regulatory agencies and identified responsible parties that has the potential to drag out for years, the prospective purchaser has offered to work with the US EPA and the GA EPD to redevelop the property under the Georgia Brownfields Redevelopment Program. The redevelopment will be designed to contribute to economic stimulus in the area through the addition of commercial and retail space producing a higher and better use of the subject property. While initiating this effort KEMRON is working closely with the US EPA and the GA EPD to produce alternative cleanup goals (Type 5 Risk Reduction Standards (RRSs)) for the site soils and groundwater that will allow for soil engineering controls and groundwater limitation of liability as an alternative to the substantial and costly soil excavation and disposal. The GA EPD agrees with this remedial approach and has approved a corrective action plan for the prospective purchaser. KEMRON and the prospective purchaser are moving forward with finalizing the remedial design and implementation plan. KEMRON will work closely with the building designers and construction contractors to ensure that any use of site after remediation activities are completed will preserve the integrity and effectiveness of the engineering controls.