United States Office of
Environmental Protection Emergency and
Agency Remedial Response
£EPA Superfund
Record of Decision:
EPA/ROD/R06-92/070
June 1992
PB93-964202
Mosley Road Sanitary
Landfill, OK
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document. All supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-92/070
3. Recipient* Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Mosley Road Sanitary Landfill, OK
First Remedial Action - Final
5. Report Date
06/29/92
7. Authors)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. ProjectfTaskWorkUnltNo.
11. Contraet(C)orGrant(G)No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Note*
PB93-964202
1E. Abstract (Limit 200 words)
The 72-acre Mosley Road Sanitary Landfill site is an inactive municipal landfill in
Oklahoma City, Oklahoma County, Oklahoma. Land use in the area is primarily
residential and undeveloped with 875 residents within a one-mile radius of the site.
The North Canadian River flows about one-half mile west of the site, and Crutcho Creek
flows near the eastern boundary of the site. The site overlies two aquifers: an
alluvial aquifer, and the Garber-Wellington aquifer, which is a source of drinking
water for three cities near the landfill. Both of these ground water areas have been
impacted by migration of landfill contaminants. Several wetland areas are located in
the vicinity of the landfill. In 1973, the site was permitted as a sanitary landfill,
and between February and August 1976 the state authorized the landfill to accept
industrial hazardous waste. During this 6-month period, the Mosley Road Sanitary
Landfill accepted approximately 1.7 million gallons of mostly liquid industrial
hazardous waste. Types of wastes included industrial sludge, caustic material,
plating sludge, acid solutions, oil emissions, alkaline solutions, solvents, paint
sludge, toxaphene, and TCE. Waste was deposited into unlined waste pits, which are
currently buried under 80 feet of municipal refuse. In 1987, the landfill reached its
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Mosley Road Sanitary Landfill, OK
First Remedial Action - Final
Contaminated Media: Soil, gw
Key Contaminants: VOCs (benzene, vinyl chloride), metals (arsenic)
fa. Identffiers/Open-Ended Terms
c. COSAT1 Field/Group
IS. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
140
22. Price
(SeeANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTB-35)
Department of Commerce
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EPA/ROD/R06-92/070
Mosley Road Sanitary Landfill, OK
First Remedial Action - Final
stract (Continued)
permitted capacity and was closed. In 1988, a compacted clay cover was installed in
accordance with existing closure regulations, and the area was vegetated to reduce
erosion. This ROD addresses the source(waste pits) and the contaminated ground water as
a final remedial action for this site. The primary contaminants of concern affecting the
soil and ground water are VOCs, including benzene, PCE and TCE; other organics, including
PAHs and pesticides; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes repairing and improving the existing
cap with addition of a vegetative soil layer to reduce erosion and infiltration; allowing
ground water to naturally attenuate; installing a landfill gas monitoring system;
monitoring of leachate migration via ground water monitoring and periodic sampling; and
implementing institutional controls including deed, land and ground water use
restrictions. If sampling indicates that after 5 years natural attenuation has not
lowered levels of contaminants, a contingent remedy is planned consisting of active
ground water extraction and treatment. The estimated present worth cost for this
remedial action is $3,600,000. O&M costs are not provided for this remedial action.
PERFORMANCE STANDARDS OR GOALS: All potential drinking water impacted by the site will
meet SDWA MCLs. Chemical-specific goals for ground water include arsenic 0.05 mg/1,
barium 1 mg/1, manganese 0.05 mg/1, selenium 0.010 mg/kg, and vinyl chloride 0.002 rag/kg.
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RECORD OF DECISION
MOSLEY ROAD SANITARY LANDFILL
OKLAHOMA CITY, OKLAHOMA
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 6
JUNE 1992
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CONCURRENCE DOCUMENTATION
FOR THE
MOSLEY ROAD SANITARY LANDFILL RECORD OF DECISION
Site Remedial Project Manager
Monica Chapa Smith
ROD Peer/Review Committee
Representative
Cathy D. Gilmore
Office of "Regional Counsel
Site Attorney
Rachel H. Blumenfeld
Wxlliam|L. Luthans
Chief
OK/NM Superfund Enforcement
Section (6H-EO)
Sam Becker, Chief
Superfund Enforcement Branch (6H-E)
Mark A. Peycke
Chief
ALON Section (6C-WA)
M. Davis, Director
Hazardous Waste Management
Division (6H)
George Alexander, Jr.
Regional Counsel (6C)
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SITE NAME AND LOCATION
Mosley Road Sanitary Landfill Site
Oklahoma City, Oklahoma
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Mosley Road Sanitary Landfill Site, in Oklahoma City,
Oklahoma developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act, as
amended by SARA, ("CERCLA"), 42 U.S.C. §9601 et sea..and to
the extent practicable, the National Contingency Plan. This
decision is based on the Administrative Record for this Site.
The State of Oklahoma concurs 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 ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE REMEDY
The Site is being handled as one operable unit, at which both
the source of the contamination (the waste pits) and the
contaminated ground water are being addressed. The existing
clay cap will be improved to further eliminate/reduce
infiltration of precipitation into the landfill. This will
also eliminate the risk of direct contact with any waste in
the landfill. The function of the long-term ground water
monitoring -program, institutional controls and landfill
maintenance are to 1) prevent human and animal exposure to
and ingestion of contaminated ground water, 2) collect data
regarding migration of contamination in both the alluvial and
Garber-Wellington aquifers to aid in determining whether
certain contingency measures should be implemented in order to
prevent further contamination of either aquifers, and 3) to
restore the alluvial aquifer to beneficial use through the
process of natural attenuation.
The major components of the selected remedy include:
Institutional Controls: land use restrictions, access
restrictions, posting of signs, fencing, and restrictions
on the extraction and use of ground water from Site water
wells;
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- Restoration of ground water as a potential source of
drinking water through the process of natural
attenuation;
Continued ground water monitoring to determine if current
conditions improve through time, remain constant, or
worsen;
Implementation of active ground water extraction, if
necessary, in accordance with the contingency measure
criteria;
Monitoring of leachate migration via ground water
monitoring and periodic sampling;
Implementation of a landfill gas monitoring' system to
prevent explosion or inhalation hazards;
Repair and improvement of the existing cap and addition
of a vegetative soil layer to reduce erosion and
infiltration.
Contingency Measures
If it is determined that contingency measures are needed to address
contamination in the ground water, EPA may require implementation
of further response actions consistent with the following:
Installation of additional monitoring wells to determine
if the natural attenuation remedy is failing based on the
contingency measure criteria. If the contingency measure
criteria are exceeded, begin extracting the contaminated
water to facilitate or accelerate cleanup of the
contamination.
- Submittal of a Remedial Action Plan describing a plan for
the extraction, treatment or disposal of contaminated
ground water in order to achieve state and Federal
standards.
- Begin extracting and treating the contaminated ground
water until the concentrations are below the SDWA
standards, or if SDWA standards do not exist, until
concentrations are achieved which do not present an
excess cancer risk greater than IxlO*6, if technically
practicable. Discharge treated ground water to either a
POTW or to surface waters in compliance with ARARs.
STATUTORY DETERMINATIONS
The selected remedy and contingency measures are protective of
human health and the environment, comply with Federal and
state requirements that are legally applicable or relevant and
appropriate to the remedial action, and are cost-effective.
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A principal threat does not exist at the Site because no "hot
spots" of contamination were identified. Ground water.
contamination is sporadic, low level, and currently confined
to the Site. The current exposure poses a low level risk.
Therefore, treatment was not found to be necessary. Thus, the
selected remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy. The selected
remedy and the contingency measures utilize permanent
solutions and alternative treatment technologies to the
maximum extent practicable for this Site. The size of the
landfill and the fact that there are no on-site hot spots that
represent the major sources of contamination preclude
selecting a remedy in which contaminants of concern could be
excavated and treated effectively. However, the contingency
measures requiring active remediation, if implemented would
satisfy the statutory preference for remedies that employ
treatment and thus, reduce toxicity, mobility and volume as a
principal element.
Because the selected remedy and contingency measures will
result in hazardous substances remaining onsite above health
based levels, a review will be conducted within five years
after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human
health and the environment.
B.VJ. Wynne
Regional Administrator
Date
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DECISION SUMMARY
FOR THE
MOSLEY ROAD SANITARY LANDFILL SITE
OKLAHOMA CITY, OKLAHOMA
I. SITE NAME AND LOCATION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
IV. SCOPE AND ROLE OF RESPONSE ACTION 4
V. SITE CHARACTERISTICS 5
Regional Geology 5
Regional Hydrogeology . 6
Historic Site Operations and Potential Sources of
Contamination 6
Extent of Contamination 7
Air and Surface Soils 7
Surface Water /Sediments 7
Subsurface Soil and Ground Water 8
Exposure Routes 8
Surface Water and Sediment 11
Ambient Air 11
Ground Water 11
VI. SUMMARY OF SITE RISKS 11
Current and Future Health Risks 12
Impacts to the Environment 14
Toxicity Assessment . 16
Uncertainties Associated with the Human Health Risk
Calculations 19
Remediation Goals 20
VII. DESCRIPTION OF ALTERNATIVES 22
Capping Remedial Alternatives 23
Capping Alternative 1 23
Capping Alternative 2 24
Capping Alternative 3 24
GROUND WATER REMEDIAL ALTERNATIVES 24
Common Elements 25
Alternative 1 26
Alternative 2 26
Alternative 3 29
Alternative 3a 30
Alternative 4 30
Alternative 4a 31
Alternative 5 31
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Alternative 5a . . . . 32
Alternative 6 32
Alternative 6a 32
Alternative 7 . 33
Alternative 7a 33
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ... 33
CAPPING ALTERNATIVES 35
Overall Protection of Human Health and the
Environment 35
Compliance with ARARs 36
Long-Term Effectiveness and Permanence 36
Reduction of Toxicity, Mobility, and Volume Through
Treatment 36
Short-Term Effectiveness . . 36
Implementability 37
Cost 37
GROUND WATER ALTERNATIVES 37
Overall Protection of Human Health and the
Environment 37
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) . . 38
Chemical Specific ARARs 38
Action-specific ARARs 39
Location-specific ARARs 39
Short-term Effectiveness 40
Protection of Workers During Remedial
Actions 40
Environmental Impacts 41
Time Until Response Objectives Are Achieved . 42
Long-Term Effectiveness and Permanence 42
Reduction of Toxicity, Mobility, and Volume Through
Treatment 43
Implementability 44
Technical Feasibility 44
Administrative Feasibility 44
Cost 44
State Acceptance 44
Community Acceptance 45
IX. SELECTED REMEDY 45
SELECTED CAP IMPLEMENTATION 45
THE GROUND WATER MONITORING PROGRAM 46
Contingency Measure Criteria and Presumptive
Responses 47
Remediation Goals 48
X. STATUTORY DETERMINATIONS 49
Protection of Human Health and the Environment 50
Compliance with Applicable or Relevant and Appropriate
Requirements 51
Cost-Effectiveness 51
Utilization of Permanent Solutions and Alternative
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Treatment Technologies (or Resource Recovery
Technologies) to the Maximum Extent Practical ... 51
Preference for Treatment as a Principal Element .... 52
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 53
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LIST OF FIGURES
Figure 1 Site Area Map
Figure 2 Topography and Surface Drainage
Figure 3 Waste Pit Soil Sample Locations
Figure 4 Volatile Organics in Alluvial Ground Water
Figure 5 Garber-Wellington Monitoring Well Locations
Figure 6 Cancer Risk Estimates (Current Use)
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LIST OF TABLES
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
Table 12
Table 13
Industrial Wastes Reportedly Disposed in the Mosley Road Sanitary
Landfill
Surface Soils Data Summary Mosley Road Sanitary Landfill
Mosley Road Sanitary Landfill Sediment Data Summary
Surface Water Data Summary Mosley Road Sanitary Landfill
Alluvial Ground Water Data Summary Mosley Road Sanitary Landfill
Garber-Wellington Ground Water Data Summary Mosley Road
Sanitary Landfill
Mosley Road Sanitary Landfill Waste Pit Soils Analytical Results
Above Contract Required Quantitation Limit
Matrix Potential Human Exposure Pathways Mosley Road Sanitary
Landfill Current-Use Scenario
Matrix of Potential Human Exposure Pathways Mosley Road Sanitary
Landfill Future-Use Scenario
Noncarcinogenic Risks Via Year-Round Ingestion of Chemicals in
Alluvial Ground Water Mosley Road Sanitary Landfill
Carcinogenic Risks Via Year-Round Ingestion of Chemicals in
Alluvial Ground Water Mosley Road Sanitary Landfill
Noncarcinogenic Risks Via Year-Round Ingestion of Chemicals in
Garber-Wellington Ground Water Mosley Road Sanitary Landfill
Carcinogenic Risks Via Year-Round Ingestion of Chemicals in
Garber-Wellington Ground Water Mosley Road Sanitary Landfill
Table 14
Human Health Risk Summary Table Mosley Road Sanitary Landfill
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Table 15
Table 16
Table 17
Table 18
Table 19
Toxicity Values: Potential Noncarcinogenic Effects for Chemicals of
Potential Concern at Mosley Road Sanitary Landfill
Toxicity Values: Potential Carcinogenic Effects for Chemicals of
Potential Concern at Mosley Road Sanitary Landfill
Estimated Cost Range for Refined Remedial Alternatives
Comparative Analyses for Capping Remedial Alternatives Mosley
Road Sanitary Landfill
Comparative Analyses for Ground Water Remedial Alternatives
Mosley Road Sanitary Landfill
Table 20
Chemical, Action and Location Specific - Applicable or Relevant and
Appropriate Requirements Mosley Road Sanitary Landfill
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LIST OF ATTACHMENTS
Attachment 1 Responsivess Summary
Attachment 2 State of Oklahoma Concurrence Letter
Attachment 3 Administrative Record Index
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DECISION SUMMARY
FOR THE
MOSLEY ROAD SANITARY LANDFILL SITE
OKLAHOMA CITY, OKLAHOMA
I. SITS NAME AND LOCATION
The Mosley Road Sanitary Landfill ("Site" or "Landfill") consists
of approximately 72 acres in an undeveloped area near the boundary
of Oklahoma City and Midwest City, Oklahoma (Figure 1). The
Landfill is located between N.E. 23rd and N.E. 36th Streets at 3300
Mosley Road , Oklahoma City, Oklahoma County, Oklahoma. The East
Oak Landfill, which is currently.in operation, is located to the
west of the site. The Landfill is in an undeveloped area on the
eastern edge of Oklahoma City. Approximately 875 people live
within a 1 mile radius of the site. Within the 1 mile radius are
an elementary school and a nursing home. Populated areas
surrounding the Landfill include Midwest City to the east, Spencer
to the northeast, and Oklahoma City to the west.
The North Canadian River, a major perennial stream, flows from
southwest to northeast about 1/2 mile west of the Site. Crutcho
Creek, a perennial stream tributary to the North Canadian River,
flows from south to north near the eastern boundary of the
facility. Other surface water bodies near the Landfill include
North Pond, South Swamp, and an inactive sand and gravel operation
(Figure 2) . In addition, a small (approximately 1/2 acre)
sedimentation pond, referred to as the retention pond, is located
in the northeastern corner of the Landfill and collects surface
runoff from near the pond.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Mosley Road Sanitary Landfill was originally owned by Floyd
Swen and operated by A-l Sanitation Company. Waste Management of
Oklahoma, Inc. (WMO) is the current owner of the Site. The Landfill
was permitted as a sanitary landfill by the Oklahoma State
Department of Health ("OSDH") in June 1973. Between February 20,
1976, and August 24, 1976, the Landfill was authorized by OSDH to
accept industrial hazardous wastes, mostly liquid, which contained
hazardous constituents. The authorization from OSDH was the result
of the temporary closure of the Royal Hardage Landfill in Criner,
Oklahoma, which previously had been accepting the wastes. During
this 6 month time period, the Mosley Road Sanitary Landfill
accepted approximately 1.7 million gallons of mostly liquid
industrial hazardous waste. These included industrial sludge,
caustic material, plating sludge, acid solutions,, oil emulsions,
alkaline solutions, solvents, paint sludge, toxaphene, and
trichlorethylene. The majority of landfilling activities
occurred at elevations above the pre-existing ground surface.
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The Landfill was not designed to receive or handle hazardous waste,
and the hazardous waste was deposited in three unlined pits,.
referred to as the waste pits, at the Mosley Road Sanitary
Landfill. The waste pits currently are buried beneath up to 80
feet of municipal refuse.
The Mosley Road Sanitary Landfill operated for approximately
sixteen years prior to reaching its permitted capacity and being
closed in November 1987. A compacted clay cover was installed
over the Landfill in 1988 in accordance with existing regulations
governing Landfill closure. The cover has a minimum thickness of
three feet on top and two feet on the sides. Vegetation has been
established to reduce erosion and to promote evapotranspiration.
Maintenance of cover integrity and vegetation is being performed by
Waste Management of Oklahoma, Inc. on an on-going basis.
The Site was scored by the U.S. Environmental Protection Agency
(EPA) on February 6, 1987, using the Hazard Ranking System (HRS)
MITRE model. In 1988, the Mosley Road Sanitary Landfill was added
to the NPL, pursuant to Section 105 of the Comprehensive
Environmental. Response, Compensation, and Liability Act, as
amended, ("CERCLA"), 42 U.S.C. S9605, qualifying the Site for
investigation and remediation under CERCLA.
In 1989, EPA identified 35 potentially responsible parties ("PRPs")
for the Site. On January 12, 1989, EPA Region VI issued a General
Notice Letter for the Site. On March 24, 1989, EPA Region VI
issued a Special Notice letter regarding Remedial Investigation/
Feasibility study ("RI/FS") activities at the Site. All PRPs, with
the exception of WHO and Mobile Waste Controls, declined the
opportunity to participate in the RI/FS for the Site. On July 28,
1989, WMO and Mobile Waste Controls signed an Administrative Order
on Consent requiring the two companies to initiate RI/FS activities
at the Landfill. Investigative activities began at the Site in
January 1990. A phased approach to characterizing the nature and
extent of potential threats posed by releases from the industrial
hazardous waste was utilized. Three initial phases of the RI
included source characterization, physical characterization, and
contaminant character i z at i on.
The RI at the Site involved field sampling and testing of surface
soil, subsurface soil, sediment, storm water, site runoff, and air
at and near the Site. Ground water wells also were installed to
collect samples and to define subsurface conditions. The report
was completed in August 1991 and is entitled "Final Remedial
Investigation Report Mosley Road Sanitary Landfill."
The FS was completed in November 1991. This study describes a
range of alternatives to treat and contain contaminated soil and
ground water. Both the RI and the FS are available in the Site
Administrative Record.
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A Preliminary Natural Resource Survey vas conducted by the
Department of Interior ("DOI") in 1991 to determine if there were
any damages to natural resources. DOI indicated to EPA that there
is no evidence of direct injuries to natural resources under its
trusteeship, however, DOI stated that it felt that there are likely
historical and current indirect injuries in the immediate offsite
area. The environmental reconnaissance conducted during the RI
indicated that this was not the case. Further studies conducted as
part of the Remedial Design Phase will verify the situation. DOI
also has stated that the bald eagle and interior least tern, both
federally endangered species, also are found along the North
Canadian River in the Site area. During the Ecological Assessment
activities, it was determined that no endangered species are found
specifically at the Site.
III. HIGHLIGHTS OP COMMUNITY PARTICIPATION
The requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 117, 42
U.S.C. SS9613(k)(2)(B)(i-v) and 9617, were met during the remedy
selection process, as illustrated in the following discussion.
A series of community interviews near the Site was conducted prior
to and upon listing of the Site on the NPL. Fact sheets on the
Site progress were mailed out in December 1991, February 1990,
September 1989, June 1989, and August 1988. These fact sheets were
mailed out to all individuals on the Site mailing list, which has
.been continually updated as Site activities progress.
