::.
PB94-964136
EPAIRODIR05-94/262
April 1995
EP A Superfund.
Record of Decision:
Wright-Patterson Air Force Base
(Operable'Unit 1), Dayton, OH
6/30/1994
......."",.
EP A Report Collection
Information Resource Center
.- US EP A Region 3
Philadelphia, PA 19107
,
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
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RECORD OF DECISION
. .
- OFF-SOURC~ O.PERABLE UNIT
AND
: FINAL REMEDIAL ACTION
LANDFILLS 8 AND 10
Wright-Patterson Air Force Base
.Greene County, Ohio.
P~epared.by:
Office of Environmental Management
Restoration Branch
645 ABW 1El\1R
5490 Pearson Road
Wright-Patterson AFB, OR 45433-5332
FINAL
JUNE 1994
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RECORD OF DECISION
OFF-SOURCE OPERABLE UNIT-LANDmLS 8& 10
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TABLE OF CONTENTS
I
I.
The Declaration
1 ..
A. Site Name and Location
B. Statem~nt of Basis and Purpose
C. Description of Selected Remedy/Rationale for No Action
D. Declaration Statement
United States Air Force
United States Environmental Protection Agency
Ohio Environmental Protection Agency
1
1
1
3
4
5
II.
Decision Summary-
6
A. Site Name, Location, and Description
B. Site History
C. Highlights of Community Participation
D. Scope and Role of the Off-Source Operable Unit
. Within Site Strategy
E. Summary of Site Characteristics
F. Summary of Site Risks
G. Description of the No Action Alternative
6
9
11
12
12
16
17
III.
Responsiveness Summary' .
18
A. Overview
B. Background on Community Involvement
C. Summary of Public Comments
18
18
18
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RECORD OF DECISION
OFF-SOURCE OPERABLE UNIT-LANDFILLS 8 & 10
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TABLE OF CONTENTS
I
Attachment 1 - Community Relations Activities Conducted for
Landfiils 8 & 10'
24 '
Attachment 2 - Administrative Index for Landfills 8 & 10
26
Attachment 3 - Citizens' Comment Letters
29
List of Figures
Figure 1 - Area Location Map
7
Figure 2 - WP AFB Location Map
7
Figure 3 - Location of Landfills 8 & 10 and Area Housing Units
8
List of Tables
, , Table 1 ,- Comprehe~~~ Site Remedial Acnen
13
. Table 2 - Comparison of Major Contaminants in
Groundwater with Regulatory Standards
15
Table 3 - Environmental Media and Potential Pathways of Concern
17
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. RECORD OF DECISION.
OFF-SOURCE OPERABLE UNIT - LANDFILLS 8 & 10
""
I.
THE DECLARATION
A.
Site Name and Location
Off-Source Operable Unit - Landfills 8 and 10
Wright-Patterson AFB'
Greene County, Ohio
(CERCUS Operable Unit 1, Event 4)
B.
,
Statement of Basis and Purpose
This decision document presents the selection of the no action remedial
alternative for the Off-Source Operable Unit and adoption of the previously
approved Source Control remedial action as the final cleanup remedy for the
Landfills 8 & 10 site, at Wright-Patterson AFB. The selection process was
conducted in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA)~ and the National Contingency
Plan (NCP).. This decision is based on the administrative record for the site.
All documents, correspondence, and other resources which comprise the
adrnini~trative record upon which this decision is based are identified in the
attached index.
C.
Description of Selected RemedylRationale For No Action
LandfiUs 8 & 10 comprise the first of eleven operable unit;s identified for
. Remedial InvestigationIFeasibility. Study (RIfFS) at 'Wright..:Patterson' AFB,
Ohio. ,Past waste disposal'siteson-base have been grouped into discreet
operable units based on geographical proximity and similarities in waste
characteristics. Separation of the Landfills 8 & 10 site into two operable units,
one which addressed the source and the other which addressed areas outside
(Le., off-source) but potentially affected by the landfills, enabled the base to
accelerate the cleanup effort. Both Wright-Patterson and the regulatory
agencies agreed there was no reason to delay that portion of the overall site
remedy dealing with the landfills themselves while awaiting sampling results
from areas outside, but potentially affected by the site. The previous'Record of
Decision (ROD) for the Source Control Operable Unit was approved in July
1993 and addressed the sources of contmnination and the threat posed by
migration of contamination to groundwater. The Focused Remedial
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RECORD OF DECISION
OFF-SOURCE OPERABLE UNIT - LANDFILLS 8 & 10
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Investigation Report and Focused Feasibility Study for the landfills themselves
. formed the basis of this previous ROD. The findings of the follow-on Off-
Source RI Report revealed that there were no new pathways of exposure
presenting a risk which had not already Peen identified during the previous
Focused RI, precluding tp.e need for anya.
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D.
Dec:Iar.ItkID Sta-~
UJIited States Ait :rera:
It - been<1J~.""" fbatm -~ ~ acciai1 II ~ef~ atdle_.
'DIe prevbJsI.y app..v1'COd Soarce.Cactto1 Jdt~ actiD11 is b...~~~re.
. . ~;- ..~ dJr;'mcd ~ WI'~ ilddvir.-1 I~i21 ~ ~ Socm:c Comcol
~a1 ciDD. is pn*CtiVeof~ br:aIth m1 ~t c:ompIies Mth . .' .
Federal aut su. ~~,*I: 1Jaat,a;m.1epDy app1:ica.b)e or .cek.... md
~ 10 -~ia1 action. and is,~ 'I:bis £e8Ded) utili-
.fefl1P"';"". so1udoJB aaJ. ~ "~&:'fe tt'ea.b11e4t cr ~~ ~
~"li01;beD~.r.....""exteat~. 'WhiJe1De~~
rop.....1iaI 8CtiaD will ~I;'.~ eiJltinA1e a1i ~ pI1hWYIIi wbere a 1iIIt ,.
~fWl. ~ ~.ta..&tQl1- wi1 ~.... abtwe hcakIl.-bme4 &"ids. k,
a rauIt, aat in ~ with. CERCLA Sec60n 300.430 (f)(4XDh a ~~..
wiJl'be CODduc:ted 'IritbiD Il1e yeaa 86et ~,~wllf of tile j'H1-tiat IL'dan
to GIS81ethattbe IIIDedy~JeS topm..a ~p1~ of~ .
1IeaIIh aod tm and-II,III., .
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THOMAS W. 1- McCAIL. Jr.,
Dep81J~~
of tile Air Fori:::
~-=--'Iu1f Safr.ty aml
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Date
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RECORD OF DECISION
OFF-SOURCE OPERABLE UNIT - LANDFILLS 8 & 10
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D.
Declaration Statement
United States Environmental Protection Agency
It has been determined that no further re.medial action is necessary at the si~. -'
. The previously approved Source Control remedial action is comprehensive and
eliminates the need to conduct additiQnal remedial action; The Source Control'
remedial action is protective of human health and environment, complies with
Feder~ and State requirements that are legally applicable or relevant and
appropriate to the remedial-action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment or resource recovery
technologies, to the maximum extent practicable. While the Source Control
remedial action will ultimately eIiminateall exposure pathways where arlsk was
identified, some contamin:mt~ will remain on-site above health-based levels. As
a result, and in accordance with CERCLA Section 300.430 (f)(4)(ii)t a review
will be conducted within five years after commencement of the remedial action
to ensure that the remedy continues to provide adequate protection of human
health and the environment.
Jll~1I&/
k VALDAS V. ADAMKUS
tr'- Regional Admroistrator
U.S. Environmental Protection Agency Region V
&~Af'
'Dare
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RECORD OF DECISION
OFFwSOURCE OPERABLE UNIT - LANDFILLS 8 & 10
'"
D.
Declaration Sbd.ement
Ohio Environmental Protection Agency
,
It bas been detel'JI$ed that no further remedial action is necessaIy at the site. .
Thc' previously approved SOurce Control remedial action is comprehensive and
e1imiDa.tes ~ need to conduct additional remedial action. The Source Control'
remedial action is protective of bnm::tn health and environment. complies with
Federal and State requirements that are legully applicable or relevant and
appropriate to the remedial action, and is cost~ffective. This remedy util1zes
peI'IIW1enI solutions and alternative treatment or resource recovery
technolo~ies. tQ the maximum extent practicab1e. While the Source Control
remedial action will ultimately eliminate all exposure pathways where a risk was
identified, some c~minan~ win remain on~sitc above health-~cd levels. As
a result, and in accordance with CERCLA Section 300.430 (f)(4)(ii), a review
will be conducted within five years after commencement of the remedial action
to ensure that the remedy conti~ to rrovide adequate protection of b:utn~T)
bealth and the environment. .
6/30/94
Date
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fi. . DECISION SUMMARy
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A.
Site Name, Location, and Description
Wright-Patterson Air Force Base (WP AFB) is 'located in southwestern Ohio, east of the City
of Dayton and adjacent to Fairbom. The Base is approximately 60 miles north'of Cincinnati
and approximately 50 miles west of Columbus (Figures 1 and 2).
,The installation is composed 'of Wright and Patterson Fields, which are separated by State. .
~o~ 444. Wright Field comprises ~ B and.Pat,terson Field comprises Areas A and C. .
Landfills 8 & 10 are located in the northeast comer of Area B. Figure 3 presents the area
location of the site which is bounded on the west by National Road, the north by Kauffman
Avenue, and the east by Zink Road. Landfills 8 & 10 are separated by roughly 1,000 feet.
, An unn~med tributary to Hebble Creek flows through the valley between the landfills.
Currently, the entire area encompassing Landfills 8 & 10 is fenced and posted as "Off Limits" .
The area surrounding the site includes on-base military housing known as the Woodiand Hills
housing subdivision and off-base private homes on National and Zink Roads and Kauffman
Avenue. These off-base homes are serviced by private drinking water wells. The Woodland
Hills military housing units are serviced by the base water supply which draws its water from
another area of base.
GeQgrap~: WP AFB lies within the Till Plains section of the Central Lowlands .
Physiographic Province.. The regional land surface typically appears flat to gently rolling.
Area streams and rivers have developed generally level flood plains, such as the Mad River
flood plain on which much of WP AFB is situated.
