United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-90/044
September 1990
Superfund
Record of Decision:
Wheeling Disposal Service, MO
-------
50272-101
REPORT DOCUMENTATION 1" REPORT NO. 2. 3. Reclpient'l Aceo..l..... No. ~
PAGE EPA/ROD/R07-90/044
4. T1t8 end Subtl1le 5. Report Dala
SUPERFUND RECORD OF DECISION 09/27/90
Wheeling Disposal Service, MO
First Remedial Action Final 6.
-
7. Authorial 8. Performing Organization Repl No.
8. Performing Orgalnlzadon Name and Add..... 10. ProjectITaakiWork Unil No.
11. Contrac"C) or Gunl(G) No.
(C)
(G)
12. Sponaoring Organization Name and Addre.. 13. Type 01 Report' Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washingtonr D.C. 20460 14.
15. Supplementary Notea
18. Ab8"act (Umlt: 200 worda)
The 200-acre Wheeling Disposal Service site is an inactive industrial and sanitary
landfill in Amazonia, Missouri. Onsite disposal features include nine solid waste
trenches, five liquid waste trenches, two evaporation ponds, a farm chemical a rea, three
tannery waste areas, and a rinsed- container area. Surrounding land use is mixed
residential and agricultural. From 1964 until the landfill was closed in 1986,
municipal and industrial wastes, including tanning sludges, pesticides, asbestos,
laboratory wastes, construction debris, paint sludges, battery and cyanide waste, and
crushed drums were disposed of in the various onsite disposal units. EPA and the State
conducted onsite and offsite investigations from 1980 to 1987 that identified the
presence of onsite contamination with no evidence of offsite contaminant migration. The
remedial investigation/ feasibility study conducted in 1989 and 1990 confirmed these
results. This Record of Decision (ROD) addresses both source control and management of
contaminant migration, and is a final remedy. The primary contaminants of concern
affecting the soil, sediment, ground water, and surface water are VOCs including TCE and
toluene; other organics including pesticides; and metals including arsenic, chromium,
and lead.
(See Attached Page)
17. Document Analyai. .. Deac:ripto..
Record of Decision - Wheeling Disposal Service, MO
First Remedial Action - Final
Contaminated Media: soil, sedimen t, gw, sw
Key Contaminants: VOCs (TCE, toluene), other organics (pesticides), metals (arsenic,
chromium, lead)
b. Id8ntlfter8lOpan-EncI8d T-
Co COSA n FI8IdIGroup
18. Avlit8bllty Sl8Iemant 19. Security Cia.. (Thl. Report) 21. No. of Page.
None 81 -
20. Security Cia.. (Thl. Page, 22. Price
Non I'>
(.'If'
(See ANSl-Z39.18)
See InelrucUone on Reve,..
(Formerly NTlSo3S)
Dapartm8ntofCornmerce
-------
EPA/ROD/R07-90/044
Wheeling Disposal Service, MO
First Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes upgrading the existing landfill cap
with a revegetated clay and soil cover; monitoring onsite ground and surface water;
abandoning onsite wells; and implementing institutional controls including deed
restrictions, and site access restrictions such as fencing. The estimated present worth
cost for this remedial action is $1,205,800, which includes an annual O&M cost of $42,000
for 30 years.
PERFORMANCE STANDARDS OR GOALS: Performance criteria for ground water and surface water
wil~ be developed, and may be based on Federal MCLs or Ambient Water Quality Criteria, or
State water quality standards. If contaminant levels exceed these criteria, ground water
treatment and/or leachate collection and treatment may be required.
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RECORD OF DECISION
DECLARATION
WHEELING DISPOSAL SERVICE COMPANY LANDFILL
AMAZONIA, MISSOURI
Prepared by:
U.s. Environmental Protection Aqency
Reqion VII
Kansas City, Kansas
SEPTEMBER 1990
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Wheeling Disposal Service Company Landfill
Amazonia, Missouri
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Wheeling Disposal Service Company Landfill (the site)
near Amazonia, Missouri, chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Contingency Plan, 40 C.F.R. Part 300.
This decision is based on the Administrative Record file for this
site.
The State of Missouri concurs on the selected remedy. A
letter from the State of Missouri stating its concurrence is
included in this Record of Decision (ROD) package.
ASSESSMENT OF THE SITE
The site is a closed industrial and sanitary waste landfill
which received approximately 81,000 cubic yards of industrial
waste between 1975 and 1986. The principal threat posed by the
site is associated with exposure to the hazardous substances
contained in the wastes which were disposed in the onsite
disposal units. Due to the principal threat, several secondary
threats exist onsite in the form of contaminated ground water and
surface water. Several seeps located onsite in a north ravine
and the shallow onsite ground water are contaminated with
hazardous substances, primarily volatile organic compounds such
as trichloroethylene and carbon tetrachloride.
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The selected remedy is intended to be a final remedial
action for the site and, subsequently, addresses all
contamination associated with the site. The major components of
the selected remedy include:
Upgrading the existing cover over the disposal units;
-------
Long-term monitoring of ground water and surface water;
Implementing site maintenance activities;
using deed restrictions to prevent farming on certain
areas onsite;
Installing security measures such as warning signs
and/or fences; and,
Closing certain onsite wells.
These response actions would minimize future
ingestion/dermal contact of hazardous substances by containing
and monitoring the onsite, contaminated ground water and surface
water, and by maintaining an effective cover over the disposal
units.
Although not required initially, contingencies for future
collection and treatment of contaminated surface water and/or
ground water are provided for in the selected remedy if
performance criteria are exceeded at designated points of
compliance.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective.
The EPA emphasizes the statutory preference for permanent
solutions and use of treatment technologies. This approach
emphasizes solutions that can ensure reliable protection over
time. However, the approach is tempered by practicability to
ensure that remedies selected are appropriate. Further, this
process considers the full range of factors pertinent to remedy
selection and provides the flexibility necessary and appropriate
to ensure that remedial actions selected are sensible, reliable
solutions for identified site problems.
This remedy utilizes permanent solutions and alternative
treatment technologies, to the maximum extent practicable for
this site. However, because treatment of the hazardous
substances was not found to be practicable, this remedy does not
satisfy the statutory preference for treatment as a principal
element. Although treatment is not being selected, the selected
remedy activities do effectively reduce hazards. The site
hydrogeology consists in part of a loess/drift interface that
acts to control the migration of leachate from the disposal
areas. Thus, the migration of hazardous substances is limited
-------
and can be effectively monitored to protect human health and the
environment. Upgrading and maintaining the cover in combination
with site security measures minimizes the formation and migration
of leachate, and prevents direct exposures to buried wastes.
Because this remedy will result in hazardous substances
remaining onsite above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate
protection to human health and the environment.
/ /JJ~;?/ / f:r
Morris It
R~gional Administrator
Environmental Protection Agency, Region VII
9'-2-7-70
Date
-------
11"15"99 16:22
Z 3147517869 ~O OH~-ijR5TE MGT
92
JOHN ASIICAOFT
c.c-
/)i >4tiW1 ol EnelJlY
1)1..'" '" 5rmro''''''fI&aI QuaJif)'
DmaiOfl d ('''(!ICIlY Ind WId 5u1'~y
[)j~~on or MII\I~IMI\I ~Ct,
DlYI.,.," of ""'., R~_lInr..
al'ld lI~o~ "",......Ii,,"
G. 'T"RAC" MtiHAN 111
OCtober 19, 1990
~iAn: OF MISSOURI
DEPARTMENT OF NA11.JRAL RESOURCES
omes OF mE DIRECTOR
P.o. eo. I"
Jd"cnon CItY, M06'IO%
31~.751-44ZZ
00---
Mr. MOrris 1C.ay
Regional Administrator
u. S. Environmental Protection
Agency, Region V:1
726 M!nnoccta AV8nue
Kansas City, KS 66101
Dear Mr. Kay:
The ~issouri DepartMent of Nat~ral Resources t~~) ha5 reviewed
the Proposed Pl~n for the WhoQling D1cposal Superfund site in
Amazonia, Missou~i. The Department concurs w1t~ the U. S.
znv1ror~ental Protection Agency'c (USEP~) preferred alternatives
of closi~q certain on-site wells, installing security warning
signs, see~inw deed re~trict~ons to prevent farming, up~ra~lng
the existln; cover over the dis~csal areas, and be91nn1~9 long
term mcn1torln~ of groundwater ~nd surface water.
