United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/H06-88/028
March 1988
3EPA
Superfund
Record of Decision
Old Midland Products, AR
eNVSRONMENTAI
PROTECTION
AGENCY
DALLAS, TEXAS
I
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50277-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-88/028
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Old Midland Products, AR
First Remedial Action
5. Report Di
irt Date
03/24/88
7. Author(s)
8. Performing Organization Rept. No
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16.
Abstract (Limit:, 200 words)
Tne Old Midland Products site is an abandoned creosote and pentachlorophenol wood
preserving plant and sawmill, located in Ola, Yell County, Arkansas. The site is flat
wich a total area of approximately 37 acres. Between 1969 and 1970, Old Midland
Products was in operation treating wood with creosote. Effluents from the treatment
process containing PCP and polynuclear aromatic compounds were discharged into lagoons 1
or 3 and other lagoons via a moveable discharge pipe. Pond overflows have occurred with
drainage to the intermittent stream west of the lagoons. The land, originally owned by
the Old Midland Products Company, was sold in 1979 to the Plainview - Ola Economic Trust
Inc. Approximately 9,000 to 21,000 yd3 of soil, 850 yd3 of drainage sediments,
450,000 gallons of ground water, 620,000 gallons of lagoon fluids, and 2,770 yd of
lagoon sludges are contaminated with PCP and polynuclear aromatic hydrocarbons
(secondarily).
The selected remedial action for this site includes: onsite thermal destruction of
the contaminated surface soils, lagoon sludges, and drainageway sediments with onsite
disposal of waste residuals and a vegetated cover; and ground water pump and treatment
using carbon adsorption. Cost estimates for these actions have not yet been fully
developed and recovery enforcement action will be pursed at a later date.
17. Document Analysis a. Descriptors
Record of Decision
Old Midland Products, AR
First Remedial Action
Contaminated Media: drainage sediments, ground water, lagoon sludge
Key Contaminants: pentachlorophenol, polynuclear aromatic
b. Identifiers/Open-Ended Terms
COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
Jone
20. Security Class (This Page)
21. No. oLEages
'36"
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-j
(Formerly NTIS-35)
Department of Commerce'
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Old Midland Products, Yell County, Arkansas
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for this
site developed in accordance with Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and the
National Contingency Plan (40 CFR Part 300).
The State of Arkansas has concurred on the selected remedy.
(Letter attached)
STATEMENT OF BASIS
This decision is based upon the administrative record for the Old
Midland Superfund Site [index attached]. The attached index identifies
the items which conprise the administrative record upon which the
selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The major components of the selected remedy include:
o On-site thermal destruction of the contaminated surface soils, lagoon
sludges, and drainageway sediments. The soils, sludges, and sediments
will be cleaned to a level of 1 ppm total pentachlorophenol (PCP).
o Placement of the clean ash on the site. Covering the ash with a
vegetated soil layer.
o Collection and onsite treatment, using carbon adsorption, of the
contaminated lagoon water and groundwater.
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DECLARATION
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant
and appropriate and is cost-effective. The remedy satisfies the statutory
preference for remedies that employ treatment which permanently and
significantly reduces the toxicity, mobility, or volume of hazardous
substances as their principle element. Finally it is determined that
this remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Date Robert E. Layton Or., P.6<
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OLD MIDLAND PRODUCTS SITE
YELL COUNTY, ARKANSAS
MARCH 1988
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EXECUTIVE SUMMARY
The abandoned Old Midland Products site is located near the city of Ola,
Arkansas in Yell County. From 1969 to 1979 a creosote and
pentachlorophenol wood preserving plant and sawmill were operated at the
site.
Investigations show contamination present in surface soils, lagoon sludges,
and on-site drainageway sediments. The lagoon area, used to store spent
treatment fluid, broached an underlying clay formation into the weathered
shale. This facilitated localized groundwater contamination with a
lighter-than-water oil phase.
Several potential remedies were evaluated against the requirements of
the Superfund Amendments and Reauthorization Act of 1986. After presenting
proposed remedies for public review, EPA has selected the options
entailing on-site incineration of contaminated soils, sediments, and
sludges; and an accelerated pumping and treating of the contaminated
groundwater.
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Summary of Remedial Alternative Selection
Old Midland Products Site
Yell County, Arkansas
February, 1988
I. SITE LOCATION AND DESCRIPTION
The Old Midland Products site is an abandoned creosote and pentachloro-
phenol wood preserving plant and sawmill located near Ola, Arkansas in
Yell County (Figure 1). The site borders the north right-of-way of
Highway 10 and extends north to the southern right-of-way of Old Highway
10. The site is flat (2-3% slope) with a total area of about 37 acres.
Areas of concern include 7 process lagoons and a treatment building. .
The process lagoons range in area from 125 to 7200 square feet with
depths from 3.5 feet to 6 feet (See Figure 1). Most surface runoff is
to an on-site intermittent stream. The stream flows into the Petit
Jean Wildlife Management Area about three-fourths of a mile downstream.
Repeated tests show that the wildlife management area is not signifi-
cantly affected, if at all, by the site.
Site History
Old Midland Products is known to have been in operation from 1969 to
1979 as a wood preserving plant. However, the Environmental Protection
Agency (EPA) aerial photos indicate that the sawmill might have been in
operation as early as 1960. Operations included treating wood with
creosote and pentachlorophenol (PCP) to preserve the wood from bacterial
and insect degradation. The chemicals were generally forced into the
wood under pressure resulting in the release of lignin and tannin based
chemicals from the wood. The treated wood was probably allowed to dry
in open areas to the east and west of the lagoons and treatment building.
Effluent from the treatment process containing PCP and polynuclear
aromatic compounds (PNAs) were discharged into Lagoons 1 or 3 (see
figure 1) and other lagoons via a moveable discharge pipe. Pond
overflows have occurred with drainage to the intermittent stream west
of the lagoons.
The land, originally owned by the Old Midland Products Company, was sold
in 1979 to the Plainview-Ola Economic Trust Inc. The First State Bank
of Plainview is the lien holder for the Old Midland Products Co.
On December 10, 1983, the site was ranked by EPA and the Arkansas
Department of Pollution Control and Ecology (ADPCE) for consideration
as a Superfund site. Based on hazards posed by the lagoons and
contaminated soils the site was included on the second update of the
National Priorities List on July 16, 1984 with a Hazard Ranking Score
of 30.77.
