r
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-88/036
June 1988
Superfund
Record of Decision:
Industrial Waste Control, AR
PROTECTION
AGSNCY
OM.LA.S, TEXAS
UHUW
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'30272-101*
RCPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-88/036
4. Titta and Subtitl*
SUPERFUND RECORD OF DECISION
Istrial Waste Control, AR
t Remedial Action - Final
7. Author(s)
3. Recipient's Accession No.
5. Report Date
06/28/88
8. Performing Organization Rept. No.
9. Performing Organization Nam* and Address
10. Project/Task/Work Unit No.
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
1C. Abstract (Limit: 200 words) ~~~~
The 8-acre Industrial Waste Control (IWC) site, an abandoned coal strip mine, is a
closed industrial waste landfill about 8 miles southeast of Fort Smith'near Jenny Lind,
Sebastian County, Arkansas. Landfilling operations began, in the late 1960s or early
1970-s and primarily dealt with municipal refuse and debris, and industrial trash. In.
August 1974, the site was purchased by Grady Shipley and granted an industrial land'fill
by the Arkansas Department of Pollution and Ecology. The site received a wide
iety of liquid wastes (including methylene chloride, phenols, cresylic acid, and
paints), solid wastes, and sludges. In addition, the site possibly contains about
9,000 buried drums. In March 1977, surface impoundments overflowed and contaminated a
local pond and pastures north of the site resulting in a fish kill in the pond and the
death of several cattle. Consequently, the site was covered, recontoured, and closed by
the State in 1978. Land use around the site primarily consists of pasture land and low
density residential areas. Although no residences within a one-half mile radius north
of the site depend on private wells for drinking water, several local wells are still
used for watering lawns and livestock, a fish pond, and occassionally for domestic uses
when the municipal supply is not functional. Four areas of contamination have been
identified at the site. Area A is the deepest portion of che strip mine which ran along
(See Attached Sheet)
7. Document Analysis a. Descriptors
Record of Decision
Industrial Waste Control, AR
First Remedial Action - Final
Contaminated Media:- gw, sediments, soil, sw
organics, VOCs (TCE)
iSATI Field/Group
lity Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
174
22. Price
(SeeA£SI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R06-88/036
istrial Waste Control, AR
it Remedial Action - Final
16. ABSTRACT (continued)
the entire northern portion of the site, and includes drums containing solidified wastes
typically of dried paint and solidified foam. Area B lies south of the strip mine and
includes shale spoils from surface mining and random crushed drums. Area C is located
in the center of the site and contains two former surface impoundments constructed in
1975 and used as evaporation ponds for bulk liquids. Shale spoils, crushed used drums,
landfill debris, and sludge-like sediments were also found in Area C. Area D, located
in the extreme southwest corner south of Area B, contains intact, liquid-filled and
crushed drums as well as contaminated shale spoil. Approximately
19,500 cubic yards of contaminated soil is located in Area C and D. The primary
contaminants of concern affecting the soils, sediments, ground water and surface water
include: VOCs including toluene, organics, and metals including arsenic, chromium, and
lead.
The selected remedial action for this site includes: installation of a french drain
along the south, west and east sides of the site with a synthetic liner or other
barrier, such as a slurry wall installed on the site side of the french drain;
excavation of Area D liquid-filled drums with offsite disposal; excavation and onsite
stabilization of Areas C and D soil with onsite disposal of residual matrix in the Area
C excavation pit; categorization of solid and liquid wastes resulting from previous*
stigations with disposal consistent with Area C and D materials; ground water pump
fsite treatment, mixture with the contaminated soil and stabilized onsite, or
treatment in an onsite facility with discharge to be determined during design;
multilayer RCRA capping to cover the area bound by the french drain system and the
northern site border; surface water diversion using ditches and berms; access and land
use restrictions; and ground water and site monitoring. The estimated present worth
cost for this remedial action is $11,400,000.
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INDUSTRIAL WASTE CONTROL SITE
RECORD OF DECISION
JUNE 1988
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3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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o A french drain system will be installed along the south, west, and east
sides of the site to intercept and divert shallow groundwater around the
site. A synthetic liner or other barrier, such as a slurry wall, will be
installed on the site side of the french drain to prevent onsite ground
water from migrating into the french drain system.
o Groundwater encountered during the excavation will be removed and
transported to an offsite RCRA compliant facility for treatment and
disposal; mixed with the contaminated soils and stabilized onsite; or,
treated in an onsite treatment facility. The treatment plant discharge
location and effluent limitations would be established by EPA and the
Arkansas Department of Pollution Control and Ecology.
o Solid and liquid wastes resulting from the previous investigations at the
site will be categorized during the remedial design with disposal
consistent with Area C and D materials.
o -A multilayer RCRA cap will be constructed to cover the area bound on the
so-uth, west, and east by the french drain system and on the north by the
site boundary.
o Ditches and berms will be constructed on the south, west and east edges of
the site to divert surface water runoff from the site.
o Impose land use restrictions and install a security fence to maintain the
integrity of the Remedial Action and to prevent further development on
site.
o Monitor groundwater onsite and adjacent to the site. Evaluate site every
five years for effectiveness of the remedy.
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. This remedy satisfies the preference for treatment
that reduces toxicity, mobility or volume as a principal element. Finally, it
is determined that this remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Date Robert E. Layton dr., P.E.
Regional Administrator
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Industrial Waste Control Site
Record of Decision Concurrences
The Industrial Waste Control Site Record of Decision has been reviewed and I
concur:
, Project Manager
Superfund Enforcement Section (6H-EE)
0.
Larry D.Wrht, Chief O
Superfund Enforcement Section (6H-EE)
Robert E. Hannesschlaoer, P.E., Chief
Superfund Enforcemeny Branch (6H-E)
/Jk«~W 'jfe^-
Bennett Stokes, Chief
Solid Waste and Emergency Response Branch (6C-H)
Allyn M. Davis, Director
Hazardous Waste Management (6H)
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
INDUSTRIAL WASTE CONTROL SITE
FORT SMITH, ARKANSAS
JUNE 1988
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VI, DALLAS, TEXAS
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TABLE OF CONTENTS
Page
1. Site Description and History 1
2. Site Geology 5
3. Groundwater 6
4. Nature and Extent of Ppoblem 10
4.1 Waste Types and Location 10
4.2 Groundwater Systems" 13
4.3 Surface Water, Soils, and Sediments 16
5. Health and Environmental Risks at the Site 18
6. Enforcement History 21
7. Community Relations History 21
8. Alternative Evaluation 22
8.1 Evaluation Criteria 22
8.2 Description of Alternatives 27
8.3 Evaluation of Alternatives ..... 34
9. Selected Remedy 40
Appendices
A. ATSDR Health Assessment
B. Applicable or Relevant and Appropriate Requirements (ARARs)
C. Responsiveness Summary
D. State of Arkansas Concurrence
E. Index to The Administrative Record
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List of Figures
Page
1. Site Location Map 2
2. IWC Site Boundary 3
f
3. Geohydrology Cross Section 8
4. Selected Remedy 41
List of Tables
1. List of Wastes Reportedly Disposed 11
at the IWC Site
2. Summary of Remedial Alternatives 28
3. Comparison of Alternatives 36
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1. SITE DESCRIPTION AND HISTORY
The IWC site is a closed and covered industrial landfill about 8 miles
southeast of Fort Smith and 1 mile west of Jenny Lind, Sebastian County,
Arkansas (Figure 1). The site includes an abandoned coal su'rface strip mine.
Extensive underground mining also occurred immediately north of the site. The
underground mining occurred around the turn of the century and surface mining
occurred in the 1940s. The area is now primarily pasture land and low density
residential areas.
s^
The' site (Figure 2), which covers approximately 8 acres, includes the former
surface strip mine that ran along the entire northern portion of the site.
Waste materials, refuse, construction debris, and fill dirt were placed into
the site during the landfill's operating life, from the late 1960s to 1978.
At least two surface impoundments were constructed at the site and apparently
used as evaporation ponds, and drummed wastes were buried at the site. The
IWC Site is now closed, the strip mine has been filled in, and the site is
graded to approximately natural contours,
During the 1890s and early 1900s, at least five underground coal mines were
operated in the general area just north of the site from Jenny Lind westward
toward Bonanza. One of these mines, Mine No. 17, lies immediately to the
north and the east of the site. In the 1940s, the same coal seam that was
mined underground was strip mined along its outcrop. The western end of this
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-«^ _i_ ; _j
FIGURE-I
SITE LOCATION
INDUSTRIAL WASTE CONTROL SITE
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strip mine was used some 20 years later for the IWC landfill ing operation.
Activities at the site between the 1940s and 1960s are not well documented,
but aerial photographs show that the strip mine remained open and activities
did not change the surface topography to any extent. In the late 1960s or
early 1970s, James "Dude" Willis began a disposal operation that primarily
dealt in refuse and industrial trash. An application for an industrial
landfill was filed with ancf'temporarily approved by the Arkansas Department of
Pollution Control and Ecology (ADPC&E) in November 1971. Between 1971 and
1974, several local industries used the site for waste disposal purposes.
In August 1974, the site was sold to Grady Shipley. Waste disposal operations
continued through 1978, under the name of Industrial Waste Control (IWC), as a state-
permitted industrial landfill. Industries in and around the Fort Smith area
used-the site for the disposal of a wide variety of liquids, solid wastes, and
sludges. Available state records indicate that waste liquids such as
methylene chloride, phenols, cresylic acid, and paints were disposed of at the
site. Surface impoundments for disposal of bulk liquids were constructed,
apparently in 1975, and were used as evaporation ponds. At least two and
perhaps four or more ponds were constructed at the site. Drummed wastes, both
liquids and solids, were also buried at the site.
