United State*
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-90/056
September 1990
lEPA
Superfund
Record of Decision:
Vertac, AR
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101
PORT DOCUMENTATION i. HEPOBTNOI *
PAGE EPA/ROD/RO6-90/056
fltte and Subtitle
SUPERFUND RECORD OF DECISION - ^
Vertac, AR
'irst Remedial Action
kunon»
>erformlng Organization Name and Addreea
Sponsoring Organization Nam* and Addreaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient'* AcoMlon No.
S. Report Date
09/27/90
6.
». Performing Organization Bept. No.
10. Pro|*ct/T*ak/Work Ural No.
It. Contr*ct
U. Security Claaa (Thi* Report)
None
20." Security Aaae (TNt Page)
None
21. No. of Page*
96
22. Price
ANS-Z3».18)
S»» Initniction* on ffctvnw
OPTIONAL FORM 272 (4-77)
(Formerly NT1&-35)
Department ol Commerce
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EPA/ROD/RO6-90/056
Vertac, AR
First Remedial Action t
*
Abstract (continued)
and ground water monitoring was initiated. Since 1986, EPA has made various improvements
to the onsite area and ordered the site owners to remove some offsite soil and install
fencing in the Rocky Branch floodplain. Currently, the State has ordered that offsite
contamination including, remediation of process wastewater to Rocky Branch
Creek, discharge of pretreated process wastewater to city sewer lines, and stormwater
runoff from the Vertac onsite area. The primary contaminant of concern affecting the
soil, sediment, and sludge is 2,3,7,8-tetra-chlordibenzo-p-dioxin.
The selected remedial action for this site includes removing contaminated sediment from
the active sewage lines between the Vertac plant and the West Wastewater Treatment Plant,
with onsite incineration of sediment, followed by onsite disposal of residual ash;
grouting abandoned sewer lines; removing sludge from the sludge digester at the Old
Sewage Treatment Plant; incinerating the sludge onsite, followed by onsite disposal of
residual ash; capping the sludge drying beds with clean soil and demolishing treatment
units after removing and treating the accumulated water at the Old Sewage Treatment
Plant, followed by onsite discharge of treated water to Rocky Branch Creek; draining and
capping the aeration basin at the West Wastewater Treatment Plant; removing soil and
sediment with TCE levels greater than 1 ug/kg from Rocky Branch Creek and Bayou Metro
floodplains; incinerating the contaminated soil and sediment onsite, followed by onsite
disposal of residual ash; continuing to enforce a commercial fishing ban and a sport
fishing advisory. The estimated present worth cost for this remedial action is
$14,000,000, which includes an annual O&M cost of $57,000 for year one and $46,000 for
years 2-30.
PERFORMANCE STANDARDS OR GOALS: The Agency for Toxic Substances and Disease Registry has
recommended a soil/sediment action level for TCDD of 1 ug/kg for the offsite area, which
will result in the reduction of carcinogenic risk from as high as 10"^ due to the sewer
line sediment to 10 or 10"^, depending on the point of exposure.
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'UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
1445 ROSS AVENUE SJiTE "20C
DALLAS TEXAS ~52CZ-:~33
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION?
VERTAC, INC., Jacksonville, Arkansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Vertac, Inc. in Jacksonville, Arkansas, which was chosen in
accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the
administrative record for this site.
The State of Arkansas concurs with the selected remedy (see
Appendix E).
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 Record of Decision is for the Vertac off-site areas. The off-
site areas include the active and abandoned sewage collection
lines, abandoned Old Sewage Treatment Plant, active West Wastewater
Treatment Plant, and the Rocky Branch Creek and Bayou Meto flood
plain and sediments.
The major components of the selected remedy include:
o Sewage Collection Lines -- Sediments would be
removed from the active sewage collection lines
between the Vertac plant site and the West
Wastewater Treatment Plant and incinerated onsite.
Pipe liners would be installed in the cleaned sewer
lines. The abandoned line would be filled with
grout to reduce the migration of contaminants in the
line.
>
"
o Old Sewage Treatment Plant -- The sludge would be
removed from the sludge digester and incinerated
onsite. Ths sludge drying beds would be capped with
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one foot of clean.soil. Accumulated water in the
treatment units would be removed, treated and
discharged, and the treatment units would be
demolished and capped with one foot of clean soil.
A notice would be placed in the deed recommending
that the Old Sewage Treatment Plant site zoning
remain commercial/industrial and access be
restricted.
o West Wastewater Treatment Plant The aeration
basin would be drained, the dikes demolished, and
the entire basin capped with one foot of clean soil.
A notice would be placed in the deed recommending
that the West Wastewater Treatment Plant site zoning
remain commercial/industrial and access be
restricted.
o Rocky Branch Creek and Bayou Meto Flood Plain In
order to minimize ecological damage to the
floodplain and to the downstream areas, the
floodplain areas that are currently residentially
zoned will be resampled and only those areas with
actual 2,3,7,8 tetrachloro-dibenzo-p-dioxin (2,3,7,8
TCDD) levels greater than 1.0 ppb will be removed
and incinerated onsite.
o Pocky Branch Creek and Bayou Meto -- Monitor fish
in these streams for dioxin and continue ban on
commercial fishing and advisory discouraging sport
fishing as long as fish fillet tissue dioxin levels
are above Food and Drug Administration alert level.
The residuals from wastewater dewatering and treatment (such as
filter spools, spent activated carbon, etc.) would be incinerated
onsite. Onsite refers to areas within the Vertac Plant fence line.
Incinerator ash would be disposed of onsite.
The drummed wastes onsite are currently being incinerated under a
state contract. The State of Arkansas is using the funds from a
trust fund that was established when Vertac went bankrupt for this
incineration project. A Remedial Investigation/Feasibility Study
(RI/FS) for the onsite facility, structures, soils, groundwater,
etc., is in progress. This RI/FS will be conducted under t-
operable units (OU). The RI/FS for OU tl (tank contents, abov-
ground structures, etc.) will be completed by December 1990. Tp>
RI/FS for OU #2 (soils, groundwater, etc.) is scheduled r
completion in March 1992.
STATUTORY DETERMINATIONS
The selected remedy is protective of human heal.th and
environment,complies with Federal and S\ate requirements that
legally applicable or relevant and appropriate to the remedia
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action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technology, 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 not result in hazardous substances
remaining onsite (that is, in the off-site areas addressed by this
ROD) above health-based levels, the five-year review will not apply
to this action.
SEP 2 71°°°
Date Robert E. Laytor/Jr. , P>E.
Regional Administrator
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VERTAC SUPERFUND SITE
RECORD OF CONCURRENCES
The Vertac Superfund Site Record of Decision for the Off-Site
Operable Unit has been reviewed and I concur:
H .S> l.A.tftMA
n.j s. Ramesh,
Remedial Project Manager
Superfund Enforcement - Arkansas/Louisiana Section (6H-EA)
Garret Fondy, jtnief
Supefrfund Enforcement - Arkansas/Louisiana Section (6H-EA)
Sam' Becker, Chief
nt Branch (6H-E)
Waste Enforcement, ALON Section (6C-WA)
R. Alexander
Regional Counsel (6C)
Allyn M. Davis, Director
Hazardous Waste Management Division (6H
Mel McFarlantr/
Waste Enforcement, ALON Section (6C-WA)
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THE DECISION SUMMARY
VERTAC OFF-SITE
JACKSONVILLE, ARKANSAS
SEPTEMBER 1990
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6, DALLAS, TEXAS
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* TABLE JDF CONTENTS
I. SITE NAME, LOCATION, AND DESCRIPTION 1
SITE NAME AND LOCATION 1
GEOGRAPHY 1
I. SITE NAME, LOCATION, AND DESCRIPTION 1
SITE NAME AND LOCATION 1
GEOGRAPHY 1
LAND USE/POPULATION 4
GEOLOGY 6
GROUNDWATER 10
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 13
HISTORY OF THE VERTAC SITE 13
HISTORY OF SITE INVESTIGATIONS 16
PRE-1985 REMEDIAL INVESTIGATION (RI) DATA 16
1985 OFF-SITE REMEDIAL INVESTIGATION 18
1986 ENDANGERMENT ASSESSMENT 19
1986 FEASIBILITY STUDY 19
POST-1985 RI DATA 20
REMOVAL ACTION BY HERCULES 21
1990 SUPPLEMENTAL FEASIBILITY STUDY 21
HISTORY OF ENFORCEMENT ACTIVITIES 22
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 24
IV. SCOPE AND ROLE OF VERTAC OFF-SITE OPERABLE UNIT WITHIN
SITE STRATEGY 25
V. SUMMARY OF SITE CHARACTERISTICS 27
SOURCES OF OFF-SITE CONTAMINATION 27
EXTENT OF CONTAMINATION 28
DATA COMPARISON 38
VI. SUMMARY OF SITE RISKS 47
TARGET CLEANUP AREAS AND ACTION LEVELS 52
VII. DESCRIPTION OF ALTERNATIVES 54
COMMON REMEDIAL ACTIVITIES 78
RCRA ARAR'S 92
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ... 94
IX. THE SELECTED REMEDY 101
X. THE STATUTORY DETERMINATIONS 103
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 106
XII. _ RESPONSIVENESS SUMMARY ^ . I1'
' . 4
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LIST «F FIGURES
Figure
Figure
Figure
Figure
Figure
Figure
Figure
Figure
Plant
Figure 9 -
1
2
3
4
5
6
7
8
Site Location Map
Vertac Off-site Investigation Area
Zoning Map
General Geology
Local Aquifers
Vertac Plant Site
Areas Sampled in Recent Investigations
TCDD Levels Measured in Residential Area South of
Site
Most Recent TCDD Levels Measured in West WWTP
Facilities and Vicinity
Figure 10 - Most Recent TCDD Levels Measured in Old STP and
Vicinity
Figure 11 - Most Recent TCDD Levels Measured in Bayou Meto &
Flood Plain - 0.1 to 0.88 River Miles Below west WWTP
Outfall
Figure 12 - Most Recent TCDD Levels Measured in Bayou Meto &
Flood Plain - 0.88 to 2.40 River Miles Below WWTP
Outfall
Figure 13 - Most Recent TCDD Levels Measured in Bayou Meto &
Flood Plain - 2.40 to 3.23 River Miles Below west WWTP
Outfall
Figure 14 - Most Recent TCDD Levels Measured in Bayou Meto and
Flood Plain - 3.23 to 4.09 River Miles Below West WWTP
Outfall
Figure 15 - 1984 TCDD Levels in Sewage Collection Lines . . .
Figure 16 - Assembled Remedial Action Alternatives
Figure 17 - Alternative 2 Flow Diagram
Figure 18 - Hydraulic Cleaning Procedure for Sewer Line . . .
Figure 19 - Alternative 3 Flow Diagram
Figure 20 - Pipe Liner Installation ,
Figure 21 - Alternative 4 Flow Diagram
Figure 22 - Alternative 5 Flow Diagram
Figure 23 - Alternative 6a and 6b Flow Diagram ,
Figure 24 - Onsite Incineration Process Schematic ,
Figure 25 - Wastewater Treatment Process Schematic . . . . ,
2
3
5
8
11
14
29
30
31
32
33
34
35
36
39
59
60
62
67
68
71
74
76
82
88
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1 -LIST OF TABLES
Table 1 - Generalized Geologic Section 7
Table 2 - Vertac Information sources 17
Table 3 - Sampling Data Comparison for 2,3,7,8-TCDD 41
Table 4 - 1986 Endangerment Assessment (Summary of Site
Problems and Associated Risks) 48
Table 5 - Identification of Potential Remedial Actions ... 55
Table 6 - 1990 FS Estimated Volumes of Material Considered For
Remediation 57
Table 7 - Alternative-Specific Rotary Kiln Incineration
Scenarios 80
Table 8 - Air Contaminants, Regulations, and Standards ... 84
Table 9 - Solids Dewatering Data 86
Table 10 - Volume & Disposition of Wastewater 87
Table 11 - Identification of Potential Location-specific
ARAR's 90
Table 12 - Comparative Analysis of Alternatives 95
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LIST OF^APPENDICES
Appendix A - EPA Memorandum on Sediments, dated January 26 ,
1989
Appendix B - ATSDR Memorandum, dated April 24, 1986
Appendix C - ATSDR Memorandum, dated June 11, 1990
Appendix D - Applicable or Relevant and Appropriate
Requirements (ARAR's)
Appendix E - ADPC&E Concurrence Letters
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THE DECISION SUMMARY
FOR VERTAC, INC. OFF-SITE
OPERABLE UNIT
I. SITE NAME, LOCATION, AND DESCRIPTION
SITE NAME AND LOCATION
The Vertac, Inc. Superfund Site is located in Jacksonville,
Arkansas (Figure 1) and consists of the Vertac Plant Site (or
Onsite) and the Vertac Off-Site area (Figure 2). The Vertac
Off-Site area addressed in this Record of Decision includes:
o Wastewater collection lines between the Vertac Plant site
and wastewater treatment facilities, including 10,350 feet
of active lines and 4,350 feet of the abandoned Rocky Branch
Creek interceptor.
o Old (abandoned) sewage treatment plant (Old STP), including
clarifiers, trickling filters, sludge digester, sludge
drying beds, and surface soils.
o West Wastewater Treatment Plant (West WWTP), including the
three-acre aeration basin (lagoon) and two 22-acre oxidation
ponds.
o Rocky Branch Creek and Bayou Meto flood plain, including the
residentially-zoned area south of the Vertac property line
and north of the fork in Rocky Branch Creek.
o Rocky Branch Creek and Bayou Meto sediments.
GEOGRAPHY
The investigation area occupies approximately 36 square miles
in and to the west, south, and east of the City of
Jacksonville, Arkansas. The surface gradient in the area is
generally to the south-southeast. There are two major
drainageways in the area, Rocky Branch Creek and Bayou Meto.
Minor drainageways are intermittent streams that flow into
Rocky Branch and Bayou Meto in the spring or during periods of
heavy rainfall.
Rocky Branch originates near the northern boundary of
Jacksonville and flows generally south, traversing the Vertac
plant property along the west side. About two miles south or
the Vertac plant it empties into Bayou Meto. Being a youna
stream, Rocky Branch is characterized by low sinuosity, lo~
levels of suspended sediments, and a high bed-load potential.
Sediment load of Rocky Branch is derived from erosion ' :
upgradient and surrounding terrain. Average sediment depth :
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OFF-SITE
TUDY i
AR
(SEE
FIGURE 2-3)
VERT AC SITE MAP
VICINITY MAP
Figure 1
VERTAC
SITE LOCATION
Vertac O
Jacksonville
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VERT AC //
PLANT
JACKSONVILLE
lllllllllllllimilltlllHIHH
OXIDATION
PONDS
MINHMIIIimiHIIIIMIIIIIIIIIIIIIIUIMIIIIIIIUIIIIIIII
IIIMIIIIIIIIIIIIIIIIIIIIIHIIIIIIIIIIIIIMI
IIIIIIIIIIIIIIIIIIIIIIIHIIIIMIIItllllllllllllllllllllll
IIIIIIIIIIIIIIIIIIIMIHIIimillllllllllltllllimtllMIIHIIIIIIMI
BOUNDS OF
OFF-SfTE FS
SCALE IN FEET
VERTAC OFF-SITE
INVESTIGATION
Vertac Off-Sue FS
Jacksonville. Arkanva?
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about 10 inches. Channel "deposits are predominantly silt and
clay.
Generally, both banks are steep, but there are occasional small
point bars at meanders. Lag gravels are found on point bars
and along the upper reaches of the stream. As the stream
approaches Bayou Meto, the channel becomes wider and deeper and
the sediments become finer.
Bayou Meto begins in the Atoka Formation approximately one mile
northwest of Jacksonville. At the Fall Line, Bayou Meto
changes course from south to east, and due to bedrock changes,
becomes broad and sinuous. Also, the gradient decreases,
resulting in sluggish water flow. Abandoned and partly filled
channels with interconnecting oxbow lakes, ponds, and minor
tributaries are common.
Sediments in Bayou Meto are generally fine grained sand, silts,
and clays. Due to the sluggish water flow, gravel deposits are
rare. Organics from vegetation decay also make up a large
portion of the sediment. About 130 miles southeast of
Jacksonville, Bayou Meto empties into the Arkansas River.
Precipitation is well distributed throughout the year, though
spring is the wettest season. August and October are the
driest months. September is not a dry month, however, and high
intensity rainfall is not uncommon. Thunderstorms are very
common, particularly in the summer and fall. An average of 56
days a year have thunderstorms, often accompanied by strong
winds and hail.
Evaporation is an important element in the area meteorological
system. During the summer, as much as 1/3 inch of water per
day evaporates. Abundant sunshine and high temperatures can
result in drought and a significant loss of soil moisture.
Severe droughts occur once every 10 to 15 years.
LAND USE/POPULATION
Land use in the investigation area is a mixture of residential
and agricultural with extensive undeveloped and uninhabited
woodlands in the area near the confluence of Rocky Branch Creek
and Bayou Meto. Land use zoning is shown on Figure 3. The
portion just south of the Vertac plant site, between Marshall
Road and the Missouri-Pacific railroad tracks, south to W. Main
Street, is residential, a combination of single-family homes
and apartments. The section immediately west of the railroad
tracks and north of W. Main Street is undeveloped. The area
between W. Main Street and S. Redmond Road is commercial and
light industrial. Just south of S. Redmond Road is
undeveloped, uninhabited land that includes the Jacksonville
Sewage Treatment Plant, DuPreis ParK, and Lake DuPree. The res*
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YERTAC1 / )
SCALE IN FEET
APPROXIMATE
RESIDENTIAL
INDUSTRIAL
COMMERCIAL
D690"1
Figure
ZONING MAP
Vertac C
Jackson.
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of the investigation area is either farmland, mainly irrigated
rice fields in the area south of Jacksonville and Bayou Meto,
woodlands, or residential. There is substantial suburban
residential development on the strip of higher ground along
Highway 161 and in the area north of Bayou Meto.
The investigation area is partly within and partly adjacent to
the City of Jacksonville. The population growth of
Jacksonville has been as follows: 1950 - 2,474; i960 -
14,488, 1965 - 18,078; 1970 - 19,832; and 1980 - 26,788. The
population in the area of investigation outside Jacksonville
is estimated to be about 3,300.
GEOLOGY
The investigation area lies along the Fall Line, a boundary of
major physiographic provinces in Arkansas. Northeast of the
Fall Line, the Arkansas Valley Province generally consists of
consolidated Paleozoic Era materials with recent alluvium in
stream valleys. Southeast of the Fall Line are unconsolidated
Quaternary sediments of the Mississippi Embayment.
Table 1 presents a generalized geologic section of the
investigation area. Figure 4 illustrates the general geology
of the area. The central area of the City of Jacksonville lies
on Wilcox Formation. Wilcox is made up of weathered brown
shale, gray micaceous shale, gray and gray-green siltstones and
clay, and thick sand beds. The general strike of Wilcox
deposits is northeast-southwest, with a southeasterly dip at
a rate of 20 to 50 feet per mile. Some of the thick sand beds
make excellent aquifers.
Underlying the Wilcox and on the outskirts of the city is the
Midway Formation. Most of the Vertac plant lies on Midway
deposits. Midway is found throughout the Mississippi Embayment
subsurface and outcrops along the Fall Line. In the
Jacksonville area it lies unconformably on Paleozoic bedrock.
In the study area, the Midway Group is undifferentiated, but
in other locations it has been divided into two members. An
upper member is blue-gray to dark gray, fissile, flaky shale,
containing sideritic, concretionary layers. The lower member
consists of soft gray, calcareous, fossiliferous shale with
basal lenses of white limestone. Structurally, the strike of
the Midway is northeast-southwest, with horizontal beds along
the Fall Line. Under the embayment, beds dip slightly
southeast. In the investigation area, the Midway Formation is
not known to provide water for wells. The basal limestone and
sandstone lenses furnish water to domestic wells southwest of
Little Rock, however.
Outside Jacksonville to the south and east, and underlyinc
approximately three-fourths of the. study area are Quaternary
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alluvial and terrace (Jeposi.ts. of the Mississippi Embayment. These
are Pleistocene Age deposits 'that are lithologically similar,
overlain by fine sand, silt, and clay of recent age. The terrace
deposits are on one or more terrace levels. Quaternary recent
alluvium has been divided into two units on the basis of where the
units are found:
o Deposits of local streams or of overbank flows of
major streams (in some areas these include deposits
in abandoned meanders of major streams) ;
o Deposits in major stream channels or in mappable
meanders of major streams (in some areas these
include alluvial deposits in natural levees).
These deposits can be further broken down into two distinct
lithologic units:
o Surface or upper alluvium is predominantly clay or
silt with basal sand and gravel;
o A lower alluvial unit consists of a coarse basal
sand and gravel grading upwards to a fine sand, silt
and clay.
The northwest part of the area of investigation is Atoka
Formation. The Atoka Formation is the most commonly found
surface formation in the Arkansas Valley and is thought to
underlie most Mississippi Embayment sediments. A small portion
of the Vertac plant lies on Atoka Formation. It outcrops along
the Fall Line escarpment, or is often covered with a thin
veneer of Quaternary recent deposits and soil. South of the
Fall Line the Atoka dips steeply to the southeast. North of
the Fall Line the formation is very thick, perhaps 7,000 to
9,000 feet, and thins rapidly to the east. Atoka Formation
consists of gray to black, splintery, finely to coarsely
textured micaceous shale containing lenses of white, tan, or
gray siltstone and fine to medium grained shaly sandstone.
The Lower Atoka member found in the study area may also be
characterized by dark colored chert and an interval of medium
to dark gray flaky shale.
Water is found in fractures in the rock, which become fewer and
less open with depth. For this reason, water wells in the
Atoka are shallow and rarely greater than 50 to 60 feet deep.
Isolated subsurface remnants of undifferentiated Cretaceous
deposits are found near the Fall Line, though they do not
outcrop in the investigation area. Hydrologically they are
unimportant. Water found in them is often salty.
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GROUNDWATER
In the investigation area, all rock formations are capable of
containing groundwater. Figure 5 shows the local aquifers.
In the relatively impermeable Atoka Formation rocks northwest
of the Fall Line, most of the groundwater movement is through
bedding planes and fractures. The unconsolidated rocks
southeast of the Fall Line are more permeable, and so have
greater quantities and higher rates of groundwater flow. In
the area of investigation only the Wilcox and Quaternary
formations can be considered aquifers.
Wilcox Aquifers
The Wilcox Formation provides two distinct aquifers. The Lower
Wilcox aquifer is the most important. This aquifer can yield
500 gpm to 2,000 gpm in some places. It is utilized as a water
source east of Jacksonville, but not in Jacksonville or the
investigation area.
The other Wilcox aquifer is referred to as the Minor Wilcox
aquifer. At this location the Wilcox can be considered a
shallow aquifer. Throughout the rest of the area, however,
where it underlies Quaternary alluvial and terrace deposits,
it is considered a deep aquifer. Wilcox aquifers in the
investigation area consist of thin sand beds interbedded with
clay. The yield and chemical quality of water from Wilcox
aquifers differs widely due to the discontinuous nature of the
sand matrix.
Quaternary Aquifers
Quaternary aquifers are also found in alluvial and terrace
deposits in the area of investigation. These are shallow
aquifers and recharge is primarily by infiltration from
precipitation. Substantial seasonal water level variations
occur because the majority of wells in these aquifers are used
for irrigation. During the summer growing season, water levels
can drop 10 to 15 feet because of over-pumping. These aquifers
are part of the Mississippi River Valley alluvial aquifer which
extends 380 miles from north to south and covers most of the
west side of the Mississippi Embayment.
Formerly, the Jacksonville municipal water source was from
Quaternary alluvial aquifers. Currently, Jacksonville gets its
water from sources outside the investigation area.
There are three categories of Quaternary alluvial aquifers in
the investigation area: surface and lower alluvial aquifers,
based on surface and lower lithologic units, and an alluvial
aquifer in stream valleys overlying Atoka deposits. Except for
" - " «
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low pumpage domestic wells', *he surface aquifer is rarely used
due to its low yield of less than 50 gpm. The lower alluvial
aquifer constitutes the most important aquifer in the area,
with yields similar to Wilcox, ranging from 500 gpm to 2,000
gpm. The alluvial aquifer in stream valleys overlying Atoka
deposits exists in the northwest part of the area of
investigation, but is not known to be used as a water source.
Major Quaternary water-bearing zones are generally confined,
being overlain by sediments with lower permeability. Aquifer
characteristics depend on the size and sorting of the host
lithologic unit. Because these vary considerably from place
to place, a quantitative statement on hydraulic characteristics
cannot be made.
Quaternary alluvial water in the investigation area is
typically of the calcium bicarbonate type. The calcium content
ranges from 4 to 85 ppm; magnesium 1 to 21 ppm; sodium 3.4 to
20 ppm; and bicarbonate 15 to 282 ppm. Analysis of water from
wells indicates that the water north of Bayou Meto is less hard
and contains less calcium and dissolved solids than typical
alluvial aquifer water. Most alluvial aquifers throughout the
area have a high iron content, ranging from 0.12 to 6.8 ppm.
Other units in the area are the Atoka and Midway formations,
and undifferentiated Cretaceour, deposits. These do not yield
sufficient water for domestic use, however.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
HISTORY OF THE VERTAC SITE
The Vertac plant was first used in the 1930's as the Arkansas
Ordnance Plant, a federal government munitions factory (see
Figure 6 for the plant's location.). In 1948, the Reasor-
Hill Company purchased the site and built a plant to formulate
insecticides and herbicides. At first, Reasor-Hill
manufactured insecticides such as DDT, aldrin, dieldrin, and
toxaphene. During the 1950's, Reasor-Hill began production of
the herbicides 2,4-dichlorophenoxyacetic acid (2,4-D); 2,4,5-
trichlorophenoxypropionic acid (2,4,5-TP or Silvex); and 2,4,5-
trichloropehenoxyacetic acid (2,4,5-T). The dioxin compound
2,3,7,8-tetra-chlorodibenzo-p-dioxin (TCDD) is an impurity
formed during the production of 2,4,5-T and is the major
contaminant of concern at the site. During Reasor-Hill's
operations, untreated process wastewater was discharged from
the west end of the plant and channeled into Rocky Branch
Creek. Rocky Branch Creek flows into Bayou Meto a few miles
south of the site.
Jacksonville residents complained about odors from the Reasor-
Hill discharge and about the quality of fish caught in the
Bayou. In 1961, the City of Jacksonville's sewage treatment
plant (referred to as the Old STP) was upgraded by adding a
sludge digester, sludge-drying beds, and two 22-acre oxidation
ponds. At that time, the city agreed to accept and treat
wastes from the pesticide plant, and Reasor-Hill began
discharging some of its process wastewater into the City of
Jacksonville's sewage treatment plant.
In 1961, the Hercules Powder Company (now Hercules, Inc.)
purchased the plant and continued to manufacture the same
products. When Hercules purchased the site, drums containing
organic wastes that had been stacked by Reasor-Hill southwest
of the plant production area were buried there. This burial
area became known as the Reasor-Hill landfill (see Figure 6 for
location).
In 1964, Hercules built a pretreatment facility consisting of
equalization basins and neutralization systems. After
complaints continued regarding water quality downstream of the
Jacksonville sewage treatment plant, it was determined that the
existing plant was overloaded. In 1969, Hercules and the city
constructed a three-acre aerated lagoon upstream of the
oxidation ponds, using a federal grant. After that time, all
process wastewater from the plant was discharged into the
Jacksonville wastewater treatment facilities.
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05
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In 1964, Hercules began to treat its product using a solvent
process. The process removed most of the dioxin from the
product, resulting in contaminated liquid and solid waste
residues. These contaminated still bottoms were pumped into
drums and allowed to solidify. The drums were then buried in
an area north of the plant production area. This area is
commonly known as the Hercules-Transvaal landfill area (see
Figure 6).
During 1967-68, Hercules produced "Agent Orange," a mixture of
2,4-D and 2,4,5-T, for the Department of Defense. Agent Orange
was used as a defoliant in the jungles of Vietnam. A finding
of possible teratogenic effects of Agent Orange by the National
Cancer Institute resulted in a ban on the use of Agent Orange
in Vietnam. Soon after the ban became effective, many other
uses of 2,4,5-T were discontinued. Hercules then ceased
operations at the Jacksonville plant.
From 1971-76, Hercules leased the plant to the Transvaal
Corporation. Transvaal resumed production of 2,4-D and
intermittently produced 2,4,5-T. In 1976, Transvaal purchased
the property from Hercules. Transvaal buried toluene still
bottom wastes in the Hercules-Transvaal landfill. However, in
1974 Transvaal discontinued burying these wastes and began
storing drums of the waste above ground.
In 1978, Transvaal was reorganized through bankruptcy
proceedings and the reorganized company, Vertac Chemical
Corporation, operated the plant until 1987. When EPA banned
most uses of 2,4,5-T in 1979, Vertac halted 2,4,5-T production.
