Unfeu
Protection
Agwxy
Office of
Emergency and
Remedial Response
Superfund
Record of Decision:
EPA/RCO/R06-9G055
September 1990
*
IX
\
Jacksonville Municipal
Landfill, AR
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PORT DOCUMEMTAT10N 1. RBWTMCX ] «•
PAGE EPA/ROD/R06-9C/C55 |
•••MjftM*
SUPERFUND RECORD OF DECISION
Tacksonville Municipal Landfill, AR
rirst Remedial Action - Final
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11 •UMMwnMiury NO«M
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09/27/90
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16. Ata«racl(UmM: 200 worts)
The 80-acre Jacksonville Municipal Landfill site is an inactive landfill outside the
city limits of Jacksonville, Lonoke County, Arkansas, in a floodplain area.
Neighboring the site are the Rogers Road Municipal Landfill and the Vertac Chemical
Superfund sites. From 1960 to 1973, approximately half the site was used to landfill
unknown types or quantities of drummed or loose waste. Before 1969, waste was openly
burned prior to onsite disposal in unlined trenches. During this period, trenching was
I used as the sole disposal method. EPA holds evidence that the onsite wastes were
physically and chemically similar to the wastes at the Vertac Chemical Superfund site,
and that the waste may have originated at Vertac. Dioxin was found in some of the
10-50 above-ground waste drums at the site. This Record of Decision (ROD) addresses
the drummed waste, soil, and loose debris, and their offsite disposal at the Vertac
facility. The primary contaminants of concern affecting the soil and debris, are
organics including pesticides, such as dioxin.
The selected remedial action for this site includes sampling of soil to determine the
amount of contaminated soil and debris onsite; excavating, with offsite thermal
(See Attached Page)
17. Docui
Record of Decision - Jacksonville Municipal Landfill, AR
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: organics (pesticides, dioxin)
-
If. Security CtaM (Thfe n^ort)
None
30. SMMri* CtaM (Thte Peg*)
None
21. N«.o(P*gM
182
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OPTIONAL FORW 272 (4-77)
(Formwty M7TS-38)
Dv0BrtMMfit of CMVWMF CA
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Record of Decision
Jacksonville Municipal Landfill
Superfund Site
U.S. Environmental Protection Agency
Region 6
September 1990
-------
EPA/ROD/R06-90/055
Jacksonville Municipal Landfill, AR
First Remedial Action - Final
Abstract (Continued)
treatment and disposal of soil and debris exceeding 2,3,7,8-TCDD 10 mg/kg at the Vertac
Chemical Superfund site; excavating, disinfecting, and onsite disposal of debris
removed from the 10 mg/kg TCDD-contaminated areas; backfilling, covering the remaining
soil and debris with clean soil; revegetating excavated areas at the site; monitoring
ground water; and implementing institutional controls including deed, ground water use,
and land use restrictions. The estimated present worth cost for this remedial action
is $1,949,940, which includes an annual O&M cost of $523,730.
PERFORMANCE STANDARDS OR GOALS: Soil action levels are based on action levels
established by the Centers for Disease Control. Soil with concentrations exceeding
2,3,7,8-TCDD 10.0 mg/kg will be excavated and transported offsite for treatment. Soil
with concentrations exceeding 2,3,7,8-TCDD 1.0 mg/kg but less than 10.0 mg/kg will be
covered with one foot of soil.
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DECLARATION FOR THE RECORD OF DECISION
JACKSONVILLE MUNICIPAL LANDFILL, ARKANSAS
SEPTEMBER 1990
Statutory Preference for Treatment as a
Principal Element is Met
and Five-Year Review is Required.
SITE NAME AND LOCATION
Jacksonville Municipal Landfill
Lonoke County, Arkansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Jacksonville Municipal Landfill site in Lonoke County,
Arkansas, which was chosen in accordance with Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP).
This decision is based upon the contents of the administrative
record file for the Jacksonville Municipal Landfill site.
The United States Environmental Protection Agency and the Arkansas
Department of Pollution Control and Ecology agree on the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This final remedy addresses remediation of soil contamination by
eliminating or reducing the principal and low-level threats posed
by the site through treatment, engineering and institutional
controls.
The major components of the selected remedy include:
i
-------
o Sampling soil in ten-foot by ten-foot grids to more accurately
define the amount of contaminated surface soil, debris, and
waste onsite;
o Excavating and packaging for transport contaminated soil and
debris containing more than 10 parts per billion (ppb)
equivalent 2,3,7,8-Tetrachlorodibenzo-p-dioxin (2,3,7,8-
TCDD);
o Transporting contaminated material to the Vertac Chemical
Corp. Superfund site in Jacksonville, Arkansas, and providing
temporary storage for the material at the Vertac site;
o Conducting thermal treatment of all contaminated material from
the Jacksonville Landfill being temporarily stored at the
Vertac site, and testing, disposal and revegetation of the
resulting ash;
o Steam cleaning and disposing of large items of refuse removed
from contaminated areas at the Jacksonville site;
o Backfilling and revegetating areas from which contaminated
soil was removed with uncontaminated native soil and
decontaminated refuse;
o Covering soil, debris and waste meeting the criteria stated
below with twelve inches of native soil;
CRITERIA: 1) Equivalent 2,3,7,8-TCDD concentrations greater
than 1.0 ppb and less than or equal to 10.0 ppb,
and/or
2) Cumulative Hazard Index greater than 0.3 for the
following compounds:
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T),
2,4,5-Trichlorophenoxy propionic acid (2,4,5-TP),
and
2,4-Dichlorophenol (2,4-DCP).
o Backfilling the open site trenches with clean fill;
o Ground water monitoring;
o Inspection and maintenance of the soil cover and of the
existing fence; and
o Land-use controls limiting ground water use on and immediately
downgradient of the site.
ii
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STATUTORY DETERMINATIQKS
The selected remedy is protective of human health and the en-
vironment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies (or resource
recovery) to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
Robert E. Layton Jp., P.E. Date
Regional Administrator
U.S. EPA - Region 6
iii
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TABLE OF CONTENTS
Section page
DECISION SUMMARY 1-1
BITE LOCATION AND DESCRIPTION 1-1
SITE LOCATION 1-1
SITE DESCRIPTION AND HISTORY 1-1
Topography and Surface Characteristics . . . 1-6
Geology 1-6
Hvdroaeo1oav 1-7
Classification of Ground Water 1-8
SURROUNDING LAND USE AND SENSITIVE RECEIVERS . . 1-10
ENFORCEMENT HISTORY 1-11
HIGHLIGHTS OF COMMUNITY PARTICIPATION 1-12
SCOPE AND ROLE OF PROPOSED RESPONSE ACTION 1-12
NATURE AND EXTENT OF CONTAMINATION 1-13
Soils 1-13
Onsite Soils and Sediment 1-13
Offsite Soils 1-25
Ground water 1-25
Monitoring Wells 1-34
Residential Wells 1-34
Surface Water 1-35
Background Water 1-35
Onsite Trench Water 1-35
Offsite Surface Water 1-35
Air Pollution 1-36
CONTAMINANT FATE AND TRANSPORT 1-36
Potential Routes of Migration 1-36
Soil 1-36
Ground water 1-37
Air 1-37
Surface Water/Sediment 1-38
SUMMARY OF SITE RISKS 1-40
EXPOSURE ASSESSMENT SUMMARY 1-43
Direct and Indirect Contact with Contaminated
Surface Soil Onsite and/or Offsite . . 1-43
Direct and Indirect Contact With Ground
water 1-44
Transport by Surface Runoff 1-45
Direct and Indirect Exposure to Surface Water
and Associated Biota 1-46
Inhalation 1-46
RISK EVALUATION SUMMARY 1-46
Explanation of Carcinogenic Risk 1-47
Explanation of Noncarcinogenic Risk .... 1-47
Results 1-48
DEVELOPMENT OF REMEDIATION GOALS 1-58
Pre-Remedial Action Levels 1-61
Page TOC-1
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Carcinogenic Risks 1-61
Noncarcinoaenic Risks 1-62
Post-Remedial Treatment Goals 1-63
DESCRIPTION OF ALTERNATIVES 1-64
COMMON ELEMENTS 1-64
Components 1-65
Costs 1-66
Applicable or Relevant and Appropriate
Requirements fARARs) 1-66
ALTERNATIVE 1 — NO ACTION 1-68
Description 1-68
Cost and Timing 1-69
Compliance with ARARs 1-69
ALTERNATIVE 2 — FENCE, CAPPING, LAND-USE CONTROLS,
MONITORING 1-69
Description 1-69
Cost and Timing 1-71
Compliance with ARARs 1-71
ALTERNATIVE 3 — EXCAVATION, OFFSITE THERMAL
TREATMENT AND LANDFILL, SOIL COVER, LAND-USE
CONTROLS, MONITORING 1-72
Description 1-72
Cost and Timing 1-73
Compliance with ARARs 1-73
ALTERNATIVE 4 — EXCAVATION, ONSITE THERMAL
TREATMENT, SOIL COVER, LAND-USE CONTROLS,
MONITORING 1-74
Description 1-74
Cost and Timing 1-75
Compliance with ARARs 1-76
ALTERNATIVE 5 — EXCAVATION, THERMAL TREATMENT AT
THE VERTAC CHEMICAL CORP. SITE, SOIL COVER,
LAND-USE CONTROLS, MONITORING 1-76
Description 1-76
Cost and Timing 1-77
Compliance with ARARs 1-77
Multiple Sites 1-78
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . 1-79
DESCRIPTION OF THE NINE EVALUATION CRITERIA . . . 1-79
ANALYSIS 1-80
Overall Protection 1-80
Compliance With ARARS 1-81
Long-Term Effectiveness 1-81
Reduction in Toxicity. Mobility, or Volume
Through Treatment 1-82
Short-Term Effectiveness 1-82
Implementability 1-84
Cost • 1-85
State Acceptance 1-85
Community Acceptance 1-85
SELECTED REMEDY 1-85
DETAILED DESCRIPTION OF REMEDY . 1-86
Page TOC-2
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REMEDIATION GOALS 1-90
1-90
COST 1-91
STATUTORY DETERMINATIONS 1-92
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT . 1-92
COMPLIANCE WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS 1-99
COST-EPPECTIVENESS 1-100
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES) TO THE MAXIMUM EXTENT
PRACTICABLE 1-100
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT . 1-101
DOCUMENTATION OF NO SIGNIFICANT CHANGES 1-101
RESPONSIVENESS SUMMARY 2-1
OVERVIEW 2-1
BACKGROUND ON COMMUNITY INVOLVEMENT 2-1
SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD 2-2
TECHNICAL QUESTIONS/CONCERNS REGARDING SELECTED
ALTERNATIVE 2-2
QUESTIONS/COMMENTS REGARDING REMEDIAL ALTERNATIVE
PREFERENCES 2-5
QUESTIONS REGARDING EFFECTIVENESS OF INCINERATION 2-10
QUESTIONS REGARDING THE REMEDIAL INVESTIGATION, RISK
ASSESSMENT AND FEASIBILITY STUDY METHODS AND
CONCLUSIONS 2-11
QUESTIONS REGARDING OTHER ISSUES 2-12
APPENDIX A — ADMINISTRATIVE RECORD INDEX A
Page TOC-3
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LIST OF TABLES
Table Pace
1 Drum Disposal Area Sample Analysis Summary 1-18
2 Secondary Hot Spot Sample Analysis Summary 1-22
3 Ground water Monitoring Well Sample Analysis
Summary 1-27
4 Residential Well Sample Analysis Summary 1-31
5 Summary of Site Risks Onsite and to Nearby
Residential Population — Carcinogenic Effects .... 1-49
6 Summary of Site Risks Onsite and to Nearby
Residential Population — Noncarcinogenic Effects . . 1-54
7 Summary of Remediation Goals 1-59
8 Cost Estimate: Alternative 5 1-93
LIST OF FIGURES
Figure Page
1 Site Location Map - State of Arkansas 1-2
2 Site Location Map - Jacksonville, Arkansas 1-3
3 Site Features Map 1-4
4 Locations with Equivalent 2,3,7,8-TCDD Exceeding
1 ppb and Exceeding 10 ppb 1-20
5 Ground Water Sample Locations (GW, RW) 1-26
Page TOC-4
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SECTION 1.0
DECISION SUMMARY
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DECISION SUMMARY
SITE LOCATION AND DESCRIPTION
SITE LOCATION
The Jacksonville Municipal Landfill site is located in Lonoke
County, outside the city limits of Jacksonville, Arkansas (Figures
1 and 2). It is situated south of Graham Road, one-tenth mile
east of the Pulaski/Lonoke County Line. Land records at the
Lonoke County Court House describe the eighty-acre plot of land as
the west half of the northwest quarter of Section 27, Township 3
North, Range 10 West. The site is approximately 12 miles
northeast of Little Rock, Arkansas.
Less than one-half mile west of the Jacksonville Landfill site
lies the Rogers Road Municipal Landfill. The Rogers Road site is
also a nationally-ranked Super fund site which is at the same stage
in the Superfund process as the Jacksonville Landfill site.
Because of the proximity of the sites and the similarities in
their features and characteristics, the site-related activities to
date have been conducted concurrently. It is further intended
that all future remedial activities will continue to be conducted
simultaneously so that "economies of scale" can be realized.
SITE DESCRIPTION AND HISTORY
The property was purchased by the City of Jacksonville in June
1960. The site has since been referred to as the Jacksonville
Landfill, Graham Road Landfill, Graham Road Site, Graham Road Dump
and Jacksonville City Dump.
Approximately 40 acres were used for landfilling (Figure 3). This
portion of the property was fenced in 1986 to prevent unauthorized
access. Records indicate that open burning and trenching with
bucket and dragline were the waste handling methods used until
1969. After 1970, trenching was the sole method used onsite.
Historical records indicate wastes were placed in burn areas and
later in unlined trenches from 1960 to 1973. Some of the wastes
in onsite drums were found to contain dioxin.
The landfill was closed in July 1973 when the Arkansas Department
of Pollution Control and Ecology (ADPC&E) refused to grant a
landfill permit because of the high water table and poor drainage
in the area.
No detailed records indicating specific waste types or quantities
are known to have been kept by the site owner/operator, making
identification of generators and operators difficult. Wastes
appear to have been disposed of in several excavated trenches and
long surface piles, and was accompanied by open dumping in
Page 1-1
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f CWvclind J Uncdn /»
SITE LOCATION MAP - STATE OF ARKANSAS
JACKSONVILLE LANDFILL, JACKSONVILLE, AR
1-5
-------
'03 EtONOI
_l
•DO nsnnd
JACKSONVILLE, ARKANSAS
1-3
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Graham Road
93
Sita Fence
N
Trenches
0 100 200 300 400
Scale (feet)
SITE FEATURES MAP
JACKSONVILLE LANDFILL, JACKSONVILLE, AR
FIG. 3
1-4
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numerous areas around the site. After waste disposal, the
excavated trenches and some of the larger surface piles appear to
have been covered with a layer of soil. After the landfill was
closed, local residents continued to use the site as an open dump
until it was fenced by the City of Jacksonville.
An underground gas transmission pipeline, operated by Texas
Eastern Corp., runs northeast-southwest through the landfill
property. The only structure onsite is a gas pipeline pumping
station and valve. An access road used by landfill operations
equipment runs roughly north-south through the fenced area of the
site. The only routine maintenance performed onsite is mowing of
the pipeline easement by Texas Eastern Corp. The remainder of the
fenced area is overgrown with brush and partially wooded. On the
eastern side of the landfill there is a subdivision with
approximately 30 houses, some of which have backyards which adjoin
the site.
The Jacksonville Landfill was identified as a possible
uncontrolled hazardous waste site on May 17, 1983, through a
citizens complaint to EPA regarding the possible disposal of
hazardous waste at the site. In July 1983, a Preliminary
Assessment/Site Investigation was conducted at the site by Ecology
and Environment, Inc. One offsite soil sample was collected
across Graham Road from the site entrance. Laboratory analysis of
this sample detected low levels of six organic compounds.
Compounds which were above laboratory detection limits were:
methylene chloride (102 ppb), methyl benzene (150 ppb) and
tetrachloroethane (740 ppb).
A Technical Assistance Team (TAT) from Weston-SPER inspected the
site on May 23, 1985, for photographic documentation and to assess
the site for access. An Ecology and Environment field
investigation team (FIT) performed site investigations in 1984 and
1985. A FIT report was prepared in August, 1985, outlining the
soil, residential well, surface water, sediment and air sampling
results. A follow-up report was prepared in November, 1986,
outlining additional air sampling results.
The initial FIT investigation report (February 1984) recommended
that additional soil, water and sediment sampling be performed to
more accurately characterize contamination at the site. The
November 1986 FIT report recommended that no additional air
sampling be conducted at the site. Review of the air sampling
data by the Centers for Disease Control (CDC) concluded that
"based on the data provided and the sampling conditions reported,
airborne volatile organic compounds do not represent a public
health problem onsite and do not appear to be contributing to
offsite exposure."
The Jacksonville Landfill was proposed for inclusion on the EPA
National Priorities List (NPL) of uncontrolled hazardous waste
Page 1-5
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sites on January 22, 1987. It was added to the NPL on July 22,
1987. The NPL score for this site was 29.64.
A remedial investigation (Rl) was conducted at the Landfill, with
field activities occurring between November 1988 and March 1990.
In conjunction with the Rl, a risk assessment (RA) was performed
based upon the analytical results for the field samples. The
results of the Rl, along with those from prior site
investigations, were summarized in the June 1990 Remedial
Investigation Report prepared by PEER Consultants, P.C. and
Resource Applications, Inc.
Having completed the Rl and RA reports, the project proceeded to
the Feasibility Study (FS) phase. The FS was conducted in order
to screen and evaluate the most promising options for remediating
the site. In addition, it provided a basis for remedy selection.
The results of the FS are documented in the Feasibility Study
Report, June 1990.
Topography and Surface Characteristics
The natural terrain at the site is flat, with less than a 1%
slope. However, trenches have been dug into the site, and soil
and debris piles created. Most soil piles are less than three
feet high, but some are up to fifteen feet high. Scattered trash
can be found on the surface at many locations. It is estimated
that 15 to 50 drums have been disposed of in an area in the
southern end of the site, known as the "drum disposal area." Most
of the drums have corroded completely away, leaving piles of
white, fibrous, adsorbent-type materials. The site is generally
covered with grass and ten to fifteen year-old wooded growth. It
is surrounded with a chain-link fence and/or barbed wire.
Portions of the chain link fence are easily climbed.
The site is partially located within a 100 year flood plain and is
poorly drained because of slow percolation of rainwater through
the type CL silty-clay and clay at the surface. Annual rainfall
averages 50 inches, but only two inches of rain is estimated to
percolate into the ground water system. The result is that the
site gets very muddy during periods of extended rainfall.
Bulldozers have been stuck in the mud during rainy weather when
the water table is high. The site is reported to be dry enough to
avoid significant problems with mud during July and August.
Geology
The Jacksonville Landfill Site is located a short distance
southeast of a fall zone formed by two major physiographic
provinces. Underlying the site is the Paleocene Age Midway
Formation and the Eocene Age Wilcox and Claiborne Groups of the
Coastal Plain. The Midway Formation is comprised of dark gray to
blue to black, noncalcareous, nonfissile, waxy clays; intermixed
Page 1-6
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with softer blue-gray, calcareous, foraminifera bearing clays.
Overlying this formation is the unfossiliferous, interbedded
chocolate-brown lignitic clays; black sandy clays; and very fine
sand of the Wilcox Group. Disconformably overlying the Wilcox is
the Claiborne Group, consisting of interbedded white to light gray
fine sand, gray to tan sandy clay, and lignite.
Thinning to the northwest, the Coastal Plain Sediments taper over
the Pennsylvanian Age Atoka Formation of the Interior Highland
physiographic provence, which outcrops along the fall zone. The
Atoka formation consists of interbedded shale and tightly cemented
siltstone and sandstone.
Most of the surface soil at the Jacksonville site consists of the
Amy Series Clay (CL) and silty clay (CL) . Some of the surface
soil can be described as high plastic clay (CH), organic clay (OH)
and organic silt (OL). These types of soil tend to be corrosive
to concrete and highly corrosive to steel. Glass fragments and
other refuse are mixed in with the soil in many areas of the site.
Figures 2-2 through 2-8 of the Jacksonville Landfill Remedial
Investigation Report show the geologic cross sections for the
Jacksonville and the nearby Rogers Road Landfill Site. These
cross sections illustrate the complexity of the subsurface strata,
as well as details concerning the locations of monitoring wells.
Hydrogeology
Ground water flow under and in the immediate vicinity of the
Jacksonville Site is to the east-southeast. A seasonally perched
water table sometimes reaches within one foot of the surface and
keeps surface soils saturated during the wet season. During the
hottest season (July and August) , it may recede to five feet or
more below the surface. The lowest rainfall levels typically occur
from August through October, and detailed information on seasonal
variations in the depth to perched water is unavailable.
However,rain can cause the perched water level to change by
several feet in a single day. The sources of the rapid changes in
the level of perched water may include the infiltration of rain-
water through the onsite open trenches, outcrop areas west of the
Rogers Road Site, and fill around the Texas Eastern Pipeline
(which is believed to be more porous than the surrounding soil).
Infiltration of rain-water through isolated areas where surface
soil contains a higher percentage of silt than other locations may
also contribute.
Shallow monitoring wells (with screen depths between 7 and 47 feet
below the surface) were placed into the perched aquifer. The
yield of water within these near-surface wells was too low for
this water to be considered a viable aquifer for commercial or
Page 1-7
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domestic use.
The Quaternary alluvial aquifer (at a depth of about 100 feet) is
the most important water bearing unit in the Jacksonville Area,
providing water for agricultural, domestic and municipal uses.
All municipal ground water wells tap Quaternary sand and gravel
deposits.
The Quaternary aquifer typically consists of 45 feet of basal
sands and gravel, overlain by about 80 feet of silts and clays.
However, the connections between this aquifer and the water in the
upper aquifer are very complex. Such a complex pattern of layers
of different material causes significant changes in hydrological
characteristics over even small distances.
Because of the preponderance of interbedded clays, silty clay, and
silts nearest to the surface (within which water is often
perched) , it is believed that the Quaternary aquifer is net in
direct hydraulic communication with the perched water at the
Jacksonville Landfill. However, long-term percolation of water
and contaminants through and around the layers of clay, silt,
sand, etc. into this aquifer may occur, thus causing indirect
communication.
Rising head slug tests indicate that the average conductivity for
the perched water zone is 2.73 x 10'5 ft/sec, whereas the average
in the deep zone is 8.43 x 10 ft/sec.
Classification of Ground Water
It is the policy of EPA's Superfund program to use as a guide the
framework provided by EPA's Ground water Protection Strategy in
determining the appropriate remediation for contaminated ground
water. Three classes of ground water have been established on the
basis of ground water value and vulnerability to contamination.
The various ground water classes follow:
Class I; Special ground water (Class I) is highly vulnerable to
contamination because of hydrological characteristics of the areas
in which it occurs, and characterized by either of the following
factors:
• The ground water is irreplaceable; no reasonable alternative
source of drinking water is available to substantial
populations.
The ground water is ecologically vital; the aquifer provides
the base flow for a particularly sensitive ecological system
that if polluted, would destroy a unique habitat.
Class II: This classification includes all other ground water
Page 1-8
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that is currently used (IIA) or is potentially available (IIB) for
drinking water, agriculture, or other beneficial use.
Class III; Class IIIA and IIIB ground water is that which is not
considered a potential source of drinking water and of limited
beneficial use. This classification may be used when the water is
saline (i.e., it has a total dissolved solids level of 10,000
milligrams per liter (mg/1), or is otherwise contaminated beyond
levels that allow remediation using methods reasonably employed in
public water treatment systems. This contamination could be due
to naturally occurring constituents, human activity that is not
associated with a particular waste disposal activity or another
site. Class III also includes ground water that is not available
in sufficient quantity at any depth to meet the needs of an
average household.
Class IIIA includes ground water that is interconnected to surface
water or adjacent ground water that potentially could be used for
drinking water. Class IIIB includes ground water that has r.o
interconnection to surface water or adjacent aquifers. For Class
IIIA ground water, establishing cleanup levels should take into
consideration the degree of interconnection to Class I or Class II
ground water or the rate of discharge to surface water so that
levels of contaminants in higher class ground water do not
increase as a result of the interconnection.
The State of Arkansas has not yet instituted an active ground
water classification program. The ground water below the
Jacksonville site has not been State-classified and was therefore
classified for the purposes of establishing remedial objectives
according to the criteria set forth above. The results of the
classification process are presented below.
The Quaternary alluvial aquifer (at a depth of approximately 100
feet) is the primary water bearing unit in the Jacksonville area.
This ground water unit is classified for the purposes of this site
as a Class IIA aquifer.
Testing results of the shallow ground water unit at the
Jacksonville Landfill site indicate an average pumping yield of
less than one gallon per minute. This is not a high enough yield
to provide an adequate supply of water for the needs of an average
household.
This ground water body is separated from the lower, Class IIA
aquifer by a layer of interbedded clays and silts. As previously
mentioned, it is believed that the interconnection between the
aquifers is not direct, however, long-term percolation of water
and contaminants through and around the layers of clay, silt and
sand into this aquifer may occur, thus causing indirect
communication.
Page 1-9
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The lack of sufficient water quantity in the shallow water bearing
zone, combined with the low degree of interconnection with the
Class IIA aquifer below results in the classification of this
aquifer as IIIA.
It should be noted that the classifications provided above are
site specific and limited in scope. Classifications performed by
EPA under the Superfund program do not apply to the general
geographic area in which they are performed, nor to any Federal,
State, or private action other than Superfund remediation.
SURROUNDING LAND USE AND SENSITIVE RECEIVERS
The site is located within a residential area. Within a 1/2 mile
radius of the Jacksonville Landfill, there are approximately 51
single family homes. One-half mile radius was chosen because of
the population distribution. That is, there were quite a few
homes within a one-half mile radius, followed by a more sparsely
populated area. Assuming an average of three to four people p*»r
home, approximately 153 to 204 people live within a 1/2 mile
radius of the site. The closest residential dwellings are located
30 yards away from the fence delineating the eastern boundary of
the Jacksonville Landfill. The northern, western, and southern
site boundaries abut undeveloped or agricultural property.
The results of a well inventory performed during the RI indicated
that all of the residential wells were screened within the lower
water-bearing unit. Most of the wells have been decommissioned;
only one residential well adjacent to the site is used as a non-
potable source for lawn watering and car washing. The residents
adjacent to the landfill currently are on a municipal water
system. With the possible exception of one household located near
the north end of the Jacksonville Site, the drinking water aquifer
is not used by local residents for indoor domestic purposes. This
household is not immediately adjacent to the landfill.
There are no businesses or commercial areas located within one and
one-half miles of the landfill. There is a school within three
quarters of a mile of the landfill. The types of receptors are
not expected to change within the next 50 years. This is because
no new businesses, commercial areas or schools are expected to
relocate within at least one mile of the landfill. Part of the
landfill is located within a flood plain area and development
would be costly. The rest of the landfill is located within a
predominantly agricultural area. Because of these factors, the
area does not lend itself to extensive commercial development.
Within the next 50 years, the number of residences immediately
adjacent to the landfill could increase. The numbers of people in
the entire City of Jacksonville area are expected to increase
relatively slowly compared to more densely populated regions in
the United States within the next 40 years. The Metropolitan
Council of Governments for the Little Rock/North Little Rock
Page 1-10
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Metropolitan Statistical Area has estimated the population of the
City of Jacksonville to be 53,000 in the year 2020 and 62,540 in
the year 2030. Taken together, within the next 50 years the types
of receptors are expected to remain relatively stable, with a
slight increase in the number of people in the immediate area of
the landfill.
Vegetation flourishes throughout the landfill, with the exception
of the drum disposal area. Here, vegetation is stressed or is
completely absent within a radius of approximately 10 feet or more
around the drums. There were many footpaths throughout the area,
most leading from the homes on the east side. The large
embankments of fill material had bicycle tracks as did the
impoundments. It appeared that children had played there quite
extensively. During a FIT Team sampling inspection in 1985, a
blue pickup truck was observed dumping some household waste
onsite; and the driver seemed to be scavenging through the other
trash as the FIT Team left the site.
Investigations indicate there are no sensitive or endangered
species or critical habitats located within or immediately
adjacent to the landfill. Animals most likely impacted are common
wildlife such as squirrels, rabbits, birds and deer, and domestic
animals that were observed onsite during the remedial
investigation.
ENFORCEMENT HISTORY
During the years that the Jacksonville Landfill was operated, the
site was run as a typical sanitary landfill and not as a RCRA
permitted disposal facility. As a result, companies which hauled
waste to the landfill were not required to provide the site
operator with detailed information regarding generators, waste
types, or quantities. The potentially responsible party (PRP)
searches described below were used identify the parties involved
in waste operations at the site and the extent of their
involvement.
In order to assist in the identification of generators and
transporters of site wastes, EPA sent requests for information
under CERCLA Section 104(e)(1) to several firms considered to have
information regarding the disposal of wastes at the site. These
requests were sent during the period of June 1985 to September
1985. Responses were received during the following months.
In February 1987, a potentially responsible party (PRP) search was
initiated. The site owner/operator during the period of its
operation as a sanitary landfill was identified as the City of
Jacksonville. The investigation concluded that the two primary
PRPs identified during the search as generators of chemical wastes
at the Rogers Road Landfill were Hercules Inc., and Vertac
Page 1-11
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Chemical Corp.
The PRPs were notified in writing on January 5, 1988 via special
notice letters and given the opportunity to conduct the RI/FS
under EPA oversight. None, however, elected to undertake these
activities. As part of their responses to the special notice
letters, the PRPs provided EPA with lists of additional parties
which may have been involved in the disposal of chemical wastes at
the site. EPA has initiated a second PRP search in effort to
investigate the actual involvement of the parties identified on
the lists, and to obtain additional information regarding
previously identified PRPs.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Jacksonville Landfill Municipal
Landfill site was finalized in November 1988. This document lists
contacts and interested parties throughout government and the
local community. It also establishes communication pathways to
ensure timely dissemination of pertinent information and
emphasizes community involvement. A fact sheet outlining the
Superfund process and the Remedial Investigation plans was
distributed at an open house in July 1988. Updates were also
released in November 1988, March 1989, July 1989, December 1989
and May 1990. The RI/FS and Proposed Plan were released to the
public in July 1990. All of these documents were made available
to the public at the two local information repositories: the
Jacksonville City Hall and Public Library. The Administrative
Record is maintained at City Hall. An open house was held on July
12, 1990 to provide an opportunity for residents to discuss the
proposed plan and prepare their comments for the public meeting.