The land surface altitude at WP AFB varies from 800 feet above the National. Geodetic Vertieal
Dat;um of 1929 (NGVD) in Ar~ A and C, located within the Mad River flood plain, to 975
,feet above NGVD in Areas B. just west of I .andfill 8. Landfills 8 and 10 are located in a high
area that overlooks the Mad River valley ~ The land surface altitude in the vicinity of Landfill
8 is 945 feet above NGVD; in the vicinity of Landfill 10, the land surface altitude is 920 feet
above NGVD. The Mad River valley immediately north of the 1andfiUs is located about 800
feet above NGVD. '
The area surrounding the landfills is drained by an unn~med tributary to Hebble Creek. This
unt)amed tributary separates the landfills and flows north to Hebble Creek.
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The Woodland Hills military housing subdivision, consisting of 368 dwelling uqiJsi occupies
the area generally north of Landfill 8 and the areas generally west, east, and south of Landfill
10. Seven private homes are located along National Road just west"aIid within 300 feet of
Landfill 8. Five private homes are located east and within about 1000 feet of Landfill 10, with
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COLUMBUS
1-70
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NILES .
DAVTON '.
AIRPORT
Figure 1 - Area location Map
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Figure 2 - WPAFB location Map
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Saae from WPAFB be8e map prepared by ~ Consultants.. March. 1987.
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Figure 3 - location of landfills 8 &, 10 and Area Housing Units
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one on Kauffm~u Avenue and four on Zink Road. A new subdivision -is currently under
construction in the area immediately south of Landfills 8 & 10.
Both landfills support several smaIl stands of cattails that have developed in saturated
depressions on the landfill caps. The depressions are the result of compaction and settling of
the previous soil covering.
Landfill 8 & 10 8T:1PP<>rt two and. eight cattail stands, respectively, that total aPout 3A50 square
feet (about 0.08 acre). Mean stand siZe is less than 0.01 acre.
Climate: The climate in the area is temperate and humid with a mean anmtal temperature of
52.3 degrees Fahre~it (oF) and a mean annual precipitation of 36.25 inches. Precipitation is
evenly distributed throughout the year. In the spring, the average final occurrence of freezing
temperann-es is in mid-April, and in the au~ the average initial occurrence of freezing
temperatures is in late October. Temperatures ofooF or below will be experienced in about
four years out of five, while 100°F or higher will occur in about one year out of five.
Site History
. .. : Landfills 8 & 10 and surrounding base property have been used~
for both operational and recreational purposes. Initially used.for military training, the area
was then converted to fill areas for refuse disposal. Landfill 8, the older of the two, began
operation about 1947 and encompasses approximately 11 acres. Landfill 10 was opened in
1965 and covers about 8 acres. Following closure in the early 1970's, just prior to
constrUction of the . Woodland Hills housing units, the Jandfil1s and surrounding area were then
used for recreation until April 1985. At that time, WPAFB designated the area off-limits and
restricted access to both landfills and the intervening valley with a security fence in response
to concerns expressed by the Ohio Environmental Protection Agency (OEP A) and the United
S~tes' Enviro~ntal ~otection Agency (U.S. EP A) over potential exposure of local residents
to hazardous waste. . .
B.
Refuse was deposited in both landfills in a trench-and-cover operation. General refuSe
CODtaininz unknown quantities of oily wastes, organic and inorganic chemicals, and hospital
wastes was reportedly deposited in the landfills. Fire training activities were conducted in an
area just north of Landfill 8 as early as 1948 until the early 1960's. Trenches east of Landfill
10 were reportedly used for disposal of hazardous chemicals.
The depth of Landfill 8 varies across the refuse trenches from 6 to 44 feet. The thickness of
the cover material varies between 3 and 12 feet. The total volume of waste material buried at
Landfill 8 is estimated at 187,300 cubic yards.
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The depth of Landfill 10 varies across the refuse trenches from 17-25 feet, and the cover
thickness is typically 1-3 feet. The total volume of waste material burled at Landfill 10 is
estimated at 171,600 cubic yards. .
History of Site Investigations and Remedial Actions: Beginning in the early 1980's, several
. investigations have been conducted at Landfills 8 & 10. A records search was perfOImed in
1981, fonowed by a limited field investigation in 1984. This limited field investigation
. included installing monitoring wells and leachate/gas wells, sampling surface water, ~eachate,
and groundwater, and performing geophysical' surveys. ,Additional field investigation work
was conducted in 1986, which included the installation of supplementary monitoring wells; ,
sampling groundwater from both new and existing wells; drilling shallow borings to
investigate landfill covers and estimate infiltration to the landfills; and monitoring landfill,
, cover borings and leachatellandfill gas wells for hydrogen sulfide and combustible gas
concentrations. Resampling the groundwater monitoring wells, as wen as sampling of
leachate, surface Water, and sediment along the unnamed tributary between Landfflls 8 & 10
was accomplished in 1988. '
Response actions were taken by WP AFB in June 1989, in consultation with OEPA, to address
the leachate seep problem closest to the Woodland Hills residential area. Dirt, gravel, and
lime were placed over the seep located on the eastern slope ofI~nc1fiU 10 in an effort to
control odors. A passive temporary leachate collection system was then installed in March '
1991 along the northern and eastern slopes of Landfill 10. This system consists of a
permeable geosynthetic fabric overlaid with an impermeable geomembrane with perforated
piping at the toe of each slope. Leachate from the ~stem holding tank is periodically emptied
to a tanker truck and appropriately diSPOsed of by WPAFB personnel.
Three corollary investigations were conducted during the preiimimny stage of the Remedial
InvestigationlFeasibility Study (RIfFS) for Landfills 8 & 10 begjnniT'lg in 1989. These
included soil gas surveys, additional geophysical surveys, and a study to.identifycombustible
gas (methane) migration from.the 1:4t1dfiUs. A comprehensive RIlFS of Landfills 8 & 10 began .
, in December 1990 and culminated with public release of the final Off-Source Remedial
Investigation (OSRI) Report in October 1993. '
, Military housing units north of Landfill 8 and east of t .andfilll 0 that are adjacent to the
landfills were vacated in 1990, partially in response to a Health Consultation issued by the
Agency for Toxic Substances and Disease Registry (ATSDR). Several factors contributed to
the decision to vacate homes, including temporary, periodic displacement of residents during
the environmental investigation fieldwork; detection of subsurface migration of methane gas
towards the housing units; and long-term planning considerations related to eventual
installation of a multi-layer cap on both landfills. Based upon the absence of significant
concentrations of methane or other gases detected during indoor air monitoring and upon
cOnsultation with ATSDR, U.S. EPA, and OEPA, the Air Force reoccupied selected homes in
1992. All vacated homes north of Landfill 8 were reoccupied. Reoccupied homes were
equipped with continuous methane monitors as a precaution. Because of the eventual
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lDstallationof a multi-layer cap, 14 structures east of Landfill 10 re~ vacant. Of these
vacant homes, there are eight structures which will be demolished in order to install the cap.
Six additional structures which are currently vacant may be salvageable depending on how the
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most Tecent comment period can be found in Section m.-Responsiveness Summary of this
document.
D.
Scope and Role of the Off-Source Operable Unit Wrthin Site Strategy
With consideration for the proximity of area residents to Landfills 8 & 10, a decision was
made among WPAFB, OEPA, and U.S. EPA early during the remedial investigation to
" proceed with selection of -a source control remedy aimed at controlling any current or potential
risks posed by contamination migrating from the site. All parties agreed that this approach
which was based on the initial sampling data would not jeopordize the remaining investigation
of areas outsi<:ie, but potentially affected by, the site and would be compatible with the final .
site remedy. .
This Record of Decision refers to the Off-Source Operable Unit or OSOU (Le., areas outside
but potentially affected by the site), as distinguished from the Source Control Operable Unit or
SCOU (Le., the landfills themselves). Separation of the site into two operable units enabled
WP AFB to accelerate the cleanup effort.
The significance of the no action decision for the OSOU must be viewed in the context of the
Source Control remedial action already chosen for the site (see ROD for Source Control,
1993). The comprehensive elements of the Source Control remedial action are descn"'bed in
Table 1.
Cleanup goals for the site as a whole are to prevent direct contact with on-site contaminants, to
prevent on-site contamination from spreading, to capture contaminated groundwater that has
already migrated from the site, and to e1iminate the potential exposure to site-related
contamimmts during use of private water sources for drinking and showering~
. ".The Sour~ Control remedial action is comprehensiv.e and will achieve these cleanup goals
through a combination of waste conta.inment and treatment and instinltional controls. The
. remedy will address air, gases, soil, surface water/sediments, and groundwater from within
and "downgradient of the landfills and will ultimately eliminate those exposure pathways where
a risk: has been identified. .
E.
Summary of Site Characteristics
Site Geology and Hydrology: The geology of the area consists of Ordovician and Silurian
Age rocks overlain by unconsolidated deposits of Pleistocene Age and Recent Age.
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The Richmond Group of Ordovician Age is the bedrock unit und~rlying m~st of WP AFB. The
Richmond Group consists of up to 265 feet of interbedded shales and limeStones that crop out
in portions of eastern Montgomery and Western Greene Counties.
The Richmond Group is caPPed by t:hin.. discontinuous erosion remmm~ of Brassfield
Limestone of Silurian Age in some areas ofWPAFB. The Brassfield Limestone is a relatively
pure limestone up to 30 feet thick.
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The bedrock reflects a preglacial drainage system that differs somewhat from that currently
seen in the area. This drainage system is masked by overlying unconsoliCiated glacial depositS.
Unconsoli~ materials of the Pleistocene Age overlie bedrock and are represented in the
area by- glacial till and outwash deposits. These materials were deposited during the last
period of major glaciation, the Wisconsin, and are pres~nt throughout the area.
- Glac.ial till cons~ of a heterogeneous Dnxture of cobbleS, gravel, sand, silt 3.nd clay that 'were
deposited directly by the glacier as it moved over the region. These deposits, interbedded with
water-beaPng sand and gravel zones~ locally may form confiniJ\f aquifers or may limit
recharge to underlying unconsolidated aquifers.