Ba,ed en current aval1abl~ informotion, the Wheeling tispo8al
site has no~ contaminated groundwater offsite. Therefo~e, the
proposea plan meet~ US~PA's identified objective to: "El~inate
current .n4 prevent future unacceptable exposures to
groundwater, 8urface water, surface soils and sediments, and
subsurface 5011.". Should future offslte contamination exist
MDNR would require that the propose~ plan be modified to address
the probler.t.
If you have any queltion~ regarding thi~ matter, please co not
hesitate .to contact me.
Very tru11 yours,
DEPARTMZN't or N~TUV.L usouact:s
onlt1r:ow. SIGNID Wi
RON KUC£nA
G. Tracy Mehan, II:
Directol'
G'1'K:rgb
ecs
Mr. RO~.l't Mor~y, USEPA
-------
RECORD OF DECISION
DECISION SUMMARY
WHEELING DISPOSAL SERVICE COMPANY LANDFILL
AMAZONIA, MISSOURI
Prepared by:
U.s. Environmental protection Aqency
Reqion VII
Kansas City, Kansas
SEPTEMBER 1990
-------
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
TABLE OF CONTENTS
SECTION
PAGE
SITE NAME, LOCATION, AND DESCRIPTION
1
SITE HISTORY AND ENFORCEMENT ACTIVITIES
1
HIGHLIGHTS OF COMMUNITY PARTICIPATION
7
SCOPE OF RESPONSE ACTION
8
SUMMARY OF SITE CHARACTERISTICS
8
SUMMARY OF SITE RISKS
30
DESCRIPTION OF ALTERNATIVES
36
SUMMARY OF THE COMPARATIVE ANALYSIS OF
ALTERNATIVES
40
THE SELECTED REMEDY
43
STATUTORY DETERMINATIONS
44
APPENDIX A - SUMMARY OF CARCINOGENIC AND
NON-CARCINOGENIC TOXICITY VALUES
48
APPENDIX B - SUMMARY OF SITE RISKS FOR ALL SCENARIOS
50
APPENDIX C - CONTAMINANT SPECIFIC ARRARS
58
RESPONSIVENESS SUMMARY
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FIGURE 1.
FIGURE 2.
FIGURE 3.
FIGURE 4.
FIGURE 5.
FIGURE 6.
FIGURE 7.
FIGURE 8.
FIGURE 9.
FIGURE 10.
FIGURE 11.
LIST OF FIGURES
PAGE
SITE LOCATION MAP
2
SITE LOCATION MAP
3
SITE DISPOSAL UNITS
4
BURIED BEDROCK VALLEY
10
BORING/MONITORING WELL LOCATIONS
13
GENERALIZED GEOLOGIC PROFILE
14
POTENTIOMETRIC SURFACE MAP FOR UPPER
GLACIAL DRIFT, AUGUST 1989
15
SURFACE AND SEEP WATER AND SEDIMENT
SAMPLING LOCATIONS
21
SURFACE SOIL AND DISCRETE SUBSURFACE
SAMPLING LOCATIONS
22
CONTINGENT PHASE SURFACE SOIL SAMPLING
LOCATIONS - DISPOSAL UNITS
23
CONTINGENT PHASE SEDIMENT SAMPLING
LOCATIONS - SOUTH RAVINE
24
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TABLE 1.
TABLE 2.
TABLE 3.
TABLE 4.
TABLE 5.
TABLE 6.
TABLE 7.
TABLE 8.
LIST OP TABLES
SUMMARY OF ORGANIC CONSTITUENTS DETECTED
IN SURFACE SOILS AND SEDIMENTS
SUMMARY OF METAL CONSTITUENTS DETECTED
IN SURFACE SOILS AND SEDIMENTS
SUMMARY OF ORGANIC CONSTITUENTS DETECTED
IN GROUND WATER
SUMMARY OF METAL CONSTITUENTS DETECTED
IN GROUND WATER
SUMMARY OF ORGANIC CONSTITUENTS DETECTED
IN SURFACE WATER
SUMMARY OF METAL CONSTITUENTS DETECTED
IN SURFACE WATER
SUMMARY OF MAXIMUM CONCENTRATIONS FOR THE
INDICATOR CHEMICALS BY MEDIA TYPE
KEY ENDANGERMENT ASSESSMENT RESULTS
PAGE
19
20
25
26
28
29
31
34
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SECTION 1.0
SITE NAME. LOCATION. AND DESCRIPTION
The Wheeling Disposal Service Company Landfill site (site)
is located in a rural setting near Amazonia, Missouri (population
314), approximately six miles north of st. Joseph, Missouri
(population 76,691) and six miles southwest of Savannah, Missouri
(population 4,158) (Figure 1). The property is owned by Wheeling
Disposal Service, Inc. (Wheeling), st. Joseph, Missouri, and
consists of two contiguous parcels of land covering approximately
200 acres (Figure 2).
The site is situated in bluffs approximately 1/4 to 1/2 mile
east of the Missouri River floodplain. The site is located on a
topographic divide with surface runoff flowing both to the north
and to the south. The runoff leaving the site to the north flows
into Mace Creek via an unnamed tributary. The runoff from the
southern part of the site flows into an unnamed tributary of
Dillon Creek which then flows into Mace Creek. Mace Creek
eventually flows into the Missouri River two miles south of the
site.
Several private residences are located within a one-mile
radius of the site. Most of these residences have private wells.
Two residences located approximately 1/4 mile west of the site
and the city of Amazonia receive their drinking water from a
water supply district originating in st. Joseph. Also, the City
of Savannah uses a well in the Missouri River alluvium located
approximately one mile northwest of the site for supplying part
of Savannah's public drinking water supply.
The site, formerly an industrial and sanitary landfill,
consists of nine (9) solid waste trenches, five (5) liquid waste
trenches, two (2) evaporation ponds, a farm chemicals area, three
tannery waste disposal areas, and a rinsed container area
(see Figure 3).
SECTION 2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1
Site Historv
Wheeling operated a sanitary and industrial landfill from a
period in the 1970s until it was closed in 1986. In 1975, the
Missouri Department of Natural Resources (MDNR) issued a permit
limiting industrial waste disposal to a ten acre area in the
central portion of the site. Information available to the
Environmental Protection Agency (EPA) indicates that the
following wastes were disposed during the period of Wheeling's
operation:
Leather tanning sludges;
Pesticides;
Asbestos;
Laboratory wastes;
Building debris;
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Paint sludges;
Battery wastes (flashlight batteries) ;
cyanide wastes;
Neutralized pickle liquor; and,
Miscellaneous crushed drums.
These wastes were disposed in the various disposal units
indicated on Figure 3. Certain disposal units received only one
type of waste, such as tannery sludge, while other areas received
a combination of wastes.
The facility ceased operating from June 1980 until September
1981. In September 1981, the facility reopened under conditions
of two new permits issued by MDNR. One permit was for the
industrial waste disposal and the other was for operation of a
sanitary landfill. The sanitary permit was subsequently revoked.