A public comment period was held from July 9, 1990 through
September 7, 1990. In addition, a public meeting was held on July
18, 1990 to present the results of the RI/FS and the preferred
alternative. All comments received by EPA prior to the end of the
public comment period, including those expressed verbally at the
public meeting, are addressed in the Responsiveness Summary which
is attached to this Record of Decision.
OP PROPOSED RESPONSE ACTION
The studies undertaken at the Jacksonville Landfill site revealed
that contaminated soil (particularly several "hot spots" near the
south end of the property) comprises the principal threat posed by
the site. The scope of this Record of Decision is to address this
and other low level site threats in the following fashion:
o Remedy contaminated soil using thermal treatment (for the
principal threat) and soil cover (for the low level threat)
so that it no longer presents a threat to human health or the
environment.
Page 1-12
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o Eliminate the health risks due to ponded water onsite by
filling the existing site trenches with clean fill.
o Establish a method of long term monitoring to ensure that the
soil cover is properly maintained and that the ground water
quality is adequately monitored.
This final remedy is intended to address the entire site with
regard to the principal and low level threats to human health and
the environment posed by site contaminants as indicated in the
risk assessment for the site. The findings of the risk assessment
are presented in the Jacksonville Landfill Risk Assessment Report,
April 1990, and are summarized in a later section of this
document.
As previously mentioned, the Rogers Road Municipal Landfill site
is located approximately 1/2 mile west of the Jacksonville site
and has been identified as having many similar site features and
characteristics. Due to the similarities of the Jacksonville and
Rogers Road sites, remedial activities for both are proposed to be
conducted simultaneously. By implementing similar treatment
methods and utilizing the same equipment, considerable cost,
logistical, and administrative benefits can be obtained.
The Jacksonville and Rogers Road wastes are very similar in
physical and chemical makeup to that waste produced by Vertac
Chemical Corp., of Jacksonville, Arkansas. In addition, EPA holds
evidence that indicates that the waste did indeed come from that
facility. After careful consideration, it has been determined
that in all likelihood the dioxin and herbicides located at these
two landfills originated at Vertac. For this reason it is
proposed that these wastes be excavated and transported back to
the Vertac facility for ultimate disposal.
SUMMARY OF SITE CHARACTERISTICS
MATURE AMD EXTENT OF CONTAMINATION
Soils
Onsite Soils and Sediment: The primary source of organic
contamination at the Jacksonville Landfill site is the drum
disposal area at the south end of the property. It is estimated
that 15-50 drums have been disposed of in this area. It appears
that the drums were disposed of only on the surface and that no
buried drums exist in the site. The contamination of most concern
in and immediately adjacent to this area is due to dioxin/furan
and herbicide compounds. The contaminants of concern that were
detected in appreciable concentrations are 2,3,7,8-
Tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD), the herbicides 2,4-
Dichlorophenoxy acetic acid (2,4-D), 2,4,5-Trichlorophenoxy acetic
Page 1-13
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acid (2,4,5-T) and 2,4,5-Trichlorophenoxy propionic acid (2,4,5-
TP or Silvex) and the semivolatile organic compound, 2,4-
Dichlorophenol (2,4-DCP).
2,3,7,8-TCDD is the most toxic of the class of compounds known as
chlorinated dibenzo-p-dioxins, or commonly referred to as simply
"dioxins". There are 75 possible dioxins. 2,3,7,8-TCDD is a
colorless solid with no known odor. It does not occur naturally
nor is it intentionally manufactured by any industry, except as a
reference standard. It can be inadvertently produced in very
small amounts as an impurity during the manufacture of certain
herbicides and germicides and has been detected in products of
burned municipal and industrial wastes. At the present time,
2,3,7,8-TCDD is not used for any purpose other than scientific
research.
In humans, 2,3,7,8-TCDD causes chloracne, a severe skin lesior
that usually occurs on the head and upper body. Unlike common
acne, chloracne is more disfiguring and often lasts for years
after the initial exposure. There is suggestive evidence that
2,3,7,8-TCDD causes liver damage and digestive disorders in
humans. Animal studies have indicated that dioxins produce
toxicity to the immune system, promotes adverse reproductive
effects, and can result in malformations in the offspring,
although these latter effects have not been demonstrated in
humans. The human evidence for 2,3,7,8-TCDD alone is inadequate
to demonstrate or reflect a carcinogenic hazard, but based on the
positive evidence provided through animal studies, 2,3,7,8-TCDD is
considered by EPA to be a probable human carcinogen.
During the late 1970s, the EPA was faced with assessing the human
health significance of exposure to 2,3,7,8-TCDD. In preparation
for the cancellation hearings for the herbicides 2,4,5-T and
Silvex, the Agency generated risk assessments for several toxic
responses for 2,3,7,8-TCDD. The quantitative cancer risk
assessment developed by the Carcinogen Assessment Group was later
adapted for use in the Water Quality Criteria Document for
2,3,7,8-TCDD. In addition to carcinogenicity concerns, the Water
Quality Criteria document contains an assessment of systemic
toxicity based on reproductive effects resulting from exposure to
2,3,7,8-TCDD.
Later, it became clear that exposure situations exist in the
country which involve more than 2,3,7,8-TCDD alone. Data on
emissions from combustion sources (e.g., hazardous waste and
municipal waste incinerators and contents of waste from certain
industrial production processes indicate that the majority of the
75 chlorinated dibenzo-p-dioxins (CDDs) and 135 chlorinated
dibenzofurans (CDFs) can be detected in the environment.
In recent years, the reporting of at least homologue-specific date:
for the CDDs and CDFs has become commonplace, and the Agency has
Page 1-14
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taken some steps to address the significance of these findings.
For example, the Health Assessment Document for Polychlorinated
Dibenzo-p-Dioxins, prepared for the Office of Air Quality Planning
and Standards, contains a quantitative risk assessment for a
mixture of hexachlorodibenzo-p-dioxins (HxCDDs) based on
carcinogenicity studies conducted by the National Cancer
Institute. These concerns have also led to regulatory action:
e.g., several industrial wastes containing tetra-, penta-, and
hexa-chlorodioxins, and -dibenzofurans were recently designated by
the Agency as EPA hazardous wastes.
Faced with increasing amounts of isomer- and homologue-specific
data, and recognizing the significant potency and structure-
activity relationships exhibited in in-vivo and in-vitro studies
of CDDs and CDFs, the CDD/CDF Technical Panel of the Risk
Assessment Forum (Forum) perceived a need to address more
generally the potential risks posed by mixtures of congeners other
than 2,3,7,8-TCDD and HxCDDs. Detailed consideration of the
toxicity of the vast majority of the CDDs and CDFs is limited by
the lack of a complete toxicological data base on most of the
congeners. Further, it is unlikely that many long-term test
results will be available soon. For example, research on 2,3,7,8-
TCDD has been under way for more than two decades at an estimated
cost of more than one hundred million dollars. Therefore, the
Forum was instrumental in leading to EPA's adoption of an interim
science policy position for use in assessing risks associated with
CDD/CDF mixtures, until more definitive scientific data are
available.
The toxicity equivalency factor (TEF) method is an interim
procedure for assessing the risks associated with exposures to
complex mixtures of CDDs and CDFs. The method relates the
toxicity of the 210 structurally related chemical pollutants and
is based on a limited data base of in-vivo and in-vitro toxicity
testing. By relating the toxicity of the 209 CDDs and CDFs to the
highly studied 2,3,7,8-TCDD, the approach simplifies the
assessment of risks involving exposures to mixtures of CDDS and
CDFs.
In 1987, the EPA formally adopted an interim TEF procedure (EPA-
TEF/87), which was used by EPA regulatory programs and Regions in
addressing a variety of situations of environmental contamination
involving CDDs and CDFs. The EPA-TEF/87 method was published as
"Interim Procedures for Estimating Risks Associated with Exposures
to Mixtures of Chlorinated Dibenzo-p-dioxins and -Dibenzofurans
(CDDs and CDFs)", (EPA/625/3-87/012). Since the time that the
1987 report was published, the Agency was active in an
international project aimed at adopting a common set of TEFs, the
International TEFs/89 (I-TEF/89), to promote consistency in
addressing contamination involving CDDs and CDFs. The first
update report, "1989 Update to the Interim Procedures for
Estimating Risks Associated with Exposures to Mixtures of
Page 1-15
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Chlorinated Dibenzo-p-dioxins and -Dibenzofurans (CDDs and CDFs)",
identifies EPA's adoption of the I-TEF/89 as a revision to the
EPA-TEF/87.
The I-TEF/89 method was followed throughout the RI/FS process at
the Jacksonville Landfill project. For comparison, the EPA-TEF/87
calculations were produced and documented in the Jacksonville
Landfill Risk Assessment Report. In general, the effect of the
modifications reflected in the I-TEF/89 method were modest, with
the calculated differences falling within 2-5 percent of each
other. The equivalency factors used in each of these methods are
presented in the Risk Assessment Report. Where the term
"equivalent 2,3,7,8-TCDD" is mentioned in this Record of Decision,
it refers to an equivalent concentration of 2,3,7,8-TCDD resulting
from the I-TEF/89 method of calculation.
Dichlorophenoxy acetic acid (2,4-D) is a systemic herbicide widely
used for control of broad leaf weeds in cereal crops and sugar
cane and on turf, pastures and non-cropland. It is a component of
Agent Orange, the defoliant most widely used in Vietnam. It
promoted tumors after being painted on the skin of mice, and it
probably is a weak mutagen. 2,4-D caused developmental
abnormalities and was fetotoxic when administered to pregnant
rats, mice, and hamsters. Dermal exposure to 2,4-D causes severe
peripheral neuropathy.
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T) is an organic acid
that possesses the property of regulating plant growth at low
concentrations and killing plants at high concentrations. It has
been used to induce coloration in fruit, as a fruit set and
antidrop agent, for brush control and to control aquatic and
herbaceous land plants. Possibly its most significant use was as
one of the major constituents of Agent Orange. It is commonly
contaminated with 2,3,7,8-TCDD, which may be responsible for some
of the effects associated with exposure to technical 2,4,5-T.
These effects include chloracne and the induction of microsomal
mixed function oxidase activity. Administration of purified
2,4,5-T has been shown to cause fetal loss, disrupt fetal
development, and induce fetal malformations. In 1979, EPA ordered
an emergency ban on 2,4,5-T production based on a report of an
increase in spontaneous abortions in women of a forestry
community. That ban has never been lifted and all uses have been
canceled.
2,4,5-Trichlorophenoxy propionic acid (2,4,5-TP) is a broad
spectrum herbicide which is contaminated with 2,3,7,8-TCDD, a
toxic byproduct formed during the manufacturing process. 2,4,5-
TP acts as a hormone-type weed killer and is readily absorbed by
leaves and stems. The toxic effects associated with exposure to
2,4,5-TP are generally considered to be caused by 2,3,7,8-TCDD.
However, pure 2,4,5-TP may have an adverse effect on reproduction
that is not attributable to 2,3,7,8-TCDD.
Page 1-16
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2,4-Dichlorophenol (2,4-DCP) is a semivolatile organic compound
which is not very persistent in the environment. There is
equivocal evidence suggesting that it may act as a tumor promoter.
Subcutaneous administration of 2,4-DCP to pregnant mice induced
minor teratogenic effects. Chronic exposure caused nonspecific
liver changes in mice.
The highest concentration of 2,3,7,8-TCDD detected at the site was
found within the drum disposal area at 193 ppb. The total
2,3,7,8-TCDD equivalence of this sample was 196 ppb. Also found
within the drum disposal area were the highest concentrations of
herbicides at 74,000,000 ppb (7.4%), 36,000,000 ppb (3.6%) and
3,000,000 ppb (0.3%) for 2,4-D, 2,4,5-T, and 2,4,5-TP
respectively. The maximum detected concentration of 2,4-DCP was
140,000 ppb. Detected compounds, concentration ranges and
detection frequencies associated with this location is summarized
in Table 1.
Based upon the results documented in the Jacksonville Landfill
Contaminant Mapping Study Report (July 27, 1990), it is estimated
that within the drum disposal area, approximately 220 cubic yards
of soil, waste and debris contain more than 1 ppb of equivalent
2,3,7,8-TCDD. Because of the strong adhesion of dioxin/furan
compounds to the clayey soil found at the site, all contamination
appears to be limited to the top one foot of soil. This quantity
also includes approximately 130 cubic yards of soil which was
found to contain more than 10 ppb equivalent 2,3,7,8-TCDD.
Secondary areas of concern are soil and refuse piles throughout
the site and former waste disposal trenches. Three locations were
found to contain moderate levels of dioxin/furan and herbicide
compounds. The surface soil samples associated with the three
locations outside the drum disposal area had equivalent 2,3,7,8-
TCDD concentrations exceeding 1.0 ppb. These areas are associated
with the following samples and are presented in Figure 4:
Location 1
o Sample No. PS/PT-07, taken from the top of a pile near the
road about 312 feet north of the drum disposal area, where
the 2,3,7,8-TCDD concentration was 6.8 ppb,
o Sample No. PS/PT-08, taken from the top of a pile on the
other side of the road from PS/PT-07, where the 2,3,7,8-TCDD
concentration was 2.3 ppb,
Location 2
o Sample No. SS-F4-01, a grid sample on the east side of the
site, about 72 feet west of the site fence, where the
2,3,7,8-TCDD concentration was 1.0 ppb,
Page 1-17
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TABLE 1
DRUM DISPOSAL AREA
SAMPLE ANALYSIS SUMMARY
JACKSONVILLE LANDFILL
Compound
No. of
Occurrences/
No. of Samples
Concentration
Range (ppb)
Sample With
Maximum
Concentration'25
Volatile*
Methylene Chloride
Acetone
Chloroform
Trichloroethene
Tetrachloroethene
Toluene
Total Xylenes
10/10
10/10
2/10
1/10
3/10
2/10
2/10
16-120*
20-430
2-3*
7*
3-10
3-7
42-120*
DS-08
DS-03
DS-07
DS-07
DS-04
DS-08
DS-03
D
D
Semivolatiles
Phenol 1/10
2-Chlorophenol 2/10
1,3-Dichlorobenzene 1/10
Benzole Acid 3/10
2,4-Dichlorophenol 8/10
1,2,4-Trichlorobenzene 3/10
Napthalene 1/10
2-Methylnapthalene 5/10
2,4,6-Trichlorophenol 1/10
2,4,5-Trichlorophenol 10/10
Fluorene 1/10
Bis(2-Ethylhexyl)
Phthalate 2/10
Dioxins
TCDFs 17/22
PeCDFs 16/22
HxCDFs 11/22
HpCDFs 6/22
OCDF 4/22
2,3,7,8-TCDF 9/22
TCDDs 17/22
PeCDDs 14/22
HxCDDs 10/22
HpCDDs 11/22
OCDD 11/22
2,3,7,8-TCDD 16/22
240'
320-670
1,100
190-9,700
1,200-140,000
130-6,900
11,000
280-84,000
3,800
8,400-3,900,000
400
2,300-29,000*
2.2-180
0.77-130
0.2-18.1
0.33-3.7
0.16-1.24
2.7-73.7
3-210
0.94-180
0.3-64
0.07-22.7
0.13-13.7
0.47-190
DS-09
DS-04
DS-06
DS-08
DS-03
DS-03
DS-03
DS-03
DS-06
DS-05
DS-09
DS-02
DS-04
DS-04
AD-05
SS-04
SS-04
DS-04/2
DS-04
DS-09
DS-09
SS-04
SS-04
DS-Q4
1-18
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TABLE 1 (Cont'd)
DRUM DISPOSAL AREA
SAMPLE ANALYSIS SUMMARY
JACKSONVILLE LANDFILL
Compound
-------
Graham Road
LOCATJON 1 0
''PS-RT-08
LOCATION 2
SS-F4-01
N
A
CONTAINS > 1 ng/g • CONTAINS > 10 ng/g o 100 200 soo 400
EQUIVALENT 2,C-,7I8-TCDD EQUIVALENT 2,3,7,8-TCDD Sca|e (feet)
LOCATIONS WITH EQUIVALENT 2,3,7,8-TCDD
EXCEEDING 1 ng/g AND EXCEEDING 10 ng/g
JACKSONVILLE LANDFILL, JACKSONVILLE, AR
FIGURE 4
1-20
-------
Location 3
o Sample No. SS-H2-01, taken about 38 feet west of the drum
disposal area, where the 2,3,7,8-TCDD concentration was 15
ppb.
The drum disposal area appears in the Figure as "Location 4".
Detected compounds, concentration ranges and detection frequencies
associated with the secondary hot spots above are summarized in
Table 2. Contaminated soil volumes are as follows:
SOIL VOLUMES
Location 1.0 < Cone. < 10 ppb > 10 ppb Total
1 90 cy 90 cy
2 5 cy 5 cy
3 85 cy 50 cy 135 cy
4 140 cy 80 cy 220 cy
Total: 320 cy 130 cy 450 cy
Contamination in Locations 1, 2 and 3 is not considered to be due
to contaminant migration from the drum disposal area, since
contaminants were not detected in any migration pathways (i.e.,
drainage areas or low lying soils near the drum disposal area);
but is more likely due to incidental dumping or spillage
associated with disposal at the main drum disposal area, with the
exception of Location 2. Here, the combination of PCBs,
pesticides and other semivolatile hydrocarbons present at this
sample location suggests that it may be contaminated as a result
of the burning of PCBs (such as those found in transformers)
and/or pesticides.
One of the primary factors considered when evaluating proper
treatment and disposal of contaminated site soil is whether the
waste material is "RCRA listed". That is, whether it is contained
in one of the lists of hazardous wastes under 40 CFR Part 261,
Subpart D.
Under 40 CFR Part 261.31, wastes from various processes that are
likely to produce dioxins are listed as F020, F021, F022, F023,
F026, F027 and F028 hazardous waste. For example, wastes from the
production or manufacturing use of tri- or pentachlorophenol (or
c-f intermediates used to produce their pesticide derivatives) are
listed as hazardous waste number F020.
The list of chemicals detected at the Jacksonville Landfill Site
includes such substances as 2,4-D, 2,4,5-TP, 2,4,5-T and
trichlorophenol, disposed of in the drum disposal area at
Page 1-21
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TABLE 2
SECONDARY HOT SPOT
(LOCATIONS 1, 2 AND 3)
SAMPLE ANALYSIS SUMMARY
JACKSONVILLE LANDFILL
Compound
No. of
Occurrences/
No. of Samples
Concentration
Range (ppb)
Sample With
Maximum
Concentration'2'
Volatile*
Methylene Chloride
Acetone
2-Butanone
Semivolatiles
2 , 4-Dichlorophenol
1,2, 4-Trichlorobenzene
2,4, 6-Trichlorophenol
2,4, 5-Trichlorophenol
Fluoranthene
Pyrene
Chrysene
Benzo (a) anthracene
Bis(2-ethylhexyl)
phthalate
Benzo(a)pyrene
Di-n-Octyl Phthalate
Pesticides/PCB
Aldrin
4, 4 -DDT
Gamma-chlordane
Aroclor 1016
Aroclor 1248
Aroclor 1254
Dioxins
TCDF'S
PeCDF'S
HxCDF ' S.
HpCDF ' S
OCDF
TCDD'S
PeCDD'S
HxCDD'S
HpCDD ' S
OCDD
2,3,7,8-TCDD
3/6
3/6
1/6
1/6
1/6
1/6
1/6
1/6
1/6
1/6
1/6
4/6
1/6
1/6
1/6
1/6
1/6
1/6
1/6
1/6
3/6
3/6
4/6
4/6
4/6
4/6
4/6
4/6
4/6
4/6
4/6
6-21*
6-31*
21
490
43
310
280
240
230
190
160
380-11,000*
130
320
69
56
240
350
510
200
0.35-11.0
0.65-17.0
0.32-11.0
0.29-5.7
0.46-2.0
0.87-110
2.0-180
2.0-140
1.7-80
5.5-65
1.0-15.0
PT-07
PT-07
PT-07
SS-H2-01
SS-H2-01
SS-H2-01
SS-H2-01
SS-F4-01
SS-F4-01
SS-F4-01 *
ss-F4-oi m
^
PT-08
SS-F4-01
PT-08
PT-07
SS-F4-01
SS-F4-01
SS-F4-01
SS-F4-01
SS-F4-01
PT-07
SS-H2-01
SS-H2-01
SS-H2-01
SS-H2-01
SS-H2-01
SS-H2-01 j
SS-H2-01 1
SS-H2-01
SS-H2-01
SS-H2-01
1-22
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TABLE 2 (Cont'd)
SECONDARY HCT SPOT
(LOCATIONS 1, 2 AND 3)
SAMPLE ANALYSIS SUMMARY
JACKSONVILLE LANDFILL
Compound
No. of
Occurrences/
No. of Samples
Concentration
Range (ppb)
Sample With
Maximum
Concentration'2*
Herbicides
2,4-D
2,4, 5-TP
2,4,5-T
Inorganics
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
fcbalt
Blpper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Cyanide
1/6
1/6
3/6
6/6
6/6
6/6
4/6
4/6
6/6
6/6
6/6
6/6
6/6
6/6
6/6
6/6
3/6
5/6
6/6
3/6
4/6
6/6
6/6
2/6
1,000
88
410
9,380-24,500
3.5-17
53-556
0.48-0.80
4.6-19
611-22,600
9.7-485
1.8-28
6.5-584
11,700-177,000
18-2,520
487-2,100
96-2,050
0.26-0.50
6.9-130
358-1,630
2.1-19
148-1,930
13-27
32-10,800
1.49-17.3
SS-H2-01
SS-H2-01
SS-H2-01
SS-F4-01
SS-F4-01
SS-F4-01
SS-H2-01
SS-F4-01
SS-F4-01
SS-F4-01
SS-F4-01
SS-F4-01
SS-F4-01
SS-F4-01
PT-08
PT-07
PT-08
SS-F4-01
SS-H2-01
SS-F4-01
SS-H2-01
PS-08
SS-F4-01
PS-08
NOTES:
(1)
(2)
Only compounds which were detected are presented in
this Table.
Refer to Remedial Investigation Report for the
Jacksonville Landfill Site. Jacksonville. Arkansas,
April 1990, for figures showing individual sampling
locations.
These compounds were detected in one or more blank
samples.
1-23
-------
concentrations up to 7.4%, 0.3%, 3.6% and 0.4% respectively.
No detailed records have yet been found that prove exactly how the
herbicides, trichlorophenol and other related chemicals were
placed in the drum pile or from which process they came. Records
are required to determine the origin, and thus the "listability",
of a waste.
It should be noted, however, that the site waste is suspected of
having originated at the Vertac facility, whose waste has been
listed as F020 and F023. If Vertac waste is indeed the same waste
that exists at the Jacksonville site, then the Jacksonville waste
could be considered to be a soil and debris contaminated with a
RCRA listed waste. Because of the lack of detailed records
regarding the specific origin of the Jacksonville site
contaminants and the observation that the site waste is a
contaminated filter material mixed in soil rather than a pure
product or a "still bottom" waste, Jacksonville Landfill wastes
are not considered to be listed. RCRA restrictions pertaining to
the treatment of listed wastes will nonetheless be considered
relevant in the determination of remediation goals. The selected
remedy will not, however, include the delisting or disposal
considerations contained in the Land Disposal Restrictions (LDRs)
for listed wastes.
This determination is consistant with the RCRA "Contained-in"
Rule, which states that any mixture of a non-solid waste (such as
soil or ground water) and a RCRA listed hazardous waste must be
managed as a hazardous waste as long as the material contains
(i.e., is above health-based levels) the listed hazardous waste.
Once the material has been treated to no longer "contain" the
listed hazardous waste, the material itself will no longer be
considered a hazardous waste.
The waste is also subject to the regulatory authority of 40 CFR
Part 261 Subpart C, which identifies it as having the
characteristics of hazardous waste, specifically the
characteristic of EP toxicity.
The highest concentrations of 2,4-D and 2,4,5-TP observed at the
Jacksonville Landfill Site were 74,000,000 ppb (7.4%) and
3,000,000 ppb (0.3%) respectively. If the leachate from
leachability tests of this material contains concentrations of
2,4-D exceeding 10,000 micrograms per liter (ug/1) or 2,4,5-TP
exceeding 1,000 ug/1, the material would be classified as D016 or
D017 hazardous waste respectively under Part 261.24.
The waste material at the site has not been subject to the TCLP
leachate tests, nor are there any detailed records indicating its
derivation. Therefore D016 and D017 classification has not been
shown to be applicable. However, it is likely that if the
aforementioned materials were so tested, the leachate would exceed
Page 1-24
-------
the limits for D016 and D017 hazardous -waste classification.
Thus, the waste can be considered "characteristic" and
consequently, RCRA regulations for D016 and D017 hazardous waste
are considered to be relevant and appropriate.
The high levels of contaminants in the drum disposal area render
this area of the site extremely hazardous. contaminants in this
area comprise the principal health threat at the site.
Calculations supporting this conclusion are presented in the Risk
Assessment Report, which indicate excess lifetime cancer risks of
2 x 10 from dioxins and furans (for maximum plausible exposure)
and a total hazard index of 511 from herbicides. This area will
be the main focus of remedial actions performed at the site.
Secondary or low level threats are derived from the locations
outside of the drum disposal area which contain moderate levels of
dioxins and herbicides. These areas will also be addressed during
the site remediation.
In addition, limited organic and inorganic contamination exists
throughout the site. Many of the compounds detected are those
commonly found at municipal landfills. The areas outside of the
dioxin disposal areas previously described contained no detectable
contamination high enough to present a significant threat to
public health. Risk calculations indicate excess lifetime cancer
risks of 6 x 10 from dioxins and furans (for maximum plausible
exposure) and a total hazard index of far less than 1.0 from
herbicides and other noncarcinogenic compounds.
Offsite Soils; Offsite surface soil contamination is limited to
octachlorodibenzo-p-dioxin (OCDD) and arsenic. The site is not
likely to be the source of these compounds, however, as both of
were found in offsite background samples and are ubiquitous in the
local environment. Nonetheless, regardless of the origin of these
compounds, they were taken into account during the calculation of
site risks in the risk assessment.
Ground water
During the remedial investigation, ground water samples were
collected from 13 monitoring wells on and immediately adjacent to
the Jacksonville Site, and at five residential wells. The depths
of the ground water monitoring wells vary. Thref pairs of nested
shallow and deep wells were installed, each with a shallow well
about 30 feet deep and a deep well up to 98 feet deep. The
remaining seven wells were shallow wells, installed to an average
depth of about 30 feet. The depths of residential wells ranged
from 80-100 feet below ground surface.
Figure 5 shows the locations of the monitoring wells (designated
MWJ-xx) and the residential wells (designated RW-xx). Table 3
summarizes the results of the sampling of the monitoring wells,
and Table 4 shows the results for the residential wells. Sample
Page 1-25
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numbers (GW designation) correlate to the monitoring well numbers
(MWJ designation). For instance, sample GW-01 was taken from
monitoring well MWJ-01, GW-02 from MWJ-02, etc. Applicable,
relevant and appropriate requirements (ARARs) are also shown in
these tables.
Monitoring Wells; Monitoring wells were sampled twice, during the
winter and spring of 1989.
Organic contaminants which exceeded the Safe Drinking Water Act
(SDWA) MCLs are vinyl chloride (MCL of 2 ug/1), 1,1-DCE (MCL of 7
ug/1), benzene (MCL of 5 ug/1) and chlorobenzene (proposed MCL of
100 ug/1). The occurrence of these compounds at levels exceeding
current and proposed standards in ground water monitoring wells is
limited to one shallow monitoring well for vinyl chloride and 1,1-
DCE (MWJ-04), one shallow monitoring well for benzene (MWJ-05) and
two shallow monitoring wells for chlorobenzene (MWJ-04, MWJ-05).
No organic compounds above the MCLs were detected in the shallow
zone offsite or the deep aquifer on or offsite.
Comparison of concentrations of inorganic substances between
onsite and background monitoring wells (MWJ-01 and 02) yielded no
significant differences. However, concentrations of barium in two
shallow wells (MWJ-09 and 13), chromium in one shallow well (MWJ-
12) and selenium in one shallow and one deep monitoring well (MWJ-
05 and 06) were above their respective MCLs.
None of the detected contaminants exhibited any consistent spacial
pattern that suggested an onsite source of contamination or
downgradient migration. Additionally, all but one of the elevated
contaminant detections was limited to the shallow water bearing
zone. This shallow formation of interbedded silts and clays was
found to contain insufficient saturated permeable material to
yield significant quantities of water to commercial or domestic
wells, and is consequently judged to be a Class IIIA, non-viable
ground water source. National Primary Drinking Water Standards
are therefore not considered to be ARARs for this aquifer, and
thus, active ground water remediation is not warranted. The
selected remedial alternative will, however, incorporate a system
of long-term ground water monitoring to ensure that the remedy
remains effective in the protection of ground water quality and to
aid in the identification of long-term trends in the quality of
the ground water.
Residential Wells: Residential wells (RW designation) were
sampled once, with the exception of RW-02 which was sampled twice.
The depths of residential wells ranged from 80-100 feet below
ground surface. The construction and integrity of residential
wells is unknown and-access to the wells is unrestricted. Sample
data from these wells must therefore be reviewed with caution.
Concentrations of organic and inorganic compounds detected in the
Page 1-34
-------
residential wells were below MCLs for those compounds which have
MCLs with the exception of benzene (MCL = 5 ug/1) and mercury (MCL
= 2 ug/1). These compounds were detected in one sample of one
well (RW-02) at 6 ug/1 and 8.2 ug/1, respectively. Benzene and
mercury were not detected in the duplicate samples taken at the
same time as the originals, nor were they detected in the second
round of sampling. Because of the initial detections of these
contaminants, however, further consideration was warranted.
The National Primary Drinking Water Regulations (40 CFR Part 141)
provide the protocol for interpreting inconsistent sampling
results such as this. The method requires averaging the sample
results exceeding MCLs with three additional samples taken from
the same sampling point. Following this procedure, the average
concentrations for both benzene and mercury fall below their
respective MCLs, thus indicating no exceedance of the drinking
water standards.
Surface Water
Surface water samples were collected from standing water in the
onsite trenches and offsite ponds and drainage ditches.