I
As the glacier retreated, melt streams flowing through the valleys and lowlands deposited large
accumulations of sand and gravel identified as outwash deposits. Outwash deposits -attain a
maximum thickness of 250 feet at Dayton and usually overlie till deposits. Outwash deposits
form the most prolific aquifer of the Ohio region.
Recent Age alluvium deposited in relatively thin sequences by modem streams is present in the
ground surface adjacent to all major streams. The alluvium consists of both sorted and
unsorted accumulations. of sand, silt, gravel, and clay.
Water is present in the unconsolidated deposits and the underlying bedrock. Water occurs in
intergranular pore spaces in the unconsolidated deposits. In bedroc~ water occurs in
fractu.res,joints, and solution openings in the shale and limestone.
The unconsolidated alluvium, outwash, and till interact to form a complex aquifer system at
WPAFB. Outwash is locally separated from overlying alluvial materials by 2 to 7 feet of
dense, unsorted till composed of clay, silt, gravel, and sand. In many areas, the till layer is
thin or absent and, alluvium directly overlays the outwash deposits. Also, in many areas two
till layers Occur within the glacial outwash, dividing it locally into separate hydraulic units.
, The till, wherever it Occurs, can be descnDed as a semiconfiniT\g layer with many holes, tears,
and missing pieces.
Alluvial deposits may be locally productive, yielding 100 to 500 gallons per minute (gpm).
Normal practice in the Dayton area, however, is to obtain water supplies from the more
productive, underlying glacial outwash deposits. The alluvium, where present at WPAFB, is
typically 40 to 60 feet thick and occurs under water-table conditions. The alluvial deposits
provide base flow to streams during low flow periods.
Outwash deposits yield greater than 1,000 gpm. At WPAFB, the hydraulic conductivity of the
outwash ranges from 1,000 to 3,000 gallons per day per square foot (gpdfft2). The buried
valley aquifer, a Federally desiV1~ted Sole Source Aquifer, is used by WP AFB for water
supply and is also the ,primary unit from which municipal supplies are drawn at the nearby
Dayton Municipal Wellfield on Rohrer's Island. The City of Fairbom's North Wellfield also
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draws water from this aquifer. Fairbom uses this wellfield only during periods of drought for
emergency use and twice a year during hydrant flushing. Groundwater occurs in the outwash
,deposits under both water table and artesian conditions and locally may provide base flow to . .
streams during low flow conditions in areas where it is at or near the ground surface. Total
depth of the sole source aquifer varies between approximately 5~250 feet depending on position
within the buried valley and also depending on water producing horizons within that range.
Groundwater contained in the 5Ca!1ered sand and gravel sequences of till provi~ domestic,
supplies on the order of 10 gpm. The till is generally more than 20 feet thick and may overlie
units of greater productivity: '
The bedrock deposits are a minor source of groundwater. The shale and interbedded
limestone of the Richmond Group yield water of sufficient quantity only for household' use.
The Brassfield Limestone generally yields greater quantities of water than the Richmond
Group and is suitable for both farm and home use.
Nature and Extent of Contamination: Results of the remedial investigation indicate that
both Landfi1h: 8 & 10 are continlIing sources of co~mination and that the conrnmin:mts ~e
dispersed throughout the landfiIIs. Based on historical data and data collected during the
remedial investigation, no extremely high and isolated COI)rnminant concentrations, or "hot
spots", were found that would indicate leaking buried containers or localized ha?ardous waste
disposal areas. Releases of COUt::lmtnants from the landfills are primarily associated with the
production of leachate from refuse and soil. Precipitation perColating through the landfills is
primarily responsible .for leachate production, with groundwater moving lateJ;ally through
Landfill 8 providing additional contribution. COTltamination was found in the groundwater
monitoring wells adjacent to the Jandfins. Spread of the contaminants off-site was limited and
there was no identifiable plume of any COT'lUlmin:mts or group of contaminant~ flowing from
either landfill. Major groundwater contaminants detected in groundwater monitoring wells
located adjacent to the site are presented in Table 2. The depth at which these COI1t::1mina11t~
were found in o~-site ~onitoring wells ranged from approximately 10-60 feet. .
TABLE 2
COMPARISON OF MAJOR CONTAMINANTS IN GROUNDWATER
WITH REGULATORY STANDARDS
CONTAMINANT CONCENTRATION RANGE IN MAXIMUM
OFF-SOURCE WELLS (ugIL) CONTAMINANT
LEVEL (MCL)
(ugIL)
Benzene 1.0-9.0 5.0
1,2-Dichloroeth.ane 1.0-11.0 5.0
Vinyl Chloride 2.0-23.0 2.0
Barium 306-1210 2000
Arsenic 2.0-139J SO
Note: ug/L=micrograms per liter and J =esrirn~ted value
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Elevated concent:ra,tions of vinyl chloride. 1.2-dichloroetbane. barium. and arsenic were
detected in off-source monitoring wells on the east and north side -of Landfill 8. Benzene and'
barium were detected in off-source wells on the west. south. and east sides of Landfill 10. ,
. Ambient (breathing) air and private water sources in the vicinity of Landfill 8 and 10 have not
shown significant chemical contamination attributable to the landfills. However. the potential
exists for these media to become contamin::4ted in the future.
Prevailing background, environmental conditions 'in the general area contributed to surface, .
water/sediment and air contaminantion. Overall. surface water contamination that may be
related to Landfills 8 & 10 was not readily discernable in the unnamed tributary to Hebble
. Creek between the landfills.
The chemicals of concern were found to be unevenly distnouted throughoUt both landfills.
which is expected from a trench-and-cover burial operation. Furtber.l.anofil1s 8 and 10 were
found to be essentially the same in terms of the types and concentrations of contamina"tl).
This conclusion is important in that the clean-up alternative selected for both landfills is the
same. .
F.
Summary of Site Risks
The human health risk assessment was conducted in two phases. Initially, a "qualitative" risk
assessment was performed in conjunction with the. SCOU. This risk assessment addressed only
the risk attributable to the actuallandfiIJs themselves. and was performed as a "screening" tool to
determine if early remedial actions were necessary to reduce human health risk. A "quantitative"
risk assessment was performed in conjunction with the OSRI. This "quantitative" risk
assessment, also known as the baseline risk assessment, addresses risk associated with the
landfills, as well as risk from ~y contamin~nts which may have migrated beyond the landfill
boundaries. The baseline risk assessment was performed withoUt regard to any present or future
remedial actions and it examined risk in both current and future land use scenarios.
Bsing hypothetical worst-case exposure scenarios developed for residential land use, which
assumed residents were ingesting soil directly from the landfiUs and drinking water from areas
adjacent to the landfills which do not ~ntly have drinking water supply wells. the
"qualitative" risk assessment identified ingestion of contamin~ted soil and groundwater, and
inhalation of chemicals volatilizing from household water as exposure pathways which may
exceed target risk levels. Migration of explosive gases, predominantly methane, into homes
directly adjacent to the landfills was also considered to present an unacceptable risk.
The baseline risk assessment identified contaminated groundwater, sediment and soil as posing
an unacceptable risk through both the ingestion and dermal exposure (direct contact) routes.
Inhalation of indoor and outdoor air and direct contact with surface water and leachate seeps
were also identified as potential sources of elevated risk. Table 3 lists the environmental media
16
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and exposure pathways of potential concern based on "the results" of the ~edial investigation.
For purposes of this risk assessment, the exposed individual (the most "at risk") is an individual
who currently lives adjacent to the landfills for a period of thirty years, and spends a certain . -
an;tount of time trespassing on the landfills, resulting in direct contact with, and ingestion ot
cont~minated soils, sediments, and surfaCe waters. For the future land use scenario, the
individual most at risk would be a future resident who might build a home in such close
proximity to the landfills as to be in direct contact with, or ingest, conmminated soils, sediments,
surface water, and/or groundwater, and live in that residence for thirty yeatS.
The ecological risk assessment portion ofthe.base!ine-risk assessment indicated a moderate .
potential for adverse ecological effects, attributable to CODtamin~ted smface water and sediments.
The comprehensive site remedial action (Source Control ROD, 1993) will ultimately eJimin::tte
all exposure pathways where a risk was identified. It will accomplish the following cleanup
objectives: prevent direct contact with site conmminants, prevent future release of contamin~nts,
eliminate potential threat from exposure to groundwater, control surface water nm-off and
erosion, evaluate the effectiveness through long-term monitoring, and continue to restrict access
to the site.
TABLE 3
ENVIRONMENTAL MEDIA AND POTENTIAL PATHWAYS OF CONCERN
ENVIRONMENTAL MEDIA POTENTIAL PATHWAYS OF CONCERN
Groundwater Ingestion, Direct Contact & It)bala.tjon
Landfill Gases Inhalation & FirelExplosion
Leachate Direct Contact & Ingestion
Landfill Wastes & Soils Direct Contact & Ingestion
Ambient (Breathing) Air* Inhalation
Surface Water/Sediments* Direct Contact
*Note.: Prevai~ing background environmental conditions in the area contributed to the risk in
these media. .<
G.
Description of the No Action Alternative
Selection of the no action alternative for the Off-Source Operable Unit is based on several
factors. No new pathways of exposure presenting a risk were identified in the Off-Source RI
Report which had not already been identified during the previous Focused RI, precluding the
need for any additional feasibility studies. The previously approved Source Control remedial
action is comprehensive and will ultimately eliminate all exposure pathways where a risk was
identified. In addition, migration of contaminants beyond the boundaries of the landfills was
found to be limited and contaminants were present at relatively low levels. The no action -
alternative for the Off-Source Operable Unit was the preferred remedy presented in the Proposed
Plan released for public review and comment from 10 January through 10 February 1994.
Adoption of the Source Control remedial action as the final cleanup for the Landfills 8 & 10 site
was also presented in the Proposed Plan. -
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While the Source Control remedial action will ultimately eliminate all exposure pathways where
a risk was identified, some contamin~nts will remain on-site above health-based levels. As a - .
result, and in accordance with CERCLA Section 300.430 (f)(4)(ii), a review will be conducted
within five years after commencement of the remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment
ID. RESPONSIVENESS SUMMARY
A. -
Overview
Wright-Patterson Air Force Base has presented the preferred no action alternative for the Off-
Source Operable Unit and adoption of the comprehensive Source Control remedial action as the -
final Site clean-up for Landfills 8 & 10.
