United States
Environmental Protection
Agency
Office o<
Emergency and
Remedial Response
EPA/ROO/R07-88/014
September 1988
Superfund
Record of Decision
Arkansas City Dump, KS
-------
.!...~... -
REPORT DOCUMENTATION r 1. REPORT NO.
PAGE I EPA/ROD/R07-88/014
2.
So Reclple.,... Acc.."on No.
.. TItle and Subtttte
SUPERFUND RECORD OF DECISION
Arkansas City Dump, KS
First Remedial Action
~hor(.)
5. ' Re~'} ~~} 8 8
I.
I. Perform/n. O...enlzetlon Rept. No.
9. Performlnc O,.anlzetlon Name and Addr...
10. ProJectITa.k/Work Unit No.
..
-- --.
--
11. Contract(C) or Grant(G) No.
(C)
"
(G)
12. Sponsorin. Or.anizetlon Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 0' Report & Period Covered
.-
Agency
800/000
14.
15. Supplementary Note.
.
II. Abstract (Umlt: 200 words)
The 200-acre Arkansas City Dump site is located in the southwest section of Arkansas
City, Cowley County, Kansas, and is bounded on the west and south by a levee that.
separates it from the Arkansas River. The site falls within the 100-year floodplain and
includes a north waste area and a south waste area, both located in the central
portion. Land use adjacent to the site is a mixture of crop and rangeland, and
commercial an~ residential. Urban areas exist to the north ,and east of th~ site w~th
r~sidential' areas bordering on the north and mixed residential and commercial areas on
east. Approximately 60 residences are adjacent to the eastern boundary" and several
8inesses that employ about 100 to 150 people are located onsite. Ground water flows
predominantly to either the southwest or southeast toward the Arkansas River due to a
ground water divide that exists near the center of the site. Upgradient ground water is
used for drinking purposes by Arkansas City as well as private residences.
Downgradient, east and southeast of the site, private wells are used to provide water
primarily for lawn and garden watering. The site was used as an oil refinery between
1916 and the mid-l920s. Residual acid sludge from the distillation process was disposed
of in pits or on the ground predominantly in the north waste area. Subsequently, 160
acres were used as a municipal landfill, referred to as the Arkansas City Landfill. For
(See Attached Sheet)
17. Document Analysl. a. Descriptors
Record of Decision
_Arkansas City Dump, KS
First Remedial Action
Contaminated Media: sludge
Kev,ron~aminants:T organics,
.". dinfmirs,open-Enaed erms
PNAs
c. COSATI Field/Group
II. Availability Statement
19. Security Class (This Report)
None
21. No. 0' Pases
68
-.----
20. Security Class (This Pase)
None
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTI5-35)
Department 0' Commerce
-------
EPA/ROD/R07-88/014
Arkansas city Dump, KS
First Remedial Action
16.
ABSTRACT (continued)
over 50 years, alkaline sludge from Arkansas City's water treatment plant as well as
municipal refuse and solid wastes were disposed into lime-sludge ponds located in the
south waste area. Investigations conducted since 1980 by the Kansas Department of
Health and Environment have determined that all media are contaminated with various
organics and inorganics primarily from refining wastes. This contamination is a result
of 1,300,000 ft3 of acid sludge and between 500,000 to 1,000,000 gallons of residual
oil product which has mixed with the subsurface soil predominantly between the north and
south waste areas. The principal contributor of organic contaminants to the ground
water, particularly polynuclear aromatic hydrocarbons (PAHs), appears to be the soil
contaminated sediments in the subsurface. However, contaminants are not. migrating
offsite. This Record of Decision (ROD) addresses remediation of acid sludge in the
north waste area; a subsequent ROD will address the oil-contaminated sediments and
ground water contamination. The primary contaminants of concern in the acid sludge are
organics including PAHs, and sulfuric acid.
The selected remedial action for the north waste area operable unit. includes: in
situ neutralization of the acid sludge followed by the installation of a soil cover;
completion of a supplemental feasibility study addressing remedial alternatives for the
su~sequent operable unit; institutional controls including deed restrictions; and ground
water monitoring.
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RECORD OF DECISION
OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION
DECLARATION
Arkansas City Dump site
Arkansas City, Kansas
Prepared By:
u.s. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1988
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RECORD OF DECISION
OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION
SITE ~ AND LOCATION
Arkansas City Dump site
Arkansas City, "Kansas
STATEMENT OF BASIS AHQ PURPOSE
This decision document presents the selected remedial action
for the Arkansas City Dump site in Arkansas City, Kansas,
developed in accordance with the comprehensive Environmental
Response, compensation and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act (SARA) of 1986,
and to the extent practicable, the National contingency Plan.
This decision is based on the administrative record for this
site.
The State of Kansas has assisted in the development of this
decision document and concurs on the selected remedy for Operable
unit One.
DESCRIPTION OF THE SELECTED REMEDY
The remedial. action select~d is part of a total remedial
action; in particular, it is the first of two operable units for
the site. This first operable unit addresses the principal
threats at the north waste area posed to the public health an~
environment, in particular, the threat posed by the acid sludge
presently located in the northern waste area of the site. The
function of this operable unit is to neutralize the acid in the
sludge waste and eliminate the potential for sulfur dioxide
emissions. A soil cover will reduce the direct contact hazar~
associated with any organic compounds remaining in the north
waste area after treatment. The second operable unit will
address the oil-contaminated sediment and the ground water
contamination.
The major components of the selected remedy include:
In situ neutralization of the acid via circulating a
solution of lime in water throug~ the acid sludge
waste, of approximately 47,000 tons.
Covering the north waste area with soil after treatment
is completed.
Completion of a supplemental feasibility study to
develop and evaluate appropriate remedial alternatives
for the oil-contaminated sediments and the ground water
contamination.
-------
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are
applicable or relevant and appropriate and is cost-effective.
However, this operable unit will invoke a waiver respecting
requirements under the Federal and state drinking water
regulations and the state's cleanup policy under the Kansas
ground water contaminant cleanup target concentrations. The
waiver provided by Section 121(d) (4) of CERCLA, as amended, is
invoked regarding drinking water standards because this operable
unit is only a part of the total remedial action which will
attain all applicable or relevant and appropriate requirements.
This remedy satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility or volume as a
principal element and utilizes alternative technologies to the
maximum extent practicable.
/IZ~ fly;/. ..
/ MORR S KAY
"Regional Administrator
9- 2r-~"V
Date
-------
RECORD OF DECISION
OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION
DECISION SUMMARY
Arkansas City Dump Site Superfund Site
Arkansas City, Kansas
Prepared By:
U.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1988
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Section
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
TABLES
TABLE OF CONTENTS
Site Name, Location and Description
site History and Enforcement Activities
2.1 Site History
2.2 Summary of Remedial Investigations
2.3 Summary of Enforcement Activities
Community Relations History
Scope and Role of Operable Unit One: Acid
.Sludge Waste in the North Waste Area
Summary of Site Characteristics
5.1 Types and Characteristics of
Contaminants
5.1.1 Acid Sludge
5.1.2 Oii-contaminated Sediments
5.2 Quantities of Contaminants
Summary of site Risks
Oocumentation" of Significant Changes
Description of Alternatives
Summary of Comparative Analysis of
Alternatives
The Selected Remedy
The Statutory Determinations
11.1 Protective of Human Health ~nd the
Environment "
11.2 Attainment of Applicable or Relevant
and Appropriate Requirements (ARARs)
and To-Be-Considered criteria (TBC)
11.3 Cost Effectiveness
11.4 utilization of Permanent Solutions
" and Alternative Treatment (or resource
" recovery) Technologies to the Maximum
Extent Practicable
11.5 Preference for Treatment as a Principal
Element
ATTACHMENTS
state Letter of Concurrence
Administrative Record Index
Page
3
7
14
15
16
20
22
23
31
37
38
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1.0
SITE NAME, LOCATION AND DESCRIPTION
The Arkansas City Dump site is located in Arkansas City,
Cowley County, Kansas, about 3.5 miles north of the Kansas-
Oklahoma state line (figure 1). The site is located in the
southwest part of Arkansas City and is bounded on the west and
south by a levee that follows the Arkansas River. The eastern
boundarY of the site is bounded by 8th Street. The northern
boundary of the site is- located just south of the railroad bed
located between the levee on the west and loth Street on the east
(figure 2).
The site consists of approximately 200 acres and between
1916 and the mid-1920's was used as an oil refinery and
subsequently as a landfill for more than 50 years. The refinery
was initially called the Milliken oil Refinery, but was later
referred to as the Arkansas City oil Refinery. After closure of
the refinery (mid-1920's), the 160 acres on the site located
south of Madison Street were used for disposal of municipal
wastes. This area was referred to as the Arkansas City Landfill.
Located in the central area of this site is the City of
Arkansas City's lime-sludge ponds. The city disposes of alkaline
.sludge generated from their water treatment plant. In the
southern area of this site there is a lake, commonly referred to
as the sand pit, that encompasses about 20 acres and is the
result of its use as a.borrow pit between the mid-1950's through
the early 1970's. .
Land use adjacent to the site is a mixture of crop and
rangeland, and commercial and residential. Current land-use
categories are shown in figure 3. Urban areas exist north and
east of the site, with residential areas bordering on the north
and mixed residential and commercial areas on the east. A park is
located west of the site along the sandy river deposits. There
are approximately 60 people that have houses directly adjacent to
the eastern site boundary. There are several business that employ
about 100 to 150 people located within the site boundaries, and
approximately 25 percent of the 200 acres of land on the site is
used for commercial purposes.
The entire site falls within the 100-yearfloodplain
(Federal-Emergency Management Agency, 1984).
The site is located within the Arkansas River Valley, which
is characterized by extreme flatness and poorly developed surface
drainage of the Arkansas River floodplain. In general, soil on
the Arkansas City Dump site is very permeable and allows rapid
infiltration by precipitation. Unconsolidated silt, clay, sand
and gravel deposits form an extensive ground water aquifer
parallel to the Arkansas River Valley. At the site, the
unconsolidated deposits range from 30 to 50 feet thick. The
gravel near the bedrock is generally less than 15 feet thick
underneath most of the site. The depth of ground water ranges
from 8 to 12 feet below the ground surface. The saturated
-------
Figure 1.--location of Arkansas City. Kansas.
~
-------
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o 1000 2000 FEET
, , 1 .1
o 300 600 METERS
..
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"
ut ,." -! - I ..
,.....~
FIGURE 2--LoCATION OF ARKANSASCITY DUMP SITE
-------
6
---
9~ 03 '0'
97' 03
----.~.
CD .~..; ':;.::>; :;...~
== 0 .. d.D . ... !
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1.000
1.500
.
50C ME7E~S
2.~ ::-~
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.
250
Figure 3 -- Land use on and adjacent to Arkansas
City Dump site
-------
thickness of the alluvial deposits ranges between 20 feet at the
north end of the site to 40 feet at the south end (figure 4).
Although the direction of ground water is variable, the principal
flow direction on the Arkansas City Dump site throughout most of
the year is towards the Arkansas River (figure 5). A ground water
divide exists near the center of the site, and ground water west
of the divide flows southwesterly toward the river, whereas
ground water east of the divide flows southeasterly toward the
river. The average velocity of ground water in the alluvial
aquifer in the vicinity of the site is very rapid, the flow is
estimated to range from 1 foot per day to more than 2 feet per
day.
The City of Arkansas City owns and operates a city well
field located north and west of site on the west side of the
Arkansas River. The city supplies water to the majority of the
city residents. North and one-quarter mile upgradient from the
site, several residents use water from the alluvial deposits as
their sole drinking water source. East and southeast of the site,
which is downgradient, several residents have private wells. The
ground water from these wells is used primarily for lawn and
garden watering. The investigations indicates that contamination
at detectable concentrations is not moving offsite, and does not
threaten these private wells. Also, there are no water supply
wells located on the site.
The Cowley County Rural Water District No.1 has a supply
well field located about 0.75 mile southeast of the site on
the south bank of the Arkansas, River. The investigation indicates
. that contamination onsite is not 'moving under the Arkansas River
and does not threaten this down gradient supply well.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1
Site History'
An oil refinery was located at the Arkansas City Dump site
between 1916 and the mid-1920's. The refinery processed between
6,000 and 12,000 barrels of oil per day until destroyed by a fire
and explosion in 1927. The refinery was initially called the
Milliken Oil Refinery, but was later referred to as the Arkansas
city Oil Refinery. The site was used as a landfill after closure
of the refinery in the mid-1920's.
A major feature of the refining process used during the
early 20th century was the treatment of each product fraction
with sulfuric acid to effect separation' of asphaltenes and
paraffins, improve the color and remove resinous substances. The
distillate products, such as gasoline, kerosene, and lubricating
oils, we.re treated with sulfuric acid in an agitator. The product
was pumped off the top, and the residual sludge, which was
-------
8
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EXPt..ANA TION
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Figure 4 -- Saturated thickness of alluvial deposits on
and adjacent to Arkansas CTty Dump site. June 1986
-------
9
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Figure 5 -- Direction of ground water flow on and adjacent
to Arkansas City Dump site.
-------
10
generally unmarketable during the early 1900's, was disposed in
pits or on the ground. Acid sludge was produced at almost every
step in the distillation process (figure 6).
The history of waste disposal practices on the site after
the closure of the refinery was determined from historical aerial
photographs. Based on aerial photOgraphs, it appears that most of
the 160 acres of the site located south of Madison street was
used for waste disposal. It is assumed that most of the waste
deposited was municipal waste.
2.2
Summary of Remedial Investigation
The Arkansas City Dump site was first identified as a
potential hazardous waste site in July 1979 by a field inspector
for the Kansas Department of" Health and Environment (KDHE). After
the site was identified, the KDHE in cooperation with the EPA
conducted a more detailed site investigation during the fall of
1980. In 1982 the KDHE received funds from EPA under the Resource
Conservation and Recovery Act to conduct a remedial investigation
referred to as Phase I-remedial investigation. The Arkansas City
Dump site was placed on the National Priorities List in 1984.