During March 27 to 29, 1977, heavy rains fell on and near the site, apparently
causing the evaporation ponds to overflow. The liquid wastes reportedly
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flowed onto property north of the site and, according to testimony in state
district court (Henson vs. IWC, 1977), resulted in a fish kill at a farm pond
on Mr. Henson's property. Several site inspections by the state were
conducted in the spring and summer of 1977 and at least one,meeting was held
between IWC, local industries, and the state. Closure activities were
initiated in mid to late 1977. Mr. Shipley made arrangements with Mr. Henson
to use spoil from the earlier strip mining operations as a cover for the
landfill. The site was covered, recontoured to approximately natural
contours, and closed in 1978. x.
2. SiTE GEOLOGY
The area geology is structurally complex and has been subject to extensive
folding and faulting related .to formation of the Ouacbfta Mountains. With the
exception of the thin veneer of quaternary-age alluvium along the stream
courses and alluvium/colluvium along ridge slopes, all the geologic strata
beneath and nearby the site are Pennsylvanian age.
The exact location of the Backbone Fault has been variously interpreted to
range from within the bounds of the site to the crest of Long Ridge,
approximately 1/4 mile south of the site (Figure 1). However, in all
probability, the site area lies within the fault zone associated with the
Backbone Fault.
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The coal bed mined by surface methods at the site has been mined extensively
immediately north of the site by underground methods. Groundwater
measurements suggest that there are no extensive direct connections (openings)
between the surface and underground mines, however, the Remedial Investigation
(RI) and Hydrogeologic and Waste Quantification Study (HWQS) have determined
that underground mine voids exist immediately adjacent (30 to 100 feet) to the
former strip mine.
The average dip (downward slope) of the coal bed north of the site is between
5 and 6 degrees to the north. Two hundred yards north of the site, the coal
seam is approximately 140 feet below the surface. The coal bed was sharply
uplifted at the site and may have been, exposed at the surface. In the strip-mined
area, the coal bed may have been nearly vertical.
The seismic survey defined the northern boundary of the strip mine and delineated
the depth of fill within the strip mine. The strip mine depth varies from 40
to 50 feet at the middle of the site to 25 to 35 feet deep at the east and
west ends. The bottom of the strip pit consists of fractured shales and interbedded
sandstones and shales. There is no evidence that a liner was placed prior to
filling operations.
3. GROUNDWATER
There are up to five groundwater-bearing zones of interest near the IWC Site.
The zones consist of two separate artesian aquifer systems within the coal
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units and related mine workings north and northwest of the site (Artesian
System Mine No. 17 and Artesian System Mine No. 18), a shallow perched
groundwater system within the strip mine fill, a discontinuous perched
zone in the overburden soils and upper portions of the McAl^ster shale north of
the site, and an apparently unconfined groundwater system in the Atoka and/or
Hartshorne formations south of the site (Figure 3).
The shallow perched onsite groundwater zone is recharged by seepage through
the hillside immediately south of the IWC Site and by direct precipitation.
This groundwater zone is apparently not continuous across the entire site,
saturated and unsaturated areas being determined to some extent by the density
of the backfill and spoils spread over the site. This groundwater zone
develops one or more springs during wetter times of the year (primarily in
Area C), but probably most often discharges into the underground coal mine
voids. The onsite perched groundwater should not be considered a usable
aquifer. If a groundwater well were installed in this onsite system (within
the limits of the strip mine), it would probably yield less than 0.5 gallons
per minute. This onsite shallow groundwater has relatively high
concentrations of both organic and inorganic constituents.
The shallow aquifer north of the site in the overburden soils and upper
portions of the McAlester Shale is apparently not continuous with the onsite
perched system. This aquifer would probably yield adequate water for
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residential use in areas 1/2 mile or so north of the site. Immediately north
of the site, however, shallow wells yield very little or no water. This
small yield is due to low permeability of the soil, to surficial bedrock units
adjacent to the site, and to the lack of an adequate recharge area.
The artesian groundwater systems north and northwest of the site are
associated with the underground mine workings (Mine Nos. 17 and 18). The
_*
artesian system northwest of the site is associated with Mine 18 and is
apparently not connected to the site. The potentiometric head in this system
\
is about 30 feet higher than the head in the Mine No. 17 artesian system.
Samples of this groundwater showed no contamination. The artesian groundwater
system due north of the site is associated with the Mine No. 17 underground
mine workings in the area. Groundwater from this system showed very low concen-
trations of organic and inorganic contamination.
The groundwater system in the Atoka and Hartshorne formations south of the site
is upgradient to the site and most likely discharges groundwater onto the site
via the hillside at the site's south edge. This groundwater system may also
discharge water into bedrock formations that lie below the site.
Elevated concentrations of inorganics (above published background levels) were
detected in the unconfined groundwater system south of the site, but these are
not attributable to the disposal activities at the site because this system is
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upgradient to the onsite perched system. The interrelationship between the
two systems is not known.
Based on the information gathered in the RI and HWQS, both the onsite and
adjacent offsite regions of the perched groundwater system may be Class 3
aquifers (groundwater not a potential source of drinking water and of limited
beneficial use) under the proposed U.S. EPA groundwater strategy because
the potential water yield would likely be inadequate for residential or
commercial/industrial use. Where the offsite perched groundwater system
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actually becomes a usable water supply cannot be accurately defined, but it is
definitely greater than 200 feet from the site boundary.
At' some point north of the site, the perched groundwater system does provide
sufficient yield to support residential or light commercial/industrial use.
The downgradient usable region of the perched groundwater system and the
artesian aquifer associated with Mine No. 17 likely would be classified as
Class 2 groundwater by EPA (current and potential sources of drinking water
having other beneficial uses).
4. NATURE AND EXTENT OF PROBLEM
4.1 Haste Types and Location
Data on the waste materials disposed at the IWC site were compiled from EPA
project files and by reviewing court testimony and written court
interrogatories presented during the Henson versus IWC court proceedings
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in 1979. Although disposal records and copies of all trucking manifests were
not maintained, a general list of chemicals and types of wastes disposed at
the IWC site has been compiled and is summarized in Table-1:
TABLE - 1
LIST OF WASTES REPORTEDLY DISPOSED AT THE IWC SITE
Methylene chloride Cutting oils
Trichloroethene Paint thinners
Sodium hydroxide Lacquer thinners
Acetone Hydraulic oils
Chromium sulfate Kerosene
Zinc phosphate \Phosphate sludges
Cresylic acid Inks
Methyl ethyl ketone Water-soluble oils
Methanol Paints
Butyl cellosolve Alkaline flotation agents
Toluene Packing materials
Stannuous octoate Plastics
Phenols Foam rubber
The results of the RI and HWQS indicate four main areas of the IWC site where
wastes were disposed (Figure 2). A physical description of each area and the
types of waste found is summarized below:
(1) Area A. Area A is the deepest portion of the strip mine, varying in depth
from 25-35 feet on the east and west ends to 40-50 feet near the middle of
the site. Generally, this area was dry, but localized pockets of perched
water exist throughout the area. Most drums were encountered in the upper 15
feet below which the waste consisted of wood and trash. Many drums contained
solidified material typical of dried paint and solidified foam. But empty and
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crushed drums were also found. No liquid-filled drm$ were encountered 1n Area A
-. Chemical analysis showed elevated levels of both organlcs and Inorganics 1n
the drummed material. Analysis of soil samples from the western half of Area
A revealed higher organic concentrations than the eastern half. Elevated
levels of several Inorganics were also documented across the area.
(2) Area 8. Immediately south of the,strip pit, this area varies 1n depth
from 20 feet on the north to approximately 15 feet on the south. The area
consists primarily of shale spoils from surface mining with some debris. The
area was relatively dry, but.several very moist zones were encountered.
* x.
Volatile organic contaminants were evident 1n borings, from very shallow
depth'to bedrock. Elevated levels of several heavy metals were also
confirmed. Random crushed, empty drums were encountered at and Immediately
below the surface. ' '"'" '
(3). Area C« Area C 1s the location of two former Impoundments for bulk
liquids. Aerial photographs from 1976 document the location and size of the
Impoundments. Evidence of the Impoundment berm Is still visible. The area
1s approximately 15 feet deep. Material 1n the area consists of shale spoils,
crushed drums some of which contained solidified foam and paint sludge or
epoxy material, landfill debris, and sludge-like sediments. Perched pockets of
water were encountered throughout this area, Including an area where a black
oily liquid was encountered. Elevated levels of both organlcs and Inorganics
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were confirmed. Area C 1$ considered a principal source of th« contaminants
1n Area A Immediately to the north.
(*) Area 0. Area D 1s the location where below grade, Intact, liquid-filled
and crushed drums were found. The depth of the area was not confirmed, but 1t
1$ at least 6 feet deep with possibly two distinct areas of drum disposal.
The liquids 1n the drums were observed to be black and brown with odors
reminiscent of wood lacquers, varnishes, and paint thlnners. Shale spoil
surrounding the burled drums"1s also contaminated. Area 0 1s considered a
principal source of the organic contaminants 1n Area 3 and the west end of
Area A.