Judging from the comments received during the public comment period, the residents of
Woodland Hills housing area on-base, the surrounding community, and the U.S. and Ohio
Environmental Protection Agencies agree with Wright-Patterson Air Force Base's recommended
alternative. .
B.
Background on Community Involvement
Community interest in Landfills 8 & IOdates back to 1985 when residents in the Woodland Hills
military family housing area-reported material, or leachate, surfacing in their backyards and
noticed an odor coming from. the general vicinity of the landfills.
Members of the community have expressed concerns during various stages of the remedial
investigation and feasibility study. Many of these concerns have been addressed in the previous
Record of Decision for the Source Control Remedial Action (see ROD, July 1993). In ~tion,
concerns raised during the public CQmment period and the public meeting for the Off-Source
. -, Operable ,Unit are addressed in Section ID. C-Snmmary of Public Comments of this ROD which
follows. ' ,- . .
C.
Summary of Public Comments
The public comment period for the Proposed Plan for the Off-Source Operable Unit at Landfills
8 & 10 was held from January 10, 1994 untilFebruary 10, 1994. A public meeting was held on
January 25, 1994. Verbal comments received during the public meeting as well as written,
comments received during the public comment period are addressed in this section.
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Comment Summary and Res.ponse to Local Community Concerns:
(1) A resident wanted to know how extensive was the list of contaminants that we tested for
in the samples taken from the landfills and would we consider that an exhaustive list in ~e
context of landfill age and suspected contaminants? .
Response: The Air Force tested for an extensive number of chemicals during the investigation.
. Early during project planning and work plan developme~t, Air Force environmental specialists
sat down with Ohio EP A, U.S. EP A, and contmctor support personnel to determine what
chemicals should be included in the testing program based 'on past AF activities and suspected
conrnrnimmts. Approximately 270 chemicals were identified as being potential conrnrninants in
the landfills and were tested for during this project. During the course of the investigation, we
sampled soil, groundwater, surface water, sediments (in surface water), gases, and air (both
indoor and outdoor) in a very specific approach. We sampled three times over the course of a
year. At the end of each sampling round, we looked at the testing results and if a chemical didn't
show up;, we made a decision as to whether or not we should continue testing for1hat specific
chemical. The chemical categories included volatile and semivolatile organic compounds,
pesticid~ polychlorinated biphenyls (PCBs), chlorinated herbicides, metals, radioactive
isotopes, dioxins, and dibenzofurans. U.S. EP A and OEP A agreed the number of chemicals
inCluded in our testing program was exhaustive and covered all categories of possible
contaminants.
(2) A resident indicated that the type of cap proposed for these landfills as described in the .
public meeting appears to be for a sanitary landfill situation (Le., household garbage) and
can that be reconciled with the situation described for Landfills 8 & 10 which involves
industrial-type chemicals?
Response: The base believes the sanitary landfill closure being proposed is adequate for the
conrnrninants and potential conrnrnination that exists at these landfills. Our investigation
confirmed .that the site ~s a typical sanitaryJandfill with the bulk of landfill material being
gerierally office waste, paper, etc. We did find some chemicals, but some of these same types of-
chemicals can also be found in a typical sanitary landfill, i.e., petroleum products such as
discarded motor oil. o~o EP A added that high levels of chemicals indicative of hot spots in
isolated areas were not found and, as a result, selective removal of wastes and hazardous site
closure requirements were not needed.
This was not a hazardous waste dump as some had initially feared four years ago when we began
the planning for this investigation.
(3) To address a quality of life aspect of this project, there are still a large number of
vacant houses along Shields Avenue. These vacancies have contributed to the rundown
appearance of the neighborhood. ' What is the ultimate fate of these houses?
Response: We hope to have the vacant units removed by the end of calendar year 1994. The
houses are being removed to facilitate construction of the landfill caps. Some of the homes are
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right at the edge of the landfill and to get the n~cessary elevation of added soil as part of the
various layers of the engineered structure of the cap, these homes will have to be demolished.
Otherwise the back of these homes would De covered up with 3-4'feet of dirt (in the back yard)."
That has prompted us to iden1:i:1Y eight homes which will definitely need to be removed and
another six homes which may need to come down dependent on the footprint of the cap and that's
why these 14 homes remain vacant. In addition, we hope to improve some of the entrance ways
to the Woodland Hills area'in the process.
(4). Is there a plan to ensure adequate drainage in the' area given, the buildup of soH and
cover material that will occur with instaDation of the cap? .
Response: Adequate drainage is one of the important considerations of the remedial design
effort. It is intended that construction of the cap will enhance natural drainage in the area.
(5) Is it correct to state that as a result of the on-site remedial action planned for Landfills
8 & 10 that no actions will be needed off-site?
Response: Yes, that is correct.
(6) One citizen who owns property adjacent to Landfill 8 expressed concern about the
appearance of small areas of seepage on his property possibly coming from the landfill and
migrating groundwater. He wanted to know if there is gro~dwater migrating away from
Landfills 8 & 10, and will the Air Force perform any further testing?
Response: The predominant groundwater flow direction in the vicinity of Landfill 8 is to the
east and north tqward the unnamed tributary to Hebble Creek between the two landfills. There is
a limited groundwater flow line to the south of Landfill 8. Groundwater in the vicinity of
Landfill 1 0 flows radially away from the landfill. Any southward flow from the immediate.
landfill area is diverted either to the east or west by a groundwater high that exists south of
LandfiIIIO. . . .
. .
. There will be an extensive monitoring progrnm. associated with the remedial action to ensure that
effectiveness is being achieved. Samples of groundwater, surface water/sediment, air, and gases
will be collected periodically for analysis during the cleanup effort. Both Ohio EP A and
U.S. EP A Region V will be involved in establishing and evaluating this monitoring program.
(7) How much of a reduction in leachate production will occur once the leachate collection
system is in place?
Response: We are hoping to capture a maximum of 50 gallons per minute through the leachate
collection system, which is a relatively smaIl amount of flow moving through the landfills. In
addition, the remedial action will be designed to keep leachate and contaminated groundwater
from moving past the boundaries of the landfills.
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(8) Just what is the risk to human health as a result of the baseline risk assessment?
,Response: There is a low risk associated with the landfills. In explaining 'the risk in numerical' '
terms, it is important to note that within the general population in this country the incidence of
cancer is 1 in 3 to 1 in 4. That is, in a random population of 1 million people, we can expect
cancer to occur in 250,000 people as a result of lifestyle, genetic heritage or a combination of
, these factors. To put the increased cancer risk associated with Landfills 8 & 10 into perspective,
under specific worst case scenariQ assumptions including living adjacent to the $ite for 30 years
and assuming'no remedial action is 'taken to mitigate risks, there would be less than a 1% . '
increase in the incidence of Cancer over and above the current incidence in the general
population. To apply this relatively small increase in risk to the previous explanation, that would
result in 250,400 ~ of cancer out of 1 million people.
We discovered during our investigation and baseline risk assessment, that background
environmental conditions which occur here in the Miami Valley as a result of urbanfmdustrial
impacts are contributing to the increased risk found in our study. These background
environmental impacts are particularly evident in air and surface water environmental media.
Automobile exhaust, smface waterrun-off from roads, emissions from industrial plants, and
general application of pesticides and herbicides can contribute to background environmental
conditions.
Ohio EP A emphasized that the baseline risk assessment and ~ciated risk numbers are used by
the regulators and the Base primarily to justify taking a remedial action and these numbers do not
necessarily translate into a probability of getting cancer. In conjunction with the baseline risk
assessment, specific risk trigger levels are established by the regulatory agencies. If those trigger
levels are exceeded under conditions considered to be worst case for a particular site, then a
remedial action may be justified in the context of other site-specific considerations.
(9) Has it been determined that Landfills 8 & 10 is not a hazardous materials waste dump?
, ,
, .
Response: Yes, under, the definitions established under the Resource Conservation and
, Recovery Act (RCRA), Landfills 8 & 10 are not classified as hazardous materialslwaste landfills.
(10) One citizen associated with the Fairborn Qty Planning Board indicated that the city's
planning board had recently heard a case involving private property just south of and
adjacent to Landfill 8. He was seeking clarification about the recommended remedial
action.
Response: The Air Force with consensus from Ohio EP A and U.S. EP A Region V has
recommended in the Proposed Plan for the Off-Source Operable Unit that no remedial action is
needed for the areas surrounding the landfills based on limited migration oflandfil1
contaminants. Additionally, the previously approved Source Control remedial action is
comprehensive and will eventually elimin~ all pathways of exposure which were identified as
pathways of concern in the baseline risk assessment The Source Control remedial action will be
confined to the area of the landfills.
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(11) A citizen expressed concerns about the impact of the landfill cap covering and
blocking the existing WP AFB bikeway. Hit jg necessary to cover the bikeway then a new' .
asphalt bikeway should be built closer to Kauffman Avenue. It jg important to connect the
streets in Woodland Hills without having to use Kauffman Avenue. . (Note: The citizen's
. letter jg included in its entirety in Attachment 3 of thjg ROD.)
Response: The existing bikeway on the south side of Kauffimm Avenue between Shie~ds
Ayenue and Long Street will likely be disrupted dming constniction of the cap at Landfill 10. A
temporary walkIbikeway will. be provided south ofKanffinan Aven~ when necessary, to... .
maintain a connection between the streets in Woodland Hills. A pennanent walkIbikeway vvill
be rebuilt once the ~ COnstruction activities are completed. .
The area north of Kauffman Avenue will not be disrupted during constl11ction of the cap at
Landfill 10. Therefore, the proposed Kauffin,m Avenue bikeway extension wi.II not be affected..
(12) A property owner south of Landfill 8 has expressed concerns about possible
contaminantion on hjg land and whether the recommended remedial action as described in
the Proposed Plan for the Off-Source Operable Unit will be an effective cleanup. The land
owner has included a report prepared by hjg environmental consultants which concerns
potential impacts of groundwater contamination. (Note: The citizen's letter and:
accompanying report jg included in its entirety in Attachme!1t 3 of thjg ROD.)