The RI and FS Reports and the Proposed Plan for the Mosley Road
site were released to the public on April 8, 1992. These documents
were made available to the public through the Administrative Record
and the information repositories maintained at the Robert Ellison
Library, Oklahoma State Department of Health Solid Waste Management
Services Office, City of Oklahoma City Public Works Department, and
EPA's Region 6 Library. A summary of the Proposed Plan and the
notice of availability of these documents and the Administrative
Record was published in the Daily Oklahoman on April 3, 1992. The
public comment period was from April 8, 1992 through Hay 8, 1992.
A request for an extension to the public comment period was made.
As a result, the public comment period was extended to June 8,
1992. -r-
An informal Open House was held on April 7, 1992 at the Crutcho
Creek Elementary School in Oklahoma City. Additionally, a public
meeting was held on April 23, 1992. Representatives from EPA and
OSDH participated in this meeting and answered questions about
problems at the Site and the remedial alternatives under
consideration. A response to the comments received during this
public comment period, including those expressed verbally at the
public meeting, is included in the Responsiveness Summary, which is
included as part of this Record of Decision ("ROD")(Attachment 1).
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This decision document presents the selected remedial action for
the Mosley Road Sanitary Landfill site, in Oklahoma City, Oklahoma,.
chosen in accordance with CERLCA, as amended by Superfund
Amendments and Reauthorization Act (SARA), and, to the extent
practicable, the National oil and Hazardous Substances Pollution
Contingency Plan ("NCP"), 40 CFR Part 300. The decision for this
Site is based on the Administrative Record. An index for the
Administrative Record is included as Attachment 3 to this ROD.
IV. SCOPE AMD ROLE OP RESPONSE ACTION
The studies undertaken at the Site have identified
the contaminated soils and sediments and the shallow ground water
as low level but significant long term threats. The contaminated
waste pit soils are a threat because of the soils' impact on ground
water. The contaminated shallow alluvial ground water is a low
level but significant long term threat at the site because of the
potential for exposure of the public to the Site contaminants via
ingestion of contaminated ground water and because of the threat of
migration of contaminants to deeper zones of ground water.
Contamination., at the Site exists in the alluvial aquifer,
immediately adjacent to the Landfill, at concentrations which
exceed EPA's acceptable risk range. No principal threats or hot
spots were identified at the Site.
The deeper ground water zones, the Garber-Wellington Aquifer, are
used for industrial, irrigation, and drinking water purposes.
Benzene has been detected in the Garber-Wellington aquifer, in the
immediate vicinity of the Landfill, at concentrations which
slightly exceed standards for drinking water prescribed by the Safe
Drinking Water Act (SDWA), but still well within EPA's acceptable
risk range. Benzene is a hazardous substance within the meaning of
CERCLA Section 101(14), 42 U.S.C. S 9601(14), and 40 CFR 3Q2.4.
Benzene has not been detected above Maximum Contaminant Levels
("MCLs") at or beyond the property boundary, and thus, human health
is not threatened by exposure to the Garber-Wellington under
current conditions.
Ground water monitoring data indicates that contamination has not
migrated the distance from the Landfill to monitoring wells located
in the alluvial or Garber-Wellington aquifers at the property
boundary in excess of either MCLs required by the SDWA or EPA's
acceptable risk levels for carcinogens.
The remedy to eliminate or minimize the threat from the Landfill
contents and this potential source of drinking water is included in
this Record of Decision and is addressed as one operable unit.
The remedial objectives for the Site are the following:
1. Prevent direct contact with and exposure to Landfill
contents through the use of clay cap and institutional
controls such as restrictions on future property use and
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restrictions on ground water use. Institutional controls
will include deed notices.
2. Control surface runoff and resulting erosion through a
continued landfill maintenance program. This also will
result in the reduction or elimination of leachate
formation within the Landfill and transport of
contaminants into the ground water.
3. Prevent inhalation of and explosion of landfill gas by
implementing a landfill gas monitoring program.
4. Prevent human and animal exposure to and ingestion of
contaminated ground water. This will be accomplished
through the long-term ground water monitoring, landfill
maintenance, institutional controls, and, if necessary,
implementation of contingency measures as described in
this ROD.
5. Prevent contamination of the Garber Wellington Aquifer
above health based risk levels. This will be accomplished
through the implementation of a monitoring program of
alluvial and Garber-Wellington wells. The program would
include contingencies for active remediation as described
in this ROD.
6. Restore the alluvial aquifer to beneficial use through
the process of natural attenuation.
This is the final ROD planned for the Mosley Road Sanitary Landfill
Site. It addresses source control and contaminated media,
including ground water.
V. SITE CHARACTERISTICS
The Landfill is predominantly an above-grade facility. The top of
the Landfill extends to an elevation of about 1230 feet above mean
sea level (MSL) . ' The surface of the Landfill was completed in a
manner which allows surface drainage to flow radially away from the
Site (Figure 2). Approximately 1.7 million gallons of mostly
liquid industrial hazardous waste were disposed of at the Landfill
between February and August of 1976. These included industrial
sludge, caustic material, plating sludge, acid solutions, oil
emulsions, alkaline solutions, solvents, paint sludge, toxaphene,
and trichlorethylene. The liquid industrial hazardous waste was
deposited in three unlined waste pits within the Landfill (see
Figure 3). The waste pits were surrounded by on-going sanitary
Landfill operations. The waste pits were subsequently covered with
fill dirt, municipal solid waste, and a low permeability clay cap.
Other potential sources of contamination near the Mosley Road
5
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Sanitary Landfill include pumping oil wells, underground storage
tanks, above-ground oil and gas storage tanks, and buried oil and
gas pipelines.
Regional Geology
The Site area geology consists of alluvium of the North Canadian
River overlying the bedrock unit referred to as the Garber-
Wellington formation. The alluvium is composed of unconsolidated
sediments deposited by the North Canadian River. The alluvium is
the uppermost of the two units and extends to an average depth of
approximately 40 feet below ground surface in this area. The
underlying Garber-Wellington formation is a consolidated unit
composed of sandstone, siltsone, and claystone. Portions of the
Garber-Wellington form an aquifer that is used as a source of
drinking water by Midwest City, Spencer, and Oklahoma City. The
maximum thickness of the Garber-Wellington formation is reported to
be approximately 900 feet.
Regional Hydrogeology
The North Canadian River, a major perennial stream, flows from
southwest to northeast about 1/2 mile west of the Site. Crutcho
Creek, a perennial stream tributary to the North Canadian River,
flows from south to north near the eastern boundary of the facility
(Figure 2). The Nosley Road Sanitary Landfill also is bounded by
three other surface water bodies. North Pond is located in a
depression north of the Landfill on Oklahoma City property that was
formerly utilized by the City as a soil borrow area. South Swamp
is located immediately south of the Site in an area that has been
used as a source of daily cover for an operating landfill west of
the Site. An inactive sand and gravel operation is located
southwest of the Site. In addition, a small (-1/2 acre)
sedimentation pond, referred to as the retention pond, is located
in the northeastern corner of the Landfill. The retention pond
collects surface runoff from near the pond, and promotes settlement
of any suspended solids.
The general direction of ground water flow in the alluvial aquifer
is from south to north. Areas directly south of the Landfill,
including the South Swamp, are hydraulically upgradient of the
waste pits. An alluvial ground water divide running north-south
extends from south of the Landfill to NE 36 Street north of the
Landfill. Alluvial ground water east of the divide flows eastward
toward Crutcho Creek. Alluvial ground water east of Crutcho Creek
flows westward toward the Creek. Thus, Crutcho Creek is a local
discharge zone for alluvial ground water in the eastern portion of
the Site. West of the alluvial ground water divide, flow is
generally to the west. In the area south of the Landfill, the
alluvial ground water may be discharging to the inactive sand and
gravel operation. Alluvial ground water flow in the area
directly west of the Landfill is westward toward the North Canadian
River. In the Garber-Wellington aquifer, ground water flow
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directions are similar to those in the alluvium, indicating that
the major surface water features, the North Canadian River and
Crutcho Creek, are influencing flow in both the Garber-Wellington
and the alluvial aquifers. Due to the poor hydraulic communication
between the two aquifers, it is unlikely that a significant amount
of ground water discharge occurs from the Garber-Wellington to the
alluvial aquifer and subsequently to Crutcho Creek. The major
point of discharge of the Garber-Wellington ground water over most
cf the Site is apparently the North Canadian River located west of
the Site. There are several wetland areas in the vicinity of the
Mosley Road Sanitary Landfill.
Historio Site Operations and Potential Sources of Contamination
Between February 20, 1976 and August 24, 1976, the Landfill was
authorized by OSDH to accept industrial wastes, mostly liquid,
which reportedly contained hazardous constituents (Table 1). This
authorization resulted from the temporary closure of the Royal
Hardage Landfill in Criner, Oklahoma, which previously had been
accepting the wastes. During this six month period, an estimated
1.7 million gallons of industrial hazardous waste were disposed of
in three unlined waste pits at the Landfill (Figure 3). The waste
pits subsequently were covered by up to 80 feet of municipal refuse
and a compacted clay cap constructed in accordance with existing
regulations governing landfill closure.
Extent of Contamination
Air and Surface Soils
Results of source and physical characterization studies during the
RI indicated that air was not a significant pathway for contaminant
migration at the Site. This is consistent with the fact that the
industrial hazardous wastes were buried beneath municipal refuse
and covered with a clay cap, making releases to air unlikely.
Based on the data obtained during the RI activities, surface and
near surface soils potentially have been impacted by runoff from
oil well pads, by runoff from the Landfill to the area immediately
north of the Landfill and by discharges from seeps that occur on
the sides of the Landfill during precipitation events (See Table
2). Based on chemical analyses of ground water samples collected
during the remedial investigation, surface and near surface soils
have not been impacted significantly by discharges of compounds
transported by ground water from the Landfill or waste pits.
Surface Water/Sediments
Analysis of organic compounds in sediments indicates that limited
impacts may have occurred in the North Pond due to runoff from the
Landfill, discharge from seeps originating within the Landfill,
pumping oil wells, and upstream discharges (See Table 3).
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a.
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Inorganic compounds in sediments appear to represent background
conditions and do not suggest a particular source. Based on
chemical analyses of ground water samples collected during the
remedial investigation, sediments have not been significantly
impacted by discharges of compounds transported by ground vater
from the Landfill or waste pits.
Selenium was present in a surface water sample which was collected
from Crutcho Creek downstream of the Landfill. The sample
exhibited a concentration of 0.0136 parts per million (ppm).
Selenium also was present in a sediment sample at a concentration
of 0.72 ppm. The data from the boreholes which were drilled in the
Landfill in the waste pit area indicate that the concentration of
selenium in the Landfill does not exceed selenium concentrations in
background soils. This suggests that there is little likelihood
of a selenium source existing within waste pits in the'Landfill.
Based on available site specific data, surface waters have not been
appreciably impacted by discharges of compounds transported by
surface runoff or ground water discharge from the Landfill or waste
pits (See Tab.le 4) .
Subsurface Soil and Ground Water
Alluvial Ground water:
Compounds detected in the alluvial ground water samples indicate
that alluvial ground water immediately north of the Landfill
potentially has been impacted by compounds migrating from the
Landfill and the waste pits (See Figure 4 and Table 5). No
definable plume of contamination has been detected beyond the area
immediately north and downgradient of the Landfill.
Garber-Wellington Ground Water:
Garber-Wellington ground water has been impacted slightly by
downward recharge from the overlying alluvial aquifer in the areas
immediately north of the Landfill (See Figure 5 and Table 6) .
Both organic and inorganic analytical results suggest elevated
concentrations of some compounds in the Garber-Wellington aquifer
north of the Landfill. Hydraulic head data support the potential
for enhanced communication between the two aquifers in the area
immediately north of the Landfill. Risk assessment calculations
indicate that existing contaminant levels in the Garber-Wellington
aquifer pose a slight threat to human health; however, that threat
falls well within EPA's acceptable risk range.
Sub-surface soils:
Waste pit soil samples collected during the RI exhibited elevated
levels of certain inorganic compounds that were likely constituents
of the industrial hazardous wastes disposed of at the Landfill (See
8
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Table 7) . The migration of compounds out of the waste pits and the
Landfill will be influenced by the amount of infiltration fro*
precipitation that is available to leach the waste. Since the clay
cap now covering the Landfill operates to prevent infiltration of
precipitation, it is unlikely that the amount of infiltration
through the clay cap will promote additional inorganics to migrate
into the alluvial ground water in significant amounts.
Exposure Routes
The Mosley Road Sanitary Landfill is located in a predominantly
rural setting on the eastern edge of Oklahoma City. Approximately
230 buildings, including a nursing home, various residences, and
an elementary school are located within one mile of the Landfill.
Assuming 3.8 persons per building, population within one mile of
the Site is approximately 875. Only one residence within a one
mile radius of the Site is potentially downgradient of the
Landfill. Neither the elementary school nor the nursing home are
downgradient of the Landfill.
Potential exposure pathways to humans from contamination at the
Hosley Road Sanitary Landfill are identified in Tables 8 and 9.
Tables 8 and 9 address the current and future use pathways,
respectively. Potential receiving media for contaminated ground
water include the alluvial aquifer and the underlying Garber-
Wellington aquifer. Other potential receiving media may include
the local surface water bodies of Crutcho Creek, the North Canadian
River, and the North Pond. Surface water in the South Swamp is
hydraulically upgradient of the waste pits and is unlikely to be a
potential receiving medium based on water level contours. Surface
water in the inactive sand and gravel pit is not hydraulically
downgradient of the waste pits and, similarly to the South Swamp,
is unlikely to be a potential receiving medium based on water level
contours.
Current-use pathways identified in Table 8 include exposure of
nearby residents and workers through drinking contaminated ground
and surface waters. Eighteen domestic wells currently are located
within a 1 mile radius of the Landfill. Based on the data gathered
during physical and contaminant characterization activities, 15 of
these wells are either upgradient of the Landfill or are located
across a ground water discharge area such as the North Canadian
River; thus, those wells would not be impacted by potential
migration of industrial hazardous wastes from the waste pits. The
three remaining wells include one located in the Nosley Road
Sanitary Landfill, one located in the East Oak Sanitary Landfill
and one located approximately 350 feet northeast of the Mosley
Road Sanitary Landfill. All of these wells are owned by HMO. WHO
has agreed to restrict the use of all wells at the Site and those
located on adjacent property which WHO owns to ensure they are not
used for domestic purposes.
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Contaminants from the Landfill also may have migrated into the
North Canadian River and Crutcho Creek. These water bodies are
classified for industrial process cooling water, agriculture, warm
water fishery, primary recreation, and aesthetics. The North
Canadian River also is classified for emergency water supply. The
likelihood of exposure of recreational users to contaminated
surface waters or sediments is considered very low; thus, this
pathway was eliminated from further evaluation. The risk of
exposure of residents through the use of the North Canadian River
as an emergency water supply is considered low. An assessment of
the risk posed, if any, by eating fish tissue, will be performed
during remedy implementation.
Other potential pathways at the Site include exposure of onsite
workers and trespassers to contaminants in surface soils and air
above the Landfill, as well as exposure of downwind residents to
airborne contaminants. The probability of these pathways being
completed is considered to be very low.
Future-use pathways (Table 9) used in the Risk Assessment are
identical to current-use pathways. The probability of exposure of
recreational users to contaminated media is expected to remain
insignificant, while the probability of exposure of residents to
contaminated ground water may increase from the current low
probability to one of moderate probability in the future if offsite
migration of contaminants takes place. The future use scenario
assumes that residents near the Site consume ground water
containing the same concentration of contaminants currently found
in ground water at the Site.
Pathways for human exposure to waste pit soils and leachate were
not included in the Risk Assessment because these contaminant
sources are buried under approximately 80 feet of municipal solid
waste and are expected to remain so buried. No pathway could be
identified through which receptors would come into direct contact
with either the waste pit soils or the leachate from the waste
pits. The possibility of contaminants from these sources reaching
the ground water is taken into account in the analysis of the
ground water exposure pathways.
Risks to human health are calculated by first determining the
exposure point concentration for each pathway. The exposure point
concentration is the concentration of a contaminant that an
individual might be exposed to through the various pathways.
Actual site data is used to calculate an exposure point
concentration. The exposure point concentration is then multiplied
by the human intake variables (e.g. average daily water
consumption, number of days exposed, and body weight) to arrive at
a chronic daily intake value.
Exposure concentrations for ingestion of ground water were based on
monitoring data. Inhalation concentrations from ground water were
10
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based on modeling that factored in the calculated ground water
concentrations. Steady state conditions were assumed. Therefore,,
current and future chemical concentrations were assumed to be
identical. This assumption may tend to overestimate long-term
exposure concentrations because.chemical concentrations are likely
to decrease over time from natural processes such as dispersion,
attenuation, and dilution occurring during migration to potential
receptors.
Long term exposure to relatively low chemical concentrations ( i.e.
chronic exposure) is of greatest concern. None of the measured
concentrations of chemicals of potential concern are high enough to
warrant concern about acute and subchronic (short-term) exposures.
Chronic daily intake values calculated for the ingestion pathway
consisted of two components: exposure point concentrations and
chemical-specific intake variables. Exposure-point concentrations
for ingestion of ground water and surface water reflect the upper
limit of the 95th percentile upper confidence interval, based on
the arithmetic means of the concentrations detected in the ground
water or on-the maximum detected value. This concentration
together with the intake variables was used to estimate the
reasonable maximum exposure (RME) baseline risk. Chemical specific
intakes for ingestion of chemicals in drinking water were
determined based on EPA's Exposure Factors Handbook and Risk
Assessment Guidance for Super fund: Volume I Human Health Evaluation
Manual Part A, Interim Final. The intake variables used in the
exposure assessment were as follows: ground water ingestion rate
of 2 liters/ day; inhalation rate of 0.6 cubic meters per hour;
body weight of 70 kg; exposure frequency of (1) 365 day/year for
exclusive ground water use, (2) 273 days/year for ground water use
supplemented by surface water use, and (3) 92 days/year for
emergency surface water use; and (4) an exposure duration of 70
years. Tables 10 through 13 summarize the calculated exposure
point concentrations and the pathway-specific human intakes for the
pathways resulting in the calculated risks of most concern,
alluvial and Garber-Wellington ground water ingestion.
Surface Water and Sediment
Aquatic life receptors are directly exposed to contaminants in
surface water and sediments through contact, ingestion, adsorption,
or absorption through gills. This pathway is of principal
importance to the aquatic life receptor group, wetlands, and those
wildlife species dependent on wetlands and other surface waters.
Animals that rely on the North Canadian River, Crutcho Creek, or
the ponds for drinking water may be exposed to contaminants through
ingestion. In addition, wildlife also may be exposed to
contaminants while foraging for plant and/or animal food in shallow
water or along shorelines.
11
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Exposure to chemicals present in sediments constitutes a probable
and important exposure pathway for aquatic life, wetlands, and
aquatic plant receptors. The primary exposure pathway to benthic
aquatic macro invertebrates and rooted aquatic plants is direct
contact with sediment contaminants. Wading birds and other animals
also may be exposed to contaminants from direct contact with
sediment while foraging for food.
Air
This exposure pathway is not completed, since the cap exists over
the waste pits.
Ground Water
Contaminant transport along the shallow ground water pathway is
considered a primary exposure route to aquatic life, wetlands, and
some wildlife where the ground water mixes with surface water.
This pathway is of particular importance to receptors located
hydrologically downgradient of the Landfill. The North Pond,
retention pond, and the northern sections of Crutcho Creek are
possibly linked to this pathway. The receptors linked to surface
water pathways also are affected indirectly by this pathway where
the surface and ground water systems mix.