4.2 Sroundwater Systems
A *
There are five groundwater bearing zones near the IWC site (Figure 3): an
unconflned upgradlent system, a limited perched onslte system, a discontinuous
perched zone north of the site, and artesian systems 1n the two underground
mines north of the site. The systems are'briefly described below:
(1) Unconflned Upgradlent System; The unconflned system was Identified
south of the site within the same bedrock units that underlie the site.
Several residential Wells are completed 1n this system. This system 1s
upgradlent and 1s not believed to be Interconnected with the perched
groundwater onslte. Ground water within the unconflned system 1s
believed to move along bedding planes and migrate down dip In the
bedrock and below the base of the strip mine.
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(4) Artesian Groundwater System - Mine No. 18. There are two separate
groundwater systems within the coal unit and underground mine workings
north of the site (Figure 2): a system associated with Mine No. 18
and a system associated with Mine No. 17. Mine No. 18 is northwest of
the site and is apparently not physically connected to Mine No. 17.
The Mine No. 18 system has an artesian pressure approximately 30 feet
higher than the system in Mine No. 17. The recharge source for the
Mine No. 18 system is west and northwest of the site and there is no
apparent connection between this system and the site. Samples of
. groundwater from this system showed no contamination.
(5) Artesian Groundwater System - Mine No. 17. Mine No. 17 is .immediately
' -north of the site. The recharge for this system is to the north and
northeast of the site. Prairie Creek has been documented a recharge
source. Leakage and seepage downward from the offsite perched and
offsite unconfined groundwater systems north of the site are potential
minor sources of recharge. The aquifer in Mine No. 17 is a usable
groundwater resource. Two wells were identified during the residential
well survey which are probably completed in this artesian system
although this could not be confirmed. These two wells are over 1/4-
mile from the site, are not currently in use, and are not contaminated.
There is evidence of limited seepage or leakage from the contaminated
onsite perched system into the Mine No. 17 artesian system. The leakage
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(2) Limited Onsite Perched System. Generally, the eastern portion of the
site is saturated with groundwater. The western portion contain
limited perched groundwater zones. The strip mine (Area A) is
relatively dry with isolated pockets of water existing within the
miscellaneous waste. The recharge for the onsite perched system is
mainly surface water infiltration with some seepage from the hillside
south of the site. This system is presently contaminated in excess of
acceptable limits for use as a drinking water source. However, because
\%
of its low-yield it is not considered a usable source. The major
. concern with this system is that-the majority of the seepage and
groundwater flow from this system is into the Mine No. 17 artesian
aquifer immediately north of the site which is a usable source.
(3) Perched Zone North of the Site. The investigations north of the site
identified the presence of a perched zone within the overburden soils
and the uppermost portion of the McAlester shale north of the site.
Recharge for this system is primarily from precipitation and surface
water infiltration on the area north of the site. This system may
become unconfined further north of the site where there are at least
two wells completed in this zone. The wells are not currently used for
domestic supplies but are still capable of being used. It is not
likely that the offsite perched system is hydraulically connected to
the onsite system, although low levels of contamination is probably the
result of past events at the site (e.g., impoundment overflow in 1977)
rather than present releases.
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occurs at the base of the strip pit where the coal seam and mine
workings are interconnected to the strip mine. Samples of the artesian
system adjacent to the site showed very low levels of organic and
inorganic contamination.
^
4.3. Surface Water, Soils, and Sediment
Surface drainage from the site is primarily north into Prairie Creek
approximately 1/2 mile north of the site. Surface runoff flows predominantly
as unchanneled flow with some localized drainage ways. Surface runoff from
higher areas south of the site, such as Long Ridge, can flow onto and across
the.site. Localized ponding exists at a depression onsite in the area of one
of the old surface impoundments. Although Prairie Creek is classified by the
Arkansas Department of Pollution Control and Ecology as a drinking water
source, no residential use of this water was identified in the survey area.
Organic contamination and elevated levels of inorganics were detected in soils
and sediments onsite. The highest concentrations and highest number of
constituents were found in Areas B, C and D and on the western third of the
site. Surface soil contamination on the eastern third of the site is much
lower.
Offsite organic and inorganic contamination of soils decreases both in number
of contaminants and in concentration with distance from the site. The
elevated levels offsite are most likely the result of past surface releases
during the operation of the evaporation ponds.
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Surface seeps at the site in the area of the former impoundments provide a
potential for release of additional contamination into the surface drainage
pathways. Surface soil and sediment of the seep are heavily stained.
However, chemical analysis of the material in the existing s'eep does not
indicate concentrations of contaminants above background levels established
for the site. The existence of buried drums in this area (Area C), however,
provides a potential source of contaminants that could be released into the
groundwater and into this seep at any time in the future.
N^
Surface water samples from Prairie Creek and three farm ponds show no
contamination. Sediment samples from Prairie Creek upstream, directly north
and downstream of the site exhibited levels of barium, chromium, and magnesium
above background levels established for the site. The concentrations
increased 'from upstream to downstream sampling stations. The elevated levels
of these heavy metals in the stream sediments downgradient from surface runoff
at the site may be the result of past activities at the site or may come from
some unknown source. Existing levels of these elements in onsite and near-
site soils do not indicate that the soils at the site are the present source
of the elevated levels of barium, chromium, and magnesium in stream sediments.
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5. HEALTH AND ENVIRONMENTAL RISKS AT THE SITE
The perched onsite groundwater is presently contaminated in excess of
acceptable limits for use as a drinking water source. However, this system
does not have sufficient yield to be used as a drinking water source. This
system is a concern because of the apparent leakage into the artesian (Mine No.
17) system north of the site, which is a usable source.
The Endangerment Assessment (EA) results indicate that the artesian groundwater
system may present a potential human health risk due to noncarcinogenic contamination
from manganese and carcinogenic contamination from arsenic, bis(Z-ethylhexyl)
phthalate, methylene chloride, and N-Nitrosodiphenylamine. The arsenic and
manganese levels are considered indigeneous to the coal mined area and the low
concentration of listed organics detected may be associated to some degree
with laboratory contamination. Thus no remediation is considered appropriate
for this aquifer, although it should be protected from further contaminated
seepage from onsite.
The potential for human exposure to contaminants from the IWC site was
assessed in the EA using four potential use settings, assuming no remedial
action at the site; residential development, light industrial/commercial
development, recreational use, and agricultural use. Health risks under the
agricultural use setting was not quantified because the extent of exposure is
difficult to predict. Use of the site and land adjacent to the site by children
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under the residential and recreational development settings results in health
risks by soil ingestion. Health concerns include noncarcinogenic toxic effects
as a result of exposure to several heavy metals including cadmium, lead, manganese,
and nickel. Maximum concentrations of these metals are in excess of the acceptable
daily intake in both onsite and offsite soils. However, the offsite levels
might be a result of the previous mining activity in the area rather than the
waste disposal operation. Therefore, no remediation is proposed for offsite
soils. None of the daily intakes for soil calculated for adults exceeded
acceptable intakes for noncarcinogenic contaminants.
Carcinogenic chemicals such as trichloroethene, bis(2-ethylhexyl) phthalate
and methylene chloride exist in onsite waste and in offsite soils at levels
which present a chronic excess lifetime cancer risk if ingested. This would
occur under both the residential and commercial land use settings.
Concentrations of carcinogic chemicals in offsite soils appear to be limited
to levels that are naturally occurring, such as the relatively low
concentration of arsenic. Onsite carcinogenic chemicals are at higher
levels than at offsite locations, and are associated with waste disposed on
the site.
It is estimated that there may be as many as 9,000 drums buried at the site.
This includes intact drums containing free liquid as well as solid-filled and
crushed empty drums. The liquid filled drums, found only in Area D during the
HWQS, are one of the principal sources of contamination at the site and can
19
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continue to release wastes which could:
o Hasten corrosion of nearby drums, with a resulting increase in hazardous
constituents and/or concentrations in soil and groundwater.
o Release additional chemicals to the groundwater, resulting in increased
solubilization and mobility of existing contaminants.
o Increase the potential health hazard from unknown chemicals.
o Disrupt the integrity of the fill material and bedrock presently
limiting migration rates.
o Potentially increase the toxicity of the^leachate seeps, thereby
increasing the health risk of exposure to onsite soils.
Buried drums containing solid material are scattered throughout the site.
The solids in the 'buried drums pose a lesser threat than the liquids
for contaminating surrounding media because of the nature of the solids in the
drums and their relatively low mobility potential. However, some contaminants
can be expected to migrate from these drums as a result of leaching. Exposure
to contaminants can also result if excavation of the area were to occur which
would cause the solids to be brought to the surface.
There is limited potential for impacts on animal and plant populations at the
IWC Site. Currently, any use of the IWC Site by animals is generally limited
and temporary, with the possible exception of rodents (i.e., field mice).
Offsite migration and impact potential are minimal. The impact on plants and
20
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animals on the site should be buffered by the generally good ecological
quality of the surrounding area.
6. ENFORCEMENT HISTORY
CERCLA §104(e) information request letters were mailed in 1983 and 1984 to
Potentially Responsible Parties (PRPs). Approximately 20 PRPs have been
identified. Several of the PRPs have formed a Steering Committee (IWC
Steering Committee) to coordinate their efforts for site cleanup.
An Administrative Order on Consent was issued in February 1987 to the IWC
Steering Committee members to allow them to conduct supplemental field studies
in summer 1987. General notice letters were sent to the PRPs prior to the
public meeting on Hay 9, 1988. Special notice letters specifying the negotiations
moratorium were mailed on June 24, 1988.