The Phase I-remedial investigation provided enough data to
ascertain that the site could pose potential hazards to health
and the environment and documented localized contamination of
water and soil. However, the available information was inadequate
to fully characterize and delineate the principal waste source~
so that remedial activities could be implemented.
In 1985, the KDHE entered into an agreement with the EPA to
conduct an additional remedial investigation to provide data
suitable for evaluating all significant health and environmental
" hazards and for selecting an appropriate. remedial solution to
site problems, as required by The Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980.
Because of funding limitations, this remedial investigation was
to be conducted in two parts, Phase IIA and Phase IIB. The Phase
IIA report was submitted to KOHE in september 1986 and included
preliminary information on the extent of contamination and an
evaluation of public health and environmental impacts, as well as
a general survey of remedial action alternatives that were
considered for the Arkansas City Dump site. -Because of questions
regarding mobility of. air and ground water contaminants offsite,
as well as ecological impacts of the site, the subsequent Phase
IIB-remedial investigation was begun in January 1987. The Phase
IIB investigation also included the evaluation of alternatives to
remediate the problems at this site.
The Phase I - remedial investigation conducted in 1982
confirmed that polynuclear aromatic (PNA) compounds, which are
-------
METHANE. ETHANE GAS
CRUDE
.-'
:-
GASOLINE
Cs'- C10
Sulfuric acid
KEROSENE
C12- C18
GAS OIL
C12 +
FUEL OIL
ASPHALT
......
......
ACid sludge
Polynuclear aromatics and heavy
mOlecular-weight aliphatic compounds
Figure 6 -- Generation of acid sludge by oil industry at the beginnin9
of 20th Century.
-------
known to be present in refinery wastes were leaching into the
ground water, and trace amounts were detected in downgradient
monitoring wells. However, because no drinking water wells
existed downgradient of the site and no contamination was
detected in the Arkansas River or in the adjacent sandpit, it was
concluded that there was no immediate health hazard or
environmental threat. Also it was .determined that most of the
volatile chemicals had dissipated, and there were no toxic gases
or vapors emanating from the site.
The Phase IIA-remedial investigation conducted in 1985 and
1986 focused on: (1) identifying the principal contaminants and
pathways of contamination that could pose hazards to public
health or the environment; (2) characterizing the wastes and
determining the quantities of waste present; (3) identifying and
isolating principal contamination sources; and (4) determining
the mobility characteristics of contaminants so that effective
long-term remedial action may be implemented.
Surface water samples were collected from the ponds on the
. site and from the Arkansas River. Bottom sediment samples also
were collected from all surface water bodies. Su~surface soil
samples were collected during the installation of eleven
monitoring wells and separate locations on and offsite. Samples
were also collected from the acid sludge wastes areas.
Various organic and inorganic contaminants were detected in
the soil, in sludge wastes onsite, in ground water fl~wing
underneath the site, and in surface water and sediments on and
adjacent to the site. In general, organic compounds, particularly
PNA compounds, are the principal contaminants of health and
environmental concern. These contaminants are thought to be from
past oil-refinery operations at the site. PNA compounds, alkanes,
and cycloalkanes are components of crude and refined 'oil. Oil-
soaked soil, detected at most wells installed on the site, and
acid sludge deposits located in the north waste area are the main
sources of organic contaminants in the ground water and soil.
The Phase IIB-remedial investigation and feasibility study
began in January 1987. The objectives of this remedial
investigation were to better define the distribution of PNA and
oil-contaminated soil; determine the presence of significant
contaminants in waste and ground water that possibly were not
detected during either the Phase I and Phase IIA-remedial
investigations: provide data to confirm that contaminants are not
.migrating offsite in ground water at concentrations that would
pose a significant health or environmental hazards: evaluate
possible environmental and health impacts: determine the hazards
associated with disturbing the acid sludge wastes: and to
evaluate the alternatives for remediation activities at this
site.
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Distribution of PNA compounds and oil-contaminated soil was
determined by augering 24 shallow boreholes on the site. Soil
samples were collected from three points at all borehole
locations--land surface, 5 feet below the land surface and at the
water table (generally about 10 feet below land surface). After
the samples were collected, the volatile organics were measured
with a.portable photoionization detector. Most boreholes onsite
had oil-contaminated aquifer material that was encountered near
the water table. These sediments were characterized as a gray,
fine-grained sand that had an oily odor. The thickness of these
sediments was generally a few feet in most boreholes. This oil is
in residual saturation and is immobile.
Seven boreholes were augered to bedrock to collect infor-
mation on depth to bedrock and to determine if contaminants
could have. moved at that depth. These boreholes were sampled at
thre~ points--the water table, at about 20 to 30 feet below land
surface, and just above the bedrock surface. The bulk of the oil-
contaminated sediments occurs at about 10 to 20 feet below the
water table.
The presence of significant contaminants within the sludge
was determined by collecting samples of sludge from the north
waste area and oil and water from an existing monitoring well
located in the north waste area. Twenty to 30 percent, by weight,.
of the acid. sludge is sulfuric acid. Organic compounds in the
sludge are composed primarily of aliphatic, polycyclic,
aromatic, and heterocyclic compounds.
Confirming that contaminants were. not migrating offsit~ was
accomplished by installing and sampling 18 temporary wells placed
between contaminant sources onsite and the Arkansas River. These
wells were installed as six well custers, each containing three
wells. Each well within a cluster was screened at a different
level within the aquifer. Water samples also were collected from
an offsite monitoring wells and a private supply well. The data
results from the supply and monitoring wells sampled offsite
indicated that the concentrations of PNA compounds did not exceed
1 part per billion (ppb).
Ground water samples were collected from monitoring wells to
evaluate the vertical distribution of contaminants from the
onsite waste source or sources to the Arkansas River. The data
provided sufficient information to allow a conceptual explanation
of what was occurring to the contaminants as they moved along the
ground water flow paths.
The determination of possible additional sources of
contaminants was accomplished using geophysical and coring
techniques. Geophysical data were used extensively in
characterizing the presence of wastes on the site. Data collected
during the Phase IIA-remedial investigation were analyzed further
during the Phase IIB-remedial investigation and various features
were identified that suggested the presence of buried metallic
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wastes or conductive fluids. In addition, small values of terrain
conductivity were found to exist near the center of the site,
suggesting the presence of significant quantities of a poorly
conductive material, possibly oil.
An evaluation of ecological conditions was conducted. This.
investigation determined the extent of contamination within the
onsite biota and identified the possible effects due to con-
tamination. Information derived from these analyses were used
to determine gross' levels of ecolOgical impact. Based on this
work, the site does not have any detrimental environmental
effects associated with chemical contamination on the site.
Characteristics of the vegetation community and the composition,
structure, and general health of the rodent communities onsite
show no difference when compared to a reference site.
The assessment of air quality at the site was accomplished
by placing test holes in the acid sludge and collecting air
samples upwind and downwind of the acid sludge wastes. The major
air quality hazard on the site are due to the presence of sulfur
dioxide. Concentrations of about 175 parts per million (ppm) per hour
were measured in air from boreholes installed in the north waste
area.
2.3
Summary of Enforcement Activities
. No negotiations with potentially responsible parties (PRP)
have been conducted up to the present. However, a PRP search has
been initiated.
It is anticipated that prior to the initiation. of the
remedial design, notice letters will be sent to the PRPs. Should
the PRP decline to conduct remedial activities, EPA intends to
provide funding for such activities contingent upon availability
of funds, but will retain its right to seek cost recovery for all
EPA-funded response actions from said PRPs.
3.0
COMMUNITY RELATIONS HISTORY
Community relations activities are conducted to ensure that
the local public has input into the decisions about Superfund
actions and is kept informed about the progress of those actions.
The community's interest in the site has been moderate. The
Kansas Department of Health and Environment (KDHE) has been
responsible for community relations. In February 1987, the KDHE
held informal interviews with some city officials and with some
of the local residents. The majority of these persons were aware
that KDHE and EPA had been investigating the site. Several
residents living near the site indicated that they were not
concerned about the site.
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No citizen inquiries have been made to local, state or
Federal officials. The local newspaper, The Arkansas City Daily
Traveler, presented several articles regarding activities at the
site.
Section 117(a) of CERCLA provides that a notice and brief
analysis of the Proposed Plan must be published, and that the
Proposed Plan be made available to the public. For the Arkansas
city Dump site~ a notice and brief analysis of the Proposed Plan
were published on September 2, 1988, in The Arkansas City Daily
Traveler. The public notice provided a brief overview of the site
and identified the lead agency (KDHE) and the support agency
(EPA). The notice informed the public of its role in the
decision-making process and provided information on the public
comment 'period, the location of the information repositories and
methods by which the public could submit oral and written
comments. The notice also presented the preferred alternative and
requested public comments on the alternative.
To provide the community with a reasonable opportunity to
submit written and oral comments on the Proposed Plan, the
Remedial Investigation (RI) reports and the Operable Unit
Feasibilty Study (OUFS) report, the KDHE and EPA established a
public comment period from september 2 through September 23,
1988. The KDHE and EPA also held on September 15, 1988~ a public.
meeting in the community to present the Proposed Plan and the
reports, answer questions and receive comments.
The Proposed Plan, the RI reports, the OUFS report and the
Administrative Record file were made available for public review
at the Arkansas City Public Library, 120 East 5th Street,
Arkansas City, Kansas, at the Kansas Department .of Health and
Environment, Bureau of Environmental Remediation, Forbes Field,
Topeka, Kansas and at the EPA Region VII Administrative Record
Library in Kansas City, Kansas.
Prior to the beginning of the public comment period, KDHE
and EPA met with the Arkansas City's city Manager. The City
Manager was briefed on the Proposed Plan and, the future response
activities proposed at the site.
No significant comments were received by KDHE or EPA on the
Proposed Plan, the preferred alternative or the Administrative
Record file during the public comment period.
4.0
SCOPE AND ROLE OF OPERABLE UNIT ONE: ACID SLUDGE WASTE IN
THE NORTH WASTE AREA
As with many Superfund sites, the problems at the Arkansas
city Dump site are complex. As a result, KDHE has divided the
work into two smaller units or phases, referred to as "operable
units." An operable unit is a discrete part of a total remedial
action for a site.
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~b
The operable units (OUs) at the Arkansas City Dump site will
address the following:
.OU One: Acid sludge waste in the north waste area.
.OU Two: Oil-contaminated sediments and ground water
contamination.
The feasibility study for Operable unit Two is still under
development. The oil-contaminated sediments appear to be the
significant source of ground water contamination. The feasibility
study for Operable Unit Two is expected to be completed in 1989.
The remedial investigations conducted at the Arkansas City
Dump site have determined that the oil-contaminated sediments in
the subsurface appear to be the principal contributor of organic
contaminants to ground water. The principal organic ground water
contaminants of concern are polynuclear aromatic compounds.
However, even though ground water is contaminated onsite, organic'
and inorganic contaminants are not migrating offsite and the
water onsite is not consumed by anyone.
The principal hazard associated with leaving the waste in
the north waste area undisturbed is direct contact with the
sulfuric acid in the sludge. If the acid sludge is excavated,
sulfur dioxide gas concentrations may exceed the Occupational
Safety and Health Administration standards on the site.
The operable unit presently under consideration at the
Arkansas City Dump is Operable Unit One which addresses the acid
sludge waste in the north waste area. The objective is to
eliminate the threat of direct contact exposure to the acid in
the sludge, to eliminate the threat which may be posed by the
possible sulfur dioxide air emissions and reduce the threat of
direct contact exposure to the organics in the sludge.
The overall strategy is to have Operable Unit One address
the principal threat of direct contact hazard associated with the
acid sludge now, while addressing th$ threat posed by the oil-
contaminated sediments and the ground water contamination as
Operable Unit Two and thereby completing the total remedial
action for this site.
5.0
SUMMARY OF SITE CHARACTERISTICS
The findings of the remedial investigations were that the
principal wastes on the site are: (1) Acid sludge associated with
the oil refinery: (2) spilled oil product, which exists in the
subsurface: and (3) municipal refuse and solid wastes. The
location of each of the three principal waste types on the
Arkansas City Dump site as shown in figure 7.
5.1
Types and Characteristics of Contaminants
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17
5.1.1
Acid Sludge
Principal characteristics typically found in acid sludge are
presented in Table 1. Unlike the sludge d~picted in Table 1, acid
sludge at the Arkansas City Dump site contains a significant
amount of mineral matter (greater than 10 percent). Based on
percolation tests conducted in July 1988, the sludge is quite
permeable; estimates of permeability ranged from about 9 to 13
inches per minute. Twenty to 30 percent, by weight, of the acid
sludge at the site is sulfuric acid. Organic compounds in the
sludge are composed primarily of aliphatic, polycyclic, aromatic,
and heterocyclic compounds. Based on an analysis of weathered
sludge collected from the north waste area, about 30 percent of
the number of organic compounds identified were polynuclear
aromatic hydrocarbons (PNA), with the remaining 70 percent being
various alkanes, cycloalkanes, and polar compounds. Con-
centrations of PHA compounds identified in sludge from the
north waste area are shown in Table 2.
The sludge in the north waste area has a hardened "skin" on
the surface of the wastes that extends 12 to 18 inches into the
sludge. Samples of sludge collected below 18 inches were a
semisolid mass that resembles fresh asphalt. Average thickness of
sludge in the north waste area is about 9 feet. Sludge in the
south waste area is relatively thin (2 feet or less) and appears
to be entirely hardened. Sulfuric acid in this sludge apparently
has been leached from the mass.
. The principal water-soluble organic compounds identified in
the sludge were napthalene, various methyl and dimethyl
napthalene compounds, and phenanthrene. The data shown in Table 2
indicate that PNA concentrations in ground water flowing beneath
the acid sludge were below the detection limit ascertainable with
the analytical equipment. Based on these data, the sludge in the
north waste area does not appear to be a significant source of
PNA compounds in ground water.
The principal gas emanating from boreholes placed. in the
acid sludge in the north waste area is sulfur dioxide. various
fuel-related hydrocarbon gases were found to be emanating from
the acid sludge waste; these gases are listed in Table 3. None of
these gases were found in ambient air above the "skin" of the
sludge in the north waste area.