Background surface water samples were collected from Bayou Two
Prairie and a creek running through the Holland Bottoms Wildlife
Management Area.
Background Water; with the exception of beryllium and manganese,
concentrations of all organic and inorganic compounds detected in
background water samples were less than the Ambient Water Quality
Criteria (WQC) for those compounds which have WQC values. The
maximum concentration detected for beryllium was 0.2 ug/1 (versus
WQC = 0.0039 ug/1) and the maximum concentration of manganese was
336 ug/1 (versus WQC = 10 ug/1).
Onsite Trench Water; Herbicides 2,4-D and 2,4,5-T were detected
at low concentrations at two sampling locations near the drum
disposal area (380 ug/1 and 74 ug/1, respectively). The
concentrations of herbicides indicate that either some
contamination migration from the drum disposal area into this
trench is occurring or that direct herbicide waste disposal into
the trench has taken place. The possibility that this water would
be ingested by humans, however, is remote due to thick brush and
other deterrents associated with getting to the trenches.
All concentrations of inorganic compounds detected in onsite
trench water samples were below WQCs for those compounds which
have WQC values, except for manganese. The high manganese content
of the water contained in the onsite trenches is likely due to
site contamination.
Offsite Surface Water; Concentrations of beryllium exceeded WQC
for surface water, however, concentrations were similar to those
Page 1-35
-------
found in a background sample ("Offsite" @ 395 ug/1 versus
"Background" § 336 ug/1). These results did not indicate any
contamination attributable to an onsite source.
Air Pollution
Ethylbenzene and xylene were detected in air samples collected
from around the site (FIT team memorandum, dated August 29, 1985).
However, they were not found in high concentrations. Further, no
volatile compounds were detected in high enough concentrations to
register on field survey instruments (flame and photo ionization
detectors) during the remedial investigation. This suggests that
the level of volatile organic compounds being emitted by the site
is very low.
CONTAMINANT FATE AND TRANSPORT
The environmental transport of the chemicals detected at the
Jacksonville Landfill Site is dependant on their individual
physical/chemical properties (especially sorption and solubility)
as well as specific site characteristics.
Potential Routes of Migration
The mechanisms of release of the chemicals of concern at the
Jacksonville Landfill Site from contaminated media are discussed
below. These routes of migration can be soil erosion, ground
water flow, air transport, and surface water/sediment transport.
Due to the physical/chemical characteristics of contaminants founc
on-site the primary route of contaminant migration is soi-
erosion; secondary routes of migration are ground water flow and
surface water/sediment transport. The primary chemicals of
concern are dioxins (2,3,7,8-TCDD and other isomers); 2,4-D;
2,4,5-T; 2,4,5-TP; and 2,4-DCP.
Soil; As a result of past operations and waste disposal
practices, chemicals were released to the soil at the Jacksonville
Landfill Site. These chemicals may remain in the soil or migrate
from the soil to other media. The movement of a chemical once it
has been released to the soil is dependent upon several factors,
including the type of soil, the tendency of the chemical to adsorb
to soil particles, the solubility of the chemical in water and the
vapor pressure of the chemical.
The surface soils present at the Jacksonville Landfill Site are
comprised predominantly of silt/clay mixtures with very little
organic carbon content. These soils are likely to provide little
attenuative capacity, as they provide few sites for adsorption of
organic chemicals or complexation of metals. The low attenuative
capacity of the soils and the very low soil permeability result in
conditions which promote migration of contaminants by erosion and
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surface water runoff.
Movement of organic chemicals of concern from the soil is
predominantly influenced by solubility. For example, lower
molecular weight compounds (2,4-DCP) are more soluble and,
therefore, would be expected to leach from the soil faster than
higher molecular weight compounds (dioxins).
Due to the chemical/physical properties of dioxins and furans
which influence their ability to migrate in soils, the vertical
migration in soils will be extremely slow. The primary indicators
which determine chemical migration are the organic carbon
partition coefficient (K^) and octanol water partition coefficient
(K^) . These values indicate a chemical's ability to remain sorbed
to soil particles versus its ability to be leached by water.
Dioxin/furan compounds values for these properties are relatively
high indicating their inability to be leached from soils.
Additional data to support this is presented in studies (National
Dioxin Study, EPA, 1988) which show that approximately 98 percent
of dioxin in soils will remain within the upper 12 inches of the
soil.
Migration of inorganics in the environment is complicated and
depends greatly on inorganic speciation. Speciation, in turn, is
influenced by environmental conditions such as pH, oxidizing or
reducing conditions of the environment, and microbial activity.
With the exception of inorganic anions such as those formed by
arsenic, chromium (VI), and cyanide, which are fairly mobile,
metals are usually tightly bound to the soil constituents such as
clays.
Ground water: Lithologic descriptions from the soil borings
indicate that the site is underlain by a complex series of clays,
silty clays and sandy silts. Perched water is, at several times
throughout the year, within two feet of the ground surface. To
reach the drinking water aquifer, the perched water and associated
contaminants must pass through the shallow aquifer and then either
through or around a layer of clay before it reaches the lower
aquifer used for drinking water. The low permeability of soils at
the surface of the site as well as the low permeability of the
clay between the upper and lower aquifers act as significant
deterrents to contaminant migration to the drinking water aquifer.
However, the possibility cannot be ruled out that contaminants in
the upper water bearing zone can migrate to the drinking water
aquifer.
Chlorobenzene, for example, was detected in shallow disposal
trench sediments, and again in nearby shallow monitoring wells.
These results suggest the possibility of contaminant migration
from site soils into the ground water below the site.
Air; Contaminants may be released into the air by wind
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entrainment of soil particles onto which contaminants are
adsorbed. Release of contaminants into the air by volatilization
is not a concern due to the very low vapor pressures exhibited by
the chemicals found on or near the surface of the landfill.
Migration of contaminants by wind entrainment of soil particles is
dependent on several factors, including particle size, wind speed
and direction, soil moisture content, site topography and presence
of vegetation. In general, unvegetated sites which have low
moisture soils containing high percentages of fine particles are
likely to experience dusty conditions. Site topography will also
affect the transport of soil particles, with sites located in
flat, open unsheltered areas being susceptible to wind erosion.
Several characteristics at the Jacksonville Landfill render the
site unsusceptible to wind transport of contaminants. The site is
primarily flat; and it is heavily vegetated. Even in the winter
months the dried vegetation provides good ground cover. Soils in
the area are not well drained. After precipitation events the
landfill typically has many areas with standing water, and during
the winter months the site becomes swampy. Given the site
environmental factors, wind erosion of soil contaminants at the
Jacksonville Landfill does not appear to be a significant pathway
for contaminant migration.
Surface Water/Sediment; Surface water drainage at Jacksonville
Landfill is via a series of undefinable drainageways which flow
into a manmade drainage ditch that parallels the access road
through the site. This ditch empties into a drainage ditch
outside the landfill gate which parallels Graham Road. This
drainage course ultimately empties into the Holland Bottoms
Wildlife Management Area.
Surface water and sediment samples collected from the drainage
areas outside the landfill contain no elevated concentrations of
compounds, compared to background samples. This would indicate
therefore, that the drainage ditches have not become established
migration pathways for contaminants.
In the past, during heavy rains, it has been reported that gross
flooding occurs such that surface water flows from the landfill
into the yards to the east. This surface runoff during heavy
rains may be an episodic migration pathway. However, soil samples
collected from residential yards east of the site showed no
elevated levels of contaminants found on the site.
Surface water, soil and sediment samples collected from a landfil.
trench just nc ~h and east of the drum disposal area showed lov
levels of herbicide contamination. The contamination may be due
to waste disposal in the trench or by erosion and surface water
runoff from the drum disposal area being collected in the trench.
Excavation at this trench provided no information to support waste
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disposal other than municipal waste in the trench.
Contaminant Persistence
Contaminant persistence in soils is primarily influenced by the
soils ability to attenuate the chemicals of concern. These
chemicals, at the Jacksonville Landfill, are: dioxins; 2,4-D;
2,4,5-T; 2,4,5-TP; and 2,4-DCP. The organic chemicals of concern
at the site can be generally categorized as one group, chlorinated
benzene rings with additional substituents.
Factors which determine a soil's ability to attenuate contaminants
include: the chemicals ability to adsorb to soil particles, water
solubility of each chemical, cation exchange capacity of the soil,
and organic content of the soil.
The water solubility of a substance is a critical property
affecting its environmental fate and persistence. Solubilities of
organic chemicals generally range from less than 0.001 mg/liter to
100,000 mg/liter. Solubilities of the chemicals of concern range
from 4,500 mg/liter for 2,4-DCP to essentially insoluble for
dioxins.
The organic carbon partition coefficient (K^) reflects the
propensity of a compound to sorb to the organic matter in soils.
The normal range of K^ values is from 1 to 107, with higher values
indicating higher sorption potential. Of the chemicals found at
the site, dioxins have the highest K^ values, and therefore are
expected to have the highest environmental persistence. The half-
life of the 2,3,7,8-TCDD isomer is estimated to be 10-12 years in
soil.
The herbicides of concern are less persistent, but more mobile
than dioxins. 2,4-D; 2,4,5-T; and 2,4,5-TP are found to be
relatively mobile in the soil/ground water system when present at
low dissolved concentrations. Bulk quantities of the solution
(e.g., from a spill, heavy spray application, or improper disposal
of excess formulations) can be transported more rapidly through
the unsaturated zone. However, the herbicides under consideration
have been shown to be highly susceptible to degradation in the
soil/ground water system and are therefore not expected to be
persistent. Under most environmental conditions, the esters which
comprise the bulk of the active ingredients of herbicide
formulations are hydrolysed in a matter of days. Biological
hydrolysis of these materials in the subsurface has also been
reported to be very rapid.
After evaluating the physical/chemical parameters of the chemicals
of concern and the geology/hydrogeology at the site, several
conclusions can be drawn. Mobility of the dioxin and herbicide
contaminants at the site will mostly be by surface water run-
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off/erosion.
Vertical contaminant migration is not expected to be a major
migration pathway because of the low solubility and mobility of
dioxins and herbicides, and the low hydraulic conductivity of the
clay at the surface. However, low levels of chlorobenzene and
2,4,5-TP were detected in on and offsite ground water (at
concentrations not exceeding MCLs) indicating the potential that
some migration could have occurred. Under the scenario that
contaminants migrated down to the drinking water aquifer, their
mobility would be very limited due to the low solubility of these
compounds in water and the low hydraulic gradient of the aquifer.
However, if off-site wells which are currently out of service are
used in the future for indoor domestic use, utilization of the
water would increase. This could subsequently increase the
hydraulic gradient in the lower aquifer and conceivably cause
significant increases in contaminant migration rates, increasing
the possibility of drinking water standards being exceeded at
offsite locations. Therefore, it is prudent not to use the
adjacent wells to provide indoor domestic water.
Since samples collected from the drainage courses and low lying
areas near the drum disposal area contained relatively low levels
of contamination, the surface water run-off/erosion migration
pathway also appears to have historically had a limited role in
the transportation of contaminants at the site. Previous studies
at the site have shown that wind erosion of contaminated soil does
not appear to be a significant migration pathway.
Persistence of chemicals in surface soils at the site is very
high. As has been revealed during the RI, high levels of
herbicides and dioxins still exist in the drum disposal area of
the site, 16 years after the site has been closed. Although the
mobility of the contaminants at the site is limited, in the
absence of additional action at the site, the contaminants can be
expected to persist for many years.
SUMMARY OP SITE RISKS
The Baseline Risk Assessment outlines the type and degree of
hazard posed by hazardous chemicals, the extent to which a
particular group of people have been or may be exposed to the
chemicals, and the present or potential health risk that exists at
the Jacksonville Landfill. The assessment also serves as a
baseline evaluation of the site under a "no-action" remedial
alternative (i.e., in the absence of any remediation and assuming
rionrestricted future site use). This will provide a basis for
assessing remedial alternatives to be considered in the
Feasibility Study. The methodology used for the baseline risk
assessment and key results are summarized below. Additional
details are provided in the Jacksonville Landfill Risk Assessment
Report.
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Risk characterization is performed by combining exposure and dose-
response assessments to form conclusions regarding the health
risks from the site. Quantitative risk estimates give an
indication of the magnitude of the potential for adverse health
effects resulting from exposure to toxic substances.
The methodology followed for the Baseline Risk Assessment was in
accordance with the EPA Superfund Public Health Evaluation Manual
(1986) and the Superfund Exposure Assessment Manual (1988).
The potential exposures identified at the Jacksonville Landfill
area are based on the distribution and extent of chemical
contamination, the potential for contaminant transport,
opportunities for exposure and the toxicity of the contaminants.
Plausible exposure results were derived using arithmetic and
geometric means of laboratory chemical analyses of field data.
Worst case exposure results were derived using the highest value
for the laboratory chemical analyses of field data.
Assumptions used to estimate the "plausible maximum" exposure
associated with dermal contact include:
o The amount of soil in contact with the skin is 2.77
mg/cm -day for clay soil. The choice of data for clay-
like soil is based on actual field classification of
soil types by geologists during the remedial
investigation.
o Unless otherwise known, one hundred percent of a
compound is assumed to be absorbed through the skin.
For dioxin, three percent of the compound is absorbed
through the skin. Ten percent of the pesticides are
absorbed through the skin. Negligible dermal absorption
is assumed for inorganics.
o Assumed body weights are:
Adult - 70 kg
Teenager - 49 kg
6-12 year old child - 30 kg
2-6 year old child - 10 kg
o An expected lifetime is 70 years.
Assumptions used to estimate the "plausible maximum" exposure
associated with accidental ingestion of contaminated soils
include:
o Exposure durations are 1,825 days for a 2-6 year old
child; 1440 days for a 6-12 year old grade schooler;
2,555 days for a teenager; and 18,250 days for an adult.
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These exposure duration assumptions are based on a
knowledge of site conditions derived from personal
observations, discussion with Rl field team
investigators and the rather temperate climate in
Arkansas. That is, it was assumed that a teenager
could, conservatively, frequent the landfill for eight
months out of the year.
o 0.8 g/day of soil is ingested by a 2-6 year old child;
0.05 g/day of soil is ingested by an adult or teenager.
0.1 g/day is ingested by a 6-12 year old grade schooler.
0.8 g/day is considered to be an upper bound. Recent
guidance recommended 0.2 g/day for a child of 1-6 years
and 0.1 g/day for adults as soil ingestion rates. The
soil ingestion rates used in the analyses were tailored
to site conditions and scenarios.
o Unless otherwise known, one hundred percent of a
compound is assumed to be absorbed through the
gastrointestinal tract. For dioxin, twenty-six percent
is assumed to be absorbed through the gastrointestinal
tract.
o Body weights and expected lifetime are as shown above
for dermal contact.
Assumptions used to estimate the dose associated with long-term
ingestion of contaminated drinking water include:
o A receptor ingests 2 liters of water/day.
o An average man weighs 70 kg.
o 100% of the compound is absorbed in the gastrointestinal
tract.
Additional information regarding these assumptions and the
resulting calculations can be found in the Risk Assessment for the
Jacksonville Landfill site, April 1990.
In December 1989, EPA's Office of Emergency and Remedial Response
published the interim final Risk Assessment Guidance for Superfund
(RAGS) - Volume I. The purpose of this guidance was to supersede
the Superfund Public Health Evaluation Manual (SPHEM) and
Endangerment Assessment Handbook which, to that date, had been
used for assessing the effects of chemical contamination on human
health. RAGS revised the SPHEM methodology in several ways.
One key modification came through the introduction of the concept
of Reasonable Maximum Exposure (RME). RME is defined as the
highest exposure that could reasonably be expected to occur at a
site. This approach differs from the SPHEM approach of defining
Page 1-42
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worst-case exposure to site contaminants.. One of the primary
differences is that while SPHEM utilized a "worst-case" scenario
based on continued exposure to the maximum detected concentration
of a chemical constituent at the site, RME bases the maximum
exposure on the 95th upper confidence limit of the mean, providing
a spatially averaged exposure concentration.
The final RAGS guidance was not available until the risk
assessment for the Jacksonville site was nearing completion. EPA
considered redeveloping the complete risk analysis based upon the
new guidance. However, upon close consideration, it was
determined that the underlying assumptions being used under SPHEM
were at least as conservative as those set forth in RAGS. Thus,
the results of the Jacksonville Risk Assessment were at least as
protective as those which would have been derived under the
alternate guidance. Additionally, the Jacksonville Risk
Assessment used exposure parameters (such as body weight,
ingestion rates, exposure frequencies and durations, etc.) which
were consistent with RAGS. Therefore, the decision was made to
finalize the risk assessment under the SPHEM guidance, and so
risks presented in this ROD are based upon "worst case" exposures
rather than the RME.
EXPOSURE ASSESSMENT SUMMARY
To determine if exposure might occur, the human and environmental
activity patterns near the site and the most likely pathways of
chemical release and transport must be defined. A complete
exposure pathway has four necessary components: (1) a source of
chemical release to the environment; (2) a route of contaminant
transport through an environmental medium; (3) an exposure or
contact point; and (4) the presence of a human or environmental
receptor at the exposure or contact point.
The mode of exposure influences risks to receptors. Modes of
exposure usually include ingestion, inhalation and direct contact.
Ingestion may take the form of direct exposure through drinking or
eating contaminated water and food or may involve indirect routes
such as use of contaminated water for food preparation and
ingestion of soil deposited on hands and transferred to food,
cigarettes, etc. Dermal exposure may result from direct contact
with contaminated water, soil or other material. The following is
a media-by-media discussion of the major potential routes of
exposure to hazardous constituents associated with the site.
Direct and Indirect Contact with Contaminated Surface Soil Onsite
and/or Offsite
Contaminated soil can cause risks to public health through direct
contact and associated incidental ingestion and dermal adsorption.
Compounds of concern include congeners and isomers of
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dioxin/furans; the herbicides 2,4,5-T and 2,4,5-TP; and 2,4-DCP.
No quantitative data are available on the size of the population
potentially exposed to onsite hazardous constituents via direct
contact. Access to the site is now somewhat restricted with a
fence and gate, but previous report(s) suggest that the landfill
access was not restricted between 1973 to 1985. Scavengers and/or
dumpers have been observed onsite.
During RI field studies, bicycle tracks were observed onsite.
Some of the barbed wire fencing is low enough with wide enough
gaps to allow access by trespassers. Receptors entering the site
boundaries via this route are at risk. Receptors most likely to
come into direct contact with surface soils are local residents.
Direct exposure with onsite surface soils and sediments is
therefore a likely exposure scenario.
Residential areas are adjacent to the landfill. Young children
can play in the soil and adults can garden in residential
backyards next to the landfill. The potential exists for exposure
via this route. Therefore, this potential route was evaluated.
Wildlife and domestic animals may also be exposed to onsite or
offsite contaminated soils and sediments. Domestic animals could
potentially carry contaminated sediments or soils to local
residences and potentially affect human occupants. Wildlife could
eat contaminated soil and the local population could eat
contaminated wildlife (rabbits), potentially being exposed to the
contaminants. Exposure to animals is, however, expected to be
sporadic and of limited duration.
Contaminants may migrate via several mechanisms at the
Jacksonville Landfill Site. These include percolation of
contamination into ground water, surface runoff and soil erosion.
It has been determined through previous studies that airborne
transport of contamination is not a significant transport
mechanism.
Direct and Indirect Contact With Ground water
Ground water at the site flows generally east-southeast towards
the residential area. Due to the physical/chemical properties of
the dioxins and furans at the site and the relatively impermeable
nature of the soils, it is not believed that the dioxins and
furans can percolate down and contaminate the deep drinking water
aquifers.
However, since several other organic chemicals have been detected
at low levels in the monitoring wells, it appears that some of
these compounds have migrated into areas of the shallow water
bearing zone near MWJ-04 & MWJ-05 in the northeast quadrant of the
site. This is the aquifer which the Arkansas Department of
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Pollution Control and Ecology considers seasonally perched and
which EPA has classified as IIIA (non-viable). Since this shallow
water bearing zone is low yielding and can dry up during dry
weather periods, it is not a viable source of drinking water. The
results of the residential well survey conducted during the RI
confirmed this point, showing that none of the documented wells
near the site were placed into the shallow zone. The only
existing potential source of exposure to contaminated ground water
in the upper aquifer on the Jacksonville Site would be to workers
sampling wells or during associated sample handling, analysis and
disposal. Appropriate protective equipment and procedures are
used during such activities to prevent significant exposure.
Isolated detections of low concentrations of several organics have
also been detected in the deep downgradient monitoring wells and
one residential well. These wells were placed in the lower (Class
IIA) aquifer. The detected contaminants do not exhibit any
consistent spacial pattern that suggests an onsite source or
downgradient migration, nor have they been confirmed in subsequent
or duplicate samples. Additionally they do not pose a significant
threat to human health or the environment because of their low
concentrations (and risk) and also due to the absence of domestic
use of the aquifer as a potable water source by adjacent
residents.
Only one residential well at a residence adjacent to the
Jacksonville Site is documented as being used as a water source.
Usage at this well is limited to non-potable uses such as lawn
watering and car washing. The possibility of ground water water
being used to provide drinking water for animals also exists.
There is a possibility of direct contact exposure, accidental
ingestion, or inhalation associated with the use of ground water
for lawn watering, car washing etc. However, it is unlikely that
these activities are significant routes of human exposure to site-
associated hazardous contaminants, since the presence of hazardous
contaminants was not confirmed in this well and no evidence exists
of a plume emanating from the site towards this well.
Transport by Surface Runoff
During heavy rainfall events, contaminants in the surface soils
around the drum disposal area can migrate via surface water
runoff. Due to the flat topography at the site, these
contaminants may slowly migrate to areas offsite through drainage
paths into the residential yards or drainage ditches adjacent to
the site. The site is located in a floodplain. Therefore,
transport as a result of a major flood is also possible. However,
chemical analyses suggest this has not been an important pathway
for dioxin and herbicide migration from the site.
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Direct and Indirect Exposure to Surface Water and Associated Biota
Environmental and/or human receptors may be exposed to hazardous
constituents in surface waters. Wild and domestic animals may
frequent potentially impacted surface waters to wade or bathe and
ingest the water. However, their exposure would be sporadic and
of short duration.
Aquatic flora and fauna inhabiting site-impacted surface waters
may also be exposed. Ingest ion of fish should not be a problem
because there are no known fish in the offsite ditches and onsite
trenches. There is, however, concern for human receptors who
might regularly eat fish from the unnamed pond in the residential
area because of the presence of certain inorganics which exceed
ambient water quality criteria. This activity, in reality, is
very unlikely since the small pond has a limited capacity to spawn
an adequate supply of fish large enough to be eaten on a regular
basis. The pond is also unlikely to be used by people for swimming
because of the presence of snakes (whose presence was confirmed
during the remedial investigation). However, the possibility can
not be entirely eliminated.
Continuous consumption of surface water in the immediate vicinity
of the site could also produce adverse effects. This too is an
unlikely event since even if local residents attempted to drink
these waters, the bitter taste imparted by manganese would tend to
make the water unpalatable. The actual risk associated with these
routes of exposure are considered to be negligible.
Inhalation
Under present site conditions, inhalation of airborne contaminated
dusts and/or inhalation of volatilized surface soil contaminants
are considered to be very minor routes of human or environmental
exposure. No dioxins and furans were observed in air samples
during previous investigations. Dioxin and phenoxy herbicides
adsorb strongly to the soil. The only organics detected in air
samples at the landfill were ethylbenzene and xylene (FIT team
document dated September 13, 1986). However, they were not found
in high concentrations. Further, no volatile compounds were
detected in high enough concentrations to register on field survey
instruments (flame and photo ionization detectors) during the
remedial investigation. Also, the vegetative cover over most
areas of the site would tend to prevent suspension or emission of
particulate contaminants.
RISK EVALUATION SUMMARY
The potency of substances and associated risks are evaluated
separately for noncarcinogenic and carcinogenic effects.
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Explanation of Carcinogenic Risk
EPA-approved methods for evaluating the carcinogenic and mutagenic
potency of substances assume that any finite exposure will be
associated with a finite amount of risk. This is because a
genotoxic insult (even if caused by only one molecule) is assumed
to have a finite probability of allowing a cell to grow into a
malignant tumor. Carcinogenic risks below one percent (0.01) are
generally computed by multiplying estimated average daily
exposures over a lifetime by slope factors. A slope factor is an
upper-bound estimate (with a 95% confidence) of the probability of
an individual developing cancer per unit intake of a chemical over
a lifetime, based on a linearized multistage model. The slope
factor is also called the Cancer Potency Factor (CPF) and is
expressed in units of (mg/kg-day) "1. The term "upper bound"
reflects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimation of the actual
cancer risk highly unlikely. Cancer risks from mixtures of
substances are assumed to be the sum of the risks associated with
the individual substances in the mixture when the total risk is
less than one percent.
Explanation of Noncarcinoaenic Risk
Forms of toxicity with endpoints other than cancer and gene
mutations are treated as if there is an identifiable exposure
threshold below which there are no observable adverse effects.
Such toxicity is called "threshold toxicity." The underlying
mechanism associated with threshold toxicity assumes that:
Multiple cells must be injured before an adverse effect
is experienced, and that
The injury must occur at a rate exceeding the rate of
cell repair.
In addition, cells and fluids between cells may contain
metabolizing enzymes that modify contaminants and allow small
amounts to be tolerated.
A chronic reference dose (RfD) is an estimated level of daily
exposure to the human population (including sensitive
subpopulations) that is likely to be without an appreciable risk
of deleterious effects during a lifetime. These levels are
estimated to be below threshold levels at which adverse effects
would occur. RfDs are used to indicate acceptable levels of daily
human exposure to individual chemicals.
Hazard indices are used to evaluate the potential noncarcinogenic
impacts of pollutant mixtures. A hazard index is the sum of the
ratios of predicted amounts of exposure to the corresponding
chronic reference doses for all substances. A hazard index less
than one indicates that adverse noncarcinogenic effects are
Page 1-47
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"3-'
-------
unlikely. Ideally, hazard indices would be calculated separately
for each threshold toxic effect for all pollutants that cause the
effect by the same mechanism. However, adequate data to identify
all effects associated with each pollutant is not available. As
a result, the hazard index used includes all pollutants with
reference doses, regardless of what effects they may or may not
share. The result is an extreme upper limit to the hazard index.
Results
Using the above procedures, the health risks identified at the
Jacksonville Landfill were determined based on the distribution
and extent of chemical contamination, the potential for
contaminant transport, opportunities for exposure and toxicity of
the contaminants.
Risk assessment findings at the landfill indicate a potential
health risk is predominantly associated with direct contact with
or accidental ingestion of contaminated soil at the "hot spots"
located at the drum site and secondary areas of contamination en
the landfill. Specifically, the hot spot contaminants cause
excess carcinogenic health risks and noncarcinogenic health
hazards. The excess carcinogenic risks calculated for the
landfill and surrounding areas including the dioxins, furans and
other carcinogens are summarized in Table 5. At the drum disposal
area, the carcinogenic risk is 1.48 x 10 for plausible exposure
and 1.61 x 10 for worst case exposure. "Plausible" or most likely
exposure results are derived using arithmetic and geometric means
of laboratory chemical analyses of field samples. Worst case
exposure values were calculated using the highest value for the
laboratory chemical analyses of these samples. The secondary hot
spots yielded a worst case excess carcinogenic health risk of 2.18
x 10"3. These risks, however, are limited to an extremely small
area on the landfill property. The remainder of the landfill
presents a worst case risk of 6.19 x 10 , due primarily to low
levels of dioxin contamination.
Analytical results indicate that 2,3,7,8-TCDD, as well as 2,4,5-
T or 2,4,5-TP herbicide contamination is not present in any
offsite residential areas above analytical detection limits.
These detection limits ranged from 0.006 to 0.08 ppb. A
hypothetical calculation was made to determine what additional
risks would occur if dioxin existed below detection limits.
Assuming that the concentrations in the residential areas average
one-half of the detection limit, risks were calculated for an
offsite 2 to 6 year old child and an adult gardener. Risks were
2..39 x 10"6 for a child and 2.71 x 10"6 for an adult gardener for
plausible exposure from 2,3,7,8-TCDD. The 2 to 6 year old age
group was chosen for detailed calculation because their exposure
rate and physical characteristics (e.g., low body weight)
represent a worst case situation for children. It should be
stressed that offsite risks from 2,3,7,8-TCDD and the family of
Page 1-48
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dioxins (including 2,3,7,8-TCDD) and furans are only hypothetical
values since no 2,3,7,8-TCDD; 2,4,5-T or 2,4,5-TP was ever
detected at these offsite residential backyards.
Total risk from all detected carcinogenic contaminants calculated
for the offsite residential soil is 9.65 x 10"5 for plausible
exposure and 1.91 x 10"4 for worst possible exposure. The major
contributor to this risk is arsenic in offsite areas which cannot
be attributed to the site. Risks calculated were 9.64 x 10"5 for
plausible exposure and 1.91 x 10"4 for worst possible exposure to
arsenic alone. These offsite risks are for a 2 to 6 year-old
child. For an adult offsite gardener, the risk for arsenic alone
is 8.61 x 10"6 and 1.70 x 10"5 for the worst case. Arsenic is
fairly widely distributed on the landfill and offsite residential
backyards. This substance, a common component of soil, is known
to exist at higher background concentrations in Central Arkansas
than throughout the contiguous United States.
A carcinogenic risk also exists from exposure to the onsite
shallow ground water. The maximum excess lifetime cancer risk was
calculated to be 1.33 x 10"3 for worst case exposure, however this
risk should be considered theoretical only. Calculations assumed
a constant ground water ingestion rate of two liters per day.
This is an unlikely scenario, since the shallow ground water
aquifer is classified as IIIA and there are no documented wells
placed into this aquifer.
The high carcinogenic risk computed for onsite ground water (1.33
x 10"3) is due primarily to the ingestion rate assumed in the risk
derivation. This rate is higher than what would realistically be
expected from the shallow class IIIA aquifer. The ground water
risk increases the overall sum of total onsite risk (1.74xlO"2),
but does not change it dramatically. The principal threat from
onsite contamination is still due to dioxin and herbicide-
contaminated soils within the hot spots on the Jacksonville site.
Offsite ground water was not found to present a significant
carcinogenic risk. The worst case exposure revealed an excess
lifetime carcinogenic risk of 8.64 x 10"6.