Geology/Hydrogeology
The site is in the center of the Arkansas Valley and the Ouachita
Mountains regions. Geology of Yell County is dominated by outcrops of
the lower and middle Atoka Formation of the Pennsylvanian Age. The Atoka
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Formation consists primarily of interbedded gray/black shale and brownish
gray sandstone and siltstone. In the site vicinity the Atoka Formation
may be several thousand feet thick, with the shale constituting about
three-fourths of the thickness. The upper forty feet of soil/rock at
the site contain (in order of descending depth) silty clay down to about
15 feet, a layer of iron nodules less than 6" thick and a layer of
weathered shale about 20 feet thick. Below these layers an unweathered
or slightly weathered (but fractured) shale goes down thousands of feet.
The weathered and unweathered shale layers represent a single water
bearing zone. Groundwater in the area occurs under Artesian conditions
and flows through fractures, faults, bedding planes and weatered zones.
The shallowest water producing intervals occur in the weathered shale
at depths of 15 to 20 feet in a zone 3 to 5 feet thick.
The weathered shale, as well as the surface topography, slope to the
north-northwest. The hydraulic gradient slopes to the northwest with a
magnitude of 0.02 to 0.34 feet/foot. In general, groundwater movement
follows the general slope of the area water table. However, the
contaminant plume initially flows against this slope (see figure 1),
apparently following a fold, fault or channel, then is redirected to
follow the general water table of the area.
Five local water supply wells have been identified within 1500 feet of
the site. Well depths range from 80 to almost 300 feet. These five
wells, and the city of Ola water well, were sampled. The results showed
those wells were free from site related contaminants. The closest well
is located approximately 450 feet west-northwest of the lagoons at a
reported depth of 80 feet. The water bearing zone is then classified
as being a potential source of water for beneficial use (Class II B).
Remediation levels will reflect such.
Remedial Investigation Results
A remedial investigation (RI) was conducted at the Old Midland Products
site from April 1985 to November 1987. During the RI, samples were
collected from soil, sediments, sludges, air, surface water and ground
water to characterize the contamination, define the extent of contami-
nation and estimate the volume of contamination present at the site.
In addition, data were collected to characterize the hydrogeology,
hydrology, demography, and ecology of the site and area to allow
assessment of potential contaminant migration and risk to public health
and the environment.
During the RI, four deep (40 feet) and eight shallow (20 feet) groundwater
monitoring wells were installed. Six deep (40 feet) and eight shallow
(20 feet) piezometers were installed to monitor groundwater elevations
and hydraulic gradients. Soil boring samples were collected during the
installation of the monitoring wells and piezometers and at 2 additional
40 feet deep holes and 9 additional 18 foot deep holes.
Three exploratory trenches approximately 20 feet deep were dug a
total of 540 linear feet to further characterize the site's shallow
geology. Permeability was measured with 23 in-situ falling head tests
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and 15 laboratory falling head tests. Twenty-one soil particle size
analyses were performed. Sludge and water samples from each of the
seven lagoons, 22 sediment samples from the intermittent stream, 37
groundwater samples, 72 soil boring samples, and 138 surface/subsurface
soil samples were all chemically analyzed. An air analysis station was
placed onsite and was used to monitor site meteorological conditions for
one year. A pumping and recovery test was completed on the shallow
groundwater bearing zone.
A lagoon sludge stabilization test was completed and carbon treatability
tests were performed on lagoon water and groundwater.
Findings of the Remedial Investigation
Pentachlorophenol (PCP) is the most widespread contaminant at the site
followed by polynuclear aromatics (PNAs). Chlorinated dibenzo dioxins
and furans are present in the more concentrated wastes (such as lagoon
sludges and nonaqueous phase liquid). However, the established clean
up levels would treat then sufficiently. Trace levels of aromatic
hydrocarbons were also detected, although of limited spatial extent and
at concentrations that present no significant health or environmental
threats.
PCP was present in surface (0"-6") soil, subsurface (6-12") soil, deeper
soil (down to water bearing zone), drainageway sediments, surface water,
groundwater; lagoon sediments, and lagoon fluids. PNAs were detected
in surface soil, subsurface soil, deeper soil, drainageway sediments,
ground water, lagoon sediments, and lagoon fluids.
Table 1 presents tne maximun PCP concentrations observed and the
maximum concentration of a specific PNA observed per media.
Soil contamination is limited to the area around the lagoons and treat-
ment building and the soil beneath the lagoons. Drainageway sediments
were contaminated at concentrations from 1 to 10 ppm PCP from near the
northwest perimeter of the lagoon area downstream to south of Old Highway
10, an estimated distance of 1,680 feet. No significant contamination
was observed in offsite drainageway sediments.
Groundwater contanination is limited to the shallow ground water.
Contamination appears to be made up of a lighter-than-water nonaqueous
phase liquid, that covers an estimated area of 24,000 square feet.
Under static, nonpunping conditions most of the groundwater contamination
is within the upper 20 feet of soil/rock.. No indications of deeper
contamination were observed. Figure 2 illustrates the estimated areal
extent of groundwater contamination.
There is estimated to be approximately 9,000 to 21,000 cubic yards of
contaminated soil. The range is due to the uncertainty in depth of
contanination beneath the lagoons. There are approximately 850 cubic
yards of contaminated drainage sediments. Approximately 450,000 gallons
of groundwater are contaminated, as are about 620,000 gallons of lagoon
fluids. The contaminated lagoon sludges measure approximately 2,770
cubic yards.
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Table 1. Maximum Detected Concentrations (in parts per million)
MEDIA
Surface soil (0-6 in)
Subsurface soil (6-12 in)
Deeper soil (1-20 ft)
Drainageway sediment
Surface water
Groundwater, oil phase
Lagoon sludges
Lagoon fluids
MAXIMUM PCP
790
690
0.32
9.5
0.012
12,000
5,900
0.6
MAXIMUM PNAs
14,000
220
270
6.6
not found
5,100
38,000
2.2
MOTE: PNAs refers to a wide variety of compounds. Some, such as
phenanthene, are not harmful. Some, such as benzo(a)anthracene,
are carinogenic.
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Potential Impact of Site Contaminants on Human Health and the Environment
The environmental fate and transport of PNAs and PCP was assessed based
on the physical and chemical characteristics of these contaminants and
the geological and topographical characteristics of the site.
PNAs, due to their low water solubility (thus non-leachable), high
octanol/water partition coefficient, high soil adsorption coefficients,
and resistance to oxidation or hydrolysis make them highly immobile in
soils. Their low vapor pressure indicates they will not volatilize.