The facility continued receiving industrial wastes until 1986.
Closure activities undertaken by Wheeling included filling,
grading, recontouring and capping of the former waste disposal
area. An inspection by MDNR in 1986 indicated that the landfill
had not received any wastes for some time. A site visit by EPA
in May 1987 confirmed that the site had been covered with soil,
graded, and no longer received wastes for disposal.
2.2
Previous Investiqations/Reports
Between 1973 and 1978, Wheeling installed onsite ground
water monitoring wells. MDNR performed periodic inspections at
the site beginning in 1975 and continuing through 1986.
Inspection reports cited a number of permit violations including
the failure to cover wastes with compacted earth after depositing
them in a waste trench, disposal of hazardous materials outside
of permitted areas, and improper construction of solid waste
trenches. Monitoring by MDNR at the site between 1976 and 1980
did not identify significant ground water contamination; however,
the analyses were limited primarily to metals.
In December 1980, a preliminary assessment and site
inspection were performed by Ecology and Environment, Inc. (E&E)
for the EPA. The report presented background information
concerning the site, including geology and hydrogeology. The
report concluded that there was no significant evidence of
leaching or offsite migration of contaminants, but noted the
potential for lateral seepage beneath the site. The site was
given a medium to high priority for further monitoring, based on
the active status of the landfill and because of the types of
wastes which had been disposed at the site.
The EPA sampled onsite ground water monitoring wells and
springs in November 1982. Analyses of these samples revealed
barium, manganese and arsenic existing at concentrations above
safe drinking water standards, and trace amounts of at least five'
organic compounds. The report concluded that there was no
5
-------
evidence of offsite migration of contaminants but recommended
further monitoring and inspections.
The EPA conducted a follow-up inspection of the site and
sampled onsite monitoring wells and springs and three offsite
private wells in November 1983. Concentrations of metals above
safe drinking water standards and twelve organic priority
pollutants were detected in onsite wells and springs. Priority
pollutants included 1,2 dichloroethane, trichloroethylene (TCE),
2-butanone, benzoic acid, chloroform, bis(2-ethylhexyl)
phthalate, bromodichloromethane, and chlorodibromomethane. Trace
amounts of organic compounds and concentrations of iron and
manganese above the safe drinking water standards were detected
in the samples from offsite private wells and springs. However,
there was no conclusive evidence of offsite migration. The
report recommended further periodic monitoring and inspections.
Roy F. Weston, Inc. prepared an Endangerment Assessment for
the EPA for the site in January 1985. The report reviewed
results and data from previous investigations and concluded that
while organic contamination existed in onsite wells and springs,
there was no evidence of offsite migration. As in the earlier
studies, continued monitoring was recommended because of the
potential for offsite transport of ground water contaminants.
The Missouri Department of Health (MDOH) performed sampling
of offsite private wells and creeks in the site vicinity in
January 1986. Results of the sampling indicated the presence of
aluminum, barium, iron, and manganese in the stream samples and
the presence of aluminum in samples from two of the private
wells. Levels of contaminants were not considered to pose a
significant health threat.
In response to complaints from local residents concerning
the possibility of contamination of drinking water supplies, the
EPA and MDOH sampled wells and springs in the site vicinity in
early 1987. Results confirmed earlier sampling events indicating
that onsite ground water is contaminated but is not migrating
offsite.
2.3
Enforcement History
On August 29, 1983, MDNR notified Wheeling that the site was
proposed for inclusion on the Registrv Q! Confirmed Abandoned or
Uncontrolled Hazardous Waste DisDosal sites in Missouri. The
Wheeling site was placed on the Reqistrv on January 3, 1984.
The EPA notified the owner and 39 generators of their
potential liability in a series of general notice and information
request letters dated either May 1987, september 1987, February
1988 or April 1988. On september 27,1989, EPA entered into a de
minimis administrative order on consent with three asbestos
generators. These parties agreed to pay past, Remedial
Investigation and Feasibility study (RI/FS), Remedial Design and
6
-------
Remedial Action (RI/RA), and Operation and Maintenance (O&M)
costs based on their volumetric share of wastes. with regard to
RD/RA and O&M costs, these parties also paid a premium of two.
Special notice letters were sent in April 1988 to
Potentially Responsible Parties (PRPs) requesting them to make a
good faith offer to perform the RI/FS. On August 24, 1989, five
generators and the owner entered into an Administrative Order on
Consent to perform the RI/FS.
SECTION 3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and Proposed Plan for the site were released to
the public on August 13, 1990. The Administrative Record file,
which included the RI/FS reports and the Proposed Plan, was made
available to the public at information repositories maintained at
the Rolling Hills Library, in Savannah, Missouri, and at the EPA
Region VII Superfund Records Center, Kansas City, Kansas. The
notice of availability for these documents was published in the
st. Joseph News-Press/Gazette and the Savannah Reporter on
August 12, 1990 and August 16, 1990, respectively. A public
comment period was held from August 13, 1990 through September
11, 1990. In addition, a public meeting was held on August 29,
1990. At this meeting, representatives from the EPA and MDNR
answered questions about problems at the site and the remedial
alternatives under consideration. A response to the comments
received during this period is included in the Responsiveness
Summary, which is part of this Record of Decision. In summary,
the public participation requirements as defined in CERCLA
113(k) (2) (B) (i-v) and 117 were satisfied.
This decision document presents the selected remedial action
for the Wheeling Disposal Service Company Landfill site, near
Amazonia, Missouri, chosen in accordance with the provisions of
CERCLA, as amended by SARA and, to the extent practicable, the
National contingency Plan (NCP). The selection of a response
action for this site is based on the Administrative Record.
7
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SECTION 4.0
SCOPE OF RESPONSE ACTION
This Record of Decision addresses the principal and
secondary threats identified at the site, including contamination
found in ground water, surface water, surface soils and sediment,
and subsurface soils.
Although the site geology controls and highly limits
exposure to the principal and secondary threats, there is a
potential threat of contaminated ground water and surface water
extending offsite, as well as the potential for contact with
onsite contaminated soils and sediments. To address the risks
from such exposures, the following remedial action objective was
identified:
*
Eliminate current and prevent future unacceptable
exposures to ground water, surface water, surface soils
and sediments, and subsurface soils.
SECTION 5.0
SUMMARY OF SITE CHARACTERISTICS
The Remedial Investigation (RI) field work, conducted in two
phases by the PRPs under EPA oversight from February 1989 to
February 1990, included the following activities to define the
types of contaminants at the site, potential routes of
contaminant migration and routes of exposure, population and
environmental areas that could be affected, and site-specific
factors that may affect the remedial actions at the site:
A geologic and hydrogeologic investigation that included
the drilling of nine deep borings and six shallow
borings, the sampling of soil from the nine deep
borings, installation of fifteen monitoring wells in the
boreholes, and subsequent sampling of the ground water
from the fifteen new monitoring wells and nine
pre-existing wells;
Surface soil sampling primarily in areas of known
previous landfill activities as well as a background
surface soil sample;
Discrete subsurface soil sampling in areas of known
previous landfill activities, as well as a background
discrete subsurface soil sample;
Sediment sampling from locations within the northern and
southern ravines on the property and the onsite dry
pond;
Sampling from the seeps located in the northern ravines
of the site as well as a background surface water
sample;
8
-------
Characterization of the existing cover located over the
previous disposal units by observation and physical
analysis of the soil;
Private well survey to the east of the site in an effort
to determine the number of wells in use, distance of the
wells from the site, hydrogeological relation of wells
to the site, and physical characteristics of the wells;
and,
Surface water sampling along the property boundary in
the ravine located in the northern portion of the site.
