ENVIRONMENTAL
v PROTECTION
\ AGENCY
DALLAS, TEXAS
LIBRARY
PB94-964212
EPA/ROD/R06-94/089
February 1995
EPA Superfund
Record of Decision:
V
\
South 8th Street Landfill
(O. U. 1), West Memphis, AR
9/29/94
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RECORD OF DECISION
South 8th Street Landfill
West Memphis, Arkansas
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Dallas, Texas 75202
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Statement of Basis
SOUTH 8TH STREET LANDFILL SUPERFUND SITE
RECORD OF DECISION
DECLARATION
STATUTORY PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT IS MET
AND FIVE-YEAR REVIEW IS REQUIRED
SITE NAME AND LOCATION
South 8th Street Landfill Superfund Site
West Memphis, AR
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the South 8th Street Superfund Site (hereinafter "site"), in
West Memphis, Arkansas, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 ("CERCLA"), as amended by the Superfund Amendments and
Reauthorization Act of 1986 ("SARA"), 42 U.S.C. §9601 et sea.. and
to the extent practicable, the National Contingency Plan ("NCP").
This decision is based on the Administrative Record for this site.
The State of Arkansas 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 Record of Decision ("ROD"), may present an
imminent and substantial endangerment to public health, welfare, or
the environment.
DESCRIPTION OF THE REI^EDY
The site is being handled as two operable units: a source
control operable unit, which is addressed by this ROD, and a
groundwater operable unit, which will be addressed in a separate
ROD at a later date. The principal concerns to be addressed at the
site are contaminated sludges and contaminated soil and debris.
The major components of the selected remedy include:
Excavation of an estimated 22,000 cubic yards of
contaminated sludge, soil and debris.
Treatment of contaminated water generated during the
excavation of the contaminated material.
Pretreatment of the contaminated material as necessary to
facilitate material handling operations.
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- Separation and cleansing of contaminated debris and
disposal of same in a Subtitle D landfill located offsite.
Backfill of the areas that are excavated with clean soil.
- Treatment of the contaminated sludges and soils in the oily
sludge pit via stabilization/solidification technology.
- Disposal of treated sludge and contaminated soil in a
Subtitle D landfill located offsite.
- Placement of a natural soil cover that complies with the
State of Arkansas Solid Waste Management Code over the former
disposal areas.
Installation of appropriate erosion control features to
minimize operation and maintenance of the soil cover.
- Placement of deed notifications to ensure that any future
landowners will be notified that the land was a former
Super fund site and has been cleaned up in accordance with
CERCLA.
- Groundwater monitoring.
- Long-term operation and maintenance.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy satisfies the statutory
preference for treatment that reduces toxicity, mobility or volume
as a principal element of the remedy. The selected remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site.
Because the remedy may result in hazardous substances remaining on-
site above health-based concentration levels, a review will be
conducted within five years of commencement of the remedial action
to ensure that the remedy continues to provide adequate protection
of human health and the environment.
Lev. Jane N.% Saginaw Date
Regional Administrator
U.S. Environmental Protection Agency
Region 6
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CONCURRENCE FOR THE
SOUTH 8TH STREET LANDFILL SITE
RECORD OF DECISION
alter L. Button, Jr., Regional Counsel
Office of Regional Counsel
Allyn Ki Davis, Director
Hazardous Waste Management Division
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CONCURRENCE FOR THE
SOUTH 8TH STREET LANDFILL SITE
RECORD OF DECISION
/
Price
Peer Review Committee Chairperson
David A. Weeks, P.E.
Remedial Project Manager
William^ L. Luthans, Chief
Arkansas/Louisiana Section
/'Sam Becker, Chief
Superfund Enforcement Branch
Rachel H>-BlumenfeM
Office of Regional Cdunsel
~ sr -
Mark Peycke, Acting Chief
Hazardous Waste Branch
Office of Regional Counsel
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TABLE OF CONTENTS
Page
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
IV. SCOPE AND ROLE OF RESPONSE ACTION 7
V. SITE CHARACTERISTICS 9
VI. SUMMARY OF SITE RISKS 38
VII. DESCRIPTION OF ALTERNATIVES 48
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES 55
IX. SELECTED REMEDY 66
X. STATUTORY DETERMINATIONS 70
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 77
XII. RESPONSIVENESS SUMMARY 78
APPENDIX A
Index of Administrative Record 104
APPENDIX B
Basis for Remediation Goals 155
APPENDIX C
Material Key, Oily Sludge Pit 200
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LIST OF FIGURES
Page
Figure 1 - Site Location Map 2
Figure 2 - Site Map 3
Figure 3 - Site Wind Rose 12
Figure 4 - Site Flood Occurrences 14
Figure 5 - Sludge Pit Investigation Trenches 16
Figure 6 - Extent of Oily Sludge Pit Waste 17
Figure 7 - Section 1 of Pit Area 22
Figure 8 - Section 2 of Pit Area 23
Figure 9 - Section 3 of Pit Area 24
Figure 10 - Section 4 of Pit Area 25
Figure 11 - Site Trench Map 31
Figure 12 - Future Population RME Risk, Oily Sludge Pit ... 42
Figure 13 - Recreational Worker and Visitor RME Risk, Landfill
Areas 43
Figure 14 - Agricultural RME Risk, Landfill Areas 44
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LIST OF TABLES
Page
TABLE 1
OILY SLUDGE PIT AREA
VOLATILE ORGANIC COMPOUNDS 19
TABLE 2
OILY SLUDGE PIT AREA
SEMIVOLATILE ORGANIC COMPOUNDS 19
TABLE 3
OILY SLUDGE PIT AREA
PESTICIDES/PCBs 20
TABLE 4
OILY SLUDGE PIT AREA
INORGANIC COMPOUNDS 20
TABLE 5
OILY SLUDGE PIT AREA
DIOXIN 21
TABLE 6
OILY SLUDGE PIT AREA
TREATMENT CHARAC 21
TABLE 7
OILY SLUDGE PIT AREA
CLAY CHARAC 26
TABLE 8
LANDFILL AREA SUBSURFACE
VOLATILE ORGANIC COMPOUNDS 28
TABLE 9
LANDFILL AREA SUBSURFACE
SEMIVOLATILE ORGANIC COMPOUNDS 28
TABLE 10
LANDFILL AREA TRENCHING
INORGANIC COMPOUNDS 29
TABLE 11
LANDFILL AREA TRENCHING
PESTICIDES/PCBs 30
TABLE 12
AREA/VOLUME OF
LANDFILL 32
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LIST OF TABLES CONT.
Page
TABLE 13
LANDFILL AREA SURFACE SOILS
VOLATILE ORGANIC COMPOUNDS 33
TABLE 14
LANDFILL AREA SURFACE SOILS
SEMIVOLATILE ORGANIC COMPOUNDS 33
TABLE 15
LANDFILL AREA SURFACE SOILS
PESTICIDES & PCBS 34
TABLE 16
LANDFILL AREA SURFACE SOILS
INORGANIC COMPOUNDS 34
TABLE 17
'LANDFILL AREA SEDIMENTS
ORGANIC COMPOUNDS 36
TABLE 18
LANDFILL AREA SEDIMENTS
INORGANIC COMPOUNDS 36
TABLE 19
LANDFILL AREA SURFACE WATER
INORGANIC COMPOUNDS 38
TABLE 20
COST COMPARISON-OILY SLUDGE PIT 62
TABLE 21
COST COMPARISON-LANDFILL AREA 65
TABLE 22
REMEDIATION GOALS 68
TABLE 23
WASTEWATER DISCHARGE LIMITS 72
TABLE 24
STABILIZATION PERFORMANCE GOALS 76
TABLE 25
THREAT COMPARISON
SLUDGE PIT/LANDFILL AREA 97
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DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
The South 8th Street Landfill site (site) is located adjacent to
the Mississippi River in West Memphis, Crittenden County, Arkansas,
as shown on Figure 1. The site, which is approximately 30 acres,
is situated in the Mississippi River floodplain between the river
and the St. Francis Levee. The site is sub-divided into three
separate disposal areas, Areas 1, 2 and 3, and an oily sludge pit
area located in Area 2. Figure 2 provides a graphical description
of each of the relevant areas.
Area 1 primarily consists of a former municipal waste landfill.
The remaining fill portions of Area 2, not associated with the
large oily sludge pit, consist primarily of industrial waste, and
Area 3 consists of several smaller municipal and industrial waste
disposal areas.
Because the site lies within the flood protection levees of the
Mississippi River, it is not unlikely for the site to flood between
the months of November through July. During the past 11 years of
record, the site was inundated on 14 different occasions, the
earliest time of the year occurring on November 25, 1985, and the
latest occurring on June 13, 1983, and June 13, 1990.
An HRS package was prepared in August 1991 (E&E 1991). The site
was proposed for listing on the National Priorities List (NPL) as
the "West Memphis Landfill Site" on February 7, 1992 (57 Fed. Reg.
4,827). The site was subsequently listed as final on the NPL as
the "South 8th Street Landfill Site" on October 14, 1992 (57 Fed.
Reg. 47,184).
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The South 8th Street Landfill site was first brought to the
attention of the United States Government in 1979 in the Eckhardt
Survey conducted by the House Congressional Sub-Committee on
Interstate Commerce and Transportation. In this survey, the
landfill was listed as the West Memphis Landfill site, South 8th
Street.
Aerial photographs indicate that the site was used as a series of
borrow pits and for disposal of waste and/or other materials since
the 1950s. Most of the early disposal activities appear to have
been conducted on a 2.61 acre parcel of land leased by Mr. W.M.
Gurley from the W.L. Johnson Company. Gurley Refining Company
(GRC) used the site for the disposal of waste sludge from its waste
oil re-refining operation located on the land side of the St.
Francis Levee just west of the site. The waste in the pit has
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FIGURE 1
SITE LOCATION MAP
RECORD OF DECISION
SOUTH 8TH STREET LANDFILL
WEST MEMPHIS, ARKANSAS
DIRECTORY: P:\ENVIRO\06639630\ENV [FILE No. RIFS-EPA |REV.O
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SLUDGE PIT BERM
SLUDGE PIT
FIGURE 2
SITE MAP
RECORD OF DECISION
SOUTH 8TH STREET LANDFILL
WEST MEMPHIS. ARKANSAS
DIRECTORY: P:\ENVIRO\06659630\ENV [FILE No. 2-1EPA |REVL0
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physical and chemical properties that are similar to waste from
waste oil reclamation processes.
The first EPA investigation of the site was conducted in August,
1981. Samples were not collected, but drums and other surface
anomalies such as stained soils and settlement depressions were
discovered. The EPA Field Investigation Team (FIT) contractor
conducted a soil boring investigation on March 22, 1982. Four
borings were drilled in a north-south direction across the
landfill. Lithology was determined to be sands and clays.
Alluvial groundwater was estimated to be 8 to 20 feet below ground
surface. Ammonia and cyanide were detected in the boring samples.
The FIT sampled the pits in March 1982 and June 1986. Polycyclic
aromatic hydrocarbons (PAHs) , polychlorinated biphenyls (PCBs) , and
benzene, toluene, ethylbenzene and xylene (BTEX) were detected in
the samples obtained by the FIT.
EPA conducted additional air monitoring in November 1986 and
collected additional pit samples in January 1987. PAHs, PCBs, and
BTEX again were detected.
The FIT conducted an extensive sampling inspection in February,
1988 that included pit, surface soil, and surface water sampling.
Pesticides were detected in the pits as well as in surface soil
samples. Heavy metals were detected in surface water samples.
Sludge pit samples contained PAHs, PCBs and BTEX.
In October, 1988, follow-up air monitoring was conducted which
detected air emissions of organic compounds including ethylbenzene,
xylenes, alkanes and PAHs.
Other than the soil boring investigation and a one-time surface
soil sampling event, the EPA sampling efforts focused in and around
the pit area. Therefore, the extent of site contamination was not
ascertained prior to the RI/FS.
A Hazard Ranking System (HRS) package was prepared in August, 1991.
The site was proposed on the National Priorities List (NPL) as the
"West Memphis Landfill site" on February 7, 1992. The site was
listed final on the NPL as the "South 8th Street Landfill site" on
October 14, 1992.
EPA issued a General Notice Letter/Information Request to 25
Potentially Responsible Parties (PRPs) on February 7, 1992. EPA
evaluated the responses received and subsequently issued Special
Notice Letters to 26 PRPs on March 18, 1992. Additional PRPs were
added to the list of PRPs based on information received from some
of the other PRPs who responded to the February 7, 1992 Information
Request.
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EPA issued a Unilateral Administrative Order (Order) to the PRPs
(with the exception of the City of West Memphis) on May 23, 1992.
The Order required the PRPs to construct a fence around the former
disposal areas and to investigate the large oily sludge pit.
Construction of the fence was completed in July 1992. Although the
PRPs initially undertook the pit investigation on August 31, 1992,
EPA took over the pit investigation in September, 1992.
The RI/FS negotiation moratorium ended on May 23, 1992, with none
of the PRPs volunteering to perform the RI/FS. Subsequently, EPA
performed the RI/FS.
EPA's contractor commenced the pit characterization on September
16, 1992. After it became apparent that the pit could not be
removed prior to the impending flood season, EPA constructed a berm
around the oily sludge pit under EPA's time-critical removal
authority to minimize the spread of contamination that could result
from flooding of the site. EPA also determined that it would
remove the pit under EPA's non-time critical removal authority to
address the primary threat at the site.
EPA mobilized to the site on October 19, 1992, and constructed a
1,600 linear foot berm around the oily sludge pit to a height that
would protect the pit from a typical flood at the site.
Construction of the berm was completed on November.4, 1992. EPA
subsequently directed the ARCS contractor to mobilize on
December 1, 1992, to complete the investigation of the large oily
sludge pit. The investigation was completed on December 8, 1992.
EPA issued Special Notice Waiver Letters for preparation of an
EE/CA (dated January 7, 1993) to the PRPs on January 15, 1993.
The PRPs were offered the opportunity to prepare the EE/CA and
informed that an Administrative Order on Consent could be
negotiated under an expedited schedule. None of the PRPs expressed
an interest in preparing the EE/CA, so EPA continued its
preparation of the EE/CA.
In May 1993, EPA re-evaluated £he feasibility of completing a non-
time critical removal during the 1993 dry season. After reviewing
the schedule that would have to be met to complete the work prior
to the beginning of the flood season, EPA determined that an action
could not be completed until after the next flood season.
Therefore, EPA determined that the most efficient manner to address
the oily sludge pit was to include the actions to address the pit
as part of the remedial action to address the entire site.
EPA issued the Proposed Plan for the site on July 27, 1993. The
Proposed Plan identified organic treatment, stabilization and off-
site disposal of the treated oily sludge pit waste at a Subtitle D
Landfill, and a natural soil cover for the landfill areas as EPA's
preferred remedy. The extended public comment period for the
Proposed Plan closed on September 24, 1993. EPA's response to
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public comments is contained in the Responsiveness Summary portion
of the ROD.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The requirements of CERCLA Sections 113 (k) (2) (B) (i-v) and 117, 42
U.S.C. §§ 9613(k)(2)(B)(i-v) and 9617, were met during the remedy
selection process.
EPA met with officials of the City of West Memphis in January 1992
to discuss the site and the Superfund process and to answer any
questions the City might have. EPA personnel also interviewed a
local store owner and staff from the county health department to
discuss citizen concerns about the potential danger posed by the
site.
A fact sheet summarizing the Superfund process and the status of
activities at the site was mailed to the local citizens and other
interested parties on April 3, 1992. The fact sheet also invited
the public to attend a "Citizens Scoping Meeting" that was
conducted on April 16, 1992. At the scoping meeting, EPA described
the Superfund process and the specific plans to investigate the
site, and solicited input from the attendees on other areas of the
site that they felt needed to be investigated.
EPA regularly met with members of the local community and news
media throughout the conduct of response activities at the site.
EPA provided reports on progress at the site and addressed issues
related to potential alternatives to address risk at the site.
The RI/FS Reports and Proposed Plan for the South 8th Street
Superfund site were released to the Public on July 27, 1993. The
documents were made available to the public in the Administrative
Record File in the noted information repositories: West Memphis
Public Library, West Memphis, Arkansas; Arkansas Department of
Pollution Control and Ecology, Little Rock, Arkansas; and the U.S.
Environmental Protection Agency Region 6 Library, Dallas, Texas.
A summary of the Proposed Plan and the notice of availability of
these documents and Administrative Record File was published in the
West Memphis Evening Times. In addition, the Proposed Plan of
Action for the site was mailed to all parties on the mailing list
and other identified parties on July 26, 1993.
The EPA held a public comment period regarding the RI/FS, Proposed
Plan and Administrative Record from July 27, 1993, through August
26, 1993. During this initial public comment period, a formal
public meeting was held at 7:00 pm, on August 17, 1993, at the West
Memphis Neighborhood Center located at the intersection of 13th
Street and Polk Street. Representatives of EPA presented the
conclusions of the RI and risk assessment, the remedial
alternatives evaluated for the oily sludge pit and landfill areas
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of the site, and EPA's preferred alternatives to address the risk
at the site. The public comment period was extended through
September 25, 1993, in response to a request by the City of West
Memphis. The extension was announced through a newspaper
advertisement in the West Memphis Evening Times.
EPA's response to all the comments received during this 60-day
public comment period, either written or verbally expressed at the
public meeting, is included in this Responsiveness Summary. The
Responsiveness Summary is included as part of the ROD.
This decision document presents the selected remedial action for
the South 8th Street Superfund site, in West Memphis, Arkansas,
chosen in accordance with CERCLA, as amended by the Superfund
Amendments and Reauthorization-Act and, to the extent practicable,
the National Contingency Plan ("NCP"). The decision for the site
is based on the Administrative Record. • An index for the
Administrative Record is included as Appendix #1 to the ROD.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The Proposed Plan addressed the site as one operable unit and
presented EPA's preferred final remedy for the entire site. This
ROD does not address the entire site as one operable unit.
Specifically, EPA has reevaluated the site data and has determined
that the data is insufficient to determine whether or not the
contaminated groundwater at the site presents a threat to human
health and the environment. In addition, EPA currently has
insufficient information to conduct a proper evaluation of
potential remedial alternatives for the groundwater if it was
determined to present a risk to the public health and the
environment. Therefore, EPA has deferred its remedial decision
with respect to the groundwater until more information is gathered
concerning the nature and extent of groundwater contamination and
the characteristics of the local aquifer.
The overall primary remedial objective that is addressed in this
ROD is the reduction or elimination of the actual and/or potential
risks associated with the oily sludge pit and the landfill areas.
The studies undertaken at the South 8th Street Landfill site have
identified both principal threats and low level risks that must be
addressed.
In general, EPA associates principal threats with "hot spots"
(e.g., liquids, areas contaminated with high concentrations of
toxic compounds, and highly mobile materials) . The oily sludge pit
and its ancillary contaminated soil and debris have been identified
as principal threat wastes at the site because these wastes, if
left unaddressed, would continue to present an acute threat to the
public health and the environment. In addition, the sludges and
contaminated soil and debris, if left unaddressed, also will
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8
continue to present potential long-term threats to the environment
(migration of contaminants during flood events and leaching to
groundwater), and to human health through direct exposure
(ingestion, dermal contact, and inhalation) and the ingestion of
crops grown in contaminated soil.
EPA generally associates low level threats with sources of
contamination that could be kept in place by engineering controls
(such as capping) and that pose a low health risk. For example,
the landfill contents are considered a low-level risk because of
the lower potential for these areas to impact human health and
environment through direct contact or long-term exposure in the
environment.
The specific remedial objectives to address the principal and low-
level threats at the South 8th Street Landfill have been defined by
EPA for both the oily sludge pit area and the landfill areas.
The remedial action objectives for the oily sludge pit area are as
follows:
Oily Sludge Pit Area
1. Prevent current and future direct contact with the highly
corrosive wastes.
2. Prevent current and future direct contact, ingestion, and
inhalation of contaminants in the waste and ancillary contaminated
soil and debris.
3. Prevent the future migration of contaminants from the oily
sludge pit area to other areas both on and off the site which may
result from site flooding.
4. Prevent the potential for future migration of contaminants to
the groundwater at concentrations above appropriate action levels.
The remedial action objectives for the landfill areas are as
follows:
Landfill Areas
1. Prevent direct contact with and ingestion of the landfill
contents.
/
2. Ensure that contaminants present in the landfill do not
migrate into the groundwater at concentrations above appropriate
action levels.
The subseguent sections of this document explain how EPA
investigated the site and selected a remedy that will accomplish
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the remedial action objectives.
V. SITE CHARACTERISTICS
• Summary
The primary objectives of the RI were to locate "hot spots" on the
site and determine the extent of contamination in the surface soil,
subsurface soil, surface water and groundwater with a reasonable
level of certainty. With the exception of the groundwater, these
objectives were met. The groundwater data collected during the RI
was not sufficient to render any conclusions regarding whether or
not contaminated groundwater at the site presents a threat to human
health and the environment or what actions may be taken to address
any such threats. Another investigation of the groundwater at the
site will be conducted in the future to address this concern.
Immediate actions to abate any potential risk associated with the
groundwater (other than removal of the oily sludge pit, the primary
source of site contamination) are not currently necessary because
the groundwater at the site is not currently used by humans.
As previously discussed, the site consists of approximately 30
acres that is further subdivided into three separate areas that
have been identified as Area 1, 2 and 3 (Figure 2) . The
northwestern portion of the site also contains a large pond. The
total area studied during the RI was approximately 48 acres and
included several areas located adjacent to the site that were
specified as part of the site in the HRS, but were later found not
to pose a risk to the public health and the environment. Hence,
these additional areas are no longer included within the site
boundaries.
In general, EPA believes that all site hot spots have been located
with a reasonable level of certainty. The only hot spot identified
at the site is the 3.5-acre oily sludge pit. The 16 acres of
former landfill were found to be contaminated enough to present a
low level threat, but were not so contaminated as to constitute a
principal threat or "hot spot" when compared to the pit threat.
Site surface soils and sediments were found to contain low levels
of contaminants that do not present a threat to the public health
and the environment. Likewise, no contaminants were found in the
pond surface water at levels that present a threat to the public
health and the environment.
• Detailed Discussion of Characteristics
Topography
The topography of the landfill has been altered by excavation and
backfilling activities over a period of many years. However, the
landfill is generally flat with numerous depressions that make up
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10
the pits, ponds and other former areas of waste disposal.
Elevations on the landfill range from approximately 206 to 220 feet
above mean sea level (m.s.l.). Tne landfill is flanked on the
south and east by the Mississippi River and on the north and west
by the St. Francis Levee.
The oily sludge pit surface is at an elevation of approximately 212
m.s.l.. The land mass immediately surrounding the oily sludge pit
within the perimeter containment berm (approximately 3.5 acres less
the area of the oily sludge pit) ranges in elevation from 210 to
215 feet m.s.l. The perimeter containment berm was constructed in
November 1992 to an elevation of approximately 217 feet m.s.l. to
prevent stormwater runon and minimize flood water intrusion onto
the oily sludge pit, and to contain stormwater runoff within the
oily sludge pit.
Land Use
The site is in an industrial zoned area. There are currently no
residential or industrial populations within the site boundaries.
Land use immediately adjacent to the landfill consists of
industrial/petroleum storage facilities. Residential areas are
located within approximately one-half mile northwest of the
landfill. Also, a Recreational Vehicle (RV) park is located
immediately adjacent and to the north of the site. The RV park is
generally occupied from late April or early May (depending upon the
flood season) until mid-November. The RV park currently is
separated from the site by a fence. Two barge terminals are
located on the banks of the river at the midpoint and southeast
portions of the landfill. Although security fences have been
erected around most of the landfill, including the oily sludge pit,
the public still is able to access the site via the banks of the
Mississippi River. Based upon reports from the landowner,
trespassing and private fishing were common prior to EPA's
involvement at the landfill. EPA continued to observe public
traffic in and around the landfill during field investigation
activities in the fall of 1992.
Climate
The area in which the site is located has an average annual
temperature of 62° F with an average temperature in January of
42° F and in July of 81° F. The average humidity at the site is
57%, with an average annual precipitation of 51 inches, including
5 inches of frozen precipitation. During the non-flood season
(July through November), rainfall averages about 3.6 inches per
month at an average temperature of 70° F within a range of 51° to
82° F.
According to data collected during various site studies, the
predominant wind direction in February was southeast to southwest
with an average wind speed of approximately 4 miles per hour. In
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11
October, temperatures ranged from 47° F to 71° F, with wind
directions varying from the west northwest to the east northeast at
1 to 3 miles per hour. Surface wind information was received for
the area from the National Weather Service, and is shown on Figure
3. For the 25 years of record, wind direction is primarily from
the south (49%), at an average speed of 8 miles per hour.
Surface Hydrology
In general, rainfall is retained within the site boundaries rather
than being drained into adjacent water bodies. Collected rainfall
runoff either infiltrates readily into the sandy clay type soils or
evaporates. No surface water discharge has been observed from the
site.
An abandoned storm sewer traverses the site, flowing from the levee
toward the river. Though a sediment sample was collected at the
outfall to the river, water was not observed to discharge from the
line, even during extended periods of localized rain. During high
river stages, this outfall is periodically underwater.
The site lies within the flood protection levees of the Mississippi
River, and may be subject to inundation on an annual basis. For
the 11 years of record, the site was inundated on 14 different
occasions, the earliest time of inundation occurring on
November 25, 1985, and the latest occurring on June 13, 1983 and
June 13, 1990.
Figure 4 presents the compilation of the site flood occurrences for
the years of record. The days of the year for this figure, 0-365
days, correspond to September 1 to August 31, and were adjusted to
show the entire flood season on one graph. The mean flood day (if
the site floods in any given flood season) would most probably
occur on March 20. One standard deviation from the mean flood day
(67% confidence level) indicates that if a flood occurs in any
given flood season, there is a 67% confidence level that the flood
would occur between January 24 and May 17, or 57 days either side
of the mean flood day. Two standard deviations from the mean flood
day (95% confidence level) indicates that if a flood occurs in any
given flood season, there is a 95% confidence level that the flood
would occur between November 27 and July 13, or 114 days either
side of the mean flood day.
Hydroqeo1ogy
The geologic sequence encountered during the exploratory drilling
conformed to the regional geology of the Mississippi embayment.
The Quaternary sediments present at the site depict the classical
coarsening downward geologic sequence, representing the lateral
migration of point bars in a meandering and mature fluvial system.
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SURFACE WIND ROSE (DIRECTION) %
1951 - 1977
N
NW
NE
W
SW
SE
PERIOD OF REPORT
YEAR(S) ANALYZED: 1951 - 1977
MONTHS: JAN. - DEC.
HOURS OF DAY: 0000 - 2300
FIGURE 3
RECORD OF DECISION
WINDROSE 1951 - 1971
SOUTH 8TH STREET UNDFILL
WEST MEMPHIS, ARKANSAS
DIRECTORY: P:\ENVIRO\06639630\ENV|FILE No. 1-4RIEPA |REV.O
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13
Locally, there is a floodplain clay deposit at the surface. This
unit is typical of an overbank mud deposit, formed by flooding.
This clay unit was identified in the areas that had not been
previously excavated for landfill disposal, and ranged in thickness
from 5 to 15 feet. The clay is very dense, very low plasticity,
with minor amounts of organics and gravels.
Below this clay unit, the sediments are predominantly clayey silts
with minor amounts of sand and gravel down to approximately 20 to
30 feet, where the sediment grades into fine sand. These sediments
are predominantly rounded quartz grains in a grayish clay matrix.
The alluvial sands continue coarsening downward, and gravel content
increases with depth. There are abundant thin peat lens laminae
present throughout the section, representing backswamp type flood
events where the organic matter has been silted over and decayed.
A basal graveliferous unit was identified in each of the deep
borings, at depths ranging from approximately 100 to 130 feet.
The Jackson Clay (Tertiary-upper Eocene) is a local confining unit
that underlies the Quaternary alluvium and the unconfined surface
aquifer. The clay is very dense, greenish-gray to brownish-gray,
very low plasticity and well lithofied (e.g., almost shale). The
depth of the Jackson Clay ranges from approximately 120 feet to 145.
feet beneath the landfill.
Groundwater levels in the monitoring wells installed during the
remedial investigation were measured on October 8, 1992 and again
on December 3, 1992. The influence of the Mississippi River on the
groundwater flow direction beneath the site is very apparent.
During October 1992, at the end of the dry season, the elevation of
the river was 186.21 feet (m.s.l.). The groundwater flow was
directly toward the river to the southeast of the site, and with
discharge into the river.
During December 1992, the water level of the Mississippi River had
risen significantly to 206.71 feet (m.s.l.). At this time, the
groundwater flow was in the opposite direction away from the river
and directed inland. The river appeared to be recharging the
alluvial aquifer.
oily Sludge Pit
Field investigation of the oily sludge pit was conducted by the EPA
to determine the nature and extent of the pit wastes and the pit's
ancillary contaminated soil and debris and to characterize the risk
the pit area posed to human health and the environment. The
investigation program was performed in three phases as described
below:
1. Exploratory trenching to define the perimeter of the
contaminated media;
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2. Phase 1 sampling and analysis of the oily sludge pit; and
3. Phase 2 sampling and analysis of the oily sludge pit.
Each of the sampling episodes is described below.
Exploratory Trenching. Exploratory trenches were excavated around
the oily sludge pit to locate the extent of subsurface
contamination associated with the pit. The locations for the oily
sludge pit area exploratory trenches are shown on Figure 5. The
RI/FS contains an extensive discussion of the methodology utilized
during the performance of the oily sludge pit area exploratory
trenching activities.
Phase 1 & 2 Pit Sampling. Sampling of the oily sludge pit was
conducted to determine the chemical/physical characteristics of the
sludge, and the horizontal and vertical extent of sludge within the
visible pit area. A total of 13 boring locations were established
as shown on Figure 6. The RI/FS contains an extensive discussion
of the methodology utilized during the performance of the Phase 1
and 2 Pit Sampling activities.
Results of Field Investigation. The following sections present the
results of the laboratory analytical testing performed on samples
extracted during the field investigation. The data gathered during
the investigation were subjected to a validation process. The
validation process is used to inform data users of data quality and
limitations. The data met the quality objectives that were
determined for the project in the RI/FS Work Plan.
Municipal and/or industrial type waste material was encountered in
12 of the 18 exploratory trenches. Oily waste was identified in 6
of the trenches (SP-1, SP-2, SP-5, SP-14, SP-15 and SP-16). In SP-
10, a layer of black soil was encountered. In 2 of the trenches,
SP-l and SP-2, the oily waste was observed to be flowing or seeping
into the excavated trench. In the remaining trenches, the soils
and/or waste materials were observed to be stained. A hydrocarbon
odor was detected in all of the contaminated trenches.
Samples from trenches SP-1, SP-3, SP-7, SP-10, SP-13 and TR6.1, SP-
1 and SP-10 were all contaminated with Acetone, Toluene, Xylenes,
Naphthalene, 2-Methylnaphthalene, Phenanthrene, and bis(2-
Ethylhexl)phthalate in the part-per-rmillion range. The primary
inorganic contaminant detected was lead.
As discussed previously, sampling of the oily sludge pit occurred
in two phases. Phase 1 sampling included a total of 13 samples
obtained from five different boreholes (PB-1 through PB-5). At
each borehole, the bottom of the pit appeared to be reached. This
conclusion was based upon the color of material encountered (light
to medium brown versus the black oily sludge) and the consistency
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18
(stiff silty clay versus moist very plastic sludge) of the
material. Identification of "layers" within each borehole was
primarily based on moisture content and consistency of the waste
materials. Two (2) layers were identified in borings PB-1 and
PB-5. Three (3) layers were identified in borings PB-2 through PB-
4. Each of the observed layers was analyzed separately according
to the grouping of the appropriate type of contaminant. Results of
analysis of the various "layers" within each boring indicate a
relatively consistent waste material within the oily sludge pit.
Due to the consistency of the Phase 1 analytical results, Phase 2
sampling and analysis was streamlined to analyze borehole composite
waste samples for treatability parameters only and to further
define the vertical limits of the oily sludge pit. Eight (8)
borings (PB-6, PB-8, PB-10, PB-11, PB-12, PB-13, PB-14 and PB-15)
were performed during Phase 2 sampling. PB-14 and PB-15 were
selectively placed within the pit for further definition of the
oily sludge pit boundaries. Analytical results obtained from
composite samples from each of the boreholes were found to be
consistent with the Phase 1 results. The pit waste analytical
results are summarized in the charts located at the end of this
section.
The oily sludge pit also was tested for dioxin in the event an off-
site disposal facility would need to know whether or not -the waste
contained dioxin. The test results confirmed the presence of octa
dioxin isomers in the waste. Since the octa isomer is less toxic
than the tetra isomer, the results were adjusted to account for
this difference and reported as 2,3,7,8 - TCDD (i.e., tetra dioxin
isomer} equivalents.
For the Organic and Inorganic TCLP Parameters, several volatiles,
semi-volatiles, herbicides, dioxin/furan, and metals were detected;
however, only lead exceeded the TCLP limit (5 mg/kg) in 7 of the 13
samples analyzed at concentrations ranging from 5.4 to 16 mg/kg.
In addition to the oily sludge samples, two "clay" samples were
extracted from PB-12 and PB-14 from below the oily sludge. PB-12
and PB-14 were relatively shallow boreholes (approximately 6-10
feet deep) , and the sampling team was able to drive the outer steel
casing into the "clay" so that the pit base material could be
sampled. A summary of the clay sample results is also provided in
the tables located at the end of this section.
The bottoms of boreholes (naturally appearing materials) for PB-10
and PB-15 were not reached. In PB-10, at a depth of approximately
17 feet below the surface of the pit, a physical obstruction was
encountered consisting of brick or rock-like material; therefore,
the hole was abandoned. In PB-15, the material consisted of a
stiff material (consistency of a clay but still black in color).
At the 18-foot depth mark, manual hand augering techniques could
not advance the sampling further. Naturally appearing soils were
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19
reached in the remaining boreholes.
The approximate horizontal extent of the oily sludge pit and its
ancillary contaminated soil and debris is shown on Figure 6. The
cross sections identified in Figure 6 are displayed in Figures 7
through 10, and a cross section key is included as Appendix C. The
sections show the oily sludge pit to be greater than 18 feet deep
with an average depth of 12 feet. Therefore, the estimated volume
of the oily sludge pit and the contaminated soil and debris is
approximately 10,000 and 12,000 cubic yards, respectively.
TABLE 1
OILY SLUDGE PIT AREA
VOLATILE ORGANIC COMPOUNDS
: ' TABLE t ".• : - •/
COMPOUND ; : . '.
Acetone
Benzene
Broioiethane
2 • Butanone
Chlorobenzene
Chloroethane
Chloroiethane
1,2 - Dichloroethane
1,2 - Dichloropropane
Ethylbenzene
2 - Hcxanone
Methylene Chloride
Tet rachloroethane
Trichloroethane
Xylene
: DANGE OF CONCENTRATIONS
:
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; ' • . : • • TABLE 2 "'"-. ;j . '•••'. -\ •' '•:',' '
COMPOUND -. . ".....;. '. '.'V1;.
Diethylphthalate
Met hylnapt ha le ne
Naphthalene
Phenanthrene
Pentachlorophenol
Phenol
i RANGEvOF CONCENTRATIONS i J
610 -
46,000 -
33,000 -
15,000 -
13,000 -
18,000 -
4,100
100,000
94,000
66,000
45,000
100,000
TABLE 3
OILY SLUDGE PIT AREA
PESTICIDES/PCBs
TABLE 9
COMPOUND ;
Arochlor-1254
2,4-D
2,4,5-T
Guthion
Couiaphos
Fensulfothion
' ';'"' ' ' ' • ' '•
BADGE OF CONCEHTflATIOMS :
:. (ug/kg)
14,000
6,100
2,900
1,000 - 9,900
1,000 - 9,900
700 - 1,000
TABLE 4
OILY SLUDGE PIT AREA
INORGANIC COMPOUNDS
TABLE 4
COMPOUND
Bariui
Cadiiim
Copper
Lead
Zinc
RANGE OF CONCENTRATIONS
(•0/kO)
1,010
11.2
39
6,460
533
- 2,760
- 12.4
- 210
- 33,600
- 4970
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TABLE 5
OILY SLUDGE FIT AREA
DIOXIN
I : TABLE :S .,..-•
Boring
Location •
PB2
PB2
PB2
PBS
Saaple Depth :
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TABLE 7
OILY SLUDGE PIT AREA
CLAY CHARAC.
