United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-88/030
September 1988
Superfund
Record of Decision
Fulbright/SAC River Landfill, MO
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REPORT DOCUMENTATJON .~11.--REPO,", NO.
PAGE' EPA/ROD/R07-88/030
2.
3. Reclpient"s Accession No.
.. Title end Subtitle
SUPERFUND RECORD OF DECISION
Fulbright/SAC River.Landfills, MO
_First Remedial Action - Final
~uttIor(s)
5. R8p!rt Dfti
u9/3U, 88
..
L Performin. O,.enizetlon Rept. No.
... 9. Performln. O....nlzetlon Neme end Add res.
10. Proj8Ct/T.slc/Wo,k Unit No.
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11. Contf8ct(C) 0' G,ent(G) No.
(C)
(G)
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12. Soonsorin. O,pnizatlon Neme and Add,ess
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
13. Type 0' Reoort .. Period Covered
800/000
1..
15. Supplementary Notes
II. Abstract (Umlt: 20Q ~rds) . . 1 d. .
The FUlbr1gnt and Sac R1ver Landf111s are ocate Just north of the C1ty of
Springfield, Missouri, in a semirural area. The site is in the flood plain of the
Little S~c River, and is owned by the City of Springfield, along with much of the
surrounding land. Adjacent land use includes a police shooting range, an animal shelter
(dog pound), and an inactive wastewater treatment plant. The landfills were operated by
the city for the disposal of municipal and industrial solid wastes. The Fu~bright
Landfill covered 98 acres and operated from 1962 through 1968. The Sac River Landfill,
'ormerly known as the Murray Landfill, covered 114 acres and was in operation from 1968
_hrough 1974. Generally, wastes (drummed or bulk) were disposed of in trenches and
covered with soil. The City of Springfield and Litton Industries Inc. agreed to conduct
the RI and the FS under the oversight of EPA. Several leachate seeps have been noted,
especially during wet weather. In addition to the landfill areas, another source of
contamination was identified where a few dozen drums and waste residues were disposed of
in a sinkhole on the bluff above the Fulbright Landfill. Based on data from the RI,
environmental contaminant concentrations in soil, ,ground water, leachate, surface water,
and sediments do not exceed applicable or relevant and appropriate requirement
standards. The site, however, could endanger human health or the environment in the
(See Attached Sheet)
17.~~t 6'PIYli~c !:sl!~ptors
Fulbright/SAC River Landfills, MO
First Remedial Action - Final
Contaminated Media: debris
Key Contaminants: acid, cyanide
b. Identlfiers/Open.Ended Terms
c. COSATI Fleld/Graup
I";"'" v.llability Statement
19. Security Clas. (Thi. Report)
None
21. No. 0' Pa.,s
39
---- --
20. Security CI... (This Pa.e)
None
22. Price
(See AN5I-Z39.18)
S.. In.tructlons on Reverse
OI"TIONAL FORM 272 (4-77\
(Formerly NTI5-35)
. Department 0' Commerce
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EPA/ROD/R07-88/030
-11bright/SAC River Landfills, MO
~rst Remedial Action - Final
...
16.
ABSTRACT (continued)
future through exposure of the industrial wastes through erosion of the landfill cover,
installation of drinking water wells at or near the landfills, or from direct contact
with leachate at the seeps. While a reference is made to disposal of cyanide and acid
wastes, the primary contaminants of concern affecting the media investigated are not
listed in the ROD.
The selected remedial action for this site includes: removal of the drum and drum
remnants found in the sinkhole and associated trench east of the Fulbright Landfill;
sampling the removed contents to determine hazardous characteristics; proper offsite
treatment or disposal of removed contents; observation of the leachate seeps during
maintenance (no action), ground and surface water monitoring for a 30-year maintenance
period; and imposition of deed restrictions and ground water use prohibitions. The
estimated present worth cost for this remedial action is $270,400 if wastes are disposed
of as hazardous waste or $246,600 if disposed of as solid waste.
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RECORD OF DECISION
DECLARATION
REMEDIAL ALTERNATIVE SELECTION
SITE NAME AND LOCATION
Fulbright/Sac River Landfills
Springfield, Missouri
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial
actions for the Fulbright and Sac River Landfills in Springfield,
Missouri. The selected remedial actions were developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and with the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300, to the extent
practicable. This decision was based upon the documents and
information contained in the Administrative Record for these
landfills. Copies of the Administrative Record are available in
the Docket Room at EPA Region VII's Office in Kansas City,
Kansas, and at the Office of the City Clerk in City Hall, 830
Boonville Avenue, Springfield, Missouri.
The State of Missouri has been consulted with and concurs
on the remedies selected.
DESCRIPTION OF THE SELECTED REMEDIES
The U.S. EPA, in consultation with the State of Missouri,
has determined that the following actions, described and
evaluated in the Feasibility Study and the Proposed Plan for
remedial action (both of which are found in the Administrative
Record), effectively protect public health and the environment and
otherwi.. satisfy or meet the nine criteria established by
Section 121 of SARA, for the evaluation and selection of remedial
actions.
The remedial actions selected for the Fulbright/Sac River
Landfills are described below:
- Drum Removal. The drums and drum remnants found in the
sinkhole ~rench east of the Fulbright Landfill will be removed
for offeite treatment or disposal. It is assumed that the
contents of the drums are hazardous wastes. Chemical analyses
will be conducted on the contents of the wastes in 'order to
determine appropriate treatment or disposal. If such analyses
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reveal the contents of the drums to be nonhazardous, the drums
and their contents may then be disposed as 80lid wastes in
accordance with state regulations.
- Post Closure Monitoring. Ground and surface water
monitoring will be continued for both landfills. Two ground
water monitoring wells at each landfill and two offsite water
wells will be sampled regularly. Surface water samples will be
collected regularly downstream of the landfills. Water samples
collected will be analyzed for hazardous substances.
Periodically, the scope (in terms of the frequency ot sample
collection, the number of wells sampled, and the compounds for
analysis) ot the monitoring program will be ~e-evaluated.
- Leachate Manaaement. At the present time no specific action
will be taken regarding leachate seeps. Leachate seeps have only
been occasionally noted. Post-closure monitoring and maintenance
for the landfills will be conducted. The need for remedial
measures for leachate seeps will be periodically evaluated after
review of post-closure monitoring data.
- Deed Restrictions. The landfills will remain on the State
of Missouri's Registry ot Hazardous Waste sites. This will
impose certain land use restrictions. In addition, EPA will
require specific deed restrictions further limiting future uses 0
the property, to prevent or control any uses (such as buildings
with basements in the waste fill) which could result in
significant contaminant releases or exposures.
DECLARATION
The selected remedy is protective ot human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate to the remedial actions
and is cost-effective. Section 121 of CERCLA identifies a
statutory preterence for treatment. Onsite treatment is not
appropriate for the landfills at this time. Drums will
be removed from the Fulbright Landfill sinkhole/trench tor
oftsite 88ftag_ment".. Treatment will be considered in lieu of
disposal for the contents of these drums.
Because the selected actions result in a hazardous substance
remaining onsite, a review will be conducted to assure that human
health and the environment are being protected. This review
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shall occur no less often than each five years after initiation
of the selected actions. sample analYtical data generated in the
post-closure monitoring will be used in these reviews.
'1- 30 .)s-~
vaJr/~r
Regional Administrator
Date
Attachments:
Decision Summary
Responsiveness Summary
Transcript of Public Meeting
Index to Administrative Record
3
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RECORD OF DECISION
Fulbright/Sac River Landfills
Springfield, Missouri
Prepared by:
u.S. Environmental Protection Agency (EPA)
Region VII
Kansas City, Kansas
September 1988
..
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Section
I.
II.
Record of Decision
Decision Summary
Contents
Introduction
1.1
1.2
1.3
1.4
1.5
1.6
Facility Location
Facility History
Hydrogeologic Setting
Enforcement History
Landfill Operation/Waste
Community Relations
Disposal
Site Characterization
3.1
3.2
Remedial Investigation-Objectives
Remedial Investigation Activities
Remedial Investigation Results
III. Site Risks
IV.