Response: The predominant groundwater flow direction in the vicinity of Landfill 8 is to the
north and east toward the unnamed tributary between Landfills 8 & 10. A limited groundwater
flow line was identified for the area south of Landfill 8. Evidence of shallow groundwater
discharge to the creek has been identified along the creek slopes as evidenced by the presence of
numerous seeps. In addition, we know from stream flow measurements that in the vicinity of the
landfin~ the creek is a "gaining" body of water. That is~ groundwater is discharging to the creek.
In terms of water balance; the ~ount of water in the creek appears from our study to be directly
proportional to the amount of groundwater estimated to be discharging into the creek. The creek
does create a hydraulic' banier for groundWater movement It would be higbly improbable for
groundwater to move under the creek and uphill to the other side given specific hydraulic and
. physical limitations. Deeper groundwater in this area is moving generally toward the buried
valley aquifer to the north and east of Landfills 8 & 10. .
Based on the results of the remedial investigation, which included sampling the creek and creek
sediments three times over a period of one year~ surface water contamination that may be related
to Landfill 8 & 10 is not readily discernible. Contaminants detected in both upstream and
downstream samples are indicative of urban/industrial environmental impact (prevailing
background conditions). However, in order to mitigate any negative contributions to overall
surface water quality resulting from erosion and surface water run-off along the landfill slopes~
the comprehensive site cleanup will include removing asphalt slabs present in the creek bed~ in
addition to smoothing out and capping the landfill slopes.
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. The comprehensive site cleanup will include a leachate collection and treatment system which
will be designed to capture leachate and contaminated groundwater flowing off the landfills.
This collection system will provide hydraulic control and prevent migration of contMn1nated .
groundwater beyond landfill boundaries. Based on the limited migration of contaminants found
during the remedial investigation and the expected capture zone or "zone of influence" of the
system once it is operational, it 'WaS not necessary to expand the leachate collection system in
off-source areas.
An extensive monitoring program will be established to determine the effectiveness of the site
cleanup. Samples of groundwater, surface water/sediments, air, and gases will be collected .
periodically for analysis. Ohio EPA and U.s. EP A Region V will be involved in evaluation of
monitoring results aq.d effectiveness of the cleanup. A formal review will be conducted within
five years after commencement of the remedial action to ensure that the remedy. continues to
provide adequate protection of human health and the environment.
The evaluation of possible contamination on property south of Landfill 8 as presented in the
Tamarron letter has thus far not included considerations of prior site history; present activities
relative to land development, including the impactofearth moving and grading activities; quality
assurance/quality control during sampling to ensure data reliability and usability; and
. background determination using the same sampling methodology employed during this
environmental consultant's limited study. It should be noted that the data collection activities
directly related to the Remedial Investigation of Landfills 8 & 1_0 were regulated by both OEPA
and U.s. EP A and met rigorous quality assurance/quality control standards set by these agencies.
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Attachment 1:
Community RelatioDS Activities Conducted for Landfills 8 and 10
WP AFB Conducted community interviews with the mayors and other local officials in the cities
of Dayton and Fairbom (1986).
WP AFB published the Community Relations Plan (1986).
wp APB issued news release announcing the Consent Order between Ohio and WP AFB.
. (February 1988). .
WP APB established the Information Repository at the Fairbom Branch of the Greene County
Library (1988). t
'WP AFB established the Administrative Record at Wright State University Library, Archives
Section (1988). .
WP APE updated the Community Relations Plan (1989).
WP AFB issued news release announcing interagency agreement between USEP A and WP AFB
(March 1991).
WP AFB held a public meeting at Fairbom High School in Fairliom, OH to update the Woodland
Hills residents on the Remedial Inv~stigation and Feasibility Study at Landfills 8 & 10 (April 29,
1992).
wr AFB issued a news release announcing the availability of the Focused Remedial
Investigation Report for Landfills 8 & 10 (May 29, 1992).
. WP AFB issued a paid public notice advising the Wright-Patterson and surrounding local
. communities of the public comment period on the Proposed Plan for the Source Control at
Landfills 8 & 10. The Faiibori1 Daily Herald and the Dayton Daily News published the notice
three times each. (October and November 1992).
WP AFB issued a news release announcing a public meeting to discuss the Proposed Plan for
Source Control at Landfills 8 & 10 (November 6, 1992).
WP AFB sent a letter to National and Zink Road residents inviting them to the public meeting on
November 10, 1992 to discuss the Proposed Plan for Source Control at Landfills 8 and 10
(October 29, 1992).
WP AFB held a public meeting at Fairbom High School in Fairbom, OH to discuss the Proposed
Plan for Source Control at Landfills 8 and 10 and respond to citizen's questions and concerns
about the proposed plan. App~ximately 50 people attended the meeting, including Woodland
24
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. Hills residents, National Road residents, local media, Environmental Management officials, and
U.S. and Ohio EP A officials (November 10, 1992).
WP AFB issued fact sheets explaining the Proposed Plan for Source Control at Landfills 8 and 10
at the public meeting (November 1992).
WP AFB issued a news release announcing that the public comment period for the Proposed Plan
for ~ource Control at Landtins 8 & 10 had been extended for an additional 30 days (November
27, 1992).' The original public comment period was from October 23-November 23, 1992. The
base accepted comments until December 23,. 1992. . ..
WP AFB issued two paid public notices advising the Wright-Patterson and surrounding
communities that the public comment period on the Proposed Plan for Source Control had been
. extended for 30 days. The Fairbom Daily Herald and the Dayton Daily News published the
public notices (November 1992).
WP AFB sent a letter to National and Zink Road and KauflTnat) Avenue residents and Woodland.
Hills residents advising them the public comment period for the Proposed Plan for Source
Control at Landfills 8 & 10 had been extended for and additional 30 days. (December 2, 1992).
WP AFB issued a news release ~ouncing the first Record of~ecisiop (ROD) for Landfills 8 '
and 10 (August 12, 1993). '.
WP AFB issued a news release announcing the availability of the second environmental
investigation report for Landfills 8 and 10. This report is also known as the Off-Source
Remedial Investigation Report forLandfills 8 & 10 (October 19, 1993). .
WP AFB released the Proposed Plan for the Off-Source Operable Unit for public review and
began the 30 day public comment period (January 10, 1994).
. WPAFB plaCed a series of paid public no~ in l~ newspapers announcing the public
comment period and the public meeting for the Off-Source Proposed Plan. The Dayton Daily
News published five notices; the Fairbom Daily Herald and the Beavercreek News-Current
. pubiished seven notices each (January-February 1994).
WP AFB held a public meeting at Fairbom High School to answer the local community's
questions and concerns about the Proposed Plan for the Off-Source Operable Unit (January 25,
1994).
WP AFB has written more than 30 articles, fact sheets, and newsletter articles related to the
remedial investigation and feasibility study for Landfills 8 and 10 (1988-1994).
25
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Attachment 2:
Administrative Record Index for Landfills 8 and 10.
Document Number: Hard Copy on File
Title: letter EPA to WPAFS Documentation Requirements for Source Control Operable Unit
Landfills 8 and 10
Date: August 14, 1991
Author. WPAFS
Document Number: Hard Copy on File
Title: Letter from WPAFB to EPA - Proposed Schemne for Focused RllFS at Landfills 8 and 10
Date: September 4, 1991 .
Author: WPAFS .
Document Number: Hard Copy on Rie
Title: letter from WPAF;) to EPA - Provides a Revised Proposed Schedule for Focused RIIFS
Date: October 2. 1992
Author: WPAFB
Document Number: Hard Copy on File
Trtle: letter from EPA to WPAFS - Provides a Date-Certain Schedule for Focused RllFS
Date: October 15, 1992
Author. USEPA:
Document Number. Hard Copy on File
Title: letter from WPAFS toEPA - WPAFS Final Schedule Proposal
Date: December 2, 1991
Author: WPAFS
Document Number: Hard Copy on File
Title: letter from EPA to WPAFS - Approving Schedule -
Date: December 9, 1991
Author: USEPA
Microfiche Number: LF8. 10-H1
TItle: Focused Remedial Investigation Report
Date: March 15, 1992
Author: Enaineerin
-------
Microfiche Number: LF8. 1O-H4
Title: Focused Feasibifrty Study
Date: August 28. 1992
Author. En. . . ~. "ence:
Microfiche Number:LF8, 10-H5
Title: Proposed Plan for Source Control Operable Unit
Date: September 1, 1992
Author: WPAFB
Document Number: Hard Copy on File . .
Title: Letter fonT! EPA to WPAFB - Approving Focused Feasibifrty Study
Date: September 24, 1992
Author: USEPA
DoCument Number. Hard Copy on File
Title: Letter from EPA to WPAFB - Approving the Proposed Plan for Source Control Operable Unit.
Date: September 29, 1992
Author. USEPA
Document Number: Hard Copy on File
Title: Letter from OEPA to WPAFB - Approving the Proposed Plan for Source Control Operable Unit.
Date: October 1, 1992
Author. OEPA
Document Number: Hard Copy on File
Title: Letter from OEPA to WPAFB - Approving the Focused Feasibifrty Study
Date: October 20. 1992
Author. OEPA
Document Number: Hard Copy of Public Comments on File
Title: Public Comment Period under the Comprehensive Environmental Response, Compensation. and
UabJTrty Ad. (CERCLA) Section 117
Date: October 23 - December 23. 1992
Author. Various Authors
Document Number: M-N4
Title: Transaipt of Public Meeting Held under CERCLA Section 117
Date: November 10, 1992
Author. WPAFB
Microfiche Number: MI1
T:rt!e: Remecfiallnv~gationJF.eaSlbDity Study Work Plan for 39 Sites As Amended
Date: June 30,1990
Author: Enaineering-Sdence'
USEPA Document Number: EPAI54OIP-911OO1
Title; Conducting Remediallnvestigations/Feasibifity Studies for CERCLA Municipal Landfill Sites
Date: February, 1991
Author: USEPA
27
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USEPA Document Number: OSWER Directive 9355.3-02
TIfIe: Decision DoaIments: The Proposed Plan and Record of Decision, DI'Cift Guidance on Pr~ng
Date: March,1988
Author. USEPA
USEPA Document Number. OSWER Directive 9285.7-016
TIfIe: Risk Assessment Guidance for Superfund, Volume 1-Human Health Evaluation Manual
(Part 6, Development of Prefminary Remediation Goals) Interim
Date: December 13, 1991
Author. USEPA
Document Number: Hard .Copy on File
TIfIe: Proposed Plan for 1heOff-SOurce Operable Unit at Landfills 8 & 10 ..