The IWC Steering Committee has expressed interest in performing the Remedial
Design/Remedial Action under" the terms of a Consent Decree. Negotiations are
underway to accomplish this objective.
7. COMMUNITY RELATIONS HISTORY
Community interest in the Industrial Waste Control site has been moderate.
Adjacent property owners have been aware of the site since the early 1970s.
Media coverage of the site has not generated an increase in local interest.
21
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Upon completion of the feasibility study in the summer of 1986, EPA
distributed a fact sheet regarding the results of the remedial investigation
and the feasible alternatives for clean-up. Thirty-seven citizens attended a
public meeting on July 1, 1986. In March and December of 1987, EPA issued
updates advising the citizens of the Steering Committee's supplemental study.
No additional concern/questions or comments were generated as a result of
these two updates.
On April 19, 1988, EPA announced its proposed plan of .action, based upon the
findings of the revised Feasibility Study. The public comment period from May
2 to June 2, 1988 was also announced. An estimated 35 area citizens and local
officials attended the meeting on May 9, 1988. Overall, the residents and
local officials do not oppose the proposed plan. Responses to the comments
received during the comment period are outlined in Appendix C entitled
"Responsiveness Summary."
8. ALTERNATIVE EVALUATION
8.1 Evaluation Criteria
Section 121 of SARA contains nine factors which U.S. EPA must consider in
selecting a remedy for a Superfund site. These items are listed below:
22
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1. Consistency with Other Environmental Laws
In determining appropriate remedial actions at Superfund sites, U.S. EPA
must consider the requirements of other Federal and State environmental
laws, as well as CERCLA as amended by SARA. Primary consideration is
given to attaining applicable or relevant and appropriate Federal and
State public health and environmental laws, regulations and standards
(ARARs). Not all Federal and State environmental laws and regulations
are applicable to each Superfund remedial action.
2. Reduction of Toxicity, Mobility or Volume-... '
' U.S. EPA must assess the degree to which remedial alternatives employ
treatment that reduces toxicity, mobility, or volume of hazaradous
»
wastes. The relevant factors include:
o The treatment processes, the proposed remedies employed and the
materials they treat;
o the amount of contaminated materials destroyed or treated;
o the degree of expected reduction in toxicity, mobility, or volume;
o the degree to which the treatment is irreversible; and
o the residuals that will remain following treatment after considering
the persistence, toxicity, mobility, and propensity for
bioaccumulation of such hazardous substances and their constituents.
23
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3. Short-term Effectiveness
U.S. EPA must assess the short-term effectiveness of an alternative by
considering the following:
o Magnitude of reduction of existing risks; and
o probable short-term risks to the community, workers, or the
environment during the implementation of an alternative including
potential threats associated with excavation, transportation, and
redisposal or containment.
4. Long-term Effectiveness and Permanence
U.S. EPA must assess for each alternative the long-term effectiveness
and permanence they afford along with the degree of certainty that the
remedy will prove successful. The relevant factors include:
o Magnitude of residual risks in terms of amounts and concentrations of
wastes remaining following implementation of a remedial action,
considering the persistence, toxicity, mobility, and propensity for
bioaccumulation of such hazardous substance and their constituents;
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;
24
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o long-term reliability of the engineering and institutional controls,
including uncertainties associated with the land disposal of
untreated wastes and residuals; and
o potential need for replacement of the remedy. ,
5. Implementability
U.S. EPA must assess the ease or difficulty of implementing the
alternatives by considering the following factors:
o Degree of difficulty associated with constructing the solution;
o expected operational reliability of the-treatment technology;
o need to coordinate with and obtain necessary approvals and permits
(or meet the intent of a permit for Superfund actions);
o availability of necessary equipment and specialists; and
o available capacity and location of needed treatment, storage, and
disposal services.
6. Costs
U.S. EPA must access the following types of costs:
o Capital costs:
o operation and maintenance costs;
o net present value of capital and operation and maintenance cost; and
o potential future remedial action costs.
25
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7. Community Acceptance
U.S. EPA must assess the concerns of the community including:
o Components of remedial alternatives that the community supports;
o features of the alternatives about which the commuriity has
reservations; and
o elements of the alternatives which the community strongly opposes.
8. State Acceptance
U.S. EPA must access the concerns of the state government which for this
site is represented by the Arkansas Department of Pollution Control and
Ecology. This assessment includes:
o Components of remedial alternatives that the State supports;
o features of the alternatives about which the State has reservations;
and
o elements of the alternatives which the State strongly opposes.
9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against individual
evaluation criteria, U.S. EPA must also assess whether the remedial
alternatives provide adequate protection of human health and the
environment. U.S. EPA is also directed by Superfund law (SARA) to
prefer solutions that use treatment to permanently remove contaminants
from the environment. Offsite transport and disposal without treatment
is the least preferred option when practicable treatment technologies
are unavailable.
26
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8.2. Description of Alternatives
Table 2 lists the alternatives, the technologies included and the costs
(present worth).
Alternative 1 - NO ACTION *
No remedial actions are taken, and the site would remain in its present
condition. This alternative, required by the NCR and SARA, is a baseline
against which the effectiveness of other alternative remedies are judged. The
RI derived wastes which have been determined hazardous would be disposed at an
offsite EPA approved facility. The nonhazardous "portion of this RI waste
wou-ld be placed on the site. The site would be left in the same condition as
existed prior to the RI, with the exception that the monitoring wells would
.remain. ,..- . ;-.^^,,».-_---_.- , .=.. -..- - ,
* .-»« t
Estimated Cost $0.16 Million
Alternative 2 - CONTAINMENT WITH GROUNDWATER CONTROLS, RIGID BARRIER AND AREA
D DISPOSAL
Alternative 2 consists of continued monitoring, surface water diversion, site
security f$nce, multilayer cap, french drain, excavation and offsite disposal
of Area D materials, and land use restrictions enforced by the PRPs. A rigid
barrier is constructed in the mine voids north of the site. The drum disposal
area (Area D) is excavated and the materials taken offsite for disposal in
lieu of containment, and the PRPs will purchase the site to enforce land use
restrictions. There are an estimated 3,000 liquid-filled and crushed drums in
27
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Ill
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Area D. The excavated liquids would be sampled and tested for compatibility.
Compatible and incompatible wastes would be separated, placed in bulk tanker
trucks, and disposed at an offsite, RCRA compliant incineration facility. The
surrounding soil contaminated by leaking drums or by the drum extraction process
will also be excavated and disposed offsite in compliance wHh RCRA regulations.
A rigid barrier consisting of sheet pile formwork and grout will be constructed
along the north side of the site to prevent potential contaminant migration
from entering the mine voids and contaminating the artesian aquifer. A multilayer
cap would be constructed over the site to the extent of the french drain on
the south, east and west sides. The multilayer "cap would essentially eliminate
the quantity of precipitation which infiltrates into the onsite perched groundwater
system. The reduced volume of infiltration.would substantially reduce the
hydraulic driving force to move the contaminated perched groundwater offsite
into the Mine No. 17 artesian aquifer. Surface water will be intercepted and
diverted around the site by diversion ditches along the south, east, and west
sides of the site. This will protect the multilayer cap from surface water
erosion.
Estimated Cost and Construction Time: $17.7 Million and 18 to 24 Months.
ALTERNATIVE 3 - ADDITIONAL CONTAINMENT WITH GROUNDWATER CONTROLS AND "HOT"
SPOT TREATMENT (STABILIZATION)
Alternative 3 consists of continued monitoring, surface water diversion, site
security fence, multilayer cap, french drain, excavation and onsite
29
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stabilization of Areas C and D soils, offsite disposal/reuse of area 0 liquid-
filled drums, slurry wall constructed around the stabilized waste area, and
land use restrictions. Area C contains approximately 200 solid-filled and
crushed drums, and 16,900 cubic yards of contaminated soilj'Area D contains
approximately 3,000 liquid-filled and crushed drums, and 2,600 cubic yards of
contaminated soil. Liquid filled drums in Area D would be disposed in an
offsite in a EPA approved RCRA compliant facility. The contaminated soil, and
solids (to be shredded) will be mixed and stabilized with a mobile stabilization
unit. The stabilized matrix, after passing appropriate Teachability and strength
tests, will be returned to the Area C excavation pit. The empty drums will be
crushed and placed into the excavation pit. After the stabilized soil is
replaced in the excavation pit and the french drain system installed, a multilayer
cap will be installed over the site. The multilayer cap would prevent contact
with contaminated surface soils and essentially eliminate infiltration into
the fill.
Restrictions on the use and development of the site would be required since
hazardous waste is left onsite and to maintain the integrity of the french
drain and cap. Thes.e would be accomplished in the form of controls on the use
and development of the site. Because the long-term reliability of organic
stabilization has not been established, the slurry wall will provide additional
containment of the stabilized waste thereby further reducing the potential for
future migration. In addition, monitoring wells would be installed inside and
30
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just downgradient of the slurry wall system to monitor the effectiveness of
the containment and to provide early warning of contaminant migration. The
wells inside the system would monitor the level of groundwater and be utilized
as a means to remove groundwater, if required, to prevent the accumulation of
^
water within the containment. The presence of groundwater would indicate the
containment components are not working effectively and additional containment
or replacement may be warranted. All wells would be sampled periodically, if
water is present, to indicate the long-term effectiveness of stabilization and
the slurry wall.
Estimated Cost and Construction Time: $11.4 Million and 18 to 24 Months.