Several types of contamination - volatile organic compounds
(VOCs), organic compounds (including pesticides), and metals -
were found during the RI in varying concentrations and in various
media including ground water, surface water, sediment, surface
soils and subsurface soils. The elevated concentrations of VOCs
in the ground water and surface water indicate a release of
chemicals from the original disposal areas. The elevated
concentrations of metals and pesticides in the surface soils
indicate either degradation of the cover or improper construction
of the cover. The following section presents the results and
conclusions of the RI.
Tables and diagrams presented in this section are either
derived in part or entirely duplicated from the RI report written
by Burns & McDonnell Engineering Company, contractor for the PRPs
who undertook the RIjFS.
5.1
HYDROGEOLOGIC SETTING
The regional geology has been developed from geologic
reports and boring logs obtained from the Missouri Geological
Survey. This data shows that the Amazonia, Missouri area is
underlain by, in descending order: unconsolidated deposits of
the Holocene and Pleistocene Series, Quaternary System; and
consolidated bedrock deposits of the Douglas Group, Virgillian
Series, Pennsylvanian System.
The surficial un.its consist of Holocene alluvium within the
Missouri River valley and Pleistocene loess and glacial drift in
the uplands to the east of the Missouri River valley. The
glacial drift consists predominantly of interbedded cohesive clay
layers, and granular sand and gravel layers. The glacial drift
is thickest over an east-west trending buried bedrock valley that
underlies the site (Figure 4).
The geology of the Wheeling Disposal site was characterized
based on the borings drilled during the 1989 Remedial
Investigation (RI) and information gathered during earlier site
investigation activities. This data has identified three
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stratigraphic units in descending order: loess, glacial drift,
and bedrock. These units are described in the following
subsections.
Loess
The loess is of Wisconsin-Illinoian age and
feet of clayey silt and silt which contains
sand. The loess is thickest on the central
wastes were disposed, and thinnest near the
around the periphery of the disposal areas.
permeability test results indicate that the
conducti~~ty of , the loess ranged from 1.0 x
2.6 x 10 cent1meters per second (cm/s).
Glacial Drift
consists of 4 to 35
minor amounts of
ridge where the
ravines located
Constant head
hydraulic
10-6 to
The loess is unconformably underlain by Pre-Illinoian aged
glacial drift. The glacial drift ranges from 48 to 155 feet
thick and is comprised of interbedded granular and cohesive
deposits. The drift is thickest within the deepest portion of
the bedrock valley located beneath the southern portion of the
site. The thickness of individual cohesive layers ranges from 2
to 10 feet. The thickness of individual granular layers ranges
from less than Qne foot to 22 feet. These sand and gravel layers
are thickest within the deepest portion of the buried bedrock
valley. Constant head permeability test results indicate that
the hYdr~~lic conductivity ~a the cohesive layers ranged from
6.7 x 10 cm/s to 6.1 x 10 cm/s. Slug test results
indicate that the hYd~~Ulic conductivity ~~ the granular layers
ranged from 1.38 x 10 cm/s to 5.45 x 10 cm/s.
Bedrock
The glacial drift is unconformably underlain by Pennsylvanian
aged bedrock. Shale belonging to the Lawrence Formation outcrops
in the unnamed tributary located along the northern boundary of
the site. The bedrock surface at this location is at
approximately 880 feet above the mean sea level elevation (msl)
which corresponds to the northern edge of the buried bedrock
valley. Shale and limestone bedrock was also encountered in four
of the borings drilled during the RI. The lowest elevation for
which the bedrock was encountered in the borings was 789 feet
msl. .
The regional hydrogeologic classification of the deposits
underlying the Amazonia, Missouri area can be generally
categorized into the Holocene alluvium aquifer, the Pleistocene
glacial drift water bearing unit, and the Pennsylvanian bedrock
aquitard.
The Holocene alluvium that occurs within the Missouri River
valley has been characterized as suitable for development as both
a potable and irrigation water supply source. The City of
Amazonia formerly used two wells screened in the alluvium for a
11
-------
potable water source. The City of Savannah, Missouri currently
uses a well screened in the alluvium as a potable water source.
This well is located approximately one mile northwest of the
site.
At some locations the Pleistocene glacial drift is
sufficiently transmissive to be characterized as suitable for
development as a potable water source (Missouri Geological
Survey, 1957). Ground water yields from this water-bearing unit
can be expected to range from 5 to 50 gallons per minute. The
higher yields are associated with the thick sand and gravel
deposits that occur within the buried bedrock channel. There are
records of six private water supply wells screened in the glacial
drift within one mile of the site. Only one well is currently
known to be used as a potable water source. In 1990, the MDNR
Division of Geology and Land Survey classified the geologic
system beneath the Wheeling Disposal Service site to be a useable
aquifer.
The Pennsylvanian age bedrock generally acts as an aquitard
due to the low transmissivity of these deposits and is not a
suitable source of potable water due to high salinity and
hardness of the ground water. The thick shale sequences within
the Pennsylvanian bedrock retards vertical ground water
migration.
During the RI, 23 wells on the Wheeling Disposal site were
monitored for ground water elevation (See Figure 5 for the
locations). These wells were installed in paired nests with one
well monitoring the top of the water table and the paired well
monitoring deeper ground water. These wells are screened in the
glacial drift and range from 33 to 174 feet deep.
One unconfined ground water system is present within the
shallow glacial drift. A prominent downward vertical gradient
averaging 0.7 feet/foot was measured in the shallow and deep
monitoring well nests. This indicates that the site is a source
of ground water recharge for the glacial drift.
Rainfall which percolates through the upper loess material
encounters the less permeable clays of the upper glacial drift.
The less permeable clays act as an aquitard. As a result, the
shallow ground water flows north on the north side of the site
and south on the south side of the site (See Figure 6). On the
north side, the shallow ground water surfaces in the north
ravines in the form of very low flowing seeps (1/2 gallon per
minute). On the south side, all of the shallow ground water
eventually migrates deeper into the glacial drift.
The ground water potentiometric surface within the upper
glacial drift as measured in August 1989 is presented in
Figure 7. The ground water flow direction within the upper
glacial drift is roughly perpendicular to the site topographic
contours with an average horizontal gradient of 0.06 feet/foot to.
the north and 0.045 feet/foot to the south.
12
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Assuming an average hydraulic conductivity of 3.5 x 10-5
cm/s for the upper glacial drift on the north portion of the
site, an average horizontal hydraulic gradient to the north of
0.06 feet/foot, and an effective porosity of 25 percent for the
glacial drift, the average horizontal ground water flow velocity
to the north would be nine feet per year (fi/yr). Assuming an
average hydraulic conductivity of 7.6 x 10- cm/sec for the upper
glacial drift on the south portion of the site, an average
horizontal hydraulic gradient of 0.045 feet/foot to the south,
and an effective porosity of 25 percent for the glacial drift,
the average horizontal ground water flow velocity to the south is
140 ft/yr.
Volatile Organic Compounds (VOCs) were detected in a seep in
the north ravine in 1983, eight years after onsite disposal
began. That seep is located approximately 380 feet from the
nearest disposal area indicating VOC contaminated ground water
may have traveled approximately 50 ft/yr. Thus, the actual
horizontal ground water flow velocity (50 ft/yr) is consistent
with EPA's theoretical estimate (9 to 140 ft/yr).
There are an insufficient number of deep wells to establish
ground water flow direction and rate within the deep glacial
drift deposits. However, the deep glacial drift ground water is
presumed to follow the contour of the bedrock (Figure 4). Thus,
the deep ground water should flow south from the north ravine
located onsite and east along the buried preglacial valley with
eventual discharge to the One Hundred and Two River. The
ultimate discharge point of the ground water and surface water at
the Wheeling Disposal site is the Missouri River or its alluvial
aquifer.