Therefore, migration of PNAs is expected to be extremely limited.
There is little information on the transport of PCP through the environ-
ment. The compound has a low vapor pressure and therefore is not likely
to volatilize readily. It is slightly soluble in water and adsorbs ta
sediments and soil, and therefore may be transported by soil and drainage-
way sediments.
The site presents potential current and future risks to public health
and the environment if no actions are implemented. The lighter-than-water
nonaqueous phase liquid plume in the shallow groundwater, direct contact
w^'-.h surface contaminants and the leaching of contaminants from lagoon
SL. .iments into the groundwater represent the primary risks. These
risks can be mitigated through treatment of contaminated soils, lagoon
liquids, sludges, and contaminated groundwater.
II. ENFORCEMENT
The enforcement goal for the EPA is to have those parties responsible
for the site contamination pay for the cleanup of the site. At least
one Potential Responsible Party (PRP) has been identified and the
Agency presently is searching for additional parties. Any PRPs would
be notified that they may undertake or participate in the chosen remedy.
If they decline involvement in the remedial action, EPA will fund the
design and implementation of the selected remedy. A cost recovery
enforcement action will be pursued at a later date.
III. COMMUNITY RELATIONS HISTORY
Initial community interest in the Old Midland Products site was high,
due in part to the cost of the remedial investigation/feasibility study
and the length of time before actual cleanup could begin. Approximately
35 people attended a public meeting in May 1986. Both EPA and the
Arkansas Department of Pollution Control and Ecology explained the
Superfund process, outlined the activities planned for the remedial
investigation, and responded to the citizen's concerns.
Upon completion of the feasibility study a public notice was released
on November 16, 1987. This notice summarized the various alternatives,
highlighted the proposed plan, announced the public comment period of
November 27 through December 31, 1987, and invited the public to a
meeting on December 9. Media coverage of this notice appeared in the
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Dardanell Post-Dispatch, Arkansas Gazette, and Arkansas Democrat. A
fact sheet was mailed to 85 area residents, local officials, and interested
citizens. Extra copies of all relevant documents are available in the
Yell County Courthouse, and Ola Community Center. Posters announcing
the public meeting were sent to all area businesses, churches, and the
Community Center.
Approximately 20 people attended the public meeting on December 9th.
There was no opposition expressed at the meeting or during the comment
period to EPA's proposed plan for onsite incineration and accelerated
recovery wells. Responses to the questions/comments received during
the comment period are outlined in Appendix A entitled Responsiveness
Summary.
IV. ALTERNATIVES EVALUATION
A. Evaluation Criteria
Section 121(a) through (f) of the Superfund Amendments and Reauthori-
zation Act (SARA) contains factors which EPA must consider in selecting
a remedy for a Superfund site. Section 121(b)l of SARA states a pre-
ference for certain items: EPA is directed to look at alternative
treatment technologies, the final selection is a remedial activity
which is protective of human health and the environment. "Remedial
actions in which treatment which permanently and significantly reduces
the volume, toxicity, or mobility of the hazardous substance as a
principal element, are to be preferred over remedial actions not
involving such treatment. The offsite transport and disposal of
hazardous substances or contaminated materials without such treatment
should be the least favored alternative remedial action where practicable
treatment technologies are available."
These factors, as well as other criteria used during the evaluation of
alternatives, are discussed below:
1. Consistency with Other Environmental Laws - Compliance with ARARs
In determining appropriate remedial actions at Superfund sites,
consideration must be given to the requirements of the various
Federal and state environmental laws, in addition to CERCLA as
amended by SARA. Primary consideration is given to attaining
applicable or relevant and appropriate Federal and State public
health and environmental regulations and standards, commonly
referred to as ARARs (Applicable or Relevant and Appropriate
Regulations). While many State and Federal laws may not be
legally applicable to the proposed remedy, they must be evaluated
to determine if the whole, or a portion, are relevant and
appropriate.
2. Reduction of Toxicity, Mobility or Volume
The degree to which alternatives employ treatment that reduces
toxicity, mobility, or volume must also be assessed. Relevant
factors are:
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o The treatment processes the remedies employ and materials
they will treat;
o The amount of hazardous materials that will be destroyed
or treated;
o The degree of expected reduction in toxicity, mobility,
or volume;
o The residuals that will remain following treatment,
considering the persistence, toxicity, mobility, and
propensity for bioaccumulation of such hazardous substances
and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of alternatives must be assessed
considering appropriate factors among the following:
o Magnitude of reduction of existing risks;
o Short-term risks that might be posed to the community,
workers, or the environment during implementation of an
alternative including potential threats to human health and
the environment associated with excavation, transportation,
and redisposal or containment;
o Time until full protection is achieved.
4. Long-terir. Effectiveness and Permanence
Alternatives are assessed for the long-term effectiveness and
permanence they afford along with the degree of certainty that
the remedy will prove successful. Factors considered are:
o Magnitude of residual risks in terms of amounts and concen-
trations of waste remaining following implementation of a
remedial action, considering the persistence, toxicity,
mobility, and propensity for bioaccumulation of such hazardous
substances and their constituents;
o The degree to which the treatment is irreversible;
o Type and degree of long-term management required, including
monitoring and operation and maintenance;
o Potential for exposure of human and environmental receptors
to remaining waste considering the potential threat to human
health and the environment associated with excavation,
transportation, redisposal, or containment;
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o Long-term reliability of the engineering and institutional
controls, including uncertainties associated with land
disposal of untreated wastes and residuals;
o Potential need for replacement of the remedy.
5. Implementability
The ease or difficulty of implementing the alternatives are
assessed by considering the following types of factors:
o Degree of difficulty associated with constructing the
technology;
o Expected operational reliability o^ the technologies;
o Need to coordinate with and obtain necessary approvals and
permits (e.g., NPDES, dredge and fill permits for off-site
actions) from other offices and agencies;
o Availability of necessary equipment and specialists;
o Available capacity and location of needed treatment,
storage, and disposal services.
6. Cost
The types of costs that should be assessed include the
following:
o Capital cost]
o Operation and maintenance costs;
o Net present value of capital and 0 & M costs;
o Potential future remedial action costs.
7. Community Acceptance
This assessment examines:
o Components of the alternatives that the community supports;
o Features of the alternatives about which the community has
reservations;
o Elements of the alternatives which the community strongly
opposes.
8. State Acceptance
Evaluation factors include assessments of:
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o Components of the alternatives the State supports;
o Features of the alternatives about which the State has
reservations;
o Elements of the alternatives under consideration that the
State strongly opposes.