The noncarcinogenic health hazards at the landfill drum site are
due to the herbicides present in the drums. Hazard Indices (His)
relating to on and offsite areas are presented in Table 6. His
calculated for 2,4,5-T and 2,4,5-TP at the drum site were large
and range from 88.5 and 3.45, respectively, for plausible
exposure, to 468 and 41.8, respectively, for worst possible
exposure. His greater than 1.00 indicate that chronic toxicity
may occur in an exposed individual, for example, a teenager coming
into contact with the drum contents or surrounding soils.
His were much lower for the secondary hot spots and remainder of
the landfill, with worst case His of 6.84 x 10"3 and 9.85 x 10"2,
Page 1-53
-------
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1-57
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respectively. The concentrations of herbicides in these locations
were not high enough to present significant health risks.
His for offsite herbicide exposure were insignificant, as
concentrations were nondetectable.
The total HI for onsite ground water was calculated at 7.89. As
was the case in the derivation of total excess cancer risk for
onsite ground water, the ingestion rate assumed is higher than
what would realistically be expected for the shallow aquifer, thus
the calculated HI is very likely a conservative estimate.
Offsite ground water Hazard Indices are computed only for
chlorobenzene. Antimony, mercury and silver were excluded from
the calculations due to the infrequency of their detections and
the fact that they were not detected in any of the ground water
samples onsite. The resulting HI for offsite ground water
ingestion and inhalation (worst case) was 9.35 x 10'2, producing a
total offsite residential HI of 1.36 x 10"1.
Since investigations indicated no sensitive or endangered species
or critical habitats located within or immediately adjacent to the
landfill, environmental risks were not calculated. Animals most
likely to be impacted are common wildlife such as squirrels,
rabbits, birds and deer, and domestic animals that were observed
onsite during the remedial investigation. Their exposure to site
contaminants, however, is sporadic and of limited duration, thus
detrimental effects due to exposure are considered to be minimal.
In conclusion, this risk assessment indicates that dioxin and
herbicide concentrations exceed criteria for excess lifetime
cancer risks and/or health hazards. Plausible routes of exposure
and a likely exposed population have been defined. Therefore, a
potential health hazard exists.
DEVELOPMENT OF REMEDIATION GOALS
Remediation goals are divided into two categories. The first,
pre-remedial action levels, is used as criteria to determine
whether cleanup is required. These levels are based upon the
targeted residual risk to remain at the site. The second
category, post-remedial treatment goals, is comprised of a
combination of health-based and regulatory treatment standards.
Both categories are discussed below and are summarized in Tables
7A and 7B.
Remediation goals are developed for contaminated soils only.
Since none of the detected contaminants exhibited any consistent
spacial pattern in the ground water that suggested downgradient
migration of surface contamination, an active ground water
remediation program was not considered. The selected remedial
Page 1-58
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alternative will, however, incorporate a system of long-term
ground water monitoring to ensure that the remedy remains
effective in the protection of ground water quality and to aid in
the identification of long-term trends in the quality of the
ground water. If comparison of the monitoring results to MCLs or
health-based levels indicates that significant degradation of
ground water quality were occurring or imminent at any time, the
data would be evaluated and confirmatory sampling performed, along
with an updated survey of ground water use. If imminent
degradation of the Class IIB aquifer is confirmed, downgradient
users would be notified and the need for, and feasibility of,
remedial action would be re-evaluated during the next year.
Options to be considered would include alternate water supplies,
extraction and treatment methods, or other viable ground water
restoration technologies.
Pre-Remedial Action Levels
The remediation goals for this alternative were derived from
recommendations by the Centers for Disease Control (with respect
to carcinogenic health threats) and from calculations produced in
the Jacksonville Landfill Risk Assessment (regarding
noncarcinogenic health effects).
Carcinogenic Risks; 2,3,7,8-TCDD is the only probable carcinogen
detected at the site above health-based levels. Thus, it will be
the only carcinogenic compound assigned a remediation goal.
The Centers for Disease Control (CDC) has recommended that
equivalent 2,3,7,8-TCDD concentrations not exceed 1 ppb in
residential surface soils. This recommendation was made for a
residential setting, where continual contact with soils would
occur over a 70-year lifetime from infancy to old-age.
Additionally, CDC has determined that subsurface soils containing
concentrations of 2,3,7,8-TCDD not exceeding 10 ppb should not
pose a significant health hazard if covered with 12 inches of
clean soil.
Although present site conditions are nonconducive to residential
development (i.e., the site is located within the 100-year
floodplain and trenched and mounded with municipal wastes) and
there are no city or county zoning ordinances restricting land-
use, it is nonetheless conceivable that the site could be used for
residential purposes in the future. This is an unlikely scenario,
but it cannot be entirely eliminated. In consideration of
potential future land-use, the 1 ppb and 10 ppb equivalent
Z,3,7,8-TCDD recommendations for the residential setting are
appropriate and therefore adopted as a remedial action objective
for the Jacksonville Landfill site.
If the maximum equivalent 2,3,7,8-TCDD concentration in surface
soil is reduced to 1.0 ppb (a maximum reduction of 99.5%), the
Page 1-61
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associated plausible maximum cancer risk from direct exposure to
dioxins and furans would be 8x10" (based on the potency and
exposure assumptions in the Baseline Risk Assessment). This risk
would be in accordance with general EPA policy to limit maximum
individual cancer risks to a range between 10"4 and 10 .
Noncarcinoaenic Risks: As mentioned previously, 2,4-DCP and the
herbicides 2,4,5-T and 2,4,5-TP may act on the same target organs
by similar mechanisms. in addition, concentrations in the drum
disposal area are very non-homogeneous. Under the circumstances,
adding the aforementioned hazard indices for the above substances
is an appropriate method for estimating the maximum combined HI
for herbicides and 2,4-DCP (for the purpose of conservatively
estimating remedial action objectives). Thus, the combined
maximum HI for 2,4,5-T, 2,4,5-TP, and 2,4-DCP in the drum disposal
area is 511, under maximum exposure.
The highest HI from substances other than herbicides and 2,4-DCP
under maximum plausible exposure is 0.54 from 3,900,000 ppb of
2,4,5-trichlorophenol associated with sample DS-05, taken near the
center of the drum disposal area. The next highest HI for an
organic substance is 0.006 from 1,2,4-trichlorobenzene, followed
by .0024 from 2-chlorophenol. In addition, the combined HI for
metals is 0.2 under maximum plausible exposure. Combining the
above His for each of these constituents yields a total Hazard
Index from substances other than herbicides and 2,4-DCP of
approximately 0.7.
The combined hazard index for all site pollutants that act on the
same target organs by the same mechanism should be less than one
for threshold toxic effects to be considered unlikely. Reducing
the hazard index for herbicides and 2,4-DCP to 1.0 would not leave
any margin of safety for exposure to other substances that may act
in a similar manner (such as those described in the previous
paragraph) or for exposure to the same substances from sources
other than the Jacksonville Landfill Site. Under the
circumstances, a representative remedial action objective is to
reduce the combined hazard index for exposure to 2,4-DCP and
herbicides (2,4,5-T and 2,4,5-TP) from the Jacksonville Landfill
Site to 0.3 or less.
As mentioned, the combined hazard index under worst case exposure
from the .herbicides is 511. Reducing this hazard index to 0.3
would require a 99.94% herbicide removal efficiency. Based on the
observed concentrations of herbicides and a 99.94% removal
efficiency, target concentrations for herbicides to achieve a
herbicide hazard index of 0.3 would be:
21,000 ppb for 2,4,5-T
1,800 ppb for 2,4,5-TP, and
Page 1-62
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500 ppb for 2,4-DCP
If, after sampling, the concentrations of either 2,4,5-T, 2,4,5-
TP or 2,4-DCP exceed these action levels, the combined hazard
index should be calculated (using the method employed in the risk
assessment) to determine if it exceeds the 0.3 HI action level.
If the recalculated HI is found to exceed the action level, these
soils will be targeted for remedial action.
It should be noted that exceedances of the target concentrations
for herbicides and 2,4-DCP have only been detected within the drum
disposal area, which also contains high dioxin concentrations.
Therefore, it is expected that as the dioxin-contaminated soil is
remediated, the herbicides will be addressed simultaneously.
Post-Remedial Treatment Goals
As discussed in the Summary of Site Characteristics section of
this ROD, the site waste is not RCRA-listed but it is
characteristic. Therefore Land Disposal Restrictions (LDRs) are
relevant and appropriate to certain constituents of the treated
waste. The regulatory treatment goals for dioxin-waste will also
be adopted to ensure adequate treatment of site contamination.
LDRs for D016 and D017 hazardous waste were published in the June
1, 1990 Federal Register (under 40CFR part 268.43). Since D016
and D017 restrictions are considered to be relevant and
appropriate, concentrations of 2,4-D in the waste will have to be
reduced to 10,000 ppb and concentrations of 2,4,5-TP in the waste
would have to be reduced to 7,900 ppb before the material can be
disposed of. Complying with these limitations will require
reducing maximum 2,4-D concentrations by 99.986% and reducing
maximum 2,4,5-TP by 99.74%.
In addition to the regulatory treatment goals, the pre-remedial
action levels will also be required of the treated waste.
Compliance to the more stringent of the criteria would be
required.
Thermal treatment is the best demonstrated available technology
for treatment of the types of waste found in the Jacksonville
Landfill soils (i.e., dioxins and herbicides). Performance
standards applicable to this type of treatment include the
requirement for a 99.9999% destruction and removal efficiency as
well as limitations on HC1 and particulate emissions. Treatment
to this degree will result in the attainment of all treatment
levels specified for the above-mentioned contaminants. Dioxin-
contaminated soil would be remediated to well below the 1 ppb
health-based goal recommended by ATSDR for residential surface
soil. Additionally, all contaminants causing the waste to be
considered characteristic of EP toxicity would be destroyed to the
point that it no longer exhibits the characteristic.
Page 1-63
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DESCRIPTION OF ALTERNATIVES
SARA requires that selected remedies utilize permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. For the
Jacksonville Landfill Site, a no-action alternative and a range of
treatment and containment alternatives were developed. Based on
the remedial technologies selected, five remedial alternatives
have been developed. One of the alternatives is the no-action
alternative; one involves containment and institutional controls;
one involves offsite treatment, containment, and institutional
controls; and two involve onsite treatment, containment and
institutional controls. The alternatives are:
1) No-Action;
2) Fence, Caps, Land-Use Controls, and Monitoring;
3) Excavation, Offsite Thermal Treatment and Landfill, Soil
Cover, Fence, Land-use Controls, and Monitoring;
4) Excavation, Onsite Thermal Treatment and Backfilling, Soil
Cover, Fence, Land-Use Controls, and Monitoring; and
5) Excavation, Thermal Treatment and Landfill at the Vertac
Chemical Corp. Site, Soil Cover, Fence, Land-use Controls,
and Monitoring.
COMMON ELEMENTS
Many of the remedial alternatives presented below share common
elements. The most frequently shared components are presented as
follows:
Remedial Alternative
Component
Ground Water Monitoring
Contaminant Mapping
Soil Cover
Filling in Site Trenches
Land-Use Controls
1 2
X X
X
X
X
X
3
X
X
X
X
X
4
X
X
X
X
X
5
X
X
X
X
X
Page 1-64
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Components
Ground Water Monitoring: The representative ground water
monitoring program would consist of sampling four deep monitoring
wells and the three residential wells annually, and three shallow
onsite wells every five years. The ground water samples would be
analyzed for Target Compound List (TCL) organics and inorganics,
along with herbicides and pesticides. This evaluation would
include a spatial and temporal analysis of existing data to
determine increasing, decreasing, or stationary trends in
contaminant concentrations. The results of this evaluation would
be used to maintain, increase or decrease the number and types of
samples and analysis required for the monitoring program. As
required by RCRA, the monitoring and evaluation program would be
implemented for 30 years, or another period of time as established
by the EPA Regional Administrator.
Contaminant Mapping; Figure 4 shows the estimated extent of
contamination at the Jacksonville Landfill site, based on linear
interpolation of results from the June 1990 Contaminant Mapping
Study. The estimated amount of soil, debris and waste containing
more than 10 ppb equivalent 2,3,7,8-TCDD in these areas is 130
cubic yards (188 tons). 450 cubic yards (650 tons) of the site is
estimated to contain equivalent 2,3,7,8 TCDD concentrations above
1 ppb. The total area contaminated above 1 ppb equivalent
2,3,7,8-TCDD is estimated as 15,200 square feet.
Soil and waste containing more than 1.0 ppb equivalent 2,3,7,8-
TCDD and/or 2,4-DCP and herbicide contamination associated with a
combined hazard index greater than 0.3 (associated with
concentrations of 1,800 ppb for 2,4,5-TP, 21,000 ppb for 2,4,5-T,
and 500 ppb for 2,4-DCP) would be mapped in 10 foot cells, using
the procedures described in Section 4.5.2 of the Jacksonville
Landfill Feasibility Study.
Generally, the representative grid sampling program would involve:
• Dividing the areas estimated to be contaminated above the
aforementioned limits into 10-foot grids,
• Collecting four grab samples of approximately equal volume
from every cell within the grid (at the approximate center of
every 5'x 5' quarter of the grid, at a depth of 3 to 9
inches),
Homogenizing the four grab samples in a bowl and taking at
least one aggregate sample from the bowl,
• Analyzing for 2,3,7,8-TCDD, 2,4-DCP, and herbicides in each
aggregate sample,
Results of each aggregate sample will be interpreted as
Page 1-65
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characterizing the chemical constituency of the total grid so
that appropriate remedial measures can be taken.
soil Cover; Soil containing between 1 and 10 ppb equivalent
2,3,7,8-TCDD and/or 2,4-DCP and herbicide contamination associated
with a hazard index above 0.3 would be graded (if necessary)
covered with 12 inches of uncontaminated clay, and revegetated.
The soil cover would be integrated into the surrounding soil for
uniform, continuous coverage.
Filling in Site Trenches; The trenches at the site are an
attractive nuisance and contribute to ground water recharge.
These trenches would be backfilled with clean, native clay and
revegetated.
Land-Use Controls; Land-use restrictions would be placed on
surrounding ground water use to prevent activities that could
endanger public health. Representative land-use restrictions
would restrict ground water use on the site and deter shallow
ground water use immediately downgradient of the site.
The method of imposing such restrictions would consist of
negotiation with the City of Jacksonville concerning the Landfill
and with owners of surrounding property concerning ground water
use.
Costs
Cost estimates were prepared during the Feasibility Study for each
of the alternatives. The accuracy range targeted for the
estimates was +50% / -30%, meaning that the actual remediation
costs may be up to 50 percent higher or 30 percent lower than the
estimates accompanying the alternatives presented below. The cost
evaluations were not produced with the intent to accurately
predict remediation expenses, but rather to establish a uniform
basis for evaluating the relative costs attributable to each
alternative.
The cost estimates presented in this ROD have been revised from
those presented in the Feasibility Study Report based upon the
revised soil volumes calculated during the Contaminant Mapping
Study.
Applicable or Relevant and Appropriate Requirements (ARARs)
This discussion will focus on only the most significant ARARs
shared by the remedial alternatives.
RCRA Land Disposal Restrictions; Land Disposal Restrictions
(LDRs) are presented in 40 CFR Part 268. LDRs establish a
timetable and treatment criteria for the restriction of disposal
of wastes and other hazardous materials.
Page 1-66
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As previously discussed, there is no affirmative evidence proving
from which process the herbicides, trichlorophenol and other site
related chemicals came. Records are required to determine the
origin (and thus the "Instability") of the waste. Since the
evidence is inconclusive, land disposal restrictions are not
applicable. Furthermore, Superfund LDR Guide No.7, "Determining
When Land Disposal Restrictions (LDRs) Are Relevant and
Appropriate to CERCLA Response Actions", states that EPA will not
consider the LDRs to be relevant and appropriate for soil and
debris contaminated with hazardous substances that are not RCRA
restricted wastes. Therefore, LDRs are not considered relevant
and appropriate for the dioxin-contaminated soils at the
Jacksonville site. Nonetheless, in the interest of ensuring
adequate treatment of the dioxin waste onsite, RCRA restrictions
pertaining to the treatment of listed wastes will be considered
relevant in the determination of remediation goals.
The contaminated soils are, however, considered "characteristic"
of hazardous waste under waste codes D016 (for 2,4-D) and D017
(for 2,4,5-TP). These waste codes became subject to LDRs with the
promulgation of the RCRA "Third Thirds Rule" in June 1990.
Treatment standards specified in this regulation must be met prior
to waste disposal. Please refer to the "DEVELOPMENT OF
REMEDIATION GOALS" section of the ROD for more information
regarding the applicability of this requirement.
Consideration was given to alternatives 4 and 5 with respect to
ARARs relevant to disposal of the treated ash. Since the ash
resulting from treatment will meet health-based treatment goals,
it will be placed directly into the ground (rather than into a
Subtitle C landfill) without any further processing, except to
modify the pH of the soil mixture to make it more suitable for
revegetation. Also, there would be no need to "delist" the ash
since the waste was not a listed waste prior to treatment.
Characteristic hazardous wastes never need to be delisted, but do
require treatment until the characteristic is no longer exhibited.
This determination is consistant with the RCRA "Contained-in"
Rule, which states that any mixture of a non-solid waste (such as
soil or ground water) and a RCRA listed hazardous waste must be
managed as a hazardous waste as long as the material contains
(i.e., is above health-based levels) the listed hazardous waste.
Once the material has been treated to no longer "contain" the
listed hazardous waste, the material itself will no longer be
considered a hazardous waste,
40 CFR 264.343. Subpart 0 - Incinerators; This regulation
provides operational standards and monitoring requirements for
hazardous waste incinerators. Key components of this regulation
include the requirement for a dioxin-waste destruction and removal
efficiency of 99.9999% for each principal organic hazardous
Page 1-67
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constituent and places limitations on . HC1 and particulate
emissions.
Subpart 0 is considered relevant and appropriate to all remedial
alternatives which employ thermal destruction as a treatment
element.
40 CFR Parts 260. 261. 264 and 270 - Standards for Owners and
Operators of Hazardous Waste Incinerators... (Proposed Rule);
These regulations are currently set forth in "Proposed Rule"
status and are not promulgated, thus they are neither applicable
nor relevant and appropriate. They are, however, "To Be
Considered (TBCs)" as they amend the current hazardous waste
incinerator regulations to improve control of toxic metal
emissions, HC1 emissions and residual organic emissions.
40 CFR Part 258. Criteria for Municipal Solid Waste Landfills
(Proposed Rule); These regulations are also TBCs. They provide
additional operating and design criteria for owners and operators
of municipal solid waste landfills. Included are closure and
post-closure requirements that are more stringent than current
Subtitle D regulations.
State ARARs; No State regulations have been identified as being
more stringent than their Federal counterparts. In order to
qualify as a State ARAR, a State requirement should be:
A State law;
An environmental or facility siting law;
• Promulgated;
More stringent than the Federal requirement;
Identified in a timely manner; and
Consistently applied.
Descriptions of the remedial alternatives follow:
ALTERNATIVE 1 — NO ACTION
Description
During the development and evaluation of alternatives, EPA
guidance requires that a no-action alternative be considered as a
"baseline case," against which all other alternatives will be
evaluated.
Under this alternative, no remedial action will be taken, other
than the ground water monitoring program described above.
Because the wastes remain at the Jacksonville Landfill Site, SARA
requires that the data collected from the site be evaluated every
five years to ensure that the remedies implemented remain
Page 1-68
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protective to human health and the environment. The first five
year review will be initiated no more than five years after the
Remedial Action begins.
cost and Timing
The cost directly associated with implementation of this
alternative is related to the long-term monitoring and the 5-year
evaluation program. The annual operation and maintenance (O&M)
cost for monitoring is estimated to be about $21,000; the cost of
the upper aquifer monitoring would be about $5,000 every five
years; and the cost of each five year evaluation is estimated at
$11,000. The present worth is $360,000 based on a 5% discounted
rate and a 30-year time period.
It is expected that this remedy would be fully implemented within
9 months of the signing of the ROD.
Compliance with ARARs
No Federal or state regulations specify soil cleanup levels for
contaminated soil that is left in-place. Because the soil would
not be treated or effectively contained, this alternative would
not comply with relevant and appropriate clean closure or landfill
closure requirements.
Action-Specific ARARs pertinent to the implementation of this
alternative would apply to the monitoring activities only.
Requirements for these activities include OSHA health and safety
standards, and RCRA facility standards pertaining to preparedness
and prevention, contingency plan and emergency procedures,
recordkeeping, and closure and post-closure procedures.
ALTERNATIVE 2 — FENCE, CAPPING, LAND-USE CONTROLS, MONITORING
Description
The objective of this alternative is the elimination of the major
potential risks to public health and to the environment with
minimum action. The most significant risk to the public is due to
direct contact with dioxin contaminated soil onsite.
Under this alternative, soil and waste would be mapped in 10 foot
cells, using the procedures described in the "COMMON ELEMENTS"
section above. The soil and waste containing more than 10 ppb
equivalent 2,3,7,8-TCDD would be wetted, excavated where
necessary, consolidated into a pile in the drum disposal area
(centered around the central waste pile in this area), graded,
compacted, and covered with a multi-layer RCRA cap.
The soil containing between 1 and 10 ppb equivalent 2,3,7,8-TCDD
and/or containing 2,4-DCP and herbicide contamination associated
Page 1-69
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with a hazard index above 0.3 would be wetted, graded and capped
with a 12 inch thick soil cover. The RCRA cap would be integrated
into any adjacent soil cover or native soil to achieve a uniform,
continuous coverage.
The trenches at the site are an attractive nuisance and contribute
to ground water recharge. These trenches would be backfilled with
clean, native, silty clay and revegetated.
All excavation should take place when the site (including the
trenches) is most likely to be dry, to avoid problems with mud and
with disposal of water in the trenches. A water spray should be
used to control dust during excavation.
In addition, a 7 foot tall, heavy-duty chain link fence with
outriggers and coiled razor wire would be erected to surround the
southern third of the site, where dioxin, 2,4-DCP and herbicide
contamination exceeds action levels and where the caps would be
located. The chain link would be of a fine mesh to make scaling
extremely difficult. The fence posts would be anchored in
corrosion resistant concrete, and the razor wire would be spot
welded to the fence posts, outriggers, and horizontal supports, to
discourage theft and breaching of the barrier. "No-trespassing"
signs warning of the hazards within would also be posted at 100
foot intervals on the fence. The fence would have a padlocked
gate to allow access. Such a fence should reduce trespassing on
the dioxin contaminated portions of the site and the associated
risks.
Land-use restrictions, as described under "COMMON ELEMENTS", would
also be placed on the site and surrounding ground water use to
prevent activities that could endanger public health.
The ground water monitoring and five year evaluation programs are
identical to those described for the no-action alternative.
The boundary of ground water compliance will be delineated by the
deep downgradient wells which have been identified for sampling
(MWJ-06, MWJ-10, RW-01, RW-02 and Motes Residence). If comparison
of sampling results to MCLs or health-based levels indicates that
significant degradation of ground water quality was occurring or
imminent in the residential area at any time, the data would be
evaluated and confirmatory sampling" performed, along with an
updated survey of ground water use. If imminent degradation of
the Class IIB aquifer is confirmed and use of the water is
occurring or likely to occur, ground water users would be notified
and the need for, and feasibility of, remedial action would be re-
evaluated during the next year. Options to be considered would
include alternate water supplies, extraction and treatment
methods, or other viable ground water restoration technologies.
The need for a separate Record of Decision, Explanation of
Significant Differences or other type of ROD amendment would be
Page 1-70
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evaluated at the time that the situation arises.
Inspections of the fence, gate and lock, along with the RCRA cap
and the soil cover would occur on an annual basis, and repair
would take place as necessary and appropriate to assure their
integrity.
During excavation and handling of contaminated material, dust and
visible emissions would be measured and the monitoring required by
OSHA would be performed, in accordance with detailed plans
developed during the design of this alternative.
This alternative will reduce site risks by providing a protective
cap, thus reducing the "direct contact" threat. It does not
eliminate the site risks but does "control" them as long as the
effectiveness of the cap is maintained.
Cost and Timing
The net present worth of ground water monitoring and five year
evaluations associated with this alternative is $360,000. Annual
review of the data, fence, cap and soil cover inspections, and
maintenance will add approximately $16,000 per year. Installation
of the cap, soil cover, and the improved fence and gate is
estimated to cost $750,000. Contamination mapping to determine
the extent of contamination would add $115,000. The present worth
of implementing this alternative is estimated to be $1,530,000.
It is expected that this remedy would be fully implemented within
15 months of the signing of the ROD.
Compliance with ARARs
Action-Specific ARARs pertinent to the implementation of this
alternative would apply to the monitoring and capping activities.
Requirements for these activities include OSHA health and safety
standards, and RCRA facility standards pertaining to minimum
technology requirements, preparedness and prevention, contingency
plan and emergency procedures, recordkeeping, and closure and
post-closure procedures.
Since no "placement" of RCRA contaminated waste would occur under
this alternative, Land Disposal Restrictions are not considered to
be ARARs.
This alternative would not remove contaminated material, but it
would provide containment of contaminated soils with an
impermeable cap. Relevant and appropriate RCRA closure/post-
closure requirements in 40 CFR Sections 264.110 through 264.120
would be met.
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ALTERNATIVE 3 — EXCAVATION/ OPP8ITE THERMAL TREATMENT AND
LANDFILL, SOIL COVER, LAND-USE CONTROLS, MONITORING
pescription
Implementation of this alternative would begin with detailed soil
monitoring. The objective of the representative monitoring
program would be to define the 10 foot by 10 foot cells within
which equivalent 2,3,7,8 TCDD concentrations in surface soil and
debris exceed 1 ppb, the cells within which the equivalent
2,3,7,8-TCDD concentrations exceed 10 ppb, and the cells in which
the hazard index from 2,4-DCP and herbicides exceed 0.3. The
establishment of these remediation criteria is outlined in the
SELECTED REMEDY section of this ROD.
The soil and waste containing more than 10 ppb equivalent 2,3,7,8-
TCDD (and associated herbicides) would be excavated, screened and
loosely packed in labeled 35-gallon fiber drums. These drums
would be overpacked in 55-gallon drums and labeled with the cell
number from which they came. The overpacked drums would be stored
in a shed erected in the north end of the Jacksonville Site
designed to comply with all relevant and appropriate requirements
for hazardous waste storage facilities. Packing all of this
material in 35-gallon overpacked drums would require about 1,500
drums and overpacks, assuming an average of 250 pounds of
contaminated soil is packed into each drum. Drums of waste
associated with monitoring and remedial action would also be
stored in the shed. Storage would continue until an offsite
thermal treatment unit is permitted to treat the soil, debris and
waste and an offsite landfill is permitted to accept the ash. The
drums would then be manifested and transported to a licenced
thermal treatment facility.
The soil that contains equivalent 2,3,7,8-TCDD concentrations
between 1 ppb and 10 ppb and/or 2,4-DCP and herbicide
contamination associated with a hazard index above 0.3 would be
graded, compacted, and capped with a soil cover. The trenches
would be backfilled, as described for Alternative 2, along with
the areas that had contained soil with equivalent 2,3,7,8-TCDD
concentrations above 10 ppb.
For the representative thermal treatment unit, it is assumed that
the facility will only be able to accept 38 t<-»ns of soil per day.
At this rate, all 188 tons of contaminated soil could be shipped
offsite for disposal within five days.
Ground water and OSHA monitoring, and five year evaluations would
be similar to that described for Alternative 2, along with soil
cover inspection and maintenance. For this alternative no new
fence would be installed. However, the existing fence at the site
would be maintained.
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Land-use controls would be the same as described with Alternative
2.
This alternative will reduce the maximum risks of cancer from
maximum plausible exposure to 8 x io"5 and will eliminate
significant risks of threshold toxic effects from herbicides
(total hazard index < l.o).
Cost and Timing
This alternative would include capital costs of $325,000 to
excavate and pack the estimated 130 cubic yards of contaminated
soil and debris into approximately 1,500 thirty five gallon
overpacked drums. Treating the contaminated soil is estimated to
cost $550,000, assuming a treatment and land disposal cost of
$3,000 per ton. Transportation of the material is estimated to
cost $40,000, assuming 80 overpacked drums per truck. Installation
of the soil cover and backfilling the trenches is estimated to
cost $150,000. Additionally, the O&M costs would include $500,000
for monitoring, annual review of the data, fence and soil cover
inspections, and fence and soil cover maintenance, as with
Alternative 2, except that the existing fence would be maintained
and no new fence installed. Periodic inspection of the drums
stored onsite will cost $6,000, assuming the drums are stored for
two years prior to disposal. The present worth of implementing
this alternative is estimated to be $2,420,000.
It is expected that this remedy could be fully implemented within
2 years of the signing of the ROD if a thermal destruction
facility could be permitted for dioxin waste within 12 months of
the ROD.
Compliance with ARARs
ARARs for this alternative apply to excavation of contaminated
soil, site closure with waste in place, reclamation of the areas
excavated and monitoring activities. Requirements for these
activities include OSHA health and safety standards; RCRA facility
standards pertaining to treatment unit operation and performance;
preparedness and prevention; contingency plan and emergency
procedures; manifesting and record keeping; and standards for
ground water protection. RCRA Subtitle C requirements are
relevant and appropriate to the dioxin, chlorophenol, and
herbicide contaminated waste. This alternative would comply with
all such requirements. Transportation would comply with Federal
and Arkansas Department of Transportation regulations.
As discussed under "COMMON ELEMENTS", although LDRs are not ARARs
for the dioxin-contaminated waste, they are applicable to waste
characteristic of EP toxicity under waste codes D016 and D017.
Treated waste will be required to meet the appropriate LDRs prior
to disposal.
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While this is not a RCRA facility, closure and post closure
requirements are considered to be relevant and appropriate. This
remedy would meet the requirements necessary to attain landfill-
closure status. Post-closure inspections to insure the integrity
of the soil cover and ground water monitoring to detect any
significant offsite ground water impacts is expected to comply
with closure requirements.
ALTERNATIVE 4 — EXCAVATION, ONSITE THERMAL TREATMENT/ SOIL COVER/
LAND-USE CONTROLS/ MONITORING
Description
This alternative is similar to Alternative 3, except that the soil
is treated onsite. As was described for Alternative 3, the
implementation of this alternative would begin with sufficient
monitoring to define the areas within which equivalent 2,3,7,8
TCDD-dioxin concentrations in surface soil and debris exceed 1
ppb, the cells within which equivalent 2,3,7,8-TCDD concentrations
exceed 10 ppb, and the cells in which the hazard index from 2,4-
DCP and herbicides exceeds 0.3.