V.
VI.
2.1
2.2
2.3
Potential site Risks
CUrrent Site Risks
Documentation of Significant Changes
Description of Alternatives
5.1
5.2
5.3
5.4
Fulbright Sinkhole and Trench Drums
Leachate Seeps
Ground and Surface Water Monitoring
site Use Restrictions
Summary of the Comparative Analysis of the
Alternatives
6.1 "Fulbright Sinkhole and Trench Drums
6.2 Leachate Seep Control
6.3 Ground and Surface Water Monitoring
6.4 Site Use Restrictions
bSm
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1
1
1
3
3
4
4
4
5
5
6
6
7
8
8
8
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10
11
11
12
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VII.
VIII.
IX.
Selected Alternatives
7.1
7.2
7.3
7.4
Fulb~iqht Sinkhole and Trench Drums
Leachate Seeps
Ground and Surface Water Monitorinq
site Use Restrictions
Statutory Determinations
Implementation
Attachments
Fiqure 1
Table 1
Area Map
Evaluation of Potential Response
Alternativs
2
13
13
13
13
13
14
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SECTION I - INTRODUCTION
1.1
Facili~v Location
The Fulbright and Sac River Landfills are located just north
of the City of Springfield (the .City") in the floodplain of the
Little Sac River (Fiqure 1). The landfills are located in a
semirural area north of the City. There are no residences
immediately adjacent to the landfills, but several in the general
vicinity.
The land on which the landfills is located is owned by the
City, which also owns much of. the surrounding land, some of which
is presently used by the City as a police shooting range and as
an animal shelter (doq pound). The"City's inactive Northwest
Wastewater Treatment Plant is located immediately south of the
Fulbright Landfill. Effluent from this plant's treatment of
municipal sewage was discharged to Pea Ridge Creek, which drains
into the South Dry Sac and Little Sac Rivers. While the remedial
investigation (RI) and endangerment assessment (EA) and
feasibility study (FS) were being conducted, the City completed
construction of its new Northwest Wastewater Treatment Plant,
located south of the Sac River Landill. Effluent from the new
plant is discharged to the Little Sac River, just downstream of
the Sac River Landfill. The old Wastewater Treatment Plant has
been closed and no longer discharges treated effluent.
1.2
Facilitv History
The Fulbright and Sac River Landfills were operated by the
City for the disposal of municipal and industrial solid wastes
generated in the Springfield area. The Fulbright Landfill
covered 98 acres and operated from 1962 through 1968. The Sac
River Landfill, formerly known as the Murray Landfill, covered
114 acres and was operated from 1968 through 1974.
The EPA placed the Fulbright Landfill on its National
prioriti.. List (NPL) of hazardous waste sites in 1981. In 1967
a death occurred-at the Fulbright Landfill, when cyanide wastes
were ai.takenly dumped into an acid pit instead of the cyanide
pit, liberating cyanide gas. The driver of the truck recovered;
however, the driver's helper died.
1.3
Hydroaeoloaic Setting
Both landfills are located in the floodplain of the Little
Sac River. The Fulbright Landfill is located along the South Dry
Sac River; a tributary of the Little Sac River. The Sac River
Landfill is located on the Little Sac River, just downstream of
the confluence with the South Dry Sac River. Approximately 10
feet of alluvial soils were generally present at ground surface
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where both landfills were located. The soil layer is thinner
closer to the bluff lines forming the boundary of the floodplain.
These alluvial soils, consisting of weathered limestone and clays
with variable permeability, were used as daily and final cover at
the landfills.
Bedrock in the vicinity is a fractured, karst limestone with
sinkholes. Ground water flow in the fractured limestone tends to
follow fractures ("secondary permeability"). In the floodplain
the water table (upper ground water level) is generally found at
a depth of 3-8 feet below ground surface, corresponding to the
level of water in the adjacent river. Available data and
information suggest that the upper bedrock ground water and
surface water run-off from the landfills wo~ld be discharging to
the adjacent (Little Sac or' South Dry Sac) rivers.
Alluvial ground water and upper bedrock ground water are
interconnected and are generally considered to be part of the
same aquifer. The upper bedrock aquifer is not a significant
ground water resource in the area, although there are a few'
private wells completed into the upper bedrock in the area. None
of these wells are believed to be at risk of contamination by
releas~s (rom the landfills.
The limestone bedrock beneath the landfills is generally abo
100 feet thick. The Northview Shale is found directly beneath
the limestone and is relatively impermeable and should not allow
the vertical transfer of significant quantities of water (either
up or down). Beneath the Northview Shale are a series of
l~mestone, shale, sandstone, and dolomite bedrock formations.
With the exception' of the shale, these are water-bearing and are
known collectively as the deep bedrock aquifer. The deep bedrock
aquifer comprises the most valuable ground water aquifer in the
area. The City of Springfield withdraws some of its drinking
water from the deep bedrock aquifer from a well upgradient of the
landfills.
Ground water flow direction in the deep bedrock aquifer is
to the northweat.... .away from the public drinking water supply and
toward ~. landfills. This tends to reduce the potential for
contamination of the water supply by any releases from the
landfill.. Available data also indicate. that the vertical
gradient is generally upward from the deep bedrock aquifer toward
the surface. No downward vertical gradients were identified in
the RI/FS. This tends to further reduce the potential for
contamination of the deep bedrock aquifer by releases from the
landfills. If uses of ground water from the deep bedrock aquifer
were significantly increased, downward vertical gradients could
be created.
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1.4
Enfofcement History
Neither landfill was permitted or licensed by the state of
Missouri, which lacked jurisdiction to requlate waste disposal
when the landfills were in operation. The landfills were not
regulated by EPA or the Federal Government durinq their
operation. However, the desiqn, construction and operation of
the landfills is believed to have been typical for landfills
operatinq durinq those time periods.
The City of Sprinqfield and Litton Industries Inc. aqreed to
conduct the RI and the FS under the oversiqht of EPA. A Steerinq
Committee was formed and headed by the city.to coordinate
activities amonq the potential responsible parties (PRPs) for the
landfills. The EPA issued an Administrative Order on Consent
under section 106 of CERCLA to the City and Litton Industries as
PRPs, settinq forth the procedures under which the RI and FS were
conducted.
At this time no administrative orders or other decrees have
yet been issued on the remedial actions to be implemented. At
the time such Orders or decrees have been completed they will be
made part of the Administrative Record.
1.5
Landfill ODeration/Waste DisDosal
Generally, wastes were disposed in the landfills in the
floodplain by the "trench and fill" method of landfill operation.
A trench would be excavated down to bedrock, usually about 10
feet deep. Wastes, either drummed or in bulk, would then be
dumped into the landfill and covered with the soil that had been
excavated in the diqqinq of the trench. Trenches qenerally ran
perpendicular to the adjacent river. Some waste settlinq now
makes the trenches evident. Neither landfill had an impermeable
liner installed beneath the wastes, nor did either landfill have
leachate collection or gas collection system or an impermeable cap,
although both landfills do have a soil cover.
At the Sac River Landfill some wastes were disposed of in a
former rock quarry. The "Quarry Pit" resulted from the mininq of
limestone and was .excavated deeper into the limestone bedrock. A
few dozen drums were disposed of in a sinkhole/trench on the
bluff above (and east) of the Fulbriqht Landfill. Althouqh now
rusted and corroded, these drums appear to have been disposed of
in the sinkhole after the Fulbright Landfill was closed. Wastes
were also reported to have been disposed of in a small pit at the
Sac River .Landfill, south of the Little Sac River, near the
landfill gatehouse on Hiqhway 13. However, no physical evidence
of this waste disposal was found. No evidence of waste disposal
or metals contamination .of ground water were noted in the
geophysical survey conducted.
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1.6.
Community Relations
A C088Unity Relations Plan (CRP) was developed and
apl_ented by EPA for the landfills. The CRP can be found in
the Ac1JIini.trative Record.