T/BLE:7 ; .
; COMPOUND
VOLATILES
1,2 - Dichloroethane
Ethylbenzene
Tet rac hlonoethylene
Xylene
PC8s & PESTICIDES
Arochlor - 1016
Arochlor - 1242
Arochlor - 1254
Arochlor - 1260
4,4 - DDE
4,4 - DDT
Endrin Aldehyde
alpha - Chlordane
SENIVOLATILES
Anthracene
2- Methylnaphthalene
Naphthalene
Phenanthrene
' * METALS
Lead
Zinc
RANGE OF CONCENTRATIONS
(vtifka) ;
5
2
6.5
0.9 - 13
550
58 - 110
580
430
13 - 22
14 - 29
4.3 - 4.7
2.7
50
90 - 91
46
52
^Et/(cO)
21 - 336
130 - 389
Landfill Areas
Field investigation of the landfill areas was conducted by the EPA
to locate "hot spots" within the landfill, determine the nature and
extent of the landfill wastes, and to characterize the risk the
landfill areas pose to human health and the environment. Hot spots
are defined as areas of high contaminant concentrations typical of
drum or sludge disposal areas within the landfill which usually
correspond ' to the greatest threat to human health and the
environment. The primary objective of the investigation was to
locate and characterize these hot spots. The investigation program
consisted of the following elements:
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• multimedia sampling of surface and subsurface soils,
sediments, surface waters, air (including volatile organic
compound (VOC) emission rates), and fish, mammal and plant
tissue;
• real-time air monitoring during intrusive work;
• exploratory trenching;
• geophysical survey of the site with magnetics;
• soil gas survey;
• toxicity testing of pond water and sediment; and
• ecological characterization for wetland determination and
habitat suitability.
Only the trenching program and the sampling of the surface soils,
surface water, sediment and air will be discussed in detail in the
ROD. The results and the methodologies employed to conduct all
other parts of the investigation are described in detail in the
RI/FS report.
Trenching. Prior to initiating trenching activities, a detailed
review of historical aerial photographs was conducted to determine
where past disposal activities at the site may have occurred. In
addition, a magnetometer and soil gas survey was conducted in an
attempt to identify hot spots within the areas of suspected
disposal.
Upon completion of the magnetometer and soil gas survey, individual
trench locations were established along surveyed lines based upon
the results of the surveys and/or physical site features such as
obvious depression areas potentially created by landfill settling.
The resulting trench spacing ranged from 50 to 100 feet, center to
center, along the base lines. The locations of all trenches are
shown in Figure 11. A total of 44 trenches was excavated
throughout the landfill. The breakdown of the number of trenches
per area is as follows: 14 in Area 1; 10 in Area 2; and 20 in
Area 3. The methodologies employed to conduct the landfill
trenching activities are described in detail in the RI/FS report.
Results of Trenching. No hot spots (i.e., numerous drums or
sludges) were observed during trenching operations. However, one
drum was discovered, the contents of which were sampled and
analyzed. EPA does not characterize one drum as a hot spot.
Chemical testing of samples collected during the trenching
operations confirmed the presence of several volatile organic
compounds, semi-volatile organic compounds, and several pesticides
and inorganic contaminants.
A summary of the contaminants detected is provided in Tables 8-10.
Values that are enclosed by parenthesis followed by the letter "U"
denote contaminant concentrations that are less than the detection
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28
limit. The analytical detection limit is the number enclosed by
the parentheses.
TABLE 8
LANDFILL AREA SUBSURFACE
VOLATILE ORGANIC COMPOUNDS
COMPOUND
Methylene chloride
Acetone
Carbon Disulfide
2-Butanone
1,1,1 -Trichloroethane
Benzene
Toluene
Ethylbenzene
Xylenes^ total
' TABLE » !
RANGE OF CONCENTRATIONS
{utfkg)
1-120
2 • 66
o.g - 1
2 - 39
(10) U - 0.4
(10) U - 300
(10) U - 3800
(10) U - 5600
o.e - 2
BACKGROUND flAMGE
{007*6}
0.9 - 3
4 - 13
NA
1 - 3
3 - 4
Not Available (NA
NA
NA
NA
. SAMPLE ID WITH HIGHEST
! CONCENTRATION
A3-TH9.7
A3-TR9.7
A3-TR2.2
A3-TR3.5
A3-TR1.6
A3-TR9.7
A3-TR9.7
A3-TR9.7
A2-TR4.13
TABLE 9
LANDFILL AREA SUBSURFACE
SEMIVOLATILE ORGANIC COMPOUNDS
. TABLE 9 !--:;.'
COMPOUNDS
Naphthalene
2-Uethylnaphthalene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Di-n-butylphthalate
Fluoranthene
Pyrene
RANGE OF CONCeiTRATIONS
: (ug/kg> : :
69 J - 33000
70 - 190
92
77
87
42 - 980
62 - 260
160
44 - 80
80 - 1100
180 - 260
BACKGROUND* RANGE
"•.: fua/ka> : -s
(350) U - (430) U
(350) U • (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
25 - (430) U
26 - (430) U
25 - (430) U
SAMPLE ID WITH HIGHEST
CONCENTRATION
A2-TR4.1b
A3-TR2.2
A3-TR2.4
A2-TR4.1a
A3-TR2.4
A2-TR4.18
A2-TR4.1a
A2-TR4.1a
A2-TR4.4
A1-TR5.12
A2-TR4.1a
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• .. TABLE 9 .-..-•" '-.
COMPOUNDS
Butylbenzylphthalate
Benzo(a)anthracene
Chrysene
bis(2-Ethylhexyl)phthalate
Di-n-octylphthalate
Benzo(b)fluoranthene
Benzo(k)f luoranthene
Benzo(a)pyrene
Indeno(1 ,2,3,cd)pyrene
Benzo(g,h,i)perylene
HAN6E OF CONCENTRATION^
fug/koy
47 - 210
110 - 170
62 - 730
44 - 4100
83 - 5400
120 - 570
230 - 240
43 - 250
70 - 330
18 - 270
BACKGROUND' RANGE
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
120 - 1200
31 - 260
(350) U • (430) U
(350) U - (430) U
(350) U - (430) U
(350) U • (430) U
(350) U - (430) U
SAMPLE ID WITH -HIGHEST :
CONCENTRATION
A3-TR3.5
A3-TR2.2
A3-TR3.5
A2-TR4.1a
A3-TR3.4
A2-TR4.18
A3-TR3.5
A3-TR3.5
A2-TR4.1a
A2-TR4.1a
TABLE 10
LANDFILL AREA TRENCHING
INORGANIC COMPOUNDS
COMPOUND
Aluninua
Antiiony
Arsenic
Bariui
Berylliui
Cadaiui
Calciui
ChroiiuB
Cobalt
Copper
Cyanide
Iron
Lead
Magnesiun
Manganese
RANGE OF CONCENTRATIONS
DETECTED (ig/kg)
517 - 26800
(3.8) U - (5.2) U
1.4 - 16.2
19.2 - 337
0.2 - 2.3 .
1.1 - 7.2
564 - 28600
3.6 - 43.5
2.6 - 15.8
1.8 - 293
/ 0.06 - 1.2
3420 - 139000
1.7 - 358
155 - 6410
61.4 - 1320
TABIJSMO"" '
BACKGROUND RANGE ("a/kg)
5170 - 14300
(4.0) U - (4.7) U
3.2 - 8
104 - 212
0.19 - 1.2
0.59 - 2.1
4750 - 7060
9.1 - 19.9
5.1 - 11
13.9 - 18.8
0.09 B - 0.41 B
11000 - 23200
26.4 - 68.8
2830 - 4050
210 J - 984
SAMPLE ID WITH HIGHEST
CONCENTRATION
A3-TR1.4-02
A2-TR4.1b
A3-TR3.4
A3-TR2.4
A2-TR9.5
A3-TR2.4
A3-TR3.4
A3-TR2.4
A3-TR3.4
A3-TR3.4
A2-TR4.1b
A3-TR3.4
A3-TR3.4
A3-TR1.4
A3-7R3.4
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30
COMPOUND
Mercury
Nickel
Potassiui
SeleniuB <
Silver
Sodiui
Thalliui
Vanadiui
Zinc
: , - -.I •' ;..^TMuH|b-">, •>-,'•.-•'• :.:.'. .'.' - I.""
I RANGE OF CONCENTRATIONS :
DETECTED (iQ/lcg) • ' : :
0.07 - 0.2
5.8 - 262
154 - 3600
0.18 - 0.65
(0.53) U - 1.2
61-689
0.23 - 0.47
1 - 59.3
33.7 • 1510
BACKGROUND RANGE Jog/kg)
(0.08) U - (0.09) U
11.7 - 27
958 - 1950
0.3 • 0.78
0.62 - 0.86
43.5 - 104
(0.18) U - (0.21) U
14.4 - 32.8
73.9 • 86.5
SAMPLE ID TKITH HIGHEST
] CONCENTRATION :
A1-TR5.5
A3-TR3.4
A3-TR1.4
A3-TR1.1
A3-TR3.4
A3-TR2.4
A3-TR1.6
A3-TR1.4
A3-TR3.4
TABLE 11
LANDFILL AREA TRENCHING
PESTICIDES/PCBS
TABtE 1t
COMPOUNDS
4, 4' -DDE
4, 4' -ODD
RANGE OF CONCENTRATIONS
DETECTED (uo/ka)
(3.7) U • 48
(3.7) U - 42
BACKGROUND, RANGE
(ua/kg)
(3.6) U - 3.8
(3.6) U - (4.4) U
SAMPLE ID WITH HIGHEST
CONCENTRATION
A2-TR4.4
A3-TR1.4-03
Based upon the initial information in the HRS package, EPA had
estimated the size of the site at 48 acres. The size of area at
the site with evidence of historical disturbance is estimated at 30
acres. The trenching data indicates that the area in which
landfilling of municipal and industrial waste occurred is
approximately sixteen acres in size. The estimated size of each
landfill and waste area is presented in Table 12.
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TABLE 12
AREA/VOLUME OF
LANDFILL
32
AREA
WO,
1
2
3
All
: . WASTE TYPE
Municipal/Industrial
Municipal/Industrial
Municipal/ Industrial
All Landfill Areas
.AREA
: (ACRES};
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33
TABLE 13
LANDFILL AREA SURFACE SOILS
VOLATILE ORGANIC COMPOUNDS
COMPOUND :
Methylene chloride
Acetone
2-Butanone
1,1,1-
Tricnloroethane
' = ' : fABLI
RANGE OP CONCENTRATIONS
(uQffcO>
1 - 8
2 - 66
2 - 7
0.3 - 4
':'« : • i -?. .
BACKGROUND RANGE
{udmrt
0.9 - 3
4 - 13
1 -7
3 - 4
SAMPLE ID WITH HIGHEST
: CONCENTRATION ;
A1-SS-3-G
A3-SS-40-G
A4-SS-23-G
A1-SS-34-G
TABLE 14
LANDFILL AREA SURFACE SOILS
SEMIVOLATILE ORGANIC COMPOUNDS
TABLE 14
COB pound
Naphthalene
2-Methylnaphthalene
Acenaphthene
Dibenzofuran
Diethylphthalate
Fluorene
Phenanthrene
Anthracene
Carbazole
Di - n - butylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
Benzo (a ) anthracene
Chrysene
bis(2-Ethylhexyl)phthalate
Di- n - octylphthalate
Benzo (b)fluoranthene
Benzo (k)fluoranthene
RANGE OF CONCENTRATIONS
{ug/*Q)
20 - 58
28 - 74
64 - 130
42 - 67
14 - 41
87 - 140
16 - 1100
11 - 290
120 - 210
13 - 1700
23 - 1300
23 - 1500
12 - 78
15 - 58
18 - 790
42 - 8000
21 - 650
45 - 1500
57 - 1700
BACKGROUND RANGE
Cog/Kg)
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U • (430) U
25 - (430) U
26 - (430) U
25 - (430) U
(350) U - (430) U
(350) U - (430) U
(350) U - (430) U
120 - 1200
31 - 260
(350) U - (430) U
(350) U - (430) U
SAMPLE ID WITH HIGHEST
CONCENTRATION
A4-SS-9
A4-SS-9
A1-SS-35
A1-SS-35
A1-SS-34
A1-SS-35
A1-SS-35
A1-SS-35
A1-SS-35
A2-SS-38
A1-SS-35
A1-SS-35
A1-SS-36
A4-SS-2
A1-SS-35
A1-SS-34
A3-SS-6
A1-SS-35
A1-SS-35
-------
34
TABLE 14
Compound
8enzo(a)pyrene
Indeno(1 ,2,3,cd)pyrene
Dibenzo (a , h ) anthracene
Benzo(g,h,i)perylene
RANGE OF CONCENTRATIONS
(aol*«i !
21 - 670
92 - 220
64
96 - 190
: BACKGROUND RANGE
(350) U - (430) U
(350) U - (430) U
(350) U • (430) U
(350) U - (430) U
: SAMPLE ID WITH HIGHEST
CONCENTRATION
A1-SS-35
A1-SS-35
A1-SS-35
A1-SS-35
TABLE 15
LANDFILL AREA SURFACE SOILS
PESTICIDES & PCBs
'= TABU 15 :
COMPOUNDS
Dieldrin
4, 4' -DDE
4, 4' -ODD
4,4'-DDT
alpha-Chlordane
gaua-Chlordane
Toxaphene
Aroclor-1248
RANGE OF CONCENTRATIONS
DETECTED
(ug/kg)
(2.0) U - 11
(2.0) U • 9500
(2.0) U - 20000
(2.0) U - 61000
(1.8) U - 22
(1.8) U - 18
(2.0) U - 460000
(35) U - 690
BACKGROUND RANGE
:
5170 - 14300
(4.0) U - (4.7) U
3.2 - 8
104 - 212
0.19 - 1.2
0.59 - 2.1
4750 - 7060
9.1 - 19.9
SAMPLE ID WITH HIGHEST
CONCENTRATION :
A4-SS-20
A1-SS-34
A1-SS-36
A1-SS-35
A1-SS-34
A1-SS-36
A4-SS-9
A1-SS-35
-------
35
COMPOUND :
Cobalt
Copper
Cyanide
Iron
Lead
Magnesiim
Manganese
Mercury
Nickel
Potassiu«
Seleniui
Silver
Sodiui
Thalliua
Vanadiua
Zinc
RANGE OF CONCENTRATIONS \
-DETECTED • . .;
|: <«o/kg) : : ;
1.8 - 14.1
2.3 - 130
0.04 - 1.3
5170 - 25600
12.2 - 5810
1030 - 6460
78.1 - 2530
(0.08) U • 0.49
8.3 • 62.9
376 - 2470
(0.13) U - 1.2
(0.40) U - 5.8
15.6 - 726
(0.19) U - 0.45
8.1 - 42.3
29.8 - 579
BACKGROUND RANGE
'. ;!M»Ws-. ..:.:. -.-
5.1 - 11
13.9 - 18.8
0.09 B - 0.41
11000 - 23200
26.4 - 68.8
2830 - 4050
210 - 984
(0.08) U - (0.09) U
11.7 - 27
958 - 1950
0.3 - 0.78
0.62 - 0.86
43.5 • 104
(0.18) U - (0.21) U
14.4 • 32.8
73.9 - 86.5
SAMPLE ID WTO HIGHEST
. : CONCENTRATION
S :-• ' . • . '•• ' :
A4-SS-14
A1-SS-35
A4-SS-4
A4-SS-18
A2-SS-38
A4-SS-22
A4-SS-9
A1-SS-35
A1-SS-35
A3-SS-41
A1-SS-3
A1-SS-35
A4-SS-9
A4-SS-26
A4-SS-18
A1-SS-36
Results of Sediment Investigation. Ten sediment samples, including
one duplicate, were collected from the site and background
locations. The comparability of the organic duplicate samples was
low for volatil.es, and the inorganic duplicate was comparable.
The results of the sediment analyses yielded positive detections
for five volatile compounds. Three are considered common
laboratory contaminants. One compound detected, 1,1,1-
trichloroethene, was found only in the background sample. The one
remaining detected compound, carbon disulfide, was reported below
the detection limit. Nine semi-volatiles were detected. As stated
above, most concentrations were reported below detection limits.
Several compounds are also considered common laboratory
contaminants. The inorganic compounds detected in on-site sediment
samples exceeded the concentrations of inorganic analytes in the
background sample, with the exception of selenium and sodium. The
results of the various analyses are provided in the tables below.
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36
TABLE 17
LANDFILL AREA SEDIMENTS
ORGANIC COMPOUNDS
. TABLE 17
: COMPOUND
} VOLATItES
Uethylene chloride
Acetone
Carbon disulfide
2-Butanone
1,1,1 -Trichloroethene
SEMI-VOLATILES
Phenanthrene
Di-n-butlyphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
Chrysene
bis(2-Ethylhexyl)phthalate
Di-n-octylphthalate
Benzo ( b)f luoranthene
PESTICIDES
4,4' -ODD
RANGE OF
CONCEHTRATIONS
(ujtfka)
2 - 19
12 - 230
2
3 - 57
(13) U - (29) U
73 - 150
53
67 • 220
55 - 150
54
92
50 - 430
150 - 650
110
4.6
BLANK :
. : "CONCENTRATIONS
: {Ufl/kfl}
2
14
(11) U
(11) U
4
(360) U
17
(360) U
(360) U
6
(360) U
32
40
(360) U
U
SAMPLE ID WITH
MnOHEST
CONCENTRATION
A3-SD-1-G
A3-SD-2-G
A3-SD-2-G
A3-SD-1-D
OS-SO-10-G
A3-SD-8-D
A2-SD-7-G
A3-SD-8-D
A3-SD-8-D
A2-SD-7-G
A3-SD-8-D
A2-SD-7-G
A4-SD-6-G
A4-SO-6-G
A3-SD-7-G
TABLE 18
LANDFILL AREA SEDIMENTS
INORGANIC COMPOUNDS
COMPOUND
Aluuinui
Antinony
Arsenic
Bariun
TABLE 18
RANGE OF CONCENTRATIONS
DETECTED :
(•a/kg)
6380 - 17700
(5.5) U
1.8 - 6.3
119 - 260
BACKGROUND
(•B/kg) 1
11200
(4.2) U
3.8
213
SAMPLE ID WITH HIGHEST
CONCENTRATION
A3-SD-2-G
NA
A2-SD-7-G
A3-SD-2-G
-------
37
COMPOUND
Berylliui
Cadiiu*
CalcitiB
Chroniua
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassiui
Seleniua
Silver
Sodiua
Thalliua
Vanadiu*
Zinc
RANGE'- OF CONCENTRATIONS ' ">
DETECTED
(•g/kg)
0.25 • 1.2
0.39 • 1.6
4940 - 23500
10.2 - 306
6.0 - 10.2
7.3 - 368
0.18 • 4.0
10900 - 24800
8.7 - 38.9
3480 - 5400
138 - 680
(0.08) U - (0.19) U
14.4 - 816
972 - 2480
0.26 - 0.93
(0.53) U - 1.2
36.9 - 85.5
(0.21) U - 0.26
18 • 42.8
41.4 - 111
"VTASL£;:«I^--.:- '•''.' ': :./: • -
• ' ¥ •• •: -. .. -. •g^QQQHOmrtt :' •' ':
i JW/KOJ ;.;. : 1
1.1
(0.27) U
9050
25.7
8.2
19.6
0.07
17800
14.1
4880
564
(0.08) U
27.3
1890
1.3
0.50
331
(0.18) U
27.2
65.3
SAMPLE ID -WITH HIGHEST
CONCENTRATION .
A1-SO-4-G/A2-SO-7-G
A3-SD-1-G
A3-SD-1-G
A2-SD-7-G
A2-SD-2-G/A1-SD-4-G
A2-SD-7-G
A2-SD-7-G
A3-SD-2-G
A2-SD-7-G
A3-SD-2-G
A4-SD-6-G
NA
A2-SD-7-G
A3-SD-2-G
A1-SD-4-G
A3-SD-1-G
A4-SD-6-G
A1-SD-5-G
A3-SD-2-G
A3-SD-2-G
Results of Surface Water Investigation. Nine surface water
samples were collected and analyzed during the RI. Six surface
water samples, including one duplicate, were collected from the on-
site pond and pools of standing water. Two blanks were also
analyzed. One sample was collected from a City of West Memphis
fire hydrant to evaluate the water used for drilling fluids and
equipment decontamination. Volatile and semi-volatile organic
compound detections were uniformly reported at or below detection
limits. The risk assessment identified two inorganic contaminants
of potential concern, arsenic and beryllium. The concentrations.
detected in the surface water samples for these compounds are below
the Primary Drinking Water Regulations Maximum Concentration Level
(MCL) of 0.05 mg/L for arsenic and 0.004 mg/L for beryllium. The
results of the inorganic analyses are provided in the chart below.
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38
TABLE 19
LANDFILL AREA SURFACE WATER
INORGANIC COMPOUNDS
: TABLE 19
COMPOUND .
AluiinuB
Antinomy
Arsenic
Barium
Beryllium
Cadiiun
Calciun
Chroiiun
Cobalt
Copper
Cyanide
Iron
Lead
Magnesiui
Manganese
Mercury
Nickel
Potassiua
Seleniun
Silver
Sodium
Thalliu.
Vanadiu»
Zinc
RANGE OF CONCENTRATIONS
nETECJHMtioa* •.-••"
356 - 1790
(27.4) U
2.9 - 5.4
51.8 - 124
0.6
1.8 - 5.1
20800 - 49900
2.0 - 4.8
2.9 - 7.0
6.0 B - 52.4
1.4 - 6.4
379 - 2500
3.4 - 37.3
2800 - 18000
13.9 - 111
(0.16) U
(8.8) U - 15.6
3240 • 6600
0.92 - 1 .9
(0.29) U
993 - 9410
(1.2) U
(2.2) U
4.2 - 117
BLANK
: «W/1)
51.9 B
(27.4) U
(1.9) 0
(1.3) U
(0.52) U
2.6 B
45.8 B
2.5 B
3.3 B
1.8 B
1.7 B
49.6 B
(1.6) U
145 B
2.1
(0.16) U
(8.8) U
(644) U
(0.92) U
(0.29) U
(2.18) U
(1.2) U
(2.2) U
1.9 B
VI. SUMMARY OF SITE RISKS
An evaluation of the potential risks to human health and the
environment from site contaminants was conducted in accordance with
OSWER Directive 9285, Risk Assessment Guidance for Superfund,
Volume 1, Human Health Evaluation Manual, (Part A), as part of the
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39
baseline risk assessment. The results of all the sampling
conducted at the site during the RI were used to evaluate the risk
the site poses to the public health and the environment.
Because EPA had originally intended to address the oily sludge pit
as a removal and the landfill areas as a remedial action, two risk
assessments were prepared. One risk assessment was prepared in
conjunction with the planned EE/CA for the oily sludge pit area,
and one risk assessment was prepared during the RI for the landfill
areas. Both risk assessments were prepared in accordance with EPA
guidance and incorporated into the baseline risk assessment for the
entire site.
The objectives of the baseline risk assessment were to (1) 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: 1) the
human health evaluation and 2) the ecological evaluation. Human
health risks are determined by evaluating chemical exposure limits
and actual concentrations of contaminants present at a site. The.
actual contaminant concentrations are compared to the exposure
concentration known or suspected to have a potential adverse
impact. In the risk assessment, carcinogenic and non-carcinogenic
risks are calculated. Conservative assumptions that weigh in
favor of protecting human health are used in calculating risks.
The environmental or ecological risk assessment is conducted to
determine if there are any current or potential impacts on
ecological receptors (such as birds or mammals) attributable to the
unremediated site.
The national risk, or probability, that an individual may develop
some form of cancer from everyday sources, over a 70-year life
span, is estimated at three in ten. Activities such as too much
exposure to sun, occupational exposures, or dietary or smoking
habits contribute to this high risk. The three in ten probability
is considered the "natural incidence" of cancer in the United
States.
To protect human health, the EPA has established an excess
acceptable lifetime cancer risk range, from one in ten thousand to
one in one million. This range may be expressed as 1 x 10~4 to
1 x 10"6. For example, a risk of 1 x 10"6 means that 1 person out
of one million could develop cancer as a result of a lifetime
exposure to a site. EPA must consider the need to conduct remedial
action at a site if the risk exceeds 1 x 10"6. EPA usually requires
remedial action at locations where excess cancer risks are greater
than 1 x 10"4 (1 excess cancer case in ten thousand people could
potentially occur) .
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40
The level of concern for non-carcinogenic contaminants is
determined by calculating a Hazard Index (HI). If the HI exceeds
one (1) , there may be concern for potential exposure to site
contaminants. EPA typically requires remedial action at locations
where the HI values are greater than 1.0 for human populations who
may reasonably be expected to be exposed.
The risk assessments conducted at the South 8th Street Landfill
site do not use either residential or industrial exposure scenarios
because the flooding pattern at the site precludes the use of such
typical scenarios. Because of the frequent flooding, it is highly
unlikely that a residence or business (other than barge transfer
operations) will ever be established on the site. However, the
site has been considered for use as a state park, and residents of
the nearby RV park had access to the site before it was fenced.
Therefore, EPA has determined that it is appropriate to use a site
specific recreational setting in order to develop the exposure
scenarios for the baseline risk assessment. EPA also considered an
agricultural scenario since the site was used for agricultural
purposes in the past, and areas near the site have been used for
agricultural purposes within the last several years.
Based upon the above scenarios, EPA considered several receptors
during the development of the human health portion of the baseline
risk assessment.. These hypothetical receptors included current
recreational visitors, future recreational visitors, future
recreational workers (e.g., site caretaker), and crop consumers.
The assumptions utilized to calculate risk are specified in detail
in the baseline risk assessment. Some of the risks associated with
both the oily sludge pit and landfill areas are shown in Figures 12
through 14.
Finally, although the risks from both the average (AVG) and
reasonable maximum exposure (RME) scenarios were calculated in the
risk assessment, the RME risks were used to evaluate threats at the
site because the NCP and current EPA policy mandate the use of the
RME when evaluating the need for response actions at Superfund
sites. EPA policy requires the AVG risk to be quantified in the
baseline risk assessment. The difference between the AVG and RME
risks results from using different assumptions in the equations
utilized to perform the risk calculations. For example, the soil
intake rate utilized for the recreational worker AVG risks is 240
mg/day as opposed to 480 rag/day for the RME risk, the exposure
frequency for AVG is 152 days per year as opposed to 250 days per
year for RME, and the exposure duration is 9 years for AVG as
opposed to 25 years for RME. RME risks are greater, and .thus more
conservative, than average risks.
-------
41
Oily Sludge Pit Area Risk Assessment Results
Human Health Risk Assessment
The most significant threat to human health from the pit area is
attributed to the low pH of the sludges in the pit. The low pH
means that the sludges are corrosive. Upon contact, corrosive
material may destroy body tissues, metals, plastics and other
materials. At a minimum, the highly corrosive nature of the pit
sludges likely will cause severe burns to recreational visitors and
workers who may come into contact with the sludge while in the
area.
The lifetime excess cancer risk for current recreational visitors
is estimated to be 6 x 10'7 (RME) and 1 x 10'8 (AVG), taking into
account the risks from surface soils in the pit area via dermal
contact and oral ingestion. This risk is below EPA's acceptable
risk range of 1 x 10~4 to 1 x 10"6. Risks to current recreational
visitors via inhalation were considered, but ultimately were not
quantified due to the low emission rates documented in the
undisturbed areas of the pit.
The lifetime excess cancer risk for future adult recreational
visitors is estimated to be 1 x 10"* (RME) and 5 x 10'6 (.AVG) , taking
into account risk from exposure to waste material that may be
spread over the entire site area in the future, groundwater from a
hypothetical future on-site well, and emissions that may be created
by the redistribution of the pit waste. This risk is within EPA's
acceptable risk range.
The excess lifetime cancer risk for a future recreational worker is
estimated to be 1 x 10'3 (RME) and 1 x 10'4 (AVG), taking into
account risk from exposure to waste material that may be spread
over the entire site area in the future, groundwater from a
hypothetical future on-site well, and emissions that may be created
by the redistribution of the pit waste. This risk exceeds EPA's
acceptable risk range of 1 x 10"4 to 1 x 10"6. The organic
contaminants that contribute to this risk are carcinogenic PAHs,
PCBs, and TCDD equivalents.
The excess lifetime cancer risk for a future crop consumer is
estimated to be 8 x 10'2 (RME) and 2 x 1CT2 (AVG), taking into
account risk from ingestion of vegetables grown in waste material
that may be spread over the oily sludge pit area in the future.
This risk exceeds EPA's acceptable risk range of 1 x 10~4 to
1 x 10"6. The organic contaminants that contribute to this risk
are carcinogenic PAHs, PCBs, and TCDD equivalents.
With regard to non-carcinogenic threats, the HI for current child
and adult recreational visitors are 0.008 and 0.004 RME,
respectively, taking into account exposure to only surface soils in
the pit area. Since these HI values are less than 1, non-
-------
1E-07
Future Ret Viator
Future Rec. Worker
Hypothetical Future Adult Populations
Future Crop Consumer
Subsoil-Oral
Subsoil-Dermal fftffl Crops-Oral
Total
FIGURE 12 SUMMARY OF EXCESS CANCER RISKS FOR
FUTURE POPULATIONS - RME
-------
= o ^ _
IlllllDlllll
w
§
ia
a
w
ID
-------
SS3DX3
-------
45
carcinogenic health threats, with the exception of the chemical
burns as previously discussed, are not expected to occur for
current child and adult recreational visitors.
The HI for future child and adult recreational visitors is 20 RME
(3 AVG) and 3 RME (0.6 AVG) , respectively, taking into account
exposure to waste material that may be spread over the entire site
area in the future, groundwater from a hypothetical future on-site
well and emissions that may be created by the redistribution of the
pit waste. These HI values exceed EPA's acceptable action level of
1.0. The primary contaminants that contribute to the high HI
values are volatile organic compounds that may be released into the
air if the pit waste is excavated and redistributed over the pit
area at some point in the future.
The HI for future recreational workers is 20 RME and 6 AVG, taking
into account exposure to waste material that may be spread over the
entire site area in the future, groundwater from a hypothetical
future on-site well, and emissions that may be created by the
redistribution of the pit waste. These HI values exceed EPA's
acceptable action level of 1.0. The primary contaminants that
contribute to the high HI values are volatile organic compounds
that may be released into the air, carcinogenic PAHs, PCBs and TCDD
equivalents.
The HI for future child and adult crop consumers is 6 RME (4 AVG)
and 70 RME (50 AVG), respectively, taking into account exposure
resulting from ingestion of vegetables grown in waste material that
may be spread over the oily sludge pit area in the future, and, for
the adult crop consumer only, direct contact, ingestion, and
inhalation of contaminants that may occur while growing the
vegetables. These HI values exceed EPA's acceptable action level
of 1.0. The contaminants that contribute to this risk are PCBs,
alpha-chlordane and bromomethane.
Ecological Risk Assessment
An ecological risk assessment was conducted to evaluate the threats
the pit area poses to the environment. Based upon a review of the
data and relevant technical literature, EPA determined that
environmental receptors are avoiding the pit area due to the highly
corrosive nature of the pit waste. As was the case with the human
health risk assessment, the low pH of the pit waste presents an
acute threat to the ecosystem. In addition, the continuous
flooding at the site will result in the spread of contamination
from the pit, potentially impacting plants and wildlife located on
or near other areas of the site.
Landfill Areas Risk Assessment Results
Due to the size of the site, it is possible that future campgrounds
-------
46
may be developed in one or more areas of the site. It is
therefore reasonable to assume that a campground could be developed
in Area 1 or in an area that includes both Area 2 and Area 3, with
the future recreational visitors being exposed primarily to
contaminants present in one of these areas.
Human Health Risk Assessment
The lifetime excess cancer risk for current recreational visitors
is estimated to be 6 x 10"6 (RME), taking into account the risks
from on-site surface soils and surface water, sediments, and fish
in the large pond located near the RV Park. This risk is within
EPA's acceptable risk range of 1 x 10~4 to 1 x 10"6.
The lifetime excess cancer risks for future recreational visitors
who camp in Area 1 is estimated to be 5 x 10"5 (RME), taking into
account risk from surface soils, groundwater from a hypothetical
future on-site well and surface water, sediments and fish in the
large pond located near the RV park. This risk is within EPA's
acceptable risk range.
The lifetime excess cancer risk for future recreational visitors
who camp in Area 2/3 is estimated to be 2 x 10"5 (RME) , taking into
account risk from surface soils, groundwater from a hypothetical
future on-site well, and surface water, sediments and fish in the
large pond located next to the RV park. This risk is within EPA's
acceptable risk range.
The lifetime excess cancer risk for a future recreational worker is
estimated to be 5 x 10'4 RME taking into account risk from on-site
surface soils, groundwater, and surface water and sediments in the
large pond located next to the RV park. It should be noted that
the risk from ingestion of the on-site surface soils accounts for
the majority of the total risk to the recreational worker. This
risk exceeds EPA's acceptable risk range of 1 x 10~4 to 1 x 10'6.
The contaminants that contribute to this risk are carcinogenic
PAHs, pesticides (including toxaphene, DDD, DDE and DDT, PCBs) and
the inorganic compounds, arsenic and beryllium.
With respect to Area 1, the excess lifetime cancer risk for a
future crop consumer is estimated to be 6 x 10"2 (RME) , taking into
account risk from ingestion of vegetables grown in waste material
from Area 1. The contaminants that contribute to this risk are
carcinogenic PAHs, pesticides (including toxaphene, DDD, DDE and
DDT, PCBs) and the inorganic compounds, arsenic and beryllium. This
risk exceeds EPA's acceptable risk range of 1 x 10'4 to 1 x 10'6.
With respect to Area 2/3, the excess lifetime cancer risk for a
future crop consumer is estimated to be 2 x 10"2 (RME) taking into
account risk from ingestion of vegetables grown in waste material
from Area 2/3. The contaminants that contribute to this risk are
carcinogenic PAHs, pesticides including toxaphene, DDD, DDE and
-------
47
DDT, PCBs, and the inorganic compounds, arsenic and beryllium.
This risk exceeds EPA's acceptable risk range of 1 x 10'" to
1 x 10'6.
In addition to evaluating cancer risks, EPA also evaluated the
potential health threats associated with non-carcinogenic effects
of the contaminants detected on the site. EPA uses the hazard
index to evaluate non-carcinogenic health threats. If the total
subchronic (for children) or chronic (for adults) is less than one
for all pathways, it is believed that non-carcinogenic health
threats will not occur. If the HI is equal to or exceeds 1, it is
believed that there is some possibility that non-carcinogenic
health effects may occur.
The risk assessment shows that, with the exception of crop
consumers, none of the potential receptors that EPA is using to
evaluate risk at the site have HI values greater than 1.
Area 1 His for both future child and adult crop consumers are 60
and 30, respectively, taking into account exposure resulting from
ingestion of vegetables grown in waste material from Area 1 that
may be spread over the site in the future. Area 2/3 His for both
future child and adult crop consumers are 5, taking into account
exposure resulting from ingestion of vegetables grown in waste
material from Area 2/3 that may be spread over the site in the
future. These HI values exceed EPA's acceptable action level of 1.
Ecological Risk Assessment
An ecological risk assessment was conducted to evaluate the threats
the landfill areas pose to the environment. Based upon site data
and relevant technical literature, EPA identified several
environmental receptors potentially affected by the site. These
receptors include small mammals such as mice, aquatic organisms
present in the large pond located next to the RV park, and birds
such as the red shouldered hawk and the least tern. The least tern
is an endangered species that was identified as an environmental
receptor of concern in the HRS package.
The ecological risk assessment indicates that soil invertebrates
(earthworms, snails, slugs, etc.) and plants may be at risk due to
exposure to metal contaminants in the soil. A comparison of the
water and sediment concentrations to U.S. EPA Ambient Water Quality
Criteria and sediment quality criteria established by the National
Oceanic and Atmospheric Administration (NOAA) indicates that the
pond's ecosystem appears to be at risk. However, toxicity tests
using pond water and sediments show that these media were not toxic
to the test organisms.