VI. SUMMARY OJ1 SITE RISKS
An evaluation of the potential risks to human health and the
environment from site contaminants was conducted as part of the
baseline risk assessment. The risk assessment was conducted as
part of the RI. The objectives of the baseline risk assessment
were to (l) help determine whether additional response actions are
necessary at the Site; (2) provide a basis for determining residual
chemical levels that are adequately protective of human health and
the environment; and (3) provide a basis for comparing potential
health impacts of various remedial alternatives.
The baseline risk assessment was divided into two parts: the human
health evaluation and the ecological evaluation. The baseline risk
assessment was based on RME. The human health evaluation considered
potentially contaminated media such as surface soils and near
surface soils, alluvial ground water, Garber - Wellington ground
water, surface water, and sediments. Because no direct pathway was
identified for human and environmental receptors to be exposed to
contaminants in waste pit soils and leachate, these media were not
evaluated in the risk assessment. Likewise, contaminant migration
via an air pathway was not evaluated in the risk assessment. Air
monitoring throughout the remedial investigation activities showed
no significant breathing hazards to the nearby populations or
terrestrial wildlife. The existing clay cap reduces the potential
exposure to contaminants via air and through direct contact.
Current and Future Health Risks:
12
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A summary of site risks from contaminants at the Mosley Road
Sanitary Landfill is presented in Table 14 and Figure 6. The risks
shown in Table 14 were calculated based on assumptions designed to
overestimate potential risks. The human health risk from potential
exposure to alluvial ground water is based on the conservative
assumption that exposure would occur at the Landfill. Such
exposure is unlikely to occur since no domestic -wells currently
exist at or near the Landfill, other than those owned by WHO, and
WHO has agreed to restrict use of onsite and offsite wells to
ensure that they are not being used for domestic purposes.
Currently, carcinogenic (cancer causing) or noncarcinogenic threats
to human health via exposure to Garber-Wellington ground water,
whether through ingestion, inhalation, dermal contact, or a
combination of all of these routes, are well within EPA's
acceptable risk range (Figure 6). For the Garber-Wellington
aquifer, the upper-bound estimate of carcinogenic health risks
associated with potential lifetime exposure was reported as 3xlO'6,
which slightly exceeds the lower bound of EPA's target risk range
but is well below the range determined by EPA to represent a
significant carcinogenic health risk. No non-cancer health risks
were reported for potential exposure to Garber-Wellington ground
water. The risk in this aquifer is driven by one detection of
benzene above the MCL.
The Hazard Indices (His) indicating unacceptable threats to human
health from noncarcinogens were calculated for exposures to
alluvial ground water, whether alone or combined with surface
water. The main compounds contributing to noncarcinogenic risk
through the potential ingestion of alluvial ground water are
arsenic, barium, manganese, and 2-chlorophenol. Noncarcinogenic
risks, such as liver and kidney damage, associated with ingestion
and total exposure (i.e., ingestion, inhalation, and dermal
contact) to contaminants in alluvial ground water indicate a
potential human health risk. However, as discussed earlier, such
a scenario is currently unlikely. The maximum detected
concentrations were within or near the immediate boundaries of the
landfill. The calculated risk assumes that an individual is
consuming ground water from a well located directly within the
Landfill. Analysis of the ground water samples indicates that
contamination has not migrated beyond current WHO'S property
boundaries.
The maximum concentrations of arsenic (0.086 mg/1), barium (3.21
mg/1), and manganese (3.09 mg/1) detected in the alluvial aquifer
exceeded the MCLs for drinking water for these chemicals (0.05, 1.0
and 0.05 mg/1 respectively). The average concentration (based on
95% upper confidence limit (UCL)) for arsenic, at 0.018 mg/1, was
below the MCL of 0.05 mg/1. The average concentration for barium
at 1.14 mg/1 slightly exceeds the MCL set at 1.0 mg/1. The average
concentration for manganese, 1.56 mg/1 exceeds the MCL of 0.05
mg/1. Some of these substances are hazardous substances within the
13
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CANCER RISK
1.0-03
1.0-04
1.0-05
1.0-06
1.0-07
1.0-08
1.0-09
1.0-04
1.0-05
1.0-06
1.0-07
1.0-08
1.0-09
ALLUVIAL GROUND WATER
1NGESTION INHALATION DERMAL
TOTAL
GARBER WELLINGTON GROUND WATER
A'S ACCEPTABLE RISK RAN
INGESTION INHALATION DERMAL
TOTAL
SOURCE: GOLDER ASSOCIATES INC.,
WASTE MANAGEMENT OF OKLAHOMA,
FINAL REMEDIAL INVESTIGATION REPORT,
APRIL 1992.
MOSLEY ROAD SANITARY LANDFILL
OKLAHOMA CITY, OKLAHOMA
N
FIGURE 6
CANCER RISK ESTIMATES
CURRENT USE
Page 1 of 2
Environmental Protection Agency
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CANCER RISK
1.0-03
1.0-04
1.0-05
1.0-06
1.0-07
1.0-08
1.0-09
COMBINED ALLUVIAL GROUND WATER AND SURFACE WATER
A'S ACCEPTABLE RISK RANG
INGESTION INHALATION DERMAL
TOTAL
1.0-04
1.0-05
1.0-06
1.0-07
1.0 - 08
1.0-09
COMBINED CAREER WELLINGTON GROUND WATER AND SURFACE WATER
INGESTION INHALATION DERMAL
TOTAL
SOURCE: COLDER ASSOCIATES INC.,
WASTE MANAGEMENT OF OKLAHOMA,
FINAL REMEDIAL INVESTIGATION REPORT,
APRIL 1992.
MOSLEY ROAD SANITARY LANDFILL
OKLAHOMA CITY, OKLAHOMA
FIGURE 6
CANCER RISK ESTIMATES
CURRENT USE
Page 2 of 2
Environmental Protection Agency
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meaning of Section 101(14) of CERCLA, 42 U.S.C. S 9601(14), and 40
CFR 302.4.
Manganese also was detected at upgradient (background) ground water
monitoring wells in the alluvial aquifer in excess of MCLs and in
slightly higher concentration than were detected in the farthest
downgradient monitoring wells. This suggests that manganese occurs
in the alluvial aquifer in naturally elevated concentrations or due
to sources in addition to the Mosley Road Landfill.
Carcinogenic risks for the Site are driven by vinyl chloride, which
causes lung cancer when ingested or dermally absorbed, and liver
cancer when inhaled. Vinyl chloride is a hazardous substance
within the meaning of Section 101(14) of CERCLA, 42 U.S.C.
S 9601(14), and 40 CFR 302.4. In the 1990 - 1991 ground water
sampling results, sporadic detections of vinyl chloride occurred in
the alluvial wells. Concentrations in the monitoring wells ranged
from non-detect to 0.029 ppm. Later samples which were collected
during January 1992 indicated that the vinyl chloride
concentrations in these same two wells were below the MCL after 3 -
4 days of pumping and remained below the MCL until the end of the
7 day test. The concentrations after 4 days of pumping were below
.0.002 ppm, the MCL for vinyl chloride.
Based on ground water sampling results, carcinogenic health risks
associated with exposure to alluvial ground water are calculated to
be 6xlO*4. This means that six additional cancer cases out of every
ten thousand people could potentially result from lifetime exposure
to a specific daily concentration of a carcinogenic compound
currently in the alluvial ground water. EPA has set a target range
for carcinogenic health risks at Superfund sites from 1 x 10"4 to
1 x 10*6. The range of 1 x 10'4 to 1 x 10'6 means that one
additional person in ten thousand to one in one million people
exposed to the conditions evaluated could develop cancer as a
result of exposure to a specific daily concentration of a
carcinogenic compound over a lifetime. Thus, any remedy selected
for the Site must reduce the carcinogenic risk associated with the
Site such that no more than one additional person (beyond the
statistical norm) in ten thousand people could develop cancer as a
result of exposure to contaminants from the Site. The selected
remedy and contingency measures are expected to meet this target.
No measurable human health risks are associated with ingestion of
surface waters in the study area. Surface water in the North
Canadian River near the Site is designated as an emergency water
supply. The alluvial ground water indirectly discharges into the
North Canadian River. Therefore, human health risks were calculated
assuming potential exposure to a combination of surface water and
ground water, with exposure to surface water assumed to occur three
months per year and exposure to ground water occurring in the
remaining nine months per year. Human health risks associated with
exposure to combinations of surface water (North Canadian River)
14
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and alluvial ground water indicate a potential threat to human
health, primarily due to ingestion of carcinogenic and
noncarcinogenic compounds in alluvial ground water. The
probability of this potential pathway being completed is low since
it is unlikely that the North Canadian River water would be used
without treatment except in emergencies.
Human health risks associated with exposure to combinations of
surface and Garber-Wellington ground water are 2 x 10*e (2 excess
cancer cases in one million people could potentially occur),
contributed to primarily by benzene through the Garber-Wellington
ground water ingestion pathway. Since benzene at a level in excess
of the MCLs was detected in only one well during one of the two
sampling events at the Site, it appears that benzene is not present
throughout the entire Site, and the risk appears to be driven only
by the isolated detection of benzene above MCLs in the' one well.
This risk is within EPA's acceptable risk range; therefore,
remediation of the Garber-Wellington ground water is not warranted
at this time.
Impacts to the Environment:
An ecological assessment was conducted. Knowledge of site ecology
is based on two site reconnaissances and a compilation of existing
ecological information. Findings of the reconnaissance surveys
conducted by WHO of the 700-acre Landfill area, a U.S. Fish and
wildlife Service report on Crutcho Creek, and a study on the fish
populations of Crutcho Creek and the North Canadian River by
Matthews and Gelwick are the information sources used for the
ecological assessment. Surveys were conducted of terrestrial
vegetation and wildlife, aquatic and wetland habitats, and aquatic
life. The ecological risk assessment was conducted in accordance
with the Risk Assessment Guidance for Super fund: Volume II,
Environmental Evaluation Manual (EPA, I989b), and Ecological
Assessment of Hazardous Waste Sites: A Field and Laboratory
Reference (EPA, 1989c).
Risks to the following media were evaluated as part of that risk
assessment:
- terrestrial vegetation;
terrestrial wildlife;
aquatic life; and
wetlands.
No significant risks to terrestrial vegetation or terrestrial
wildlife in the study area were identified. Based upon results of
the risk assessment, selenium appears to present potential chronic
environmental risks to aquatic life in the adjacent North Pond and
Crutcho Creek. Selenium also presents potential adverse chronic
risks to water fowl and other wetland-associated birds in the study
area. The maximum concentration of selenium detected was present
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in a surface water sample which was collected from Crutcho Creek
downstream of the Landfill. The water sample exhibited a
concentration of 0.0136 ppm. Selenium also was present in a
sediment sample at a concentration of 0.72 ppm.
The Federal freshwater acute and chronic criteria for selenium are
0.260 and 0.035 ppm, respectively (Quality Criteria for Hater
1986). The criterion to protect freshwater life as derived using
the Guidelines is a concentration of 0.035 ppm as a 24-hour
average, and should not exceed a concentration of 0.260 ppm at any
time. The Oklahoma chronic toxicity standard for selenium to
protect aquatic life is 0.005 mg/L. The Federal ambient water
quality criterion for selenium is a concentration of 0.010 ppm and
is based on the human daily consumption of 6.5 grams of aquatic
organisms. Surface water concentrations indicated in the Site data
are, generally, within the acceptable risk ranges. However, the
maximum concentration detected exceeded the Oklahoma chronic
toxicity standard, and slightly exceeded the ambient water quality
criterion. The sediment concentrations are reflective of typical
background levels of concentrations in soils.
The distribution of selenium in surface water and sediments
suggests that sources other than the Mosley Road Sanitary Landfill
or the waste pits may be responsible for its occurrence. The
recent Agency for Toxic Substances and Disease Registry (ATSDR)
Toxicological Profile for Selenium (1990, p 110) reported that
selenium has been found in petroleum at concentrations ranging from
500-950 ppm (i.e., up to about 0.10%), and in heavy petroleum at
concentrations ranging from 500-1650 ppm. These data and the known
drilling practices in the Site area, suggest that oil production in
the area may be a source of selenium.
Fish tissue studies were not performed during the ecological
assessment; yet, such studies will be conducted subsequent to the
finalized ROD. If any fish tissue studies performed indicate a
significant risk to human health and the environment, remedial
measures will be evaluated to address risk to the public from
ingestion of fish (e.g. fencing to limit public access, etc.).
Toxicity Assessment r
The objective of the toxicity assessment is to weigh available
evidence regarding the potential for particular contaminants to
cause adverse effects in exposed individuals. Also, the toxicity
assessment provides, where possible, an estimate of the
relationship between the extent of exposure to a contaminant and
the increased likelihood and or severity of adverse effects. The
types of toxicity information considered in this assessment
include the reference dose (RfD) used to evaluate noncarcinogenic
effects and the slope factor to evaluate carcinogenic potential.
16
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RfDs have been developed by EPA for indicating the potential for
adverse health effects from exposure to contaminants of concern
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of acceptable lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of contaminants of concern from environmental
media (e.g., the amount of a contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans and to protect sensitive subpopulations) to
ensure that it is unlikely to underestimate the potential for
adverse noncarcinogenic effects to occur. The purpose of the RfD
is to provide a benchmark against which the sum of the other doses
(i.e. those projected from human exposure to various environmental
conditions) might be compared. Doses that are significantly higher
than the RfD may indicate that an inadequate margin of safety could
exist for exposure to that substance and that an adverse health
effect could occur.
No RfD or slope factors are available for the dermal route of
exposure. In some cases, however, noncarcinogenic or carcinogenic
risks' associated with dermal exposure can be evaluated using an
oral RfD or an oral slope factor. Exposures via the dermal route
generally are calculated and expressed as absorbed doses. These
absorbed doses are compared to an oral toxicity value that is also
expressed as an absorbed dose. Toxicity information used in the
toxicity assessment for the Site was obtained from the Integrated
Risk Information System (IRIS). If values were not available from
IRIS, the Health Effects Assessment Summary Tables (HEAST) were
consulted. The toxicity factors used in this evaluation for
noncarcinogenic effects and carcinogenic effects are summarized in
Tables 15 and 16 respectively.
For chemicals that exhibit noncarcinogenic health effects,
authorities consider organisms to have repair and detoxification
capabilities that must be exceeded by some critical concentration
(threshold) before the health is adversely affected. For example,
an organ can have a large number of cells performing the same or
similar functions. To lose organ function, a significant number of
those cells must be depleted or impacted. This threshold view
holds that exposure to some amount of a contaminant is tolerated
without an appreciable risk of adverse effects.
Health criteria for chemicals exhibiting noncarcinogenic effects
for use in risk assessment are generally developed using EPA's RfDs
developed by the Reference Dose/Reference Concentration ("RfD/RfC")
Work Group and included in the IRIS.
For chemicals that exhibit carcinogenic effects, most authorities
recognize that one or more molecular events can evoke changes in a
single cell or a small number of cells that can lead to tumor
17
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formation. This is the non-threshold theory of carcinogenesis
which purports that any level of exposure to a carcinogen can
result in some finite possibility of generating the disease.
EPA's Carcinogenic Risk Assessment Verification Endeavor (CRAVE)
has developed slope factors (i.e., dose-response values) for
estimating excess lifetime cancer risks associated with various
levels of lifetime exposure to potential human carcinogens. The
carcinogenic slope factors can be used to estimate the lifetime
excess cancer risk associated with exposure to a potential
carcinogen. Risks estimated using slope factors are considered
unlikely to underestimate actual risks, but they may overestimate
actual risks. Excess lifetime cancer risks are generally
expressed in scientific notation and are probabilities. An excess
lifetime cancer risk of 1 x 10'6 (one in one million), for example,
represents the probability that one additional individual in a
population of one million will develop cancer as a result of
exposure to a carcinogenic chemical over a 70-year lifetime under
specific exposure conditions.
Slope factors (SFs) have been developed for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic contaminants of concern. SFs, which are expressed in
units of (mg/kg-day) "1 , are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the SF. Use of
this approach makes underestimation of the actual cancer risk
highly unlikely. Slope factors are derived from the results of
human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied( e.g., to account for the use of animal data to predict
effects on humans).
There are varying degrees of confidence in the weight of evidence
for carcinogenicity of a given chemical. The EPA system involves
characterizing the overall weight of evidence for a chemical's
carcinogenicity based on the availability of animal, human, and
other supportive data. The weight - of- evidence classification is
an attempt to determine the likelihood that the agent is a human
carcinogen, and thus, qualitatively affects the estimation of
potential health risks. Three major factors are considered in
characterizing the overall weight of evidence for carcinogenicity:
(1) the quality of evidence from human studies; (2) the quality of
evidence from animal studies, which are combined into a
characterization of the overall weight of evidence for human
carcinogenicity; and (3) other supportive information which is
assessed to determine whether the overall weight of evidence
should be modified. EPA uses the weight of evidence classification
system to categorize carcinogenicity of contamination as one of the
following five groups:
18
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Group A - Human Carcinogen: This category indicates that there
is sufficient evidence from epidemiological studies to support
a causal association between an agent and cancer.
Group B - Probable Human Carcinogen: This category generally
indicates that there is at least limited evidence from
epidemiological studies of carcinogenicity to humans (Group
Bl) or that, in the absence of adequate data on humans, there
is sufficient evidence of carcinogenicity in animals (Group
B2)
Group C - Possible Human Carcinogen : This category indicates
that there is limited evidence of carcinogenicity in animals
in the absence of data on humans.
Group D - Not Classified: This category indicates that the
evidence for carcinogenicity in animals is inadequate.
Group E - No Evidence of Carcinogenicity to Humans; This
category, indicates that there is no evidence for
carcinogenicity in at least two adequate animal tests in
different species, or in both epidemiological and animal
studies.
Several of the chemicals of concern have been classified as
potential carcinogens by EPA. Each of these also has been assigned
a carcinogenicity weight-of-evidence category. These chemicals
are:
Group A-Human Carcinogens
* arsenic
* benzene
* chromium (VI) (inhalation route)
* nickel refinery dust; nickel subsulfide (inhalation
route)
* vinyl chloride
Group B
*
*
*
*
*
Probable Human Carcinogens
alpha -BHC
beta-BHC (inhalation route)
beryllium
cadmium (inhalation route)
chlordane
4,4' - ODD
4,4" - DDT
Dieldrin
Heptachlor
benzo(a)anthracene
benzo(b) fluoranthene
benzo(k) fluoranthene
benzo (a) pyrene
19
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chrysene
indeno (1,2,3-cd) pyrene
lead
bis (2-ethyIhexy1)phthalate
carbon tetratchloride
1,2 - dichloropropane
tetrachloroethene
trlchlorethene
Group C - Possible Human Carcinogens
*
*
*
*
beta-BHC (oral route)
butylbenzylphthalate (oral route)
1,1-dichloroethane.
1,1,2-trichlorothane
Group D - Not Classified As To Human Carcinogenicity
* delta-BHC
* Endrin
Uncertainties Associated with the Hunan Health Risk Calculations
Risk assessment is a scientific activity subject to uncertainty.
In addition to the uncertainty, and the use of conservative
assumptions, to calculate slope factors and RfDs, the analysis of
environmental conditions is difficult and inexact. The Mosley Road
risk assessment is subject to uncertainty from a variety of sources
including:
- sampling and analysis;
- toxicological data;
- exposure estimation;
- fate and transport estimation; and
- risk characterization.
Uncertainties -associated with sampling include the
representativeness of the samples; sample cross contamination;
statistically significant sample size; sampling strategy; temporal
changes; and seasonal variability.
Uncertainties associated with sample analysis include the inherent
variability in the laboratory equipment; laboratory contamination;
contamination introduced during dilution; and estimated values.
Although the quality assurance/quality control program used during
the RI serves to reduce the variability, it cannot eliminate all
variability associated with sampling and analysis.