The RI Report and Endanqerment Assessment was released for
public review and co_ent. A Public Notice of the RI Report's
availability was _de in the Sprinqfield Newsleader on April 28,
1988. The RI Report was _de available for public review and
co..ent in the Sprinqfield Public Library. A Responsiveness
Summary was developed on the sinqle comment received and is found
in the Administrative Record.
The PrOp08ed Plan for r..8diation (PP), the Peasibility
Study (FS), and the Remedial Investiqation (RI) Report and
Endanqeraent As.e...ent (D) were released for 21 days of public
review and co..ent on Sept88ber 8, 1988 with another public
notice in the sprinqfield Newsleader. The PP, FS and the RI
Report and D were placed in the Office of the Sprinqfield city
Clerk, the Sprinqfield Public Library, and the EPA Reqion VII
Docket Room for the public's review. The Administrative Record
was placed in both the Office of the Sprinqfield City Clerk and.
the EPA Region VII Docket Room.
A public meetinq was held on September 19, 1988, durinq
which oral comments on. the PP, FS and RI Report and EA were
received and questions on the proposed actions were responded tOG
In response to some of the comments received durinq the public
meetinq, EPA conducted a door-to-door survey of area residents to
qauqe the level of community concern. Most, but not all,
residents interviewed were aware of the RI/FS conducted on the
Fulbriqht/SAC River Landfills. None of the residents ~nterviewed
expressed serious reservations about the recommended actions.
A Responsiveness Summary has been prepared as part of this
Record of Decision on the oral and written comments received on
the PP, FS, and RI Report and EA.
SECTION II - SITE CHARACTERISTICS
2.1 Remedial Invest.tsAtJ.on - Ob~
The SPA prepared the RI/FS Workplan, which the City and
Litton Industries, Inc. (the PRPs) implemented under EPA
oversiqht. Subsequent plans, such as the health and safety plan
and the quality assurance project plan, were developed by the
PRPs and approved by EPA. The Objectives of the RI were to: 1)
identify contaminants present in the wastes which aiqht be
released into the environment: 2) determine the hydrogeologic
settinq of the landfills: 3) Identify potential routes of
contaminant. release and the ultimate fate of any contaminants
released from the landfills: and 4) evaluate potential human
exposure from releases from the landfills and adverse
environmental impacts.
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2.2 Remedial Invest~ion Act~
The RI field work, performed by the PRPs in 1986 and 1987
under EPA oversight, included the following activities.
-A geophysical investigation was conducted using remote
sensing techniques. E1ectromaqnetic measurements and resistivity
soundings were taken over both landfills. The purposes of the
geophysical investigations were: to tentatively identify depth to
bedrock and fill depth, to provide 80me information on subsurface
soils types, to identify any plumes of metal contamination in
shallow ground water, and to locate larqe deposits or
concentrations of buried drums. The results. of the geophysical
investigation were then used to select locations for monitoring
well installation.
-A series of alluvial and shallow bedrock ground water
monitoring wells were installed to detect releases of
contamination in ground water. Ground water samples were
collected for chemical analyses.
-Several leachate seeps were sampled for chemical analysis.
-Surface water and sediment samples were collected from the
adjacent river and were analyzed for hazardous substances.
-Ground water elevations were measured in the monitoring
wells to determine directions and patterns of ground water flow.
-Drum remnants and contaminated soil from the
sinkhole/trench on the bluff above the Fulbright Landfill (the
only known location of surface drums) were sampled and analyzed.
2.3 Remedial Investiaation Results
Contaminant concentrations in the environmental media
sampled (soil, ground water, leachate, surface water, and
sediments) were relatively low. Contaminant concentrations in
the environmental samples collected are summarized in detail in
the RI Report.
Using the analytical data trom the RI Report and available
hydroqeoloqic datA. and information, estimates were then made on
contaminant concentrations at expected or potential "points of
use". The.e calculations can be found in the Endangerment
Assessment portion ot the RI Report.
Three endangered species have been reported by the U.S. Fish
and wildlife service in the vicinity: Bald Eagle (Haliaeetus
leucoceohalus), Gray Bat (Mvotis arisescens), and Missouri
Bladderpod (Lesquerella tiliformis). Two additional threatened
species ar~ present in the area: Nianqua Darter (Etheostoma
nianauae) and Ozark Cavetish (Amolvoosis rosae). It is not
expected that contaminant releases from the landfills will have
any measurable adverse impact on the endangered and threatened
species. .
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SECTION III - SITE RISKS
3.1 Potential Site Risks
When the Fulbright Landfill was placed on the NPL, it was
believed by EPAthat wastes in the landfill potentially posed the
following risks.
-The wastes disposed could result in contamination of both
shallow and deep ground water. Since the directions "of ground
water flow and vertical gradients were not known or" fully
understood, it was assumed that all area ground water might
be at risk. Actual ground water contamination could have
precluded future uses of ground water. "
-The disposed wastes could also contaminate the adjacent
South Dry Sac River and the Little Sac River. Potentially
adverse impacts on water quality and fishing and recreation were
a concern. .
-Very little historical information was available on the
operation of the landfills (i.e. the specific methods of waste
disposal). It was not known whether wastes or drums might still
be at or near the ground surface posing potential direct contact
exposure hazards. In addition, it was suspected that contami-
nated leachate seeps might pose a direct contact threat and
release contaminants to the ground or surface water.
-Although surrounding land uses and the potential for human
pedestrian traffic onsite was generally known before the
RIfFS was begun, little or no information was available about
wildlife or endangered or threatened species which might have
been at risk from contaminants released from the landfills~
Review of the data and information provided in the RI and FS
has now greatly expanded EPA's knowledge about the site.
AnalYtical or hydrogeological data about the landfills has
eliminated many of the concerns related to potential endanger-
ment. FOE example,' the direction of ground water flow is to the
northwe.t, which i. DQt toward the public drinking water supply.
For much of the area the vertical hydraulic gradient appears to
be upward, not down. Contaminant concentrations found in the
soil, ground water, surface water, and sediments were all
relatively low. Leachate seeps occur infrequently, and in small
quantities with very low levels of contamination. A few private
drinking water wells were found during the ground water use
survey. None of these wells appear to be at risk of contamina-
nation by 'the landfills.
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The BPA has determined the contaminant concentrations in all
media sampled do not represent an immediate threat to human
health or the environment.
3.2 CUrrent site Risks
Based upon data from the RI, environmental contaminant
concentrations do not exceed applicable or relevant and
appropriate requirement standards for a realistic worst-case
scenario. CUrrent and future site risk were evaluated in detail
in the Endangerment Assessment Chapter of the RI Report. The
endangerment of human health or the environment at the landfills
are described below.
-Industrial wastes, some of which contain hazardous
substances, remain in the landfills beneath the cover. If the
cover is damaged or erodes, these wastes may be exposed,
increasinq the potential for direct contact exposures and
releases to the environment (ground water, air and surface
water).
-Additional withdrawals of ground water from public or
private drinkinq water wells could potentially alter the ground
water flow and subsequent risk of contamination. However, current
data indicate that a chanqe the direction' of ground water flow
alone would probably not result in siqnificant endanqerment.
contaminant concentrations so far detected would be diluted below
any health related standards or criteria before they reached a
drinking water well. Higher levels of contamination in qround
water alone, would also not necessarily result in siqnificant
endangerment, since there is no current down-gradient ground
water usage at risk.
-There is currently no prohibition against the drilling and
use of new wells for drinking water at or near the landfills,
where contaminant concentrations might exceed those which would
be acceptable or recommended for drinking purposes.
-Draa remnants and waste residuals were identified in a
sinkhole on the bluff above (and east of) the Fulbright Landfill.
Due to the difficulty and hazards associated with sampling in
such confined spaces, adequate samples could not be collected for
complete characterization of the levels of contamination.
contaminant concentrations in some of the less accessible
portions of the sinkhole could still pose a direct contact
threat and potentially release contaminants into the
environment.