5.2
SOURCE CHARACTERISTICS
The closed landfill disposal units, past operating practices
and closure procedures are the sources for elevated levels of
contamination found at the site in the ground water, surface
water, surface soils, sediments and subsurface soils. Both
industrial and sanitary landfill units were used between 1964 and
1986. Information regarding the disposal units varies
dramatically in detail depending upon whether the unit was used
prior to 1975 or after 1975. As previously mentioned, the
records required by the permits and maintained by Wheeling
Disposal Service, Inc. and by MDNR document with great detail the
types, volume and locations of industrial waste disposed at the
site after 1975. Information regarding the volume of waste
received prior to 1975 does not exist. However, aerial
photographs and the permit application reports submitted by
Wheeling Disposal Service document the types and locations of the
pre-1975 disposal units.
16
-------
In addition, a magnetometer survey was conducted over the
area of pre-1975 solid waste trenches and the area containing
rinsed containers in an attempt to more clearly define the limits
of those areas. Large buried metallic objects would cause
anomalous magnetic field readings which would be detected during
the survey. No magnetic anomalies were present which indicated
disposal of metallic objects beyond the boundaries of the rinsed
container disposal area, the pre-1975 solid waste trenches or the
sanitary landfill as shown in Figure 3.
All disposal units (both pre-1975 and post-1975) were
constructed and closed using onsite soils and did not include
leachate collection systems. During the RI, the cover over the
disposal units was found to range from approximately two to five
feet in thickness. RI results indicate that the hygraulic
conductivity for the cover is approximately 1 x 10- cm/s.
However, inspections (both historic and recent) document the
tendency for the cover material to fracture and to quickly absorb
rainfall.
As defined in the NCP, the wastes that cannot be reliably
controlled in place are principal threats. At this site, wastes
disposed in the closed disposal units may be the principal threat
to human health and the environment. Hazardous substances
contained in these wastes potentially migrate in the various
media and produce secondary threats such as contaminated ground
water, surface water, and surface soils and sediment.
5.3
Contaminated Media
5.3.1
Subsurface Soil
Analytical results indicate the presence of VOCs, highly
mobile contaminants, in areas of previous landfilling activities.
Concentrations of methylene chloride at 180 parts per billion
(ppb) , and TCE at 20 ppb were detected in Boring 23D (refer to
Figure 5) at the 12 to 13 foot sampling interval. Boring 23D is
located immediately east of the liquid waste disposal trenches in
the central portion of the site. Neither of these contaminants
was encountered at greater depths in this boring. No other
subsurface soil data showed evidence of VOC contamination which
was attributable to the site.
Mercury and magnesium, inorganic contaminants which are
relatively immobile contaminants under conditions at this site,
were detected in borings 24D and 27D at 5.03 parts per million
(ppm) and 9570 ppm, respectively, above background levels.
Cyanide was detected in the bedrock boring 26D at the level of
1.77 ppm, slightly above the detection limit. Mercury and
cyanide were not detected above background levels (0.19 ppm and
1.0 ppm) at greater depths in the same borings. Magnesium levels
were only slightly elevated in relation to other background
magnesium levels (5190 ppm) detected on the site.
17
-------
Discrete subsurface soil samples were taken from the 0 to 18
inch and 18 to 36 inch intervals below the surface in the pre-
1975 and post-1975 tannery waste disposal areas as shown on
Figure 5. These "root" zone intervals were chosen due to the
crops which are grown in these locations. Chromium is the
primary contaminant of concern for tannery wastes and was
detected above onsite background levels (22.8 ppm) at both
locations. Specifically, chromium was found at levels up to
594 ppm and 89.1 ppm in the pre-1975 and post-1975 locations,
respectively.
5.3.2
Surface Soils and Sediments
Tables 1 and 2 present the levels of contaminants which were
found above onsite background levels. Figures 8, 9 and 10
indicate the site locations for the sample locations presented in
Tables 1 and 2.
Results of samples analyzed during the RI for pesticides
revealed the presence of pesticides at low levels, except for one
sample at location 52 where aldrin was found at 8600 ppb. The
high aldrin level in the south ravine required additional
investigation. The results for that work are presented in Figure
11. In summary, the 8600 ppb aldrin level found in the first
phase is not representative of the aldrin level in the south
ravine. The highest aldrin concentration found in the second
phase was 226 ppb. The typical level is below 20 ppb.
The cluster of various types of pesticides at the former
farm chemicals disposal area, location 49, and downgradient of
that area, location 65, indicates that the source of those
contaminants may be due to an ineffective closure such as using
contaminated onsite soil for the cover material. The presence of
chromium in the cover material over the disposal trenches at a
concentration 100 times above background levels is also
consistent with the conclusion that contaminated onsite soil was
used for cover material.
5.3.3
Ground Water
Tables 3 and 4 present the contaminants which were
identified in onsite ground water at levels above background
levels. VOCs and pesticides do not occur naturally in nature
and, as such, any detectable level of these contaminants is
considered above background. Table 4 also presents the
corresponding background concentrations and the supporting
references. Figure 5 indicates the well locations noted in
Tables 3 and 4.
18
-------
TABLE 1.
SUMMARY OF ORGANIC CONSTITUENTS DETECTED
IN SURFACE SOILS AND SEDIMENTS
MAXIMUK LOCATIONS
CONCENTRATION OF
CONSTITUENT (UG/L) DETECTED LEVELS
PESTICIDES
ALDRIN 8600 33, 44, 52*, 65
ATRAZINE 372 35, 41, 49*, 65
A CHLORDANE 380 33, 35, 44, 52*, 65
G CHLORDANE 350 33, 35, 44, 52*, 65
DIAZINON 816 46, 49*, 5051, 65
DIELDRIN 470 35, 40, i4, 45,
5051, 52 , 65
DISULFOTON 99 46*, 47, 49, 5051
4-DDD 13 44* GRAMER
,
4,4-DDE 31 44, 65*
4,4-DDT 6 44
2, 4-D 56 49
PHORATE 80 49
SEVIN 626 45, 46, 47, 49*,
5051, 56
2,4,5-T 13 40, 49, 65*
(*)
DESIGNATES LOCATION OF MAXIMUM CONCENTRATION
19
-------
TABLE 2.
SUMMARY OF METAL CONSTITUENTS DETECTED
IN SURFACE SOILS AND SEDIMENTS
BACKGROUNDl MAXIMUM LOCATIONS OF
CONCENTRATION CONCENTRATION LEVELS ABOVE
CONSTITUENT (UG/L) (UG/L) BACKGROUND
ANTIMONY < 7 14.9 LT-SW, LT-NE,
ST-NE
CHROMIUM < 22.8 2000 43, 45, 46*,
47, 49, 5051,
53, 54, LT-SW,
LT-SE, LT-NE,
LT-NW, ST-SW,
ST-NE, LT-NW
MERCURY < 0.19 0.49 46, ST-NW*
(*)
(1)
DESIGNATES THE LOCATION OF MAXIMUM CONCENTRATION
DEVELOPED FROM A COMBINATION OF THE FOLLOWING REFERENCES:
TABLE 3.2 FROM "THE SOIL CHEMISTRY OF HAZARDOUS MATERIALS,"
JAMES DRAGUN, 1988, Page 79; IN RELATIVELY HUMID REGIONS;
TOTAL METALS.