ALTERNATIVE 4 - CONTAINMENT WITH GROUNDWATER CONTROLS AND "HOT" SPOT TREATMENT
(ONSITE INCINERATION)
Alternative 4 consists of continued monitoring, surface water diversion, site
security fence, clay cap, french drain, excavation and onsite incineration of
Areas C and D wastes, and land use restrictions. A mobile incinerator will be
set up onsite to incinerate drum contents determined to be hazardous and
contaminated soil excavated with the drums. The individually intact drums
will be excavated, tested, and incinerated. The incineration residue would be
fixed to immobilize the inorganics and returned to the site and covered with
a clay cap. The liquid portion of the investigation derived waste and water
encountered during excavation would be treated on site with a temporary water
treatment system prior to discharge to a nearby drainageway.
31
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Incineration will eliminate organics as contaminants of concern. Incineration
does not affect inorganics. However, the inorganic ash will be fixed and
buried rendering them immobile and with little potential for future migration
offsite. Since inorganic contamination would remain on site, land development
s
restrictions would be required. These restrictions would preclude future use
of the site. Continued monitoring of the artesian groundwater system for
inorganic contamination would be required.
Estimated Cost and Construction Time: $34 Million and 30 to 36 Months.
ALTERNATIVE 5 - COMPLETE EXCAVATION AND ONSITE DISPOSAL
An onsite RCRA-type landfill would be constucted for storing and securing
contaminated onsite soil, solid wastes in buried drums, and the solid portion
of the RI derived wastes that can be landfilled. All waste posing a cancer
risk greater than 1 x 10 and all waste exceeding the reference doses for
noncarcinogens by ingestion would be excavated and placed into the landfill.
The drummed liquid waste and surrounding contaminated soil would be excavated
and incinerated offsite. The liquid portion of the investigation dreived
wastes that is considered hazardous, and water encountered during excavation
of the contaminated soil would be treated with an onsite treatment unit and
discharged to the artesian aquifer. Sludges generated during the treatment
would also be placed in the RCRA vault. The landfill would be constructed in
substantial compliance with RCRA requirements for a land disposal facility.
32
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A site security fence would be installed around the site. Land development
restrictions would be required since the hazardous waste is left on the site
and to ensure the integrity of the landfill. These restrictions would preclude
future use of the site. A surface water diversion ditch will be constructed
around the south, east, and west sides of the site to divert'overland surface
water flow around the site to maintain the finished grade of the site. The
remainder of the site would be regraded, with clean native material added as
necessary to restore a suitable finished grade. Monitoring of the groundwater
and the leachate collection and detection systems would be conducted to comply
V
with RCRA requirements.
Estimated Cost and Construction Time: $17.6 Million and 24 to 30 Months.
ALTERNATIVE 6 - COMPLETE EXCAVATION AND ONSITE INCINERATION
Contaminated onsite soils, waste, and buried drums posing a cancer risk
greater than 1 x 10~^ and exceeding the reference doses for noncarcinogens by
ingestions under the residential setting would be excavated, field analyzed,
and incinerated in an onsite mobile incineration unit. The RI derived waste
and the sludge from the onsite water treatment plant would also be
incinerated. The incinerator ash is anticipated to contain unacceptable
levels of inorganics to allow for direct land disposal. It is assumed that
the ash will be transported to an offsite RCRA approved landfill.
The areas will be excavated and the materials temporarily stored in pre-fabricated
metal buildings to reduce fugitive emissions and then fed to the incinerator.
33
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Scrubber water, following treatment, will be discharged with the treated water
from the onsite groundwater treatment system or consolidated with the incinerator
ash. The ash will be transported to an offsite RCRA landfill.
The excavated areas would be backfilled with clean native material, graded to
drain, and revegetated. The RI derived waste that is suitable for
incineration would be incinerated while the liquid portion would be treated at
the onsite treatment facility and discharged to the Mine No. 17 artesian
system or to a drainage ditch.
Estimated Cost and Construction Time: $146 Million and 30 to 36 Months.
In alternatives 2 through 6, groundwater encountered during the excavation
wi.ll be removed and transported to an offsite EPA .approved, RCRA compliant,
facility for treatment and disposal; mixed with the contaminated soils and
stabilized onsite; or treated in an onsite treatment facility. Solid and
liquid wastes resulting from the previous investigation at the site will be
categorized with disposal consistent with the disposition of Area C and D
materials. Similarily, the area around monitoring well 098 will be excavated.
Contaminated soils and groundwater will be handled with the Area C and 0 materials,
8.3 Evaluation of Alternatives
The degree to which the remedial alternatives meet the nine selection criteria
is contained in Table 3. The following values were assigned to compare remedy
selection criteria:
34
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Table 3
Comparison of Alternatives - IWC Site
CRITERIA
Complies with ARARs
Reduces Toxicity
Reduces Mobility
Reduces Volume
Short-term Effectiveness
Long-term Effectiveness
Implementability
Cost in Million $ (Present Worth)
Community Acceptance
State Acceptance
Protectiveness
ALTERNATIVE
1
»
+
^
++
0.16
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++ Alternative would greatly exceed a selection criterion when compared
to other alternatives.
+ Alternative would exceed a criterion in comparison to other
alternatives.
o Alternative can be designed to meet the selection criterion.
Special efforts will be necessary in the design of the remedy
to meet the selection criterion.
~ In comparison to the other remedies, these alternatives would present
most difficulty in achieving -a selection criterion.
The Rationale for the ratings assigned in Table 3 is as follows:
1. Complies with ARARs
No action was assigned a "--" because it violates the intent of SARA Secti
121 regarding the selection of a remedy that is protective of human health
and the environment.
All other alternatives were rated "o" since they all can be designed to
meet the ARARs established for the IWC Site.
2. Reduces Toxicity, Mobility, and Volume
No action was rated "" because it does not reduce any of those
parameters.
36
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Alternative 2 was rated "0" since toxicity is reduced by incineration reuse
of Area D liquid-filled drums, mobility of onsite contaminants is reduced
indirectly by installation of containment system (french drain, rigid
barrier and cap) and the volume of the waste remains essentially the same.
Alternatives 3 and 4 were rated "+" since toxicity is reduced for materials in
both Areas C and D, mobility of wastes is reduced by installation of containment
system and slight reduction of volume of the wastes occurs.
Alternative 5 was rated "0", ++, 0" since the toxicity and the volume of the
\
waste remains the same in the RCRA vault and the mobility of all site wastes
is reduced by the vault system.
Alternative 6 was rated "++" since incineration completely reduces the toxicity»£±
mobility and volume of the waste.
3. Short-Term Effectiveness
No action alternative was rated "+" since there are no risks associated with
construction.
Alternative 3 and 4 were rated "0" because the short-term risks associated
with construction is moderate in comparison to risks associated with
Alternatives 2,5, and 6.
Alternatives 2,5, and 6 were rated "-" because of increased risks to construction
workers and nearby residents from extensive construction activities (such as
37
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construction of rigid barrier for the mine voids and large scale excavation for
RCRA vault or incineration).
4. Long-Term Effectiveness
No action was rated "" because of the potential human health and the environ-
mental risks involved in leaving untreated wastes at a site'where long-term
site control cannot be insured.
Alternative 2,3,4, and 5 were rated "0" since these remedies would still involve
long term monitoring and maintenance, even though the toxicity, mobility and
volume of wastes is reduced.
Alternative 6 was rated "++" since it would remove all contaminants from the
site.
5. Implementabi'lity
No action was rated "++" since it can be easily implemented.
Alternatives 2, 5 and 6 were rated "-" because of difficulty involved in the
construction of a rigid barrier in mine voids, construction of a RCRA vault
and excavation and incineration of large quanity of wastes.
Alternatives 3 and 4 were rated "0" since they are complex alternatives
but still relatively easy to construct and implement.
38
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6. Cost
The cost for Alternative 1 is low; the relative cost for Alternative 3 is
moderately low; The cost for Alternatives 2 and 5 are moderate; The cost
for Alternative 4 is moderately high; while the cost for Alternative 6 is
the highest in comparison to other alternatives.
7. Community Acceptance
Based upon the two public meetings and comments received, it is evident
that the local residents want a solution to the problem. The proposed
remedy, therefore, is considered to be acceptable to the community. The
public expressed no opposition.
No Action was rated "" since it is not acceptable to the Community.
The remaining alternatives were rated "0" since they are acceptable to the
community.
8. State Acceptance
No Action was rated "" since it is not acceptable to the State.
Since the State is favorable to the proposed remedy (Alternative 3) it was
rated "+" while the remaining alternatives were rated "0".
9. Protectiveness
No action was rated "" because it does not provide protection from the
potential risks involved with leaving untreated wastes on site.
Alternative 2,3, and 4 were rated "+" since risks are reduced by treatment
and containment systems.
39
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Alternatives 5 and 6 were rated "++" since all the wastes on site would
either be placed in a RCRA vault (Alternative 5) or destroyed by
incineration (Alternative 6), thereby minimizing the health risks.
10. Selected Remedy
"^""^^- "T - - -"" " if
Based on the information contained in the Administrative Record and the
results of the evaluation of Alternatives (Section 8.3), Alternative 3
(Figure 4) has been selected as the remedy for IWC site cleanup.
Construction activities for the selected remedy would probably commence
with installation of the french drain system" to prevent upgradient
groundwater from entering the site and complicating excavation in Areas C
. and D. Area D drums would be excavated and compatible wastes consolidated
for bulk transport to an offsite RCRA compliant facility for disposal/reuse. ;"
Contaminated soils from Areas C and D and the area around monitoring well
098 and solids from the drums would be stabilized onsite using a mobile
stabilization unit. The stabilized matrix must pass TCLP and or other EPA
approved leachate test and ASTM strength tests to meet performance specifi-
cations. Stabilized material will be returned to the Area C excavation
pit and a slurry wall will be installed to the bedrock around the stabilized
soils to provide additional containment and reduce the long term uncertainties.
