\
I
X
United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R06-90/063
September 1990
Superfund
Record of Decision:
Rogers Road Municipal
Landfill, AR
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/RO6-90/063
3. Recipient1* Accession No.
THIe ind Subtitle
ISUPERFUND RECORD OF DECISION
Rogers Road Municipal Landfill, AR
First Remedial Action - Final
5. Report Date
09/27/90'
7. AuthOf(«)
8. Performing Organization Rept No.
8. Performing Organization Name and Address
10. ProjecVTask/Work Unit No.
11. Contract(C) or Gram(G) No.
(C)
(C)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
IS. Supplementary Notes
°
O
16. Abstract (Limit: 200 words)
The 10-acre Rogers Road Municipal Landfill site is an inactive landfill in a
residential and agricultural area in Pulaski County, outside the city limits of
Jacksonville, Arkansas. Approximately 50 residences are located within one-half mile
of the site. Furthermore, the site lies within a 100-year floodplain and has poor
^drainage because of slow percolation of rainwater. From 1953 until 1974, approximately
ne half of the site was used intermittently as a municipal waste disposal facility.
'Specific waste types and quantities are unknown; however, wastes appear to have been
disposed of in a long excavated trench and in several surface piles. In addition,
chemical waste materials probably originating from the nearby Vertac Chemical
Corporation, including herbicides and associated dioxin impurities, have been disposed
of at the site. Currently, as many as 50 drums of contaminated materials are estimated
to be onsite, of which 30 drums are visibly corroded with their contents exposed.
Investigations by EPA beginning in 1983 revealed that a 1/2-acre drum disposal area
containing drums, waste piles of other types of contaminated debris, and associated
soil contaminated with herbicides and dioxin, comprises the principal threat from the
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Rogers Road Municipal Landfill, AR
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: organics [dioxin, furans, 2,3,7,8-TCDD, pesticides (dieldrin),
b. Identifiers/Open-Ended Terms
and herbicides (2,4-D, 2,4,5-T, 2,4,5-TP)]
c. COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
164
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
Ur IIUNAL rUHM 272 (4-f I)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R06-90/063
Rogers Road Municipal Landfill, AR
irst Remedial Action - Final
Abstract (Continued)
site. Vertac Chemical Corporation wastes were also disposed of at the Jacksonville
Municipal Landfill Superfund site, which is 1/2 mile east of the site. To achieve
economies of scale, the two sites will be remediated concurrently, including
excavating highly contaminated wastes and soil, and transporting these to Vertac for
final treatment and disposition. The primary contaminants of concern affecting the
soil and debris are organics including dioxin/furan (2,3,7,8-TCDD), the pesticide
dieldrin, and herbicide compounds (2,4,5-T, 2,4-D, and 2,4,5-TP).
The selected remedial action for this site includes additional soil sampling with
excavation of approximately 50 cubic yards of highly contaminated soil and debris
(i.e., greater than 10 ug/kg of 2,3,7,8-TCDD), followed by offsite temporary storage
of the material at the Vertac Chemical Corporation Superfund site; conducting thermal
treatment of all Rogers Road site material stored at the Vertac site, followed by
residual analysis to evaluate treatment effectiveness, backfilling of residuals on
the Vertac site, and revegetating backfilled ash areas; steam cleaning and disposing
of debris removed from the Rogers Road site at the Vertac site; backfilling excavated
areas and the open trench with uncontaminated n-ative soil and decontaminated refuse;
covering onsite soil, debris, and waste contaminated at low levels (i.e., below the
cleanup criteria) with twelve inches of native soil; inspecting and maintaining soil
caps and fences; ground water monitoring; and implementing institutional controls
including ground water and land use restrictions. The estimated present worth cost
for this remedial action is $1,226,000, which includes a total O&M cost of $384,000
pver 30 years.
ERFORMANCE STANDARDS OR GOALS: Pre-remedial action levels have been identified and
will be used to determine where soil remediation is required. Post-remedial
treatment goals will be used to assure that effective treatment has been achieved.
Moderately-contaminated soil and debris triggering action levels, including
2,3,7,8-TCDD between 1 and 10 ug/kg (10~5 excess cancer risk), dieldrin greater than
37.0 ug/kg (10~7 excess cancer risk), and/or a dieldrin and herbicide (2,4,5-T and
2,4,5-TP) combination resulting in a cumulative Hazard Index (HI) exceeding 0.7, will
be covered with 12 inches of clean soil. Thermal treatment will be used for
approximately 50 cubic yards of soil and debris with 2,3,7,8-TCDD exceeding 10 ug/kg.
Treatment goals include achieving 2,3,7,8-TCDD 1.0 ug/kg (health-based) or a 99.9999%
destruction removal efficiency (40 CFR 264.343), and 2,4-D 10,000 ug/kg (40 CFR
268.43), 2,4,5-TP 7,900 ug/kg (40 CFR 268.43), and dieldrin 37 ug/kg (health-based),
as well as a combined dieldrin and herbicide cumulative HI less than 0.7. The
overall residual risk attained by these goals will be less than 8 x 10~^ and a
maximum cumulative HI of 1.0.
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Record of Decision
Rogers Road Municipal Landfill
Superfund Site
U.S. Environmental Protection Agency
Region 6
September 1990
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DECLARATION FOR THE RECORD OF DECISION
ROGERS ROAD MUNICIPAL LANDFILL, ARKANSAS
SEPTEMBER 1990
Statutory Preference for Treatment as a
Principal Element is Met
and Five-Year Review is Required.
SITE NAME AND LOCATION
Rogers Road Municipal Landfill
Pulaski County, Arkansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Rogers Road Municipal Landfill site in Pulaski County,
Arkansas, which was chosen in accordance with Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP).
This decision is based upon the contents of the administrative
record file for the Rogers Road Municipal Landfill site.
The United States Environmental Protection Agency and the Arkansas
Department of Pollution Control and Ecology agree on the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This final remedy addresses remediation of soil contamination by
eliminating or reducing the principal and low-level threats posed
by the site through treatment, engineering and institutional
controls.
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The major components of the selected remedy include:
o Sampling soil in ten-foot by ten-foot grids to more accurately
define the amount of contaminated surface soil, debris, and
waste onsite;
o Excavating and packaging for transport contaminated soil and
debris containing more than 10 parts per billion (ppb)
equivalent 2,3,7,8-Tetrachlorodibenzo-p-dioxin (2,3,7,8-
TCDD);
o Transporting contaminated material to the Vertac Chemical
Corp. Superfund site in Jacksonville, Arkansas, and providing
temporary storage for the material at the Vertac site;
o Conducting thermal treatment of all Rogers Road Landfill
material being temporarily stored at the Vertac site, and
testing, disposal and revegetation of the resulting ash;
o Steam cleaning and disposing of large items of refuse removed
from contaminated areas at the Rogers Road site;
o Backfilling and revegetating areas from which contaminated
soil was removed with uncontaminated native soil and
decontaminated refuse;
o Covering soil, debris and waste meeting the criteria stated
below with twelve inches of native soil;
CRITERIA: 1) Equivalent 2,3,7,8-TCDD concentrations greater
than 1.0 ppb and less than or equal to 10.0 ppb, or
2) Dieldrin concentrations greater than 37.0 ppb,
or
3) Cumulative Hazard Index greater than 0.7 for the
following compounds:
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T),
2,4,5-Trichlorophenoxy propionic acid (2,4,5-TP),
and
Dieldrin.
o Backfilling the open site trenches with clean fill;
o Ground water monitoring;
o Inspection and maintenance of the soil caps and of the
existing fence; and
o Land-use controls limiting ground water use on and immediately
downgradient of the site.
ii
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STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the en-
vironment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies (or resource
recovery) to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
Robert E.Layton Jr<,P.E.Date
Regional Administrator
U.S. EPA - Region 6
111
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TABLE OF CONTENTS
Section
DECISION SUMMARY 1-1
SITE LOCATION AND DESCRIPTION 1-1
SITE -LOCATION 1-1
SITE DESCRIPTION AND HISTORY 1-1
Topography and Surface Characteristics . . . 1-5
Geology 1-8
Hydrogeoloav 1-9
Classification of Ground Water 1-11
SURROUNDING LAND USE AND SENSITIVE RECEIVERS . . 1-12
ENFORCEMENT HISTORY 1-13
HIGHLIGHTS OF COMMUNITY PARTICIPATION 1-14
SCOPE AND ROLE OF PROPOSED RESPONSE ACTION 1-15
SUMMARY OF SITE CHARACTERISTICS 1-16
NATURE AND EXTENT OF CONTAMINATION 1-16
Soils 1-16
Onsite Soils and Sediment 1-16
Offsite Soils 1-24
Ground water 1-24
Monitoring Wells 1-29
Residential Wells 1-30
Surface Water 1-30
Background Water 1-31
Onsite Trench Water 1-31
Offsite Surface Water 1-31
Air Pollution 1-32
CONTAMINANT FATE AND TRANSPORT 1-32
Potential Routes of Migration 1-32
Soil 1-32
Ground water 1-33
Air 1-34
Surface Water/Sediment 1-35
SUMMARY OF SITE RISKS 1-37
EXPOSURE ASSESSMENT SUMMARY 1-39
Direct and Indirect Contact with Contaminated
Surface Soil Onsite and/or Offsite . . 1-40
Direct and Indirect Contact With Ground
water 1-41
Transport by Surface Runoff 1-41
Direct and Indirect Exposure to Surface Water
and Associated Biota 1—41
Inhalation 1-42
RISK EVALUATION SUMMARY 1-42
Explanation of Carcinogenic Risk 1-42
Explanation of Noncarcinogenic Risk .... 1-43
Results 1-43
DEVELOPMENT OF REMEDIATION GOALS 1-49
Pre-Remedial Action Levels 1-52
Page TOC-1
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Carcinogenic Risks 1-52
Noncarcinoaenic Risks 1-53
Post-Remedial Treatment Goals 1-54
DESCRIPTION OF ALTERNATIVES 1-55
COMMON ELEMENTS 1-55
Components 1-56
Costs 1-57
Applicable or Relevant and Appropriate
Retirements fARARs) 1-58
ALTERNATIVE 1 — NO ACTION 1-60
Description 1-60
Cost and Timing 1-60
Compliance with ARARs 1-60
ALTERNATIVE 2 — FENCE, CAPPING, LAND-USE CONTROLS,
MONITORING 1-61
Description 1-61
Cost and Timing 1-62
Compliance with ARARs 1-63
ALTERNATIVE 3 — EXCAVATION, OFFSITE THERMAL
TREATMENT AND LANDFILL, SOIL COVER, LAND-USE
CONTROLS, MONITORING 1-63
Description 1-63
Cost and Timing 1-64
Compliance with ARARs 1-65
ALTERNATIVE 4 — EXCAVATION, ONSITE THERMAL
TREATMENT, SOIL COVER, LAND-USE CONTROLS,
MONITORING 1-65
Description 1-65
Cost and Timing 1-67
Compliance with ARARs 1-67
Multiple Sites 1-68
ALTERNATIVE 5 — EXCAVATION, THERMAL TREATMENT AT
THE VERTAC CHEMICAL CORP. SITE, SOIL COVER,
LAND-USE CONTROLS, MONITORING 1-68
Description 1-68
Cost and Timing 1-70
Compliance with ARARs 1-70
Multiple Sites 1-71
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . 1-71
DESCRIPTION OF THE NINE EVALUATION CRITERIA . . . 1-71
ANALYSIS 1-73
Overall Protection 1-73
Compliance With ARARS 1-74
Long-Term Effectiveness 1-74
Reduction in Toxicitv. Mobility, or Volume
Through Treatment 1-74
Short-Term Effectiveness 1-75
Implementability 1-76
Cost 1-77
State Acceptance 1-77
Community Acceptance 1-77
SELECTED REMEDY 1-78
Page TOC-2
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DETAILED DESCRIPTION OF REMEDY ......... 1-79
REMEDIATION GOALS ................ 1-82
...................... 1-83
COST ...................... 1-83
STATUTORY DETERMINATIONS ............... 1-84
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT . 1-84
COMPLIANCE WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS .......... 1-91
COST-EFFECTIVENESS ............... 1-92
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES) TO THE MAXIMUM EXTENT
PRACTICABLE ................ 1-93
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT . 1-93
DOCUMENTATION OF NO SIGNIFICANT CHANGES ..... 1-93
RESPONSIVENESS SUMMARY .................. 2-1
OVERVIEW ....................... 2-1
BACKGROUND ON COMMUNITY INVOLVEMENT ......... 2-1
SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD ..................... 2-2
TECHNICAL QUESTIONS/CONCERNS REGARDING SELECTED
ALTERNATIVE ................ 2-2
QUESTIONS/COMMENTS REGARDING REMEDIAL ALTERNATIVE
PREFERENCES ................ 2-5
QUESTIONS REGARDING EFFECTIVENESS OF INCINERATION 2-10
QUESTIONS REGARDING THE REMEDIAL INVESTIGATION, RISK
ASSESSMENT AND FEASIBILITY STUDY METHODS AND
CONCLUSIONS . . .............. 2-11
QUESTIONS REGARDING OTHER ISSUES ........ 2-12
APPENDIX A — ADMINISTRATIVE RECORD INDEX .......... A-l
Page TOO 3
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LIST OF TABLES
Table page
1 Drum Disposal Area Sample Analysis Summary 1-21
2 Ground water Monitoring Well Sample Analysis
Summary 1-26
3 Summary of Site Risks Onsite and to Nearby
Residential Population — Carcinogenic Effects .... 1-45
4 Summary of Site Risks Onsite and to Nearby
Residential Population — Noncarcinogenic Effects . . 1-47
5 Summary of Remediation Goals 1-50
6 Cost Estimate: Alternative 5 1-85
LIST OF FIGURES
Figure Page
1 Site Location Map - State of Arkansas 1-2
2 Site Location Map - Jacksonville, Arkansas 1-3
3 Site Sampling Locations 1-6
4 Site Details 1-7
5 Ground Water Sample Locations (GW, RW) 1-25
Page TOC-4
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SECTION 1.0
DECISION SUMMARY
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DECISION SUMMARY
SITE LOCATION AND DESCRIPTION
SITE LOCATION
The Rogers Road Landfill Site is located in Pulaski County,
outside the city limits of Jacksonville, Arkansas (Figures l and
2). It is situated immediately east of Rogers Road, one-tenth
mile south of Graham Road. An old unpaved dirt road extends from
Rogers Road and goes through the residential area, terminating at
the landfill. Land records at the Pulaski County Court House
describe the ten acre plot of land as the east half of the
northeast quarter of Section 28, Township 3 North and Range 10
West. The site is approximately 12 miles northeast of Little
Rock, Arkansas.
Less than one-half mile east of the Rogers Road Landfill site lies
the Jacksonville Municipal Landfill. The Jacksonville site is
also a nationally-ranked Superfund site which is at the same stage
in the Superfund process as the Rogers Road Landfill site.
Because of the proximity of the sites and the similarities in
their features and characteristics, the site-related activities to
date have been conducted concurrently. It is further intended
that all future remedial activities will continue to be conducted
simultaneously so that "economies of scale" can be realized.
SITE DESCRIPTION AND HISTORY
The property was acquired by the City of Jacksonville on September
16, 1953. Approximately half of the site was used intermittently
as a municipal waste disposal facility, in conjunction with the
Jacksonville Landfill, until October 1974. The landfill was
closed when the Arkansas Department of Pollution Control and
Ecology (ADPC&E) refused to grant a landfill permit because of the
high water table and poor drainage in the area.
Records indicate that open burning and trenching with bucket and
dragline were the waste handling methods used until 1974, along
with open dumping and landfilling. No detailed records indicating
specific waste types or quantities are known to have been kept by
the site owner/operator, making identification of generators and
operators difficult. Wastes appear to have been disposed of in
one long excavated trench, and in several surface piles,
accompanied by open dumping in numerous areas around the site.
After waste disposal, the trench, some of the surface piles and
possibly other objects appear to have been covered with a layer of
soil. After the landfill was closed, local residents continued to
use the site as an open dump until the site was fenced. The
portion of the facility used for burning and land disposal was
fenced in 1986, by the City of Jacksonville, to prevent
Page 1-1
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'SITE LOCATION
SITE LOCATION MAP
ROGERS ROAD LANDFILL, JACKSONVILLE, AR
FIG 1
1-2
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09 OOM01
_J
•oa Dunn*
1-3
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unauthorized access. The dimensions of this area are 300 feet x
237 feet (1.63 acres).
In addition to municipal waste, waste materials from the Vertac
Chemical Corp in Jacksonville, Arkansas may have been disposed of
at the Rogers Road site. This chemical plant produced numerous
chemical products, including herbicides (and associated dioxin
impurities). An estimated 15 to 50 drums of dioxin contaminated
herbicide manufacturing waste were disposed of at the landfill.
Approximately 30 drums are visible at the Rogers Road Landfill.
They are not labeled and are very corroded. Parts of the drums
are missing and the contents are exposed.
There are no structures on the landfill site property. The site
is heavily vegetated, including the area used for drum disposal
which is overgrown with tall grasses, except for the pile of
corroded drums and herbicide waste, where herbicide contaminated
material is exposed on the surface.
The Rogers Road Landfill was identified to EPA on May 10, 1983,
through a citizens complaint while EPA was conducting a site
inspection of the Jacksonville Landfill, located one-half mile to
the east. During a private investigation conducted for the EPA as
part of a Potentially Responsible Party search, it was reported
that municipal wastes from the City of Jacksonville as well as
chemical wastes were disposed of at the Rogers Road Landfill. No
written records were apparently maintained by the commercial or
residential users that identify the quantities or types of wastes
disposed of at the site.
In May, 1983 a Technical Assistance Team (TAT) from Weston-SPER
inspected the site. A Field Investigation Team (FIT) from Ecology
and Environment inspected the site in May, 1985 for photo
documentation and to assess the site for access. The Ecology and
Environment FIT performed a site investigation in June 1985. A FIT
report was prepared in September 1985 outlining the soil, residen-
tial well, surface water, sediment and air sampling results.
The Rogers Road Landfill was proposed for inclusion on the EPA
National Priorities List (NPL) of uncontrolled hazardous waste
sites on January 22, 1987. It was added to the NPL on July 22,
1987. The NPL score for this site was 29.64.
A remedial investigation (RI) was conducted at the Landfill, with
field activities occurring between November 1988 and March 1990.
In conjunction with the RI, a risk assessment (RA) was performed
based upon the analytical results for the field samples. The
results of the RI, along with those from prior site
investigations, were summarized in an June 1990 Remedial
Investigation Report prepared by PEER Consultants, P.C. and
Resource Applications, Inc. The description of the site and of
Page 1-4
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associated contamination in this Feasibility Study is based
largely on material in the RI report.
Having completed the RI and RA reports, the project proceeded to
the Feasibility Study (FS) phase. The FS was conducted in order
to screen and evaluate the most promising options for remediating
the site. In addition, it provided a basis for remedy selection.
The results of- the FS are documented in the Feasibility Study
Report, June 1990.
Topography and Surface Characteristics
The natural terrain at the Rogers Road Landfill is flat. However,
there are several soil mounds (approximately two to four feet
high) covering piles of waste and possibly at least one buried
container or transformer. A partially backfilled trench, where
waste disposal and burning took place, is located at the north end
of the fenced portion of the site. It appears that no excavation
had taken place since the landfill was closed in 1974 until the
remedial investigation.
Figure 3 shows the shows the locations from which soil and
sediment samples were taken and the general layout of the site;
Figure 4 shows general features of the fenced portion of the site,
where the most contaminated soil is located.
The site is generally covered with grass and ten to fifteen year-
old wooded growth. Vegetation is very lush throughout the
landfill, with the exception of the drainage ditch alongside the
western edge of the landfill and an area used for the disposal of
drums of chemical waste, called the drum disposal area.
The drum disposal area contains a central waste pile and several
smaller piles. The central pile includes pieces of corroded drums
and shipping pallets, along with crusted, fibrous waste material
contaminated with herbicides and dioxins. Smaller waste piles
containing similar waste, debris and pieces of corroded drums are
located near the central pile in the drum disposal area. Five
mounds, each approximately three feet long, two feet wide and two
feet tall are located at the west and northwest edges of the drum
disposal area, within 50 feet of the nearest waste pile. At least
one of the mounds contains contaminated waste and possibly
transformers or other objects. A ridge is located northeast of
the drum disposal area. A pile of rusty paint cans is located
near the fence on the west side of the site; and a large portion
of the south end of the site is covered with briars, bottles and
broken glass.
The contaminated portion of the site is surrounded with a four
foot tall fence. It is not effective at keeping people off the
site. Portions of the fence were barbed wire and were reported to
have been removed by scavengers.
Page 1-5
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DS-H*
*DS-Q8
DS-05* *DS-07
*SSB-04
*w<
5DS-10
%^^
ENLARGED
DRUM SAMPLING
AREA
*SSC-04
*SSD-03
Pfrp™»/- 00^)2
SS-SUBSURFACE SOIL GRID SAMPLE
PS-SUBSURFACE SOIL SAMPLE(2-3 FEET)
PT-SOIL PILE SURFACE SAMPLE
OS-OFF SITE SOIL SAMPLE
SB-BULK SOIL SAMPLE
TB-BULK TRENCH SAMPLE
TS-TRENCH SEDIMENT SAMPLE
DS-ON SITE DRUM SAMPLE
OD-OFF SITE DRAINAGE SEDIMENT SAMPLE
BS-OFF SITE BACKGROUND SOIL SAMPLE
SSE-OI
*
SSF-01
SSE-02
DRUM
SAMPLING
AREA
(DS 01-11)
SSF^32
OD-01*
*
SSE-03
SSF-03
*SSD-04
*SSE-04
N
*BS-01
*BS-02
Scale (feet)
SOIL SAMPLING LOCATIONS
ROGER'S ROAD SITE, JACKSONVILLE, AR
FIG. 3
1-6
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WATER FILLED TRENCH
HEAVILY WOODED
PATHT
DRUMAJR
0 50 100
SCALE (FEET)
HEAVILY WOODED IN NORTH
SWAMP/MARSH GRASS IN SOUTH
SITE DETAILS
ROGERS ROAD LANDFILL, JACKSONVILLE, AR
FIG,
1-7
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The site is located within a 100-year flood plain and is poorly
drained because of slow percolation of rainwater through the type
CL clay and silty-clay at the surface. Annual rainfall averages
50 inches, but only two inches of rain is estimated to percolate
into the ground water system. After precipitation events, the
landfill typically has many areas with standing water; and the
site becomes swampy during the winter months. In the area of the
Rogers Road Landfill, there is also a seasonal perched water table
within five feet of the surface that keeps surface soils saturated
during wet seasons. The result is that the site gets extremely
muddy during periods of extended rainfall. During the remedial
investigation, heavy vehicles had serious problems with on-site
mud. For example, a bulldozer reportedly got stuck in the mud.
March, April and May are the wettest months; and August, September
and October are the driest months. The site is reported to most
likely be dry enough to avoid significant problems with mud during
July and August, the hottest months of the year.
Bayou Two Prairie is located approximately two miles east and
northeast of the landfill and exerts the greatest hydrological
influence on the site area. The surface gradient at the landfill
is predominantly to the east-northeast, and surface drainage is
reported to be to be toward a manmade drainage ditch at the
Lonoke-Pulaski County Line, which empties into the Holland Bottoms
Wildlife Management Area.
Geology
The Rogers Road Landfill Site is located a short distance
southeast of a fall zone formed by two major physiographic
provinces. Underlying the site is the Paleocene Age Midway
Formation and the Eocene Age Wilcox and Claiborne Groups of the
Coastal Plain province. The Midway Formation is comprised of dark
gray to blue to black, noncalcareous, nonfissile, waxy clays;
intermixed with softer blue-gray, calcareous, foraminifera bearing
clays.
Overlying the Midway Formation is the unfossiliferous, interbedded
chocolate-brown lignitic clays; black sandy clays; and very fine
sand of the Wilcox Group. Disconformably overlying the Wilcox is
the Claiborne Group, consisting of interbedded white to light gray
fine sand, gray to tan sandy clay, and lignite.
Thinning to the northwest, the Coastal Plain Sediments taper over
the Pennsylvanian Age Atoka Formation of the Interior Highland
physiographic provence, which outcrops along the fall zone. The
Atoka formation consists of interbedded shale and tightly cemented
siltstone and sandstone. This formation was not encountered in
any of the borings.
Page 1-8
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Figures 2-2 through 2-8 of the Rogers Road Landfill Remedial
Investigation Report show the locations of geologic cross sections
for the Rogers Road and the nearby Jacksonville Landfill Sites.
These cross sections illustrate the complexity of the subsurface
strata, as well as details concerning the locations of monitoring
wells.
The borings ne.ar the Rogers Road Site generally encountered a
layer of clay, and then a layer of sand with intermittent, thin
veins of clay. Clay from the Midway Formation was encountered at
the bottom of boring MWR1 and MWR7, at 58.5 ft and 71.5 ft
respectively and appears to underlay the sand in the aquifer under
the area.
The geologic cross-section profiles were drawn based on lithologic
data obtained from 20 ground water monitoring wells. Four groups
of sediments were identified in the boring logs: clay, silty
clay/clayey silt, fine silt, and medium sand. Two thick clay
layers occur underneath Rogers Road Site, in contrast with, three
or more clay layers underneath the Jacksonville Landfill Site. At
Rogers Road, the surface layer is clay, with a layer of clayey
silt beneath. A fine to medium-grained sand layer occurs below
this, with thin veins or lenses of clay within it. This is
situated above a thick layer of clay. The silt and the sand with
thin clay veins and lenses appear to function as one aquifer.
Two separate aquifers exist at the Jacksonville Landfill Site
because a clay layer at about 25 feet acts as an aquitard.
The transition from one aquifer at the Rogers Road Site to two
aquifers at the Jacksonville Site occurs at MWR-06 (approximately
mid-way between the two landfills), where a thin clay layer (4
feet thick) separates a reddish brown, clayey silt from fine
sands.
Most of the surface soil at the Rogers Road site consists of the
Amy Series Clay (CL) and Silty Clay (CL) . The predominant soil
units within the series are the Amy Silt Loam and the Amy-Urban
land complex. Some of the surface soil can be described as high
plastic clay (CH), organic clay (OH) and organic silt (OL). These
types of soil tend to be corrosive to concrete and highly
corrosive to steel. Glass fragments, rusty discarded appliances,
and other refuse are mixed in with the soil in many areas of the
site. The debris often interfered with subsurface sampling. It
was not unusual for four or more attempts to be required before it
was possible to take a soil sample with a hand auger at a depth of
two feet near the southern end of the fenced portion of the site.
Hydrogeology
Ground water flow under and in the immediate vicinity of the
Rogers Road Site is to the east-southeast. As previously
indicated, standing water and near-surface water is sometimes
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present on the site and keeps the soil saturated during the rainy
season. During the hottest season (July and August), the surface
conditions may become dry. Detailed information on seasonal
variations in the depth to near-surface water is unavailable.
Shallow monitoring wells (with screen depths between 15 and 25
feet below the surface) were dug into the upper sand layer, except
for one well (MWR-05) , which was installed in the silty clay
overlying the sand layer.
The section underlying both the Rogers Road and the Jacksonville
Landfill Sites actually consists of deep sands and clays, which
are probably representative of the Eocene series, and shallow
silts and clays, which most likely represent the upper, fine
grained Quaternary deposits. The boundary between the Eocene
series and the Quaternary deposits is difficult to define because
of the absence of the Quaternary basal sands and gravels.
Therefore, the deposits overlying the Paleocene Midway Formation
are defined as the Eocene/Quaternary section.
The Quaternary/Eocene alluvial aquifer (at a depth of about 100
feet) is the most important water bearing unit in the Rogers Road
Area, providing water for agricultural, domestic and municipal
uses. All municipal ground water wells tap Quaternary sand and
gravel deposits.
The Quaternary/Eocene aquifer downgradient of the Rogers Road Site
typically consists of 45 feet of basal sands and gravel, overlain
by about 80 feet of silts and clays. However, under the Rogers
Road Site, the surface clay and silty clay is only 10 to 25 feet
thick.
Because of the presence of the clay layer at the surface at the
Rogers Road Landfill, it is difficult for the rain water to
percolate to the underlying silt and sand. However, when water
does percolate into the sand layer, the thin veins and lenses of
clays that occur within this sand may not function as aquitards
because of their limited extent. This suggests that connections
between the Quaternary/Eocene aquifer and the water percolating
through the clay and silty clay at the surface may be fairly
direct at the Rogers Road Site. However, while such connections
may be reasonably inferred, they cannot be positively proven from
the existing data.
Ground water was encountered in both shallow and deep wells across
the two landfill sites. The deep wells (up to 130 feet deep) at
both the Rogers Road and the Jacksonville Landfill Sites were
screened across the lowermost sand units just above the Paleocene
Midway Formation. Although local variations should persist
between the wells, it is believed that the lower sand units are
correlative and allow for direct hydraulic communication. In
contrast, examination of the boring logs reveal that the shallow
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wells were screened across different lithologies between the
Rogers Road and Jacksonville sites.
At Rogers Road, the dominant shallow water bearing zone consists
of a white to light gray, fine to medium grained, clean sand,
which comprises most of the section and is believed to extend
stratigraphically downward to the levels encountered by the deep
wells. At the Jacksonville site, thick clay and silty clay layers
separate the Quaternary/Eocene aquifer from one or more semi-
confined aquifers above.
In general, the hydraulic conductivity values for wells completed
in sand (average 7.3 x 10" 5 ft/sec) were an order of magnitude
higher than the values for wells completed in silt (average 8.3 x
10" 6 ft/sec) .
Classification of Ground Water
It is the policy of EPA's Superfund program to use as a guide the
framework provided by EPA's Ground water Protection Strategy in
determining the appropriate remediation for contaminated ground
water. Three classes of ground water have been established on the
basis of ground water value and vulnerability to contamination.
The various ground water classes follow:
Class I; Special ground water (Class I) is highly vulnerable to
contamination because of hydrological characteristics of the areas
in which it occurs, and characterized by either of the following
factors:
The ground water is irreplaceable; no reasonable alternative
source of drinking water is available to substantial
populations.
The ground water is ecologically vital; the aquifer provides
the base flow for a particularly sensitive ecological system
that if polluted, would destroy a unique habitat.
Class II; This classification includes all other ground water
that is currently used (IIA) or is potentially available (IIB) for
drinking water, agriculture, or other beneficial use.
Class III: Class IIIA and IIIB ground water is that which is not
considered a potential source of drinking water and of limited
beneficial use. This classification may be used when the water is
saline (i.e., it has a total dissolved solids level of 10,000
milligrams per liter (mg/1), or is otherwise contaminated beyond
levels that allow remediation using methods reasonably employed in
public water treatment systems. This contamination could be due
to naturally occurring constituents, human activity that is not
associated with a particular waste disposal activity or another
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site. Class III also includes ground water that is not available
in sufficient quantity at any depth to meet the needs of an
average household.