Uncertainties associated with exposure estimation include the
description of current actual and future potential exposure
scenarios. The variables and assumptions in these scenarios
20
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include physical parameters (e.g. body weight, contact rates),
activity patterns of potential receptors, physiological variability
of individuals, and the presence and exposure of sensitive'
populations. There are a number of uncertainties regarding the
assumptions made for likelihood of exposure, frequency of contact
with contaminated media, the concentration of contaminants at
exposure points, and the time period of exposure.
Uncertainties associated with fate and transport can be attributed
to the estimation of chemical movement through different media and
the assumption that all conditions remain constant over time. The
Mosley Road baseline risk assessment assumed that individuals would
be exposed to the most contaminated conditions found at the Site.
x
Uncertainties, associated with risk characterization include
potential chemical interactions (e.g. synergy). There is no
guidance for determining synergistic effects (where the whole is
greater than the sum of the parts) in risk characterization.
Therefore, it is assumed that all risks are additive.
Uncertainties, in the Mosley Road baseline risk assessment are a
function of risk assessments in general and a function of the
uncertainties specific to the Mosley Road Site in particular.
Although all risk assessments contain a certain amount of
uncertainty, an attempt to reduce the uncertainty in the Mosley
Road baseline risk assessment was made whenever possible.
Remediation Goals
The contaminated sediments and waste pit soils were determined to
be a potential threat at the Site because of direct contact,
ingestion, and inhalation risks and because of the soils7 impact on
ground water. The remedial objectives for the soil are: 1) to
eliminate potential exposure via ingestion, inhalation, or direct
contact with contaminants and 2) to reduce the potential for the
soil to act as a continued source for surface water and ground
water contamination.
The contaminated shallow ground water also was determined to be a
low level but significant long term threat at the Site both because
of the potential exposure of the public to the Site contaminants
and because of the threat of migration of contaminants to deeper
zones of ground water. The deeper ground water zones are used for
industrial, irrigation, and drinking water purposes. The remedial
objective for shallow ground water is to prevent the exposure of
potential receptors to onsite contamination in amounts above human
health-based standards and to restore ground water quality through
the process of natural attenuation.
Vinyl Chloride was determined to be the contaminant contributing
most to the risk in the alluvial ground water and the greatest need
for remediation at the Site. The other contaminant found at the
21
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Site of most concern was benzene which was detected in the Garber-
Wellington, but benzene concentrations were within EPA's acceptable.
risk range for carcinogenic and non-carcinogenic effects. In any
event, all contaminants detected during the ground water monitoring
program, including benzene and vinyl chloride, will be evaluated
against MCLs and health based risk levels. MCLs are considered to
be relevant and appropriate requirements (ARARs) because the
aquifers in the area are potential sources of drinking water.
During implementation of the remedy, all of the contaminants of
concern identified during the RI will continue to be monitored and
evaluated to determine if MCLs or acceptable risk ranges have been
exceeded.
The selection of appropriate remediation levels is based primarily
on an evaluation of the potential health effects caused by human
exposure to the contaminants, assuming that the future land use
will be residential and commercial/industrial. The reasoning
behind designating the future land use as possibly residential is
that the Landfill is located near a residential area. Therefore,
EPA takes a -conservative approach and calculates risk so that all
potential scenarios are taken into consideration.
The national risk of getting some form of cancer over a 70 year
life span is estimated at one chance in five or 0.2. The one in
five probability is the baseline situation or "natural incidence"
of cancer. A one in ten thousand (10'4) risk is an increment above
the baseline risk (an increase from 0.2000 to 0.2001). EPA policy
calls for an evaluation of remediation levels that range from a
cancer risk of one in ten thousand to one in one million (1 X 10'4
to 1 X 10'*). In accordance with EPA policy, EPA does not expect
to require remediation of contamination that exists within or below
the acceptable risk range (excess cancer risk between 10"4 to 10"'
and non-carcinogenic HI less than 1.0). However, if active
remediation treatment technologies are triggered by the contingency
measure criteria, EPA policy includes an expectation that the
treatment goal will be to the lowest end of the risk range (10*6)
unless site specific factors dictate that an alternate remediation
goal is appropriate. The goal of the selected remedy is to restore
all potential drinking waters impacted by the site to levels within
EPA's acceptable risk range for carcinogenic and non-carcinogenic
effects. In the event that active treatment is required, the
remediation goal for those ground water areas being actively
remediated will be MCLs, or in the absence of MCLs, to levels
within EPA's acceptable risk range.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
VII. DESCRIPTION OF ALTERNATIVES
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The National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) states that containment technologies will generally be,
appropriate remedies for wastes that pose a relatively low-level
threat or where treatment is impracticable. Containment has been
identified in EPA's guidance "Conducting Remedial
Investigation/Feasibility Studies for CERCLA Municipal Landfill
Sites" as the most likely response action for landfills because (1)
CERCLA municipal landfills are primarily composed of municipal and
to a lesser extent hazardous waste; therefore, they often pose a
low-level threat rather than a principal threat; and (2) the
volume and heterogeneity of waste within CERCLA municipal landfills
will often make treatment impractical. Removal of contaminated
soils at municipal landfills is generally limited to hot spots or,
when practicable, to landfills with a low to moderate volume of
waste (e.g. less than 100,000 cubic yards). Complete excavation of
municipal landfill contents often is not considered practicable
because of the large volume of waste typically found at CERCLA
municipal landfills. At the Site, hot spots have not been found to
exist. The primary source materials remaining in the waste pit area
consist of elevated chromium levels in soils located beneath up to
80 feet of municipal garbage. Ground water data indicate that
there .has not been significant migration of chromium.
Several gases typically are generated by decomposition of organic
materials in a landfill. The composition, quantity, and generation
rates of the gases depend on such factors as refuse quantity and
composition, landfill depth, refuse moisture content, and amount of
oxygen present. The principal gases generated are carbon dioxide,
methane, nitrogen, and, occasionally, hydrogen sulfide. Vinyl
chloride, toluene, benzene, hydrogen cyanide, and other toxic
contaminants also may be present. During a landfill's early
stages the refuse undergoes aerobic ( oxygen rich ) decomposition,
and the principal gas generated is carbon dioxide. Once all the
free oxygen is depleted, the refuse decomposition becomes oxygen
deficient, and the principal gases become carbon dioxide and
methane. Migration of landfill gas can pose onsite and offsite
fire and explosion hazards. In addition, landfill gas can be an
inhalation hazard and can become soluble in ground water. Because
of these potential hazards, EPA's selected alternative includes
implementation of a landfill gas monitoring system.
EPA's selected alternative does not directly address the waste pits
or the other waste in the Landfill. This is based on the fact that
the liquid wastes were disposed in the three unlined pits over 15
years ago, and thus likely are no longer present in the pits. The
conclusion that the liquid wastes are no longer located in the pits
is supported by data generated from soil borings throughout the
pits that indicate that hot spots do not remain. Finally, waste
in the landfill other than the liquid waste does not pose a threat
to the environment. Thus, leaving the landfill waste in place with
an overlying cap is a component of all remedy alternatives.
23
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The descriptions of remedial alternatives are separated into
capping alternatives and those addressing ground water.
contamination.
A. Capping Remedial Alternatives
The capping alternatives for the source containment portion of the
complete remedy, as discussed in the Feasibility Study (FS), are
the following:
Alternative 1 Repair and improvement of the existing cap and
addition of a vegetative soil layer
Alternative 2: Repair of the.existing cap, addition of 2 feet
of additional clay cover over the waste pit
areas, and addition of a vegetative 'soil layer
Alternative 3: Repair of the existing cap, addition of 2 feet
of additional clay cover over the entire
landfill, and addition of a vegetative soil
layer
CAPPING ALTERNATIVES:
Capping alternatives are significant in terms of achieving
protection of human health and the environment in that they
-eliminate any direct contact threat. Capping alternatives also are
designed to reduce the potential for excess precipitation to
infiltrate the landfill, thereby reducing the potential for
leachate production.
The existing compacted clay cover met existing requirements at the
time of landfill closure in 1988. The existing cover, which is
three feet thick on top and 2 feet thick on side slopes, should be
sufficient to restrict infiltration into the Landfill if it is
properly repaired and maintained. WHO currently is maintaining the
existing cap on an on-going basis.
EPA's Hydrogeologic Evaluation of Landfill Performance (HELP)
modeling described in the Final RI Report indicates that minimal
water (less than 0.009 inches/year) will penetrate the compacted
clay cap as long as the cap is repaired and maintained properly.
The HELP model predicts the movement of water across, into, and
through landfills. The purpose of HELP analyses is to evaluate the
degree of runoff and infiltration expected given the current
conditions of the clay cap. Each capping alternative considered
would minimize the potential for precipitation to infiltrate into
the landfill and eliminate any direct contact threat.
Capping Alternative 1
Alternative 1 includes repair and maintenance of the existing clay
24
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cap on the Landfill as necessary. The existing cap is a minimum 3
feet thick on the top and 2 feet thick on side slopes. Repair of.
the existing cap may include stripping of the upper l foot of clay
(if necessary to repair cracking upon inspection), replacement and
compaction of the clay, and addition of a minimum of 6 inches of
vegetative soil. It is proposed that the clay cover thickness on
the side slopes will be increased from 2 to 2.5 feet plus a 6 inch
cover that will support vegetative growth in order to meet current
Oklahoma closure regulations (Oklahoma Regulations Governing Solid
Waste and Sludge Management, Sec. 3.0.13, 1990). It may be
necessary to regrade portions of the top surface of the Landfill to
re-establish suitable surface slopes (i.e. 4 percent). This
alternative includes 50% coverage of side slopes with erosion
control protection while the vegetative layer is being established.
Capping Alternative 2
Alternative 2 is identical to Alternative 1 except that an
additional 2 feet of clay cover would be added over the waste pit
areas of the Landfill. This alternative would further reduce the
potential for infiltration into the waste pit soils and would
provide additional protection against cracking of the cover caused
by settling or desiccation. It is assumed that the additional clay
cover would extend a minimum of 20 feet beyond the footprint of the
waste pits as determined from historical air photographs.
Provisions for erosion control and a drainage layer also would be
considered under this option. Capping Alternative 2 would exceed
currently existing OSDH requirements regarding capping of
landfills.
Capping Alternative 3
Alternative 3 is identical to Alternative 1 except that an
additional 2 feet of clay would be added to the existing cover over
the main body of the Landfill. This alternative would leave the
existing clay cap intact, but would further restrict potential
infiltration into the main body of the Landfill. The additional 2
feet of compacted clay would provide additional protection against
cracking of the cover caused by settling or desiccation. Capping
Alternative 3 would exceed currently existing OSDH requirements
regarding capping of landfills.
GROUND WATER REMEDIAL ALTERNATIVES
The following alternatives for the leachate and ground water
remediation were evaluated in the FS:
Alternative 1: No Action
Alternative 2: Limited Action: Source containment, Ground
Water and Landfill Gas Monitoring with
Contingencies for Active Remediation
25
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Alternative 3: Source containment; Ground water
extraction and discharge
Alternative 4: Source containment; Ground water extraction,
treatment, and discharge
Alternative 5: Source containment; leachate extraction,
treatment, and discharge
Alternative 6: Source containment; Ground water extraction
and discharge; and leachate extraction,
treatment, and discharge
Alternative 7: Source containment; Ground water and Leachate
extraction, treatment, and discharge
Each of the above leachate and ground water Alternatives through 7
also considered the addition of a slurry wall to prevent migration.
With addition of a slurry wall, the alternatives are numbered 3a,
4a, 5a, 6a, and 7a respectively.
Common Elements
This section discusses common elements of remedial alternatives
considered for the Site.
The alternatives considered that require either ground
water or leachate extraction (i.e. Alternatives 3 through
7) could take as long as 20 years to complete.
All of the ground.water alternatives with the exception
of No Action and Limited Actions require that the North
Pond be drained.
Site-use restrictions will be implemented, as part of all
alternatives except No Action, to prohibit activities
such as soil excavation and construction of buildings,
and/or domestic water wells at the Site.
The goal of all of the alternatives is that ARARs for
exposure to ground water and ARARs for discharge of
ground water to surface waters or to a Publicly Owned
Treatment Works (POTW - "sewage treatment plant") be
reached for any scenario of reasonable maximum exposure.
All of the alternatives, other than No Action, include
implementation of an active landfill gas monitoring
program. By monitoring the landfill gas, the human
health and the environment will be protected from
potential exposure to explosion or inhalation hazards.
Information gathered during the monitoring program will
be used to determine what, if any, action should be taken
26
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to prevent build-up of pressure below the cap and to help
prevent damage to the vegetative cover.
A slurry wall is included in Alternatives 3a, 4a, 5a, 6a,
and 7a. A slurry wall is commonly used to reduce or
eliminate horizontal ground water flow out of or into the
contaminated zone surrounded by the slurry wall. It is
typically a low-permeability bentonite slurry uniformly
placed into a trench excavated around the perimeter of
the contaminated area.
All present worth values for the ground water
alternatives do not include the capping cost ($3.1
million).
GROUND WATER ALTERNATIVES:
Alternative l:
NO ACTION
Present Worth (PW): $0
, Years to Implement: 0
EPA is required by the NCP (40 CFR 300) to consider the No Action
alternative. This alternative assumes that nothing would be done to
restrict site access, monitor offsite contaminated soil, or
maintain the existing temporary cap. This alternative also assumes
that no offsite or onsite ground water monitoring would be
performed. No action would be taken to prevent migration of
contaminated ground water at the Site. No costs are associated with
the alternative.
If the contamination within the alluvial aquifer were to reach the
underlying Garber - Wellington aquifer and migrate offsite, future
use of contaminated ground water offsite could result in
unacceptable public health risks. This alternative will not ensure
overall protection of human health and the environment; compliance
with ARARs; long-term or short-term effectiveness; or, reduce
toxicity, mobility or volume of hazardous substances and,
therefore, it is not favored by EPA.
Alternative 2
LIMITED ACTION: Institutional Controls; Access Restrictions; and
Ground Water and Landfill Gas Monitoring
PW: $500,000
Years to Implement: Indefinitely
. Capping Alternative 1 (EPA's Selected Capping
Alternative)
. Restoration of ground water as a potential source of
drinking water through natural attenuation.
27
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. Continued ground water monitoring to determine if
current conditions improve through time, remain
constant, or worsen;
. Monitoring of leachate migration via ground water
monitoring and periodic sampling;
. Access restrictions, including installation of signs,
restrictions on future use of the property,
fencing, and restrictions on use of ground water from
site water wells;
. Implementation of a landfill gas monitoring system
to prevent explosion .or inhalation hazards; and
. Implementation of active ground water remediation
contingencies if triggered by the contingency measure
criteria discussed in Section IX of this ROD.
This alternative meets the NCP (40 CFR 300) requirements for the
development of an alternative that involves little or no treatment
but may provide protection of .human health and the environment if
properly implemented primarily by preventing or controlling
exposure to hazardous substances.
Institutional controls to be implemented at the Site include
fencing the Site, posting signs, deed notices, land use
restrictions, and ground water monitoring. Ground water monitoring
may include modification of the existing network of wells to
identify changes in alluvial and Garber-Wellington ground water
quality. This alternative would not prevent continued ground water
contamination. However, as explained below, if site conditions
worsen over time, contingency measures for active remediation would
be implemented as necessary.
Since treatment is not a principal element of this alternative, the
alternative does not meet the Super fund preference for treatment of
contaminants. EPA has determined that treatment is not warranted
at this time. This determination is based on EPA's evaluation of
site specific data indicating that ground water contamination
currently is very limited in extent and , sporadic, and natural
attenuation is believed to be able to remediate the existing
contamination.
The conclusion as to the limited extent of alluvial ground water
contamination is based upon a ground water pump test and analysis
that showed that after 4 days of pumping all contaminant
concentrations were below health based standards. This indicates
that the vinyl chloride contamination is sporadic, rather than
being present throughout the entire aquifer, further indicating
that remediation of the entire alluvial aquifer is impracticable.
Also, based on the pump test and analysis, future concentrations of
28
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site contaminants are not expected to exceed any applicable state
or Federal standard beyond the property boundaries. Risk due to
— exposure to contaminated alluvial ground water which solely exists
within WMO's property boundaries is low due to WMO's agreement to
restrict use of ground water from on-site wells to prevent their
use for domestic purposes. Thus, active remediation of the aquifer
is not warranted at this time.
This alternative provides for natural attenuation to reduce
contaminant concentrations in the ground water. The alternative
also provides for ongoing monitoring of Site wells established as
part of the ground water monitoring program during remedy design to
determine 1) whether natural attenuation of the contamination is
talcing place, and 2) whether the extent of contamination has spread
or diminished. If during the monitoring of the Garber-Wellington
and alluvial wells, contaminant concentrations either meet or
exceed the contingency measure criteria set forth in Section IX of
this ROD, EPA may require implementation of any or all of the
following actions:
**}
Contingency measures;
If it is determined that contingency measures are needed to address
contamination in the ground water, EPA may require implementation
of further response actions consistent with the contingency
measures. Actions that might be required include, but are not
limited to, the following:
Installation of additional monitoring wells to confirm
and better define the changing conditions in contaminant
concentrations. If contingency measure criteria are
triggered, begin extracting contaminated water or
leachate to facilitate or accelerate cleanup of the
affected area and/or its source.
submittal of a Remedial Action Plan describing a plan for
the extraction, treatment, or disposal of contaminated
ground ' water in order to achieve state and Federal
~ standards.
Begin extracting and treating the contaminated ground
water until the concentrations are below the SDWA
standards, or if SDWA standards do not exist, until
concentrations are achieved which do not present an
excess cancer risk greater than IxlO'6, if technically
practicable. Discharge treated ground water to either a
POTW or to surface waters in compliance with ARARs. (See
Ground Water Alternative 4).
The selected remedy and contingency measures are protective of
human health and the environment, comply with Federal and State
requirements that are legally applicable or relevant and
29
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appropriate to the remedial action, and are cost-effective.
Because treatment of the contaminated alluvial ground water was not.
found to be warranted at this time, this remedy does not satisfy
the statutory preference for treatment as a principal element of
the remedy. However, if monitoring data indicates that the
contingency measures need to be implemented, treatment nay take
place. Also, the selected remedy does not call for treatment of
contaminated soils because there are no identifiable on-site hot
spots that represent the major sources of contamination, meaning
that a remedy providing for excavation and treatment of soils would
not be practicable because it would require excavation and
treatment of the entire Landfill.
Because the selected alternative will result in hazardous
substances remaining on-site above health based levels, a periodic
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. Five year
reviews will be conducted during each five year period until
completion of the remedy.
Alternative 3
Source containment with ground water extraction and discharge
alternative that includes capping/ access restrictions, and ground
irater and landfill gas monitoring:
PW: $ 8,100,000
Years to Implement: 20
. Implement selected capping alternative;
. Land use restrictions;
. Pump contaminated ground water from alluvial aquifer;
. Discharge contaminated ground water to Publicly Owned
Treatment Works (POTW) or surface water; and
. Implement a landfill gas monitoring system to
prevent exposure to explosion or inhalation.
In addition to the physical containment provided by the clay cap,
this alternative includes hydraulic containment through ground
water withdrawal. Ground water would be collected by installing a
perimeter system of extraction wells or trenches and discharged,
without treatment, to a POTW or nearby surface water. This
alternative would reduce the potential for further migration of
contaminants from the alluvial aquifer into the Garber - Wellington
aquifer. If the contaminant concentrations in the extracted ground
water are above National Pollution Discharge Elimination System
(NPDES) permit requirements, treatment will be necessary; in that
30
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case, discharge to surface water would not be allowed.
Additionally, if the POTW does not accept the contaminated ground^
water, this alternative may not be feasible. Although this
alternative is a viable and feasible alternative, site specific
data indicate that the occurrence of the contaminated ground water
is limited and within the boundaries of the Site; thus, treatment
is not warranted at this time. Also, a ground water pump test
performed in January 1992, indicated that the sporadic nature of
contaminants in the alluvial ground water may reduce the technical
practicability of active ground water treatment.