"WATER POSSIBILITIES FROM THE GLACIAL DRIFT OF ANDREW
COUNTY," DALE L. FULLER, J. R. MeMI LLEN, HARRY PI CK,
W.B. RUSSELL, AND JACK S. WELLS; MISSOURI GEOLOGICAL
SURVEY AND WATER RESOURCES, 1957, Pages 7-8.
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~ \ ~ ;15$o'~~~'~~) J, / :'-:., L!~.:::~',:"~,~:!~../:::.,.., N ~.~ \\ \
. j ~ ,Aldr.ln 1a.(k-T-) i / "~~;~....:::::::::;:'.::~:~::':: ~...",,::::,)/ 1
: : : "'~""':~ :: 11 100 O. 100 200
, . . ... . .. .-
, : '365$052-190 '." ~: ,'. ...-...~ ,
~ + \ \ { ~Idrl,~' ~,~/~ \ -' f f seA LEI N ~ E E T
k ; \ 66(Contlngent 9-17-89): ;
. ~: o.66-19O(Contingent 1.17.90) t....o
~< iJ ~ldrlt1 17,6':: ~ ~ l \
NOTES:
. All CONCENTRATIONS EXPRESSED IN PARTS PER BilliOt
(Ppb)
. ND = NOT DETECTED
"
PIGt1U
11.
,
-,
,
.
,
i
!
-24-
-------
TABLE 3.
SUMMARY OF ORGANIC CONSTITUENTS DETECTED
IN GROUND WATER
CONSTITUENT
MAXIMUM
CONCENTRATION
(UG/L)
LOCATIONS
OF
DETECTED LEVELS
(VOLATILE ORGANIC COMPOUNDS)
CARBON DISULFIDE
76
30D
CARBON TETRACHLORIDE
3100
*
3 , 255, 31D
CHLOROFORM
128
*
3 , 255, 31D
1,2-DICHLOROETHANE
106
3
1,2-DICHLOROETHENE
26
3*, 17
METHYLENE CHLORIDE
1000
*
17 , 20, 245, 24D,
25D, 26D, 28D, 290
TOLUENE
1600
*
MARKS , 17, 20
TRICHLOROETHENE
1200
*
3, 17, 20 ,
245, 24D
(PESTICIDES)
ATRAZINE
1.2
20, 23D*, 285
23D, 295, 30S*,30D
NABAM
250
SEVIN
63
GRAMER, 14*, 30D
(*)
DESIGNATES LOCATION OF MAXIMUM CONCENTRATION
25
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TABLE 4.
SUMMARY OF METAL CONSTITUENTS DETECTED
IN GROUND WATER
BACKGROUND 1 MAXIMUM LOCATIONS OF
CONCENTRATION CONCENTRATION LEVELS ABOVE
CONSTITUENT CUG/L) CUG/L) BACKGROUND
ALUMINUM < 1000 6550 14*, 30S
BARIUM < 500 1440 14*, 29S
CADMIUM < 1 5.0 28D, 29D
CALCIUM < 141,200 391,000 14*, 27D,
28S, 29S
CHROMIUM < 5 119 29S, 30S*
COBALT < 10 14 29S
COPPER < 30 33.9 30S
IRON < 3800 16,300 14, 30S*
MAGNESIUM < 30,500 118,000 14*, 30S
MANGANESE < 400 3550 14*, 27D,
30S
NICKEL < 50 207 14
VANADIUM < 10 26 30S
(*)
( 1)
DESIGNATES THE LOCATION OF MAXIMUM CONCENTRATION
DEVELOPED FROM A COMBINATION OF THE FOLLOWING REFERENCES:
TABLE 3.2 FROM "THE SOIL CHEMISTRY OF HAZARDOUS MATERIALS,"
JAMES DRAGUN, 1988, Page 79; IN RELATIVELY HUMID REGIONS;
TOTAL METALS.
"WATER POSSIBILITIES FROM THE GLACIAL DRIFT OF ANDREW
COUNTY," DALE L. FULLER, J. R. MeMI LLEN, HARRY PI CK,
W.B. RUSSELL, AND JACK S. WELLS; MISSOURI GEOLOGICAL
. SURVEY AND WATER RESOURCES, 1957, Pages 7-8.
26
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VOC contamination has extended to the shallow ground water
found underneath the site, primarily on the north side of the
site. The results indicate that the VOC contamination has not
migrated offsite or into the deep ground water underneath the
site. Carbon tetrachloride and chloroform were detected in one
deep well (310) in one sampling. event. However, several
subsequent sampling events were conducted for well 310 and no
contamination was detected. Well 3, located just south of the
industrial disposal units, is the only VOC contaminated well on
the south side of the site.
Pesticides detected in onsite ground water appear to be
associated with onsite farming activities.
The first phase of samples analyzed for metals indicated
high concentrations in most onsite wells but also indicated very
high levels of suspended solids in the samples. High suspended
solids is typically associated with either poor well development
during construction or with failing to effectively screen out
fine soil particles such as clays. A second phase of sampling
was conducted in an effort to minimize suspended solids in the
samples. The results from the second phase are presented in
Table 4. The important point learned for this site is that
future monitoring should use wells which are properly designed
and constructed for the site's geology: specifically, drinking
water quality wells will be required for future monitoring.
The data presented in Table 4 for monitoring wells 14, 295
and 305 indicate contamination with several metals. These
results are suspect however because sampling events have
experienced difficulties in minimizing suspended solids in these
wells. The metal contaminants detected in wells 270, 285 and 280
are aesthetic water quality concerns and appear to be related to
the natural geology.
Toluene and sevin were found in the Marks' and Gramer's
private wells, respectively. Based on analysis of the data, the
source of these contaminants is not the Wheeling Disposal site.
5.3.4
Surface Water
Tables 5 and 6 present the contaminants which were
identified at levels above background. Figure 8 identifies the
locations of the surface water samples.
Three seeps which are contaminated with various VOCs were
found onsite in the north ravine. As stated earlier, VOCs are
highly mobile in ground water. The seeps are simply ground water
daylighting. The concentrations found in the surface water are
significantly higher than the VOC concentrations found in the
27
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TABLE 5.
SUMMARY OF ORGANIC CONSTITUENTS DETECTED
IN SURFACE WATER
CONSTITUENT
MAXIMUM
CONCENTRATION
(UG/L)
LOCATIONS
OF
DETECTED LEVELS
(VOLATILE ORGANIC COMPOUNDS)
CARBON TETRACHLORIDE 2,800 33B*, 33A, 41
CHLOROFORM 380 33A*, 41
DIBROMOCHLOROMETHANE 56 33A
l,l-DICHLOROETHANE 53 33A
1,2-DICHLOROETHANE 24,000 33B*, 33A
l,l-DICHLOROETHENE 9 33A
1,2-DICHLOROETHENE 201 33A* 41
,
1,2-DICHLOROPROPANE 35 33A
METHYLENE CHLORIDE 510 41*, 33A
1, 1, I-TRICHLOROETHANE 152 33A
TRICHLOROETHENE 15,000 33A*, 33B, 41
PESTICIDES
ATRAZINE
6.9
41*, 33A
ETHYLENE DIBROMIDE
4.7
33A
OTHER
CYANIDE
11.8
41
(*)
DESIGNATES LOCATION OF MAXIMUM CONCENTRATION
28
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TABLE 6.