Class IIIA includes ground water that is interconnected to surface
water or adjacent ground water that potentially could be used for
drinking water. Class IIIB includes ground water that has no
interconnection- to surface water or adjacent aquifers. For Class
IIIA ground water, establishing cleanup levels should take into
consideration the degree of interconnection to Class I or Class II
ground water or the rate of discharge to surface water so that
levels of contaminants in higher class ground water do not
increase as a result of the interconnection.
The State of Arkansas has not yet instituted an active ground
water classification program. The ground water below the Rogers
Road site has not been State-classified and was therefore
classified for the purposes of establishing remedial objectives
according to the criteria set forth above. The results of the
classification process are presented below.
The Quaternary alluvial aquifer (at a depth of approximately 100
feet) is the predominant water bearing unit in the Jacksonville
area. Since this ground water unit is presently used as a
drinking water source, it is classified for the purposes of this
site as a Class IIA aquifer.
It should be noted that the classification provided above is site
specific and limited in scope. Classifications performed by EPA
under the Superfund program do not apply to the general geographic
area in which they are performed, nor to any Federal, State, or
private action other than Superfund remediation.
SURROUNDING LAND USE AMD SENSITIVE RECEIVERS
The site is located within a residential and agricultural area.
The area immediately adjacent to the site on the north, east, and
south is wooded. Rogers Road is immediately to the west of the
site. A pig pen is situated about 100 yards north of the fenced
portion of site, past an area of forest. A house-trailer is
situated about 160 yards north of the fenced portion of the site;
and several more homes are located along Rogers Road, north and
northwest of the site. The area immediately west of the site and
Rogers Road is used for agriculture.
A residential well inventory was conducted as part of the Remedial
Investigation. Information was collected from residences near the
landfill. Only one residence near the Rogers Road Landfill ever
used ground water; this household stopped using the well when
municipal water was made available. The other residences have
used only the City water system. The City of Jacksonville
installed a municipal water system, which has been serving the
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residents in the area of Rogers Road since sometime prior to 1974.
Within a one-half mile radius of the Rogers Road Landfill, there
are approximately 51 single family homes. The one-half mile
radius was chosen because of the population distribution. That
is, there is a fairly high population density within one-half mile
radius, followed by a more sparsely populated area. Assuming an
average of threje to four people per home, approximately 153 to 204
people live within a one-half mile radius of the site.
There are no businesses or commercial areas located within one and
one-half miles of the landfill. There is a school within three
quarters of a mile of the landfill. The types of receptors are
not expected to change in the foreseeable future. This is because
no new businesses, commercial areas or schools are expected to
relocate within at least one mile of the landfill. The landfill
is located within a predominantly agricultural area. Because of
these factors, the area does not lend itself to commercial type
deve1opment.
Within the next 50 years, the number of residences immediately
adjacent to the landfill could increase (personal communication,
City Engineer, Jacksonville, Arkansas). The numbers of people in
the entire City of Jacksonville are expected to increase
relatively slowly compared to more densely populated regions in
the United States within the next 40 years. The Metropolitan
Council of Governments for the Little Rock/North Little Rock
Metropolitan Statistical Area has estimated the population of the
City of Jacksonville to be 53,000 in the year 2020 and 62,540 in
the year 2030. Taken together, within the next 50 years, the
types of receptors are expected to remain relatively stable,
increasing slightly in the number of people within the immediate
area of the landfill.
The Holland Bottoms State Wildlife Management Area is located
approximately one-half mile northeast of the site. Investigations
indicate there are no sensitive or endangered species or critical
habitats located within or immediately adjacent to the landfill.
Animals most likely impacted are common wildlife, such as
squirrels, rabbits, birds and deer and domestic animals that were
observed on-site during the remedial investigation.
ENFORCEMENT HISTORY
During the years that the Rogers Road Landfill was operated, the
site was run as a typical sanitary landfill and not as a RCRA
permitted disposal facility. As a result, companies which hauled
waste to the landfill were not required to provide the site
operator with detailed information regarding generators, waste
types, or quantities. The potentially responsible party (PRP)
searches described below were used identify the parties involved
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in waste operations at the site and the extent of their
involvement.
In order to assist in the identification of generators and
transporters of site wastes, EPA sent requests for information
under CERCLA Section 104(e)(1) to several firms considered to have
information regarding the disposal of wastes at the site. These
requests were sent during the period of June 1985 to September
1985. Responses were received during the following months.
In February 1987, a potentially responsible party (PRP) search was
initiated. The site owner/operator during the period of its
operation as a sanitary landfill was identified as the City of
Jacksonville. The investigation concluded that the two primary
PRPs identified during the search as generators of chemical wastes
at the Rogers Road Landfill were Hercules Inc., and Vertac
Chemical Corp.
The PRPs were notified in writing on January 5, 1988 via special
notice letters and given the opportunity to conduct the RI/FS
under EPA oversight. None, however, elected to undertake these
activities. As part of their responses to the special notice
letters, the PRPs provided EPA with lists of additional parties
which may have been involved in the disposal of chemical wastes at
the site. EPA has initiated a second PRP search in effort to
investigate the actual involvement of the parties identified on
the lists, and to obtain additional information regarding
previously identified PRPs.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Rogers Road Landfill Municipal
Landfill site was finalized in November 1988. This document lists
contacts and interested parties throughout government and the
local community. It also establishes communication pathways to
ensure timely dissemination of pertinent information and
emphasizes community involvement. A fact sheet outlining the
Superfund process and the Remedial Investigation plans was
distributed at an open house in July 1988. Updates were also
released in November 1988, March 1989, July 1989, December 1989
and May 1990. The RI/FS and Proposed Plan were released to the
public in July 1990. All of these documents were made available
to the public at the two local information repositories: the
Jacksonville City Hall and Public Library. The Administrative
Record is maintained at City Hall. An open house was held on July
12, 1990 to provide an opportunity for residents to discuss the
proposed plan and prepare their comments for the public meeting.
A public comment period was held from July 9, 1990 through
September 7, 1990. In addition, a public meeting was held on July
18, 1990 to present the results of the RI/FS and the preferred
alternative. All comments received by EPA prior to the end of the
public comment period, including those expressed verbally at the
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public meeting, are addressed in the Responsiveness Summary which
is attached to this Record of Decision.
SCOPE AND ROLE OF PROPOSED RESPONSE ACTION
The studies undertaken at the Rogers Road Landfill site revealed
that contaminated soil (particularly one "hot spot" near the
southeast end of the property) comprises the principal threat
posed by the site. The scope of this Record of Decision is to
address this and other low level site threats in the following
fashion:
o Remedy contaminated soil using thermal treatment (for the
principal threat) and soil cover (for the low level threat)
so that it no longer presents a threat to human health or the
environment.
o Eliminate the health risks due to ponded water onsite by
filling the existing site trenches with clean fill.
o Establish a method of long term monitoring to ensure that the
soil cover is properly maintained and that the ground water
quality is adequately monitored.
This final remedy is intended to address the entire site with
regard to the principal and low level threats to human health and
the environment posed by site contaminants as indicated in the
risk assessment for the site. The findings of the risk assessment
are presented in the Rogers Road Landfill Risk Assessment Report,
April 1990, and are summarized in a later section of this
document.
As previously mentioned, the Jacksonville Municipal Landfill site
is located approximately 1/2 mile east of the Rogers Road site and
has been identified as having many similar site features and
characteristics. Due to the similarities of the Rogers Road and
Jacksonville sites, remedial activities for both are proposed to
be conducted simultaneously. By implementing similar treatment
methods and utilizing the same equipment, considerable cost,
logistical, and administrative benefits can be obtained.
The Rogers Road and Jacksonville wastes are very similar in
physical and chemical makeup to that waste produced by Vertac
Chemical Corp., of Jacksonville, Arkansas. In addition, EPA holds
evidence that indicates that the waste did indeed come from that
facility. After careful consideration, it has been determined
that in all likelihood the dioxin and herbicides located at these
two landfills originated at Vertac. For this reason it is
proposed that these wastes be excavated and transported back to
the Vertac facility for ultimate disposal.
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SUMMARY OF BITE CHARACTERISTICS
NATURE AND EXTENT OF CONTAMINATION
Onsite Soils and Sediment; The primary source of organic
contamination at the Rogers Road Landfill Site is the drum
disposal area and nearby mounds southeast of the middle of the
fenced area. Remnants of an estimated 15 to 50 drums are visible
in piles in the drum disposal area. The size of this area is less
than one-half acre.
It appears probable that drums were disposed of only on the
surface, rather than buried below the natural grade. However, a
metal object was encountered at a depth of approximately eighteen
inches below the surface of one of the five 2'x2'x3' mounds on the
west and northwest side of the drum disposal area. The object
could have been a buried or covered container or a transformer.
The highest level of 2,3,7,8-TCDD observed anywhere on the Rogers
Road Site (150 ppb) was collected from the sample immediately
above the metal object.
The contamination of most concern is from dioxin/furan, dieldrin
and herbicide compounds in the drum pile and adjacent mounds. The
contaminants of concern that were detected in appreciable
concentrations are 2,3,7,8-Tetrachlorodibenzo-p-dioxin (2,3,7,8-
TCDD), the herbicides 2,4-Dichlorophenoxy acetic acid (2,4-D),
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T) and 2,4,5-
Trichlorophenoxy propionic acid (2,4,5-TP or Silvex) and the
pesticide Dieldrin.
2,3,7,8-TCDD is the most toxic of the class of compounds known as
chlorinated dibenzo-p-dioxins, or commonly referred to as simply
"dioxins". There are 75 possible dioxins. 2,3,7,8-TCDD is a
colorless solid with no known odor. It does not occur naturally
nor is it intentionally manufactured by any industry, except as a
reference standard. It can be inadvertently produced in very
small amounts as an impurity during the manufacture of certain
herbicides and germicides and has been detected in products of
burned municipal and industrial wastes. At the present time,
2,3,7,8-TCDD is not used for any purpose other than scientific
research.
In humans, 2,3,7,8-TCDD causes chloracne, a severe skin lesion
that usually occurs on the head and upper body. Unlike common
acne, chloracne is more disfiguring and often lasts for years
after the initial exposure. There is suggestive evidence that
2,3,7,8-TCDD causes liver damage and digestive disorders in
humans. Animal studies have indicated that dioxins produce
toxicity to the immune system, promotes adverse reproductive
effects, and can result in malformations in the offspring,
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although these latter effects have not been demonstrated in
humans. The human evidence for 2,3,7,8-TCDD alone is inadequate
to demonstrate or reflect a carcinogenic hazard, but based on the
positive evidence provided through animal studies, 2,3,7,8-TCDD is
considered by EPA to be a probable human carcinogen.
During the late 1970s, the EPA was faced with assessing the human
health significance of exposure to 2,3,7,8-TCDD. In preparation
for the cancellation hearings for the herbicides 2,4,5-T and
Silvex, the Agency generated risk assessments for several toxic
responses for 2,3,7,8-TCDD. The quantitative cancer risk
assessment developed by the Carcinogen Assessment Group was later
adapted for use in the Water Quality Criteria Document for
2,3,7,8-TCDD. In addition to carcinogenicity concerns, the Water
Quality Criteria document contains an assessment of systemic
toxicity based on reproductive effects resulting from exposure to
2,3,7,8-TCDD.
Later, it became clear that exposure situations exist in the
country which involve more than 2,3,7,8-TCDD alone. Data on
emissions from combustion sources (e.g., hazardous waste and
municipal waste incinerators and contents of waste from certain
industrial production processes indicate that the majority of the
75 chlorinated dibenzo-p-dioxins (CDDs) and 135 chlorinated
dibenzofurans (CDFs) can be detected in the environment.
In recent years, the reporting of at least homologue-specific data
for the CDDs and CDFs has become commonplace, and the Agency has
taken some steps to address the significance of these findings.
For example, the Health Assessment Document for Polychlorinated
Dibenzo-p-Dioxins, prepared for the Office of Air Quality Planning
and Standards, contains a quantitative risk assessment for a
mixture of hexachlorodibenzo-p-dioxins (HxCDDs) based on
carcinogenicity studies conducted by the National Cancer
Institute. These concerns have also led to regulatory action:
e.g., several industrial wastes containing tetra-, penta-, and
hexa-chlorodioxins, and -dibenzofurans were recently designated by
the Agency as EPA hazardous wastes.
Faced with increasing amounts of isomer- and homologue-specific
data, and recognizing the significant potency and structure-
activity relationships exhibited in in-vivo and in-vitro studies
of CDDs and CDFs, the CDD/CDF Technical Panel of the Risk
Assessment Forum (Forum) perceived a need to address more
generally the potential risks posed by mixtures of congeners other
than 2,3,7,8-TCDD and HxCDDs. Detailed consideration of the
toxicity of the vast majority of the CDDs and CDFs is limited by
the lack of a complete toxicological data base on most of the
congeners. Further, it is unlikely that many long-term test
results will be available soon. For example, research on 2,3,7,8-
TCDD has been under way for more than two decades at an estimated
cost of more than one hundred million dollars. Therefore, the
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Forum was instrumental in leading to EPA's adoption of an interim
science policy position for use in assessing risks associated with
CDD/CDF mixtures, until more definitive scientific data are
available.
The toxicity equivalency factor (TEF) method is an interim
procedure for assessing the risks associated with exposures to
complex mixtures of CDDs and CDFs. The method relates the
toxicity of the 210 structurally related chemical pollutants and
is based on a limited data base of in-vivo and in-vitro toxicity
testing. By relating the toxicity of the 209 CDDs and CDFs to the
highly studied 2,3,7,8-TCDD, the approach simplifies the
assessment of risks involving exposures to mixtures of CDDS and
CDFs.
In 1987, the EPA formally adopted an interim TEF procedure (EPA-
TEF/87), which was used by EPA regulatory programs and Regions in
addressing a variety of situations of environmental contamination
involving CDDs and CDFs. The EPA-TEF/87 method was published as
"Interim Procedures for Estimating Risks Associated with Exposures
to Mixtures of Chlorinated Dibenzo-p-dioxins and -Dibenzofurans
(CDDs and CDFs)", (EPA/625/3-87/012). Since the time that the
1987 report was published, the Agency was active in an
international project aimed at adopting a common set of TEFs, the
International TEFs/89 (I-TEF/89), to promote consistency in
addressing contamination involving CDDs and CDFs. The first
update report, "1989 Update to the Interim Procedures for
Estimating Risks Associated with Exposures to Mixtures of
Chlorinated Dibenzo-p-dioxins and -Dibenzofurans (CDDs and CDFs)",
identifies EPA's adoption of the I-TEF/89 as a revision to the
EPA-TEF/87.
The I-TEF/89 method was followed throughout the RI/FS process at
the Rogers Road Landfill project. For comparison, the EPA-TEF/87
calculations were produced and documented in the Rogers Road
Landfill Risk Assessment Report. In general, the effect of the
modifications reflected in the I-TEF/89 method were modest, with
the calculated differences falling within 2-5 percent of each
other. The equivalency factors used in each of these methods are
presented in the Risk Assessment Report. Where the term
"equivalent 2,3,7,8-TCDD" is mentioned in this Record of Decision,
it refers to an equivalent concentration of 2,3,7,8-TCDD resulting
from the I-TEF/89 method of calculation.
Dichlorophenoxy acetic acid (2,4-D) is a systemic herbicide widely
used for control of broad leaf weeds in cereal crops and sugar
cane and on turf, pastures and non-cropland. It is a component of
Agent Orange, the defoliant most widely used in Vietnam. It
promoted tumors after being painted on the skin of mice, and it
probably is a weak mutagen. 2,4-D caused developmental
abnormalities and was fetotoxic when administered to pregnant
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rats, mice, and hamsters. Dermal exposure .to 2,4-D causes severe
peripheral neuropathy.
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T) is an organic acid
that possesses the property of regulating plant growth at low
concentrations and killing plants at high concentrations. It has
been used to induce coloration in fruit, as a fruit set and
antidrop agent, for brush control and to control aquatic and
herbaceous land plants. Possibly its most significant use was as
one of the major constituents of Agent Orange. It is commonly
contaminated with 2,3,7,8-TCDD, which may be responsible for some
of the effects associated with exposure to technical 2,4,5-T.
These effects include chloracne and the induction of microsomal
mixed function oxidase activity. Administration of purified
2,4,5-T has been shown to cause fetal loss, disrupt fetal
development, and induce fetal malformations. In 1979, EPA ordered
an emergency ban on 2,4,5-T production based on a report of an
increase in spontaneous abortions in women of a forestry
community. That ban has never been lifted and all uses have been
canceled.
2,4,5-Trichlorophenoxy propionic acid (2,4,5-TP) is a broad
spectrum herbicide which is contaminated with 2,3,7,8-TCDD, a
toxic byproduct formed during the manufacturing process. 2,4,5-
TP acts as a hormone-type weed killer and is readily absorbed by
leaves and stems. The toxic effects associated with exposure to
2,4,5-TP are generally considered to be caused by 2,3,7,8-TCDD.
However, pure 2,4,5-TP may have an adverse effect on reproduction
that is not attributable to 2,3,7,8-TCDD.
Dieldrin is the common name of an insecticide that has been used
in agriculture for soil and seed treatment and in public health to
control disease vectors such as mosguitos and tse-tse flies. It
also had veterinary use as a sheep dip and has been used in
treatment of wood and mothproofing of woolen products. Because
dieldrin is not currently produced in, or imported into, the
United States, their use is believed to be minimal. Studies with
animals fed dieldrin have shown that the liver can be damaged and
the ability of the immune system to protect against infections can
be suppressed. Although there is inadequate evidence to judge
whether dieldrin is carcinogenic in humans, the EPA considers it
to be a probable carcinogen based on sufficient evidence in
animals.
The highest concentration of 2,3,7,8-TCDD detected at the site was
found within the drum disposal area in a subsurface sample
eighteen inches below the surface of a mound west of the drum
pile. The 2,3,7,8-TCDD concentration was 150 ppb, while the total
2,3,7,8-TCDD equivalence of this sample was 159 ppb. Also found
within the drum disposal area were the highest concentrations of
herbicides at 32,000,000 ppb (3.2%), 7,700,000 ppb (0.8%) and
1,000,000 ppb (0.1%) for 2,4-D, 2,4,5-T, and 2,4,5-TP
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respectively. The highest concentration of dieldrin was 37,000
ppb, detected at the top of a mound southwest of the drum pile.
Detected compounds, concentration ranges and detection frequencies
associated with this location is summarized in Table 1.
Based upon the results documented in the Rogers Road Contaminant
Mapping Study Report, July 27, 1990, it is estimated that within
the drum dispo'sal area approximately 250 cubic yards of soil,
waste and debris contain more than 1 ppb of equivalent 2,3,7,8-
TCDD. Because of the strong adhesion of dioxin/furan compounds to
the clayey soil found at the site, all contamination appears to be
limited to the top one foot of soil. This quantity also includes
approximately 50 cubic yards of soil which was found to contain
more than 10 ppb equivalent 2,3,7,8-TCDD.
An additional 120 cubic yards of soil containing dieldrin above 37
ppb, the concentration equivalent to the 1 x 10"6 risk level, was
found at the perimeter of the drum disposal area. (An explanation
of the derivation of this concentration and the associated risk
level will be presented later in the ROD.) The degree of overlap
between the areas contaminated with dieldrin and 2,3,7,8-TCDD is
presently uncertain, but will be defined as part of the remedial
design so that the appropriate method of remediating the soil can
be determined. For the purposes of this study, however, the areas
were considered to be mutually exclusive.
Contaminated soil volumes are as follows:
CONTAMINATED SOIL VOLUMES
IN DRUM DISPOSAL AREA
Contaminant Action Level Quantity
2,3,7,8-TCDD 1.0 < Cone. < 10 ppb 200 cy
< 10 ppb 50 cy
Dieldrin < 37 ppb 120 cy
Total 370 cy
One of the primary factors considered when evaluating proper
treatment and disposal of contaminated site soil is whether the
waste material is "RCRA listed". That is, whether it is contained
in one of the lists of hazardous wastes under 40 CFR Part 261,
Subpart D.
Under 40 CFR Part 261.31, wastes from various processes that are
likely to produce dioxins are listed as F020, F021, F022, F023,
F026, F027 and F028 hazardous waste. For example, wastes from the
production or manufacturing use of tri- or pentachlorophenol (or
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TABLE 1
DRUM DISPOSAL AREA
SAMPLE ANALYSIS SUMMARY
ROGERS ROAD LANDFILL
NO. Of
Occurrences/
Compound(1) No. of Samples
Volatiles
Bromomethane
Methylene Chloride
Acetone
Toluene
Semivolatiles
^
Phenol
2-Chlorophenol
Benzoic Acid
2 , 4-Dichlorophenol
2,4, 5-Trichlorophenol
^entachlorophenol
JBk-n-butylphthalate
^Ruoranthene
Pyrene
Butylbenzylphthalate
Benzo (a) anthracene
Bis(2-Ethylhexyl)
Phthalate
Di-n-octyl Phthalate
Festicides/PCBs
Dieldrin(3)
Gamma-Chlordane
Herbicides
2,4-D
2,4,5-TP
. 2,4,5-T
1/12
5/12
8/12
3/12
1/12
1/12
2/12
2/12
2/12
2/12
2/12
1/12
1/12
1/12
1/12
2/12
1/12
7/18
1/12
12/13
4/13
9/13
Sample With
Concentration Maximum
Range (ppb) Concentration(2)
9,900
6-15,000*
46-6,600*
6-1,600*
*
3,100
35
1,000
1,200-1,900
1,800-2,400
600-2,200
280-290
92
110
330
140
^
660-3800
570
11-37,000
48
310,000-32,000,000
118-1,000,000
140,000-7,700,000
DS-03 D
DS-08
DS-11
DS-04
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
DS-10
PT-03
DS-10
DS-11
DS-01
DS-01
1-21
-------
TABLE 1 (Cont'd)
DRUM DISPOSAL AREA
SAMPLE ANALYSIS SUMMARY
ROGERS ROAD LANDFILL
Compound<1)
Dioxins
TCDFs
PeCDFs
HxCDFs
HpCDFs
OCDF
2,3,7,8-TCDF
TCDDS
PeCDDs
HxCDDs
HpCDDs
OCDD
2,3,7,8-TCDD
2,3,7,8-TCDDC3)
Inorganics
Aluminum
Antimony
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
NOTES: (1)
(2)
No. of
Occurrences/
No. of Samples
-
9/13
12/13
4/13
4/13
2/13
1/13
6/13
6/13
3/13
3/13
2/13
11/13
8/24
12/12
2/12
6/12
9/12
12/12
12/12
11/12
12/12
12/12
12/12
9/12
12/12
1/12
12/12
2/12
12/12
12/12
12/12
Only compounds
this Table.
Refer to Reined
Sample With
Concentration Maximum
Range (ppb) Concentration'2'
7.2-134
2.1-66.0
0.18-9.9
0.17-10.8
1.3-10.7
30.3
1.8-19.5
2.4-9.4
0.79-9.6
0.38-8.0
1.6-9.8
1.6-14.5
0.15-150
1,130-6,040
12.9-16.0
0.91-4.3
5.3-155
69.3-1,790
65.4-3,450
5.6-30.9
2.5-260
13,800-104,000
4.7-252
61.1-259
135-992
0.33
111-2,100
302-314
499-55,800
3.4-26.8
12.9-243
which were detected are
ial Investigation Report
DS-ll
DS-11
DS-03 D
DS-03 D
DS-03 D
DS-11/2
DS-11/2
DS-03 D
DS-03 D
DS-03 D
DS-03 D
DS-02
PS-04
DS-11 A
DS-07 ^
DS-09
DS-09
DS-09
DS-07
DS-07
DS-07
DS-09
DS-09
DS-09
DS-06
DS-68
DS-04
DS-07
DS-07
DS-09
DS-09
presented in
for the
Jacksonville Landfill Site. Jacksonville, Arkansas,
(3)
April 1990, for figures showing individual sampling
locations.
This listing is from the set of selected surface soil
samples (PS/PT designation) taken near the drum
disposal area.
These compounds were detected in one or more blank
samples.
1-22
-------
of intermediates used to produce their pesticide derivatives) are
listed as hazardous waste number F020.
The list of chemicals detected at the Rogers Road Landfill Site
includes such substances as 2,4-D, 2,4,5-TP, 2,4,5-T and
trichlorophenol, disposed of in the drum disposal area at
concentrations up to 3.2%, 0.1%, 0.8% and 600 ppb respectively.
*
No detailed records have yet been found that prove exactly how the
herbicides, trichlorophenol and other related chemicals were
placed in the drum pile or from which process they came. Records
are required to determine the origin, and thus the "listability",
of a waste.
It should be noted, however, that the site waste is suspected of
having originated at the Vertac facility, whose waste has been
listed as F020 and F023. If Vertac waste is indeed the same waste
that exists at the Rogers Road site, then the Rogers Road waste
could be considered to be a soil and debris contaminated with a
RCRA listed waste. Because of the lack of detailed records
regarding the specific origin of the Rogers Road site contaminants
and the observation that the site waste is a contaminated filter
material mixed in soil rather than a pure product or a "still
bottom" waste, Rogers Road Landfill wastes are not considered to
be listed. RCRA restrictions pertaining to the treatment of
listed wastes will nonetheless be considered relevant in the
determination of remediation goals. The selected remedy will not,
however, include the delisting or disposal considerations
contained in the Land Disposal Restrictions (LDRs) for listed
wastes.
This determination is consistent with the RCRA "Contained-in"
Rule, which states that any mixture of a non-solid waste (such as
soil or ground water) and a RCRA listed hazardous waste must be
managed as a hazardous waste as long as the material contains
(i.e., is above health-based levels) the listed hazardous waste.
Once the material has been treated to no longer "contain" the
listed hazardous waste, the material itself will no longer be
considered a hazardous waste.
The waste is also subject to the regulatory authority of 40 CFR
Part 261 Subpart C, which identifies it as having the
characteristics of hazardous waste, specifically the
characteristic of EP toxicity.
The highest concentrations of 2,4-D and 2,4,5-TP observed at the
Rogers Road Landfill Site were 32,000,000 ppb (3.2%) and 1,000,000
ppb (0.1%) respectively. If the leachate from leachability tests
of this material contains concentrations of 2,4-D exceeding 10,000
micrograms per liter (ug/1) or 2,4,5-TP exceeding 1,000 ug/1, the
material would be classified as D016 or D017 hazardous waste
respectively under Part 261.24.
Page 1-23
-------
The waste material at the site has not been subject to the TCLP
leachate tests, nor are there any detailed records indicating its
derivation. Therefore D016 and D017 classification has not been
shown to be applicable. However, it is likely that if the
aforementioned materials were so tested, the leachate would exceed
the limits for D016 and D017 hazardous waste classification.
Thus, the waste can be considered "characteristic" and
consequently, RCRA regulations for D016 and D017 hazardous waste
are considered to be relevant and appropriate.
The high levels of contaminants in the drum disposal area render
this area of the site extremely hazardous. Contaminants in this
area comprise the principal health threat at the site.
Calculations supporting this conclusion are presented in the Risk
Assessment Report, which indicate excess lifetime cancer risks of
2.19 x 10"3 from dioxins, furans and dieldrin (for maximum
plausible exposure) and a total hazard index of 163 from
herbicides and dieldrin. This area will be the main focus of
remedial actions performed at the site.
In addition, limited organic and inorganic contamination exists
throughout the site, especially in the soil and refuse piles and
former waste disposal trenches. Many of the compounds detected
are those commonly found at municipal landfills. The areas
outside of the dioxin disposal area contained no detectable
contamination high enough to present a significant threat to
public health. Risk calculations indicate excess lifetime cancer
risks of 1 x 10"5 from dioxins and furans (for maximum plausible
exposure) and a total hazard index of far less than 1.0 from
herbicides and other noncarcinogenic compounds.
Offsite Soils: Offsite surface soil contamination is limited to
octachlorodibenzo-p-dioxin (OCDD). The site is not likely to be
the source of these compounds, however, as it was found in offsite
background samples and is ubiquitous in the local environment.
Nonetheless, regardless of the origin of these compounds, they
were taken into account during the calculation of site risks in
the risk assessment.
Ground water
Ground water samples were collected from monitoring wells
installed during the Remedial Investigation and from one
residential well north of the site. The locations of monitoring
wells are shown in Figure 5. Detected compounds, concentration
ranges and detection frequencies associated with this location is
summarized in Table 2. Monitoring wells MWR-01, MWR-02, MWJ-01
and MWJ-02 were installed upgradient and used as background
samples. Monitoring well MWR-03 was installed just to north of
the site. Monitoring wells MWR-04 and MWR-05 were installed near
the northeast and southwest corners of the fenced area of the
Page 1-24
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-------
Rogers Road Site, respectively. These wells were installed to
monitor any contaminant migration in the shallow water bearing
zone. Monitoring wells MWR-06 and MWR-07 were between the Rogers
Road and Jacksonville Sites, east-northeast of the fenced portion
of the Rogers Road Site. Wells MWJ-01 and MWJ-02 were installed
as part of the Remedial Investigation for the Jacksonville
Landfill Site.
Monitoring Wells: Monitoring well samples (GW designation) were
collected during two sampling events (February 1989 and May 1989)
at the Rogers Road Landfill Site.
Monitoring wells at the Rogers Road Landfill Site consisted of
three deep wells (MWR-Ol, MWR-06 & MWJ-01) and five shallow wells
(MWR-02, 03, 04, 05 & 07). Ground water sampling depths in the
deep wells averaged 62 feet below ground surface. Ground water
sampling depths in the shallow wells averaged 27 feet below ground
surface.
One shallow well sample from MWR-05, a shallow well at the
southeast corner of the fenced portion of the landfill, contained
toluene at an estimated concentration of 4 ppb. The deep
monitoring well sample (from MWR-06, located between the Rogers
Road Landfill and the Jacksonville Landfill) also contained
toluene at 7 ppb and chlorobenzene at 17 ppb. Both of these
samples were taken in May, 1989. Samples from the same wells
taken in February 1989 revealed no volatile organic contamination.
Toluene is a common solvent used in paint and industrial
applications, and was detected in three drum disposal area samples
at concentrations up to 1,600 ppb. Toluene is moderately soluble
in water and, therefore, is likely to be transported via ground
water to some degree. However, toluene was not detected in any
soil samples upgradient of MWR-05. Under the circumstances, no
definitive conclusion can be drawn as to whether or not the
toluene detected in the ground water is associated with the Rogers
Road Site.
Chlorobenzene is an intermediate chemical used for the production
of pesticides and other chemicals, a solvent carrier for chemicals
such as methylene diisocyanate, and an industrial solvent. No
chlorobenzene was detected in soil or drum waste samples, and
monitoring well MWR-06 may or may not actually be downgradient of
the contaminated portions of the Rogers Road Site. Under the
circumstances, no definitive conclusion can be made on whether or
not the chlorobenzene detected in MWR-06 is from the Rogers Road
Site.