The treatability study conducted as part of the Phase IIB-
remedial investigation found no significant concentrations of PNA
compounds in the sludge leachate. with deionized water. In
addition, no detectable concentrations of PNA compounds were
found in filter water collected from a monitoring well screened
below the water table beneath the sludge in the north waste area.
Therefore, it has been determined that the acid sludge does not
contribute significant concentrations of dissolved PNA compounds
to ground water.
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18
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Figure 7 -- Principal features of Arkansas City Dump site.
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19
5.1.2 oil-Contaminated Sediments
spillage and disposal of oil and oily wastes occurred over
much of the Arkansas City Dump site. Oil-contaminated sediments
were found during the course of drilling in many of the
boreholes and wells onsite. Most boreholes onsite had oil-
contaminated aquifer material that was encountered near the water
table.' ,
A few wells on the site had free-floating hydrocarbons at
the water table. Information collected from well screenings
suggest that oil was trapped below the water table in the
subsurface in areas where the water table had lowered. When the
water table recovered, the oil remained trapped in pore spaces of
the sediment. This oil is immobile. The oil found had an odor
similar to diesel fuel. Based on a chromatogram of oil collected
from KDHE monitoring well No.6, the oil Qn the site is composed
predominantly of compounds having from 11 to 19 carbon atoms.
Based on analyses of oil contaminated sediments collected from
one of the most contaminated areas, alkanes, alkenes, and
cycloalkanes compose 80 percent of compounds identified in the
oil. About 20 percent of the number of compounds identified in
the oil are composed of aromatic compounds, most of which were
PNA compounds.
Oil-contaminated aquifer sediments at or beneath the water
table have been determined to be the main source of ground water
contaminants. A comparison of filtered water with an 'analysis of
oil, indicates that the principal dissolved contaminants from
this oil are soluble PNA compounds, such as napthalene and
phenanthrene. Methyl napthalene and dimethylnapthalene were also
detected at significant concentrations (see Table 2). However the
largest concentrations of PNA compounds in filtered samples (the
dissolved fraction) are only about 140 to 150 parts per billion
(ug/L). It is assumed that the principal mobile component in
ground water is the dissolved fraction.
Most of'the light aromatic compounds, such as benzene,
toluene and xylene, apparently have volatilized or have been
flushed from these oily sediments by moving ground water. Large
concentrations of volatile aliphatic compounds were detected in
the sediment samples having free oil product. Concentrations of
these volatile compounds, however, do occur at concentrations of
less than 6 to 8 ug/L in water samples collected away from the
contaminated oily sediments.
5.2
Quantities of contaminants
Based on coring work conducted in 1986, a maximum volume of
approximately 1,300,000 cubic feet of acid sludge waste is
located on the site. About 95 percent of this material is located
in the north waste area, with the remaining 5 percent located in
the south waste area. Based on density estimates of the sludge,
about 47,000 tons exist on the site.
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2U
The largest concentration of subsurface oil occurs near the
center of the site in an area of about 9 acres. Although there
are scattered occurrences of oil at several locations on the
site, most oil is located between the north and south waste
areas.
The bulk of the oil-contaminated sediments occurs at about
10 to 20 feet below the water table. The thickness of aquifer
sediments contaminated with residual petroleum is estimated to
range from 10 to more than 20 feet and is caused by smearing of
oil product caused by the rise and fall of the water table.
It is estimated, based on an area of 9 acres, that there are
approximately 500,000 gallons of residual oil product on the
site. Because virtually all of the area between the north and
south waste areas could contain pockets of oil in residual
saturation, the total quantity of oil product on the site could
be between 500,000 and 1,000,000 gallons.
No estimate was made for the volume
deposited at the site because this waste
to be a main contributor of contaminants
site.
of municipal wastes
source does not appear
to ground water on the
6.0
SUMMARY OF SITE RISKS
A baseline public health evaluation was conducted on the
potential hazards associated'with possible exposure to
contaminants found at the site. A baseline public health
evaluation is defined as an anaiysis of site conditions in the
absence of remedial action. It is intended to provide ,an
understanding of the nature of chemical releases from the site,
the pathways of human exPosure, the degree to which such releases
violate applicable or relevant and appropriate environ~ental and
public health requirements.
contamination on the Arkansas City Dump site is primarily
from refinery waste, acid sludge and oil-soaked soils. There are
varipus media contaminated on this site. Soils are significantly
contaminated by organic and elemental chemicals. Ground water is
contaminated by a wide variety of chemicals. Surface water
contained none of the organics, but many of the inorganics and
elementals present in the ground water. There was evidence of air
contamination, when drilling onsite resulted in release of gases
from beneath the surface.
The analysis of surface water, ground water, soil and sludge
samples yielded a list of 137 suspect compounds that were
tentatively identified. A group of 57 positively identified
chemicals were considered initially and then pared down to a
final list of indicator chemicals to be considered for this
public health evaluation. The list of indicator chemicals
selected were considered representative of the highest risk
chemicals at the site. The indicator chemicals used in the
baseline public health evaluation are listed in Table 4.
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21
Chemicals contaminating this site have the potential to move
only from the soil, the ground water or the acid sludge deposits.
Stability of surface soil and sludge, and the presence of site
vegetation appear to prevent air contamination by fugitive
particles. An exception to this may occur if the acid sludge
deposits were disturbed. If this would occur, emissions of
sulfur dioxid~ gases may result.
Human exposure at the Arkansas City Dump site is
characterized by two populations. The greatest potential for
exposure is in the work force of approximately 70 people employed
by the various small businesses located on the site. The second
group are those who intermittently gain access to the site and
would experience infrequent, short-term exposures.
The major pathways of potential exposure to environmental
releases are via inhalation, ingestion or direct contact. At this
site, inhalation exposure is not an exposure route. Fugitive
particle emissions were not significant and sampling for
volatile emissions gave negative results.
Direct contact exposure is deemed to constitute a
significant risk on this site. The north waste area contains
20 to 30 percent, by weight, of sulfuric acid and has a pH of
less than 2. Direct contact by exposed skin would likely result
in caustic burns.
The other route of exposure "present at this site is that .of
ingestion of contaminated media. Ingestion of contaminated soil
or sludge is not considered a likely event; nor is ingestion of
surface water from the two surface containments on this site
considered a likely source of exposure. Ingestion of ground water
and dermal contact are considered significant routes of exposure
on this site.
Aluminum and barium, present in ground water, pose oral
toxicity hazards. Sulfuric acid, present in the acid sludge
waste, poses a direct contact hazard. Because aluminum is poorly
absorbed from the gut, the risk of toxicity from aluminum
consumption via the ground water is not expected to pose a
significant risk. Barium has been implicated in the increased
incidence of heart disease from chronic consumption of water
containing high levels. The concentration of barium found on site
is too low to cause acute toxicity. However; a significant risk
of heart disease from chronic exposure to barium by consumption
of onsite contaminated ground water could result if the ground
water were used for drinking.
There is a carcinogenic risk associated with this site. This
risk is associated only with consumption of onsite ground water
and is due to the presence of arsenic, beryllium and a mixture of
polynuclear aromatic hydrocarbons (PNAs). Most onsite monitoring
wells yielded water with concentrations that would produce a
cancer risk greater than 1:1,000 if consumed by a ?O-kilogram
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adult over a 70-year lifetime. Levels of arsenic in most of the
ground water wells on site exceeded the Kansas Action Level (KAL)
and the EPA water quality criteria ~tandard. Ingestion of arsenic
produced a cancer risk of 3.6 x 10- . lhis a much greater value
th~n the Kansas and EPA targets of 10- . Beryllium was found in
three ground water wells onsite with a maximum concentration of 2
micrograms per liter (ug/l). The KAL for beryllium in ground
water is 0.~3 ug/l and the EPA recommended criteria for cancer
risk of 10- is 3.7 nanograms per liter (ng/l). PNAs were found
in most of the ground water samples analyzed onsite. Due to the
large number of PNAs present in various mixtures, and because
little or no health effects data are available for many of them,
the mixture found onsite was considered as a summation of total
PNAs. The total concentration of PNAs present was evaluated as if
their health effects were the same as an identical concentration
of benzo(a)pyrene, for which there are health effects data
available. The maximum additive concentration of all PNAs
detected in ground water would be 234 ug/l. The KAL for
benzo(a)pyrene is 3 ng/l and the EPA recommended criteria for
cancer risk of 10-6 is 2.8 ng/l. Thus, the total concentration of
PNAs is much greater than the KAL and EPA criteria.
It must be emphasized, however, that the risk. of cancer is
present only if consumption of ground water from contaminated
aquifers were to occur based on a 70-kilogram adult over a 70-
year lifetime. At the present time there is no known consumption'
of onsite ground water, and consumption of offsite water poses no
risk.
. Environmental risks at the site are. considered low. The low
solubilities, sorption characteristics and biodegradability all
tend to minimize environmental risks. Accumulation in plant
material of the contaminants present is not expected to be
significant, nor is entry into the food .chain. Surface water
contamination is not considered to pose a significant risk, nor
is it a source for entry of contaminants into the food chain.
Movement from the current deposits of contamination, the soil,
the acid sludge and ground water is not considered likely, nor
is impact on th~ environment from these sources.
In summary, the principal hazards posed by the Arkansas City
Dump site is through direct contact with the sulfuric acid and
organic compounds in the acid sludge waste and ingestion of the
contaminated ground water onsite. If the sludge is left
undisturbed, sulfur dioxide emissions from the site are not
significant. Presently, there is no consumption of onsite ground
water and consumption of offsite water poses no risk.
7.0 DOCUMENTATION OF SIGNIFICANT CHANGES
The KDHE and the EPA presented the Proposed Plan to the
community in a public meeting held September 15, 1988. The
Proposed Plan as prepared was limited to the acid sludge waste in
the north waste area and identified Alternative 8: Neutralization
followed by Covering with Soil, as the preferred alternative for
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23
Operable Unit One at the Arkansas City Dump site. There have been
no significant changes made to the preferred alternative as a
result of public comments.
8.0
Description of Alternatives
The objective of the Operable Unit Feasibility Study (OUFS)
was to evaluate possible remedial action alternatives and to
pr~sent detailed cost and environmental impact information on the
most feasible remedial action alternatives appropriate for the
acid sludge deposits at the Arkansas City Dump site.
During the evaluation of remedial alternatives, different
processes were evaluated to control the risk of direct contact
and to control the migration of the contaminants. Initially,
eleven alternatives were evaluated and screened based on their
general effectiveness, reliability, implementability, costs and
safety. Table 5 summarizes the effectiveness, implementability,
public health assessment and cost factors of the eleven
alternatives.
Of the eleven options considered, eight of the alternatives
were evaluated further. These alternatives involve technologies,
which have been sufficiently developed so they can be quickly
implemented. These alternatives ranged from no action to treating
all the acid wastes to treating the ground water underneath the
acid s.ludge. The following is a summary of the detailed analysis
presented in the OUFS report dated September .1988. The eigh~
alternatives are numbered to correspond with the numbers in the
OUFS.
ALTERNATIVE 1: NO ACTION
The Superfund program requires that the "no action"
alternative be considered at every site. This alternative does
not provide fo~ cleanup of the acid sludge waste. This
alternative provides only for institutional actions, such as deed
restrictions which would be taken to protect the public from the
hazards associated with the north waste area. The environmental
and public health risks would remain as they presently exist. The
principal hazards associated with the north waste area is the
contact hazard associated with acid in the sludge. Organic
compounds are also contained in the sludge and are composed
primarily of aliphatic, polycyclic, aromatic, and heterocyclic
compounds. If the sludge is disturbed, the potential exists for
the emission of large concentrations of sulfur dioxide onsite and
offsite. The hazards associated with the acid sludge would
remain if this alternative was implemented.
This alternative would require no time for implementation,
and there would be no capital cost associated with the no action
alternative.
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24
Adoption of this alternative would require continuation of
an ongoing sampling and analysis program by the Kansas Department
of Health and Environment. This would include monitoring of
onsite wells and some offsite wells. Analytical results would be
used to monitor future conditions and to assess the effectiveness
of the remedy.
This alternative does not satisfy the remedial act10n
objectives which are to provide adequate protection for public
health and the environment. .
ALTERNATIVE 2: RESTRICT ACCESS
The restriction of access alternative would involve the
installation of a 6-foot chain-link fence topped with three
strands of barbed wire to surround the areas where human contact
with the acid sludge provides a hazards. This would require the
use of a fence and deed restrictions to prevent site entry and
direct contact with the acid sludge waste.
The principal hazard associated with the acid sludge waste
is the risk of direct contact with the acid in the sludge.
Implementation of this alternative would reduce the risk of
direct contact with the acid sludge, but would not eliminate such
risk.
. The hazard posed by the organic' compounds contained in th~
sludge and the potential for the emission of large concentrations
of sulfur dioxide onsite and offsite if the north waste area was
disturbed would remain if this al ternati ve was. implemented.
This alternative does not satisfy the remedial
objectives which are to provide adequate protection
health and the environment, because the toxicity of
the sludge would remain.
This alternative would require only several months .for
implementation. The capital cost for this alternative is
estimated to be $14,000.
action
for public
the acid in .
Adoption of this alternative would require the adoption of
an operation and maintenance program to ensure the integrity of
the fence and the continuation of an ongoing sampling and
analysis program. The Kansas Department of Health and
Environment would be responsible for this program. This would
include inspection of the fence and monitoring of onsite wells
and some offsite wells. Analytical results would be used to
monitor future conditions and to assess the effectiveness of the
remedy.
Deed restriction and other institutional controls would be
required with this alternative. A deed restriction would prohibit
soil excavation and construction of buildings on any part of the
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25
site still containing hazardous materials and would ensure that
drinking water supply wells are not drilled into contaminated
parts of the aquifer upon completion of this alternative.
ALTERNATIVE 5: NEUTRALIZATION
This neutralization alternative would reduce the direct
contact hazards and the potential for emissions of large
concentrations of sulfur dioxide "onsite and offsite if the north
waste area was disturbed.
The principal hazard associated with the acid sludge waste
is the contact hazard associated with acid in the sludge.