However, Vertac continued to produce 2,4-D, using the equipment
previously used to formulate 2,4,5-T. Therefore, the 2,4-D
waste may have been cross-contaminated with dioxin. In 1982,
Vertac began recycling 2,4-D waste liquids and also reportedly
eliminated the potential for cross-contamination by using new
equipment. Vertac continued to accumulate drums of 2,4,5-T
waste until 1979 and 2,4-D waste until 1987, when pesticide
production at the site was discontinued.
In 1979, the Arkansas Department of Pollution Control and
Ecology (ADPC&E) issued an order that required Vertac, Inc. to
improve their hazardous waste practices, and in 1980 the U.S.
Environmental Protection Agency (EPA) and ADPC&E jointly filed
suit in federal district court against Vertac, Inc. and
Hercules, Inc. A Consent Decree entered into by EPA, ADPC&E,
Vertac, and Hercules in January 1982 required an independen*
consultant to assess the conditions of onsite wastes and t~.
develop a proposed disposal method for the wastes. Tl>-
proposal, called the "Vertac Remedy," was deemed by EPA to \ -
unsatisfactory and EPA returjied to court in early 1984 for
. *
15
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resolution. The covfrt decided^ in favor of the proposed remedy,
which'was implemented in the*summer of 1984 and completed in
July 1986.
As part of the remedy, the Vertac plant cooling water pond and
the equalization basin were closed and sediments from these
units were removed and placed in a sediment vault (shown on
Figure 6). The burial area was capped and a French drain and
leachate collection system were installed around the burial
areas. Groundwater monitoring wells were also installed and
a groundwater monitoring program was initiated. The remedy did
not address: 1) 28,500 drums of still bottom wastes from the
manufacturing process stored onsite or 2) contaminated process
equipment, surface soils, and buildings.
Vertac abandoned the plant in February 1987. However,
Hercules, Inc. remained onsite to operate and maintain the
leachate collection system and treatment facilities. Since
1987, EPA and its contractors have made improvements to the
site by repairing leaking tanks, constructing concrete storage
buildings for drums, improving existing storage areas for
drums, and overpacking leaking drums.
In 1989, ADPC&E signed a contract to have the 28,500 barrels
of waste incinerated onsite. The State used funds from a trust
fund that was established through litigation. Incineration of
these wastes is scheduled to begin in Fall 1990.
HISTORY OF SITE INVESTIGATIONS
A great deal of data have been collected since the Vertac Plant
was identified as a potentially hazardous site in 1978. These
data have formed the basis for several reports covering onsite
and off-site contamination, environmental conditions,
groundwater, and geology. The major documents are listed in
Table 2.
PRE-1985 REMEDIAL INVESTIGATION (RI) DATA
ADPC&E and EPA conducted preliminary environmental sampling for
pesticide contamination in the Vertac off-site investigation
area before the 1985 RI. This sampling occurred between June
1975 and May 1983. ADPC&E compiled the sampling results in
their 1983 report. The pre-RI sampling was not conducted under
rigorous field and laboratory quality control practices, and
accurate records concerning sampling methods and locations are
not available for all cases. Consequently, these data are of
questionable quality. Subsequent data, described in the
following discussions, are much more extensive and were
collected, handled, and analyzed under strict data quality
procedures. The data from more recent site investigations are
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* Table
Vertac Information So
Source
Aerial reconnaissance of Vertac. Inc., Jacksonville.
Arkansas; U.S. EPA. Las Vegas, Nevada,
November-May 1979.
Final Report for Environmental Assessment Study,
Venae Chemical Corp. Site, Jacksonville, Arkansas.
Developers International Service Corp. (DISC),
Memphis, Tennessee, October 1982.
Supplemental Report for Environmental Assessment
Study, Venae Chemical Corp. Site, Jacksonville,
Arkansas. DISC, December 1982.
Technical Repon for Rocky Branch, Bayou Meto, and
Lake DuPree. Environmental lexicological
Consultants, March 1983.
Summary of Technical Data, Jacksonville, Arkansas.
Arkansas Department of Pollution Control and
Ecology, no date (mid- 1983).
Offsue Remedial Investigation Final Repon.
Prepared by CH2M HILL and Ecology and
Environment for U.S. EPA Region 6, December 1,
1985.
Venae Off-site Endangerment Assessment, Final
Repon. Prepared by CH2M HILL for U.S. EPA
Region 6. June 1986.
Venae Off-site Feasibility Study, Final Repon.
Prepared by CH2M HILL for U.S. EPA Region 6,
June 1986.
Report on Fine Gnd Sampling Plan (For TCDD and
2.3,7,8-TCDD). Prepared by IT Corporation for
Hercules Inc., October 1988.
Venae Chemical Plant Draft Repon. Prepared by
Jacobs Engineering Group Inc. for U.S. EPA
Region 6, September 28. 1988.
TES IV Work Assignment #649-Venac Soil
Sampling. Prepared by Jacobs Engineering Group
for U.S. EPA Region VI, June 1. 1989
Hercules/Venae Off-site Study Final Repon, May
1990
2
urces
Description
Historical photographs used to document changes
at Vertac site and locations of spills and
contamination.
Developed to satisfy the requirements of 1982
Consent Decree; contains assessment of onsite
conditions.
DISC response to EPA questions that followed
review of previous DISC report. Includes results
of recent testing and outlines proposed remedial
measures.
Summarizes off-site data collected since 1979 for
the three water bodies. (Final report with recent
sampling data published in late 1983.)
Compiles data collected in conjunction with the
Vertac Plant. Includes virtually all sampling data
and excerpts of reports listed above.
Presents results of environmental sampling, plus
special studies including delineating sonar survey.
water use inventory, sewer lamping, and aquatic
biota survey. Also, characterizes the off-site area
and site history.
Evaluates potential for contaminant migration,
exposure pathways and scenarios, and risks
associated with off-site contamination.
Based on the 1985 RI. Includes an evaluation of
alternatives for remediating potential hazards
posed by off-site contamination. Identifies seven
potential remedial alternatives.
Summarizes off-site sampling results from 1988
sampling effort sponsored by Hercules Inc.
Includes results of analysis of duplicate samples
taken by IT Corporation.
Includes results of fine-grid and dust sampling.
Includes results of 1987 Hercules-sponsored
sampling.
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assumed to best* represent the nature and extent of
contain inat ion.
1985 OFF-SITE REMEDIAL INVESTIGATION
The RI for the Vertac off-site area was performed between the
fall of 1983 and spring of 1985. The purpose was to determine
if TCDD migrated beyond the plant site and, if it had, to
identify contaminated areas.
Previous studies suggested that contamination in the
investigation area would be concentrated in the sewage
collection and treatment system and along the nearby
watercourses (Rocky Branch Creek and Bayou Meto). TCDD is
known to have an extremely low water solubility and a strong
tendency to bind to soils or sediments. Therefore, the RI
field work consisted of soil and sediment sampling and
analysis, as well as a series of special investigations,
including:
o A flood plain delineation study to estimate the
amount of soil that may have been contaminated by
flooding
o A sewer lamping study to estimate the amount of
sediment in the sewage collection system
o A sonar survey to estimate the amount of sediment
in the impoundments, including aeration basin and
oxidation ponds
o An aquatic biota survey
The soil and sediment sampling results are tabulated in Volume
II of the 1985 off-site RI report (EPA, December 1985). A
total of 324 soil and sediment grab samples were collected
during the RI and tested for TCDD. Of the 324 samples:
o 74 samples were taken in December 1983; 40 samples
contained measurable quantities of TCDD
o 21 samples were taken in June 1984; one contained
a measurable quantity of TCDD
o 225 samples were taken in August 1984; 79 contained
measurable quantities of TCDD
TCDD method detection limits for these analyses generally were
within the range of 0.01 to 1.0 ppb.
Groundwater sampling and analysis were not included in tnp>
study plan. EPA's decision fcto exclude groundwater samplina
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was based on thet low. water solubility of TCDD and on the
resul-ts of a limited testing of wells in the early stages of
the RI, which showed no measurable TCDD in groundwater.
Air was considered a potential pathway of contaminant
migration. Air monitoring off-site was not pursued because the
area is heavily vegetated, minimizing airborne transport of
soil and sediment.
Previous studies indicated the presence of contaminants other
than TCDD in the investigation area, such as 2,4-D, 2,4,5-T,
2,4,5-TP, chlorinated benzenes, and chlorinated phenols. The
RI concentrated on TCDD because it was determined to be the
most hazardous contaminant in the area, and remediation for
TCDD would likely remediate other contamination problems.
Limited exploratory testing was performed for the other
compounds. Elevated levels of chlorobenzenes, chlorophenols ,
and other contaminants were found principally in the sewage
system, to a much lesser degree at surface locations near the
Vertac Plant, and sporadically at locations distant from the
plant in Rocky Branch Creek. Findings on these other
contaminants appear consistent with the known tendency of these
contaminants to degrade more readily than TCDD. In the areas
where contaminants other than TCDD were found, TCDD was found
at concentrations of greater concern than concentrations of the
other contaminants. This supported the assumption that
remediation for TCDD will also remediate other compounds.
1986 ENDANGERMENT ASSESSMENT
Based on the Remedial Investigation results, an endangerment
assessment (EA) was performed in 1986 to evaluate the potential
health and environmental effects if no remedial action is
taken. Potential exposure pathways to contaminants include
direct skin contact or ingestion of sediments or soils
originating from the sewer system, sewage treatment plants,
Rocky Branch, Bayou Meto, or the flood plains; inhalation of
volatilized organics, if any, from contaminants in the sewer
system, creek, or flood plain sediments or soils; ingestion of
fish and other aquatic organisms from Rocky Branch or Bayou
Meto; and ingestion of agricultural products that have been
grown in contaminated soils.
1986 FEASIBILITY STUDY
The initial Feasibility Study was completed in June 1986.
Several alternatives, including no action, onsite and offsite
disposal, containment in place, and onsite or offsite
incineration, were developed. A public meeting was held ir
Jacksonville on July 15, 1986, to explain the results of th-
Feasibility Study, answer questions, and accept comments.
However, in October 1986, ^Congress passed the Superfur.
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Amendments and Reauthori'zatio*i Act (SARA) , which amended CERCLA
and set new requirements for the Superfund RI/FS process.
Because of this new development, the selection of a remedy was
postponed.
POST-1985 RI DATA
Several sampling efforts have been conducted in the Vertac off-
site area since 1985. A brief description of these sampling
events is given below.
1. 1987 Hercules Grab Sampling. Samples were collected
from many of the locations sampled in the 1985 RI
studies. This investigation included:
o TCDD analysis of fish tissue from Lake DuPree
o TCDD and partial priority pollutant analysis
of sediment samples from the West WWTP aeration
basin and oxidation ponds, and TCDD analysis
from areas in and around the Old STP and West
WWTP
o TCDD analysis of soils and sediments from Rocky
Branch Creek, Bayou Meto, and Lake DuPree, and
land adjacent to Rocky Branch Creek and Bayou
Meto
2. 1988 Hercules Fine-Grid Sampling. Soil and sediment
samples were collected for TCDD analysis from the Rocky
Branch Creek banks, the residentially-zoned flood plain
immediately west of the east leg and immediately east of
the west leg of Rocky Branch Creek, and the West WWTP
facilities. Fish samples from Lake Dupree were also
analyzed for TCDD. The results of this sampling effort
are compiled in the Report on Fine Grid Sampling Plan
(For TCDD and 2,3,7,8-TCDD), Volume I (Hercules Inc.,
October 1988) .
3. 1988 EPA Fine-Grid Sampling. Soil samples were collected
from the undeveloped residentially-zoned flood plain
immediately west of the west leg of Rocky Branch Creek
and south of the Vertac property. The samples were
analyzed for TCDD.
4. 1989 EPA Fine-Grid Sampling. The extent of
contamination was delineated by sampling areas
surrounding the soil grids found to contain TCDD levels
greater than 5.0 ppb in the 1988 EPA sampling effort.
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5. Ongoing Ignited States Fish and Wildlife Services
(USFWS) Wood Duck "Studies. The effect of contamination
on wood duck reproduction is currently being studied.
REMOVAL ACTION BY HERCULES
In 1988, EPA signed an Administrative Order on Consent (AOC)
with Hercules. The AOC required Hercules to remove soils from
residential yards, South of Vertac plant, that were
contaminated above 1 ppb TCDD. It also required Hercules to
perform some onsite excavation and drainage control. Areas
that were excavated are shown on Figure 8. Excavated soils
were bagged and placed in a storage facility on the plant site.
These bagged soils are being addressed as part of the onsite
RI/FS.
1990 SUPPLEMENTAL FEASIBILITY STUDY
Several developments since the June 1986 report created a need
to revise the 1986 Feasibility Study report. These
developments included:
o Several major sampling efforts were conducted by Hercules,
Inc. (one of the potentially responsible parties, or PRPs)
and EPA that further defined the extent of offsite
contamination by TCDD.
o The Agency for Toxic Substances and Disease Registry (ATSDR)
and EPA have delineated TCDD remediation levels that are
site-specific and area-specific.
o Remedial technologies that are potentially applicable to
TCDD contamination, such as incineration, were further
developed and evaluated.
o In October 1986, Congress passed the Superfund Amendments
and Reauthorization Act (SARA), which amended CERCLA and set
new requirements for the Superfund RI/FS process. Chief
among these new requirements is the preference for remedial
actions that (1) permanently reduce volume, toxicity, or
mobility of hazardous substances and (2) meet Federal and
State Requirements.
o Some remedial actions were taken in offsite areas at Vertac
since 1986. Contractors for Hercules, Inc. removed some
contaminated soils from developed residential areas in the
Rocky Branch flood plain. Access to certain contaminated
areas in the Rocky Branch flood plain was also restricted
by fencing.
As a result of these developments, EPA revised the Feasibility
Report in June 1990.
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*
HISTORY OF ENFORCEMENT ACTIVITIES
A Potentially Responsible Party (PRP) search was not conducted
since the Agency knew the identities of former owners,
operators, and some generators of waste at the Vertac site, and
since litigation was already going on prior to CERCLA
activities. However, CERCLA Section 104(e) information
request letters were mailed in March 1990 and later to several
companies, some of which had "tolling agreements" with the
Vertac Chemical Corporation and/or Hercules, Inc.
The following is a chronology of enforcement activity at the
Vertac site:
1. Litigation was filed in 1980 under RCRA Section 7003 and
other statutes by the United States and the State of
Arkansas against Vertac Chemical Corp. and Hercules, Inc.
(the "Parties"). In January 1982, EPA and the State of
Arkansas entered into a Consent Decree with Vertac Chemical
Corp. and Hercules, Inc. in the litigation for developing
a remedial plan for certain onsite and off-site areas.
After EPA invoked dispute resolution and a hearing on the
remedy, the court ordered the implementation of "Vertac
Remedy" in July 1984. (See Site History for a discussion
of the action taken.)
2. On July 15, 1986, pursuant to an agreement between the
parties and entered by the court, Vertac established a Trust
Fund, as part of a bankruptcy agreement. Placed in this
Fund were $6,700,000 and a $4,000,000 letter of credit to
be used to remediate portions of the plant. Both EPA and
the State of Arkansas have access to this fund, and it is
being used to incinerate the 28,500 drums.
3. In August 1986, EPA issued a Unilateral Administrative Order
to all PRP's to require posting of warning signs and the
fencing of portions of the West Wastewater Treatment Plant
and certain areas of Rocky Branch Creek. This work was
performed by Hercules.
4. In January 1987 EPA issued a notice letter to Vertac
Chemical Corp. that required Vertac Chemical Corp. to
continue operation and maintenance of leachate collection
and treatment system.
5. In June 1988 EPA signed an Administrative Order on Consent
with Hercules to allow Hercules to implement fine grid
sampling for off-site areas.
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6. In September 1^88 EPA- signed an Administrative .Order on
Consent with Hercules that required Hercules to remove
contaminated soils from residential yards.
7. In July 1989 EPA signed an Administrative Order on Consent
with Hercules that required Hercules to conduct the onsite
RI/FS.
8. In March 1990 EPA sent CERCLA Section 104(e) information
request letters to several companies which had been involved
in business deals with Vertac Chemical Corp. and Hercules,
Inc., including "tolling agreements".
9. In July 1990 EPA sent General Notice letters to the PRP's
regarding the proposed off-site remedial plan and other site
actions.
10. A consent decree between the U.S. government and companies
created from Vertac Chemical Corp. is currently pending
before the court. These companies would contribute
approximately $1,800,000 to the Trust Fund, plus a
percentage of future profits over twelve years, in return
for a release from liability.
11. In September 1990, Hercules, Inc. filed a motion in Federal
court to stop EPA from selecting a remedy for the off-site
areas. Hercules' position is that the entire Vertac
facility and off-site areas are under the jurisdiction of
the court, according to the 1982 consent decree. The U.S.
government disagrees with this position, and the motion is
still pending.
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III. . HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Vertac site was completed
in 1983. This plan lists contacts and interested parties
throughout government and the local community. It also
establishes communication pathways to ensure timely
dissemination of pertinent information. Numerous fact sheets,
open houses and workshops have been conducted on the Vertac
site. A satellite community relations office was established
in Jacksonville in July 1990 to provide easy access to
documents and information. The Supplemental Feasibility Study
(SFS) and the Proposed Plan were released to the public in July
1990. These documents were made available at five local
repositories. The Administrative Record is maintained at the
City Hall. A public comment period was held from July 9 to
September 7, 1990. In addition, an open house was held on July
12 and a public meeting on July 17 to present the results of
the SFS and the proposed plan. 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 section of this Record of Decision.
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IV. SCOPE AND R*OLE OF VESffAC OFF-SITE OPERABLE UNIT WITHIN
SITE STRATEGY
Since the Vertac Superfund Site is a very large and complex
site, the site is divided intothe following operable units:
1. "Vertac Remedy". As required by the 1984 Consent
Decree, the Vertac plant cooling water pond and the
equalization basin were closed and sediments from these
units were removed and placed in a sediment vault. The
burial areas were capped and a French drain and
leachate collection system were installed around the
burial areas. Groundwater monitoring wells were also
installed and a groundwater monitoring program was
initiated.
2. Vertac Off-Site. This Record of Decision addresses the
clean-up of the off-site areas that were contaminated
as a result of untreated and partially treated surface
and underground (city sewer) discharges of waste water
from the plant.
3. Drummed Wastes Incineration. When Vertac abandoned the
plant in 1987, approximately 28,500 drums of 2,4-D and
2,4,5-T wastes (mostly still bottoms) were left onsite.
In 1989, ADPC&E signed a contract to have these drummed
wastes incinerated onsite. EPA will provide
incineration support, and has performed an engineering
analysis/cost evaluation for incineration support.
Incineration of these wastes is scheduled to begin in
Fall 1990.
4. Onsite Operable Unit tl. In July 1989, Hercules, Inc.
(a Potentially Responsible Party or PRP) signed an
Administrative Order on Consent (AOC) with EPA to
conduct a Remedial Investigation/Feasibility Study
(RI/FS) for all above-ground items, such as buildings,
process equipment, tanks and their contents, shredded
trash and pallets, bagged soils (removed from dioxin
contaminated residential yards). This RI/FS is
scheduled for completion in late 1990.
5. Onsite Operable Unit #2. This operable unit addresses
surface and subsurface soils, underground storage tanks
and piping and groundwater. Hercules is conducting
an RI/FS for this operable unit under the terms of the
above-mentioned AOC and this RI/FS is scheduled for
completion by March 1992.
The Vertac Off-Site Operable Unit RI/FS and this Record c:
Decision address the areas described below. Figure 7 shows t).-
*25 "' *
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study area. No further, remedial actions are expected to be
necessary for off-site areas ^following the implementation of
the selected remedy.
o Wastewater Collection Lines. Included are
approximately 10,350 linear feet of the active
Rocky Branch Creek interceptor collection system
and approximately 4,350 linear feet of the
abandoned Rocky Branch Creek interceptor
collection system.
o Old (Abandoned) Sewage Treatment Plant. Included
are treatment units (clarifiers, trickling
filters, sludge digester, sludge drying beds) and
surrounding plant surficial soils.
o West Wastewater Treatment Plant. Included are a
three-acre aeration basin and two 22-acre
oxidation ponds.
o Rocky Branch Creek and Bayou Meto Flood Plain.
o Rocky Branch Creek and Bayou Meto Stream
Sediments.
The following are not included in the scope of this study:
o Groundwater. Potential groundwater contamination
was not included in the 1986 Off-site FS or the
1990 supplemental FS. Potential groundwater
contamination is being addressed as part of the
Onsite RI/FS. Groundwater contamination found to
have migrated beyond the Vertac plant site will
be investigated as part of the onsite
investigation.
o Non-TCDD Contaminants. Previous studies indicated
contaminants other than TCDD exist in the
investigation areas, such as 2,4-D, 2,4,5-T,
2,4,5-TP, chlorinated benzenes, and chlorinated
phenols. The 1985 RI and recent site
investigations have concentrated on TCDD because
it is considered the most hazardous contaminant
in the area, and remediation for TCDD is presumed
to remediate most other contamination problems.
o Bagged Onsite Soils. Soils removed from
residential properties and excavated onsite soils
currently stored in bags on the plant site are not
within the scope of the Off-site FS. These bagged
soils will be addressed during the Onsite RI/FS.
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V. - SUMMARY OF SITE' CHARACTERISTICS
The Vertac off-site investigation area is shown in Figure 2.
Surface runoff from the Vertac Plant site flows into Rocky
Branch Creek, which flows into Bayou Meto, a larger watercourse
that flows into the Arkansas River. Currently, Hercules
operates an onsite system that collects and treats initial site
runoff prior to discharge to Rocky Branch Creek. The treatment
system consists of pH reduction, filtration, carbon adsorption,
and pH neutralization. This system treats collected liquids
from the French drain system as well as surface runoff to less
than 1 ppb TCDD. Four sumps, with a total capacity of over
6,000 gallons, are used to collect initial site runoff for
treatment.
The pesticide plant and adjacent residential, commercial, and
industrial areas are served by a sanitary and storm sewerage
system. Wastewater from these areas in the city and treated
effluent from Vertac French drains are now conveyed directly
to the aeration basin and treatment occurs in the aeration
basin and oxidation ponds, collectively referred to as the West
Wastewater Treatment Plant. Adjacent to the West plant is the
abandoned or "Old" Sewage Treatment Plant that consists of
sludge drying beds, two primary clarifiers, two trickling
filters, two secondary clarifiers, and a sludge digester.
A new EPA-funded wastewater treatment plant has been
constructed for the City of Jacksonville (see Figure 2). This
facility treats Jacksonville municipal wastewater and is
intended to treat sewage currently conveyed to the West WWTP.
However, the federal construction grant for the new plant
stipulates that the new plant not receive TCDD-contaminated
waste. Therefore, before the collection lines serving
residences south of the Vertac Plant site can be connected to
the new wastewater treatment plant, the lines must be cleaned
or replaced.
SOURCES OF OFF-SITE CONTAMINATION
Off-site contamination is the result of 1) direct discharges
of process wastewater to Rocky Branch Creek; 2) discharge of
pretreated process wastewater to the city sewer; and 3)
stormwater runoff from Vertac plant site.
Release of TCDD-contaminants to off-site areas probably dates
back to 1948, when pesticide production began, and became more
substantial during the production of Agent Orange in the
1960's.
The Arkansas Ordnance Plant sewer lines were constructed i:.
1941 and were in operation when Reasor-Hill purchased t!.-
"' «
27
-------
plant. During the* Rea.sor-Hi.ll period, it is likely that
pesticide wastes were continuously discharged into the" sewer
lines and into Rocky Branch Creek. Stormwater runoff and
flooding probably contributed to the migration of contaminants
from the Vertac Plant site to off-site areas.
It is likely that, prior to 1961, operational problems in the
Old STP were caused by discharges from the pesticide plant,
which did not have arrangements to treat pesticide wastes. A
process waste outfall line was constructed in 1961 to convey
plant wastes to the Rocky Branch Creek interceptor, the main
line of the area's sewage collection system. Pretreatment of
the process waste consisted only of pH neutralization and
stabilization. However, other sewer lines existed between the
Arkansas Ordnance Plant and the Rocky Branch Creek interceptor,
and some plant wastes may have entered the sewer system through
these lines before and after the construction of the process
waste outfall.
Before arrangements were made to treat pesticide plant waste,
commercial fishermen and residents along Bayou Meto frequently
complained of odors in the Bayou, odd odors and tastes in fish,
and occasional fish kills. After the Old STP began accepting
the plant waste for treatment, the complaints continued but
were fewer. As a result of the complaints, the Arkansas
Pollution Control Commission conducted a special survey in the
upper Bayou Meto basin in the first half of 1967. The study
linked the problem with high 5-day biochemical oxygen demand
(BOD.J loading and ineffective phenolics removal in the sewage
treatment system.
Since 1969, process wastewater from the Vertac Plant site was
conveyed via the sewage collection lines to the aeration
basin/oxidation ponds complex known as the West WWTP.
Currently, the West WWTP receives sanitary sewage from
residential and commercial areas and treated effluent from the
onsite leachate collection and treatment system.
Because treated leachate and sanitary sewage are the only
discharges from the plant, and because the initial site runoff
is collected from a series of sumps and treated, no additional
contamination is believed to be migrating from the Vertac
plant facility to the off-site areas.
EXTENT OF CONTAMINATION
Figure 7 is a base map showing all areas sampled during the
investigations referenced above. Data on TCDD concentrations
in the off-site areas are available from several
investigations. These areas are enlarged in Figures 8 through
14, which summarize the most recent TCDD sampling data
available for the Vertac off-site investigation area.
*
28
-------
0 v
i I
5 H- <
=5 ». UJ TI
I S£?
Z < 5 i
-------
UOfND
» PARKING LO1
o MANHOLE
DRAJNAGE
APARTMENT
[~~! HOUSE
.'~G] GARDEN
ROAD
CHURCH
" <.««
NOTE:
AVERAGE OF COMPOSPTE
SAMPLES WAS IN
RANGE SHOWN.
BASED ON 1988 HERCULES
AND T988 AND 1989 EPA
P! ING
8
TCDD LEVELS MEASURED IN
THE RESIDENTIAL AREA SOUTH OF
THE VERTAC PLANT SITE
venae Off-Site FS
Jacksonville Arkansas
-------
-------
-------
! II I
-------
-------
-------
-------
Different investigations and the resultant data vary with
respect to time, sampling protocols, and quality
assurance/quality control (QA/QC) procedures. This is
discussed further in the subsequent data comparison section.
Figure 8 presents the sampling results for the floodplains
immediately south of the Vertac plant site. This data
represents fine grid sampling conducted by EPA in 1988 and
Hercules in 1988-89. This land south of the Vertac Plant site
is zoned for residential use. This figure shows where soil
containing TCDD concentrations above the 1.0 ppb action level
has already been excavated from currently developed residential
areas. These soils were placed in bags and temporarily stored
on the Vertac Plant site. However, there is still soil with
TCDD levels greater than 1.0 ppb in undeveloped portions of
this residentially-zoned area. A strip of land along the west
flood plain of the west leg of Rocky Branch Creek contains TCDD
concentrations between 1.0 and 5.0 ppb (Figure 8). In addition,
the sections immediately south of the Vertac property in the
same flood plain area contained greater than 5.0 ppb (maximum
of 9.65 ppb) TCDD (Figure 8).
The land east of the west leg of Rocky Branch Creek north of
the confluence with the east leg also contains TCDD levels
between 1.0 and 5.0 ppb (Figure 8). The wide section of
elevated contamination in the middle of this parcel of land
encompasses the location of former creek meanders. Hercules
Inc. has purchased this property and fenced the area to
restrict access.
Other than the areas mentioned above, sampling has shown that
the remaining soil within the Rocky Branch Creek flood plain
residential area contains TCDD concentrations lower than the
1.0 ppb action level.
Figure 9 presents the results of sampling of the West WWTP
facilities. This sampling was performed in both 1984 and 1988.
As the figure indicates, only the eastern half of the aeration
basin sediments contained TCDD levels greater than 1.0 ppb.
Composite sample concentrations were 2.83 ppb in the southeast
quadrant and 1.41 ppb in the northeast quadrant of the aeration
basin. The most recent sampling of the western half of the
aeration basin, the north and south oxidation ponds, the
outfall ditch, and the outfall delta sediments in Bayou Meto
found TCDD levels that were less than 1.0 ppb or nondetectable
(Figure 9).
The old STP facility was sampled as shown on Figure 10. A
composite sample of the sludge-drying beds contained 2.79 ppb
TCDD. A composite sample of the soil surrounding the sludge
beds contained 1.01 ppb TCDDV The soil surrounding the other
'' .
37
-------
facilities of the 01«Q STP cqntained less than 1.0 ppb of TCDD.
The contents of the treatment 3nits have not been sampled' since
1984. At that time, the sludge in the digester contained a
maximum of 12.46 ppb TCDD, the east primary clarifier contained
1.62 ppb TCDD, and the west primary clarifier contained 0.23
ppb TCDD. The trickling filters and the secondary clarifiers
were not sampled. However, because the trickling filter and
secondary clarifiers receive sewage already treated in the
primary clarifiers, it is highly likely that any contamination
in these units will be less than that in the primary
clarifiers.