The concentrations of toluene and chlorobenzene were substantially
less than the Safe Drinking Water Act (SDWA) proposed Maximum
Contaminant Levels (MCLs) of 2,000 ppb for toluene and 100 ppb for
chlorobenzene.
Page 1-29
-------
The herbicide 2,4,5-T was detected at 3.9 ppb in one shallow down
gradient monitoring well, MWR-07, located approximately 1,300 feet
east-northeast of the fenced portion of the Rogers Road Site.
This compound was not detected in this well during the first round
of sampling. The health advisory for 2,4,5-T is 21 ppb, more than
five times the concentration detected. No other herbicides were
detected in the deep wells.
Concentrations of inorganics detected in the monitoring wells are
below MCLs for those compounds which have a MCL. Monitoring well
samples were not analyzed for inorganic compounds in the second
round of sampling conducted in May 1989 since they were within
background ground water concentrations of the samples collected
from the upgradient wells near the site (MWJ-01 and 02).
Since none of the detected chemicals exceeded National Primary
Drinking Water Standards, active ground water remediation is not
warranted. The selected remedial alternative will, however,
incorporate a system of long-term ground water monitoring to
ensure that the remedy remains effective in the protection of
ground water guality and to aid in the identification of long-
term trends in the quality of the ground water.
Residential Wells: Samples from the residential well north of the
site (RW-05) were collected in conjunction with the Jacksonville
Landfill Site RI. The data from this well was included as part of
the Jacksonville Landfill RI report. Since this well is located
approximately 400 yards northeast of the Rogers Road Site, the
well is probably not downgradient of the Rogers Road Site.
Nevertheless, the data is presented as an indicator of
concentrations of contaminants in ground water in the vicinity of
the Rogers Road Site.
No volatile, semivolatile, pesticide/PCB, dioxin/furan or
herbicide compounds were detected at levels exceeding (or even
approaching) regulatory limits.
Concentrations of inorganic compounds detected in the residential
well were below the SDWA MCLs for those compounds which have SDWA
MCLs. Concentrations of inorganics in this well are also within
concentrations found in the background ground water samples
collected near the site.
Surface Water
Surface water samples were collected from standing water in the
onsite trenches and offsite ponds and drainage ditches.
Background surface water samples were collected from Bayou Two
Prairie and a creek running through the Holland Bottoms Wildlife
Management Area.
Page 1-30
-------
Background Water: With the exception of beryllium and manganese,
concentrations of all organic and inorganic compounds detected in
background water samples were less than the Ambient Water Quality
Criteria (WQC) for those compounds which have WQC values. The
maximum concentration detected for beryllium was 0.2 ug/1 (versus
WQC = 0.0039 ug/1) and the maximum concentration of manganese was
336 ug/1 (versus WQC = 10 ug/1).
Onsite Trench Water: Herbicides 2,4-D and 2,4,5-T were detected
at low concentrations at two sampling locations in an open site
trench near the drum disposal area (0.47 ug/1 and 1.5 ug/1,
respectively). The concentrations of herbicides were well below
the SDWA MCLs of 100 ug/1 for 2,4-D and the health advisory of 21
ug/1 for 2,4,5-T. These detections, however, indicate that either
some contamination migration from the drum disposal area into this
trench is occurring or that direct herbicide waste disposal into
the trench has taken place.
Concentrations of inorganic compounds detected in trench water
samples were less than water quality criteria for those compounds
which have WQC values, except for manganese. Manganese was
detected at 220 ug/1 and at 244 ug/1 in the trench, and the water
quality criteria is 10 ug/1. The detected concentrations,
however, fall within the general range detected in the background
surface water samples taken upgradient and away from the Rogers
Road and Jacksonville sites (up to 336 ug/1). This indicates that
the compound is common to the local area and not the result of
site contamination.
Offsite Surface Water; The presence of inorganic compounds in an
offsite surface water sample was detected during the Remedial
Investigation. Beryllium and manganese were found in a shallow
drainage ditch adjacent to the south end of the site at levels
exceeding Ambient Water Quality Criteria (AWQC). AWQC are
standards which are developed for protection of human health from
two routes of exposure — exposure from drinking the water and
from consuming aquatic organisms, primarily fish, and from fish
consumption alone. The sampling results for this location are
shown below. Offsite background results and AWQC are included for
comparison.
MAXIMUM LEVEL DETECTED (ug/1)
LOCATION BERYLLIUM MANGANESE
Offsite Ditch (OW-01) 0.7 9,330
Offsite Background 0.2 336
AWQC 0.0039 10
Page 1-31
-------
Observations made during a subsequent sampling attempt revealed
that the area under consideration completely dries up during
periods of dry weather and that although some intermittent ponding
may occur during wet intervals, the area is not a consistent
source of surface water. AWQC, therefore, are not ARARs for this
location since the shallow ditch cannot be considered a consistent
source of drinking water or fish production. Because of the
inconsistent supply of water, exposure from humans, wildlife or
domestic animals is estimated to be sporatic and of limited
duration, thus health and environmental impacts from this route of
exposure are expected to be very low.
Air Pollution
The only volatile organic contamination observed in surface soil,
waste or sediment not attributable to laboratory contamination was
from bromomethane, and the bromomethane was not consistently
detected. The vegetation on most of the site, common wet muddy
conditions, and the crust on the waste pile prevent significant
dust emissions. A review of the available air sampling data by
the Centers for Disease Control (CDC) concluded that "based on the
data provided and the sampling conditions reported, airborne
volatile organic compounds do not represent a public health
problem on-site and do not appear to be contributing to off-site
exposure."
CONTAMINANT FATE AND TRANSPORT
The environmental transport of the chemicals detected at the
Rogers Road Landfill Site is dependant on their individual
physical/chemical properties (especially sorption and solubility)
as well as specific site characteristics.
Potential Routes of Migration
The mechanisms of release of the chemicals of concern at the
Rogers Road Landfill Site from contaminated media are discussed
below. These routes of migration can be soil erosion, ground
water flow, air transport, and surface water/sediment transport.
Due to the physical/chemical characteristics of contaminants found
on-site the primary route of contaminant migration is soil
erosion; secondary routes of migration are ground water flow and
surface water/sediment transport. The primary chemicals of
concern are dioxins (2,3,7,8-TCDD and other isomers); 2,4-D;
2,4,5-T; 2,4,5-TP; and dieldrin.
Soil; As a result of past operations and waste disposal
practices, chemicals were released to the soil at the Rogers Road
Landfill Site. These chemicals may remain in the soil or migrate
from the soil to other media. The movement of a chemical once it
has been released to the soil is dependent upon several factors,
Page 1-32
-------
including the type of soil, the tendency of the chemical to adsorb
to soil particles, the solubility of the chemical in water and the
vapor pressure of the chemical.
The surface soils present at the Rogers Road Landfill Site are
comprised predominantly of silt/clay mixtures with very little
organic carbon content. These soils are likely to provide little
attenuative capacity, as they provide few sites for adsorption of
organic chemicals or complexation of metals. The low attenuative
capacity of the soils and the very low soil permeability result in
conditions which promote migration of contaminants by erosion and
surface water runoff.
Movement of organic chemicals of concern from the soil is
predominantly influenced by solubility. For example, lower
molecular weight compounds (dieldrin) are more soluble and,
therefore, would be expected to leach from the soil faster than
higher molecular weight compounds (dioxins).
Due to the chemical/physical properties of dioxins and furans
which influence their ability to migrate in soils, the vertical
migration in soils will be extremely slow. The primary indicators
which determine chemical migration are the organic carbon
partition coefficient (Koc) and octanol water partition coefficient
(KOH) . These values indicate a chemical's ability to remain sorbed
to soil particles versus its ability to be leached by water.
Dioxin/furan compounds values for these properties are relatively
high indicating their inability to be leached from soils.
Additional data to support this is presented in studies (National
Dioxin Study, EPA, 1988) which show that approximately 98 percent
of dioxin in soils will remain within the upper 12 inches of the
soil.
Migration of inorganics in the environment is complicated and
depends greatly on inorganic speciation. Speciation, in turn, is
influenced by environmental conditions such as pH, oxidizing or
reducing conditions of the environment, and microbial activity.
With the exception of inorganic anions such as those formed by
arsenic, chromium (VI), and cyanide, which are fairly mobile,
metals are usually tightly bound to the soil constituents such as
clays.
Ground water: Lithologic descriptions from the soil borings
indicate that the site is underlain by a complex series of clays,
silty clays and sandy silts. The water table is, at several times
throughout the year, within two feet of the ground surface. This
perched water is contained within the clay layer at the surface of
the site.
Acetone, methylene chloride and toluene were detected in the drum
pile. These chemicals are moderately soluble in water and
therefore likely to be transported via leachate and ground water
Page 1-33
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to some degree. Some leachate production can be expected when
this material gets saturated. Some of the chemicals in the
leachate can be expected to reach the perched water table in the
underlying clay. Some of this perched water may percolate down
and reach the underlying aquifer. The aquifer below the Rogers
Road Site is believed to be part of the regional drinking water
aquifer system.
The presence of low concentrations of toluene in the ground water
(4 ppb at MWR-05, and 7 ppb at MWR-06) indicates that migration of
toluene into the ground water might have occurred. Chlorobenzene
was also detected in ground water at MWR-06, at a concentration of
17 ppb. However, the concentrations of toluene and Chlorobenzene
were considerably lower than the proposed MCLs of 2,000 ppb and
100 ppb respectively. The concentrations detected do not pose a
significant risk to public health or to the environment.
The distribution of the organic chemicals in the monitoring wells
and soil do not show any patterns that clearly link them to the
Rogers Road Landfill Site. The toluene and Chlorobenzene detected
may or may not be coming from the landfill. Toluene and
Chlorobenzene were seen in only one of the two sets of samples
taken from the aforementioned wells, and the wells may not
actually be downgradient of the contaminated portions of the
Rogers Road Landfill.
Toluene was detected (at 2 ppb) in a residential well (RW-05)
which is not believed to be downgradient of the Rogers Road Site,
and in background well MWJ-02 (at 3 ppb) , upgradient of the Rogers
Road Site. Toluene was also detected in soil blank samples. This
indicates that sources of toluene may exist near the Rogers Road
Landfill other than the landfill itself or that it is a laboratory
contaminant. Chlorobenzene was not detected in any soil samples
at the Rogers Road site.
The herbicide 2,4,5-T was also detected at 3.9 ppb in a well (MWR-
07) about 1,300 feet east-northeast of the fenced portion of the
site. This well may not be downgradient of the contaminated
portions of the Rogers Road Site. The health advisory for 2; 4, 5-
T is 21 ppb, indicating that the 2,4,5-T does not pose a threat to
public health.
Inorganic compounds detected in monitoring well and residential
well samples were within the range detected in the background
wells (MWJ-01 & 02).
Air; Contaminants may be released into the air by wind
entrainment of soil particles onto which contaminants are
adsorbed. Release of contaminants into the air by volatilization
is not a concern due to the very low vapor pressures exhibited by
the chemicals found on or near the surface of the landfill.
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Migration of contaminants by wind entrainment of soil particles is
dependent on several factors, including particle size, wind speed
and direction, soil moisture content, site topography and presence
of vegetation. In general, unvegetated sites which have low
moisture soils containing high percentages of fine particles are
likely to experience dusty conditions. Site topography will also
affect the transport of soil particles, with sites located in
flat, open unsheltered areas being susceptible to wind erosion.
Several characteristics at the Rogers Road Landfill render the
site unsusceptible to wind transport of contaminants. The site is
primarily flat and it is heavily vegetated. Even in the winter
months the dried vegetation provides good ground cover. Soils in
the area are not well drained. After precipitation events the
landfill typically has many areas with standing water, and during
the winter months the site becomes swampy. Given the site
environmental factors, wind erosion of soil contaminants at the
Rogers Road Landfill does not appear to be a significant pathway
for contaminant migration.
Surface Water/Sediment; Surface water drainage at Rogers Road
Landfill is a series of undefinable drainageways which flow
generally east-northeast towards a manmade drainage ditch at the
Lonoke/Pulaski County line. This ditch flows north under Graham
Road and ultimately empties into the Holland Bottoms Wildlife
Management Area.
Surface water and sediment samples collected from the drainage
areas adjacent to the landfill contain no elevated concentrations
of compounds, compared to background samples, with the exception
of the herbicides (2,4,D at 3.48 ppb; 2,4,5-TP at 0.61 ppb and
2,4,5-T at 0.30 ppb) collected in the surface water just outside
the south portion of the Rogers Road Landfill site fence. The
herbicide concentrations are more than an order of magnitude less
than drinking water standards, and pose no threat to public
health.
Contaminant Persistence
Contaminant persistence in soils is primarily influenced by the
soils ability to attenuate the chemicals of concern. These
chemicals, at the Rogers Road Landfill, are: dioxins; 2,4-D;
2,4,5-T; 2,4,5-TP; and dieldrin. The organic chemicals of concern
at the site can be generally categorized as one group, chlorinated
benzene rings with additional substituents.
Factors which determine a soil's ability to attenuate contaminants
include: the chemicals ability to adsorb to soil particles, water
solubility of each chemical, cation exchange capacity of the soil,
and organic content of the soil.
Page 1-35
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The water solubility of a substance is a critical property
affecting its environmental fate and persistence. Solubilities of
organic chemicals generally range from less than 0.001 mg/liter to
100,000 mg/liter. Solubilities of the chemicals of concern range
from 620 mg/liter for 2,4-D to essentially insoluble for dioxins.
The organic carbon partition coefficient (K^) reflects the
propensity of a compound to sorb to the organic matter in soils.
The normal range of K^ values is from 1 to 107, with higher values
indicating higher sorption potential. Of the chemicals found at
the site, dioxins have the highest K^ values, and therefore are
expected to have the highest environmental persistence. The half-
life of the 2,3,7,8-TCDD isomer is estimated to be 10-12 years in
soil.
The herbicides of concern are less persistent, but more mobile
than dioxins. 2,4-D; 2,4,5-T; and 2,4,5-TP are found to be
relatively mobile in the soil/ground water system when present at
low dissolved concentrations. Bulk quantities of the solution
(e.g., from a spill, heavy spray application, or improper disposal
of excess formulations) can be transported more rapidly through
the unsaturated zone. However, the herbicides under consideration
have been shown to be highly susceptible to degradation in the
soil/ground water system and are therefore not expected to be
persistent. Under most environmental conditions, the esters which
comprise the bulk of the active ingredients of herbicide
formulations are hydrolysed in a matter of days. Biological
hydrolysis of these materials in the subsurface has also been
reported to be very rapid.
After evaluating the physical/chemical parameters of the chemicals
of concern and the geology/hydrogeology at the site, several
conclusions can be drawn. Mobility of the dioxin and herbicide
contaminants at the site will mostly be by surface water run-
off/erosion; vertical contaminant migration is not expected to be
a major migration pathway because of the low solubility and
mobility of dioxins and herbicides, and the low hydraulic
conductivity of the clay at the surface. Even considering the
hypothetical scenario that contaminants would migrate down to the
drinking water aquifer, their mobility would be very limited due
to the low solubility of these compounds in water. Since samples
collected from the drainage courses and low lying areas near the
drum disposal area contained relatively low levels of
contamination, the surface water run-off/erosion migration pathway
also appears to have historically had a limited role in the
transportation of contaminants at the site. Previous studies at
the site have shown that wind erosion of contaminated soil does
not appear to be a significant migration pathway.
Persistence of chemicals in surface soils at the site is very
high. As hai been revealed during the RI, high levels of
herbicides and dioxins still exist in the drum disposal area of
Page 1-36
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the site, 16 years after the site has been, closed. Although the
mobility of the contaminants at the site is limited, in the
absence of additional action at the site, the contaminants can be
expected to persist for many years.
SUMMARY OF SITE RISKS
The Baseline Risk Assessment outlines the type and degree of
hazard posed by hazardous chemicals, the extent to which a
particular group of people have been or may be exposed to the
chemicals, and the present or potential health risk that exists at
the Rogers Road Landfill. The assessment also serves as a
baseline evaluation of the site under a "no-action" remedial
alternative (i.e., in the absence of any remediation and assuming
nonrestricted future site use). This will provide a basis for
assessing remedial alternatives to be considered in the
Feasibility Study. The methodology used for the baseline risk
assessment and key results are summarized below. Additional
details are provided in the Rogers Road Landfill Risk Assessment
Report.
Risk characterization is performed by combining exposure and dose-
response assessments to form conclusions regarding the health
risks from the site. Quantitative risk estimates give an
indication of the magnitude of the potential for adverse health
effects resulting from exposure to toxic substances.
The methodology followed for the Baseline Risk Assessment was in
accordance with the EPA Superfund Public Health Evaluation Manual
(1986) and the Superfund Exposure Assessment Manual (1988).
The potential exposures identified at the Rogers Road Landfill
area are based on the distribution and extent of chemical
contamination, the potential for contaminant transport,
opportunities for exposure and the toxicity of the contaminants.
Plausible exposure results were derived using arithmetic and
geometric means of laboratory chemical analyses of field data.
Worst case exposure results were derived using the highest value
for the laboratory chemical analyses of field data.
Assumptions used to estimate the "plausible maximum" exposure
associated with dermal contact include:
o The amount of soil in contact with the skin is 2.77
rog/cm2-day for clay soil. The choice of data for clay-
like soil is based on actual field classification of
soil types by geologists during the remedial
investigation.
o Unless otherwise known, one hundred percent of a
compound is assumed to be absorbed through the skin.
For dioxin, three percent of the compound is absorbed
Page 1-37
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through the skin. Ten percent of the pesticides are
absorbed through the skin. Negligible dermal absorption
is assumed for inorganics.
o Assumed body weights are:
Adult - 70 kg
Teenager - 49 kg
6-12 year old child - 30 kg
2-6 year old child - 10 kg
o An expected lifetime is 70 years.
Assumptions used to estimate the "plausible maximum" exposure
associated with accidental ingestion of contaminated soils
include:
o Exposure durations are 1,825 days for a 2-6 year old
child; 1440 days for a 6-12 year old grade schooler;
2,555 days for a teenager; and 18,250 days for an adult.
These exposure duration assumptions are based on a
knowledge of site conditions derived from personal
observations, discussion with RI field team
investigators and the rather temperate climate in
Arkansas. That is, it was assumed that a teenager
could, conservatively, frequent the landfill for eight
months out of the year.
o 0.8 g/day of soil is ingested by a 2-6 year old child;
0.05 g/day of soil is ingested by an adult or teenager.
0.1 g/day is ingested by a 6-12 year old grade schooler.
0.8 g/day is considered to be an upper bound. Recent
guidance recommended 0.2 g/day for a child of 1-6 years
and 0.1 g/day for adults as soil ingestion rates. The
soil ingestion rates used in the analyses were tailored
to site conditions and scenarios.
o Unless otherwise known, one hundred percent of a
compound is assumed to be absorbed through the
gastrointestinal tract. For dioxin, twenty-six percent
is assumed to be absorbed through the gastrointestinal
tract.
o Body weights and expected lifetime are as shown above
for dermal contact.
Assumptions used to estimate the dose associated with long-term
ingestion of contaminated drinking water include:
o A receptor ingests 2 liters of water/day.
o An average man weighs 70 kg.
Page 1-38
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o 100% of the compound is absorbed in the gastrointestinal
tract.
Additional information regarding these assumptions and the
resulting calculations can be found in the Risk Assessment for the
Rogers Road Landfill site, April 1990.
^
In December 1989, EPA's Office of Emergency and Remedial Response
published the interim final Risk Assessment Guidance for Superfund
(RAGS) - Volume I. The purpose of this guidance was to supersede
the Superfund Public Health Evaluation Manual (SPHEM) and
Endangerment Assessment Handbook which, to that date, had been
used for assessing the effects of chemical contamination on human
health. RAGS revised the SPHEM methodology in several ways.
One key modification came through the introduction of the concept
of Reasonable Maximum Exposure (RME). RME is defined as the
highest exposure that could reasonably be expected to occur at a
site. This approach differs from the SPHEM approach of defining
worst-case exposure to site contaminants. One of the primary
differences is that while SPHEM utilized a "worst-case" scenario
based on continued exposure to the maximum detected concentration
of a chemical constituent at the site, RME bases the maximum
exposure on the 95th upper confidence limit of the mean, providing
a spatially averaged exposure concentration.
The final RAGS guidance was not available until the risk
assessment for the Rogers Road site was nearing completion. EPA
considered redeveloping the complete risk analysis based upon the
new guidance. However, upon close consideration, it was
determined that the underlying assumptions being used under SPHEM
were at least as conservative as those set forth in RAGS. Thus,
the results of the Rogers Road Risk Assessment were at least as
protective as those which would have been derived under the
alternate guidance. Additionally, the Rogers Road Risk Assessment
used exposure parameters (such as body weight, ingestion rates,
exposure frequencies and durations, etc.) which were consistent
with RAGS. Therefore, the decision was made to finalize the risk
assessment under the SPHEM guidance, and so risks presented in
this ROD are based upon "worst case" exposures rather than the
RME.
EXPOSURE ASSESSMENT SUMMARY
To determine if exposure might occur, the human and environmental
activity patterns near the site and the most likely pathways of
chemical release and transport must be defined. A complete
exposure pathway has four necessary components: (1) a source of
chemical release to the environment; (2) a route of contaminant
transport through an environmental medium; (3) an exposure or
Page 1-39
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contact point; and (4) the presence of a human or environmental
receptor at the exposure or contact point.
The mode of exposure influences risks to receptors. Modes of
exposure usually include ingestion, inhalation and direct contact.
Ingestion may take the form of direct exposure through drinking or
eating contaminated water and food or may involve indirect routes
such as use of contaminated water for food preparation and
ingestion of soil deposited on hands and transferred to food,
cigarettes, etc. Dermal exposure may result from direct contact
with contaminated water, soil or other material. The following is
a media-by-media discussion of the major potential routes of
exposure to hazardous constituents associated with the site.
Direct and Indirect Contact with Contaminated Surface Soil Onsite
and/or Offsite
Contaminated soil can cause risks to public health through direct
contact and associated incidental ingestion and dermal adsorption.
Compounds of concern include congeners and isomers of
dioxin/furans; herbicides; and the pesticide dieldrin.
No quantitative data are available on the size of the population
potentially exposed to onsite hazardous constituents via direct
contact. Access to the site is now somewhat restricted with a
fence and gate, but previous report(s) suggest that the landfill
access was not restricted between 1973 to 1986.
The fencing is low enough to allow relatively easy access by
trespassers. Receptors entering the site boundaries via this
route are at risk. Receptors most likely to come into direct
contact with surface soils are nearby residents. Direct exposure
with on-site surface soils and sediments is therefore a likely
exposure scenario.
Wildlife and domestic animals may also be exposed to onsite or
offsite contaminated soils and sediments. Domestic animals could
potentially carry contaminated sediments or soils to local
residences and potentially affect human occupants. Wildlife could
eat contaminated soil and the local population could eat
contaminated wildlife (rabbits), potentially being exposed to the
contaminants. Exposure to animals is, however, expected to be
sporadic and of limited duration.
Contaminants may migrate via several mechanisms at the Rogers Road
Landfill Site. These include percolation of contamination into
ground water, surface runoff and soil erosion. It has been
determined through previous studies that airborne transport of
contamination is not a significant transport mechanism.
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Direct and Indirect Contact With Ground water
Ground water at the site flows generally east-southeast. However,
there are no residences located in this direction west of the
Jacksonville Landfill, and residences near the Rogers Road
landfill in other directions are using city water. The closest
well downgradient of the Rogers Road Landfill Site that is used
for any purpose (other than monitoring) is non-potable use by a
resident located immediately east of the Jacksonville Landfill.
Under the circumstances, the only existing significant potential
source of exposure to contaminated ground water on the Rogers Road
Site would be to workers sampling wells or during associated
sample handling, analysis and disposal. Appropriate protective
equipment and procedures are used during such activities to
prevent significant exposure.
Transport by Surface Runoff
During heavy rainfall events, contaminants in the surface soils
around the drum disposal area can migrate via surface water
runoff. Surface water drainage at Rogers Road Landfill is a
series of drainageways which flow east-northeast towards a manmade
drainage ditch at the Lonoke/Pulaski County line. This ditch
flows north under Graham Road and empties into the Holland Bottoms
Wildlife Management Area.
Surface water and sediment samples collected from the drainage
areas adjacent to the landfill contain no elevated concentrations
of compounds, compared to background samples. Therefore, it is
assumed that these drainage ditches are not migration pathways for
contaminants.
The site is located in a floodplain. Therefore, transport as a
result of a major flood is also possible. However, chemical
analyses suggest this has not been an important pathway for dioxin
and herbicide migration from the site.
Direct and Indirect Exposure to Surface Water and Associated Biota
Manganese and beryllium have been detected in the drainage ditch
south of the site. Manganese has also been detected in the
landfill trench water. Human exposure to surface water
contaminants could potentially occur in these bodies of water.
People can gain access to the landfill, wade in the trench and
accidentally ingest the contaminated water. However, such
exposure would probably be sporadic and of short duration. The
manganese in the water would make it taste bitter, discouraging
any potential consumption.
Environmental receptors may also be exposed to hazardous
constituents in surface waters. Wild and domestic animals may
Page 1-41
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frequent potentially impacted surface waters to wade or bathe and
ingest the water. As with humans, their exposure would be
sporadic and of short duration.
Aquatic flora and fauna inhabiting site-impacted surface waters
may also be exposed. Ingestion of fish should not be a problem
because there are no known fish in the off-site ditches and on-
site trench.
Inhalation
Under present site conditions, inhalation of airborne contaminated
dusts and/or inhalation of volatilized surface soil contaminants
are considered to be very minor routes of human or environmental
exposure. No dioxins and furans were observed in air samples
during previous investigations. Dioxin and phenoxy herbicides
adsorb strongly to the soil. The only organics detected in air
samples at the landfill were ethylbenzene and xylene (FIT team
document dated September 13, 1986). However, they were not found
in high concentrations. Further, no volatile compounds were
detected in high enough concentrations to register on field survey
instruments (flame and photo ionization detectors) during the
remedial investigation. Also, the vegetative cover over most
areas of the site would tend to prevent suspension or emission of
particulate contaminants.
RISK EVALUATION SUMMARY
The potency of substances and associated risks are evaluated
separately for noncarcinogenic and carcinogenic effects.
Explanation of Carcinogenic Risk
EPA-approved methods for evaluating the carcinogenic and mutagenic
potency of substances assume that any finite exposure will be
associated with a finite amount of risk. This is because a
genotoxic insult (even if caused by only one molecule) is assumed
to have a finite probability of allowing a cell to grow into a
malignant tumor. Carcinogenic risks below one percent (0.01) are
generally computed by multiplying estimated average daily
exposures over a lifetime by slope factors. A slope factor is an
upper-bound estimate (with a 95% confidence) of the probability of
an individual developing cancer per unit intake of a chemical over
a lifetime, based on a linearized multistage model. The slope
factor is also called the Cancer Potency Factor (CPF) and is
expressed in units of (mg/kg-day)"1. The term "upper bound"
reflects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimation of the actual
cancer risk highly unlikely. Cancer risks from mixtures of
substances are assumed to be the sum of the risks associated with
the individual substances in the mixture when the total risk is
less than one percent.
Page 1-42
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Explanation of Noncarcinoqenic Risk
Forms of toxicity with endpoints other than cancer and gene
mutations are treated as if there is an identifiable exposure
threshold below which there are no observable adverse effects.
Such toxicity is called "threshold toxicity." The underlying
mechanism associated with threshold toxicity assumes that:
• Multiple cells must be injured before an adverse effect
is experienced, and that
• The injury must occur at a rate exceeding the rate of
cell repair.
In addition, cells and fluids between cells may contain
metabolizing enzymes that modify contaminants and allow small
amounts to be tolerated.
A chronic reference dose (RfD) is an estimated level of. daily
exposure to the human population (including sensitive
subpopulations) that is likely to be without an appreciable risk
of deleterious effects during a lifetime. These levels are
estimated to be below threshold levels at which adverse effects
would occur. RfDs are used to indicate acceptable levels of daily
human exposure to individual chemicals.
Hazard indices are used to evaluate the potential noncarcinogenic
impacts of pollutant mixtures. A hazard index is the sum of the
ratios of predicted amounts of exposure to the corresponding
chronic reference doses for all substances. A hazard index less
than one indicates that adverse noncarcinogenic effects are
unlikely. Ideally, hazard indices would be calculated separately
for each threshold toxic effect for all pollutants that cause the
effect by the same mechanism. However, adequate data to identify
all effects associated with each pollutant is not available. As
a result, the hazard index used includes all pollutants with
reference doses, regardless of what effects they may or may not
share. The result is an extreme upper limit to the hazard index.
Results
Using the above procedures, the health risks identified at the
Rogers Road Landfill were determined based on the distribution and
extent of chemical contamination, the potential for contaminant
transport, opportunities for exposure and toxicity of the
contaminants.
Risk assessment findings at the landfill indicate a potential
health risk is predominantly associated with direct contact with
or accidental ingestion of contaminated soil at the "hot spot"
located at the drum site within the landfill. Specifically, the
hot spot contaminants cause excess carcinogenic health risks and
Page 1-43
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noncarcinogenic health hazards. The excess carcinogenic risks
calculated for the landfill and surrounding areas including the
dioxins, furans and other carcinogens are summarized in Table 3.
At the drum disposal area, the carcinogenic risk is 4.27 x 10"4 for
plausible exposure and 2.19 x 10 for worst case exposure.
"Plausible" or most likely exposure results are derived using
arithmetic and geometric means of laboratory chemical analyses of
field samples.. Worst case exposure values were calculated using
the highest value for the laboratory chemical analyses of these
samples. These risks, however, are limited to an extremely small
area on the landfill property. The remainder of the landfill
presents a worst case risk of i.oi x 10" , due primarily to low
levels of dioxin contamination.
Analytical results indicate that 2,3,7,8-TCDD, as well as 2,4,5-
T or 2,4,5-TP herbicide contamination is not present in any
offsite residential areas above analytical detection limits.
These detection limits ranged from 0.006 to 0.08 ppb. A
hypothetical calculation was made to determine what additional
risks would occur if dioxin existed below detection limits.
Assuming that the concentrations in the residential areas average
one-half of the detection limit, risks were calculated for an
offsite 2 to 6 year old child and an adult gardener. Risks were
1.05 x 10"5 for a child and 1.20 x 10"5 for an adult gardener for
plausible exposure from 2,3,7,8-TCDD. The 2 to 6 year old age
group was chosen for detailed calculation because their exposure
rate and physical characteristics (e.g., low body weight)
represent a worst case situation for children. It should be
stressed that offsite risks from 2,3,7,8-TCDD and the family of
dioxins (including 2,3,7,8-TCDD) and furans are only hypothetical
values since no 2,3,7,8-TCDD; 2,4,5-T or 2,4,5-TP was ever
detected at these offsite residential backyards.