9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against individual
evaluation criteria, the alternatives are assessed from the
standpoint of whether they provide adequate protection of human
health and the environment considering the multiple criteria. .
B. Description of Alternatives
Based on appearance and past site operations, the following structures
will be treated as contaminated with PCP and/or PNAs: yard offices A
and B, storage trailer, maintenance shop, wood storage shed, treatment
building, tanks A through E, and portions of the interior of the sawmill.
All these contaminated areas are addressed by this Record of Decision.
The conditions at the site dictated looking at alternatives to address
the site as two problems: (1) source control-cleaning the surface
soils, drainageway sediments, and lagoon water and sludges; (2) ground
water.
In conformance with EPA regulation, 40 CFR Part 300, also known as the
National Contingency Plan, the universe of possible applicable techno-
logies was screened to determine whether they might be appropriate for
this site. (See the Feasibility Study for details of this evaluation).
This set of possible technologies was then screened based on existing
site wastes and conditions, and their ability to minimize long term
threat to human health and the environment. The protection of workers
working onsite was also considered. This process highlighted 23 available
technologies. Then, from these 23 possible technologies, six source
control and five groundwater alternatives were chosen for more detailed
evaluation and comparison with respect to the nine remedy selection
criteria outlined above. The source control and groundwater remedies
were evaluated separately but they will be implemented concurrently.
Certain actions are common to all alternatives. For example, all existing
monitor wells, peizometers and water wells on the site were assumed to
be plugged and abandoned for cost estimating purposes except for monitor
well MW-ls. This well will be retained to provide an upgradient well
for post-remediation monitoring. The remedial action and any possible
future use of the site would present a risk of damaging the wells.
Plugging and abandonment of the wells will eliminate the risk of damage
to the integrity of the well seal and casing with the consequent risk
of contamination of the aquifer through the damaged well.
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C. SOURCE CONTROL ALTERNATIVES
As part of the source control alternatives, a carbon adsorption treatment
system will be used for decontaminating the liquid wastes for all alter-
natives except alternative I, which does not include any treatment, and
alternative VI, which recommends using UV/ Ozonatton.
The recovered oil from the oil-water separator will be sent to a
hazardous waste incinerator. The carbon will either be regenerated or
disposed of as residue from hazardous waste treatment unit.
ALTERNATIVE I. NO ACTION This alternative consists primarily of
restricting public access to the contaminated areas and monitoring the
site. The existing fence would be maintained and warning signs would
be installed. The site monitoring will involve periodic air and ground-
water sampling and analysis. This action would continue for at least
30 years.
ALTERNATIVE II, CONTAINMENT - This alternative involves in-situ solidifi-
cation of lagoon wastes; excavation of drainageway sediments, solidifi-
cation of drainage sediments if necessary, and placement of drainage
sediments in lagoons; then construction of a surface cap designed to
meet all pertinent regulations and statutes. Approximately 998,000
gallons of contaminated stormwater runoff during construction and 620,000
gallons of lagoon liquids, would be collected, treated, and discharged.
Any liquid discharges would be sent to the onsite stream. The discharged
water would conform to applicable or relevant and appropriate standards.
ALTERNATIVE III. ONSITE LANDFILL - Since there is adequate space available,
a landfill could be located on site. The landfill would have protective
top and bottom liners which satisfy all requirements and are protective
of hunan health and the environment. The site wastes (surface soils,
sediments, and sludges) would be stabilized then placed in the landfill.
The lagoon liquids would be collected, treated, and discharged.
The discharged water would conform to applicable or relevant and
appropriate standards.
ALTERNATIVE IV. ONSITE BIOLOGICAL TREATMENT - Alternative IV involves
onsite biotreatment of wastes using a combination of a liquid/solids
contact reactor and land treatment technologies. The reactor would be
used for the concentrated wastes (lagoon sediments) and landfarming
would be applied to the less contaminated soils and drainageway sediments.
An integral part of this remedial action would be securing a waiver to
the RCRA Land Ban as it impacts the proposed landfarming operation.
The lagoon liquids would be collected, treated and discharged. The
discharged water would conform to applicable or relevant and appropriate
standards. This action could require monitoring for up to 30 years.
ALTERNATIVE V, ONSITE INCINERATION - Alternative V is composed of
bringing to the site a transportable incinerator to destroy the wastes.
All soils, sediments and sludges contaminated with greater than 1 ppm
PCP, would be treated and returned to the site, as an ash. The ash
will be tested to insure it meets the clean-up standards described on
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10
page 6. As with all source control remedies, except no action, the
lagoon liquids will be collected, treated and discharged. The discharged
water would conform to applicable or relevant and appropriate standards.
This action would take two years to implement.
ALTERNATIVE VI. ONSITE INCINERATION WITH ULTRAVIOLET/OZONATION - Same
remedy as alternative V but using UV/Ozonation as the water treatment
system instead of carbon adsorption. It was initially felt UV/Ozonation
could be a more cost-effective water treatment alternative. Now it is
projected to be similar in effectiveness to Alternative V. This action
could take for up to seven years to implement.
0. GROUNDWATER ALTERNATIVES
ALTERNATIVE 1. NO ACTION - Includes only groundwater monitoring. No
remedial actions would be implemented to address groundwater contamination.
This action would be continued for at least 30 years.
ALTERNATIVE 2. CONTAINMENT - This alternative consists of constructing
a soi1-bentonite slurry wall barrier to such depth that the wall surrounds
the plume. A surface cap would also be constructed to cover the contami-
nated surface area.
ALTERNATIVE 3, RECOVERY UELLS - MINIMAL PROGRAM - This alternative
includes installation of two recovery wells, completed to depths of just
below the oil phase. The groundwater treatment system would include an
oil-water separator and a carbon adsorption system which would treat
the water. The cleanup is estimated to take between 5-10 years.
ALTERNATIVE 4, RECOVERY WELLS - ACCELERATED PROGRAM - This remedy is
the same as Alternative 3 but proposes four wells instead of two.
The accelerated program reduces cleanup time from 5-10 years to 1-5
years.
ALTERNATIVE 5, FRENCH DRAIN - The french drain and sump would be constructed
on the downgradient edge of the plume. At the sump discharge there
would be an oil-water separator with a carbon adsorption unit. This
method could take up to 30 years. This is expected to be less effective
than alternatives 3 and 4 in recovering the oil phase because of the
reduced ability to draw down contaminants to the french drain.