SUMMARY OF METAL CONSTITUENTS DETECTED
IN SURFACE WATER
BACRGROUNDl MAXIMUM LOCATIONS OF
CONCENTRATION CONCENTRATION LEVELS ABOVE
CONSTITUENT (UG/L) (UG/L) BACRGROUND
ALUMINUM < 1000 31,000 41*, 33A
CALCIUM < 141,200 887,000 41* 33A
,
CHROMIUM < 5 32 41
COPPER < 30 33.5 41
MAGNESIUM < 30,500 220,000 41 * 33A
,
MANGANESE < 400 1100 41
LEAD < 15 24.5 41
VANADIUM < 10 56 41
DESIGNATES THE LOCATION OF MAXIMUM CONCENTRATION
(*)
(1)
DEVELOPED FROM A COMBINATION OF THE FOLLOWING REFERENCES:
TABLE 3.2 FROM "THE SOIL CHEMISTRY OF HAZARDOUS MATERIALS,"
JAMES DRAGUN, 1988, PAGE 79; IN RELATIVELY HUMID REGIONS;
TOTAL METALS.
"WATER POSSIBILITIES FROM THE GLACIAL DRIFT OF ANDREW
COUNTY," DALE L. FULLER, J.R. McMILLEN, HARRY PICK,
W.B. RUSSELL, AND JACK S. WELLS; MISSOURI GEOLOGICAL
SURVEY AND WATER RESOURCES, 1957, PAGES 7-8.
29
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ground water. As stated in Section 5.1 Hvdroaeoloaic Setting,
the loess/drift interface is capable of effectively controlling
the shallow ground water flow. Since the wells are screened
below this interface, the wells do not screen the zone of highest
contamination.
The seeps are stagnant puddles and only flow during rainfall
events. Sample 35, located at the property line and in the
drainage path for the seeps, was sampled several times during
both drought and wet conditions, and no contamination was found.
However, computer modelling indicates the potential for the seep
contamination to reach the property line during a rainfall event.
The modelled concentrations for trichloroethene and
1,2-Dichloroethane at the property line are 1300 ppb and
1450 ppb, respectively.
The pesticide and metal levels identified in the seeps are
not different from levels found in the ground water for the same
types of contaminants.
SECTION 6.0
SUMMARY OF SITE RISRS
As part of the RI/FS process, a risk assessment was
conducted in order to assess the current and potential risks to
human health and to the environment due to the site. This
section summarizes the findings concerning the quantified risks
under both current site conditions, called the baseline risk
assessment, and future site conditions. The risk assessment
provides valuable information used to determine the need for
cleanup action(s).
6.1
Identification of Contaminants of Concern
Close to fifty different contaminants were identified above
background levels in various media onsite during the RI. Due to
the wide variations in occurrence, concentrations, and toxicities
between contaminants, a selection process was implemented to
identify indicator chemicals for evaluation in the risk
assessment. Indicator chemicals are selected to focus the
assessment on the chemicals that represent the most probable risk
to the public and the environment. This process resulted in the
selection of the following eleven indicator chemicals: aldrin,
arsenic, barium, carbon tetrachloride, chlordane, chromium,
dieldrin, 1,2-dichloroethane, lead, nickel and trichloroethene.
Table 7 lists the highest concentration detected for each
indicator chemical in each media.
30
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TABLE 7.
SUMMARY OP MAXIMUM CONCENTRATIONS POR THE
INDICATOR CHEMICALS BY MEDIA TYPE
SEDIMENT AND
GROUND WATER SURFACB WATER SURFACE SOIL
MAXIMUM MAXIMUM MAXIMUM
INDICATOR CONCENTRATiON1 CONCENTRATION CONCENTRATION
CHEMICAL (UG/L) (UG/L) (UG/G)
VOLATILE ORGANIC COMPOUNDS
CARBON TETRACHLORIDE 3,100 2,800 BDL
1,2-DICHLOROETHANE 106 24,000 BDL
TRICHLOROETHENE 1,200 15,000 BDL
PESTICIDES
ALDRIN BDL BDL 8,600
CHLORDANE (TOTAL) BDL BDL 730
DIELDRIN BDL BDL 470
METALS
ARSENIC4 53 26 10
BARIUM 1,440 400 BDL
CHROMIUM 119 32 2,000
LEAD 11.8 24.5 BDL
NICKEL 207 50 BDL
BDL - BELOW DETECTION LIMIT
(1) - METALS RESULTS ARB BASED ON UNFILTERED, SECOND PHASE
DATA ONLY.
(2) - UG/L IS EQUAL TO A PART PER BILLION
(3) - UG/G IS EQUAL TO A PART PER MILLION
(4) - METAL CONCENTRATION IN GROUND WATER IS BASED ON UNFILTERED,
FIRST PHASE DATA.
31
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6.2
EXDosure Assessment
Exposure assessment involves analysis of the following
factors which will affect the quantification of risks: location
of contamination, contaminant concentrations, exposure pathways,
affected populations, and exposure frequency.
As presented in the Summary of Site Characteristics section,
contamination was detected in the following media: surface soils
and sediment, subsurface soils, ground water and surface water.
Concentrations for the indicator chemicals varied significantly
depending on site location. As a result, risks were calculated
for each media depending on location.
The rural setting, demographics and existing deed
restrictions (drafted by both the State and the property owner)
for the site were important factors in determining the current"
potential exposure scenarios. The following scenarios were used
to calculate the current risks due to exposure to the
contaminants:
(1)
Trespassers crossing the north ravine and central
disposal areas:
(2)
(3)
Trespassers crossing the south ravine:
Persons using the st. Joseph drinking water
supply:
(4)
Persons ingesting beef from cattle grazing on the
site: and,
(5)
Environmental receptors (plants, animals and
fish).
The EPA calculated the future risk for someone residing
onsite and using onsite ground water for drinking water and for
other personal needs such as showering. This is a future risk
scenario which is highly unlikely given the poor marketability of
land used for industrial waste disposal and given the fact that
an existing deed restriction prevents onsite residences.
Exposure analysis classified the population into adults and
children. Exposure frequency varied depending on the pathway of
exposure. As an example, the trespassers were assumed to spend
eight hours per day, twelve days per year, for ten years
(typical) to thirty (worst) in contact with the onsite
contaminated media. Both "typical" and "worst" case risks are
calculated due to the many assumptions involved in quantifying
the baseline risks.
32
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6.3
Toxicity Assessment
Seven of the eleven indicator chemicals are classified as
possible, probable or known human carcinogens with arsenic being
the known human carcinogen. In Appendix A, the cancer potency
factors are presented for the indicator chemicals. These factors
are used to calculate excess cancer risks associated with the
site based on site contaminant concentrations. As defined in the
NCP, the EPA considers in2ividual excess cancer riiks in the
range of 1 in 10,000 (10- ) to 1 in 1,000,000 (10- ) as
protective of human health with the 1 in 1,000,000 risk level as
the point gf departure. However, when a risk is in the 1 x 10-4
to 1 x 10- range, EPA makes a site specific determination as to
whether the risk is unacceptable. The EPA implements response
actions at all sites with an excess cancer risk greater than
1 x 10-4.
Cancer potency factors (CPFs) have been developed by EPA's
carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs are multiplied by the estimated intake of a
potential carcinogen to provide an upper-bound estimate of the
excess lifetime cancer risk associated with exposure at that
intake level.
Appendix A also lists the non-carcinogenic reference dose
(RfD) levels for the indicator chemicals. The RfD is a
concentration to which humans can be exposed on a daily basis
without adverse effect. The RfDs are used to calculate the
potential Hazard Index (HI) for each contaminant based on site
contaminant concentrations. Potential Hazard Indices greater
than 1.0 would be considered unacceptable.
Through the defined exposure pathways, carcinogenic and non-
carcinogenic risks exist for the exposed population due to each
contaminant. Cumulative contaminant risks are also calculated
and evaluated for exposed populations by simply adding the
individual contaminant risks.
6.4
Risk Characterization
Quantified carcinogenic and non-carcinogenic risks for all
exposure scenarios and populations are presented in Appendix B.