Total risk from all detected carcinogenic contaminants calculated
for the off site residential soil is 9.42 x 10"6 for plausible
exposure and 1.70 x 10" for worst possible exposure. The major
contributor to this risk is arsenic in offsite areas which cannot
be attributed to the site. These offsite risks quoted are for a
2 to 6 year-old child. Arsenic is fairly widely distributed on
the landfill and offsite areas. This substance, a common
component of soil, is known to exist at higher background
concentrations in Central Arkansas than throughout the contiguous
United States. Since downgradient arsenic concentrations are not
higher than background levels, the offsite arsenic risk is not
likely to be associated with the landfills.
The noncarcinogenic health hazards at the landfill drum site are
related to the herbicides present in the drums. Hazard Indices
(His) relating to on and offsite areas are presented in Table 4.
His calculated for 2,4,5-T, 2,4,5-TP and dieldrin at the drum site
were large and range from 12.4; 6.01 and 4.35, respectively, for
plausible exposure, to 129; 20.9 and 13, respectively, for worst
Page 1-44
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possible exposure. His greater than 1.00.indicate that chronic
toxicity may occur in an exposed individual, for example, a
teenager coming into contact with the drum contents or surrounding
soils.
His were much lower for the remainder of the landfill, with worst
case His of 7.69 x 10"2 and 1.36 x 10"1, respectively, for 2,4,5-T
and 2,4,5-TP. The concentrations of herbicides in these locations
were not high enough to present significant health risks.
His for offsite herbicide exposure were insignificant, as
concentrations were nondetectable.
Since investigations indicated no sensitive or endangered species
or critical habitats located within or immediately adjacent to the
landfill, environmental risks were not calculated. Animals most
likely to be impacted are common wildlife such as squirrels,
rabbits, birds and deer, and domestic animals that were observed
onsite during the remedial investigation. Their exposure to site
contaminants, however, is sporadic and of limited duration, thus
detrimental effects due to exposure are considered to be minimal.
In conclusion, this risk assessment indicates that dioxin and
herbicide concentrations exceed criteria for excess lifetime
cancer risks and/or health hazards. Plausible routes of exposure
and a likely exposed population have been defined. Therefore, a
potential health hazard exists.
DEVELOPMENT OF REMEDIATION GOALS
Remediation goals are divided into two categories. The first,
pre-remedial action levels, is used as criteria to determine
whether cleanup is required. These levels are based upon the
targeted residual risk to remain at the site. The second
category, post-remedial treatment goals, is comprised of a
combination of health-based and regulatory treatment standards.
Both categories are discussed below and are summarized in Tables
5A and 5B.
Remediation goals are developed for contaminated soils only.
Since none of the detected contaminants exhibited any consistent
spacial pattern in the ground water that suggested downgradient
migration of surface contamination, an active ground water
remediation program was not considered. The selected remedial
alternative will, however, incorporate a system of long-term
ground water monitoring to ensure that the remedy remains
effective in the protection of ground water quality and to aid in
the identification of long-term trends in the quality of the
ground water. If comparison of the monitoring results to MCLs or
health-based levels indicates that significant degradation of
ground water quality were occurring or imminent at any time, the
data would be evaluated and confirmatory sampling performed, along
Page 1-49
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with an updated survey of ground water use. If imminent
degradation of the Class IIB aquifer is confirmed, downgradient
users would be notified and the need for, and feasibility of,
remedial action would be re-evaluated during the next year.
Options to be considered would include alternate water supplies,
extraction and treatment methods, or other viable ground water
restoration technologies.
Pre-Remedial Action Levels
The remediation goals for this alternative were derived from
recommendations by the Centers for Disease Control (with respect
to carcinogenic health threats) and from calculations produced in
the Rogers Road Landfill Risk Assessment (regarding
noncarcinogenic health effects).
Carcinogenic Risks: 2,3,7,8-TCDD and dieldrin are the only
probable carcinogens detected at the site above health-based
levels. Thus, they will be the only carcinogenic compounds
assigned a remediation goal.
The Centers for Disease Control (CDC) has recommended that
equivalent 2,3,7,8-TCDD concentrations not exceed 1 ppb in
residential surface soils. This recommendation was made for a
residential setting, where continual contact with soils would
occur over a 70-year lifetime from infancy to old-age.
Additionally, CDC has determined that subsurface soils containing
concentrations of 2,3,7,8-TCDD not exceeding 10 ppb should not
pose a significant health hazard if covered with 12 inches of
clean soil.
Although present site conditions are nonconducive to residential
development (i.e., trenched and mounded with municipal wastes) and
there are no city or county zoning ordinances restricting land-
use, it is nonetheless conceivable that the site could be used for
residential purposes in the future. This is an unlikely scenario,
but it cannot be entirely eliminated. In consideration of
potential future land-use, the 1 ppb and 10 ppb equivalent
2,3,7,8-TCDD recommendations for the residential setting are
appropriate and therefore adopted as a remedial action objective
for the Rogers Road Landfill site.
If the maximum equivalent 2,3,7,8-TCDD concentration in surface
soil is reduced to 1.0 ppb (a maximum reduction of 99.5%), the
associated plausible maximum cancer risk from direct exposure to
dioxins and furans would be 8x10 (based on the potency and
exposure assumptions in the Baseline Risk Assessment). This risk
would be in accordance with general EPA policy to limit maximum
individual cancer risks to a range between 10"4 and 10"6.
Under maximum plausible exposure, the maximum individual risk of
cancer from dieldrin exposure was calculated to be 9.89xlO"4 based
Page 1-52
-------
on a dieldrin concentration in one sample at 37,000 ppb. To
reduce the cancer risk from exposure to dieldrin to less than 1 x
10"6 under maximum plausible exposure, the maximum dieldrin
concentration would have to be reduced to 37.4 ppb.
A reduction in potential maximum plausible exposure to dieldrin by
99.90% at these locations would reduce the maximum individual risk
attributable to, this contaminant to IxlO"6.
Noncarcinogenic Risks: As mentioned previously, dieldrin and the
herbicides 2,4,5-T and 2,4,5-TP may act on the same target organs
by similar mechanisms. In addition, concentrations in the drum
disposal area are very non-homogeneous. Under the circumstances,
adding the aforementioned hazard indices for the above substances
is an appropriate method for estimating the maximum combined HI
for herbicides and dieldrin (for the purpose of conservatively
estimating remedial action objectives). Thus, the combined
maximum HI for 2,4,5-T, 2,4,5-TP, and dieldrin in the drum
disposal area is 163, under maximum exposure.
The highest HI from substances other than herbicides and dieldrin
under maximum plausible exposure is 0.127 from 9,900 ppb of
bromomethane, detected near the center of the drum disposal area.
The next highest HI for an organic substance is 0.085 from 4,4'-
DDT (2,400 ppb), found outside the drum disposal area. Combining
the above His for each of these constituents yields a total Hazard
Index from substances other than herbicides and dieldrin of 0.212.
The combined hazard index for all site pollutants that act on the
same target organs by the same mechanism should be less than one
for threshold toxic effects to be considered unlikely. Reducing
the hazard index for herbicides and dieldrin to 1.0 would not
leave any margin of safety for exposure to other substances that
may act in a similar manner (such as those described in the
previous paragraph) or for exposure to the same substances from
sources other than the Rogers Road Landfill Site. Under the
circumstances, a representative remedial action objective is to
reduce the combined hazard index for exposure to dieldrin and
herbicides (2,4,5-T and 2,4,5-TP) from the Rogers Road Landfill
Site to 0.7 or less.
As mentioned, the combined hazard index under worst case exposure
from the herbicides is 163. Reducing this hazard index to 0.7
would require a 99.57% reduction in exposure. Based on the
observed concentrations of herbicides and a 99.57% removal
efficiency, target concentrations for herbicides and dieldrin to
achieve a hazard index of 0.7 would be:
33,100 ppb for 2,4,5-T
4,300 ppb for 2,4,5-TP, and
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• 160 ppb for dieldrin
If, after sampling, the concentrations of either 2,4,5-T, 2,4,5-
TP or dieldrin exceed these action levels, the combined hazard
index should be calculated (using the method employed in the risk
assessment) to determine if it exceeds the 0.7 HI action level.
If the recalculated HI is found to exceed the action level, these
soils will be targeted for remedial action.
It should be noted that exceedances of the target concentrations
for herbicides and dieldrin have only been detected within the
drum disposal area, which also contains high dioxin
concentrations. Therefore, it is expected that as the dioxin-
contaminated soil is remediated, the herbicides will be addressed
simultaneously.
The above discussion indicates that there are two target levels
for dieldrin, 37.4 ppb based on cancer risk, and 160 ppb based on
a non carcinogenic hazard index. Under the circumstances, the
37.4 ppb level, being the more restrictive number, is adopted as
the cleanup criterion for dieldrin.
Post-Remedial Treatment Goals
As discussed in the Summary of Site Characteristics section of
this ROD, the site waste is not RCRA-listed but it is
characteristic. Therefore Land Disposal Restrictions (LDRs) are
relevant and appropriate to certain constituents of the treated
waste. Regulatory treatment goals for dioxin-waste are also
adopted to ensure adequate treatment of site contamination.
LDRs for D016 and D017 hazardous waste were published in the June
1, 1990 Federal Register (under 40CFR part 268.43). Since D016
and D017 restrictions are considered to be relevant and
appropriate, concentrations of 2,4-D in the waste will have to be
reduced to 10,000 ppb and concentrations of 2,4,5-TP in the waste
would have to be reduced to 7,900 ppb before the material can be
disposed of. Complying with these limitations will require
reducing maximum 2,4-D concentrations by 99.97% and reducing
maximum 2,4,5-TP by 99.21%.
In addition to the regulatory treatment goals, the pre-remedial
action levels will also be required of the treated waste.
Compliance to the more stringent of the criteria would be
required.
Thermal treatment is the best demonstrated available technology
for treatment of the types of waste found in the Rogers Road
Landfill soils (i.e., dioxins and herbicides). Performance
standards applicable to this type of treatment include the
requirement for a 99.9999% destruction and removal efficiency as
well as limitations on HC1 and particulate emissions. Treatment
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to this degree will result in the attainment of all treatment
levels specified for the above-mentioned contaminants. Dioxin-
contaminated soil would be remediated to well below the 1 ppb
health-based goal recommended by ATSDR for residential surface
soil. Additionally, all contaminants causing the waste to be
considered characteristic of EP toxicity would be destroyed to the
point that it no longer exhibits the characteristic.
DESCRIPTION OF ALTERNATIVES
SARA requires that selected remedies utilize permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. For the Rogers
Road Landfill Site, a no-action alternative and a range of
treatment and containment alternatives were developed. Based on
the remedial technologies selected, five remedial alternatives
have been developed. One of the alternatives is the no-action
alternative; one involves containment and institutional controls;
one involves offsite treatment, containment, and institutional
controls; and two involve onsite treatment, containment and
institutional controls. The alternatives are:
1) No-Action;
2) Fence, Caps, Land-Use Controls, and Monitoring;
3) Excavation, Offsite Thermal Treatment and Landfill, Soil
Cover, Fence, Land-use Controls, and Monitoring;
4) Excavation, Thermal Treatment and Backfilling at the
Jacksonville Municipal Landfill site, Soil Cover, Fence,
Land-Use Controls, and Monitoring; and
5) Excavation, Thermal Treatment and Landfill at the Vertac
Chemical Corp. Site, Soil Cover, Fence, Land-use Controls,
and Monitoring.
COMMON ELEMENTS
Many of the remedial alternatives presented below share common
elements. The most frequently shared components are presented as
follows:
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Remedial Alternative
Component
Ground Water Monitoring
Contaminant Mapping
Soil Cover
Filling in Site Trench
Land-Use Controls
1 2
X X
X
X
X
X
3
X
X
X
X
X
4
X
X
X
X
X
5
X
X
X
X
X
Components
Ground Water Monitoring; The representative ground water
monitoring program would consist of sampling two existing, and
three new shallow monitoring wells annually. The ground water
samples would be analyzed for Target Compound List (TCL) organics
and inorganics, along with herbicides and pesticides. This
evaluation would include a spatial and temporal analysis of
existing data to determine increasing, decreasing, or stationary
trends in contaminant concentrations. The results of this
evaluation would be used to maintain, increase or decrease the
number and types of samples and analysis required for the
monitoring program. As required by RCRA, the monitoring and
evaluation program would be implemented for 30 years, or another
period of time as established by the EPA Regional Administrator.
Contaminant Mapping: The extent of contamination at the Rogers
Road Landfill Site is based on linear interpolation of results
from the June 1990 Contaminant Mapping Study. The estimated
amount of soil, debris and waste containing more than 10 ppb
equivalent 2,3,7,8-TCDD in these areas is 50 cubic yards (72
tons) . 250 cubic yards (362 tons) of the site is estimated to
contain equivalent 2,3,7,8 TCDD concentrations above 1 ppb. In
addition, 120 cubic yards of soil contaminated with dieldrin above
37 ppb is expected to be encountered. The total area contaminated
above 1 ppb equivalent 2,3,7,8-TCDD and 37 ppb dieldrin is
estimated as 10,000 square feet.
Soil and waste containing greater than 1.0 ppb equivalent 2,3,7,8-
TCDD or 37 ppb dieldrin, and/or dieldrin and herbicide
contamination associated with a combined hazard index greater than
0.7 would be mapped in 10 foot cells, using the procedures
described in Section 4.5.2 of the Rogers Road Landfill Feasibility
Study.
Generally, the representative grid sampling program would involve:
• Dividing the areas estimated to be contaminated above the
aforementioned limits into 10-foot grids,
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• Collecting four grab samples of approximately equal volume
from every cell within the grid (at the approximate center of
every 5'x 5' quarter of the grid, at a depth of 3 to 9
inches),
• Homogenizing the four grab samples in a bowl and taking at
least one .aggregate sample from the bowl,
Analyzing for 2,3,7,8-TCDD, dieldrin, and herbicides in each
aggregate sample,
Results of each aggregate sample will be interpreted as
characterizing the chemical constituency of the total grid so
that appropriate remedial measures can be taken.
Soil Cover; Soil containing between 1 and 10 ppb equivalent
2,3,7,8-TCDD, greater than 37 ppb dieldrin, and/or dieldrin and
herbicide contamination associated with a hazard index above 0.7
would be graded (if necessary), covered with 12 inches of
uncontaminated clay, and revegetated. The soil cover would be
integrated into the surrounding soil for uniform, continuous
coverage.
Filling in Site Trench; The trench at the site is an attractive
nuisance and contributes to ground water recharge. This trench
would be backfilled with clean, native clay and revegetated.
Land-Use Controls; Land-use restrictions would also be placed on
the site and surrounding ground water use to prevent activities
that could endanger public health. Representative land-use
restrictions would limit ground water use onsite and deter use of
the shallow ground water immediately downgradient of the site.
The method of imposing such restrictions would consist of
negotiation with the City of Jacksonville concerning the Landfill
and with owners of surrounding property concerning ground water
use.
Cost estimates were prepared during the Feasibility Study for each
of the alternatives. The accuracy range targeted for the
estimates was +50% / -30%, meaning that the actual remediation
costs may be up to 50 percent higher or 30 percent lower than the
estimates accompanying the alternatives presented below. The cost
evaluations were not produced with the intent to accurately
predict remediation expenses, but rather to establish a uniform
basis for evaluating the relative costs attributable to each
alternative.
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The cost estimates presented in this ROD have been revised from
those presented in the Feasibility Study Report based upon the
revised soil volumes calculated during the Contaminant Mapping
Study.
Applicable or Relevant and Appropriate Requirements fARARs)
This discussion will focus on only the most significant ARARs
shared by the remedial alternatives.
RCRA Land Disposal Restrictions; Land Disposal Restrictions
(LDRs) are presented in 40 CFR Part 268. LDRs establish a
timetable and treatment criteria for the restriction of disposal
of wastes and other hazardous materials.
As previously discussed, there is no affirmative evidence proving
from which process the herbicides, trichlorophenol and other site
related chemicals came. Records are required to determine the
origin (and thus the "listability") of the waste. Since the
evidence is inconclusive, land disposal restrictions are not
applicable. Furthermore, Superfund LDR Guide No.7, "Determining
When Land Disposal Restrictions (LDRs) Are Relevant and
Appropriate to CERCLA Response Actions", states that EPA will not
consider the LDRs to be relevant and appropriate for soil and
debris contaminated with hazardous substances that are not RCRA
restricted wastes. Therefore, LDRs are not considered relevant
and appropriate for the dioxin-contaminated soils at the Rogers
Road site. Nonetheless, in the interest of ensuring adequate
treatment of the dioxin waste onsite, RCRA restrictions pertaining
to the treatment of listed wastes will be considered relevant in
the determination of remediation goals.
The contaminated soils are, however, considered "characteristic"
of hazardous waste under waste codes D016 (for 2,4-D) and D017
(for 2,4,5-TP). These waste codes became subject to LDRs with the
promulgation of the RCRA "Third Thirds Rule" in June 1990.
Treatment standards specified in this regulation must be met prior
to waste disposal. Please refer to the "DEVELOPMENT OF
REMEDIATION GOALS" section of the ROD for more information
regarding the applicability of this requirement.
Consideration was given to alternatives 4 and 5 with respect to
ARARs relevant to disposal of the treated ash. Since the ash
resulting from treatment will meet health-based treatment goals,
it will be placed directly into the ground (rather than into a
Subtitle C landfill) without any further processing, except to
modify the pH of the soil mixture to make it more suitable for
revegetation. Also, there would be no need to "delist" the ash
since the waste was not a listed waste prior to treatment.
Characteristic hazardous wastes never need to be delisted, but do
require treatment until the characteristic is no longer exhibited.
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This determination is consistent with the RCRA "Contained-in"
Rule, which states that any mixture of a non-solid waste (such as
soil or ground water) and a RCRA listed hazardous waste must be
managed as a hazardous waste as long as the material contains
(i.e., is above health-based levels) the listed hazardous waste.
Once the material has been treated to no longer "contain" the
listed hazardous waste, the material itself will no longer be
considered a hazardous waste.
40 CFR 264.343. Subpart 0 - Incinerators: This regulation
provides operational standards and monitoring requirements for
hazardous waste incinerators. Key components of this regulation
include the requirement for a dioxin-waste destruction and removal
efficiency of 99.9999% for each principal organic hazardous
constituent and places limitations on HC1 and particulate
emissions.
Subpart 0 is considered relevant and appropriate to all remedial
alternatives which employ thermal destruction as a treatment
element.
40 CFR Parts 260. 261. 264 and 270 - Standards for Owners and
Operators of Hazardous Waste Incinerators... (Proposed Rule);
These regulations are currently set forth in "Proposed Rule"
status and are not promulgated, thus they are neither applicable
nor relevant and appropriate. They are, however, "To Be
Considered (TBCs)" as they amend the current hazardous waste
incinerator regulations to improve control of toxic metal
emissions, HC1 emissions and residual organic emissions.
40 CFR Part 258. Criteria for Municipal Solid Waste Landfills
(Proposed Rule); These regulations are also TBCs. They provide
additional operating and design criteria for owners and operators
of municipal solid waste landfills. Included are closure and
post-closure requirements that are more stringent than current
Subtitle D regulations.
State ARARs; No State regulations have been identified as being
more stringent than their Federal counterparts. In order to
qualify as a State ARAR, a State requirement should be:
A State law;
An environmental or facility siting law;
Promulgated;
More stringent than the Federal requirement;
Identified in a timely manner; and
Consistently applied.
Descriptions of the remedial alternatives follow:
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ALTERNATIVE 1 — NO ACTION
Description
During the development and evaluation of alternatives, EPA
guidance requires that a no-action alternative be considered as a
"baseline case," against which all other alternatives will be
evaluated.
Under this alternative, no remedial action will be taken, other
than the ground water monitoring program described above.
Because the wastes remain at the Rogers Road Landfill Site, SARA
requires that the data collected from the site be evaluated every
five years to ensure that the remedies implemented remain
protective to human health and the environment. The first five
year review will be initiated no more than five years after the
Remedial Action begins.
Cost and Timing
The cost directly associated with implementation of this
alternative is related to the long-term monitoring and the 5-year
review program. The total cost of drilling and casing the new 40-
foot deep wells is estimated to be $15,000, including indirect
costs. The annual operation and maintenance (O&M) cost for
monitoring is estimated to be about $17,000; and the cost of each
five year review is estimated at $10,000. The total present worth
is approximately $302,000 based on a 5% discount rate and a 30-
year time period.
It is expected that this remedy would be fully implemented within
9 months of the signing of the ROD.
Compliance with ARARs
No Federal or state regulations specify soil cleanup levels for
contaminated soil that is left in-place. Because the soil would
not be treated or effectively contained, this alternative would
not comply with relevant and appropriate clean closure or landfill
closure requirements.
Action-Specific ARARs pertinent to the implementation of this
alternative would apply to the monitoring activities only.
Requirements for these activities include OSHA health and safety
standards, and RCRA facility standards pertaining to preparedness
and prevention, contingency plan and emergency procedures,
recordkeeping, and closure and post-closure procedures.
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ALTERNATIVE 2 — FENCE, CAPPING, LAND-USE CONTROLS, MONITORING
Description
The objective of this alternative is the elimination of the major
potential risks to public health and to the environment with
minimum action. The most significant risk to the public is due to
direct contact .with dioxin contaminated soil onsite.
Under this alternative, soil and waste would be mapped in 10 foot
cells, using the procedures described in the "COMMON ELEMENTS"
section above. The soil and waste containing more than 10 ppb
equivalent 2,3,7,8-TCDD would be wetted, excavated where
necessary, consolidated into a pile in the drum disposal area
(centered around the central waste pile in this area), graded,
compacted, and covered with a multi-layer RCRA cap.
The soil containing between 1 and 10 ppb equivalent 2,3,7,8-TCDD,
greater than 37 ppb dieldrin and/or containing dieldrin and
herbicide contamination associated with a hazard index above 0.7
would be wetted, graded and capped with a 12 inch thick soil
cover. The RCRA cap would be integrated into any adjacent soil
cover or native soil to achieve a uniform, continuous coverage.
The trench at the site is an attractive nuisance and contributes
to ground water recharge. This trench would be backfilled with
clean, native, silty clay and revegetated.
All excavation should take place when the site (including the
trenches) is most likely to be dry, to avoid problems with mud and
with disposal of water in the trenches. A water spray should be
used to control dust during excavation.
In addition, a 7 foot tall, heavy-duty chain link fence with
outriggers and coiled razor wire would be erected to surround the
southern third of the site, where dioxin, dieldrin and herbicide
contamination exceeds action levels and where the caps would be
located. The chain link would be of a fine mesh to make scaling
extremely difficult. The fence posts would be anchored in
corrosion resistant concrete, and the razor wire would be spot
welded to the fence posts, outriggers, and horizontal supports, to
discourage theft and breaching of the barrier. "No-trespassing"
signs warning of the hazards within would also be posted at 100
foot intervals on the fence. The fence would have a padlocked
gate to allow access. Such a fence should reduce trespassing on
the dioxin contaminated portions of the site and the associated
risks.
Land-use restrictions, as described under "COMMON ELEMENTS", would
also be placed on the site and surrounding ground water use to
prevent activities that could endanger public health.
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The ground water monitoring and five year evaluation programs are
identical to those described for the no-action alternative.
The boundary of ground water compliance will be delineated by the
deep downgradient wells which are identified in the "DETAILED
DESCRIPTION OF REMEDY" section of the ROD. If comparison of
sampling results to MCLs or health-based levels indicates that
significant degradation of ground water quality was occurring or
imminent downgradient of the site at any time, the data would be
evaluated and confirmatory sampling performed, along with an
updated survey of ground water use. If imminent degradation of
the Class IIB aquifer is confirmed and use of the water is
occurring or likely to occur, ground water users would be notified
and the need for, and feasibility of, remedial action would be re-
evaluated during the next year. Options to be considered would
include alternate water supplies, extraction and treatment
methods, or other viable ground water restoration technologies.
The need for a separate Record of Decision, Explanation of
Significant Differences or other type of ROD amendment would be
evaluated at the time that the situation arises.
Inspections of the fence, gate and lock, along with the RCRA cap
and the soil cover would occur on an annual basis, and repair
would take place as necessary and appropriate to assure their
integrity.
During excavation and handling of contaminated material, dust and
visible emissions would be measured and the monitoring required by
OSHA would be performed, in accordance with detailed plans
developed during the design of this alternative.
This alternative will reduce site risks by providing a protective
cap, thus reducing the "direct contact" threat. It does not
eliminate the site risks but does "control" them as long as the
effectiveness of the cap is maintained.
Cost and Timing
The cost of ground water monitoring and five year evaluations
associated with this alternative is approximately $293,000.
Annual review of the data, fence and cap inspections, and
maintenance will add $11,000 per year. Installation of the caps,
the improved fence and gate is estimated to cost $364,000. The
present worth of implementing this alternative is estimated to be
$930,000.
It is expected that this remedy would be fully implemented within
15 months of the signing of the ROD.
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Compliance with ARARs
Action-Specific ARARs pertinent to the implementation of this
alternative would apply to the monitoring and capping activities.
Requirements for these activities include OSHA health and safety
standards, and RCRA facility standards pertaining to minimum
technology requirements, preparedness and prevention, contingency
plan and emergency procedures, recordkeeping, and closure and
post-closure procedures.
Since no "placement" of RCRA contaminated waste would occur under
this alternative, Land Disposal Restrictions are not considered to
be ARARs.
This alternative would not remove contaminated material, but it
would provide containment of contaminated soils with an
impermeable cap. Relevant and appropriate RCRA closure/post-
closure requirements in 40 CFR Sections 264.110 through 264.120
would be met.
ALTERNATIVE 3 — EXCAVATION, OFFSITE THERMAL TREATMENT AND
LANDFILL, SOIL COVER, LAND-USE CONTROLS, MONITORING
Description
Implementation of this alternative would begin with detailed soil
monitoring. The objective of the representative monitoring
program would be to define the 10 foot by 10 foot cells within
which equivalent 2,3,7,8-TCDD and dieldrin concentrations in
surface soil and debris exceed 10 ppb and 37 ppb, respectively,
the cells within which the equivalent 2,3,7,8-TCDD concentrations
exceed 1 ppb, and the cells in which the hazard index from
dieldrin and herbicides exceed 0.7. The establishment of these
remediation criteria is outlined in the SELECTED REMEDY section of
this ROD.
The soil and waste containing more than 10 ppb equivalent 2,3,7,8-
TCDD (and associated herbicides) would be excavated, screened and
loosely packed in labeled 35-gallon fiber drums. These drums
would be overpacked in 55-gallon drums and labeled with the cell
number from which they came. The overpacked drums would be
transported and stored in a shed erected in the north end of the
Jacksonville Municipal Landfill Site designed to comply with all
relevant and appropriate requirements for hazardous waste storage
facilities. (The Jacksonville site was chosen because it is more
easily accessible, there is more space available, and there would
already be a shed erected there housing 1500 drums of Jacksonville
Landfill waste.) Packing all of this material in 35-gallon
overpacked drums would require about 575 drums and overpacks,
assuming an average of 250 pounds of contaminated soil is packed
into each drum. Drums of waste associated with monitoring and
remedial action would also be stored in the shed. Storage would
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continue until an offsite thermal treatment unit is permitted to
treat the soil, debris and waste and an offsite landfill is
permitted to accept the ash. The drums would then be manifested
and transported to a licenced thermal treatment facility.
The soil that contains equivalent 2,3,7,8-TCDD concentrations
between 1 ppb and 10 ppb, greater than 37 ppb dieldrin, and/or
dieldrin and herbicide contamination associated with a hazard
index above 0.7 would be graded, compacted, and capped with a soil
cover. The site trench would be backfilled, as described for
Alternative 2, along with the areas that had contained soil with
equivalent 2,3,7,8-TCDD concentrations above 10 ppb.
For the representative thermal treatment unit, it is assumed that
the facility will only be able to accept 38 tons of soil per day.
At this rate, all 72 tons of contaminated soil could be shipped
offsite for disposal within two days.
Ground water and OSHA monitoring, and five year evaluations would
be similar to that described for Alternative 2, along with soil
cover inspection and maintenance. For this alternative no new
fence would be installed. However, the existing fence at the site
would be maintained.
Land-use controls would be the same as described with Alternative
2.
This alternative will reduce the maximum risks of cancer from
maximum plausible exposure to 8 x 10"5 and will eliminate
significant risks of threshold toxic effects from herbicides
(total hazard index < 1.0).
Cost and Timing
This alternative would include capital costs of $222,000 to
excavate, transport, and pack the estimated 50 cubic yards of
contaminated soil and material containing more than 10 ppb
equivalent 2,3,7,8-TCDD into approximately 580 thirty-five gallon
overpacked drums. Storing the drums at the Jacksonville Landfill
Site is estimated to cost $50,000, including $6,000 for periodic
inspection, assuming the drums are stored for two years prior to
disposal.
Incinerating the contaminated soil is estimated to cost $216,000,
assuming an incineration and land disposal cost of $3,000 per ton.
Transportation of the material is estimated to cost $16,000,
assuming 80 overpacked drums per truck.
Installation of the soil cover at the Rogers Road Site and
backfilling areas from which the highly dioxin contaminated soil
was removed, along with the trenches, is estimated to cost
$104,000.
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Additional O&M costs would include $293,000 for monitoring and 5-
year review as with Alternative 2. Annual review of the data,
fence and soil cover inspections, and fence and soil cover
maintenance would add $6,000 per year. The present worth of
implementing this alternative is estimated to be $1,404,000.
It is expected jthat this remedy could be fully implemented within
2 years of the signing of the ROD if a thermal destruction
facility could be permitted for dioxin waste within 12 months of
the ROD.
Compliance with ARARs
ARARs for this alternative apply to excavation of contaminated
soil, site closure with waste in place, reclamation of the areas
excavated and monitoring activities. Requirements for these
activities include OSHA health and safety standards; RCRA facility
standards pertaining to storage as well as treatment unit
operation and performance; preparedness and prevention;
contingency plan and emergency procedures; manifesting and record
keeping; and standards for ground water protection. RCRA Subtitle
C requirements are relevant and appropriate to the dioxin,
chlorophenol, and herbicide contaminated waste. This alternative
would comply with all such requirements. Transportation would
comply with Federal and Arkansas Department of Transportation
regulations.
As discussed under "COMMON ELEMENTS", although LDRs are not ARARs
for the dioxin-contaminated waste, they are applicable to waste
characteristic of EP toxicity under waste codes D016 and D017.
Treated waste will be required to meet the appropriate LDRs prior
to disposal.