Figures 10 through 14 show that the most recent samples of the
Bayou Meto flood plain and the Rocky Branch Creek flood plain
downstream from the Old STP contained TCDD concentrations lower
than 1.0 ppb.
The sewer collection line sediments were sampled only in 1984.
The 1984 data are shown in Figure 15. At that time, the
sediments in the active sewer line contained a maximum
concentration in excess of 200 ppb TCDD. The abandoned Rocky
Branch Creek interceptor contained a maximum sediment
concentration of 70.5 ppb TCDD.
Rocky Branch Creek and Bayou Meto sediments have been sampled
in 1984, 1987, and 1988. Figures 9-12 show the most recent
sediment data. Three additional samples were taken in Rocky
Branch Creek but are not shown on these figures. One was taken
at the Vertac plant boundary in the west leg, one was taken
near the plant boundary in the east leg, and the third was
taken at the confluence of the two legs. Figure 12 shows that
two sediment samples from Bayou Meto contained TCDD
concentrations between 1.0 and 5.0 ppb. It should be noted
that the actual concentrations in these samples were 1.0 and
1.03 ppb. All other samples were below 1.0 ppb.
DATA COMPARISON
Sampling Techniques and Locations
The 1985 RI report presented TCDD data for grab samples
collected from the soils, sediments, and sludges from the
wastewater collection and treatment system, flood plains, Rocky
Branch Creek, and Bayou Meto. Most samples were collected in
1984. In 1987, Hercules Inc. sponsored a sampling effort
designed to be comparable to the 1985 RI data. The 1987 effort
consisted of grab samples collected from approximately the same
locations and depths as in 1984. Soils/sediments were sampled
at three-inch intervals down to 30 inches.
Sampling techniques changed considerably in 1988. Hercules
sponsored another sampling effort, and IT Corporation
«
38
-------
LEGEND
. EXISTING LATERAL AND MANHOLE
__. ABANDONED ROCKY BRANCH INTERCEPTOR
(CONSTRUCTED" 1941 HEJIREO I9?8l
m^^^ NEW ROCKY BRANCH INTERCEPTOR
(CONSTRUCTED 1978'
RESIDENTIAL AREA TRUNK LINE
(PART OF ORIGINAL ARKANSAS
ORDNANCE PLANT LINE BUILT 19411
( ) DETECTION LIMITS
[ ] ESTIMATED MAXIMUM CONCENTRATION
4.5
1200
SCALE IN FEET
APPROXIMATE
2400
WEST
WWTP
-jp.46)
VERTAC
PLANT
SITE
3.81
NEW
WWTP
FIGURE 15
1984 TCDD LEVELS
SEWAGE COLLEC*
venae Oft-Sne FS
Jacksonville. Arka-
-------
(Hercules' contractor) sampled soils and sediments using grid
sampling. In the grid sampling, aliquots of soil or sediment
were collected from locations spaced 10 feet apart within a
defined area (grid) not larger than 5,000 square feet. The
individual aliquots were then composited for analysis. Soil
and sediment samples were taken from 0 to 3 inches deep. Creek
banks were sampled at distances of 6, 36, and 60 inches from
the water line. Stream sediment was collected midstream in
nearly dry creek beds. Sediment samples were collected at the
sediment/water interface and at the interface between sediment
and the clay bottom of the aeration basin and oxidation ponds.
In November 1988 EPA conducted fine-grid sampling of soil along
the west side of the west leg of Rocky Branch Creek south of
the Vertac property. Additional grid sampling was performed
near the Vertac property line in January 1989.
Comparability of Data
The 1984 and 1987 TCDD sampling data are directly comparable,
and comparison of these two data sets may identify trends, if
any. The 1988 grid-sampling data are not directly comparable
to the earlier findings; however, general comparisons can be
made in some cases. Individual grab samples may either
overestimate or underestimate contaminant concentrations
present in a given area. Grid sampling gives a better estimate
of representative concentrations, but does not identify "hot
spots" (areas of severe contamination). Some of the grid-
sampling data cannot be compared to earlier data because those
locations were not previously investigated.
Historical Trends
The TCDD concentrations found in soil/sediment in the various
sampling efforts between 1984 and 1988 are compared in Table
3. (This table presents only the data that can be compared.
Data summary tables for each of the off-site areas can be found
in the 1990 Feasibility Study report.) Once the source of
contamination, i.e. releases from the plant site, is removed
or reduced, TCDD levels in the environment are expected to
decrease due to the combined actions of dispersion by wind and
water, downstream transport of contaminated soil/sediment,
dilution by mixing and covering with clean material,
biotransformation, and physical/chemical transformation.
TCDD levels tended to decrease between 1984 and 1987. A total
of 59 samples are directly comparable between the 1984 and 1987
sampling events (that is, sample aliquots were collected at the
same location and depth and analyzed individually). These 59
samples compare as follows:
40
-------
TABLE 3
SAMPLING DATA COMPARISON TABLE FOR 2,3.7,8-TCDD (ppb)
SAMPLING AREA
BACKGROUND
SAMPLING
LOCATION
VANBERG BLVD
SAMPLE
DEPTH 1984 DATA
ABCD
1987 DATA
ND-0.023
1988 DATA'
OXIDATION POND NW QUAD
NE QUAD
A 0-3 inch
B » 3-6 inch
C - 6-9 inch
D» 9-12 inch
E-12-15 inch
SW QUAD
SE QUAD
F- 15-18 inch
G «18-21 inch
H- 21 -24 inch
I - 24-27 inch
J » 27-30 inch
A
D
S
IN
A
A
D
F
S
IN
A
D
S
IN
A
A
A
C
G
J
S
IN
3
0.7
3.6
1.8
0.98
0.51
1.98
0.34
0.92
0.2
1.3
0.57
0.44
0.15
1.2
0.4
1.5
1.8
ND-0.01
0.025
0.41
0.0061
1.3
0.022SP
1.1
0.0059
ND-0.029
0.015
0.29 [4]
NA (ND-0.3) [4]
0.97 [4]
NA(ND-0.3)DU [4
NA (ND-0.3) (4)
NA (ND-0.3) [4]
NA (ND-0.3) [4)
NA (ND-0.3) [4)
S - surface sample
IN - interface smp! b/w bottom sedmnt & liner
X « deep bottom samples
NA . not analyzed for 2,3,7,8-TCDD when TCDD < 1
() * non-isomer-specifc TCDD concentration
ND - non-detectable at given detection concentration
DU * duplicate associated with sample; highest value shown
SP * split sample; highest value shown
* Highest value of sampling grid used
'* samples taken at 6,36, and 60 inches
[ ] = number of grabs (surface samples) or cores ^interface samples)
taken in the sampling gnd " " «
-------
* -. . TABLE 3
SAMPLING DATA COMPARISON TABLE FOR 2,3,7,8-TCDD (ppb)
SAMPLING AREA
OXIDATION POND
OUTFALL
AERATION BASIN
BAYOU METO
1-. 88 mi below
outfall
.88-2.4 mi below
outfall
SAMPLING
LOCATION
DELTA
NBANK
N BANK LEFT
NW QUAD
NE QUAD
SW QUAD
SE QUAD
MIDSTREAM
NBANK
CONFLUENCE
NBANK
S DUPREE PRK
SOYBEAN FLD.
DRY CREEK
MIDSTREAM (1m)
SAMPLE
DEPTH
A
S
A
**
A
B
C
**
S
IN
A
E
F
S
IN
A
E
S
IN
A
G
S
IN
A
A
A
D
A
A
A
A
A
A
1984 DATA
0.74
2
3.5
1.1
2.1
37.9
6.5
16.2
2.08
0.27
0.47
0.53
0.74
0.22
0.06
0.9
0.37
0.1
1987 DATA
0.45
1.2SP
0.5SP
0.6SP
0.68
2.9
1.5DU
1.7
2.7
0.8DU/SP
7.6
1.9SP
0.024SP
0.036SP
0.29
ND-0.0065
0.8SP
0.36DU
0.068DU
0.46SP
1
1 03
1988 DATA*
NA(ND-0.3)DU [10]
NA(ND-0.3)DU [261
NA(ND-0.3)DU [26{
NA (ND-0.3) [6]
NA (ND-0.3) [6]
1.41 [6]
NA (ND-0.3) [6)
NA (0.71) [61
NA (ND-0.3) [6]
2.83 DU [6]
NA(ND-0 3)DU [61
N BANK
NA(NC :
-------
" TABLE* 3
SAMPLING DATA COMPARISON TABLE FOR 2,3,7,8-TCDD (ppb)
DEPTH 1984 DATA 1987 DATA
SAMPLING AREA
2.4-3.23 mi below
outfall
3.23-4.09 rrt
below outfall
ROCKY BRANCH
WEST LANE
MINES ST.
W.LEG(0-250ft.
frm junct.Qf.
W and E legs)
SAMPLING S
LOCATION !
S BANK (1 mi)
BAY MOUTH
WOODLAND
NBANK
MIDSTREAM
RR TRACK
N BANK (2m)
S BANK (2mi)
MIDSTREAM(2.25mi)
N BANK (2.4mi)
S BANK (2.4mi)
HWY161
SBANK
IRRIGATION
FLOODPLAIN
«
RUNOFF DITCH
WOODED PENN.
(end of st.)
0-20ft.frm cn\
20-40ft.frm crk
40-60ft.trm cn\
iAMI
DEP
A
B
C
**
A
A
C
A
A
A
B
B
C
A
A
*
A
A
D
*
A
A
C
A
A
C
A
C
S
S
S
0.81
1.2
1.1
0.86
1.58
1.1
0.54
1.52
0.78
0.39
0.34
0.79
1.08
0.09
0.84
0.01
7.58
0.34
0.12SP
0.33
0.41 SP
0.098
0.0046SP
0.49
0.53
0.85SP
0.75SP
0.64
1.7SP
0.22
0.25
A
A
D
0.25
0.31
0.18
0.18
0.0029
0.14SP
1988 DATA'
NA (ND-0.3) [38]
NA (ND-0.3) [50]
NA (ND-0.3) [50]
NA (ND-0.3) [50]
NA (ND-0.3) [42]
0.22DU
0.54DU/SP
ND-0.0055DU/SP
0.12
0.011SP
6.8
1.3SP
2.88 (150}
1 98(150]
NA(0869)['5:
-------
* . TABLE 3
SAMPLING DATA COMPARISON TABLE FOR 2,3,7.8-TCDD (ppb) ' '
SAMPLING AREA
W.LEG(250-500ft.
frm junct.of
W and E legs)
E.LEG(0-250ft.
frm junct.ol
W and E legs)
SAMPLING
LOCATION
0-20ft.frm crk
20-40ft.fnn crk
40-60tt.frm crk
60-80ft.frm crk
80-1 OOft.fnn crk
1 00-1 20ft. frm crk
0-20tt.frm crk
SAMPLE
DEPTH 1984 DATA 1987 DATA
S
s
S
s
s
s
s
1988 DATA'
2.73(150]
2.02 [150]
1.74(150]
1.45(150]
1.34(150]
NA (0.96) (150
NA(ND-0.3)(150]
E.LEG(250-500ft.
frm junct.of
W and E legs)
E.LEG(500-750ft.
frm junct.of
W and E legs)
0-20tt.frm crk
0-20tt.frm crk
NA(ND-0.3)(150]
NA(ND-0.3)(150]
ROCKY BRANCH IN THE
VICINITY OF STP
DRY CREEK
WBANK
MIDSTREAM
DRY CREEK
W BANK DELTA
BEND MIDDLE
MIDSTREAM
A
A
S
A
A
S
C
A
A
A
A
1.7
0.05
0.17
1.5
0.11
0.15
0.16
0.41
0.97SP
0.0049
0.098SP
0.64
0.85SP
0.63
0.46SP
0.86
0.52
NA (0.569)DU [50]
NA (ND-0 3) [25]
OLD STP AREA
PERIMETER
SLUDGE DRY BED
S
A-
1 01 [66j
2.79DL "
ND-p.01
-------
TABLE* 3
SAMPLING DATA COMPARISON TABLE FOR 2.3,7,8-TCDD (ppb)
SAMPLING AREA
SAMPLING
LOCATION
CLARIRERS
SAMPLE
DEPTH
A
B
B
A
A
1984 DATA 1987 DATA 1988 DATA"
0.77
6.59
0.56
1.62
0.23
CLARIRER AREA S
SLUDGE DIGESTER B 5.3
B 12.46
SLUDGE COLLCT.ARE A ND-0.76
A ND-0.05
E ND-0.21
E 0.42
X ND-0.48
X 1.19
NA (0.307) [39]
-------
o In 1987, 47 samples (80 percent) were lower than in
1984, with 32 samples (53 percent) at least 50
percent lower. The largest decrease was from 37.9
ppb in 1984 to 2.9 ppb in 1987 in the aeration
basin.
o In 1987, 11 samples (19 percent) were higher than
in 1984, and 5 samples (8.5 percent) were more than
50 percent higher. The greatest increase was from
0.92 ppb in 1984 to 1. 3 ppb in 1987 in the oxidation
pond.
o In 1987, one sample (2 percent) was exactly the same
as in 1984.
It should be noted that this is not a statistical treatment of
the data (e.g. , lower than does not imply a statistically
significant difference), but simply a mathematical comparison.
TCDD levels at nearly half of the 1987 sampling stations were
within plus or minus 50 percent of their 1984 concentration.
The elevated levels detected in aeration basin samples of 1984
(37.9 and 16.2 ppb) and 1987 (7.6 ppb) were not found in later
samples. This decrease may stem from the sampling methods used
(e.g., grab sampling of a hot spot versus dilution via
composite sampling) or may reflect biodegradation or another
attenuation process. In any case, the 1988 fine-grid sampling
found TCDD levels of less than 5.0 ppb in the aeration basin
and less than 1.0 ppb in the oxidation ponds.
46
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VI. SUMMARY OF SITE RISKS
1986 Endanaerment Assessment
An endangerment assessment (EA) was conducted to support the
June 1986 FS. The objective of the EA was to evaluate the
potential health and environmental effects if no remedial
action is taken at the Vertac site. It defined the current or
potential future exposures and risks attributable to
contaminants at the site, primarily TCDD.
The EA is based upon the 1984 data and included a discussion
of this RI data and how they are used, including soil,
sediment, and fish sampling data. In some cases, chlorophenoxy
herbicides, chlorinated benzenes, and chlorinated phenols were
analyzed in addition to TCDD.
A discussion of the potential for migration of TCDD from the
sewer system, Rocky Branch Creek, and Bayou Meto was included.
The EA concluded that TCDD has the potential to migrate out of
the sewage treatment plant, adsorb onto soils and sediments,
and be transported in the creek beds and flood plains.
Potential exposure pathways to contaminated media were
identified and included direct dermal contact or ingestion of
sediments or soils originating from the sewer system, Rocky
Branch Creek, Bayou Meto, or the flood plains; inhalation of
volatilized organics, if any, from contaminants in the sewer
system, creek, or flood plain sediments or soils; ingestion of
fish and other aquatic organisms from Rocky Branch Creek or
Bayou Meto; and ingestion of agricultural products that have
been grown in contaminated soils.
From the estimate of intakes, and considering various exposure
scenarios, risks were quantified. A range of risks were
calculated based on the range of TCDD concentrations found in
the media. A summary of the calculated risks in the 1986 EA
is presented in Table 4.
Revised Risk Assessment
The 1986 EA was updated to reestimate off-site risks based on
the most recent TCDD data and current EPA exposure and risk
assessment guidelines. While the 1986 EA addressed several
media and both TCDD and non-TCDD compounds, this update focuses
specifically on ingestion of TCDD-contaminated soils and
sediments. Since ingestion of TCDD contaminated soil and
sediments presents the dominant risk, this exposure scenario
was used to calculate baseline risk. In calculating the risk..
due to exposure to the various components of the study area
'' «
47
-------
S
o
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>-> N~-
igerment Assessmen
ind Associated Risk
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langerment Assessment
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(e.g. floodplains* West. STP, etc.), exposure to the
concentrations found in each Component was assumed. For each
component, either a residential or occupational exposure
scenario was assumed, based upon the zoned use for the area.
A zoning map is shown on Figure 3.
The exposure parameters used to estimate cancer risks in both
the 1986 and revised EA's are: fraction of the year that
exposure occurs; fraction of the chemical that is absorbed in
the gut; and lifetime average soil ingestion rate (LASI). The
exposure fractions used in 1986 and the revised EA are the
same since no new information is available that would change
them. The exposure fraction for the occupational setting is
0.39 and is based upon time spent at work. The exposure
fraction for the residential setting was based upon weather
conditions (from meteorological data) that typically prohibit
outdoor activities and was set at 0.58. No new information is
available to change the absorption factor. Therefore, the same
was used in both the 1986 and revised EA for both the
occupational and residential settings and was 0.3. No new
information on the LASI for the occupational setting is
available and the same was used in 1986 and the revised EA.
It was .0008 g/Kg/day. The LASI for the residential setting
in 1986 was 0.028 g/Kg/day. However, new information is
available which suggests that children ingest less soil than
was used to calculate the LASI in 1986. Therefore, the revised
EA used a LASI for the residential setting which was re-
calculated, according to EPA's 1989 risk assessment guidance,
at 0.0022 g/Kg/day.
The cancer potency factor used in the 1986 EA was 156,000
(mg/Kg/day)". This continues to be the cancer potency factor
used in EPA risk assessments for 2,3,7,8-TCDD (EPA, 1989).
The following subsections present revised exposure and risk
estimates for each of the off-site areas.
Sewage Collection Lines
The sewer collection lines have not been sampled since the 1984
RI sampling, where the maximum concentration was found to be
200 ppb TCDD. The occupational exposure setting used in 1984
has not changed and, therefore, the risk estimates for the
collection lines remain at 10"3 to 10"6.
Old STP
As part of the 1988 fine-grid sampling conducted by Hercules,
73 surface (0 to 3-inch) samples were composited and analyzed
from the sludge drying beds. The TCDD concentration in this
composite sample was 2.79 ppb. Using the same occupational
50
-------
exposure parameters used-in the 1986 EA, the risks associated
with ingestion of sludge from tr ~ ---J--- - - - - -
4 x 10~s based on the 1988 data.
The only other areas of the Old STP where post-RI data are
available are the perimeter of the sludge drying beds and the
soil surrounding the clarifiers (available from 1988 fine-
grid sampling). Neither of these specific areas were sampled
during the 1985 RI. Sixty-six samples were composited from the
perimeter of the sludge beds and 39 from the clarifier area.
The concentrations in these composite samples were 1.01 and
0.307 ppb TCDD, respectively. The risks associated with these
areas, using the occupational exposure setting, would be 1.5
x 10~5 and 4.5 x 10~6, respectively.
WWTP
The 1984 RI data showed maximum and average concentrations
from the aeration basin of 37.9 and 20.2 ppb TCDD,
respectively. In 1988, composite samples were taken in each
of the four quads of the aeration basin. Each composite
consisted of six samples. The highest composite sample was
2.83 ppb TCDD. Using the occupational exposure parameters and
a 2.83 ppb TCDD concentration, the risks associated with
aeration basin sediments would be 4.1 x 10"5.
The north oxidation pond showed maximum and average
concentrations of 3.6 and 2.8 ppb TCDD, respectively, in 1984.
In 1988, two composite samples were taken from the north pond.
The highest composite sample showed a TCDD concentration of
0.97 ppb. The risk associated with this concentration, using
the occupational exposure setting, would be 1.4 x 10"5.
The maximum and average concentrations from the south pond in
1984 were 1.3 and 1.2 ppb TCDD, respectively. in 1988, both
composite samples showed nondetectable concentrations. At the
detection limit of 0.3 ppb TCDD, the risk would be 4.3 x 10 e.
Rocky Branch Creek Flood Plain
In 1988 and 1989, EPA sponsored sampling of the flood plain
soils along the west leg of Rocky Branch Creek. Samples were
composited from grids that were approximately 20 feet by 250
feet. The highest composite sample showed a concentration ot
9.6 ppb TCDD. The risk associated with this concentration,
using the revised residential LASI, is 5.7 x 10"4.
51
-------
Rocky Branch Creek* and -Bayou Meto Sediments
^
Assuming a continued and effective State advisory discouraging
ingestion of fish, the TCDD levels in the sediments should not
pose an unacceptable health risk (see Appendix A).
TARGET CLEANUP AREAS AND ACTION LEVELS
In 1986, the ATSDR reviewed the Vertac off-site RI report and
assessed the human health significance of the contamination and
the need for off-site cleanup. Based on this evaluation, ATSDR
developed guidelines and criteria for remediation of TCDD-
contaminated materials in the Vertac off-site area. The
following levels were derived from ATSDR recommendations (the
ATSDR memorandum is included as Appendix B).
o Wastewater Collection System. Sewer lines indicated
in the RI to have TCDD concentrations equal to or
greater than 1.0 ppb require remediation. This
action level was chosen because the contaminants in
the sewer line could migrate downstream and
contaminate the wastewater treatment facilities,
Bayou Meto, and nearby flood plains.
o Old Sewage Treatment Plant. TCDD-contaminated
sludges, wastes, soils, and sediments in the
abandoned facilities would be remediated so that an
action level of 5.0 ppb TCDD is not exceeded. The
ATSDR recommended an action level of 5 to 7 ppb TCDD
for soils in and around the abandoned sewage
treatment facilities if the following conditions
were imposed:
The site must not be developed for
agricultural or residential use
The use and activities of the site must
not become associated with the
production, preparation, handling,
consumption, or storage of food, other
consumable items, or food-packaging
materials
The site soils must be protected from
erosion that would uncover or transport
TCDD that could cause unacceptable human
exposure at a future date
o West Wastewater Treatment Plant. An action level
of 5 to 7 ppb was recommended for the aeration
basin, oxidation ponds, outfall ditch, and
"52 .
-------
peripheral* land, zoried for manufacturing. .This
action level is subject to the same conditions
listed above for the Old STP.
o Flood PlainResidential and Agricultural. An
action level of 1.0 ppb TCDD would be adopted for
residential and agricultural areas.
o Flood PlainNonresidential and Nonagricultural.
Nonresidential and nonagricultural areas in the
flood plain (such as woodlands, industrial, and
commercial areas) that are not subject to erosion
and transport processes would have an action level
of 5 ppb TCDD. If the areas are subject to erosion
and transport processes (lack sufficient ground
cover to inhibit erosion), the action level would
be 1.0 ppb.
On several occasions in late 1988 and early 1989,
representatives of EPA and ATSDR discussed the most
recent sediment data and its potential risk to human
health. The results of these discussions is the
following conclusion regarding Rocky Branch Creek and
Bayou Meto sediments. The basis for this conclusion is
outlined in a memo in Appendix A. Assuming a continued
and effective State advisory discouraging ingestion of
fish, the TCDD levels in the sediment in Rocky Branch
Creek and Bayou Meto should not pose an unacceptable
health threat.
53
-------
VII. DESCRIPTION OF ALTERNATIVES
The Vertac off-site area is complex in the number and variety of
target cleanup areas; however, the number of potential remedial
actions is constrained by the limited number of treatment/disposal
processes that are implementable and proven effective for TCDD
waste. Table 5 lists area-specific potential remedial actions,
along with the maximum TCDD levels detected in the most recent
sampling event, the TCDD action levels established for the site,
and the reason for concern. Table 6 lists quantities of
contaminated material that were considered for remediation. These
quantities were based upon the most recent data available and upon
area specific action levels.
A range of remedial action alternatives was assembled for the site
as a whole using the area-specific potential remedial actions
listed in Table 5. The assembled alternatives are briefly outlined
in Figure 16 and described in detail below.
ALTERNATIVE 1
The no-action alternative consists of taking no further action to
prevent human exposure to contaminated materials, prevent migration
of contaminants, or protect the environment. However, the
currently existing conditions, institutional controls, and studies
would continue. These include:
o The fences that restrict access from the developed
residential area to contaminated sections of Rocky Branch
Creek.
o The access and use restrictions at the undeveloped
residential area along the east side of the west leg of
Rocky Branch Creek owned by Hercules Inc. This land is
fenced and has signs to restrict access.
o The access and use restrictions at the Old STP and West
WWTP. These facilities are only partially fenced.
ALTERNATIVE 2
Figure 17 is a flow diagram of Alternative 2.
Alternative 2--Collection Lines
The sewer collection lines under consideration include two
interceptor lines running parallel to Rocky Branch Creek (Figure
15). The westernmost Rocky Branch Creek interceptor was abandons!
in 1978 when the eastern most interceptor was constructed. In t."..
alternative, only the active sewer lines would be cleaned; the
54
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abandoned interceptor would be left in place. The collection lines
to be cleaned include the -ti^ink line running diagonally through
the residential area from the Vertac Plant site and the active
Rocky Branch Creek interceptor.
Damaged manholes along the active sewer lines would be repaired
or, if necessary, replaced. The 1985 RI evaluation of manhole
structural integrity found that most of the defects occurred on the
Vertac Plant site and along the abandoned Rocky Branch Creel*
interceptor, neither of which are part of the active sewage
collection system. The 1985 RI findings indicate that defects ir
manholes along the active lines are minor and could be repaired
using an epoxy grout lining. Other possible rehabilitatior
measures include preformed polyethylene liners, formed-in-place
resin liners, or manhole replacement. It is assumed that groutinc
would be sufficient to rehabilitate most of the manholes but a more
extensive restoration method would be employed if necessary.
The volume of sediment in the active collection lines is estimated
to be 10 cubic yards (cy). This volume is based on the results of
the 1985 RI sewer lamping study. It is assumed that upstrean
laterals and service lines tying into the Rocky Branch interceptor
do not contain contaminated sediments and do not require
remediation.
In this alternative, 10,350 feet of collection lines would be
cleaned of contaminated sediments and debris by hydraulic flushing
combined with vacuum pumping. The pipe-cleaning procedure is
illustrated in Figure 18. An obstruction is placed in the pipe
immediately downstream from a manhole. A hose, fitted with a
nozzle that directs flow backwards, is fed through the manhole into
the upstream pipe. The hydraulic force of the water jet is allowed
to carry the nozzle upstream to the adjacent manhole. The flushing
hose is then slowly retrieved to hydraulically flush the entire
length of pipe with a pressurized stream of water. The water and
sediment are simultaneously pumped through a hose at the downstream
manhole into a tank truck. The obstruction is then removed and the
procedure repeated in downstream segments. Additional vacuuming
would be employed as needed to remove sediments from manholes.
The RI reported that the primary obstructions in the sewer lines
were grease, roots, dirt, and gravel. Bricks and concrete from
manholes have also fallen into sewer lines. The lines to be
cleaned would be inspected with video cameras to locate
obstructions. Some sections (5 percent of the total active pipe
length is assumed) may require supplemental mechanical cleaning to
remove major obstructions.
It is likely that damaged sections of pipeline would have to ;
repaired to allow hydraulic cleaning. Based on the lamping stu<:.
conducted during the RI, it is assumed that three percent of -
sewer lines, excluding the abandoned Rocky Branch Creek inter-
"' - * 6"l '
-------
-------
ceptor, would reqifire -.repair. At least one foot., of soil
surrounding damaged pipe and *(250 cy) would be excavated during
repair and incinerated because of the likelihood of TCDD
contamination.
The poor structural characteristics of the 4,350-foot abandoned
Rocky Branch Creek interceptor, described in the 1985 RI , indicate
that it cannot be hydraulically cleaned. It is plugged with
concrete at both ends and there are no known interconnections,
including exfiltration/infiltration, between the abandoned and
active Rocky Branch Creek interceptors. As long as the abandoned
interceptor remains undisturbed in the ground, there is no direct
route for human exposure. Therefore, in this alternative, the
abandoned Rocky Branch Creek interceptor would be left in place.
There are two main advantages of hydraulic cleaning: essentially
all the sediment can be flushed to manholes and removed from the
sewers, and there is little or no disruption of service. During
the hydraulic cleaning, sanitary flow would be pumped to adjacent
manholes.
Hydraulic flushing generates large quantities of water (estimated
at seven gallons per foot of sewer). Further contamination of the
aeration basin would be prevented by collecting the flushing water
as each segment is cleaned. This water would be treated by
sedimentation, filtration, and carbon adsorption (see "Wastewater
Treatment" later in this section).
Sediments can be effectively removed from the water by
sedimentation and dewatering (see "Solids Dewatering" later in this
section). It is assumed that the 10 cy of sediment separated from
the bulk liquid would contain 20 percent solids. This material
would be dewatered to 6.7 cy at 30 percent solids. Because the
sediments in the collection lines have been found to contain TCDD
concentrations in excess of 200 ppb (1984 data), the dewaterec
solids would be incinerated.
Inspection of the sewers after cleaning would involve:
o Television inspection to determine the adequacy of the
cleaning and required repairs and to detect any
unauthorized connections
o Smoke testing to identify points of infiltration
exfiltration and unauthorized inflow
If television inspection indicated remaining obstructions,
additional cleaning (probably mechanical followed by hydrau!.
flushing) would be required. It is assumed that the inspect! :
would indicate that no additional cleaning and repair would :
required.