Treatability studies conducted on the acid sludge demonstrated
that neutralization of the acid sludge can be carried out with
time. Experiments showed that 20 pounds of lime are needed to
neutralize 100 pounds of acid sludge. Based on density estimates
of the sludge, 47,000 tons exist in the north waste area. The
quantity of lime required to neutralize the sulfuric acid is
estimated to be 9,000 tons.
In situ neutralization of the acid sludge can be achieved by
two treatment methods. The first method involves circulating a
solution of lime in water through the acid sludge to neutralize
the acid in the sludge. The second method involves using
equipment designed to drill through the acid sludge-and mix in
dry lime as the hole is drilled.
" The first method can be implemented by using a post-hole
digger to drill -holes 2 to 3 feet deep at a number of locations.
The holes would be approximately 1 foot in diameter and 3 feet
apart, with a rectangular grid of holes. The holes wo~ld be
filled with a saturated solution of lime in water. Water would be
pumped from wells at the edges of the sludge deposits so that the
water is recirculated within the acid sludge deposit. The water
would be pumped into'a tank which contains lime. From the tank,
the lime solution would flow by gravity through hoses or pipes
into the holes. The pumping rate would be controlled so that the
tank and the holes do not overflow. Based on percolation tests,
the permeability of the acid sludge is approximately 60 inches
per hour.
The second treatment method involves drilling holes and
utilizing a new in-place soil-consolidation method to mix dry
lime into the acid sludge as the hole is drilled. In-place soil-
blending equipment with air pollution control for particulates
and sulfur dioxide is available to minimize the health risk
associated with the emissions from the acid sludge waste. Soil
blending occurs in a cylinder that is 6 to 12 feet in diameter.
Implementation of these treatment methods would not
completely reduce the organic contaminants in the acid sludge.
Organic compounds are also contained in the sludge and are
composed primarily of aliphatic, polycyclic, aromatic, and
heterocyclic compounds. The more soluble organics would undergo
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volatilization while the treatment process was being implemented.
Those organic compounds remaining in the north waste area are
considered immobile.
This alternative would not completely satisfy the remedial
action objectives which are to provide adequate protection for
public health and the environment because direct contact with
organic compounds on the surface 'of the sludge deposits could
occur.
This alternative would require 5 to 8 months to implement
depending on the selected treatment method. The capital costs for
the liquid treatment method are estimated to be $788,000. The
capital costs for the in-place soil-blending treatment method are
estimated to be $2,080,000.
Adoption of this alternative would require continuation of
an ongoing sampling and analysis program by the Kansas Department
of Health and Environment. This would include monitoring of
onsite wells and some offsite wells. Analytical results would be
used to monitor future conditions and to assess the effectiveness
of the remedy.
Deed restriction and other institutional controls would be .
required with this alternative. A deed restriction would prohibit
soil excavation and construction 'of buildings on any part of the
site still containing hazardous materials and would ensure that
drinking water supply wells are not drilled into contaminated
parts of -the aquifer upon completion of this alternative.
ALTERNATIVE 7: SOIL COVER
This alternative would involve covering the acid sludge
waste with soil or a combination of soil and lime. The principal
hazards associated with the acid sludge waste is the contact
hazard associated with sulfuric acid in the sludge. Implemen-
tation of this alternative would significantly reduce the
possibility of someone coming into contact with the acid sludge.
The direct contact hazards associated with the acid sludge
waste from organic compounds contained in the sludge and the
potential for the emission of large concentrations of sulfur
dioxide onsite and offsite if the sludge was disturbed would be
significantly reduced, but would not be eliminated.
This alternative would be implemented by spreading
approximately 100 tons of lime on the surface of the acid sludge
followed by the covering with 2 feet of soil cover. A native
vegetation stand would be established on the soil cover. The
spreading of lime would neutralize the top surface of the acid
sludge. The soil cover would reduce infiltration through the
north waste area.
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This alternative would not completely satisfy the remedial
action objectives which are to provide adequate protection for
public health and the environment because sulfuric acid in the
sludge remains. The possibility exists that the cover could be
disturbed or degrade with time, and direct contact with the acid
sludge could occur. .
This alternative would take approximately 3 months to
implement. The capital cost for this alternative is estimated to
be $131,000.
Adoption of this alternative would require the adoption of
an operation and maintenance to assure the integrity of the soil
cover and the continuation of an ongoing sampling and analysis
program. The Kansas Department of Health and Environment would
be responsible for this program. This would include inspection of
the soil cover and monitoring of onsite wells and some offsite
wells. Analytical results would be used to monitor future
conditions and to assess the effectiveness of the remedy.
Deed restriction and other institutional controls would be
required with this alternative. A deed restriction would prohibit
soil excavation and construction of buildings on any part of the
site still containing hazardous materials and would ensure that
drinking water. supply wells are not drilled into contaminated
parts of the aquifer upon completion of this alternative.
ALTERNATIvE 8: NEUTRALIZATION FOLLOWED BY SOIL COVER
This alternative would implement the same in situ
neutralization and soil cover as described in alternative 5 and
alternative 7.. This neutralization alternative would reduce the
direct contact hazard and the potential for the emission of large
concentrations of sulfur dioxide onsite and offsite if the north
waste area were disturbed.
Implementation of this treatment method would not completely
reduce the organic contaminants in the acid sludge. Organic
compounds are also contained in the acid sludge waste and are
composed primarily of aliphatic, polycyclic, aromatic, and
heterocyclic compounds. The more soluble organics would undergo
volatilization while the treatment process was being implemented.
Those organic compounds remaining in the sludge are considered
immobile.
This alternative would satisfy the remedial action
objectives which are to provide adequate protection for public
health and the environment because direct contact with organic
compounds would be prevented by the soil cover.
This alternative would take approximately 6 to 8 months to
implement. The capital costs for the wet neutralization along
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with soil cover are estimated to be $919,000. The capital costs
for the dry blending neutralization along with soil cover are
estimated to be $2,211,000.
Adoption of this alternative would require the adoption of
an operation and maintenance program to assure the integrity of
the soil cover and the continuation of an ongoing sampling and
analysis program. The Kansas Department of Health and
Environment would be responsible for this program. This would
include inspection of the soil cover and monitoring of onsite
wells and some offsite wells. Analytical results would be used to
monitor future conditions and to assess the effectiveness of the
remedy.
Deed restriction and other institutional controls would be
required with this alternative. A deed restriction would prohibit
soil excavation and construction of buildings on any part of the
site still containing hazardous materials and would ensure that
drinking water supply well~ are not drilled into contaminated
parts of the aquifer upon completion of this alternative.
ALTERNATIVE 9: SOIL COVER AND SEALING THROUGH SOLIDIFICATION
This alternative would involve covering the acid sludge with
soil and the surface would be sealed using solidification
technology. The principal hazards associated with the acid
sludge waste is the contact hazard associated with sulfuric acid
in the sludge. Implementation.of this alternative would
significantly reduce the possibility of someone coming into
contact with the acid sludge.
The hazard associated with the sludge from the organic
compounds contained in the sludge and the potential for the
emission of large concentrations of sulfur dioxide onsite and
offsite if the sludge was disturbed would be significantly
reduced, but would not be eliminated. .
This alternative would be implemented by covering with at
least 2 feet of soil and placing the equivalent" of concrete or
other hardened surface on top of the acid sludge waste. The
hardened surface would reduce the infiltration through the acid
sludge deposits. The area could possibly be used as a parking
lot, playground or ~or commercial activity.
This alternative would provide an extra margin of safety
over the simple soil cover as describe in alternative 7. This
alternative would not completely satisfy the remedial action
objectives which are to provide adequate protection for public
health and the environment because the majority of the sulfuric
acid in the sludge remains. The possibility exists that the
hardened surface could be disturbed or degrade with time, and
then direct contact with acid sludge could occur.
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This alternative would take approximately 3 to 5 months to
implement. The capital cost for this alternative is estimated to
be $328,000.
Adoption of this alternative would require the adoption of
an operation.and maintenance program to assure the integrity of
the hardened surface and the continuation of an ongoing sampling
and analysis program. The Kansas Department of Health and
Environment could be responsible for the entire program. This
would include inspection of the surface and.monitoring of onsite
wells and some offsite wells. Analytical results would be used to
monitor future conditions and to assess the effectiveness of the
remedy.
Deed restriction and other institutional controls would be
required with this alternative. A deed restriction would prohibit
soil excavation and construction of buildings into any part of
the site still containing hazardous materials and would ensure
that drinking water supply wells are not drilled into
contaminated parts of the aquifer upon completion of this
alternative. .
ALTERNATIVE 10: NEUTRALIZATION AND IMMOBILIZATION OF THE SURFACE.
LAYERS
This alternative would involve neutralizing the surface
layer and then solidifying the surface. Implementation of this
alternative would reduce the. possibility of someone coming into
contact with the. acid slud~e waste.
The direct contact hazard associated with the sludge from
the organic compounds contained in the acid sludge waste and
the potential for the emission of large concentrations of sulfur
dioxide onsite and offsite if the sludge was disturbed would be
reduced, but would not be eliminated.
This alternative would be implemented by spreading lime on
the surface and then working the lime into the acid sludge waste
with suitable equipment such as a Bomag blender which is similar
in function to a roto tiller. The top 1 or 2 feet of acid sludge
waste would be neutralized and then followed by solidification
using fly ash, zeolite and a proprietary sOlidification-aiding
reagent (URRICHEM). The treatability study' performed on the acid
sludge demonstrated that the acid sludge can be effectively
treated with the URRICHEM stabilization-solidification process.
This treatment method would involve the treatment of only 10% of
the sludge. The hardened surface would reduce the infiltration
through the north waste area. The area could possibly be used as
a parking lot, playground or for commercial activity.
This alternative would provide an extra margin of safety
over the simple soil cover as describe in alternative 7. This
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alternative would not completely satisfy the remedial action
objectives which are to provide adequate protection for public
health and the environment because sulfuric acid remains in the
majority of the north waste area. The possibility exists that
the cover could be disturbed or degrade with time, and then direct
contact with ~cid sludge could occur.
This alternative would take approximately 5 to 7 months to
implement. The capital cost for this alternative is estimated to
be $858,000.
Adoption of this alternative would require the adoption of
an operation and maintenance program to assure the integrity of
the solidified surface and the continuation of an ongoing
sampling and analysis program. The Kansas Department of Health
and Environment could be responsible for the entire program. This
would include inspection of the solidified surface and monitoring
of onsite wells and some offsite wells. Analytical results would
be used to monitor future conditions and. to assess the
effectiveness of the remedy.
Deed restriction and other institutional controls would be
required with. this alternative. A deed restriction would prohibit
soil excavation and construction of buildings on any part of the
site still containing hazardous materials and would ensure that
drinking water supply wells are not drilled into contaminated
parts of the aquifer upon completion of this alternative.
ALTERNATIVE 11: NEUTRALIZATION AND IMMOBILIZATION OF ALL OF THE
. A.CID SLUDGE
This alternative would involve neutralization and
immobilization of all the acid sludge. This alternative 'would
eliminate direct contact hazards and sulfur dioxide emissions.
Implementation of this treatment method would immobilize the
organic contaminants in the acid sludge.
This alternative would involve either of two treatment
methods. The first treatment method would involve the excavation
of the acid sludge waste. Neutralization of the surface prior to
the excavation would be required to prevent the release of sulfur
dioxide emissions. Lime applied to the surface would be blended
into the surface layer using suitable equipment. This layer then
would be removed using a front-end loader or other suitable
equipment. This process would be repeated as necessary. When the
bottom of the acid sludge is located, the process of
solidification of the neutralized sludge would be started. Fly
ash, zeolites, and a proprietary solidification-aiding reagent
(URRICHEM) would be mixed with the sludge to produce a solidified
product. This material would be placed back into the excavated
hole at the site.
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The second treatment method would involve in-place soil-
blending as described in alternative 5 and the addition of fly
ash, zeolites, and a proprietary solidification-aiding reagent
(URRICHEM) would be blended together with the sludge in a 6- to
12-foot cylinder. The volume expansion caused by added
ingredients would require that some of the product be used either
to elevate the area where the acid sludge waste is located or to
fill some of the lower areas that are nearby.
. .
These alternatives would take over 12 months to implement.
The capital costs for the excavation of the acid sludge followed
by solidification are estimated to be $9,846,000. The in-place
dry blending neutralization and solidification are estimated to
be $9,571,000.
Adoption of this alternative would not require the adoption
of an operation and maintenance program or the continuation of an
ongoing sampling and analysis program.
Deed restriction and other institutional controls would be
required with this alternative. A deed restriction would prohibit
soil excavation and construction of buildings on any part of the
site still containing hazardous materials and would ensure that
drinking water supply wells are not drilled into contaminated
parts of the aquifer upon completion of this alternative.
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
OVERALL PROTECTION. All of the alternatives with the
exception of the no action alternative would provide adequate
protection of human health and the environment. Alternative 1,
which would allow site conditions to remain unchanged, would not
be protective of human health and the environment. The potential
for direct contact exposure to the acid sludge and the potential
exposure to sulfur dioxide emissions from acid sludge deposits
will rema'in. Alternatives 2, 7 and 9. protect human health, but
they do not change the environmental state of the acid sludge.
. For alternatives 1,. 2, 7 and 9 the sludge remains acidic and
the possibility of sulfur dioxide emissions if the sludge was
excavated is not eliminated. Alternative 2 would reduce the risk
of direct contact by restricting the access. Alternatives 7 and 9
would provide an environmentally acceptable surface condition at
the site, but would not eliminate the possibility of sulfur
dioxide emissions if the acid sludge waste was excavated.
Alternative 7 would allow the site to support natural vegetation
and some types of human activity. Alternative 9 would allow the
surface to be used as a parking lot, playground Dr for commercial
activity.
Alternatives 5, 8, 10 and 11 would all be protective of the
public health and the environment. For these alternatives, the
acid sludge would be neutralized: thereby, the direct contact
threat would be eliminated or reduced with respect to the acid in
the sludge. The sulfur dioxide emissions from the acid sludge
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waste would be eliminated or reduced. Solidification' in
Alternatives 8, 10 and 11 would reduce the ability of
infiltration through the north waste area to leach the
contaminants.