Date: December, 1993
Author: WPAFB
Document Number. HarcfCopyon File
Tltie: Letter from OEPAto WPAFB-OEPA Approval of the Proposed Plan for the Off-SOurce Operable Unit
at WPAF6LandfiIJs 8 and 10
Date: January 13, 1994
Author.OEPA
Document Number. Hard Copy on File
Tltie: Letter from USEPA to WPAfB.Off..Source Operable Unit Final Proposed Plan
Date: JanuaJy 14,1994
Author: USEPA
DocumentNumber. Hard Copy 00 File
TIfIe: Video Tape and Overhead Briefing Slides for the Public Meeting for the Off-source Operable Unit
ProposedF?lan
Date: January 25, 1994 -
Author: WPAFB
28
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Attachment 3
Citizens' Comment Letters
29
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,,- i.. r.
~~
2- ~ ~FY
~
1304 Horizon Drive
Fairborn, OH 45324-5816
January 27, 1994
Florence Brown. .
Environmental Public Affairs Specialist
645 ABWIEMPABldg 89
5490 Pearson Road
Wright-Patterson AFB, OH 45433-5332
To Whom It May Conce~
This letter is about Landfills 8 and 10 at WPAFB and the proposed plan to solve
problems caused by these two landfills. Overall the project is good and should proceed as
planned. .. .
I do have some minor concerns about the clay cap b~g placed over the land fill. I
have no problem with the clay cap per se but I do object to having the cap 'COvering and
blocking the existing WPAFB Bikeway. !fit is necessary t.o cover the bikeway then a
new asphalt bikeway should be built closer to Kauffman Avenue. It is important to
connect the streets in Woodland Hills without having to use Kauffinan Avenue.
The proposed plan should not affect the proposed Kauffinan Avenue Bikeway
Extension. The Kauffman Avenue Bikeway will stay on the North side-ofKauffinan
. Avenue and then cross at National Road to the South side of the street. Test holes or
shallow wells that were drilled in this area were place so that they would not interfere with
the proposed Kauffmari Avenue Bikeway. .
The Environmental Office at WP AFB is doing a very good job and should be
commended for their work. .
.J"
Sincerely,
~A ~-~._-
ELWOOD 1. EN&' - . .,'
Atch: Map of Bikeways
RECEIVED
JAR 1 3 \994
645 ABW/EMX:'
1~fA
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l
Tamarron
Corporation
"-
. 535 Windsor Park Dr.
Centerville, Ohio 45459
Phone (513) 438-9050
(513) 294-2420
Fepruary 9, 1994
Plorence Bro'wn
Environmental Public Affairs Specialist
645 ABW/EMPA B~dg. 89
5490 Pearson Rd.
Wright~Patterson APB, OH 45433-5332
Dear Ms~ Brown:
Tamarron Corporation owns 1 and adjacent to Landfi 11 Number 8 on
Wright-Patterson Air Force Base. In our environmental studies for
usage of the property we have found some underground water
contamination at subsurface levels.
Enclosed you will find a report from our environmental engineers
indi eating the probl em. I am forwarding this report to you as a
COm..l!ent on the Off-Source Operabl e Uni t Proposed PI an for the
remediation of the problem at Wright-Patterson-AFB. I would like
this concern on record so that if the proposed measures do not
alleviate the problem at least the Wright-Patterson AFB has been
made aWare of the existence of tne problem and that they may bear
additional responsibilities for the cleanup should the proposed
methods not work as anticipated. .
Sincer:~
,?~~tJ ~
Ja~'es W. .lckey
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Enclosed: Groundwater
Jones and Beals
contamination
iss'Ue
prepared by
Lopkwood
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RECEIVED
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GROUNDWATER CONTAMINATION
ISSUES'
Tamarron Co~ration Property
National Road & R&se Drive
Fairbom, Ohio
Prepared For:
Jim Hickey
Tamarron Corporation
7041 Corporate Way
CenterviUe, OH 45459 -
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January 25, 1994
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Prepared By:
LOCKWOOD, JONES AND BEALS, INC.
1563 East Dorothy Lane
Kettering, Ohio 45429
Project No. 8514.EO
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GROUNDWATER CONTAMINATION ISSUES
Taman-on Corporation Property
National Road & Reese Drive, Fairborn, Ohio
INTRODUCTION
This report presents infonnation conceming potential impacts of conrnmin~tion from " .
WP AFB on property" O'WIled by Tammon Corporation ~d locat(:deast of National Road and
directly south or-Landfill 8. Unless these issues are resolved, there is no assurance that the
proposed remedi~tion plan for Landfill 8 will be adequate to protect the Taman-on property
from adverse effects from WPAFB CODtBmination.
It is the assertion of this 'Writer that WP AFB has not conclusively delineated the full impact
of its landfills on the Tamarron property and therefore cannot be certain that the proposed
remediation program will be effective at remediating the conrnminm.on on the subject
property. This report provides the basis for these assertions.
The intent of this document is to present sufficient information to raise a reasonable concern
that important issues remain unresolved and that they should be resolved prior to fin~t17.ing a
remediation plan. The b~den of proof should lie with WP AFB that a problem does not exist
rather than lie with Tammon that there is a problem. '
As a working hypothesis this report assumes that all raw data collected so far by all parties
are accurate so as to determine what inconsistencies. if any. exist in those data. The second
step involves re-examining inferred assumptions that Engineering-Science made in
interpreting the raw data. The premise is that interpretations should change to fit the data
rather than disr~ding data that don't fit the interpretations.
DISCOVERY OF CONTAMINATED GROUNDWATER
Concern over poSsible contamination of the TamaITon property from WP AFB and
particularly Landfill 8 first arose during a site inspection of the property on September 17.
1992. During"the site visitsevera1 groundwater seeps were observed along the stream
flowing northeasterly across the northwest comer of the Tamarron property and at the
detention basin in the northeast comer of the property.
Because of the proximity ofWP AFB Landfill 8, it was prudent to sample these seeps and
this was done on October 2 & 4. 1992. The intention of the .$1impling was to provide an
inexpensive, first approximation screening to determine whether components of concern
were present. The samples were not intended to fully "characterize or delineate possible
conmmin~tion. A more complete description of the screening investigation process for the -
groundwater seeps is attached as Appendix A
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. The analytical results for the groundwater samples, summarized in Table A-I. show elevated
levels of heavy metals and of COD. well above natural background.leVels. For comparison,
Table 1 also includes results of selected samples from previous investigations at WP AFB.
The similarities in the patterns of sample constituents indicate that Landfill 8 is the
presumptive source of the contaminants in the absence of any other knO'WIl or susp~
source.
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INITIAL INTERACDONS WITH WPAFB
The sample results from the groundwater seeps were of sufficient concem that contact was
made with WP AFB and the Ohio EP A to provide them with this information and request
their assistance in further investigations to define the extent of the problem.
. .
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A site waJk-over survey was held on November 3, 1992 which included representatives of
WP AFB, WP AFB consultants, Ohio EPA, UB, and J'amaIrOn Corporation. During this
meeting, the analytical results from the groundwater seeps were provided to the relevant
parties, the sampling locations were observed, and additional information available to
WP AFB was diseussed. The outcome of the site meeting was that WP AFB would consider
the analytical data provided to them and would supply Tamarron with information being
prepared for WP AFB on Landfill 8 and on the Earth Fill Disposal Zones west of National
Road.
WP AFB responded to Temarron Corporation by letter dated November 17, 1992 from.
Ronald J. Lester (copy attached) which included excerpts from the Site Investigation.(SI)
Report for Eight Earthfill Disposal Zones(EFDZ) and the draft Off-Source Remedial
Investigation (OSRI) Report on Landfills 8 and 10. In that letter, WP AFB took issue with
the reliability of the sample results and stated that they did not believe the COD~m;n9n~
found on the Tamarron property were migrating from Landfill 8 or the EFDZ's west of l
LandfillS. On November 30, 1992, UB fequested additional information from WP AFB'
which was supplied on January 22, 1993.
ISSUES TO BE RESOLVED
Based on the information provided above and based on review of the data supplied by
WP AFB, three specific issues affecting the Tamarron property have been identified.
Adequate resolution of these issues should precede fJ.ml1i7.ation of the remediation plans to
ensure that any contam11'ation impacting the TamatrOn property is properly addressed. The
specific issu;es ident:ified are the following:
1. Do the analytical results for the two grab samples taken on the Tamarron property
indicate a reasonable probability that groundwater con~min911on has been
discovered?
2. Is there a reasonable probability that conrnminan~ from Landfill 8 ha-Ve migrated onto
the Tamarron property? .
3. Is there a reasonable possibility that conrnmin.::tt1on £min an unidentified WP AFB
source west of National Road has migrated onto the Tamarron property?
Unless all three of these concerns can be conclusively shown to be invalid, then the probable'
CODUimin911on of the Tamarron property must be fully and adequately addressed in the .
proposed Landfill 8 remediation plan. ,,' .'";,
Based on review of the information supplied by WP AFB, it is our belief that the possibility
of contaminant migration from WP AFB is significant and fully consistent with the primary
data provided by WP AFB. In the sections which follow each of the issues is addressed to
demonstrate that it is reasonable ti> expect that WP AFB undertake additional investig~tion
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regarding contamination of the Tamarron property, and its remediation ~d protection from .
additional contamination.
ISSUE 1. GRAB SAMPLE RESULTS
In Oerober 1992 as part of an Environmental Site Assessment conducted for Tamarron
Corporatio~Lockwood. Jones and BeaI.s (LJ;B) insta.l1ed very shallow monitoring wells. in
order to sample groundwater creating two seeps on the-property. One seep was located m
the storm water detention basin near the northeast comer of the property and the second. seep
was one of many along the stream in the northwest comer of the TamaII'C'11. property located
east of National Road and directly south ofWPAFB Landfill 8.
t
One water sample was taken from each location and sent unfiltered to the laboratory for
. analysis. The intention of the sampling was to provide an inexpensive first approximation
screening to determine whether components of concem were present. The samples were not
intended to fully ~ or delineate possible contAminMion. Wen insta.l1a1ion and
sampling pfocedmes' are-attach.ed to this report. The analytical results were provided to
WPAFB.