Alternative 3a
Same as Alternative 3 with the addition of a slurry vail.
This alternative is identical to Alternative 3 with the addition of
a slurry wall.
EPA does not favor the use of a slurry wall at the Site for the
following reasons:
1. It May not be feasible to install a slurry wall at the
Mosley Road Sanitary Landfill due to the geological and
hydrogeological conditions at the Site.
2. Slurry walls do not reduce the volume or toxicity of
contaminants. Additionally, mobility of contaminants at
the Site can be controlled effectively by ground water
pumping if necessary.
3. The construction of a slurry wall at a depth greater
than 50 feet may be difficult. The waste pits at the Site
are located at an approximate depth of 80 feet.
4. In constructing a slurry wall at the Site, the North
Pond, a wetlands, will need to be drained. This action
may not meet the Federal ARARs regarding wetlands. (40
CFR, Part 6, Appendix A).
Alternative 4
Source containment, ground water extraction, treatment/ and
discharge alternative that includes capping, access restrictions,
and ground water and landfill gas monitoring:
PW: $20,000,000
Years to Implement: 20
. Restrict land use;
. Implement selected capping alternative;
. Pump ground water from contaminated alluvial
aquifer;
31
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. Treat extracted contaminated ground water onsite
and discharge treated ground water to POTW or
area surface water;
. Maintain ground water monitoring; and
. Implement a landfill gas monitoring system to
prevent exposure to explosion or inhalation.
This alternative is identical to Alternative 3 with the addition of
ground water treatment. The addition of ground water treatment
adds flexibility in discharge options from those available under
Alternative 3.
Alternative 4a
Same as Alternative 4 with the addition of a slurry wall:
PW:
Years to Implement:
This alternative is identical to Alternative 4 with the addition of
a slurry wall. See the slurry wall discussion in the common
element section and Alternative 3a.
Alternative 5
Source containment, leachate extraction, treatment, and discharge
alternative that includes capping, access restrictions, and ground
water and landfill gas monitoring:
PW: $14.,400,000
Years to Implement 20;
. Implement selected capping alternative;
. Land use restrictions;
. Extraction and on-site treatment of leachate;
. Discharge of treated leachate to area surface
water or POTW; and
. Implement a landfill gas monitoring system to
prevent exposure to explosion or inhalation.
This alternative primarily remediates the contaminated leachate and
also may indirectly remediate contaminated alluvial ground water.
As with Alternatives 3 and 4, it includes options for upgrading the
existing landfill cap to (1) increase its effectiveness in
preventing infiltration by precipitation; and (2) prevent future
erosion.
Leachate withdrawal under this alternative would include extraction
32
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both of leachate from within the Landfill refuse and of ground
water from the underlying alluvial aquifer. Alluvial ground water.
from outside the Landfill also would be intercepted by the leachate
extraction system. Thus, indirect remediation of a portion of the
contaminated ground water is •potentially feasible under this
alternative. Continued operation of the leachate extraction system
would be required to maintain upward vertical gradients from the
Garber-Wellington aquifer to the alluvial aquifer. This
alternative might be effective in preventing future migration of
contaminants from the alluvial aquifer to the Garber-Wellington
aquifer. Treatment of leachate would be accomplished through either
on-site treatment or off-site treatment by a POTW. However, if
the POTW does not accept the leachate, or if the leachate can not
be treated to comply with NPJDES permit requirements, this
alternative might not be effective.
Alternative 5a
Same as Alternative 5 with the addition of a slurry vail:
This alternative is identical to Alternative 5 with the addition of
a slurry waLl. See the slurry wall discussion in the common
element section and Alternative 3a.
Alternative 6
Source containment, ground water extraction and discharge; leachat*
extraction, treatment, and discharge alternative that includes
capping, access restrictions, and ground water and landfill gas
monitoring:
PW: $14,700,000
Years to Implement: 20 for leachate, 1 for ground
water
. Implement selected capping alternative;
. Implement land use restrictions;
. Pump contaminated ground water from the alluvial
aquifer;
. Discharge contaminated ground water to POTW or
nearby surface water;
. Extraction and on site treatment of leachate;
. Discharge of treated leachate to area surface
water or POTW; and
. Implement a landfill gas monitoring system to
prevent exposure to explosion or inhalation.
Alternative 6 remediates both leachate and ground water.
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This alternative is identical to Alternative 5 with the addition of
ground water extraction and discharge. Treatment of leachate would
be accomplished through either on-site treatment or off-site
treatment by a POTW. Ground water extraction would be accomplished
by wells or drains located outside the landfill area. Extracted
ground water would be discharged to surface water under an NPDES
permit, or discharged to a POTW. Remediation of the contaminated
alluvial ground water is anticipated to require extraction for six
months to a year. Continued operation of the leachate extraction
system would be required to maintain upward vertical gradients from
the Garber-Wellington aquifer to the alluvial aquifer.
Alternative 6a
Same as Alternative 6 with the addition of a slurry vallt
This alternative is identical to Alternative 6 with the addition of
a slurry wall. See the slurry wall discussion in the common
element section and Alternative 3a.
Alternative 7
Source containment, ground vator and leachate extraction, treatment
and discharge alternative that includes capping, access
restrictions, and ground water and landfill gas monitoring :
PW: $15,000,000
Years to Implement: 20 years for leachate
extraction, 1 for ground water
. Implement selected capping alternative;
. Land use and access restriction;
. Pump contaminated ground water from the alluvial
aquifer;
. Extraction and on-site treatment of leachate;
. "Treat extracted contaminated ground water onsite
or discharge treated ground water to POTW or area
surface water;
. Maintain ground water monitoring; and
. Implement a landfill gas monitoring system to
prevent exposure to explosion or inhalation.
This alternative is identical to Alternative 6 with the addition of
ground water treatment. This alternative provides for direct
remediation of both contaminated ground water and leachate.
Remediation of the alluvial ground water is anticipated to require
extraction for six months to a year. This alternative provides a
high degree of overall protection of human health and the
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environment in the shortest time frame. This alternative would
reduce site risk by substantially decreasing ground water and
leachate contamination present in the vicinity of the Site and
within the Landfill.
Alternative 7a
Saa« aa Alternative 7 with the addition of a slurry vail:
This alternative is identical to Alternative 7 with the addition of
a slurry wall. See the slurry wall discussion in the common
element section and Alternative 3a.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The nine criteria used to evaluate each alternative identified in
the FS are as follows:
Overall protection of human health and the environment;
- Compliance with applicable or relevant and appropriate
requirements;
Long-term effectiveness and permanence;
r Reduction of toxicity, mobility, or volume through
treatment;
Short-term effectiveness;
Implementability;
Cost;
State/Support Agency Acceptance; and
Community acceptance.
These nine criteria are categorized into three groups. The first
group contains what are referred to as the Threshold Criteria.
These criteria are: 1) Overall Protection of Human Health and the
Environment and 2) Compliance with Applicable or Relevant and
Appropriate Requirements. In order for a remedial alternative to
be selected, it must satisfy both Threshold Criteria. The second
group of criteria contains what are referred to as the Primary
Balancing Criteria. These criteria include: 1) Cost Effectiveness,
2) Short Term Effectiveness, 3) Long Term Effectiveness, 4)
Reduction of Toxicity, Mobility, and Volume of Contaminants Through
Treatment, and 5) Implamentability. These criteria are used to
weigh major tradeoffs among alternatives in making the final remedy
selection decision. The third group of criteria are referred to as
the Modifying Criteria. The criteria consist of 1) State
Acceptance and 2) Community Acceptance. These criteria are
considered by EPA in making its final remedy selection decision.
THRESHOLD CRITERIA
Overall Protection of Human Health and Environment addresses
whether or not a remedy provides adequate protection and
assesses how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering
controls, or institutional controls.
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Compliance with ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate,
requirements of other Federal and State environmental statutes
and /or provide grounds for invoking a waiver.
CRITERIA
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
examines the anticipated performance of the treatment
technologies that may be employed in a remedy.
Short-term effectiveness refers to the speed with' which the
remedy achieves protection, as well as the remedy's potential
to create an adverse impact on human health and the
environment that may result during the remedy construction and
implementation period.
Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
Cost includes both capital and operation and maintenance
costs .
MODIFYING CRITERIA
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 selected alternative.
Community Acceptance addresses the public's concerns and
comments regarding the RI/FS reports and the Proposed Plan of
Action for the Site.
A symbolic ranking of the comparative analysis for the capping and
ground water remedial alternatives and for the ground water
alternatives is included as part of this ROD (see Tables 18 and
19) . The symbolic ranking is based on the narrative analysis that
follows.
CAPPING ALTERNATIVES
THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment
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Each of the three capping alternatives will provide overall
protection of Human Health and the Environment. In addition, each.
of the capping alternatives will assist in eliminating the
migration of existing leachate and will reduce infiltration of
precipitation and subsequent formation of leachate. All of the
capping alternatives will prevent direct contact with the waste and
reduce the potential for precipitation to infiltrate into the
Landfill (and thereby assist in protecting human health and the
environment by preventing the formation of additional leachate) by
repairing and maintaining the existing clay cap on the Landfill.
The placement of the additional 2 feet of clay over the waste pit
areas required by capping Alternative 2, does not provide
additional protection to human health and the environment, since it
has been concluded that hot spots do not exist within the Landfill.
As with capping Alternative 2, the addition of an additional 2 foot
clay cap over the entire landfill required in capping Alternative
3, does not provide additional protection to human health and the
environment, since it has been concluded that hot spots do not
exist within, .the Landfill.
There will be no added benefit to protection of human health and
the environment provided by the more expensive Alternatives 2 and
3.
Compliance with ARARs
A detailed list of ARARs for the Site is provided in Table 20.
Chemical-specific ARARs do not apply directly to the capping
alternatives. Capping Alternatives 1-3 are designed to assist
indirectly in meeting chemical-specific ARARs for other media such
as ground water. None of the capping alternatives involve
treatment.
Action-specific ARARs for closure and post-closure (40 CFR 264.310
and 40 CFR 264.117) and the Oklahoma Solid Waste Management Act (63
O.S. 1981) and the Oklahoma Controlled Industrial Haste Disposal
Act (63 O.S. 1981) are expected to be met by all capping
alternatives.
Location-specific ARARs are not applicable to the Site in the
context of capping alternatives.
PRIMARY-BALANCING CRITERIA
Long-Term Effectiveness and Permanence
All of the capping alternatives would achieve long-term
effectiveness and permanence. All capping alternatives require
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long-term maintenance. with proper maintenance, all of the
capping alternatives are expected to assist in ensuring thai;
potential exposure to human and environmental receptors is within
acceptable levels. Although capping Alternatives 2 and 3 provide
extra protection due to the added thickness, Alternative 1 also
will adequately minimize infiltration at a lower cost.
Redaction of Toxicity, Mobility, and Volume Through Treatment
Since treatment is not taking place by improving the existing cap,
this criterion is not met.
Short-Term Effectiveness
Risks to workers and the community during implementation of all of
the capping alternatives are expected to be negligible.
Construction activities for all capping alternatives would be
conducted primarily on the outer surface of the Landfill without
exposing underlying waste. Therefore, environmental impacts are
expected to be insignificant for all three capping alternatives.
Upgrading the existing clay cap is likely to be completed in a
relatively short time period compared to remediation of other media
such as leachate or ground water. Upgrading the existing clay cap
will not significantly affect the time until response objectives
•are achieved.
ImplementaJbility
All of the capping alternatives would utilize readily available
equipment and technologies. Therefore, all of the capping
alternatives are technically and administratively feasible.
Cost
The present net worth cost for implementing capping Alternative 1
is approximately $3.1 million dollars. The present net worth cost
for implementing capping Alternative 2 is approximately $3.3
million dollars. The present net worth cost for implementing
capping Alternative 3 is approximately $5.7 million dollars.
MODIFYING CRITERIA
The modifying criteria are discussed in the ground water
alternative analysis.
GROUND WATER ALTERNATIVES
THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment
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Overall protection of human health and the environment is provided
by all of the alternatives with the exception of No Action. The
manner in which each of the alternatives protects human health and
the environment varies. Alternatives 6 and 7 protect human health
and the environment by extracting both ground water and leachate
and implementing institutional controls. Alternatives 5, 6, and 7
provide the greatest reduction in contaminant mobility by providing
a hydraulic barrier to ground water flow. Alternative 5 protects
human health and the environment by extracting leachate in
combination with institutional controls to ensure ground water
from onsite wells is not being used for domestic purposes.
Alternatives 3 and 4 protect human health and the environment by
extracting ground water and applying institutional controls to
ensure domestic ground water use is not taking place. Alternative
2 protects human health and the environment through implementation
of institutional controls, natural attenuation of the ground water
contamination, continual ground water monitoring to assure ground
water contamination is not worsening without being detected,
implementation of contingency measures for active ground water
remediation - if necessary, and continual maintenance of the clay
cap. The clay cap will 1) prevent direct contact with the waste
and 2) reduce the potential for precipitation to infiltrate into
the Landfill and prevent the formation of leachate within the
Landfill; thus, it will help reduce mobility through containment.
Alternative 1, No Action, does not include actions designed to
protect human health and the environment.
Implementing a slurry wall with any of the alternatives discussed
above would not greatly enhance the overall protection of human
health and the environment provided by their respective
alternatives which do not include the slurry walls.
Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs).
The alternatives were evaluated against chemical, action, and
location specific ARARs. This discussion compares each of the
alternatives to the three categories of ARARs and addresses whether
the alternatives comply with ARARs. A detailed list of ARARs for
the Site is presented in Table 20.
Chemical Specific ARARs
There are two key types of potential chemical specific ARARs at the
Site. NPDES, Federal, and State water quality requirements or
pretreatment standards (i.e Effluent. Limitation Guidelines for
Wastewater Discharge (Oklahoma Pollution Remedies Regulations
1070.2) , Raw Water Numerical Criteria for Public and Private Water
Supplies (Oklahoma Water Quality Standards, 300.5), Numerical Water
Criteria for Ground Water, (Oklahoma Ground Water Quality
Standards, 400.2) , and Oklahoma Water Quality Standards, 300.7 (F))
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may be ARARs for the discharge of extracted ground water or
leachate. SDWA regulations (MCLs) may be ARARs for ground water
quality in the event that the ground water is used as a source for
drinking water. MCLs are considered relevant and appropriate
requirements that must be met upon completion of the remedy.
Chemical-specific ARARs for the alternatives potentially apply to
the quality of ground water in the alluvial aquifer immediately
north of the Landfill and to discharge of leachate, ground water,
or a combination of leachate and ground water. Alternative 7
incorporates active collection and treatment of leachate and ground
water; thus, it would most likely meet all the chemical specific
ARARs. Alternative 6, which incorporates collection and treatment
of leachate but does not include treatment of collected ground
water prior to discharge, potentially would not meet chemical
specific ARARs. Alternative 5 includes extraction and treatment of
leachate prior to discharge, but does not include direct
remediation of alluvial ground water north of the Landfill.
Alternative - 5 may collect a portion of the contaminated alluvial
ground water .north of the Landfill during pumping; yet, it will
not provide for remediation of. this ground water and thus might not
meet all of the chemical-specific ARARs. Alternative 4 includes
extraction and treatment of alluvial ground water north of the
Landfill prior to discharge, but does not include direct
remediation of leachate and might not meet all chemical-specific
ARARs. Alternative 3 also may not meet all chemical-specific
ARARs since direct leachate remediation is not involved.
Chemical specific ARARs applicable to ground water quality may not
be met by Alternatives 3a, 4a, and 5a since ground water extraction
outside of the slurry wall is not included, and contaminated ground
water potentially could remain outside of the slurry wall.
Alternative 6a would meet chemical specific ARARs by implementing
a leachate and ground water collection system and subsequent on-
site treatment of leachate. Alternative 7a provides for treatment
of contaminated leachate and ground water, and would be expected to
meet chemical specific ARARs.
Alternatives 1 and 2 do not include remedial actions that directly
address compounds of concern in ground water or discharges *o
surface water from alluvial ground water. Thus, chemical-specific
ARARs, such as NPDES requirements, do not apply to these
alternatives.
Action-specific ARARs
Action specific ARARs are NPDES, RCRA and the Oklahoma Solid Waste
Management Act (63 O.S. 1981), the Oklahoma Controlled Industrial
Waste Disposal Act (63 O.S. 1981) , the Oklahoma Pollution Remedies
Law (82 O.S. 1981) and Control of Emissions of Hazardous Toxic Air
Contaminants (OSDH Regulation 3.8). Action-specific ARARs
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potentially apply to closure with waste in-place, discharge of
ground water and leachate to a POTW, discharge of ground water and
leachate to surface water, and air stripping. With the exception
of Alternative 1, all of the alternatives are expected to meet the
action-specific ARARs for capping and closure with waste in-place.
Alternative 2 provides for long-tern maintenance of a cap that will
minimize infiltration as required by the Resource Conservation and
Recovery Act (RCRA). Alternatives 4, 5, and 7 are expected to meet
the action-specific ARARs for discharge of ground water and/or
leachate to a POTW or surface water body under an NPDES permit.
Alternatives 3 and 6 may not meet action-specific ARARs for
discharge of ground water and/or leachate to a surface water body,
if the waste water effluent discharge does not meet the NPDES
permit requirements. Alternative 1 may not meet the action-
specific ARARs regarding closure requirements under RCRA.
Alternatives 3a, 4a, 5a, 6a, and 7a are expected to meet with all
action specific ARARS regarding capping, closure with waste in
place, discharge of treated leachate and discharge of untreated
ground water to a POTW.
Location-specific ARARs
Location-specific ARARs for the Site include RCRA, the National
Historical Preservation Act (NHPA), the Endangered Species Act
(ESA), and provisions of the Clean Water Act (CWA) regarding
wetlands. The State regulations regarding underground storage
tanks may be considered an ARAR at the Site.
Location-specific ARARs do not apply to Alternatives 1 and 2, since
these alternatives do not include hazardous waste treatment,
storage, or disposal; construction or alteration of terrain;
actions that may impact endangered or threatened species; or
actions that may impact wetlands. All of the alternatives other
than Alternatives 1 and 2 may not meet location-specific ARARs
regarding wetlands (40 CFR, Part 6, Appendix A), since all of the
alternatives other than Alternatives 1 and 2 include provisions for
draining North Pond, a wetland.
The slurry wall alternatives are expected to meet the location
specific ARARs, with the possible exception of the Clean Water Act
requirements regarding the preservation of wetlands.
PRIMARY BALANCING
Short-term Effectiveness
Risks to the community during construction and operation of any of
the remedial alternatives would be negligible. Risks to the
community during implementation of all the alternatives, except
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Alternatives 1 and 2, include potential emission of contaminants
during treatment. Alternatives 1 and 2 are considered to offer the
least risk to the community during remedial actions. Alternatives'
3, 4, 5, and 7 are considered to offer a slightly higher risk to
the community, since they have the potential to generate air
emissions or include transport of materials. Alternative 6 is
considered to offer the highest risk to the community, since this
alternative has the potential to generate air emissions via
treatment of leachate and includes transport of materials via truck
or pipeline to a POTW.
Risk to the community posed by the slurry vail alternatives is
similar to their respective non-slurry wall alternatives.
Protection of Workers During Remedial Actions
Alternative 1 does not include remedial actions. Risks to workers
during remedial actions taken under Alternative 2 would be
negligible. Risks to workers during remedial actions taken under
Alternatives., 3 and 4 would be comparable to risks normally
associated with closure of a municipal landfill and installation of
wells; therefore, risks to workers under these alternatives are not
considered significant.
Risks to workers during remedial actions taken under Alternatives
5, 6 and 7 would be greater than under Alternatives 3 and 4
because wells would be drilled into municipal refuse. Previous
drilling experience at the Site indicates that respiratory
protection would be needed during drilling. Risks to workers
during remedial actions taken under Alternatives 5, 6 and 7 would
be comparable to each other.