Alternative 11 would be somewhat more protective than
alternatives 5, 8 and 10 because it has the potential to reduce
organic compounds by volatization in the sludge as a source of
ground water contaminants. However, the ground water onsite is
presently not used for drinking purposes, is not a present need
and the acid sludge is not a significant contributor to onsite
ground water contamination. Alternatives 8, 10 and 11 would allow
the site to support natural vegetation and/or some type of human
activity. Alternatives 5, 8, 10, and 11 have the potential to
reduce concentrations of iron, .anganese, sulfates and to
increase the pH of ground water beneath the acid sludge.
Alternatives 5, 8 and 11 would have a greater potential to
reduce these contaminants because all the acid sludge, not just
the top portion, would be neutralized.
Deed restrictions for all alternatives would be required to
prohibit soil excavation and construction of buildings on any
part of the site still containing hazardous materials upon
completion of Operable Unit One.
COMPLIANCE WITH ARARs. section 121(d) of The Comprehensive
Environmental, Recovery, Compensation, and Liability Act
. (CERCLA), as amended by the Superfund Amendments and.
Reauthorization Act (SARA), requires selection of a remedial
action that is protective of human health and the environment.
The EPA's approach to' determining protectiveness involves risk
assessment, considering applicable or relevant and appropriate
(ARARs) requirements promulgated under Federal or State law and
to-be-considered criteria (TBC). .
ARARs (and TBCs necessary for protection) must be attained
for hazardous substances, pollutants or contaminants remaining on
site at the completion of the remedial action, unless a waiver of
an ARAR is justified. Table 6 provides a list of the appropriate
ARARs and TBCs for the site.
Alternatives 1, 2, 7, 9, and 10 would not be protective of
human health and the environment because the acidic material
would remain in the north waste area. Alternative 2 would be
somewhat more protective than alternative 1'because the fence
around the north waste area would restrict access. Alternatives
7, 9 and 10 would be'somewhat more protective than alternative 2
because the risk of direct contact exposure with the acid sludge
would be reduced or a portion of the acid sludge would be
neutralized.
Alternatives 5, 8 and 11 would be protective of human health
and the environment because these alternatives would neutralize
all the acid sludge and, thereby, the direct contact risk.
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Alternatives 1, 2 and 5 would not meet ARARs under the
Resource Conservation and Recovery Act (RCRA) definition of a
closure-in-place. Alternatives 7, 8, 9, 10 and 11 would meet
ARARs under the RCRA definition of a hybrid closure. A hybrid
closure or alternative approach to closure may occur where RCRA
closure is not applicable but may be relevant and appropriate.
This would be where residual contamination is above health-based
levels and contamination does not pose a direct contact exposure
threat or impa"ct ground water. .
Alternatives 5, 8, 10 and 11 would need to met ARARs for
sulfur dioxide emissions while the neutralization process is
being implemented. Disturbance or excavation of acid sludge waste
may exceed the standard of sulfur dioxide for employees of
onsite businesses or construction workers.
ARARs and TBCs would not be .et for alternatives 1, 2, 7, 9
and 10 for the existing State and Federal drinking water
standards. Alternatives 5, 8 and 11 have the potential to reduce
the contaminants in ground water beneath the site. Alternative 11
is the only alte~native that has the potential to significantly
improve the ground water under the site with respect to organic
and inorganic contaminants in the acid sludge.
Ground water underneath the site contains both organic and.
inorganic contaminants that exceed the acceptable concentrations
for drinking water; .however, this does not pose an immediate
health hazard because water from wells onsite is not consumed. by
anyone and the contaminants are not migrating offsite. From the
" ground water data, it has been determined that the north waste
area is not a major source of contaminants to the ground water.
The principal contributors of organic and inorganic contaminates
are the oil-contaminated sediments and the solid waste landfill
area.
The CERCLA, as amended, provides that under certain
circumstances an ARAR may be waived. These waivers apply only to
meeting ARARs with respect to cleanup onsite.
CERCLA provides a waiver where the cleanup being proposed is
only an interim measure. Specifically, CERCLA Section
121(d)(4)(A), as amended, provides that such waiver may be
invoked if the remedial action selected will only be part of a
total remedial action that will attain such levels or standards
of control when completed.
Operable Unit One will invoke a waiver. The selected
alternative (alternative 8) will not meet ARARs for the Federal
and State drinking water standards or for theTBCs for the Kansas
Groundwater contaminant Cleanup Target Concentrations. However,
Operable Unit One is an interim measure; and it is intended that
the ARARs and TBCs will be attained in the final remedy (Operable
Unit Two) upon completion.
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LONG TERM EFFECTIVENESS. Long-term effectiveness and
performance are evaluated with respect to the magnitude of
residual risk, adequacy and reliability of controls over
remaining waste and long-term management requirements.
Alternative 11 would provide the best long-term
effectiveness. because this alternative uses treatment and
fixation technologies on the acid sludge waste. Alternative 11
would neutralize the acid in the sludge and the solidification
process would immobilize the remaining organic compounds.
Alternatives 5 and 8 would Deutralize the acid in the sludge and
provide long-term effectiveness because the direct contact hazard
and the potential sulfur dioxide emissions would be eliminated.
Alternatives 7, 9 and 10 would employ a multimedia cap to
reduce the potential for direct contact and for sulfur dioxide
emissions. Leaching of organic compounds into the ground water
will be reduced somewhat more with alternatives 9 and 10 because
they would solidify the surface and provide a hardened surface.
The cap in alternative 7 is effective at reducing risk from
direct contact with the acid sludge, but in the long-term it is
less reliable than solidifying the top surface. These'
alternatives have long-term ground water monitoring and cap
. maintenance requirements. These maintenance activities (mowing, .
revegatation, cap repair) are more critical for these
alternatives since not all of the acid sludge are neutralized
under the cap. Failure to detect a probl~m with the cap may
result in direct contact exposure with the acid sludge, sulfur
dioxide emissions and further degradation of the ground water
through leachate production.
Alternative 2 is a reliable technology to reduce the direct
contact hazards associat~d with the acid sludge. However, a fence
is susceptible to vandalism and periodic. inspection and repair
would be required.
Alternative 1 would provide no long-term effectiveness in
protecting human health and the environment. The contaminants
that would remain onsite would diminish over time as a result of
dispersion, adsorption, biodegradation, and vOlatilization.
Ground water monitoring would still need to be implemented to
monitor the migration of residual contamination.
Deed restrictions for all alternatives would be required to
prohibit soil excavation and construction of buildings on any
part of the site still containing hazardous material upon
completion of Operable Unit One.
REDUCTION OF TOXICITY, MOBILITY OR VOLUME. Alternative 11
is the only alternative which would use treatment to reduce
toxicity, mobility and volume of contaminants in the acid sludge.
Alternatives 5, 8, and 10 would eliminate or reduce the toxicity
and volume of contaminants in the acid sludge by neutralizing the
acid in the sludge and the potential for sulfur dioxide
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emissions. Alternatives 5 and 8 would eliminate the toxicity and
volume of contaminants than alternative 10 because all the acid
sludge, not just the top portion, would be neutralized.
Alternatives 7, 8, 9 and 10 would reduce the mobility of
contaminants by reducing the infiltration of water into the
sludge. Alternatives 1 and 2 will achieve no reduction of
toxicity, mobility or volume of contaminants on the site.
SHORT-TERM EFFECTIVENESS. Adverse impacts to offsite
residents from sulfur dioxide emissions would not be significant
for any of the alternatives.
There are adverse impacts to employees of the onsite
businesses and construction workers with some of the remedial
alternatives. Alternatives 5, 8, 10 and 11 have the potential for
releases of sulfur dioxide while the neutralization process
is being implemented. The potential' for the release of sulfur
dioxide is somewhat greater for alternative 11 than for the other
neutralization methods.
Protection to employees of the onsite businesses and
construction workers would be accomplished by controlling the
area of exposed surface and by applying ,lime to neutralize
exposed surfaces as soon as they are disturbed, Construction
workers implementing the cleanup would be ~equired to wear
protective equipment to prevent inhalation of sulfur dioxide.
. '
Alternatives 5 and 8 would have an environmental risk
associated with the movement of large quantities of water; but
this would be controlled by designing the recirculation system to'
minimize movement of contaminated water to other locations.
Because the ground water at the site is not used for any purpose,
the environmental risks associated with circulation of the water
are small.
The time required for implementation of any alternative
would be short, except alternative 11. It is anticipated that
over 12 months would be required to neutralize and solidify all
the acid sludge waste in the north waste area.
There would be a short-term risk to construction workers
when installing the fence in alternative 2~
All alternatives, with the exception of alternative 1, would
minimize the short-term risks to construction workers by
requiring proper clothing and safety equipment.
IMPLEMENTABILITY. The no action alternative can be readily
implemented at the site. The existing ground water monitoring
network would be utilized, and the program implemented within a
short time. Alternatives 2 and 7 could also be implemented in a
short time.
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The technologies for alternatives 1, 2, 7 and 9 are well
developed. Technologies for alternatives 5, 8, 10 and 11 are
somewhat less developed, but knowledge is sufficient to implement
the alternatives.
The treatability study performed during the Phase lIB
remedial investigation demonstrated that neutralization of the
acid sludge can be carried out with time. Based on permeability
tests, the permeability of the acid sludge would allow
Alternatives 5 and 8 to be implemented.
Alternatives 1, 2 and 7 are the simplest to construct and
operate. A 80il cover would be more difficult to construct than a
fence because of the significant materials handling require-
ments. Periodic maintenance of the soil cover should ensure its
reliability in the future.
Alternatives 5, 8, 9, 10 and 11 would be somewhat more
difficult to construct and operate. In situ neutralization of the
acid sludge would require some specialized equipment. Proper
engineering design would be required to ensure that recirculation
system or soil-blending equipment would work as intended. In-
place soil-blending equipment would require air pollution
controls for particulates and sulfur dioxide.
Alternative 11 is more comple~ to construct and operate.
Treatment reagents and special handling equipment would be
required. to implement this remedy. The possibility exists that
there would be scheduling delays due to treatment reagents not
being shipped to the site in a timely manner.
COST. CERCLA requires the selection of the most cost-
effective alternative that protects human health and the
environmen~ and meets other requirements of the law. The no
action alternative which involves no capital cost, was considered
in order to meet requirements of the law.
Capital costs include those expenditures required to
implement a remedial action. The estimated total capital costs
are shown in Table 7. Annual post-closure costs have been
included in the present worth cost.
Alternative 8 (wet process) is the selected
it is the most cost-effective alternative and is
human health and. the environment and meets other
the law.
remedy because
protective of
requirements of
SUPPORT AGENCY ACCEPTANCE indicates whether, based on its
review. of the Remedial Investigation reports, the Operable unit
Feasibility Study report and the Proposed Plan, the EPA concurs
with, opposes, or has no comment on the selected alternative.
The EPA has reviewed the Proposed Plan, the Remedial
Investigation reports, and the Operable Unit Feasibility Unit
report and agrees with KDHE's preferred alternative presented in
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37
the Proposed Plan for Operable Unit One. The EPA also invokes a
waiver pursuant to Section 121 of CERCLA, as amended, to
implement Operable unit One.
COMMUNITY ACCEPTANCE reflects the community's apparent
preferences or concerns about alternatives.
The Proposed Plan, the Remedial Investigation reports, the
Operable Unit"Feasibility Study report, and the Administrative
Record file were made available for public review. Prior to the
beginning of the public comment period, the KOHE and EPA met with
the Arkansas city's City Manager. The City Manager was briefed on
the Proposed Plan and the future response activities proposed at
the Arkansas City Dump site. The KOHE and EPA received acceptance
from the City Manager on the preferred alternative presented in
the Proposed Plan.
The KDHE held a public meeting on September 15, 1988, in the
community to present the Proposed Plan and the preferred
alternative. There were no significant comments raised in
opposition to the preferred alternative.
10.0 THE SELECTED REMEDY
The "Neutralization followed by Soil Cover" alternative has"
been selected for Operable Unit One at the Arkansas City Dump
site. The EPA, in consultation with KDHE has determined that the
acid in the sludge in the north waste area poses a significant
direct contact threat to public health and the environment, and
that therefore taking remedial measures is appropriate. This
determination "is primarily based on : (1) the Phase I-remedial
investigation conducted by KDHE: (2) the Phase IIA and IIB-
remedial investigations conducted under contract by the KDHE:
(~) the public health evaluation conducted under contract by the
KDHE: and (4) Health Consultation provided by the Agency for"
Toxics Substance and Disease Registry (ATSDR). It is also
determined that a waiver for Operable Unit One will be invoked.
The selected alternative will neutralize the acid in the
sludge (pH less than 2.0) and eliminate the potential for sulfur
dioxide emissions. The soil cover will reduce the direct contact
hazard associated with any organic compounds remaining in the
north waste area after treatment.
As will be discussed in detail in section 11 of this
document, the selected remedy is protective of human health and
the environment, attains Federal and State requirements that are
applicable or relevant and appropriate, to-be-considered
criteria, and is cost effective.
11.0
THE STATUTORY DETERMINATIONS
The selected remedy for Operable Unit One satisfies the
requirements under Section 121 of The Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA) I as
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amended by SARA. The remedy provides protection of public health
and the environment, achieves applicable or relevant and
appropriate requirements (ARARs) and is cost effective. Operable
Unit One will invoke a waiver for appropriate ARARs with respect
to the Safe Drinking Water Act, Clean Water Act and to-be-
considered criteria (TBC) under the Kansas Groundwater
Contaminant Cleanup Target Concentrations.
The selected remedy for Operable Unit One addresses only the
direct contact hazards associated with the acid sludge waste in
the north waste area.
Ground water underneath the site contains both organic and
inorganic contaminants that exceed the acceptable concentrations
for drinking water. However, the ground water does not pose an
immediate health hazard because water from wells installed onsite
during the remedial investigations is not consumed by anyone and
the contaminants are not migrating offsite. Further, from the
ground water data, it has been determined tha~ the north waste
area is not a major source of ground water contamination. The
principal contributors of organic and inorganic contaminants are
the oil-contaminated sediments and contaminants originating from
the landfill. .