E. EVALUATION OF ALTERNATIVES
The degree that the remedial alternatives meet the nine selection
criteria described earlier is contained in Table 2. The following
symbols were assigned to compare remedial selection criteria:
+ Alternative would exceed a criterion in comparison to other
alternatives.
0 Alternative achieves selection criteria.
- Special efforts will be necessary in the design of the remedy
to meet the selection criterion.
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11
( ) Blank indicates no discernable opinion.
1. COMPLIES WITH ARARs (i.e., meets or exceeds applicable or relevant
and appropriate Federal and state requirements)
SOURCE CONTROL
The no action remedy was rated "-" because it does not meet the
intent of the RCRA and Superfund requirements for remediation of
a hazardous waste site. Containment can meet requirements, but it
would likely be ineffective due to the fractured site geology.
Containment was given "0". The National Contingency Plan provisions
to respond to a threat of release are not satisfied by this remedy.
The onsite landfill was rated "-" because the existing levels of
dioxins and furans possibly exceed the allowable land disposal
concentrations for this waste. According to contemporary laboratory
and literature data, biological treatment is uncertain for these
particular wastes. Thus, the rating is ( ).
Incineration was rated the highest for this criterion (+) because in
addition to exceeding all relevant or applicable and appropriate
environmental regulations, this alternative most effectively meets
the intent of SARA for permanently addressing the site contaminants.
GROUNDWATER
No action would not attain ARARs and would not reduce existing
contamination and thus received a "-". Containment was given a "-"
because the subsurface geology would prevent it from achieving the
ARARs. The two punping alternatives were given "+" due to their
ability to acnieve the specified clean up levels. The french drain
was given a "-" because it is not expected to be able to attain
clean up levels within the plume.
2. REDUCES MOB.. TOX., VOL. (i.e., Reduces the Mobility, Toxicity, or
Volume of Waste)
SOURCE CONTROL
No action was rated "-" for mobility, toxicity, and volume reduction
because it does nothing to address any of the stated criteria.
Containment was rated""-" for mobility reduction due to the fractured
subsurface geology. Percolation would be reduced but with negligable
impact on the subsurface flow. Containment would not reduce the
toxicity of the waste, thus it received a "-" for toxicity reduction.
The contaminated volume would not decrease, therefore containment
receives a "-" for volume reduction.
Onsite landfill was rated "0" for mobility reduction because this
alternative could reduce percolation and thus the mobility of contami-
nants; for reduction of toxicity and volume the landfill alternative
was rated "-" because neither of these are reduced. Onsite biological
treatment, due to the relative uncertainity associated with this
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12
i
remedy for reducing the toxicity of these wastes, was given a "-".
(Mobility might be reduced with the biotreatment alternative, and so)
received a "+". Volume would not reduced since there would be soil
addition, thus it received a "-". The thermal destruction alternatives
(with carbon adsorption and UV/ Ozonation) were given ratings of "+"
due to the complete destruction achieved by these remedies. For
both remedies, mobility, toxicity, and volume would be reduced.
Thus, all three categories for both alternatives were rated positively.
GROUNDWATER
No action was given a "-" because ther.5 would be no reduction of
mobility, toxicity, or volume. Containment was given "-" ratings
since the fractured subsurface geology would render the slurry walls
ineffective for reducing mobility, toxicity, or volume.
The two pump and treat methods were given "+" ratings because they
reduce the mobility, toxicity and volume of the plume. The french
drain would not be as effective due to the reduced ability to draw
the contaminants down to the french drain, thus it was given "0" for
all three categories.
3. SHORT TERM EFFECTIVENESS
SOURCE CONTROL
No action leaves contaminated seeps and waste exposed to the public,
thus the no action rated "-". Tne simple containment remedy (Alt.
2) was judged capable of being designed to present essentially no
risk to workers or residents. It would reduce direct contact threats
but would not address groundwater problems. It received a neutral
rating "0". Onsite landfilling was also assigned a "0" because
although the handling would require additional attention, standard
safety precautions would adequately protect the site workers.
Onsite biotreatment was assigned a "-" because of the uncertainty
of the ability of this technology to be effective. The on-site
thermal treatment options were assigned a single "0" because potential
risks can be prevented through careful design and standard safety
precautions.
GROUNDWATER
No action and containment received negative ratings ("-"). No action
would do nothing to address site risks. Based on the subsurface
geology, containment would not be effective. The minimal pump and
treat was given a "0" because, although better than the first two
alternatives, it is not as effective in the short term as the
accelerated program. The accelerated program would be most effective
in the short term, thus it received a "+". The french drain alternative
received a "0" rating. This alternative would be marginally effective
in the short term.
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13
4. LONG TERM EFFECTIVENESS
SOURCE CONTROL
No action will do nothing to reduce long term risks to human health
and the environment thus received a rating of "-". Containment is
rendered ineffective due to the subsurface geology thus it receives
a "-". Onsite landfill ing leave the waste in place, the toxicity is
not reduced, and the volume is increased, these alternatives therefore
each merited a "-". Uncertainties with the ability of biotreatment
to treat the site specific wastes lead to a "-". Because of the
added assurance of complete destruction of the waste with thermal
destruction technology, those remedies were rated "+".
GRO'iNDWATER
No action would have no long term effectiveness, therefore it received
a "-". Containment would be ineffective in the long term due to the
fractured subsurface geology, thus it also received a "-". Minimal
pumping and treatment will be effective in the long term, thus it
received a "+". The accelerated pump and treat program would be the
most effective and received a "+". The effectiveness of the french
drain system is seriously questionable, thus received a "-".
5. IMPLEMENTABILITY
SOURCE CONTROL
No action alternative is easy to implement, it receives a "+".
Containment is implementable, as is the landfill. They both
received "0". Biotreatment would require more attention during
design than other remedies to ensure implementability (acquiring a
waiver to the Land Ban) and was therefore given "-". The thermal
destruction alternatives are both implementable, they both received
a "0".
GROUNDWATER
No action is easy to implement and received a "+". Containment is
implementable and receives a "0". The two pump and treat methods
are implementable and received "0". The french drain is not
practical to implement because the depth required broaches the
current water bearing zone, it received a "-".
6. COST
Estimated costs for each alternative are summarized in Table 2.
7. COMMUNITY ACCEPTANCE
From prior meetings and correspondence, it is evident that local
residents want something done about the problem (i.e. not the "no
action" remedy). Thermal destruction, without UV/Ozonation, was the
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14
only source control remedy that the community discussed and accelerated
pumping and treatment was the only ground water remedy discussed.