63
-------
After completion of sfwer cleaning, the equipment involved (trucks,
hoses, pumps) would be decontaminated. Decontamination procedures
would include hydrocleaning, with water from the procedure captured
for treatment. When the decontamination procedure is completed,
the equipment would be wipe-tested and the wipe cloths analyzed for
TCDD to assure that no contamination remained on the equipment.
The equipment would be impounded until the test results indicated
decontamination was complete.
Alternative 2Old STP
Sludge would be removed from the sludge digester using a vacuum
pumping system. The estimated 890 cy of digested biological sludge
assumed to be 5 percent solids would be dewatered (as described
under "Solids Dewatering" later in this section) to approximately
300 cy at 15 percent solids. The dewatered sludge would be
consolidated on the Vertac Plant site and capped. This and other
consolidated material would be covered with a multilayered cap
consistent with RCRA requirements. Onsite consolidation and
capping of waste materials is described in more detail under
"Alternative 2--Rocky Branch Creek and Bayou Meto Flood Plain"
later in this section.
The empty sludge digester would be cleaned with a hot, pressurized,
biodegradable cleaning mixture. All other equipment would be
decontaminated by hydrocleaning. The leachate from sludge
dewatering and the used washing and decontamination solutions would
be treated by sedimentation/filtration and carbon adsorption (see
"Wastewater Treatment" later in this section).
No action would be taken on the remaining treatment units. The
grounds of the Old STP would be fenced (1,500 linear feet) and
signs posted every 100 feet to restrict access to contaminated
areas of the plant.
Alternative 2--West WWTP
The oxidation ponds and aeration basin would be fenced
(7,500 linear feet) and signs posted to restrict access to those
facilities.
Alternative 2Rocky Branch Creek and Bayou Meto Flood Plain
In developed residential areas, all soils with greater than 1.0 ppb
of TCDD have already been excavated and are temporarily stored in
plastic bags on the Vertac Plant site. The 1,623 bags contain
2,400 cubic yards of soil including: a) soil from the residential
areas immediately east of the west leg of Rocky Branch Creek,
b) soil from the residential area just south of the Vertac proper-y
line and west of the east leg of Rocky Branch Creek, and c) so:!
from a drainage area on the Vertac Plant site just north of ::
64
-------
Vertac property line and adjacent to (b) (see Figure..8). These
stored- soils will be addressed as part of the onsite FS.
Soils from undeveloped residential areas with TCDD levels greater
than 5.0 ppb (see Figure 8) would be removed with backhoes to c
depth of one foot. This category includes two sampling grids--
Numbers 17 and 18 from EPA's 1988 sampling effortjust west of th«
west leg of Rocky Branch Creek and just south of the Vertac
property line, and would result in 400 cubic yards of soi:
(assuming a 25 percent bulking factor). This soil would be con-
solidated on the Vertac Plant site and capped as part o:
Alternative 2. The excavated areas would be backfilled with clear
soil and seeded with grass.
Residentially zoned, but undeveloped areas that contain 1-5 ppt
TCDD (see Figure 8) would not be excavated. Rather, the zoning o
these areas, which include privately owned land (approximately O.f
acres) west of the west leg of Rocky Branch Creek and land ownec
by Hercules (approximately one acre) east of the west leg of Rocki
Branch Creek would be changed to a commercial/industrial use.
The total of 700 cy of material to be consolidated in Alternative 2
includes 300 cy of dewatered sludge from the digester and 400 ci
of soil. Since this material consists largely of contaminated
native soil, it is assumed that it would be compactable and that
compaction would reduce the volume of soil by 25 percent. For
consolidation, the material would be placed on the plant site and
compacted into a mound.
A multilayer cap would then be placed over the contaminatec
material. The cap would be consistent with federal and state RCR?
requirements for landfill closures. The overall surface area
required for consolidation would be roughly 0.3 acre. The native
materials required for construction of the cap would be 162 cy of
topsoil and sand; 475 cy of native soil; and 650 cy of clay. Based
on soil type descriptions in the Jacksonville area, it is expected
that materials suitable for cap construction are available locally.
Alternative 2Rocky Branch Creek and Bayou Meto Sediments
The remedy for Rocky Branch Creek and Bayou Meto sediments is based
on the recommendations contained in the 1989 memorandum from EP£
to ATSDR (see Appendix A). These recommendations include a
continued advisory against ingestion of fish taken from Rocky
Branch Creek and Bayou Meto. The memorandum states that the levels
of TCDD found in the sediments should not pose an unacceptable
human health threat if this advisory is continued and is
effective. This remedy also includes continued monitoring of fish.
65
-------
ALTERNATIVE 3 *
Figure 19 is a flow diagram of Alternative 3.
Alternative 3Collection Lines
The collection lines would be cleaned by hydraulic flushing as
described in Alternative 2. Only the active lines would be
cleaned; the abandoned Rocky Branch Creek interceptor would be left
in place. Sediments removed from the sewer lines would be
dewatered and the solids incinerated. The flushing water and the
water from the solids dewatering would be treated by the wastewater
treatment system.
Damaged manholes along the active sewer lines would be repaired as
described in Alternative 2.
The hydraulically cleaned collection lines would be lined with a
resin-type lining system. One such system employs a liquid
thermosetting resin that is hardened in place to conform to the
interior contours of the existing pipe. Installation of this type
of pipe liner is illustrated in Figure 20. A resin-impregnated
felt "sock" is fed into the pipe and filled with water to press the
resin-coated side firmly against the pipe walls. Hot water is
circulated to cure the resin. The sock is then removed, the resin
pipe ends cut off, and the lateral connections reopened using a
remote-controlled cutting device.
Rehabilitating the manholes and sewer lines would greatly reduce
the probability of contaminant migration to the new WWTP. Soil
surrounding the sewer lines may have been contaminated by
exfiltration over the years that waste was conveyed from the Vertac
Plant site. The liners would virtually eliminate infiltration of
contaminated soil and water. Also, the resin-type liners can be
made thick enough to provide structural integrity.
The main sewer line running through the residential area south of
the Vertac Plant site consists of clay pipe installed in 1941.
This pipe is approaching the end of its service life, and would
soon require replacement if not rehabilitated. Excavation of this
line in the future could constitute a hazard due to exposure to
TCDD-contaminated soil. Rehabilitation of the active sewer lines
with resin-type liners should provide sufficient structura:
integrity to preclude the need to replace those lines in the near
future.
Alternative 3Old STP
The sludge digester would be emptied and cleaned as
Alternative 2; however, in this alternative the 300 cubic yards
dewatered biological sludge from the digester would be incinera-
rather than consolidated onsite^. The digester sludge had a max.
66
-------
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1. ATTACH SOCK TO n
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TCDD concentration of 12.4 ppb in 1984. Incineration wou..ld destroy
this contamination, as opposed to consolidating it as in
Alternative 2.
The sludge drying beds and surrounding soils would be capped with
asphalt. Sampling in 1988 found TCDD levels of 2.30 and 1.01 ppb
in composite samples of the drying beds and surrounding soils,
respectively (see Figure 10). Although these concentrations are
less than the ATSDR 5.0 ppb action level for TCDD in nonresidential
and nonagricultural areas, the sludge beds have been used for
vegetable and flower gardening in the past. Paving this area with
a hard asphalt cap would prevent gardening and direct human contact
in the future.
The area to be paved would be prepared by demolishing the concrete
curbs surrounding the sludge-drying beds and then grading. A small
bulldozer and, if necessary, a light grader would be employed for
these tasks. A geotextile would be rolled over the prepared
subgrade. A layer of four to six inches of crushed gravel would
be spread over the geotextile and compacted. The compacted gravel
base would be covered with a two-inch layer of dense graded
asphalt-concrete pavement. The pavement mixture would be designed
with a high asphalt content to retard oxidation and subsequent
thermal cracking. All equipment used to move or grade contaminated
soil would be decontaminated.
No action would be taken at the other STP units. Fencing and
posting signs would further deter access to or use of the Old STP
grounds.
Alternative 3--West WWTP
The highest TCDD concentrations found in the 1988 grid sampling of
the West WWTP facilities were 2.8 ppb in the aeration basin and
0.97 ppb in the oxidation ponds. Both of these values are below
the ATSDR/EPA site-specific action level of 5.0 ppb for
nonresidential and nonagricultural areas, and there is no known
direct human use of these areas. However, this action level
includes the condition that contaminated sediments be prevented
from migrating and allowing exposure to humans.
The primary concern for the West WWTP is that sludge and sediment
from the bottom of the oxidation ponds may be scoured during a
flood event and transported to relatively uncontaminated areas.
Information from the USGS indicates that the 100-year flood
elevation in this area is 250.8 feet above mean sea level (msi).
The walls of the aeration basin are higher than 253 feet above ms1,
placing that facility out of the 100-year flood plain. However,
the oxidation ponds, with walls approximately 246 feet above ms . ,
are in the five-year flood plain. In this alternative, *
oxidation ponds would be protected against inundation during a 1
69
-------
year flood by constructing earthen berms around their perimeter
(5,800 ft). » - .
The berms would be constructed using a low permeability soil such
as the local silts and clays and would feature a 252.8 foot
elevation (msl) berm, vegetative cover, except for a crushed gravel
road surface, and an exterior perimeter drainage ditch. Roughly
141,800 cy of material would be required to construct berms around
the oxidation ponds (this number assumes an average ground surface
elevation of 242 feet above msl and is an overestimate because it
was not reduced by the volume of material in the existing berms,
which would be incorporated into the new ones).
The West WWTP facilities (oxidation ponds and aeration basin) would
be fenced and signs posted to restrict public access and use in
Alternative 3.
Alternative 3--Rocky Branch Creek and Bayou Meto Flood Plain
As in Alternative 2, soils containing above 5 ppb TCDD would be
excavated, and those areas would be backfilled and seeded.
However, in this alternative, these soils (approximately 400 cubic
yards) would be incinerated (see "Incineration" later in this
section).
As in Alternative 2, zoning changes would be sought for undeveloped
residential areas with soil TCDD levels between 1.0 and 5.0 ppb.
A zoning change to nonresidential/nonagricultural would help
prevent long-term direct human contact with contamination in those
areas.
Alternative 3--Rocky Branch Creek and Bayou Meto Sediments
The remedy for this area is identical to Alternative 2.
ALTERNATIVE 4
Figure 21 is a flow diagram of Alternative 4.
Alternative 4--Collection Lines
The active sewer lines would be cleaned by hydraulic flushing and
the cleaned pipes would be lined, as described in Alternatives 2
and 3, respectively.
The abandoned Rocky Branch Creek interceptor (see Figure 15) con-
tained TCDD levels as high as 70.5 ppb in 1984. In this
alternative, mechanical trenching and excavation equipment, such
as backhoes, would remove the 4,350-foot abandoned, along with
contaminated sediments within the pipe, and a minimum of two feet
of potentially contaminated soil surrounding the pipe (4 feet x 4
feet). These materials (approximately 3,200 cubic yards,
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considering a 25 per*cenf .bulking factor) would be dewa.tered and
incinerated (see "Solids Dewatering" and "Incineration" later in
this section). The resulting trench would be backfilled with clean
soil. All flushing and decontamination liquids would be treated
by the onsite wastewater treatment system.
Alternative 4Old STP
Backhoes would excavate to a depth of one foot the sludge drying
beds and surrounding soil. Approximately 1,500 cubic yards of
excavated material (assuming 25 percent bulking) would be
incinerated. As in Alternative 3, the sludge would be pumped from
the sludge digester, dewatered, and incinerated. No action would
be taken at the other STP units. The Old STP grounds would be
fenced and warning signs posted to restrict access.
Alternative 4--West WWTP
The 6.8 million gallons of water in the three-acre aeration basin
would be drained and pumped into the oxidation ponds and the
aeration basin would be allowed to dry. After dewatering and
drying, the aeration basin would be capped. The purpose of the
cap would be to provide a barrier against migration of contaminated
basin sediments. The cap would consist of compacted native soil,
six to 12 inches of topsoil, and a vegetative layer. The cap would
be designed to grade naturally with the surrounding soil. Assuming
an average depth of 10 feet in the aeration basin, the cap would
require 46,000 cy of native soil and 2,400 cy of topsoil (compacted
volumes).
As described in Alternative 3, berms would be constructed to
protect the oxidation ponds against inundation during a 100-year
flood. Water accumulating in the oxidation ponds from
precipitation would be allowed to flow to Bayou Meto via an outfall
designed to prevent sediment entrainment.
The West WWTP facilities would be fenced and warning signs posted.
Alternative 4Rocky Branch Creek and Bayou Meto Flood Plain
Soil would be excavated from all residential areas (developed or
undeveloped) with TCDD concentrations greater than 1.0 ppb.
Removal of this soil would remove the risk associated wit;1.
potential future development in areas zoned residential with TCDD
concentrations greater than the 1.0-ppb action level for
residential areas. These lands would be backfilled with clean so:.
and revegetated following excavation. The excavated so:.
(4,100 cubic yards, including a 25 percent bulking factor) woui !.
be incinerated.
72
-------
Alternative 4Rocky Branch creek and Bayou Meto Sediments
t
Same as Alternatives 2 and 3."
ALTERNATIVE 5
Figure 22 is a flow diagram of Alternative 5.
Alternative 5Collection Lines
In this alternative, all 14,700 feet of active and inactive sewe
lines and all manholes would be mechanically removed, as would a
least two feet of soil surrounding the pipes. The contaminate!
sediments and debris (approximately 10,900 cubic yards) would b<
dewatered. Solids would be incinerated, and liquids would b<
treated by the wastewater treatment system. Removal of thi
contaminated collection lines and installation of new lines woul<
preclude contamination of the new WWTP.
Wastewater collection must continue during the removal of tin
contaminated sewer lines; therefore, a new sewerage system, runninc
from the residential area south of the Vertac property to the ne\
wastewater treatment plant, must be installed before excavating the
existing lines. For this alternative as well as the others, the
timing of various actions is critical for providing continuous
wastewater collection and preventing contamination of the nev
wastewater treatment facility. Remedial actions that must be
temporally coordinated include:
o Disconnection of sewer lines from the Vertac Plant site
wastewater treatment system
o Cleaning, removal, and replacement of existing collectior
lines
o Connection of cleaned, new lines to the new WWTP
o Closeout of the West WWTP
Alternative 5Old STP
As in Alternative 4, the sludge digester would be emptied anc
cleaned and the sludge drying beds excavated and backfilled.
Material from both the digester and drying beds would be
incinerated.
Other facilities that comprise the Old STP include two primarv
clarifiers, two trickling filters, and two secondary clarifiers.
All are inactive.
The water and sediments would be removed from the prima:,
clarifiers. The water (126,000 gallons) would be treated by
73 ' «
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filtration and carbon adsorption and the sediments (90 cubic yards)
dewatered and incinerated. tfb action would be taken on the two
trickling filters and two secondary clarifiers.
The Old STP grounds would be fenced and warning signs posted.
Alternative 5West WWTP
Roughly 8,000 cubic yards of contaminated sludge estimated to be
on the bottom of the aeration basin would be removed, dewatered,
and incinerated. The sludge could be removed from the bottom using
a pontoon-mounted, floating pumping system. The 37 million gallons
of water would be pumped from the aeration basin and oxidation
ponds to the onsite wastewater treatment system (see "Wastewater
Treatment" later in this section). After dewatering, the oxidation
ponds would be allowed to dry and then covered with a soil/
vegetative cap. It is assumed that the bottom sediments would dry
sufficiently to allow capping/compaction. The cap would consist
of native compacted soil covered with six inches of topsoil and a
vegetative layer, constructed so that its surface grades naturally
with the surrounding soil. Assuming an average depth of three feet
in the oxidation ponds, the cap will require 178,000 cy of native
soil and 36,000 cy of topsoil (compacted volumes). Also, the
outfall ditch from the oxidation ponds would be filled with clean
native soil, and seeded. Fences and warning signs would be
constructed around the West WWTP facilities.
Alternative 5Rocky Branch Creek and Bayou Meto Flood Plain
Soils with TCDD concentrations greater than i.o ppb would be
removed and incinerated as described in Alternative 4.
Alternative 5Rocky Branch Creek and Bayou Meto Sediments
Same as Alternatives 2, 3, and 4.
ALTERNATIVES 6A AND 6B
Figure 23 is a flow diagram of Alternatives 6a and 6b.
Alternatives 6a and 6bCollection Lines
The active sewer lines would be cleaned by hydraulic flushing as
described in Alternative 2. Sediments removed from the active
lines would be dewatered and incinerated onsite. Water from the
collection lines would be treated through sedimentation, filtra-
tion, and carbon adsorption. Pipeliners would be installed in the
clean active line as described in Alternative 3.
In Alternatives 6a and 6b, the
Branch Creek Interceptor will be
migration of contaminants in the
abandoned section of the Rock
filled with grout to reduce :
line.
75
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The grout will be placed in the old interceptor directly from ,
ready-mix truck. Grouting will begin at the manhole on the lowes-
end of the line (near the treatment plant). The grout will b<
poured into the manhole, and a concrete vibrator will be used t
force the grout into the interceptor. Pouring will be discontinue*
when the level is just above the interceptor, and no additiona
grout can be forced into the line. The operation will then mov
to the next manhole up the line, and continue until the end of th
abandoned line is reached.
The new interceptor was installed in close proximity to the ol
interceptor. In several locations, the lines cross each other
and lateral lines pass through the old interceptor befor
connecting to the new interceptor. Care must be exercised t
ensure that the new interceptor and the lateral lines are no
affected by the grouting operation. The Jacksonville Sewag<
Treatment Authority should be consulted to safeguard the opera
tion.
Alternatives 6a and 6b--Old STP
In both Alternatives 6a and 6b, the sludge in the digester wouL
be pumped out, dewatered, and incinerated as in Alternative 5
Water contained in the trickling filters and clarifiers would b<
pumped out ai:d treated through a filtration and carbon adsorptio
process. Clean water would be discharged to Rocky Branch Creek ant
the carbon and filter solids would be incinerated.
The old sewage treatment plant units will be demolished, and buriec
onsite. The primary clarifiers, sludge digester, tricklinc
filters, and curbs from the sludge drying beds, along with the pumj
house and associated structures will be torn down, usinc
conventional construction techniques, and the rubble reduced tc
debris suitable for burial. The secondary clarifiers, which ar<
below grade, will be filled with demolition debris. Remaininc
debris, including filter media from the trickling filters, will b<
consolidated in an area over the secondary clarifiers, am
compacted for stability. The fill area will be covered with <
minimum of one foot of clean soil. The sludge drying beds wi i
also be covered with one foot of clean soil.
The irregular nature of the demolition debris may cause settleme:.
of the soil cover over time. Seeding of the cover soil will :
required to reduce erosion. Periodic inspection and maintena:
will be required, including addition of soil and seeding to rep;
the cover.
Deed notices will be sought to warn against access and developr
of the old STP area.
77
-------
Alternatives 6a and 6bWest WWTP
The aeration basin would be dewatered, the water treated, and the
carbon and filter solids incinerated as in Alternative 4. The
dikes of the aeration basin would be demolished by mechanically
pushing the dike soils into the basin. The entire basin would then
be covered by one foot of clean soil.
Notices would be placed in the deeds to restrict access and use of
the West WWTP.
Alternative 6aRocky Branch Creek and Bayou Meto Flood Plain
This alternative would be identical to Alternative 5: All soils
with greater than l ppb TCDD would be excavated and incinerated.
Alternative 6bRocky Branch Creek and Bayou Meto Flood Plain
In Alternative 6b, all floodplain soils with greater than 1 ppb
TCDD would be excavated. However, in this alternative, the
excavated soils would be consolidated onsite and capped.
Approximately 4,100 cy of soil would require consolidation. Since
the material consists largely of contaminated native soil, it is
assumed that it would be compactable and that compaction would
reduce the volume of soil by 25 percent. For consolidation, the
material would be placed on the plant site and compacted into a
mound.
A multilayer cap would then be placed over the contaminated
materials. The cap would be consistent with federal and state RCRA
requirements for landfill closure. The overall surface area
required for consolidation would be roughly one acre. The native
materials required for construction of the cap would be 800 cy of
topsoil and sand; 2,400 cy of native soil; and 3,250 cy of clay.
Based on soil descriptions in the Jacksonville area, it is expected
that materials suitable for cap construction are available locally.
Alternatives 6a and 6bRocky Branch Creek and Bayou Meto Sediment
Alternatives 6a and 6b would be identical to the previous
alternatives: no action with a continued advisory against fish
ingestion and further monitoring of fish.
COMMON REMEDIAL ACTIVITIES
Incineration, solids dewatering, and wastewater treatment are rem<
dial activities that are common to more than one remedial actn
alternative. To reduce repetition, these activities are discuss.
under separate headings below.
78
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Incineration
This section discusses onsite incineration and related issues fo
Alternatives 2 through 6. Each of these alternatives include
onsite incineration with an assumed "mobile" or "transportable
rotary kiln incinerator. The use of the rotary kiln process wa
selected for detailed development and evaluation because of it
versatility in treating a range of wastes, its successful use a
several hazardous waste sites, and its success in destroying TCD
wastes.
There is a range of trailer-mounted rotary kiln incineratio
equipment available from several incineration vendors. Three basi
system sizes currently available on the market include:
o Small mobile system. Approximately 5,000,000 t
10,000,000 Btu per hour; one or two standar
semitrailers; maximum processing rate of 0.5 to one to
per hour of low Btu content, low moisture conten
contaminated soils.
o Large mobile system. Approximately 30,000,000 Btu pe
hour; three to 10 standard semitrailers; maximu
processing rate of four to five tons per hour of low Bt
content, low moisture content contaminated soils.
o Transportable system. Approximately 60,000,000 Btu pe
hour; approximately 50 to 70 standard semitrailer
(complete modularized ancillary support facilities, nig
degree of system redundancy) ; maximum processing rate o
15 to 25 tons per hour of low Btu content, low moisturi
content contaminated soils.
The trailer-mounted incineration technology has been developim
rapidly in recent years. Several vendors are currently developing
more efficient systems that minimize combustion air and allo1
higher waste throughput. Improvements in waste feed systems
process operation for wastewater minimization, and air emissio
control systems are also under development.
The actual size and type of incinerator would be determined b
competitive bidding and would depend on waste volumes, wast
characteristics, site location constraints, utility suppor
requirements, and final performance specifications fo
incineration.
Potential alternative-specific incineration scenarios for t:.
Vertac off-site wastes are shown in Table 7.
79
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Alternative
2
3
4
5
6a
Table 7
Alternative-Specific Rotary Kiln Incineration Scenarios
Assumed Waste
Volume for
Incineration
Tons
260
3,400
11,900
22,000
4,650
Probably Rotary
Kiln System
Small mobile
system
Small to large
mobile system
Large mobile or
transportable
system
Large mobile or
transportable
system
Small to large
mobile system
Approximate
Footprint
Size (acres)
0.25 to 0.5 '
0.5 to 1.0
1.0 to 2.0
1.0 to 2.0
.75 to 1.25
Approximate
Incineration
Rate
(tons/hour)
0.3 to 1
1 to 3
3 to 15
3 to 15
2 to 4
Incinerator
Operating
Time
(months)*
0.5 to 1.5
2 to 7
2 to 8
3 to 14
2 to 7
aBased on 70 percent operating factor (17 hours per day).
CVOR195/116.51
-------
Basic Incineration System Description
A generic rotary kiln process flow diagram is shown in Figure 24.
Onsite rotary kiln incineration systems for Alternatives 2 througl-
6 would include:
o Feed storage. Feed storage would include a minimum one-
week inventory of solid wastes to allow for continuous
operations. An enclosed feed building would likely be
needed for control of fugitive particulate emissions.
Conveyor systems or other feed systems would be enclosed.
o Feed preparation. The waste feed may require some waste
size classification and/or size reduction processing
prior to incineration. Any large rocks or heavy objects
greater than four to six inches in diameter would require
waste feed preparation. Depending on the quantity anc
nature of the objects they may be processed througl-
shredders or crushers and fed to the incinerator or
separated out, decontaminated, and sent to a RCRA or, if
possible, a sanitary landfill.
o Primary and secondary combustion chambers. Organic
wastes are destroyed by combustion in the primary anc
secondary combustion chambers. The efficiency of
combustion is dependent on temperature, residence time,
and contacting of fuel, combustion air, and waste
materials. In accordance with the January 1989 Title 40
Code of Federal Regulations (CFR) Part 264 Subpart 0,
incinerators at Superfund sites must provide
99.9999 percent destruction and removal efficiency (six
nines ORE) for F-listed hazardous wastes. Typical
operating temperatures to achieve such DRE's are 1,800 F
for primary combustion chambers and 2,200°F for secondary
combustion chambers.
o Air pollution control system. Air emissions frorr
incineration depend on several factors, including:
Waste composition
Feed rate and method
Combustion design
Combustion air rate
Air emission control systems
The first four factors determine the type and rate
of air pollutants generated, and the fifth
determines the percentage of these pollutants
discharged into the atmosphere. Typical air
emissions control systems include a combination of
quench towers, scrubbers, demisters, electrostatic
81
-------
2 <
z 5
't
-------
precipitators, and fabric filters. For this study,
the assumed air emission control systems include
quench towers, wet scrubbers, and demisters.
Table 8 lists general air contaminants and pertinent
air regulations and standards.
o Wastewater processing and treatment system.
Typically, onsite rotary kiln incineration systems
generate scrubber blowdown brine that must be
treated before discharge. Scrubber water is
typically recycled within the system to minimize
blowdown. In this study, it is assumed that
blowdown brine would be treated with a pH
adjustment/precipitation system with filtration and
solids dewatering. Dewatered solids would be
managed as RCRA-listed wastes and probably would
require disposal at a RCRA landfill. The TCDD
concentration in the extract from the dewatered
solids must be less than 1 ppb to meet land disposal
restrictions (LDR), as determined by the toxicity
characteristic leaching procedure. Treated
wastewater would be managed as RCRA-listed wastes
and probably would be discharged to surface water
under National Pollutant Discharge Elimination
System (NPDES) discharge criteria. Alternately, it
may be possible to evaporate/concentrate the
blowdown brine to form solid wastes that would
likely require disposal at a RCRA landfill (subject
to LDR).
o Ash storage. A one-week enclosed ash storage
stockpile facility is assumed in this study. The
ash would presumably be tested in batches for
residual TCDD and other toxics and would be
transported and disposed at a RCRA landfill.
o Ancillary support facilities. Ancillary support
facilities would presumably include fuel storage,
onsite analytical facilities, and site personnel,
decontamination, and administration trailers.
Other Incineration Options
There are currently no incineration facilities off the site wit)
permits to burn dioxin wastes.
At least one facility off the site currently has an approved RCP;
Part B permit, is permitted to burn PCB wastes, and has applied t^:
a permit to burn dioxin wastes. Even with the approval to b',::-
dioxin wastes, incineration off the site would likely not be coc
83
-------
Table 8
Air Contaminants, Regulations, and Standards
Air Contaminant
Paniculate Matter (PM)
Sulfur Dioxide (SOj)
Carbon Monoxide (CO)
Nitrogen Dioxide (NO2)
Lead (Pb)
Ozone
Hydrochloric Acid (HC1)
Pertinent Air
Regulation
PM-10*
40 CFR 264.340b
PAAQS0
40 CFR 264.340
PAAQSC
PAAQSC
PAAQSC
PAAQSC
40 CFR 264.340
Emission Standard
50 Mg/m3 annual arithmetic mean (AAM)
150 Mg/m3 (24-hour max)d
0.08 grains/dscf
80 Mg/m3 or 0.03 ppm (AAM)
365 Mg/m3 or 0.114 ppm (24-hour max)d
10,000 Mg/m3 or 9 ppm (8-hour max)d
40,000 jig/m3 or 35 ppm (1-hour max)d
100 ppm 1-hour rolling average)
500 ppm (10- minute rolling average)
10,000 Mg/m3 or 9 ppm (8-hour max)d
100 fig/m3 (max calendar quaner arithmetic
mean)
1.5 jig/m3 (max calendar quaner arithmetic
mean)
235 Mg/m3
Less than 4 Ib/hr or 99 percent control efficiency
aPM-10 = Paniculate matter less than iOtmkrons (respirable particulates).
^uperfund incinerators must meet RCRA requirements as outlined in Title 40 Code of Federal
regulations Pan 264, Subpart 0.
°PAAQS = Primary Ambient Air Quality Standards (criteria pollutants).
dNot to be exceeded more than once per.year.
CVOR195/115.51
-------
effective, evert for the relatively small volume in Alternative 2.
Incineration off the site probably would require:
o Drum purchase
o Handling and drumming of TCDD wastes
o Transport of drummed wastes several hundred miles
o Incineration at premium prices (costs would likely b«
significantly greater than the approximate $2,000 per tor
rate to incinerate drummed PCB wastes)
Solids Dewatering
A mobile plate-and-frame filter press would be employed foi
dewatering sludge and sediment under Alternatives 2 through 5.
Approximately 900 cy of material would be dewatered ir
Alternatives 2 through 4, and 6, whereas approximately 9,000 cy oi
material would be dewatered under Alternative 5. Table 9 lists the
materials to be dewatered, their volumes, and assumed solids
contents.