-Several leachate s~eps were noted, especially durinq wet
weather. The leachate seeps have the potential to result in
direct contact exposures and a150 contribute to contaminant
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levels in the river. CUrrent data indicates the contaminant
levels in the leachate seeps do not exceed applicable criteria or
standards. However, future releases could contain elevated
contaminant concentrations, resulting in direct contact exposures
risks.
SECTION IV - DOCUMENTATION OF SIGNIFICANT CHANGES
section 117(a) of CERCLA/SARA requires that a Proposed Plan
for remedial action (PP) be prepared by EPA and released with the
Feasibility Study (FS) for public review and comment. The PP
highlights key information from the RI and FS Reports, briefly
describes the alternatives for site remediation and identifies
preferred alternatives and rationale. EPA released the PP and
the FS, along with the RI Report and EA, for public review and
comment on September 8, for a 21-day comment period.
section 117(b) of CERCLA/SARA further requires that any
changes in the remedy or response actions selected in the final
remedial action plan, that differ from those recommended in the
PP, be described along with the reasons for such changes. The
response actions recommended in the PP are the same aa those
which are selected in this final remedial action plan. However,
EPA notes that the two surface water sampling points discussed in
the FS for the Intermediate Ground and Surface Monitoring
Alternative (C.2 of the PP) were inadvertently omitted from this
alternative in the PP. This alternative was selected as the
preferred alternative in the PP, including the two downstream
surface water sampling points.
SECTION V - DESCRIPTION OF ALTERNATIVES
Alternative response actions were developed to respond to
each of the problems representing a potential endangerment at
each of the landfills. The EPA considered alternatives not
discussed in the PS: 1) Complete waste excavation and removal
for off.it. treatment or disposal in lieu of site-use
restriction.; 2) Complete waste removal for offsite disposal or
treatment to control leachate seeps. Although these altern~tives
were considered, they are not preferred EPA.
5.1 Fulbriaht Sinkhole and Trench Drums
Five alternatives were identified as potentially applicable
for the d~s in the Fulbright sinkhole and trench.
-No-action.
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-Excavation for disposal/management as hazardous waste.
-Excavation for disposal/management as solid waste, if
subsequent sampling and analysis characterized the waste as non-
hazardous.
-In-place soil cover.
5.2
Leachate SeeDS
Five potentially applicable alternatives were identified-for
the leachate"seeps on the g~ound surface and in the river banks
at both landfills.
-No-action.
-Seep isolation barriers (such as rocks. or geotextile
membranes) .
-Upqradient collection/interception.
-Downgradient leachate collection and treatment.
-Complete waste excavation and removal for
disposal/treatment.
5.3
Ground and Surface Water Monitoring
Four alternatives were identified as potentially applicable
for ground and surface water monitoring at both landfills.
-Extensive ground and surface water monitoring (periodically
collecting water samples from all onsite monitoring wells, from
two nearby offsite wells, and up and downstream in the adjacent
river and analyzing for all hazardous substances).
-Intermediate ground and surtace water monitoring
(periodically collecting and analyzing water samples for
pertinent fractions of the hazardous substances from two
monitoring wells at each landfill, from two additional nearby
wells, and from the adjacent river just downstream of each
landfill).
-Liaited monitoring (periodically collecting and analyzing
downstr... surfac.water samples for some hazardous substances).
-No-action (other than monitoring of the adjacent river for
the discharge from the wastewater treatment plant).
5.4 site Use Restrictions
Three alternatives were identified as potentially applicable
for site use restrictions, including restrictions to prevent;
direct contact exposures, the drilling of additional wells at the
landfills, and. the consumption of potentially contaminated ground
-water.
9
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-No-action (The landfills would still be on the Missouri
Registry of Hazardous Waste Sites, which would provide certain
protections and limitations on changes in land use.)
-Deed restrictions/ground water use prohibitions/recommendations.
-Complete removal of all hazardous wastes and wastes
containinq hazardous substances for offsite disposal. or
management (in lieu of any access restrictions and including
removal from the. Missouri Registry).
SECTION VI - SUMMARY OF THE COMPARATIVE ANALYSIS OF THE
ALTERNATIVES
The alternatives described in section 5 were evaluated using
criteria presented in EPA Directive 9355.02, Draft Guidance on
Preparing Superfund Decision Documents: The Proposed Plan and
Record of Decision". These criteria relate to factors mandated
in section 121 of CERCLA/SARA, and considerations of the overall
feasibility and acceptability of the remedy. The nine criteria
are as follows.
-Protection of human health and the environment.
-Compliance with applicable, or relevant and appropriate
regulatory requirements (ARARs).
-Long-term effectiveness and permanence.
-Short-term effectiveness.
-Reduction of (waste) toxicity, mobility, or volume.
-Implementability. .
-Cost.
-State acceptance..
-Community Acceptance.
To some extent the problems and potential response actions
(alternatives) are independent of each other and were therefore
evaluated separately. For example, response actions taken for
the drum remnants in the Fulbright sinkhole have no direct
bearing on response actions for the leachate at both Landfills.
Also, S088 qround and surface water monitoring needed to be
considered whether or not the leachate was controlled or captured
at this time.
As' required by law, the no-action alternative is retained,
even when it does not accomplish the remedial objective
identified, to establish a baseline comparison.
Table 1 screens and evaluates the potentially applicable
response action alternatives for each problem statement. A bri~
statement of the qoals and ~bjectives for each problem statement
is also included in Table 1. (Refer to Table 1 for .numbering
identification of the alternatives discussed below.)
10
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6.1 Fulbria~t Sinkhole and Trench Drums
Alternative A.2, Excavation and Disposal (or Treatment) as a
hazardous waste, is the recommended alternative. Of the three
alternatives accomplishing the remedial objectives, this
alternative affords the greatest degree of protection and would
b. most certain of accomplishing this objective. This
alternative also meets applicable or relevant and appropriate
requirements (ARARs), and is most effective for both the short
and long term. It is preferred over Alternative A.2, Excavation
and Disposal as a solid waste, because it i. probable that when
fully characterized at least some of the wastes would be
hazardous and would still have to be managed as a hazardous
waste. If sampling and analyses reveals these wastes to be
nonhazardous, they could still be managed as'solid, nonhazardous
wastes in compliance with state regulations under the recommended
alternative (A.2). In practical application Alternative A.2 will
differ little, if at all, from Alternative A.3.
6.2 Leachate SeeD Control
Alternative B.1, No-Action, is the preferred alternative.
EPA believes it is prefe~able to address any seeps at either
landfill which need control in a post-closure monitoring and
maintenance plan. If large or enduring seeps are noted in post-
closure monitoring, it would then be more appropriate to consider
control measures, and possibly additional access restrictions.
Controls such as the rock barriers discussed in Alternative 8.2
might then be considered for implementation.
Although Alternative 8.2, seep"Isolation Barriers, appears
to afford a higher degree of protection of public health, EPA
notes that.under present use conditions the leachate does not
pose a significant threat to health or the environment. Seeps
have only been occasionally noted. EPA is concerned about the
poor effectiveness of Alternative 8.2. Even after covering all
currently existing seeps, additional seeps could always develop.
Also any .e.ps now existing only occasionally occur. A more
effective means: of-preventing potential direct contact exposures
would be to address' them as part of post-closure monitoring and
maintenance. Alternative 8.3, Upgradient leachate collection
Interception Barrier, is rejected because it would not
effectively accomplish the remedial objectives and because of
costs. Alternative 8.4, Complete Waste Excavation and Removal
for Offsite Disposal/Treatment, is rejected because of poor
implementability, the hazards related to excavation and waste
handling, and costs. Since the landfills have been closed for
over 14 years, records regarding the chemical nature of all
wastes disposed are not available. It would have to be assumed
that a wide variety of potentially incompatible wastes are
present in the landfill, alt~ough soluble contaminants are
apparently not being released in significant quantities. It is
11
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unlikely that any single treatment or disposal process would be
suitable for all of the wastes if excavated. MUlti-stage
process.s for treatment and disposal would have to be considered.
6.3 Ground and Surface Water Monitorina
EPA recommends Alternative C.2, the Intermediate Level of
Monitoring, a. the preferred alternative for both landfills.