CERCLA, as amended, provides that under certain
circumstances ARARs may be waived. In section 121(d) (4) (a) of
CERCLA, a waiver is provided where the cleanup being proposed is
only part of a total remedial action that will attain ARARs when
completed'.
The KDHE proposed in the Proposed Plan a waiver for
Operable Unit One because the preferred alternative (selected
remedy) would not meet ARARs for the Federal and State drinking
water regulations or the TBC for the Kansas Groundwater
contaminant Cleanup Targets. The EPA is invoking a waiver for
Operable unit One based on the determination that this is an
interim measure for this site.
11.1
Protective of Human Health and the Environment
Both the health. assessment conducted during the Phase
remedial investigation and the ASTDR's Health Consultation
concluded that the north waste area poses a direct contact
to human health and the environment.
The selected remedy will treat the acid in the sludge in the
north waste area and eliminate the potential for sulfur dioxide
emissions. The remedy would also use a soil cover.to further
reduce any direct contact hazard to remaining contaminants.
IIB-
hazard
Deed restrictions and other institutional controls would
prohibit soil excavation and construction of buildings on any
part of the site still containing hazardous materials and would
ensure that drinking water supply wells are not drilled into
contaminated parts of the aquifer upon completion of Operable
-------
,:,~
unit One.
The adoption of an operation and maintenance program would
be required to assure the integrity of the soil cover and an
ongoing sampling and analyses program would be necessary. The
KDHE would be responsible for these programs. This would include
inspection of the soil cover and monitoring of onsite wells and
some offsite wells. Analytical results would be used to monitor
future conditions and to assess the effectiveness of the remedy.
11.2 Attainment of Applicable or Relevant and Appropriate
Requirements (ARARs) and To-Be-Considered criteria (TBC)
Section 121(d) of CERCLA, as amended by SARA, requires that
remedial actions comply with applicable or relevant and
appropriate requirements or standards (ARARs) under Federal
environmental or State environmental laws or facility siting laws
and'to-be-considered criteria (TBC). Table 8 provides a summary
of ARARs and TBCs of the appropriate Federal and State
environmental laws for the remedial actions at the north waste
area.
The Safe Drinking Water Act (SWDA) and the Kansas Public
Health-chapter 65, Article 15 statutes have been identified as
relevant and appropriate'requirements for the selected remedy.
The SWDA and Kansas State Statutes established primary drinking'
water standards, MCLs, which protect human health from the
potential adverse effects of drinking water contaminants and
established secondary drinking water standards, which protect
human health from the specific contaminants that may affect the
aesthetic qualities of drinking water~ Primary and secondary
drinking water standards are generally relevant and appropriate
where the ground water is or may be used for drinking.
For the Arkansas City Dump site, the primary and secondary
drinking water standards are relevant and appropriate where the
ground water may be used for drinking water. .Ground water under
the north waste area had concentrations of iron, manganese,
sulfate, and PNA compounds that were greater than existing State
and Federal drinking water standards. The Arkansas River alluvial
aquifer is considered a Class-!! aquifer because it is a
potential source of drinking in the vicinity of the site and is
used for drinking water purposes elsewhere.
The policy of the KDHE is that cleanup of contaminated
aquifers should be to target cleanup standards, as indicated in
the "Ground Water Contaminant Cleanup Target Concentrations."
The KDHE established this policy to remediate entire plumes of
contamination in fresh and usable aquifers to comply with
concentration levels which would meet the Kansas Notification
Level or Alternative Kansas Notification Level. These KDHE
standards have not yet been officially promulgated as official
legal standards and are currently treated as guidelines or goals
for cleanup.
-------
40
For the Arkansas City Dump site, KDHE's ground water
contaminant cleanup target concentrations are to-be-considered
criteria for Operable Unit One. Ground water under the north
waste area had concentrations of iron, manganese, sulfate, and
PNA compounds that exceeded the Kansas Action Level. The Arkansas
River alluvial aquifer is a Class-!! aquifer which is defined by
the state of Kansas as an aquifer having from 500 to 5,000
milligrams per liter dissolved solids concentration and is,
therefore, a usable aquifer.
As previously discussed, the EPA is invoking a waiver
the Federal and State drinking water regulations for this
selected remedy and will address the ARARs and the TBC
requirements in Operable Unit Two.
The Resource Conservation and Recovery Act (RCRA) and the
Kansas Public Health-Chapter 65, Article 31 statutes have been
identified as relevant and appropriate requirements for the
selected remedy. The criteria and limitations used to identify
wastes as being hazardous or nonhazardous in the Federal and
State environmental laws are relevant and appropriate to the
selected remedy. The waste in the north waste area meets the
three criteria as defined in the regulations.
under
The selected remedy will neutralize the acid in the sludge
and will eliminate the potential for sulfur dioxide emissions.
.Under the Federal and state RCRA regulations if residuals remain
that potentially pose a direct contact threat but do not pose a
threat to ground water a hybrid closure, which consists of a
cover to address the direct contact threat, may be used. The
RCRA regulations on placement of a cap over waste designed and
constructed to provide long-term minimization of liquids through
the cap is relevant and appropriate to the selected remedy.
The Clean Air Act and the Kansas Public Health-Chapter 65,
Article 19 statutes have been identified as being relevant and
appropriate requirements for the selected remedy~ The Clean Air
Act is designed to protect and enhance the quality of the
nation's air resources so as to protect the public health and
welfare. The Kansas ambient air quality standards and air
poliution control regulations are to protect and enhance the
quality of the state's air resources so as to protect the public
health and welfare. .
The sulfur diox!de emissions could exceed the Fede~al
standard of 365 mg/m and the State standard of 13 ug/m , 24-hour
average onsite if the hardened surface were removed. The in situ
neutralization treatment process will be implemented to minimize
this from occurring.
-------
41
11.3
Cost Effectiveness
The selected remedy is the most cost-effective treatment
alternative that protects human health and the environment and
meets other requirements of the law.
The capital costs of the selected remedy (neutralization
followed by a soil cover) are estimated to be $788,000. The
annual operation and maintenance costs are estimated to be $3,000
per year.
Although the other treatment alternatives that were
evaluated might in some cases afford a better overall
effectiveness, such effectiveness is not proportional to their
total costs. However, the selected remedy is cost-effective and
protective of the publ~c health and the environment.
The non-treatment alternatives that were evaluated do not
afford the overall effectiveness that is required to address the
direct contact hazards for the north waste area.
11.4
Utilization of Permanent Solutions and Alternative
Treatment (or Resource Recovery) Technologies to the
Maximum Extent Practicable
The rationale for the ,remedy selection w~s judged to be the
best balance among tradeoffs in terms of long-term effectiveness
and permanence, reduction in toxicity, mobility or volume
afforded through treatment, short-term effectiveness,
implementability and cost, also weighing the statutory preference
for treatment as a principal element.
The selected remedy provides .overall protection of human
health and the environment by addressing the principal threat of
direct contact exposure from the north waste area and the
potential exposure to sulfur dioxide emissions from the acid
sludge deposits and effectively eliminates such risk of direct
contact.
The selected remedy does not attain ARARs and TBCS for
Federal and State drinking water standards: however, the acid
waste sludge is not a major source of contaminants to the ground
water and the organics remaining after treatment in the north
waste area is considered to be immobile.
The selected remedy will reduce toxicity, mobility, and
volume of contaminants in the acid sludge by neutralizing the
acid in the sludge and the potential for sulfur dioxide
emissions.
The treatability study performed during the Phase-IIB
remedial investigation demonstrated that neutralization of the
acid sludge can be implemented.
-------
~~
11.5
Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference for
remedies employing treatment that permanently and significantly
reduce the toxicity, mobility or volume of hazardous substances.
The preference for treatment is satisfied by addressing the
principal threat in the north waste area. The principal threat of
direct contact exposure and the potential for sulfur dioxide
emissions if the north waste area is disturbed is addressed by
neutralizing the acid in the sludge.
The principal threat from the oil-contaminated soil and
ground water will be addressed in future response activities at
the Arkansas City Dump site.
-------
43
Table 1. Principal ch.aracteristics o(a.t:id sludge
[Data from Abraham. 1918]
Color in mass. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Black
Homogeneity to the eye at room temperature........... Uniform
Homogeneity under microscope. . . . . . . ... . . . .. . . . . .... Variable
Appearance surface-aged indoors 1 week. . . . .. .. . . .. . .. Bright
Fracture. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Conchoidal
Lustre. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. Bright
Specific gravity at 77 of .............................. 1.05-1.20
,. .
Odor on heating. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. Oily; similar to residual.
asphalt
Behavior on melting
........... IO.....................
Passes rapidly from the .
solid to liquid state
Volatile matter 500 ~F in 4 hours
..................... .
2.20 percent
Flash point. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 300.500 OF
Fixed ca.rbon ...............:........................ 5-30 percent
Solubility in carbon disulphide ....................... 95-100 percent
Nonmineral matter. insoluble. . . . . . . . . . . . . . . . . . . . . . .. 0-5 percent
Mineral matter. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 0-1 percent
Solubility at 880 naphtha. . . . . . . . . . . . .. . . . . . . . . . . . . . .. 60-95 percent
Sulfur. . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . ... . .
5-10 percent
Oxygen. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3- 7 percent
Saturated hydrocarbons.............................. Less than 10 percent
-------
44
table 2.
CO~rt.lf'GliortS 01 s~l~ct~d o"'GII~ t'Ompounds in Gt"id sluclgt. oil, ,round tuatu urtdtl'
path acid SIud6t. GNJ ,ro4UlJi WtUuoU-colU4mi1l4Ud .~d.i~11U.
rValues are in parts per b!llion]
Contaminant Source
Compound Acid Sludl~1 Cround water Oil Cround water
under acid from oil-conta.
Sludge lIIinated sediments
uses wr2 IDHE HW63 kDHE HW6l1 TW25
Anthracene <10,000 <5 310,000 <5 <5
Benzo(a)anthracene 73,000 <5 320,000 <5 "0
BenzO(b} fluoranthene <10,000 <5 <100,000 <5 <5
Benzo(a)pyrene 120,000 <5 320,000 <5 <5
Benzo(k)fluoranthe~e 26,000 <5 <100,000 <5 <5
Chrysene 530,000 <5 530,000 <5 .<5
Dibenzo(a,h)anthracene <10,000 <5 <100,000 <5 NO
Fluoranthene <10,000 <5 <100,000 <5 <5
Fluorene <10,000 <5 200,000 <5 <5
Napthalene < 10, 000 <10 130,000 13 30
Methyl. NO <5 NO NO 62
NapthaJene
Dimethyl. NO <5 NO NQ 39
napthalene
Phenanthrene 20,000 <5 , ,500 ,000 <5 8
Methyl- NO <5 "Q NQ <5
phenanthrene
Pyrene 15,000 <5 870,000 <5
-------
Table 3
45
Fuel-related hydrocarbon pses identified in air from boreholes in acid
slud2e
Compound or gas
Maximum
concentration (parts per
billion)
Sulfur dioxide
Benzene
Chlorobenzene
1,2 dichloroethane
1,3 dichloropropylene
Ethylbenzene
. Methylene chloride
. Tetrachloroethane
1,1,2,2 tetrachloroethane.
Toluene
1,1,1 trichloroethane
> 150,000
140
>100
.6
>100
>110
2.6
.5
>68
>120
1.1
..
-------
46
Table 4 The liat of Indi~ator Chem!~a15. ~ximum concentrations. exposure
.ed 1& and expolure routes present at the Arkansas City dump lite.
Indlcator Ch_l~al Maximum Concentration Expo.ure Kedia Exposure Route
Aluminum 9300 PilL Iroundvater oral
Ammon 14 76 .IIL Iroundvater oral
Arsenlc: 84 uaIL Iroundvater oral
aar1um 2000 "IlL Iroundvater oral
Beryllium 2 "IlL aroundvater oral
DDD 0.02 ugIL Iroundvater oral
I od id e 4000 agIL Iroundvat et' oral
Iron 24000 usIL Iroundva t er onl
Mansanese 1600 uS/L Iroundvater oral
Sulfate 300 1IIIL aroundvater oral
Sulfur 1~ acid .20 % dudge contact
PNAs 234 uS!L Iroundvater oral
-------
rable 5
--~~~ry of remedial-action alternatives for the ~cid-slud~e waste at the Arka~sas City dump site evaluation.
~lternatJve
Estimated Cost
1 .
No Action
? .
Restricted
3.
ReIIOval of ma-
terial from
site
IJ .
Thermal pro-
cessing
5.
Neutralization
Effectiveness
Very Poor....
",eet ARAR 1.
Does not
acceS8 ~ Lowest level of
protection. Does not
allow productive use
of the property.
Poor. There 18 no pre-
sent hazard which jus-
tifies ~vlng the acid
sludge to a new loca-
tion.
Poor short-term effec-
tiveness. Good long-
term effectiveness.
Air pollution Is a
potential problem.
~ Neutralization
removes the contact
hazard and the sulfur
dioxide hazard. The
surface of the site
contains large concen-
trations of PNA compounds.
~lementablllt~
Not applicable.
Excellent.
Poor.--Acid sludge
cannot be moved safely.
Poor.--Thermal-process-
ing technology for
acidic high-sulfur sludge
Is not well developed or
reliable.
Good.--Several technolo-
gies exist for neutra-
lization of acid
sludge.
Public Health Evaluation
Contact health risk.
low Cost
Potential for human con-
tact rem.ains.
low Cost
.Substantlal rlsk.--The health risk Exceeds
to the public and the remediation $1.000,000
ers is substantial.
Some rlsk.--The risk associa-
ted with potential 8ulfur-
dioxide emissions is a public-
health concern.
Exceeds
.10,000,000
Small risk.--The potential risk
associated with sulfur-dioxide
emissions Is very small. The
risk associated with ground-water
contamination offsite Is very small.
Moderate.
less than
$1,000,000
.
,
I
I
, i
I
A
......
-------
Table 5
.--Summary of remedial-action alternatives for the acld-sludRe waste at the Arkansas City dump site evaluation.
--Continued
Alternative
Estimated Cost
6.
Biodegradation
1.
Covering with
so11
8.
Neutralization
followed by
; cover Ing wi th
so 11
9.