The presence of pesticides and PCBs in bluegill, largemouth bass,
and channel catfish obtained from the pond indicates that a
bioaccumulation impact could be present and potentially could be a
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48
threat to fish-eating birds and mammals. However, the data was
insufficient to substantiate that the contamination is attributable
to the site as fish in the nearby Mississippi River upstream of the
site contain similar levels of contaminants. The fish located in
the pond may have very well come to be located there during one of
the frequent flood events and could have been exposed to pesticides
and PCBs prior to arriving at the site. The hypothesis is
substantiated by the fact that none of the pond sediment or surface
water samples indicated the presence of PCBs or pesticides above
the detection limit. Therefore, a foodchain link between organisms
that feed off the pond sediments and the fish cannot be
established. In addition, the ecological risk assessment shows
that small mammals and birds are not at risk from exposure to other
food sources located in the landfill areas.
Finally, EPA was concerned that the least tern might be exposed to
chemicals through ingestion of the fish present in the large pond
located next to the RV park. However, information regarding the
least tern's foraging habits indicates that the pond is not likely
to provide a forage base for the least tern. This is because the
pond is located more than 100 meters from the nearest known least
tern colony, and that distance is beyond the usual foraging range
of the least tern. Furthermore, even if the least tern's foraging
range were to include the site area, the least tern's preference
for foraging on suitable fish species in large open bodies of water
such as the Mississippi River would preclude its use of the pond as
a viable forage base. Consequently, the least tern almost
certainly will not be exposed to contaminants associated with fish
in the pond.
VII. DESCRIPTION OF ALTERNATIVES
Oily Sludge Pit Area - Generic Response Actions
With the exception of the no action alternative, all of the
remedial alternatives that were evaluated contain common elements
that are described here rather than repeated for each alternative.
The alternatives discussed later in the ROD differ only in their
handling of the principal threat posed by the oily sludge and its
ancillary contaminated soil and debris.
Excavation
All of the treatment alternatives will require the excavation of an
estimated 22,000 cubic yards of sludge, contaminated soil and
debris from the pit area. This volumetric estimation is based on
existing sampling data indicating that the sludge and visibly
contaminated soil and debris encompass approximately 3.5 acres and
are present at depths of up to 18 feet below the existing surface
of the site.
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Water Treatment and Management
All of the treatment alternatives will require that contaminated
water be properly collected and disposed of during removal of the
pit contents. Sources of contaminated water will include water
contained within the waste matrices that may be released during
excavation activities, accumulated rainfall within the area of
remedial activities, and water used for decontamination of
personnel and equipment.
Rain water that falls within the berm surrounding the oily sludge
pit will have to be managed during the remedial action. The
average monthly precipitation in the West Memphis .area is
approximately 4.2 inches. Over the approximate area inside the
berm (3.5 acres), 4.2 inches of rain water will result in the
accumulation of approximately 400,000 gallons of water each month,
not accounting for infiltration or evaporation. In addition, an
estimated volume of 1,000 gallons/month of water produced from
miscellaneous operations (decontamination, blowdown, etc.) will
require management.
Disposal of the contaminated waters may be addressed by one or both
of two methods. The exact method or combination of the two methods
that will be used to handle and dispose of contaminated water will
be further refined in the remedial design. The two methods that
may be used to dispose of contaminated water are: (1) use
contaminated water in connection with implementation of the
remedial alternative; and/or (2) discharge water that has been
treated to meet applicable and relevant and appropriate
requirements to either a nearby stream or river and/or to a
publicly owned wastewater treatment plant (such as the one owned by
the City of West Memphis).
The technology options available for the remediation of sludges
involve the excavation and movement of the contaminated material,
and/or treatment of the contaminated material prior to final
disposition. Water may be required for dust control to minimize
the release of airborne contaminants during either movement or
pretreatment of these sludges and soils. EPA anticipates that
contaminated surface water will be utilized in the already
contaminated process area to the extent possible to knock down dust
particles before they migrate from the contaminated process area.
Extensive monitoring of the air will be conducted throughout the
process to ensure that contaminants in the water or in the sludge
will not pose a risk to nearby human and environmental receptors.
Water that cannot be incorporated into the treatment process will
be treated and discharged to a nearby stream and/or to publicly
owned wastewater treatment plant. Although discharge to a nearby
stream or river will not require a permit, the substantive
requirements of the Clean Water Act (CWA) and relevant state
requirements (Arkansas Water and Air Pollution Control Act) must
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still be met. Discharge to a POTW may require less stringent
treatment requirements at the site because the wastewater treatment
plant may provide some treatment of the water before it is
discharged. Furthermore, studies conducted during the remedial
design may determine that discharge of the contaminated water to a
publically owned wastewater treatment plant might be less expensive
and easier to implement than discharge from the site to nearby
streams and rivers.
Sludge Pretreatment
Pretreatment of the sludge material may be necessary prior to
implementation of the remedial alternative. The analytical data
available for the oily sludge pit indicate that the waste exhibits
the characteristic of a corrosive hazardous waste pursuant to 40
CFR Part 268.41. Additionally, the waste matrix is a thick,
viscous tar material that likely will adhere to the excavation and
transportation equipment, potentially reducing the efficiency of
the excavation operation.
Pretreatment would involve the addition of a material handling
agent, such as kiln dust or the nearby contaminated soils/sands, to
improve the handling characteristics of the sludge. Improved
handling characteristics will increase the effectiveness of the
excavation and hauling equipment and should reduce the amount of
time needed to decontaminate equipment. Therefore, the
alternatives described and evaluated below include this
pretreatment step as part of the alternative.
Debris Management and Disposal
All of the remedial alternatives address the contaminated debris
and non-contaminated debris present in and around the contaminated
soils in the pit area. Non-contaminated debris will be removed and
sent to a Resource Conservation and Recovery Act (RCRA) Subtitle D
landfill for disposal in order to comply with ARARs. Accordingly,
non-contaminated debris will be segregated, to the extent possible,
during the excavation of contaminated materials.
Debris that is either contaminated when excavated or becomes
contaminated as a result of the excavation processes will be
segregated from the contaminated soils and the non-contaminated
debris. Once the contaminated debris has been separated from the
contaminated soils, it will be transported to an area of the site
where it will be decontaminated. A potential technique that may be
used to separate the contaminated debris from the contaminated soil
involves the use of large diameter screens placed over a sump to
separate and collect contaminated residues removed from the
contaminated debris. High pressure steam may then be used to wash
the contaminated soils from the debris. Material removed from the
contaminated debris and small items of debris passing through the
screen will be treated in conjunction with the oily sludges in the
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pit. Although the separation and decontamination process is labor
intensive, it is considered more effective and efficient than
remediating large items of debris in conjunction with the
contaminated soils.
The actual separation technique will be addressed in the remedial
design. Design considerations will include the ability of the
selected remedial alternative to manage the contaminated debris,
the economics of decontaminating various sizes of contaminated
debris, and the effectiveness of decontamination methods.
Decontaminated debris will be disposed of in a RGRA Subtitle D
landfill.
Backfill
Since each of the alternatives involves excavation of the waste,
each alternative will require the placement of some type of fill
into the excavated area in order to stabilize the sides of the
excavation. The extent of the backfill will be determined in the
remedial design. EPA may not backfill all of the excavation in
order to create a small depression in the oily sludge pit area to
facilitate the creation of compensatory wetlands that will be
needed to effectuate EPA's preferred alternative for the landfill
areas (described in following sections of this ROD). Regardless.
of whether EPA backfills all or only a portion of the excavation,
a sufficient amount of clean imported fill will be placed to ensure
that vegetable crops cannot be grown in site surface soils
contaminated with site-related contaminants.
Oily Sludge Fit Area - Response Actions Evaluated
The following alternatives to address the oily sludge pit hot spot
contamination were evaluated in detail in the FS. Three additional
alternatives, containment/institutional controls, low temperature
thermal desorption and off-site disposal at an energy recovery
facility were screened out earlier in the evaluation process for
reasons described in detail in the FS.
ALTERNATIVE 1: NO ACTION
Total Cost (present worth): $0
Time of Implementation: 0 months
The NCP requires EPA to consider the No Action alternative. No
action assumes that no action would be taken to reduce the threat
to the public health and the environment posed by the oily sludge
pit. The remedial action objectives for the oily sludge pit area
would not be met.
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ALTERNATIVE 2: ON-SITE INCINERATION, STABILIZATION OF ASH, OFF-
SITE DISPOSAL OF ASH IN SUBTITLE D LANDFILL
Total Cost (present worth): $17,900,000
Time of Implementation: 18 months
Alternative 2 consists of pretreatment and excavation of the sludge
and contaminated soil and debris; decontamination and subsequent
disposal of the debris in a RCRA Subtitle D landfill; reduction of
the waste volume and destruction of organic contaminants in a
transportable on-site incinerator; stabilization of incineration
residues; off-site disposal of the stabilized residues to a
regulated RCRA Subtitle D landfill facility; and backfill of the
excavated area with clean imported fill. The remedial action
objectives for the oily sludge pit area would be met.
ALTERNATIVE 3: ON-SITE INCINERATION, OFF-SITE DISPOSAL OF ASH IN
SUBTITLE C LANDFILL
Total Cost (present worth): $22,800,000
Time of Implementation: 18 months
Alternative 3 consists of pretreatment and excavation of the sludge
and contaminated, soil and debris; decontamination and subsequent
disposal of the debris in a RCRA Subtitle D landfill; reduction of
the waste volume and destruction of organic contaminants in a
transportable on-site incinerator; off-site transportation and
disposal of incineration residues to a regulated RCRA Subtitle C
treatment, storage, and disposal facility; and backfill of the
excavated area with clean imported fill. This alternative is
similar to Alternative 2 with the exception that incineration
residues will be managed by the RCRA Subtitle C, treatment,
storage, and disposal facility. The remedial action objectives for
the oily sludge pit would be met.
ALTERNATIVE 4: STABILIZATION, OFF-SITE DISPOSAL AT SUBTITLE D
LANDFILL
Total Cost (present worth): $6,900,000
Time of Implementation: 10 months
Alternative 4, the alternative selected by this ROD, consists of
pretreatment and excavation of the sludge and contaminated soil and
debris; decontamination and subsequent disposal of the debris in a
RCRA Subtitle D landfill; stabilization of the waste to reduce the
mobility of the contaminants; disposal of the stabilized waste at
a regulated RCRA Subtitle D landfill facility; and backfilling the
excavated area with clean imported fill material. The remedial
action objectives for the oily sludge pit would be met.
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ALTERNATIVE 5: DISPOSAL OF WASTE AT SUBTITLE C TREATMENT, STORAGE,
DISPOSAL FACILITY
Total Cost (present worth): $12,800,000
Time of Implementation: 8 months
Alternative 5 consists of pretreatment and excavation of the sludge
and contaminated soil and debris; decontamination and disposal of
the debris in a RCRA Subtitle D landfill; disposal of the waste at
a RCRA Subtitle C treatment, storage, and disposal facility; and
backfilling the excavated area with clean imported fill material.
The RCRA Subtitle C facility likely would be required to treat the
waste further to comply with the land disposal restrictions. The
remedial action objectives for the oily sludge pit would be met.
ALTERNATIVE 6: OFF-SITE INCINERATION
Total Cost (present worth): $45,700,000
Time of Implementation: 8 months
Alternative 6 consists of pretreatment and excavation of the sludge
and contaminated soil and debris; decontamination and subsequent
disposal of the debris in a Subtitle D landfill; destruction of the
organic contaminants at an off-site commercial incineration
facility that also would be responsible for disposing of the ash in
accordance with EPA and state regulations; and backfill of the
excavated area with clean imported material. The remedial action
objectives for the oily sludge pit would be met.
ALTERNATIVE 7: ORGANIC CONTAMINANT TREATMENT, STABILIZATION OF
INORGANICS, OFF-SITE DISPOSAL AT SUBTITLE D LANDFILL
Total Cost (present worth): $14,800,00 to $18,100,000
Time of Implementation: 18 to 24 months
Alternative 7, the alternative that EPA identified as its preferred
alternative in the Proposed Plan, consists of excavation of the
sludge and contaminated soil and debris; decontamination and
subsequent disposal of the debris in a RCRA Subtitle D landfill;
separation, reduction of volume and/or treatment of the organic
contaminants; stabilization of treatment residuals and inorganic
contaminants; disposal of the stabilized residuals in a RCRA
Subtitle D landfill; and backfill of the excavated area with clean
imported fill material. The remedial action objectives for the
oily sludge pit would be met.
EPA identified three separation, volume reduction and treatment
techniques that could be employed to reduce the mobility, toxicity
and volume of the organic contaminants. These options are solvent
extraction, oil treatment, and slurry biodegradation. The Proposed
Plan contains an extensive discussion of the technical aspects of
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these three options.
Landfill Areas - Response Actions Evaluated
The following alternatives to address the landfill areas were
evaluated in detail. One additional alternative, a composite cap,
was screened out earlier in the evaluation process for reasons
described in detail in the FS.
ALTERNATIVE 1: NO ACTION
Total Cost (present worth) : $0
Time of Implementation: 0 months
The NCP requires EPA to consider the No Action alternative. No
action assumes that no action would be taken to reduce the threat
to the public health and the environment posed by the site. The
remedial action objectives for the landfill areas would not be met.
ALTERNATIVE 2: INSTITUTIONAL CONTROLS
Total Cost (present worth): $600,000
Time of Implementation: 12 months
Alternative 2 utilizes institutional controls designed to restrict
public access to the site. Institutional controls consist of
maintaining the existing site perimeter fencing and warning signs,
the imposition of deed notices, regular maintenance and five (5)
year reviews. Although EPA has deferred its decision regarding the
selection of remedial action for the groundwater until a later
date, this alternative does include groundwater monitoring, in
addition to 5-year reviews, to ensure that any contaminants left in
the landfill that may migrate into the groundwater do not present
a threat to the public health and the environment at a future date.
.The remedial action objectives for the landfill areas would be met.
ALTERNATIVE 3: NATURAL SOIL COVER IN CONJUNCTION WITH
INSTITUTIONAL CONTROLS
Total Cost (present worth): $2,260,000
Time of Implementation: 24 months
Alternative 3, the alternative chosen in this ROD and identified as
EPA's preferred alternative in the Proposed Plan, consists of
containment (primarily a native soil cover designed and constructed
in accordance with the Arkansas Solid Waste Management Code), the
creation of a compensatory wetlands, and institutional controls.
The remedial action objectives for the landfill areas would be met.
The cover material would be a native soil capable of supporting
vegetative growth. The native soil will likely be porous (sand or
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silty sand) to allow natural diffusion of landfill gas (LFG), such
as methane, throughout the entire surface area of the cap, thereby
controlling any buildup of explosive gases within the landfill. A
more extensive LFG collection system is not anticipated to be
necessary because the levels of LFG that were identified in the RI
were not high enough to present a risk to the public health and the
environment so long as it is not allowed to build up under a semi-
impermeable barrier.
However, additional review of the data or further studies conducted
during the remedial design may determine that a more extensive LFG
is prudent. A more extensive LFG collection and treatment system
will be added to this alternative if EPA determines that a more
extensive LFG system is required to protect the public health and
the environment.
Installation of a soil cap may consist of clearing and grubbing
existing vegetation, performing initial site grading, and
installing a biotic barrier consisting of a geotextile or cobbles
to prevent root uptake. At least two feet of native soil will then
be placed on top of the existing landfill areas and remediated oily
sludge pit area, and vegetative growth will be established on the
final topsoil layer. The native soil cap must be porous to allow
LFG diffusion and graded to divert surface water runoff away from
the fill areas and toward a series of surface ditches leading to
nearby drainage areas. The vegetation selected for the cover must
be self-sustaining and suited to the climatic conditions of the
site.
The final cover must also be designed to minimize erosion from
flooding and drainage. An established vegetative cover combined
with regular maintenance will provide the primary method of erosion
control. Additional design features may also include synthetic
erosion control netting for slopes arid cap ditches, silt fences and
riprap spillways. Erosion control details will be addressed in the
remedial design. The institutional controls outlined in
Alternative 2, with the exception of fencing, would also be an
integral part of this alternative.
The compensatory wetlands would likely be created by obtaining the
cover material from the flood plain near the site. Once the cover
material was excavated from the floodplain, the area could be
planted with appropriate vegetation, stocked with appropriate
biota, and engineered to provide the requirements necessary to turn
the borrow area into a wetlands area.
VIII. COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA is required to use certain criteria to evaluate alternatives
for addressing a Superfund site. These nine criteria are
categorized into three groups: threshold, primary balancing, and
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modifying. The threshold criteria must be met in order for an
alternative to be eligible for selection. The primary balancing
criteria are used to weigh major tradeoffs among alternatives. The
modifying criteria are taken into account after state and public
comment is received on EPA7s preferred alternative as identified
and described in the Proposed Plan of Action.
NINE CRITERIA
The nine criteria used in evaluating all of the alternatives are as
follows:
Threshold Criteria
• Overall Protection of Human Health and the Environment
addresses the way that an alternative would reduce, eliminate,
or control the risks posed by the site to human health and the
environment. Total elimination of risk is often impossible to
achieve. However, a remedy must minimize risks to assure that
human health and the environment are protected.
• Compliance with ARARs. or "applicable or relevant and
appropriate requirements," assures that an alternative will
meet all related federal, state, and local requirements.
Primary Balancing Criteria
• Long-term Effectiveness and Permanence addresses the ability
of an alternative to reliably provide long-term protection for
human health and the environment after the remediation goals
have been accomplished.
• Reduction of Toxicity. Mobility, or Volume of Contaminants
through Treatment assesses how effectively an alternative will
address the contamination on a site. Factors considered
include the nature of the treatment process; the amount of
hazardous materials that will be destroyed by the treatment
process; how effectively the process reduces the toxicity,
mobility, or volume of waste; and the type and quantity of
contamination that will remain after treatment.
• Short-term Effectiveness addresses the time it takes for
remedy implementation. Remedies often require several years
for implementation. A potential remedy is evaluated for the
length of time required for implementation and the potential
impact on human health and the environment during
implementation.
• Implementabilitv addresses the ease with which an alternative
can be accomplished. Factors such as availability of
materials and services and other obstacles are considered.
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• Cost (including capital costs and projected long-term
operation and maintenance costs) is considered and compared to
the benefit that will result from implementing the
alternative.
Modifying Criteria
• State Acceptance addresses whether the State agrees with,
opposes, or has no comment on the proposed remedy.
• Community Acceptance addresses comments and concerns raised by
the community and other members of the public during the
public comment period for the Proposed Plan and Administrative
Record. EPA considers these comments in making its final
remedy selection. The comments are addressed in the
responsiveness summary that is part of this ROD.
Oily Sludge Pit Area
Overall Protection of Human Health and the Environment
Alternative 4 will eliminate the threat to public health and the
environment from direct contact with the corrosive waste and
contaminated soils and debris and will eliminate the potential for
future off-site migration of contaminants via other pathways such
as migration to the ground and surface water. The inorganic
contaminants will be immobilized, and the remaining contaminants
will be disposed of in a regulated landfill.
Each of the alternatives, with the exception of no action,
effectively reduces the threat to public health and the environment
at the site through the removal of the waste or treatment residuals
to an off-site, regulated landfill. Alternatives 2, 3 and 7
require the treated residuals from the incineration or organic
treatment process to be disposed of in either a regulated RCRA
Subtitle D or Subtitle C offsite landfill. Alternatives 5 requires
the waste to be disposed of in a RCRA Subtitle C landfill.
Alternative 6 requires the waste to be incinerated at an offsite
facility that will ultimately be responsible for disposing of the
treated residuals in a regulated offsite landfill.
Because the no action alternative is not protective of the public
health and the environment, it will not be considered further in
the evaluation process.
Compliance with ARARs
Alternative 4, as well as the other alternatives, will comply with
the ARARs identified in the FS. Because the sludge in the oily
sludge pit is meets the definition of hazardous waste due to its
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low pH and high leachable lead content, the selected alternative
must achieve the relevant requirements of RCRA. The site's
location in a flood plain necessitates an evaluation of each
alternative's ability to comply with the requirements relevant to
implementation of response actions in a floodplain such as
40 CFR § 6, Appendix A, and 40 CFR §§ 230 and 231. The likelihood
that contaminated water will be produced as a result of the
remediation process means that each of the alternatives must adhere
to the requirements of the CWA and the Arkansas Water and Air
Pollution Control Act.
Each of the alternatives is expected to comply with the relevant
ARARs via the use of engineered controls and equipment. A detailed
discussion regarding how Alternative 4 will comply with ARARs is
provided in the following section of this ROD entitled "Selected
Remedy."
Long-term Effectiveness and Permanence
Alternative 4 achieves long-term effectiveness through the
treatment of the corrosive pit wastes, the stabilization and off-
site disposal of the inorganic contaminants, and the stabilization
and off-site disposal of organic contaminants in a regulated
Subtitle D landfill. Alternative 2 is both effective over the
long-term and permanent because the .organic contaminants will be
permanently destroyed via the combustion process, and the inorganic
contaminants will be stabilized and disposed of offsite in a
regulated Subtitle D landfill. Alternative 3 is both effective
over the long-term and permanent because the organic contaminants
will be permanently destroyed via the combustion process, and the
inorganic contaminants will be secured offsite in a regulated
Subtitle C hazardous waste landfill. Alternative 5 is effective
over the long-term because the waste will be disposed of off-site
in a regulated Subtitle c hazardous waste landfill, but it is not
permanent because the organic contaminants will be neither
destroyed nor immobilized. Alternative 6 is both effective over
the long-term and permanent because the waste will be incinerated
and disposed of offsite in accordance with all relevant
environmental laws and regulations. Alternative 7 is both
effective over the long-term and permanent because the organic
contaminants will be destroyed and the inorganic contaminants will
be immobilized and disposed of offsite in a regulated Subtitle D
landfill.
While the alternatives considered in the FS all would achieve long-
term effectiveness; they differ with respect to permanence.
Alternative 4 achieves permanence with respect to the corrosivity
of the oily sludge pit waste through treatment to render the waste
non-corrosive. However, there is some uncertainty as to
Alternative 4's permanence with respect to the remaining organic
waste. This is because the nature of the remaining site organic
waste (i.e., the waste matrix and the percentage of organics
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contained in the waste) raises some question as to whether
stabilization will effectively immobilize the organics.
Although the nature of the waste is such that there is no absolute
certainty that stabilization will effectively immobilize the
organics, there is still the possibility that stabilization
potentially could immobilize the organics at the site at a
significant cost savings over EPA's original preferred alternative
as identified in the Proposed Plan, which called for use of a
destruction technology such as incineration to deal with the
organic wastes at the site. Despite the uncertainties associated
with the stabilization process, the community and the State
supported this alternative based primarily upon that cost savings.
Finally, the selected remedy is further protective of human health
and the environment because the stabilized waste will be disposed
of in a properly constructed and operated regulated Subtitle D
landfill where the risks associated with the waste can be more
appropriately managed. Placement of the stabilized waste into a
Subtitle D landfill will reduce the risk posed by the waste to the
public health and environment by limiting exposure pathways and
subjecting the stabilized waste to greater controls and monitoring
than if the waste were left at the site. For example, the
likelihood that the waste will be reexcavated in the future
(thereby resulting in direct exposure to landfill workers and site
visitors and trespassers) is substantially reduced by virtue of
regulations governing Subtitle D landfills. Moreover, the landfill
itself will be an engineered and carefully controlled disposal
location designed to retard and monitor the potential migration of
contaminants, as opposed to the site, where conditions are highly
uncontrolled and conducive to contaminant migration by virtue of
the site topography, hydrology, geology, and the site's close
location to the Mississippi River.
Reduction of Mobility, Toxicity, or Volume (MTV) Through
Treatment
Alternative 4 will reduce the toxicity of the waste through
treatment by elevating the pH of the waste to levels that will no
longer be corrosive and will immobilize the inorganic contaminants
via the stabilization process. Likewise, Alternatives 2, 3, 6, and
7 reduce the toxicity of the waste by elevating the pH and reduce
the mobility of the waste by stabilizing the inorganic
contaminants. Alternative 5 will reduce the toxicity of the waste
through treatment by making the waste noncorrosive, but it will not
treat either the inorganic or organic contaminants.
Alternatives 2, 3, and 6 also reduce the toxicity, mobility, and
volume of the waste by permanently destroying the toxic organic
contaminants via the incineration process. Alternative 7 results
in the permanent destruction of the organics through biodegradation
or by separating the organics from the remainder of the waste and
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then sending it offsite for permanent destruction in an incinerator
or energy recovery facility.
As discussed earlier, if, upon completion of the excavation and
stabilization of the oily sludge pit waste and associated
contaminated soil and debris, the stabilized waste meets the
performance criteria for stabilization specified in this ROD, then
immobilization of the organic contaminants through treatment will
have occurred. However, it must be noted that there is some
uncertainty as to whether stabilization of these particular site
wastes will effectively immobilize the organic contaminants. This
is because the nature of the remaining site organic waste (i.e.,
the waste matrix and the percentage of organics contained in the
waste) raises some question as to whether stabilization will
effectively immobilize the organics. Section IX of this ROD
(Selected Remedy) discusses factors contributing to EPA's decision
to utilize stabilization as the principal form of treatment at the
site.
In summary, Alternatives 2, 3, 6, and 7 more effectively reduce MTV
than Alternatives 4 and 5. Alternatives that employ treatment to
permanently reduce the risk associated with both the organic and
inorganic contaminants achieve greater reduction of MTV than
alternatives that treat organic or inorganic contaminants only.
Alternatives that treat the organic contaminants, but not the
inorganic contaminants, achieve greater MTV reduction than
alternatives that treat inorganic contaminants only since the
primary risk at the site is associated with the organic
contaminants. Alternatives that do not employ treatment do not
meet this criterion.
Short-term Effectiveness
Most of the short-term risks to the community and site workers that
are associated with Alternative 4 and the other alternatives, with
the exception of the no action alternative, are the result of air
emissions generated during the excavation, handling, and
pretreatment of the raw waste. However, there are some additional
alternative-specific short-term risks.
Risks associated with upsets to an on-site incinerator are greater
than the risks posed by treatment processes that do not employ
incineration technology. These types of risks can be monitored and
controlled through the use of site-specific air monitoring and
action plans. Risks associated with transportation related
accidents are greater for those alternatives that do not treat the
waste prior to off-site disposal than those alternatives that do
include treatment of the waste on-site prior to off-site disposal.
Overall, the short-term risk to the community and site workers is
equal for all of the alternatives because the risk assumed for on-
site incineration or other process upsets and additional material
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handling steps is comparable to the risk associated with the
transportation of untreated waste.
Alternatives 2, 3, 4, and 7 have more potential for adverse
environmental impacts than Alternatives 5 and 6. Since
Alternatives 5 and 6 do not include any active onsite treatment,
these alternatives will require fewer material handling steps and
may be completed in less time than the other alternatives. Most of
the potential environmental impacts can be attributed to flood
events that may occur during implementation of the remedial action,
thereby spreading the contamination to the river and the
surrounding areas. Alternatives that require less time to
implement, therefore, are less likely to result in an adverse
impact to the environment.
Implementability
The technical feasibility of Alternative 4 is considered to be
excellent. The equipment and personnel associated with the
pretreatment, excavation, transportation, and stabilization
components of the alternative are readily available in the
hazardous waste remediation and construction industries.
Regulated RCRA Subtitle D landfill space is generally available
through private and/or local solid waste disposal facilities. The
technical feasibility of Alternatives 2, 3, 5, and 6 is also quite
good. The technical feasibility of implementing Alternative 7,
although good, is less than the other alternatives because it
requires the use of innovative technologies.
The administrative feasibility of constructing and operating either
the stabilization technology or the other on-site treatment
technologies on the river side of the levee for Alternatives 2, 3,
4, and 7 may be difficult. Remedial action contractors may charge
higher fees to construct flood protection devices or to cover any
potential losses they might incur as a result of flood events.
Additionally, it might be necessary for EPA to seek access to
property on the land side of the St. Francis levee to aid in
implementing the remedial action. For example, the
treatment/verification process may be too lengthy to be
accomplished during the dry period, and the treatment component of
the remedy may have to implemented on the land side of the levee in
order to minimize adverse environmental impacts. Alternatives 2,
3, and 7 face similar administrative obstacles.
Alternatives 5 and 6 do not face significant administrative
obstacles because these alternatives will not require space on the
land side of the levee to be implemented. The waste will only have
to be pretreated as it is being excavated and then shipped to the
offsite disposal facility.
In summary, Alternatives 2, 3, 4, and 7 are considered to be less
implementable than Alternatives 5 and 6 because of administrative
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feasibility issues. The alternatives that involve only excavation
and transportation to some off-site treatment or disposal facility
are more implementable than alternatives that employ some type of
on-site treatment as long as disposal facilities will take the
untreated waste.
Cost
This criterion compares the capital costs of implementing the
alternatives to address the oily sludge pit area. The alternatives
for the oily sludge pit area do not require any long-term operation
and maintenance. Alternative 6 is the most costly, followed by
Alternatives 3, 7, 2, 5 and 4, in that order. The costs are
compared in the table below.
TABLE 2O
• COST COMPARISON-rOILY SLUDGE PIT
ALTERNATIVE
1 - No Action
2 - On-site Incineration,
Stabilization, Disposal in Subtitle
D Landfill
3 - On-site Incineration,
Stabilization, Disposal in Subtitle
C Landfill
4 - Stabilization, Disposal in
Subtitle D Landfill
5 - Disposal in Sub/title C Landfill
6 - Off-site Incineration
7 - Organic Treatment,
Stabilization, Disposal in Subtitle
D Landfill
COST ($)
0
17,900,000
22,800,000
6,900,000
12,800,000
45,700,000
14,800,000 -
18,100,000
Landfill Areas
Overall Protection of Human Health and the Environment
Alternative 1 (no action) does not achieve the remedial action
objectives and does not provide protection to human health and the
environment-. The no action alternative does not prevent direct
contact with and ingestion of landfill contents present on the
surface of the site.
Alternative 2 provides limited protection by keeping humans away
from the landfill, thereby greatly reducing the risk of direct
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63
contact, but it does not prevent trespassers and wildlife from
coining into contact with the landfill contents. In addition, the
off-site migration of contaminated surface soils via the air
pathway (dust) is not addressed.
Alternative 3 provides overall protection of human health and the
environment by preventing direct contact with landfill contents,
eliminating air/dust emissions, and providing for landfill gas
diffusion through the porous native soil cover into the atmosphere
(the diffusion prevents an explosive buildup of the gas). In
addition, institutional controls will limit traffic at the site,
thereby reducing the risk of direct contact should the soil cover
ever be breached at some point in the future.
Compliance with ARARs
Alternative 2 does not achieve ARARs. The Arkansas Solid Waste
Management Code states in Section XVIII that "Existing open dumps
and other unpermitted disposal facilities shall be required to meet
the same closure criteria as set out in this Code for permitted
facilities." The site and the landfill areas on the site
constitute an unpermitted disposal facility in accordance with
Section II.F of the Code. The site does not currently comply with
the requirements of Section XII.6.e of the Code, which states "A
compacted layer of at least two (2) feet of material capable of
supporting vegetation...shall be placed over the entire surface of
all completed portions of the landfill."
Alternative 3 complies with the Arkansas Solid Waste Management
Code because it provides for a native soil cover capable of
supporting vegetation over the entire surface of the landfill.
However, care must be taken during the implementation of
Alternative 3 because the site is located in a flood plain, and
certain portions of the site are wetlands. As result, the site
remedy must comply with 40 CFR § 6, Appendix A, and 40 CFR §§ 230
and 231. Alternative 3 will comply with these location specific
ARARs by creating a compensatory wetlands during the implementation
of the remedial action. In addition, Alternative 3 will have to be
designed to ensure that the stormwater runoff from the covered
landfill will meet the requirements of the Clean Water Act upon
discharge to the Mississippi River.
The new requirements for solid waste landfills (40 CFR § 258)
issued by EPA in 1991 are not applicable to this response action
because disposal at the site ceased prior to October 6, 1991,
(56 Fed. Reg. 51,001 (1991)). Since the design and operating
requirements specified in the regulation pertain to new landfills
or lateral expansions of existing landfills, they are not relevant
and appropriate for this response action since none of the
alternatives involve construction of a new landfill on the site.
The siting requirements of the regulation are not relevant and
appropriate to the response action because the landfill is already
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closed. The closure requirements are not relevant and appropriate
because the construction of an impermeable clay layer is
nonsensical when the groundwater table is close to the surface and
the site is routinely flooded.
All of the alternatives must comply with the relevant and
appropriate post-closure monitoring requirements of the regulation.
These requirements include maintaining the effectiveness and
integrity of the final cover and groundwater monitoring. Leachate
management is not necessary because the landfill areas do not
include a leachate collection system. Gas monitoring will not be
necessary because the final cover will be designed to facilitate
the permeation of landfill gas through the cover material.
Long-term Effectiveness and Permanence
Alternatives 1 and 2 provide little or no long-term effectiveness.
Alternative 3 provides the best long-term effectiveness and
permanence possible because the installation of the native soil
cover with vegetative growth will eliminate direct contact with the
landfill and its contents, control air/dust emissions, control LFG
emissions, prevent root uptake, and minimize erosion and surface
soil migration from flood events. Any remedy short of excavation
and offsite disposal of all waste at the site can never be
completely permanent and effective over the long-term because the
site is subject to flooding and erosion by the Mississippi River.
Excavation and offsite disposal of all waste at the site is not
considered practicable for landfills (OSWER Directive 9355.3-11,
"Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites," p. 4-12) and is not specified by EPA's
presumptive remedy guidance for landfills (OSWER Directive 9355.0-
49FS, "Presumptive Remedy for CERCLA Municipal Landfill Sites").
In addition, groundwater monitoring will ensure that any future
migration of contaminants from the site will be detected so that
appropriate response actions can be implemented.
Arkansas Solid Waste Regulations (ADPCE, 1984) require maintenance
of the final cap for the first two years following completion.
After that period, regular maintenance must be performed to
continue meeting the remedial action objectives for the site.
Regular maintenance is necessary to ensure the effectiveness of the
remedy because erosion of the cap caused by flooding could expose
the landfill contents.
Reduction of Mobility/ Toxicity or Volume Through Treatment
None of the alternatives will provide reduction in mobility,
toxicity, or volume of the landfill waste through treatment.
However, Alternative 3 will immobilize the dust emissions
associated with solid waste materials and hazardous substances that
may be present on the surface of the site.
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Short-term Effectiveness
Over the short-term, implementation of Alternatives 1 and 2 would
not significantly affect the levels of risk to the community or
site workers. Implementation of Alternative 3 may take up to two
years to design and construct. Construction of a native soil cover
may increase emissions, especially dust, during site grading,
material handling and placement. The greatest exposure to the site
media .during implementation of Alternative 3 would be to site
workers. The risk to site workers will primarily result from
exposure to hazardous air and/or dust emissions that may be created
when the site is disturbed by heavy remediation equipment, and the
release of LFG from the solid waste mass. Short term risk will be
mitigated by using an approved Health and Safety Plan (HSP) and
contingency plan during remedial construction. The HSP will
specify various procedures and safety equipment that the
remediation workers must use to conduct the work safely. The HSP
will also include plans to detect and address any release of
pollutants from the site during the work.
Implementability
Alternatives 1 and 2 are the most implementable. Alternative 1
does not require any construction activity, and Alternative 2
requires only minor construction, limited mostly to existing fence
repair. Deed notices should also be fairly easy to implement.
Alternative 3, while slightly more difficult to implement than
Alternatives 1 and 2, does not require any highly specialized
equipment or services. Construction of the native soil cap can be
accomplished by following standard engineering design and
construction techniques.
Cost
This criterion compares the capital, O&M, and present worth costs
of implementing the alternatives to address the landfill area.
Alternative 3 is the most costly, followed by Alternatives 2 and 1
in that order. The costs are compared in the chart below.