Alternative C.l might appear to provide greater protection of
public health and the environment. However, given the very low
contaminant level. so far found in the environmental samples
collected, Alternative C.2 provide. sufficient early warning of
any potentially significant changes in qround water quality. The
EPA notes that the rate. and patterns of qround water flow are
likely to be more important determinants of any increased
potential endangerment than ground water contaminant
concentrations. Alternatives C.3 and C.4 do not provide
sufficient data to identify trends or changes in surface or
ground water flow or quality and resultant impacts on
endangerment. Although C.2 is selected for the initial phases of
monitoring it will eventually be appropriate to re-evaluate the
o scope of the continued monitoring, based upon the data received
and revi~wed.
6.4 Site Use Restrictions
EPA recommends Alternative D.2, Deed Restrictions/Ground
Water Use Prohibitions. Alternative D.l, No-Action/Missouri
Registry, also provides much of the same protection. However,
D.2 is more specialized to the needs of these landfills and is
preferred over D.l for that reason. Alternative D.3, Complete
Waste Removal, is rejected on the basis of the difficulty of
implementation, the associated hazards to health and the
environment, and because of costs.
In selecting D.2, EPA will require deed restrictions on the
City property on which the landfills are located. EPA has
required .imilar deed restrictions on other sites. At the
present tiae SPA does not see a need for any deed restrictions on
the surrounding property, not owned by the City. EPA would
recommend that the State and local authorities be used to control
or prevent the drilling of any new wells on such adjacent or
nearby properties for drinking water unless the water is
initially and periodically tested for contamination. Any new
wells drilled, should be properly installed and cased in order
not to create new avenues for contaminant release to ground
water.
12
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SECTION VII - SELECTED ALTERNATIVES
EPA reviewed the data and information from the RI Report and
Endanqerment Assessment, the Feasibility study, and other
relevant data and information in the evaluation of the
potentially applicable alternatives. The followinq are the
alternatives selected for the Fulbriqht /Sac River Landfills.
7.1
Fulbriaht Sinkhole and Trench Drums
The contents of the. sinkhole and associated trench on the
bluff above the Fulbriqht Landfill shall be removed. Sampling
and analysis of the contents of the sinkhole' shall be conducted
in order that the wastes or materials excavated can be safely
disposed. It will be assumed that the wastes are hazardous and
must be disposed as hazardous wastes. However if review of
analytical data on the samples collected indicates the contents
of are nonhazardous, they may then be disposed as solid wastes' in
accordance with state requlations.
7.2
Leachate SeeDS
No remedial actions will be taken on leachate seeps at this
time. The need for remedial actions for leachate at the
landfills will be periodically re-evaluated upon review of post-
closure monitorinq and maintenance data an4 information.
7.3
Ground and Surface Water Monitorina
The intermediate level of qround and surface monitorinq
shall be conducted. This will include periodic samplinq of two
monitorinq wells at each landfill, two nearby offsite wells, and
samplinq of the adjacent river just downstream of each landfill.
Water samples collected will be analyzed for pertinent fractions
of the hazardous substances list.
7.4
Sit. Use Restr~
Dead restrictions will be required on the City property
containing the landfills. The restrictions will prevent or
safely control future uses of the property which could result in
direct contact exposures or result in siqnificant contaminant
releases to the environment. It is recommended that state and
local authorities be considered for preventinq or controllinq the
drillinq of new wells for drinkinq on nearby property not owned
by the City.
13
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SECTION VIII - STATUTORY DETERMINATIONS
Based upon all of the available information, the selected
actions satisfy the remedy selection requirements under
CERCLA/SARA and the NCP. The actions provide protection of
public health and the environment, meet all applicable or
relevant and appropriate requirements, and is cost-effective.
Innovative treatment technologies will be given preference when
evaluating options for the disposal of the drum remnants from the
Fulbright sinkhole, as well as any leachate collected, 'if ever
necessary.
To the extent practical the remedy is a~so permanent.
However, it is quite appropriate at this site that post-closure
monitoring of ground and surface water be provided. Such data
will provide the basis for the 5-year evaluations mandated by
SARA for sites such as these landfills.
SECTION IX - IMPLEMENTATION
The response actions selected by this Record of Decision
will not be initiated before December 1988. '
The Regional Administrator retains the authority to make
changes in the scope and nature of the actions undertaken at
either of the landfills. If new information or additional
environmental data is received by EPA, the selected actions will
be reviewed and additional response actions will be considered in
light of the new information or data.
14
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RESPONSIVENESS SUMMARY
Record of Decision for
Fulbright/Sac River Landfills
Springfield, Missouri
This Responsiveness Summary presents the responses of the
Environmental Protection Agency (EPA) to public comments received
regarding the proposed remedial actions for the Fulbright and Sac
River Landfills in Springfield, Missouri. This document
addresses all comments received by the Agency during the public
comment period conducted as part of the remedy selection process.
A remedial investigation/feasibility study (RI/FS) was
conducted on the landfills by the potentially responsible parties
(PRPs) under EPA oversight. A Propo8ed Plan was developed by
EPA, which made recommendations on the remedial actions for the
landfills. The RI/FS report and the Proposed Plan were released
for public review and comment for a 21 day period which began on
September 8, 1988 with a public notice in the SDrinafield ~
Leader. A public meeting was held in springfield at the City
Hall on September 19, 1988 at 7:00 p.m. A number of verbal
comments from the public were received by EPA during that public
'meeting. .
The following are the substantive public comments, and EPA's
response, to the RI/FS and the Proposed Plan.
Comment: A commenter stated that the individuals who actually
conducted the RI/FS, the City and generators of wastes disposed
in the landfills, had motivation not to find any problems at the
landfills in order to limit their liability.
lEA ReSDonse: Potentially responsible parties (PRPs), such as
the owners of the site or the generators of the wastes disposed,
do sometimes have a motivation to not identify problems at a
site. For this reason EPA oversees such efforts closely, as
required by the Superfund Amendments and Reauthorization Act
(SARA). On this RI/FS, EPA actually developed the RI/FS
workplan. Subsequent plans were developed by the PRPs with
substantial SPA review and approval. Field work was witnessed or
overseen by SPA or SPA contractors. In EPA's opinion, the RI/FS
was properly and professionally conducted.
~
Comment: The same commenter asked whether or not the RI/FS was
conducted by an "uninterested party". The same commenter asked
why the City and Litton Industries were selected to conduct the
RI/FS.
lEA ReSDonse: The RI/FS was,~onducted by the City, as the owner
of the landfills, and som. of the generators of wastes disposed
in the landfills. These are, of course, not disinterested
1
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parties. EPA is statutorily required to offer the opportunity to
conduct ~e RIjFS, as well as other response actions, to
potentially responsible parties (PRPs). The EPA had identified
the City and Litton as 'PRPs and notified them of their potential
liabiliti.. tor the landfills and that an RIjFS would have to be
conducted, if not by tham, then by EPA. As potentially
responsible parties they could be liable for the costs of EPA's
RIjFS if they refused to conduct it. The City and Litton then
aqre8d to conduct ~e RIjFS under EPA oversight.
Comment: A commenter asked whether or not all pertinent
information was revealed to ~e public by EPA in the September
19, 1988 public .eetinq.
lEa Res~onse: All pertinent inforaation regardinq ~e landfills
is contained in ~e Adainistrative Record on ~e landfills. This
record is available for the public'. review in the office of the
Springfield City Clerk in City Hall. The public meeting lasted
slightly more than two hours and concluded only when there were
no more comments or questions from the public. Of course all of
the documents or information in the Administrative Record, which
is approximately 24 inches thick, could not be discussed in a two
hour ..eting. However, EPA believes that all relevant
intormation was presented and explained, either durinq the
meetinq or in the documents (the RI Report, the FS, and the
Proposed Plan) that were the subject of the meeting.