Groundwater encountered during the excavation will be removed and transported
to an offsite RCRA compliant facility for treatment and disposal; mixed
.with the contaminated soils and stabilized onsite; or, treated in an onsite
40
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treatment facility. The treatment plant discharge location and efflutnent
limitations would be established by EPA and the Arkansas Department of
Pollution, Control and Ecology. Solid and liquid wastes resulting from
the previous investigations at the site will be categonzed during the
Remedial Design with disposal consistent with disposition of Area C and D
wastes. Then a multilayer RCRA cap will be constructed to cover the area
bounded on the south, east, and west by the french drain system and on the
north by the site boundary (the cap will cover approximately 7 acres).
Site access will be controlled by installation of a security fence and
land use restrictions to maintain the integrity of the containment system
and prevent future development on site. Groundwater will be monitored and
the site reviewed every five years to evaluate the effectiveness of the
r - ---'_- ' " ' *;- " -
remedy and to take future corrective action, if necessary.
The selected remedy is protective of human health and the environment, cost-
effective, and attains applicable or relevant and appropriate requirements.
It utilizes permanent solutions and treatment technologies that reduce
contaminant mobility, toxicity and volume to the maximum extent
practicable.
Other alternatives were not selected for the following reasons:
42
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No Action: This alternative does not protect public health and the
environment. It does not meet the intent of SARA.
Alternative 2: This alternative was not selected because the
constructability of the rigid barrier in mine void is questionable. Also,
the cost of the barrier is too high in comparison to the benefits it would
provide.
Alternative 4: This alternative was rejected because it provides about
the same level of protection as the remedy selected but costs almost three
times as much. The only significant difference, between this remedy and the
remedy selected is that in this alternative soils and solids from Areas C and
D would be incinerated, instead of being stabilized.
Alternative -5: This alternative was not selected because this alternative
would not provide much more protection than the selected remedy and costs
about $5 million more. Also, the short term risks are higher because of
extensive excavation in Area A and other areas of the site to create a RCRA
vault.
Alternative 6: This alternative was rejected because of the higher short term
risks associated with extensive excavation on site and large scale onsite
incineration. Also, the cost is almost thirteen times that of the selected
remedy and the incremental benefits do not justify the high cost.
43
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APPENDIX A
-------
Public Health Service '
DEPARTMENT OF HEALTH & HUMAN SERVICES ,-*-!. -TQ Agency for Toxic Substance
"' ,! VT anci D'sease Registry
''""'
.-- j
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Page 2 - Mr. Carl Hickam
the State In 1974. In 1977, impoundments on the site overflowed and
contaminated a local pond and pastures; local fanners reported a fish kill
in a pond and the death of several cattle. Consequently, the State closed
the landfill in 1978. In addition to a variety of liquids, sludges, and
solid wastes, the 8-aere site possibly contains about 9,000 buried drums.
Land use around the IWC site consists of pastureland, scattered
residences, and a residential subdivision (Douglas Acres) to the northeast
(about 1,400 feet). A residential well survey revealed that no residences
within a one-half mile radius north of the site depend on private wells
for drinking water. Most of the private residential wells identified in
.the RI are no longer used because of the existence of the South Sebastian
County Rural Water Users Association and connection to the Fort Smith
municipal water system. However, several local wells are still used for
watering lawns, gardens, and livestock, a fish pond, and occasionally for
domestic uses when the municipal supply is not functional.
Please refer to our January 8, 1986, report for our assessment of local
residential well data. In this report, ATSDR recommended that residents
should avoid drinking water from Well 28 because of elevated levels of
benzo (A) pyrene (580 and 890 ppt). ATSDR could not find any other record
of previous involvement on the site, or on the draft phases of the
Remedial Investigation Report. We are concurrently reviewing the Final
Draft Feasibility Study Report and the Endangerment Assessment Report; we
will provide reports on them under separate cover.
LIST OF DOCUMENTS RE7TSWED
1. Final Remedial Investigation Report, Industrial Waste Control Site,
WA No. 69.6L37.0, Volume I and Volume II (Appendices), prepared for
EPA by CH2M Hill, March 31, 1986.
CONTAKTHANTS DF
On-site monitoring wells reveal elevated levels of organic and inorganic
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Page 3 - Mr. Carl Hickam
constituents including toluene (190 mg/L), methylene chloride (10 mg/L),
arsenic (0.44 mg/L), lead (0.383 mg/L), chromium (0.300 ng/L), nickel
(0.590 mg/L), manganese (44.4 ag/L), and barium (1.66 mg/L). Soil samples
in the vicinity of the site revealed elevated levels of cadmium
(56 mg/kg), beryllium (240 mg/kg), nickel (902 eg/kg), manganese
(3,690 mg/kg), benzidine (13 mg/kg), and benzo (A) pyrene (37 mg/kg).
ENVIRONMENTAL AND ETPOSUBE PATHWAYS
Ground Water
The RI provides little information on the possibility of future subsurface
releases from buried drums. Of the environmental pathways present on the
site, subsurface migration of contaminants from the site may pose the most
potential public health threat. Liquid wastes and deteriorating drums
containing liquid wastes are possible sources of contaminants.
According to the RI, up to four groundwater systems or aquifers exist in
the vicinity of the JVC site: two separate artesian aquifers within the
Lower Hartshorne Coal unit; a perched aquifer within the overburden, strip
mine fill, and upper portions of the McAlester shale; and an unconfined
aquifer within the Atoka Formation. With the exception of-the perched
aquifer beneath and immediately north of the site, all four aquifers have
been or can be used as a water supply source. The perched aquifer that
lies beneath the site has been contaminated from the site with both
organic and inorganic constituents. Although off-site contamination
exists in the perched aquifer north of the site, the concentrations are
significantly lower except for manganese in one residential well. ^ While
the possibility exists that the perched aquifer is connected to the other
three aquifers, no connection or contamination plume has been definitively
demonstrated to date.
On-site well samples in the perched aquifer revealed elevated levels of
toluene (190 mg/L), methylene chloride (10 mg/L), and acetone (45 mg/L).
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Page 4 - Mr. Carl Hiokan
Toluene and methylene chloride levels exceed both the draft health
advisories^ and the proposed Recommended Maximum Contaminant Levels
(HMCL's)3 for drinking water. On-site wells have been shown to be
contaminated with arsenic (0.44 mg/L), chromium (0.300 mg/L), nickel
(0.590 mg/L), lead (0.383 mg/L), barium (1.66 mg/L), selenium
(0.049 mg/L), iron (515 mg/L), and manganese (44.4 mg/LJ at levels which
exceed one or more of the following: the current Maximum Contaminant
Levels (MCL's)c, Secondary MCL's D, proposed RMCL'a, and the draft
health advisories for drinking water. Although arsenic was also detected
in most of the artesian groundwater samples near the site, arsenic was not
detected in the artesian groundwater samples taken farther from the site.
Chromium and nickel were also detected in the near off-site perched and
artesian groundwaters although no concentration plumes could be defined.
While beryllium was detected in only on-site wells, vanadium was found
both on-site and off-site in the perched aquifer. Although elevated
levels of inorganics have been found in the unconfined aquifer south of
the site, the RI indicates that this contamination is not related to the
site. Elevated levels of iron and manganese have been found in nearly all
of the groundwater samples. The iron and manganese levels in on-site
wells are significantly higher than in upgradient samples. The iron and
manganese levels in the near off-site wells (just to the north and
downgradient) are less than the on-site levels. However, these near
off-site levels are greater than the levels found upgradient of the site,
or the levels found farther north of the site, except for possibly one
residential well.
Ve believe the discussion of the presence and potential for off-site
migration through subsurface pathways is confusing in the RI. EPA
informed us on June 30, 1986, that while the- potential exists for off-site
migration, they do not believe any subsurface migration has occurred to
offsite areas.E This opinion was based on the study of the site
hydrogeology, particularly four shallow monitoring wells (04S, 39S, 23S,
and 40S) which were installed just north of the site. EPA explained that
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Page 5 - Mr. Carl Hickam
these wells demonstrated that little or no groundwater flowed from the
site through the perched aquifer.&
Because local geology is complex, we understand that it has been difficult
to define the possible extent of contamination in the perched aquifer for
off-site areas. However, we are concerned that three (04S, 39S, and 233)
of the four shallow monitoring wells Just to the north of the site could
not be used to measure groundwater quality in the perched aquifer. These
three wells have gone dry. Initially, they contained very small -amounts
of groundwater which was attributed to minor leakage or seepage from the
perched aquifer. Even though drilling information (Table 5-7 and
Appendix C) confirmed the presence of a perched aquifer and an
"unsaturated zone" (between the perched aquifer and the artesian aquifer),
the perched aquifer is limited in both thickness and water yield just
north of the site (p. 5-53). While Well 04S was set below the perched
aquifer (Figure 5-20), Well 39S was set above the static water level of
the perched aquifer (Figure 5-20). These two monitoring wells are the
only two monitoring wells installed between the site and the residential
wells (which lie north and northeast) to measure shallow groundwater flow
in the perched aquifer. The other two shallow monitoring wells (235
and 40S) lie outside the predominant groundwater flow direction from the
site. The "Geohydrology Cross Section11 (Figure 5-21) also shows Well 23S
to be screened in the "unsaturated zone" between the perched aquifer and
the artesian aquifer.