For the representative process option, an estimated 188 tons of
soil containing equivalent 2,3,7,8-TCDD concentrations above 10
ppb would be sampled and packed in 3,000 Ib capacity labeled
polyester bags and stored in a shed at the north end of the
Jacksonville Site in a manner complying with all relevant and
appropriate requirements for a hazardous waste storage facility.
Storage would continue until a suitable thermal treatment system
is brought to the site and treats all of the bagged contaminated
material (along with any contaminated drummed material).
Treatment unit sizing requirements and detailed operational
specifications would be developed during the Remedial Design.
For the representative process, the treated soil, debris and waste
would be analyzed to assure that it meets treatment goals
specified in the "DEVELOPMENT OF REMEDIATION GOALS" section of the
ROD, mixed with manure and seeds, and backfilled into the areas
from which it came-where it would revegetate.
As with Alternative 3, soil containing between 1 and 10 ppb
equivalent 2,3,7,8-TCDD and/or 2,4-DCP and herbicide contamination
associated with a hazard index above 0.3 would be covered with 12
inches of uncontaminated silty clay, and revegetated.
Also as with Alternative 3, the onsite trenches would be
backfilled, and the soil cover and the existing fence would be
inspected and maintained. Ground water monitoring, land-use
controls, and five year evaluations would also take place as
described for Alternative 2.
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As with the previous alternative, this alternative will reduce the
maximum risks of cancer from maximum plausible exposure to Sxio"5
and will eliminate significant risks of threshold toxic effects
from herbicides (total hazard index < 1.0).
A variance to this Alternative was considered during the FS. It
involved utilizing chemical dechlorination as the principal
treatment technology rather than thermal treatment. Chemical
dechlorination is a relatively new process capable of rendering
certain hazardous wastes non-toxic. This technology has been
successfully implemented at other commercial and Superfund sites.
Literature and data searches into past applications of this
process had indicated its potential effectiveness on the dioxins
and herbicides contained in the landfill wastes.
The overall cost and implementation time for utilizing
dechlorination, however, is approximately the same as for onsite
incineration. This technology was, therefore, not selected for
detailed analysis and presentation since it did not appear to
provide any additional benefits above those available with thermal
treatment. Additionally, it had the disadvantage of being neither
as proven nor as effective as thermal technologies. Incineration
has been demonstrated to be effective many times at full scale
application, however dechlorination does not have a demonstrated
track record with these contaminants in soils similar to those
encountered at the Jacksonville Landfill site. Thermal treatment,
therefore, was chosen as the preferred treatment method.
Cost and Timing
Testing of the treatment alternative (e.g. trial burn testing of
the thermal treatment unit along with testing leachate from
treated soil mixtures) is estimated to cost $100,000. The
monitoring, excavation, screening and packing of 130 cubic yards
of contaminated soil is estimated to cost $150,000. The treatment
of the contaminated soil and debris onsite would cost $150,000.
The covering of low level dioxin contaminated soil and long term
cover inspection and maintenance would cost $80,000.
Additionally, the O&M costs would include $430,000 for monitoring,
annual review of the data, fence inspections, and fence
maintenance, as with Alternative 2 (except that the existing fence
would be maintained, and no new fence installed). Periodic
inspection of the bags stored onsite will cost $3,000, assuming
the bags are stored for one year prior to treatment. The present
worth of implementing this alternative is estimated to be
$1,870,000.
It is expected that this remedy wculd be fully implemented within
2 1/4 years of the signing of the ROD.
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Compliance with ARARs
As with Alternative 3, ARARs for this alternative apply to
excavation of contaminated soil, reclamation of the areas of
excavation, and monitoring activities. Requirements for these
activities include OSHA health and safety standards; RCRA facility
standards pertaining to treatment unit operation and performance;
preparedness and prevention; contingency plan and emergency
procedures; record keeping; standards for ground water protection;
and closure and post-closure requirements. In addition, Land
Disposal Restrictions are considered to be applicable only for
waste codes D016 and D017. This remedy would comply with all such
requirements.
ALTERNATIVE 5 — EXCAVATION, THERMAL TREATMENT AT THE VERTAC
CHEMICAL CORP. SITE, SOIL COVER, LAND-USE CONTROLS, MONITORING
Description
This alternative is similar to Alternative 4, except that the soil
is treated at the Vertac Chemical Corp. site in Jacksonville,
Arkansas. As was described for Alternative 4, the implementation
of this alternative would begin with sufficient monitoring to
define the areas within which equivalent 2,3,7,8 TCDD-dioxin
concentrations in surface soil and debris exceed 1 ppb, the cells
within which equivalent 2,3,7,8-TCDD concentrations exceed 10 ppb,
and the cells in which the hazard index from 2,4-DCP and
herbicides exceeds 0.3.
For the representative process option, an estimated 188 tons of
soil containing equivalent 2,3,7,8-TCDD concentrations above 10
ppb would be placed in 12 cubic yard capacity storage containers.
The storage containers would then be transported to the Vertac
Chemical Corp. site and stored in a manner complying with all
relevant and appropriate requirements for a hazardous waste
storage facility. Storage would continue until a suitable thermal
treatment system is brought to the site and treats all of the
contained contaminated material. Treatment unit sizing
requirements and detailed operational specifications would be
developed during the Remedial Design.
The treated soil, debris and waste would be analyzed to assure
that it meets the treatment goals specified in the "DEVELOPMENT OF
REMEDIATION GOALS" section of the ROD, mixed with manure and
seeds, and backfilled into suitable areas at the Vertac site.
As with Alternative 4, onsite soil containing between 1 and 10 ppb
equivalent 2,3,7,8-TCDD and/or 2,4-DCP and herbicide contamination
associated with a hazard index above 0.3 would be covered with 12
inches of uncontaminated silty clay, and revegetated.
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Also as with Alternative 4, the onsite trenches would be
backfilled, and the soil cover and the existing fence would be
inspected and maintained. Ground water monitoring, five year
evaluation and land-use controls would also take place as
described for Alternative 2.
As with the previous alternative, this alternative will reduce the
maximum risks of cancer from maximum plausible exposure to 8xlO"5
and will eliminate significant risks of threshold toxic effects
from herbicides (total hazard index < 1.0).
It should be noted that Alternative 5 does not appear in the
Feasibility Study Report. This alternative was developed as a
variation to Alternative 4 (Onsite thermal treatment) — the sole
modification being that the waste treatment and ash disposal would
occur at the Vertac site rather than at the Jacksonville Landfill.
All other elements of this alternative are identical to those
comprising Alternative 4. Alternative 5 was, however, outlined
and recommended in the Proposed Plan of Action, July 1990, for the
purpose of providing information specific to this alternative and
to encourage comments from interested parties on its components.
Cost and Timing
Testing during the selected treatment alternative (e.g.
contaminant mapping, trial burn testing of the thermal treatment
unit and testing leachate from treated soil) is estimated to cost
approximately $200,000. The monitoring, excavation, screening,
packing and transport of 130 cubic yards of contaminated soil is
estimated to cost $170,000. The treatment of the Jacksonville
Landfill contaminated soil and debris at Vertac would cost
$150,000. The covering of low level dioxin contaminated soil and
long term cover inspection and maintenance would cost $80,000.
Additionally, the O&M costs would include $430,000 for monitoring,
annual review of the data, fence inspection and maintenance, as
with Alternative 2 (except that the existing fence would be
maintained, and no new fence installed). Periodic inspection of
the containers stored at Vertac will cost $3,000, assuming they
are stored for one year prior to treatment. The present worth of
implementing this alternative is estimated to be $1,950,000.
It is expected that this remedy would be fully implemented within
2 1/4 years of the signing of the ROD.
Compliance with ARARs
As described in Alternative 3, ARARs for this alternative apply to
excavation of contaminated soil, reclamation of the areas of
excavation, and monitoring activities. Requirements for these
activities include OSHA health and safety standards; RCRA facility
Page 1-77
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standards pertaining to operation and performance; preparedness
and prevention; contingency plan and emergency procedures, record
keeping; and standards for ground water protection.
As discussed under "COMMON ELEMENTS", although LDRs are not ARARs
for the dioxin-contaminated waste, they are applicable to waste
characteristic of EP toxicity under waste codes D016 and D017.
Treated waste will be required to meet the appropriate LDRs prior
to disposal.
Since the ash resulting from treatment would meet health-based
treatment goals, it will be placed directly into the ground
(rather than into a Subtitle C landfill) without any further
processing, except to modify the pH of the soil mixture to make it
more suitable for revegetation. Also, there would be no need to
"delist" the ash since the waste was not a listed waste prior to
treatment.
While this is not a RCRA facility, closure and post closure
requirements are considered to be relevant and appropriate. ThJs
remedy would meet the requirements necessary to attain landfill-
closure status. Post-closure inspections to insure the integrity
of the soil cover and ground water monitoring to detect any
significant offsite ground water impacts is expected to comply
with closure requirements.
Multiple Sites
Multiple, non-contiguous CERCLA sites may be treated as one for
the purpose of a response action under CERCLA § 104(d)(4). The
preamble to the 1990 NCP discusses the issue of how to determine
whether to treat such sites as one for the purpose of a response
action under this section. 55 Fed. Reg. 8690-8691 (March 8,
1990). As stated in the preamble, "CERCLA section 104(d)(4)
allows EPA broad discretion to treat noncontiguous facilities as
one site for the purpose of taking a response action. The only
limitations prescribed by the statute are that the facilities be
reasonably related 'on the basis of geography' or 'on the basis of
the threat, or potential threat to the public health or welfare or
the environment.' Once the decision is made to treat two or more
facilities as one site, wastes from several facilities could be
managed in a coordinated fashion ar one of the facilities and
still be an 'on-site' action, within the permit waiver of CERCLA
section 121(e)(l)." Id. at 8690.
EPA has determined that consolidation and treatment of landfill
waste at the Vertac site satisfies the above criteria. The sites
are reasonably close to one another and the wastes at the sites
are compatable for the selected treatment and disposal approach.
In addition, EPA has received and responded to comments from the
public, the PRPs, and the State regarding this strategy.
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SUMMARY OP COMPARATIVE XMALYfilB QP ALTERNATIVES
The following section profiles the performance of the described
remedial alternatives against the nine criteria that EPA uses for
their evaluation. This evaluation provides support for EPA's
selection of a site remedy by showing that the selected remedy
would provide the best balance of trade-offs among the
alternatives with respect to the nine criteria. The evaluation
criteria are provided below.
DESCRIPTION OF THE NINE EVALUATION CRITERIA
* Overall Protection of Human Health and Environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment
engineering controls or institutional controls.
* Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) addresses whether or not a remedy will
meet all of the requirements of other Federal and State
environmental statutes and/or provide grounds for invoking a
waiver.
* Long-Term Effectiveness and Permanence refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
* Reduction of Toxicity. Mobility, or Volume Through Treatment
is the anticipated performance of the treatment technologies
that may be employed in a remedy.
* Short-Term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential
to create adverse impact on human health and the environment
that may result during the construction and implementation
period.
* Impleroentability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
* Cost includes capital and operation and maintenance costs.
• * State Acceptance indicates whether, based on its review of
the RI/FS and Proposed Plan, the State concurs with, opposes,
or has no comment on the preferred alternative.
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* Community Acceptance is assessed in the Record of Decision
following a review of the public comments received on the
RI/FS report and the Proposed Plan.
The nine criteria are categorized into three groups: Threshold,
primary balancing, and modifying. The threshold criteria must be
satisfied in order for an alternative to be eligible for
selection. The primary balancing criteria are used to weigh major
tradeoffs among alternatives. The modifying criteria are taken
into account after public comment is received on the Proposed Plan
of Action.
Threshold Criteria
o Overall Protection of Human Health and Environment
o Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Primary Balancing Criteria
o Long-Term Effectiveness and Permanence
o Reduction of Toxicity, Mobility, or Volume Through Treatment
o Short-Term Effectiveness
o Implementability
o Cost
Modifying Criteria
o State Acceptance
o Community Acceptance
ANALYSIS
Overall Protection
The no-action alternative (Alternative 1) will provide no
protection of human health and the environment since it does
nothing to reduce the potential of exposure to site contaminants.
Alternatives 3, 4 and 5 all provide approximately the same overall
protection to human health and to the environment (cancer risks of
8 x 10"5) . Additionally, they are the most protective since they
will prevent exposure by treating and destroying the most
contaminated surface soil and replacing it with clean fill,
covering surface soil containing between I and 10 ppb TCDD, and
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maintaining the existing fence. Alternative 2 will prevent direct
exposure to contaminated soil by installing and maintaining a
capping and fence system. Alternatives 2,3,4 and 5 reduce risks
posed by ponded surface water onsite by filling in site trenches
and grading to promote drainage.
Overall, Alternatives 3, 4 and 5 provide a higher level of long-
term protection than Alternative 2 because the most contaminated
material is treated in these alternatives. Alternative 3 involves
offsite treatment of contaminated soil and its replacement with
clean native backfill. Alternative 4 involves onsite treatment of
contaminated soil and backfilling the treated material onsite
after verifying that the backfill meets treatment criteria.
Alternative 5 involves onsite thermal treatment and disposal of
the treated material at the Vertac plant site.
Overall, implementation of Alternatives 3 and 4 may cause higher
material handling impacts in the immediate vicinity of the site
than Alternatives 5. This could be due to fugitive emissions from
packing the contaminated material in relatively low volume
containers such as drums and 3,000 Ib capacity bags versus packing
the material in large volume 12 cubic yard bulk storage
containers.
Alternatives 3 and 5 would have higher potential offsite impacts
than Alternative 4 because of the transportation of the material
offsite. The offsite transportation risks between alternatives 3
and 5 vary greatly in that the risk of accidents are much lower
and are more easily controlled with alternative 5 due to the very
short hauling distance.
Land-use controls in Alternatives 2, 3, 4 and 5 are directed
toward preventing potential future risks from improper use of
ground water on and near the site. Obviously the risks associated
with development of alternative 2 is greatest among the action
alternatives since wastes remain in place.
Compliance With ARARS
The no-action alternative (Alternative 1) will not meet RCRA
closure requirements, while Alternatives 2, 3, 4 and 5 would meet
their respective applicable or relevant and appropriate
requirements of Federal and State environmental laws.
Lona-Term Effectiveness
Alternative 1 will do nothing to eliminate the 2 x 10"2 maximum
individual risk of cancer from incidental soil ingestion of dioxin
contaminated soil by trespassers. It will also not eliminate
significant risks of threshold toxic effects from exposure to
herbicides. The risk could become more severe if the land were to
be improperly developed.
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Alternative 2 will reduce site risks by providing a protective
cap. This alternative does not eliminate the site risks but does
"control" them as long as the effectiveness of the cap is
maintained.
Alternatives 3, 4, and 5 would all reduce maximum risks of cancer
from maximum plausible exposure to the same level (8 x 10 ) and
eliminate significant risks of threshold toxic effects from
herbicides.
Alternative 2 would reduce the risk from incidental soil ingestion
by capping contaminated soil and making contaminated areas much
more difficult to access. Alternatives 3, 4 and 5 would use a
combination of soil cover and permanent treatment of the most
highly contaminated soil using thermal treatment. As a result,
Alternatives 3, 4 and 5 are considered to be more reliable and
permanent than Alternative 2.
Implementation of Alternative 2 will significantly reduce the
possibility for future development. Alternatives 3, 4 and 5 may
allow limited or controlled site development.
Reduction in Toxicity. Mobility, or Volume Through Treatment
Alternatives 1 and 2 provide no reduction in the current
contaminant toxicity, mobility or volume through treatment. Risks
to human health would remain unacceptable.
Alternatives 3, 4 and 5 reduce the volume and toxicity of an
estimated 130 cubic yards of the most heavily contaminated soil
onsite by thermal treatment methods. An additional estimated 320
cubic yards of low level dioxin contaminated soil is secured under
a soil cover, preventing exposure.
Short-Term Effectiveness
Since the no-action alternative involves only annual monitoring,
onsite activities will cause very little impact. Emissions from
implementation of this alternative, the risk to workers, and the
time to implement this alternative are all less than for any other
alternatives. Exposure to waste remaining onsite, however, could
still result to site workers in acute, short-term adverse health
effects. Short-term risks to site workers from Alternative 2 are
higher than those associated with the no-action alternative
because of the direct contact risk associated with consolidation
of contaminated soil and risks during installation, inspection,
and maintenance of the fence and soil cover.
Potential short-term risks to site workers during implementation
of Alternatives 3, 4 and 5 are higher than for Alternative 2 due
to the increased handling of contaminated material during packing
of drums and transportation. Alternative 5 also has inherent
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short term risks associated with offsite transportation of the
wastes, but are significantly less than those posed by
Alternative 3. The risks associated with the highway
transportation of 130 cubic yards of Jacksonville Landfill waste
materials can be assessed by evaluating the statistical
probability of a highway accident and the risk associated with the
waste spill. Utilizing the Handbook of Chemical Hazard Analysis
Procedures published by the Federal Emergency Management Agency,
U.S. Department of Transportation and the U.S. EPA results in the
following risk numbers:
Accident Frequency Spill Frequency
Alternative (accidents/year) fspills/year)
3 0.031 0.006
5 0.003 0.001
An Accident Frequency of 0.031 can be interpreted to mean that the
statistical chance of an accident occurring while waste is being
transported is 31 out of 1000 or roughly one in 32. A Spill
Frequency of 0.006 means that the chance of an accident resulting
in the actual spilling of waste material is six in one thousand.
The specific risks can be significantly reduced by a detailed
transportation / spill prevention plan. Such a plan will be an
integral part of any approved design dealing with highway
transportation of wastes.
The potential risks to the communities near the treatment sites
during implementation are highest for Alternatives 3, 4 and 5 due
to the treatment of contaminated material at their respective
locations. The risks to onsite workers are similar for the same
Alternatives. However, the likelihood of adverse impacts to the
communities from all these activities is considered to be very
low. Air pollution emissions can be detected very quickly with
standard industrial hygiene monitoring equipment, visible emission
monitoring for fugitive emissions, and stack monitoring
instruments normally associated with hazardous waste thermal
treatment units. Standard construction contingency plans can
address fugitive dust emissions while adherence to federal air
discharge standards will eliminate the possibility of adverse
discharges from the treatment unit. Based on past experience with
similar applications, maximum individual risks of cancer from
emissions associated with these Alternatives are expected to be
substantially less than 10"5.
For all treatment technologies, site workers are not expected to
be adversely impacted. This is because of personal protective
equipment, implementation of proper personnel protection
procedures in accordance with OSHA regulation, the design of the
process equipment and procedures, and proper operating procedures.
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Only 6 months would be required to start the no-action
alternative, since nothing would be done except to perform limited
annual monitoring. For Alternative 2, contaminated soil could be
mapped, contaminated soil could be consolidated, and the soil
cover and fencing could be improved and installed, and land-use
controls could be implemented within 15 months, provided the major
field activities can be scheduled for the summer months, when the
site is most likely to be dry. Alternative 3 could be fully
implemented within approximately 2 years (assuming an offsite
treatment facility is given appropriate permits with 12 months of
the ROD) . Alternative 4 could take up to 2 1/4 years to
implement. Alternative 5 will likely take from 2 to 2 1/4 years
to complete.
Implementability
All components of Alternatives 1, 2, 4 and 5 use commercially
available equipment and services. Alternative 3, also uses
thermal treatment, a proven and reliable technology for treating
dioxins, although, to date no offsite commercial treatment
facility has been issued appropriate permits to treat dioxin.
However, there is expected to be at least one facility available
within a year.
Alternative 1 is technically the easiest to implement, but may be
administratively infeasible because of the high risks to public
health associated with the contaminated material, EPA's legal
mandate and institutional commitments to remediate such risks, and
the concerns of the public, state and local officials.
Alternative 2 is easier technically to implement than Alternatives
3, 4 and 5 because it involves no treatment technology, however it
may not be administratively easier to implement compared to
alternatives involving treatment, because of the congressionally
mandated preference for alternatives involving treatment.
Thermal treatment is known to be technically implementable, and is
in fact the Best Demonstrated Available Technology for RCRA-listed
dioxin wastes. A variety of mobile treatment units are available
with a proven history of effective treatment of dioxin-
contaminated soil. However, at this time no stationary units are
available with appropriate permits to burn dioxin contaminated
soil. As a result, Alternatives 4 (onsite treatment) and 5
(treatment at Vertac) are administratively easier to implement
than Alternative 3 (offsite treatment); however the situation
could change if permits for offsite thermal treatment units to
burn dioxin-contaminated soil are issued.
Some design considerations would be required to select the most
cost effective method of performing Alternatives 3, 4 and 5.
However, several proven and reliable soil cover, excavation, and
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soil processing technologies are available. Thermal treatment of
dioxin-contaminated soil is known to be effective.
Cost
Alternative 1, No-Action, is the least expensive to implement with
a total present worth of $360,000. The total present worth of
Alternative 2 is $1,530,000. The total present worth of
Alternative 3 is expected to be $2,420,000, assuming a cost of
$3,000 per cubic yard for offsite treatment and landfilling
services and that between 130 cubic yards of dioxin-contaminated
material must be packed in 35 gallon fiber drums to be accepted at
the treatment facility. it should be noted that the price of
$3,000 per cubic yard could easily vary by the time this remedy is
implemented due to the uncertainties associated with price
fluctuations in this (as yet unestablished) market. The total
present worth for Alternatives 4 and 5 are $1,870,000 and
$1,950,000, respectively.
The costs outlined above include Capital and Operation &
Maintenance expenses, and are presented in more detail in the
DESCRIPTION OF ALTERNATIVES section of this ROD.
State Acceptance
The Arkansas Department of Pollution Control and Ecology (ADPC&E)
has been consulted and is in agreement with the EPA regarding the
selected remedy outlined in this Record of Decision.
Community Acceptance
Judging from the comments received during the public meeting
conducted in Jacksonville and the subsequent public comment
period, the local citizens are split with regard to their
preference for thermal treatment as the principal treatment
element. A summary of the public comments received and EPA's
responses are presented in the "RESPONSIVENESS SUMMARY" section of
the ROD.
SELECTED REMEDY
The selected remedy is Alternative 5 — Excavation, Thermal
Treatment at the Vertac Chemical Corp. Site, Soil Cover, Land-Use
Controls, and Monitoring. The major components of the selected
remedy include:
o Sampling soil in ten-foot by ten-foot grids to more
accurately define the amount of contaminated surface soil,
debris, and waste onsite;
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o Excavating and packaging for transport contaminated soil and
debris containing more than 10 ppb equivalent 2,3,7,8-TCDD;
o Transporting contaminated material to the Vertac Chemical
Corp. Superfund site in Jacksonville, Arkansas and providing
temporary storage for the material at the Vertac site;
o Conducting thermal treatment of all contaminated landfill
material being temporarily stored at the Vertac site, and
testing, disposal and revegetation of the resulting ash;
o Steam cleaning and onsite disposal of large items of refuse
removed from contaminated areas;
o Backfilling and revegetating areas from which contaminated
soil was removed with uncontaminated native soil and
decontaminated refuse;
o Covering soil, debris and waste meeting the criteria stated
below with twelve inches of native soil;
CRITERIA: 1) Equivalent 2,3,7,8-TCDD concentrations greater
than 1.0 ppb and less than or equal to 10.0 ppb,
and/or
2) Cumulative Hazard Index greater than 0.3 for
the following compounds:
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T),
2,4,5-Trichlorophenoxy propionic acid (2,4,5-TP),
and
2,4-Dichlorophenol (2,4-DCP).
o Backfilling the trenches;
o Ground water monitoring;
o Inspection and maintenance of the soil cover and of the
existing fence; and
o Land-use controls limiting ground water use on and
immediately downgradient of the site.
DETAILED DESCRIPTION OF REMEDY
The Jacksonville and Rogers Road wastes are very similar in
physical and chemical makeup to that waste produced by Vertac
Chemical Corp., of Jacksonville, Arkansas. In addition, EPA holds
evidence that indicates that the waste did indeed come from that
facility. After careful consideration, it has been determined
that in all likelihood the dioxin and herbicides located at these
two landfills originated at Vertac. For this reason it is
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proposed that these wastes be excavated and transported back to
the Vertac facility for ultimate disposal.
Implementation of this alternative would begin with detailed soil
monitoring. The objective of the monitoring program would be to
define the 10 foot by 10 foot cells within which equivalent
2,3,7,8 TCDD-dioxin concentrations in surface soil and debris
exceed 1 ppb, the cells within which the equivalent 2,3,7,8-TCDD
concentrations exceed 10 ppb, and the cells in which the hazard
index from 2,4-DCP and herbicides exceed 0.3. Detailed
methodology of the soil monitoring program is described in Section
4.5.2 of the Jacksonville Landfill Feasibility study.
After mobilization activities and detailed, cell by cell mapping
of contaminated soil are completed, excavation will begin. Ten
foot by ten foot cells of soil and debris with dioxin
concentrations exceeding 10 ppb within one foot of the surface
will be excavated one at a time. After all aforementioned surface
soil is excavated, the soil in the underlying cells will be
sampled again, and any soil in the next foot exceeding the 10 ppb
equivalent 2,3,7,8-TCDD will be excavated down to an additional 12
inches. The process will continue to a maximum depth of 4 feet if
necessary. A water spray will be used for dust control during
excavation. It is estimated that approximately 130 cubic yards of
soil will be addressed in this fashion. The general locations of
the contaminated soil to be mapped are provided previously on
Figure 4.
The contaminated soil will be excavated and dumped directly into
twelve cubic yard dump trailers next to the excavation. The dump
trailers would then be labeled to indicate which cells of wast-
were placed into the dump trailer (each trailer would be used fc
up to three cells), then covered and moved to a coarse gratin
facility. The contents of the trailer would be dumped through th.
coarse grating which would remove items larger than 4" in
diameter. The screened material would drop directly into a
separate twelve cubic yard dump trailer parked under the coarse
grating.
Rocks and other large objects rejected by the grating would roll
off the screen and be collected. They would then be
decontaminated for use as rip rap onsite, after inspection and
dioxin, chlorophenol and herbicide screening to assure that
adequate decontamination has occurred.
The dump trailers containing the material passing through the
coarse screen would be decontaminated and transported
approximately 10 miles to the Vertac Chemical Corp. site ir
Jacksonville, Arkansas. Upon arrival at the Vertac site, the
containers would be stored in a manner complying with all relevant
and appropriate requirements for a hazardous waste storage
facility. Storage would continue until a suitable thermal
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treatment system is brought to the site and treats all of the
contained material.
The treated soil, debris and waste would be analyzed to assure
that it meets the treatment goals outlined in the "DEVELOPMENT OF
REMEDIATION GOALS" section of the ROD. Daily aggregate samples
would be taken of the ash and analyzed for 2,3,7,8-TCDD,
chlorophenols, and herbicides (to verify the effectiveness of the
treatment process) and TCLP leachability (to verify that it does
not have characteristics of hazardous waste). Any ash which does
not meet treatment objectives would be retreated (if the problem
is from organics) or solidified (if the problem is from the
leaching of inorganics). Ash meeting treatment criteria would be
mixed with manure and seeds, and backfilled into suitable areas on
the Vertac site property.
The areas from which dioxin contaminated soil was excavated would
be backfilled with at least 12" of clean silty clay where the
residual equivalent 2,3,7,8-TCDD concentration exceeds 1 ppb. The
backfill would be compacted and would extend to at least the level
of the surrounding surface (6" above the surface where only one
foot of soil was removed). The backfill would be integrated with
the surrounding native soil and soil cover (over soil containing
between 1 and 10 ppb equivalent 2,3,7,8-TCDD) and graded to
promote drainage. In addition, these areas would be revegetated
and rip-rap would be incorporated where necessary.
Soil containing between 1 and 10 ppb equivalent 2,3,7,8-TCDD
and/or 2,4-DCP and herbicide contamination associated with a
hazard index above 0.3 would be graded (if necessary), covered
with 12 inches of uncontaminated silty clay, and revegetated.
Open site trenches which are an attractive nuisance and contribute
to ground water recharge would be backfilled, and the site would
be re-vegetated to minimize erosion. In addition, those non-
contaminated areas disturbed during the implementation of this
alternative would be graded and revegetated. Rip-rap would be
used, where necessary and appropriate.
Continued monitoring of ground water would be required. For the
selected alternative, the wells to be monitored and the rationale
for monitoring them are shown below:
MWJ-01 Deep well indicating regional natural
background levels.
MWR-06 Deep well between Rogers Road and Jacksonville
Site, indicating background levels of
contamination possibly related to Rogers Road
Site.
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• MWJ-06 Deep well downgradient of Jacksonville Site to
indicate impacts of contamination from near
the center of the Jacksonville Site.
MWJ-10 Deep well downgradient of site near southeast
corner of site, potentially downgradient of
drum disposal area, a dioxin and herbicide hot
spot.
RW-02 Residential well near center of the site where
contamination was previously detected.
• Motes Residential well near the northeast end of the
Residence site where the occupant reportedly drinks the
ground water.
• RW-01 Residential well southeast of site possibly
downgradient of site.
• MWJ-02 Shallow natural background well.
MWR-07 Shallow well between Rogers Road and
Jacksonville Sites, indicating background
levels, possibly related to Rogers Road Site.
• MWJ-07 Shallow well to indicate potential impacts on
upper aquifer ground water quality of
contamination from the Jacksonville Site.
The ground water samples would be analyzed for TCL organics and
inorganics, along with herbicides and pesticides.
The monitoring would occur, as recommended under SARA, for at
least thirty years. The four deep monitoring wells and the three
residential wells would be sampled annually, and the three shallow
wells would be sampled every five years. The ground water
monitoring in the shallow wells every five years is performed for
the purpose of evaluating long-term trends.
The results of this monitoring would be summarized every five
years. At that time, the EPA could decide to increase, decrease,
or maintain the scope of the monitoring plan.
The boundary of ground water compliance will be delineated by the
deep downgradient wells identified for sampling above (MWJ-06,
MWJ-10, RW-01, RW-02 and Motes Residence). If comparison of
sampling results to MCLs or health-based levels indicates that
significant degradation of ground water quality was occurring or
imminent in the residential area at any time, the data would be
evaluated and confirmatory sampling performed, along with an
updated survey of ground water use. If imminent degradation of
the Class IIB aquifer is confirmed and use of the water is
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occurring or likely to occur, ground water users would be notified
and the need for, and feasibility of, remedial action would be re-
evaluated during the next year. Options to be considered would
include alternate water supplies, extraction and treatment
methods, or other viable ground water restoration technologies.