Comment: A commenter noted that the drum remnants in the
sinkhole above the Fulbright Landfill had not been identified or
characterized. The commenter then questioned why the contents of
the sinkhole were not adequately characterized during the RI.
lEA Response: The sinkhole containinq the drums and the drum
remnants was difficult to sample because of the confined space
and physical limitations of sending personnel into such spaces
where hazardous substances are suspected. Some samples were
collected in which some hazardous substance. were identified,
althouqh not in toxic concentrations given the settinq and
inacce..ibility of the sinkhole. It was determined that the most
eftective ..thod for dealinq with the drum remnants was to remove
th.. fro. the .inkhole and then sample and analyze the contents
to deteraine appropriate treatment or disposal. This was the
alternative reco_ended in EPA's Proposed Plan.
Comment: A' commenter stated that SPA's recommendation tor
monitorinq two ot ~e monitorinq wells at the Fulbright sinkhole
in lieu ot removinq the drums was inadequate protection of human
health and the environment.
lEa Response: EPA did not recommend monitoring in lieu of
removal of drums the Fulbrig~t sinkhole. The Proposed Plan
recommended that the contents of the Fulbright sinkhole be
removed for treatment or disposal atter sampling and analyses.
2
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Ground water and surtace water monitoring was recommended for
both landfills in lieu of removal ot all wastes from both
landfiils for treatment or offsite disposal.
Comment: A commenter stated that the Administrative Record
released by EPA on the landfills is three feet tall and that a
21-day comment period was inadequate and did not allow the public
to review and co_ent on the _terial.
lEi ReSDonse: The National contingency Plan (NCP) requires a
mini8um 21-day comment period ti8e tor co..enting on these
dOCUJlents in EPA's superfund Proqraa. EPA note. that it has
attempted to keep the public inforaad about the landfill status
and activities by periodically distributing fact sheets to
aembers ot the co_unity, the new. aadia, and a8Jlbers ot the
local co..unity. EPA believe. the 21-day public comment period
does provide sufficient ti8e tor public review and comment.
Comment: A commenter, based upon review of the Administrative
Record, stated that in 1982 the Federal Government (either EPA or
the Department of Health and Human Services) found the ground
water monitoring tor the Fulbright Landfill inadequate.
IE6 ReSDonse: The document referenced by the commenter from the
Administrative Record was written in 1982. The ground water
monitoring network in place in 1982 was. much less extensive than
that installed as part of the RIfFS. Although the earlier
network may have been usetul for screening, it was not, in EPA's
opinion, sufficient as the final ground water monitoring network
for the site. The network installed during the RIfFS is
sutficient to monitor ground water flow and contamina~t releases
from both landtills.
Comment: A commenter asked how EPA can state in the Proposed
Plan that no health-based criteria are being exceeded since
intormation published in 1982 correspondence trom EPA noted that
the levels tound ot chloroethylene (980 parts per billion) and
dichloroethylene (140 parts per billion) exceed health-based
criteria.
IE& Re.non.e: Soae ot the contaminant levels tound in earlier
s..pling of the landtills were not replicated in the RI sampling.
Althougb lov levels of contamination were tound in some of the
sample. collected during the RI, it is not expected that any
health-based criteria or standards would be exceeded at expected
or potential points ot use or exposure (i.e. the nearest drinking
.water wells).
3
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Commen~: A co..en~er s~a~ed, .referencing 1980 correspondence
found in the Adainistrative Record noting "terrible" leachate
probl... a~ the Pulbrigh~ Landfill, tha~ since percolation of
precipi~ation falling onto a landfill con~ributes ~o the
formation ot leachate, capping the landfills would se.. to be
ineffec~iv.~ The commenter added tha~ the landfills' location in
a floodplain a180 ..ke. capping ineffec~iv..
lEA Re.Donse: EPA aqree. with this comment regarding the
ineftec~ivene.. ot a cap for th..e landfill.. The Propo.ed Plan
did not reco..end a cap for .o.e of the.e ...e technical reasons.
Leachate .eeps ..y have been a probl.. at the landfills in the
pa.~. However during the course of the RIfFS leachate .eeps have
only occasionally been noted and tho.. which have been noted have
been ...11 and not heavily contaainated. EPA will require that
any leachate probl... which develop at either landfill be
addre.sed in the po.t-closure 80nitoring and ..intenance. At the
pre.ent time leachate does not appear to pos. a risk to human
health at either landfill.
Comment: A commenter stated, referencing March 1982
correspondence found in the Administrative Record regarding the.
Soil Conservation Survey, that "the Fulbrigh~ site was quite
extensive, encompassing an area larqer than that proposed for
sampling".
lEA ReSDonse: EPA agrees that. the landfills are relatively
large, although fairly typical for landfill sites (approximately
212 acres for both landfills). Geophysical investigations were
used to confirm the dimensions of the landfills. In EPA's
opinion the sampling and analyses conducted under the RI was
sufficient to evaluate potential endangerm~nt associated with
both landfills. Any plan referred to in the above referenced
document was not what was proposed or implemented during the
RIfFS.
Comment: A commenter asked, referencing correspondence found in
the Administrative Record from an engineering firm regardinq the
n.ed for worker protection when working on the site, how the
landfill. can be safe if such protection was required?
IE6 ResDen..: EPA has acknowledged that industrial wastes, some
of which probably contain hazardous .ub.~ance., are s~ill in the
landfill.. Although the levels of con~aaination curren~ly being
released in~o qround and surface wa~er are very low and currently
po.. no ~r.at to health or the environment, personnel protection
was warranted in the instance of the activity discussed by that
corre.POndence. Activities which have the potential ~o penetrate
area. of was~e dispo.al, such a. the excavation for the
con.~ruction of the new wastewater treatment plant adjacent to
the Sac River Landfill or the drilling of monitoring wells in the
RIfFS, warrant monitoring and protection of onsita personnel
because of the much greater potential for contaminant releases
and exposures associated with those specific, high-risk
4
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activities. Such levels o~ BCnitoring and protection would not
be needed ~or .ost onsite activities; such as just walking across
the land~lll surfaces, unl..s the landfills have been opened up
exposing the wastes c:Usposed.
.
Comment: A camaenter asked whether or not the landfills were
atill listed by EPA as potential uncontrolled sites.
IE& Resoonse: Both landfills indeed continue to be listed as
potential uncontrolled sites. This i. essentially a working list
of all site. on which EPA or the State are addressing or may
address under its Superfund prograa. Generally aites are not
removed fro. this list even after it has been determined that
they pose no threat to health or the environment. However, a
site's status on the list ..y be chanqed to reflect current
conditions relating to endangerment.
Comment: A commenter asked whether it was justified to have
allowed the City to reduce the area of the ground water use
survey to 1.0 mile.
IE& Resoonse: Ground water use surveys are generally site-
specific based upon the hydrogeologic conditions of a particular
site. The area surveyed for the landfills was generally about
one mile on either. side of the river adjacent to the landfills.
Given the hydrogeoloqysetting of this site, the area surveyed is
judged to be appropriate.
Comment: A commenter stated that a review of the Administrative
Record noted a document between EPA and a consultant for the City
which requested that higher than no~l, or appropriate,
detection limits be allowed on the water samples collected in the
~. .
lEA Resoonse: This correspondence reflects an effort on the part
of one of the City's consultants to persuade EPA to accept higher
detection limits on samples collected. EPA approval of the RI
work was contingent upon the lower detection limits generally
associated with drinking water supplies. By adhering to the more
rigorous detectio~ li.its, EPA thereby assured protection of
health and-the environment.