The risk posed by Alternatives 3 and 3a are comparable. The risk
posed by 4 and 4a are comparable. The risk to workers presented by
Alternatives 5a, 6a, and 7a are equivalent to the risk posed by
Alternative 5, and are higher than the risk posed by Alternatives
3, 3a, 4 and 4a. This is due to the fact that Alternatives 3 and
4 require wells to be installed at the perimeter of the Landfill
while the others require installation of wells into the Landfill.
Thus, the potential exists for exposure to inhalation of landfill
gas that may be present due drilling.
Environmental Impacts
This Section discusses the potential environmental impacts that
might occur as a direct result of construction and implementation
of the various alternatives. In this context, environmental
impacts do not include impacts of site contamination.
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Alternative 1 does not include remedial actions. No significant
environmental impacts would occur as a direct result of
construction and implementation of Alternative 2.
Potential environmental impacts under Alternatives 3, 4, and 5 are
comparable to each other. These alternatives include drainage of
North Pond, decreases in alluvial ground water levels, potential
decreases in stream flow of Crutcho Creek, and potential lowering
of water levels in South Swamp and the abandoned sand and gravel
pit. No current ground water users that would be affected by
decreased alluvial water levels have been identified near the Site.
Reduced flows in Crutcho Creek could affect downstream water users
and may involve water rights issues. Impacts to wetlands may occur
as a result of draining the North Pond, if this is determined to be
necessary.
Several possible environmental impacts could occur as a result of
construction and operation of Alternatives 6 and 7. As with
Alternatives 3, 4, and 5 these impacts include drainage of the
North Pond, decreases in alluvial ground water levels, decreases in
stream flow j.n Crutcho Creek, and potential lowering of water
levels in South Swamp and the abandoned sand and gravel pit.
Alternatives 6 and 7 also require operation of a ground water
collection system that would lower water levels in the alluvial
aquifer near the Site. No current ground water users that would be
affected by decreased alluvial water levels have been identified
near the Site. The ground water collection system also may
intercept surface water contained in Crutcho Creek, the South Swamp
and the abandoned sand and gravel pit, and thus impact the wetlands
in the area.
As with Alternatives 3,4,5,6,and 7, Alternatives 3a, 4a, 5a, 6a,
and 7a could cause environmental impacts since it may be necessary
to drain or partially drain the North Pond to construct the slurry
wall.
Time Until Response Objectives Are Achieved
It is anticipated that Alternatives 3, 4, 5, 6, and 7 would require
several months to implement. Once implemented, these alternatives
would provide hydraulic containment within a relatively short
period (i.e., several days to weeks). Remediation of contaminated
alluvial ground water under these alternatives is estimated to take
up to one year. Calculations indicate that Alternatives 5, 6, and
7 may require 3 to 15 years to achieve the desired reduction in
alluvial water levels beneath the Landfill in order to reverse
vertical gradients between the alluvial and Garber-Wellington
aquifers and protect the Garber - Wellington aquifer from the
migration of contaminants from the alluvial ground water.
Alternatives 3 and 4 may require 10 to 150 years to achieve the
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desired gradient reversal that is necessary for these alternatives
to achieve their remedial objectives.
It is anticipated that Alternatives 3a, 4a, 5a, 6a, and 7a would
require up to a year to implement. The time until the response
objectives are achieved under Alternatives 3a, 4a, 5a, 6a, and 7a
is the same as that associated with their respective non-slurry
wall counterparts.
The time to achieve response objectives under Alternative 2 would
be dependent on the time needed to enact the institutional controls
along with the time to implement contingency measures as needed.
No response actions would be undertaken as part of Alternative 1.
Long-Term Effectiveness and Permanence
The goal for all of the alternatives calls for the eventual
reduction of vinyl chloride concentrations in the ground water to
0.002 ppm and the reduction of all other contaminants to within
the acceptable risk range and below MCLs at any reasonably expected
point of exposure as established in the remedial design phase. The
selected alternative remediates contamination by natural
attenuation, prevents future spread of contaminants, and should
achieve the remedial goal.
Permanence of the alternatives considered for the Site is reliant
upon proper maintenance of the cap. This is because the cap is
necessary to reduce infiltration of precipitation and further
migration of contaminated leachate from the Landfill into the
ground water and soils. All of the alternatives provide for
continual maintenance and/or upgrading of the existing cap. The
alternatives which do not involve treatment of the contaminants
should be effective for as long as the cap effectively reduces
infiltration of precipitation.
Alternatives 5, 6, and 7 would provide the most effective long-
term control of contaminant migration by introduction of a
hydraulic barrier (through reversal of the hydraulic gradient
between the alluvial and Garber - Wellington aquifers) to
contaminant migration. Alternative 7 assumes that treatment of
alluvial ground water north of the Landfill will be necessary to
reduce the magnitude of residual risks to an acceptable risk level,
making this (7 and 7a) the most permanent of all of the
alternatives considered. Alternative 6 assumes that the
concentration of contaminants in ground water is low enough that
treatment will not be necessary to reduce the magnitude of residual
risks to, acceptable levels. Each of these alternatives assumes
that leachate will be treated prior to discharge. The residual
risks associated with these alternatives are expected to be low.
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Alternatives 3 and 4 provide essentially equivalent long-term
effectiveness and permanence. These alternatives include alluvial
ground water extraction from the Landfill perimeter, which is
assumed to be less desirable than extraction of leachate from
within the landfill boundaries due to the difficulty in achieving
the desired lowering of hydraulic heads beneath the Landfill under
these alternatives. The long-term effectiveness of Alternatives 3
and 4 would be dependent on continued operation and maintenance of
the extraction and discharge system.
Implementing a slurry wall with any of the alternatives discussed
above would not enhance the overall protection of human health and
the environment beyond that provided by their respective non slurry
wall counterparts. However, if slurry walls were properly
implemented 'at the Site, they potentially could provide greater
long-term effectiveness. (However as discussed in previously, the
installation of a slurry wall may not be feasible at this site.)
Alternative 2 is considered to be effective in meeting the goals
for long-term effectiveness and permanence if current site
conditions improve over time. If the concentration of contaminants
in ground water increases over time, Alternative 2 will be less
able to meet the goals of long-term effectiveness and permanence
than are the other alternatives. However, in the event contingency
measure criteria are met, the contingency measures provided for in
Alternative 2 which provide for treatment of the contaminated
ground water and/or leachate would provide long term effectiveness
and permanence.
Alternative 1 does not meet the goal of providing long term
effectiveness or permanence.
Reduction of Toxicity, Mobility, and Volume Through Treatment
Alternatives 4, 4a, 7 and 7a are the alternatives which include a
treatment component and meet the requirement of reduction of
toxicity, mobility, and volume through treatment. Both of these
alternatives are comprised partially or wholly of ground water
extraction, treatment, and discharge.
Alternatives 1, 2, 3, 3a, 5, 5a, 6 and 6a do not provide for
treatment of contaminated ground water and thus do not provide for
the reduction of toxicity, mobility, and volume through treatment.
Alternative 6 reduces contaminant mobility, volume, and toxicity
through recovery of both alluvial ground water recovery north of
the Landfill and leachate. This alternative does not meet the
treatment preference because extraction of ground water and
leachate is not considered a form of treatment.
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Jmplementability
Technical Feasibility
Alternative l does not include response actions.
All other alternatives utilize readily available materials and
equipment and are technically practical. Though the technology for
Alternatives 3a, 4a, 5a, 6a, and 7a is readily available; it nay
not be feasible to install a slurry wall at the Site due to
geological and hydrogeological condition at the Site. The
construction of a slurry wall at a depth greater than 50 feet may
be difficult. The waste pits are located at a depth of
approximately 80 feet.
Administrative Feasibility
Administration would not be necessary under Alternative 1.
Monitoring of site conditions under Alternative 2 would be
administratively feasible. Alternatives 3, 4, 5, 6 and 7 are
considered slightly less feasible from an administrative standpoint
due to the increased potential for the need to obtain and comply
with the requirements of NPDES permits due to the potential for
releasing extracted ground water or leachate contaminated with
hazardous substances above acceptable levels and the need to
comply with wetlands requirements.
The administrative feasibility Alternatives 3a, 4a, 5a, 6a, and 7a
is comparable to that associated with their respective non-slurry
wall counterparts.
Cost
The cost of the selected alternative, which does not include the
cost of the selected cap ($3,100,000), is $500,000. This is the
lowest-cost alternative. The highest-cost alternative is
Alternative 4a at $23,000,000.
MODIFYING CRITERIA
••».
State Acceptance
The State of Oklahoma, through OSDH, concurs with both the capping
and ground water remedies, including contingencies, selected by EPA
(Attachment 2).
Community Acceptance
The community comments for both the capping and ground water
remedies were received during the public comment period, and are
addressed in the attached Responsiveness Summary (Attachment 1) .
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II. SELECTED REMEDY
As previously stated in Section IV of this ROD, the goal of the
remedial action is to: 1) contain the slight ground water
contamination that currently exists within the current boundaries
of property owned by the site owner; 2) implement institutional
controls to prevent exposure to on site contaminants; 3) preserve
the current beneficial use of off site ground water, as a potential
source of drinking water; 4) prevent degradation of the Garber-
Wellington aquifer; 5) prevent water infiltration through the
Landfill that could increase contaminant transport into the ground
water; 6) restore ground water to beneficial use through natural
attenuation; 7) prevent direct contact with and exposure to
landfill contents; and 8) prevent inhalation of and explosion of
landfill gas.
Based on consideration of the requirements of CERCLA, the detailed
analysis of the alternatives, and public comments, EPA has
determined that the combination of capping Alternative 1 (Repair
and improvement of the existing cap and addition of a vegetative
soil layer) and ground water Alternative 2 ( Limited Action:
Source containment via a cap, Ground water and Landfill Gas
Monitoring with Contingencies for Active Remediation) with
contingency measures is the most appropriate remedy for the Mosley
Road Sanitary Landfill Site in Oklahoma City, Oklahoma.
EPA believes that the selected remedy will achieve the goals
described. However, it may become apparent, during implementation
of the selected remedy, and its ongoing ground water monitoring
program, that contamination is increasing either in the Garher-
Wellington aquifer or in the alluvial aquifer. If that occurs,
contingency measures (as discussed in this Section of this ROD)
will be implemented. The initial phase of such contingency
measures will consist of increasing the number of wells and/or the
frequency of sampling to confirm and further define changes in
detected conditions. Upon confirmation that ground water
contamination does exceed the established contingency measure
criteria, appropriate remedial alternatives may be implemented.
Any of the remedy alternatives evaluated in the FS that meet the
nine evaluation criteria ultimately may be implemented based upon
an evaluation of technical practicability and what is necessary to
achieve protection of human health and the environment.
SELECTED CAP IMPLEMENTATION
Repair of the existing cap at a minimum will include stripping and
replacement of the upper 1 foot of clay (if necessary to repair
cracking), compaction of both any replaced clay and any clay being
added to the existing cap, and addition of a minimum of 6 inches of
vegetative soil on top of the cap. Erosion control protection of
the side slopes shall be provided while the vegetative layer is
being established.
47
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The cover thickness on the side slopes of the cap will be increased
from 2 to 2.5 feet of clay plus a 6 inch cover which is capable of
supporting vegetative growth in order to meet current Oklahoma
closure regulations (Oklahoma Regulations Governing Solid Waste and
Sludge Management, Sec 3.0.13, 1990). Suitable surface slopes
(i.e. 4 percent) shall be reestablished on the surface of the
Landfill.
The cap shall be maintained in accordance with the remedial design
phase, and for the duration of the remedial performance.
THE GROOHD WATER MONITORING PROGRAM
Implementation of the ground water monitoring program requires that
risks presented by contaminants be calculated as part of each
monitoring cycle (as established in the remedial design), and/or
that contaminant concentrations be compared with pre-calculated
ground water concentrations resulting from the RI. All ground
water risk calculations shall take into account cumulative risk
posed by Site contaminants. The methodology used to calculate and
compare risks shall be the same as that used to calculate lifetime
risk under a residential scenario in the Risk Assessment conducted
during the RI.
The specific ground water monitoring program will be developed as
part of remedy design, but shall contain at a minimum:
1. Quarterly monitoring of the Site wells during the first two
years, and semi-annual monitoring thereafter. In the event
that contingency measure criteria are exceeded, the monitoring
frequency and/or the number of wells may be increased.
2. Reliance on the "Guidance Document on the Statistical Analysis
of Ground-Water Monitoring Data at RCRA Facilities", or
alternate methods as allowed by the guidance, to establish a
method for determining whether contaminant concentrations have
experienced a statistically significant increase at the
designated ground water monitoring locations.
3. At least three (3) wells in the alluvial aquifer, and at least
three (3) wells in the Garber-Wellington aquifer at the point
of compliance. The point of compliance shall not be set
beyond the current property boundary owned by the current Site
owner at the time of the original signing of this ROD. At
least two (2) wells will be required in the Garber-Wellington
aquifer downgradient of the point of compliance. At least
four (4) wells will be required in the alluvial aquifer
upgradient of the point of compliance, with at least two (2)
being adjacent to the Landfill. At least two (2) wells will
be required in the Garber-Wellington upgradient of the point-
of-compliance.
48
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4. Calculation and evaluation of risk posed by specific
contaminants and combinations of contaminants as part of each
sampling cycle.
5. Establishment of "background" concentrations and risks in each
sampling location during the first two years of remedy
implementation. In the event that the calculated background
risks exceed the risks presented in the Risk Assessment in the
RI/FS, EPA may, as warranted by the actual results and in
consideration of the contingency measure criteria and
technical practicability, require the implementation of
contingencies based on the background data.
Contingency Measure Criteria and Presumptive Responses.
The following criteria will be considered as indicators that the
selected remedy is not performing as required. They will trigger
contingency measures, beginning with confirmation ground water
sampling, and potentially resulting in implementation of active
ground water treatment remedies if determined to be necessary by
EPA. The ..following criteria, when used to require the
implementation of active remediation contingency measures, will
ensure that the remedial goals are met and that the remedy will be
protective of human health and the environment.
l. A statistically significant increase in contamination in the
wells established as part of the ground water monitoring
system. The statistical increases also will be evaluated in
terms of the impact on cumulative risk to human health and the
environment. For example, if a contaminant exhibits a
statistically significant increase, but there is no net
increase in risk due to factors such as decreases in
previously detected contaminants or the fact that the new
contaminant is not toxic at the concentrations detected, there
will not necessarily be a presumption that active remediation
is required. Exceptions to this presumption would include,
but not be limited to, situations such as that in which data
indicates that risk is increased at other locations such as
beyond the monitoring point or in the Garber-Wellington due to
migration, or if the newly detected contaminant concentration
indicates that an MCL may be exceeded beyond the point of
compliance.
2. The appearance in the Garber-Wellington aquifer of any
contaminant or combination of contaminants that exceed a
1 X 10"5 (l in 100,000) excess cancer risk or that have a non-
carcinogenic HI greater than 1.0.
There shall be a presumption that an increase in risk in
the Garber - Wellington above 1 x 10"5 excess cancer
cases is indicative that natural attenuation is not
49
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working to prevent further degradation of the Garber -
Wellington aquifer by the more contaminated overlying
alluvial aquifer. Active remediation of the alluvial
aquifer and/or the Garber - Wellington will be required
unless demonstrated to EPA to be technically
impracticable.
3. Any contamination that creates a risk greater than 1 X 10"4
excess cancer cases in either the alluvial or Garber -
Wellington aquifer at the point of compliance or in off-site
wells. There shall be a presumption in such cases that the
remedy is not performing as required, and that active ground
water remediation will be required unless demonstrated to EPA
to be technically impracticable.
4. The effectiveness of natural attenuation to reduce
contamination in the alluvial aquifer will be evaluated after
each five year review of the remedy. If natural attenuation
is not working to reduce contaminant concentrations, including
but not limited to concentrations of vinyl chloride and/or
benzene,, in the alluvial aquifer after the initial five year
review, or subsequent five year reviews, EPA may require
implementation of active ground water remediation measures.
Such measures may include new technologies, not considered for
this ROD, that are technically practicable. In the event such
technologies are implemented at the Site, EPA will make
appropriate changes in this ROD.
Remediation Goals
MCLs are ARARs for ground water at the Site. All ARARs must be met
upon completion of the remedy.
In the event that active ground water remediation is required, the
remediation goal for ground water shall be MCLs. If there is no
MCL for a particular contaminant, the remediation goal shall be set
so that the combination of particular contaminants of concern does
not pose a cumulative cancer risk greater than 1 X 10'6, and has
a non-cancer HI less than 1.0, if technically practicable, as
determined by EPA.
It may become apparent during implementation or operation of the
ground water or leachate extraction system and its upgrades or
modifications, that contaminant levels have ceased to decline, or
decline very rapidly to non-detect levels only to rebound upon
cessation of extraction. If EPA determines that implementation of
the selected contingency measure demonstrates, in corroboration
with hydrogeo logical and chemical evidence, that it will be
technically impracticable to achieve and maintain the performance
standards, EPA may require that any or all of the following
measures be taken:
50
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1. Long-term gradient control may be provided as a containment
measure;
2. Chemical-specific ARARs or risk based clean-up goals may be
waived;
3. Institutional controls may be expanded to restrict access to
portions of the aquifer where contaminants remain above
remediation goals; and/or
4. Different remedial technologies for ground water restoration
may be evaluated and implemented.
Depending on whether a significant or fundamental change in the
remedy is proposed, an Explanation of Significant Differences or an
Amendment to the Record of Decision will be issued to 'inform the
public of the details of the modification. A change from active
restoration to passive restoration would be considered a
fundamental change.
x. STATUTORY; DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA, 42 U.S.C. $ 9621, establishes
several other statutory requirements and preferences that the
selected remedy must meet. Section 121 specifies that when
complete, the selected remedial action for this Site must comply
with ARARs 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 capping and ground
water remedies meet these statutory requirements.
In the event the selected ground water remedy fails to address the
contaminant concentrations in accordance with the performance
standards set forth in the ROD and the contingency measure criteria
set forth in the ROD are met, the contingency measures will be
implemented at the Site. Depending upon the nature of the data or
events triggering implementation of the contingency measures, any
of the other more active remedial alternatives discussed in the ROD
(i.e., Alternatives 3, 4, 5, 6, and 7, all of which are variations
of a ground water and/or leachate pumping technology) may be
implemented at the Site. The ROD has subjected each of these
alternatives to the required nine criteria assessment. In addition
to discussing the selected remedy, the following sections also
51
-------
describe how each of •the potential contingency measures meet 'the
statutory requirements.
Protection of Health and the
The selected capping remedy protects human health and the
environment by eliminating the direct contact risk and reducing the
potential for any contaminants to migrate from the waste pits to
the ground water as a result of precipitation and leachate
formation. The capping will eliminate all threats relating to
direct contact with and inhalation of the residual contamination by
covering and maintaining the contaminated soils in place. Site
capping also will all but eliminate the continued migration of
vinyl chloride from the waste pit soils into the ground water by
preventing infiltration of precipitation and the subsequent
formation and migration of leachate.
The selected remedy also protects human health and the environment
by providing for continual landfill gas monitoring and ground water
monitoring with contingencies for active remediation of the ground
water if necessary (e.g. if contamination is spreading
unacceptably, or if natural attenuation is not taking place) . The
natural attenuation that is expected to occur during the
implementation of the selected remedy should operate to reduce the
contaminant levels in the ground water. Thus, the ground water
would no longer pose a risk to human health and the environment
beyond the established compliance points. If during the monitoring
of the alluvial and Garber Wellington aquifer wells it is
determined that active remediation is warranted, one of the
contingency measures will be implemented.