While this is not a RCRA facility, closure and post closure
requirements are considered to be relevant and appropriate. This
remedy would meet the requirements necessary to attain landfill-
closure status. Post-closure inspections to insure the integrity
of the soil cover and ground water monitoring to detect any
significant offsite ground water impacts is expected to comply
with closure requirements.
ALTERNATIVE 4 — EXCAVATION, ON8ITE THERMAL TREATMENT, SOIL COVER,
LAND-USE CONTROLS, MONITORING
Description
This alternative is similar to Alternative 3, except that the soil
is treated at the Jacksonville site. As was described for
Alternative 3, the implementation of this alternative would begin
with sufficient monitoring to define the areas within which
equivalent 2,3,7,8 TCDD-dioxin concentrations in surface soil and
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debris exceed 1 ppb, the cells within which equivalent 2,3,7,8-
TCDD and dieldrin concentrations exceed 10 ppb and 37 ppb,
respectively, and the cells in which the hazard index from
dieldrin and herbicides exceeds 0.7.
For the representative process option, an estimated 72 tons of
soil containing equivalent 2,3,7,8-TCDD concentrations above 10
ppb would be 'sampled, packed in 3,000 Ib capacity labeled
polyester bags, transported and stored in a shed at the north end
of the Jacksonville Site in a manner complying with all relevant
and appropriate requirements for a hazardous waste storage
facility. Storage would continue until a suitable thermal
treatment system is brought to the Jacksonville site and treats
all of the bagged contaminated material from the landfill sites
(along with any contaminated drummed material). Treatment unit
sizing requirements and detailed operational specifications would
be developed during the Remedial Design.
For the representative process, the treated soil, debris and waste
would be analyzed to assure that it meets treatment goals
specified in the "DEVELOPMENT OF REMEDIATION GOALS" section of the
ROD, mixed with manure and seeds, and backfilled at the
Jacksonville site where it would revegetate.
As with Alternative 3, soil containing between 1 and 10 ppb
equivalent 2,3,7,8-TCDD, greater than 37 ppb dieldrin, and/or
dieldrin and herbicide contamination associated with a hazard
index above 0.7 would be covered with 12 inches of uncontaminated
silty clay, and revegetated.
Also as with Alternative 3, the onsite trench would be backfilled,
and the soil cover and the existing fence would be inspected and
maintained. Ground water monitoring, land-use controls, and five
year evaluations would also take place as described for
Alternative 2.
As with the previous alternative, this alternative will reduce the
maximum risks of cancer from maximum plausible exposure to 8xlO"5
and will eliminate significant risks of threshold toxic effects
from herbicides (total hazard index < 1.0).
A variance to this Alternative was considered during the FS. It
involved utilizing chemical dechlorination as the principal
treatment technology rather than thermal treatment. Chemical
dechlorination is a relatively new process capable of rendering
certain hazardous wastes non-toxic. This technology has been
successfully implemented at other commercial and Superfund sites.
Literature and data searches into past applications of this
process had indicated its potential effectiveness on the dioxins
and herbicides contained in the landfill wastes.
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The overall cost and implementation • time for utilizing
dechlorination, however, is approximately the same as for onsite
incineration. This technology was, therefore, not selected for
detailed analysis and presentation since it did not appear to
provide any additional benefits above those available with thermal
treatment. Additionally, it had the disadvantage of being neither
as proven nor as effective as thermal technologies. Incineration
has been demonstrated to be effective many times at full scale
application, however dechlorination does not have a demonstrated
track record with these contaminants in soils similar to those
encountered at the Rogers Road Landfill site. Thermal treatment,
therefore, was chosen as the preferred treatment method.
Cost and Timing
Testing of the selected treatment alternative (i.e. trial burn
testing of the incinerator along with testing leachate from and
the erosion resistance of treated soil mixtures) is estimated to
cost $77,000. These costs are prorated, assuming the same, tests
will be applicable to the contaminated material at the
Jacksonville Landfill Site.
The monitoring, excavation, transport to the Jacksonville Site,
screening and packing of 50 cubic yards of contaminated soil is
estimated to cost $167,000. Temporary storage at the Jacksonville
Site is estimated to cost $59,000 including periodic inspection of
the bags stored on-site, assuming the bags are stored for one year
prior to disposal. The incineration of the contaminated soil and
debris at the Jacksonville Site would cost $54,000.
The covering of low-level dioxin and herbicide contaminated soil
and long term cover and fence inspection and maintenance would
cost $104,000.
Additional O&M costs would include $293,000 for monitoring, annual
review of the data, fence and soil cover inspections, and fence
and soil cover maintenance, as with alternative 2. The present
worth of implementing this alternative is estimated to be
$1,201,000.
It is expected that this remedy would be fully implemented within
2 1/4 years of the signing of the ROD.
Compliance with ARARs
As with Alternative 3, ARARs for this alternative apply to
excavation of contaminated soil, reclamation of the areas of
excavation, and monitoring activities. Requirements for these
activities include OSHA health and safety standards; RCRA facility
standards pertaining to treatment unit operation and performance;
preparedness and prevention; contingency plan and emergency
procedures; record keeping; standards for ground water protection;
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and closure and post-closure requirements. In addition, Land
Disposal Restrictions are considered to be applicable only for
waste codes D016 and D017. This remedy would comply with all such
requirements.
Multiple Sites
Multiple, non-contiguous CERCLA sites may be treated as one for
the purpose of a response action under CERCLA § 104(d)(4). The
preamble to the 1990 NCP discusses the issue of how to determine
whether to treat such sites as one for the purpose of a response
action under this section. 55 Fed. Reg. 8690-8691 (March 8,
1990). As stated in the preamble, "CERCLA section 104(d)(4)
allows EPA broad discretion to treat noncontiguous facilities as
one site for the purpose of taking a response action. The only
limitations prescribed by the statute are that the facilities be
reasonably related 'on the basis of geography1 or 'on the basis of
the threat, or potential threat to the public health or welfare or
the environment.' Once the decision is made to treat two or more
facilities as one site, wastes from several facilities could be
managed in a coordinated fashion ar one of the facilities and
still be an 'on-site1 action, within the permit waiver of CERCLA
section 121(e)(l)." Id. at 8690.
EPA has determined that consolidation and thermal treatment of
Rogers Road Landfill wastes at the Jacksonville Landfill site,
along with the Jacksonville wastes, satisfies the criteria of
CERCLA § 104(d)(4), and that these two sites should be considered
as one for the purpose of such consolidation and treatment of
wastes from both sites at Jacksonville. These two sites are
within several hundred feet of each other, and are therefore
reasonably close to each other such that they are reasonably
related on the basis of geography. Also, the wastes at
Jacksonville Landfill and Rogers Road Landfill are very similar in
nature. They both consist of soils contaminated with herbicides
and dioxins at approximately the same levels of contamination.
Further, soils from both sites with contamination above an
identical action level will be incinerated. Therefore, the sites
are compatible for the selected treatment and disposal approach,
and are reasonably related based on the threat to public health or
welfare or the environment. The public, the PRPs and the State
were provided an opportunity to comment on the preferred
alternative and the other alternatives, in line with the NCP and
the preamble section referenced above.
ALTERNATIVE 5 — EXCAVATION, THERMAL TREATMENT AT THE VERTAC
CHEMICAL CORP. SITE, SOIL COVER, LAND-USE CONTROLS, MONITORING
Description
This alternative is similar to Alternative 4, except that the soil
is treated at the Vertac Chemical Corp. site in Jacksonville,
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Arkansas. As was described for Alternative 4, the implementation
of this alternative would begin with sufficient monitoring to
define the areas within which equivalent 2,3,7,8 TCDD-dioxin
concentrations in surface soil and debris exceed 1 ppb, the cells
within which equivalent 2,3,7,8-TCDD and dieldrin concentrations
exceed 10 ppb and 37 ppb, respectively, and the cells in which the
hazard index from dieldrin and herbicides exceeds 0.7.
*
For the representative process option, an estimated 72 tons of
soil containing equivalent 2,3,7,8-TCDD concentrations above 10
ppb would be placed in 12 cubic yard capacity storage containers.
The storage containers would then be transported to the Vertac
Chemical Corp. site and stored in a manner complying with all
relevant and appropriate requirements for a hazardous waste
storage facility. Storage would continue until a suitable thermal
treatment system is brought to the site and treats all of the
contained contaminated material. Treatment unit sizing
requirements and detailed operational specifications would be
developed during the Remedial Design.
The treated soil, debris and waste would be analyzed to assure
that it meets the treatment goals specified in the "DEVELOPMENT OF
REMEDIATION GOALS" section of the ROD, mixed with manure and
seeds, and backfilled into suitable areas at the Vertac site.
As with Alternative 4, onsite soil containing between 1 and 10 ppb
equivalent 2,3,7,8-TCDD, greater than 37 ppb dieldrin, and/or
dieldrin and herbicide contamination associated with a hazard
index above 0.7 would be covered with 12 inches of uncontaminated
silty clay, and revegetated.
Also as with Alternative 4, the onsite trench would be backfilled,
and the soil cover and the existing fence would be inspected and
maintained. Ground water monitoring, five year evaluation and
land-use control would also take place as described for
Alternative 2.
As with the previous alternative, this alternative will reduce the
maximum risks of cancer from maximum plausible exposure to 8xlO"5
and will eliminate significant risks of threshold toxic effects
from herbicides (total hazard index < 1.0).
It should be noted that Alternative 5 does not appear in the
Feasibility Study Report. This alternative was developed as a
variation to Alternative 4 (Onsite thermal treatment) — the sole
modification being that the waste treatment and ash disposal would
occur at the Vertac site rather than at the Jacksonville Landfill.
All other elements of this alternative are identical to those
comprising Alternative 4. Alternative 5 was, however, outlined
and recommended in the Proposed Plan of Action, July 1990, for the
purposes of providing information specific to this alternative and
encouraging comments from interested parties on its components.
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Cost and Timing
Testing during the selected treatment alternative (e.g.
contaminant mapping, trial burn testing of the thermal treatment
unit and testing leachate from treated soil) is estimated to cost
approximately $176,000. The monitoring, excavation, screening,
packing and transport of 50 cubic yards of contaminated soil is
estimated to cost $135,000. The treatment of the Rogers Road
Landfill contaminated soil and debris at Vertac would cost
$54,000. The covering of low level dioxin contaminated soil and
long term cover inspection and maintenance would cost $52,000.
Additionally, the O&M costs would include $384,000 for monitoring,
annual review of the data, fence inspection and maintenance, as
with Alternative 2 (except that the existing fence would be
maintained, and no new fence installed). Periodic inspection of
the containers stored at Vertac will cost $3,000, assuming they
are stored for one year prior to treatment. The present worth of
implementing this alternative is estimated to be $1,226,000.
It is expected that this remedy would be fully implemented within
2 1/4 years of the signing of the ROD.
Compliance with ARARs
As described in Alternative 3, ARARs for this alternative apply to
excavation of contaminated soil, reclamation of the areas of
excavation, and monitoring activities. Requirements for these
activities include OSHA health and safety standards; RCRA facility
standards pertaining to operation and performance; preparedness
and prevention; contingency plan and emergency procedures, record
keeping; and standards for ground water protection.
As discussed under "COMMON ELEMENTS", although LDRs are not ARARs
for the dioxin-contaminated waste, they are applicable to waste
characteristic of EP toxicity under waste codes D016 and D017.
Treated waste will be required to meet the appropriate LDRs prior
to disposal.
Since the ash resulting from treatment would meet health-based
treatment goals, it will be placed directly into the ground
(rather than into a Subtitle C landfill) without any further
processing, except to modify the pH of the soil mixture to make it
more suitable for revegetation. Also, there would be no need to
"delist" the ash since the waste was not a listed waste prior to
treatment.
While this is not a RCRA facility, closure and post closure
requirements are considered to be relevant and appropriate. This
remedy would meet the requirements necessary to attain landfill-
closure status. Post-closure inspections to insure the integrity
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of the soil cover and ground water monitoring to detect any
significant offsite ground water impacts is expected to comply
with closure requirements.
Multiple Sites
The previous alternative included a discussion regarding the NCP's
provision for -considering noncontiguous sites as one for the
purposes of implementing CERCLA response actions. As was the case
in Alternative 4, EPA has determined that consolidation and
thermal treatment of wastes from Rogers Road at the Vertac
facility, along with the Jacksonville wastes, meet the criteria of
CERCLA § 104(d)(4) and that these three sites should be considered
as one for the purpose of such consolidation and treatment. The
sites are reasonably close to one another and the wastes at the
sites are compatible for the selected treatment and disposal
approach. In addition, EPA has received and responded to comments
from the public, the PRPs, and the State regarding this strategy.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The following section profiles the performance of the described
remedial alternatives against the nine criteria that EPA uses for
their evaluation. This evaluation provides support for EPA's
selection of a site remedy by showing that the selected remedy
would provide the best balance of trade-offs among the
alternatives with respect to the nine criteria. The evaluation
criteria are provided below.
DESCRIPTION OF THE NINE EVALUATION CRITERIA
* Overall Protection of Human Health and Environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment
engineering controls or institutional controls.
* Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) addresses whether or not a remedy will
meet all of the requirements of other Federal and State
environmental statutes and/or provide grounds for invoking a
waiver.
* Long-Term Effectiveness and Permanence refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
* Reduction of Toxicity. Mobility, or Volume Through Treatment
is the anticipated performance of the treatment technologies
that may be employed in a remedy.
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* Short-Term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential
to create adverse impact on human health and the environment
that may result during the construction and implementation
period.
* Implementajaility is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
* Cost includes capital and operation and maintenance costs.
* State Acceptance indicates whether, based on its review of
the RI/FS and Proposed Plan, the State concurs with, opposes,
or has no comment on the preferred alternative.
* Community Acceptance is assessed in the Record of Decision
following a review of the public comments received on the
RI/FS report and the Proposed Plan.
The nine criteria are categorized into three groups: Threshold,
primary balancing, and modifying. The threshold criteria must be
satisfied in order for an alternative to be eligible for
selection. The primary balancing criteria are used to weigh major
tradeoffs among alternatives. The modifying criteria are taken
into account after public comment is received on the Proposed Plan
of Action.
Threshold Criteria
o Overall Protection of Human Health and Environment
o Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Primary Balancing Criteria
o Long-Term Effectiveness and Permanence
o Reduction of Toxicity, Mobility, or Volume Through Treatment
o Short-Term Effectiveness
o Implementability
o Cost
Modifying Criteria
o State Acceptance
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o Community Acceptance
ANALYSIS
Overall Protection
The no-action - alternative (Alternative 1) will provide no
protection of human health and the environment since it does
nothing to reduce the potential of exposure to site contaminants.
Alternatives 3, 4 and 5 all provide approximately the same overall
protection to human health and to the environment (cancer risks of
8 x.lO"5). Additionally, they are the most protective since they
will prevent exposure by treating and destroying the most
contaminated surface soil and replacing it with clean fill,
covering surface soil containing between 1 and 10 ppb TCDD, and
maintaining the existing fence. Alternative 2 will prevent direct
exposure to contaminated soil by installing and maintaining a
capping and fence system. Alternatives 2, 3,4 and 5 reduce risks
posed by ponded surface water onsite by filling in site trenches
and grading to promote drainage.
Overall, Alternatives 3, 4 and 5 provide a higher level of long-
term protection than Alternative 2 because the most contaminated
material is treated in these alternatives. Alternative 3 involves
offsite treatment of contaminated soil and its replacement with
clean native backfill. Alternative 4 involves onsite treatment of
contaminated soil and backfilling the treated material onsite
after verifying that the backfill meets treatment criteria.
Alternative 5 involves onsite thermal treatment and disposal of
the treated material at the Vertac plant site.
Overall, implementation of Alternatives 3 and 4 may cause higher
material handling impacts in the immediate vicinity of the site
than Alternatives 5. This could be due to fugitive emissions from
packing the contaminated material in relatively low volume
containers such as drums and 3,000 Ib capacity bags versus packing
the material in large volume 12 cubic yard bulk storage
containers.
Alternatives 3, 4 and 5 would have higher potential offsite
impacts because of the transportation of the material offsite.
The offsite transportation risks between alternative 3, and
alternatives 4 and 5 vary greatly in that the risk of accidents
are much lower and are more easily controlled with alternatives 4
and 5 due to the very short hauling distance.
Land-use controls in Alternatives 2, 3, 4 and 5 are directed
toward preventing potential future risks from improper use of
ground water on and near the site. Obviously the risks associated
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with development of alternative 2 is greatest among the action
alternatives since wastes remain in place.
Compliance With ARARS
The no-action alternative (Alternative I) will not meet RCRA
closure requirements, while Alternatives 2, 3,4 and 5 would meet
their respective applicable or relevant and appropriate
requirements of Federal and State environmental laws.
Lona-Term Effectiveness
Alternative 1 will do nothing to eliminate the 2 x 10"3 maximum
individual risk of cancer from incidental soil ingestion of dioxin
and dieldrin-contaminated soil by trespassers. It will also not
eliminate significant risks of threshold toxic effects from
exposure to herbicides. The risk could become more severe if the
land were to be improperly developed.
Alternative 2 will reduce site risks by providing a protective
cap. This alternative does not eliminate the site risks but does
"control" them as long as the effectiveness of the cap is
maintained.
Alternatives 3, 4, and 5 would all reduce maximum risks of cancer
from maximum plausible exposure to the same level (8 x 10"5) and
eliminate significant risks of threshold toxic effects from
herbicides.
Alternative 2 would reduce the risk from incidental soil ingestion
by capping contaminated soil and making contaminated areas much
more difficult to access. Alternatives 3, 4 and 5 would use a
combination of soil cover and permanent treatment of the most
highly contaminated soil using thermal treatment. As a result,
Alternatives 3, 4 and 5 are considered to be more reliable and
permanent than Alternative 2.
Implementation of Alternative 2 will significantly reduce the
possibility for future development. Alternatives 3, 4 and 5 may
allow limited or controlled site development.
Reduction in Toxicitv. Mobility, or Volume Through Treatment
Alternatives 1 and 2 provide no reduction in the current
contaminant toxicity, mobility or volume through treatment. Risks
to human health would remain unacceptable.
Alternatives 3, 4 and 5 reduce the volume and toxicity of an
estimated 50 cubic yards of the most heavily contaminated soil
onsite by thermal treatment methods. An additional estimated 170
cubic yards of low level dioxin contaminated soil is secured under
a soil cover, preventing exposure.
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Short-Term Effectiveness
Since the no-action alternative involves only annual monitoring,
onsite activities will cause very little impact. Emissions from
implementation of this alternative, the risk to workers, and the
time to implement this alternative are all less than for any other
alternatives. -Exposure to waste remaining onsite, however, could
still result to site workers in acute, short-term adverse health
effects. Short-term risks to site workers from Alternative 2 are
higher than those associated with the no-action alternative
because of the direct contact risk associated with consolidation
of contaminated soil and risks during installation, inspection,
and maintenance of the fence and soil cover.
Potential short-term risks to site workers during implementation
of Alternatives 3, 4 and 5 are higher than for Alternative 2 due
to the increased handling of contaminated material during packing
of drums and transportation. Alternatives 4 and 5 also have
inherent short term risks associated with offsite transportation
of the wastes, but are significantly less than those posed by
Alternative 3. The risks associated with the highway
transportation of 50 cubic yards of Rogers Road Landfill waste
materials can be assessed by evaluating the statistical
probability of a highway accident and the risk associated with the
waste spill. Utilizing the Handbook of Chemical Hazard Analysis
Procedures published by the Federal Emergency Management Agency,
U.S. Department of Transportation and the U.S. EPA results in the
following risk numbers:
Accident Frequency Spill Frequency
Alternative (accidents/year) (spills/year)
3 0.029 0.006
4 0.0001 0.00002
5 0.0003 0.0001
An Accident Frequency of 0.029 can be interpreted to mean that the
statistical chance of an accident occurring while waste is being
transported is 29 out of 1000 or roughly one in 34. A Spill
Frequency of 0.006 means that the chance of an accident resulting
in the actual spilling of waste material is six in one thousand.
The specific risks can be significantly reduced by a detailed
transportation / spill prevention plan. Such a plan will be an
integral part of any approved design dealing with highway
transportation of wastes.
The potential risks to the communities near the treatment sites
during implementation are highest for Alternatives 3, 4 and 5 due
to the treatment of contaminated material at their respective
locations. The risks to onsite workers are similar for the same
Alternatives. However, the likelihood of adverse impacts to the
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communities from all these activities is considered to be very
low. Air pollution emissions can be detected very quickly with
standard industrial hygiene monitoring equipment, visible emission
monitoring for fugitive emissions, and stack monitoring
instruments normally associated with hazardous waste thermal
treatment units. Standard construction contingency plans can
address fugitive dust emissions while adherence to federal air
discharge standards will eliminate the possibility of adverse
discharges from the treatment unit. Based on past experience with
similar applications, maximum individual risks of cancer from
emissions associated with these Alternatives are expected to be
substantially less than 10" .
For all treatment technologies, site workers are not expected to
be adversely impacted. This is because of personal protective
equipment, implementation of proper personnel protection
procedures in accordance with OSHA regulation, the design of the
process equipment and procedures, and proper operating procedures.
Only 6 months would be required to start the no-action
alternative, since nothing would be done except to perform limited
annual monitoring. For Alternative 2, contaminated soil could be
mapped, contaminated soil could be consolidated, and caps and
fencing could be improved and installed, and land-use controls
could be implemented within 15 months, provided the major field
activities can be scheduled for the summer months, when the site
is most likely to be dry. Alternative 3 could be fully
implemented within approximately 2 years (assuming an offsite
treatment facility is given appropriate permits with 12 months of
the ROD) . Alternative 4 could take up to 2 1/4 years to
implement. Alternative 5 will likely take from 2 to 2 1/4 years
to complete.
Imp1ementab i1ity
All components of Alternatives 1, 2, 4 and 5 use commercially
available equipment and services. Alternative 3, also uses
thermal treatment, a proven and reliable technology for treating
dioxins, although, to date no offsite commercial treatment
facility has been issued appropriate permits to treat dioxin.
However, there is expected to be at least one facility available
within a year.
Alternative 1 is technically the easiest to implement, but may be
administratively infeasible because of the high risks to public
health associated with the contaminated material, EPA's legal
mandate and institutional commitments to remediate such risks, and
the concerns of the public, state and local officials.
Alternative 2 is easier technically to implement than Alternatives
3, 4 and 5 because it involves no treatment technology, however it
may not be administratively easier to implement compared to
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alternatives involving treatment, because of the congressionally
mandated preference for alternatives involving treatment.
Thermal treatment is known to be technically implementable, and is
in fact the Best Demonstrated Available Technology for RCRA-listed
dioxin wastes. A variety of mobile treatment units are available
with a proven history of effective treatment of dioxin-
contaminated soj.1. However, at this time no stationary units are
available with appropriate permits to burn dioxin contaminated
soil. As a result, Alternatives 4 (treatment at the Jacksonville
site) and 5 (treatment at Vertac) are administratively easier to
implement than Alternative 3 (offsite treatment); however the
situation could change if permits for offsite thermal treatment
units to burn dioxin-contaminated soil are issued.
Some design considerations would be required to select the most
cost effective method of performing Alternatives 3, 4 and 5.
However, several proven and reliable soil cover, excavation, and
soil processing technologies are available. Thermal treatment of
dioxin-contaminated soil is known to be effective.
Cost
Alternative 1, No-Action, is the least expensive to implement with
a total present worth of $302,000. The total present worth of
Alternative 2 is $930,000. The total present worth of Alternative
3 is expected to be $1,404,000, assuming a cost of $3,000 per
cubic yard for offsite treatment and landfilling services and that
50 cubic yards of dioxin-contaminated material must be packed in
35 gallon fiber drums to be accepted at the treatment facility.
It should be noted that the price of $3,000 per cubic yard could
easily vary by the time this remedy is implemented due to the
uncertainties associated with price fluctuations in this (as yet
unestablished) market. The total present worth for Alternatives
4 and 5 are $1,201,000 and $1,226,000, respectively.
The costs outlined above include Capital and Operation &
Maintenance expenses, and are presented in more detail in the
DESCRIPTION OF ALTERNATIVES section of this ROD.
State Acceptance
The Arkansas Department of Pollution Control and Ecology (ADPC&E)
has been consulted and is in agreement with the EPA regarding the
selected remedy outlined in this Record of Decision.
Community Acceptance
Judging from the comments received during the public meeting
conducted in Jacksonville and the subsequent public comment
period, the local citizens are split with regard to their
preference for thermal treatment as the principal treatment
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element. A summary of the public comments received and EPA's
responses are presented in the "RESPONSIVENESS SUMMARY" section of
the ROD.
SELECTED REMEDY
The selected remedy is Alternative 5 — Excavation, Thermal
Treatment at the Vertac Chemical Corp. Site, Soil Cover, Land-Use
Controls, and Monitoring. The major components of the selected
remedy include:
o Sampling soil in ten-foot by ten-foot grids to more
accurately define the amount of contaminated surface soil,
debris, and waste onsite;
o Excavating and packaging for transport contaminated soil and
debris containing more than 10 ppb equivalent 2,3,7,8-TCDD;
o Transporting contaminated material to the Vertac Chemical
Corp. Superfund site in Jacksonville, Arkansas and providing
temporary storage for the material at the Vertac site;
o Conducting thermal treatment of all Rogers Road Landfill
material being temporarily stored at the Vertac site, and
testing, disposal and revegetation of the resulting ash;
o Steam cleaning and onsite disposal of large items of refuse
removed from contaminated areas;
o Backfilling and revegetating areas from which contaminated
soil was removed with uncontaminated native soil and
decontaminated refuse;
o Covering soil, debris and waste meeting the criteria stated
below with twelve inches of native soil;
CRITERIA: 1) Equivalent 2,3,7,8-TCDD concentrations greater
than 1.0 ppb and less than or equal to 10.0 ppb,
and/or
2) Dieldrin concentrations greater than 37 ppb,
and/or
3) Cumulative Hazard Index greater than 0.7 for
the following compounds:
2,4,5-Trichlorophenoxy acetic acid (2,4,5-T),
2,4,5-Trichlorophenoxy propionic acid (2,4,5-TP),
and
Dieldrin.
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o Backfilling the site trench;
o Ground water monitoring;
o Inspection and maintenance of the soil cover and of the
existing fence; and
o Land-use -controls limiting ground water use on and
immediately downgradient of the site.
DETAILED DESCRIPTION OF REMEDY
The Rogers Road and Jacksonville wastes are very similar in
physical and chemical makeup to that waste produced by Vertac
Chemical Corp., of Jacksonville, Arkansas. In addition, EPA holds
evidence that indicates that the waste did indeed come from that
facility. After careful consideration, it has been determined
that in all likelihood the dioxin and herbicides located at these
two landfills originated at Vertac. For this reason it is
proposed that these wastes be excavated and transported back to
the Vertac facility for ultimate disposal.
Implementation of this alternative would begin with detailed soil
monitoring. The objective of the monitoring program would be to
define the 10 foot by 10 foot cells within which equivalent
2,3,7,8 TCDD-dioxin concentrations in surface soil and debris
exceed 1 ppb, the cells within which the equivalent 2,3,7,8-TCDD
and dieldrin concentrations exceed 10 ppb and 37 ppb,
respectively, and the cells in which the hazard index from
dieldrin and herbicides exceed 0.7. Detailed methodology of the
soil monitoring program is described in Section 4.5.2 of the
Rogers Road Landfill Feasibility Study.
After mobilization activities and detailed, cell by cell mapping
of contaminated soil are completed, excavation will begin. Ten
foot by ten foot cells of soil and debris with dioxin
concentrations exceeding 10 ppb within one foot of the surface
will be excavated one at a time. After all aforementioned surface
soil is excavated, the soil in the underlying cells will be
sampled again, and any soil in the next foot exceeding the 10 ppb
equivalent 2,3,7,8-TCDD will be excavated down to an additional 12
inches. The process will continue to a maximum depth of 4 feet if
necessary. A water spray will be used for dust control during
excavation. It is estimated that approximately 50 cubic yards of
soil will be addressed in this fashion. The general location of
the contaminated soil to be mapped is provided previously on
Figure 4.
The contaminated soil will be excavated and dumped directly into
twelve cubic yard dump trailers next to the excavation. The dump
trailers would then be labeled to indicate which cells of waste
were placed into the dump trailer (each trailer would be used for
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up to three cells), then covered and moved to a coarse grating
facility. The contents of the trailer would be dumped through the
coarse grating which would remove items larger than 4" in
diameter. The screened material would drop directly into a
separate twelve cubic yard dump trailer parked under the coarse
grating.
Rocks and other large objects rejected by the grating would roll
off the screen and be collected,. They would then be
decontaminated for use as rip rap onsite, after inspection and
dioxin, chlorophenol and herbicide screening to assure that
adequate decontamination has occurred.
The dump trailers containing the material passing through the
coarse screen would be decontaminated and transported
approximately 10 miles to the Vertac Chemical Corp. site in
Jacksonville, Arkansas. Upon arrival at the Vertac site, the
containers would be stored in a manner complying with all relevant
and appropriate requirements for a hazardous waste storage
facility. Storage would continue until a suitable thermal
treatment system is brought to the site and treats all of the
contained material.
The treated soil, debris and waste would be analyzed to assure
that it meets the treatment goals outlined in the "DEVELOPMENT OF
REMEDIATION GOALS" section of the ROD. Daily aggregate samples
would be taken of the ash and analyzed for 2,3,7,8-TCDD,
chlorophenols, and herbicides (to verify the effectiveness of the
treatment process) and TCLP leachability (to verify that it does
not have characteristics of hazardous waste). Any ash which does
not meet treatment objectives would be retreated (if the problem
is from organics) or solidified (if the problem is from the
leaching of inorganics). Ash meeting treatment criteria would be
mixed with manure and seeds, and backfilled into suitable areas on
the Vertac site property.
The areas from which dioxin contaminated soil was excavated would
be backfilled with at least 12" of clean silty clay. The backfill
would be compacted and would extend to at least the level of the
surrounding surface (6" above the surface where only one foot of
soil was removed). The backfill would be integrated with the
surrounding native soil and soil cover (over soil containing
between 1 and 10 ppb equivalent 2,3,7,8-TCDD) and graded to
promote drainage. In addition, these areas would be revegetated
and rip-rap would be incorporated where necessary.
Soil containing between 1 and 10 ppb equivalent 2,3,7,8-TCDD,
greater than 37 ppb dieldrin, and/or dieldrin and herbicide
contamination associated with a hazard index above 0.7 would be
graded (if necessary), covered with 12 inches of uncontaminated
silty clay, and revegetated.
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The open site trench which is an attractive nuisance and
contributes to ground water recharge would be backfilled, and the
site would be re-vegetated to minimize erosion. In addition, the
non-contaminated areas disturbed during the implementation of this
alternative would be graded and revegetated. Rip-rap would be
used, where necessary and appropriate.