Covering with
soil and seal-
Effectiveness
Good. Neutralization
followed by biodegra-
dation is an effective
treatment technology.
Removes contact hazard
and sulfur-dioxide
hazard. Potential
technology to restore
ground water under the
site.
Good. Meets goals of
Objective 1. Removes
danger of contact
hazard.
Very aood. Removes
contact danger of
acid sludge. Removes
danger of sulfur
dioxide emissions.
Provides good envir-
onment for natural
biodegradation pro-
cesses.
Very aood. Re.oves
contact danger of
Impleme~tabl1lty
Public-health evaluation
Innovatlve.--Pllol scale
study of blodegrad-
(0
Small risk. Rlsk~ associated with Moderate.
neutralization process as de- less than
scribed In alternative 5. $1,000,000
Good.
Excellent. Technology'
Is well developed.
Small risk. No risk associated
wilh implementation. Potential
Inexpensive.
Hore expen-
-------
abJe 5.
--Summary of remedIal-actIon alternatives fo~ lhe acld-sJud~e waste at the Arkansas CIty dumn site evaluatIon.
--Continued
lternattve Effectiveness ImplemenlabiJily PublIc Health Evaluation Estimated Co,~
Ing through acId sludge. Pro- rIsk associated with aald sludge !!live than
so 11 d i fie a ti on vldes high quality Is greatly reduced. Hardened alternatives.
surface for construc- surface reduces the probabIlity 2 and 7.
lIve use of the pro- of accidental penetration Into
perty. leaching of the acid sludge.
acid from the site Is
reduced relative to
alternative 1.
10. Neutralization Very Rood~ Removes Good.--Technology Is . Some risk. Risk assoatated with Moderate.
and Innoblllza- contact danger of feasible based on lab- implementation Is greater than Hore expen-
tion of surface acid sludge. Provides oratory st~dles. alternative 9 because ~f the 8ul- sive than
layer of ac i d hardened surface for fur-dioxide emissions durIng the alternative ~
1.0
sludge constructive use of neutralization proeess. Potential 9.
property. leaching of risk associated with acId sludge
acid from the site Is Is greatly reduced. Hardened sur-
reduced relative to face .reduces the probabIlity of
a lterna t1 ve 1. accidental penetration into the
acid sludge.
11. Neutralization Excellent. R~ves all Good.--Technology is Smallrisk. RIsk 'saoclated with Expensive.
and Innobll iza- hazards associated feasible based. on lab- Implementation because of sulfur
lion of all with acid sludge. Po- oratory studies. dioxide emissions during the neu-
acid sludge tentlal exists fOf re- ttallzation process. He~lth risk
storatlon of ground- associated With acid sludge Is
water under the site. eliminated by the treatment.
.
-------
Table 6 --Applicable. relevant a~~~uproprlale regui~ements (ARA") for remedial-actions
alternati v~s for _E_C t~L~!!
-------
Table 6
--Applicable. relevant and appropriate requirements CARAR) for remedial-actions
alternaU yes for acid sh!!!&e w~stes at the A"rkans1!s ei ty dum~i te--ConUnued
------------------------------------------------------------------------------------------
ARAR1
Type of Oescrlption
requlrement2
Compliance
on
Implemen
-taUon?
Appli-
cable
or .
appro-
priate)3
AHernatives
------------------------------------------------------------------------------------------
(5) Neutrallzatlon-- NAAQS es Air contaminants No RA
Conl1nued (during
response)
Yes
(after 111
treatment) ~
kansas water AS Extraction of RA
Appropriation ground-water for
Act treatment
ReRA AS TreatmentAclosure RA
(~OefR Subpart K
26~.220)
AS facility Slandards RA
(~O erR Subpart 0,
2611. 10)
AS Ground-water RA
monitoring (110 CfR
Subpart f
OSHA AS Operational Standards A
for response personnel
(20 eFR 1910)
(6) In-situ biological KCS CS Ground-water contaminants Partial TOC
treatment (pH)
ros CS do. Part lal RA
(pH)
.
-------
Table 6
--Applicable. relevant and ~ropriate r~~ire~ents (ARAR) for r~medlal-actions
alternatives for a~id- sludg(>~a~~.~~~.L_~~__!\:r~~!!~ft~~ dl!!!1J1~_ll~--Conlinued
-----------------------------------.------------------------------------------------------
Alternatives
ARAR'
Appli-
cable
or
appro-
priate)J
Type of Description
requirement2
Comp I i ance
011
implemen
-tallon?
-------------------------------------------------------------------------------------------
(6) In-situ biological RCRA LS Flood plain Yes RA
treatment--continued RCRA/State AS Solid ha7.ardous RA-s
waste storage RA-f
CIIA CS Surface-water contaminants Yes RA
NAAQS CS Air contaminant No RA
(during
response) V1
I'V
Yes
(after
treatment)
Kansas water AS Extraction of A
Appropriation ground,water for
Act treatment
RCRA AS Treatment and closure RA
(~OeFR Subpart K
2M.220)
AS Facility standards RA
(hO efR Subpart 8,
26... 10-).
AS Ground-water RA
monitoring (~O CfR
Subpart F
OSHA AS Operational standards A
for response personnel
(20 erR 1910)
-------
Table 6
--Applicable. relevant and a~propriate re~lIire~ent5 (ARAR) for remedial-actions
alternatives for acid slu~Re wastes at !~e_~rkal~~~~~Lty du~site--Conllnued
------------------------------------------------------------------------------------------
ARAR1
Type of Description
rNlu I rement?
Compliance
on
implemen
.-tation?
Appli-
cable
or
appro-
priate)3
Alternatives
------------------------------------------------------------------------------------------
(7) Covering with soil
ICCS CS Ground-water contaminants No RA
FDS CS do. No RA 111
w
RCRA lS J:"loodpJa In Yes RA
RCRA/Stat.e AS Solid/hazardous. RA-s
waste storage RA-f
CVA CS SW contaminants Yes RA
NAAOS CS Air contaminant Yes RA
OSHA AS Op~ratlonal Standards A
for response personnel
(20 eFR 1910)
(8) Neulrallzatlon
followed by soil cover
ICCS CS Ground-water contaminants Partial TOC
(pH)
FDS es do. Partial RA
(pH)
ReRA LS Floodpla In Yes RA
RCRA/Stale AS Solid hazardous- RA-s
wasle slorage RA-f
.
-------
Table 6
.--Appllcable. relevant and appropriate reQI~lre~nts (ARAR) for remedial-actions
alternatives for acid ~llldKe wastes at the Arkansas City dump sile--Conl1nued
------------------------------------------------------------------------------------------
ARAR1
Type qf Description
reQuirement2
'Compliance
on
Implemen
-tation?
Appli-
cable
or
appro-
prlate)3
Alternatives
---------------------------------------------.--------------------------------------------
(8) Neulrallzatlon eWA CS Surface-water contaminants Yes AA
followed by soU NAAQS CS Iu r contami nant No RA
cover--Contlnued (during
response)
Yes
(after VI
treatment) ~
Kansas water AS Ext.ract Ion of A
Appropriation ~round water for
Act treatment
RCRA AS Treatment and closure -.. RA
(~OCFR Subpart K
26~.220)
AS Facility standards RA
(110 eFR Subpart 8,
2611. 10)
AS Ground-water RA
MOnitoring (110 eFR
Subpart F
OSHA AS Operational standards A
for response personnel
(20 CFR 1910)
-------
Table 6
.--Appllcable. relevanl and~~ro~~~~p.quireme~ts~~AR) for remedial-actions
aJlerna 11 ves for acid s I u~r.(' -~i!~~~S --,"!UhQ..j\rk_
-------
Table 6 .--Applicable. relevant and~ropriate require~ents (ARAR) for remedial-actions
al ternatives for ac id. sl~~g~-~~sle_s. _at li!..~Arka_nsas C i ly dump s i le--Continued
ARAR1
------------------------------------------------------------------------------------------
Type of Oescriptton
requiremenl2
Compliance
on
implemen
-tat ion?
Appli-
cable
or
appro-
priate)3
Alternatlve~
---------------.--------------------------------------------------------------------------
(9) Sol1 cover
and solidification--
Continued
OSHA
(10)Neutrallzation
and immobilization
of surface layer
ICS
FDS
RCRA
RCRA
CVA
NAAQS
AS
Ground-water
monitoring (qO CFR
Subpart F
Operational standards
for response personnel
(20 CFR 1910)
AS
CS
Ground-water contaminants
CS
do.
LS
CS
. Flood plain
Solid hazardous-
waste storage
Surface-water contaminants
Air contaminant
CS
CS
RA
A
U1
C1\
Partial
leachate
reduction
Partial
leachate
reduction
Yes
TOC
RA
RA
TOC-s
RA-f
RA
Yes
No
(onsite)
during
operation)
RA
-------
Table 6
--Applicable. relevant and appropriate requirements CARAR) for ~emedial-actlons
alternatives for acid sludv.e wastes at Lhe Arkan~~City~~site--Continued
------------------------------.-----------------------------------------------------------
ARAR1
Type of Oescriplion
reQuirement2
Comp 11 anee
on
Implemen
-tallon?
App 11-
cable
or
appro-
priate )3
Alternatives
-----------------------------------------------------------------------------------------.
(10) NeutralIzation
and Immobilization
of surface layer--
conllnu8d
ItCRA
Air contaminant Yes RA
(after
treatment)
AS Treatment Bnd closure itA
(~OCFR Subpart K
2611.220)
AS facility standards itA U1
(qO eFR Subpart B, "
26". 10)
AS Ground-water RA
monitoring (qO efR
Subpart f)
AS Operational standards RA
for response personnel
(20 eFR 1910)
OSHA
(11) Neutralization and Immobilization
of all acid sludge
KCS
es
Ground-water contaminants
Yes
TOC
FDS
es
do.
Yes
itA
ReRA
LS . Flood plain
Yes
RA
-------
Table 6 --Aool1cable. relevant and appropriate reQuirementa (ARAR) for re.edi.l-actions
alternatives for acid slud~e wastes at the Ark~nsas City dump site--Contlnued
-----------------------------------------------~------------------------------------------
ARAR1
Typ of Description
requlrement2
Compliance
on
I IIIp I emen
-tallon?
Appli-
cable
or
appro-
prlate)~
Alternatives
------------------------------------------------------------------------------------------
(11) Neutralization RCRA/State AS Solid/hazardous Yes A-l
and immobilization waste storage (corrosl vlty RA-f J
or 811 acid sludge-- ell.lnated)
continued CUA CS Surface-water contaminants Yes A
NAAQS CS Air contaminant No (onslte A
during
operation) lit
Yes(after co
operation)
ReRA AS Treat8ent and closure RA
(_OCFR Subpart K
2611.220).
AS Facility Itandards RA
(qo CFR Subpart 8,
26q. 10)
AS Ground-water RA
~nitorln8 (qO eFR
Subpart F)
OSHA AS Operational standards A
for response personnel
(20 CFR 1910)
-------
Table 6 .--Appllcable. relevant and appropriate requireMents CAHAR} for remedial-actions
alternatives for acId sludv.e wastes at lhe Arkansas City du~p slte--Continued
------------------------------------------------------------------------------------------
ARAR1
Type of Description
requlremenl2
Compliance Appll-
on cable
IMplemen or
-latlon? appro-
prlate)3
Alternatives
-------------------------------------------------------------------------------...--------
1
ICS = lan8a8 Cl.anup Standard (Kansas Department or Health and Envlron8ent,
c~n., 10¥e8ber 1981).
FDS = Federal 8econdar, drlnk!nl water standard.
CNA = Clean Water Act (U.5. Envlron.ental Protection Agency 1986).
NAAOS . National 88blent air quality standards.
2 CS = CheMical specific retolatlon or standard.
AS = ActIon specific rrotatlon or standard.
lS = location-specific regulation or standard.
3 A = Applicable.
RA= Relevant and appropriate.
-S = State regulatIons.
w~ltt.n
~
\D
-F : Federal relulatlons.
TeC = To be considered
-------
60
TAfU 7.
!UWlRY If ESTIftATED alSTS If Ie£DIAL ACTI~
.. ~TI~ ~ (ftJWl£ ~IT 11£: ACID !UGE IMSTE
AL TERNATI~ IEl£DIAL terttlllTfl ESTWm
C'lfITfL PIESENT OTH
aJST COST
1. NO ACT! ON tOE . 28, 000
:. RESTRICTED AU:£SS . 14,000 . 42,000
5. t€UTR4LI!A:ION
.we~ Froel's: S ~,OOO S BI6,OO()
Dry process . 2,080,600 . 2,108,000
i. CO\!F:INE WITH SOIL f 1~I,OOO . 15'9,000
8. ~UTR~ I Z A TI (Ii ~1l.L:rt.D
Pi' CDVERIN6 !lITH SDIL
WET r€l,"TRAL I ,ATION . 919,000 . 947,000
DF:Y NEUTRAI~!ATI(li S 2,211., 000 . 2,239,000
9. CQI.'ERItE WITH SOIL AND SEALING
THROU6H SOLIDIFICATION . 328,000 . 356, oOcJ
10. tEUTRALIZATICIf MD D.IDIFICATI~
If SlR=ACE LAYER . &:58,000 . .,000
u. J€IJTRAL.IZATICII ffiD D.IDIFlCATI~
If ACID su.w
EXCAVATION . 9,&46,000 . 9,874,000
I N-Pt.ItC£ TREA n£NT . 9,571,000 . 9,599,000
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61
T AI!l.£ 8
MMS AND TIt I8IDTIFIED FtJ! 1)£ ARKM5AS CITY J1W SITE
tITATI~
IQJlREP£NT
FFJDAL IOJIREJ£NTS
C. S. EPA RCR~ RE6Il.ATHJlS
~; Cf'F; 261 Identi fies those Nistrs subject to
reg~latior. a5 hazardous Niste.
~C! cr.:. :6~.1e(b)
Facilities located within a 1~J-year
flood plain lUst be designed, constructed,
operated and Nintained to avoid Nishout.
40 ~ 204.111
Flace.ent cf , cap ov.er Maste desig~ea
and constrl,;:t~ to pt'ovidelon~-teral
.inimizati~n ot li9'a~ior, of liguids
t~~o~g~ ths cap?e~ arec.