Comment: A commenter noted the apparent discrepancy in .EPA's
. position of saying that ground water .onitoring and deed
restrictions were warranted, while also saying that the sites did
not po.e a threat to the cOJllJlUni ty. The commenter asked how EPA
expects the community to deal with this apparent discrepancy.
lEA Resoonse: EPA's position reflects its assessment of the risk
associated with potential direct contact exposures associated
with opening either landfill "and reexposing the potentially
contaminated wastes previously dispQsed. Such activities would
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create a potential for direct contact exposures which are
otherwi.e abaent. Opening either landfill also increases the
potential for cont..inant releases when the soil cover is removed 0
Ground and surface, wat8r .onitorinq are required to assure
contaJIinant levels do not at s01le tiJIe exceed acceptable levels,
and also poat-closure care to ensure the integrity of the covero
Comment: A co..enter requested that the public comment period of
21 days be extended to allow .01le of the owners of nearby
property who had not known o'f the __ting to review the record on
the landfills aDd be able to co_ent.
lEa Resoonse: A8 pr8Vioualy 81:ated, the Hational Contingency
Plan (HCP) requires a ..ini1l\Dl 21-day comment period. In response
to so.e of the c~ents received during the public .eeting, EPA
has conducted a door-to-door survey of residents in the area.
Many of the residents were aware of the RI/FS which had been
conducted on the Fulbright/Sac ai¥8r Landfills. Hone of the
residents interviewed expressed seriaus reservations regarding
. the actions rec0888nded by EM in the .Proposed Plan. EPA
believes the comments received to da~ are representative of the
community's concerns about the site. An extension of the comment
period would not result in the rai.i~ of additional technical
issues that would impact the selected response activities. The'
actions recommended for the la~ill. will not be implemented
before December 1988. Any c~ts received from the public will
be evaluated by EPA in terDS of recommended changes in the
remedial actions.
Comment: Several commenters stated 1:!a1: "tae notice on the pub 1 ic
meeting was inadequate and t!aa~ Dany_"'-'" of nearby property
did not know of the meeting.
lEA ReSDonse: Local media and tbe Ci~ anA State government were
advised of the public meeting. Jfctu. :of the public meeting was
sent to individuals on EPA's maili~q .listy which included
individual's -who tmd px-."i~sly ~~~.~ .. interest in the site.
EPA believes that the estimated 40 peaple ~o did attend the
meeting provided substantive camments zepresentative of the
community at large.
Comment: A ccmaenter asked how'1IUIf or 'tb8 private drinking
water well. in the area were sampl-e4 4urillg the RI.
lEA Resl)OD8.: All of the 1Ioni tari'DIJ ~118 on or adj acent to the
landfill. v.re ...pled in the RZ. 'J!a8 only drinking water well
sampled was the ..11 at the new vast-c.r treatment plant next
to the Sac .River Landfill. A _1.1 U88d as an alternate, or
suppl..ental, source of City drinking ..ter upqradient of the
Fulbright Landfill, is routinely sampled under the drinking water
proqraJI. Sine. the hydrogeology ot 'the area indicated none of
the private drinking water wells in ~ general vicinity of the
site were at risk of contamination by ~e landfills, none were
sampled as part of this RI/FS.
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..
Co~ent: Several commenters asked why alternate water supplies
were provided to residents in the North U Drive area.
lEA Resoon.e: Sampling of private wells in the North U Drive
area revealed many of those wells to be contaminated with
organic, petroleum-based contaminants not found in the landfill
analYtical-results. EPA has used the Superfund Response Fund to
provide the municipal drinking water to homes in which private
veIl. had been cont..inated. Thi. va. done as part of a separate
Superfund .ite, the North U Drive .ite. The hydrogeologic and
ch_ical data on vater ...ple. fro. North U Drive and from the
Fulbright/sac River Landfill., indicate that neither landfill is
a source of the contaainants found in those veIls.
.
Comment: A commenter asked hov 8Uch it cost to sample and
analyze vater saaples from drinking vater veIls, hov much it cost
to do this RI/FS, and vhether or not this money vould not have
been better spent sampling all drinking vater veIls in the area.
lEA ReSDonse: Analyses of water samples for drinking water
detection limits for hazardous substances generally costs from
$1500-2000 each. The City estimates that the RI/FS cost
$1,100,000. The objectives of this RI/FS were to identify
contaminant releases and potential endangerment associated with
the landfills. Since the hydrogeology of the sites, and the very
low levels of contaminants found in the ground and surface water
lead EPA to conclude ~at no drinking water wells .re.at risk of
contamination, EPA did not require that any of the private
drinking wells be sampled as part. of the Fulbright and Sac River
RI/FS.
Comment: A commenter noted that many of the private drinking
water wells in the area are poorly cased or constructed, which.
can allow contaminants to flow down along the well casing into
the aquifer from which water for drinking is withdrawn. The
commenter asked if these wells should not be tested for
contamination.
lEA ReSDonse: It would probably be worthwhile to sample and
analyze water fro. these wells for contamination for
contaJIin.~ion by sources other than the landfills. However, data
from the RI/FS indicates that no drinking water wells are at risk
of contaa1nation by the landfills. It vas therefore not
nece.sary to s..ple these veIls in order to evaluate endangerment
associated with releases from the landfills. However, in order
to be responsive to the community and to attempt to identify
other (than the landfills) sources of ground vater contaJIination
in the area, EPA will assure that some high risk wells be tested
for contamination.
Comment: A commenter pointed out an apparent discrepancy in the
FS and the Proposed Plan. ~e commenter stated the FS states
that no private wells were sampled in the RI/FS and the~Proposed
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Plan states that no private wells are contaminated.
lEi ResDonse: No private wells were found at risk ot
contaaination in the RI/FS trom the landfills. Therefore none
were s..plad in th. RI/FS. No private wells were found to be
contaainatad by the landfills, because none were sampled. EPA
has aqre8dto assure that some of these wells will be tested for
contaaination, even though they are not believed to be at risk of
contaaination by releases fro. the landfills.
Comment: A co_enter asked why the wast.s in the cyanide pit had
not been r..oved for oftsite disposal.
lEa ResDonse:' Disposal of wastes in the cyanide pit ceased
approxiaately 20 years ago. Ground water monitoring wells were
placed through the cyanide pit (as best as it could be located)
and downgradient of the Pit. Ch_ical analyses of water. samples
fro. those wells did not reveal siqniticant lavels of
contamination. It is likely that the more soluble hazardous
substances have already been released from the area via shallow
ground water to the adjacent river. The analYtical data from the
RI did not support the need for waste removal at the Cyanide Pit.
Comment: Several commenters asked what kind of site use
restrictions would be sought for the landfills, and for
properties i~ediately adjacent to the lan~fi~ls.
lEA ReSDonse: For the properties on which the landfills are
located~ EPA will seek deed restrictions which would prohibit
activities which would siqnificantly increase the risk of direct
contact exposures or the potential for siqnificantly increased
contamination of ground or surface water. The following types of
land uses would be prohibited or monitored:
1. The drilling of wells through or very near wastes for the
consumption of water, or in a manner which could create an avenue
of contaminant release into the bedrock aquifers.
2. Construction activities which would require excavation into
areas of waste fill.
3. Th. construction of buildings or structures over waste fill
which would have the potential tor settling, and where settling
of such surface structure might create safety or structural
hazard.. .
4. The development of surface land for residential (homes) or
recreational u... (parks) without adequate sampling and analyses
ot surtace soil. to assure no siqniticant increase in potential
direct contact exposures to contaminated surface soils.
certain of the above would not necessarily always be
prohibited. However, EPA would seek to assure that no
unacceptable endangerment resulted. For example, wastes were
safely excavated and redisposed tor the construction of the new
wastewater treatment plant next to the Sac River Landfill. Other.
types of similar construction .ight also be deemed safe, but only
it the appropriate monitorinq and personnel protection is
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'"
provided.
At this time EPA does not believe deed restrictions for the
adjacent properties surrounding the landfills are necessary. The
EPA would reeo_end that any use of ground water downgradient and
near the landfills first require that the well water to be
sampled and analyzed to assure contaainants above relevant
standards or criteria are not exceeded. At this time there is no
inforaation indicating a change in ground water uses.
"
~
Comment: A co..enter asked what type. of hazards are associated
with leachate ~eeps.
lEA Rescons.: Generally the leachate which develops and surfaces
fro. a landfill ..y be corrosive or toxic upon direct contact
exposures. 'Corrosive leachate could burn the skin contacted.