1 TABLE 21
COST COMPARISON-LANDFILL AREA
ALTERNATIVE
1 - No Action
2 - Institutional
Controls
3 - Natural Soil
Cover
CAPITAL
.COST <$)
0
50,000
1,780,000
ANNUAL O&M
COST <$)
0
550,000
480,000
PRESENT NET
WORTH ($)
0
600,000
2,260,000
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IX. SELECTED REMEDY
Based on consideration of the requirements of CERCLA, the
comparative analysis of alternatives, and public comments, the EPA
has determined that Alternative 4 (excavation, on-site
stabilization, and off-site disposal at a Subtitle D landfill) will
best provide a remedy that is protective of human health and the
environment for the oily sludge pit area. Similarly, EPA has
determined that Alternative 3 (natural soil cover and institutional
controls) will best provide a remedy that is protective of human
health and the environment for the landfill areas.
The remedy selected by EPA for the site is consistent with the
presumptive remedy for landfills guidance (OSWER Directive 9355.0-
49FS). The presumptive remedy for municipal landfills is
containment. Containment components suggested for municipal
landfills in the directive include: (1) landfill cap; (2) source
area groundwater control; (3) leachate collection and treatment;
(4) landfill gas collection and treatment; and/or (5) institutional
controls to supplement engineering controls. The remedy selected
in this ROD includes a landfill cap and institutional controls.
Landfill gas is not currently recognized as a threat at the site.
Issues regarding contaminated groundwater and leachate will be
addressed in a separate ROD.
As discussed in Section IV of this ROD, the specific remedial
objectives determined to be necessary at the site are:
Oily Sludge Pit Area
1. Prevent current and future direct contact with the highly
corrosive wastes.
2. Prevent current and future direct contact, ingestion, and
inhalation of _ contaminants in the pit waste and ancillary
contaminated soil and debris.
3. Prevent the future migration of contaminants from the sludge
pit area to other areas both on and off the site.
4. Prevent the potential for future migration of contaminants to
the groundwater at concentrations above appropriate action levels.
The selected remedy for the oily sludge pit area will meet the
relevant objectives by:
- Treating all the sludges and ancillary contaminated soil at the
site by neutralizing it in either the pre-treatment or
stabilization process and subsequently disposing of the treated
residuals at an off-site regulated Subtitle D landfill.
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- Treating and/or removing the contaminants in the sludge and its
ancillary contaminated soil and debris by stabilizing the inorganic
contaminants, disposing of both the organic and inorganic
contaminants that are present in the waste at concentrations below
those which define a waste as hazardous in an off-site regulated
Subtitle D landfill, and backfilling the excavations with clean
soil.
- Removing the contaminants from the flood plain where they are
currently located to a regulated Subtitle D landfill and
backfilling the excavation with clean soil, thereby precluding the
further spread of contaminants from the site through migration
caused by site flooding and other events.
- Treating and/or removing all contaminants present in the sludge
and its ancillary soil and debris above the Remediation Goals (RGs)
and disposing of the treated residuals in a regulated Subtitle D
landfill.
Remediation Goals (RGs) for the oily sludge pit were established to
ensure that the above remedial objectives for the oily sludge pit
area will.be met upon completion of the remedial action. The RGs
are based on the recreational risk scenario developed in the
baseline risk assessment. A more detailed discussion of the
baseline risk assessment can be found in Section VI. of this ROD.
The recreational worker (i.e., site caretaker) scenario was used to
assess site risk because EPA believes that scenario represents the
most plausible reasonable maximum exposure scenario at the site.
Other site risk scenarios, including the crop consumer and
recreational visitor, were not used because these scenarios were
too uncertain or did not best represent a reasonable maximum
exposure. After performing the risk calculations and developing
the risk based RGs for the primary contaminants of concern (PAHs,
PCBs, and TCDD) in accordance with OSWER Directive 9285.7-018,
"Risk Assessment Guidance for Superfund, Volume 1 - Human Health
Evaluation Manual, Part B, Development of Risk Based Remediation
Goals," EPA discovered that the RGs were much lower than the
cleanup concentrations typically selected for similar contaminants
at other sites.
In fact, the concentrations were so small that the analytical
detection limit would actually control the degree of cleanup
because it is not possible to measure such small concentrations of
contaminants in soil. Also, EPA noted that the methodology
specified in the guidance for determining cleanup levels does not
allow for consideration of the fact that the pit area will be
backfilled with clean soil as part of every clean up alternative
considered.
If the oily sludge pit were re-excavated in the future to construct
a fishing pond or some other recreational feature, the soils
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located in the bottom of the pit would be mixed with clean backfill
material present in the upper area of the pit, resulting in the
reduction of the concentration of contaminants in the pit bottom
soils such that the total concentration of contaminants in the
mixed material excavated and deposited on the surface of the site
would be significantly less than the concentrations found in the
bottom of the pit. EPA developed RGs at the site that are based on
risk in accordance with existing EPA guidance, and also took into
account the reduction in contaminant concentration that inevitably
will occur due to the mixing of material located at the bottom of
the pit with clean backfill at the top of the pit in the event the
pit is re-excavated at some future time. A more detailed
discussion pertaining to the development of the RGs for the site
may be found in Appendix B of this ROD.
An RG was established for lead because the concentrations of lead
in the oily sludge pit area are greater than concentrations that
are considered to be protective of public health and the
environment. The 500 mg/kg RG established for lead was developed
by setting the UBK Lead Exposure Model (Version 5.0) to its default
values. The default values assume a residential exposure scenario.
This practice is appropriate at the site because the future
recreational use planned for the site includes the exposure of
children to lead. Risk-based RGs for lead cannot be established
because a .published slope factor or reference concentration for
lead is unavailable.
The RGs for the oily sludge pit area are specified in Table 22
below:
TABLE 22
REMEDIATION GOALS
TABLE 22
CONTAMINANT
PAH as
Benzo(a)Pyrene
Equivalents
PCB (Total)
Pb
RG ;
(MG/KG)
3
10
500
Treatment goals for the sludge and ancillary contaminated soil and
debris are identified in the following section, entitled "Statutory
Determinations." The treatment goals identified for the remedy are
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based on ARARs and "To Be Considered" information relevant to the
implementation of stabilization remedies.
Since all the contaminated sludge and its ancillary contaminated
soil and debris will be excavated, treated and disposed of in an
off-site Subtitle D landfill, the remedy is protective of the
public health and the environment and complies with all ARARs.
There are expected to be no unmanageable short-term risks
associated with this remedy. Although the selected remedy is not
as permanent as many of the other remedies evaluated in the FS, it
utilizes permanent solutions and alternative treatment technologies
to the maximum extent practicable at this particular site. The
remedy is cost effective. The State has stated that it will accept
this remedy, and this remedy is most like the remedy preferred by
the public. Therefore, the -selected remedy provides the best
balance among alternatives with respect to the criteria used to
evaluate remedies.
The criterion that ultimately weighed most heavily and contributed
most to the selection of the alternative for the oily sludge pit
over the other evaluated alternatives was State and community
acceptance. The remedy .selected in this ROD is as protective of
human health and the environment as the preferred alternative
identified in EPA's Proposed Plan. The main differences between
the two alternatives are 1) the remedy selected in this ROD is less
permanent than, but equally as protective as, the preferred
alternative identified in the Proposed Plan, and 2) the remedy
selected in this ROD is significantly less expensive than the
preferred alternative identified in the Proposed Plan.
The State and members of the community were adamant in their
opposition to EPA's preferred alternative as identified in the
Proposed Plan. Their opposition was based on the belief that the
preferred alternative was too expensive, while other less expensive
and less permanent alternatives also would achieve protection of
human health and the environment. The State and community have
maintained their opposition to the preferred alternative despite
EPA's explanation that its original basis for selecting the
preferred alternative was grounded in EPA's desire to select a more
permanent remedy.
The State and community have spoken and made clear their desire for
a less expensive, less permanent, but equally protective remedy.
The selected remedy is as protective as the originally identified
preferred alternative. Accordingly, EPA has determined that it is
appropriate in this instance to give deference to the State and
community desire for a less expensive, albeit less permanent,
remedy.
Landfill Areas
1. Prevent direct contact with and ingestion of ,the landfill
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contents.
2. Ensure that contaminants present in the landfill areas that may
migrate into the groundwater will not constitute a threat to public
health and the environment.
The selected remedy for the landfill area will meet the objectives
by:
- Covering the landfill areas with a natural soil cover to prevent
humans and animals from contacting or ingesting exposed waste
materials.
- Placing notifications in the property deeds to alert potential
future owners that hazardous substances are present at the site and
explaining actions taken to address contamination at the site.
- Long-term groundwater monitoring to detect and evaluate any
threat posed by migration of contaminants at the site.
RGs were not developed for the landfill areas because the risk
assessment shows the landfill areas to be a low-level threat that
will not require active remediation in order to be protective if
the above remedial action objectives are met.
No treatment goals have been established for the landfill area of
the site because treatment of the landfill contents is not a
component of the selected remedy for the landfill areas. Any
necessary groundwater action levels will be established in the ROD
for the groundwater operable unit, not this source control operable
unit.
X. STATUTORY DETERMINATIONS
This section describes how stabilization and off-site disposal of
the oily sludge pit wastes in a Subtitle D landfill, and
installation of a natural soil cover over the landfill areas, along
with implementation of institutional controls and long-term
groundwater monitoring, will meet the statutory requirements of
CERCLA Section 121.
• Be protective of human health and the environment
The remedy is prote9tive of human health and the environment. The
remedial action objectives and goals specified for the site in
section IV of this ROD will be met.
The remedy for the oily sludge pit area is protective of the public
health and the environment because:
I. The soils underlying the excavated material will not present
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a risk from the direct contact, ingestion, or inhalation of any
contaminants remaining in such soils;
2. If the visible waste and soils with contaminant concentrations
greater than the RGs are excavated and treated in accordance with
ARARs and the criteria specified in this ROD, then the threat due
to the corrosivity of the waste will be removed;
3. Based on contaminant transport modeling performed during the
RI/FS, the low concentrations of any contaminants remaining in the
soils after excavation and treatment of the oily sludge pit waste
and associated contaminated soil and debris should not present a
threat to groundwater from leaching; and
4. Based on the analysis of the cleanup criteria contained in
Appendix B to this ROD, concentrations of contaminants in the
remaining soils after excavation and treatment of the oily sludge
pit waste and associated contaminated soil and debris should not
present a threat to public health or the environment if they
migrate offsite.
The selected remedy for the landfill portion of the site is
protective of the public health and the environment because the
natural soil cover will prevent direct contact and ingestion of the
landfill contents. The institutional controls will inform
potential future owners that the site contains hazardous
substances, and the groundwater monitoring will alert EPA to any
future contaminant migration from the landfill. Thus, the remedial
action objectives for the landfill area are met by the selected
remedy.
• Comply with ARARs
The selected remedy will comply with all ARARs identified for the
site. The ARARs that have been identified can be classified as
chemical-specific, location-specific and action specific. The
specific reguirements applicable or relevant and appropriate to the
selected remedy are discussed below. Additionally, although the
selected remedy must comply with all substantive reguirements of
federal and state environmental statutes, on-site activities will
not have to comply with the administrative requirements of these
laws.
CHEMICAL-SPECIFIC ARARS
Clean Water Act - If water is generated and discharged on-site
during the course of the remedial action, it will have to meet
the substantive requirements of the Clean Water Act and the
applicable standards for discharges to waters of the State of
Arkansas as specified by ADPCE. The wastewater discharge limits
specified by ADPCE are set forth in Table 23.
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TABLE 23
WASTEWATER DISCHARGE LIMITS
TABLE 23
Parameter
Temperature
Turbidity
pH
Phosphorus, Total
Oil and Grease
Chlorides
Sulfates
Total Dissolved Solids
Arsenic
Beryllium
Cadmium
Cyanide
Lead
Mercury
Nickel
Silver
Thallium
Chlordane
PCB's
DDT
TCDD
ADPCE Discharge Standard
; ug/1
(Unless Specified Otherwise)
:-•*-.
32° Celcius
50 NTU
6-9 s.u.
100 ug/1
10 mg/1 monthly avg.
15 mg/1 daily max.
60 mg/1
175 mg/1
450 mg/1
1.75
0.076
1.66
5.2
5.9
0.012
100
0.12
40
0.0043
0.014
0.001
l.Oe-6
Consistent with CERCLA § 121(d)(2)(A) & (B) , EPA has determined
that EPA's Water Quality Criteria developed in accordance with
the CWA § 304 are relevant and appropriate to the remedial
action at the site. EPA considered the potential uses of the
surface water near the site, the environmental media affected
and the purposes of the criteria. The State of Arkansas has
identified several potential uses for the Mississippi River near
the area of the site, including primary contact recreation,
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secondary contact recreation, domestic and industrial water
supply and as a perennial delta fishery. Thus, since both
humans and aquatic life may potentially use the surface water
near the site, EPA has determined that the criteria that apply
to both human health and the protection of aquatic life are
relevant and appropriate to the remedial action at the site.
The remedial action will comply with this ARAR through treatment
of any wastewater before it is discharged from the site to the
Mississippi River.
LOCATION-SPECIFIC ARARs
40 CFR S 6. Appendix A - The remedial action must minimize the
potential for harm to the wetlands and restore and preserve
natural and beneficial values of the floodplain. This
requirement is applicable to the remedial action because the
site is located in the two-year floodplain of the Mississippi
River. The remedial action will restore and preserve the
natural and beneficial uses of the floodplain by eliminating the
severe threat to the environment associated with the corrosive
oily sludge pit and by restoring the area to its natural
condition through the introduction of native grasses and soils.
40 CFR S 230 and 231 - The discharge of fill material into a
wetland without a permit is prohibited. The substantive
requirements of this regulation are applicable to the remedial
action because portions of the site are wetland areas.
Generally, a permit for discharging fill material into a wetland
will only be granted where the permittee agrees to either create
compensatory wetlands or take other appropriate abatement
action. The remedial action will comply with this ARAR through
the creation of compensatory wetlands during the excavation of
the natural soil material that will be used to construct the
soil cover.
Migratory Bird Act of 1918 (16 USC SS 703-712) - Prohibits the
unregulated and unintentional "taking" of native birds in the
United States, such as would be the case if a bird landed in the
oily sludge pit and was chemically burned or poisoned. The
remedial action will comply with this ARAR through the
excavation, stabilization and off-site disposal of the pit
wastes and installation of a native soil cover because there
will be no hazard to native birds after these actions are
completed.
ACTION-SPECIFIC ARARS
Several requirements of Arkansas Hazardous Waste Management Act
and the Arkansas Solid Waste Management Act are applicable or
relevant and appropriate to the selected remedy.
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1. ADPCE Regulation No. 22, Section XII.B, which
incorporates 40 CFR § 258.61 - Post closure of the
landfill must be conducted in accordance with state
regulations. The Operation and Maintenance Plan
developed in the remedial design phase of the project
will specify appropriate inspection procedures designed
to maintain the integrity and effectiveness of the final
cover. In addition, the selected remedy requires
groundwater monitoring to ensure that any migration of
contaminants remaining in the landfill is detected and
evaluated appropriately to ensure they do not create or
pose an unacceptable risk to the public health and the
environment.
2. ADPCE Regulation No. 23 § 268.42 - Because the waste in
the oily sludge pit demonstrates the characteristic of
corrosivity (EPA Waste Code D002) , based on 40 CFR §
261.22(a)(1), prior to off-site disposal in a Subtitle D
landfill, the waste must be deactivated to remove its
corrosive characteristic, and it must be treated such
that each underlying hazardous constituent in the waste
meets the same concentration-based treatment standard
promulgated for that constituent in the treatment
standards for F039 wastewaters and nonwastewaters. F039
is the hazardous waste code for liquids that have
percolated through land disposed wastes (i.e., leachate)
resulting from the disposal of more than one listed
hazardous waste (40 CFR § 261.31).
3. ADPCE Regulation No. 23 § 268.41 - Because the waste in
the oily sludge pit demonstrates the characteristic of
toxicity for lead (EPA Waste Code DO08) , based on 40 CFR
§ 261.24(a), prior to off-site disposal the waste must be
treated such that the concentration of lead in the
extract of the treatment residuals does not exceed
5 mg/1.
4. ADPCE Regulation No. 23 § 264 - The systems utilized to
effectuate waste treatment or storage prior to waste
treatment must conform to the design and operating
standards set forth in this regulation for hazardous
waste treatment and storage units. Systems that may be
utilized in the treatment process include tanks, surface
impoundments and waste piles.
5. ADPCE Regulation No. 23 § 264.111 - Portions of this
regulation, to be determined during RD, are relevant and
appropriate to the oily sludge pit area because
excavation of the waste in the oily sludge pit and
placement of clean backfill is analogous to closure of a
RCRA Subtitle C storage or treatment unit. This
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regulation is not applicable because the waste was
disposed in the oily sludge pit prior to November 19,
1980.
In addition to the chemical specific requirements specified earlier
in this ROD, the substantive portions of the Arkansas Water and Air
Pollution Control Act could be applicable or relevant and
appropriate to the remedial action depending upon how treatment and
disposal of the contaminated waters is accomplished.
l. ADPCE Regulation No. 6 which incorporates 40 CFR §§ 122
and 125.3 - If wastewater is discharged from the site to
a surface water of the State of Arkansas, it must meet:
1) certain technology-based requirements for the removal
of pollutants from the wastewater prior to discharge, and
2) certain monitoring requirements. During RD, EPA will
examine the pollutants present in the wastewater and
determine to what degree proven technologies have been
successful in treating those pollutants. Based upon this
information, specific numerical effluent limitations or
treatment efficiency requirements will be established
that the remediation contractor must meet prior to
discharging the wastewater.
2. ADPCE Regulation No. 6 which incorporates 40 CFR § 403 -
If wastewater is discharged from the site to a publicly
owned treatment works (POTW), it must meet discharge
standards that prevent pass through or interference with
the POTW. For example, if heavy metals enter the POTW,
the POTW's processes may not treat heavy metals in the
wastewater (the metals may "pass through" the POTW), or
the heavy metals may inhibit POTW operations and
contaminate the POTW's sludge (the metals may interfere
with the POTW) . In such a circumstance, the remediation
contractor would be required to remove the heavy metals
before discharging wastewater to the POTW.
TO BE CONSIDERED CRITERIA
Off-site Disposal Policy - CERCLA wastes may only be disposed in
a regulated landfill that complies with EPA's Off-site Disposal
Policy. In general, a facility must be in compliance with all
environmental laws in order to comply with EPA's off-site
disposal policy.
Performance Criteria for Stabilization - EPA Region 6 has
established certain performance goals for stabilization
technologies that will measure the overall effectiveness of
stabilization remedies. The goals which the selected remedy
must meet are outlined in the following table:
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TABLE 24
STABILIZATION PERFORMANCE GOALS
; TABLE 24
PARAMETER
TESTS • ; • - : • ;
Unconfined Compressive Strength
ASTM D1633
Permeability
ASTM 05084-90
Free Liquids
Microbial Growth
ASTM G-21, G-22
Stabilization of Organics
SW846-3550, 8270
(Adjusting for Dilution)
PERFORMANCE CRITERIA
> 50 psi
<10's cm/sec
No visible liquid exuded under'
maximum strength test
No growth; test required only if
>10% organic content in the
treated waste
Reduction in Contaminant Cone.
>50% Bases
>30% Neutrals
>60% Acids
* Be Cost-Effective
The selected remedy is cost-effective. Excavation, stabilization
and off-site disposal at a Subtitle D landfill is the least costly
remedy evaluated by EPA in the RI/FS that achieves the remedial
action objectives established for the oily sludge pit area.
Installation of a natural soil cover, execution of deed notices,
and implementation of long-term groundwater monitoring is a cost
effective solution to the problem posed by the landfill areas at
the site. Although it is the most costly of the remedial
alternatives evaluated for the landfill areas, it is the only
alternative that achieves the remedial action objectives. In
addition, the natural soil cover alternative is the most permanent
alternative for the landfill areas and is also the only alternative
that complies with ARARs.
• Utilize Permanent Solutions and Alternative
Technologies to the Maximum Extent Practicable
Treatment
EPA has determined that the selected remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable, given the site-specific circumstances,
including issues relating to State and community acceptance of the
originally proposed remedy and the remedy selected in this ROD.
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• Preference for Treatment as a Principal Element
The selected remedy satisfies EPA's preference for treatment as a
principal element of the remedial action to address the principal
threat at the site. The principal threat at the site is the 3.5
acre oily sludge pit that contains an estimated 22,000 cubic yards
of corrosive sludge and associated contaminated soil and debris.
The most significant threat associated with the oily sludge pit
area is the corrosivity of the oily sludge pit wastes. The
selected remedy will address this threat through treatment via the
stabilization process. During the stabilization process, the pH of
the wastes will be raised to at least 7, thereby rendering the
waste non-corrosive, or neutral.
The baseline risk assessment identifies the organic contaminants in
the pit waste as the source of long-term risk at the site. If,
upon completion of the excavation and stabilization of the oily
sludge pit waste and associated contaminated soil and debris, the
stabilized waste meets the performance criteria for stabilization
specified in this ROD, then "immobilization of the organic
contaminants through treatment will have occurred. However, as
discussed earlier, there is some uncertainty as to whether
stabilization of these particular site wastes will effectively
immobilize the organic contaminants.
Any threat associated with inorganic contaminants (e.g., lead)
leaching from the waste into the groundwater will be addressed
through the stabilization/treatment process. Although it is
currently unclear whether or not the groundwater at the site has
been impacted by the high lead content of the wastes, the
stabilization process will treat the lead to render it immobile in
the natural environment. During RD, EPA will evaluate and select
an appropriate binder (e.g., cement, pozzolan, etc.) that will be
mixed with the waste to promote the formation of insoluble lead
hydroxides or other compounds with very small solubility
coefficients.
XI. DOCUMENTATION OF SIGNIFICANT CHANGES
The remedy selected in this ROD to address the oily sludge pit is
significantly different than the remedy identified by EPA as the
preferred remedy in the Proposed Plan. Specifically, EPA is
selecting stabilization and off-site disposal of the oily sludge
pit wastes at a Subtitle D landfill (Alternative 4) rather than
organic treatment, stabilization and off-site disposal at a
Subtitle D landfill (Alternative 7), which was EPA's original
preferred remedy. The change occurred as a direct result of
comments EPA received from the public, PRPs, and the State of
Arkansas during the public comment period.
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In general, the public, the PRPs, and the State of Arkansas felt
that the cost of the remedy preferred by EPA was not justified in
light of the fact that the selected remedy, which costs
significantly less, would also achieve protectiveness of human
health and the environment. The Proposed Plan specifically
discussed the fact that the selected remedy is less permanent than
EPA's originally identified preferred remedial alternative. This
issue also was explicitly addressed by EPA during the public
meeting held in West Memphis, Arkansas on August 17, 1993.
The results of selecting Alternative 4 rather than Alternative 7
are: (1) the selected remedy is less permanent than (although
equally as protective as) the remedy preferred by EPA because the
risk associated with the organic contaminants will not be
permanently addressed through destruction of the organic
contaminants; and (2) the cost associated with cleaning up the oily
sludge pit decreased from an estimated $14.8 - $18.1 million to an
estimated $6.9 million.
In addition, a minor change is being made to the remedial
alternative selected for the landfill areas at the site.
Specifically, the selected remedy does not include backfilling the
fishing pond near the RV park located north of the site as
specified by EPA in the Proposed Plan. This change occurred
because EPA reevaluated its decision to backfill the fishing pond
to address the risk to fish eating birds and mammals from
contaminants found in the pond fish.
It is now EPA's opinion that the fish from the Mississippi River
may have been washed into the pond during past flood events. Since
the fish in the Mississippi River contain contaminants at
concentrations similar to those found in the fish in the pond, it
is unclear whether or not the contaminants in the fish came from
the site. This fact coupled with the fact that the contaminants in
the fish were not found in either the pond water or sediments, has
led EPA to conclude that backfilling the pond is not necessary to
achieve protection of human health and the environment.
Additionally, as noted in this ROD, the least tern is not
anticipated to forage in the pond area.
XII. RESPONSIVENESS SUMMARY
This response to comments is provided to document EPA's
consideration of relevant technical comments regarding the
Administrative Record, including EPA's Proposed Plan. EPA has
endeavored to address every comment it received. However, certain
comments generally relating to EPA's selection of its originally
identified preferred alternative for the oily sludge pit area are
not specifically addressed in this Responsiveness Summary since
that alternative was not selected to address the risk posed by the
South 8th Street site.
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In lieu of responding to those comments, EPA can best sum up the
comments it received regarding the proposed alternative for the
oily sludge pit area by stating that no comments in support of the
preferred remedy were received by EPA. The public, the State of
Arkansas, and the PRPs all stated that EPA's preferred alternative
was too costly. Although EPA initially determined that the
benefits of added permanence and increased reduction of mobility,
toxicity, and volume justified the higher cost of EPA's proposed
alternative, EPA has selected the remedy set forth in this ROD
based upon the strong public sentiment to select a less costly
remedy that is as protective, but less permanent than, the
preferred remdy identified in the Proposed Plan. Although the
selected remedy is less permanent than EPA's originally identified
preferred remedy set forth in the Proposed Plan, the selected
remedy meets the threshold criteria for selecting remedies mandated
by the NCP.
COMMENTS SUBMITTED BY INDIVIDUAL CITIZENS
1. I do not accept as justified the charging of West Memphis
taxpayers for any part of the Eighth Street Superfund Site
actions.
Response: The comment is not relevant to the selection of remedial
alternatives.
2. The site has been inundated almost every year for the past 30-
40 years and any health hazards that may have existed have
long since washed down the river and into the Gulf. The
logical thing to do is cover the oil pit with gumbo clay and
leave it alone.
Response: EPA disagrees. Health hazards at the site have not all
washed downstream, as the risk at the site is above EPA's
acceptable risk range. Merely capping the site was considered
early in the evaluation of remedial alternatives, but was screened
out because it was determined to be ineffective. Readers are
referred to Section 2.5 of the Feasibility Study for more
information regarding the reasons capping alone was screened out
prior to the detailed analysis of alternatives.
3. The risk at the site is minimal and the reported risks are
overinf lated. Minimal risks at the site can be controlled via
fencing and, berm construction that has already been conducted.
Response: EPA disagrees. The risk at the site is neither minimal
nor overinf lated. EPA does not believe that the fence and berm are
protective of the public health and the environment over the long-
term because these remedies do not address the underlying hazards
associated with the waste; nor do they comply with ARARs. Any
remedy that does not include the excavation and off-site disposal
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of the oily sludge pit will not accomplish the remedial action
objectives and will not comply with ARARs. As recently as spring
of 1994, local flooding destroyed part of the fence at the site,
further indicating that such a remedy as that suggested by the
commentor is not at all permanent.
4. The risk at the site is minimal. Risks attributed to the
landfill can be controlled via maintenance of the fence and
warning signs and limiting future development. A practical
solution to the oily sludge pit would be to stabilize and
dispose of the sludge on-site, cover it with a natural soil
cover, and restrict public access by maintaining perimeter
fencing.
Response: EPA disagrees. Merely limiting the remedial action to
institutional controls for the landfill areas does not comply with
ARARs. Stabilization and disposal of the sludge pit waste on the
site is not protective of the public health and the environment
because flood plains and other environments tend to promote the
mobility of the contaminants, meaning there would be potential for
the waste to migrate as a result of future flood events.
COMMENTS BY THE STATE OF ARKANSAS
5. The oily sludge pit should be remediated via alternatives 4
(stabilization) or 5 (subtitle C) and the landfill should be
remediated via alternative 3 (natural soil cover). Comment
submitted by Office of the Governor.
Response: EPA is selecting Alternative 4 for the oily sludge pit
and Alternative 3 for the landfill areas.
6. The Governor of Arkansas urges that EPA eliminate any
requirement to collect costs from the City of West Memphis.
Comment submitted by Office of the Governor.
Response: The comment does not affect the selection of a remedial
alternative for the site.
7. ADPCE supports Alternative 3 (natural soil cover) for the
landfill area and, for the oily sludge pit area, ADPCE
supports pretreatment of the oily material only and disposal
in a Subtitle D or C landfill.
Response: EPA is selecting the natural soil cover, institutional
controls, and long-term groundwater monitoring for the landfill.
EPA disagrees with ADPCE's assessment that only pretreatment is
necessary prior to offsite disposal in order to ensure the
protection of public health and the environment. The waste will
need to be treated via stabilization/solidification as necessary to
comply with land disposal restrictions and performance goals
identified in this ROD.
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8. ADPCE will not support EPA's preferred alternative.
Response: EPA has selected a remedy other than its initially
identified preferred alternative.
COMMENTS BY THE CITY OF WEST MEMPHIS, ARKANSAS
9. The scenarios used in the base'line risk assessment to develop,
screen and select the EPA's preferred alternatives are
unreasonable, unrealistic and do not accurately represent any
risks associated with the current or reasonably possible uses
of the site.
Response: EPA disagrees. The receptors that were considered in
the baseline risk assessment include: (1) current and future
recreational visitors; (2) future recreational workers; and (3)
current and future crop consumers. A recreational exposure and
crop consumer scenario were utilized because:
- The site is in the two-year flood plain of the Mississippi
River, thereby precluding the construction of any residential
or commercial facilities.
- The site was seriously considered as a possible location for
a state park by the Arkansas Department of Parks and
Recreation.
- There is currently a large RV park that borders the site
immediately on the north.
- The site was used as a parking lot for an annual local
festival where total attendance was as great as 30,000 people.
- The EPA Remedial Project Manager (RPM) personally observed
numerous people, including children, engaged in recreational
activities near the river in the vicinity of the site before
it was fenced.
- Aerial photography shows that the site was farmed as recently
as 1986.
10. Remediation goals (RGs) should be established for the landfill
areas. If RGs are not required, then the landfill areas
should not be cleaned up.
Response: EPA disagrees. RGs are not necessary for the landfill
areas because the remedial alternatives for the landfill areas do
not involve the excavation of the waste. The presumptive remedy
for landfills (OSWER Directive 9355.0-49FS) states that EPA does
not usually excavate landfills because it is impractical and too
costly for the amount of risk reduction that would be achieved.
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Were excavation of the landfill contents contemplated, RGs would be
established in order to ensure that the excavation proceeded until
all the contaminated material was removed from the landfill.
11. The Proposed Plan dismisses "No Action" without proper
development of this alternative.
Response: EPA disagrees. The "No Action" alternative was
developed to the extent necessary to determine that a decision of
"No Action" would be inconsistent with the NCP because it would not
meet the threshold requirements and would neither be protective of
human health and the environment nor comply with ARARs.
12. The EPA's preferred alternatives are more costly than other
possible alternatives that meet the remedial action objectives
for the oily sludge pit and the landfill and should be
eliminated on the basis of cost.
Response: EPA agrees that there is a difference in the costs of
all of the alternatives considered in the FS. However, EPA
disagrees that alternatives should have been eliminated solely on
the basis of cost. The NCP requires EPA to consider a wide range
of possible response actions and nine different criteria in the
evaluation process. The NCP identifies only two criteria as
threshold criteria that a remedy .must meet in order to be
considered further for a site. Cost is not one of those threshold
criteria, and, accordingly, may not be used alone to eliminate an
alternative from consideration.
13. There are no "hot spots" in the landfill areas requiring
remedial action.
Response: EPA agrees. However, while there are no "hot spots"
requiring active treatment, the landfill areas pose risks to human
health and the environment that must be addressed.
14. The level that the EPA proposes to reduce the lifetime cancer
risk associated with the site greatly and unreasonably exceeds
the national lifetime risk of cancer from everyday sources.
Response: EPA agrees that the level to which the risks are
proposed to be reduced are less than the national lifetime risk,
but disagrees with the commentor's opinion that this action is
unreasonable. The level to which risk is proposed to be reduced
(between 1 in 1 million and 1 in ten thousand) is the level
mandated by the NCP, and EPA must act not inconsistently with the
NCP. Changing or amending the NCP is beyond the scope of the
remedial action decision at the South 8th Street Landfill site.
15. The EPA's preferred alternatives are not reasonable or
appropriate considering overall protection of human health and
the environment, compliance with applicable or relevant and
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appropriate requirements, long-term effectiveness and
permanence, reduction of toxicity or volume through treatment,
short-term effectiveness, implementability, cost, state
acceptance, and community acceptance.
Response: EPA disagrees. As discussed in the ROD, EPA's preferred
alternatives are appropriate when considering the primary and
balancing criteria.
16. The risk assessment fails to consider that before any
recreational use could be made of the property some
development and improvements would be necessary. The filling
in of low areas and raising the elevation of the entire site
provide a covering which would reduce the risk of exposure for
any future recreational visitor or worker.
Response: EPA disagrees. The site has been utilized for
recreational purposes in the past without any improvements and
there is no reason to believe that it would not be so utilized in
the future. In addition, future improvement and development would
likely result in the excavation and spreading of contaminants over
the site, thereby increasing the risk to the public.
17. The cost of on-site incineration, stabilization of ash and
disposal in a Subtitle D landfill appears to be excessive for
meeting the remedial action objectives for the oily sludge
pit.
Response: EPA disagrees. The cost of the remedial action
described by the commentor is not excessive considering the high
degree of permanence and contaminant destruction that would be
achieved via implementation of that remedy.
18. In regards to on-site incineration and disposal of ash in a
Subtitle C landfill, the necessity of disposal in a Subtitle
C landfill as opposed to the disposal in a Subtitle D landfill
has not been demonstrated.
Response: The inclusion of an incineration alternative in the FS
that specified disposal of ash in a Subtitle C landfill rather than
a Subtitle D landfill was performed to comply with the NCP's
mandate to develop a range of alternatives.
19. Of the proposed alternatives meeting the remedial action
objectives for the pit, Alternative 4 is the most cost
effective.
Response: EPA agrees that Alternative 4 is a cost effective
remedy. However, EPA notes that other alternatives set forth in
the FS are also cost effective.
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20. The disposal of waste at a Subtitle C landfill is not
necessary when a Subtitle D landfill will suffice.
Response: EPA agrees that ARARs would not require the disposal of
non-hazardous waste at a Subtitle C facility rather than a Subtitle
D facility. However, decisions as to the appropriateness of the
use of a Subtitle C versus a Subtitle D facility for the disposal
of any given waste must be viewed in the context of the particular
site and waste being considered and with reference to the nine
criteria EPA must utilize in evaluating potential remedial
alternatives, especially long-term permanence and compliance with
ARARs. Finally, EPA notes that hazardous waste cannot be legally
disposed in a Subtitle D landfill without first being rendered
nonhazardous. See also response to comment 18 above.
21. Off-site incineration should be eliminated on the basis that
its cost is excessive.
Response: EPA disagrees. Cost alone is not a sufficient reason to
eliminate an alternative from the range of alternatives that will
be evaluated in the analysis of alternatives. If a particular
alternative is expensive, but also achieves a high degree of
permanence and significantly reduces the mobility, toxicity and
volume of the waste, it can still be cost effective. Indeed, the
NCP requires EPA to develop a wide range of alternatives, including
an alternative that "removes or destroys hazardous substances,
pollutants, or contaminants to the maximum extent feasible,"
[40 CFR § 300.430 (e)(3)]. Off-site incineration is one such
alternative.
22. The cost and time associated with EPA's preferred alternative
(organic treatment, stabilization, disposal in Subtitle D
landfill) are greater than the cost and time of other
alternatives that also meet the remedial action objectives.
Response: EPA agrees. However, many of the less costly
alternatives, inter alia, are less permanent and reduce mobility,
toxicity and volume to a lesser degree.
23. Institutional controls meets the remedial action objectives
(for the landfill areas) and is more cost effective than EPA's
preferred alternative.
Response: Institutional controls was not selected as the remedial
alternative for the landfill areas because Institutional Controls
alone can not meet the threshold criterion of compliance with
ARARs.
24. Groundwater monitoring is unnecessary in that the remedial
investigation has determined that any groundwater
contamination is below applicable action levels.
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Response: EPA disagrees. EPA is deferring any decision regarding
the groundwater operable unit at this time pending further
investigation. Current groundwater data is insufficient to render
any decision regarding the threat or lack of a threat to human
health and the environment posed by the groundwater. Groundwater
monitoring is specified as a component of the selected remedy
because hazardous substances will remain at the site after the
remedial action is completed, and monitoring will enable EPA to
detect any migration of contaminants in the groundwater.
Additionally, groundwater monitoring is included as a component of
EPA's presumptive remedy for landfills.
25. EPA has failed to demonstrate that the requirements of the
Arkansas Solid Waste Management Act and the regulations
adopted by the Arkansas Pollution Control and Ecology
Commission, particularly the requirement of a two-foot clay
cover, are applicable, relevant or appropriate for this site.