The mobile plate-and-frame filter presses available typically have
capacities of 2.0 to 2.5 cy per cycle. Cycle times vary depending
on the material being treated, but 1.5 hour is a representative
duration. One of those dewatering units would be adequate for
implementing Alternatives 2, 3, 4, or 6, while multiple units would
be employed if Alternative 5 were implemented.
Wastewater Treatment
Use of a mobile water treatment system is assumed for treatinc
miscellaneous wastewater in Alternatives 2 through 6. Table 1C
lists wastewater information for these alternatives.
Figure 25 shows a wastewater treatment schematic for the mobile
treatment processes conceptualized in these alternatives. The use
of carbon adsorption treatment is consistent with the current
onsite treatment of leachate collected in the French drain system.
All discharges would comply with the NPDES requirements and
treatment standards. All solid residuals (filter spools, spent
carbon, etc.) resulting from treatment would be incinerated.
ARARS FOR THE VERTAC OFF-SITE AREA
CHEMICAL-SPECIFIC ARARS FOR THE VERTAC OFF-SITE AREA
The scope of this study includes only 2,3,7,8-TCDD as t>>-
contaminant of concern. Currently, there are no chemical-specit .
ARAR's for 2,3,7,8-TCDD. There are, however, a number of hea1.
85
-------
Table 9
Solids Dewatering Data
Alternative
2-4, and 6
5
Material
Collection line sedi-
ment
Digester sludge
Digester sludge
Primary clarifier sedi-
ment
Aeration basin sedi-
ment
Estimated Initial
Volume (cy) Assumed
Solids Content
10 (20%)
890 (5%)
890 (5%)
90 (5%)
8,000 (5%)
Estimated Final
Volume (cy) Assumed
Solids Content
6.7 (30%)
300(15%)
300 (15%)
30 (15%)
2,700(15%)
-------
Table 10
Volume and Disposition of Wastewater
From Alternatives 2 Through 6
Alternative
2,3,4,6
5
Description
Filtrate from dewatering
sewer sediments after
hydraulic flushing
Filtrate from dewatering
sludge digester sludge
Decontamination and
miscellaneous liquids
Pump water from
aeration basin
Wastewater from primary
clarifiers
Wastewater from
oxidation ponds and
aeration basin
Decontamination liquids
and miscellaneous
collected wastewater
Estimated
Volume (gallons)
72,000
130,000
50,000
6,800,000
126,000
37,000,000
50,000
Disposition
Treat in mobile system;
NPDES discharge
Treat in mobile system;
NPDES discharge
Treat in mobile system;
NPDES discharge
Discharge to oxidation
ponds
Discharge to oxidation
ponds
Treat in mobile system;
NPDES discharge
Discharge to oxidation
ponds
Note: Scrubber blowdown discussed under general discussion of incineration.
NPDES permit not required but must meet substantive requirements.
-------
l/l
O
z
-------
advisories and suggested cleanup criteria that could be TBC's for
the Vertac off-site remedial action.
The most important TBC is in the April 24, 1986, memo from the
Agency for Toxic Substances and Disease Registry (ATSDR) to EPA
Region 6 (see Appendix B). This memo recommends cleanup levels
specific to the Vertac off-site area. Another important TBC is the
January 26, 1989, memo from EPA to ATSDR stating that the highest
concentration of TCDD found in the Rocky Branch Creek and Bayoi
Meto sediments does not pose an unacceptable health threat
(Appendix A).
The EPA l-ppb action level previously employed at other TCDD-
contaminated sites (EPA, 1987) is also an important TBC. That
level was based on a Centers for Disease Control (CDC)
recommendation developed primarily for long-term direct contact
with TCDD-contaminated soils in residential areas (Kimbrough et al.
1984).
Other TBC's that could be of use include proposed advisories or
protection of human health and aquatic life developed under the
Clean Water Act. The advisories for aquatic life are specific tc
individual fish species, and may have to be adjusted for conditions
in Rocky Branch Creek. These criteria should be consulted tc
determine design goals for the wastewater treatment system included
in Alternatives 2 through 6.
LOCATION-SPECIFIC ARAR'S FOR THE VERTAC OFF-SITE AREA
Location-specific ARAR's have been evaluated for the Vertac off-
site area as a whole. Table 11 includes the location-specific
requirements identified as ARAR's.
The federal regulations that form the list of potential location-
specific ARAR's include the Resource Conservation and Recovery Act
(RCRA), the National Archaeological and Historic Preservation Act,
the National Historic Preservation Act, the Endangered Species Act,
the Clean Water Act, the Wilderness Act, the Fish and Wildlife
Coordination Act, the Scenic Rivers Act, the Coastal Zone
Management Act, the Marine Protection Resources and Sanctuary Act,
and the Executive Orders on the Protection of Wetlands and the
Protection of Flood Plains. No State of Arkansas regulations were
identified that addressed other location-specific requirements or
that were more strict than federal regulations.
Location-specific ARAR's that will be applicable or relevant a;u
appropriate to the Vertac off-site area include flood pla::
requirements and requirements under the Fish and Wildlit-
Coordination Act.
Flood Plain Requirements. Under RCRA, any hazardous wa
treatment, storage, or disposal facility constructed within a
89
-------
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endangered
cies are kno
iting
Aw
status
No e
speci
site.
site s
3
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xecutive Order 1
rotection of Flood Plains,
40 CFR 6, Appendix A)
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lands.,
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tive
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of endangered
tened species
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Table 1 1
Identification of Potential Locatk
For Vcrtac Off-clte Area (page 2 o
A
e
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2
1 Citation
PrereqMlalle(a)
i
i
r
at
e
!
2
Nol a wilderness ar
2?
%
I
Wilderness Acl (16 USC
1131 el seq ); SO CFR 35.1 el
!3
Federally owned area designated as
wilderness area
11-
.5 ,«
e S.'u
administered i
1 leave it unim
and 10 preserv
iracter
i!!i
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Nol a wildlife re-lug*
%
2j
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16 USC 668 dd cl scq ; 50
CFR Pan 27
Area designated as pan of
National Wildlife Refuge System
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fill I
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Any remedial action
adversely affect Hoc
Bayou Melo must tx
with Ihe Departmeni
Wildlife
a
3
1
Fish and Wildlife
Coordination Acl (16 USC
661 el seq.); 40 CFK 6.302
Diversion, channeling, or other
activity that modifies a stream or
nver and affects fish or wildlife
u
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1.2
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Kocky Branch and 1
are not classified as
scenic nvers
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Activities that affect or may affect
any of Ihe riven specified in
Section I276(a)
i s
N
or assisting in i
direct adverse
r
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551
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The site is not wilhi
zone
^
5§
i
Coastal Zone Managemeni
Acl (16 USC Section 14SI el
seq)
Activities affecting Ihe coasul zone
including lands thereunder and
adjacent shorelands
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No dredge disposal i
walen of the United
included in the rcmc
alternatives for Ihe V
area
s?
$*
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Clean Water Acl Section 404
40 CFR !25Subpan M;
Manne Protection Resources
and Sanctuary Acl Section
103
Oceans and walen of Ihe United
Stales
g
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100-year flood plain must be designed, constructed, operated, and
maintained in a manner that will avoid washout of hazardous waste
during a 100-year flood (40 CFR 264.18(b)). For any activity that
occurs in a flood plain, Executive Order 11988, Protection of Flood
Plains, requires action to avoid adverse effects, minimize
potential harm, and restore and preserve natural and beneficial
values.
Since the Vertac off-site area is within a flood plain,
Alternatives 2 through 6 must comply with the requirements listed
above. For Alternatives 2 and 6b, the RCRA requirements would be
especially important for onsite consolidation. Construction of
treatment facilities in Alternatives 2 through 6 would also be
subject to the RCRA requirements.
Fish and Wildlife Coordination Act. Any action that might modify
or adversely affect a river or stream is subject to review by the
state fish and wildlife agency under the Fish and Wildlife
Coordination Act. This act requires protection of fish and
wildlife in riparian areas. Discharge of treated wastewater
effluent and continued discharge of water from the oxidation ponds
would require coordination with ADPC&E.
ACTION-SPECIFIC ARAR's FOR THE VERTAC OFF-SITE AREA
Appendix D identifies potential action-specific ARAR's. Action-
specific ARAR's are discussed further in the analysis of the
alternatives and, in particular, in the analysis of the common
elements of the alternatives.
RCRA ARAR'S
EPA has made several determinations regarding RCRA ARAR's at the
Vertac off-site areas. These are presented below and discussed in
greater detail in Appendix D.
Wastes that are part of a permitted discharge to a publicly-owned
treatment works (POTW), are regulated under the Clean Water Act,
and are exempt from regulation under RCRA as long as the wastes
remain in place. Therefore, RCRA hazardous waste management
requirements are not applicable to wastes in the collection lines.
Old STP, or West WWTP. For the collection lines, EPA has
determined that RCRA may be relevant but not appropriate due t -
depth of the lines (three to 15 feet) and the absence of a direct
exposure route. Similarly, for the Old STP and West WWTP, RCRA .s
relevant but not appropriate because of the low Tcr^
concentrations, which are below ATSDR action levels (except t :
sludge digester). EPA has determined that material removed t r ~,
the collection lines or sludge digester must meet RCRA hazard. ,
waste management requirements.
-------
The Rocky Branch Creek and Bayou Meto flood plain soils do no
represent a RCRA unit and, therefore, RCRA is not applicable
However, if soils or sediments are excavated, they must be manage
in accordance with RCRA hazardous waste management requirements.
Another important RCRA determination addresses the ash generate
from incineration in each of the alternatives. The status of as
from incineration depends on the material being burned:
o Ash from incineration of dioxin wastes must meet a
treatment standard (less than 1 ppb of dioxin in
extract from TCLP test) before it can be disposed
of in land-based RCRA-hazardous-waste disposal
units.
o The ash generated by incinerating F020-listed
hazardous waste is classified as a hazardous waste
(F028).
o The ash from incinerating wastes and soils not
classified as hazardous is not classified as a
hazardous waste.
o If the hazardous and nonhazardous ash are mixed,
the mixture is a listed waste.
93
-------
VIII.' SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA uses nine criteria to evaluate relative performance of each
alternative. The nine criteria are categorized into three
groups: Threshold criteria (overall protection of human health
and the environment and compliance with ARAR's), primary
balancing criteria (long-term effectiveness and permanence,
reduction of toxicity, mobility, and volume through treatment,
short-term effectiveness, implementability, and cost), and
modifying criteria (State and community acceptance). 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.
Table 12 provides a comparative analysis of alternatives.
Overall Protection of Human Health and The Environment. All
of the alternatives, with the exception of the "no action"
alternative, would provide a certain level of protection of
human health and the environment by eliminating, reducing, or
controlling risks through treatment, capping, or deed and land
use restrictions. Alternative 5 is the most protective action
alternative since human health and environmental risks
associated with exposure and migration of contaminated material
in and around the active and abandoned sewer lines, sludge in
the digester, contaminated soil in drying beds and Rocky Branch
flood plain and contaminated sediments in the primary
clarifiers, aeration basin, and oxidation ponds would be
eliminated. Alternatives 4, 6a and 6b provide the same degree
of overall protection relative to each other by eliminating or
reducing risks associated with the contaminated sediments in
the sewer lines, sludges and sediments in the sewage treatment
plants and the contaminated soils in the residentially zoned
areas. Alternative 3 is less protective than Alternatives 4,
5, 6a and 6b because contaminated soil with TCDD >5 ppb would
remain in the Rocky Branch flood plain. Alternative 2 is the
least protective action alternative because very few areas
would be remediated in this alternative.
In addition to the protection of the environment provided by
the action alternatives noted above, all of the action
alternatives provide that the commercial fishing ban will
remain in effect, that the advisory against ingestion of fish
taken from Rocky Branch Creek and Bayou Meto will continue and
that fish and wildlife will continue to be monitored. However,
no TCDD-contaminated sediments will be removed from Rocky
Branch Creek or Bayou Meto. The specified remedy for the creek
and bayou sediments is the most protective remedy of th«=
alternatives available. Any removal of contaminated sediment:;
94
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from the creek or bayou could resuspend the sediments and
release contaminated sediments downstream, resulting in
exposing the environment, in particular fish, to additional
TCDD exposure. Such removal of sediments would also very
likely result in loss or destruction of fish habitat and more
overall destruction of the environment than leaving the
sediments in place. The U. S. Fish and Wildlife Service has
recommended that the sediments in the creek and bayou not be
disturbed for these reasons. Therefore, the remedy for the
creek and bayou sediments is more protective of the environment
than any removal of the sediments, even though it may result
in fish and other biota being exposed to low levels of TCDD.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs). The "no action" alternative does not
comply with ARAR's since contaminated soils/sludges with
concentrations exceeding the ATSDR-recommended action level
would be left. Alternatives 2 and 3 also would not comply with
ARAR's, unless the zoning of the undeveloped residential area
south of Vertac is changed from residential to
commercial/industrial. Alternatives 4, 5, 6a and 6b meet or
exceed the ARAR's and remedial action goals.
Long-Term Effectiveness and Permanence. Alternative 5 has the
lowest residual risks of all the alternatives, since a large
volume of contaminated material would be destroyed.
Alternatives 2 and 3 have the highest residual risk of the
action alternatives, since soils having a dioxin concentration
higher than 1 ppb would remain in the Rocky Branch flood plain
south of the plant and very little contaminated materials are
destroyed. Alternative 4 provides more long-term protection
and permanence than Alternatives 2, 3, 6a and 6b because more
contaminated material is destroyed. Alternatives 6a and 6b are
more protective and permanent than Alternatives 2 and 3.
Alternative 6a is more protective and permanent because the
contaminated floodplain soils are incinerated rather than
consolidated onsite.
Reduction of Toxicity. Mobility, or Volume of Contaminants
through Treatment. Alternative 1 does not reduce toxicity,
mobility, or volume of contaminants present in the off-site
areas. In Alternatives, 2, 3, 4, 5, 6a and 6b, approximately
260, 1,550, 9,950, 25,480, 5,250, and 1,150 cubic yards ot
contaminated soils/sludges/sediments would be treated by
incineration, respectively. However, in Alternatives 4 and 5,
buried sewer lines (abandoned line in alternative 4 and both
abandoned and active lines in Alternative 5) would be excavated
and incinerated. Excavation and incineration of the sewer
lines is considered unnecessary for protection of public
health.
98
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Short-Term Effectiveness. This criterion is not applicable to
Alternative 1, because no action will be taken. Alternatives
2 and 3 provide the greatest short-term effectiveness, assuming
access to the contaminated areas is effective, and because they
include the smallest amount of construction activities that
could cause short-term adverse impacts on workers and the
community. However, since land use controls are difficult to
enforce and must be negotiated with landowners, the short-
term effectiveness of these is questionable. Alternatives 4
and 5 offer the lowest degree of short-term effectiveness
because they involve the largest amounts of construction
activities and thus would result in the greatest impact to
workers and the community. Alternatives 6a and 6b provide a
moderate amount of short-term effectiveness because threats are
addressed, yet the construction will cause a moderate amount
of impacts to workers and the community.
ImplementabilitY- Alternative 1 is no action and therefore
easily implementable. The remaining alternatives are
implementable. Implementing Alternatives 2 and 3 require
changing the zoning of undeveloped residential area south of
the Vertac plant site from residential to
commercial/industrial. This change in zoning may be difficult
to accomplish because it would require negotiating these
changes with landowners, particularly the owners of the western
floodplain of the west fork of Rocky Branch Creek. For
Alternatives 3, 4 and 5, the large amounts of material required
for berming and/or capping oxidation ponds may be difficult to
obtain locally. Alternatives 6a and 6b would be the easiest
to implement among the action alternatives because no change
in zoning would be required, and no large amounts of material
would be required for berming and/or capping of oxidation
ponds.
Cost. The cost of and time to implement each alternative is
shown below:
Alter-
native
1
2
3
4
5
6a
6b
Capital
Cost
-0-
3,900,000
7,600,000
20,000,000
38,000,000
13,400,000
10,400 ,000
Annual O&M
First
Year
-0-
35,000
61,000
110,000
200,000
57,000
72,000
After
First
Year
(2-30 Yrs)
-0-
33,000
45,000
66 ,000
150,000
46 ,000
58,000
30-Year
Present
Value Cost
(5% Dis-
count Rate
-0-
4,000,000
8,000,000
21,000,000
40,000,000
14,000,000
11,000,000
Years
to
Imple-
ment
-0-
4
4
5
5
4
4
99
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State Acceptance. The State of Arkansas is in general
agreement with the proposed remedy. However, the State has
requested EPA to carefully evaluate the advantages of
excavating the contaminated soil in the Rocky Branch flood
plain against the resulting ecological damage and cost from
excavation, before selecting the remedy. The State also
recommends that, since it has been some time since the sewer
lines, sewage treatment plants and floodplains have been
sampled, these areas be resampled prior to being remediated.
Community Acceptance. The community response was generally
favorable to the proposed remedy, except that several citizens
are opposed to onsite incineration. Specific responses to
public comments are addressed in the responsiveness summary.
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IX. ' THE SELECTED REMEDY
The remediation goals for the Vertac off-site area are:
1. Residential and agricultural areas should be remediated
to 1 ppb TCDD.
2. For nonresidential/nonagricultural areas (Old STP, West
WWTP), prevent direct public contact with contaminated
soils containing TCDD concentrations above 1.0 ppb
TCDD. For the Old STP and West WWTP, this action level
is 1.0 rather than 5 to 7 ppb TCDD as recommended by
ATSDR, because levels above 1 ppb still represent a low
level risk to the public that can be eliminated through
cost-effective measures such as soil capping. Public
access to these areas was demonstrated when persons
used the sludge drying beds for gardening.
3. Prevent migration of TCDD-contaminated soils into the
waterways and surrounding flood plains.
4. Prevent migration of TCDD-contaminated sediments
through the sewage collection lines to the new
Jacksonville sewage treatment facility.
The selected remedy is Alternative 6a, with some minor
modification to address comments by the State of Arkansas. The
major components of the selected remedy include:
Sewage Collection Lines Sediments would be
removed from the active sewage collection lines
between the Vertac plant site and the West
Wastewater Treatment Plant and incinerated onsite.
Pipe liners would be installed in the cleaned sewer
lines. Cleaning the line and installing the pipe
liner will allow the interceptor to be routed to the
new Jacksonville sewage treatment facility, without
contaminating the new facility. The abandoned line
would be filled with grout to reduce the migration
of contaminants in the line.
Old Sewage Treatment Plant The sludge would be
removed from the sludge digester and incinerated
onsite. The sludge drying beds would be capped with
one foot of clean soil. Accumulated water in the
treatment units would be removed, treated and
discharged, and the treatment units would be
demolished and capped with one foot of clean soil.
EPA win negotiate with the City of Jacksonville to
place a notice in the deed recommending that the Old
101
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STP site zoning remain commercial/industrial and
access be restricted.
o West Wastewater Treatment Plant -- The aeration
basin would be drained, the dikes demolished, and
the entire basin capped with one foot of clean soil.
A notice would be placed in the deed recommending
that the West WWTP site zoning remain
commercial/industrial and access be restricted.
o Rocky Branch and Bayou Meto Flood Plain In order
to minimize ecological damage to the floodplain and
to the downstream areas, the floodplain areas that
are currently residentially zoned will be resampled
and only those areas with actual 2,3,7,8
tetrachloro-dibenzo-p-dioxin (2,3,7,8 TCDD) levels
greater than 1.0 ppb will be removed and incinerated
onsite.
o Rocky Branch Creek and Bayou Meto Monitor fish
in these streams for dioxin and continue ban on
commercial fishing and advisory discouraging sport
fishing as long as fish tissue dioxin levels are
above Food and Drug Administration alert level.
The implementation of the selected remedy will result in the
reduction of carcinogenic risk from being as high as 10"3 due
to the sewer line sediments to the 10 5 to 10 6 range, depending
on the point of exposure.
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X. . THE STATUTORY DETERMINATIONS
The remedy selected must satisfy the requirements of Section 12:
of CERCLA to:
o Protect human health and the environment;
o Comply with ARAR's (or justify a waiver);
o Be cost-effective;
o Utilize permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent practicable; and
o Satisfy the preference for treatment as a principal
element or justify not meeting the preference.
A discussion of how the selected remedy satisfies these statutory
requirements is presented below:
Protection of Human Health and The Environment. Implementation o:
the selected remedy would eliminate the risk of exposure o
migration associated with contaminated sediments in the active
sewer lines, sludge in the digester, and Rocky Branch Creek flooc
plain soils containing greater than 1 ppb TCDD. The removec
sediments, sludge, and excavated contaminated soil would b
incinerated. The grouting of the abandoned Rocky Branch
interceptor will minimize the potential for further contaminant
migration in those lines. Demolition of the old STP structures,
burial onsite, and capping will reduce the potential for future
exposure to these contaminated materials. Capping of sludge dryinc
beds will eliminate the risk of agricultural use of the drying beds
and the potential for migration of contaminated soil. Dewaterinc
and capping of the aeration basin in the West Wastewater Treatment
Plant will reduce the risk of exposure to contaminated sediments
and eliminates the potential for migration.
Compliance with ARAR's. The selected remedy will comply with al.
ARAR's. The selected remedy addresses contamination in the active
sewer lines, sludge digester, and Rocky Branch Creek flood plair
soils to the levels recommended by ATSDR for each area. Sediments
from active sewer lines, sludge from the digester, and Rocky Branc:
Creek contaminated floodplain scils would be incinerated. RCP;
hazardous waste management requirements would be applicable :-:
removal and treatment of these wastes.
Solids dewatering prepares solid wastes for treatment in the ons:
incinerator. The RCRA hazardous waste management requirements
relevant and appropriate to the dewatering process and manager'
103
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of residuals. (See Appendix D for RCRA requirements for container
storage', tank storage, and treatment.)
Onsite incineration would treat (destroy) dioxin in contaminated
materials, and would satisfy RCRA hazardous waste disposal
requirements. (See Appendix D for RCRA requirements for
incineration, treatment, and tank storage.)
The flushing water from collection lines, liquid from solids
dewatering, liquid decontamination wastes, and scrubber blowdown
water from incineration would be treated by an onsite filtration
and carbon adsorption treatment system. Wastewater treatment
standards for liquids contaminated by dioxin are not specified by
RCRA. However, treated effluent would meet the substantive
requirements of the National Pollutant Discharge Elimination System
(NPDES). Effluents regulated by the Clean Water Act are not
hazardous wastes, by definition. However, the RCRA hazardous waste
management requirements would be applicable to management of the
residuals from the treatment process. (See Appendix D for
requirements for container storage, direct discharge of effluent,
tank storage, and treatment.)
RCRA hazardous waste management requirements are considered
relevant to the contamination in and around the abandoned
collection lines, but not appropriate because there is little risk
of exposure. Therefore, although there is no ARAR requiring
grouting, this remedy component provides a cost-effective means of
minimizing further contaminant migration through the collection
lines.
Cost Effectiveness. The 30-year present value cost for the
selected remedy is estimated to be $14,000,000 and is moderate when
compared to the most expensive alternative, which would cost
$40,000,000 (30-year present worth). The selected remedy provides
a similar degree of protectiveness as the most expensive
alternative but is much less expensive. The less costly
alternatives do not afford adequate protection of human health and
the environment and they are not considered appropriate.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologist to the Maximum
Extent Practicable ("MEP"). The selected remedy meets the
statutory requirement to utilize permanent solutions and treatment
technologies, to the maximum extent practicable, because
approximately 5250 cubic yards of contaminated materials would be
permanently destroyed. Alternative 6a was selected because this
alternative is protective of human health and the environment,
complies with all ARAR's, reduces the toxicity, mobility, a:.-1.
volume of the contaminants to the maximum extent practicable, .
implementable and is the most cost-effective. Alternatives 4, .
6a, and 6b provide similar degrees of protectiveness, but the co^-
for Alternatives 4 and 5 are much higher (1.5 times to about th:
104
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times higher than the cost for the selected remedy) . These tw
alternatives involve tasks not considered necessary for protectio
of human health, such as excavation and incineration of sewe
lines. Alternatives 6a and 6b are identical, except that i
Alternative 6a the soils excavated from the Rocky Branch Cree
flood plain would be incinerated, whereas in Alternative 6b tf
excavated soil would be consolidated onsite and cappec
Alternative 6a was chosen because this alternative utilizes a mor
permanent solution and treatment technology to a greater exter
than Alternative 6b.
Preference for Treatment As A Principal Element. By treating tl"
dioxin contaminated soils/sludges/sediments in a thermal treatmer
unit, the selected remedy addresses the principal threats posed t
the site through the use of treatment technologies. Therefore, tl-
statutory preference for remedies that employ treatment as
principal element is satisfied.
105
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XI. , DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed Plan for the Vertac site was released for public
comment in July 1990. The Proposed Plan identified Alternative 6a,
incineration of removed soils/sediments/sludges, capping of drying
beds, demolished STP structures, aeration basin, etc., 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.
106
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XII. RESPONSIVENESS SUMMARY
The following is a summary of the questions and comments receive
at the public meeting and during the public comment period. Mar
of the comments received relate to the Vertac site, in general, ar
not specifically to the proposed plan for the Vertac off-sit
areas. Most of the questions and comments received regardir
incineration were made with respect to the State of Arkanse
incineration of the 28,500 drums of dioxin waste on the Verta
plant site. The responses to these questions are meant as
response to both the incinerator currently onsite and ar
incinerator to be built onsite for destruction of the contaminatic
from the Vertac off-site areas. Comments received from Hercules
Inc. , a potentially responsible party, are summarized separate:
in this Responsiveness Summary.
TOXICOLOGY AND HEALTH CONCERNS
COMMENT #1: What is the basis for the Toxicological Profile c
dioxin which was distributed at the meeting?
RESPONSE: The Toxicological Profile was based on a review of al
of the literature on dioxin. The profile was compiled by Syracus
Research Corporation for the Agency for Toxic Substances ar
Disease Registry and EPA.
COMMENT #2: What is the airborne standard for dioxin which i
considered to be dangerous?
RESPONSE: The action level set by the Center for Disease Contro
for airborne dioxin is 5.5 picograms per cubic meter. This is th
level which is considered safe. EPA has set a working action leve
of 3.0 picograms per cubic meter, which includes additional safet
factors.
COMMENT #3: Why are silvex, xylene, chlordane, mirex, heptachlcr
toluene, aldrin, dieldrin, DDT, lindane, and toxaphene no
discussed with respect to the site?
RESPONSE: Dioxin is used as an indicator compound for the abcv
listed compounds. Dioxin is considered to be much more toxic v
if the soils are cleaned up to the dioxin cleanup levels, the ot:
compounds will also be cleaned up. In addition, many of
compounds listed above are highly volatile or biodegradable,
therefore, are not likely to currently exist at levels of conce:
COMMENT #4: Why will a health study not be done until 1991?
EPA not giving the citizens of Jacksonville a fair health s-
because Vertac produced Agent Orange for the Government?
107
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RESPONSE: The Arkansas Department of Health has established a
community panel so that the citizens of Jacksonville will have
input on what they would like to see in a health study relating to
the Vertac site. The Agency for Toxic Substances and Disease
Registry win support the study by providing help on the final
study design and review.
COMMENT #5: Will the results of the National Dioxin Study be used
as a basis for the health assessment?
RESPONSE: The National Dioxin Study focused on levels of dioxin
in the environment (i.e.,in the soil, water, and fish tissue) not
on health effects from dioxin. However, there is a registry of
workers exposed to dioxin, which is kept by the National Institute
of Occupational Safety and Health. The institute monitors the
health of these workers and their families. A series of initial
reports are due to be published over the next six months.
COMMENT #6: Why is the cleanup level of 1 ppb dioxin being used
when more recently published data indicates a higher value of 100
ppb for a cleanup level?
RESPONSE: The 1.0 ppb clean-up level for dioxin is used for
residential areas by EPA because it is within the acceptable risk
range set by the National Contingency Plan and is recommended by
the Agency for Toxic Substances and Disease Registry. It has been
used at numerous other dioxin sites. According to the EPA accepted
methodology for calculating risks, a 100 ppb clean-up level would
leave a residual risk in excess ^of 10"3, which is far above the
accepted risk range of 10~4 to 10 6.
COMMENT #7: If the contamination has not caused any health
problems or migrated in the last 40 years, why can't the material
sit there for another 40 years?
RESPONSE: The offsite contamination does not appear to have caused
any health problems, but uncertainties in this assessment do exist
and the offsite contamination does pose a risk to human health and
the environment and, thus, should be remediated. Dioxin has been
seen to migrate downstream through the sediments and has been
detected in fish tissue. Even though a decrease in dioxin
concentrations in the stream sediments and the fish tissue has been
observed, the removal of the contaminated materials in the
floodplain will expedite the cleansing of the system.
INCINERATION
COMMENT #1: Will particulate matter and contamination be spre.i :
out over Jacksonville during incineration?
RESPONSE: No. The particulates are limited by the air standar
which are required to be met by the particulate removal syste:-
108
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any hazardous waste incinerator. The removal system on th
incinerator that is currently constructed onsite is designed t
remove the particulates down to 1/6 of the air standard. Wit
respect to contamination, any incinerator used to destroy dioxi
contaminated waste at the Vertac site will be designed and require
to destroy or capture 99.9999% of the contamination in th
material. In addition, EPA will be monitoring air quality at tl"
site regularly.