Continued monitoring of ground water would be needed. For a
representative ground water monitoring program, the wells to be
monitored and the rationale for monitoring them are shown below:
• MW-XX1 A new shallow well downgradient of Rogers Road
Site.
• MW-XX2 A new shallow well downgradient of Rogers Road
Site.
MW-XX3 A new shallow well downgradient of Rogers Road
Site.
• MWR-05 An existing shallow well on the southeast
corner of the Site.
MWR-01 An existing shallow well upgradient of the
Rogers Road Site.
MW-XX1, MW-XX2 and MW-XX3 are about 500 feet downgradient of the
drum disposal area at angles about 22.5 degrees apart centered
around the most probable direction of ground water flow. They are
shallow wells because contamination from the Rogers Road Site
(within 500 feet of the site) is most likely to be detected in the
upper portions of the aquifer rather than within the lower
portions of the aquifer.
Ground water in the upper portions of the aquifer could ultimately
be directed into the lower aquifer as a result of the clay and
silt layers dipping down towards the lower portion of the aquifer
between the Rogers Road and the Jacksonville Site, as shown in the
geologic cross-sections found in the Remedial Investigation
Report. The nearest users of the aquifer are east of the
Jacksonville Site, and monitoring at wells XXI, XX2 and XX3 should
constitute an early warning system if significant levels of
contamination from the Rogers Road Site should ultimately occur.
Well MWR-01 represents upgradient water quality, and Well MWR-05
would be sensitive to any ground water contamination from the
southern portion of the site. The wells would be sampled
annually. The ground water samples would be analyzed for TCL
organics and inorganics, along with herbicides and pesticides.
The monitoring would occur for at least thirty years. The results
of this monitoring would be summarized every five years. The
Page 1-81
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summaries would be used to help EPA decide whether or not to
increase, decrease, or maintain the scope of the monitoring plan.
The boundary of ground water compliance will be delineated by the
deep downgradient wells identified for sampling above. If
comparison of sampling results to MCLs or health-based levels
indicates that significant degradation of ground water quality was
occurring or imminent downgradient of the site at any time, the
data would be evaluated and confirmatory sampling performed, along
with an updated survey of ground water use. If imminent
degradation of the Class IIB aquifer is confirmed and use of the
water is occurring or likely to occur, ground water users would be
notified and the need for, and feasibility of, remedial action
would be re-evaluated during the next year. Options to be
considered would include alternate water supplies, extraction and
treatment methods, or other viable ground water restoration
technologies. The necessity of a separate Record of Decision,
Explanation of Significant Differences or other type of ROD
amendment would be evaluated at the time that the situation
arises.
Inspections of the fence, gate and lock, along with the soil cover
would occur on an annual basis, and repair would take place as
necessary and appropriate to assure their integrity.
Land-use restrictions would also be placed on the site and
surrounding ground water use to prevent activities that could
endanger public health. Representative land-use restrictions
would limit ground water use onsite and deter use of the shallow
ground water immediately downgradient of the site.
Imposing such restrictions would be negotiated with the City of
Jacksonville concerning the landfill and with owners of
surrounding property concerning ground water use.
The activities described above outline the conceptual framework of
the preferred alternative. Engineering design considerations will
be taken into account during the detailed design which will
optimize the efficiency of the remedial action. It is possible
that minor changes could be made to the remedy outlined above
which would reflect modifications resulting from the remedial
design and construction processes.
REMEDIATION GOALS
The remediation goals for this alternative were derived from
recommendations by the Centers for Disease Control (with respect
to carcinogenic health threats) and from calculations produced in
the Rogers Road Landfill Risk Assessment (regarding
noncarcinogenic health effects). This discussion presents a
summary of the remediation goals that were established in the
"DEVELOPMENT OF REMEDIATION GOALS" section of the ROD.
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Pre-remedial action levels will be used as criteria to determine
whether soil remediation is required. The action levels are given
as follows:
ACTION LEVEL RESULTING
COMPOUND fppb) ACTION
2,3,7,8-TCDD . 1.0 < Cone. < 10.0 Soil Cover
equivalents Cone. > 10.0 Thermal Treatment
Dieldrin Cone. > 37.0 Soil Cover
2,4,5-T
2,4,5-TP Cumulative HI > 0.7 Soil Cover
Dieldrin
Post-remedial treatment goals will be used as standards to assure
that effective treatment of remediated soil and debris has been
achieved and to determine whether additional treatment is
required. Where more than one goal is provided for a single
compound, the most restrictive applies. These goals are presented
below:
COMPOUND TREATMENT GOAL
2,3,7,8-TCDD 1.0 ppb, OR
equivalents Thermal treatment unit operating
requirements, as provided in 40 CFR
Part 264.343.
2,4-D 10,000 ppb
2,4,5-TP 7,900 ppb
Dieldrin 37 ppb
AND
2,4,5-T
2,4,5-TP Cumulative HI < 0.7
Dieldrin
Treatment to these levels will result in a residual site risk of
less than 8 x 10"5 and a maximum cumulative Hazard Index of 1:0.
COST
Several of the costs included in this estimate were prorated among
the Rogers Road and Jacksonville sites since they would both share
much of the same equipment and facilities. The estimate for the
Rogers Road site includes only its share of the costs.
Mobilization and general site preparation activities are estimated
to cost approximately $62,000. Contaminant mapping will cost
$99,000.
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Excavation, packing, transport, storage, and treatment of the
contaminated soil and debris is expected to cost $205,000. This
cost includes the trial burn testing of the thermal treatment unit
and bench scale tests of the chemical and physical properties of
treated soil, which is estimated to cost approximately $70,000.
Testing the ash to assure that it meets treatment criteria is
estimated to cost an additional $30,000. The covering of low
level dioxin -contaminated soil would cost $52,000. Site
restoration and backfilling the trenches is estimated to cost
$56,000. Additionally, the O&M costs would include $384,000 for
monitoring, annual review of the data, soil cover and fence
inspections, and maintenance.
The present worth is estimated to be $1,226,000. A complete cost
summary is shown in Table 6. Additional details on costs are
provided in Appendix D of the Rogers Road Landfill Feasibility
Study.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
protection of human health and the environment. In addition,
section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through thermal treatment of dioxin and herbicide-contaminated
soil which presents the principal threat, and covering the lesser-
contaminated soils which present low level threats. The areas to
be covered will be closed in accordance with RCRA landfill closure
requirements to reduce the likelihood of contaminant migration.
Thermal treatment will eliminate the threat of exposure to the
most toxic contaminants from direct contact with or ingestion of
contaminated soil. The current risks associated with these
exposure pathways is 2 x 10"3 for carcinogenic risk and 163 total
hazard index for noncarcinogenic risk. By excavating the hotspots
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TABLE 6
COST ESTIMATE
ALTERNATIVE 5: EXCAVATION, TREATMENT AND BACKFILLING AT VERTAC,
SOIL CAP, FENCE, LAND USE CONTROLS AND MONITORING
Rogers Road Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
I.
Capital Cost
A. Direct Cost
1. General Actions/
Site Preparation
• Clearing and
Grubbing 1100 S.Y.
• Temporary Ditches,
Dikes and Berms for
Sediment Control and
Runoff Diversion
• Sediment Control Basin
• Decontaminate
Facility
• Access Roads, etc.
• Administrative and
Health & Safety
Trailers
L.S.
L.S.
L.S.
L.S.
2 months
SUBTOTAL:
2. Contamination Mapping
• Analytical
- Background Finger
Printing 4 Samples
-Onsite Laboratory
Mobilization L.S.
- Onsite Laboratory
for Sample
Analysis 2 Weeks
$1/S.Y.
$4,000/mo
1100
2,000
5,000
5,000
5,000
8.000
26,100
$2,000/each 8,000
5,000
$25,000/wk 50.000
63,000
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TABLE 6 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Rogers Road Landfill Site
Jacksonville, Arkansas
«
Activity
• Professional
• Equipment
• Other Direct Charges
3 . Contaminated Soil
Treatment
Estimated
Quantity
L.S.
L.S.
L.S.
Unit Cost($)
Price (1990)
28,400
2,180
4.260
SUBTOTAL: 97,840
Mob/Demob for
Excavation and
Site Operations
Soil Excavation
and Handling
12 C.Y. Storage
Container Cost
L.S.
50 C.Y.
5 Containers
20,000
$ 12/C.Y. 600
$2,000/each 10,000
Packing, Loading,
Transporting and
Unloading Containers
at Vertac. (Average
10 C.Y./Container) 5 Each
Mobilization, De-
mobilization, and
Set-up for Treatment
Including Temporary
Storage (Prorated)
$750/each
Trial Burn Test
(Prorated)
Water Spraying and
other Miscellaneous
Costs
L.S.
L.S,
L.S,
3,750
41,700
41,700
10,000
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TABLE 6 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Rogers Road Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
Support Facilities and
Dust Control, etc. 15 Days
• Soil Treatment
• Confirmational Testing
of Ash - One
Aggregate Sample
Per Day
• Construction of
Storage Facility to
Store 5 Containers
for One Year
72 Tons
15 Samples
750 S.F.
4. Environmental Studies
• Environmental Impact
Studies (Prorated) L.S.
5. Soil Cover
• Covering Areas Containing
1 to 10 ng/g of
Equivalent
2,3,7,8 - TCDD 8,650 S.F.
6. Site Restoration and Backfilling
• Steam Cleaning and Disposal
of Large Items of
Refuse Removed from
Contaminated Areas L.S.
$ 750/Day 11,250
$ 750/Ton 54,000
$ 2,400/Each 36,000
$ 50/S.F. 37.500
SUBTOTAL: 266,500
SUBTOTAL:
41.700
41,700
$6/SF 5i:900
SUBTOTAL: 51,900
15,000
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TABLE 6 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Rogers Road Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
• Mixing Incinerated Soil
with Manure or Sewage
Sludge and
Backfilling 50 C.Y.
• Revegetation
• Backfilling the
Trenches
7. Land Use Controls
• Deed Restriction
8. Monitoring Well Inst.
• Well Drilling
(3 Wells)
• Well Casing Inst.
(Stainless Steel)
• Mob/Demob and
Decontamination
B. Indirect Cost
• Health & Safety
e 10% of Direct Cost
Bid and Scope Contin
gency § 15% of
Direct Cost
1,110 S.Y.
2,000 C.Y,
$200/C.Y.
$1/S.Y.
$15/C.Y.
SUBTOTAL:
L.S.
SUBTOTAL:
120 L.F. $30/L.F.
60 L.F. $50/L.F.
L.S.
SUBTOTAL:
TOTAL DIRECT COST:
10,000
1,110
30.000
56,110
50.000
50,000
3,600
3,000
5.000
11,600
601,750
60,180
90,260
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TABLE 6 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Rogers Road Landfill Site
Jacksonville, Arkansas
Activity
Estimated
Quantity
Unit
Price
Cost($)
(1990)
Administrative & Legal
§ 5% of Direct Cost
• Engineering & Services
§ 10% of Direct Cost
TOTAL INDIRECT COST:
TOTAL CAPITAL COST (DIRECT + INDIRECT):
30,190
60.180
240,710
842,460
II.
O & M Cost
• Annual Data Review 8 Hrs
5-Year Evaluation 160 Hrs
Maintenance of Existing
Fence L.S.
Annual Inspection and
Maintenance of Soil Cover L.S.
A. Periodic Inspection of
Containers Stored Onsite
for One Year L.S.
B. Present Worth of Long-
Term Groundwater Monitoring
(Annual and 5-Year) (See
Rogers Road FS Report,
Table 6-1 for Details).
C. Present Worth of Annual
Data Review
($480 X 15.3725)
D. Present Worth of 5-Year
Evaluation ($9,600 X 2.782)
$60/Hr
$60/Hr
480
9,600
2,000
3,000
3,000
259,800
7,380
26,700
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TABLE 6 (Cont'd)
COST ESTIMATE
ALTERNATIVE 5
Rogers Road Landfill Site
Jacksonville, Arkansas
Estimated Unit Cost(S)
Activity * Quantity Price (1990)
E. Present Worth of Existing
Fence Maintenance Based
on 5% Discount Rate for
30 Years ($2,000 X 15.3725) 30,750
F. Present Worth of Inspection
and Maintenance of Soil Cover
Based on 5% Discount Rate
for 30 Years ($3,000 X
15.3725) 46.,120
G. Land Use Control Contingencies
for 30 Years 10.000
TOTAL O & M COST
(NET PRESENT WORTH): 383,750
III. TOTAL COST OF ALTERNATIVE 5
(CAPITAL + O & M) ===========
(NET PRESENT WORTH): $ 1,226,210
1-90
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of contaminated soil and treating them in a thermal treatment
unit, the cancer risks from exposure will be reduced to 8 x 10"5
for carcinogenic risk and less than 1.0 total hazard index for
noncarcinogenic risk. This level is within the range of
acceptable exposure levels of between 10** and 10"6 for carcinogenic
risk and less than 1.0 total hazard index for noncarcinogenic
risk. There are no short-term threats associated with the
selected remedy, that cannot be readily controlled.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
The selected remedy of excavation, thermal treatment, and soil
cover will comply with all applicable or relevant and appropriate
chemical-, action-, and location-specific requirements (ARARs).
Key ARARs are presented below.
Action-specific ARARs:
RCRA Land Disposal Restrictions (LDRs) are presented in 40
CFR Part 268. LDRs establish a timetable and treatment
criteria for the restriction of disposal of wastes and other
hazardous materials.
Transportation of hazardous wastes is regulated under 40 CFR
Part 263 and 49 CFR Parts 107 and 171-177.
40 CFR 264 Subpart 0 provides operational standards and
monitoring requirements for hazardous waste incinerators.
Key components of this regulation include the requirement for
a destruction and removal efficiency of 99.9999% and
limitations on HC1 and particulate emissions.
40 CFR 256.23 provides guidance for the closure of open
dumps. These regulations specify closure in a fashion that
minimizes potential health hazards and incorporates long-
term monitoring where necessary.
40 CFR 264.117(a)(1) Subpart G post-Closure and Monitoring
requirements for thirty years or another period determined by
the Regional Administrator.
Chemical~specific ARARs;
There are no chemical-specific ARARs for contaminated soil
and debris.
Location-specific ARARs;
Executive Order on Floodplain Management, Executive Order No.
11988, requires Federal agencies to evaluate the potential
effects of actions they may take in a floodplain to avoid
Page 1-91
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adverse impacts associated with direct and indirect
development of a floodplain.
Other Criteria. Advisories or Guidance to be Considered for this
Remedial Action (TBCs);
CDC's 2,3,7,8-TCDD recommendations for residential settings
have been adopted for this remedial action. These
recommendations provide that the following action levels will
not result in excess threats to public health:
1.0 ppb TCDD on surface soil;
10 ppb TCDD, when covered by at least 12
inches of clean fill.
CERCLA section 104(d)(4) allows EPA to treat noncontiguous
facilities as one where those facilities are reasonably
related on the basis of geography, or on the basis of threat
to public health or welfare or the environment.
40 CFR Part 258 - Criteria for Municipal Solid Waste
Landfills, is currently set forth in "Proposed Rule" status.
These proposed regulations provide operating and design
criteria for owners and operators of municipal solid waste
landfills. Also included are closure and post-closure
requirements that are more stringent than current Subtitle D
regulations.
40 CFR Parts 260, 261, 264 and 270 - Standards for Owners and
Operators of Hazardous Waste Incinerators... (Proposed Rule):
These regulations amend the current hazardous waste
incinerator regulations to improve control of toxic metal
emissions, HCl emissions and residual organic emissions.
State ARARs;
No State regulations have been identified as being more
stringent than the Federal requirements.
COST-EFFECTIVENESS
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs, the net present worth value being $1,226,000. The estimated
costs of the selected remedy are only slightly higher (only 1.30
times) than the costs associated with onsite capping of the
contaminated soils, and yet the selected remedy assures a much
higher degree of certainty that the remedy will be effective in
the long-term due to the significant reduction of the toxicity and
volume of the wastes achieved through thermal destruction of the
principal contaminants onsite.
Page 1-92
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UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE MAXIMUM
EXTENT PRACTICABLE
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner for the final source control operable unit
at the Rogers Road Municipal Landfill site. Of those alternatives
that are protective of human health and the environment and comply
with ARARs, EPA and the State have determined that this selected
remedy provides the best balance of tradeoffs in terms of long-
term effectiveness and permanence, reduction in toxicity, mobility,
or volume achieved through treatment, short-term effectiveness,
implementability, and cost, also considering the statutory
preference for treatment as a principal element and considering
State and community acceptance.
Thermal treatment offers a high degree of long-term effectiveness
and permanence and will significantly reduce the principal threat
and inherent hazards posed by the contaminated soils. Low level
threats can be effectively addressed through covering such that
the residual material that remains onsite can be contained with a
high degree of certainty over the long term.
The selection of treatment of the contaminated soil is consistent
with program expectations that indicate that highly toxic and
mobile waste are a priority for treatment and often necessary to
ensure the long-term effectiveness of a remedy. Since the three
treatment options evaluated are reasonably comparable with respect
to compliance with ARARs, long-term effectiveness and the reduction
of toxicity, mobility and volume, the major tradeoffs that provide
the basis for this selection decision are implementability and
community acceptance. The selected remedy can be implemented more
easily and in a comparable timeframe as the second and third-
choice remedies, and the community has expressed a preference for
returning the contaminants back to the location of their
originating source.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating the dioxin and herbicide-contaminated soils in a
thermal treatment unit, the selected remedy addresses the principal
threats posed by the site through the use of treatment
technologies. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Proposed Plan for the Rogers Road Municipal Landfill site was
released for public comment in July 1990. The Proposed Plan
identified Alternative 5, thermal treatment and disposal of ash at
the Vertac site, as the preferred alternative. EPA reviewed all
Page 1-93
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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.
Page 1-94
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SECTION 2.0
RESPONSIVENESS SUMMARY
-------
JACKSONVILLE AMD ROGERS ROAD
MUNICIPAL LANDFILLS, ARKANSAS
RESPONSIVENESS SUMMARY
OVERVIEW
At the tine of the public comment period, EPA had issued a
Proposed Plan setting forth the preferred alternatives for the
Jacksonville and Rogers Road Landfill sites near Jacksonville,
Arkansas. These alternatives were presented to the public for
their review and comment. EPA's recommended alternatives
addressed the soil contamination problems at the sites and
involved thermal treatment and capping of dioxin and herbicide
contaminated soils, site grading and restoration, and long-term
site and ground water monitoring.
Judging from the comments received during the public meeting
conducted in Jacksonville and the subsequent public comment
period, the local citizens are split with regard to their
preference for thermal treatment as the principal treatment
element. The Arkansas Department of Pollution Control and Ecology
(ADPC&E) is in favor of thermally treating soils containing dioxin
above 10 parts per billion (ppb), but is not in agreement with the
need to cap residual soils containing dioxin concentrations
between 1.0 and 10 ppb. Hercules, Inc., the only potentially
responsible party (PRP) responding during the comment period,
proposes deleting the thermal treatment and capping components
from the site remedy altogether.
The responsiveness summary that follows is required by CERCLA. It
provides a summary of the significant comments and concerns
received during the public comment period, and EPA's responses to
those comments and concerns. All comments received by EPA during
the public comment period are considered in EPA's final decision
for selecting the remedial alternative for addressing
contamination at the Jacksonville and Rogers Road Landfill sites.
These sections follow:
Background on Community Involvement.
• Summary of Comments Received during the Public Comment Period
and Agency Responses.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Jacksonville and Rogers Road Landfills
dates to 1973, when a citizen's complaint was submitted to EPA
regarding the possible disposal of hazardous wastes at the sites.
Page 2-1
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Since then, community concern and involvement has remained
relatively strong. Several individuals have been particularly
vocal in expressing their concerns to the Jacksonville City
Council, ADPC&E, and EPA. In addition, a considerable amount of
media attention has been focused on the sites. A significant
factor contributing to the amount of public involvement observed
at the landfill sites is their close proximity to the City of
Jacksonville and to the Vertac Chemical Corporation Superfund
site. The Vertac site has been an ongoing source of controversy
on the national scale for over ten years. Because of the
attention and scrutiny that has been directed toward the city of
Jacksonville, public sensitivity to environmental issues is quite
high.
SUMMARY OP COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
TECHNICAL QUESTIONS/CONCERNS REGARDING SELECTED ALTERNATIVE
1) Several local citizens and business persons offered their
support for the remedial alternative set forth in the
Proposed Plan of Action, July 1990.
EPA Response: No response required.
2) Several citizens expressed transportation-oriented concerns
regarding the shipment of contaminated soils from the
landfills to the Vertac site.
EPA Response: EPA seriously reviewed the merit of
transporting the landfill wastes to the Vertac site,
especially considering that transportation of the Vertac
wastes to an offsite location was previously, and remains to
be, regarded as unfavorable (although other factors in
addition to transportation concerns were accounted for in the
Vertac determination). Transport of the landfill soils to
the Vertac facility is considered to be far safer than
transporting the Vertac waste offsite, primarily due to the
difference between the quantity and type of waste to be
shipped. The landfills are estimated to contain only a total
of approximately 200 cubic yards (cy) of soil contaminated
with relatively low levels of hazardous substances while the
wastes at Vertac consist of approximately 29,000 barrels of
drummed, highly concentrated liquid waste. At 10 cy per
truckload, 200 cy of landfill soil can be transported in 20
trips.
Detailed transportation specifications will be developed
during the remedial design, however a few general concepts
can be outlined here. Haul routes between the landfill sites
and the Vertac facility will be established only after
careful consideration is made with respect to minimizing the
number of affected parties, and after the development of
Page 2-2
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appropriate safety procedures and emergency plans.
Decontamination facilities will be constructed in order to
properly rinse contaminants from the trucks and material
containers prior to their leaving the landfill sites.
3) Two commenters requested that the Remedial Design include
provisions -for improving site drainage.
EPA Response; Based upon this comment, as well as through
interviews with adjacent residents and visual observations,
EPA recognizes that the site drainage patterns are
undesirable in their present state. Although not
specifically set forth in the Record of Decision (ROD) , the
remedial action will examine the need for site improvements
such as drainage enhancement. One likely possibility is that
the ditch which parallels the eastern fenceline of the
Jacksonville site will be regraded to improve the efficiency
of runoff from the site.
4) One citizen quoted a report that an earthquake of sizable
proportion was predicted to occur in the early part of this
decade - December 3, 1990, to be precise. The concern was
raised regarding the capability of the thermal treatment unit
to withstand seismic forces.
EPA Response; The thermal technology which is specified in
the ROD will likely be carried out by a mobile treatment
unit. Rather than design a treatment unit to withstand the
extremely high stresses imposed by seismic events, EPA can
require design and performance modifications of the unit
which will minimize the volume of material which could
potentially be exposed in the event of earthquakes or other
natural disasters.
Since there is such a small volume of waste requiring
treatment, the treatment unit used will likely be of small
scale. The low capacity of these smaller units means that
less than five cubic yards of material is would be undergbing
the treatment process at any given time during operation.
This, coupled with the automatic shutoff features which will
be specified in the operating requirements, will result in a
very low exposure potential even to those working in the
immediate treatment area.
Another point worth mentioning is that because there is such
a small amount of soil being treated, the total duration of
treatment will be very short - likely 40 to 50 days for 200
cy of soil. This results in an extremely low probability of
a predicted seismic event occurring within any given
time frame of such short duration.
Page 2-3
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5) One comment was raised regarding the need for appropriate
qualifications of the construction personnel who would be
conducting the remedial action.
EPA Response; Remedial Actions (RAs) which are paid for
using Federal Superfund monies are required to follow EPA
acquisition regulations. This process requires free and open
competition, meaning that all jobs are subject to competitive
bidding. EPA is then required to award the job to the lowest
cost responsive, responsible bidder. An evaluation is
conducted by EPA to make sure that the party being awarded
the construction contract is capable of conducting the type
of services requested. In addition, the contractor will be
required to meet the health and safety standards found in 29
CFR 1910.120, and other quality assurance/quality control
guidelines.
6) One person asked whether the thermal treatment unit would
require permits.
EPA Response; The Superfund Law (known as CERCLA) exempts
onsite response actions from the requirement of obtaining
permits. Because the EPA has determined to treat these sites
as one for the purpose of remedial action, incineration at
Vertac is considered an "onsite" action. The permit
exemption allows the response action to proceed in an
expeditious manner, without the potential lengthy delays of
obtaining approval by administrative bodies. While the
formal process of obtaining and administering permits is not
required, response actions must meet the substantive
requirements of whatever permits would otherwise apply to the
action. These requirements pertain directly to actions or
conditions in the environment and include health-,
technology- and location-based standards and restrictions.
7) A local citizen requested clarification as to whether the
incinerator currently in operation at Vertac would be the
treatment unit used for the Jacksonville and Rogers Road
wastes.
EPA Response; As discussed in Comment No. 5, this remedial
action is required to comply with EPA acquisition regulations
which, among other things, requires free and open
competition. This requirement precludes EPA from "pre-
selecting" any single firm. EPA selects contractors through
a formal open bidding process. VSC, who operates the
incinerator currently located at Vertac, and any other
interested qualified firms would be invited to submit a
competitive bid for the Landfill contracts.
8) One citizen asked when the Remedial Design (RD) would be
complete.
Page 2-4
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EPA Response; EPA anticipates that the RD will be complete
within 12 months from the signing of the ROD.
9) One citizen asked how long "long term" monitoring would be
conducted.
EPA Response; Current regulations specify a monitoring
period of' 30 years from the completion of the remedial
action. This period of time can be extended or reduced
depending on when the determination is made by EPA and the
State that the remedy is, and will remain, protective to
human health and the environment.
QUESTIONS/COMMENTS REGARDING REMEDIAL ALTERNATIVE PREFERENCES
10) One individual asserted his distrust for thermal destruction
and recommended that EPA cap the contaminated soils in place
without treatment until more is known about effective dioxin
treatment.
EPA Response; Thermal destruction is a widely used
technology, capable of safely and permanently destroying
dioxin waste. It has been identified by EPA as being the
Best Demonstrated Available Technology (BOAT) for the types
of contaminants encountered at the Landfill sites, and has
been documented as being able to treat the wastes to the
levels specified in the ROD.
The BOAT classification signifies a type of "approval"
rating. In order for a technology to be classified as BOAT,
EPA performs an analysis to make sure that the technology
meets the following criteria: 1) performance data must show
that the technology is significantly more effective than any
others for a given waste type; 2) a full-scale facility is
known to be in operation and successfully treating similar
wastes; and 3) the process is generally or commercially
available.
It is unlikely that another technology could be developed and
demonstrated to be as effective as thermal destruction in the
near future. Thus, the present course of action is
consistent with EPA's goals of providing timely and
expeditious action at sites which present human health and
environmental threats.
11) Several commenters requested that the waste be incinerated
somewhere other than Jacksonville.
EPA Response; This alternative was seriously considered in
the Feasibility Study and is, in fact, presented as
Alternative 3 in the "DESCRIPTION OF ALTERNATIVES" section of
Page 2-5
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the ROD. There are two principal issues that discourage the
selection of this alternative. The first is the fact that
there are currently no commercial hazardous waste
incinerators permitted to accept dioxin waste from the
Landfill sites. Some facilities have submitted permit
applications for this type of waste but, to date, none have
been approved. It is uncertain when, if ever, approval would
come.
The second consideration taken into account is EPA's strong
preference for onsite action. That is, it is EPA's policy to
give preference to remedies that are conducted onsite rather
than sending the waste offsite to private treatment, storage
or disposal facilities, etc. (It should be noted that the
National Contingency Plan, EPA's "guidance" document for
Superfund sites, allows the selected remedy to be considered
an onsite action because it satisfies the criteria of site
proximity and waste similarity.)
12) One resident who lives near the landfills proposed that any
and all soils containing detectable levels of dioxins be
excavated and treated at Vertac.
EPA Response; Because the selected remedy removes the most
heavily contaminated soil and reduces site-related risks to
levels within the acceptable risk range, no further treatment
will be specified. A review will be initiated within five
years of the remedial action to re-evaluate whether the
remediation goals remain protective. If the re-assessment
reveals that further action is warranted to assure
protectiveness, studies would be conducted to determine the
most efficient method of accomplishing this.
13) One local citizen asked that EPA consider excavating the hot
spot near the eastern fence line of the Jacksonville landfill
(at Sample No. SS-F4-01) and consolidating it in the vicinity
of the other secondary hot spots prior to capping.
EPA Response; Although sufficient protection would be
achieved by capping the hot spot in place, other
considerations make the idea of consolidating this hot spot
among the others more attractive. An obvious benefit would
be more "aesthetic" in nature, as removal of the hot spot
from near the eastern fenceline would place some distance
between the hot spot and the residential back yards which are
adjacent to the fence. A more tangible benefit comes from
possible capital and maintenance cost savings due to having
one less cap to construct and maintain. This is a comment
worth further consideration during design.
14) One commenter expressed her disappointment that In-Situ
Vitrification (ISV) was not examined further.
Page 2-6
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EPA Response; ISV was evaluated in the early stages of the
Feasibility Study. It was screened out because of technical
impracticalities including the high moisture content and
garbage contained in the soils which would make
implementation of this technology difficult. Also, there was
concern that ISV might generate other hazardous constituents
as by-products of the process.
15) One commenter proposed that the capping of soils containing
between 1.0 and 10 ppb of dioxin is unnecessary considering
present land use.
EPA Response; The Agency for Toxic Substances and Disease
Registry (ATSDR) is the governmental agency which EPA
consults regarding health matters. ATSDR has recommended
that, in a residential setting, subsurface soils containing
concentrations of 2,3,7,8-TCDD not exceeding 10 ppb should
not pose a significant health hazard if covered with 12
inches of clean soil. This recommendation has been used at
several other Superfund sites contaminated with dioxins.
Based upon ATSDR's recommendation, EPA has incorporated a
component into the site remedy which calls for placing 12
inches of clean fill over areas found to contain dioxins
between 1.0 and 10 ppb. (Recall that soils containing over
10 ppb will be removed and thermally treated.)
The commenter's main point is that the Jacksonville and
Rogers Road landfill sites are not presently considered
residential areas. They assert that perhaps EPA should use
ATSDR's less stringent recommendations for commercial /
industrial sites. This is a valid claim, however, Superfund
site remedies are required to provide protectiveness not only
with regard to present land use, but also based upon future
land use scenarios. As discussed in the ROD, present site
conditions are not very conducive to residential development
(i.e., the site is partially located within the 100-year
floodplain and is trenched and mounded with municipal
wastes). However, there are no city or county zoning
ordinances restricting land-use and therefore it is
conceivable that the site could potentially be used for
residential purposes in the future. This is an unlikely
scenario, but it cannot be eliminated and EPA is therefore
required to consider residential use as a possible future
land use. In consideration of this potential scenario, the
residential setting and corresponding action levels are
appropriate and therefore adopted with regard to remedial
action objectives for the landfill sites.