Response: EPA disagrees. EPA agrees with the State of Arkansas
that the 2-foot cover requirement is a State ARAR for the response
action. Section XVIII of the Arkansas Solid Waste Management Code
states that existing open dumps and other unpermitted disposal
facilities shall be required to meet the same closure criteria as
set out in the Code for permitted facilities. The closure criteria
for permitted facilities require that a compacted layer of at least
2 feet of material capable of supporting vegetation be placed over
all completed portions of the landfill.
COMMENTS BY W.L. JOHNSON COMPANY. A PRP
26. The three-acre or so area comprising the "Gurley Pit" should
be separated out and treated independently.
Response: EPA agrees. The three acres comprising the pit that
resulted from Mr. W.M. Gurley's re-refining operation are being
treated differently from the landfill area.
27. The legal process needs to be sped up to keep pace with the
technical work performed at the site.
Response: comment so noted. EPA has endeavored to move the
enforcement process forward as expeditiously as possible.
28. The pond should not be backfilled due to a possible risk to
fish-eating birds and mammals when any contamination that is
present in the fish may very well have resulted from fish in
the Mississippi River being washed into the pond.
Response: EPA agrees. After further review of the relevant data,
EPA has determined that the contaminated fish may very well have
come from the Mississippi River as no contaminants similar to those
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found in the fish were found above detection limits in the pond
water or sediments.
COMMENTS BY CHEVRON, A PRP
29. Health risks have clearly been overestimated due to the use of
default exposure parameters throughout the risk assessment.
Response: The EPA disagrees. The use of default exposure factors
does not a priori result in overestimates of risk. EPA selected
standard default exposure factors to represent high end exposures
in situations where site-specific data are not available. In this
case, the commentor did not provide studies quantifying exposure
factors for this site, or any other site-specific information, that
could be reviewed by EPA for determination of its usability in the
site risk assessment. It should be re-emphasized that default
values were not used when more specific scenarios were utilized
(e.g., the maximum length of stay in an Arkansas campground/park,
the number of days the site is flooded, etc.).
30. Assumed soil ingestion rates for workers are inconsistent with
EPA guidance, are unrealistic, and are the least validated of
the default exposure parameters propagated by EPA.
Response: EPA disagrees. EPA's guidance does not prohibit the use
of the 480 mg/day soil ingestion rate for workers who are engaged
in outdoor activities that would result in more contact with soil.
It simply says that the exposure duration generally (not "only")
will be short, but that it might vary according to site-specific
plans. EPA believes the assumed exposure durations are consistent
with the assumed future use of the area as a campground or as a
state park. It is acknowledged that the default ingestion rate is
based upon limited empirical evidence. It should be noted,
however, that there is some possibility that actual measurements
(were they to be performed) could be even higher. A more detailed
discussion of EPA's risk scenarios for recreational workers may be
found in Appendix B to this ROD.
31. The assumed skin surface areas are unjustified given the
temperate environment in Arkansas and that a more appropriate
surface area value would take into account the seasonal
climate at the site.
Response: EPA disagrees. EPA believes that the default assumption
for skin surface area (25% of total skin area, from EPA's dermal
guidance) is appropriate for this site. Although the guidance
suggests that this value could be adjusted for climate, the
adjustment would likely increase the assumed exposed skin area
since climate conditions in Arkansas would favor warmer weather for
a greater portion of the year than in a more temperate region of
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the country. Indeed, the time of year when visitors will likely
visit the site is when the weather is warm.
32. The exposure duration for an agricultural worker of 25 years
does not appear to be reasonable. It is unusual for workers
to be associated with one particular agricultural property for
more than a few years unless it is a farm family.
Response: EPA disagrees that an exposure duration of 25 years is
unreasonable. Given the size and location of the site, it is not
unreasonable to assume that the agricultural worker is part of a
farm family that works a portion of the site continuously for 25
years.
33. The average ingestion rate assumed for the child camper (200
mg/day) is not the average soil intake by children at a
residence but is an upper bound for soil and dust and is
therefore inappropriate for use in an average exposure
scenario.
Response: EPA disagrees with the commentor's opinion that it is
inappropriate to use 200 mg/day to represent an average soil intake
rate by children at a campground. While it is true that the 200
mg/day ingestion rate represents an upper bound estimate for a
residential scenario, EPA used a recreational scenario in the risk
assessment. Soil intake rates for recreational scenarios are
likely to be greater than soil intake rates for a residential
scenarios because children will likely spend more time outside
engaged in activities that promote the intake of dust and
contaminated soil. Thus, it is appropriate to assume an average
soil intake in a campground situation of 200 mg/day when 300 mg/day
represents the reasonable maximum intake, as performed in the risk
assessment.
34. The assumed soil ingestion rates for the adult recreational
visitor are high and appear not to be validated by scientific
studies.
Response: EPA agrees that the soil ingestion rates may appear high
and that they are not validated by scientific studies. However,
the rates utilized in the risk assessment are not inappropriate
given the overall lack of scientific information available
regarding ingestion rates in recreational situations. The rates
that were used in the risk assessment are based on judgmental
extrapolations based on best professional judgment by a
professional toxicologist and represent EPA's best efforts to
perform a risk assessment that is protective of the public health
and the environment. Since no other data were available, EPA
believes the rates are reasonable and appropriate for this
situation.
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35. The assumption of 40% of vegetable intake for the RME consumer
greatly overestimates risks and should be re-evaluated or
quantitatively evaluated in the uncertainty section.
Response: EPA disagrees. The fractional intake assumption was
based on a farm family in the area who used the site to grow
produce both for their consumption and for sale in a truck-farm
type situation (not a commercial agricultural operation, per se).
The Agency recognizes the uncertainty in quantification of the
vegetable pathway and has appropriately factored that information
into its risk management decisions regarding remediation at this
site.
36. The models for estimating chemical concentrations in produce
are not well validated and supporting data are sparse.
Response: EPA recognized the uncertain methodology for estimating
risks from the vegetable pathway and factored this information into
its risk management decisions regarding remediation at this site.
37. Soil data used to determine vegetable concentrations was
biased.
Response: EPA disagrees. The site data were developed by using a
systematic/random approach in which some samples were collected
from areas that were obviously contaminated and some samples were
collected from areas where no obvious contamination existed. In an
effort to control the cost of the investigation and ensure the
protection of public health and the environment, more samples were
collected from areas which appeared to be visibly contaminated than
areas in which no visible contamination was identified.
38. Likely crops that would be grown in the area were not
evaluated.
Response: EPA disagrees. An evaluation was conducted of the
possible types of crops that could be grown at the site. EPA
concluded that all three types of plants (leafy, root, fruits)
could be grown, and this information was considered in the risk
assessment. In the absence of site specific information, the
evaluation conducted is appropriate, and the uncertainty associated
with the agricultural scenario was factored into EPA's risk
management decisions at the site.
39. Soil samples were taken in biased locations and then
inapprbpriately used in exposure point concentrations.
Response: EPA disagrees, see response to comment 37 above.
40. In area 2/3 it was assumed that excavated soils were spread on
the surface and this methodology biases the data.
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Response: EPA disagrees. EPA believes it is reasonable to assume
that the site will be excavated and the soils spread on the surface
because such an event actually occurred at the site when the
current owner constructed the fishing pond located at the north end
of the site. Other commentors (see comments 16 and 64) have noted
that improvements to the site may be conducted in order to make it
more suitable for recreational visitors. These improvements could
very well involve the excavation and spreading of subsurface
materials on the site surface, thereby increasing the likelihood
that receptors will come into contact with the contaminated
subsurface soils. EPA believes that its assumption does not bias
the data, but rather presents a plausible scenario that considers
the risk associated with the most highly contaminated portions of
the site.
41. The appropriateness of using the maximum toxaphene value as
being representative of the data set needs to be further
evaluated since the chemical was detected at a low frequency.
Response: EPA disagrees. The calculation of the exposure point
concentration for toxaphene was conducted according to EPA guidance
(i.e., the upper 95th confidence limit of the arithmetic mean, or
the maximum concentration (whichever was lower) was used). In
areas where toxaphene was never detected, the exposure point
concentration was assumed to be zero.
The fact that toxaphene was detected only twice is not a valid
reason for eliminating it from the chemicals of potential concern.
Since both samples detecting toxaphene were clustered in Area 1 and
showed fairly high concentrations (40-240 ppm), inclusion of this
chemical in the risk assessment was warranted.
42. It is unclear which soil values were used to evaluate the
future recreational worker risk. Since naturally occurring
chemicals (beryllium and arsenic) contribute significantly to
risk, .there needs to be further discussion of their
significance.
Response: The risk assessment clearly shows which soil values were
used to evaluate future recreational worker risk. The specific
sample identifiers used in exposure point concentration
calculations for this scenario are listed in Table 3-2 of the risk
assessment. EPA acknowledges that total site risks were calculated
without regard to the source of the chemicals (either from
background or site activities) and that the levels of arsenic and
beryllium found at the site are not significantly different from
background. However, EPA disagrees with the commentor's assertion
that arsenic and beryllium contribute significantly to the risk at
the site. in any event, a review of Table 5-2 (depicting risk
associated with each major contaminant) in the oily sludge pit risk
assessment establishes that, even without considering the risk from
arsenic and beryllium, the risk at the site is 1 x 10"3, which
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corresponds to the total RME risk reported for the recreational
worker pathway in Table 5-1.
A similar evaluation of the risk associated with the landfill areas
shows that even when the risk from arsenic and beryllium is
subtracted from the total site risk for the future recreational
worker as specified in Table 5-1, the risk (4 x 10"4) still exceeds
EPA's acceptable risk range of between 1 x 10"4 and 1 x 10"6.
43. It is unclear how background samples were used for the site.
The contribution of background levels to risk estimates needs
to be understood to help evaluate the significance of the risk
estimates.
Response: See response to comment 42.
44. It is recommended that chemical-specific degradation data be
used to more accurately assess representative exposure
concentrations over the chronic exposure periods.
Response: EPA disagrees. Exposure concentrations were assessed
consistent with relevant EPA Risk Assessment and RI/FS guidance and
policy, which do not require the development and use of chemical-
specific degradation data. Consistent with that guidance and
policy, most EPA RI/FSs do not include the collection of site
specific degradation data, and degradation is typically not
considered in the baseline risk assessment.
45. The effect of degradation from flooding events is also not
considered or discussed.
Response: EPA agrees that degradation caused by flooding was not
considered in the risk assessment. However, given the fact that
the contaminants have been located at the site for a significant
period of time and continue to pose a significant risk to the
public health and. the environment, the potential effect of
degradation from flooding events is not expected to be significant.
See also EPA's response to comment 44 above.
46. The uncertainties associated with the toxicity treatment for
carcinogenic PAHs needs to be further quantitatively evaluated
and discussed.
Response: EPA disagrees. At the time the risk assessment was
conducted, the Toxicity Equivalency Factor (TEF) approach for
characterizing the carcinogenic risks associated with PAHs was not
yet officially adopted by EPA. If the toxicity equivalency factor
approach was considered in the baseline risk assessment, the risk
estimates would be approximately one order of magnitude lower. For
example, the future risk to a recreational worker would be 1 x 10"4
rather than 1 x 10"3. This would still exceed EPA's acceptable risk
range.
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47. The terminology to describe the landfill is confusing. There
seem to be several uses of the word "site". Also it would be
useful to understand the rationale for separating the two
areas.
Response: The term "site" refers to the 30 acre area encompassed
by the fence in Figure 1 of the ROD. The two landfill areas were
separated when evaluating the risk to recreational visitors and
agricultural workers because it is conceivable that neither of
those receptors would be likely to frequent the entire 30 acre
area. The site was not separated to address the risk to a
recreational worker because a recreational worker would be expected
to frequent the entire site area.
48. On Table 2-1 are the detection frequencies for the landfill
area or for the landfill plus study area.
Response: The table lists detection frequencies for samples from
the landfill area only. Sampling data from the study area are
summarized in Appendix A, Tables Al-6 and Al-7 of the risk
assessment.
49. An Executive Summary should be included to summarize the
approach and findings of the risk assessment.
Response: An Executive Summary was prepared for the risk
assessment for inclusion in the RI report. The RI report includes
a summary of the risk assessment in Section 5.
50. The introduction should be expanded to include a discussion of
proposed future land uses.
Response: EPA believes that the discussion of future land uses is
appropriately included in the exposure assessment.
51. The risks on Table 5-3 presented for the Recreational Worker
are those associated with the RME, not the average.
Response: There is a typographical error in the heading and it
should read "RME," not "average".
52. There is an inconsistency between Appendix 2 and Table 3-5 on
the exposure frequency for the crop consumer.
Response: The assumed exposure frequency for the crop consumer is
350 days per year, and this is the value that appears in both
Appendix 2 and Table 3-5.
53. On Page 3-7 flux rates were presented and it is unclear why
these data are presented here. Simple calculations are
available to give an indication of the relationship between
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the flux and an estimated risk.
Response: The purpose of this section of the report was to
identify all possible, reasonable exposure pathways and to then
evaluate if the pathway was complete and the degree to which it
would be evaluated quantitatively in the risk assessment. The flux
data were presented with other monitoring data in Section 2.1.2 and
were merely discussed in the exposure assessment as the data relate
to potential exposures to volatile chemicals on site.
54. A Monte Carlo analysis should be utilized to provide true
estimates of the average and RME risks.
Response: Average and RME risks for the site were developed
consistent with relevant EPA guidance and policy, which do not
require the use of a Monte Carlo analysis in risk assessments.
COMMENTS SUBMITTED BY PRP GROUP
55. The conclusions of the risk assessment are invalid based on
the use of unrealistic and unreasonable exposure scenarios.
Response: EPA disagrees. As noted in its response to comment
No. 9, EPA believes that the exposure scenarios used to develop the
baseline risk assessment are consistent with the NCP and EPA
guidance and relevant site specific information. In making its
risk management decision, the EPA has taken into consideration the
uncertainty associated with each of the exposure pathways.
56. The land uses proposed by EPA in the risk assessment are not
reasonable or justifiable for the site in its current physical
state.
Response: EPA disagrees. See response to comment No. 9.
57. The use of the site for agricultural production is
unreasonable.
Response: EPA disagrees. See response to comment No. 9.
58. The frequency and duration of exposure via crop consumption
are greatly overestimated.
Response: While the EPA agrees that agricultural future use likely
is not as probable as the recreational future use, the assumed
exposure duration and frequency are standard defaults specified in
EPA guidance for a farm family scenario. They are designed to
represent the reasonable maximum exposure for this type of human
activity.
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59. Accurate quantitative presentations of risks posed by crop
consumption are not possible given the lack of developed
contaminant transport models for crops. In addition there was
no effort to account for differential uptake or different
types of edible crops.
Response: In the risk assessment, the EPA acknowledged the
uncertainty associated with attempts to quantify any crop
consumption pathway. The EPA has'taken this into consideration
when making remedial decisions regarding this site. Ignoring the
agricultural scenario would not be protective of the public health
and environment because aerial photographic analysis and site
visits by EPA personnel confirmed that the site has been used for
agricultural purposes in the past and that areas near the site were
being used for agriculture at the time the site was proposed to the
NPL.
60. The future recreational use of the site is not reasonable
given the current condition of the site.
Response: EPA disagrees. See response to comment No. 9.
61. There is no reasonable scenario which would result in
subsurface soils.being excavated and spread on the ground.
Response: EPA disagrees. See response to comment No. 16 and 40.
62. The ingestion of fish from the on-site pond, especially for
the long term assumed in the risk assessment, is unreasonable
and unrealistic.
Response: EPA disagrees. Catching and eating one fish meal each
day the pond is visited is not unrealistic and represents an
estimate of a reasonable maximum exposure from this pathway.
63. The occasional trespasser scenario or recreational worker
scenario should have been used as the reasonable maximum
exposure.
Response: EPA disagrees. The RME exposures utilized in the risk
assessment are appropriate. An occasional trespasser does not
represent the current reasonable maximum exposure because the site
has a history and potential for frequent visits by a large number
of people. See response to comment No. 9 regarding the rationale
used by EPA to develop exposure scenarios.
64. Potential future land use for the site would only occur after
site improvements were performed which would result in the
elimination of exposure pathways.
Response: EPA disagrees. See response to comment 16.
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65. The removal of the direct contact pathway will result in
acceptable risks under any reasonable exposure scenario.
Response: EPA agrees with this comment to the extent that it
addresses risks posed by direct contact with the site contaminants.
The removal of direct contact with the contaminated soil (with the
associated subsequent ingestion or dermal absorption of the
material) will reduce direct contact risks at the site to
acceptable levels. The direct contact threat associated with the
landfill areas will be removed by installing a natural soil cover
the site.
EPA disagrees with the comment to the extent that the comment fails
to acknowledge that there are other risks and exposure pathways at
the site that would not be addressed adequately solely through the
elimination of the direct contact pathway (e.g., migration of site
contaminants to the groundwater).
66. The RI does not present an adequate evaluation of the data.
Response: EPA disagrees. Section 3.4 of EPA's "Guidance for
Conducting Remedial Investigation and Feasibility Studies Under
CERCLA" states that the requirements for site characterization and
data analyses shall include: the site physical characteristics,
source characteristics, nature and .extent of contaminants, and
contaminant fate and transport. EPA has addressed these
requirements through field activities, assembling data in the
Administrative Record, and project reporting. EPA investigated the
site, visually and technically identified hot spots, determined the
physical characteristics and nature and extent of contaminants,
assessed contaminant fate and transport, evaluated and documented
risk considerations, and produced a comprehensive RI/FS report. As
such, EPA has, in fact, provided an adequate evaluation and
reporting of the data.
67. The RI does not provide the basis for the constituents/
concentrations which are subsequently used in the risk
assessment.
Response: EPA disagrees. The analytical results summarized in the
RI report, in several instances, did not include concentrations
below contract required detection limits that were reported in the
data packages. The organic data from the oily sludge pit were
estimated (i.e., "J" qualified) on several accounts due to inherent
problems with extraction and dilution on this difficult type of
matrix. This data Was included in the appendices for the RI report
(and the Administrative Record) and was concurrently available for
evaluation and use in the risk assessment. According to EPA's
guidance, J-gualified data are used for risk assessment
calculations as if they were unqualified. Data from previous EPA
investigations (HRS Documentation Record, FIT report 5/88, and TAT
report 6/87) established that carcinogenic PAHs (i.e.,
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95
benzo(a)pyrene, chrysene) are present in the oily sludge material
and contaminated soils at concentrations comparable to those
reported in the RI data package. Therefore, the EPA determined
that the estimated concentrations for the referenced compounds are
appropriate for calculating risk for the site.
68. The constituents of concern, which are identified as
carcinogens in the Proposed Plan, are not, in fact,
carcinogenic.
Response: EPA concurs. However, this comment is not entirely
correct and is misleading if considered outside of the context in
which the statement was rendered. While it is true that
naphthalene, 2-methylnaphthalene, phenanthrene, and anthracene are
not carcinogenic by themselves (assuming the Toxicity Equivalent
Rule), their presence typically is indicative of the presence of
carcinogenic PAHs. The detection limits for the individual
carcinogenic PAH compounds reported in Tables 3-6 through 3-12 and
Appendices P, R, X and Z of the RI Report were so high due to the
interference caused by the oily nature of the wastes, that they
were not detected as individual constituents. However, based upon
the confirmed presence of carcinogenic PAHs in previous studies and
in wastes found at other similar sites created by the depositing of
wastes generated during waste oil re-refining (e.g., Double Eagle
and Fourth Street sites, Sand Springs site, and Gurley Pit site
(where wastes were generated by the same facility utilizing the
same process that generated waste at the South 8th Street site)),
it is reasonable to report the concentrations of non-carcinogenic
PAHs as strongly indicating the probable presence of carcinogenic
PAHs.
69. EPA's proposed remedy for the landfill area is not appropriate
based on the evaluation of current and future risks posed by
this area.
Response: EPA disagrees. The risks attributed to the landfill
area exceed EPA's acceptable risk, as set forth in the NCP.
70. The degree of mitigation of wetlands during site remediation
should be dictated by the current usefulness of wetlands.
Response: EPA agrees. The wetlands mitigation plan will be
developed during the remedial design. EPA currently estimates that
1.1 acres will need to be mitigated during the remedial action.
71. The risk associated with a current recreational visitor
scenario demonstrates that the pit area actually poses a lower
current risk than the landfill areas.
Response: The comment is irrelevant since the current visitor
scenario is not the scenario that drives the risk management
decision at the site. The current recreational visitor risk for
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96
both areas is within the range of 10"6 to 10"7. However, the risk
associated with the oily sludge pit area is one order of magnitude
greater than the landfill area for the future recreational worker.
Furthermore, the comment ignores the immediate threat posed by the
corrosive oily sludge pit waste and the need to address the risks
to the public health and the environment that it poses.
72. The remedial measures proposed for the landfill would be
adequate as well for the pit area.
Response: EPA disagrees. The sole application of a soil cap for
the oily sludge pit area was considered in the FS but screened out
early in the process because it would be ineffective at controlling
the oily sludge pit risk over the long-term. See also response to
comment 2.
73. The stated remedial action goals for the pit area will be met
by removing the direct contact pathway, the need for removal
of pit materials is not warranted to meet the remedial action
goals.
Response: EPA disagrees. The removal of the direct contact
pathway is only one of a number of considerations which were
incorporated into the remedial action goals for this site. For
example, merely covering the oily sludge pit area to eliminate the
direct exposure pathway for the oily sludge pit waste will not
address the potential for migration of contaminants into the
groundwater. See also EPA's response to comment 65.
74. The numerical remedial goals presented in Figure 5-2 of the FS
for total carcinogenic PAHs (O.33 mg/kg) and total PCBs (0.07
mg/kg) are not justified based on the risk assessment and are
not consistent with the remedial goals at other Superfund
sites.
Response: EPA has reassessed the remediation goals identified in
the FS and established new goals that more adequately consider the
specific factors at the South 8th Street site. The basis for the
revised remediation goals is provided in Section IV and Appendix B
of the ROD.
75. In-place neutralization of the pit sludge will adequately
address EPA's stated "most significant risk" from the pit
area.
RESPONSE: EPA agrees that neutralization, either in-place or at an
intermediate location, will achieve a reduction in the risk
associated with the corrosivity of the pit waste. However,
neutralization is only one step in the process of addressing the
overall risk at the site. Addressing the corrosivity of the pit
waste does not diminish the need to address the other components of
risk presented by organic and inorganic contaminants at the site.
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76. EPA has not demonstrated that the pit area is a "hot spot"
requiring additional remedial measures.
Response: EPA disagrees. Considering the site as a whole, the
oily sludge pit clearly constitutes a principal threat as defined
by the NCP and EPA guidance. The NCP defines a principal threat or
"hot spot" as those source materials that generally cannot be
reliably contained or would present a significant risk to human
health or the environment should exposure occur. Wastes that
generally will be considered to constitute principal threats
"include waste contained in drums, lagoons or tanks, ...,
containing contaminants of concern," (Draft Guide to Principal
Threat and Low-Level Threat Wastes, November 1991 (Publication
9380-06FS) (emphasis added). The chart below summarizes the
differences between the oily sludge pit area and the landfill area
that have resulted in the oily sludge pit area's designation as a
"hot spot":
TABLE 25
THREAT COMPARISON
SLUDGE FIT/LANDFILL AREA
TABLE 25
Characteristic
Corrosive
Mobility
Risk
Sludge Fit
Yes
High (esp. Pb)
1 x 10'3
Landfill
No
No
1 x 1CT4
77. EPA rejected onsite remedies including [sic] without
justification.
Response: EPA disagrees. The remedial action alternatives
considered and developed by EPA are appropriate and were based upon
the technical characteristics of the site. The NCP does not
require EPA to develop every potential alternative for a site, or
even to develop a cadre of on-site and off-site remedies. Rather,
EPA is required to develop a range of alternatives in which
treatment is a principal element, one or more alternatives that
involve little or no treatment, the no action alternative, and one
or more innovative treatment technologies for further consideration
if those technologies offer the potential for comparable or
superior treatment.
78. The use of in-place stabilization was rejected without proper
technical evaluation. Stabilization has been demonstrated to
be effective in immobilizing organic constituents.
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Response: EPA disagrees. See EPA's response to comment 77 for a
discussion of EPA's compliance with the NCP's requirement regarding
the evaluation of alternatives. EPA is not required to
exhaustively evaluate in-place stabilization. EPA also disagrees
with the commentor's suggestion that stabilization is an effective
technique for the treatment of all organic waste, irrespective of
the specific characteristics of a given waste. Furthermore, EPA
notes that the coromentor, in an attempt to support its statement,
appears to have erroneously interpreted various treatability
studies from other sites.
An example of the commentor's erroneous interpretation of other
site treatability studies is the commentor's discussion of the use
of stabilization at the PAB Oil site. The commentor cited the PAB
Oil site as one at which EPA Region 6 has selected stabilization to
treat organic waste. The commentor's citation of PAB is
misleading, in that the selected remedy for the PAB Oil site
consists of the use of stabilization in con-junction with
bioremediation to treat the organic waste at the site. In fact,
the PAB Oil ROD specifically discusses the fact that stabilization
alone would be insufficient to address the organic waste at the PAB
Oil site.
79. The need for immobilization of the constituents in the waste
mass has not been demonstrated.
Response: EPA disagrees. The risk assessment establishes that the
waste that will be immobilized constitutes the principal threat at
the site. If the contaminants are not immobilized, they may
migrate into the groundwater or be released to the surface water
during flood events. Finally, the oily sludge fails the TCLP for
lead and must be immobilized prior to final disposal in order to
comply with land disposal restrictions.
80. EPA has not considered that an on-site remedy could actually
result in a lower overall ultimate risk for the site.
Response: EPA disagrees. The waste must be disposed of off-site
in a secure landfill in order for the risk at the site to be
properly addressed. The disposal of a hazardous or solid waste in
a floodplain where it can easily come into contact with both
surface and groundwater is generally not considered to be
protective of the public health and the environment. For example,
recent EPA regulations pertaining to the siting of solid waste
landfills preclude new landfill construction in a floodplain. See
also EPA's response to comment 77 regarding the development and
evaluation of remedies that specify in-situ stabilization.
81. The remedy selection process was not consistent with the NCP.
Response: EPA disagrees.
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82. EPA has not developed appropriate remedial goals or ARARs for
the proposed alternative.
Response: EPA disagrees. See response to comment No. 74 with
reference to remediation goal issues. With respect to ARARs
issues, chemical and location specific ARARs for the site are
provided in Tables 2-1 and 2-2 in the landfill portion of 'the FS.
These ARARs were not repeated in Section 5 of the FS because it is
apparent that chemical and location specific ARARs would not change
between the landfill and oily sludge pit portion of the site (i.e.,
the oily sludge pit and landfill area are located in the same
vicinity (both in a flood plain) relative to a discussion of ARARs,
and the chemicals of concern had not changed except with regard to
concentration). Action specific ARARs were identified separately
for the two areas in Tables 2-11 and 5-3. The discussion of each
alternative in the FS contains a specific statement relative to
whether or not an alternative would comply with the identified
ARARs.
83. The NCP does not absolutely require a remedy that includes
treatment.
Response: EPA concurs. However, the context in which the comment
is presented is misleading. The commentors implied that EPA
screened out non-treatment alternatives simply because they did not
require treatment. Alternatives were screened from further
consideration based on the nine criteria set forth and discussed in
the FS report and this ROD.
84. EPA did not consider the NCP-specified criteria in screening
alternatives.
Response: EPA disagrees. The NCP-specified criteria were used to
screen alternatives as discussed in detail in the FS Report.
85. EPA has not performed an adequate detailed analysis of
potential remedial alternatives, especially regarding the
implementability of the remedies.
Response: EPA disagrees. EPA conducted a detailed analysis of
remedial alternatives and considered in depth the potential impacts
flooding and other technology specific concerns, including
technical feasibility, administrative feasibility, and
availability, may have upon the overall implementability of the
various alternatives.
86. EPA has selected a remedy and assumed that ARARs will be
attained even though no demonstration that the proposed remedy
will attain ARARs has been made.
Response: EPA disagrees. See response to comment No. 82. In
addition, a more detailed discussion regarding how ARARs will be
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100
attained by the selected remedy is included in Section IX of the
ROD.
87. EPA did not address the NCP bias against a remedy entailing
off-site land disposal.
Response: EPA assumes the commentor is referring to the NCP's
description of remedies calling for the off-site disposal of
untreated hazardous waste as "least favored." With the exception
of Alternative 5, all of the alternatives proposed for the oily
sludge pit provided for treatment of the waste. In the context of
this site, EPA has determined that disposal of hazardous waste in
a floodplain poses far more serious threats to the public health
and the environment than disposing of the oily sludge pit waste in
a secure off-site landfill, either with or without treatment. See
also EPA's response to comment 80.
88. The commentors proposed an alternative remedy that includes
(1) placement of a soil cover over landfill "hot spots", (2)
in-situ neutralization of the pit sludges, and (3) covering,
regrading, and revegetating the sludge pit area.
Response: EPA has evaluated the proposed remedy and offers the
following comments:
* Placement of a natural soil cover over areas of the landfill
which are visible and may pose a direct contact or ingestion
risk;
EPA agrees that a soil cover is needed over the landfill area.
However, placement of the soil cover over only the areas which
are visibly contaminated or which may pose a direct contact or
ingestion risk is not consistent with the State of Arkansas
Landfill Closure Requirements (ARARs). The ARAR requires a
minimum 2-foot natural soil cover over the entire landfill area.
As can be seen from the landfill trench profiles presented in
the RI, there is minimal (<2 feet) to no cover over nearly the
entire landfill. Therefore, a 2-foot native soil cover is
warranted for the entire site, as provided for in EPA's selected
remedy.
* Construction of erosion control features;
EPA agrees that this is an appropriate component for remedial
action at the site. Any civil construction type work involving
soil placement requires proper grading and surface features to
minimize -erosion potential, especially in a floodplain. EPA's
selected remedy provides for erosion control features.
* Establishment of mitigating wetlands to replace those which are
"lost" during performance of this remedy;
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101
EPA agrees that this is an appropriate component for remedial
action at the site. Lost wetlands must be mitigated according
to federal law. EPA's selected remedy provides for wetlands
mitigation.
* The in-situ treatment of the sludge by the addition of a
neutralizing agent such as Portland cement, kiln dust, and fly
ash. The treatment would be performed in-place using mixing
devices for deep applications;
EPA disagrees. The proposed in-situ neutralization process is
not a proven technology and has several shortcomings associated
with implementation at this site. These shortcomings include,
inter alia; (1) The long-term protectiveness of the alternative
is highly suspect because neutralization will not immobilize the
contaminants in the waste, and the contaminants may be exposed
to groundwater; (2) The radius of influence of in-situ
neutralization is severely limited due to the consistency of the
waste material; and (3) As established by the trench profiles
presented in the RI, approximately 50% of the site waste is
present outside of the "observed pit" in landfill waste
material. The effectiveness of drilling/mixing into and through
concrete, steel wire and debris is questionable.
* Backfill of the pit area with imported material. The need for
low permeability material (i.e., a cap) may be addressed, if
necessary, pending the results of treatability testing;
EPA agrees that this is an appropriate component for remedial
action at the site. EPA's selected alternative provides for
backfill of the pit area with imported material.
* Establishment of deed notification;
EPA agrees that this is an appropriate component for remedial
action at, the site. EPA's selected alternative provides for
deed notifications.
* Long-term operations and maintenance.
EPA agrees that this is an appropriate component for remedial
action at the site. Long-term operation and maintenance will be
required.
89. The commentors compared EPA's preferred alternative to their
alternative remedy.
Response: Although the ROD selected a different remedy from the
remedy preferred in the Proposed Plan, EPA's response to the
comparison is provided for informational purposes.
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102
* The technology to be used for the neutralization of the sludge
will provide a high degree of control over the treatment
process.
EPA disagrees. The inability to effectively verify in-situ
treatment precludes the commentors from being able to
substantiate their claim that their proposed technology would
provide a "high degree of control" over the treatment process.
Ex-situ treatment as proposed by EPA in the Proposed Plan would
provide a higher degree of control.
* The neutralization process proposed herein will allow for
control of potential emissions from the treatment, as well as
minimizing worker exposure to the waste constituents, resulting
in greater short-term effectiveness than EPA's ex-situ remedies.
EPA agrees that in-situ treatment could potentially provide a
greater short-term effectiveness than ex-situ treatment in terms
of potential emissions. However, EPA believes that the increase
in short-term effectiveness would be out-weighed by a
substantial decrease in long-term effectiveness.
* Both remedies meet all of the stated remedial action objectives
for the Pit Area. Neither remedy will achieve the numerical
remedial goals for carcinogenic PAHs or PCBs. Therefore, the
remedies offer equivalent long-term effectiveness.
EPA disagrees. The commentors suggested remedy does not address
the potential for contaminant migration to the groundwater (one
of the remedial action objectives for the oily sludge pit area).
EPA believes that the remedy selected in this ROD will achieve
the remediation goals established in Appendix B to the ROD. The
commentors' suggested remedy will not achieve the remediation
goals. In addition, removal of the waste material from the site
with disposal of waste residues at a facility permitted to
accept these wastes provides for greater long-term effectiveness
than in-situ treatment providing "some chemical stabilization"
with the waste remaining in an uncontained, unpermitted facility
(i.e., the site).
* Both remedies offer reduction in toxicity and mobility of
contaminants of concern. Both remedies also result in an
overall increase in waste volume. A larger increase in waste
volume would likely be realized under the EPA remedy because of
the need to add reagents on two occasions.
EPA disagrees. If the in-situ treatment would work, then the
first two sentences of this comment are correct. However, due
to the inefficiency of in-situ stabilization techniques, a large
volume of reagents would be required to compensate for the
overlap needed to cover 100% of the area and volume of the waste
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103
matrix (assuming uniform radial coverage). Therefore, the
volume of reagents required to assure complete coverage under
the PRP plan could potentially equal or exceed the volume
required under the EPA plan.
* This remedy can be completed in a much shorter time frame (3 to
4 months vs. 12 construction months for EPA''s preferred remedy)
making it a more attractive remedy from a statutory standpoint.
In addition, this means that potential flood waters and high
water table will have less of an impact.
The EPA's plan provides for pretreatment on-site followed by
additional treatment on the land side of the levee. This
procedure could be accomplished in the same time frame as the
PRPs' proposed plan. Therefore, protection from flood water and
high groundwater conditions would be equally realized by both
remedies.
* The PRP Group's proposed remedy will eliminate the need for
transportation of waste off-site (with over 1500 tractor
trailers through Nest Memphis) and comply with the NCP
preference for on-site handling of wastes at NPL sites.
EPA agrees with the first part of the comment but disagrees with
the latter part. The alternative selected in this ROD also
utilizes on-site handling of the waste; only final disposal
would be conducted off-site. Also, as noted in EPA's response
to comments 80 and 87, EPA does not believe that it is
appropriate to dispose of the oily sludge pit waste on the site.
* The cost for this remedy is significantly less than the cost for
implementing EPA's proposed remedy.
EPA agrees. However, it should be noted that EPA's proposed
remedy meets the remedial action objectives while complying with
the ARARs while the PRP's plan does not comply with ARARs or
meet the remedial action objectives. Therefore, the two
alternatives cannot legitimately be compared side to side on the
basis of cost alone.
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APPENDIX A
Index of Administrative Record
104
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
105
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
1 AR PAGE NUMBER: 002049 - 002053
Undated
005
Office of Research and Development:
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Agency Guidelines
"Guidelines for Effective Stabilization Currently Being
Considered by U.S. EPA's Office of Research and Development'
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:'
DOCUMENT TYPE:
DOCUMENT TITLE:
2 AR PAGE NUMBER: 000027 - 000039
07/02/82
013
Dave Peters, Chief, Hazardous Waste Section
U.S. EPA Region 6
Sam Nott, Chief, Enforcement Section, U.S.'EPA Region 6
Transmittal memo w/attached report
Boring and Sampling Program field report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
3 AR PAGE NUMBER: 008457 - 008503
01/01/84
047
Renate D. Kimbrough, et al.