COMMENT #2: How will EPA monitor the performance of tf
incinerator?
RESPONSE: The performance of the incinerator currently buil
onsite and of any future incinerator built onsite will be monitore
through the operating parameters which will be set during the tes
burn. The purpose of the test burn is to define the specific moc
of operation needed to operate at the 99.9999% destruction remove
efficiency level. Once these parameters are established, they mus
be met at all times during incinerator operation. In addition, EP
will be monitoring the air quality around the site during tf
operation of the incinerator.
COMMENT #3: Who will be responsible for shutting down tl"
incinerator if there is a problem?
RESPONSE: During the State incineration of the drums, the Stat
and their contractor will be responsible for shutting down tl"
incinerator if there is a problem. EPA will be monitoring tl"
performance and will coordinate closely with the State during tl"
incineration of the drums. During the incineration of the off
site material, EPA will be responsible for shutting down th
incinerator if there is a problem.
COMMENT #4: Wnat is the danger to people living next to the sit
from the incineration, especially the children?
RESPONSE: There is no danger from the incineration to the people
including the children, living next to the site during incinera
tion. The incineration performance regulations require a minimi
destruction and removal efficiency of 99.9999% for dioxin wastes
These standards were set based on analyses of potential risks t
the health or the environment and the levels of performance tha
have been measured for properly operated and well designs
incinerators. Although the 99.99% destruction and remove
efficiency is protective of public health and the environment,
more stringent standard of 99.9999% destruction and removr
efficiency was set for wastes containing dioxin because of EPA'
and the public's concern about this particularly toxic chemical.
COMMENT #5: How can the residents of Jacksonville be assured t!
the incinerator at Vertac will not be used to commercially b
Hazardous wastes or to burn wastes from other Superfund si'-
109
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other than from the Jacksonville and Rogers Road landfills, after
the Vertac wastes are incinerated?
RESPONSE: In order to commercially burn hazardous waste at an
incinerator, a permit under the Resource Conservation and Recovery
Act would be required. This permitting process requires public
comment prior to issuance of any type of permit. With respect to
waste from other Superfund sites being brought to Vertac for
incineration, Federal regulations only allow waste from one
Superfund site to be brought to another site when sites are
geographically close and contain similar wastes.
COMMENT #6: Why doesn't EPA know exactly how much soil needs to
be incinerated at this time?
RESPONSE: The purpose of the Feasibility Study, which is
culminated by the issuance of the Record of Decision, is to develop
the conceptual remedy for the site. Not until the design and
actual remediation process, which includes testing to verify the
complete extent of the contamination, is the exact amount of soil,
which needs to be incinerated, known.
COMMENT #7: How can EPA incinerate this material without a
completed health assessment or environmental impact study?
RESPONSE: EPA has determined that the preparation of an
Environmental Impact Statement is not required in connection with
a Superfund cleanup because of the functional equivalency of the
Remedial Investigation/Feasibility Study process. Since the
procedures in the Superfund Remedial Investigation/Feasibility
Study process result in a rigorous review of environmental and
health considerations, the health and safety of the community and
the environment can be ensured without a separate environmental
impact statement.
COMMENT #8: Has an incinerator been used to burn dioxin waste in
a residential neighborhood anywhere in the country before?
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 Resource
Conservation and Recovery Act, the Hazardous and Solid Waste
Amendments, and the Toxic Substances Control Act, among others.
Additionally, there are other agencies besides EPA which overs<-...
the operations of these facilities, for example, the Department :
Energy and the Department of Defense.
no
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Although there are known instances of hazardous waste (i.e.,
dioxinO incineration being conducted in or adjacent to cities anc
towns, information detailing the specific location of incinerators
relative to population density within a known proximity is not
readily available. However, it is known that dioxin contaminatec
soil was incinerated, in a residential area in Gulfport
Mississippi.
COMMENT #9: What will the incinerator be doing during times whe
there is no burning going on?
RESPONSE: If it will be a long time before the next time soil wil
be burned, the incinerator will be shut down. If incineration wil
begin again soon, the incinerator will continue to be heated.
COMMENT #10: Is it possible that the MRK incinerator will not bi
the incinerator used at Vertac after the drums have bee
incinerated?
RESPONSE: At present, it is not known what incineration contracto
will be used to incinerate the off-site waste. If EPA performs thi
off-site cleanup action, EPA will follow the Federal procuremen
regulations and the competitive bidding process. If a potentially
responsible party performs the off-site cleanup action, th<
potentially responsible party can contract with any qualifie<
incineration contractor, with oversight by EPA.
COMMENT #11: How can EPA bypass a city ordinance which allows tha
only the 28,500 barrels be burned at Vertac?
RESPONSE: CERCLA mandates that Superfund response actions comply
with all Applicable or Relevant and Appropriate Requirement;
(ARAR's). ARAR's consist of all Federal or State environmentally
protective requirements that either address specific circumstance;
related to Superfund sites, or situations sufficiently similar t<
those encountered at the CERCLA site that their use is well suitec
to the particular site. Compliance with the substantive
requirements of State regulations is required only when th<
regulation is uniformly applied on a State-wide basis. Loca
ordinances would not qualify under this criteria because they an
not applied consistently across the state. Another reason tha
compliance with standards other than Federal and State regulation:
(i.e., local ordinances) is not required is that they might undul-
restrict or otherwise encumber timely remedial response a
Superfund sites.
COMMENT #12: If the destruction efficiency is 99.9999%, wha
happens to the 0.0001% that is left?
RESPONSE: The remaining 0.0001% is allowed to be discharged fr
the stack into the air. This standard was set based on
analyses of potential risks to health and the environment and
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levels of performance that have been measured for properly operated
and we'll designed incinerators. 100% destruction is only
theoretical and is not possible in reality.
COMMENT #13: Can the incinerator at Vertac withstand an
earthquake, since one is predicted for the New Madrid fault?
RESPONSE: It is not possible to plan for all natural disasters,
but EPA and the State are attempting to mitigate the effect of any
natural disaster by destroying the waste now so that a natural
disaster will not create a risk from the contamination as it sits
today.
SAFETY
COMMENT #1: During the excavation of the Creek and Bayou
floodplains, what precautions will be taken to ensure that the
excavated material will not be blown, washed, or tracked into the
community?
RESPONSE: The precautions to be taken to ensure that the excavated
material win not be blown, washed, or tracked into the community
will be thoroughly developed during the design phase of the
project. These design elements are standard procedures in modern
hazardous waste management projects.
COMMENT #2: Is there an evacuation plan for Jacksonville and who
is responsible for implementing it?
RESPONSE: The City of Jacksonville is responsible for the
evacuation plan. More information concerning the evacuation plan
can be obtained from the Jacksonville Fire Department.
ROCKY BRANCH CREEK AND BAYOU METO
COMMENT #1: As part of the offsite remediation, can EPA post and
identify Rocky Branch Creek with signs so that people are aware of
where it is located?
RESPONSE: EPA and the State of Arkansas searched for signs along
Rocky Branch Creek. Fourteen signs were found to already exist and
the State of Arkansas posted several additional signs.
COMMENT t2: Is the contamination so extensive in Rocky Brancn
Creek to warrant the excavation of the Creek and Bayou? This could
cause excessive damage to the ecological habitat.
RESPONSE: EPA believes that it is not necessary to excavate th<-
Creek and Bayou sediment because the level of contamination do-
not pose an unacceptable risk to human health. However, rr\
believes that it is necessary to excavate residentially-zon-
areas, including floodplain, which are above the residential act .
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level of 1 ppb. This will ensure the safety of area resident:
exposed to the floodplain. In order to minimize ecological damagi
due to excavation, retesting of the floodplain areas prior t<
excavation will be required to ensure that only those areas wit
concentrations greater than 1 ppb will be excavated. In addition
the remedial design will require that great care be taken t<
minimize damage and tree removal during excavation and that grasse
and tree saplings be planted in the excavated areas to minimiz
erosion.
COMMENT #3: The State of Arkansas commented that carefu
consideration should be given to the advantages of excavating th
very low TCDD concentrations in the Rocky Branch Creek floodplai
versus the ecological damage resulting from that action.
RESPONSE: EPA is very sensitive to this "trade off." EPA believe
that the large area that contains greater than 1.0 ppb TCDD shoul
be excavated, but that every effort should be made to minimiz
disruption to the area ecology. With this in mind, the remed
requires that all areas be resampled prior to excavation. Onl
those areas above 1.0 ppb will be excavated. Furthermore, th<
design will require that excavation procedures be used to minimiz
the removal of trees, and that the excavated areas be seeded wit
grasses and tree saplings planted.
COMMENT #4: Why hasn't there been a study to assess the impact o
the contamination on the food chain?
RESPONSE: EPA has recently entered into an interagency agreemen
with the United States Fish and Wildlife Service for the Fish am
Wildlife Service to conduct a study to assess the availability o
dioxin to the food chain. The study is scheduled to begin in th<
winter of 1990 and to be completed in 1992.
WASTEWATER TREATMENT PLANT
COMMENT #1: How extensive was the EPA remedial investigation o
the sewer system? Was the entire city investigated or just thi
system around and near Vertac? Is it possible that th'
contamination could have spread throughout the Jacksonville sewe
system?
RESPONSE: Only the portions of the sewer system which serviced th
Vertac plant were investigated. There is no evidence to indica*-
that any other parts of the system were impacted by the plant, an-i
therefore, were not investigated.
COMMENT t2: After the remediation, will the Vertac site conti:
to discharge from outfall 002 into the West Wastewater Treats-
Plant? Jacksonville Wastewater Utility wants to close the '/.-
Wastewater Treatment Plant after completion of the off
remediation. The Wastewater Utility also requests that all ur. .
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building sewers be sealed off at the Vertac property line and that
all active sewer lines on the plant be either replaced or lined
before any water on the Rocky Branch interceptor is diverted to the
new Johnson Wastewater Plant.
RESPONSE: After the remediation, outfall 002 will discharge
directly to Rocky Branch Creek or Bayou Meto or discharge via the
wastewater treatment plant. The exact details of this discharge
will be determined during the remedial design/remedial action
phase. All unused building sewers will be addressed in the
remedial design. The selected remedy states that all active sewer
lines will be replaced or lined before any wastewater in the Rocky
Branch interceptor is diverted to the new treatment plant.
COMMENT #3: will one foot of soil over the top of the old
structures at the sewage treatment plant be enough considering soil
erosion?
RESPONSE: Yes. The soil cover will be designed, seeded, and
maintained to prevent soil erosion.
FURTHER INVESTIGATIONS AND ANALYSES
COMMENT #1: Request by Kelly Denise Jones to test her property.
RESPONSE: The sampling was conducted by EPA on August 20-21, 1990,
and results from the sampling are expected in early October, 1990.
COMMENT #2: Request by Mr. Roy Hawks to test the property
surrounding his house.
RESPONSE: The sampling was conducted by EPA on August 20-21, 1990,
and results from the sampling are expected in early October, 1990.
COMMENT #3: Request for EPA to collect samples at Pinewood
Elementary School.
RESPONSE: The sampling was conducted by EPA on August 20-21, 1990,
and results from the sampling are expected in early October, 1990.
COMMENT #4: Request for EPA to test sewers across Marshall Road
from the Vertac plant.
RESPONSE: While there is no reason to believe that Vertac coui<]
have discharged to these sewers, EPA will sample these sewers tc
allay community concerns. Results are expected in late October,
1990.
COMMENT t5: How can EPA and the public determine if a lab i.
qualified to test for dioxin?
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RESPONSE: When EPA does sampling for dioxin, either the EPi
Houston laboratory does the analysis or the sample is sent to ,
qualified contract lab that has met certification requirements fo
the EPA. These laboratories must meet stringent certificatio
requirements and must adhere to very specific quality contro
procedures. The public can contact the EPA Region 6 Office o
Quality Assurance to check on the qualifications of a laboratory
COMMENT #6: is it normal to have analyses done at loca'
laboratories?
RESPONSE: Local laboratories can be used if they are qualified.
MISCELLANEOUS
COMMENT #1: How long will it take to complete the off site project
RESPONSE: It will likely be a number of years before constructio
is completed. After the Record of Decision is signed in Septembe
1990, the design will begin. The design phase of the project wil
take at least 18 months. After that the construction can begin
However, there may be advantages to coordinating the onsit
construction with the off-site construction, which could delay th
off-site construction.
COMMENT t2: How long will it take to complete the onsite project
besides the drummed wastes?
RESPONSE: A remedy is scheduled to be selected for the abov
ground material, located onsite, in mid-1991. The remedy for th
soils and the below ground contamination onsite, will be selecte
in 1992. Since the extent of these remedies is unknown at thi
time, the timeframes to complete the remedies are unknown.
COMMENT #3: In 1981, Vertac applied for a water discharge permit
requesting to discharge 30,000 pounds per day of 2,4-D and 15,00
pounds per day of 2,4,5-T into Rocky Branch Creek.
RESPONSE: The 30,000 pounds per day of 2,4-D and the 15,000 pound
per day of 2,4,5-T which were shown in the Vertac permi
application were not discharge limits requested, but were th
production rates of each compound at the Vertac facility, at tha
time. The water permit was issued to Vertac in 1984 and containe
very stringent discharge limits for these substances.
COMMENT #4: What were the results from the broken water pipe a
Vertac?
RESPONSE: The pipe was repaired and drinking water samples wer
collected from several homes of area residents. No dioxin --a
found in any of the samples.
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COMMENT #5: Is there creosote on the Vertac site?
RESPONSE: No, there is no creosote on the Vertac site.
COMMENT #6: Is Rebel Drive on the Reasor-Hill landfill?
RESPONSE: No, Rebel Drive is not located on the Reasor-Hill
landfill.
COMMENT #7: Has there ever been a surface or ground water study
done for the Vertac site? Why wasn't the ground water study for
the Vertac site not initiated earlier?
RESPONSE: The surface water samples from Rocky Branch Creek and
Bayou Meto and the fish tissue samples from the Creek and Bayou do
show the presence of dioxin. The ground water study is being
conducted as part of the onsite investigation. The first priority
of each of the operable units being addressed at the Vertac site
is the removal of the largest amount of contamination first.
Therefore, incineration of the drums and the off-site removal were
moved to the forefront. The onsite investigation and ground water
study were sequenced after the drums and the off-site study, and
are ongoing.
The following is a summary of written comments received from
Hercules, Inc., a Potentially Responsible Party at the Vertac site.
Some of the Hercules comments contained general objections or were
somewhat vague. EPA has, in the responses below, addressed all
comments and has given specific responses where specific comments
were made. However, EPA has not speculated regarding the exact
meaning of Hercules' comments which were not clear.
COMMENT #1: According to the 1990 Feasibility Study, the areas
proposed for remediation, other than the sewage collection lines,
pose a risk of 10"4 to 10"6. Since the 1990 National Contingency
Plan (NCP) states that for known or suspected carcinogens,
acceptable exposure levels are generally between 10 4 and 10 .
Since the calculated risk for the sewage lines is overly
conservative, there are no health or environmentally based reason.s
for the proposed remedy.
RESPONSE: The areas proposed for remediation pose a threat to bo"!:
human health and the environment. The NCP states that an
acceptable level of lifetime cancer risk is the 10 4 to 10 ~ ranc>-.
It also states that other factors, such as ARAR's and protect:
of the environment , should also be considered in remedy selectio: .
The 1990 Feasibility Study states that the risk posed by the sewa -
collection lines is on the order of 10"3 and that the risk posed .
the residentially zoned floodplains is 5.7 x 10"4. Both of tn-
risks exceed the range considered acceptable by the NCP,
warrant the selected remediation. The selected remedy is . .
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necessary to protect the environment. Fish tissue samples show t.
presence of dioxin and a commercial fishing ban is in effect f
the Bayou Meto and a sports fishing advisory is in place. T
selected remedy is designed to minimize the migration of a
additional contamination from the floodplain, sewage lines a
sewage treatment plants, into the Creek and Bayou.
COMMENT #2: Hercules, Inc. suggests that higher dioxin acti
levels for both residential and industrial areas may be mo
appropriate (ChemRisk paper). According to the ChemRisk pape
28 ppb TCDD should be the residential action level, compared to
ppb used by EPA, and 113 to 209 ppb should be the industrial acti
level compared to 10 ppb used by EPA.
RESPONSE: Hercules, Inc. submitted a report prepared by ChemRis
which calculates alternative cleanup goals for dioxin, The repo
calculates these alternative cleanup goals using calculations a
assumptions that are contrary to EPA guidance. The resulta.
cleanup levels are, therefore, much higher than those used by EPi
The paragraphs below discuss some of the assumptions a
calculations advocated in the report that are contrary to E.
policy. All section references in the paragraphs below refer
the ChemRisk report.
A cancer potency factor for 2,3,7,8-tetrachloro-dibenzo-p-diox:
(2,3,7,8-TCDD) of 9,700 (mg/kg-day)~A is presented in Section
(Dose-Response Assessment for Dioxin). This cancer potency factc
or slope factor has not been verified by the EPA Carcinogenic Ri£
Assessment Verification Endeavor (CRAVE) workgroup and is not :'
accordance with EPA policy. The CRAVE workgroup is responsible fc
reviewing and verifying cancer slope factors for EPA. Review t
CRAVE is the mechanism by which EPA ensures consistency in tf
slope factors used by EPA and others, such as Potential:
Responsible Parties. The EPA slope factor for 2,3,7,8-TCDD is 1.5
x 105 (mg/kg-day) '.
Several exposure parameters used in Section 4 (Recommended Actic
Levels for TCDD-Contaminated Soil) are not in accordance with EF
guidance. The Hercules, Inc. submission used a soil contact rat
or adherence factor of 0.5 mg/cm2, which underestimates by
factor of 3 to 6 the quantity of soil adhering to the skin, whi.
results in an underestimate of dermal absorption. This, in tur:
results in the calculation of higher allowable containing:
concentrations.
The Hercules, Inc. submission used soil ingestion rates of
mg/day for children aged 0 to 1 years, 50 mg/day for children a
1 to 5 years, and 10 mg/day for older children and adults.
guidance (OSWER Directive 9850.4) recommends soil ingestion r..-
f 200 mg/day for children aged 1 to 6 years, and 100 mg/day
older children and adults. Use of lower ingestion rates as
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in the ChemRisk report results in the calculation of higher
allowab-le contaminant concentrations.
The Hercules, Inc. submission used 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 the risk for recreational
fishermen who consume larger amounts of fish than the general
population.
The National Contingency Plan states that the acceptable risk range
is one excess cancer case in ten thousand individuals (10~4) to one
excess cancer case in a million individuals (10~6). Using the EPA
risk assessment approach, the cleanup levels advocated by the
ChemRisk report would result in a residual risk, in the
residentially zoned floodplain areas, in excess of 10"3, which
greatly exceeds the acceptable risk according to the NCP.
COMMENT #3: The EPA Endangerment Assessment, which assumes
exposure to the highest concentration, is too conservative, and
exposure to an area's average concentration is more appropriate.
RESPONSE: The risk Assessment Guidance for Superfund Volume I
Human Health Evaluation Manual states that actions at Superfund
sites should be based on the reasonable maximum exposure (RME).
Because of the uncertainty associated with sampling, the 95 percent
upper confidence limit on the arithmetic average is often being
used as a conservative estimate of the exposure concentration
contacted over time. The use of the highest concentration in the
EPA Endangerment Assessment is more appropriate than the use of the
average concentration. The use of the average concentration does
not account for the uncertainty associated with sampling.
COMMENT #4: The presentation of data in Table 2-2 of the 1990
Feasibility Study (FS) is misleading because there is no
distinction made on the depth of the 1988 "surface sampling" as
compared to the 1984 data collected at a depth of 0-3".
RESPONSE: The 1988 sampling was conducted by collecting r-.o
spoonfuls of soil from the top 3" with a stainless steel table
spoon. Therefore it was assumed that the data would be comparable
with the 0-3" collection method cited for the 1984 data.
COMMENT #5: There is no indication on Figure 2-6 of the 1990 F'<
that the west side of the east leg of Rocky Branch was sampled.
RESPONSE: This area is identified on Figure 2-6 with a ligh* .
shaded marking. The legend identifies this marking as ND which
not detected with the method detection limit of 0.3 ppb.
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COMMENT t6: While not discussed in the 1990 FS, sampling was als
done by Hercules in 1988 in areas surrounding manholes which ar
part of the sewer collection system.
RESPONSE: If true, these data were not available to EPA at tl-
time the 1990 Feasibility Study was prepared. In addition, sine
these samples were taken from areas surrounding manholes, they c
not impact the selection of the remedy for the sewer system.
COMMENT t7: There is no indication in the 1990 FS that ATSDR he
reviewed post-1985 RI data for the off-site areas or that they ha\
concurred with the EPA proposed plan.
RESPONSE: EPA summarized the post-1985 RI data and discussed tr
proposed plan with ATSDR during a meeting held on May 3, 199C
ATSDR concurred with the EPA proposed plan by letter dated June i:
1990 (Appendix C to this ROD).
COMMENT #8: EPA Region 6 has not followed ATSDR recommendation
for the Vertac off-site areas or TCDD cleanup levels at sites i
other EPA regions. The remedy proposed for the Vertac off-sit
areas is also not consistent with the proposed remedy for tr
landfills in Jacksonville.
RESPONSE: The proposed plan is consistent with the ATSDR actic
levels for the off-site areas. See responses to comment number 1C
regarding residential action levels, comment number 12, regardir
the Old Sewage Treatment Plant, and comment number 13, regardir
the West Wastewater Treatment Plant. Regarding the cleaning of tr
sewer lines, the proposed remedy at Vertac (remove contaminate
sediments and incinerate sediments) is the same as that employe
for sewer lines at Love Canal site in EPA Region 2. Regardir
consistency with the landfills, the residentially zoned floodplai
areas that contain above 1 ppb TCDD should not be capped with clea
soil, as proposed at the landfills where TCDD is between l and 1
ppb, because this residentially zoned area is subject to erosic
and any capping could be washed out, allowing contaminar
migrations.
COMMENT #9: ATSDR action levels are overly conservative and recer
information about TCDD supports a soil cleanup level for TCDD tha
is greater than 1 ppb for residential and greater than 7 ppb fc
industrial areas. ATSDR should have been consulted on whether tr
1 ppb was still appropriate for residential areas.
RESPONSE: see response to Hercules comment #2. In addition,ATSL
was consulted and has concurred on the remedy. In addition
according to ATSDR, it is unlikely that these action levels w:.
be changed in the near future.
COMMENT #10: The undeveloped residentially-zoned areas south
the Vertac plant are not readily accessible, less than 10% ot
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area has TCDD concentrations greater than 1 ppb and one acre is
fenced. This area has an average concentration below 1 ppb and
need not be remediated.
RESPONSE: The 1 ppb TCDD action level for residential areas is a
well-established and widely-accepted level. Over two acres of
floodplains along Rocky Branch Creek contain more than 1 ppb TCDD,
some areas contain as much as 9.6 ppb TCDD. This large area, while
undeveloped, is zoned residential, and still poses a direct contact
threat to nearby residents. Since this area is zoned residential,
it is possible that it could be used as such. If this were the
case, then under the residential use scenario, the residents would
be exposed to these concentrations in their yards, not an average
concentration for the entire two-acre area, as suggested by
Hercules. Therefore, it is inappropriate to use an average
concentration, under this scenario, for the entire two-acre area.
In addition, this large area of contamination still acts as a
source of contamination to Rocky Branch Creek, Bayou Meto, and the
already contaminated fish in the Creek and Bayou, and thus poses
a risk to the environment. By removing these contaminated soils
in the floodplains, a source of contamination to the aquatic life
will be removed, possibly expediting the removal of the ban and
advisory against fishing in the Bayou.
COMMENT #11: The undeveloped, residentially zoned area south of
the Vertac plant should be re-zoned as non-residential, thus
removing the need to remediate the area.
RESPONSE: According to the NCP, institutional controls may be used
only as a supplement to engineering controls and should not be
substituted for active response measures as the sole remedy, unless
active response measures are not practicable. Since excavation of
floodplain soils in the undeveloped residentially-zoned areas is
practicable and desirable to prevent migration of these
contaminated soils into the waterways, EPA is not in favor of
changing the zoning in order to leave the contaminated soils.
COMMENT #12: ATSDR has recommended a cleanup level of 5-7 ppb TCDD
for the Old Sewage Treatment Plant and the Region had selected 5
ppb in 1986. Despite this recommendation and precedent, an action
level of 1 ppb has been selected in the 1990 FS and the proposed
plan.
RESPONSE: The sludge in the digester contained 12.4 ppb TCDD,
which is above the ATSDR action level. Therefore, the sludge will
be removed and incinerated. The ATSDR recommendation also included
that migration of contaminants via surface runoff be prevented.
The drying beds will be capped with one foot of clean soil
prevent contaminant migration. This would prevent unexpec*-":
exposure by humans to these contaminants and would protect
environment by preventing migration into the environment.
other treatment units, such as clarifiers and trickling filte:
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pose a safety problem and contain small amounts of contaminate
sedime'nts. Because of the safety concerns and the SARA requiremer
that the selected remedy utilize permanent solutions, the treatmer
units would be demolished and covered with a foot of clean soi.
This additional measure is considered to be a cost-effective we
to further reduce the risks posed by the area.
COMMENT #13: In 1986, ATSDR recommended a cleanup level of 5-7 pj
for the West Wastewater Treatment Plant, but the 1990 FS and tf
proposed plan select an action level of 1 ppb TCDD.
RESPONSE: The ATSDR action level of 5-7 ppb includes tt
stipulation that contaminants be prevented from migrating from tl
plant. Grab sampling in 1984 showed that the aeration bas"
sediments contained TCDD as high as 37.9 ppb. 1988 grid samplir
showed the aeration basin sediments to contain TCDD as high as 2.
ppb. While the 1984 samples were grab samples, which can identif
hot spots, and the 1988 samples were composites from a grid, whic
tend to average the concentrations over the area sampled, such
large reduction in sediment concentration indicates that the TCE
contaminated sediments may be flushing into the environment. I
order to prevent further degradation of the environment, closur
of the aeration basin is considered necessary. The two oxidatic
ponds contain sediments with less than 1 ppb TCDD and, therefore
will not be remediated.
COMMENT #14: CDC approved capping an area that contained 51 pp
TCDD in an industrial area in Midland, Michigan and an area wit
20 ppb TCDD at Times Beach, Missouri.
RESPONSE: CDC/ATSDR provided site-specific cleanup levels for th
Vertac off-site areas and also concurred with the EPA propose
remedy for the Vertac off-site areas. The selected remed
incorporates the ATSDR recommendations for Vertac off-site areas
COMMENT #15: The assumption that a sewer worker would ingest 0.
grams of the sediment each day during his/her working years i
developing the risk for excess lifetime cancer for sewag
collection lines is overly conservative. The risks of disease
e.g., from viral hepatitis, are greater than from the infrequen
exposure that might occur from the TCDD in the sewer line.
RESPONSE: The cancer risk estimate for sewage collection lines i
based on a worst-case scenario. However, this risk estimate is no
the basis for the remediation. Rather, prevention of migration o
contaminated sediments to the new STP and into the environment, :
general, require that these actions be taken.
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APPENDIX A
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j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\~Ti~V ' WASHINGTON D C 20460
' «.;"
January 26, 1989
MEMORANDUM
SUBJECT: Remediation of Dioxin-Contaminated Sediments Near the
Vertac NPL Sit*
<£_ '?-&.
FROM: J. Winston Porter, Assistant Administrator
Office of Solid Waste and Emergency Response (WH-562)
THRU: Renate Kimbrough, M.D.
Office of the Administrator (A-101)
TO: Barry Johnson, Director
Agency for Toxic Substances and Disease Registry
Sediments in and along the West Leg of Rocky Branch Creek and
Bayou Meto downstream from the Vertac NPL site are contaminated
with 2,3, 7, 8-tetrachlorodibenzo-p-dioxin (TCDD) . This memorandum
is intended to provide the rationale used by EPA in determining
appropriate remedial actions regarding these sediments. Your
comments are requested.
A limited number of channel sediment samples from Rocky Branch
Creek and Bayou Meto were analyzed in 1984. Additional sampling
was conducted in 1987 and again in 1988. TCDD concentrations in
these channel sediments reportedly ranged from <0.3 ppb to 2.3
ppb. Rocky Branch Creek bank sediments were sampled in September,
1988. TCDD concentrations in ten composited samples reportedly
ranged from 0.50 ppb to 2.30 ppb.
EPA has previously employed 1 ppb as an action level for
remediation of TCDD in creek sediments (EPA, 1987) . The use of 1
ppb as an action level is based on a Centers for Disease Control
(CDC) recommendation developed primarily for direct contact with
TCDD-contaninated soils in residential areas. The CDC
recommendation is derived from Kimbrough et al. (1984), which
described 1 ppb as "...a reasonable level at which to .begin
consideration of action to limit human exposure to contaminated
soil." It also stated, "Environmental situations may very widely,
and whether a certain level of TCDD in soil will give rise to
concern has to be evaluated on a case-by-case basis." As this
statement indicates, the 1 ppb action level was not intended to
be interpreted or applied as an all-encompassing standard.