Skin rashes .ight result fro. leachate containing high levels of
organic contaainants. However, the leachate found at these
landfills has been found to contain only low levels of
contamination. If the leachate were to somehow be accidentally
ingested (an extremely unlikely occurrence), short-term
gastrointestinal adverse effects (i.e., upset stomach, nausea,
etc.) could result. If a sufficient quantity of the leachate.
were to be ingested, toxic, systemic effects could theoretically
result. In addition the volume of the leachate surfacing as
seeps has so far (during the RIfFS) been minimal. Contact with
leachate is generally not intensive enough or frequent enough to .
. make carcinogenic (i.e. cancer) effects a concern, even if the
leachate contains potential carcinogens.
Comment: A commenter asked whether or not the sinkhole
containing drum remnants was on City property.
lEA Resconse: The
not in the part of
disposed. Most of
The sinkhole is on
sinkhole is on City property, although this is
the landfill where most of the wastes were
the wastes were disposed in the floodplain.
the bluff above the floodplain.
Comment: A co_enter asked if there was not a well, used by the
city for drinking water, located near the Fulbright Landfill.
IE6 ReSDOn.e: The City doe. have a deep bedrock well located
near Fulbright Spring, approxi.ately 1,600 feet south
(upgradient) of the Fulbright Landfill. The well i. used as a
supplemental (only w~en additionalwatar is needad) .ource of
.unicip.l drinking water. The direction of ground water flow is
from the well toward the landfill.. In addition the vertical
gradient from the surface to the deep bedrock aquifer is either
up, or at laast absent. Because of the.e factors, this well is
not at any significant risk of the contamination by releases from
either landfill. This results in little or no risk of
contamination of the drinking water supply by releases from the
landfills.
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C~en~: Several comaen~ers had que.~ion. regarding ~e No~ U
Drive .i~e. While ou~.ide ot ~e scope ot ~e Fulbright/Sac
River Landtill RI/PS, EPA and ~e S~a~e, ~e lead agency on ~e
North U Drive .i~e, responded to a number ot ~ese inquiries.
One c0888ft~er noted ~at a varie~y ot contaminants had been tound
in ~e private wells in ~e North U Drive area and ~at a variety
ot cont..inan~. have also been tound in ~e monitoring wells at
the landtill.. 'The co..enter a.ked it it is ju.t a coincidence
that both .et. of wells had a varie~y ot contaainants, or are ~e
landtill. actually .uspected contaainan~ .ource. ot the
contaaina~ion ot the North U Drive.
Il& ReSDonse: Although a nWlber ot cont_inan~. were tound in
both .ets ot well., the type. ot contaainants pre.ent in ~e
8Onitoring well. tor ~e landtill. did not aatch the contaminants
tound in the private well. at North U Drive. Thi. lead. EPA to
.u.pect cont_inan~ .ource. o~er ~an the landtills tor ~e
problema a~ ~e North U Drive site. The direction ot ground
water tlow and ~e hydroqeoloqic setting ot ~e landtills
reintorce EPA's determination ~at ~e landtills are not ~e
source ot contaminants in ~ose drinking water wells.
Comment: A commenter wanted to know it ~e source(s) of
contamination at ~e North U Drive site would be identitied.
lEA ReSDonse: A separate RI/FS is planned tor ~e North U Drive
site. The State has been the lead agency on ~at site. That
RI/FS will attempt to identity and characterize ~e sources of
~e contamination in those private wells. .
Comment: One comaenter noted ~at ~e samples collected from the
landtills during ~e RI/FS were only analyzed tor chemicals on
EPA's list ot priority pollutants or hazardous substances. The
commenter asked it it was not possible tor other contaminants,
no~ analyzed tor in ~e RI/FS, to be escaping trom ~e landfills.
lEA ResDonse: It i. correct ~a~ ~e sample. collected in ~e
RIIFS only analyzed for hazardous sub.tance li.t chemicals
(-HSL8-). Thi. i. .~dard tor an RI/PS unle.. there i. some
.pecific rea.on to.. .u.pect a ch..ical which i. not an HSL was
dispo.ed of at the .ite. There would be thousand. of chemicals,
both natural and 8AD-aade, which could theoretically be present
in the wa.te. dispo.ed in the landfill. and released from the
site. In order to .easure compounds at .eaningful detection
. li.its, analytical standards are needed by ~e analyzing
laboratory. Since only a given number of standards are
available, labora~ories can really analyze for a given number of
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..
contaminants. Contaainant. can be added in special circumstances
wh.re specific knowledge of their presence warrants.
In general analyse. performed in an RIfFS are limited to
HSLs. BSL8 "ere selected as the most toxic, persistent and
mobile coapounds. Even though analytical laboratories can not
conclusively identify compounds which are not HSLs, laboratories
do "tentatively identify" other compounds. Tentatively
identified coapounds are those whose cbromatoqrapbic peak
(analytical .ethod) is .bilar to another compound. The compound
i. thus "tentatively" identified. Potentially .iqnificant levels
of tentatively identified compound. were not reported in the
.aaple analyse. under this RIfFS.
.
Comment: A co_enter asked what could cause a change in the
vertical qradient.
lEA ReSDonse: If water is .oving frOll the surface down, a
downward vertical gradient is said to exist. . If qround water
would flow upward, sucb as under artesian conditions, the
vertical gradient is upward. The absence of a downward vertical
gradient contributes to the absence of current endangerment at
the landfills. In some areas the vertical qradient is even
upward. In terms of natural forces the only event that could be
identified which might change the vertical qradient would be a
large area-wide earthquake, altering or increasing the fracturing
of bedrock. The withdrawal of very larqe quantities of ground
water from the deep bedrock aquifer very near the site could
.. create a downward gradient. Ground water withdrawal will be
tracked closely during the post-closure monitoring for the
landfills.
Comment: A commenter suggested that the United States Geologic
Survey (USGS) model be used' to evaluate post-closure monitoring
data for the landfills.
lEA Re$Donse: The USGS paper, wbicb pertains to the potential
for additional deep bedrock qround water withdrawals to create a
downward vertical gradient, and which generated this comment, is
not yet published or available for review. When the document is
releasec:t, SPA intends to u.e the USGS model in review of post-
closure lIOni toriDCJ., ~t the .i te.
Comment: One co_enter asked wby waste excavation was allowed
for the construction of the new wastewater treatment plant next
to the Sac. River Landfill, and. if this kind of activity is to be
prevented in deed restrictions for the landfills.
IE& ReSDonse: The waste excavation for the treatment plant
construction was carefully monitored. Onsite workers were not
exposed to toxic levels of contamination. The wastes exposed
were found to be nontoxic and were safely redisposed in another
part of the landfill. Any future excavatiort would require
~
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~--
simiiar precautions.
Hazardous \J
Information
US EP A Regi«
Philadelphia.
change ---/
after.
Comment: A commenter asked whether or not there was any
in ground vater contaminant concentrations before versus
the construction of the new wastewater treatment plant.
lEA ReSDonse: All of the samples for the RI/FS were collected
after the construction of the plant. Contaminant levels in these
wells before the plant construction are not known.
Comment: A number of commenters asked why their drinking water
well had not been sampled during the RI.
lEA ReSDonse: Review of the hydroq.eoloqic setting and data
during.the RI indicated none of the private drinking water wells
were at risk of contamination by releases from the landfills.
Comment: A commenter asked, on behalf of a number of the
citizens present at the public meeting, how the scope of this
RI/FS could be expanded to include sampling of the private
drinking water wells in the area' for contamination.
IE6 ReSDonse: Review of the hydroqeoloqic data from the RI/FS
determined that none of these wells are at risk of contamination
by releases from the landfills. The very low contaminant levels
in onsite ~onitoring wells further reduced the potential for'
contamination of any drinking water wells, even if flow would
have been from the landfills toward such wells. However, in
order to be responsive to the needs of the community, EPA will
assure that private wells in the area be sampled and analyzed for
contamination. Such sampling will be outside the scope of this
RI/FS. However, EPA will review all such data generated to
determine if assessments of potential endangerment at
Fulbright/Sac River Landfills should be reassessed.
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