These were both accepted by the community, therefore they merited a
"0". Ratings for all other remedies are left blank.
8. STATE ACCEPTANCE
The State (Arkansas Department of Pollution Control and Ecology)
has concurred with the onsite incineration and accelerated pump and
treatment for groundwater. These, therefore, received a "+". The
other remedies were judged to be less desirable, they receive "0".
9. Overall Protection of Human Health and the Environment
SOURCE CONTROL
Due to the health threat posed by untreated waste remaining on-site,
the no action, containment, and landfill alternatives received a
rating of "-". The uncertainities associated with biotreatment lead
to a rating of "-". The thermal destruction remedies received the
highest rating of "*", because they result in elimination of the
organic contaminants. The thermal treatment unit would be designed
to neet RCRA standards. Destruction of the organic contamination
will reduce the potential for human exposure.
GROUNDWATER
No action is not protective and receives a "-". The subsurface
geology is fractured such that containment would be rendered
ineffective; thus, containment received a "-". The two recovery
well programs receive "+" because these are the most effective in
addressing the contamination. Since the effectiveness of the french
drain is questioned, its protection is questioned. It receives a
II M
V. PROPOSED REMEDY: V. ONSITE THERMAL DESTRUCTION OF CONTAMINATED
SOILS, SLUDGES, AND SEDIMENTS and 4. ACCELERATED PUMP AND TREATMENT
OF THE GROUNDWATER.
Considering the current and potential site hazards, and also taking
into account the unique hydrogeology of the site, EPA selects and ADPCE
concurs with the above remedy. This remedy consists of: excavating
the contaminated drainageway sediments and surface soils, dewatering
the lagoons and removing the sludges, then thermally treating and
destroying these wastes. The air emissions of the thermal destruction
unit will be monitored to ensure safe operation. The systems will
be designed to meet all ARARs. Soils with greater than 1 ppm PCP
will be excavated and incinerated. A sampling strategy will be
developed during the Remedial Design phase of the project to ensure
attainment of this soil cleanup level. Treated water will achieve
two cleanup levels: the maximum contaminant level goal of 0.2 mg/1
for PCP; the 1 x 10 ~5 increased cancer risk concentration of 28
ng/1 for PNAs. The contaminated groundwater will be pumped and the
-------
15
oil will be separated from the water. The water will be treated
with carbon adsorption and the oil will be recycled if possible. If
it is not possible to recycle the groundwater will be pumped and the
oil will be separated from the oil it will be thermally destroyed.
The "spent" carbon will be disposed of appropriately. The site air
and groundwater will be monitored to ensure that an adequate cleanup
has been completed.
Rationale
This alternative is protective and cost-effective, and attains
applicable or relevant and appropriate Federal and state standards.
It utilizes permanent solutions and treatment technologies that
reduce contaminant mobility, toxicity, and volume to the maximum
extent practicable.
The value of this remedy is three-fold: the acceptance and cooperation
of all parties; relatively low cost for permanent treatment; finally
thermal destruction would allow for a walk-away remedy.
Cleanup Level
The soils, sludges, and sediments will all be addressed to a level
of 1 ppm PCP. This level is derived from the Arkansas Water Quality
Regulation # 2, which has been determined to be the most stringent
existing regulation. Attached is a letter from ADPCE stating that
this regulation has been sufficiently promulgated and consistently
enforced. This level is expected to clean the site to a 1x10
incremental cancer risk level. It is planned to excavate at least
13,000 cubic yards of soils, sludges, and sediments. This clean-up
level will be verified with periodic sampling during excavation.
This sanpling scenario will be further delineated in the Remedial
Design phase of the project.
The total PCP cleanup level of 1 ppm is sufficiently stringent so that
coexisting PNA contaminants will be destroyed to concentrations well
below those that present any significant threat to the public health
or environment. The PNA clean-up level achieved is expected to
exceed cleanup levels at Superfund sites where PNAs are the main
contaminant of concern.
The lagoon water and the groundwater will be treated to two clean-up
levels: For PCP, a health based goa1> of 0.2 mg/1, established by the
Safe Drinking Water Act; for PNAs the 1 x 10 cancer risk level,
from EPA's Ambient Uater Quality Criteria. It is estimated that
1.07 million gallons of lagoon water and groundwater will have to
the pumped and treated. This volume verification will also be outlined
in the Remedial Design phase.
The reasons for elimination of the other remedies are as follows:
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16
SOURCE CONTROL
ALTERNATIVE I, NO ACTION - This alternative is not protective of
public health and the environment. It meets neither the intent of
RCRA nor SARA.
ALTERNATIVE II, CONTAINMENT - Due to the site subsurface geology, a
slurry wall, and thus this alternative, is rendered ineffective.
The underlying formation is weathered and fractured shale. The cost
associated with this alternative is high compared to its level of
protection.
ALTERNATIVE III, ONSITE LANDFILL - This remedy is not permanent
treatment and is not "walk away". It does not provide long term .
protection and would require perpetual operation and maintenance.
The cost relative to alternative V is high considering the level
of protection for the environment and public health offered by
Alternative III. Since this is considered regulated waste, compliance
with the RCRA Land Disposal Restrictions is required. Use of a
landfill violates the Land Ban, therefore this remedy is rejected.
ALTERNATIVE IV, ONSITE BIOLOGICAL DEGRADATION - The effectiveness of
this alternative is questioable. Because of the uncertainity associated
with this alternative, and the high cost, which includes a contingency
for process failure, this alternative was viewed as less attractive
than the proposed action. The cost savings is not significant
compared to tne uncertainity in the technology.
ALTERNATIVE VI, ONSITE THERMAL DESTRUCTION WITH UV/OZONATION - This
is the same remedy as Alternative V except the water would be treated
with UV/Ozonation instead of carbon adsorption. It was initially
thought that UV/Ozonation could be a more effective water treatment
alternative; this was, however, found not to be the case. Since the
UV/Ozonation costs were estimated to be higher than those for carbon
adsorption, the selected alternative is preferred.
GROUNDWATER
ALTERNATIVE 1, NO ACTION - Same as no action above.
ALTERNATIVE 2, CONTAINMENT - Same as containment above.
ALTERNATIVE 3, PUMP AND TREAT, MINIMAL - This is the same as
alternative 4, the selected alternative, but at a greater cost and
more time since this remedy only utilizes two pumps.
ALTERNATIVE 5, FRENCH DRAIN - Installation may not be practical due
to the depth required by the system. This depth is lower than the
artesian head of the water bearing zone. This alternative is also
less effective at reducing mobility, toxicity, and volume than
alternative 4 and it is more expensive.