-------
- 2 -
:ather, the assumptions and uncertainties underlying its
evelopment need to be understood and compared to site-specific
lircumstances. It should also be noted that 1 ppb does not
'epresent a fine line between safe and unsafe conditions as the
.era. "action level" implies. Rather, it was intended to represent
level of concern. In addition, soil ingestion data developed
ubsequent to publication of the Kimbrough et al. (1984) article
hould also be considered.
Valuation of the risk assessment assumptions used to derive the
, ppb level in the context of site-specific exposure scenarios
pplicable to Rocky Branch Creek and Bayou Meto sediments
ndicates that it is inappropriate to apply this directly as the
ction level for these sediments.
'here are two plausible scenarios by which humans may be exposed
o TCDD contaminating Rocky Branch Creek and Bayou Meto
ediments. One is direct contact with the affected sediments
resulting in TCDD intake by ingestion, transdermal absorption
nd/or inhalation). This scenario would be more applicable to
xposed bank sediments than to the submerged channel sediments,
s the latter are less accessible for direct contact.
he 1 ppb level was developed primarily for residential soils, as
pposed to creek sediments. It was based on a cancer risk
ssessment which incorporated numerous conservative exposure and
oxicity assumptions. Prominent among these were assumptions that
oung children would come into contact with the contaminated
oils on a daily basis, and that young children ingest 10 grams
f soil per day. Since these two assumptions "drove" the risk
ssessment (Kimbrough, personal communication), their relevance
o the potential for contact with Rocky Branch Creek and Bayou
eto sediments is of particular importance.
he daily contact assumption can be reasonable for residential
oils, which would be readily accessible to children. In
ontrast, the affected Rocky Branch Creek sediments are not as
eadily accessible, and may be essentially inaccessible to young
hildren. It is also unlikely that children would come into daily
ontact with Bayou Meto sediments since these are not in a
esidential area. In addition, the assumption of 10 grams/day
oil ingestion has since become viewed as overly conservative;
ess than 1 gram/day is now viewed as a more reasonable
-sumption for soil ingestion by "typical11 young children (Binder
t al., 1986; Clausing et al., 1987; EPA, 1988; LaGoy, 1987). In
ther words, both of the critical assumptions supporting 1 ppb as
level of concern appear overly conservative for application to
scky Branch Creek and Bayou Meto sediments.
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- 3 -
Another pertinent assumption in Kimbrough et al. (1984) involve
the distribution of TCDD -in the contaminated areas. Mor
specifically, the 1 ppb designation was predicated on th
assumption that 100% of the affected soils are contaminated a
peak levels (i.e., assuming uniform distribution of 1 ppb TCD
throughout the area of potential soil contact). The sampling fro
residential areas near Rocky Branch Creek has shown a few area
(mostly near the creek) with average soil concentrations for TCO
equivalents greater than 1 ppb. Removal of these contaminate
soils is in progress. Upon completion of this removal action th
average TCDO contamination in surface soil of this residentia
area will be substantially less than 1 ppb. While the bank o
Rocky Branch Creek can be considered a portion of the residentia
area, it comprises less than 1 percent of the area. The nearl;
vertical banks of the creek make access to the contaminated sol
difficult for the young child. In addition, it is separated fro
the residential area by a fence. These factors combine to reduc
the opportunity for the young child to have even the normal
frequency of exposure opportunities to these contaminated soils
Figure 2 in Kimbrough et al. (1984) shows that if 1 percent o:
the area is contaminated at the maximum concentration, th<
estimated lifetime excess cancer risk is two orders of magnitudi
less than if the entire area is contaminated at a unifor
concentration. Thus, if the entire creek bank, which represent
less than 1 percent of the residential area, is contaminated at
maximum concentration of 2.3 ppb, the estimated excess lifetim
cancer risk is equivalent to that if the entire residential are
were contaminated to less than 0.023 (0.02) ppb.
The second plausible human exposure scenario leading to TCDC
intake from the contaminated sediments is food-chain ingestion.
Based on concern regarding exposure to TCDO via this route, th<
State of Arkansas Department of Health has imposed an advisory
discouraging consumption of fish taken from the affected
waterways. For the same reason, ATSDR has previously recommended
that an interim action level of less than 1 ppb be achieved ir
Rocky Branch Creek and Bayou Meto sediments (ATSDR, 1986). ATSDF
also recommended monitoring of TCDD levels in edible fish
portions, to assist in determining the need for continuation of
the State advisory.
Kimbrough et al. (1984) provided no specific acceptable sediment
concentrations pertaining to this exposure route. It was stated,
however, that acceptable levels for soils which might contaminate
waterways (i.e., creek sediments) might have to be lower than l
ppb due to the potential for bioconcentration of TCDD in fist
tissue. A potential for 20,000 fold or greater TCCC
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- 4 -
bioconcentration in fish (National Research Council of Canada,
1981) was mentioned in support of this position.
Results of fish sampling conducted downstream from the Vertac
ite in 1984 are noteworthy in this regard. TCDD levels were
valuated in fish sampled from sections of Bayou Meto in which
ediment TCDD concentrations were less than 1 ppb. TCDO levels in
dible portions of those fish ranged from 136 ppt to 704 ppt,
'ell in excess of the 25 ppt FDA concern level.
Both these data and the potential for TCDO bioconcentration would
'.ndicate that the ATSDR recommendation to achieve levels less
:han 1 ppb should not be interpreted as a recommendation to
chieve 1 ppb or less. Rather, remediation to levels
ubstantially lower than 1 ppb may be necessary to achieve TCOD
.evels in edible fish tissue which meet the current FDA concern
.evel of 25 ppt.
'o date, neither EPA nor ATSDR have specified sediment TCDD
:oncentrations permissible for unlimited fish ingestion.
therefore, an action level for Rocky Branch Creek and Bayou Meto
ediments based on potential risks to human health posed by fish
.ngestion cannot readily be designated. However, action levels
:an be based on potential human health risks posed by direct
:ontact with the sediments, in conjunction with continuation of
he State of Arkansas Department of Health advisory against
onsumption of fish taken from the affected waterways. In
ddition, EPA will be conducting long-term monitoring of TCDD
evels in fish and other wildlife in Bayou Me£o and Rocky Branch
reek, in accordance with the ATSDR recommendation.
he recommendation of 1 ppb as a level of concern was qualified
ith, "The appropriate degree of concern for which management
ecisions are made should consider an evaluation of the specific
ircumstances at each contaminated site." (Kimbrough et al.,
984). It is clear that the derivation of the l ppb concern level
as based on soil exposure assumptions which were more than
everal-fold greater than the exposures to sediments expected in
nd along Rocky Branch Creek and Bayou Meto. Therefore, assuming
continuing and effective State advisory discouraging ingestion
f fish taken from the affected areas, the reported <0.3 ppb to
.3 ppb TCDD levels in these sediments should not pose an
nacceptable health threat. Based on the above evaluation, EPA
.s determined that no clean up of either the West Let, of Rocky
ranch Creek or Bayou Meto to protect human health is necessary.
-------
REFERENCES
ATSDR, 1986. Memorandum dated April 24, 1986 from Jeffery A.
Lybarger, ATSDR, to Carl Hickam, Public Health Advisor for U.S.
EPA Region VI
Binder, S., 0. Sokal and 0. Maughan. 1986. Estimating soil
ingestion: the use of tracer elements in estimating the amount at
soil ingested by young children. Arch. Environ. Health 41:341-345
Clausing, P., B. Brunekreef and J.H. van Wijnen. 1987. A method
for estimating soil ingestion by children. Int. Arch. Occup.
Environ. Health 59:73-82
Kimbrough, R.D., H. FalJc, P. Stehr, and 6. Fries. 1984. Health
implications of 2,3,7,8-tetrachlorodibenzodioxin (TCDO)
contamination of residential soil. J. Toxicol. Environ. Health
14:47-93
LaGoy, P.K. 1987. Estimated soil ingestion rates for use in risk
assessment. Risk Analysis 7:355-359
National Research Council of Canada (NRCC). 1981. Polychlorinated
dibenzo-p-dioxins. Publ. NRCC No. 18574 of the Environmental
Secretariat. Ottawa, Canada: National Research Council of Canada
U.S. EPA, 1987. Superfund Record of Decision: Minker
Stout/Romaine Creek, MO. EPA/ROD/R07-87/007. September, 1987
U.S. EPA, 1988. Superfund Exposure Assessment Manual. EPA/540/1-
88/001. April, 1988
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APPENDIX B
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l HW'h S*rv*C(
DEPARTMENT OP HEALTH 4 HUMAN SERVICES
irq
MdmOfemu
°"f APR 2 4 1936
prom Acting Director
Office of Health Assessment
Health Assessment, Off-site Remedial Investigation,
Vertao Chemical Corporation, Jacksonville, Arkanaaa SI-85-079
To Mr. Carl Hiokam
Public Health Advisor
EPA Region VI
The Environmental Protection Agency (EPA), Kef loo VI Office, submitted
data indicating that sludge* and aediaenta in the Jacksonville vaatevatar
treataent plant ayatea (WVTP), Rooky Branch, Bayou Meto, and aaaoolated
floodplalna are contaminated with aeveral compounda including
tetraohloro-dibenzo-p-dioxins (TCPD). Becatu* of the potential for human
exposure to these compound*, and the potential for a major releaae of
these compounds froo the WWTP to dovnatreaa water and land resources, the
Agenoy for Toxic Substancea and Disease Registry (AT3DR) offera the
following recoooendationa: (1) restrict general public aoeeas to the
abandoned and existing WWTP, and to the channel and flood way soils of the
west lag of the Rooky Branch in the residential area juat aouth of Vertao;
(2) pravent additional migration and flood releases of oontaainants fro*
the WVTP system, other environmental sinks in Rocky Branch, Bayou Mate,
and their flood ways, and from Vertac; (3) residential land uaea on the
Vertac site would constitute an unacceptable health risk; (4) provide
additional characterization of both on-site and off-ait* contamination to
determine the need for additional remediation; and (5) iapleaant a health
and safety plan for all on- and off-alte remedial activities.
OF PSOBLZM
The ATSDR has been requested by ths U.S. Environaental Protection Agency
(EPA), Region VI, to review and comment on the Draft Off-site Rtmsdial
Investigation (RI) for ths Vertao Chemical Corporation plant,
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Page 2 - Mr. Carl Hickam
Jacksonville, Arkansas. In addition, EPA has asked us to address tb«
following concerns:
1. The public health significance of the oontaoinant
levels found in environmental pathways.
2. The need for off -sit* cleanup .
3. Assistant)* in developing guidelines and criteria
for off-site remediation of dioxin-oontaainatad
soils/ sludges/ sediaents to protect public health.
3TTE PgSCSTPTIOM AMP BAOCGRntTHT)
The Vertao Chemical Corporation pesticide plant lies on the site of a
former World Var II ordnance plant. Pesticides hare) been produced oa the
site sinoe 1948 by three foraer companies. Residential subdivisions lie
issediatsiy south *s4 «M>t of the Tertac plant site. The land use to the
north and west is primarily undeveloped or commercial/light industrial.
For additional background information on the sits, please refer to our '
reports to EPA Region VI dated April 11, 1983, and January 13, 1986, on
the Vertao Site and February 25, 1986, oa fish data.
LTST gy
1. Off-sits Remedial Investigation, Draft Report Voluae I-Report 4
Bibliography, Draft Report Volume XX- Tables e Appendices, Draft
Report Volume III- Maps 4 Figures, Project Ho. CB313-6, Site
So. 98-6L04, prepared for the E?A under Contract lo. 68-01*6(92 by
CR2M Hill, Inc. and Ecology aad Environment, Inc., July 12, 1985.
2. Supplement to the Off-sits Reaedial Investigation, Draft Report-
Delineations 4 Voluft.es/ A Working Paper, Project Mo. CB313-6, Site
*-
Ho. 98-6L08, prepared for the SPA under Contract Mo. 68-01-6692 by
CH2M Hill, Inc. and Ecology and Envlronaent, Inc., July 19, 1985.
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Page 3 - Mr. Carl Hiclcia
3. Memorandum datad Septtabtr 3, 1985, froa Mr. Larry p. Rexroat,
Super fund Enforceaent Section, EPA Region 71, to Mr. Ctrl Biokaa,
Public Health Adviaor, CBC/EPA Region 71.
4. ATSDR projaot file.
LTST OF
The primary oontaaiaanta of oonoern In off-flte tret* Inolud*:
2,3,7,6-TCSfi, 2,^-dichlorophecoxyacetio acid (2,4-0),
2,H,5-trichloroph*noxytcttic acid (2,4,5-T), ail vex, ofiloriMttd ph«nol»
and b«nz«nas. Th« RZ foouaaed on 2,3,7,8-TCDD, and uc«d th« f«n«ria t«r«
"dioxin" for 2,3,7,8-TCDO (p. 1-1, Vol. I).
QIIAL
To data, only tha 1964 aaapling data have reeelred QC. An aooaptabl*
avaluatlon of tha QC for tha 1984 data vaa provided in Appendix 10 (Vol.
HI).
TM3PECTTQg
On March 5 and 6, 1966, AT3DR conducted a aita inapaotion and mat with
Mr. Larry Hexroat, Project Officer, and Mr. Larry Xifht of EPA Region 71,
and Richard Satardal of CH2M Hill. Please refer to Attaonaeat 1
summarizing ATSDR'a itinerary, information obtained, and problaaa obaarvad
during the aite inapaotion. Photographs ware taken of both the 7ertao
aita and off-tit« areaa.
SAKPLTMO
In Oaoaabar 1983, aeventy-four aadiaant and aoil aaaplaa were oollaotad in
the off-aita atudy area and analyzed for "dioxin," 2,4-D, 2,4,5-T, ailrax,
chlorinated benzanaa, chlorinated phanola, and other organiea. Forty of
tha aeventy-four aaaplea contained "dioxin" (See Tablaa-5-1 4 5-2, 7ol.
II, and rafar to AttaohAitnt 2).
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Page ft - Mr. Carl HioJcaa
In June 1984, twenty-one «oil sanples were collected in areas within 600
feet of Bayou Heto that, Judged by visual inspection, had been frequently
flooded. These saoples were analyzed for "dioxin." Only one of theee
oontalned aeasurabla levels (0.43 ppb) of "dioxin."
In August 1984, 225 field saaplea of soil and sediaenta were oolleoted for
dioxin" analysis; 29 additional aaaplea vere oolleeted for background and
quality oontrol. Seventy-nine of the 225 field samples contained
measurable aaounts of "dioxin* ranging fro« 1.0 ppb to lore than 200 ppb.
Until this particular sampling effort, the abandoned WWT? and the existing
WWTP aeration pond "...had never been saapled..." (p. 5-7, 7ol. I), in
addition, Hoolcy Branch and Bayou Meto bad only been saapled at road and
railway crossings; this saapling effort included other sediaent sampling
locations in the streaa channels as well aa soils throughout the 2-year
and 5-year floodplalns. Please refer to Attachment 2 for a summary of the
"dioxln* data.
The highest 2,4-0 level (20,000 ppm) and the highest 2,1,5-T
level (7,200 ppa) were found in a 1984 sludge staple froa WWTP oanbole #77
(10161). This saae sludge saaple also contained the higheat "dioxla"
level O200 ppb) found during tfte ?984 saapliag and analysis effort. The
highest concentrations of silvex were found IB 1983 la sludge saaples froa
an abandoned interceptor/manhole 12 (67 ppa, 1-5) and a new
interoeptor/aanhole #19 «100 ppa, 1-4). Bexacblorobeazene (300 ppa,
1-3), pentschlorophenol (300 ppa, 1-3), oalordane (48.3 ppa, I006A),
snd 2,4,6-triohlorophenol (5.7 ppa, I016A) were also found la the WT?
colleotlon systea sludge. In the vicinity of Bines Cove along Rooky
Branch weet leg, 2.8 ppa PCS 1254, 1.5 ppa 2,4-D, and 2.7 ppa 2,4,5-T
(N030A) were found in a 1984 floodplain soil saaple (SO301).
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Page 5 - Mr. Carl Hiokaa
Food Chain
Siooonoentration has been documented In iquatio organlama dovnatreaa of
both the Yertao plaat in Rooky Branch and the Bayou Mtto and tht WPT
outfall in the Bayou Mate. Flab aaaples collected a* far M 15 milca
downstream from Socky Branch contained levels of 2,3,7,8-TCDD In tht
ediole portions that exceeded FDA 'a Great Lakea adviaory lav«l. vhela
fiah aaaples collaotad in Bayou Meto aa far as 73 milee dovnatreaa (Bayou
Mato Wlldlifa Kana«affl«nt Araa) of Rooky Branoh hava baon found to ba
oootaoinatad .
Larga ground aurfaca araaa are axpoaad on the alta to vatar and wind
erosion. This raiaaa the poeeibUity of off-aita Migration of
contaminants through the air. In addition, the potential for aubaurfaoa
tranaport of volatile gaa vapor* froa the vaate landfilla ahould be
explored.
Surface Vtt«r/Se4im«nt
Sediment tranaport of 2,3,7,8-TCHD and other hazardoua aubatanoea froa the
site to Rocky Branch, Bayou Me to, and the savage treatment plant haa been
observed. The Rooky Branoh and the Bayou Hato dovnatreaa of the Tartao
aita flow adjacent to aeveral residential aubdiviaiona , individual bosma,
agricultural lands, industrial and oommercial areaa, and recreational
areaa auob as Dupree Park.
Rooky Branoh t
In the Rocky Branch channel and floodplain, "dioxia" levela in the 1984
aedlment staples ranged from the detection Halt (i.e., variea from 0.02
to 0.70 ppb) to 7.58 ppb. The levels appeer to decrease with distance
from the Vertac plftr" '.«.- *.« 0.7U ppb (queationable result) Juat abov«
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Page 6 - Mr, Ctrl Hiakaa
leg of Rocky Branch near the West Lane dead end (3.01 ppb, N026C) and near
the end of Hines Drive (7.56 ppb, N030C). These level* are of particular
concern because of their proximity to residences. Detectable "dioxin"
levels ranged from 0.19 to 0.74 ppb for in-streaa sediaents.
While no 1984 samples were collected froa the east lag of Kooky Branch ~ '
seven locations vere sampled in 1983 in the east leg watershed. Three of
the sample locations (N-8, H-12, & K-16) were belov 7ertao s^ast Ditch"]
discharge. The data results indicate the need for additional sampling -ta-
aasure that TCDD contamination does not exist in the residential areas
east and south of the Vertao plant.
Bayou Meto:
Bayou Meto channel and floodplain sediaent samples ia 198* showed
concentrations of "dioxin" ranging from the detection limit to 2.1 ppb.
The highest "dioxin" concentrations vere found between the WTP outfall
and a point about 2000 feet downstreaa of the Highway 161 bridge. The
highest "dioxin" level found in 1964 was the estimated maxiaua
concentration of [3.5 ppb)(F047A) in a near-etreaa, near-surface sediaent
sample; this was found about 25 feat downstream of the WTP outfall in
Bayou Meto and 1?0 feet froa the left bank's water edge. The detectable
"dioxin" levels found in the 1984 in-stream sediaent samples ranged
/
from 0.10 to 0*39 ppb in shallow eediments sad from 0.10 to 1.10 ppb for
deeper sediaents.
Vastewater Treatment Plant (WTP) 3yste«:
Sludge and sediaent samples in the WTP collection and treatment system
revealed an average concentration of 21.5 ppb "dioxin" which included the
three highest values (70.5, 119.4, and >200 ppb). Sampling in 1984 of the
abandoned WTP found[6.59 PP9 "dioxin" in the sludge drying beds
"dioxin" in the digestor. In the existing WTP facilities,
and
12.16 ppb
1984 sludge samples ia the/aeration lagoon were found to have Bsxiaua
levels as high asT3TT"ppbj (S018A, invalid or questionable data)
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Page 7 - Mr. Ctrl liakaa
and (16.2 pp&)(S019A). Sludge staples in the oxidation ponds were found to
contain maximum "dioxin" values of] 9.37 ppb/in 1979, tad]3.6 ppbjin 1984
According to the IX, manhole #106 (200 feet south of Tertao property ia
the vest leg of Reeky Branch between Brmdea a lita Cove) was noted during
the 1984/1985 sever saepling investigation (Table 4-6, Tol. II) to
overflow. The XI also desoribed manholes #1198, #1202, #1206, and 1301 to
overflow. The overflow potential for other manholes in the residential
areas immediately aouth and east of the Vertao site during major storms.
should be desoribed. The interceptor which serves the residential
subdivision immediately south of Tertae vas found to contain the three
highest "dioxin" conoentratione (see above) ia sever sludgee/sedlmenta.
Agricultural Uses Downstream:
Efforts have not been made to identify existing or toned agricultural
areas along Bayou Meto downstream of the WVTP or Hocky Branch to a point
upstream of Southeastern Avenue that may have been affeoted by flooding
and contaminated sediments. Of theae agricultural areas, feedlot and
grazing areas in the floodplain are the most important since 2,3,7,8-TCDD
accumulates in the tissues of grazing cattle and rooting swine. Cattle
grating areas and other agricultural activities were observed during the
site inspection. Bach' of these areas should be sampled. Mote that levels
of 2,3,7,8-TCDD in soils from 0.0062 to 0.079 ppb have been projected by
Kimbrough et al.* to produce maximum allowable residues of 2,3,7,8-TCDD
in foods (i.e., beef, pork, and milk).
Sediments IB the vicinity of three Bayou Meto surface water withdrawal
points may be of public health concern for certain agricultural uses. We
note that site 23 (about 500 feet upstream of Highway 67/167) withdraws
for waterfowl purposes, site 13 (near Bighvay 16'.) withdraws for 60-aores
of rice, and site 11 (about 0.3 miles upstream of Southeastern A*e.)
withdraws for 280-«cres of rioe. While site 25 li«e about 1000 feet
downstreaa of the sedisent sampling station contai&iog the tvo hlgheet
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Page 3 - Kr. Carl Hickta
dicxin" values (2.1 and 3,5 ppb) found in the Bayou Meto, the 3ayou Meto
channel sediments next to the lake at alt* 25 were not found to contain
"dlozin.1 The oolleotion and analyses of a few additional sediment and
blologio saaplea aay be prudent if (1} the waterfowl may b« consumed, or
(2) flooding lay bar* occurred aiaoe the laat sampling P«riod. The Bayou
Meto sediments in tba rioiaity of site 13 appear to bat* a hiatory of
Y PPb
The aoat likely ezpoaure pathways for local reeidenta, City Beautifloatioa
eaployeea, and VW7P employees to tbe oontaainanta of eoaeern would be by
direct contact witb contaminated aludgea/aediMnt«/*oil and inhalation of
contaminated duat, If laall onildren play in oontaadnated yard* or gardea
aoilj, ia tbe weat let of Rooky Branob juat aouth of tb« Tertao plant, or
lire in tbe iaawdlato area, tbey amy be aubjeot to expoaurea through
direct oontaot and ingeation of oontaadaated toil or duat. Other probable
ezpoaure pathway* include tbe ingeation of food orope grown ia
contaminated aludgea and aoila, ingeetioa of local fiah (and poaalbly
other local wildlife), and iageatioa of farm aniaala that grace on or are
confined to laada containing oontaadnated aoila/ aediaeata*
?or iTSDR'a diaouaaioa on tbe health effecta of 2,3i7|8-TGDO, 2,t=u; -
and 2,4,5-T, pleaae rafer to our Health iaaeaaaeat report oa tho
Jacksonville Uadfill dated October 23, 1985.
The seotloa of the U dealing with the toxloologio and oarolaogeaia
effaota of TCDO azpoaor* ia adaquato, Bovovor, the »lu»aa Iffeota*
aeotioa requlraa seyerml roriaioiw. Pirat of all, it should b« noted that
the reproductive data oolleoted following the seveao incident are still
being evaluated. Secondly, the oonoluding stateaeata derived froa the
oaae study of the 55-ye»r*old woman need to be re-examined. Tha
eliminatioa half-lifa for TCDO ia a variety of aalaml apeoiea raagea
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Page 9 - Mr. Ctrl Hickas
fro* 10 to 43 days. In addition, McNulty reported the TCDD ellaiaatioa
half-lift in the fat of monkeys was approximately 3$5 days. For the oaae
in question, 58 percent of the recovered TCDD was taken froa adipose
tissue . It is lapossible, la the absence of human data, to predict
whether twenty, several, or no half-lire* Bay have occurred in the seven
month period. Therefore, it is inaccurate to definitively state "...the
people included in this study accumulated large amouats of dioxia..."
Furthermore, it is unacceptable to compare actual amounts (ug, aass units)
of an absorbed toxicant between differing species without normalization to
factors such ss body weight, surface area, metabolic rate, or life spaa.
If the total amount of dioxia (40 ug) calculated for the case in question,
is normalized to body weight (70 kg), the actual absorbed
dose (0.57 ug/kg) is not 1000 to 3000 tiaea higher than the tolerable doae
calculated (LDjo* 0.6 ug/kg) using guinea pig acute toxicity data.
QTHgf OISCPSSIQS
Of special concern is the fact that the WTP's oxidation ponds would be
subject to inundation by floods equal to or greater than a 5-year flood
(p. 3-20, Vol. I; Table 4.1, Vol. II; plates 4-t 4 4-2, Vol. III).
Because a mass release froa the oxidation lagoons as a result of major
stora oould spread 2,3i7|8-TCDD-oontaminated materials to aa extensive,
area downstreaa, remedial effort must be taken to reduce this potential
impact .
In inspecting the alte and the HI exhibits (Plate Ifo. 3-10, Vol. Ill) of
the "Old Sewage Treatment Plant," the police shooting range portrays
features that reveal the possible existence of some previous treatment
works that may have been covered after being abandoned. This area should
be sampled if it waj a part of the old treatment works.
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Page 10 - Mr. Cirl Hiekaa
Multiple land uaea exist dovnstreas of the 7ertao site and the existing
WVTP, These include residential, industrial, commercial, agricultural,
and unzoned areaa, Cleanup levela for 2,3,7,3-ICDD in sediments/soils in
dovnatreaa land uae area* ahould depend upon the potential human exposure
aaaociated with these laad uses. The future development potential and
realization of the undeveloped floodplaln areas depend upon the Flood
Daoage Prevention Ordinance dated September 15, 1977. 3inoe this
floodplain ordinance doea perait construction of new structure*, cleanup
levela for currently undeveloped floodplaln/floodway land uaea ahould
till apply,
Existing residences along both the east and west leg of Rooky Branch nay
be subject to a variety of flood events. Residences on Alta Cove, Uta
Lane, Hill Road, and the ends of Brad en, West Lane, Bines Lane, and Hlnes
Cove, and at the Willow Bend Apartments off Marshall Road lie within
the 100-year floodplaln, the designated floodway, or the 2-year or 5-year
floodplaln. Many of the residential yards incorporate the Rocky Branch
creek banks as part of the yard and lack any physical barrier between the
yard and the creek. Toys, play areas, and human paths were observed in
and next to the Rocky Branch channel and banks.
Currently, health advisory levels for 2,3,7,8-TCDD ia flab hart been
developed only for the Great Lakes. Tn* 1TSDR ha* previously reoossMndeil -
that FDA determine whether the Great Lakes health advisory for
2,3,7,8-TCDD la flab ahould be revised for the Jacksonville area. The
Justification for a cleanup level for 2,3,7,8-TCDD la waterway sediments,
and /or soils subject to erosion, ahould depend upon the potential for
huaan exposure. If the existing fish baa for the Jacksonville area is
ineffective in preventing human exposure froa the affected food-chain,
additional remedial efforts would be required. If soil sampling of
agricultural land uses along the Bayou Heto channel and floodway
downstream and subsequent biological sampling reveal unacceptable exposure
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?a«e 11 - Mr. Carl Hickaa
to farn aniaals, additional remedial aeaaurea would bt required.
The 1TSDR offera the followiaf rooomcndationa to safeguard pubilo health
froa the oonttainttioa of off-ait* areas and to better assess tht public
health hazard aaaooiated with this centtalnation, These reooBaendations
are made assuming the term, "dioxia," that is uaed ia the RX it aeant to
be equivalent to 2,3,7,8-TCDD. This ia atated in th« HI (p. 1-1, Vol. 1).
1. Specify what dloxin iaomera were analyzed for in the Rl "dloxin" dat*.
2. Obtain total and i*omer specific data for determining the 2,3,7,8-TCDD
equivalenta in off-aite aoU/aediaeat/aludge aaoplca.
3. Reatrlot general public aoceaa, including the Jaokaonrnie Oepvtaant
of Beatification eaployeea, to the abandoned WT? facilitiea (i.e.,
aludge drying beda, adjacent aurfaoe aoila, digeator, trickling
filter(a), clarifiera, aewage interceptors, pump houae, and poeaible
other contaminated faollitlea), the exiating WV7? faoilitiea
(diatribution/bypaae plpelinea and boxes, aeration lagoon, oxidation
lagoons), and adjacent aoila at the exiating WT?.