Ronald J. Lester in his letter to rIm Hickey ofTamarron Corporation dated November 17,
1992, questioned the analytical results obtained for the two water samples taken by LJB. We
certa.iply agree tbat interpretation of the resul1sdepends on the manner in which the samples
were collected and analyzed. However, we disagree that the results can be rejected; they are
direct evidence of a possible problem and are not contradicted by other evidence.
We also agree that the sampling procedures, number of samples, and quality control for the
two grab samples were not at the level needed to positively quantify the coDtaminMion level;
they were never intended for this purpose. Rather, the samples were taken for screening
purposes.. We do contend that the samples and analytical results are adequate to show
probable conrnmination worthy of additional investigation.
The heavy metal and COD concentrations are far too, high for trace contAmin~tion from
sampling equipment or sample handling to have affected the analytical results to the point
where it would be reasonable to conclude there was not contamination.
The results have also been reviewed for the possibility that by using unfiltered samples the
high metals concentrations were due to the background levels in the soil particles '
constituting the unfiltered suspended solids. The maximum con1ribution from soil particles
can be calculated from estimating the solids concentration in the groundwater samples and
using the WP AFB data for background soil concentrations. _.--
From experienced observatio~ the concentration of suspended solids in the water sample
was well under 100 mgll which can be taken as a very conservative upper limit. From Table
6.2.30, Data Summary for Background SUIface Soil, of the OSRI Report, the maximum
levels detected were used to calculate the maximum possible contribution to the D\etals
concentration from the suspended solids. ..I
The calculations show that for the heavy metals arsenic, barium, chromium, cobalt, and
copper which were found in the unfiltered grab samples, the maximum possible contribution
from background soil particles was 1.00.10. That is, 1.0% or less of the measured amount of
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these metals in the groundwater samples can be attributed to background soil particles in the
water samples; the remaining 99% or more of each metal was in the groUndwater itself. '
In summary, the presumption must be that the cont8TJ11nant levels in the grab samples are
, sufficiently high that there is a problem worth investigating further. Generalized complaints
about sampling procedures and QAlQC cannot obscure the obvious concern raised by the
high levels found in the immediate proximity of Landfill 8.
ISSUE 2.
CONTAMINANT MIGRATION FROM LANDFll..L 8 ONTO THE, .
TAMARRON PROPERTY. '
The possibility that coDrnmin~on from Landfill 8 has migrated onto the Tamarron property
is actually demonstrated directly by the data provided by WP AFB. Plates 5, 6 and 7 of the
OSRI Report actually show flow lines from Landfill 8 onto the Tamarron property in exactly
the area were the seeps into the stream in the northwest comer of the property were
observed. Therefore, WPAFB's own data show that the conrnmin~tM seeps are likely to
have originated at Landfill 8. . .' '
For the 'purposes of this report the stream originating on WP AFB west of National Road,
crossing National Road just north of Reese Drive, flowing northeasterly across the Tamarron
property and entering WP AFB again near: the southeast comer of Landfill 8 shall be referred
to as "Branch A It of the un-named tributary ofHebble Creek. -.
The possibility that the seep found in the detention basin at the northeast camerof the .
Tamanon property also orig;n~ted at Landfill 8 depends on whether Branch A actually
serves as a hydrogeologic boundary. This in turn depends on two factors: 1) whether there
is a good hydraulic connection between the stream and the permeable strata, and 2) whether
there is another stronger sink for groundwater flow further from the source.
The OSRI Report assumed that,Branch A served as a hydrogeologic boundary although there
are no direct monitoring well data to verify this assumption as it relates to the Tamarron
property. Although this assumption is commonly made, it must be explicitly verified
especially when there is information which calls the assumption into' question. Because such
information is available regarding the Tammon site. Branch A cannot be assumed to be a
hydrogeologic boundary without verification. .
Specifically, the stream branches located east of the Tamarron property (north ofPeppertree
Subdivision) are at a lower elevation and were observed during a field visit to contain strong
seep activity where they cut into highly permeable materials. Therefore, there is a
significant probability that these branch streams serve asa strpnger sink than Branch A The
seep activitY is strongest south of the WP AFB property but north ofPeppertree. Additional
seep activity is likely to be found beneath Peppertree where the original ravines were filled
during construction of Peppertree. This is consistent with the substantial amount of dry .
weather flow observed discharging from the storm sewer systems at the upper end of the
cwrent stream channels.
...1' ,
The extent of the hydraulic connection between Branch A and the pe,rmeable strata can only
be determined by locating monitoring wells on both sides of the stream and determining the
true groundwater gradient This was not done during the WP AFB investigations.
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Furthermore, the analytical results from the LJB grab sample located in~e Tamarron
detention basin would be consistent with groundwater flow past Branch A, Until there is
direct evidence to the contrary,' the hypothesis that the detention basin seep originated from
LandfillS cannot be rejected. Therefore, further investigation and protection during
remedia.tion is clearly indicated. '
ISSUE 3.
CONTAMINANT MIGRATION FROM UNID~TJ!t1.ED SOURCE
WEST OF NATIONAL ROAD. '
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A third issue is the possibility that conUlmin~tion from an unidentified source west of
National Road has migrated onto the Tamarron property. Close examination cithe data
provided by WP AFB shows that an important gap exists in the CUITent info~on.
The information for Monitoring Well WP-EFDZ06-M\V03 shows that two wells were set at
this location; one screened from 73 to 78 feet (MW03A) and the other screened from 8 to 13
feet (MW03B). The permeable strata noted on the well logs from 21.5 to 22.5 feet and from
24.5 to 25.3 feet were not- screened. Review of the various geologic cross-sections and
boring logs provided by WP AFB shows that the unscreened permeable strata at MW03 are
the most likely to be those hydraulically connected to the seeps in stream Branch A on the
Tamarron property.
Because M\V03 was not screened in the intervals from 21.5 to 25.3 feet, there is no ,
information available on either groundwater levels or chemical constituents in these strata.
Therefore, there is no certainty that the conrnminants found in the grab samples on the
Tamarron property did not originate west of National Road. Although, no such sources of
contamination have been identified in the information made available to this writer, there is
sufficient possibility that hitherto unknown sources of conrnmin~tion exist at WP AFB that
this possibility demands further investigation.
S~Y AND CONCLUSIONS
As shown in this report, there is significant evidence that cont~min~ted groundwater from
WPAFB, particularly from LandfillS is migrating beneath the property, owned by Tamarron
Corporation, located immediately to th,e south. The major components of this evidence are
the following.
1. Analysis of screening samples from two groundwater seeps on the Tamarron property
has shown the groundwater to be con~minated with heavy metals. '
WP AFB Landfill 8, located immediately to the north,p the only known or suspected
source of COnDmJil1ation that could affect the Tamarron property.
Information provided by WP AFB shows groundwater from Landfill 8 migrating
directly toward one of the two groundwater seeps.
The chemical profIle of the two groundwater seeps is very similar indicatiag the
likelihood they came from the same source. ,...,
The known hydrogeologic conditions are consistent with gromldwater migration from
Landf1l1 8 to both of the sampled groundwater seeps.
2.
3.
4.
5.
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The assumption made by Engineering-Science that the creek flowing across the
northeast portion of the Tamarron property forms a hydrogeologic boundary has not
been verified and is not consistent with the observed coD~m1nation pattern.
Although Landfill.8 is the likely source of the cont~m;nation found on the Tamarron
property) close examination of the available data provided by WP AFB shows that there is
also a possibility of conwm;nant mig!'8.tion from some unidentified WP AFB source west of
National Road. The permeable strata most likely to be connected to the gr.:oundwater seeps,'
'were not $ampled during previous investigations so the possibility of a cont::\mination source
cannot be ex~luded without additional inv.estigation. ..
6.
Based on the information presented in this report, it is concluded that:
1. Groundwater flow patterns south of Landfill 8 have not been adequately defmed by
the work done to date by WP AFB. '
Con~m;nant migration south from Landfill 8 has not been properly delineated.
Previous investigations have not excluded the possibility of con~mination migrating
from an unidentified source west of National Road.
An adequate remedial action plan for Landfill 8 must include protection of the Tainarron
property from further contamination from WP AFB and provide remediation of existing
cont~m;n(Jtion on the Tammon property. To insure adequate protection and remediation,
the deficiencies identified above must be corrected. .
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3.
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APPENDIX A
Inyestigation of Groundwater Seeps
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.. Investigation of Groundwater Seeps.
Samples of groundwater were taken in two locations on Lot 7 north of the subject site
following discovery of discolored groundwater seeps. The samples were authorized for
screening purposes only and were not intended to fully characterize or delineate possible
contamination. '.
The seeps were located in the detention basin in the northeaSt comer of the Tama.m>n
property and along the north side of the creek{Branch A) flowing along the north edge
, of the property. .At the time of the 1992 site visit and the site visit conducted with OEP A
. and WP AFB representatives, the eroded swale ~ the center of the d~on basin . .
contained a seep with a very dark brown-orange .cOlor and a slick appearance, above
which the water in the swale was clear except for minor turbidity, and below which the
standing water had an orange color and an oily swface sheen. The creek below the
catchbasin outlet had orange bacterial growth in areas of calm water. This growth was
similar to that noted in the unnamed creek described below.
Along the northern edge of the Tam.an:on property ran an nnn~med cree~ designated
Branch A, which was tributary to HebbleCreek. The Branch A was fed by a large "
culvert passing under National Road and ori&nating in Wright Patterson Air Force Base
Area B and outflow from a concrete drainagechanne1 serving National Road in the road
easement west of the subject property. Along the north side of the creek in calm areas of
water protected by the creek bank and in a concrete drainage channel on the west side of
National Road, clumps of orange material resembling iron-stained bacterial growth were '.
seen. An orange, rusty stain was aIso seen on the northwest side of the road easement ':
concrete drainage channel.