Site access and land use restrictions prohibiting any commercial or
residential activity will be implemented. This will help achieve
protection of human health and the environment by ensuring that any
contaminated ground water remaining on site will not be used as a
source of drinking water. Through the combined use of
institutional controls and the monitoring program, the potential
for exposure from ingestion of contaminated ground water is greatly
reduced. Site access restrictions also will serve to lessen the
potential for completion of the direct exposure pathway.
Each of the potential contingency remedies, which may be selected
based on the specific circumstances triggering contingency
measures, is protective of human health and the environment. This
protection is achieved by reducing the concentration of
contaminants in the ground water. Contingency Alternatives 3 and
6, which do not require treatment of all extracted liquids, may not
be protective at the point of discharge, and therefore would not be
implemented, if ground water or leachate concentrations exceed
limits that can be discharged to surface waters or a POTW.
52
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There are no short-term threats associated with the implementation
of either the selected remedy or any of the contingency
alternatives that cannot readily be controlled. Further, no
adverse cross-media impacts are expected from the capping remedy.
c*^le or Relevant an* QP^ ia t e
The selected remedy for the Site complies with all applicable or
relevant and appropriate action-, chemical-, and location-specific
requirements ("ARARs") . The Site ARARs are presented in Table 20.
As discussed in the alternatives evaluation section, contingency
Alternatives 3 and 6 may not meet chemical specific ARARs if
chemical concentrations in extracted ground water or leachate
exceed discharge criteria. In the case where discharge criteria
are exceeded, Alternatives 3 and 6 would not be the selected
contingencies. Each of the contingencies may not meet action
specific ARARs for wetlands protection if draining the North Pond
is required.. In the event, that draining the North Pond is
required to ensure success of the selected ground water contingency
remedy, an ARAR waiver might be invoked in order to prevent a
greater risk to human health and the environment. Each of the
ground water contingency remedy Alternatives 3, 4, 5, 6 and 7 is
expected to meet all other ARARs.
Cost-Effectiveness ;
The selected capping remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs, the net present worth value being $3,100,000.00. The
estimated amount of infiltration allowed through the existing cap
is very low, and since a discrete source of contamination was not
detected within the Landfill, there is no need for the additional
clay layers contemplated by the other two capping alternatives.
Also, neither of the other two capping alternatives would be more
protective of human health and the environment than the selected
capping remedy, yet would increase the cost of the remedy by up to
$2.5 million.
The selected ground water remedy is also cost-effective, its
present worth value being $500,000.00. The estimated costs of the
selected remedy are less than the cost associated with installation
of a ground water extraction and discharge system ($8,100,000.00),
but are more than the costs associated with the No Action
alternative ($0.00). Since the selected remedy will be fully
protective of human health and the environment if implemented
properly, it is the most cost effective of the alternatives.
There is currently insufficient information to determine the cost
effectiveness of the contingency ground water remedies that might
53
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be implemented. In the event it becomes necessary to implement the
contingency ground water remedies, each of the Alternatives 3
through 7 will be evaluated in light of the particular
circumstances to determine their relative cost effectiveness.
Extent Practical*
The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practical at the
Mosley Road Sanitary Landfill site.
Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that the
selected remedy provides the best balance of trade of f s in terms of
long-term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term
effectiveness, implementability, costs, and taking into
consideration State and community acceptance.
The selected remedy does not meet the statutory preference for
treatment as a principal element. However, no principal threats or
"hot spots" have been identified which warrant treatment.
When discussing short-term effectiveness and implementation, the
other capping alternatives meet the criteria just as well as the
selected capping alternative component of the remedy.
The selected ground water remedy satisfies the long-term
effectiveness and permanence criterion by preventing future spread
of contamination to receptors beyond the points of compliance and
promoting restoration of ground water quality. It satisfies the
implementability and short term effectiveness criteria better than
all of the other alternatives investigated for possible solutions
to the contamination problems at the Nosley Road Sanitary Landfill
Site. It does, however, fall behind pump and treat alternatives
with respect to meeting reduction in toxicity, mobility and volume
criteria. Again, the cost associated with implementing the
selected ground water remedy is less than the cost associated with
implementing the more aggressive extraction and discharge
alternatives. However, site specific data currently does not
indicate that active remediation is warranted. The sporadic nature
of contaminant detections, combined with the results of the January
1992 seven day pump test conducted in the alluvial aquifer, suggest
that under current conditions, ground water pumping to remove
contaminated ground water may not be technically practical.
If implemented, each of the contingency ground water remedies will
satisfy the requirement for long-term effectiveness and permanence,
unless demonstrated to be technically impractical.
54
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fog Treatment as a Principal
The statutory preference for remedies that employ treatment as a
principal element will not be satisfied through implementation of
the selected remedy under current site conditions. However, the
selected remedy provides for the statutory requirement to utilize
permanent solutions and treatment technologies to the m^yim""
extent practicable based on criteria established by this ROD
through implementation of certain contingency measures in the event
future data indicates that active remediation is warranted.
Each potential contingency ground water remedy meets the
requirement for treatment as a principal element of the remedy.
The Proposed Plan for the Mosley Road Sanitary Landfill Site was
released for public comment in April 1992. The Proposed Plan
identified capping Alternative 1 (Repair and improvement of the
existing cap.and addition of a vegetative soil layer), and ground
water Alterative 2 ( Limited Action: Source containment via a clay
cap. Ground water and Landfill gas monitoring with Contingencies
for Active Remediation) as the selected alternatives for the Site.
EPA reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, it was
determined that in addition to the preferred remedy as it was
originally identified in the Proposed Plan, a fish tissue study
might be necessary. Accordingly, provision has been made for the
performance of fish tissue studies.
55
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TABLES
-------
TABLE 1
INDUSTRIAL WASTES REPORTEDLY DISPOSED
IN THE MOSLEY ROAD SANITARY LANDFILL
"
:
Type of Waste
Acetylene Sludge
Acid Solution
Alkaline Solution
Cannery Waste
Carbon Stripper
Caustic
Caustic Rinse Water
Caustic Sludge
Caustic Soda
Caustic Soda Water
Caustic Water
Chlorbethane V.G.
Emulsion
Etching Solution
Floor Water
Glycol Alcohol
Grease
Hydroxide Sludges
Kerosene
News Ink
Nontoxic mud and water
Oil
Other materials
Paint Sludge
Polypropylene
Resins
Skydrol
Sludge
Solvent
Solvent & Ink
Toxaphene
Toxic mud and water
Toxic Tank Bottom Sediment
Treated Plating Sludge
Trichloroethylene
Water
Total Disposed
Estimated Volume Disposed*
(gaflons)
1,250
35,423
10,522
150
165
2,900
2,400
600
11,800
2,900
13,200
4,220
1,500
2,424
500
165
125
1 ,397,259
240
744
12,848
36,145
1,200
27,609
3,960
500
110
4,200
27,660
8,400
38,150
160
100
10,000
3,800
1.930
1,665,259
* Source: Oklahoma State Department of Health manifest records.
Source: Colder Associates, Inc, Waste Management of Oklahoma, IDC, Draft Final Feasibility Study Volume
n, November 1991
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TABLE 2
SURFACE SOILS DATA SUMMARY
MOSLEY ROAD SANITARY LANDFILL
Sheet 1 of 1
Parameter
Acetone
1,1,2-TCA'
Carbon Tetrachloride
Chlorobenzene
Cyanide
Ethyl Benzene
Tetrachloroethene
Total Xylenes
Benzo (g,h,i)perylene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Bis(2-ethylhexyl)phthalate
Butlbenzylphthalate
Chrysene
Fluoranthene
Indeno( 1 ,2,3-cd)pyrene
Phenanthrene
Pyrene
Frequency
of
Detection
1/14
9/14
6/13
9/13
14/14
1/13
5/13
1/13
2/14
1/14
2/14
2/14
2/14
2/14
2/14
2/14
4/14
2/14
3/14
4/14
Range
of
SQL
frg/kg)
0.010-1.2
0.005-0.8
0.005-0.007
0.005-0.007
0.44-0.63
0.005-0.007
0.005-0.007
0.005-0.007
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
0.35-0.46
Range
of
Detected
Cone.
(fflg/kg)
5.2
0.001-0.075
0.002-0.015
0.0007-0.032
0.58-6.3
0.025
0.0005-0.016
0.065
0.049-0.057
0.079
0.052-0.07
0.045-0.059
0.046-0.066
i 0.085-0.11
0.042-0.15
0.055-0.067
0.038-0.16
0.042-0.046
0.028-0.079
0.031-0.14
95%
UCL
(mg/kg)
1.04
0.096
0.0058
0.013
1.88
0.0078
0.0068
0.016
0.214
0.219
0.214
0.214
0.214
0.210
0.217
0.214
0.203
0.214
0.206
0.201
Data
Qualifiers
" • : :' -. ••:-: • •"""
. - ':'--:.:£*S:..; -;:
' ' : " '.. ;- •<:':':'.:'
Yes(U*)
Yes (U,jr)
Yes(U,J)
Yes(U,J)
Yesr)
Yes(U)
Yes(U,J)
Yes(U)
Yes(U,J)
Yes (U,J)
Yes (U,J)
Yes (U,J)
Yes (U,J)
Yes (U,J)
Yes(U,J)
Yes (U,J)
Yes (U,J)
Yes (U,J)
Yes (U,J)
Yes (U,J)
Note: 95% UCL = upper limit of the 95th-percentile confidence interval on the arithmetic average
concentration.
• 1,1,2 - TCA-Trichloroethane
* u - The material was not analyzed for, but was not not detected. The associated numercial value
is the sample quantitation limit.
• J - The associated numerical value is an estimated quantity.
* * - Duplicate analysis not within control limits.
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation Report,
April 19912.
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TABLE 4
WATER DATA
IAD SANITAR
Sheet 2 of 2
*W
r c
£S
II
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V 'P'-T T T
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-------
TABLE 6
GABER-WEULINGTON GROUND WATER DATA SUMMARY
MOSLEY ROAD SANITARY LANDFILL
Frequency Range
Parameter
of
of
• Range
of
Detected
95%
UCL
Detection SQL (mg/L) Cone. (mg/L^ ' ing/E' Qualifiers
Chloroethane . 2/15 0.01-0.01
Vinyl Acetate 1/15 0.01-0.01
Benzene 4/15 0.005-0.005
Chforobenzene .. 2/15 0.005-0.005
1,1-Dichloroethane 1/15 0.005-0.005
1,2-Dichloroethene (total) 1/15 Q.005-0.005
Total Xylenes 1/15 0.005-0.005
Carbon Oisulfide 1/15 0.005-0.005
Arsenic 11/15 0.0-1-0.01
Barium U/15 0.0013-0.2
Manganese 15/15 0.015-0.015
Vanadium 2/15 0.0038-0.05
0.009-0.021
0.002
0.002-0.008
0.011-0.026
0.001
0.004
0.001
0.004
0.0066-0.022
0.038-0.331
0.0485-1.74
0.0527-0.0621
0.0082 Yes(U,J)
0.0052 Yes(U,J)
0.0035 Yes (U.J)
0.0075 Yes(U)
0.0026 Yes (U.J)
0.0028 Yes(U.UJJ)
0.0026 Yes(U.J)
0.0028 Yes (U.J)
0.0123 Yes (B,S,J,U,BW,BS)
0.155 Yes (B)
0.621 No
0.0018 Yes(B.U)
NOTE: 95% UCL = upper limit of the 95th-percentile confidence interval on the arithmetic average
concentration.
Source: Colder Associates, Inc, Waste Management of Oklahoma, In&, Final Remedial Investigation Report
April 1991
-------
TABLE 7
MOSLE Y ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT Jfa
SHEET 1 OF 10
Chemical
Name
BH-101-56
VOA
Acetone
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
BH-101-58
VOA
Acetone
INORGANIC
Aluminum
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Zinc
BH-101-58-MS
VOA
Acetone
BH-101-58-MSD
VOA
Acetone
Validated
Result
•
79
23,600
20.2
338
1.4
67,100
22.2
13.3
23.5
24,200
20.8
12,700
563
22
4,150
19.9
56.2
29
5,710
6.9
91.2
18,900
7.2
7.4
7,310
5
3,790
120
17.1
44
51
Contract
Required
QuantitatioB
Limit
15
44
11
44
1.1
1,100
2.2
11
5.5
22
2.7
1,100
3.3
8.8
1,100
11
4.4
14
40
2.1
40
1,000
2
5
20
0.62
1,000
3
4
14
14
Units
-
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/Kg
ug/Kg
Lab4
Qualifier
.
E*
-E
E
E*
E
E
E
N
E*
NE*
E
E
E*
E
E*
E
E
E
SN
E
NE*
E*
* *^l
Validation"
Qualifier
J
J
A
J
J
J
J
J
J
J
J
J
J
UJ
J
J 1
J |
f
J
J
A
J
J
J
J
J
J
J
J
J
J
J J
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT
SHEET 2 OF 10
Chemical
Name
BH-102-19A
VOA
Acetone
Total xylenes
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
BH-102-EB
VOA
Acetone
INORGANIC
Iron
Validated
Result
*
98
6
21,000
21
358
1.3
61,500
21
12.4
24.6
26,000
17.9
10,300
513
21.2
3,950
29.1
59.2
17
106
Contract
Required
QuantitatioB
Limit
13
5
44
11
44
1.1
1,100
2.2
11
5.6
22
1.4
1,100
3.3
8.9
1,100
11
4.4
10
100
Units
ug/Kg
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ing/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/L
ug/L
Lab-
Qualifier
J
E*
E
E
E*
E
E
E
N
E*
NE*
E
E
E
Validation"
;' O«*lif i«r
•••: -..::/ :
.- ' ; ' -
J
A
J
A
J
J
J
J
J
J
J
J
J
J
UJ
J
J
J
A
UJ
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT
SHEET 3 OF 10
Chemical
Name
BH-103-10
VOA
Methylene chloride
Acetone
Toluene
BNA
Fluoranthene
Pyrene
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Validated
Result
79
180
7
46
45
19,800
16.9
234
1.2
40,800
19.5
11.3
18.8
19,300
16
9,950
407
0.36
20.3
3,400
1,120
21.4
46.6
Contract
Required
Quantitatioa
Limit
6
12
6
10
10
41
10
41
1
1,000
2
10
5.1
20
0.61
1,000
3.1
0.12
8.2
1,000
1,000
10
4.1
Units
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Lab'
Qualifier
B
J
J
E*
E
E
E*
E
E
E
N
E*
NE*
E
E
E
Validation*
Qualifier •
J
J
A
A
A
J
A
J
J
J
J
J
UJ
'
J I
J 1
J
A
UJ
J
J
J
J
Source: Golder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTTTATION LIMIT
SHEET 4 OF 10
Chemical
Name
BH-103-11
VOA
Methylene chloride
Acetone
1 ,2-Dichloroethene (total)
Toluene
Ethyl benzene
Total xylenes
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Validated
Result
•
88
110
14
12
34
51
24,400
19.5
161
1.4
49,100
23
12.6
23.2
23,200
16.1
11,800
443
1.8
22.8
4,260
1,370
27.4
59
Contract
Required
Quantitation
Limit
6
13
6
6
6
6
42
10
42
1
1,000
2.1
10
5.2
21
2.5
1,000
3.1
. 0.12
8.3
1,000
1,000
10
4.2
Units
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
LaV .
Qualifier
B
.
E*
S
E
E
E*
E
E
E
SN
E*
NE*
E
E
E
Validation*
Qmitfier
A
J
A
A
A
A
J
A
J
J
J
J
J
J
J
J
J
J
A
UJ
J
J
J
J
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7 |
MOSLEY ROAD SANITARY LANDFILL 1
WASTE PIT SOILS ANALYTICAL RESULTS |
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT 1
SHEET 5 OF 10 fl
Chemical
Name
BH-104-8,9C-A
VGA
Acetone
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
BH-104-8,9C-DUP
VOA
Acetone
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
BH-104-TB
VOA
Methylene chloride
Validated
Result
-
2,200
36,100
28.5
374
1.7
75,000
30.4
14.3
24.8
27,200
20.2
14,800
516
26.5
5,450
55.7
64.1
2,700
38,400
26.1
503
1.9
72,600
32
13.9
27.1
27,000
19.3
14,400
517
22.3
5,910
94.7
69.4
16
Contract
Required
Quantitation
Limit
1,500
43
23
43
1.1
1,100
2.1
11
5.3
21
2.8
1,100
3.2
8.5
1,100
11
4.3
1,500
40
19
40
1
1,000
2
10
5
20
5.7
1,000
3
8
1,000
10
4
5
Units
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg.
mg/kg
mg/kg
mg/kg
mg/kg
ug/L
Lab*
Qualifier
• ?
••
N
_*
*
E
SN
*
Validation"
Ojwlifkr -'-:
- -. •>: • .
:-.-::::. : .. 1
A
A
J
A
J
A
J
UJ
A
A
J
A
A
UJ
J
A Jj
A J
I
J
A
J
A
J
A
J
UJ
A
A
J
A
A
UJ
J
A
A
J
A J
Source: Golder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT
SHEET 6 OF 10 ' •
Chemical
Name
BH-105-3
VOA
Acetone
1,2-DichIoroethene (total)
Tetrachloroethene
BNA
Phenol
4-Methylphenol
Naphthalene
2-Methylnaphthalene
Fluorene
Phenanthrene
Pyrene
bis(2-Ethylhexyl)phthalate
INORGANIC
Aluminum
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Zinc
BH-105-3-DL
BNA
4-Methylphenol
Naphthalene
2-Methylnaphthalene
Fluorene
Phenanthrene
Chrysene
Validated
Result
•
5,800
5,300
23,000
740
10,000
2,000
1,900
1,600
2,100
520
6,000
12,900
11.6
185
37,000
21.8
41.1
33,700
20.4
6,960
338
24
2,420
116
10,000
1,900
1,400
920
1,400
5,300
Contract
Required
QuantitatioB
Limit
1,700
840
840
450
450
450
450
450
450
450
450
45
11
45
1,100
2.3
5.7
23
1.4
1,100
3.4
9.1
1,100
4.5
900
900
900
900
900
900
Units
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
rug/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
Lab*
Qualifier
.
E
E*
E
E*
E
E
E
N
E*
NE*
E
E
D
D
D
D
D
D
Validation"
Qwrfifter
J
A
A
A
A
A
A
A
A
A
A
J
A
J
J
J
J
J
J
J
J
UJ
J
J
A
A
A
A
A
A
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7 - |
MOSLEY ROAD SANITARY LANDFILL |
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT 1
SHEET 7 OF 10 f
Chemical
Name
BH- 105-5
VOA
Acetone
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene • •
Toal xylenes
BNA
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1 ,2-Dichlorobenzene
1 ,2,4-Trichlorobeiizene
Naphthalene
2 -Methylnaphthalene
Acenaphthene
Fluorene
Phenanthrene
Fluoranthene
Pyrene
bis(2 -Ethy lhexyl)phthalate
Chrysene
INORGANIC
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Silver
Sodium
Vanadium
Zinc
Cyanide
Validated
Result
«
3,500
3,000
9,800
53,000
14,000
82,000
7,800
12,000
21,000
9,900
11,000
17,000
2,100
2,600
9,800
17,000
1,600
13,000
1,300
18,500
198
27.3
851
562
237,000
29,300
31.2
287
7,240
748
7,840
1,110
1.2
3,350
142
2,330
75
329
24
Contract
Required
Quantitalioa
Limit
2,500
,300
,300
,300
,300
,300
690
690
690
690
690
690
690
690
690
690
690
690
690
61
73
15
61
6.1
6,100
3
15
7.6
30
0.91
1,500
4.5
0.2
12
12
1,500
61
6.1
0.92
Units
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/Kg
ug/kg
ug/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Lab*
Qualifier
E
E
E
E
E
E
E*
N
E
E*
E
E
E
N
E*
NE*
N
E
E
Validation*
Qualifier
J
A
A
A-
A
A
A
A
A
A
• A
A
A
A
A
A I
A 1
A f
J
J
A
J
A
J
J
J
J
J
J
J
J
A
J
J
J
J
J
A
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT
SHEET 8 OF 10
Chemical
Name
BH-105-5-DL
BNA
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1 ,2-Dichlorobenzene
1 ,2,4-Trichlorobenzene
Naphthalene
2-Methylnaphthalene
Phenanthrene
Fluoranthene
bis(2-Ethylhexyl)Phthalate
BH-105-10
INORGANIC
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
Validated
Result
-
9,000
13,000
41,000
11,000
31,000
39,000
11,000
34,000
30,000
24,900
22.9
343
1.6
1.9
68,500
29.7
15.1
25.9
25,500
21.1
13,700
522
26.2
4,660
37.1
64.1
Contract
Required
Quant! tatioa
Unit
6,900
6,900
6,900
6,900
6,900
6,900
6,900
6,900
6,900
48
12
48
1.2
1.2
1,200
2.4
12
6
24
0.71
1,200
3.6
9.5
1,200
12
4.8
Units
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
fcab«
Qualifier
. • •:.