16) Hercules, Inc., one of the PRPs for the sites, proposed that
the treatment and capping components of the site remedies be
Page 2-7
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deleted altogether. Hercules maintains that adequate
protection of human health and the. environment can be
afforded even without treatment or capping.
EPA Response: Hercules' basis for this proposition is a risk
analysis produced by a private company (ChemRisk) on
Hercules' behalf. Their conclusion contends that the
allowable level of TCDD in residential soils should be 28
ppb, and 113 to 209 ppb at industrial sites. By adopting the
levels calculated for the industrial setting, Hercules
concludes that no treatment or capping of site soils is
required.
Two issues need to be addressed in order to respond to this
comment: 1) the use of residential vs. industrial settings,
and 2) the reasoning behind using EPA's Risk Assessments
rather than ChemRisk's for the landfill sites. Issue number
1 was discussed in the previous comment; i.e., EPA has
adopted the residential setting as the basis for determining
acceptable remediation goals.
Regarding issue number 2, Hercules Inc. submitted a report
prepared by ChemRisk which provided calculations resulting in
cleanup goals differing from EPA's for dioxin. The report
utilized certain calculations and assumptions which were
contrary to EPA guidance and resulted in cleanup goals much
less restrictive than those calculated used by EPA. The
paragraphs below discuss some of the discrepancies between
EPA's and ChemRisk's methods of calculating site related
risks.
The cancer potency factor for 2,3,7,8-tetrachlorinated
dibenzo-p-dioxin (2,3,7,8-TCDD) of 9,700 (mg/kg-day) "1 is
presented in ChemRisk's Section 2 ("Dose-Response Assessment
for Dioxin"). This cancer potency factor or slope factor has
not been verified by the CRAVE workgroup and is not in
accordance with EPA policy. The EPA slope factor for
2,3,7,8-TCDD is 1.56 x 105 (mg/kg-day)"1.
Several exposure parameters used in ChemRisk's Section 4
("Recommended Action Levels for TCDD-Contaminated Soil") are
not in accordance with EPA guidance. ChemRisk uses a soil
contact rate or adherence factor of 0.5 mg/cm2, which
underestimates by a factor of 3 to 6 the quantity of soil
adhering to the skin, and which results in an underestimate
of dermal absorption.
ChemRisk uses soil ingestion rates of 10 mg/day for children
aged 0 to 1 years, 50 mg/day for children aged 1 to 5 years,
and 10 mg/day for older children and adults. EPA's Exposure
Factors Handbook (EPA/600/8-89/043) provides upper-range soil
ingestion rates of 800 mg/day for children aged 1 to 6 years,
Page 2-8
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and 100 mg/day for older children and 50 mg/day for adults.
ChemRisk uses fish consumption rates of 0 g/day, 0.49 g/day,
and 1.48 g/day for ages 0 to 1 years, 1 to 12 years, and 12
to 70 years, respectively. The EPA guidance recommends fish
consumption rates of 38 g/day for the 50th percentile daily
intake. This rate represents per capita consumption and may
underestimate recreational fishermen who consume larger
amounts of'fish than the general population.
EPA, in preparing the risk assessment, used the cancer
potency factor, soil contact rate, soil ingestion rates and
fish consumption rates that were in accordance with agency
guidance and policy. Using EPA's risk assessment approach,
the cleanup levels provided in the selected remedy will
result in excess cancer risks within the National Contingency
Plan's acceptable range of 10"4 to 10"6. ChemRisk's proposed
cleanup goals, using EPA's risk assessment approach, would
not result in excess cancer risks (after remediation) within
the acceptable risk range.
In addition, Hercules questions how the 1984 risk assessment
produced by Dr. Renate Kimbrough for the Times Beach,
Missouri Superfund site relates to the landfill sites. In
response, Kimbrough's paper was not relied on for the
derivation of the landfills' risk assessments. However, the
results of the Kimbrough paper were cross-referenced in an
informal comparison at the completion of the landfill risk
analyses in order to see where we fell with respect to
Kimbrough's findings. Results of this comparison revealed
that, as was the case with Times Beach, an action level of
1.0 ppb for 2,3,7,8-TCDD resulted in the risks for the
landfill sites falling within the range of acceptable risk
provided in the National Contingency Plan. This action level
is consistent with current EPA thinking regarding dioxin-
contaminated Superfund sites.
The risk assessments themselves were produced independently
of Kimbrough's paper and in accordance with the methodology
outlined in the Superfund Public Health Evaluation Manual
(1986) and the Superfund Exposure Assessment Manual (1988).
The assumptions and standard exposure parameters used in
assessing landfill site risks were consistent with the
aforementioned guidance documents, and were not intended to
be consistent on all counts with the Kimbrough paper.
As a final note, it should be emphasized that long term
protection to human health and the environment would not be
achieved without the treatment and. containment components of
the ROD. Without further treatment or containment, the risks
at the Jacksonville and Rogers Road Landfill sites will
remain unabated. The remedies that Hercules proposes —
Page 2-9
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primarily comprised of fencing, land use controls and long
term monitoring — will not reduce the toxicity, mobility, or
volume of site contaminants. Further, these measures have
not been proven effective in precluding direct contact to
contaminated surface soils. Fences are easily breached and
land use controls are difficult, if not impossible, to
enforce. .For these reasons, EPA has chosen not to rely on
these types of controls as primary measures for effective
site remediation.
QUESTIONS REGARDING EFFECTIVENESS OF INCINERATION
17) Several commenters expressed concerns over the effectiveness
of thermal treatment on dioxins, and the safety of those
residing in the proximity of the treatment unit.
EPA Response: EPA has experience in treating these types of
wastes at other sites (Times Beach, Denny Farm - Missouri).
Test burns completed at these sites indicated that the
incinerated soils met all appropriate goals. The trial burn
for the landfill sites' waste will be required to attain a
99.9999% reduction of dioxin in the stack emissions. Also,
the treated ash will be sampled to verify that all other
treatment goals have been met. All of EPA's experience with
thermal destruction indicates it provides protection of human
health and the environment. Therefore, as previously
discussed, incineration is considered the "Best Demonstrated
Available Technology" for the destruction of dioxin.
18) Two local citizens asked whether this type of incineration
had ever been conducted within a residential area.
EPA Response; The incineration of hazardous material has
been occurring for many years. There are numerous facilities
in operation throughout the country which incinerate many
different types of hazardous wastes on an ongoing basis.
Only a small fraction of the incinerators of this type are
operated under the authority of Superfund. Instead, most are
private or commercial facilities regulated under other
Federal Laws such as the Recourse Conservation and Recovery
Act, the Hazardous and Solid Waste Amendments, and the Toxic
Substances Control Act, among others. Additionally, there
are other agencies besides EPA which oversee the operations
of these facilities, for example, the Department of Energy
and the Department of Defense.
Although there are known instances of hazardous waste (i.e.,
dioxin) incineration being conducted in or adjacent to cities
and towns, information detailing the specific location of
incinerators relative to population density within a known
proximity is not readily available.
Page 2-10
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QUESTIONS REGARDING THE REMEDIAL INVESTIGATION, RISK ASSESSMENT
AND FEASIBILITY STUDY METHODS AND CONCLUSIONS
19) Several citizens were concerned that EPA may not have sampled
deep enough to find all of the waste that may be buried
onsite.
EPA Response: This is an understandable concern, since no
records were kept regarding the locations or depths of the
wastes that were disposed of at the sites. EPA recognized
this at the outset of the Remedial Investigation (RI), thus
the sampling strategy which was instituted at the sites
included provisions for sampling at various depths. Shallow
soils (<2 feet) were sampled using a short hand-driven auger.
Deeper soils (up to 30 feet or more) were monitored through
the use of large drilling rigs. For these samples, soil
borings were sampled at regularly spaced intervals and at any
other location suspected of being contaminated. A third
sampling method involved digging to the bottom of the
existing site trenches, where dumping was known to have
occurred, until native undisturbed soils were encountered.
Samples were taken at the bottoms of these trenches in order
to characterize the waste. Finally, in an attempt to locate
any other areas where we might not have thought to look, EPA
and their site contractor solicited the assistance of a
nearby resident who suspected that drums were buried onsite.
At the discretion and direction of the resident, EPA trenched
the site at various locations until all parties were
satisfied that the suspected areas had been addressed. More
information regarding sampling methods employed at the sites
can be found in Chapter 3.0 of the sites' respective Remedial
Investigation Reports.
20) A local resident asked if the city water supply was being
polluted by Jacksonville landfill site contaminants.
EPA Response; No. As far as the City's municipal wells are
concerned, it is highly unlikely that they could be even
remotely affected by contamination from the Jacksonville and
Rogers Road sites. The most obvious reason is because no
ground water contamination which could be attributable to the
site was found even immediately down-gradient (down-stream)
of the sites. In addition, ground water flow in the area is
toward the east-southeast and the closest municipal wells are
approximately 2 miles southwest of the landfills.
EPA recognizes, however, that the ground water near sites
which operated in the fashion as these (i.e., open dumping)
can be somewhat vulnerable to leaching from buried wastes
onsite. Because of this, EPA is instituting a long-term
ground water monitoring program to ensure that the remedies
taken at the sites continue to provide protection to the
Page 2-11
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ground water quality in the area. Through this monitoring
program, any trends in water quality will be detected and
appropriate actions will promptly be taken.
21) One commenter, speaking on behalf of a local citizen's group,
requested that a full health study be performed throughout
the City of Jacksonville.
EPA Response: The Agency for Toxic Substances and Disease
Registry (ATSDR), in association with the Arkansas Health
Department and ADPC&E, is currently evaluating the scope of
a possible health study in the Jacksonville area. They are
presently seeking the input of a Community Advisory Panel
comprised of members of the local and medical communities,
elected officials, and representatives of public
environmental groups. It should be noted that the decision
to conduct the health study rests with ATSDR and the Arkansas
Health Department, not EPA.
QUESTIONS REGARDING OTHER ISSUES
22) Several citizens referred to the "No Burn Ordinance" and
asked why it appears that the ordinance is not being
observed.
EPA Response: CERCLA mandates that Superfund response
actions comply with all Applicable or Relevant and
Appropriate Requirements (ARARs). ARARs consist of all
Federal or State environmentally protective requirements that
either address specific circumstances related to Superfund
sites, or situations sufficiently similar to those
encountered at the CERCLA site that their use is well suited
to the particular site. Compliance with the substantive
requirements of State regulations is required only when the
regulation is uniformly applied on a State-wide basis. Local
ordinances would not qualify under this criteria because they
are not applied consistently across the state. Another
reason that compliance with standards other than Federal and
State regulations (i.e., local ordinances) is not required is
that they might unduly restrict or otherwise encumber timely
remedial response at Superfund sites.
23) One commenter was concerned that the remedial action would
set a precedent for the importing of Superfund wastes to
Vertac from other areas of the State and beyond.
EPA Response: EPA will not establish the Vertac site as a
hazardous waste treatment center. EPA's rationale for
bringing the landfill wastes back to Vertac is that they are
suspected of having originated at that facility in the first
place. As mentioned in Comment No. 11, the sites satisfy the
NCP's criteria of close proximity and similarity of wastes to
Page 2-12
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the degree that the selected remedy is considered an "onsite"
action. Other unrelated sites would not very likely be able
to satisfy such criteria.
Page 2-13
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APPENDIX A
ADMINISTRATIVE RECORD INDEX
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INTRODUCTION
Section 113(j)(l) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) provides that judicial review of any issues concerning the
adequacy of any response action shall be limited to the administrative record which has
been compiled for the site at issue.
Section 113(k)(l) of CERCLA, requires that the United States Environmental Protection
Agency (Agency) establish administrative records for the selection of CERCLA response
actions. The administrative record is the body of documents upon which the Agency
based its selection of a remedy. The agency's selection of a particular response action
must be documented thoroughly in the administrative record. The Agency must ensure
that the record is a compilation of documents leading up to and reflecting the Agency's
response decision.
In accordance with U.S. EPA Headquarters OSWER Directive 9833.3, Section 113(k) of
the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), as amended in 1986 by the Superfund Amendments and Reauthorization
Act (SARA) the U.S. EPA is required to compile and make available to the public
Administrative Records containing documents used to support response actions
authorized under CERCLA and SARA. The Administrative Records are to be
maintained at the relevant U.S. EPA Regional Offices as well as "at or near the facility
at issue".
This Administrative Record File Index consists of information upon which the Agency
based its decision on selection of response actions. It is a subset of information included
in the site files. The records hi this Administrative Record File Index have been
arranged in chronological order (from the earliest date to the most recent date), based
on the date of the corresponding document. Each document contained in the
Administrative Record File has been stamped with sequential document numbers, to
assist in the location of the document with the Record File.
This Administrative Record File Index has been compiled in accordance with OSWER
Directive Number 9833. la Interim Guidance on Administrative Records for Decisions
on Selection of CERCLA Response Actions. This guidance reflects, to the extent
practicable revisions being made to the National Contingency Plan (NCP).
-------
ADMINISTRATIVE RECORD INDEX
FINAL
SITE NAME: ROGERS ROAD LANDFILL
SITE NUMBER: ARD 981055809
INDEX DATE: 10/01/90
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*****************************************************************************
I. CHRONOLOGICAL LISTING
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SITE NAME:
SITE NUMBER:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000001 - 000003
04/18/84
. 3
Allyn M. Davis, Director, Air and Waste Management Division
U.S. EPA Region 6
Bill Owen, City Engineer, City of Jacksonville
Correspondence
104(e) letter
000004 - 000004
05/18/84
1
Keith Vaughan, City Attorney
City of Jacksonville, AR
Bonnie DeVos, U.S. EPA Region 6
Correspondence
Re: Response to letter from Allyn M. Davis on 04/18/84,
addressed to Bill Owen, City Engineer for the City of
Jacksonville
000005 - 000012
05/13/85
8
Gene A. McDonald, Field Investigation Team (FIT)
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Assessment Report
Re: Rogers Road Landfill Site, Potential Hazardous Waste Site
Identificiation and Preliminary Assessment
000013 - 000013
05/21/85
1
Keith Bradley, FIT Remedial Project Officer (RPO), Hazardous
Waste Section
U.S. EPA Region 6
Marth McKee, Chief, Compliance Section, U.S. EPA Region'6
Cover Sheet
Preliminary Assessment and Site Inspection Report
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000014 - 000014
05/28/85
- 1
Gary W. Guerra, FIT
U.S. EPA Region 6
Keith Bradley, RPO, Hazardous Waste Section, U.S. EPA Region 6
FIT Task Request
Request to complete sampling and investigative work
000015 - 000025
05/30/85
11
Gene A. McDonald, FIT Technician
Ecology and Environment, Inc.
U.S. EPA Region 6 Site Files
Report
Site Inspection Report
000026 - 000035
06/01/85
10
Keith Bradley, FIT RPO, Hazardous Waste Section
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section, U.S. EPA Region 6
Site Report
Site Inspection Report, field data, and sampling plan
000036 - 000044
06/06/85
9
Frank E. Onellion, Technical Assistance Team (TAT) member,
Region 6-Dallas
Weston-Sper
Gerald Fontenot, Deputy Project Officer (DPO), Emergency
Response Branch (ERB), U.S. EPA Region 6
Report
Rogers Road Hazardous Waste Site-FIT site inspection
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000045 - 000045
06/06/85
'1
Samuel L. Nott, Chief, Superfund Branch
U.S. EPA Region 6
Don-Michael Bradford, Captain, USAF, Director, Environmental
Planning Div., AF Regional Civil Eng.
Correspondence
Re: Investigation at the Rogers Road Site and City of
Jacksonville Landfill
000046 - 000049
06/06/85
4
Bill Hathaway for Allyn M. Davis, Director, Air & Waste
Management Division
U.S. EPA Region 6
Doug Keilman, Hercules, Inc.
Correspondence
Re: City of Jacksonville Landfill and Rogers Road Site,
requesting information about generic name and chemical
character of hazardous wastes
P.E. Chief, Public Water Supply Section
Superfund Compliance Section, U.S. EPA
000051 - 000052
06/11/85
2
James L. Graham, Jr
U.S. EPA Region 6
Martha McKee, Chief
Region 6
Site Inspection Report
Potential Hazardous Waste Site- Response to CERCLA
investigation reports sent to the Water Supply Branch
000053 - 000054
06/19/85
2
Bill Hathaway for Allyn M. Davis, Director, Air & Waste
Management Division
U.S. EPA Region 6
James G. Reid, Mayor, City of Jacksonville, AR
Correspondence
104(e) letter request for information on City of Jacksonville
Landfill and Rogers Road Site
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000055 - 000055
06/24/85
- 1
Roxanne Jayne
Hercules Incorporated
Tim Perdue, U.S. EPA Region 6
Record of Communication
Re: Rogers Road/Jacksonville Landfill-
letter and request 30 day extension
Response to 104(e)
000056 - 000056
06/24/85
1
Roxanne E. Jayne, Associate Counsel, Law Department
Hercules Incorporated
Gary Guerra, Superfund Compliance Section, U.S. EPA Region 6
Correspondence
Acknowledge receipt of Allyn M. Davis' letter dated 06/06/85.
Request 30 day extension to respond until August 12, 1985
000056 - 000162
06/24/85
107
Kendall Young, Chief Laboratory Section, Houston Branch
U.S. EPA Region 6
Keith Bradley, Hazardous Waste Section, U.S. EPA Region 6
Analytical Data
Contract Laboratory Program (CLP) Data Review, Organic
#1731F-01 - 1731F-03
000164 - 000333
06/27/85
170
Jill B. Henes, Dioxin Project Manager
Compuchem Laboratories
Richard Thacker, Viar and Company
Correspondence and Attachment
Report of Data - EPA Contract #68-01-6915, Case # 4463-1
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000334 - 000348
07/01/85
-15
Jairo Guevara, Chemical Engineer, FIT Region 6
Ecology and Environment Inc., Region 6
Keith Bradley, DPO, Hazardous Waste Section, U.S. EPA Region 6
Memorandum
Re: Interim Report-Sampling residential wells in the vicinity
of the old Jacksonville City Landfill
000349 - 000407
07/02/85
59
Kendall Young, Chief Laboratory Section, Houston Branch
U.S. EPA Region 6
Keith Bradley, Hazardous Waste Section, U.S. EPA Region 6
Lab Data
Re: CLP Data Review, Rogers Road Landfill, Case #4463
000408 - 000408
07/08/85
1
Martha M. McKee, Chief, Superfund Compliance Section
U.S. EPA Region 6
Roxanne E. Jayne, Associate Counsel, Hercules Incorporated
Correspondence
Re: Request for a 30 day extension to the 07/11/85 deadline
000409 - 000410
07/10/85
2
Kendall Young, Chief Laboratory Section, Houston Branch
U.S. EPA Region 6
Keith Bradley, Hazardous Waste Section, U.S. EPA Region 6
Memorandum
CLP Data Review for Organic #DF017305, DF017312, Case #4463
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FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000411 - 000463
07/11/85
"53
Kendall Young, Chief Laboratory Section, Houston Branch
U.S. EPA Region 6
Keith Bradley, Hazardous Waste Section, U.S. EPA Region 6
Memorandum
CLP Data Review of Case #4463-Inorganic MFA 706- MFA 710 and
MFA 753 - MFA 755
000464 - 000469
07/16/85
6
M.L. Ritter, Chemist, Houston Branch Laboratory
U.S. EPA Region 6
K. Young, Laboratory Chief, Houston Branch Laboratory, U.S.
EPA Region 6
Memorandum
Re: Pesticide Surrogate Recovery Data in Case #4463 and SAS
1731F.
000470 - 000471
07/18/85
2
James G. Reid, Mayor
City of Jacksonville, AR
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence
Re: EPA letter dated 06/19/85, City of Jacksonville operated
two sanitary landfills from 1953-1974 for the disposal of
garbage and misc. rubbish debris
000472 - 000473
07/22/85
2
Roxanne E. Jayne, Associate Counsel, Law Department
Hercules Incorporated
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence
Response to letter of 06/06/85 to Doug Keilman concerning
Hercules lack of liability
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000474 - 000655
07/24/85
182
Ken D. Faust, Section Manager, EPA Organic Superfund Division
Rocky Mountain Analytical Laboratory
Tony Nesky, Sample Management Office, U.S. EPA Region 6
Sampling and Analysis
Results for Case #4463/SAS 1731F analyzed for TCDD under
contract #68-07-6914
000656 - 000708
07/26/85
53
Kendall Young, Chief Laboratory Section, Houston Branch
U.S. EPA Region 6
Keith Bradley, Hazardous Waste Section, U.S. EPA Region 6
Memorandum
CLP Data Review for Case #4463
000709 - 000710
08/02/85
2
Oscar Cabra, Jr., P.E., Chief, Water Supply Branch
U.S. EPA Region 6
Bruno Kirsch, Jr., P.E., Director, Division of Engineering,
Arkansas Department of Health
Correspondence
Organics Analysis for samples taken from Jacksonville Public
Water Supply on 06/07/85
000711 - 000712
08/30/85
2
Ken D. Faust, Section Manager, EPA Organic Superfund Division
Rocky Mountain Analytical Laboratory
Mel Ritter, Houston Branch, U.S. EPA Region 6
Correspondence and Attachment
Re: Resubmission of Form B-l for Case #4463/SAS 1731F
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000713 - 000760
09/10/85
'48
Gene A. McDonald, FIT
Ecology and Environment Inc., Region 6
Keith Bradley, RPO, U.S. EPA Region 6
Memorandum
Re: Sampling Inspection of Rogers Road Site, Jacksonville, AR.
Describes sampling operations conducted during the period
06/04-07/85
000761 - 000763
09/11/85
3
Allyn M. Davis, Director, Air & Waste Management Division
U.S. EPA Region 6
R.D. Karkkainen, Director, Environment and Safety, Vertac
Chemical Corporation
Correspondence
Re: 104(e) letters concerning City of Jacksonville Landfill
and Rogers Road Site.
000764 - 000764
09/24/85
1
James L. Graham, Jr., P.E., Chief, Public Water Supply Section
U.S. EPA Region 6
Martha McKee, Chief, Superfund Compliance Section
Site Inspection Report
Response to CERCLA investigation reports
000765 - 000765
10/02/85
I
Staff Consultants
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Letter
Re: Data received from sampling conducted at Jacksonville and
Rogers Road Landfill, and area drinking water
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000766 - 000766
10/16/85
- 1
Mary Ellen Crowley
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Site Identification
Citizen's complaint of 05/10/85 alleging that the landfill
accepted hazardous waste during its operation 07/53-10/74
000767 - 000767
10/18/85
1
Dick Karkkainen, Director of Environment and Safety
Vertac Chemical Corporation
Gary Guerra, Superfund Compliance, U.S. EPA Region 6
Correspondence
Re: City of Jacksonville Landfill and Rogers Road Site
investigated and Vertac has no documents pertinent to
questions 1-6 of Mr. Davis's 09/13/85 letter
000768 - 000770
10/25/85
3
Stephen Margolis, Ph.D, Acting Director, Office of Health
Assessment
Agency for Toxic Substances and Disease Registry (ATSDR)
Carl Hickam, Public Health Advisor, U.S. EPA Region 6
Memorandum
Health Assessment
000771 - 000772
11/06/85
2
Dale Bumpers
United States Senate
Dick Whittington, Regional Administrator, U.S. EPA Region 6
Correspondence
RE: Test results from samplings at the Jacksonville, Arkansas
landfill
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000773 - 000774
11/07/85
' 2
Office of Public Awareness
U.S. EPA Region 6
Public
Environmental News
Re: Test results from sampling at the Rogers Road hazardous
waste site near Jacksonville, AR
000775 - 000775
11/18/85
1
Dick Whittington, Regional Administrator
U.S. EPA Region 6
Dale Bumpers, U.S. Senate
Correspondence
RE: Letter of 11/06/85 regarding the inclusion of the
Jacksonville Landfill on the Superfund National Priority List
(NPL), also the Rogers Road Landfill
000776 - 000776
11/26/85
1
Staff Consultants
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Attachment #1
Enforcement Sensitive - included in Action Memo
000777 - 000780
01/09/86
4
Dick Whittington, Rigional Administrator
U.S. EPA Region 6
Honorable Dale Bumpers, United States Senate
Correspondence
Response to inquiry of 12/12/85 concerning security at the
landfill
10
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FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000781 - 000781
08/14/86
.1
Robert Hannesschlager, Chief, Superfund Enforcement Branch
U.S. EPA Region 6
Russ Wyer, Director, Hazardous Site Control Division, U.S. EPA
Headquarters
Memorandum
RE: Narrative summaries for Region 6 NPL update 6 sites
000782 - 000783
11/05/86
2
B. Bobbie, Supervisor, Dioxin Unit
Ministry of the Environment, Ontario
J. Oskowis, Manager - Engineer, Jacksonville Water Commission
Correspondence and Attachment
Results of analysis of two Jacksonville well water samples for
chlorinated dibenzo-p-dioxins (CDD) and chlorinated
dibenzofurans (CDF) received on 09/08/86
000784 - 000786
11/13/86
3
Jim Oskowis, P.E. , Manager-Engineer
Jacksonville Water Commission
Harold Seifert, Division of Engineering, Arkansas Department
of Health
Correspondence and Attachment
Analysis transmitted to recipient for his files concerning lab
report (see 11/05/86 document)
000787 - 000790
07/30/87
4
Barry L. Johnson, Ph.D., Associate Administrator
Department of Health & Human Services
David Wagoner, Director, Waste Management Division, U.S. EPA
Region 7
Correspondence
Response to request for elaboration on the mathematics
underlying the development of support for the 20 parts per
billion (ppb) cleanup level for certain Missouri dioxin sites
11
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000791 - 000795
10/02/87
- 5
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Honorable Tommy Swain, Mayor
Notice Letter
City of Jacksonville may be Potentially Responsible Party
(PRP) - request for written response
000796 - 000801
12/02/87
6
Allyn H. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Lee Thalheimer, Esq., Vertac Chemical Corporation, Arnold,
Grobmeyer & Haley
Correspondence
Notification letter to a PRP
000802 - 000804
12/16/87
3
Carl E. Edlund, Chief, Superfund Program Branch
U.S. EPA Region 6
Joe Gillespiey, Manager, State Programs, Office of
Intergovernmental Services, Dept. of Fin. & Admin
Correspondence
Notification of a proposed Superfund project that includes the
Remedial Investigation/Feasibility (RI/FS) at the Rogers Road
Municipal Landfill site
000805 - 000805
01/04/88
1
Bill Hall, Acting State Historic Preservation Officer ,
Arkansas Historic Preservation Program
Carl E. Edlund, Chief, Superfund Program Branch, U.S. EPA
Region 6
Correspondence
Environmental Review-EPA Rogers Road Municipal Landfill Site;
response to inquiry of 12/16/87
12
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FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000806 - 000809
01/05/88
- 4
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Doug Keilman, Hercules, Inc.
Correspondence
EPA has information to indicate that Hercules, Inc. may be a
responsible party. EPA has reason to believe that Hercules
transported hazardous material to Jacksonville Landfill
000810 - 000816
01/05/88
7
Allyn M. Davis, Director, Hazardous Waste Mangement Division
U.S. EPA Region 6
Tommy Swain, Mayor, City of Jacksonville, AR
Correspondence
Investigation by EPA indicate that the City of Jacksonville
may be a responsible party. EPA has reason to believe that
the City of Jacksonville was owner of Jacksonville & Rogers
Road Landfills
000817 - 000818
01/19/88
2
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Bill Hall, Acting State Historic Preservation Officer,
Arkansas Historic Preservation Program
Correspondence
Re: Review of the Jacksonville and Rogers Road Municipal
Landfills, per request, enclosing site location map,
Statements of Work and copies of photos depicting structures
adjacent to site
000819 - 000819
01/25/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Carl R. Stapleton, Ph.D., Environmental Sciences and Resource
Planning, Inc.
Correspondence
RE: Freedon of Information Act (FOIA) request on Jacksonville
Municipal Landfill (Graham Rd. Landfill) and the Rogers Road
Municipal Landfill
13
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000820 - 000823
01/27/88
* 4
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
C.P. Bomar, Jr., Director/Officer, Phoenix Capital
Enterprises, Inc.
Correspondence
Notice of potential liability
000824 - 000824
02/02/88
1
Bill Hall, Acting State Historic Preservation Officer
Arkansas Historic Preservation Program
Martin Swanson, RPM, ALONM Remedial Section, U.S. EPA Region 6
Correspondence and Attachment.
Recommendation that a cultural resources survey be conducted
of both landfill locations since records indicate that an
archeological site is located at the sites
000825 - 000826
02/09/88
2
Robert E. Bamburg, Assistant City Attorney
City of Jacksonville, AR
Suzette Turner, Enforcement Branch, U.S. EPA Region 6
Correspondence
Re: Letter received, dated 01/05/88, designating the City of
Jacksonville as a PRP
000827 - 000827
02/18/88
1
Douglas J. Keilman
Hercules, Inc.
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
Request for extension of 30 days to respond to 01/12/88
request for Hercules to voluntarily undertake a RI/FS
14
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SITE NAME:
SITE NUMBER:
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DOCUMENT DATE:
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FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000828 - 000828
02/24/88
- 1
Scott Slaughter
Mott & Associates, P.C.
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
Re: 01/09/88 letter sent to Lee Thalheimer, Receiver for the
Vertac Corp. asking Vertac to perform the RI/FS at
Jacksonville and Rogers Road Landfill
000829 - 000829
03/01/88
1
Martin Swanson, RPM
U.S. EPA Region 6
John Vetter, Consulting Archeologist
Record of Communication
Mr. Vetter feels that a cultural resource survey has to be
conducted at the site and that the lead agency is responsible
for the work
000830 - 000830
03/28/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Bob Lombardi, Peer Consultants, P.C.
Correspondence
Federal funding is currently being allocated for the RI/FS at
the Jacksonville Landfill and Rogers Road Landfill
000831 - 000834
04/18/88
4
Roxanne E. Jayne, Counsel
Hercules, Inc.
Suzette Truner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
RE: Response to Mr. Davis' letter requesting Hercules
voluntarily undertake an RI/FS at the site
15
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000835 - 000837
04/19/88
- 3
Curtis L. Frisbie, Jr.
Gardere & Wynne, Attorneys and Counselors
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Correspondence
RE: PRP information
000838 - 000841
04/22/88
4
Robert E. Bamburg, Assistant City Attorney
City of Jacksonville
Suzette Turner, Superfund Enforcement Branch, U.S. EPA Region
6
Correspondence
RE: Potentially Responsible Party (PRP) Letter Graham Road
and Rogers Road Landfills - response to 01/05/88 and request
for extension of time to respond to PRP letter
000842 - 000842
05/20/88
1
Cath Buford, State Historic Preservation Officer
Arkansas Historic Preservation Program
Michael A. Klevenz, PEER Consultants, P.C.