4. Develop a health and site aafety plan for workers in accordance with
OSRA standards. Outline the activities associated with contaminated
areaa in tbia plan and require individuals who engage in those
activities to wear personal protective gear/clothing in accordance
with OSHA standards and NIOSR guideliaea.
S. Restrict all general public access to both the channel and the
floodway of the west leg of Rooky Branch froa the Yertao property line
to West Main Ro«d in the residential area south of Tertao until
up-to-date aoil and sediment saapling data are Bade available.
-------
Ptft 12 - Kr. Ctrl Hiokaa
6. Insure that migration of contaainanta via surface runoff oo the 7«rtao
it* to off-site areas, particularly Rocky Branch, is no longer
occurring^
7. Insure the adequacy of exiatin* control measures en the Vertao aite to
avoid unacceptable releases, apilla, or dischargee of 2,3,7,8-TCDD and
other contaminants of concern to the VWTP. Where txistinf aeaaurea
are determined ineffective, iapleoent additional on-site reaedial
meaaurea.
8. Prevent existing pretreatment sumps on the Vertac site from bypaasin*
site contaainanta to Rooky Branch. Monitor discharges from 7ertao
sit* periodically.
9. Sample and analyze sediments for 2,3,7,8-TCDD and other contaminants
of concern on the 7ertac sits in the Rocky Branch, East Ditch, South
Ditch, the Central Ditoh, and other drainage ditohes.
N
10. Investigate the need for additional remediation of certain on-aite '
area* (i.e., portion* of Rocky Branch and drainage ditohea that have
not received any previous reaedlation, or drainage ditohea that appear
to bypaaa the pretreataent systea) before iaplemeatinf off^iu
reaediatioa of contaminated channel sediaeata or flocdplain soils
dovnatream.
11. Request local authorities to prohibit residential land uaes within the
Vertao site boundary (plate 5-2, 7.XIX). Request that aation be taken
to permit no one to live on the aite. Include anyone currently ~
residing on the Tertac aite in the State'a ezpocure study.
12. Saaple the surface soils in the immediate vicinity of the mobile boae
found on-site and its interior dusts for 2,3,7,8-TCBD and other
contaminants of concern, Insure that the aobile home reaidence on the
-------
Pag« 13 - Mr. C4rl Hiokta
site i* properly cleaned if it la found to be contaminated and moved
off-site.
13. Ptrform sampling tnd analysis of surface soils around manholes that
are dovngrtdieat of the Tertao site, have a history of overflow, or
hare the potential to OTerflov.
14. Investigate the potential for vaatevater overflows in aay building
floor drains that aay be connected to a 2,3,7,8-TCDD-contaminated WTP
Interceptor having a history of surcharge.
15. Prevent the continued degradation of Bayou Meto and Rooky Branch by
the transport of oontaainanta of concern froa both on-aite and
off-site sources of contamination.
16. Perfore detailed (fine grid) sampling and analysis of ohannel
sedlaents and floodplaln soils for 2,3,7,8-TCDD and other contaminants
of concern in and along the west leg and east leg of Rooky Branch
between the Vertao property line and the confluence point of both
Rooky Branch legs.
17. Perform fine grid sampling and analysis of ohannel sediaonts and
floodplain soils for 2,3,7,8-TCDD and possibly other oontaainanta of
concern In depositions! areas of Rocky Brsnch, upstreaa of its
confluence with Bayou Meto, and Bayou Meto between the WT? outfall
end 2000 feet downstream of the Highway 161 bridge. Conduct this
sampling or additional stapling after reaedittion of the upstreaa
areas.
18. Perfora fine grid sampling and analyses of soils/sediments for
2,3,7,8-TCDD in the Bayou Meto floodplain adjaoent to and in the
Woodhaven Mobile Home Park near Highway 161.
-------
page itt . Mr. Carl Hickam
19. Perform stapling and analysts of floodplain soil*/ sediments for
2,3,7,8-TCDD and other contaainanta of concern in any pastures,
feedlots, or farms upstreaa of the Southeastern Avenue bridge in the
Bayou Meto floodplain. Conduct sampling to a depth greater than that
which would be disturbed by local farm equipment.
20. Perform monitoring and analyses of surface waters for contaminants of
concern and other priority pollutants in Rooky Branch and in Bayou
Meto adjacent to residential areas. Designated uses and applicable
water quality standard* should be disclosed for the affected waterways
and compared with the monitoring data.
21. Consider the following guidance criteria for dloxin remediation:
a. MunlfllBftl y>*t*wfttar CallgatlQH Svaten
(1) Prevent human exposure to sludges, wastes, and sediments
containing 2,3,7.8-TCDD and other contaminants of oonoern in the
affeoted sanitary sever and/or stormaewer collection system (abandoned
and existing}*
(2) Prevent the above contaminants from contaminating the future
sewage treatment plant and any new interceptors.
b. Abandoned WTP
(1) Prevent exposure of the general publio to contaminated sludges,
wastes, soils, and sediments in the abandoned sewage treatment
facilities.
Prevent these contaminated materials from contaminating the future
evage treatment plant and collection system via aay subsurface sewer
connect ions or surface runoff.
-------
Page 15 - Kr. Carl £iekaa
(3) Consider requiring eurface toils in tnd around the abandoned
aeuage treatment faculties to Beet an action level of not acre
thaa 5-7 ppb 2,3,7,8-TCBO after remediation. [Thia la Justified
because of the infrequent contact with aurfaot aoila by the general
public, and because the preaeat land uae prectioee in th« rieinity of
th« abandoned WWT? do not appaar to ba any Mr* intanaiva thaa tna
ooaatroial araaa of tha Zroabound Diatriot n«ar Xavark, lav Jaraay,
where EPA Ragion II aatabllahed a aimilar action Iav»l6.]
impoaa tht following conditions on tha abova 5-7 ppb action laval:
Tha us«a and actiritiaa of tha aita oust not baooma
aaaooiatad with the production, preparation, handling t
consumption, or storage of food or other oonauaabla itaoa,
and food packaging materials.
-Site soils auat ba protected from aroaion that would unoorar
or transport 2,3,7,8-TCDD causing unacceptable huaan azpoaura
at a future date (refer to section on EXPOSURE PATHWAYS for
poaaibla exposure pathvaya).
(5) devaluate the applicability of the 5-7 ppb action level If
present land uae ia changed and 2,3,7,8-TCDD ia left on the aite ia
surface or subsurface aoila at levels greater than 1 ppb.
0. E»latinf WTP
(T) Prevent expoaure of tha general public to contaminated aludgea,
wastes, sddiaents, and aeila.
(2) Prevent effluent discharges or surcharge releases of
2,3,7,8-TCSD-contaminated aaterials and other contaminants of concern
*
in the treataent syatea to Bayou Heto and make every poaaible effort
to achieve desired wstevater treataent in the interim until the
future WWT? is <- ' ' ' '
-------
?ace 16 - Mr. Carl Hiokaa
(3) Reduce the potential for a aajor release of
2,3,7i8-TCBD-oontaBiaated aaterialj acd other oontaminenta of oonoern
froa the oxidation lagoons due to a major flood event,
(ft) Prevent the contaminated materials froa contaminating the future
WT? aad collection
(5) Prevent the eludfea, sodiMnts, wastes, aad soils containing
2,3,7,8-TCDD and other contaminants of oonetro in th» trvatmnt ayataa
and adjacent soils froa mUratinj to and oontaoinatinc additional
off-titt areas.
(6) Consider usiaf as action lerel leas than 1 ppb 2,3»T»^TCDD to
preTent unaooeptable buoan exposure in tht fatw for these, lands in
and vest of the oxidation lacoona that art aoned residential, or
r^ueatiaf looal autaorltiea to inrestlf ata the feasibility of
recoainc lands oontaainated with 2,3i7i*-TCDD to a leaa sanaltiye land
use.
(7) Zapleownt reaedial aeaaures to eliminate future releaaea
of 2,3i7,8-TCDD froa the site and avoid bioaoouaulation in the
foodohaia, partioularl/ food fish, and prevent adverse iapaoU upon
other sensitive land uaea dovnati
(8) Por areas on the axlatinc WT? aite vnloa are aoned for
aanufaoturini and vnion would be protected froa eroeion 67 surface
runoff or potential flood events, consider uainf the action laral of
not aoro than 3-7 ppo 2,3,7,1-ICBO *±th tna oondltloaa dlaooaaed above
under 21. b. (3), ('),* (9).
Insure that .*latln« reaidential yards contain levels < than 1 ppb
2,3,7,8-TCDD in surface soils and sediments to ainiaiae onaooeptable
huaan exposure.
-------
Ptfa 17 r Mr. Ctrl Hioku
C2J Xaoocniia that -adaquata aiaanup of r«.idantial araaa, fro. a
public hoalta parap..tlT., wqulTM that the concentration of TCDD
lift la .urftca .oil 5. i..s thta on. ppb.-S CHot. that llabrou** .t
ti,« iad Dr. Y.raoa Houk 3,5 Of CDC itat.d that larelf tt or abor.
1 PPb 2,3,7,8-TCDD la r.«ideatial ^11, ownflt b« ooa*id«r*d Mf« and
...ooajtitut* aa un*co«ptablt rlA to tuaan
(3) Por ourroatly uador^opod land. son«d for rm.14.otUl land
oon.id.r ualn, *a totloa 1^,1 IM. than 1 ppo a.S.T.e-TCBD to prtrut
uaaoo.ptabl. DUMB «poaur« la ta« futurt, or roquutlac looal
authorltlM to larMti«.t. th« f*aaibility of r«ioalac ooaUalamt*
land* to a ! Maaltlrt laad UM.
(») For floodplaia ar^j aloa« th. aff«ot«d ofiaan.l aad fLxxtvaja
whloh ar« u.*d or sea«i for ladtutrUl or owi-olal u«Mtaad «aloa
would b. prot«ot«d fro. .ro.ioa by surfto. nwoff or potantlal flood
T.nt», oowidw tulac ** totloa l.r.1 of not wr. than 5.7 ppb
2,3t7,8-TCBD with th. condition. dl*auj.*l a&cr. undar 21.b.(3),
(5).
(3) Por a«rioulturU ar.a. in th. affact^t noodplain.,
site-flpeoiflo r.qu..ta for a h.alth a....u.at wh.r. Juatlfltd bj
additional soil aaapliag and .oU l.r.l. of 2,3,7,8-TCDD and oth.r "
oontaainant. of oouoarn, or by biologioal data.
(6) To mlaiaiza th. bioaoouaulation pot.nti.1 of 2,3,7,8-TCDD la th.
aquatio foodonala, oonaidar aoairria, an intaria aotion 1^^ of laaa
than 1 ppb 2,3,7,8-TCDD la ohanaal MdliMaU tad floodplaia soil.
ubj.ot to troaioo and tranaport proo.M... [ThU r^coamandation ia
ba..d on «ciatln< aaaplinc data that r«T.al. that (a) til .dibl. fl*h
aaaplaa (136 ppt to 70* ppt 2,3,7,8-TCDD) ooll.oUd la 1984 dovn.tr.a«
of th. 7artao .it. and th. WVTP outfall to a point (BM3) 3 1/2 alia.
dovnatraaa on B.jeu Mate froa Ita oonflu.no. with Rooky Brtnoh
-------
?«< 18 - Mr. Carl Riokaa
xoe«ded PDA's Or«at Lakaa health adviaory (23 ppt) for 2,J,7,8-TC5D
In flab, tad (b) ia-atreaa, near-eurface aodiaenta collected In 1964
were equal to or leaa than 0.39 ppb 2,3,T,8-TCDD In th« Bayou Meto
from a point 200 feet upetreaa of tbe Highway 161 bridge (» poiat far
upatroam of BM3)]. Conduot future evaluation* of Bayou Meto edible
fiah tiaaue portioaa la aooordanoe with fDA'a prooedurea to aaaiat
appropriate State authoritiee deterviae the neoeeaity for ««i»»-^n^g
the preaeat fiah baa.
22. Derelop and iapleaent apeoial eroaion control criteria and a
oonti«enoy plan for reawdial operationa to avoid any further transport
of oentaoinanta dovsatreaa*
22. Beviae the buaas effeota eeotioa of the II to refleot the eoaweata
ade under BSAL7B VTICTa above.
23. To obtain information on the poaaible dlapoaition of
dredfed aediaenta, oontaot the 9.3. Any Corps of m«iae«rB for
information on any permit* for maintenance of ohannela near bridge*
and oonatruotioa of new road* that may have been performed ia looky
Branch aad Bayou Meto,
rieaae refer to Attaohment 3.
Ve appreoiate the opportunity to provide reoommeadatioaa oa thia off-eite
remediation. ₯e thank you aad Meeara. Rexroat, Jtifht, aad Saterdal for
their aaaiataaoe ia our inapeotioa of the alto.
Jeffrey A. Lyberier, M.O,
Attachaeata
-------
ATTACHMENT 1:
Itinerary
March 5, 1986:
1. Visited Mr. Dick Morris, manager of the City of Jacksonville
Wastewater Utility, for general inforaatioa on bow the wastewster
collection and treataent system it affected by the Tertac Plant.
Visited the existing vaatevater treatment plaat (WT?) which receives
vaatea from the Vertao Plant. Observed the abandoned portion of the
old WHT? (clarifiera, triokling filters, digester, and sludge drying
beds), as well as those WT? facilities (aerator, oxidation lagoons)
currently be used.
2. Flew over the Tertao Plant, adjacent residential areas, downstream
flood pi tin areas of Rooky Branch end Bayou Heto, and the WT?.
3. Drove on the Vertao Plant site to see drainage pathways and how
effective past remedial measures have been in containing on-site
wastes.
March 6, 1966:
1. Drove off the site to see potentially affeoted residential sreas,
recreation areas, and drainage pathways and their association with
adjacent land uses.
2. Visited Mr. Duane Reel, City Engineer, for information on ourrent and
projected land use toning in areas around the Vertao Plant sad
downstream in the flood plain. Zoning maps and flood Baps were
obtained .
Problem
1, According to the City Engineer, the WTP is in violation of its
discharge permit effluent limitations but the City has indioated that
they are unable to do anything about it because of the dioxin
contamination in the WTP ayetem. The oxidation lagoons are'neexly
-------
A77ACSMEXTS 1 _Coa't.
full and have inadequate retention tiae left. The City is waiting for
EPA to take action oa cloning up the existing WWT? systea and ponds.
The connection of the new interceptor to tht future VW7? (scheduled
for completion in July 1987) will depend upon th« approved cleanup of
the WTP interceptor systsa.
2. Possible evidence of air pollution exiat around the existing WT?
aerator. The City Engineer pointed out nuaeroua dead trees oa the
northwest aide of the aeration lagoon, and suggested that air
pollution from the aeration lagoon nay be responsible.
3. The public ha« excess to the abandoned WVTP areas which are
contaminated, Both potential health and safety hazards exist. The
City is usinc the contaminated sludge drying beds for growing garden
vegetables (i.e., tomatoes, cabbage, etc.) and other planta. Photos
were taken. Levels of 2,3,7,8-TCDD aa high as 7 ppb have been found
la the sludge drying beds. A potential health hazard exiata because
of bunan contact, possible transport of contaminants to the boce
environment, and ingeation of possible contaalnanta In and on
vegetables. No record exists of past people who have re&oved sludge
for boae garden use.
*. The oxidation lagoonj oould be inundated by a 5-year flood event. The
lagoons oontaln aany contaminants including 2,3,7,8-TCDD.
5. Ho aaapling has been done after on-site remedial work la the upper
portions of Rocky Branch for either the east leg or weat leg.
6. Noxious odors were apparent both on the Vertac aite and la downwind
areaa in reaidential areas south and eaat of the Vertao Plant site.
It could not be determined if these odors were related to current
production activities or waatsa disposed or stored co-site.
7. Drainage (Eaat Ditch, South Ditch, I Central Ditch) from the Vertac
Plant does not receive proper pretreament because of suap bypass
-------
ATTACHMENTS 1 Con't.
features and inadequate capacity during storm periods. Photos were
taken.
8. Portions of Rocky Branch exist oa the Vertac site that were not
included la thi oa-site remedial work.
9. Despite the newly instslled freneh drain, seeps were observed between
the new slurry wall snd Rocky Branch In the area of the on-site burial
site. Aerial photoa were taken.
10. Evidence txists that ohildren probably play in Rooky Branch
immediately downstreaa of the Vertao Plant property lice. Toys and
numerous footpaths were found in and alone Rooky Branch in the
subdivision ianedlately south of the Vertao Plant. Photos were taken.
11. i mobile home residence was observed on the Vertao site (Plate 5-2,
Vol. Ill} about 600 to 1000 feet froa the highly contaminated
"T-waetea" (druaa containing 30 ppa 2,3,7,8-TCDO), and 1000 fee*- -
from 25,000 drums containing "D-vaates." The residents of this mobile
home appear to hare access to the site by a locked baokgate. i dog
and toys were seen obaerred in the yard. Photos were taken.
12. Some residential yards immediately downstreaa of the Vertao Plant
share en intimate assooiation with both the west and east legs of
Rocky Branch.
13. Some Bayou Meto floodplaln areas downstream of the Vertao Plant and
the WWTP are used for gracing, erop production (rioe and soybeans},
and possibly other agricultural purposes.
1«. Even though a flood prevention ordinance exists, portions of the
in can atill be developed for residential purposes and other
-------
"!:'& :. s:w»v :r :::;:? .-VEIS rets: M :«-srs :RE:S, ^CKSIN.IH-, «»;«;><
. :r
L!r:"!V ;i'
?tsi:t.v.:i: /ir::
Ate JN04MAIJ. MM^Oi
CinCSnlS 11 r!
SLijt tfryiflj 3«aj
:i;iitor
Cltnfiir
Sludji Calleitian Am
Emtinq VUTPi
Airitian li^can
Oxidiiiai Ijgcan
Smtrhm
*inhai»
finholi 171
Binhail '77
r»i.iha!e 174
"nholi
Reck/ Irinch:
«Mt 1|?*
Cut !*<)
2-iTr Floirtpliift
At Hifhi^ ^/147
At Blyou fltto
l«rou Htta:
At UHTP disctiirgt
Flooaal. S Ll. Duprii
Just Above no'Pic.RR
At Kt-Pic.RR
At Hi)ft««r lil'
8*1 4. U-^h.i. lil
'c'.: ?ArJ I!!? !"«'::!! (Cji....-.i
:"?
:??
1?32
;?3<
1994
1984
1?84
1984
1779
197f
lf«
1984
1979
1981
1993
[984
1'U. Ur.il
NO
4.:f
12. U
1.42
1.11 (20'NE of kinnii)
37.?
1.7 (north pond)
7. 73 (Hut* pond)
7.4 tcoioailti)
3.4 (ncrth)
1.13
10.9 (frtden 1 Alti)
33. 4 (Indin 4 Alti>
>2CO (nr SE of VirUc)
119.4 (Hill Rd.)
22.3 (IridM 4 Alti)
0.27
3.2 Imtr Alti Cavil
3.01 (Ar V. Line wd)
7.18 (new Him Cs»«)
0.41 1 dupliciti*0.n3
(Ifirihill Rd ditch)
0.!3S (Hill Rd)
0.8 (SE corner Vertic)
0.17 IHjll Id)
1.7 (MIT UUTPI
1.3 tniir MVTP)
,2.3
<1.9
1.13
0.74 (100 ft ibott 1R)
2.1
l.IS
1.32
1.4:
1.4
(1.0
1.10 (200 ft u«ftrm>
1.08 (2000 ft dawutrt
;p.:-4,v.u
!p.2-4,v.:j
!p.2-!,V.:i
(50238)
(S02:il
(S02&A1
(S027I1
(S018A)
(P.2-4.V.1)
(P.2-4.V.D
(p.2-4,7.I)
(S01!«l
(p.2-4,V.l)
(p. 2-4, V.I)
IK-HI
U014A)
II013A)
mon A)
(p.2-4,V.I)
(M-21)
(N02&C1
(N030C)
(Ti»le 3-1,7.
(Tlbll 5-1, V.
(Tiblt 3-1, V.
U-9)
(F104A1
(F105C)
(p.2-4,V.l)
(p. 2-4, V. I!
(F-10)
IF014A)
(F047C)
(FCWC)
IF0408)
u»;»'
-
-
JFCC«013
OFOOHO&
BFW304
DF004309
DfO«40» t,
3FM3412 t,
-
!FOOI«04 i,.,
BF004U4 |,
9F0041C! (,
-
-
-
OFOOJ5U
BF003113
111
III, p. 5-20)
llI.p.MO)
OF004212
3F004210
:FOO;&:O e,
1F003:13 *
OFOOI817
3F003403
J-l,V.[tll
-
3F004001
9FQ04004
3iti crisr ta tin X! KI huttd iuf ta inidiqujti quality
'fit 1913 jtijjtian !»^:tn sueltt »fi t*t«n frji h4rd battea
In »rr i»«^ ««d/or ifl l«tmtt nse:iition
net 5» .«-i»:rt 5\ **ttli 5-1 in Vsl. II
-------
ATTACHMENT 3:
1. U.S. Environmental Protection Agency, national Interim Primary
Drinking tfatsr Regulations, Appendix A Background Document,
EPA-570/ 9-76-003, 1976.
7. Sax, N, Irvine, Dangerous Properties of Industrial Materials, Sixth
Edition, 1984.
3. utter dated July 3, 198U, from Or. 7ernon Houk, CDC, ATSDR, to
Mr. Morris, U.S. EPA, Region Til.
4. Kimbrough, Senate D., Falk, Henry, and Stahr, Paul of Center for
Environmental Health, CDC, and Fries, George of Department of
Agriculture, Health Implications of 2,3,7,8-TCDD Contamination of
Residential Soil Journal of Toiloologv md Environmental Health.
5. Letter dated July 9, 195*, from Dr. Vernon Houk, CDC, ATSDR, to
Mr. Devi ing, Regional Adminatrator, U.S. EPA, Region IX.
6. Memorandum dated October 26, 1981, from Ms. Georgi Jones, Chief,
Superfund Implementation Group, CDC/ ATSDR, to Mr. David P. Inorowski,
Public Health Advisor, EPA Region II.
-------
APPENDIX C
-------
4
^
DEPARTMENT OF HEALTH & HUMAN SER\ ICES Pubi.c Hea'th Series
Age-'Cv 'or T,;» C Shasta'
and D seasr Reg,sir.'
Atlanta GA 30333
June 11, 1990
Mr. Sam Becker
Chief, Superfund Enforcement Branch (6H-E)
United States Environmental Protection Agency
Region 6
1445 Ross Avenue, Suite 1200
Dallas, Texas 75202-2733
Dear Mr. Becker:
I have received your letter of May 29, 1990 requesting the Agency for
Toxic Substances and Disease Registry (ATSDR) to approve, in terms of
public health protection, the remedial plans for the Vertac, Jacksonville
Landfill, and Rogers Road Landfill Superfund sites located in
Jacksonville, Arkansas.
On May 3, 1990 a meeting vas held in Atlanta to discuss, in depth, the
proposed remediation at these Superfund sites. Present at the meeting
were members of your staff and representatives of the Centers for Disease
Control and ATSDR. A brief synopsis of your proposed remedies follows:
VERTAC SITE
Sever Lines and Manholes:
The 2,3,7,8 tetrachlorodibenzo-p-dioxin (TCDD) contaminated sediments from
the active interceptor and manholes will be removed by hydraulic flushing,
followed by remote TV camera inspection to assure that all sediments have
been removed. Sediments will be devatered and incinerated. A pipe liner
will be installed in the active interceptor to improve structural
stability and to avoid possible recontamination by inflow. The abandoned
interceptor will be filled vith grout to immobilize any contaminated
sediments and to prevent flow into and out of the line.
Abandoned Trickling Filter Plant:
The accumulated water in the trickling filters and clarifiers will be
treated in activated carbon columns prior to discharge, and the spent
carbon and filter spools will be incinerated. The digester sludge will
also be incinerated. All of the units in the trickling filter plant will
be demolished, and the debris covered with a foot of clean soil. The
sludge drying beds will also be covered with a foot of clean soil. The
abandoned trickling filter plant will continue to be fenced and access
restricted.
-------
Page 2 - Mr. Sam Becker
Active Vest Vastevater Treatment Plant:
The aeration basin vill be devatered, and the water treated with activated
carbon prior to discharge. The dikes of the aeration basin will be
demolished, and the basin covered with a foot of clean soil. The
oxidation ponds will, aost likely, be used for storage and release of
effluent from the Vertac leachate collection and treatment system. The
wastewater treatment plant will continue to be fenced and access
restricted.
Rocky Branch Creek and Bayou Meto Flood Plain:
In these flood plains, soil containing more than 1 ppb TCDD in undeveloped
residentially zoned areas, will be excavated and hauled back to the Vertac
site for ultimate disposal.
Rocky Branch Creek and Bayou Meto Sediments:
The TCDD concentrations in the sediment are as high as 2.3 ppb in the
creek, and as high as 1.03 ppb in the Bayou. A fishing ban will remain in
place.
JACKSONVILLE AND ROGERS ROAD LANDFILLS
All material with TCDD concentrations greater than 10 ppb will be
excavated for treatment and the dioxins will be destroyed to levels below
1 ppb. Residual contamination exceeding 1 ppb will be capped by a foot
or more of clean fill. The fence around these sites will be maintained by
the City and the deeds will indicate that the sites are considered
unacceptable by EPA for residential use.
I believe that the above briefly but accurately summarizes your proposed
remedies. The ATSDR in consultation with the Centers for Disease Control
believes that with the following clarifications the proposed cleanup
strategies for these Superfund sites will be protective of human health:
1. Erosion controls are necessary to protect the additional soil used as
clean cover.
2. With regard to the Rocky Creek and Bayou Meto sediments, the fish
tissue concentrations must be monitored for dioxin and the fishing ban
should remain in effect until the fish are determined to be safe for
unlimited human consumption.
-------
Page 3 - Mr. Sam Becker
If you have any questions or require additional clarification please do
not hesitate to contact me.
Sincerely yours,
Edvin Kent Gray
Chief, Emergency Response
and Consultation Branch
Division of Health Assessment
and Consultation
-------
APPENDIX D
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APPENDIX E
-------
STATE OF ARKANSAS
DEPARTMENT OF POLLUTION CONTROL AND ECOLOGY
8001 NATIONAL DRIVE, P.O. BOX 9583
LITTLE ROCK, ARKANSAS 72209
PHONE: (501) 562-7444 -- PTC 1 - f, ' : W5
FAX: (501) 562-4632
September 7, 1990
Ms. Ellen Greeney
Community Relations Coordinator
U.S. EPA, Region 6 (6H-MC)
1445 Ross Avenue
Dallas, TX 75202-2733
RE: Vertac Off-Site Proposed Remedies
The Arkansas Department of Pollution Control and Ecology presents
the following comments regarding the proposed plan for Vertac
Off-Site:
1. The extremely low concentration of TCDD in the Rocky
Branch Creek Flood Plain requires careful evaluation of
the advantages of remedial action, verses the ecological
damage resulting from that action.
2. The analytical data for the sewer lines, sewer treatment
plant, and lagoons were derived from samples taken in
1984. The flood plain was sampled over two years ago.
All of these areas should be resampled prior to any
remedial action.
3. The cleanup levels in the flood plain are based on health
risks associated with the residential soil contamination.
Rezoning the flood plain area from residential to
commercial, in the flood plain areas where no development
has occurred, would eliminate the remedial action needs
based on a change in health risk scenario. It would serve
to save millions of dollars and remain protective of human
health and the environment and be non-destructive to the
existing ecology. These issues should be seriously
considered while finalizing a Record of Decision.
We concur with the balance of the proposed remedy as outlined by
EPA in the proposed plan. We appreciate your consideration of the
State's comments.
Mike Bates
Chief
Hazardous Waste Division
MB:cw
-------
STATE OF ARKANSAS
DEPARTMENTS POLLUTION CONTROL AND ECOLOGY
8001 NATIONAL DRIVE, P.O. BOX 9583
LITTLE ROCK, ARKANSAS 72209
PHONE: (501) 562-7444
FAX: (501) 562-4632
September 18, 1990
Garret Bondy
Chief, AR/LA Superfund Enforcement Section
U.S. EPA Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
RE: Vertac Off-Site Proposed Remedy
Dear Mr. Bondy:
It has come to my attention that my September 7, 1990, letter to
Ms. Ellen Greeney regarding the Vertac off-site proposed remedies
may have been mis interpreted by EPA. The comments relative to the
proposed remediation of the flood plain areas was not intended to
suggest our nonconcurrence. We understand the basis for selection
of the clean-up criteria and agree that application of said
criteria (clean-up to 1 ppb TCDD) should be accomplished based on
this criteria.
Our comments were intended to point out the ability to use or
provide flexibility in the application of cleanup criteria during
the decision making process. We urge EPA to exercise as much
flexibility as feasible in the application of the clean-up standard
(and particularity in the design and implementation of the remedy).
I hope this clarifies any questions EPA may have regarding our
position on the Proposed Plan.
Sincerely,
Mike Bates
Chief
Hazardous Waste Division
MB:cw
-------
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