D
D
D
D
-D
D
D
D
D
E*
E
E
E*
E
E
E
N
E*
NE*
E
E
Validation*
Qaaiifler
A
A
A
A
A
A
A
A
A
J
A
J
J
A
J
J
J
J
J
J
J
J
J
J
J
J
Source: Golder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT
SHEET 9 OF 10
Chemical
Name
BH-106-19A
VOA
Acetone
INORGANIC
Aluminum
Calcium
Chromium
Copper
Iron
Lead
Manganese
Vanadium
Zinc
Validated
Result
-
29
1,330
4,230
3.1
. 6.1
2,080
2.4
25.1
4.4
6.1
Contract
Required
Quantitation
Limit
13
40
1,000
2
5.1
20
0.62
3
10
4
Units
ug/Kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Lab*
Qualifier
E*
E*
-E
E
E
SN
NE*
B
E
Validation*
Qualifier
J
J
J
J
UJ
J
UJ
T II
J
UJ 1
Notes:
95% UCL - Upper limit of the 95th percentile confidence interval on the arithmetic average
concentration.
a Lab data qualifiers for VGA'S, BNA's, and Pesticides:
U - The material was analyzed for, but was not detected. The associated numerical value
is the sample quantitation limit.
J - The associated numerical value is an estimated quantity.
R - The data are unusable (compound may or may not be present). Resampling and
reanalysis is necessary for verification.
N - Presumptive evidence of presence of material
JN - Presumptive evidence of the presence of the material at an estimated quantity.
UJ - The material was analyzed for, but was not detected. The sample quantitation limit is
an estimated quantity.
B - The material was found in the associated blank as well as in the sample
E - The reported value is estimated because of the presence of interference.
D - This flag identifies all analyses at a secondary dilution factor. In an analysis some
compounds can exceed the calibration range of the instrument. Therefore, two
analyses are performed, one at the concentration of the majority of the analyses, and a
second with the sample diluted so that high concentration analyte(s) fall within the
calibration range.
a Lab Data Qualifiers for Inorgancis:
B - Reported value is less than the Contract Required Detection Limit (CRDL), but greater
than the Instrument Detection Limit (IDL).
U - The analyte was analyzed for, but not detected.
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
TABLE 7
MOSLEY ROAD SANITARY LANDFILL
WASTE PIT SOILS ANALYTICAL RESULTS
ABOVE CONTRACT REQUIRED QUANTITATION LIMIT
SHEET 10 OF 10
E - The reported value is estimated because of the presence of interference. An
explanary note must be included under comments on the Cover Page (if the problem
applies to all samples) or on the specific FORM-I-IN (if it is an isolate problem).
D - This flag identifies all anlaytes at a secondary dilution factor. In an analysis some
compounds can exceed the calibration range of the instrument. Therefore, two
analyses are performed, one at the concentration of the majority of the analyses, and a
second with the sample diluted so that high concentration analyte(s) fall within the
calibration range.
N - Spiked sample recovery not within control limits.
S - The reported value was determined by the Method of Standard Additions (MSA).
W - Post-digestion spike for Furnace A A analysis is out of control limits (85-115%), while
sample absorbance is less than 50% of spike absorbance.
* _ Duplicate analysis not within control limits.
+ - MSA correlation <0.995
b Validation Qualifiers for Official Results:
A - Acceptable
AB - The "B" qualifier assigned by the laboratory was reassignmed as an unqualified
detected compound. This qualification was necessary because the sample result
exceeded the 10X criteria for the associated blank contamination.
J - The associated numerical value is an estimated quantity.
R - The data are unusable (compound may or may not be present). Resampling and
reanalysis is necessary for verificatin.
U - The analyte was analyzed for, but not detected.
JN - Presumptive evidence of the presence of the material at an estimated quantity.
UJ - The material was analyzed for, but was not detected. The sample quantitation limit is
an estimated quantity.
Source: Colder Associates, Inc., Waste Management of Oklahoma, Final Remedial Investigation
Report, April 1991.
-------
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ESTIMATED COST RANGE FOR
REFINED REMEDIAL ALTERNATIVES
Page 1 of 2
MEDIA ADDRESSED BY ALTERNATIVES
WASTE PIT SOILS
LEACHATE
GROUNDWATER
.; f:V. '.- • "•••' - •
SOURCE
CONTAINMENT;
GROUNDWATER
EXTRACTION
TREATMENT A
DISCHARGE
(CAPPING)
$200,000
$3.100.000-$S.700.000
-
$300.000-$000.000
$40.000
$85.000
$800.000-$5.8 million
$1.6-$5.3 million
$*50.000-$22.3 million
$700.000-$16.5 miffion
$800.000-$1. 5 million
$400.000-$|7.3 million
$5.8 to $34.2
million
1
i 1
• af
o' 1
••-••••: ••-• . 5 A .. . :..-
SOURCE
CONTAINMENT;
LEACftATE
EXTRACTION,
TREATMENT,
A DISCHARGE
(CAPPING)
$200.000
$3.100.000- J5.700.000
•
$900.000
;
$40.000
S85.000
J700.000-J2 8 minion
$1.6-$5.3 million
$a50.000-$10.7 million
$S50.000-t8.0 minion
$800.000-$1.5 miffidF"
$300.000-$8.4 minicD
3
$6.0 to $22.9 M
million cd
»
e Alternative provide* primary remediation of medium.
o Alternative provide* *eeondary remediation at medium.
NOTE: To(al« may not tare* with th» turn of individual vilu** du» to rounding.
Dieeharg* co*t* Include monitoring and permit itwanee c«*t«. O O
Diecharg* cod* include monitoring, permit inuanc* and piping cotf*)
Q.
-------
ESTIMATED COST RANGE FOR
REFINED REMEDIAL ALTERNATIVES
Page 2 of 2
DIA ADDRESSED BY ALTERNATIVES
ASTE PIT SOILS
T3KiAfE~
^Te^pwiwATER
--.. .•.:-*.".. "-••• : • ••
TERNATIVES
nnotogy
•
CCESS RESTRICTIONS
MO
NITORINQ
'PINO
Option 1 -$3.1 00.000
vxion2-$3.300.000
Don 4 -$5.700.000
LURRY WALL
.LECTION
««1 Optima
o slurry wsl, 13or26w*ni.
520 gom. 20 ysars
• 2 Options
o slurry waH. 30 wells In
landflB. 60-250 gpm. 20 years
igHU. is w*0* in
^^•0-200 gpm. 20 years
aesTOpflons
(lurry wsfl. 30 ws!1 sin Undnn: and 5
s In groundwater. 60-250 gpm for
;h«te, 125 gpm for groundwater. 20
isrs for leachats. 1 year for groundwatsr
Tywal. IBwsDsIn landfill: and 5 wells
roundwsler. 25-150 gpm for toacnate.
^=100 gpm for groundwatsr. 9-20 years
( Isachat*. 1-20 years for groundwater
CHARGE
5W-NPOES- Capital Cost
TW"
s pita) Cost
..scharge Fee $2.50/1000 gals.
REATMENT
onl
»ES
id Capital Coat Rangs
kriogteal Treatment
tange 52.36-58 6/1000 gala.
Biological Tr*atm*nt
tg* 51.W-57.1/1000 gala.
rag* Cost
$5.53/1000 gals.
on 2
"W/Pretrsatmsnt
»d Capital Cost Rangs
•r*atm*nt Rang* 51.13-57.47/1000 gals.
~^^^BoO gallons
„„ AL ESTIMATED 1901
resent Net Worth
t
•
.0
"•••• -SB- :.-
SOURCE
CONTAINMENT;
LEACHATE
EXTRACTION,
TREATMENT,
A DISCHARGE
(CAPPINQ &
SLURRY WALL)
$200.000
$3,100.000-55.700.000
$2.1 to $3.6
million
-
-
$450.000
-
-
_,
$40.000
5*5.000
5350.000-52-2 million
$1. 6-55.3 million
$300.000-58.6 million
5250.000-56.4 minion
$800.000-51 .5 million
$150 .000-56.7 million
$7.2 to $234
million
' •
•
•
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•
•
• • .' ••:&: OB x::.^ -.i.:.j-
SOURCE CONTAINMENT;
GROUNDWATER
EXTRACTION A DISCHARGE;
LEACHATE EXTRACTION,
TREATMENT. A DISCHARGE
(CAPPINQ)
$200.000
$3.100.000-55.700.000
—
-
-
-
$1.0 million
_
$40.000
5*5.000
$850.000-53.0 minion
$1.6-55.3 million
$850.000-510.7 million
$550.000-58.0 million
$800.000-51. 5 million
$300.000-58.4 million
$6.3 to $23.0
minion
(CAPPING &
SLURRY WALL)
$200.000
$3.100.000-55.700.000
$2.1 to $3.8
million
-
-
-
-
$550.000
$40.000
$15.000
5500.000-52.4 million
$1.6- 55.3 miBion
5300.000-5*6 million
5250.000-58.4 million
$800.000-51.5 million
5150.000-58.7 minion
$7.5 to 5240
mid ion
e)
•
•
^.•'^y.'^ 7 A 'i.-V'V?^:
•
- >•
• .
5 »••;•?•**:• . ID •' • ,..
SOURCE CONTAINMENT;
GROUNDWATER A
LEACHATE EXTRACTION.
TREATMENT. A DISCHARGE
(CAPPINQ)
•
5200.0&
$3.100.000-55.700.000
— -
-
-
-
$1.0mimon
.
540.000
585000
5*50.000- 53.0 million
$1.8-55.3 million
$800.000-511.4 miffion
$850.000-51.4 mifflon
5800.000-51. 5 million
$400.000-$8.t million
PCX
c
$8.4 to 523.6
million
(CAPPINQ &
SLURRY WALL)
$200.000
$3.100.000-$5.700.000
$2.1 to $3.6
million
•
-
-
-
$550.000
$40.000
585.000
$500.000-52.4 million
$1.6-55.3 million
$450 000-58.2 million
$400.000-58.8 million
5800.000-51.5 minion
5225.000-57.2 million
•> ry i \ ! STV
-------
TABLE 18
COMPARATIVE ANALYSES FOR CAPPING REMEDIAL ALTERNATIVES
MOSLEY ROAD SANITARY LANDFILL
SHEET 1 OF 1
! CRITERION
Overall Protection of Human Health and the
Environment
Compliance with ARARs
Long-term Effectiveness and Permanence
Reduction of Tdxicity, Mobility, or Volume
through Treatment
Short-term Effectiveness
Implementability
Cost
ALTERNATIVE
Most
1,2,3
Least
Most
1,2,3
Least
Most
1,2,3
Least
Most
Not applicable
Least
Most
1,2,3
Least
Most
1,2,3
Least
Least Expensive
1,2,3
Most ^Expensive
Source: Goldger Associates, Inc., Waste Management of Oklahoma, Draft Technical
Memorandum on Comparative Analysis, April 1991.
-------
TABLE 19
COMPARATIVE ANALYSES FOR GROUND-WATER REMEDIAL ALTERNATIVES
MOSLEY ROAD SANITARY LAND
Sheet 1 of 2
CRITERION
ALTERNATIVE
Overall Protection of Human Health and the
Environment
Most
5, 5a, 6, 6a, 7, 7a
3, 3a, 4, 4a
2
1
Least
Compliance with ARARs
Most
2, 4, 4a, 5, 5a, 7, 7a
3, 3a, 6
1
Long-term Effectiveness and Permanence
Most
7, 7a
5, 5a, 6, 6a
3, 3a, 4, 4a
2
1
Least
Reduction of Toxicity, Mobility, or Volume
through Treatment
Most
4, 4a, 7, 7a
1,2, 3, 3a, 5, 5a, 6, 6a
Least
Sho.rt-Term Effectiviness
Most
1
2
3, 3a, 4, 4a
5, 5a, 6, 6a, 7, 7a
Least
Implementability
Most
1,2
3, 3a, 4, 4a, 5, 5a, 6, 6a, 7, 7a
Source: Colder Associates, Inc., Waste Management of Oklahoma, Draft Technical Memorandum
on Comparative Analysis, April 1991.
-------
TABLE 19
COMPARATIVE ANALYSES FOR GROUND-WATER REMEDIAL ALTERNATIVES
MOSLEY ROAD SANITARY LAND
Sheet 2 of 2
CRITERION
Cost
ALTERNATIVE
Least Expensive
1
2
3, 3a
5,6
7,5a
6a, 7a
4, 4a
Most Expensive
Source: Colder Associates, Inc., Waste Management of Oklahoma, Draft Technical Memorandum
on Comparative Analysis, April 1991.
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This requires meeting state standards that may be
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The NPOES permll should meet the requirements
lor technology-based elllueni llmllallons and
standards promulgated under Section 301 ol CWA
or new source performance standards promulgatec
under Section 306 ol CWA. Technology based
limitations may be determined on a case-by-case
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resulting In Interference:
o Any pollulani, Including oxygen demanding
pollutants (BOO, etc.) released In a Discharge
at a flow rale and/or pollulani concentration
which wilt causa Interference with the POTW.
o Heal in amounts which will inhibit biological
acltvlly In the POTW resulting In Interference,
but In no case heat in such quanlllles that the
lempefalure at the POTW Treatment Plant
exceeds 40*C (104*F) unless the Approval
Authority, upon request of IhaPOTW. approve
alternate temperature limits. '
'
MO CFH 403.5 (b)|
Provides specific prohibitions on Inlroducllon of
pollutants to a POTW Including:
o Pollutants which create a fire or explosion
hazard In the POTW, Including, but nol limited
to, wasteslreams with a closed cup llashpoinl
of less than 140 degrees Fahrenheit or 60
' degrees Centigrade using the lest methods
specified In 40 CFR 261.21.
o Pollutants which will cause corrosive structura
damage to the POTW, but In no case
Discharges wllh pH lower than 5.0. unless the
works Is specifically designed to accommodat
such Discharges;
o Solid or viscous pollutants In amounts which
will cause obstruction to the flow in the POTW
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Resource Conservation and Recovery Act
(42 USC 6901 el seq.)
Excavation ol contaminated soil lor construction ol
a slurry wall could trigger RCRA land disposal
restrictions.
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<0
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Excavation ol contaminated soil that would b
considered a RCRA hazardous waste Is unlik
since the slurry wall would be constructed In
soils around the perimeter ol the landllll and
through the Industrial hazardous waste pits.
Excavation wllhin the landllll or waste pit sol
considered as an alternative.
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(42 USC 6901 el seq)
No ARARs under RCRA are anticipated.
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Allernallves being considered do not Include
discharge ol leachale and/or contaminated g
that would be classilled as a RCRA hazardou
Land application ol leachale and/or conlamir
groundwater Is considered feasible only alter
treatment.
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|40 CFR 270.60 (c)|
RCRA permlt-by-rule requirements must be
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wastes to POTWs.
Federal
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Pertains to transport ol RCRA hazardous wa
POTWs by truck, rail or dedicated pipe (as d
In 40 CFR 264. which discharges from within
boundaries of the CERCLA site to within the
boundaries of the POTW). For NPDES perm
Issued alter November 8, 1964, corrective ac
requirements ol 40 CFR 264.101 must be co
with.
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(40 CFR 403. 12)
Sets forth reporting requirements for Industrial
users subject to prelrealment standards. Section
(pXI) requires nollllcallon by the user to the POTW
EPA Regional Waste Management Division, and
Stale hazardous waste authorllles ol any discharge
to a POTW ol a substance, which, If otherwise
disposed ol, would be a hazardous waste under 40
CFR 261 .
In a quantity that may cause acute worker
health and safely problems.
o Any trucked or hauled pollutants, except at
discharge points designated by the POTW.
[40 CFR 403.6)
Requires that existing or new Industrial users In
specific categories meet applicable pretreatment
standards.
-
o Petroleum oil. nonblodegradable culling oil. or
product! ol mineral oil origin In amounts that
will cause Interference or pass through.
o Pollutants which will result In the presence ol
toxic gases, vapors, or lumes wllhin the POTW
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DISCUSSION
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riffflfl
ona establish standards for air emlsslms lor
and equipment leaks lor owners and iperalors c
tt* facilities. Organic emissions Irom process
ms containing 10 ppm organlcs by weght lor
are regulated. Process vent ernlsslois are not
our. Organic concentrations greater tian 10
ghl are managed under equipment leiks.
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Emissions ol Hazardous Toxic Air Ctntamlnant
(OSDH Regulation 3.8)
ons adapt the NESHAP^slandards by eference.
Federal
Mai Protection Agency Interim Status Standards
i and Operators ol Hazardous Wastt facilities
(41 USC 6905 et seq)
Organic air emission standards exist lor process
venls. Organic air emission standards exist lor
leaks Iron) equipment carrying organic
concentrations greater than 10 percent by weight.
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These reguiatl
vinyl chloride a
(42 USC 7401 et seq)
DOS establish standard, lor the emlssUn of
nd benzene Into ambient air.
benzene and vinyl chloride Irom air strippers.
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National Emlsi
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NESHAP standards exist lor volatile emissions of
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Federal
1/rCe Conservation and Recovery Act ol 1976
(42 USC 6901 et seq)
ontamlnated soil for conslrucllon ol
Kh may trigger RCRA land disposal
Federal
/.
Excavation ol contaminated soil that would be
considered a RCRA hazardous waste is unlikely.
Excavation within the landfill or waste pit soils is not
considered as an allernallve.
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POTENTIA
LARARs
DISCUSSION
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STATE OF OKLAHOMA CONCURRENCE LETTER
-------
Joan K. Leavift, M.D. OKLAHOMA STATE
Commissioner DEPARTMENT OF HEALTH
Board of Health 1000 NE TENTH
John B. Carmieha*!, D.D.S. Gordon H. Deckert, M.D. OKLAHOMA CITY OK
President Don H. Fleker, D.O. 731 ) 7-1299
Ernest D. Martin, R.Ph. Linda M. Johnson, M.O.
Vice President Walter SeoH Mason, III
Burdge F. Green, M.D. Lee W. Paden
Secretary-Treasurer
June 29,1992
Mr. Altyn M. Davis
Director
Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region VI
1445 Ross Avenue
Dallas, Texas 75202-2733
Dear Mr. Davis:
The Oklahoma State Department of Health (OSDH) has reviewed the Record of Decision
for the Mosiey Road Superfund site. The OSDH concurs with the Record of Decision for
the site, which provides for upgrading the existing cap, monitoring the ground water, and
if necessary remediating the ground water. The OSDH believes that the remedial action
will protect public health and the Garber-Wellington aquifer, and is a safe and reasonable
approach to the remediation of the Mosiey Road site.
The OSDH looks forward to our continued cooperation on the Mosiey Road Superfund site
as we proceed through Remedial Design and Remedial Action.
Sincerely,
Mark S. Coleman, Deputy Commissioner
for Environmental Health Services
------- |