Correspondence
RE: After reviewed of additional information, no cultural
resources survey will be necessary
000843 - 000843
06/08/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Doice Hughes, Hazardous Waste Division, Arkansas Department of
Pollution Control & Ecology (ADPC&E)
Correspondence
Transmittal for Draft Work Plans
16
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000844 - 000844
06/14/88
' 1
Mike Bates, Chief, Hazardous Waste Division
ADPC&E
Martin Swanson, RPM, ALONM Remedial Section, U.S. EPA Region 6
Correspondence
Re: Letter to Doice Hughes, dated 06/08/88, regarding comments
on draft work plans, etc.
000845 - 000845
06/29/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Suzette Turner, Compliance Section, U.S. EPA Region 6
Memorandum
Re: Replacement of missing fence at the Rogers Road Landfill
Site. During 04/29/88 visit EPA & City of Jacksonville
personnel observed approx 200' of fence missing from the
southern boundary.
000846 - 000846
07/12/88
1
Suzette Turner
U.S. EPA Region 6
Martin Swanson, RPM, ALOMN Remedial Section, U.S. EPA Region 6
Record Of Communication
Re: City Council approved the dollars needed to replace the
stolen fence at Jacksonville and Rogers Road Landfill site
Program Manager
000847 - 000998
07/27/88
152
Robert A. Lombard, Jr.
PEER Consultants, P.C.
U.S. EPA Region 6 Site Files
Report
Performance of Remedial Response Activities at Uncontrolled
Hazardous Waste Sites, Sampling and Analysis Plan, Quality
Assurance Project Plan, Data Management Plan for Rogers Road
Landfill
17
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
000999 - 000999
08/04/88
- 1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Hank Thompson, ESD
Memorandum and Attachment
Re: CLP Sample Bottle Repository Authorization
001000 - 001001
08/04/88
2
Dennis C. Cossey, Executive Vice President
Innotek Corporation
Steve Gilrein, Chief, ALONM/Remedial Section, U.S. EPA Region
6
Correspondence
RE: In Situ Vitrification
001002 - 001002
08/09/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Dave Stockton, CLP/DPO, Houston Branch, U.S. EPA Region 6
Memorandum
Re: CLP Detection Limits for Dioxins and Furans.
001003 - 001269
08/12/88
267
Robert A. Lombard, Jr., Program Manager
Peer Consultants, P.C.
U.S. EPA Region 6 Site Files
Report
Final Work Plan for Rogers Road Landfill RI/FS Jacksonville,
AR, Vol. 1 - Technical, (Vol. 2 - Cost, Health & Safety Plan)
18
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SITE NUMBER:
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RECIPIENT:
DOCUMENT TYPE:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001270 - 001270
08/22/88
- 1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Ben Chavez, Inter-Agency Agreement (IAG) Coordinator,
Management Division, U.S. EPA Region 6
Memorandum
Re: Jacksonville Landfill and Rogers Road Landfill, IAG
001271 - 001271
09/09/88
1
Martin Swanson, RPM
U.S. EPA Region 6
Dave Stockton, CLP/DPO, U.S. EPA Region 6
Memorandum
RE:: CLP Detection Limits for Dioxins and Furans
001272 - 001275
09/14/88
4
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Seth Low, Office of Regional Counsel (ORC), U.S. EPA Region 6
Memorandum
Re: Access Agreements for Investigations at the Jacksonville
and Rogers Road Landfill Sites
001276 - 001279
09/19/88
4
David Rosa, Site Manager
Resource Applications, Inc. (RAI)
Martin Swanson, RPM, ALONM Remedial Section, U.S. EPA Region 6
Correspondence
Re: Property Ownership Search Information for the proposed
monitoring well and soil sampling locations recently collected
for properties around Rogers Road Landfill sites
19
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SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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COMPANY/AGENCY:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001280 - 001280
09/30/88
- 1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Duane Reel, Jacksonville City Engineer, Jacksonville, AR
Record Of Communication
Re: Fence replacement at the Rogers Road Landfill site
001281 - 001285
10/07/88
5
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Vincent Gonzles, Contract Officer (CO), Contracts and'
Procurement Mgmt. Division, U.S. EPA Region 6
Memorandum
Re: Technical Direction Memorandums Pertaining to the
Jacksonville and Rogers Road Landfill sites to allow for
reallocation of previously approved funds.
001286 - 001286
10/17/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Suzette Turner, Compliance Section, U.S. EPA Region 6
Memorandum
Re: Missing Fence at the Rogers Road Landfill Site - summary
of 09/20/88 telephone conversation with Duane Reel regarding
approval of funds to replace the fence.
001287 - 001287
10/20/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Myra Perez, CLP Coordinator, U.S. EPA Region 6
Correspondence
Re: Copies of sample request forms for the Jacksonville and
Rogers Road Landfill sites. Sampling & shipping dates are
11/07 - 11/12 and additional sampling through the end of
12/88.
20
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001288 - 001290
10/20/88
. 3
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Addressees Listed
Correspondence
Re: Consent to access a portion of addressees property so EPA
and its contractors can proceed with the the investigation
activities at the Rogers Road Landfill
001291 - 001292
10/24/88
2
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Myra Perez, CLP Coordinator, U.S. EPA Region 6
Memorandum
Re: Sample request forms for the Jacksonville and Rogers Road
Landfill sites, sampling and shipping dates are 11/14-19/88.
001293 - 001296
10/26/88
4
Myra Perez, CLP Coordinator
U.S. EPA Region 6
Jeb Livingood, U.S. EPA Regio 6 Memorandum
Memorandum
RE: Special Analytical Services (SAS) request forms -
Sampling event 11/07/88 to 12/19/88
001297 - 001298
10/31/88
2
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Jimmy Wright, Jr., Little Rock, AR
Correspondence
Request consent to access a portion of Mr. Wright's property
so investigation activities by EPA and its contractors can
proceed at the Rogers Road Landfill
21
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
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AUTHOR:
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NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001299 - 001299
11/02/88
- 1
Bob Bland
Arkansas Alliance
Ellen Greeney, Community Relations, U.S. EPA Region 6
Record of Communication (ROC)
RE: Tours of Jacksonville and Rogers Road Landfill
001300 - 001303
11/07/88
4
Myra Perez
U.S. EPA Region 6
Brian Burgess, U.S. EPA Region 6
Report
Weekly sample report 11/07/88 - 11/12/88
001304 - 001304
11/07/88
1
Martin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Doice Hughes, ADPC&E
Correspondence
Re: Remedial activities at the Jacksonville and Rogers Road
Landfill sites from 11/7-12/88. Contractors will conduct
thorough investigation to determine nature and extent of
contamination
001305 - 001316
11/07/88
12
Martin Swanson, RPM
U.S. EPA Region 6
David Rosa, RAI
Correspondence and Attachments
RE: Access Agreements
22
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
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DOCUMENT NUMBER:
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AUTHOR:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001317 - 001317
12/12/88
, 1
M'artin Swanson, RPM, ALONM Remedial Section
U.S. EPA Region 6
Bob Lombard, Peer Consultants, P.C.
Correspondence
CLP Sampling Schedule
001318 - 001318
12/16/88
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
John Wicklund, U.S. EPA Region 6
ROC
Replacement of Fence at the Rogers Road Landfill Site
001319 - 001320
12/16/88
2
Robert A. Lombard, Program Manager
Peer Consultants, P.C.
Martin Swanson, RPM, ALOMN Remedial Section, U.S. EPA Region 6
Correspondence
CLP Sampling Schedule
001321 - 001321
01/12/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Myra Perez, CLP Coordinator, U.S. EPA Region 6
Memorandum
CLP to mail results to Resource Applications Inc.
23
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SITE NUMBER:
DOCUMENT NUMBER:
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DOCUMENT TYPE:
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AUTHOR:
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AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001322 - 001323
02/24/89
. 2
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Jeff Parks, Peer Consultants, P.C.
Correspondence
RI/FS status meeting
001324 - 001324
02/28/89
1
Jon Rauscher, Toxicologist
U.S. EPA Region 6
Teresa Hoffman, PEER Consultants, P.C.
ROC
RE: Risk Assessment Assumption for a 6-12 year old child
001325 - 001326
03/01/89
2
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Site Status Update
Update for Rogers Road and Jacksonville Municipal Landfill
001327 - 001329
03/15/89
3
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Tom Simmons, Corps of Engineers
ROC
Site background information
24
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ADMINISTRATIVE RECORD INDEX
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SITE NUMBER:
DOCUMENT NUMBER:
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RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
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AUTHOR:
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RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001330 - 001330
03/20/89
- 1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Dave White, Chief, Automatic Data Procvessing (ADP) Section,
U.S. EPA Region 6
Memorandum
CLP/ADP user accounts for PEER Consultants
001331 - 001331
03/29/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Tom Simmons, Corps of Engineers
Transmittal Letter
Transmittal of RI/FS Study Work Plans for Rogers Road
001332 - 001332
03/30/89
1
Bob Wassmann
PEER Consultants
Martin Swanson, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for slides and prints taken during the
first round of sampling at the Jacksonville and Rogers Road
Lanfill (no attachments)
001333 - 001333
04/03/89
1
Martin Swanson, RPM
U.S. EPA Region 6
Doice Houghes, ADPC&E
Transmittal Letter
Dioxin analytical results from the Jacksonville Landfill and
Rogers Road Landfill projects (no Attachments)
25
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DOCUMENT NUMBER:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001334 - 001334
04/04/89
- 1
Martin Swanson, RPM
U.S. EPA Region 6
Pat Hanmack, Emergency Response Branch, U.S. EPA Region 6
Transmittal Memorandum
RE: Analytical results from the Jacksonville Landfil and
Rogers Road Landfill
001335 - 001335
04/06/89
1
Robert A. Lombard, Jr, Program Manager
Peer Consultants, P.C.
Helen Newman, Regional Project Officer, U.S. EPA Region 6
Correspondence
Assignment of RAI as Feasibility Study Contractor
001336 - 001340
04/14/89
5
David S. Rosa, Site Manager
RAI
Martin Swanson, RPM, ALOMN Remedial Section, U.S. EPA Region 6
Correspondence
Phase 2 - Groundwater and Air Sampling
001341 - 001348
04/18/89
8
Myra I. Perez, Primary Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Sampling Analyses
Sampling results for 05/08/89 and 05/15/89
26
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001349 - 001349
04/18/89
. 1
Myra I. Perez, Primary Coordinator
U.S. EPA Region 6
Diane Cutler, Coordinator, Sample Management Office, U.S. EPA
Region 6
Memorandum
Soil testing requirements
001350 - 001350
04/27/89
1
Freddy D. Gentry
Property Owner, Rogers Road Landfill
Freedom of Information Officer
Correspondence
Consent was given EPA to access property to investigate,
monitor, and test for contamination on 10/13/88
001351 - 001352
05/01/89
2
Mike Wilson
Jacksonville People With Pride Cleanup Coalition
U.S. EPA Region 6 Site Files
Superfund Fact Sheet
Technical assistance grant awarded
001353 - 001360
05/08/89
8
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Sampling Results
Analysis for Polychlorinated Dioxins and Furans - CLP Analyses
27
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DOCUMENT DATE:
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AUTHOR:
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DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TYPE:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001361 - 001362
05/22/89
- 2
Myra I. Perez, Primary Coordinator
U.S. EPA Region 6
Brian Burgess, U.S. EPA Region 6
Weekly Sample Report
Report for 05/15/89 - 05/20/89
001363 - 001364
05/24/89
2
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Robert Lombard, PEER Consultants
Correspondence
CLP shipping, well installation cleaning
001365 - 001365
05/25/89
1
Russell F. Rhoades, Director, Environmental Services Division
U.S. EPA Region 6
Allyn Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Transmittal Memorandum
Transmittal for follow-up on Rogers Road/Jacksonville Landfill
Issues (no attachment)
001366 - 001366
05/26/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Freddy Gentry, Property Owner, Rogers Road Landfill
Record of Communication
Re: Request for analytical results
28
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001367 - 001369
05/26/89
- 3
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
James White, Chairman, Bayou Two Water Users Association
Correspondence
City water usage
001370 - 001395
05/31/89
26
Office of Waste Programs Enforcement
U.S. EPA Headquarters
U.S. EPA Region 6 Site Files
Compendium and Users Manual
"Compendium of CERCLA Response Selection Guidance Documents
Users Manual"
001396 - 001396
05/31/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Freddy Gentry, Property Owner, Rogers Road Landfill
Record of Communication
Re: Property damage at the Rogers Road Landfill site
001397 - 001397
06/02/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Freddy Gentry, Property Owner, Rogers Road Landfill
Response to FOIA
Re: Sampling activities at the Rogers Road Landfill site
29
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SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001398 - 001398
06/06/89
- 1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Dave Rosa, RAI
Correspondence
Property owner at the Rogers Road Landfill site requests that
property damage be repaired
001399 - 001399
06/07/89
1
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Russell F. Rhoades, Director, Environmental Services Division,
U.S. EPA Region 6
Memorandum
RE: Site security; runoff
001400 - 001400
06/09/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Doice Hughes, ADPC&E
Correspondence
Request for State Applicable or Relevant and Appropriate
Regulations (ARARs)
001401 - 001403
06/09/89
3
Carl R. Hickam, R.S.
ATSDR/ROHR Region 6
Martin Swanson, RPM,
Memorandum
Health Consultation
, Senior Regional Representative
ALOMN Remedial Section, U.S. EPA Region 6
30
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SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001404 - 001405
07/01/89
' 2
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Superfund Update
Jacksonville Landfill and Rogers Road Landfill
001406 - 001418
07/06/89
13
Dave Rosa
RAI
Martin Swanson, RPM, ALOMN Remedial Section, U.S. EPA'Region 6
Memorandum
Preliminary Risk Assessment results
001419 - 001419
07/11/89
1
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
EPA Announcement
Open House 07/11/89 - Ramada Inn in Jacksonville, AR
001420 - 001420
07/13/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Dave Rosa, RAI
Record of Communication
Conference call for RI/FS meeting
31
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001421 - 001421
07/18/89
- 1
David Gray, On-Scene Coordinator
U.S. EPA Region 6
Martin Swanson, RPM, ALOMN Remedial Section, U.S. EPA Region 6
Memorandum
Review of sample results
001422 - 001422
07/25/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Duane Reel, City Engineer, City of Jacksonville, AR
Correspondence
Warning signs at the site
001423 - 001423
08/17/89
1
Martin Swanson, RPM, ALOMN Remedial Section
U.S. EPA Region 6
Tom Simmons, U.S. Army Corps of Engineers
Correspondence
Sampling activities nearly complete - preliminary evaluations
indicate that none of the adjacent residential areas have been
contaminated
001424 - 001459
11/30/89
36
Stephen A. Veale, RPM
U.S. EPA Region 6
Robert Lombard, Jr., PEER Consultants
Correspondence and Attachment
RE: Comments on the Jacksonville Landfill Superfund Site
Draft Remedial Investigation Report (October 1989)
32
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, Program Manager
EPA Region 6
ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001460 - 001460
11/30/89
. 1
Robert A. Lombard, Jr.
PEER Consultants
Steve Veale, RPM, U.S.
Correspondence
Transmittal letter for the Draft Remedial Investigation and
Risk Assessment Reports
001461 - 001462
12/01/89
2
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Site Update
RE: Remedial Investigation; Opportunities for involvement
001463 - 001463
12/19/89
1
Steve Veale, RPM
U.S. EPA Region 6
Myra Perez, Regional Sample Control Coordinator, U.S. EPA
Region 6
Memorandum
RE: Missing CLP Data Jacksonville and Rogers Road Landfill
Superfund Sites, Jacksonvill, Arkansas
001464 - 001465
12/20/89
2
Myra I. Perez, Primary Coordinator
U.S. EPA Region 6
Diane Cutler, Region 6 Coordinator, Sample Management Office,
U.S. EPA Region 6
Memorandum and Attachment
RE: Attached memo from Steve Veale concerning missing CLP
data was received today
33
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
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RECIPIENT:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001466 - 001466
12/28/89
- 1
Jon Rauscher
EPA Toxicologist
Teresa Haffman, PEER Consultants
Record of Communication
RE: Risk Assessment Assumptions for a 6-12 year old child for
Jacksonville Landfill site
001467 - 001493
01/10/90
27
Stephen A. Veale, RPM
U.S. EPA Region 6
Robert Lombard, Jr., Project Manager, PEER Consultants, P.C.
Correspondence and Attachment
Comments on the Rogers Road Landfill site draft RI Report,
dated 11/01/89
001494 - 001525
01/12/90
32
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Program Manager, PEER Consultants,
P.C.
Correspondence and Attachment
EPA' s comments on the Rogers Road Landfill site draft Risk
Assessment Report dated 11/01/89
001526 - 001526
01/22/90
1
Steve Veale, RPM
U.S. EPA Region 6
Dave Rosa, Resource Applications, Inc.
Correspondence
RE: Removal Strategy
34
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001527 - 001529
01/26/90
- 3
Doice Hughes, Manager, Superfund Program, Hazardous Waste
Division
ADPC&E
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal of State Environmental Regulations for ARARs
001530 - 001533
01/29/90
4
Don R. Clay, Assistant Administrator
EPA Headquarters
Regional Administrators, Regions 1-10
Memorandum
RE: Twenty First Remedy Delegation Report
001534 - 001537
02/06/90
4
David S. Rosa, P.E., Site Manager
Resource Applications, Inc.
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
RE: Post Remedial Investigation Site Conditions
001538 - 001538
02/13/90
1
Steve Veale, RPM
U.S. EPA Region 6
Doice Hughes, ADPC&E
Correspondence
RE: EPA requires a concise summary of ARARs which apply to
the Jacksonville and Rogers Road Sites
35
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
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AUTHOR:
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RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001539 - 001539
02/16/90
' 1
Robert A. Lombard, Project Manager
Peer Consultants, P.C.
Steve Veale, RPM, U.S. EPA Region 6
Corrspondence
Cover letter for Risk Assessment (no attachment)
001540 - 001547
03/01/90
8
Stephen A. Veale, RPM
U.S. EPA Region 6
Robert Lombard, Jr., Peer Consultants, P.C.
Correspondence and Attachment
Comments on the Rogers Road Landfill site draft RI Report
dated 02/01/90
001548 - 001550
03/14/90
3
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Program Manager, PEER Consultants,
P.C.
Correspondence and Attachment
EPA' s comments on the Rogers Road Landfill site draft Risk
Assessment Report dated 02/01/90
001551 - 001778
04/01/90
228
Staff
PEER Consultants
U.S. EPA Region 6 Site Files
Report
Risk Assessment for Rogers Road Landfill Site
36
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001779 - 001779
04/11/90
- 1
Robert A. Lombard, Jr.
PEER Consultants, P.C.
, Program Manager
EPA Region 6
Steve Veale, RPM, U.S.
Correspondence
Transmittal letter for the Draft Feasibility Study Report
001780 - 001789
04/12/90
10
Robert A. Lombard, Jr., Program Manager
PEER Consultants, P.C.
Steve Veale, RPM, U.S. EPA Region 6
Correspondence and Attachment
Sampling Plan for Contamination Mapping for the Jacksonville
and Rogers Road Landfill
001790 - 001790
04/12/90
1
Robert A. Lombard, Jr., Program Manager
PEER Consultants, P.C.
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
Transmittal letter for the Final Draft Risk Assessment report
001791 - 001791
04/27/90
1
Robert A. Lombard, Jr.
PEER Consultants, P.C.
Steve Veale, RPM, U.S.
Correspondence
Transmittal letter for the revised RI report for the Rogers
Road Landfill
, Program Manager
EPA Region 6
37
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TYPE:
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ADMINISTRATIVE RECORD INDEX
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001792 - 001797
04/27/90
- 6
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Program Manager, PEER Consultants,
P.C.
Correspondence and Attachment
EPA's comments on the Rogers Road Municipal Landfill site
draft Feasibility Study dated 04/11/90
001798 - 001799
05/01/90
2
Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Fact Sheet
RE: Results of the Remedial Investigation; upcoming site work
001800 - 001802
05/09/90
3
Robert A. Lombard, Jr., Program Manager
PEER Consultants, P.C.
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
RE: Report and Subcontract Documents for the Rogers Road and
Jacksonville Landfill Sites RI/FSs
001803 - 001805
05/29/90
3
Sam Becker, Chief, Superfund Enforcement Branch
U.S. EPA Region 6
Edwin K. Gray, Chief, Emergency Response and Consultation
Branch, U.S. EPA Region 6
Correspondence
Follow-up to 05/03/90 meeting in Atlanta with regard to
Vertac, Jacksonville Landfill and Rogers Road Landfill
Superfund Sites
38
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
ROGERS ROAD LANDFILL
ARD 981055809
001806 - 002111
06/01/90
306
Staff
PEER Consultants
U.S. EPA Region 6 Site Files
Report
Remedial Investigation Report for the Rogers Road Landfill
Site
002112 - 002116
06/07/90
5
Steve Veale, RPM
U.S. EPA Region 6
Robert A. Lombard, Jr., Program Manager, PEER Consultants,
P.C.
Correspondence and Attachment
RE: EPA's comments on the Rogers Road Landfill draft
Feasibility Study Report dated 05/31/90
002117 - 002119
06/11/90
3
Edwin Kent Gray, Chief, Emergency Response and Consultation
Branch
Agency for Toxic Substances and Disease Registry (ATSDR)
Sam Becker, Chief, Superfund Enforcement Branch, U.S. EPA
Region 6
Correspondence
Request for ATSDR to approve the Remedial Plans for the
Vertac, Jacksonville/Rogers Road Landfill Superfund Sites
002120 - 002120
06/19/90
1
Barbara J. Goetz, Congressional Liaison
U.S. EPA Region 6
Ken Smith, Special Assistant for Natural and Cultural
Resources, Governor' s Office
Correspondence
Scheduled meeting with the Arkansas Congressional delegation
39
-------
ADMINISTRATIVE RECORD INDEX
FINAL
SITE NAME: ROGERS ROAD LANDFILL
SITE NUMBER: ARD 981055809
DOCUMENT NUMBER: 002121 - 002121
DOCUMENT DATE: 06/20/90
NUMBER OF PAGES: " 1
AUTHOR: Robert A. Lombard, Jr., Program Manager
COMPANY/AGENCY: PEER Consultants
RECIPIENT: Steve Veale, RPM, U.S. EPA Region 6
DOCUMENT TYPE: Correspondence
DOCUMENT TITLE: Transmittal for page revisions to the Remedial Investigation
Report
DOCUMENT NUMBER: 002122 - 002122
DOCUMENT DATE: 06/26/90
NUMBER OF PAGES: 1
AUTHOR: Robert A. Lombard, Jr., Program Manager
COMPANY/AGENCY: PEER Consultants
RECIPIENT: Steve Veale, RPM, U.S. EPA Region 6
DOCUMENT TYPE: Correspondence
DOCUMENT TITLE: Transmittal letter for the Final Remedial Investigation & Risk
Assessment Reports for the Rogers Road/Jacksonville Landfills
40
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME: ROGERS ROAD LANDFILL
SITE NUMBER: ARD 981055809
INDEX DATE: 10/02/90
-------
I. CHRONOLOGICAL LISTING
*****************************************************************************
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ADMINISTRATIVE RECORD INDEX
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DOCUMENT DATE:
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RECIPIENT:
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DOCUMENT TITLE:
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AUTHOR:
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RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000009 - 000009
06/25/90
0*01
Steve Veale, RPM
U.S. EPA Region 6
Bob Lombard, PEER Consultants
ROC
RE: Resampling the Ditch at Rogers Road
000010 - 000010
06/26/90
1
Robert A. Lombard, Jr.
PEER Consultants, P.C.
, Program Manager
EPA Region 6
Steve Veale, RPM, U.S.
Transmittal Letter
RE: Transmittal for Final RI and Risk Assessment Reports
000011 - 000026
07/01/90
16
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Proposed Plan
EPA announces Proposed Plan for the remedial action at the
Site
000027 - 000027
07/09/90
1
Robert A. Lombard, Jr.
PEER Consultants, P.C.
Steve Veale, RPM, U.S.
Transmittal Letter
RE: Transmittal for the Draft Final FS Report
, Program Manager
EPA Region 6
A-2
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SITE NUMBER:
DOCUMENT NUMBER:
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DOCUMENT DATE:
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COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000001 - 000004
07/30/87
4'
Barry L. Johnson, Ph.D., Associate Administrator
ATSDR
David Wagoner, Director, Waste Management Division, U.S. EPA
Region 7
Correspondence
Response to request for elaboration on the mathematics
underlying the development of support for the 20 ppb cleanup
level for certain Missouri dioxin sites
000005 - 000006
05/22/90
2
Steve Veale, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
RE: Meeting with ADPC&E
000007 - 000007
06/07/90
1
Bert Cooper
ATDCR
Sam Becker, U.S. EPA Region 6
ROC
RE: Letter to EPA from ATSDR regarding approval of EPA's
proposed remedies for the site
000008 - 000008
06/19/90
1
Barbara Goetz, Congressional Liaison
U.S. EPA Region 6
Ken Smith, Special Assistant for Natural & Cultural Resources,
Governor's Office, State Capitol
Correspondence
RE: Confirmation for meeting scheduled 06/26/90 in the
Governor' s Conference room
A-l
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SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000157 - 000272
07/26/90
116
Robert A. Lombard, Jr.
PEER Consultants, P.C.
Steve Veale, RPM, U.S.
Technical Memorandum
Draft Technical Memorandum for contaminant mapping at the
Jacksonville Landfill and Rogers Road Landfill
000273 - 000273
07/29/90
1
Robert A. Lombard, Jr.
PEER Consultants, P.C.
Steve Veale, RPM, U.S.
Transmittal Letter
RE: Transmittal for Final Draft Feasibility Study Report
, Program Manager
EPA Region 6
, Program Manager
EPA Region 6
000274 - 000275
07/30/90
2
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
D.J. Keilman, Director, Environmental Affairs, Hercules,
Incorporated
Correspondence
RE: Response to request for 60 day extension to the public
comment periods for the Feasibility Studies and Proposed Plans
of action for the sites
000276 - 000276
08/03/90
1
Mike Bates, Chief, Hazardous Waste Division
ADPC&E
Carl Edlund, U.S. EPA Region 6
Correspondence
"Extension Request of Comment Period"
A-4
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AUTHOR:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000028 - 000151
07/18/90
1-24
Patricia Hendrix
Hendrix Reporting Service
U.S. EPA Region 6 Site Files
Public Meeting Transcript
Transcript of public meeting held regarding Jacksonville and
Rogers Road Landfills proposed plan
000152 - 000152
07/20/90
1
Henry Smith
Jacksonville Resident
Steve Veale, RPM, U.S. EPA Region 6
ROC
Landfill Operator Personal Observations
000153 - 000154
07/23/90
2
Bill Wright
Operating Engineers Local 38
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
Question regarding site contractor' s qualifications
000155 - 000156
07/23/90
2
D.J. Keilman, Director, Environmental Affairs
Hercules, Incorporated
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Correspondence
RE: Request for 60 day extension to the public comment period
for the FS
A-3
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000283 - 000283
08/13/90
t
Betty Williamson, Chief, Superfund Management Branch
U.S. EPA Region 6
Ms. Kelly Jones, Resident, Mayflower, AR
Correspondence
RE: Request from citizen to sample her yard for dioxin
000284 - 000285
08/14/90
2
M. Blackman
PEER Consultants, Inc.
U.S. EPA Region 6 Site Files
Sampling Information
Recalculation of Health Risks Presented by the Jacksonville
and Rogers Road Landfills (Excluding "Hot Spots")
000286 - 000286
08/20/90
1
Wally Tucker, General Manager
KEZQ Radio Station
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments regarding the dioxin burn
000287 - 000290
09/01/90
4
Tim Herrin
Resident of Cabot
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments on the dioxin burn
A-6
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000277 - 000279
08/10/90
3-
James R. Weber, M.D.
Resident of Jacksonville
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
Comments regarding the dioxin burn at the site
000280 - 000280
08/13/90
1
Mr. & Mrs. Ronald L. Knight
Residents of Jacksonville, AR
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments on dioxin burn at the site
000281 - 000281
08/13/90
1
Nicholas P. Kohut
Resident of Jacksonville
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
RE: Comments regarding the dioxin burn
000282 - 000282
08/13/90
1
S. Andres
Resident of Jacksonville
Carl E. Edlund, Chief, Superfund Program, U.S. EPA Region 6
Correspondence
RE: Comments regarding the dioxin burn at the site
A-5
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COMPANY/AGENCY:
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000445 - 000447
09/07/90
3
Mike Bates, Chief, Hazardous Waste Division
ADPC&E
Steve Veale, RPM, U.S. EPA Region 6
Correspondence
RE: Review comments of the Proposed Remedial Plan
000448 - 000448
09/10/90
1
Randall Mathis, Director
ADPC&E
Allyn M. Davis, Director, Hazardous Waste Section, U.S. EPA
Region 6
Correspondence
RE: Comments on Proposed Plan for the "offsite" superfund
sites
000449 - 000451
09/18/90
003
Stephen A. Gilein, Chief, ALNM, Remedial Section
U.S. EPA Region 6
Mike Bates, Solid and Hazardous Waste Division, ADPC&E
Correspondence
RE: Response to ADPC&E's 09/07/90 comments regarding proposed
plans
000452 - 000452
09/24/90
001
Stephen A. Gilrein, Chief, ALNM Remedial Section
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
RE: State concurrence with proposed remedy at Jacksonville
and Rogers Road Landfills
A-8
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
ROGERS ROAD LANDFILL
ARD 981055809
000291 - 000292
09/05/90
002
Nancy Bailey
Resident
U.S. EPA Region 6 Site Files
Letter
RE: Incineration at the sites
000293 - 000442
09/05/90
150
Staff
ChemRisk
Hercules, Inc.
Report
Establishing Acceptable Levels of TCDD in Residential and
Industrial Soils
000443 - 000443
09/06/90
1
Donna C. Hartzell
Resident of Cabot
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspodence
Comments regarding dioxin burn at the site
000444 - 000444
09/06/90
1
Kathy Copas
Resident of Cabot
Ellen Greeney, Community Relations Coordinator, U.S. EPA
Region 6
Correspondence
Comments regarding dioxin burn at the site
A-7
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME: ROGERS ROAD LANDFILL
SITE NUMBER: ARD 981055809
DOCUMENT NUMBER: 000453 - 000569
DOCUMENT DATE: 09/27/90
NUMBER OF PAGES: 117
AUTHOR: Robert Layton, Regional Administrator
COMPANY/AGENCY: U.S. EPA Region 6
RECIPIENT: U.S. EPA Region 6 Site Files
DOCUMENT TYPE: Record of Decision
DOCUMENT TITLE: Rogers Road Landfill Record of Decision
A-9
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