Journal of Toxicology and Environmental Health
U.S. EPA Region 6 Superfund Site File
Journal Article
"Health Implications of 2, 3 , 7, 8-Tetrachlorodibenzodioxin
(TCDD) Contamination of Residential Soil"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
4 AR PAGE NUMBER: 000040 - 000040
10/29/85
001
Joe Roberto
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Tentative Disposition
Summary of initial investigation and recommendations for
action, such as preparing a preliminary Hazard Ranking System
(HRS) package
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
106
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
5 AR PAGE NUMBER: 000041 - 000048
01/27/87
008
Rashid A. Khalid
Roy F. Weston, Inc.
Pat Hammack, On-Scene Coordinator (OSC) , Emergency Response
Branch (ERB), U.S. EPA Region 6
Emergency Response Report
Sludge and soil sampling report from the West Memphis Landfill
DOCUMENT NUMBER:
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6 AR PAGE NUMBER: 000049 - 000053
02/13/87
005
Dorothy C. Lane, Ph.D., Projecc Manager
Western Research Institute
Roy F. Weston, Inc.
QA Report, Case Narrative, Case SAS 2636F
Laboratory quality assurance information relating to soil
sampling conducted by Technical Assistance Team (TAT), results
reflected in 01/27/87 ERB report
DOCUMENT NUMBER:
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7 AR PAGE NUMBER: 000054 - 000064
06/19/87
Oil
Donald M. Smith, TAT
Ecology & Environment, Inc. (E&E)
Pat Hammack, OSC, ERB, U.S. EPA Region 6
Emergency Response Report
Compilation of laboratory data from the March 1987 site
investigation
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RECIPIENT:
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DOCUMENT TITLE:
8 AR PAGE NUMBER: 000065 - 000163
05/17/88
099
Jean Koeninger, Field Investigation Team (FIT) Geologist
E&E
David Wineman, Remedial Project Officer (R-PO) U.S. EPA Region
6
Field Sampling Report
Results of soil, ground water, surface water, pit, and air
sampling conducted for the proposed Hazardous Ranking System
(HRS) II Package
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ARD 980496723
107
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9 AR PAGE NUMBER: 000164 - 000188
08/29/88
025
Brian K. Boerner, FIT Chemist
E&E
David Wineman, RPO, U.S-. EPA Region 6
Memorandum
Proposed air sampling strategy for October 1988
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RECIPIENT:
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DOCUMENT TITLE:
10 AR PAGE NUMBER: 000189 - 000201
12/27/88
013
Brian K. Boerner, FIT Chemist
E&E
David Wineman, RPO, U.S. EPA Region 6
Memorandum
Results of air sampling conducted October 3-7, 1988
DOCUMENT NUMBER:
DOCUMENT DATE:
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DOCUMENT TITLE:
11 AR PAGE NUMBER: 002054 - 002055
03/31/89
002
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance - Interim Final
"Risk Assessment Guidance for Superfund: Volume 2 -
Environmental Evaluation Manual"; (EPA/540/1-89/001) (This
document may be reviewed at U.S. EPA Region 6)
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
12 AR PAGE NUMBER: 000001 - 000026
05/31/89
026
Office of Waste Programs Enforcement
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Compendium of Guidance: Users Manual
Guidance to documents used by EPA in selecting a response
action
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SITE NUMBER:
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DOCUMENT DATE:
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DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
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RECIPIENT:
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DOCUMENT TITLE:.
DOCUMENT NUMBER:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX 108
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARC 980496723
13 AR PAGE NUMBER: 002056 - 002057
12/31/89
002
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance - Interim Final
"Risk Assessment Guidance for Superfund: Volume 1 - Human
Health Evaluation Manual (Part A)"; (EPA/540/1-89/002) (This
document may be reviewed at U.S. EPA Region 6)
14 AR PAGE NUMBER: 002058 - 002059
12/31/89
002
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance for Superfund - Interim
Volume 1 - "Human Health Evaluation Manual (Part B,
Development of Risk-based Preliminary Remediation Goals)";
(Publication 9285.7-01B) (This document may be reviewed at
U.S. EPA Region 6)
15 AR PAGE NUMBER: 002060 - 002061
12/31/89
002
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance for Superfund - Interim
Volume 1 - "Human Health Evaluation Manual, (Part C, Risk
Evaluation of Remedial Alternatives)"; (Publication
9285.7-01C) (This document mav be reviewed at U.S. EPA Region
6)
16 AR PAGE NUMBER: 000202 - 000224
07/27/90
023
EPA Staff
U.S. EPA Headquarters
U.S. EPA Region 6 Site Files
Federal Register/ Vol. 55, No. 145/ Proposed Rules
Technical data relating to cleaning levels for various
hazardous substances
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ADMINISTRATIVE RECORD INDEX
FINAL
109
SITE NAME: SOUTH 8TH STREET LANDFILL SITE
SITE NUMBER: ARD 980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
17 AR PAGE NUMBER: 002062 - 002365
02/28/91
304
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
EFA Guidance Document
"Conducting Remedial Investigations/Feasibility Studies for
CERCLA Municipal Landfill Sites"; (EPA/540/P-91/001)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
18 AR PAGE NUMBER: 001952 - 002007
03/22/91
056
Sally Mansbach, Acting Director, CERCLA Enforcement Division
U.S. EPA - Washington, D.C.
Remedial Administrative Record Coordinators - Regions I-X
CERCLA Administrative Records Compendium of Guidance - Us
"CERCLA Administrative Records: First Update of the Compendium
of Documents Used for Selecting CERCLA Response Actions"
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
19 AR PAGE NUMBER: 000225 - 000284
12/10/91
'060
Abbott C. Widdicombe
Property Owner, West Memphis, AR
David Weeks, Remedial Project Manager (RPM), U.S. EPA Region 6
Correspondence and Attachment
General site history information
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TITLE:
20 AR PAGE NUMBER: 000285 - 000285
01/02/92
001
David Weeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Record of Communication (ROC)
Phone conversation with Jim Covington (Director, Planning and
Development, West Memphis, AR) to request a meeting between
EPA, the Mayor, and other city officials
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SITE NUMBER:
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SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
110
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
21 AR PAGE NUMBER: 000286 - 000286
01/15/92
001
David Weeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
Status of EPA activities at Wesc Memphis Site
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
22 AR PAGE NUMBER: 002366 - 002401
01/15/92
036
Gregory Day, Region 6 Technical Assistance Team (TAT)
Ecology and Environment, Inc.
Mike Ryan, On-Scene Coordinator (OSC), Emergency .Response
Branch, U.S. EPA Region 6
Site Assessment and Attachments
Site Assessment for West Memphis Landfill, West Memphis,
Crittenden County, AR
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
AR PAGE NUMBER: 000287 - 000287
23
01/31/92
001
David Weeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
"Documentation of Site Visit"
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
24 AR PAGE NUMBER: 000288 - 000299
02/06/92
012
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Mr. W.M. Gurley
General Notice Letter/104(e) Information Request
Re: 1) Notification of potential liability/potential response
activities Mr. Gurley may be requested to perform or finance;
and 2) request for information regarding site activities
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FINAL
111
SITE NAME: SOUTH 8TH STREET LANDFILL SITE
SITE NUMBER: ARD 980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
25 AR PAGE NUMBER: 000300 - 000312
02/06/92
013
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Addressees
General Notice Letter/104(e) Information Request
Re: 1) Notification of potential liability/potential response
activities addressees may be requested to perform or finance;
and 2) request for information regarding site activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
26 AR PAGE NUMBER: 000313 - 000313
02/11/92
001
Harold Lashner, Controller
Northern Shipping Company
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
General Notice Response Letter
Response to EPA 02/06/92 104(e) General Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
27 AR PAGE NUMBER: 000314 - 000314
02/14/92
001
W.L. Reid, Jr.
Landowner of property adjoining West Memphis, AR Landfill Site
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to EPA 02/06/92 104(e) Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
28 AR PAGE NUMBER: 000315 - 000325
02/19/92
Oil
Ralph McFerrin, Owner
Tri-State Adhesives & Resins
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to 02/06/92 EPA 104(e) Letter
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARC 980496723
112
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
29 AR PAGE NUMBER: 000326 - 000328
02/20/92
003
James Day, Director of Administration and Secretary
Truman Arnold Companies (TAG)
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to EPA 02/06/92 L04(e) Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
30 AR PAGE NUMBER: 000329 - 000329
02/21/92
001
David Weeks, RPM
U.S. EPA Region 6
Wilce Rawles, International Paneling Products, Inc. (IPPI)
ROC
IPPI's potential responsible party (PRP) status
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
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DOCUMENT TITLE:
31 ., AR PAGE NUMBER: 000330 - 000331
02/21/92
002
Cheryl Followell and Connie Brandenburg
Property Owners, West Memphis, AR
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to EPA 02/06/92 104(e) Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
32 AR PAGE NUMBER: 000332 - 000455
02/25/92
124
Martha Horvitz
Borden, Inc.
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice.Letter Response
Response to EPA 02/06/92 104(e) Notice Letter
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SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
113
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
33 AR PAGE NUMBER: 000456 - 000457
02/25/92
002
David Weeks, RPM
U.S. EPA Region 6
Helen Tracy, Attorney for Sun Company, Inc.
Correspondence
Regarding Sun Company' s 02/12/92 verbal request for an
extension of time to respond to 02/06/92 104(e) General Notice
Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
34 AR PAGE NUMBER: 000458 - 000531
02/25/92
074
Gary Simpson, Attorney-at-Law
Attorney for Coastal Unilube
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Coastal Unilube' s partial response to questions 1 through 32
of EPA 02/06/92 CERCLA 104(e) Letter; request for an
additional 30 days to file supplemental responses
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
35 AR PAGE NUMBER: 000532 - 000599
02/26/92
068
Helen Tracy, Law Department
Sun Refining and Marketing Company
David Weeks, RPM, U.S. EPA Region' 6
104(e) General Notice Letter Response/Attachments
Response to questions 21 and 22 of EPA 104(e) General Notice
Letter
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DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
36 AR PAGE NUMBER: 002402 - 002405
02/26/92
004
Mary Aronov, Attorney
Law Offices of Heiskell, Donelson, Bearman, Adams, Williams &
Kirsch (for Nortek, Inc.)
David Weeks, Remedial Project Manager (RPM), U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information Letter
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SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
114
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DOCUMENT TITLE:
37 AR PAGE NUMBER: 000600 - 000621
02/27/92
022
James Gentry, Jr., Attorney
Law Offices of Spears, Moore, Rebman & Williams, Inc.
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Respondent refuses to respond for Mr. Gurley and returns
104(e) information request
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
38 AR PAGE NUMBER: 000622 - 000624
02/28/92
003
Wilce Rawles, President
IPPI
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Persuant to telephone conversation of 02/21/92
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
39 AR PAGE NUMBER: 008453 - 008454
02/28/92
002
Office of Emergency and Remedial Response
U.S. EPA - Headquarters
U.S. EPA Region 6 Superfund Site Files
Guidance - Volume 1, Summary Report
"Evaluation of Ground Water Extraction Remedies: Phase II";
(Publication 9355.4-05, PB92-963346) (Document may be reviewed
at U.S. EPA Region 6)
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
40 AR PAGE NUMBER: 008455 - 008456
02/28/92
002
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Guidance - Case Studies and Updates, Volume 2
"Evaluation of Ground Water Extraction Remedies: Phase II"
(Publication 9355.4-05A, PB92-963347) (Document may be
reviewed at U.S. EPA Region 6)
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ARD 980496723
115
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
41 AR PAGE NUMBER: 000625 - 000635
03/02/92
Oil
David Peeples, City Attorney
City of West Memphis, AR
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to EPA 02/06/92 104(e) Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
42 AR PAGE NUMBER: 002406 - 002406
03/02/92
001
Harold Lashner, Controller
Northern Shipping Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
43 AR PAGE NUMBER: 000636 - 000718
03/05/92
083
Sam Blair, Jr.
Heiskell, Donelson, Beannan, Adams,
Attorneys for William L. Johnson Co
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response t3 02/06/92 EPA 104(e) Notice Letter
Williams & Kersch -
, Inc.
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
44 AR PAGE NUMBER: 000719 - 000733
03/11/92
015
Robert Jacobsen, Vice President
Aero-Data Corporation
Jonathan Stewart, Fluor Daniel, Inc.
Correspondence and Attachment
"A Historical Aerial Photography Analysis of West Memphis
Landfill Site, West Memphis, TN~
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COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
45 AR PAGE NUMBER: 000734 - 000743
03/18/92
010
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
President, Chevron U.S.A., Inc., c/o The Corporation Company
Combined General/Special Notice Ltr./Info. Request Ltr.
104(e) General Notice, 104(e) Information Request and Special
Notice Letter (Enclosures omitted)
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DOCUMENT DATE:
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AUTHOR:
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DOCUMENT TITLE:
46 AR PAGE NUMBER: 000744 - 000915
03/18/92
172
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
List of Addressees
Special Notice Letter
EPA Special Notice Letter, Draft RI/FS Work Plan and Draft
Administrative Order on Consent for performance of Remedial
Investigation/Feasibility Study (RI/FS)
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
47 AR PAGE NUMBER: 000916 - 000931
03/23/92
016
Gary Simpson, Attorney-at-Law
Attorney for Coastal Unilube
David Weeks, RPM, U.S. EPA Region 6
Supplemental 104(e) General Notice Ltr. Response
Coastal Unilube' s supplemental answers to questions 1 through
32 of EPA 02/06/92 CERCLA 104(e) Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
48 AR PAGE NUMBER: 000932 - 000953
03/26/92
022
Ralph McFerrin, Owner
Tri-State Adhesives & Resins
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to EPA Notice Letter received on 03/23/92
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
49 AR PAGE NUMBER: 002407 - 002414
03/26/92
008
Harold Lashner, Controller
Northern Shipping Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachments
Response to U.S. EPA 104(e) Request for Information Letter
DOCUMENT NUMBER:
DOCUMENT DATE:'
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
50 AR PAGE NUMBER: 000954 - 000955
03/27/92
002
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Cheryl Followell, Property Owner, West Memphis, AR
Correspondence
EPA response to Ms. Followell's 02/21/92 104(e) Response
Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
51 AR PAGE NUMBER: 000956 - 000957
03/27/92
002
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Connie Brandenburg, Property Owner, West Memphis, AR
Correspondence
EPA response to Ms. Brandenburg's 02/21/92 104(e) Response
Letter
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
52 AR PAGE NUMBER: 000958 - 000959
04/10/92
002
Steve Dehmer
Chevron Corporation
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice/Special Notice Ltr. Response
Response to 02/06/92 EPA 104(e) Notice Letter
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53 AR PAGE NUMBER: 002415 - 002419
04/10/92
005
Steve Dehmer
Chevron Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information
Letter/General Notice Letcer dated 03/18/92 (Cover Letter also
included in 01/26/93 Administrative Record as Document No.
000958-000959.)
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
54 AR PAGE NUMBER: 000960 - 000976
04/16/92
017
David Ueeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Citizens' Meeting
Copies of overhead projector transparencies from the
"Citizens' Scoping Meeting" and RPM's notes indicating subject
matter discussed
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
55 AR PAGE NUMBER: 000977 - 001008
04/21/92
032
Cheryl Followell
Property Owner, West Memphi-s, AR
David Weeks, RPM, U.S. EPA Region 6
104(e) General Notice Letter Response
Response to EPA 02/06/92 104(e) Letter on behalf of Cheryl
Followell and Connie Brandenburg
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56 AR PAGE NUMBER: 001009 - 001070
04/22/92
062
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Attached Addressee List
Correspondence and Attachment
"Location of Exploratory Trenches" and "Rationale for the
Placement of Piezometers and Ground Water Monitoring Wells"
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57 AR PAGE NUMBER: 008504 - 008504
04/22/92
001
Lenice Watkins, Staff Writer
West Memphis Evening Times
Public
News Article
"Accused dumpers protest EPA pollution accusations'
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58 AR PAGE NUMBER: 001071 - 001083
04/24/92
013
David Weeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Memorandum
Information received from Coastal Unilube 04/16/92 meeting
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59 AR PAGE NUMBER: 001084 - 001757
04/29/92
674
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6 Site Files
Work Plan
First revision of the RI/FS Work Plan
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60 AR PAGE NUMBER: 001758 - 001782
04/29/92
025
David Weeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Access Agreements
"Voluntary Access Agreements" signed by various land owners
granting EPA access to property
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61 AR PAGE NUMBER: 001783 - 001785
04/29/92
003
David Weeks, RPM
U.S. EPA Region 6
Attached List of Addressees
Cover Letter and Attached List (Work Plan not attached.)
Re: First revision of the RI/FS Work Plan which describes the
work to be performed for South 8th Street
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62 AR PAGE NUMBER: 001786 - 001786
05/04/92
001
David Weeks, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
ROC
Meeting with the South 8th Street PRPs regarding the status of
EPA's activities at the site
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63 AR PAGE NUMBER: 001787 - 001795
05/07/92
009
Gary L. Simpson
Attorney for Coastal Unilube
David Weeks, RPM, U.S. EPA Region 6
Supplemental 104(e) General Notice Ltr. Response
Coastal Unilube's third set of answers co question 1 through
32 of EPA 02/06/92 CERCLA 104(e) Letter supplementing their
02/25/92 and 03/23/92 responses
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64 , AR PAGE NUMBER: 002420 - 002429
05/11/92
Oil
Craig Carroll, OSC
U.S. EPA Region 6
B.J. Wynne, Regional Administrator, U.S. EPA Region 6
Memorandum and Attachment
Request for removal action ("Enforcement Confidential"
attachment is not included)
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65 AR PAGE NUMBER: 001796 - 001796
05/13/92
001
William P. Rainey
Attorney for Coastal Unilube
Rachel Blumenfeld, Office of Regional Counsel (ORC), U.S. EPA
Region 6
Correspondence
Fencing of the South 8th Street Landfill Site
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66 AR PAGE NUMBER: 001797 - 001826
05/22/92
030
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
W.M. Gurley, Memphis, TN
Correspondence and copy of UAO issued to PRPs
Unilateral Administrative Order (UAO) for Removal Action
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AR PAGE NUMBER: 001827 - 001829
67
05/26/92
003
Steve Dehmer
Chevron Corporation
Rachel Blumenfeld, ORC, U.S
Correspondence
"UAO for Removal Action"
EPA Region 6
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68 AR PAGE NUMBER: 001830 - 001834
05/27/92
005
David Richman, Attorney for Sun Company, Inc., Sun Pipeline
Co. , and Sunray DX Oil Co.
Pepper, Hamilton & Scheetz
Rachel Blumenfeld, Assistant Regional Counsel, Office of
Regional Counsel, U.S. EPA Region 6
Correspondence
Re: UAO for Removal Action
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69 AR PAGE NUMBER: 001835 - 001837
05/27/92
003
Gary Simpson
Attorney for Coastal Corporation
Rachel Blumenfeld, ORC, U.S. EPA Region 6
Correspondence
UAO for Removal Action*
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70 AR PAGE NUMBER: 001838 - 001849
05/30/92
012
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Community Relations Plan
"Community Relations Plan for the South 8th Street Landfill
Superfund Site"
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71 AR PAGE NUMBER: 001850 - 001891
06/18/92
042
Charles T. Wehland
Jones, Day, Reavis & Pogue
Rachel H. Blumenfeld, ORC, U.S. EPA Region 6
Response to UAO
Requests that EPA amend the referenced Order so that Borden
and Perkins Industries, Inc. are no longer named as
respondents
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72 AR PAGE NUMBER: 001892 - 001895
07/06/92
004
David Weeks, RPM
U.S. EPA Region 6
Craig Carroll, U.S. EPA Region 6
Memorandum
RPM' s comments regarding the Removal Investigation Work Plan
prepared by the PRPs
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73 AR PAGE NUMBER: 001896 - 001951
08/06/92
056
Helen Tracy, Law Department
Sun Company, Inc.
David Weeks, RPM, U.S. EPA Region 6
Supplemental Response to 104(e) Information Request Ltr.
Supplemental response by Sun Company Inc., Sun Pipeline Co.,
and Sunray DX Oil Co. to EPA's information request
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74 AR PAGE NUMBER: 002430 - 002484
09/09/92
053
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
See Attached Addressee List
104(e) Request for Information/General Notice Letter
1) Notification of potential liability incurred at the site
and of possible participation in response activities; and 2)
request to provide information regarding addressees'
activities at the site
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75 AR PAGE NUMBER: 002485 - 002485
09/14/92
001
W.N. Taylor III. President
Memphis Machine Works
.David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e)/General Notice Letter dated
09/09/92
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76 AR PAGE NUMBER: 002486 - 002486
09/15/92
001
W.M. Gurley
Gurley Refining Company, Inc.
U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notics Letter dated 09/09/92
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77 AR PAGE NUMBER: 002487 - 002558
09/15/92
072
John Mueller, Region 6, TAT
Ecology and Environment, Inc.
Craig Carroll, OSC, Emergency Response Branch, U.S. EPA Region
6
Site Assessment and Attachments
Site Assessment: West Memphis Landfill Site, West Memphis,
Crittenden County, AR
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78 AR PAGE NUMBER: 002559 - 002559
09/16/92
001
Marcia K. Cowan, Associate Counsel
Kimberly-Clark Corporation
David Weeks, RPM, U.'s. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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79 ' AR PAGE NUMBER: 002560 - 002560
09/18/92
001
Wendy S. Fisher, Vice President/General Counsel
Schilling Enterprises
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e)/General Notice Letter dated
09/09/92
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80 AR PAGE NUMBER: 002561 - 002562
09/18/92
002
Monice Moore Hagler, City Attorney, Law Division
City of Memphis, Tennessee
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information
Letter/General Notice Letter dated 09/09/92
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81 AR PAGE NUMBER: 002563 - 002563
09/21/92
001
Robert M. Myers, Secretary/Treasurer
Tri-State Mack
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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AR PAGE NUMBER: 002564 - 002564
82
09/21/92
001
Lance S. Tolson,
Texaco, Inc.
David Weeks, RPM,
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
Attorney
U.S. EPA Region 6
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83 AR PAGE NUMBER: 002565 - 002565
09/21/92
001
William C. Lowrey, Senior Attorney, Environmental &
Manufac tur ing
Shell Oil Company
David Weeks, RPM", U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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84 AR PAGE NUMBER: 002566 - 002567
09/21/92
002
Allen T. Malone, Attorney
Law Offices of Apperson, Crump, Duzane & Maxwell (for Memphis
Area Transit Authority)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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85 AR PAGE NUMBER: 002568 - 002568
09/21/92
001
C. Barry Ward, Attorney
Law Offices of Glankler, Brown, Gilliland, Chase, Robinson &
Raines .(for Hull Dobbs Ford)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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86 AR PAGE NUMBER: (502569 - 002569
09/21/92
001
Ben M. Hogan, President
Hogan Construction Company, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUKEiR OF PAGES:
.-.;-.:OR:
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RECIPIENT:
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87 AR PAGE NUMBER: 002570 - 002571
09/21/92
002
James L. Conner II, Attorney
Brooks, Pierce, McLendon, Humphrey & Leonard, Attorneys at Law
(for Halstead Industries, Inc.)
Rachel H. Blumenfeld, Office of Regional Counsel (ORC), U.S.
EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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88 AR PAGE NUMBER: 002572 - 002573
09/21/92
002
Barbara A. Hindin, Attorney
Shaw, Pittman, Potts & Trowbridge (for Emerson Eleccric Co.)
Rachel H. Blumenfeld, ORC, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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89 AR PAGE NUMBER: 002574 - 002575
09/22/92
002
Brett Hughes, Senior Attorney
The Williams Companies, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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90 AR PAGE NUMBER: 002576 - 002576
09/22/92
001
Barry B. Walton, Senior Attorney
Tennessee Valley Authority (TVA)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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91 AR PAGE NUMBER: 002577 - 002578
09/22/92
002
Charlotte A. Knight, Attorney at Law
Memphis Light, Gas and Water Division
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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92 AR PAGE NUMBER: 002579 - 002579
09/28/92
001
Eugene F. Jordan, Associate General Counsel
Brown Group, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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93 AR PAGE NUMBER: 002580 - 002590
09/30/92
010
Craig Carroll, OSC
U.S. EPA Region 6
Russell F. Rhoades, Director, Environmental Services Division,
U.S. EPA Region 6
Action Memorandum
Request for removal action at the South Eighth Street Landfill
(a.k.a. West Memphis Landfill) Site ("Enforcement
Confidential" attachment is not included)
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AR PAGE NUMBER: 002591 - 002592
94
10/06/92
002
Victor E. Toledo,
Greyhound Lines,
David Weeks, RPM,
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
Legal-Environmental Management
Inc.
U.S. EPA Region 6
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95 AR PAGE NUMBER: 002593 - 002593
10/13/92
001
Bill Yendt, Manufacturing Engineer
Hoffinger Industries, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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DOCUMENT DATE:
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AUTHOR:
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96 AR PAGE NUMBER: 002594 - 002599
10/13/92
006
Donald E. Bourland, Esquire
Rickey, Bourland, Heflin, & Alverez, Attorneys at Law (for
Federal Compress & Warehouse Co., Inc.)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. 7.PA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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97 AR PAGE NUMBER: 002600 - 002601
10/15/92
002
Roberr L. Hutton, General Counsel
Glankler, Brown, Gilliland, Chase, Robinson & Raines (for
Chuck Hutcon Chevrolet)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR: .
COMPANY/AGENCY:
RECIPIENT:
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98 AR PAGE NUMBER: 002602 - 002689
10/16/92
088
John Mueller, Region'6, TAT
Ecology and Environment, Inc.
Craig Carroll, OSC, Emergency Response Branch, U.S. EPA Region
6
Oversight Report
Potentially Responsible Party (PRP) Oversight Report
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99 AR PAGE NUMBER1: 002690 - 002699
10/16/92
010
Ronald T. Allen, Senior Counsel
Georgia-Pacific Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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DOCUMENT DATE:
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AUTHOR:
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AR PAGE NUMBER: 002700 - 002702
10/19/92
003
W. Brigham Klyce Jr., President
White Rose, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter
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101 AR PAGE NUMBER: 002703 - 002704
10/23/92
002
Steven Case, Attorney
McGrach, North, Mullin & Kracz, P.C. (for Armour Food Company)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
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102 AR PAGE NUMBER: 002705 - 002708
10/23/92
004
Neal S. Brody, Senior Attorney
Atlantic Richfield Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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103 AR PAGE NUMBER: 002709 - 002716
10/26/92
008
Mary C. Bryant, Attorney
Brown & Bryant, P.C., Attorneys at Law (for Illinois Central
Railroad)
David Weeks, RPK, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
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104 AR PAGE NUMBER: 002717 - 002720
10/27/92
004
Joseph M. Holden, Attorney
Brouse & McDowell (for Mohawk Rubber Company)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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105 AR PAGE NUMBER: 002721 - 002724
10/28/92
004
Thomas P. O'Brien Jr., Law Department
The Kroger Co.
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
106 AR PAGE NUMBER: 002725 - 002730
10/28/92
006
James R. Sowell, Corporate Engineer
Baldwin -Piano & Organ Company ("Baldwin")
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
107 AR PAGE NUMBER: 002731 - 002735
10/28/92
005
Robert M. Myers. Secretary-Treasurer
Tri-State Mack
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
108 AR PAGE NUMBER: 002736 - 002745
10/28/92
010
Gail Helfrick, Environmental Health and Safety Department,
Superfund Response Group
Mobil Oil Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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109 AR PAGE NUMBER: 002746 - 002848
10/29/92
103
Kenneth Lund, Attorney
Holme Roberts & Owen (for St. Louis Southwestern Railway
Company, a.k.a. Cotton Belt Railroad)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachments
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
110 AR PAGE NUMBER: 002849 - 002850
10/29/92
002
Steven D. Stern, General Attorney, Corporate Law Department
Sara Lee Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
111 AR PAGE NUMBER: Q02851 - 002859
10/29/92
009
Dave Yesland, Environmental Support & Regulations
Shell Oil Company
David Weeks, RPM', U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCL~:ZNT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
112 ' AR PAGE NUMBER: 002860 - 002863
10/29/92
004
Jess Askew III, Attorney
Rose Law Firm (for J.A. Riggs Tractor Company, Inc.)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
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ARD 980496723
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
113 AR PAGE NUMBER: 002864 - 002880
10/29/92
017
Richard J. Ualsh, Esq.
Phillips Petroleum Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
114 AR PAGE NUMBER: 002881 - 002883
10/29/92
003
Judie Koopmans, Legal Assistant
Owens/Corning Fiberglas Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
115 AR PAGE NUMBER: 002884 - 002892
10/29/92
009
T.W. Ambler, General Attorney
Norfolk Southern Railway Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
116 AR PAGE NUMBER: 002893 - 002896
10/29/92
004
Daniel S. Pupel Jr., Senior Attorney
Kellogg Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
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ARD 980496723
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RECIPIENT:
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117 AR PAGE NUMBER: 002897 - 002902
10/29/92
006
Barbara A. Hindin, Attorney
Shaw, Pittman, Potts & Trowbridge (for Emerson Electric Co.)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
118 AR PAGE NUMBER: 002903 - 002907
10/29/92
005
Ellen A. Green, Senior Legal Assistant
E.I. du Pont de Nemour & Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
119 AR PAGE NUMBER: 002908 - 002922
10/29/92
015
Lance S. Tolson, Attorney
Texaco, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachments
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT DUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TITLE:
120 AR PAGE NUMBER: 002923 - 002927
10/30/92
005
J.B. Malone, P.E., Head, Installation Branch, Restoration
Branch
U.S. Department of the Navy (for Naval Air Station, Memphis)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to EPA 104(e) Request for Information/General Notice
Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
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121
AR PAGE NUMBER: 002928 - 002934
10/30/92
007
Clinton Wilier, Colonel, Corps of Engineers, District Engineer
U.S. Department of the Army (for Memphis District, Corps of
Engineers)
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Response Letter and Attachments
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
122 AR PAGE NUMBER: 002935 - 002935
10/30/92
001
J. Patrick Boland, Counsel
Exxon Company, USA ("Exxon")
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
123 AR PAGE NUMBER: 002936 - 002939
10/30/92
004
Walter W. Grim, Assistant Counsel
Union Oil Company of California dba Unocal Corporation
David Weeks, RPM', U.S. EPA Region 6
Response Letter
Res-t;nse to U.S. EPA 104(e) Request for Information/General
Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
124 AR PAGE NUMBER: 002940 - 002953
10/30/92
014
Barry Turner, Deputy Attorney General
Office of Attorney General, State of Tennessee (for Memphis
State University)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
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DOCUMENT NUMBER:
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COMPANY/AGENCY:
RECIPIENT:
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125 AR PAGE NUMBER: 002954 - 002967
10/30/92
014
Randall £. Uomack, Attorney
Glankler, Brown, Gllliland, Chase, Robinson & Rains (for
Shelby County Airport Authority)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
126 AR PAGE NUMBER: 002968 - 002987
10/30/92
020
Frederick L. Hitchcock, Attorney
Strang^ Fletcher, Carriger, Walker, Hodge & Smith (for Memphis
Light, Gas & Water Division)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
127 AR PAGE NUMBER: 002988 - 003001
10/30/92
014
Bruce M. Smith, Attorney
Law Offices of Apperson, Crump, Duzane & Maxwell (for Memphis
Area Transit Authority)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
128 AR PAGE NUMBER: 003002 - 003003
10/30/92
002
Carol A. Grissom, Attorney
Law Offices of Boone, Smith, Davis, Hurst & Dickman (for AMR
Services)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
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DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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129 AR PAGE NUMBER: 003004 - 003009
10/30/92
006
Jack C. Shih, Senior Environmental Engineer
Navistar International Transportation Corp.
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachments
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
130 AR PAGE NUMBER: 003010 - 003012
10/30/92
003
Neal T. Rountree, Attorney
The Goodyear Tire & Rubber Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
131 AR PAGE NUMBER: 003013 - 003022
10/30/92
010
Eugenia Jones, Manager, Environmental Systems
Frito-Lay, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
132 AR PAGE NUMBER: 003023 - 003029
10/30/92
007
Anne Blythe Little, Assistant General Counsel, Law Department
Burlington Northern Railroad
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
138
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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133 AR PAGE NUMBER: 003030 - 003030
10/30/92
001
Steven J. Poplawski, Attorney
Law Firm of Bryan Cave (for Brown Shoe Company)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Request for extension of time to respond to U.S.
EPA 104(e)
Request for Information/General Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
134 AR PAGE NUMBER: 003031 - 003046
10/30/92
014
Barry B. Walton, Senior Attorney
TVA
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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135 AR PAGE NUMBER: 003047 - 003048
11/02/92
002
C.R. Wilcox, Director of Installation Operations
Department of the Army, Red River Army Depot
David Weeks, RPM, U.s". EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
136 AR PAGE NUMBER: 003049 - 003057
11/06/92
009
Eugene F. Jordan, Associate General Counsel
Brown Group, Inc.
David Weeks. RPM, U.S. EPA Region 6
Response Le~er and Attachments
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
139
DOCUMENT NUMBER:
DOCUMENT .DATE:
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AUTHOR:
COMPANY/AGENCY:
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137 AR PAGE NUMBER: 003058 - 003071
11/09/92
014
Diana Hull, Associate Division Counsel
Ryder System, Inc. (for Ryder Truck Rental, Inc.)
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
138 AR PAGE NUMBER: 003072 - 003082
11/13/92
Oil
Nicholas W. Hetman, Senior Attorney
Texas Gas Transmission Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
139 AR PAGE NUMBER: 003083 - 003087
11/13/92
005
Virginia E. Carlson, Staff Counsel
The Hertz Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information
Letter/General Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
140 AR PAGE NUMBER: 003088 - 003093
11/16/92
006
Clarence Gillespie III, Manager - Environmental Services
Fruehauf Trailer Corporation
David Weeks, RPM, U.S. EPA Region 6
Response Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
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ARD 980496723
140
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
141 AR PAGE NUMBER: 003094 - 003095
12/16/92
002
Bradford Wright, President
Western Real Estate Services
David Weeks, RPM, U.S. EPA Region 6
Correspondence and Attachment
Information on date of incorporation of Mr. Wright's company
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TYPE:
DOCUMENT TITLE:
142 AR PAGE NUMBER: 003096 - 003256
01/07/93
161
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
See Attached Addressee List
Notice of Decision Not to Use Special Notice Procedures
Notice of Decision Not to Use Special Notice Procedures and
Draft Administrative Order on Consent for Engineering
Evaluation/Cost Analysis
•DOCUMENT NUMBER:
DOCUMENT DATE:
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143 AR PAGE NUMBER: 003257 - 003268
01/15/93
012
Tom Metzler, President
AMR Combs, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e)/General Notice Letter dated
09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
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144 AR PAGE NUMBER: 003269 - 003272
02/08/93
004
William G. Ross Jr., Attorney
Brooks, Pierce, McLendon, Humphrey & Leonard (for Mohasco
Corp. and Chromcraft Revington, Inc.)
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to EPA 104(e) Request for Information/General Notice
Letter dated 09/09/92
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
SOUTH 8TH STREET LANDFILL SITE
ARD 980496723
141
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RECIPIENT:
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145 AR PAGE NUMBER: 003273 - 003274
02/22/93
002
Richard Walsh, Esq.