The necessity of a separate Record of Decision, Explanation of
Significant Differences or other type of ROD amendment would be
evaluated at the time that the situation arises.
Inspections of the fence, gate and lock, along with the soil cover
would occur on an annual basis, and repair would take place as
necessary and appropriate to assure their integrity.
Land-use restrictions would also be placed on the site and
surrounding ground water use to prevent activities that could
endanger public health. Representative land-use restrictions
would preclude improper use of ground water on the site and would
deter use of the shallow ground water immediately downgradient of
the site.
Imposing such restrictions would be negotiated with the City of
Jacksonville concerning the Landfill and with owners of
surrounding property concerning ground water use.
The activities described above outline the conceptual framework of
the preferred alternative. Engineering design considerations will
be taken into account during the detailed design which will
optimize the efficiency of the remedial action. It is possible
that minor changes could be made to the remedy outlined above
which would reflect modifications resulting from the remedial
design and construction processes.
REMEDIATION GOALS
The remediation goals for this alternative were derived from
recommendations by the Centers for Disease Control (with respect
to carcinogenic health threats) and from calculations produced in
the Jacksonville Landfill Risk Assessment (regarding
noncarcinogenic health effects). This discussion presents a
summary of the remediation goals that were established in the
"DEVELOPMENT OF REMEDIATION GOALS" section of the ROD.
Pre-remedial action levels will be used as criteria to determine
whether soil remediation is required. The action levels are given
as follows:
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ACTION LEVEL RESULTING
COMPOUND (ppbl ACTION
2,3,7,8-TCDD i.o < Cone. < 10.0 Soil Cover
equivalents Cone. > 10.0 Thermal Treatment
2,4,5-T
2,4,5-TP Cumulative HI > 0.3 Soil Cover
2,4-DCP
Post-remedial treatment goals will be used as standards to assure
that effective treatment of remediated soil and debris has been
achieved and to determine whether additional treatment is
required. Where more than one goal is provided for a single
compound, the most restrictive applies. These goals are presented
below:
COMPOUND TREATMENT GOAL
2,3,7,8-TCDD 1.0 ppb, OR
equivalents Thermal treatment unit operating
requirements, as provided in 40 CFR
Part 264.343.
2,4-D 10,000 ppb
2,4,5-TP 7,900 ppb
AND
2,4,5-T
2,4,5-TP Cumulative HI < 0.3
2,4-DCP
Treatment to these levels will result in a residual site risk of
less than 8 x 10"5 and a maximum cumulative Hazard Index of 1.0.
COST
Several of the costs included in this estimate were prorated among
the Jacksonville and Rogers Road sites since they would both share
much of the same equipment and facilities. The estimate for the
Jacksonville site includes only its share of the costs.
Mobilization and general site preparation activities are estimated
to cost approximately $125,000. Contaminant mapping will cost
$115,000.
Excavation, packing, transport, storage, and treatment of the
contaminated soil and debris onsite is expected to cost $170,000.
This cost includes the trial burn testing of the thermal treatment
unit and bench scale tests of the chemical and physical properties
of treated soil, which is estimated to cost approximately $70,000,
Testing the ash to assure that it meets treatment criteria is
estimated to cost an additional $30,000. The covering of lov
level dioxin contaminated soil would cost $70,000. Site
restoration and backfilling the trenches is estimated to cost
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$190,000. Additionally, the O&M costs would include $500,000 for
monitoring, annual review of the data, soil cover and fence
inspections, and maintenance.
The present worth is estimated to be $1,950,000. A complete cost
summary is shown in Table 8. Additional details on costs are
provided in Appendix D of the Jacksonville Landfill Feasibility
Study.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
protection of human health and the environment. In addition,
section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through thermal treatment of dioxin and herbicide-contaminated
soil which presents the principal threat, and covering the lesser-
contaminated soils which present low level threats. The areas to
be covered will be closed in accordance with RCRA landfill closure
requirements to reduce the likelihood of contaminant migration.
Thermal treatment will eliminate the threat of exposure to the
most toxic contaminants from direct contact with or ingestion of
contaminated soil. The current risks associated with these
exposure pathways is 2 x 10"2 for carcinogenic risk and 511 total
hazard index for noncarcinogenic risk. By excavating the hotspots
of contaminated soil and treating them in a thermal treatment
unit, the cancer risks from exposure will be reduced to 8 x 10"5
for carcinogenic risk and less than 1.0 total hazard index for
noncarcinogenic risk. This level is within the range of
acceptable exposure levels of between 10"4 and 10"6 for carcinogenic
risk and less than 1.0 total hazard index for noncarcinogenic
risk. There are no short-term threats associated with the
selected remedy that cannot be readily controlled.
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TABLE 8
COST ESTIMATE
ALTERNATIVE 5: EXCAVATION, TREATMENT AND BACKFILLING AT VERTAC,
SOIL CAP, PENCE, LAND USE CONTROLS AND MONITORING
Jacksonville Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
I. Capital Cost
A. Direct Cost
1. General Actions/
Site Preparation
• Clearing and
Grubbing
• Temporary Ditches,
Dikes and Berms for
Sediment Control and
Runoff Diversion
• Sediment Control Basin
• Decontaminate
Facility
• Access Roads, etc.
• Administrative and
Health & Safety
Trailers
400 S.Y.
L.S.
L.S.
L.S.
L.S.
4 months
SUBTOTAL:
2. Contamination Mapping
• Analytical
- Background Finger
Printing 4 Samples
-Onsite Laboratory
Mobilization
- Onsite Laboratory
for Sample
Analysis
L.S.
2.5 Weeks
$1/S.Y.
$4,000/mo
40u
2,000
5,000
5.. 000
10,000
16.000
38,400
$2,000/each 8,000
5,000
$25,000/wk 62.500
75,500
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TABLE 8 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Jacksonville Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
• Professional L.S.
• Equipment L.S.
• Other Direct Charges L.S.
SUBTOTAL:
32,850
3,330
4.860
116,540
Contaminated Soil
Treatment
• Mob/Demob for
Excavation and
Site Operations
• Soil Excavation
and Handling
• 12 C.Y. Storage
Container Cost
• Packing, Loading,
Transporting and
Unloading Containers
at Vertac. (Average
10 C.Y./Container)
• Mobilization, De-
mobilization, and
Set-up for Treatment
Including Temporary
Storage (Prorated)
• Trial Burn Test
(Prorated)
• Water Spraying and
other Miscellaneous
Costs
L.S.
130 C.Y. $ 12/C.Y.
13 Containers $2,000/each
13 Each
L.S.
L.S.
L.S.
$750/each
20,000
1,560
26,000
9,750
66,000
66,000
10,000
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TABLE 8 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Jacksonville Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cdst($)
(1990)
• Support Facilities and
Dust Control, etc. 15 Days
• Onsite Treatment 189 Tons
• Confirmational Testing
of Ash - One
Aggregate Sample
Per Day
• Construction of
Storage Facility to
Store 13 Containers
for One Year
15 Samples
1,950 S.F.
4. Environmental Studies
• Environmental Impact
Studies (Prorated) L.S.
5. Soil Covering
• Covering Areas Containing
1 to 10 ng/g of
Equivalent
2,3,7,8 - TCDD 11,800 S.F.
6. Site Restoration and Backfilling
• Steam Cleaning and Disposal
of Large Items of
Refuse Removed from
Contaminated Areas L.S.
$ 750/Day 11,250
$ 750/Ton 141,750
$ 2,400/Each 36,000
$ 50/S.F. 97.500
SUBTOTAL: 485,810
SUBTOTAL:
72.000
72,000
$6/SF 70.800
SUBTOTAL: 70,800
15,000
1-95
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TABLE 8 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Jacksonville Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Co'st($)
(1990)
• Mixing Incinerated Soil
with Manure or Sewage
Sludge and
Backfilling
• Revegetation
• Backfilling the
Trenches
7. Land Use Controls
• Deed Restriction
130 C.Y.
1,310 S.Y.
10,000 C.Y.
$200/C.Y.
$1/S.Y.
$15/C.Y.
SUBTOTAL:
L.S.
SUBTOTAL:
TOTAL DIRECT COST:
26,000
1,310
150.Qpn
192,310
50.000
50,000
1,025/860
B. Indirect Cost
Health & Safety
e 10% of Direct Cost
Bid and Scope Contin-
gency § 15% of
Direct Cost
Administrative & Legal
@ 5% of Direct Cost
Engineering & Services
@ 10% of Direct Cost
TOTAL INDIRECT COST:
TOTAL CAPITAL COST (DIRECT + INDIRECT):
102,590
153,880
51,290
102.590
410,350
1,436,210
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TABLE 8 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Jacksonville Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
II. O & M Cost
• Annual Data Review 8 Mrs
• Maintenance of Existing
Fence L.S.
Annual Inspection and
Maintenance of Soil Cover L.S.
A. Periodic Inspection of
Containers Stored Onsite
for One Year L.S.
B. Present Worth of Long-
Term Groundwater Monitoring
(Annual and 5-Year) (See
Jacksonville FS Report,
Table 6-1 for Details) .
C. Present Worth of Annual
Data Review
($480 X 15.3725)
D. Present Worth of Existing
Fence Maintenance Based
on 5% Discount Rate for
30 Years ($2,000 X 15.3725)
E. Present Worth of Inspection
and Maintenance of Soil Cover
Based on 5% Discount Rate
for 30 Years ($2,500 X
15.3725)
F.. Land Use Control Contingencies
for 30 Years
$60/Hr
480
2,000
2,500
3,000
360,170
7,380
30,750
TOTAL O & M COST
(NET PRESENT WORTH):
38,430
74.000
513,730
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TABLE 8 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Jacksonville Landfill Site
Jacksonville, Arkansas
Estimated Unit Cost($)
Activity Quantity Price (1990)
III. TOTAL COST OF ALTERNATIVE 5
(CAPITAL + O 6 M) ===========
(NET PRESENT WORTH): $ 1,949,940
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COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
The selected remedy of excavation, thermal treatment, and soil
cover will comply with all applicable or relevant and appropriate
chemical-, action-, and location-specific requirements (ARARs).
Key ARARs are presented below.
Action-specific ARARs;
RCRA Land Disposal Restrictions (LDRs) are presented in 40
CFR Part 268. LDRs establish a timetable and treatment
criteria for the restriction of disposal of wastes and other
hazardous materials.
Transportation of hazardous wastes is regulated under 40 CFR
Part 263 and 49 CFR Parts 107 and 171-177.
40 CFR 264 Subpart 0 provides operational standards and
monitoring requirements for hazardous waste incinerators.
Key components of this regulation include the requirement for
a destruction and removal efficiency of 99.9999% and
limitations on HC1 and particulate emissions.
40 CFR 256.23 provides guidance for the closure of open
dumps. These regulations specify closure in a fashion that
minimizes potential health hazards and incorporates long-
term monitoring where necessary.
40 CFR 264.117(a)(1) Subpart G post-Closure and Monitoring
requirements for thirty years or another period determined by
the Regional Administrator.
Chemical-specific ARARs;
There are no chemical-specific ARARs for contaminated soil
and debris.
Location-specific ARARs;
Executive Order on Floodplain Management, Executive Order No.
11,988, requires Federal agencies to evaluate the potential
effects of actions they may take in a floodplain to avoid
adverse impacts associated with direct and indirect
development of a floodplain.
Other Criteria. Advisories or Guidance to be Considered for this
Remedial Action (TBCs);
CDC's 2,3,7,8-TCDD recommendations for residential settings
have been adopted for this remedial action. These
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recommendations provide that the following action levels will
not result in excess threats to public health:
1.0 ppb TCDD on surface soil;
10 ppb TCDD, when covered by at least 12
inches of clean fill.
CERCLA section 104(d)(4) allows EPA to treat noncontiguous
facilities as one where those facilities are reasonably
related on the basis of geography, or on the basis of threat
to public health or welfare or the environment.
40 CFR Part 258 - Criteria for Municipal Solid Waste
Landfills, is currently set forth in "Proposed Rule" status.
These proposed regulations provide operating and design
criteria for owners and operators of municipal solid waste
landfills. Also included are closure and post-closure
requirements that are more stringent than current Subtitle D
regulations.
40 CFR Parts 260, 261, 264 and 270 - Standards for Owners and
Operators of Hazardous Waste Incinerators... (Proposed Rule):
These regulations amend the current hazardous waste
incinerator regulations to improve control of toxic metal
emissions, HC1 emissions and residual organic emissions.
State ARARs;
No State regulations have been identified as being more
stringent than the Federal requirements.
COST-EFFECTIVENESS
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs, the net present worth value being $1,950,000. The estimated
costs of the selected remedy are only slightly higher (only 1.30
times) than the costs associated with onsite capping of the
contaminated soils, and yet the selected remedy assures a much
higher degree of certainty that the remedy will be effective in
the long-term due to the significant reduction of the toxicity and
volume of the wastes achieved through thermal destruction of the
principal contaminants onsite.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE MAXIMUM
EXTENT PRACTICABLE
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner for the final source control operable unit
at the Jacksonville Municipal Landfill site. Of those alternatives
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that are protective of human health and the environment and comply
with ARARs, EPA and the state have determined that this selected
remedy provides the best balance of tradeoffs in terms of long-
term effectiveness and permanence, reduction in toxicity, mobility,
or volume achieved through treatment, short-term effectiveness,
implementability, and cost, also considering the statutory
preference for treatment as a principal element and considering
State and community acceptance.
Thermal treatment offers a high degree of long-term effectiveness
and permanence and will significantly reduce the principal threat
and inherent hazards posed by the contaminated soils. Low level
threats can be effectively addressed through capping such that the
residual material that remains onsite can be contained with a high
degree of certainty over the long term.
The selection of treatment of the contaminated soil is consistent
with program expectations that indicate that highly toxic and
mobile waste are a priority for treatment and often necessary to
ensure the long-term effectiveness of a remedy. Since the three
treatment options evaluated are reasonably comparable with respect
to compliance with ARARs, long-term effectiveness and the reduction
of toxicity, mobility and volume, the major tradeoffs that provide
the basis for this selection decision are implementability and
community acceptance. The selected remedy can be implemented more
easily and in a comparable timeframe as the second and third-
choice remedies, and the community has expressed a preference for
returning the contaminants back to the location of their
originating source.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating the dioxin and herbicide-contaminated soils in a
thermal treatment unit, the selected remedy addresses the principal
threats posed by the site through the use of treatment
technologies. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Proposed Plan for the Jacksonville Municipal Landfill site was
released for public comment in July 1990. The Proposed Plan
identified Alternative 5, thermal treatment and disposal of ash at
the Vertac site, as the preferred alternative. EPA reviewed all
written and verbal comments submitted during the public comment
period. Upon review of these comments, it was determined that no
significant changes to the remedy as it was originally identified
in the Proposed Plan were necessary.
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SECTION 2.0
RESPONSIVENESS SUMMARY
-------
JACKSONVILLE AND ROGERS ROAD
MUNICIPAL LANDFILLS, ARKANSAS
RESPONSIVENESS SUMMARY
OVERVIEW
At the time of the public comment period, EPA had issued a
Proposed Plan setting forth the preferred alternatives for the
Jacksonville and Rogers Road Landfill sites near Jacksonville,
Arkansas. These alternatives were presented to the public for
their review and comment. EPA's recommended alternatives
addressed the soil contamination problems at the sites and
involved thermal treatment and capping of dioxin and herbicide
contaminated soils, site grading and restoration, and long-term
site and ground water monitoring.
Judging from the comments received during the public meeting
conducted in Jacksonville and the subsequent public comroenc
period, the local citizens are split with regard to their
preference for thermal treatment as the principal treatment
element. The Arkansas Department of Pollution Control and Ecology
(ADPC&E) is in favor of thermally treating soils containing dioxin
above 10 parts per billion (ppb), but is not in agreement with the
need to cap residual soils containing dioxin concentrations
between 1.0 and 10 ppb. Hercules, Inc., the only potentially
responsible party (PRP) responding during the comment period,
proposes deleting the thermal treatment and capping components
from the site remedy altogether.
The responsiveness summary that follows is required by CERCLA. It
provides a summary of the significant comments and concerns
received during the public comment period, and EPA's responses to
those comments and concerns. All comments received by EPA during
the public comment period are considered in EPA's final decision
for selecting the remedial alternative for addressing
contamination at the Jacksonville and Rogers Road Landfill sites.
These sections follow:
Background on Community Involvement.
• Summary of Comments Received during the Public Comment Period
and Agency Responses.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Jacksonville and Rogers Road Landfills
dates to 1973, when a citizen's complaint was submitted to EPA
regarding the possible disposal of hazardous wastes at the sites.
Page 2-1
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Since then, community concern and involvement has remained
relatively strong. Several individuals have been particularly
vocal in expressing their concerns to the Jacksonville City
Council, ADPC4E, and EPA. In addition, a considerable amount of
media attention has been focused on the sites. A significant
factor contributing to the amount of public involvement observed
at the landfill sites is their close proximity to the City of
Jacksonville and to the Vertac Chemical Corporation Superfund
site. The Vertac site has been an ongoing source of controversy
on the national scale for over ten years. Because of the
attention and scrutiny that has been directed toward the city of
Jacksonville, public sensitivity to environmental issues is quite
high.
SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
TECHNICAL QUESTIONS/CONCERNS REGARDING SELECTED ALTERNATIVE
1) Several local citizens and business persons offered their
support for the remedial alternative set forth in tho
Proposed Plan of Action, July 1990.
EPA Response; No response required.
2) Several citizens expressed transportation-oriented concerns
regarding the shipment of contaminated soils from the
landfills to the Vertac site.
EPA Response; EPA seriously reviewed the merit of
transporting the landfill wastes to the Vertac site,
especially considering that transportation of the Vertac
wastes to an offsite location was previously, and remains to
be, regarded as unfavorable (although other factors in
addition to transportation concerns were accounted for in the
Vertac determination). Transport of the landfill soils to
the Vertac facility is considered to be far safer than
transporting the Vertac waste offsite, primarily due to the
difference between the quantity and type of waste to be
shipped. The landfills are estimated to contain only a total
of approximately 200 cubic yards (cy) of soil contaminated
with relatively low levels of hazardous substances while the
wastes at Vertac consist of approximately 29,000 barrels of
drummed, highly concentrated liquid waste. At 10 cy per
truckload, 200 cy of landfill soil can be transported in 20
trips.
Detailed transportation specifications will be developed
during the remedial design, however a few general concepts
can be outlined here. Haul routes between the landfill sites
and the Vertac facility will be established only after
careful consideration is made with respect to minimizing the
number of affected parties, and after the development of
Page 2-2
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appropriate safety procedures and emergency plans.
Decontamination facilities will be constructed in order to
properly rinse contaminants from the trucks and material
containers prior to their leaving the landfill sites.
3) Two commenters requested that the Remedial Design include
provisions for improving site drainage.
EPA Response; Based upon this comment, as well as through
interviews with adjacent residents and visual observations,
EPA recognizes that the site drainage patterns are
undesirable in their present state. Although not
specifically set forth in the Record of Decision (ROD), the
remedial action will examine the need for site improvements
such as drainage enhancement. One likely possibility is that
the ditch which parallels the eastern fenceline of the
Jacksonville site will be regraded to improve the efficiency
of runoff from the site.
4) One citizen quoted a report that an earthquake of sizable
proportion was predicted to occur in the early part of this
decade - December 3, 1990, to be precise. The concern was
raised regarding the capability of the thermal treatment unit
to withstand seismic forces.
EPA Response: The thermal technology which is specified in
the ROD will likely be carried out by a mobile treatment
unit. Rather than design a treatment unit to withstand the
extremely high stresses imposed by seismic events, EPA can
require design and performance modifications of the unit
which will minimize the volume of material which could
potentially be exposed in the event of earthquakes or other
natural disasters.
Since there is such a small volume of waste requiring
treatment, the treatment unit used will likely be of small
scale. The low capacity of these smaller units means that
less than five cubic yards of material is would be undergoing
the treatment process at any given time during operation.
This, coupled with the automatic shutoff features which will
be specified in the operating requirements, will result in a
very low exposure potential even to those working in the
immediate treatment area.
Another point worth mentioning is that because there is such
a small amount of soil being treated, the total duration of
treatment will be very short - likely 40 to 50 days for 200
cy of soil. This results in an extremely low probability of
a predicted seismic event occurring within any given
timeframe of such short duration.
Page 2-3
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5) One comment was raised regarding the need for appropriate
qualifications of the construction personnel who would be
conducting the remedial action.
EPA Response; Remedial Actions (RAs) which are paid for
using Federal Superfund monies are required to follow EPA
acquisition regulations. This process requires free and open
competition, meaning that all jobs are subject to competitive
bidding. EPA is then required to award the job to the lowest
cost responsive, responsible bidder. An evaluation is
conducted by EPA to make sure that the party being awarded
the construction contract is capable of conducting the type
of services requested. In addition, the contractor will be
required to meet the health and safety standards found in 29
CFR 1910.120, and other quality assurance/quality control
guidelines.
6) One person asked whether the thermal treatment unit would
require permits.
EPA Response; The Superfund Law (known as CERCLA) exempts
onsite response actions from the requirement of obtaining
permits. Because the EPA has determined to treat these sites
as one for the purpose of remedial action, incineration at
Vertac is considered an "onsite" action. The permit
exemption allows the response action to proceed in an
expeditious manner, without the potential lengthy delays of
obtaining approval by administrative bodies. While the
formal process of obtaining and administering permits is not
required, response actions must meet the substantive
requirements of whatever permits would otherwise apply to the
action. These requirements pertain directly to actions or
conditions in the environment and include health-,
technology- and location-based standards and restrictions.
7) A local citizen requested clarification as to whether the
incinerator currently in operation at Vertac would be the
treatment unit used for the Jacksonville and Rogers Road
wastes.
EPA Response; As discussed in Comment No. 5, this remedial
action is required to comply with EPA acquisition regulations
which, among other things, requires free and open
competition. This requirement precludes EPA from "pre-
selecting" any single firm. EPA selects contractors through
a formal open bidding process. VSC, who operates the
incinerator currently located at Vertac, and any other
interested qualified firms would be invited to submit a
competitive bid for the Landfill contracts.
8) One citizen asked when the Remedial Design (RD) would be
complete.
Page 2-4
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EPA Response; EPA anticipates that the RD will be complete
within 12 months from the signing of the ROD.
9) One citizen asked how long "long term" monitoring would be
conducted.
EPA Response; Current regulations specify a monitoring
period of 30 years from the completion of the remedial
action. This period of time can be extended or reduced
depending on when the determination is made by EPA and the
State that the remedy is, and will remain, protective to
human health and the environment.
QUESTIONS/COMMENTS REGARDING REMEDIAL ALTERNATIVE PREFERENCES
10) One individual asserted his distrust for thermal destruction
and recommended that EPA cap the contaminated soils in place
without treatment until more is known about effective dioxin
treatment.
EPA Response; Thermal destruction is a widely used
technology, capable of safely and permanently destroying
dioxin waste. It has been identified by EPA as being the
Best Demonstrated Available Technology (BOAT) for the types
of contaminants encountered at the Landfill sites, and has
been documented as being able to treat the wastes to the
levels specified in the ROD.
The BOAT classification signifies a type of "approval"
rating. In order for a technology to be classified as BOAT,
EPA performs an analysis to make sure that the technology
meets the following criteria: 1) performance data must show
that the technology is significantly more effective than any
others for a given waste type; 2) a full-scale facility is
known to be in operation and successfully treating similar
wastes; and 3) the process is generally or commercially
available.
It is unlikely that another technology could be developed and
demonstrated to be as effective as thermal destruction in the
near future. Thus, the present course of action is
consistent with EPA's goals of providing timely and
expeditious action at sites which present human health and
environmental threats.
11) Several commenters requested that the waste be incinerated
somewhere other than Jacksonville.
EPA Response; This alternative was seriously considered in
the Feasibility Study and is, in fact, presented as
Alternative 3 in the "DESCRIPTION OF ALTERNATIVES" section of
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the ROD. There are two principal issues that discourage the
selection of this alternative. The first is the fact that
there are currently no commercial hazardous waste
incinerators permitted to accept dioxin waste from the
Landfill sites. Some facilities have submitted permit
applications for this type of waste but, to date, none have
been approved. It is uncertain when, if ever, approval would
come.
The second consideration taken into account is EPA's strong
preference for onsite action. That is, it is EPA's policy to
give preference to remedies that are conducted onsite rather
than sending the waste offsite to private treatment, storage
or disposal facilities, etc. (It should be noted that the
National Contingency Plan, EPA's "guidance" document for
Superfund sites, allows the selected remedy to be considered
an onsite action because it satisfies the criteria of site
proximity and waste similarity.)
12) One resident who lives near the landfills proposed that any
and all soils containing detectable levels of dioxins be
excavated and treated at Vertac.
EPA Response; Because the selected remedy removes the most
heavily contaminated soil and reduces site-related risks to
levels within the acceptable risk range, no further treatment
will be specified. A review will be initiated within five
years of the remedial action to re-evaluate whether the
remediation goals remain protective. If the re-assessment
reveals that further action is warranted to assure
protectiveness, studies would be conducted to determine the
most efficient method of accomplishing this.
13) One local citizen asked that EPA consider excavating the hot
spot near the eastern fence line of the Jacksonville landfill
(at Sample No. SS-F4-01) and consolidating it in the vicinity
of the other secondary hot spots prior to capping.
EPA Response; Although sufficient protection would be
achieved by capping the hot spot in place, other
considerations make the idea of consolidating this hot spot
among the others more attractive. An obvious benefit would
be more "aesthetic" in nature, as removal of the hot spot
from near the eastern fenceline would place some distance
between the hot spot and the residential back yards which are
adjacent to the fence. A more tangible benefit comes from
possible capital and maintenance cost savings due to having
one less cap to construct and maintain. This is a comment
worth further consideration during design.
14) One commenter expressed her disappointment that In-Situ
Vitrification (ISV) was not examined further.
Page 2-6
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Response; isv was evaluated in the early stages of the
Feasibility Study, it was screened out because of technical
impracticalities including the high moisture content and
garbage contained in the soils which would make
implementation of this technology difficult. Also, there was
concern that ISV might generate other hazardous constituents
as by-products of the process.
15) One commenter proposed that the capping of soils containing
between 1.0 and 10 ppb of dioxin is unnecessary considering
present land use.
EPA Response; The Agency for Toxic Substances and Disease
Registry (ATSDR) is the governmental agency which EPA
consults regarding health matters. ATSDR has recommended
that, in a residential setting, subsurface soils containing
concentrations of 2,3,7,8-TCDD not exceeding 10 ppb should
not pose a significant health hazard if covered with 12
inches of clean soil. This recommendation has been used at
several other Superfund sites contaminated with dioxins.
Based upon ATSDR's recommendation, EPA has incorporated a
component into the site remedy which calls for placing 12
inches of clean fill over areas found to contain dioxins
between 1.0 and 10 ppb. (Recall that soils containing over
10 ppb will be removed and thermally treated.)
The commenter's main point is that the Jacksonville and
Rogers Road landfill sites are not presently considered
residential areas. They assert that perhaps EPA should use
ATSDR's less stringent recommendations for commercial /
industrial sites. This is a valid claim, however, Superfund
site remedies are required to provide protectiveness not only
with regard to present land use, but also based upon future
land use scenarios. As discussed in the ROD, present site
conditions are not very conducive to residential development
(i.e., the site is partially located within the 100-year
floodplain and is trenched and mounded with municipal
wastes). However, there are no city or county zoning
ordinances restricting land-use and therefore it is
conceivable that the site could potentially be used for
residential purposes in the future. This is an unlikely
scenario, but it cannot be eliminated and EPA is therefore
required to consider residential use as a possible future
land use. In consideration of this potential scenario, the
residential setting and corresponding action levels are
appropriate and therefore adopted with regard to remedial
action objectives for the landfill sites.
16) Hercules, Inc., one of the PRPs for the sites, proposed that
the treatment and capping components of the site remedies be
Page 2-7
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deleted altogether. Hercules maintains that adequate
protection of human health and the environment can be
afforded even without treatment or capping.
EPA Response; Hercules' basis for this proposition is a risk
analysis produced by a private company (ChemRisk) on
Hercules' behalf. Their conclusion contends that the
allowable level of TCDD in residential soils should be 28
ppb, and 113 to 209 ppb at industrial sites. By adopting the
levels calculated for the industrial setting, Hercules
concludes that no treatment or capping of site soils is
required.
Two issues need to be addressed in order to respond to this
comment: 1) the use of residential vs. industrial settings,
and 2) the reasoning behind using EPA's Risk Assessments
rather than ChemRisk's for the landfill sites. Issue number
1 was discussed in the previous comment; i.e., EPA has
adopted the residential setting as the basis for determining
acceptable remediation goals.
Regarding issue number 2, Hercules Inc. submitted a report
prepared by ChemRisk which provided calculations resulting in
cleanup goals differing from EPA's for dioxin. The report
utilized certain calculations and assumptions which were
contrary to EPA guidance and resulted in cleanup goals much
less restrictive than those calculated used by EPA. The
paragraphs below discuss some of the discrepancies between
EPA's and ChemRisk's methods of calculating site related
risks.
The cancer potency factor for 2,3,7,8-tetrachlorinated
dibenzo-p-dioxin (2,3,7,8-TCDD) of 9,700 (mg/kg-day)-1 is
presented in ChemRisk's Section 2 ("Dose-Response Assessment
for Dioxin"). This cancer potency factor or slope factor has
not been verified by the CRAVE workgroup and is not in
accordance with EPA policy. The EPA slope factor for
2,3,7,8-TCDD is 1.56 x 105 (mg/kg-day) "1.
Several exposure parameters used in ChemRisk's Section 4
("Recommended Action Levels for TCDD-Contaminated Soil") are
not in accordance with EPA guidance. ChemRisk uses a soil
contact rate or adherence factor of 0.5 mg/cm2, which
underestimates by a factor of 3 to 6 the quantity of soil
adhering to the skin, and which results in an underestimate
of dermal absorption.