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17
Consistency with the National Contingency Plan (NCR) and the Provisions
of the Superfund Amendments and Reauthorization Act of 1986 (SARAT
The proposed remedy provides adequate protection of public health,
welfare, and the environment. This alternative is also consistent with
the National Contingency Plan (NCP), in 40 CFR 300.68(H)(2)(iv) and
(vi), (Federal Register, 1985) which requires:
(iv) An assessment of each alternative in terms of the extent to which
it is expected to effectively mitigate and minimize threats to and
provide adequate protection of public health, welfare and the
environment.
(vi) An analysis of any adverse environmental impacts, methods for
mitigating these impacts, and costs of mitigation.
Additionally, the long-term effectiveness factors cited in SARA Section
§121(b)(l) were addressed. These include:
A) The long-term uncertainties associated with land disposal;
B) The goals, objectives, and requirements of the Solid Waste Disposal
Act;
C) The persistence, toxicity, mobility, and propensity to bioaccumulate
of site hazardous substances and their constituents.
D) Short- and long-term potential for adverse health effects from human
exposure;
E) Long-term maintenance cost;
F) The potential for future remedial action costs if the remedial action
in question were to fail; and
G) The potential threat to human health and the environment associated
with excavation, transportation, and redisposal, or containment.
Operation and Maintenance (O&M)
Site operation and maintenance will include a 1 year groundwater and
air monitoring and analysis program.
Future Actions
" ' " '" * a
No future remedial actions are anticipated after completion of the
proposed remedy. The selected remedial action is considered permanent.
If, however, significant unforeseen off-site contamination occurs as a
result of the site, appropriate remedial measures will be taken. As
stated under the O&M section, the site will be monitored for 1 year
to ensure the reliability of the implemented remedial action.
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18
Remedial Action Schedule
Approve Remedial Action (sign ROD)
Complete Enforcement Negotiations
Obligate Funds to Begin Remedial Design
(assuming the PRPs do not take over)
Complete Design
Obligate Funds to Start Remedial Action
Complete Remediation
(Depending on ground water clean-up)
March 1988
July 1988
July 1988
October 1989
October 1989
April 1991
-------
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STATE OF ARKANSAS
DEPARTMENT OF POLLUTION CONTROL AND ECOLOGY
8001 NATIONAL DRIVE. P.O. BOX 9583
LITTLE ROCK. ARKANSAS 72209
PHONE:(501)562-7444
March 21, 1988 ac
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Dr. Allyn M. Davis, Director £5 ** ^.P-',
Hazardous Waste Management Division (6H) c £ r^-rn
U.S. EPA, Region VI £ 2^
1445 Ross Avenue, Suite 1200 3 3 Sm
Dallas, TX 75202-2733 z -^ ^O
§ . " 5
Dear Dr. Davis: ^ S
o
RE: Old Midland Products Co.
Record of Decision (ROD)
I received the draft ROD for the Old Midland Superfund site under
your transmittal letter of February 23, 1988, which requested our
concurrence with the proposed remedy. This letter serves notice of
our concurrence with the proposed remedy which includes on-site
thermal destruction of contaminated soils, sludges, and sediments
and accelerated pumping and treatment of the groundwater.
However, one issue which we feel deserves additional investigation
regards Comment #2 in the Responsiveness Summary-Section II. As
stated in EPA's response, we did perform more sampling to the north
of Old Highway 10 and in areas of Keeland Creek above and below the
confluence of Keeland Creek and the ditch draining from the site.
While the results indicate that the constituents of concern do not
exist above the ROD limits of concern, we feel that additional
investigation in this area is justified during the Remedial Design
Phase. We would propose that remaining funds from the original
Remedial Investigation funding allocation be used to further
document the existence or nonexistence of significant levels of
contaminant migration from the Old Midland site. The funds
remaining should be adequate for this purpose and would be
implemented concurrently with the Remedial Design Phase.
Should you have any questions in this regard, please call my staff
or me at (501) 562-7444. We look forward to the success of this
project.
Sincerely,
Paul Means
Director
PM:fw:davismidland
cc: Mike Bates, ADPC&E
-------
Responsiveness Summary
Old Midland Products
Ola, Arkansas
This Community Relations Responsiveness Summary has been prepared to provide
written responses to comments submitted regarding the proposed plan of action
at the Old Midland Wood Products hazardous waste site. The summary is divided
into two sections:
Section I. Background of Community Involvement and Concerns. This section
provides a brief history of community interest and concerns raised during
the remedial planning activities at the Old Midland site.
Section II. Summary of Major Comments Received. The comments (both oral
and written) are summarized and EPA's responses are provided.
I, Background of Community Involvement
In June 1984, the National Campaign Against Toxic Hazards listed the Old
Midland Products site as a candidate for Superfund action. Three months
later, in September 1984, Representative James Florio of New Jersey listed
the Ola site among those he said posed a public hazard. The local press
(the Yell County Record and the Dardanelle Post Dispatcher) and the state-
wide newspapers (the Arkansas Gazette and the Arkansas Denvpcrat) gave some
coverage to the events at the site. Compared to other Superfund sites in
the State, the coverage was modest.
Community interviews were conducted by the Arkansas Department of Pollution
Control and Ecology (ADPC&E) and an approved Community Relations Plan was
released in August 1985. On May 8, 1986, ADPC&E held a public meeting at
the Ola Coimunity Center. The purpose of the meeting was to announce the
start of the remedial investigation. About 35 residents attended and voiced
their concerns regarding the lengthy Superfund process and requested that
the surface contamination be removed immediately. An information bulletin
addressing the citizens' concerns was mailed by EPA shortly after the meeting.
II. Summary of Major Comments Received
The press release and Proposed Plan fact sheet announcing the public comment
period and the public meeting was issued on November 16, 1987. The comment
period began on November 27 and ended December 31, 1987. A public meeting
was held with 20 area residents and local officials on December 9 at the Ola
Community Center to explain tHe results of the remedial investigation and to
outline the various alternatives presented in the Feasibility Study. Twenty
people from the area attended the meeting, and six residents made oral state-
ments or asked questions. Written comments or questions were received from
an additional citizen.
-------
The residents and local officials do not oppose the proposed plan of onsite
incineration/carbon adsorption and (accelerated) recovery wells. Several
people expressed an interest in a permanent remedy that would allow the site
to be reused.