Phillips Petroleum Company ("Phillips")
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Phillips' response to U.S. EPA Notice of Decision Not To Use
Special Notice Procedures Letter dated 01/15/93
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
146 AR PAGE NUMBER: 003275 - 003275
02/24/93
001
Donna Mullins, PCB Case Development Officer
U.S. EPA Region 6
David Weeks, RPM, U.S. EPA Region 6
Memorandum
"Toxic Section Comments on Applicability of PCB Regulations to
CERCLA Response Action"
DOCUMENT NUMBER:
DOCUMENT DATE:
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147 AR PAGE NUMBER: 003276 - 003289
03/15/93
014
James Sowell, Corporate Engineer
Baldwin
David Weeks, RPM, U.S. EPA Region 6
Supplemental Response Letter
Supplemental response to 10/28/92 Baldwin response co EPA' s
104(e)/General Notice Letter dated 09/09/92
DOCUMENT NUMBER:
DOCUMENT DATE:
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148 AR PAGE NUMBER: 003290 - 003389
03/16/93
100
Jack Courtney, Air Force Legal Services Agency, Environmental
Law Division - Central Region
U.S. Air Force
David Weeks, RPM, U.S. EPA Region 6
Cover Letter and Attachment
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 09/09/92
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
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ARD 980496723
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149 AR PAGE NUMBER: 003390 - 003391
03/24/93
002
Lara J. Zacny, Engineer II, Hazardous Waste Division
ADPC&E
David Weeks, RPM, U.S. EPA Region 6
Correspondence
Comments on "Site Characterization and Alternative Analysis'
for the oily sludge pit
DOCUMENT NUMBER:
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150 AR PAGE NUMBER: 002008 - 002048
03/29/93
041
Office of Waste Programs Enforcement
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Updated Compendium of Guidance Index from EPA Region 9
Compendium of CERCLA Response Selection Guidance Documents
Index
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151 AR PAGE NUMBER: 003392 - 003396
03/30/93
005
Wendy Fisher, Vice President/General Counsel
Schilling Enterprises
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TITLE:
152 AR PAGE NUMBER: 003397 - 003411
04/01/93
015
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Gurley Refining Company, Inc., Memphis, TN
104(e) Request for Information/General Notice Letter
Requests recipient to respond to 104(e) Request for
Information/General Notice Letter
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AR PAGE NUMBER: 003412 - 003413
153
04/20/93
002
Kenneth Ries, Director, Environment and Enerev
Transportation Leasing Company
David Weeks, RPM, U.S. EPA Region 6
Response Letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:'
DOCUMENT TYPE:
DOCUMENT TITLE:
003414 - 003416
154 AR PAGE NUMBER-
04/22/93
003
W.M. Gurley
Gurley Refining Company, Inc.
David Weeks, RPM, U.S. EPA Region 6
Response Letter
Response to U.S. EPA 104(e) Request for Information/General
Notice Letter dated 04/01/93 ^^i-ion/^eneral
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES'
AUTHOR:
COMPANY/AGENCY:
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DOCUMENT TITLE:
AR PAGE NUMBER: 003417 - 003417
155
04/23/93
001
Kenneth Ries, Director, Environment and Energy
Transportation Leasing Co.
David Weeks, RPM, U.S. EPA Region 6
Supplemental Response Letter
Supplement to Transportation Leasing Go's. 04/20/93 response
to EPA's 104(e) Request for Information/General Notice Letter
about Greyhound Bus Lines' involvement at the site
AR PAGE NUMBER: 003418 - 003674
156
04/30/93
257
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6 Superfund Site Files
Technical Report and Analysis
"Site Characterization/Alternatives Analysis
and Ancillary Contaminated Media"
Oily Sludge Pit
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157 AR PAGE NUMBER: 003675 - 003692
05/17/93
018
Steve Dehmer
Chevron Research and Technology Company ("Chevron")
David Weeks, RPM, U.S. EPA Region 6
Memorandum
Re: Site Characterization and Alternatives Analysis
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158 AR PAGE NUMBER: 008505 - 008533
05/24/93
029
Unspecified
U.S. EPA
General Public
Federal Register/Rules and Regulations
Federal Register/Vol. 58, No. 98/Rules and Regulations. "Land
Disposal Restrictions for Ignitable and Corrosive
Characteristic Wastes Whose Treatment Standards Were Vacated;
Interim Final Rule"
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159 AR PAGE NUMBER: 003693 - 003699
05/28/93
007
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Files
Agency Guidelines
"U.S. EPA Region 6 Guidelines to Define Effective
Stabilization"
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160 , AR PAGE NUMBER: 003700 - 003993
06/30/93
294
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6 Superfund Site Files
Final Report
Final Remedial Investigation - South 8th Street Landfill, West
Memphis, AR - Revision 1
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161 AR PAGE NUMBER: 003994 - 004445
06/30/93
462
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6 Superfund Site Files
Remedial Investigation Appendexes
Appendexes A and B
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162 AR PAGE NUMBER: 004446 - 005075
06/30/93
630
Staff Consultants
Fluor Daniels, Inc.
U.S. EPA Region 6 Superfund Site Files
Remedial Investigation Appendexes
Appendexes C-0
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163 AR PAGE NUMBER: 005076 - 005982
06/30/93
907
Staff Consultants
Fluor Daniels, Inc.
U.S. EPA Region 6 Superfund Site Files
Remedial Investigation Appendexes
Appendexes P-V
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164 AR PAGE NUMBER: 005983 - 006306
06/30/93
324
Staff Consultants
Fluor Daniels, Inc.
U.S. EPA Region 6 Superfund Site Files
Remedial Investigation Appendix
Appendix W
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-N*>
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ARD 980496723
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165 AR PAGE NUMBER: 006307 - 007302
06/30/93
996
Staff Consultants
Fluor Daniels, Inc.
U.S. EPA Region 6 Superfund Site Files
Remedial Investigation'Appendix
Appendix X
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166 AR PAGE NUMBER: 007303 - 008241
06/30/93
939
Staff Consultants
Fluor Daniels, Inc.
U.S. EPA Region 6 Superfund Site Files
Remedial Investigation Appendexes
Appendexes Y-Z
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167 AR PAGE NUMBER: 008242 - 008452
06/30/93
211
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6 Superfund Site Files
Feasibility Study
Feasibility Study - South 8th Street Landfill, West Memphis.
AR - Revision 1
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168 AR PAGE NUMBER: 008534 - 008837
06/30/93
304
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6 Superfund Site- File
Baseline Risk Assessment
"Baseline Risk Assessment - Landfill Area - Human Health
Evaluation"
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169 AR PAGE NUMBER: 008838 - 008839
07/19/93
002
Judy Sarles, Staff Writer
West Memphis Evening Times
Public
News Article
"EPA says dump presents little threat to health"
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170 AR PAGE NUMBER: 008840 - 008863
07/26/93
024
EPA Staff
U.S. EPA Region 6
Public
Proposed Plan of Action
"EPA Announces Proposed Plan of Action"
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171 AR PAGE NUMBER: 008864 - 008865
07/27/93
002
Judy Sarles, Staff Writer
West Memphis Evening Times
Public
News Article
"EPA puts dump site cleanup cost at $20 million"
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172 AR PAGE NUMBER: 008866 - 008866
08/13/93
001
Joe Baker, Resident of West Memphis, Ark.
Unspecified
U.S. EPA Region 6 Superfund Site Files
Public Comment Letter
Response to proposed plan
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FINAL
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ARC 980496723
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173 AR PAGE NUMBER: 008867 - 008929
08/17/93
063
Jan Meyer, Court Reporrer, Notary Public for the State of
Term, at Large
Daniel, Dillinger, Dominski, Richberger, Weatherford & Parker
- Court Reporters
U.S. EPA Region 6 Superfund Site Files
Public Hearing Transcript
"The South 8th Street Landfill Superfund Site Public Hearing,
August 17, 1993, 7:00 p.m."
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174 AR PAGE NUMBER: 008930 - 008931
08/18/93
002
Judy Sarles, Staff Writer
Vest Memphis Evening Times
Public
News Article
"Cleanup plan too costly, local residents tell EPA"
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175 AR PAGE NUMBER: 008932 - 008940
08/24/93
009
Citizens Against Abusive Government
West Memphis, Ark.
U.S. EPA Region 6 Superfund Site Files
Public Comment Statement
Response to proposed plan
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176 AR PAGE NUMBER: 008941 - 008941
08/24/93
001
Roger Sumpter, Resident of West Memphis, Ark.
Unspecified
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Letter
Response to proposed plan
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177 AR PAGE NUMBER: 008942 - 008942
09/01/93
001
EPA Staff
U.S. EPA Region 6
Public
Public Comment Period Announcement (Published in West Mem
"U.S. EPA Extends Public Comment Period to September 24, 1993
for the S. 8th St. Landfill Superfund Site"
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178 AR PAGE NUMBER: 008943 - 008944
09/01/93
002
Joe Baker, Resident of West Memphis, Ark.
Unspecified
Honorable Jim Guy Tucker, Governor of Arkansas
Correspondence
Letter regarding site and EPA proposed plan
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179 AR PAGE NUMBER: 008945 - 008946
09/02/93
•002
Judy Sarles, Staff Uriter
West Memphis Evening Times
Public
News Article
"More time due for talk on landfill"
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180 AR PAGE NUMBER: 008947 - 008947
09/02/93
001
Jim Turner, Crittenden County Quorum Court
West Memphis, Ark.
Honorable Jim Guy Tucker, Governor of Arkansas
Correspondence
Letter regarding site and EPA proposed plan
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ADMINISTRATIVE RECORD INDEX 15°
FINAL
SITE NAME: SOUTH 8TH STREET LANDFILL SITE
SITE NUMBER: ARC 980496723
DOCUMENT NUMBER: 181 AR PAGE NUMBER: 008948 - 008948
DOCUMENT DATE: 09/03/93
NUMBER OF PAGES: 001
AUTHOR: Eddie Brawley, Resident of West Memphis, Ark.
COMPANY/AGENCY: Unspecified
RECIPIENT: Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
DOCUMENT TYPE: Public Comment Letter
DOCUMENT TITLE: Response to proposed plan
DOCUMENT NTJMBER: 182 AR PAGE NUMBER: 008949 - 008950
DOCUMENT DATE: 09/07/93
NUMBER OF PAGES: 002
AUTHOR: Resident of West Memphis, Ark.
COMPANY/AGENCY: Unspecified
RECIPIENT: Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
DOCUMENT TYPE: Public Comment Letter
DOCUMENT TITLE: Letter regarding site and general environmental concerns
DOCUMENT NUMBER: 183 AR PAGE NUMBER: 008951 - 008952
DOCUMENT DATE: 09/10/93
NUMBER OF PAGES: 002
AUTHOR: F. Wade Callicutt, Resident of West Memphis, Ark.
COMPANY/AGENCY: Unspecified
RECIPIENT: Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
DOCUMENT TYPE: Public Comment Letter
DOCUMENT TITLE: Response to proposed plan
DOCUMENT NUMBER: 184 AR PAGE NUMBER: 008953 - 008953
DOCUMENT DATE: 09/15/93
NUMBER OF PAGES: 001
AUTHOR: ' Joe Baker, Resident of West Memphis, Ark.
COMPANY/AGENCY: Unspecified
RECIPIENT: Randall Mathis, Director, Arkansas Department of Pollution
Control & Ecology (ADPC&E)
DOCUMENT TYPE: Correspondence
DOCUMENT TITLE: Letter regarding site and EPA proposed plan
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151
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185 AR PAGE NUMBER: 008954 - 008968
09/16/93
015
Steve Dehmer
Chevron Research and Technology Company (Chevron)
Donn Walters, Community Relations Coordinator, U.S.
6
Public Comment Letter w/Attachment
Response to proposed plan
EPA Region
DOCUMENT NUMBER:
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186 AR PAGE NUMBER: 008969 - 008970
09/17/93
002
Randall Mathis, Director
ADPC&E
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Letter
Response to proposed plan
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187 AR PAGE NUMBER: 008971 - 008975
09/17/93
005
David Peeples, City Attorney
City of West Memphis, Ark.
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Letter and Enclosure
Response to proposed plan
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188 AR PAGE NUMBER: 008976 - 009123
09/21/93
148
Charlotte Knight, Attorney at Law
Memphis Light, Gas and Water Division
Donn Walters, Community Relations Coordinator,
6
Cover Letter v/Enclosure
Response to proposed plan
U.S. EPA Region
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189 AR PAGE NUMBER: 009124 - 009124
09/22/93
001
Staff Writer
West Memphis Evening Times
Public
News Article
"Huckabee joins local protest against EPA cleanup proposal'
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190 AR PAGE NUMBER: 009125 - 009125
09/22/93
001
Joe Baker, Resident of West Memphis, Ark.
Unspecified
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Letter
Letter regarding site and EPA proposed plan
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191 AR PAGE NUMBER: 009126 - 009132
09/22/93
007
Citizens of West Memphis, Ark.
Unspecified
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Statements
Response to proposed plan
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192 AR PAGE NUMBER: 009133 - 009135
09/22/93
003
Abbot C. Widdicombe, President
William L. Johnson Co., Inc.
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Letter w/Attachment
Response to proposed plan
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193 AR PAGE NUMBER: 009136 - 009140
09/23/93
005
David Peeples, City Attorney
City of West Memphis, Ark.
Donn Walters, Community Relations Coordinator, U.S. EPA Region
o
Public Comment Letter
Response to proposed plan
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194 AR PAGE NUMBER: 009141 - 009141
09/23/93
001
Jim Guy Tucker, Governor
State of Arkansas
Donn Walters, Community Relations Coordinator, U.S. EPA Region
6
Public Comment Letter
Response to proposed plan
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195 AR PAGE NUMBER: 009142 - 009145
12/30/93
004
David Weeks, P.E., Remedial Project Manager
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Files
Internal Analysis
"Past Record of Decision (ROD) Analysis -
Stabilization/Solidification Conducted for South 8th Street
Landfill Site"
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196 AR PAGE NUMBER: 009146 - 009191
02/15/94
046
David Weeks, P.E., RPM
U.S. EPA Region 6
Administrative Record
Memorandum
Remediation Goals at the South Eighth Street Landfill Site
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197 AR PAGE NUMBER: 009192 - 009401
09/29/94
210
Jane N. Saginaw, Regional Administrator
U.S. EPA Region 6
Public
Record of Decision and Responsiveness Summary
Record of Decision and Responsiveness Summary
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APPENDIX B
Basis for Remediation Goals
155
-------
THE SELECTION OF REMEDIATION GOALS
at the
SOUTH 8TH STREET LANDFILL SITE
February 15, 1994
The selection of remediation goals (RGs) at the 8th Street site has
been difficult because of inconsistencies between cleanup goals
based on risk and those cleanup goals that have typically been used
at other sites in the past (e.g. "policy goals"). The goals
initially selected by the RPM were supposedly based on policy.
However, once questioned, the RPM could not support the goal for
carcinogenic PAHs with any firm policy statement. Upon further
investigation, the RPM discovered that the policy based cleanup
goals for PCBs and dioxin result in a residual risk greater than
1 x 10"4 if strictly applied to the risk scenario's developed for
the baseline risk assessment in the absence of other relevant
technical factors. Hence, an analysis was undertaken to provide
senior management at EPA Region 6 with the information needed to
select the RGs at the 8th Street Site.
BACKGROUND
The South 8th Street Landfill site is a 30 acre site located on the
banks of the Mississippi River in West Memphis, Arkansas. It is
comprised .of a 3.5 acre oily sludge pit (waste is
characteristically hazardous for pH and lead) and 16 acres of
landfill. No other hot spots were found within the landfill.
Based on the baseline risk assessment, the primary contaminants of
concern at the site are: carcinogenic PAHs, PCBs and dioxin. The
maximum concentration of these contaminants as detected in the oily
sludge pit are provided as follows:
CONTAMINANT CONCENTRATION (ppb)
Total PAH approx. 109 ppm
PCB approx. 14-38 ppm
TCDDE 0.651 ppb (TEF, only octa isomers, no
2,3,7,8 detected)
EPA evaluated the available land use data and determined that the
baseline risk assessment should consider recreational and
agricultural scenarios for the following reasons:
The site' is in the one year flood plain of the
Mississippi River thereby precluding the construction of
any residential or commercial facilities.
The site was seriously considered as a possible location
for a state park by the Arkansas Department of Parks and
Recreation.
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157
There is currently a large RV PARK that borders the site
on the north that is owned by the same landowner as the
site.
The site was used as a parking lot for an annual local
festival where attendance was as great as 30,000 people.
The RPM has personally observed numerous people,
including children, playing near the river in the
vicinity of the site before it was fenced.
Aerial photography shows that the site was farmed as
recently as 1986.
The receptors that were considered in the baseline risk assessment
include: (1) current and future recreational visitors; (2) future
recreational workers; and (3) current and future crop consumers.
Current and future recreational visitors includes adults and
children that visit the site for very short periods of time (14
days per year adult RME, 3 days AVG) to camp and engage in other
recreational activities. The future recreational worker was based
on the assumption that the site will either be turned into a state
park, or the RV park will be significantly expanded to include the
entire site. The recreational worker may be engaged in park.
maintenance activities such as mowing the grass, pond cleanout, and
repair of park facilities. The current and future crop consumer
scenario postulates that a family will grow vegetables and fruits
at the site for private consumption and commercial sale. A
detailed discussion of the risk associated with each of these
scenarios can be found in the ROD. The results are also summarized
in the top portion of the table included in Attachment 1.
EPA used the exposure assumptions developed in the baseline risk
assessment to calculate RGs. Overall, the crop consumer risks were
judged by the RPM to be too uncertain for the purpose of developing
realistic RGs. Due to the large amount of conservatism built into
the crop uptake models, the RGs that may be developed by utilizing
the crop consumer scenario are significantly less than the
analytical detection limits for the contaminants of concern (PAH,
PCB, TCDDE). The risk for the recreational visitors is within the
acceptable risk range. Therefore, the future recreational worker
scenario was used to develop the risk based RGs.
In addition, the risk assessment assumes that subsurface soils are
excavated and spread over the surface in the future in support of
some recreational feature such as a pond. This was assumed
primarily because a similar activity has actually occurred on one
portion of the site. The landowner excavated a former disposal
area (determined to be relatively clean during the RI) to prepare
a fishing pond for his RV park visitors. He used the excavated
material to facilitate the construction of an embankment around
the pond and possibly to fill in low areas on the site.
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158
ANALYSIS
This paper details of the differences between policy based RGs and
risk based RGs through the following activities: (1) a comparison
of policy based goals and their.associated risks with goals based
on the site specific risk scenario at a risk of 1 x 10"6 for both
RME and AVG risks; (2) a comparison of 1 x 10~6 RG's based upon the
recreational worker risk scenario with RG's based on standard
residential and industrial exposure assumptions; (3) a review of
relevant statutory, regulatory, and policy language concerning the
development of RGs; (4) a consideration of specific technical
concerns relative to analytical limitations and the remedy that
will implemented at the site; and (5) a comparison of the
recommended risk based RG's to the new soil screening numbers
recently proposed by EPA HQ in a draft report entitled "Qualitative
Analysis of Impact of Soil Numbers on the Superfurtd Process," dated
September 30, 1993.
A comparison of the site risk, current policy based RGs and risk
based RGs is presented in Attachment 1. This review shows that
strict application of policy based goals in a vacuum will result in
a residual risk at the site in excess of IxlO'4. The strict RME
IxlO"6 risk based RGs are several orders of magnitude lower than the
policy based RGs. In fact, the risk based RGs are so small, that
for PAHs and TCDDE, the RG is less than the analytical detection
limit for the contaminants in soil. The AVG IxlO"6 risk based RGs
are relatively similar to the policy based RGs. The large
difference between the supposed "policy" based and risk based RGs
are due to several reasons that vary somewhat for each contaminant.
PAHs
In the case of the PAHs, a review of the "policy" based RG of 3 ppm
revealed that this number is based on cleanup goals selected in
past RODs (Attachment 2). The 3 ppm number does not consider
multiple contaminants and multiple pathways at a specific site.
Nor does the 3 ppm number correlate with either standard
residential or industrial risk scenarios at a risk equal to
1 x 10'6.
Attachment 3 clearly shows that a risk based approach utilizing
standard residential and industrial exposure assumptions at a risk
equal to 1 x 10"6 results in RGs of 0.09 ppm and 0.81 ppm
respectively for carcinogenic PAH. In a standard residential
exposure scenario, 3 ppm equates to a risk equal to 3 x 10"5,
without considering other contaminants of concern and risk pathways
other than soil ingestion.
The difference between the site specific recreational worker risk
based RG of 0.16 ppm and the standard industrial risk based RG of
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159
0.81 ppm is readily apparent in Attachment 3. The primary
difference between the standard industrial calculation and the
recreational worker calculation utilized at the South 8th Street
Site is the contaminant ingestion rate (50 mg/d vs. 480 mg/d).
The 480 mg/d rate utilized in the site specific baseline risk
assessment was selected based on information contained in OSWER
Directive 9285.6-03, Human Health Evaluation Manual, Supplemental
Guidance: "Standard Default Exposure Factors" (excerpt provided as
Attachment 4). The standard rate of 50 mg/d is based upon indoor
air studies and the 480 mg/d is based upon exposures during outdoor
activities such as "yardwork". It was the opinion the RPM and
contractor risk assessors that the 480 mg/d rate seemed to more
accurately reflect an ingestion rate for a recreational worker
working outside performing site maintenance activities than the 50
mg/d rate that is based on indoor exposures.
The EPA toxicologist did advise the RPM that the 480 mg/d rate was
typically used for shorter exposure durations than the duration
normally used to calculate industrial intake rates. In order to
account for this factor, the risk assessment employed a fractional
intake factor of 0.5 (based on professional judgement) to account
for the fact that a worker will not spend his/her entire work day
conducting "yardwork" type activities. In summation, the RPM made
a risk management decision based on currently available information
that the 480 mg/d rate more accurately reflected exposures
associated with a recreational worker than the 50 mg/d rate.
Therefore, it is clear that application of the standard industrial
exposure scenario will result in an 1 x 10"6 remediation goal of
0.81, which is considerably less than the policy based goal of 3
ppm. The 3 ppm is based upon a review of RGs used in past RODs and
is not based on risk. The site specific risk based goal of 0.33
ppm presented in Attachment 1 is based on the detection limit of
benzo(a)pyrene in soil. The actual site specific risk based RG is
0.16 ppm.
PCBS
For PCBs, the difference between the policy based goal of 10 ppm
for industrial exposure scenarios and the 1 x 10"6 risk based site
specific RG of 0.07 ppm results primarily in the way the risk
calculations are executed. These differences are summarized in
Attachment 5.
The policy based RG assumes that the concentration of PCBs in the
soil will degrade over time. EPA's standard risk assessment
methodology does not assume that contaminants will degrade over
time. In addition, the policy RG for industrial scenarios is not
based upon a specific set of exposure assumptions, but was
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160
developed by simply multiplying the residential RG by a factor of
10.
In summation, there are numerous differences between the two sets
of risk calculations presented in Attachment 5 that are used to
develop the two different "worker type" RGs (10 ppm vs. 0.07 ppm).
A review of those differences confirms that the site specific
calculations result in contaminant intakes that are less than the
contaminant intakes used to calculate the risk associated with the
policy based goals. Therefore, the difference between the policy
based RG of 10 ppm and the site specific, risk based, RG of 0.07
ppm is the result assuming that the concentration of PCBs degrade
over time and the "factor of 10 approach" used to perform the risk
calculation. Both of these methodologies are inconsistent with
current EPA Region 6 risk assessment practices and the site
specific baseline risk assessment.
Dioxin
Similar to PCBs, the cleanup concentrations EPA typically utilizes
for dioxin are not based on current standard EPA risk assessment
methodologies, but rather on a 1984 U.S. Public Health Service risk
assessment conducted by Dr. Renate Kimbrough. Since the highest
concentration of dioxin at the South 8th Street site (0.651 ppb,
TCDDE) is less than the typical policy based action levels (1 ppb
residential, 20 ppb commercial), establishing a cleanup goals for
dioxin based upon policy is nonsensical when one considers that the
site specific risk associated with 0.651 ppb is greater than 1 x
10"4. The difference between the policy based goals for dioxin
remediation of 1 pbb residential and 20 ppb industrial, and the
site specific 1 x 10"6 risk based RG is not easily explained.
ONE PART PER BILLION
The 1 ppb RG is based upon a paper authored by Dr. Renate Kimbrough
et.al. entitled "Health Implications of 2,3,7,8
Tetrachlorodibenzodioxin (TCDD) Contamination of Residential Soil"
that was published in the Journal of Toxicology and Environmental
Health in 1984 and reprinted by the U.S. Public Health Service. In
this paper the authors examined the results of rat studies from
which a Virtual Safe Dose (VSD) was derived and developed risk
estimates (based upon certain exposure assumptions) that showed 1
ppb is an appropriate action level for TCDD in a residential
location. Referenced pages from Kimbrough's paper are provided in
Attachment 6.
Several of the exposure assumptions used to calculate risk in the
study are summarized along with typical EPA assumptions as follows:
1. The Kimbrough paper assumes three exposure routes,
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161
ingestion, inhalation, and dermal absorption (p. 187). EPA
also evaluates all three routes vrhen developing remediation
goals for dioxin.
2. The Kimbrough paper assumes that the concentration of TCDD
will degrade over a 70-year lifetime with a half-life equal to
12 years (p. 189). EPA risk assessments do not usually assume
the degradation of contaminants over the exposure duration.
3. The Kimbrough paper assumes that exposure will only occur
six months of every year due to seasonal influences and
varying activity patterns that are not conducive to exposure
(p. 189) . EPA never utilizes such assumptions to estimate RME
risk. EPA usually assumes the exposure frequency for a
residential scenario to be 350 days per year for RME risk
calculations and 250 days per year for RME industrial exposure
scenarios.
4. The Kimbrough paper assumes a wide range of ingestion
rates for children, with some as low as 0 (children age 0-9
months) and as high as 10,000 mg/d (children age 1.5-3.5 yr).
Child age rates are the same as adult (100 mg/d) beginning at
age 5 (p. 190) . EPA assumes 200 mg for children to age 6 and
100 mg/day thereafter.
5. The Kimbrough paper assumes a dermal absorption rate of 1%
(p. 189) . EPA uses 3% to estimate the absorption of TCDD
through the skin via direct contact.
6. The Kimbrough paper assumes that air is exchanged at a
rate of 15 m3/day (p. 189). EPA uses 20n£/day to estimate
adult exposures to TCDD via the air pathway for 30 yrs.
The above noted differences and their effects on risk calculations
are compared in a table provided as Attachment 7.
After reviewing data from two separate animal studies, Dr.
Kimbrough calculated a VSD and, utilizing the exposure assumptions
discussed above, determined the following:
1. If the most conservative toxicological results (i.e.
Virtual Safe Dose (VSD) = 28 fg/kg b.w.*d at 1 x 10'6
risk) are used to estimate risk via exposure to an area
100% contaminated with 1 ppb TCDD, the risk is 2.3 x 10'5
(p. 191).
2. If the least conservative toxicological results (i.e. VSD
= 1428 fg/kg b.w.*d at 1 x 10'6 risk) are used to
estimate risk via exposure to an area 100% contaminated
with Ippb TCDD, the risk is less than 1 x 10'6 (somewhere
around 4E-7), (p. 191; Figure 2, p. 186).
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162
The risk associated with 1 ppb in a residential setting using
standard EPA risk assumptions and methodologies is equal to
2.4 x 10"4. The manner in which the risk varies between the three
separate risk assessment methodologies is compared in the following
table.
Comparison of Dioxin Risks as Determined
by Three Different Methodologies
Risk
Standard EPA
2.4 X 1(T4
Lower Bound
VSD
2.3 x 10*5
upper Botrnd
VSD
4 x icr7
It is clear from a review of the table that the risk associated
with 1 ppb of dioxin may vary by up to three orders of magnitude
depending on how the risk is calculated. Furthermore, it is quite
evident that the least conservative data from the Kimbrough study
is used to support the claim that 1 ppb is protective at a
1 x ID'6 risk.
TWENTY PARTS PER BILLION
In response to a question regarding TCDD cleanup levels at several
sites in Region VII, ATSDR outlined the basis for the 20 ppb
cleanup level in industrial areas in a letter dated July 30, 1987,
(Attachment 8). Also addressed in this letter is the concept of
using a 12 inch clean soil cover over soils contaminated with 5 to
10 ppb TCDD to provide a level of protection similar to 1 ppb TCDD.
Once again, ATSDR utilized radically different assumptions from
those typically assumed most EPA Region 6 risk assessment to
develop the 20 ppb RG. These differences are summarized as
follows:
1. Exposure via ingestion or inhalation does not occur
because a commercial site "would be frequented by adults
who would primarily walk through the area" and that "It
is unlikely that there would be any gardening".
2. The exposure frequency for dermal exposure to 1 gram of
soil is 5 times per week for 6 months per year;
3. The exposure duration is 20 years.
4. The amount of TCDD absorbed through the skin = 1%; and
5. Only 10 % of the relevant area is contaminated with TCDD.
-------
163
The dose calculated when using the above assumptions is 33
(fg/kg b.w.*d). If one compares the 33 fg/kg b.w.*d dose to
Kimbrough's lower and upper bound VSDs of 28 and 1428 fg/kg b.w.*d,
the dose associated with 20 ppb is within the 10-6 risk range.
ATSDR also addressed the concept of using dilution to support a
subsurface soil RG of 5 to 10 ppb TCDD. ATSDR stated in the letter
that leaving soils contaminated with 5 to 10 ppb in residential
locations was acceptable so long as the contaminated soils were
covered with at least 12 inches of clean soil. The rationale for
this decision being that "the clean surface soil would represent a
barrier restricting human access to contact with the contaminated
soil. In the event that the soil was disturbed, the 12 inches of
clean soil would be mixed with contaminated soil and the
concentration at the surface would, at most, reach ippb."
In summary, the methodology used to develop the 20 ppb RG for
commercial or industrial areas appears to be extremely
inappropriate for the South 8th Street site and is radically
different from the methodology typically utilized to estimate risk
for industrial land use scenarios.
AUTHORIZED BASIS FOR CLEANUP DETERMINATIONS
In addition to outlining the differences between the policy based
goals and the site specific goals, a discussion of EPA regulation
and policy regarding the development of RGs was also conducted.
The starting point for the evaluation is of course the statute
itself which states in § 121 of CERCLA that a remedial action
"shall attain a degree of cleanup of hazardous substances, ...,
released into the environment and of control of further release at
a minimum which assures protection of human health and the
environment." This standard is very broad and was defined further
in the NCP.
The NCP states at 40 CFR § 300.430 (e)(2)(i)(A)(2) that:
The 10E-6 risk level shall be used as the point of departure
for determining remediation goals for alternatives when ARARs
are not available or are not sufficiently protective because
of the presence of multiple contaminants at a site or multiple
pathways of exposure.
This was interpreted to mean that EPA should strive to achieve 1 x
10"6 cleanups and should deviate from this goal only if some
specific rationale for deviating from the goal can be provided.
The preamble to the NCP at p. 8712 provides further detail
regarding how RGs are to be established. In the context of
developing and analyzing alternatives, the NCP states
-------
164
the risk associated with potential alternatives, both during
implementation and following completion of the remedial
action, are assessed, based on the reasonable maximum exposure
assumptions and any other controls necessary to ensure that
exposure levels are protective and can be attained. These are
generally assessed for each exposure route unless there are
multiple exposure routes where combined effects may have to be
considered.
In regards to departing from a risk level of 10-6, the NCP states
at 8717 that:
Preliminary remediation goals for carcinogens are set at a 10-
6 excess cancer risk as a point of departure, but may be
revised to a different risk level within the acceptable risk
range based on the consideration of appropriate factors
including, but not limited to: exposure factors, uncertainty
factors, and technical factors. Included under exposure
factors are: the cumulative effect of multiple contaminants,
the potential for human exposure from other pathways at the
site, population sensitivities, potential impacts to
environmental receptors, and cross-media impacts of
alternatives. Factors related to uncertainty may include:
the reliability of alternatives, the weight of scientific
evidence concerning exposures and individual and cumulative
health effects, and the reliability of exposure data.
Technical factors may include: detection/quantification limits
for contaminants, technical limitations to remediation, the
ability to monitor and control movements of contaminants, and
background levels of contaminants. The final selection of the
appropriate risk level is made when the remedy is selected
based on the balancing of criteria.
EPA guidance provides some additional information regarding this
subject. OSWER Directive 9355.0-30, Role of the Baseline Risk
Assessment in Superfund Remedy Selection Decisions (April 22,
1991), states on page 7 that:
Preliminary goals may be modified based on results of the
baseline risk assessment, which clarifies exposure pathways
and may identify situations where cumulative risk of multiple
contaminants or multiple exposure pathways at the site
indicate the need for more or less stringent cleanup levels
than those initially developed as preliminary remediation
goals.
This guidance seems to indicate that preliminary goals (i.e. goals
developed during scoping such as is the case with policy goals) may
be modified based on the site specific risk assessment. However,
this same policy states further that:
preliminary remediation goals and the corresponding cleanup
-------
165
levels may also be modified based on the given waste
management strategy selected at the time of remedy selection
that is based upon the balancing of the nine criteria used for
remedy selection.
Finally, recent discussions concerning the use of central tendency
in baseline risk assessments may also be applicable to the
consideration of RGs at the site. The only currently available
written information regarding this topic is found in a memorandum
from Henry Longest to the Division Directors dated May 26, 1992
entitled "Implementing the Deputy Administrator's Risk
Characterization Memorandum". The memo does not directly address
the issue of RGs, but it does state that:
Regarding risk management, we will continue to use the RME
scenario, as described in the preamble of the National
Contingency Plan, in the remedial decision in evaluating what
is necessary to achieve protection against risk to human
health. The central tendency estimate will be used for
informational purposes in discussing uncertainties.
CONCLUSION
The analysis quite clearly shows that RGs are to be based on risk
in the absence of ARARs or when ARARs are not protective. Policy
RGs are not ARARs. Therefore, there is no basis for utilizing
policy RGs when those goals conflict with risk at a specific site.
In the case of the South 8th Street site, the policy RGs conflict
with the reasonable maximum exposure scenario risk at the site.
Therefore, policy based goals should not be utilized as a basis for
determining cleanup based solely on the rationale that the goals
are appropriate because they are based on policy.
This is not to say that the various methodologies and assumptions
used to develop the policy based goals are incorrect. One set of
assumptions is likely as good as another thereby rendering
arguments over such issues matters of professional opinion rather
than technical fact. However, it appears to be technically
inconsistent use one set of assumptions and methodologies to
determine that a risk exist at a specific site and then use a
radically different set of assumptions and risk methodologies to
develop RGs. It is, therefore, the author's opinion (and the
opinion of RAGs Part B - Development of Preliminary Remediation
Goals) that site specific RGs should be developed based on the
specific risk scenario utilized at a specific site.
Conversely, the preceding analysis also shows that EPA is not
required to blindly specify that all cleanups achieve a 1 x 10"6
risk for every contaminant of concern. Several factors may be
considered when establishing specific RGs within the risk range of
1 x 10"* to ixlO'6. Among the factors to be considered include
-------
166
exposure factors, uncertainty factors, and technical factors. The
NCP suggests that exposure factors and uncertainty factors are
typically considered for rendering RGs that are even more stringent
than the typical 1 x 10~6 cleanup. Only technical factors are
typically considered to be an appropriate basis for amending RGs to
a less stringent number.
At the South 8th Street site, the only technical factor discussed
in the literature (NCP) that may provide grounds for revising
cleanup levels upwards are detection/quantification limits. The
detection limits that one could actually achieve in the field are
likely to be greater that the MDLs cited in Attachment 1. Thus, in
the absence of any other technical factors, the detection limits
will control the degree of cleanup at the site, not the actual
remediation goal.
In spite of the regulatory accuracy of the above analysis, it fails
to consider the fact that the pit area will be backfilled with
clean soil to a depth of up to 18 feet. First, the RI determined
that the average depth of the sludge pit is 12 feet, with a maximum
depth of 18 feet. It seems unlikely that anyone would excavate the
pit area to a depth greater than 12' to construct a recreational
feature such as a fishing pond etc... Therefore, the likelihood
that contaminated material will be excavated and spread over the
site at some point in the future is quite slim.
Secondly, if the area is excavated to construct a fishing pond or
some other recreational feature, the fact that part of the site has
now been established as a wetland area will generally preclude the
placement of the excavated material back onto the site per Section
404 of the CWA. The excavated material will likely be disposed in
a landfill, used as cover for a landfill, or used for some other
purpose where it would be mixed thoroughly before being subjected
to human contact.
.Finally, assuming in a worst case scenario that all of the clean
fill material used to backfill the sludge pit is excavated
including a one foot layer of material contaminated at policy based
cleanup values, 833 cubic yards (150' x 150' x 1') of the
contaminated material will be mixed with at least 10,000 cubic
yards of clean material thereby resulting in a reduction factor of
0.08. This factor, when applied to the policy based cleanup values
and the actual dioxin concentration of the pit waste, has the
following effects on risk:
-------
167
Cleanup Cone.
In Pit Bottom
Risk if
Directly
Accessible To
Rec . Worker
Cleanup Cone.