ChemRisk uses soil ingestion rates of 10 mg/day for children
aged 0 to 1 years, 50 mg/day for children aged 1 to 5 years,
and 10 mg/day for older children and adults. EPA's Exposure
Factors Handbook (EPA/600/8-89/043) provides upper-range soil
ingestion rates of 800 mg/day for children aged 1 to 6 years,
Page 2-8
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and 100 ing/day for older children and 50 ing/day for adults.
ChemRisk uses fish consumption rates of 0 g/day, 0.49 g/day,
and 1.48 g/day for ages 0 to 1 years, 1 to 12 years, and 12
to 70 years, respectively. The EPA guidance recommends fish
consumption rates of 38 g/day for the 50th percentile daily
intake. This rate represents per capita consumption and may
underestimate recreational fishermen who consume larger
amounts of fish than the general population.
EPA, in preparing the risk assessment, used the cancer
potency factor, soil contact rate, soil ingestion rates and
fish consumption rates that were in accordance with agency
guidance and policy. Using EPA's risk assessment approach,
the cleanup levels provided in the selected remedy will
result in excess cancer risks within the National Contingency
Plan's acceptable range of 10"4 to 10"6. ChemRisk's proposed
cleanup goals, using EPA's risk assessment approach, would
not result in excess cancer risks (after remediation) within
the acceptable risk range.
In addition, Hercules questions how the 1984 risk assessment
produced by Dr. Renate Kimbrough for the Times Beach,
Missouri Superfund site relates to the landfill sites. In
response, Kimbrough's paper was not relied on for the
derivation of the landfills' risk assessments. However, the
results of the Kimbrough paper were cross-referenced in an
informal comparison at the completion of the landfill risk
analyses in order to see where we fell with respect to
Kimbrough's findings. Results of this comparison revealed
that, as was the case with Tiroes Beach, an action level of
1.0 ppb for 2,3,7,8-TCDD resulted in the risks for the
landfill sites falling within the range of acceptable risk
provided in the National Contingency Plan. This action level
is consistent with current EPA thinking regarding dioxin-
contaminated Superfund sites.
The risk assessments themselves were produced independently
of Kimbrough's paper and in accordance with the methodology
outlined in the Superfund Public Health Evaluation Manual
(1986) and the Superfund Exposure Assessment Manual (1988).
The assumptions and standard exposure parameters used in
assessing landfill site risks were consistent with the
aforementioned guidance documents, and were not intended to
be consistent on all counts with the Kimbrough paper.
As a final note, it should be emphasized that long term
protection to human health and the environment would not be
achieved without the treatment and containment components of
the ROD. Without further treatment or containment, the risks
at the Jacksonville and Rogers Road Landfill sites will
remain unabated. The remedies that Hercules proposes —
Page 2-9
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primarily comprised of fencing, land use controls and long
term monitoring — will not reduce the toxicity, mobility, or
volume of site contaminants. Further, these measures have
not been proven effective in precluding direct contact to
contaminated surface soils. Fences are easily breached and
land use controls are difficult, if not impossible, to
enforce. For these reasons, EPA has chosen not to rely on
these types of controls as primary measures for effective
site remediation.
QUESTIONS REGARDING EFFECTIVENESS OF INCINERATION
17) Several commenters expressed concerns over the effectiveness
of thermal treatment on dioxins, and the safety of those
residing in the proximity of the treatment unit.
EPA Response; EPA has experience in treating these types of
wastes at other sites (Times Beach, Denny Farm - Missouri).
Test burns completed at these sites indicated that the
incinerated soils met all appropriate goals. The trial burn
for the landfill sites' waste will be required to attain a
99.9999% reduction of dioxin in the stack emissions. Also,
the treated ash will be sampled to verify that all other
treatment goals have been met. All of EPA's experience with
thermal destruction indicates it provides protection of human
health and the environment. Therefore, as previously
discussed, incineration is considered the "Best Demonstrated
Available Technology" for the destruction of dioxin.
18) Two local citizens asked whether this type of incineration
had ever been conducted within a residential area.
EPA Response; The incineration of hazardous material has
been occurring for many years. There are numerous facilities
in operation throughout the country which incinerate many
different types of hazardous wastes on an ongoing basis.
Only a small fraction of the incinerators of this type are
operated under the authority of Superfund. Instead, most are
private or commercial facilities regulated under other
Federal Laws such as the Recourse Conservation and Recovery
Act, the Hazardous and Solid Waste Amendments, and the Toxic
Substances" Control Act, among others. Additionally, thsre
are other agencies besides EPA which oversee the operations
of these facilities, for example, the Department of Energy
and the Department of Defense.
Although there are known instances of hazardous waste (i.e.,
dioxin) incineration being conducted in or adjacent to cities
and towns, information detailing the specific location of
incinerators relative to population density within a known
proximity is not readily available.
Page 2-10
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QUESTIONS REGARDING THE REMEDIAL INVESTIGATION, RISK ASSESSMENT
AND FEASIBILITY STUDY METHODS AND CONCLUSIONS
19) Several citizens were concerned that EPA may not have sampled
deep enough to find all of the waste that may be buried
onsite.
EPA Response; This is an understandable concern, since no
records were kept regarding the locations or depths of the
wastes that were disposed of at the sites. EPA recognized
this at the outset of the Remedial Investigation (RI), thus
the sampling strategy which was instituted at the sites
included provisions for sampling at various depths. Shallow
soils (<2 feet) were sampled using a short hand-driven auger.
Deeper soils (up to 30 feet or more) were monitored through
the use of large drilling rigs. For these samples, soil
borings were sampled at regularly spaced intervals and at any
other location suspected of being contaminated. A third
sampling method involved digging to the bottom of the
existing site trenches, where dumping was known to have
occurred, until native undisturbed soils were encountered
Samples were taken at the bottoms of these trenches in order
to characterize the waste. Finally, in an attempt to locate
any other areas where we might not have thought to look, EPA
and their site contractor solicited the assistance of a
nearby resident who suspected that drums were buried onsite.
At the discretion and direction of the resident, EPA trenched
the site at various locations until all parties were
satisfied that the suspected areas had been addressed. More
information regarding sampling methods employed at the sites
can be found in Chapter 3.0 of the sites' respective Remedial
Investigation Reports.
20) A local resident asked if the city water supply was being
polluted by Jacksonville landfill site contaminants.
EPA Response; No. As far as the City's municipal wells are
concerned, it is highly unlikely that they could be even
remotely affected by contamination from the Jacksonville and
Rogers Road sites. The most obvious reason is because no
ground water contamination which could be attributable to the
site was found even immediately down-gradient (down-stream)
of the sites. In addition, ground water flow in the ?rea is
toward the east-southeast and the closest municipal wells are
approximately 2 miles southwest of the landfills.
EPA recognizes, however, that the ground water near sites
which operated in the fashion as these (i.e., open dumping)
can be somewhat vulnerable to leaching from buried wastes
onsite. Because of this, EPA is instituting a long-term
ground water monitoring program to ensure that the remedies
taken at the sites continue to provide protection to the
Page 2-11
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ground water quality in the area. Through this monitoring
program, any trends in water quality, will be detected and
appropriate actions will promptly be taken.
21) One commenter, speaking on behalf of a local citizen's group,
requested that a full health study be performed throughout
the City of Jacksonville.
EPA Response; The Agency for Toxic Substances and Disease
Registry (ATSDR), in association with the Arkansas Health
Department and ADPC&E, is currently evaluating the scope of
a possible health study in the Jacksonville area. They are
presently seeking the input of a Community Advisory Panel
comprised of members of the local and medical communities,
elected officials, and representatives of public
environmental groups. It should be noted that the decision
to conduct the health study rests with ATSDR and the Arkansas
Health Department, not EPA.
QUESTIONS REGARDING OTHER ISSUES
22) Several citizens referred to the "No Burn Ordinance" and
asked why it appears that the ordinance is not being
observed.
EPA Response; CERCLA mandates that Superfund response
actions comply with all Applicable or Relevant and
Appropriate Requirements (ARARs). ARARs consist of all
Federal or State environmentally protective requirements that
either address specific circumstances related to Superfund
sites, or situations sufficiently similar to those
encountered at the CERCLA site that their use is well suited
to the particular site. Compliance with the substantive
requirements of State regulations is required only when the
regulation is uniformly applied on a State-wide basis. Local
ordinances would not qualify under this criteria because they
are not applied consistently across the state. Another
reason that compliance with standards other than Federal and
State regulations (i.e., local ordinances) is not required is
that they might unduly restrict or otherwise encumber timely
remedial response at Superfund sites.
23) One commenter was concerned that the remedial action would
set a precedent fui. the importing of Superfund wastes to
Vertac from other areas of the State and beyond.
EPA Response; EPA will not establish the Vertac site as a
hazardous waste treatment center. EPA's rationale for
bringing the landfill wastes back to Vertac is that they are
suspected of having originated at that facility in the first
place. As mentioned in Comment No. 11, the sites satisfy the
NCP's criteria of close proximity and similarity of wastes to
Page 2-12
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the degree that the selected remedy is considered an "onsite"
action. Other unrelated sites would not very likely be able
to satisfv such r*yi *•/»»• -i * •*
to satisfy such criteria.
Page 2-13
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APPENDIX A
ADMINISTRATIVE RECORD INDEX
-------
INTRODUCTION
Section 113(j)(l) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) provides that judicial review of any issues concerning the
adequacy of any response action shall be limited to the administrative record which has
been compiled for the site at issue.
Section 113(k)(l) of CERCLA, requires that the United States Environmental Protection
Agency (Agency) establish administrative records for the selection of CERCLA response
actions. The administrative record is the body of documents upon which the Agency
based its selection of a remedy. The agency's selection of a particular response action
must be documented thoroughly in the administrative record. The Agency must ensure
that the record is a compilation of documents leading up to and reflecting the Agency's
response decision.
In accordance with U.S. EPA Headquarters OSWER Directive 9833.3, Section 113(k) of
the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), as amended in 1986 by the Superfund Amendments and Reauthorization
Act (SARA) the U.S. EPA is required to compile and make available to the public
Administrative Records containing documents used to support response actions
authorized under CERCLA and SARA. The Administrative Records are to be
maintained at the relevant U.S. EPA Regional Offices as well as "at or near the facility
at issue".
This Administrative Record File Index consists of information upon which the Agency
based its decision on selection of response actions. It is a subset of information included
in the site files. The records in this Administrative Record File Index have been
arranged in chronological order (from the earliest date to the most recent date), based
on the date of the corresponding document. Each document contained in the
Administrative Record File has been stamped with sequential document numbers, to
assist in the location of the document with the Record File.
This Administrative Record File Index has been compiled in accordance with OSWER
Directive Number 9833.la Interim Guidance on Administrative Records for Decisions
on Selection of CERCLA Response Actions. This guidance reflects, to the extent
practicable revisions being made to the National Contingency Plan (NCP).
-------
ADMINISTRATIVE RECORD INDEX
FINAL
SITE NAME: JACKSONVILLE LANDFILL
SITE NUMBER: ARD 980809941
INDEX DATE: 10/01/90
-------
*******-^**************************************
I. CHRONOLOGICAL LISTING
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000001 - 000009
05/17/83
9
C. Phillip Watts, Field Investigation Team (FIT)
Ecology and Environment, Inc.
EPA Staff, U.S. EPA Region 6
Report
Potential Hazardous Waste Site - Identification and
Preliminary Assessment for the Jacksonville City Landfill site
000010 - 000026
10/13/83
17
C. Phillip Watts, FIT
Ecology and Environment, Inc.
U.S. EPA Region 6 Site Files
Report
Potential Hazardous Waste Site Investigation (SI) Report for
Jacksonville City Landfill (Includes Analysis Summary)
000027 - 000029
04/18/84
3
Allyn Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Bill Owen, City Engineer, City of Jacksonville
Request Letter
Letter requesting information related to activities at the
Jacksonville and Rogers Road Landfill
000030 - 000030
05/18/84
1
Keith Vaughn, City Attorney
City of Jacksonville
Bonnie DeVos, Superfund Enforcement, U.S EPA Region 6
Correspondence
City of Jacksonville response to Section 104(e) letter,
records do not indicate that there has been any hazardous
waste disposed of at the Jacksonville landfill before it was
closed in 1972
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000031 - 000037
05/01/85
7
Gene McDonald, FIT
Ecology and Environment, Inc.
Bill Davis, Arkansas State Program Manager, EPA Region 6
Memorandum
A summary of events and activities to date for the
Jacksonville Landfill site
000038 - OOOOA3
05/23/85
6
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Report
Site Status Summary updated 05/23/85
000044 - 000048
06/06/85
5
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Doug Keilman, Hercules, Inc.
Correspondence
104(e) letter
000049 - 000050
06/19/85
2
Bill Hathaway for Allyn Davis, Director, Hazardous Waste
Management Division
U.S. EPA Region 6
James Reid, Mayor, City of Jacksonville
Correspondence
A Section 104(e) letter requesting information related to
activities at the Jacksonville and Rogers Road Landfill
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ADMINISTRATIVE RECORD INDEX
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000051 - 000163
06/24/85
112
Kendall Young, Chief Laboratory Section
U.S. EPA Region 6
Keith Bradley, Remedial Project Officer (RPO) Hazardous Waste
Section, U.S. EPA Region 6
CLP Data Review
Contract Laboratory Program (CLP) Data Review
000164 - 000164
06/24/85
1
Roxanne E. Jayne, Associate Counsel
Hercules, Inc.
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence
Acknowledgment of request for information regarding activities
at Jacksonville and Rogers Road Landfill Sites relating to
hazardous wastes
000165 - 000165
06/24/85
1
Roxanne Jayne
Hercules Incorporated
Tim Perdue, U.S. EPA Region 6
Record of Communication
RE: Rogers Road/Jacksonville Landfill
letter and request 30 day extension
- Response to 104(e)
000166 - 000180
07/01/85
15
Jairo Guevara, Chemical Engineer, FIT
Ecology and Environment, Inc.
Keith Bradley, RPO, Hazardous Waste Section, U.S. EPA Region 6
Memorandum
Interim Report - Sampling of residential wells in the vicinity
fo the Jacksonville and Rogers Road Landfill Sites
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000181 - 000181
07/08/85
1
Martha M. McKee, Chief, Superfund Compliance Section
U.S. EPA Region 6
Roxanne E. Jayne, Associate Counsel, Hercules, Inc.
Correspondence
Response to request for extension to the 07/11/85 deadline - 2
week extension is granted
000182 - 000183
07/10/85
2
Georgi Jones, Chief, Public Health Service
Superfund Implementation Group, U.S. EPA Region 6
George Buynoski, Public Health Advisor, U.S. EPA Region 6
Memorandum
Comments on Jacksonville Landfill Dioxin and Furan Water
Sample Results by Human Health & Safety Superfund
Implementation Group
000184 - 000189
07/18/85
6
James Reid, Mayor
City of Jacksonville
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence and Attachments
City of Jacksonville response to Section 104(e) Letter, City
operated two sanitary landfills from 1953 to 1974 for disposal
of garbage and miscellaneous rubbish debris, types and
quantities unknown
000190 - 000193
07/22/85
4
Keith Bradley, RPO, Hazardous Waste Section
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section, U.S. EPA Region 6
Report
Potential Hazardous Waste Site- Interim report on the sampling
conducted on 06/05/85. Data are given for two soil samples
collected in vicinity of drum near Brenda Jones property
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ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000194 - 000195
07/22/85
2
Roxanne E. Jayne, Associate Counsel
Hercules, Inc.
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence
Response letter to 104(e) letter
000196 - 000212
07/29/85
17
Keith Bradley, FIT RPO, Hazardous Waste Section
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section, U.S. EPA Region 6
Report
Potential Hazardous Waste Site: Attached is the Interview
Report on results of dioxin and furan analyses of water wells
collected by FIT on 07/11/85
000213 - 000213
07/30/85
1
Robert Booth, Director
Environmental Monitoring & Support Lab - Cincinnati, OH
Dick Whittington, Regional Administrator, U.S. EPA Region 6
Memorandum
Re: Technical Consultation on Dioxin Analysis
000214 - 000215
08/02/85
2
Oscar Cabra, Jr., P.E., Chief, Water Supply Branch
U.S. EPA Region 6
Bruno Kirsch, Jr., P.E., Director, Division of Engineering,
Arkansas Department of Health
Correspondence
Organics Analysis for samples taken from Jacksonville Public
Water Supply on 06/07/85
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000216 - 000253
08/19/85
38
Russell Rhoades, Director, Environmental Services Division
U.S. EPA Region 6
Dick Whittington, Regional Administrator, U.S. EPA Region 6
Correspondence
Re: Jacksonville, AR Groundwater Sampling Workplan
000254 - 000254
09/03/85
1
Phillip H. McMath
The McMath Law Firm, P.A.
Robert E. Hannesschlager, P.E. Acting Chief, Superfund Branch,
U.S. EPA Region 6
Correspondence
Re: Freedom of Information Act (FOIA) request (6)RIN-708-85,
Graham Road Cases, acknowledge receipt of correspondence of
08/15/85, with enclosures on the Graham Road Landfill in
Jacksonville, AR
000255 - 000328
09/03/85
74
Keith Bradley, FIT RPO, Hazardous Waste Section
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section
Report
Potential Hazardous Waste Site- Comments- Hazardous Ranking
System (HRS) package and sampling/inspection chronology report
attached
000329 - 000331
09/06/85
3
James L. Graham, Jr., P.E. Chief, Public Water Supply Section
U.S. EPA Region 6
Martha McKee, Chief, Superfund Compliance Section, U.S. EPA
Region 6
Correspondence
Potential Hazardous Waste Site-Site Inspection report.
Comments on CERCLA investigation reports sent to the Water
Supply Branch
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000332 - 000337
09/11/85
6
Barry Nash, Environmental Analysis Section
U.S. EPA Region 6
Russell F. Rhoades, Director, Environmental Services Division,
U.S. EPA Region 6
Memorandum
Re: Jacksonville Groundwater Sampling- attached field audit
report concerning FIT sampling at two residential wells in
Jacksonville, AR
000338 - 000340
09/11/85
3
Allyn M. Davis, Director, Hazardous Waste Mangement Division
U.S. EPA Region 6
R.D. Karkkainen, Director, Environment and Safety, Vertax
Chemical Corporation
104(e) Letter
Requesting types of hazardous waste and chemical character of
each hazardous identified on site
000341 - 000343
09/13/85
3
Russell Rhoades, Director, Environmental Service Division
U.S. EPA Region 6
Dick Whittington, P.E., Regional Administrator, U.S. EPA
Region 6
Memorandum
A summary of results of groundwater sampling for
Octachlorodibenzo-p-dioxin (OCDD) at residential wells of A.
Glover & E. Lumen in Jacksonville, AR
000344 - 000344
09/13/85
1
Don-Michael Bradford, Major, Director, Regional Civil
Engineer, Environmental Planning Division
U.S. Air Force
Robert Hannesschlager, Chief, Superfund Branch, U.S. EPA
Region 6
Correspondence
Response by U.S. Air Force with respect to the letter of
inquiry as to possible use by Little Rock AFB of Jacksonville
and Roger Road Landfill sites
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000345 - 000346
09/20/85
2
Gene A. McDonald, FIT
Ecology and Environment Inc.
Keith Bradley, RPO, Hazardous Waste Section, U.S. EPA Region 6
Memorandum
Results of OCDD Analysis of Samples collected from two
residential wells in Jacksonville, AR
000347 - 000347
09/25/85
1
Diana G. Ayers, Chief, Houston Branch
U.S. EPA Region 6
D. Oscar Ramirez, Deputy Director, Environmental Services
Division, U.S. EPA Region 6
Memorandum
Re: Jacksonville Summary Analysis
000348 - 000348
10/18/85
1
Dick Karkkainen, Director of Environment and Safety
Vertac Chemical Corporation
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence
Re: Vertac has no documents pertinent to sites. Neither
Hercules or Vertac disposed of chemical still bottoms
000349 - 000365
10/23/85
17
Stephen Margolis, Ph.D., Acting Director
Agency for Toxic Substances and Disease Registry (ATSDR)
Carl Hickam, Public Health Advisor, U.S. EPA Region 6
Memorandum
ATSDR Health Assessment for Jacksonville Landfill site
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000366 - 000367
10/28/85
2
Philip A. Charles, Office of Public Awareness
U.S. EPA Region 6
Public
News Release
EPA Environmental News- Test Results from recent sampling at
Jacksonville Landfill show that, while contamination was found
on site, conditions there do not pose an immediate public
health threat
000368 - 000369
10/29/85
2
None Specified
U.S. EPA Region 6
List of Addressees
Correspondence
Old Jacksonville Landfill, enclosed copies of FIT sampling
mission report, Center for Disease Control's (CDC's) advisory
memorandum and EPA press release concerning latest results and
analyses
000370 - 000385
11/01/85
16
Citizens of Jacksonville, AR
None Specified
U.S. EPA Region 6
Correspondence
Complaints filed by the citizens of Jacksonville, AR
000386 - 000387
11/06/85
2
Dale Bumpers
U.S. Senate
Dick Whittington, Regional Administrator, U.S. EPA Region 6
Correspondence
Re: Released test results from recent samplings at a
Jacksonville, AR landfill, which once served as a dumping
ground for Vertac
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ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000388 - 000388
11/18/85
1
Dick Whittington, Regional Administrator
U.S. EPA Region 6
Dale Bumpers, U.S. Senate
Correspondence
Re: letter of 11/06/85 regarding the inclusion of the
Jacksonville Landfill on the Superfund National Priority List
(NPL), also the Rogers Road Landfill
000389 - 000390
11/22/85
2
Stephen Margolis, Ph.D., Acting Director
USHHS/ATSDR, Office of Health Assessment
Carl Hickam, Public Health Advisor, U.S. EPA Region 6
Memorandum
ATSDR supplement Health Assessment for Jacksonville Landfill
site
000391 - 000391
12/05/85
1
Gary Guerra, Mary Ellen Crolwey, Rosemary Henderson, Ellen
Greeney (EPA Staff)
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Record of Communication (ROC)
Follow-up for Citizen's Inquiry re: Graham Road Landfill
000392 - 000395
01/09/86
4
Frances E. Phillips for Dick Whittington, P.E. Regional
Administrator
U.S. EPA Region 6
Dales Bumpers, U.S. Senate
Correspondence
Re: Inquiry of 12/12/85 concerning Graham Road and Rogers Road
Landfills
10
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000396 - 000396
01/16/86
1
Bill Davis
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
Request for resampling at City Well No. 4. Mayor Reid repeated
his request for another analysis of City Well #4 for dioxins
per instructions from City Council
000397 - 000398
01/23/86
2
Tommy F. Robinson, M.C., House of Representatives
Congress of the United States
Dick Whittington, Regional Administrator, U.S. EPA Region 6
Congressional Request
Request for retest of municipal well system in Jacksonville,
AR for dioxins
000399 - 000399
01/27/86
1
Dick Whittington, P.E., Regional Administrator
U.S. EPA Region 6
Tommy F. Robinson, House of Representatives, Congress of the
United States
Correspondence
Re: Retesting of municipal water wells at Jacksonville, AR.
Both domestic and municipal wells were tested and no dioxins
have been detected. No sampling mission for dioxins is
necessary
000400 - 000404
04/07/86
5
Gene McDonald, FIT
Ecology and Environment
Keith Bradley, RPO, U.S. EPA Region 6
Mmeorandum
RE: Proposed Air Lampling Plan for Jacksonville Landfill
11
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ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000405 - 000405
08/13/86
1
JoAnn Miller
U.S. EPA Region 6
Myra Perez, U.S. EPA Region 6
ROC
FIT sampling at Jacksonville Landfill, information was
requested by Betty Williamson on sampling schedule at
Jacksonville because of possible filming at the site by NBC
000406 - 000406
08/14/86
1
Robert Hannesschlager, Chief, Superfund Enforcement Branch
U.S. EPA Region 6
Russ Wyer, Director, Hazardous Site Control Division, U.S. EPA
Headquarters
Memorandum
Re: Narrative summaries for Region 6, NPL update 6 sites
000407 - 000408
10/07/86
2
Robert E. Bamberg, Assistant City Attorney
City of Jacksonville
Dennis Cossey, American Fuel & Power Corporation
Correspondence and Attachment
RE: In Situ Vitrification
000409 - 000409
10/14/86
1
Melissa Stallings, FIT Environmental Scientist
Ecology and Environment, Inc.
Keith Bradley, RPO, U.S. EPA Region 6
Memorandum
Re: Status report of sites containing FIT
investigation-derived waste
12
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000410 - 000410
10/16/86
1
Keith Bradley, FIT RPO, Hazardous Waste Section
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section
Report
Potential Hazardous Waste Site-Disposal of FIT-investigation
derived waste, FIT recommends this Technical Directive
Document (TDD) be closed out and re-tasked under the new
contract
000411 - 000412
11/05/86
2
B. Bobbie, Supervisor, Dioxin Unit
Ministry of the Environment
J. Oskowis, Manager- Engineer, Jacksonville Water Commission
Correspondence
Results of analysis of two Jacksonville well water samples for
chlorinated dibenzo-p-dioxin (CDD) and chlorinated
dibenzofurans (CDF). No CDD/CDF were detected
000413 - 000413
11/13/86
1
Jim Oskowis, P.E., Manager-Engineer
Jacksonville Water Commission
Harold Seifert, Division of Engineering, Arkansas Department
of Health
Correspondence
For your information and files- copies of a letter of
transmittal and a laboratory report of dioxin and furan
analyses of two Jacksonville water samples. No dioxins or
furans were detected
000414 - 000425
11/19/86
12
K.H. Malone, Jr., FIT RPM
Ecology & Environment
Keith Bradley, FIT RPO, Emergency Response Branch, U.S. EPA
Region 6
Report
Air Sampling Report and Results for Jacksonville
13
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ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000426 - 000426
11/21/86
1
Phil Charles
U.S. EPA Region 6
Dave Peters, U.S. EPA Region 6
ROC
Re: Ms. Jeanette Colberg/Jacksonville Water Supply - 07/11/85
water well #4 and two adjacent wells in which hepta-and TCDD
were detected. 07/30/85 resampling showed no contamination
000427 - 000427
12/05/86
1
Barry Nash
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
Air Sampling results at the Jacksonville Landfill
000428 - 000439
12/12/86
12
David Peters, Chief, Hazardous Waste Section
U.S. EPA Region 6
Mrs. Jeanette Colberg, Minot Air Base
Correspondence
Letter in response to request for information on Jacksonville
water sampling data. Enclosed is the request for information
000440 - 000455
12/19/86
16
Martha M. McKee, Chief, Superfund Site Assessment. Section
U.S. EPA Region 6
Barbara Goetz, Congressional Liaison, Office of External
Affairs, U.S. EPA Region 6
Memorandum
Attached results of air sampling conducted at Jacksonville
Landfill, also a copy of the letter transmitting these results
to Arkansas Department of Pollution Control & Ecology (ADPC&E)
14
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FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000456 - 000461
01/02/87
6
Oscar Cabra, Jr., P.E. Chief, Water Supply Branch
U.S. EPA Region 6
Martha McKee, Chief, Superfund Compliance Branch, U.S. EPA
Region 6
Memorandum
Comments on CERCLA investigation reports - Potential Hazardous
Waste Site- Site Inspection Reports
000462 - 000474
01/12/87
13
Carl Hickam, R.S, Senior Public Health Advisor
ATSDR/EPA Region 6
Martha McKee, Chief, Superfund Site Assessment Section, U.S.
EPA Region 6
Memorandum
"Health Consultation for Jacksonville Landfill"
000475 - 000478
07/30/87
4
Barry L. Johnson, Ph.D, Associate Administrator
Agency for Toxic Substances and Disease Registry
David Wagoner, Director, Waste Management Division, U.S. EPA
Region 6
Correspondence
Response to request for elaboration on the mathematics
underlying the development of support for the 20 parts per
billion (ppb) cleanup level
000479 - 000483
10/02/87
5
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Tommy Swain, Mayor, City of Jacksonville
Correspondence and Attachments
Inquiry into willingness of Jacksonville to enter into an
agreement on a voluntary basis to conduct Remedial
Investigation/Feasibility (RI/FS) Study at Jacksonville &
Rogers Road sites
15
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000484 - 000485
12/16/87
2
Carl E. Edlund, Chief, Superfund Program Branch
U.S. EPA Region 6
Joe Gillespiey, Manager, State Programs, Office of
Intergovernmental Services, Dept of Fin & Admin
Correspondence
Re: Notifies Mr. Gillespiey of a proposed Superfund project
that includes the RI/FS at the Jacksonville Municipal Landfill
site. Subject to State intergovernmental review process
000486 - 000488
01/04/88
3
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Lee Thalheimer, Esquite, Vertac Chemical, Arnold, Grobmeyer &
Haley
Correspondence
Based on its investigation, EPA has information which
indicates that Vertac may be a responsible party. Will Vertac
voluntarily perform RI/FS at Jacksonville Landfill and Rogers
Road Landfill?
000489 - 000489
01/04/88
1
Bill Hall, Acting State Historic Preservation Officer
Arkansas Historic Preservation Program
Carl E. Edlund, Chief, Superfund Program Branch, U.S. EPA
Region 6
Correspondence
Re: Pulaski County-Jacksonville, Environmental Review-EPA,
Jacksonville Municipal Landfill Site
000490 - 000496
01/05/88
7
Allyn H. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Tommy Swain, Mayor, City of Jacksonville, AR
Correspondence
Investigation by EPA indicate that the City of Jacksonville
may be a responsible party. EPA has reason to believe that the
City of Jacksonville was owner of Jacksonville & Rogers Road
Landfills
16
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000497 - 000500
01/05/88
4
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Doug Keilman, Hercules Inc
Correspondence
EPA has information to indicate that Hercules, Inc may be a
responsible party. EPA has reason to believe that Hercules
transported hazardous material to Jacksonville Landfill
000501 - 000508
01/19/88
8
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Bill Hall, Acting State Historic Preservation Officer,
Arkansas Historic Preservation Program
Correspondence
Re: Recent letter of 01/04/88, enclosing, site location map,
Statements of Work and copies of photographs depicting
structures on or directly adjacent to the two sites
000509 - 000509
01/25/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Carl R. Stapleton, Ph.D., Environmental Sciences and Resource
Planning, Inc.
Correspondence
Re: FOIA request on Jacksonville Municipal Landfill (Graham Rd
Landfill) and The Rogers Road Municipal Landfill
000510 - 000514
01/27/88
5
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
C.P. Bomar, Jr., Director/Officer Phoenix Capital Enterprises,
Inc., Intercapital Industries, Inc.