"0 C~ 2b4; 310
3O-yea1' post-closure care to ensure that
Iii te is uintaintd and ICIrli tared.
U. S. £FA SAFE DRH'OtE WATER ACT
40 CP.1 141 Drinhng 88iter regulation dftigntd to
protect hu8in heal th fr'Ol the potential
adverse ~fect5 of drinking 88iter
contilinants.
40 CFR 14::
DrinUng 88ittr regul.tions dftigntd to
protect hUNn health fral tht spteHic
contaminants that uy .Htet the
aesthetic qualities of drinking Niter.
,5. EF:' CLE~~; ~r:R A:r
4(' ~ 1:: Clean Wa~er Act is to restore and
lai~tlin the chelical, physical, and
bDJog!:al inte'-grity of the nation's
Nite"s.
POTOOIrL
IIJItR or T1IC
r£m!ftlNATI~
Rtlrvant and
If'propri.te to
.11 .lttrn.tivrs
ApFlicable to
altern.tive 11
Applicable to
alternat i ve 11
Relevant and
If'propriate to
alternatives 7,
8, 9, lC and 11
Applicable to
.1terMtive 11
Relevant ind
appropriate to
.11 .ltermtives
Relrvant and
lpflropri.te to
allaltematim
Relevant and
appropriate to
.lte..n.tiv!S S,
8 II\d 11
MrLVSIS
The criteria and lilit.tions used to identify
88ist!S .5 being h.z.rdous or nonh.:ardous
in 40 Cf"I( 261 .re relevant and appropriate
to .11 prapoMd cleanup .ctlonS at the Ark."sa5
City Du8p lite. The NistfS leets the th~
criteria as defined in 40 OFR 2cl~
The RCAA hiZ.rd0lJ5 ..ste wi 11 be treated ..,d
dispOSld an si tee
The IDA hJzal"dous ..ste wi 11 be trelted and
disposed on lite for the purpose of leavin9
it behind after the r!ledy is cOlFlete.
Hybrid approach to closure for waste left in
place liIich does not pose a direct contract
threat Dr ilpact groun~ Niter,
The RCRA ha%ardous 88iste wi 11 be treated and
disposed an si tee
. The priaary IIxilUl cantllin.nt levels set
IItdtr the Sife Drinking "-ter Act for
cantlainants at this site art appropriate
for CI.ss II...ters.
The lICondary llxi- contuinant levels
lit lWIer the Sife Drinking Miter Act
for contuinanh It his si te .re appropriate
for Cl.55 II ..ters.
The ..ter qu.li ty standirds Ire blSfd on
Federal .ater quality Criterli to protect
existing and .ltern.tlve use or uses of
receiving Miters.
-------
tITATI~
UJIRD£NT
u. S. EPA IUIIH AIR fC
40 CfR 50 The Cl.., Air kt is to pt"Otlet Ind
IMIne, tilt ~li ty cf the nihil!' s
Ii r rftOrtel 50 IS to ,rootlet the
public tlftl tit and .1fIl'l.
U. S. DCl oc:tF'~TII)W. Stf£TY AND .aL TH ADffINlSTRATII)J
~ CFR It;IO The rtgulations includ, operational
stitldards for etploytf protfCtion
for NOrkers Ingag': in ha:ardous ..ste
operations.
STATE (J t.:~ RE6'iJLMTIDIlS
----
~ P'JB:.IC !£ALii; - owm: 65
bS-~..43C: Identifies those Mutes suDJt:t to
reg.,letiorl as hi:ardou~' lliste.
Article 31
Facilities locat~ Mithir. a l00-year
flood plain ..st be cltsigned, constructed,
operited ifI~ 8iint.ined to .void ..shout.
PlaCteent of I CIP over ..ste desigr.ed
Iftd constructed to provid, lang-t.rtI
linili:ltion cf ligrltion of liguids
thrQ.l9h ttlt CIPPfd .re..
3O-year post-closure clre to ln5Ure that
5it, i5 aaint.ined Ind lOftitortd.
Artj:;]e 15
Drir,.ing ..ter regul.tion desi9~ed to
protect hUla" health fro. th. potent.al
aC:..,rsl' ,Hects o~ d"inUng ...t,r
CJnt...inaflts,
62
flaTEMTI"-
MM or m:
IlEm'UNATI~
RlIPilnt Ind
IPf'raprilte to
all alt1rn1tiYII
Appliclbl, for
Ilt.matim 5,
7, 9, 10 iIId 11
Rtlevitlt Ind
IPPropride to
.11 alternatives
Applicabl' to
alternative 11
Applicatl. ~o
aJ t.1'nI t iv, 11
RlI.vant and
appropriat. to
IlttmltiY6 7,
8, 9, 10 Ind J1
Appl iclbl. to
Ilt.mati vi 11
Relevant ifld
IPPropriat. to
all alternatives
.. YSIS
The sulfur diDXide l8iuians could exc~
ttw ~ 19/113 CII Ii tI if the hardened iUrTaCe
..... r8DV1d. Thil ltandard 88DUld nMd to be
.t if altlrnlti¥15 5, 8, 10" 11 .re
tap llMfttld.
The 5Ulfur dioxid. !li5Sions could be It levels
that exceed occupational heal th and safety
standards for NOrkers ",gaged in hizlrdous
..ste operations. .
The crit,ria and lilitations usee to idliiiiY
IMStes is bting hazaraous or nalhizaP'do
in "'apt.r 6S are relevant and appropriite
to .11 proposed eltitl\JP arhon5 It the ArkanSis
Ci ty fwF si te. Tht ..stes leets the three
cri ttria IS deHftId in 40 ::FR 26:.
The RCRA hizardous ..ste _ill be treite~ and
disposed on site (Article 31 5fChon 29-31-8).
The RCRA hazardous ...ste ..i 11 be treated itld
disposed an lite 'for tht purpose of leaving
it blhind Ifter tht r'IIIdy is cOlpl,te
~ticl, 31 IICtian 2B-3J-S'.
Hybrid IfIPr'OIdI to clDiUre for ..st! l.ft in
plaet "'ich dots not poll a direct contriCt
'threat or ilplCt 9f'OII'd ..ttr (Artie Ie 31
SlChCII 2&-31-8>.
ThI RCM hizardaus 181Stt .ill bt treated itld
disposed on site (Article 31 IfCtlon 28-31-8',
The uxilUl contalin."t l.veJ s set under
Article 15 It sit. are IPp"Cfrlate.
-------
CJTATI~
Article 16
Article 1~
IQJIR8£NT
SuNlee "Iter ~1 i ty IUndlrds ind ..ter
.,.1 i ty cri ttri. for "Iter ,rotlction to
8Iint.in Ind protKt the ,.lic hit 1 th
II1d wHare or uses o~ Qlrfle' ..t,r for
.gricultur.l .at,r supply, IqUItic life,
doIestic ..ter supply, groundMater
rfCh.rge, industri.l ..ter supply, and
r!creat ion.
The .ltient air quality standards and air
pollutiorr contol rPgulations .re to
protect .nd enhance the quality of
state.s air rtSOUrce! so as to protect the
publi~ health and M!l~are. .
Af('~ ;;~~::R C1)(iA!'!:~ CL.E,w"P TM&'T CtKENTRATl()4S
I£PG'AI~'LIIJ1! dited Entire F!UDe: of contamin.tion in fresh
~elber 30, 1~B6 .nd usable aUlte~ will be re8ediated to
cOlPly with concentrations not to exceed
the Kansas Not~ticatiorl Level (KNLJ or
or the Alternate Kao5as Notification Level
CAl1{.1 as applicible .nd appropriate for
cle':'IuF.
63
PUT9lTIAl
MAR ~ 111:
JIE'TEHIINATl~
Rl1!YlI1t to
111 11 ternJti WI
Relevint ind
iflPropri ate to
all alt!!rr,atives
To Be Considered
...terial for
all alternatives
WLVSIS
The ..tr ~lity ltandirds and criteria Ire
IIaId on the Fan1 Sift Dr inking ... ter At t
for CCI1ti1iy,ts it ttlillitt Ire ",p~riate
fDr' Class II ..ttr'S - tM F_raJ CIHn
Miter Act to protKt existing and alternative
USf or uws rH r"ICei ving Miters.
Th, sulfur.dioxide flissions could !!xc!ed.
the 13 119/113, 24-hour I~age on 51 te i ~
the h.rdened surfac!! Ntre rtIOvtd. ThIS
Itil'ld.rd tOlld need to be .t it .ltemativ!S
5, 8, 10 wi 11 .re ilpI !8ented.
The pri8lry and secondArY 8IxilU8 contuini11t
1Ml, 5I!t under the Kan!tl5 SurfACe IiIter
QI.lrty Stind.rds for contUlna.r.ts at this si~
Ire appropriat!! for Cllss II ..ters, but the
groLl'ldMlttr contllinant clHnUF tI~et.
concentr.tions 'f'! not pr'(8J19at~ under
State Ulif.
-------
STATE OF KANSAS
.-. ..... i
DEPARTMEl':T OF HEALTH Al'D EJ\"VIRO!'\ME!':T
F~, Field
Topeka. KGn,.., 66620-0001
~ne(91J)~lSOO
Mike Hayden. Goumor
Stanley C. Grant. Ph.D.. Secretary
Gary K. Hulett, Ph.D.. Und('r Secretary
September 26, 1988
Morr1s Kay
Regional Adminis~rator
U. S. Environmental Pro~ect10~
Agency -- Region VII
726 Minnesota Avenue
Kansas City, Kansas 6S101
Dear Mr: Kay:
The -Department has reviewed ~he p~oposed Re:crd of De:.s1~r
De=ia~at10r. for the Arkansas City Dump SuperfunO si~e at Arkansas
Ci~y, Kansas. The Agency concurs w1th alternative numcer 6 W~,iC~
was recommen~ed by the Proposed Plan prepared fer th1S si~e. The
1n-s1tu neutraliza~ion followed .by soi: cover combin.ed Won:\-; a
restrict~ve covena~t is agreeatle with ~he putlic and ~he t1~! cf
Arkansas City and is suppor~ed by this Agency.
T~e Department recommends that ~he U.S. Environmental
Agsr.cy 1nitiate the appropr1ate ~rocedures to com~~::e
of Decision Declaration for Phase I of the Arka~sas City
p,..=.te::t., ~r,
't.~~ F-=:::C
D...m::- Si:e.
J me sA. Powe r ,
irector
ivision of Environment
JAP:cas
C - Ronald F.
Ham~ersch!Ti~d~
-------
ARKANSAS CITY DUMP
SUPERFUND SITE
ARKANSAS CITY, KANSAS
ADMINISTRATIVE RECORD INDEX
I '
~~
~~~ ,~
u.S. ENVIRONMENTAL PROTECTION AGENCY
CONTRACT NO. 68-01-7351 (TES IV)
WORK ASSIGNMENT NO. 570
JULY
1988
-------
RECORD OF DECISION
OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION
THE RESPONSIVENESS SUMMARY
ARKANSAS CITY DUMP SITE
ARKANSAS CITY, KANSAS
Prepared By:
u.S. Environmental Protection Agency
Region VII-
Kansas city, Kansas
September 1988
-------
RESPONSIVENESS SUMMARY
RECORD OF DECISION FOR
ARKANSAS CITY DUMP SITE
ARKANSAS CITY, KANSAS
Th is Respons i veness Summary presents KDHE' s response to pub 1 i c
comments received regarding the proposed remedial action for the
first operable unit, the north waste area. No written comments were
received during the public comment period however there were a few
limited comments made during the public meeting which was held at
7:00 pm on September 15, 1988 in Arkansas City. The Responsiveness
Summary is a component of the Record of Decision (ROD) package,
which also includes the ROD declaration, ROD summary and index to
the administrative record.
Introduction
On September 2, 1988 KDHE announc~d the Proposed Plan for. the
remediation of the first Operable Unit for the Arkansas City Dump
site. Under the Proposed Plan the preferred remedial alternative
would consist of the following actions: .
. ,
Neutralize the acid sludge by ci~culating a solution ~f lime
in water through the acid sludge. The in situ neutralization
will be implemented by installing a series of holes into which
the lime solution will be introduced. The water used by th1S
process will be pumped from the aQuifer underlying the acid
sludge to avoid creating a groundwater mound below the site.
Cover the neutralized acid sludge with 100 tons of 1ime and
install a 2 foot thick soil cover.
A deed'restriction would be established which would prohibit
soil excavations and construction of buildings over the waste
buried on site.
An operat; on and ma; ntenance program wou 1 d be adopted to
assure the integrity of the soil cover and provide an ongoing
sampling and analysis program.
Public particieation
KDHE and EPA received no written comments during the public comment
period regarding the Proposed Plan and Remedial
Investigation/Feasibility Study for the Arkansas City Dump
Superfund site. .
A few limited comments were received at the September 15, 1988
public meeting. A list of those members of the general public who
were present at the public meeting and their comments are as
follows:
-------
Hazardous ~,
Information '::
US EPA Reg;
II
PhilodelphlC'
Curtis B. Freeland - City Manager - City of Arkansas City.
Mr. Freeland made no specific convnents during the publ ic
l118eting~
'.
\
Albert Beach - R.R. 1, 1800 West Madison - Arkansas City, KS 67005
Mr. Beach expressed this displeasure regarding the Quantity
of tax dollars being spent on a site where he felt the
expenditure was unnecessary. He explained that he lives on
north aide of Madison Avenue immediately next to the site and
does not understand the concern regarding the site.
Mr. Beach was informed that the KDHE and EPA were obligated
by superfund regulations to provide a solution which would
eliminate the contact hazard and provide a permanent solution
for the north waste area.
David R. Meyer - Ebasco Services Inc. - 143 Union Blvd~ Ste., 1010 -
Lakewood, Colorado 80228
Mr. Meyer indicated that he was interested in the site because
his company performs remedial work. Mr. Meyer asked that his
company be provided information when a contractor is being
selected. " .
Jasper DeVore - Rt.'3 - Arkansas City, KS
67005
Mr. DeVore made no comments., .
------- |