The creek water and a small amount of standing water at ~eorigin of the concrete
drainage channel were reasonably clear. Near the double bow in the cr~ a metal drum
or wheel hub was noted; no staining or odors were noted in its vicinity. One abandoned
drum in somewhat deteriorated condition was seen on the north side of the creek near the
southwest comer of theWP AFB property. The vegetation around the drum was healthy,
and no stains were noted. No seeps were noted in the area of the drum. .
A total of four shallow groundwater monitoring wells were installed on Lot 7 on
September 17, 1992. WeUs L)B;.TCI-A and UB-TCI-B were located in the vicinity of
the detention basin seep (see Figure 2), while wells LJB- TC2-A and LJB- TC2-B were
located along the north side of the creek near the double bow. Two wells were put at
each location to ensure an adequate sample volume.
The wells were each installed by b~ring with a hand auger to approximately 18 inches
below the surface, inserting a 2" diameter ~VC well riser with.atta.ched one-foot screen
in the boring, backfilling with washed pea gravel to approJcinfately six inches below the
ground surface, and backfilling the rem~1n;.nf space with native soils. Well LJB- TCI-A
was sampled on October 2, 1992, and wen UB- TC2-A was sampled on October 4, 1992. .
The water collected was sampled for Chemical Oxygen Demand (COD), Copper, Iron,
Manganese, Arsenic, Selenium, Mercury, Barium, Cadmium, Chromium, Cobalt,.Lead,
and Silver, Volatile Organic Compounds, Semi-Volatile Organic Compounds ~liiding
Acid and BaseINeUtral Compounds, Pesticides, and Herbicides. Samples were preserved
on blue ice in coolers until their delivery to NET :Midwest, Inc. on October 5, 1992.
The laboratory results for COD, metals, and acetone for both sample wells may be found,
in Table A-I below. For' comparison, sample results for the same compounds for.
A-I
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Table A-1
Laboratory Results for Wells LJB-TC1-A and LJB-TC2-A. and Reported Values for Related WPAFB Leachate Samples
Analyte LJB-TC1-A1. UB- TC2..A2 02-L01 02-L 10 02-L 11 LS01-SW03 LS02-SW03
10/02/92 10/04/92 1989 1989 1989 02112/92 02/12/92
COD, mg/L 522 725 . NA3 NA NA' NA NA
Arsenic. mg/L .0.346 0.134 0.035 0.27 0.012 0.199,' 0.110
Barium, mglL 4.05 1.95 0.25 0.86 ~ 0.28 1.35 1.01
Cadmium. mg/L 0.0056 0.0051 NA NA NA 0.013 0.008
Chromium. Total, mg/L 0.619 0.209 ND 0.043 ND4 0.037 0.032
Cobalt. mglL 0.392 0.121 ND 0.069 ND 0.026 0.027
Copper, mg/L 0.515 0.219 ND 0.069 ND 0.075 0.086
Iron, mglL 593 166 1.9 93.1 9.9 143 103
Lead, mg/L 0.32 0.37 ND 0.052 0.0058 0.09 0.06
Manganese, mg/L 13.0 4.72 1.4 2.0 1.4 1.32 1.11
Mercury, mg/L <0.0002 <0.0002 ND ND ND ND ND
Selenium. mg/L <0.0050 0.0052 NA NA. NA R5 R
Sliver, mg/L <0.0010 0.0016 NA NA NA ND ND
Acetone, ug/L 26.5 17.3 25 (GomposlteValue for Landfill 8, 1984) ND ND
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1 Detent/on Basin Seep
2 StreaffitSeep
3 NA ::: Not Analyzed
4 ND = Not Detected
5 R ::: Sample Rejected by Lab for This Analyte
02-L01. L 10, t.11 from Phase II, Stage 2 Site Assessment Report by Weston, 1989
LS01-SW03 and lS02-SW03 from Draft OSRI Report by Engineering-Science, Inc., 1992
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APPENDIX B
November 17,1994 WPAFB Letter
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DEPARTMENT OF THE AIR FORCE
;<.
HEADQUARTERS, 645ni AIR SASE WING (AFMC)
WRIGHT-PATTERSOH AIR FORCE SASE, OHIO
1 , NOV 1992
FROM::
645 ABil /EHB.
Wr~~-Fatter8on AFB OR
45433-5000
SUB.J:
Environmental Data Collected in Conjunction with the Remedial
Investigation (R.I) of Landfi~~s 8 and ~O in qood~and Hil~s
TO:
Mr. James W. Hickey
Tamarron Corporation
535 Windsor Park Drive
Centervi~le OR 45459
1. During a telecon held on 28 Oct 92 between you and 'Hs Libby Domingue of my
staff, you inquired about the remedia1 actions planned for Landfi11.s (LF) 8 and
10 and the results of the B.emed1a1 Investigation/FeasibiU.ty Study (RIfFS).
You also indicated that your A&E consultants, Lockwood. Jones and Beals (L!B) ,
Inc.. had conducted a. ~imited site enVironmental assessment on your property
~ocated south of LF 8 and bordered on the west by Natioua~ ltoad. Th1.s
assessment was conducted in early Oct in anticipation of the sa1e of your
property and was buad on vUua.1. observati.ons of existing environmeutal ;<
coucl1t1ona and analytica1 results of. two grab samples, one of which was
collected from a large retention ba.sin southeast of LF 8 and the other from the
stream bed just south of LF 8.
2. In order to address your concerns about possib1e contaminant migration
south of 1.F 8. we met with you on 3 Nov 92 and conducted a wa~k-over survey on
your property and observed the 'sa.mp1.1.ng po1.nts e'stabU.shed during the previous
assessment by L!B, Inc. as well as other site features. In addition. we
discussed the methodo~ogy used for co~1ect1ng the grab samples. Several
people, representing several different organizations were. present dur1.ng this
survey: you: Hr Tim Clendeum and H.s Domingue from my staff; H.s Bonnie Buthlter.
Project Coord:inator from Ohio EPA: Dr John Eastman and Hs J'enni.fe.r !U.~~er from
LJBj and project hydrogeo~ogists from Hartin-Marietta. Hr Tim Post and Hr Chr1.s
Wallen. who provide technical support to our program.
3. The attached data are provided for your information as discussed at the
3 Nov 92 meeting. These data include chemi.ca~ analytical results together with
hydrogeo~ogic aud ~itho~ogic information obtaiued from various ~ocatious north,
east and west of your property. These data .are ~erpted from the draft
Off-Source (OS) RI Report for Landfills 8 and 10 (Engineering-Science. Oct 92)
~h1.ch l.s presently undergoing re.v1.ev 'by OEPA and USEPA and the fina~ S1.te. -
Inspection (SI) Report. for Eight Earthfi~~ Disposal Zones (E-S. Aug 92). While
the Focused RJ: and FS Reports for the Source Control Operable Unit at LFs 8 and
10 are availab~e for pub~ic review in the Administrative Record boused at ~
ilr1.ght State Universi.ty. avai.~abi.~i.ty o£ the OSRI: Report must awai.t regulatory'
concurrence. The program which has generated thezso datA-1$ rogula'Ced by bo'Cb
OEPA and USEPA and has met rigorous quality assurance/quality control (QA/QC)
standards set by these agencies.
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LIB'r OP BIIVI1WIDfBJf.l DAn PROVIDBD
TO JIR.JIK DICKEY OF .
'I1IB i'AIIARROH CORPORATION
Excerpts from the Draft
OSRI Report for LFs 8 & 10
lS-S. Oct ~2)
/1"ig 2.6
surface-Wate~ Leachate & Sediment
sampling Looations and streamflow
Measurement Looations Map
Bedrock Topography Map
./Fig 3.6
'/Pi9 3. 7
/Fi9 3.8
,/ Pig 3.9
vFig 3.10
/Fig 3.14 I"
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Plate 3
Plate 5
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Plate 6
Plate 7'
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streamflow Measurements and
Location Map
Cross-Section Location Map
,
North-South Trending Geologic
Cross-Section, A-G
North-South Trending Geologic
Cross-Section, B-F .
East-West Trending Geologic
Cross~Section, I-C
Groundwater and Leaohate/Landfill
Gas Monitoring Well Locations
Water Table & Generalized Groundwater
Hovement in Glacial Till (May 1991)
Water ~able & Generalized'Groundwater
Hovement' ~n Slacial Till (September 1991)
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Water Table & Generalized Groundwater
Movement in Glaoial Till (January 1992)
COMMENTS
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TABLES 6.2.29, 6.2. 30,
AND 6. 2 . 31
DATA SUMMARY FOR BACKGROUND
SURFACB WATER, SURFACE SOIL,
AND STREAM SEDIMENT
CHEMICAL RESULTS FOR
GROUNDWATER SAMPLES
....p. N-l Thru N-3
(SUMMARY OF DATA PRESEnTATION)
/p. N-223
""'p. N-251 Thru N-254
"'p. N-257 Thru "-263
---p. N-421
""p. N-268
"'1>. N-52 Thru "-54
"p. N-74 Thru N-82
.... p. N-304
...p. N-86 & N-81
**VOLATILE ORGANIC
AND METALS ANALYSIS
SUMMARIES
EXCBPTS FROM TUB
FINAL SITE INSPECTION
REPORT FOR 8EFDZs
{S-S. Aug 23}
vtig 2.2
./ Piq 3. 2-4
Konitorinq Well Locations
MW & Soil Doring Locations
for EPDZ 5
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vpiq 3.30
Pig 4.10 & 4.9
HW Locations for BPDZ 6
prelinlnary Remediation Goal (PRG)
compar!son for BFDZ 5 Soil ,
Groundwater
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Fig 4. 11 & 4. ~2
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PRG comparison for EFDZ 6 Soil &
Groundwater
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COMMENTS
SAMPLING LOCATIONS
REPRESENTED:
SAME AS BORING/
WELL CONSTRUCTIon
LOGS
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IGIIWAY EASEMENT
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dc.B.
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AESIOENTI~--" /~, ~ /'
/ ....... .- ....." (EMPTY D~M .?1 .
~ '» ~ /
( ~~ .
\
WB-TC2-Bb~ 1?~']
..! ~ WB-TC2-A
)'
@/
l'
~
OLD WOODS
LOT 6
HEAOWALL
LOT 7
JAT BEAM
YOUNG
"
REESE DRIVE
LOTS 1. 2 & 3
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