During the public comment period, there were comments/questions regarding
the following:
Comment II;
What is the proposed timetable for the proposed remedy?
EPA response: Once the remedy is selected, the engineering designs or blue-
prints for the actual remedy will be developed. This is expected to take
about 18 months. Estimated time for the groundwater cleanup is from one to
five years, due to the uncertainty of the existing conditions and pumping
ability. The incineration process should take about 18 months also. Ground-
water treatment and incineration would take place simultaneously.
Comment 12
Several years ago, a hard rain and subsequent flood caused water from the
site to overflow past the railroad tracks and Old Highway 10 into Keeland
Creek. The trees along the creek died. What samples were taken in this
area and will it be cleaned up also?
EPA response: Trace amounts of the contaminants from Old Midland were found
on the south side of Old Highway 10, and soil samples were taken further
north of Old Highway 10. The Arkansas Department of Pollution Control and
Ecology has further sampled the area in question.
Based on the comments expressed at the public meeting, additional offsite
samples were collected. This sampling event included Keeland Creek all the
way down to the Petit Jean Wildlife Management Area. Based on the results
of this sampling, there is currently no significant downstream migration.
Comment 13
Was an Environmental Impact Statement prepared as required by the National
Environmental Policy Act (NEPA)?
EPA response: Not as a separate document. The Remedial Investigation
report, Feasibility Study report and Record of Decision incorporate the NEPA
requirements.
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Conrnent 14
Low level toxic chemicals may be present in the discharge water during
cleanup and these chemicals could affect the Santa Fe Ridge Waterfowl Area.
Because of the higher accumulative retention for ducks and other wildlife,
the chemicals could enter the foodchain or endanger the area's habitat.
Will EPA monitor the waterfowl and other wildlife during cleanup?
EPA response: No monitoring of the wildlife is planned. The water discharged
from the site will be treated to meet drinking water standards which will not
pose a threat to area ducks or other wildlife.
Comment #5
The Santa Fe Ridge Waterfowl Area provides habitat needs of wintering water-
fowl until nesting migration begins in March, when the impoundment is drained.
Will EPA reduce or minimize water discharges into Keeland Creek during the
October-March period?
EPA response: It is not anticipated that the amount of water discharged into
Keeland Creek will harm the needs of any wildlife.
Comment 16
Can the Dardanelle Library be included as an official repository for the Old
Midland site?
EPA response: Yes. Copies of the re-nedial investigation/feasibility study
have been placed in the Dardanelle Library and the library will continue to
receive documents regarding Old Midland.
Comment 17
Once the cleanup is completed, can the property be used for production and/
or will it be returned to the owners?
EPA response: Site clean-up goals are to reduce contaminant concentration
to 1 part per million total pentachlorophenol for the treated surface soils.
This is estimated to allow people to participate in any activities on the
site for 70 years and have only a 1 in 100,000 chance of contracting cancer.
EPA remedial actions do not consider future land use. EPA has not taken
title to the property and has not considered how the property will be used,
pending completion of the remedial action. The owners, however are among
those "potentially responsible parties" that will be offered the opportunity
to execute the chosen remedy under court decree. If EPA and ADPC&E fund the
clean-up, those funds can be recovered from the land owners.
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Comment 18
Only a small portion of the property is contaminated. Could the "new mill"
area which is not contaminated be used now or while the cleanup is in process?
EPA response: No, the "new mill" area is currently projected as the location
for the thermal destruction system.
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OLD MIDLAND PRODUCTS
ADMINISTRATIVE RECORD INDEX
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DOCUMENT NUMBER:
8-1-85
Sampling Analysis Data
Spectrix Corporation
Pat Hammack, BSD
U.S. Environmental Protection Agency Region VI
Crganics Analysis Data Sheets
8-85
Work Plan
Gary Martin, Doice Hughes
Arkansas Department of Pollution Control & Ecology
Jim Peronto
U.S. Environmental Protection Agency Region VI
Final Work Plan for Old Midland Products Co.
71
1-13-86
Sampling Analysis Data
R. F. Weston, Inc.
Pat Hamnack, ESD
U.S. Environmental Protection Agency Region VI
Organic Analysis Data Sheets, Case No. 5445
223
6-5-86
Correspondence
Dick Whittington
U.S. Environmental Protection Agency Region VI
Senator Stanley Ross
Arkansas Senate
Fact Sheet, Cost Proposal, Old Midland Products
5
7-2-86
Intra-Agency
Jim Peronto
U,S. Environmental Protection Agency Region VI
Steve Gilrein
U.S. Environmental Protection Agency Region VI
Record of Meeting - Onsite Audit of Lab
3
DFW6H/027
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OLD MIDLAND PRODUCTS
Administrative Record Index
fiNyiRONMENTAl
PROTECTION
AGENCY
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DOCUMENT NUMBER:
BAitAS, TEXA8
UBRARY
7-10-86
Sampling and Analysis Plan
Dennis Reece
IT Corporation
Gary Martin
Arkansas Department of Pollution Control and Ecology
Site Investigation/Feasibility Studies, Old Midland
Products Co. Site
91
7-15-86
Correspondence - Interagency
Jim Peronto
U.S. Environmental Protection Agency Region VI
Doice Hughes
Arkansas Department of Pollution Control and Ecology
Followup Comment on Old Midland Products
4
9-9-86
Sampling and Analysis Plan
Dennis Reece
IT Corporation
Gary Martin
Arkansas Department of Pollution Control and Ecology
Quality Assurance Project Plan RI/FS
78
10-87
Remedial Investigation Report - Vol I of II
Dennis Reece
IT Corporation
Doice Hughes
Arkansas Department of Pollution Control and Ecology,
and U.S. Environmental Protection Agency Region VI
Final Report, Remedial Investigation, Volume II
DFW6H/027
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OLD MIDLAND PRODUCTS
Administrative Record Index!
DOCUMENT DATE:
DOCUMENT TYPE:
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RECIPIENT AFFILIATION:
DESCRIPTION:
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DOCUMENT NUMBER:
10-87
Remedial Investigation Report - Vol II of II
Dennis Reece
IT Corporation
Doice Hughes
Arkansas Department of Pollution Control and Ecology,
and U.S. Enviromental Protection Agency Region VI
Final Report, Remedial Investigation, Volume 1
10-87
Feasibility Study
Dennis Reece
IT Corporation
Doice Hughes
Arkansas Department of Pollution Control and Ecology,
and U.S. Environmental Protection Agency Region VT
Final Report, Feasibility Study
DFW6H/027
DFV76H/027
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