Nevertheless, the HI states that "the results of inorganic sampling
Indicate that on-site contaminants have been transported off-site into
both the perched and artesian groundwater systems" (p. 5-68). The HI also
states the "most important pathway ..." for shallow off-site migration
"...is probably lateral movement of contaminated perched groundwater to
off-site locations'* (p. 5-93). Nevertheless, due to the limited off-site
contaminant concentrations found, the RI concludes that "...contaminant
-------
criteria do set levels which prevent contamination which will be injurious
to human health or aquatic life as defined by EPA and the Arkansas Wate
and Air Pollution Control Act, they are considered relevant and appro-"
priate.
4.2.1.3 Solid Waste Disposal Act. The hazardous substances at the IWC
site contain waste for which land disposal restrictions have been pro-
mulgated (40 CFR 268). This section lists waste where land disposal is
either prohibited or will be prohibited at a future date. Since EPA
Hazardous Waste Nos. F001-F005 have been disposed onsite, requirements in
40 CFR 268.30 relating to land disposal of material generated during a
CERCLA response action between November 8, 1986 and November 8, 1988 are
considered applicable. After November 8, 1988, prohibition of land
disposal of solvent waste generated as a result of a CERCLA response
action, unless it meets the treatment standards expressed as concentration
limits for specific contaminants, will be applicable.
4.2.1.4 State Water Standards. The Arkansas Regulation Establishing Water
Quality Standards for Surface Waters provides that the concentrations of
toxicants in the receiving waters, after mixing with water from a point or
non-point source, shall not exceed 0.1 of the 96-hour LC50 for the most
sensitive indigenous species. These requirements are considered applicable
to surface discharges from the site such as treatment plant effluent and
runoff.
4.2.2 Action-Specific ARARs
4.2.2.1 Solid Waste Disposal Act (SWDA). The Solid Waste Disposal Act
was amended by the Resource Conservation and Recovery Act and subsequent
amendments (e.g. Hazardous and Solid Waste Amendments of 1984) to control
hazardous substances. The provisions of RCRA pertinent to the IWC site
have been promulgated under 40 CFR Parts 257, 260, 261, 262, 263, 264, 268,
and 280. EPA has determined that the above regulations are "applicable"
to RCRA characterized or listed hazardous wastes (40 CFR Part 260) which
either: (1) were disposed at a site after November 19, 1980; or (2) the
68523.ORF 4-5
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CERCLA remedial action consists of treatment, storage, or disposal as
defined by RCRA (40 CFR Part 264). In addition, these regulations are
"relevant and appropriate" to RCRA hazardous wastes disposed at a site
prior to November 19, 1980.
The contaminants of concern at the IWC site include listed RCRA hazardous
wastes (methyiene chloride, trichioroethene, tetrachioroethene, bis(2-ethyi-
hexyDphthlate, and toluene), but landfill operations ceased in 1978.
Therefore, the RCRA regulations are directly applicable" for any remedial
action involving treatment, storage, and disposal as defined by RCRA.
RCRA permits are not required for -onsite remedial actions. Therefore,
administrative RCRA requirements (i.e., reporting, record keeping, etc.)
are not "applicable or relevant and appropriate" for onsite activities.
However, all hazardous waste disposed offsite are required by CERCLA
121(d)(3) to be in compliance with all pertinent RCRA requirements.
o RCRA Storage Requirements - EPA defines storage under RCRA to be
a RCRA hazardous waste which is held for a temporary period, at
the end of which the hazardous waste is treated, disposed, or
stored elsewhere (40 CFR 260.10). The RCRA requirements are
"applicable" to activities of this type. In some cases, the
hazardous waste may first become subject to regulation as a
result of the action taken at the cleanup site. If the party or
parties conducting the cleanup are considered the generators of
the waste, 40 CFR 262.34 provides that, under certain conditions
the waste may be stored for 90 days before the RCRA Part 264
requirements become "applicable".
In the case of the IVC site, the RCRA requirements are applicable
only to any waste collected during remedial activities which may
be stored over 90 days. The requirements are relevant and appro-
priate for ail other storage activities such as temporary storage
of the buried drums because the actions governed by the require-
ment are sufficiently similar to those which may take place.
68523.ORF 4-6
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RCRA Treatment Requirements - CERCLA 121 establishes a preference
for remedial actions involving treatment that permanently and
significantly reduces the volume, toxicity, or nobility of the
hazardous substance, pollutants, and contaminants at the CERCLA
site. The RCRA requirements are applicable at a site if (1) the
waste is defined as hazardous, (2) the treatment complies with
the RCRA definition contained in 40 CFR 260.10, and (3) the
special jurisdictional prerequisites in the pertinent subpart for
each category of treatment are satisfied. Otherwise, the RCRA
requirements are "relevant and appropriate".
The RCRA requirements are applicable for all treatment units at
the IWC site such as incineration which are described by one of
the RCRA regulations. The RCRA requirements are only "relevant
and appropriate" for other treatment units such as tanks which
might be used to treat a non-RCRA hazardous waste because they
are well suited for the particular remedial actions being
proposed.
RCRA Disposal Requirements - EPA has defined disposal under RCRA
to be the movement (grading, excavation, etc.) of a RCRA. hazard-
ous waste originally disposed before the 1980 effective date of
RCRA from within a unit area of contamination and placed in
another location outside the unit area of contamination. The
RCRA requirements are "applicable" to activities of this type,
and "relevant and appropriate" to similar activities.
In the case of the IWC site, the landfill and the surface im-
poundments are considered to be "units", and therefore onsite and
offsite disposal outside of the unit area of contamination would
fall under these requirements and therefore be applicable. Using
the disposal requirements in this manner requires that the RCRA
design and operational requirements be met. These would include
the design requirements for landfills (Including waste piles
during construction).
68523.ORF 4-7
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Land Disposal Requirements - The disposal of RCRA hazardous waste
during the course of remedial action may also be subject to the
special restrictions on land disposal of hazardous waste estab-
lished by the Hazardous and Solid Waste Amendments of 1984
(HSWA). According to HSWA, all RCRA hazardous waste are to be
reviewed by EPA to determine if they should be banned from land
disposal facilities. Banned waste cannot be placed in or on the
land unless they have been first treated to levels achievable by
best demonstrated available technology (BDAT) for each hazardous
constituent in the waste. These conditions are applicable to the
offsite disposal of the buried drums containing free liquid and
will become applicable to onsite disposal or treatment of this
waste after November 8, 1988.
4.2.2.2 NPDES. During remediation, CERCLA 121(d) requires that storm
water discharges and remedial-activity generated discharges meet the pol-
lutant limitation and performance standards included in the Clean Water
Act. The wastewater treatment technology proposed in response alternatives
for CERCLA sites are required to meet the equivalent of best conventional
pollutant control technology (BCT) and best available technology economic-
ally achievable (BAT). EPA has promulgated the technology-based require-
ments through effluent limitation guidelines for specific categories
of industries with on-going operations which are then transferred into
specific discharge limits by NPDES permit writers. Where effluent guide-
lines for a specific industry or industrial category do not exist (e.g.,
Superfund sites), technology-based treatment requirements equivalent to
BCT/BAT will be determined on a case-by-case basis using best professional
judgment (BPJ) in accordance with CWA 402(a)(l)(B) and 40 CFR '125.3(c)(2).
Such requirements would be applied to the scrubber effluent from an onsite
Incinerator as an example.
68523.CRT 4-8
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4.2.2.3 State Hazardous Waste Management Act. The Arkansas Hazardous
Waste Management Code states siting criteria that are in addition to
contained in RCRA (40 CFR 264.18). Although permits are not required
onsite CERCLA activities, the substantive portions are .considered applic-
able to onsite remedial actions. Specifically, these requirements include:
o the active portions of a hazardous waste management facility can
not be located within 200 feet of a property line;
o the active portions of a hazardous waste management facility can
not be located within 300 feet of a public road, a water or
wastewaster line other than a service line to the facility, and
power transmission lines other than service lines to the
facility; and
o landfills or surface impoundments shall not be located where the
bottom of the liner is less than 10 feet from the historically
high water table.
\_
All of the above requirements may be applicable to the IWC site.
4.2.2.4 Air Quality. The Clean Air Act was promulgated "to protect and
enhance the quality of the Nation's air resources so as to promote the
public health and welfare and the production capacity of its population".
Sections of the Clean Air Act establishing Standards of Performance for
Incinerators (40 CFR 60.50-54) and the National Emission Standards for
Hazardous Air Pollution (40 CFR 61) which set emission standards for
incineration and the handling of volatile organic compounds (fugitive
emissions) are considered applicable to some of the alternatives
developed in this FS.
Regulations promulgated by the State of Arkansas Water and Air Pollution
Control Act are also considered to be applicable or relevant and appro-
priate. The Arkansas Air Pollution Control Code sets standards for
particulates that are applicable to any alternative utilizing onsite
incineration. Regulations for the Control of Volatile Organic Compounds
may be relevant and appropriate for the storage of volatile organics
because of the hazardous nature of the materials found onsite even though
the capacity limits for storage tanks will not be exceeded.
68523.ORF 4-9
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4-2.3 Location-Specific ARARs
No location specific ARARs were identified for the IWC site. The IWC site
is not located within a flood plain, wetlands, wilderness area, historic
site, or other protective designations.