After Pit
Bottom Mixed
w/Clean
Backfill
Risk
Assoc.w/ Pit
Bottom After
Mixed w/
Clean
Backfill
:' leas, (ppm)'.;-1
3
1.8 x i
-------
168
ground water remedy at the site due to a lack of conclusive data
linking contaminants in the ground water to the site. Furthermore,
even if the ground water did present a risk, it may not be possible
to remediate an aquifer located next to such a large recharge
source as the Mississippi River.
The Organic Leaching Model was used during the RI to evaluate the
potential for the contaminants in the pit to leach into the ground
water. The modeling shows that there is no potential for leachate
from the pit area to contain concentrations of PAHs that exceed
MCLs or that may be outside the 1 x 10~6 risk range. The modeling
does indicate, however, that leachate from the pit area could
contain concentrations of PCBs in the leachate at the 1 x 10"5 risk
range level, and the concentration of TCDDE in the leachate may
exceed the MCL. However, this possibility is not likely as dioxin
is extremely insoluble in water and the leachate concentration
would most surely be diluted by the ground water to a level well
below the MCL.
Finally, the recommended RGs were compared to the recently proposed
default soil screening numbers proposed by EPA HQ in the table
below.
CONTAMINANT
PAH as BAPE
PCB
TCDDE
SITEiRO
(mg/kg)
3
10
None
son. ro
GRODNDWATER
SCREENING:
LEVEL
(«g/kgj
0.71
0.82
n/a
.. INHALATION
.. SCREENING
LEVEL
(»g/kg)
320
n/a
n/a
INOESTION
{SCREENING;
LEVEL c
(ner/Jcg) ,
0.11
1
n/a
In general, the site specific risk based RGs that consider site
specific technical factors are greater than the soil screening
levels that are being considered by EPA HQ.
-------
169
ATTACHMENT 1
REVIEW OF CLEANUP CONCENTRATIONS AND DECISION MATRIX
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ATTACHMENT 2
REVIEW OF SOME REMEDIATION GOALS
IN REGION 6
171
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SURFACE MATERIAL REMEDIATION LEVELS
CURRENT SITUATION!
The Risk.Assessment Guidance for Superfund (RAGS) has standardized
most of the "risk assessment assumptions used by EPA to set
remediation goals at Superfund sites. This guidance has lead to
greater consistency in remediation goals over the past two years
(See examples of Wood Treating Site Action Level Graphs). However,
site by site application of this guidance continues to result in
wide variations of remediation goals. These variations are
perceived by many agency critics as problematical.
PERCEIVED PROBLEMS;
• EPA is viewed as inconsistent, both over time and from site to
site, by a variety of different interests.
0 Concepts of risk assessment are not easily^ understood by the
general public despite intensive education efforts by EPA.
• EPA is viewed as soft on PRP sites. Responsible party sites
are much more likely to be in active commercial operation.
EPA's AOC's and consent decrees give the agency much more
assurance of future land use. Resulting remediation levels
are generally less stringent than encountered for residential
land use.
PROPOSED SOLUTION;
OSWER should publish simple, unambiguous, expected remedial levels
for Superfund sites. An example for surface materials is: *
AT ALL SUPERFUND SITES THE EXPECTED REMEDIAL GOAL FOR THE
TOP TWO FEET OF MATERIAL IS:
- 3 PPM TOTAL CARCINOGENIC PAH'S FOR
RESIDENTIAL EXPOSURES, OR
-30 PPM TOTAL CARCINOGENIC PAH'S FOR
INDUSTRIAL EXPOSURES
These levels are equivalent to risk of 1 X 10*5, and is consistent
with such standards as the-PCB TSCA requirements. Deviations from
these expectations would be explained in the ROD (e.g., ecological
risk changing clean up level, deeper pockets of high contamination,
etc). The difference of this approach from current guidelines is,
that, instead of giving Regions the "plans for how to build cars"
(the current RAGS guidance), OSWER would set expected performance
of the "vehicle".
-------
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176
SOIL ACTION LEVELS VERSUS RISK
CARCINOGENIC PAH'S AT SUPERFUND WOODTREATING SITES
1990 TO 1992
SITE
ACTION LEVEL
DuBoise Oil, FL
50 ppm
RISK NOTE
RESIDENTIAL EXPOSURES
1.
2.
3.
4.
5.
6.
7.
8.
9.
10
11
Old Springfield Landfill, VT
(9/90)
Myers Property, NJ
(9/90)
Cabot/Koppers, FL
(9/90)
Burlington Northern, MT
(9/90)
J. H. Baxter, CA
(9/90)
INDUSTRIAL
Imperial Oil, NJ
(9/90)
Moss/Kerr McGee, IN
(9/90)
Hastings Coal Gas, IA
(9/90)
Arlcvood, AR
(9/90)
. Texarkana Wood, TX
(9/90)
. Hastings GW, NB
(9/90)
OTHER
Greenwood Chemical, VA
3
10
0.6
36
0.5
ppm
ppm
ppm
ppm
ppm
5xlO'6
(10-5)
IxlO'6
IxlO'*
IxlO*6
A
EXPOSURES
10
6
0.5
6
3
0.5
GOALS
ppm
ppm
ppm
ppm
ppm
ppm
5,000 ppm
-------
ATTACHMENT 3
BENZO(A)PYRENE REMEDIATION
GOALS
177
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ATTACHMENT 4
EXCERPT FROM OSWER DIRECTIVE 9285.6-03
"HUMAN HEALTH EVALUATION MANUAL"
179
-------
ATTACHMENT B
ESTIMATING ADULT SOIL IKGESTION
IN THE COMMERCIAL/INDUSTRIAL SETTING 180
Most of the available soil ingestion studies focus on children in
the residential setting; however, tvo studies were found that
address adult soil ingestion that also have application to the
commercial/industrial setting (Havley, 1985; Calabrese, et al.,
1990).
Havley (1985) used a number of assumptions for contact rates and
body surface area to estimate the amount of soil and dust adults
may ingest during a variety of residential activities. For
indoor exposures, Havley estimated levels based on contact with
soil/dust in tvo different household areas, as follows:
0.5 nig/day for daily exposure in the "living space"; and 110
mg/day for cleaning dusty areas such as attics or basements. [For
outdoor exposures, Havley estimated a soil ingestion rate during
yardvork of 480 mg/day. I The assumptions used to model ex;
in the residential setting nay also be applied to similar
situations in the workplace.! The amount of soil and dust adults
contact in their houses may be similar to the amount an office or
indoor maintenance worker would be expected to contact.
Likewise, the amount of soil contacted by someone engaged in
construction or landscaping nay be more analogous to a resident
doing outdoor yardwork.
Calabrese, et al. (1990) conducted a pilot study that measured
adult soil ingestion at 50 mg/day. Although the study has
several drawbacks (e.g., a limited number of participants and no
information.on the participants daily work activities), it
included subjects that worked outside the home. It is also
interesting to note that this measured value falls within the - •;"
range Havley (1985) estimated for adult soil ingestion during
indoor activities. " .."'*'.
From these studies, 50 mg/day vas chosen as the standard default
value for adult soil ingestion in the workplace. > It was chosen ;
primarily because it is a measured value but also/because it " ; .*
falls within the range of modeled values representing two widely
different ^til"™" exposure scenarios. The 50 mg/day value is to
be used in conjunction with an exposure frequency of 250
days/year and an exposure duration of 25 years. For certain
outdoor activities in the commercial/industrial setting (e.g.,
construction or landscaping), a soil ingestion rate of 480 mg/day
may be used; however, this type of work is usually short-term and
is often dictated by the weather. Thus, exposure frequency would
generally be less than one year and exposure duration would vary
according to site-specific construction/maintenance plans.
-------
ATTACHMENT 5
POLY-CHLORINATED BIPHYENL
REMEDIATION GOALS
181
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ATTACHMENT 6
EXCERPTS FROM "HEALTH IMPLICATIONS OF 2,3,7,8
TETRACHLORODIBENZODIOXIN (TCDD)
CONTAMINATION OF
RESIDENTIAL SOIL"
183
-------
Reprinted by the
U£. DEPARTMENT OF HEALTH AND HUMAN SERVICES
PUBLIC HEALTH SERVICE
HEALTH IMPLICATIONS OF 2,3,7,8-TETRACHLORO-
DIBENZODIOXIN (TCDD) CONTAMINATION
OF RESIDENTIAL SOIL
Route 0. Kfmbrough, Henry Falk, Paul Stehr
Center for Environmental Health Centers for Disease
Control, Public Health Service, U.S. Department
of Health and Human Services, Atlanta, Georgia
George Fries
U.S. Department of Agriculture, Beltsville, Maryland
Extrapolation* from animal toxiclty experiment (Including corc/rtooenlctty and repro-
ductive effects) to possible human health effects can bt tatd to estimate a reasonable
level of risk for 2,3,7,8-tetnchtorodlbentodloxln (2,3,7,3-TCDD). Extrapolations art
derived from: (I) review of published studies, (2) a complex ttt of assumptions related
to human exposure to contaminated salt, and (3) estimates of (a) a dose response curve,
(b) appropriate margins of safety, and/or (e) applicable mechanisms of action.
One ppb of 2,3,7,8-TCOO hi soil ha reasonable level at vhlch to begin consideration of
action to limit human exposure for contaminated soil.
SUMMARY
From the available literature dealing with the toxic effects of
2,3,7,8-tetrachlorodibenzodioxin (TCDD), only reports on a few chronic
feeding studies in rodents can be used for risk assessment calculations. The
smallest lower confidence bound on the virtually safe dose by the linear
derived multistage model using an added cancer risk of 1/1,000,000 is
calculated to be 28 fg/kg bprfy w.ejghfd (body wei|hT= b.w.). ThK
The list of consultants whose advice* was sought durln( the preparation of this document can
be obtained by writing to: Renate D. Klmbroufh, M.D., Center for Environmental Health, Centers
for Disease Control, Public Health Service, U.S. Department of Health and Human Services,
Atlanta, Geor|la 30333.
Use of trade names b for Identification only and does not constitute endorsement by the
Public Health Service or by the U.S. Department of Health and Human Services.
The statistical analysis of the rodent carcinofeniclty data was performed by Dr. Christopher
Portler, Biometry and Risk Assessment Program, National Institute of Environmental Health
Sciences, P.O. Box 12233, Research Triangle Park, North Carolina 27709. Dr. Paul J. Wiesner,
David l_ Forney, Linda W. Anderson, and Debra ). Kinney assisted In the preparation of the
document and the coordination of the reviewers' comments.
Requests for reprints should be sent to Publications Activities, Center for Environmental
Health, Centers for Disease Control, Atlanta, Georgia 30333.
Journal of Toxicology and Environmental Health, 14:47-93, 1984
Copyright e 1984 by Hemisphere Publishing Corporation
-------
calculation is based on data for hepatocellular carcinoma or neoplastic
nodules. The increased cancer risk of 1/1,000,000 based on data for tissue
less sensitive than liver would not be expected to occur until doses as high
as 1428 fg/kg b.w.-d were administered. The corresponding levels for an
increased risk of 1/100,000 are 276 fg to 143 pg/kg b.w.-d (Figs. 1 and
2). These calculations assume that a linear dose-response relationship exists
for carcinogens (such as TCDD) that, based on current evidence, are
thought to be primarily promoters. However, the dose-response curve for.
promoters may not be linear, causing an overestimate of the risk. The
Anodel was used on a hypothetical basis, and the cancer risk for TCOD
should be reevaluated as the data base enlarges. Human exposure would
primarily occur by the dermal and the oral route.
To estimate human TCDD intake after exposure to TCDD-
contaiminated soil in residential areas, we calculated estimates for dermal,
ingestion, and inhalation doses. With these estimates (the assumptions on
which they are based are outlined in the text) the best estimate of a daily
dose at 1 ppb in residential soil (assuming uniform distribution of TCDD
in soil at 1 ppb) is calculated to be 44.6/pg/d (or 636.5 fg/kg b.w.-d for a
person weighing 70 kg). In consideration of the range of the estimated
VSD and because of.the unlikelihood trial all of the conservative exposure
assessment assumptions will be realized on. a continuous or lifetime basis,
we have concluded that residential soil levels greater than 1 ppb TCDD
pose a level of concern. The appropriate qegree of concern for which
'jTjanagement decisions are made should also consider an evaluation of the
specific circumstances at each contaminated site\
Exposure in contaminated residential areas would be preater than in
9000.000-1
coos
0.0001
0.0010 04100 0.1000 1.0000 HUOOO 1000000
INITIAL MIL CONCENTRATION UVtL M *f
FIGURE 1. This figure illustrates the averafe dally dose of TCDD that would be received If 100.10,
or IX of the accessible soil were contaminated with the peak recorded level of TCOD. The boundaries
for an excess lifetime cancer risk (or 10'' and 10"' are also Illustrated.
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186
0001 0010 O.WO
INITIAL (Oil CONCfNTftAtMN LIVf L IN fft
FIGURE 2. Thb figure (Ihatntet the lower ami upper bounds of UK virtually safe dote for a lifetime
excess cancer risk. This Information was derived from tty calculations developed from animal data
(T»Wes«ind9}.Atth«eoneentritlonoflppb.»f70<>Kotih«acce»»IW«s<)nconnJn«lTCDOatthlj
concentration, the area of risk bordered by the upper and tower bound of the virtually safe dose does
not represent an unacceptable cancer risk liven the fact tlat the backfround cancer Incidence In the
general population b of a much W«her order of magnitude. If less than 100% of the sol w«
contaminated, this risk would even be further reduced. However, at levels much above 1 ppbtnerfek
would become i
only occasionally frequented commercial areas. In residential areas, levels
(afror above^Xppb TCDD ipjoilJa^cr_joiU^ls may still be of concern, since TCDD
accumulates in the tissues oT grazing cattle and rooting swine.
BACKGROUND
In the early 1970s, a waste-oil dealer iin Missouri disposed of waste
material containing 2,3,7,8-tetrachtorodiberizodioxin (TCDD) in high con-
centrations by mixing this material with salvage oil and spraying it on din
roads and riding arenas. The contamination of the riding arenas by TCDD
was established in 1975 (Carter et at., 1975). Until recently, investigators
had not realized the extent to which several other areas, many of them
residential, were also contaminated with TCDD. Thus far, concentrations
measured in soil in these areas have ranged from less than 1 ppb to over
1000 ppb. Once it was determined that TCDD was present in residential
areas, it had to be decided what level represented an unacceptable risk to
the population living in these contaminated areas. This document presents
-------
187
In addition, questions of continued habitability must also include
considerations of the potential for limiting or eliminating ongoing ex-
posures.
Developing a level of concern about an unacceptable risk due to
exposure to TCDO poses significant difficulties because TCOD has such
unique properties, as outlined in the preceding pages of this paper.
In the past, as a first approach, several groups have used a series of
risk-assessment estimates based on several of these factors to determine
what an "acceptable" risk for exposure to TCDD would be. As more
information on the toxicity of this chemical has become available, these
levels have generally been reduced.
To determine whether a specific concentration of TCOO in soil
presents a risk to humans, we must first examine how humans might
absorb TCOD from such soil. Unfortunately, the amount of any chemical
present in soil that may be absorbed by humans coming in contact with
the soil is not well known. Most risk assessments that have been made in
the past have been made for such media as food, where it is assumed that
a certain amount of food with a certain concentration of the chemical in
it is consumed; for air, where how much air is inhaled simply needs to be
calculated; or for chemicals in water, where the only number needed is the
amount of water consumed—although, as far as water-quality criteria'are
concerned, the bioaccumulation of chemicals in fish from contaminated
water is also considered. Unfortunately, the analogous series of estimates is
more complicated for soil.
Basically, three exposure routes must be considered: dermal absorption
through direct contact with the soif. ingestion of soil, and the inhalation
oTTfOsT to which TCDD is attached. Vapors may be an additional,
probably minor, route of exposure. Another issue, which doesjot directh
enter into the current risk assessment, is the fact
environment could eventually end UP in the food chain, particularly in
fish. If TCDD enters a food chain, there is an unknown additional source
of exposure which must be added to the risk of those individuals exposed
to contaminated soil and of a larger, undefined population. .
Regarding dermal absorption, there is some evidence that TCDD binds
to the soil and would not be as easily available for absorption. (Vegetation
covering contaminated soil may also decrease TCDD availability.). Informa-
tion on bioavailability, however, is currently limited and may vary for
different types of soil. According to the literature (Poiger and Schlatter,
1980, and a personal communication), anywhere from 1 to 1096 of the
TCDD in the soil may be absorbed through the skin, and tnis percentage" is
likely to depend on the T'CDD concentration in thTsoiTir.e.. it may be
greaterjrt higher concentration*:) and on the type of soil. When Poiger and
Schlatter (1980) applied soil with a dose of 350 ng TCDD to the backs of
rats, 1.7 ± 0.5% of the dose was found in the liver; at a dose of 26 ng,
about 0.05% of the dose was found in the liver. The authors do not state
-------
188
in the article how long the soil was left in contact with the skin of the
rats,1 except that after 24 h it was not possible to recover all of the
" applied dose from the skin surface. Therefore, the subsequent estimates
£v^. will allow for this range of skin absorption factors.
>'•.. In regard to the port/on of total dose due to ingestion of soil particles,
*£*J-' feeding studies in animals suggest that 30% or more of the TCDD
^"~ adsorbed on soil will be absorbed in the gastrointestina/ tract~TETT:
'•£>;• McConnell et al., 1984). Poiger and Schlatter (1980) touRMV-24* of the
- -' administered dose of TCDD in the liver. According to Fries and Marrow
, . (1975), this represents about 70% of the body burden of TCDD.
*>-- In regard to inhaled doses, little information is available on the
s";~i amount of dust that may be present in the air in situations of known soil
•2*v: contamination; measurements in Seveso showed that the,amount of dust
./, V in air was 0.14 m^/m* air (Dinomj»niV-n et a/., 1980). No dust levels in air
%.~ whose sole source is soil are available from air monitoring stations. Soil,
--•. - . vegetable matter, and particles from other sources such as car exhaust are
^'-- -• measured as paniculate matter. The use of particufate matter would highly
**."' overestimate dust derived from soil. In riding arenas or in relatively drier
••-_ : areas, dust levels would be possibly higher.
- On the other hand, immediately after a rainfall there would probably
rf\ be less dust. In the same investigation, it was shown that TCDD levels in
'£••' dust were comparable to those found in soil. Another unknown is the
'': - amount of material that could be carried into the house from the outside.
:.:. It is cgnserj3^te/y_assumed that the exposure to dust inside a house
surrounded hy contaminated soil is'sim'rtar to the exposure that jvould
occur if people spent their entife_Jime in contact with the contaminated
soil outside. (One of the CDC consultants commented that the assumption
that indoor levels will equal outdoor levels appears unnecessarily conserva-
tive.) An average adult at rest exchanges approximately 10 m3 air/24-h-
period, and this would increase with mild activity to 18-24 m'/d, and to
40 m*/d with hard physical labor. Finally, it is assumed that whatever
TCDD isUnhaltd adsorbed -to dust twti'rlrt if ahc/ir^ n'fhrr rhrmfffT
deposition inOhe respiratory tract orJ>y fngestion after beine brought up
b~ylh"e ciliary action of the respiratory tract epithelial cellsT
Several comments were received from CDC consultants on exposure
estimates: e.g., how much soil does a young child eat when playing
outside? how much soil gets onto the skin during gardening activities? how
much soil gets onto the skin of children playing football or other games?
Unfortunately, there is no documentation in the literature that clarifies
the problems raised. For illustrative purposes, 1 g soil less than 1 mm
thick can be spread over an area of 4-5 cm* or 1{-2 in1. Ten grams of
soil less than 1 mm thick can be spread over an area of about 15 cm2 or
about 6 in3. (The volume of dirt will vary somewhat with moisture
content.) The soil used in calculating the above surface areas was
124 h. (Pol|cr, 19(4, penonti communication.)
-------
189
Georgia clay that had been stored for several months at room temperature.
All of the calculations regarding exposure are based on the assumption
that humans have access to and contact with the contaminated soil and
that a percentage of the TCDO present in the soil is absorbed. The
frequency of access and contact must also be considered, and for dermal
exposure it must be remembered that clothing will afford some protection.
The doses calculated below are, in some sense, worst-case estimates for the
concentrations used.
A large number of estimated total daily doses can be derived from the
many combinations of the exposure route-specific doses (given different
sets of assumptions as to absorption rates, soil contamination, etc.).
However, in an attempt to derive a more accurate estimate of exposure to
and uptake from contaminated soils, a simulation analysis was performed
utilizing a further set of assumptions, which are most likly to be obtained
in reality. For instance, TCDO is suggested to have an environmental
half-life of approximately 10-12 yr. Therefore, the simulation model
assumed that soil contamination levels would decrease in a log-linear
fashion with a 12-yr half-life following the equation
TCDD, ^fr-0-00014"
where TCDD, — current soil level on day t (ppb)
a — In (initial soil contamination level, ppb)
f = number of days elapsed since initial soil contamination
measurement
Consideration of the route-specific uptakes does not require an
assumption of constant exposure but merely postulates an a priori
reasoned absolute daily amount of soil contact. For inhalation, we
assumed that airborne dust is contaminated at the same level as surround-
ing outside soil and that 15 m* air is exchanged per day. In regards to
ingestion, based on preliminary results of bloavatla'BTIity studies, a Gl
absorption rate of_30% from soil seems most tenable. In addition, the
amount of soil that the average person is likely to ingest will be dependent
on characteristic activity patterns, which, in turn, are closely dependent on
age. Based on work done studying lead uptake from contaminated soils, a
reasonable pattern of soil ingestion (which still maintains conservative
estimates) for specific age groups was constructed and is presented in
Table 5. Based on animal experimentation, the best estimate for dermal
absorption of TCOO is approximately J96 (especially in the low ppb
contamination ranges). Reasoning for an agFtfSpendent pattern of deposi-
tion of soil on exposed skin similar to soil ingestion was used to derive
Table 6. Finally, it was assumed that these exposures would be likely to
take place only 6 mo of the year because of seasonal influences and
varying activity patterns. '
The simulation model was run using a computerized iterative pro-
cedure by daily increments to estimate total lifetime dose using the
following formula:
-------
190
Total T
lifetime « V TCDD, (ING, X Gl + DERM, X ABS + INH X DUST) SEAS
dose ,= i
where T = expected lifespan (d)
ING, = age-specific amount of soil ingested at time t
Gl = 96 absorbed through gastrointestinal tract
DERM, = age-specific amount of soil deposited on skin at time t
ABS = % absorbed through skin
INH — amount of air exchanged per day
DUST = concentration of dust in air
SEAS — "dummy" variable for seasonal access to outdoor con-
taminated areas (i.e., =1 for fair-weather months and 0 for
cold weather months)
For the sake of brevity, extreme total daily dose estimates were compiled
for two divergent levels of TCDD soil contamination (1 ppb and 100 ppb).
Based on the assumptions set forth above, at an initial soil contamination
of 1 ppb in residential areas, the average daily TCDD dose to an individual
over a 70-yr lifetime would be 44J5_eg. This is equivalent to 63
-------
191
Since the no-observable-effect levels for reproduction, immune tox-
icity, and various other toxic effects are not established in various species,
a conservative approach for chronic tox/city in general is in order. The
study by Murray et al. (1979) suggested that 0.001 ftgfkg-d is a
no-observed-effect level for reproduction in rats. Nisbet and Paxton (1982)
recalculated the data developed by Murray et al. (1979), using results from
different generations as independent variables. They concluded that 0.001
fjg/kg b.w.'d was still an effect level. However, the study by Murray et al.
(1979) shows a very varied fertility index among the controls through
different generations; in addition, TCOO body burdens of the dams are
greatly affected by lactation, introducing another variable. CDC con-
sultants Drs. Hoel, Van Ryzin, and Portier also reviewed these data and
concluded that there was insufficient evidence for an effect at 0.001 fig/kg
b.w.'d. For these reasons, this study was not used for risk assessment
calculations, but only the chronic toxicity studies which demonstrated a
carcinogenic response in rodents were used.
Subhuman primates (which are much more susceptible to the effects
of TCDD) show an effect on reproduction if fed for 6 mo at a daily dose
of 1.8 ng/kg. If the toxicology data from subhuman primates are used,
then a 1000-fold safety factor would have to be used, since the lowest
dose of 1.8 ng/kg'd was not a no-observed-effect level and was not
obtained from a chronic feeding study. Thus, a daily dose rate of 0.0018
ng/kg—corresponding to a total daily dose of 144 pg—would be tolerable
for an 80-kg person. For a 60-kg person, the tolerable total daily dose
would be 108 pg. Thus, at the daily dose likely to be obtained as
estimated above for a soil level of 1 ppb (44.6 pg/d), these extrapolations
from reproductive studies in subhuman primates appear to suggest a
situation of no excess risk in humans. However, at virtually all other
estimated levels of daily dose (i.e., under more severe sets of assumptions
or the higher level of TCOO in soil), one might expect adverse repro-
ductive health effects.
As shown in Frg. 2, the upper-bound cancer risk estimate of 1.4 pg/kg
^>.w.-d for an increased risk of 1 X 10"' over a 70-yr lifetime (assuming
100% of contaminated area is at peak recorded level) is more than the
amount of TCOD (637 fg/kg b.w.-d) that could theoretically be absorbed
from soil initially contaminated with TCOO at 1 ppb, under the simula-
tion model as discussed above. For the estimates illustrated in Fig. 2, the
excess lifetime cancer risk for exposure to residential soil with a peak
TCDP contamination level of 1 ppb ranges over 4 orders of magnitude,
frojTiabove 1Q-* jQ-helow 10J:». At the lower bound tor the VSi) or 28
Tg/kg b.w.'d (or r960pg/70-kg person-d), it would take just over 3 yr to
accumulate a total dose sufficient to increase an individual's lifetime risk
of developing cancer by 1 in a million, using the estimates derived herein
and assuming 10096 of the contaminated area is at the peak recorded
level). Over a 70-yr lifetime, this would amount to a 0.000023 absolute
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192
increase (equivalent to 0.01% relative increase) over Okie's "normal" 25%
probability of developing cancer in the United States (RR = 25.0023/
r25 = 1.0001).
' It must be stressed that the exposure assessments \used in estimating
fetes for carcinogenic#y-aS|i reproductive health effecKs^oatalajcntica'l
assumptions that are^not (j^fely to be actually encountered. Most prom-
inent of these"s tnV assumption of uniform levels of contamination
throughout the Itvmg space. In fact, areas with elevated TCDD levels are
likely to 1>e found in specific, well-defined locations that have concomitant
unique use and access characteristics. Therefore, in an area where acceg is
^jggs than total, the actual daily exposure will be lower. Similarly, different
usage patterns or arrected areas (e.g., sports activities, gardening, horseback
riding) or an individual's characteristics (e.g., pica in children) are not
likely to lead consistently to worst-case situations and will have differing
effects on the determination of total cumulative dose. It could be further
argued that the daily dose rate is more important than the cumulative
total dose. It appears, however, that exposure has to be for a sufficiently
long time for cancer to develop since short exposure periods may result in
recovery (Farber, 1974), or would not appreciably inggasethe cancer risk
over background (Office on Smoking and Healtby^9S2p"W*N»ave there-
fore concluded that a soil level of 1 ppb TCpf^in residential Jkreas is a
reasonable level at which to express concern abc
Implications for Risk Management
Therefore, where residential soil levels exceed 1 'ppb, risk-management
decisions on habitability and limiting exposure may rany from rr™"""*"-
dations to avoid identified "hot spots, limit specific activities in these
"areas (If possible), and lu temporarily"" relocate while contamination
clean-up and onsite stabilization operations are performed :to permanent
relocation ?nd accew n*trietinn far a ftlven y|te (n addition, Such
recommendations will have to be prepared in terms of situations that
range from the need for near-term action to those of a less urgent nature.
'In all of these scenarios, however, these dMtySonp nnnp u/iH slowly degrade, and that
_peQple_j»dll not_he exposed extensively to the Mil onjt continuous
daily ^asis. For instance, it is anticipated that during cold or rainy
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ATTACHMENT 7
TCDD REMEDIATION GOALS
193
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ATTACHMENT 8
LETTER FROM ASTDR REGARDING TCDD RGs FOR
INDUSTRIAL SITES
195
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DEPARTMENT OF HEALTH 4 HUMAN SERVICES Public Health Service
Agency for Toxic Substances
and Disease Registry
Atlanta GA 30333
July 30, 1987
Mr. David Wagoner
Director
Waste Management Division
EPA VII
Kansas City, Kansas 66101
Dear Mr. Wagoner:
This letter is in response to your request for elaboration on the
mathematics underlying the development of support for the 20 ppb cleanup
level for certain Missouri dioxin sites as proposed in the letter froa
Mr. Morris Kay to Dr. Renate Kimbrough dated January 16, 1987. In
•Dr. Kimbrough*s January 22. 1987 response she indicated that the proposed
cleanup activities vould restore the areas so that they would no longer be
of concern for public health. In the enclosed memorandum from Dr. Vernon
N. Houk, Director. Center for Environmental Health (CEH) dated May 8,
1987, the basic CEH guidance established for these sites was listed. In
order to provide you with the assumptions and calculations underlying the .
CEH guidance I have included the following material from Dr. Kimbrough.
In 1984, Kimbrough et al., published a paper which examined the potential
for exposure to TCDD in the environment. Since that time, new information
has become available which appreciably alters the basic assumptions
dealing with both the amount of soil young children ingest and the amount
of absorption of TCDD from Missouri soil within the intestine. It now
appears that the amount of soil ingested by small children is less than 10
grams and is more in the order of 100-2000 mg over a 24-hour period,
(Binder et al., 1986). ' While Kimbrough et al., assumed that 30 percent of
TCDD bound to ingested soil was bioavailable, subsequent tests with soil
from different areas in Missouri have shown that 60 to 80 percent of TCDD
may be absorbed following ingestion (McConnell et al., Science
223:1077-1079, 1984). The nature of these changes are essentially
offsetting so that for Missouri soils the 1 ppb concern level in
residential areas has not changed.
It has been established recently that TCDD bioavailability following
ingestion of TCDD contaminated soil varies a great deal and depends on a
variety of factors, such as:
o The concentration of TCDD in the soil;
o The length, of time the TCDD was in contact with the soil; and
o The composition of the soil [Ombreit et al., Science 232:497499
(1986), and Umbreit et al., Society Toxicology meeting abstract
1273 (1986)].
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197
Page 2 - Mr. David Wagoner
However, the level of concern established by Kimbrough et al.. as 1 ppb
for residential areas has not changed because of these findings.
Based on the assumptions presented in the paper by Kimbrough et al., it .
can be concluded that soil in residential areas contaminated vith 5 to 10
ppb of TCDD vould not present a hazard if covered vith 12 inches of clean
soil. The rationale being that the clean surface soil vould represent a
barrier restricting human access to contact vith the contaminated soil.
In the event that the soil vas disturbed, the 12 inches of clean soil
vould be mixed vith contaminated soil and the concentration at the surface
vould, at most, reach 1 ppb. Thus, the risk in these areas, even after
mixing of the subsurface contaminated soil vith the clean cover soil vould
be comparable to that in other residential areas vhere the concentration
of TfDD is 1 ppb or less at the surface. This approach vould be
acceptable in residential areas vhere the soil has not been physically
disturbed by human activities.
Experience has shown, that concentrations decrease dramatically vith depth
in areas vhere the TCDD vas applied to the surface. The 5 to 10
ppb/12-inch cover cleanup level vould therefore be appropriate for sites
like Castlewood, Times Beach, and Piazza Road. The 5 to 10 ppb vould not
be acceptable for residential areas vhere fill has been brought in from
highly contaminated areas and vhere the levels of contamination may
actually be inverted, resulting in increasing concentrations vith depth.
The article of Kimbrough et al., focused primarily on residential
exposure. However, the methods used to assess exposure in other
situations vere briefly discussed, (see pages 82-85). Basically the dose
a person vill receive depends on his or her activities and the ability of
the TCDD to detach from the soil and enter the body. Thus, at sites vhich
are not residential, the levels of concern may be different. For instance
at a commercial site:
o Children vould not play on * daily basis;
o It vould be frequented by adults who vould primarily walk through
the area;
o It is unlikely that there vould be any gardening; and
o There might be some short-term exposure during construction.
Thus, it is reasonable to assume that there vould be little or no
exposure. In a vorst case scenario, dermal exposure of an adult to 1 gram
of soil 5 times a veek for 6 months per year could be assumed.
Although through ingest ion of TCDD contaminated soil the amount of TCDD
absorbed can be substantial, this is not true for skin absorption. As
discussed in the paper by Kimbrough, et al., (pp. 71-74), the most likely
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198
Page 3 - Mr. David Wagoner
amount that would be absorbed would be 1 percent or less of the TCDD on
the soil. Thus, the dose received from one gram of soil containing 20 ppb
(20 ng/gram of soil) on the skin vould be 0.2 ng or 200 picograms (pg).
The dose, on a kilogram body weight basis, would be 200 pg divided by
70 kg or roughly 3 pg/kg. However, since for these small concentrations
the cumulative dose is more important than the daily doses, it must also
be considered that the dosing is intermittent and not for a lifetime.
Furthermore, the contamination of the area is not uniform and allowances
would have to be made for the percent of contamination at different
concentrations.
If only 10 percent of the area were contaminated at a concentration of
20 ppb then contact with contaminated soil would not be 100 percent but
the corresponding fraction thereof (10 percent in this case). Thus, the
daily dose if averaged out over a lifetime, taking the above assumptions
of 5 days exposure for 6 months per year for 20 years as a basis, would
result in an average daily dose of 330 femtograms/kg body weight.
However, if only 10 percent of an area were contaminated at 20 ppb, then
the dose would more likely be one-tenth of that or 33 femtograms/kg. .
Thus, such contamination with the exposure scenario outlined above would
represent an acceptable risk based on the paper by Kimbrough et al.,
(1984).
It would not, however, be acceptable to leave higher levels of
contaminated soil even with a cover of 12 inches. Leaving such soil with
concentrations higher than 20 ppb could pose a threat to health and the
general environment if the soil were disturbed In the future.
Kimbrough et al., (1984), stated that inhalation of TCDD bound on soil was
negligible (pp. 71-72).' Some work has recently been advanced that TCDD
volatilizes to some extent from soil (Monsanto data, Schroy et al.).
However this has not been substantiated by others (Tanders at al.), and
only involves the surface area immediately above the soil but not the
normal breathing zone of people. Furthermore, there is also re-absorbtion
and slight movement into the lower layers of the soil. Particularly, such
exposures would be even more unlikely in areas which have vegetation or
where the surface is covered in some other fashion. In any case,
volatilization of TCDD would not contribute to the overall exposure of
people frequenting the area.
In summary, these proposed levels would not deviate from the general
concept presented and developed in the paper by Kimbrough et al., (1984).
When the paper was developed all available information on human health
effects was taken into consideration. Since that time additional health
studies have been performed. They have not provided any information which
vould suggest that TCDD is more toxic to humans than was assumed in 1984.
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Page 4 - Mr. David Wagoner
Recently, the information on human health effects was reviewed (Kimbrough,
R.D., and Houk, V.N., Effects of Chlorinated Dibenzodioxin as Chapter 5 in
Solving Hazardous Waste Problems, ACS Symposium Series 338. ACS
Washington, D.C., 1987). Chloracne and some acute health effects have
been found in highly exposed workers. However, there is no evidence that
low level exposure such as that which might result from TCDD in soil at a
concentration of 1 ppb would result in any acute or chronic clinical or
subclinical effects.
Sincerely yours.
Barry L./Johnson, Ph.
Associat%. Administrate1
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APPENDIX C
Material Key, Oily Sludge Pit
200
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KEY
TAN SANDY (LIGHT BROWN)
t
BROWNISH SANDY SOIL
BROWN GRANULAR SOIL
BROWN - GREY SANDY SOIL
DARK BROWN GRANULAR SOIL
GREY SANDY SOIL
GREY CLAY
GREY TO BLACK SOIL
BLACK CHARRED OR BLACK GRANULAR
MUNICIPAL SOLID WASTE
INDUSTRIAL WASTE
RUBBLE/CONSTRUCTION WASTE
OILY WASTE
V////////A
/
KEY
RECORD OF DECISION
SOUTH 8TH STREET LANDFILL
WEST MEMPHIS, ARKANSAS
DIRECTORY: P:\ENVIRO\06639630\ENV [FILE No. KEY-EPA |REV.O
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