104(e) Letter
EPA has information to indicate that Phoenix Capital
Enterprises, Inc, Intercapital Industries, Inc & Inter-Ag are
Potential Responsible Party's (PRP's)
17
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000515 - 000515
02/02/88
1
Bill Hall, Acting State Historic Preservation Officer
Arkansas Historic Preservation Program
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence
Recommendation that a cultural resources survey be conducted
of both landfill locations
000516 - 000517
02/09/88
2
Robert E. E. ^burg, Assistant City Attorney
City of Jacksonville, AR
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
Re: Letter of 01/05/88 designating the City of Jacksonville as
a PRP in the Graham Road and Rogers Road Landfill. Requesting
a 30 day extension
000518 - 000518
02/18/88
1
Douglas Keilman, Attorney
Hercules, Inc.
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Corres-ondence
Reques for extension of time (30 days) by Hercules, Inc. to
respond to question of voluntary undertaking of RI/FS
000519 - 000519
02/24/88
1
Scott Slaughter
Mott & Associates, P.C.
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
Re: Letter to Lee Thalheimer, Receiver of Vertac Corp on
01/09/88 asking Vertac to perform RI/FS at Rogers Road, unable
to perform RI/FS.
18
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000524 - 000524
03/23/88
1
Martha M. McKee, Chief, Superfund Site Assessment Section
U.S. EPA Region 6
Carl Hickam, ATSDR
Memorandum
Closeout of Requests for Assistance
000525 - 000528
04/18/88
4
Roxanne E. Jayne, Counsel, Law Department
Hercules Incorporated
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Response Letter
Re: Letter from Allyn M. Davis dated 01/05/88, requesting that
Hercules voluntarily undertake RI/FS at the Jacksonville
Landfill and Rogers Road Sites
000529 - 000531
04/19/88
3
Curtis Frisbie, Jr., Attorney
Gardere and Wynne
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Correspondence
A response for Phoenix Capital, et. al, as to deny and decline
voluntary participation in RI/FS activities described in the
EPA letters of 01/27/88 and 04/07/88
000532 - 000535
04/22/88
4
Robert Bamburg, Assistant City Attorney
City of Jacksonville
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
A letter describing remedial actions taken by City of
Jacksonville at Jacksonville and Rogers Road Landfill sites
and expressing that such actions are all that are necessary
20
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000520 - 000520
03/01/88
1
Norma Hoffrichter
Arkansas Archeological Survey
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence
RE: Site 3LN149 near the proposed Jacksonville Municipal
Landfill, Lonoke County
000521 - 000521
03/01/88
1
Martin Swanson, RPM
U.S. EPA Region 6
John Vetter, Consulting Archeologist, Region II
Record of Communication
RE: Archeological Site Located on the Jacksonville Municipal
Landfill
000522 - 000522
03/02/88
1
Martin Swanson, RPM
U.S. EPA Region 6
George McClusky, Arkansas Historic Preservation Program
Correspondence
RE: Request for Additional Information on Archeological Site
3LN149
000523 - 000523
03/03/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Mike Bates, ADPC&E
Correspondence
Transmittal letter for 02/02/88 correspondence from the
Historic Preservation Program concerning cultural resources
surveys at Jacksonville and Rogers Road Landfills
19
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000536 - 000536
05/20/88
1
Cathy Buford, State Historic Preservation Officer
Arkansas Historic Preservation Program
Michael A. Klevenz, PEER Consultants
Correspondence
RE: Cultural resources survey is no longer necessary
000537 - 000537
06/08/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Doice Hughes, Hazardous Waste Division, ADPC&E
Correspondence
Transmittal letter for Jacksonville and Rogers Road Landfill
Draft Work Plans
000538 - 000556
06/29/88
19
Martin Swanson, RPM
U.S. EPA Region 6
Bob Lombard, PEER Consultants
Correspondence and Attachment
Comments on the RI/FS Work Plan
000557 - 000825
07/26/88
268
Staff
Peer Consultants, P.C.
EPA Staff, U.S. EPA Region 6
Work Plan
Re: Jacksonville Landfill RI/FS:
Volume 1 - Technical;
Volume 2 -Cost; Appendix A - Health & Safety Plan
21
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000826 - 000972
07/27/88
147
Staff
Peer Consultants, P.C.
EPA Staff, U.S. EPA Region 6
Plan
Sampling & Analysis Plan and Quality Assurance Project Plan
for Jacksonville Landfill RI/FS
000973 - 000973
08/01/88
1
Dennis C. Cossey, Executive Vice President
Innotek Corporation
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence
RE: In Situ Vitrification
000974 - 000975
08/04/88
2
Dennis C. Cossey, Executive Vice President
Innotek Corporation
Steve Gilrein, Chief ALONM/Remedial Section, U.S. EPA Region 6
Correspondence
RE: In Situ Vitrification
000976 - 000976
08/04/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Hank Thompson, Environmental Services Division, U.S. EPA
Region 6
Memorandum
RE: CLP Sample Bottle Repository Authorization
22
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000977 - 000977
08/22/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Ben Chavez, Inter-Agency Agreements (IAG) Coordinator, U.S.
EPA Region 6
Memorandum
RE: Jacksonville and Rogers Road Landfill Interagency
Agreements
000978 - 000978
09/09/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Dave Stockton, CLP/DPO, Houston Branch, U.S. EPA Region 6
Memorandum
RE: CLP detection limits for dioxins and furans
000979 - 000982
09/14/88
4
Martin Swanson, RPM
U.S. EPA Region 6
Seth Low, Office of Regional Counsel, U.S. EPA Region 6
Memorandum and Attachments
RE: Access Agreements for Investigations at the Jacksonville
and Rogers Road Landfill Sites
000983 - 000988
09/19/88
6
David S. Rosa, Site Manager
Resource Applications, Inc.
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence and Attachments
RE: Property ownership search information
23
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
000989 - 000992
10/20/88
k
Martin Swanson, RPM
U.S. EPA Region 6
Myra Perez, CLP Coordinator, U.S. EPA Region 6
Memorandum
RE: Sample Request Forms for the Jacksonville and Rogers Road
Landfill Sites
000993 - 000994
10/24/88
2
Martin Swanson, RPM
U.S. EPA Region 6
Myra Perez, CLP Coordinator, U.S. EPA Region 6
Memorandum
RE: Sample request forms for the Jacksonville and Rogers Road
Landfill Sites
000995 - 000998
10/26/88
4
Myra Perez, CLP Coordinator
U.S. EPA Region 6
Jeb Livingood, U.S. EPA Region 6
Memorandum
RE: Special Anaylitical Services (SAS) request forms -
sampling event 11/07/88 to 12/19/88
000999 - 001000
11/01/88
2
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Superfund Update
Jacksonville and Rogers Road Landfill update
24
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001001 - 001001
11/02/88
1
Bob Bland
Arkansas Alliance
Ellen Greeney, Community Relations, U.S. EPA Region 6
Record of Communication
RE: Tours of Jacksonville and Rogers Road Landfill
001002 - 001013
11/07/88
12
Martin Swanson, RPM
U.S. EPA Region 6
David Rosa, Resource Applications, Inc.
Correspondence and Attachments
RE: Access Agreements
001014 - 001014
11/07/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Doice Hughes, ADPC&E
Correspondence
RE: State involvement in the RI activities
001015 - 001018
11/07/88
4
Myra Perez
U.S. EPA Region 6
Brian Burgess, U.S. EPA Region 6
Report
Weekly sample report 11/07/88 - 11/12/88
25
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001019 - 001019
11/10/88
1
Steve Gilrein, Chief, ALONM Remedial Section
U.S. EPA Region 6
Mike Carter, Contract Officer for CLP Program, U.S. EPA Region
6
Memorandum
RE: Dioxin Analysis for Samples from the Jacksonville and
Rogers Road Landfills
001020 - 001022
12/08/88
3
Jeff Parker
U.S. EPA Region 6
Martin Swanson, RPM, U.S. EPA Region 6
Memorandum
RE: News articles concerning EPA soil testing
001023 - 001025
12/12/88
3
Martin Swanson, RPM
U.S. EPA Region 6
Bob Lombard, PEER Consultants
Correspondence and Attachment
RE: Sampling activities taking place at the Jacksonville and
Rogers Road Landfill sites
001026 - 001027
12/16/88
2
Robert A. Lombard, Program Manager
PEER Consultants
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence
RE: RI/FS studies at the Jacksonville and Rogers Road
Landfill sites
26
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ADMINISTRATIVE RE-CORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001028 - 001028
01/12/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Myra Perez, CLP Coordinator, U.S. EPA Region 6
Memorandum
RE: Mailing of Sample Results from the Jacksonville and
Rogers Road Landfill Sites
001029 - 001029
01/27/89
1
Martin Swanson, RPM
U.S. EPA Region 6
John Wicklund, Enforcement Section, U.S. EPA Region 6
Memorandum
RE: Field Activities at the Jacksonville Landfill site
001030 - 001031
02/24/89
2
Martin Swanson, RPM
U.S. EPA Region 6
Jeff Parks, PEER Consultants
Correspondence and Attachment
RE: Meeting to be held in EPA's office 03/02/89 at 10:00 a.m.
to discuss the status of the Jacksonville and Rogers Road
sites
001032 - 001033
03/01/89
2
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Update
Jacksonville Landfill and Rogers Road Landfill update
27
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001034 - 001034
03/15/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Tom Simmons, Corps of Engineers
Record of Communication
Transmittal for background information
001035 - 001035
03/20/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Dave White, Chief, Automated Data Processing (ADP) Section,
U.S. EPA Region 6
Memorandum
RE: National Communication Center User Accounts for EPA
Contractors
001036 - 001036
03/29/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Tom Simmons, Kansas City Corps of Engineers
Correspondence
Transmittal for Remedial Investigation/Feasibility Study Work
Plans for the Jacksonville and Rogers Road Landfill Sites
001037 - 001037
03/30/89
1
Bob Uassmann
PEER Consultants
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence
Transmittal for slides and prints taken during the first round
of sampling at the Jacksonville and Rogers Road Landfill (no
attachment)
28
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ADMINISTRATIVE RECORD INDLA
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001038 - 001038
04/03/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Doice Hughes, ADPC&E
Transmittal Letter
Dioxin analytical results from the Jacksonville Landfill and
Rogers Road Landfill projects (no attachments)
001039 - 001039
04/04/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Pat Hammack, Emergency Response Branch, U.S. EPA Region 6
Transmittal Memorandum
RE: Analytical results from the Jacksonville Landfill and
Rogers Road Landfill sites
001040 - 001040
04/06/89
1
Robert A. Lombard, Program Manager
PEER Consultants
Helen Newman, Regional Project Officer, U.S. EPA Region 6
Correspondence
Resource Applications, Inc. assigned to Feasibility Study
subcontractor for Jacksonville and Rogers Road Landfill sites
001041 - 001045
04/14/89
5
David S. Rosa, Site Manager
Resource Applications, Inc.
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence and Attachment
Jacksonville and Rogers Road Landfill Sites Remedial
Investigation, Phase II Field Efforts
29
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001046 - 001046
04/18/89
1
Martin Swanson, RPM
U.S. EPA Region 6
John Wicklund, Enforcement Section, U.S. EPA Region 6
Memorandum
RE: Photographs of Materials Removed from the Jacksonville
Landfill
001047 - 001047
04/18/89
1
Mrya Perez
U.S. EPA Region 6
Diane Cutler, U.S. EPA Region 6
Memorandum
RE: Soil testing at the Jacksonville and Rogers Road Landfill
sites
001048 - 001049
05/01/89
2
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
For Your Information
Technical Assistance Grant awarded to Jacksonville People With
Pride Cleanup Coalition
001050 - 001057
05/08/89
8
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Sampling Results
Analysis for Polychlorinated Dioxins and Furans - CLP Analyses
30
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001058 - 001063
05/22/89
6
Mrya Perez
U.S. EPA Region 6
Brian Burgess, U.S. EPA Region 6
Sample Report
Weekly Sample Report 05/15/89 - 05/20/89
001064 - 001065
05/24/89
2
Martin Swanson, RPM
U.S. EPA Region 6
Robert Lombard, PEER Consultants
Correspondence
RE: Problems in shipping to the incorrect laboratory,
improperly labeling samples, and incorrectly filling out CLP
paperwork
001066 - 001066
05/25/89
1
Russell F. Rhoades, Director, Environmental Services Division
U.S. EPA Region 6
Allyn M.Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Memorandum
Follow-up on Rogers Road/Jacksonville Landfill Issues
001067 - 001069
05/26/89
3
Martin Swanson, RPM
U.S. EPA Region 6
James White, Chairman, Bayou Two Water Users Association
Correspondence
RE: Two maps are inclosed which further detail the locations
of the landfills
31
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001070 - 001095
05/31/89
26
Office of Waste Programs Enforcement
U.S. EPA Headquarters
U.S. EPA Region 6 Site Files
Compendium and Users Manual
"Compendium of CERCLA Response Selection Guidance Documents -
Users Manual"
001096 - 001096
06/07/89
1
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Russell F. Rhoades, Director, Environmental Services Division,
U.S. EPA Region 6
Memorandum
RE: Issues concerning the need for increased security and
whether runoff from the sites is a problem
001097 - 001097
06/09/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Doice Hughes, ADPC&E
Correspondence
RE: Request for State's ARARs to be forwarded
001098 - 001100
06/09/89
3
Carl R. Hickam, R.S.
Agency for Toxic Substances and Disease Registry
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence and Attachment
RE: Health consultation
32
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001101 - 001102
07/01/89
2
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Superfund Update
Update on Remedial Investigation activities at the
Jacksonville and Rogers Road Landfill Sites
001103 - 001115
07/06/89
13
Dave Rosa
U.S. EPA Region 6
Martin Swanson, RPM, U.S. EPA Region 6
Memorandum and Attachment
RE: Preliminary Risk Assessment Results for the Jacksonville
and Rogers Road Landfill Sites
001116 - 001116
07/11/89
1
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
EPA Announcement
RE: Open House 07/11/89
001117 - 001117
07/18/89
1
David Gray, On-Scene Coordinator
U.S. EPA Region 6
Martin Swanson, RPM, U.S. EPA Region 6
Memorandum
RE: Sample Data Review; Rogers Road and Jacksonville Landfill
sites
33
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001118 - 001118
07/25/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Duane Reel, City Engineer, City of Jacksonville
Correspondence
RE: Warning signs at the Jacksonville and Rogers Road
Landfill sites
001119 - 001119
08/17/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Tom Simmons, U.S. Army Corps of Engineers
Correspondence
RE: Sampling activities nearly compete - preliminary
evaluations indicate that none of the adjacent residential
areas have been contaminated
001120 - 001120
10/12/89
1
Robert A. Lombard, Jr.
PEER Consultants
Steve Veale, RPM, U.S.
Correspondence
Transmittal letter for Draft Remedial Investigation and Risk
Assessment Reports for the Jacksonville Landfill
, Program Manager
EPA Region 6
001121 - 001121
10/16/89
1
Steve Veale, RPM
U.S. EPA Region 6
Ted Salveter, ADPC&E
Correspondence
Transmittal letter for two copies of the draft Remedial
Investigation and Risk Assessment Reports for the Jacksonville
Landfill Superfund Site
34
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001122 - 001122
10/16/89
1
Steve Veale, RPM
U.S. EPA Region 6
Tom Simmons, USAGE
Correspondence
Transmittal letter for two copies of the draft Remedial
Investigation and Risk Assessment Reports for the Jacksonville
Landfill Superfund Site
001123 - 001123
10/27/89
1
Steve Veale, RPM
U.S. EPA Region 6
Carl Hickman, Senior Regional Consultant ATSDR
Memorandum
RE: Transmittal memo for the Health Assessment for the
Jacksonville Municipal Landfill Site
001124 - 001159
11/30/89
36
Steve Veale, RPM
U.S. EPA Region 6
Robert Lombard, Jr., PEER Consultants
Correspondence and Attachments
EPA' s Comments on the Jacksonville Landfill site draft RI
Report and Risk Assessment dated 10/01/89
001160 - 001161
12/01/89
2
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Site Update
35
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001162 - 001162
12/19/89
1
Steve Veale, RPM
U.S. EPA Region 6
Myra Perez, Regional Sample Control Coordinator, U.S. EPA
Region 6
Memorandum
RE: Missing CLP Data Jacksonville and Rogers Road Landfill
Superfund Sites
001163 - 001164
12/20/89
2
Myra I. Perez, RSCC Primary Coordinator
U.S. EPA Region 6
Diane Cutler, Region 6 Coordinator, U.S. EPA Region 6
Memorandum
RE: Missing Data - Jacksonville & Rogers Road Landfills
001165 - 001165
12/20/89
1
Stephen A. Gilrein, ALONM Remedial Section
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Record of Communication
RE: Planned Removal Action
001166 - 001166
12/28/89
1
Jon Rauscher, Toxicologist
U.S. EPA Region 6
Teresa Hoffman, PEER Consultants
Record of Communication
RE: Risk Assessment assumption for a 6-12 year old child for
Jacksonville Landfill Site
36
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001167 - 001167
01/08/90
1
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for the Risk Assessment Report
001168 - 001168
01/22/90
1
Steve Veale, RPM
U.S. EPA Region 6
Dave Rosa, Resource Applications, Inc.
Correspondence
RE: Removal strategy addressing the potential health threat
posed by dioxin waste and dioxin-contaminated soil at the
Jacksonville and Rogers Road Municipal Landfill sites
Superfund Program, Hazardous Waste
001169 - 001171
01/26/90
3
Doice Hughes, Manager
Division
ADPC&E
Steve Veale, RPM, U.S. EPA Region 6
Correspondence and Attachment
Transmittal of State Environmental Regulations for ARARs
001172 - 001175
01/29/90
4
Don R. Clay, Assistant Administrator
EPA Headquarters
Regional Administrators, Regions I-X
Memorandum
RE: Twenty First Remedy Delegation Report
37
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001176 - 001179
02/06/90
4
David Rosa, Site Manager
Resource Applications, Inc.
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
RE: Post RI Site Conditions
001180 - 001191
02/08/90
12
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Project Manager, PEER Consultants
Correspondence and Attachment
RE: EPAs comments on the Jacksonville Landfill site draft RI
Report dated 01/01/90
001192 - 001192
02/13/90
1
Steve Veale, RPM
U.S. EPA Region 6
Doice Hughes, ADPC&E
Correspondence
RE: Request for State ARARs within 30 days
001193 - 001197
02/16/90
5
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Project Manager, PEER Consultants
Correspondence ant Attachment
EPAs comments on the Jacksonville Landfill site draft Risk
Assessment Report dated 01/01/90
38
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001198 - 001203
03/01/90
6
Robert A. Lombard, Jr. , Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
RE: Latest draft table of contents for the Jacksonville
Landfill Site Feasibility Study.
001204 - 001204
03/23/90
1
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for the draft Feasibility Study report
001205 - 001492
04/01/90
288
Staff
PEER Consultants
U.S. EPA Region 6 Site Files
Report
Risk Assessment for Jacksonville Landfill Site
001493 - 001502
04/11/90
10
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Project Manager, PEER Consultants
Comments
EPA' s comments on the Jacksonville Landfill site draft
Feasibility Study Report dated 03/23/90
39
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001503 - 001513
04/12/90
11
Robert A. Lombard, Jr.
PEER Consultants
Steve Veale, RPM, U.S.
Sampling Plan
Sampling Plan for the Contamination Mapping for the
Jacksonville and Rogers Road Landfill Sites
, Project Manager
EPA Region 6
001514 - 001514
04/12/90
1
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for the Final Draft Risk Assessment Report
001515 - 001515
04/23/90
1
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM. U.S. EPA Region 6
Correspondence
Transmittal for the Final Draft Remedial Investigation Report
001516 - 001516
05/01/90
1
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Fact Sheet Update
Update of remedial action at the site
40
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001517 - 001519
05/09/90
3
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal for page changes, proposed contaminant mapping
001520 - 001520
05/16/90
1
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for RI and Risk Assessment Reports - page
changes in the Risk Assessment and revised Figure 3-6 for the
RI Report
001521 - 001523
05/29/90
3
Sam Becker, Chief, Superfund Enforcement Branch
U.S. EPA Region 6
Edwin K. Gray, Chief, Emergency Response and Consultation
Branch, ATSDR
Correspondence
RE: Proposed remediation for offsite Vertac
001524 - 001919
06/01/90
396
Staff
PEER Consultants
U.S. EPA Region 6 Site Files
Report
Remedial Investigation Report for Jacksonville Landfill Site
41
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
JACKSONVILLE LANDFILL
ARD 980809941
001920 - 001920
06/04/90
1
Steve Veale, RPM
U.S. EPA Region 6
Mike Bates, ADPC&E
Correspondence
Transmittal letter for the EPA' s Proposed Plan for the
Jacksonville Landfill Superfund Site - request for comments
001921 - 001923
06/11/90
3
Edwin Kent Gray, Chief, Emergency Response and Consultation
Branch
Agency for Toxic Substances and Disease Registry
Sam Becker, Chief, Superfund Enforcement Branch, U.S. EPA
Region 6
Correspondence
Request for Agency for Toxic Substances and Disease Registry
to approve the Remedial Plans for the Vertac, Jacksonville
Landfill, and Rogers Road Landfill Superfund Sites
001924 - 001924
06/19/90
1
Barbara J. Goetz, Congressional Liaison
U.S. EPA Region 6
Ken Smith, Special Assistant for Natural and Cultural
Resources, Governor's Office
Correspondence
Scheduled meeting with the Arkansas Congressional delegation
001925 - 001925
06/26/90
1
Robert A. Lombard, Jr., Project Manager
PEER Consultants
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for the Final Remedial Investigation & Risk
Assessment Reports
42
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME: JACKSONVILLE LANDFILL
SITE NUMBER: ARD 980809941
INDEX DATE: 10/02/90
-------
I. CHRONOLOGICAL LISTING
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000001 - 000004
07/30/87
4
Barry L Johnson, Ph.D., Associate Administrator
ATSDR
David Wagoner, Director, Waste Management Division, U.S. EPA
Region 7
Correspondence
Response to request for elaboration on the mathematics
underlying the development of support for the 20 ppb cleanup
level for certain Missouri dioxin sites
000005 - 000006
05/22/90
2
Stephen A., Gilrein, Chief, ALONM Remedial Section
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
Meeting with ADPC&E to discuss the proposed remedy at the
Jacksonville Landfill, Rogers Road Landfill and Vertac Sites
000007 - 000007
06/04/90
1
Steve Veale, RPM
U.S. EPA Region 6
Mike Bates, ADPC&E
Proposed Plan
Request for comments by 06/11/90 on enclosed Proposed Plan for
the Jacksonville Landfill Site so that they may be considered
before the Plan's finalization on 06/15/90
000008 - 000008
06/07/90
1
Bert Cooper
ATSDR
Sam Becker, U.S. EPA Region 6
ROC
RE: Letter to EPA from ATSDR concerning approval of EPA's
proposed remedies for the Vertac, Jacksonville and Rogers Road
Landfill sites
A-l
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ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000009 - 000009
06/19/90
1
Barbara J. Goetz, Congressional Liaison
U.S. EPA Region 6
Dean Smith, Special Assistant for Natural and Cultural
Resources, Governor's Office, State Capitol
Correspondence
Confirmation for the meeting scheduled for 06/26/90 in the
Governor's Conference room to discuss the sites
000010 - 000010
06/26/90
1
Robert A. Lombard, Jr.
PEER Consultants, P.C,
Steve Veale, RPM, U.S.
Transmittal Letter
RE: Transmittal for the Final RI & Risk Assessment Reports
, Program Manager
EPA Region 6
000011 - 000011
06/29/90
1
Robert A. Lombar, Jr.,
PEER Consultants, P.C.
Steve Veale, RPM, U.S.
Transmittal Letter
RE: Transmittal for Final Draft FS Reports for the
Jacksonville and Rogers Road Sites
Program Manager
EPA Region 6
000012 - 000012
07/09/90
1
Robert A. Lombard
PEER Consultants,
Steve Veale, RPM,
Jr.
P.C.
U.S.
, Program Manager
EPA Region 6
Transmittal Letter
RE: Transmittal for Draft Final Feasibility Study Reports for
the Rogers Road and Jacksonville Landfill Sites
A-2
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ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000013 - 000013
07/13/90
1
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Sampling Rationale
Rationale for establishing cleanup goal for 2, 4-Dichlorphenol
000014 - 000137
07/18/90
0124
Patricia Hendrix
Hendrix Reporting Service
U.S. EPA Region 6 Site Files
Public Meeting Transcript
Transcript of public meeting held regarding Jacksonville and
Rogers Road Landfills proposed plan
000138 - 000138
07/20/90
1
Henry Smith
Jacksonville Resident
Steve Veale, RPM, U.S. EPA Region 6
ROC (Phone Conversation)
RE: Landfill operator's personal observations and work
related health problems
000139 - 000140
07/23/90
2
Bill Wright
Operating Engineers Local 38
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Corre spondenc e
Question regarding site contractor's qualifications
A-3
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ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000141 - 000142
07/23/90
2
D.J. Keilman, Director, Environmental Affairs
Hercules, Incorporated
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Correspondence
Request for 60 day extension to the public comment periods for
the FS Studies and Propose Plans of Action for the Vertac
Offsite, Jacksonville Landfill Site and the Rogers Road
Landfill Site
000143 - 000258
07/26/90
116
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Program Manager, PEER Consultants, P.C.
Technical Memorandum
Draft Technical Memorandum for Contaminant Mapping at the
Jacksonville and Rogers Road Landfill Sites
000259 - 000260
07/30/90
2
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
D.J. Keilman, Director, Environmental Affairs, Hercules,
Incorporated
Correspondence
Response to request for 60 day extension to the public comment
period
000261 - 000261
07/31/90
1
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Superfund Update
EPA Extends Comment Period on the Proposed Plan to remedy the
contamination problems at the Site
A-4
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ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000262 - 000262
08/03/90
1
Mike Bates, Chief, Hazardous Waste Division
ADPC6.E
Carl Edlund, U.S. EPA Region 6
Correspondence
"Extension Request of Comment Period"
000263 - 000269
08/09/90
7
Jeffrey Parks, Senior Hydrogeologist
PEER Consultants, Inc.
Steven Veale, RPM, U.S. EPA Region 6
Correspondence and Attachment
RE: Shallow Saturated Soils at the Jacksonville Landfill site
000270 - 000272
08/10/90
3
James R. Weber, M.D.
Resident of Jacksonville
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
Comments regarding the dioxin burn at the site
000273 - 000273
08/13/90
1
Mr. & Mrs. Ronald L. Knight
Residents of Jacksonville, AR
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments on dioxin burn at the site
A-5
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ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000274 - 000274
08/13/90
1
Nicholas P. Kohut
Resident of Jacksonville
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments regarding the dioxin burn
000275 - 000275
08/13/90
1
S. Andres
Resident of Jacksonville
Carl E. Edlund, Chief, Superfund Program, U.S. EPA Region 6
Correspondence
RE: Comments regarding the dioxin burn at the site
000276 - 000276
08/13/90
1
Betty Williamson, Chief, Superfund Management Branch
U.S. EPA Region 6
Ms. Kelly Jones, Resident, Mayflower, AR
Correspondence
RE: Citizen's request to sample her yard for dioxin
000277 - 000278
08/14/90
2
M. Blackman
PEER Consultants, Inc.
U.S. EPA Region 6 Site Files
Sampling Information
"Recalculation of Health Risks Presented by the Jacksonville
and Rogers Road Landfills" (Excluding "Hot Spots")
A-6
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ADDENDUM
JACKSONVILLE LANDFILL
ARD 980809941
000287 - 000436
09/05/90
150
Staff
Chem Risk
Hercules, Inc.
Report
Establishing Acceptable Levels of TCDD in Residential and
Industrial Soils
000437 - 000439
09/06/90
3
Marshall Steinber, Ph.D., Vice President, Health and
Environment
Hercules, Inc.
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence and Attachment
Comments on the EPA Region 6 Porposed Plan of Action
000440 - 000440
09/06/90
1
Kathy Copas
Resident of Cabot
Ellen Greeney, Community Relations coordinator, U.S. EPA
Region 6
Correspondence
RE: Proposed dioxin burn
000441 - 000441
09/06/90
1
Donna C. Hartzell
Resident of Cabot
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Proposed dioxin burn
A-8
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JACKSONVILLE LANDFILL
ARD 980809941
000279 - 000279
08/20/90
1
Wally Tucker, General Manager
KEZQ Radio Station
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments regarding the dioxin burn
000280 - 000283
09/01/90
4
Tim Herrin
Resident of Cabot
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments on the dioxin burn
000284 - 000284
09/04/90
1
Ann Malham
Resident of Cabot
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Proposed dioxin burn
000285 - 000286
09/05/90
2
Nancy Bailey
Resident, Jacksonville, AR
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
Comments regarding the dioxin burn at the site
A-7
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ADMINISTRATIVE RŁCORD INDEX
ADDENDUM
SITE NAME: JACKSONVILLE LANDFILL
SITE NUMBER: ARD 980809941
DOCUMENT NUMBER: 000450 - 000573
DOCUMENT DATE: 09/27/90
NUMBER OF PAGES: 0124
AUTHOR: Robert Layton, Regional Administrator
COMPANY/AGENCY: U.S. EPA Region 6
RECIPIENT: U.S. EPA Region 6 Site Files
DOCUMENT TYPE: Record of Decision
DOCUMENT TITLE: Jacksonville Municiple Landfill Record of Decision
A-10
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ADDENDUM
JACKSONVILLE LANDFILL
ARC 980809941
000442 - 000444
09/07/90
3
Mike Bates, Chief, Hazardous Waste Division
ADPC&E
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
RE: Review comments of the Proposed Plan
000445 - 000445
09/10/90
1
Randall Mathis, Director
ADPC&E
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Correspondence
State priority list requirements
000446 - 000448
09/18/90
0003
Stephen A. Gilrein, Chief, ALNM, Remedial Section
U.S. EPA Region 6
Mike Bates, Solid and Hazardous Waste Division, ADPC&E
Correspondence
RE: Response to EPA's 09/07/90 comments regarding the
proposed plans
000449 - 000449
09/24/90
0001
Stephen A. Gilrein, Chief, ALNM, Remedial Section
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
RE: State concurrence with proposed remedy at Jacksonville
and Rogers Road Landfills
A-9
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