68523.ORF 4_10
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APPENDIX D
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Industrial Waste Control
Community Relations Responsiveness Summary
This Cotmiunity Relations Responsiveness Suttmary has been prepared to provide
written responses to comments submitted regarding the proposed plan of action
at the Industrial Waste Control (IVC) 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 Industrial Waste
Control site.
Section II: Summary of Major Comments Received. The comments (both
oral and written) are sumnarized and EPA's responses are provided.
I. -Background of Community Involvement
Adjacent property owners have been aware of the'site since the early 1970s.
As a result of the heavy rains in 1977/ a resident whose property is directly
north (downgradient) of the F/C property filed suit in 1978 against IWC for
loss of cattle, forage, and fish. Since that time adjacent property owners
have had contact with the state during well testing trips and other site
investigation activities.
Local officials and residents of Greenwood and Fort Smith were generally not
aware of the Superfund site until the National Priorities List (NFL) was
published in December 1982. The Southwest Times Record and KFSM-TV of
Fort Smith ran stories about the site at that time. The Greenwood Democrat
also ran an article on the site in December 1983. The media coverage did
not appear to generate a great deal of local interest. Area residents
expressed a general concern regarding possible well contamination.
In the sutttner of 1986, EPA distributed a fact sheet regarding the results of
the remedial investigation and the feasible alternatives for clean-up.
Thirty-seven citizens attended a public meeting on July 1, 1986. In March
and December of 1987, EPA issued updates advising the citizens of the Steering
Committee's supplemental study. No additional concern/questions or comments
were generated as a result of these two updates.
-------
II. Summary of Major Garments Received
The press release and Proposed Plan fact sheet announcing the public cormient
period and public meeting were distributed on April 19, 1988. The comment
period began on May 2 and ended June 2, 1988. A public meeting was held with
area residents and local officials on May 9 at the South Sebastian County
Courthouse. The purpose of this meeting was to explain the results of the
remedial investigation and to outline the various alternatives presented in
the feasibility study. Thirty-five people from the area attended the meeting,
and 5 residents made oral statements or asked questions. Written comnents
or questions were received from one additional citizen and the IWC Steering
Committee.
Overall, the residents and local officials do not oppose the proposed plan.
During the public comment period, there were comments/questions regarding
the following:
Comment #1; If the proposed remedy is implemented, what restrictions will be
placed on land use?
EPA Response; Because this remedy leaves some contamination on the site
covered by a cap, it is not appropriate for either residential or commercial
use after the remedy is completed. The site will be fenced to restrict access.
Carment #2; For the neighbors near the site, what hazards or risks are
associated with the actual construction?
EPA Response; At this time, we cannot say specifically the amount of air
emissions that might be released during the construction. As we are designing
the remedy, we will include various measures to ensure the safety of the
neighbors. During excavation, air monitors will be used continuously to
measure the situation and storm water runoff control will be required.
Comnent #3; What information do you have about contamination in the strip mine
near the east end?
EPA Response; Samples taken from the trenches in the strip mine area indicate
that the contamination is located on the west end of the strip mine. The east
side of the mine was used for disposal of construction debris -and similar
materials that are not toxic.
Comment #4; What will the sequence of construction be; i.e., will stabilization
and drum ranoval be happening at the same time?
EPA Response; The construction sequence will be determined during the design
'phase. However, the liquid-filled drums will probably be removed before work
begins on the stabilization portion.
-------
Comment 15: A clay cap will meet the remedial objectives, so a multilayer
cap is not necessary.
EPA Response; During the technology screening phase of the Feasibility Study,
several types of caps were considered and assessed with respect to meeting the
remedial action objectives. Native soil, clay, sprayed asphalt, multilayer,
and other cap types were considered. Clay cap and multilayer cap were compared
in detail. The multilayer cap was considered most appropriate for this site
because: -
a) There are considerable quantities of biodegradable material in some
portions of the site, such as wood, that will decompose with time and
cause some subsidence. The multilayer cap should not fail under
moderate subsidence areas, while a clay cap probably would.
b) If groundwatar monitoring north (downgradient) of the site detects
offsite migration of contaminants, it is an indication that the remedy
has failed. Because reaction time is extremely limited, the design
should be conservative on the protective side.
. c) There is no bottom barrier, other than natural rocks and strata,
incorporated into the design of the partial containment structure
at the site. Therefore, the elements of the remedial alternative
that prevent water entry into the site should be the most protective
ones available.
Comment #6: The site-side barrier associated with the french drain could be
either a synthetic membrane or a slurry wall. The design phase of the project
should determine which is more appropriate.
EPA Response; EPA agrees. The design intent for this barrier is to prevent
onsite groundwater, which may be contaminated, from entering the french drain
systau. The barrier also provides an additional means of assuring that upgra-
dient groundwater does not flow past the french drain. Designs which meet the
intent will be acceptable.
Comment 17; The slurry wall around the stabilized waste is overprotective
because the area is already protected by a french drain and cap.
EPA Response; Bench scale studies performed during the Remedial Investigation/
Feasibility Study process indicated that the organic wastes at the site could
be stabilized. The stabilization process would produce a mixture that when
subjected to leaching tests would not release organic constituents at levels
which exceeded those established by EPA. However, the long-term dependability
of the stabilization of organic waste has not been demonstrated.
> EPA has accepted stabilization of organic wastes at other sites as part of a
final remedy, in almost every case, the stabilization mixture has been placed
in a secondary containment structure such as a landfill vault. EPA believes
that the slurry wall proposed for this site provides secondary containment
consistent with the unproven long-term performance of stabilized organic
wastes.
-------
The primary purpose of the french drain and cap is to minimize water entering
the site. These actions do not provide secondary containment of the stabilized
organic wastes.
Comment 18; The selected alternative is too restrictive with respect to offsite
disposal of liquid wastes. It should allow fuel blending in addition to, or in
place of, incineration.
EPA Response; EPA agrees with this comment. Current federal and state regula-
tions are very restrictive concerning techniques for disposal of liquid
hazardous wastes. Incineration has been a standard, almost universal, techno-
logy for liquid wastes because they can no longer be landfilled. However, if
there are reuse-type technologies or other disposal technologies that meet
current or anticipated (near-term) federal and state regulations, EPA would
consider these as acceptable.
Comment #9; The surface water diversion element in the selected remedy is
appropriate and properly designed.
EPA response; EPA agrees that the surface water diversion structure is a
logical design feature that ties the cap into the natural contours adjacent
to the site. The surface water diversion structure should adequately divert
surface water flowing towards the site from the south around the east and
west ends of the site so surface water then continues into natural drainage
north of the site.
Comment f10; Site access must be controlled to prevent possible destruction
or damage to remedial elements such as the cap. A new permanent fence around
the entire site would provide adequate protection.
EPA Response; EPA agrees. Fencing will be required as part of the final
action.
Comment #11; There are several design-related issues that EPA plans to
incorporate into the decision document that would be premature. These should
be determined during the renedial design.
EPA Response; Presentation of design details in the Feasibility Study should
not be construed to establish specific requirements for the final design.
Rather, the level of detail presented in the Feasibility Study should be used
to establish the design intent or minimum level of performance. Design details
have been presented to demonstrate that a design concept can in fact be
constructed and to provide a basis for estimating cost. EPA has attempted to
establish minimum levels of performance and will review design details as they
are developed.
Comment #12; Soils containing less that 1,000 parts per million total volatile
organics or total base/neutral organics should be left on site, unstabilized.
-------
EPA Response; The extent of clean up at a hazardous waste site should not be
based just on the total concentration of a chemical group. The chemicals within
that group will vary, probably considerably, with respect to toxicity. For
example, 1,000 ppm of volatile organics that are mostly trichloroethene would
be much more toxic than 1,000 ppm of volatile organics that are mostly acetone.
Clean-up criteria should be based on specific chemicals. Furthermore, this
proposed concentration of 1,000 ppm has no basis. It is not related to a health
risk, background level, or other appropriate criteria.
Clean-up levels should be based on chemicals and metals that were disposed at
this site that are toxic or hazardous. These might include volatile organics
such as toluene, trichloroethene, and methylene chloride and metals such as
lead, nickel, and chromium. The clean-up levels (concentrations) should be
established considering each chemical's toxicity, background levels, potential
leachability, mobility, and onsite concentrations.
Comment #13: Could the site be used for a house or garden after the remedial
action is complete?
EPA Response; The selected action is not a clean closure; that is, there will
be wastes left in some parts of the site. Also, structures such as a multi-
layer cap and a french drain (for groundwater control) will be built on the
site to contain the wastes that are left. Therefore, the site cannot be used
after the remedial action is in place. A fence will be constructed around the
site to prevent access and the site will not be usable as long as the wastes
remain. This will be much longer than 30 years. The groundwater would be
monitored frequently throughout the first 30 years at a minimum.
Comment #14; When material is excavated to be stabilized, will it all be dug
up at one time?
EPA Response; Only wastes within areas C and D will be excavated for stabili-
zation. These two areas are on the southcentral and southwest portions of the
site, and represent less than ten percent of the area of the 8-acre site. The
excavation will be planned so that only one specific area will be opened at a
time. The excavation process will also be planned to protect the landowners
adjacent to the site from dust or odors as much as possible. Areas C and D
do not include the former coal strip mine, so the old strip pit will not be
dug up.
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APPENDIX E
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E RECOF.D IND
In-Just ~ia3. W£ui7.e C:ri;r:l
SITE NUMBER: flRD 980496366
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