Table 8 presents key carcinogenic and noncarcinogenic risks.
The results for the baseline risk assessment show that no
offsite unacceptable health risks (a cancer risk greater than 1
in 10,000 or a Hazard Index greater than 1.0) are present with
"typical" conditions. However, the onsite "worst" case cancer
risks for the Beef Ingestion, South Ravine (both adult and
child), Total Adult and Total Child scenarios exceed the 1 in
1,000,000 point of departure standard. Also, the Hazard Index
for the Child in the South Ravine and the Total Adult exposure
scenarios exceed the 1.0 standard.
33
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TABLE 8.
RECEPTOR
KEY ENDANGERMENT ASSESSMENT RESULTS
NON-CANCER RISK
(HAZARD INDEX)
CANCER RISK
TYPICAL
0.1
WORST
0.7
TYPICAL
3 X 10-7
SOUTH RAVINE
ADULT
SOUTH RAVINE
2.1
CHILD
0.1
2 X 10-7
BEEF INGESTION
ST. JOSEPH3
WATER SUPPLY
TOTAL ADULT1
TOTAL CHILD2
ONSITE
RESIDENT4
(1)
(2)
(3)
(4)
0.03
7 X 10-7
0.4
8 X 10-9
WORST
6 X 10-6
4 X 10-6
3 X 10-5
2 X 10-10
0.1
8 X 10-7
1 X 10-7
1.0
0.1
0.8
N/A
135.0
N/A
WEIGHTED SUM OF ALL EXPOSURE SCENARIOS
4 X 10-5
1 X 10-6
4 X 10-2
WEIGHTED SUM OF ALL EXPOSURE SCENARIOS EXCEPT BEEF
INGESTION AND ST. JOSEPH WATER SUPPLY
8 X 10-9 - O.0000000P8
ONSITE RESIDENT RISKS ARE NOT INCLUDED IN
N/A - NOT APPLICABLE
THE "TOTAL" RISK SUMMATIONS
,:,3L1~
-------
One individual exposure scenario accounts for the majority
of the above risks: exposure to sediment in the south ravine.
Risks associated with exposure to south ravine sediment are
predominantly due to one surface sediment sample from the south
ravine in which the pesticide aldrin was detected at a
concentration of 8600 parts per billion (ppb). As indicated in
Section 5.3.2 Surface Soils and Sediments, subsequent sampling
and analyses throughout the south ravine did not confirm the high
aldrin level. Instead, the second highest aldrin level detected
in the subsequent sampling was 226 ppb.
The EPA calculated risks associated with the situation where
individuals lived onsite. For the exposure of onsite resident~
to onsite ground water, four additional people in 100 (4 x 10- )
could contract cancer. The hazard index for the same exposure
scenario was calculated to be as high as 135.0. It should be
noted that deed restrictions for the Wheeling site prevent
installation of wells and residences onsite.
The Environmental Risk Assessment identified that the site
is within the native range of three federally endangered species:
the bald eagle, the Indiana bat and the interior least tern.
However, because the site does not contain the preferred habitat
of these species, it is highly unlikely that exposure of site.
contaminants to these species will occur. The uptake of
contaminants from the soil through the root system was modelled
for vegetables. No evidence of toxicity to site plants has been
noted. No significant exposure pathway for chlorinated, volatile
organic compounds (VOCs) from the north ravine seeps has been
identified. Under current conditions, no adverse impacts were
identified for the local flora and fauna ecosystems. This
assessment will be re-evaluated in the event that offsite
migration occurs.
The EPA bases its remedial action decisions on the
Reasonable Maximum Exposures (RME) calculated for a particular
site. For the Wheeling Risk Assessment, the EPA has determined
that the risks presented as the typical case scenarios are the
RME risks. The EPA does not find the worst case to be the RME
risks. One reason is that it is based on an anomolous south
ravine aldrin level detected in the first round of samples.
Also, the EPA finds the future risk to onsite residents to have a
very low probability of occurrence due to the deed restrictions
preventing such an exposure.
As defined in the section 5.0 Site Characteristics, the
principal threat associated with the Wheeling site is the waste
disposed in the closed disposal units. Risk assessment indicates
that exposures due to the principal threat and related secondary
threats are either within the acceptable risk range or a low
probability of occurrence. As a result, remedial actions at the
site will be based on the typical case risks. Worst case risks
and future risks will be used to identify monitoring
requirements.
35
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In addition, the EPA has determined that cancer cleanup
goals will be based on the 1 in 1,000,000 cancer standard and
upon the 1.0 Hazard Index standard due to the many assumptions
associated with quantifying risks for a remote site s~ch as the
Wheeling site. State and Federal Applicable or Relevant and
Appropriate Requirements (ARARs) will be used to define cleanup
goals, as appropriate.
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or, the environment.
SECTION 7.0
DESCRIPTION OF ALTERNATIVES
The alternatives analyzed in detail are presented below and
are numbered to correspond with the numbers in the RI/FS reports.
All costs and implementation times are estimated.
Alternative I:
No Action
Alternative II:
Long-term ground water and surface water
monitoring program, closure of certain
onsite wells, and installation of
security measures (warning signs and/or
fences).
Alternative III:
Same as Alternative II with the
addition of upgrading the existing cover
over the disposal areas, and site
maintenance activities to maintain the
containment system.
Common Elements
Except for the "No Action" alternative, all other
alternatives for the site will be required to comply with the
following ADDlicable or Relevant and ADDroDriate Reauirements
(ARARs): 1) the Missouri Solid Waste Management (MSWM) Law of
1988 (Sections 260.200 to 260.245, RSMo, Supplement 1973), and
the MSWM Regulations, 10 CSR 80 (Effective December 29, 1988);
2) the Resource Conservation and Recovery Act (RCRA) of 1976, as
amended by the Hazardous and Solid Waste Amendments of 1984, 42
U.S.C. ~ 6901 et.seq.; 3) the Missouri Water Quality Standards
(MWQS), 10 CSR 20-7.031; 4) the Federal Safe Drinking Water Act
(SDWA) of 1974, as amended in 1986, 42 U.S.C. ~ 300f et. ~;
and 5) the Federal Clean Water Act (CWA) of 1977, as amended by
the Water Quality Act (WQA) of 1987, 33 U.S.C. ~ 1251 et. ~
Since the landfill closed before the 1988 MSWM went into
effect, the State regulations, which include, among other things,
closure and post-closure plans, are not legally aDDlicable to the
Wheeling site. The purpose of these closure and post-closure
plans is to ensure that where wastes are permitted to be
36
-------
disposed, measures will be taken to protect against environmental
harm that could result from migration of contaminants from the
permitted area to soil or ground water. When Wheeling Disposal
Service, Inc. closed its facility voluntarily, it did not follow
procedures that subsequently became law. Therefore, the
activities taken by Wheeling Disposal Service in closing the
facility were not necessarily protective of the environment. It
is, therefore, relevant and appropriate to impose the State's
closure and Post-closure procedures to ensure protectiveness to
human health and the environment.
The MSWM closure and Post-closure procedures can be met by
substituting the RI/FS and the Record of Decision for the closure
and Post-closure plans. State closure procedures further require
submittal of plans for the following activities: placement of a
soil and vegetative cover, and ground water monitoring and
leachate collection and treatment, if necessary.
Wheeling Disposal Service ceased receiving RCRA-type hazardous
wastes prior to the effective date of the RCRA amendments
(November 19, 1980), and these alternatives do not involve
placement/disposal of RCRA-regulated waste. Therefore, the RCRA
Subtitle C closure standards are not legally apPlicable.
However, the standards have been determined by EPA to be relevant
and appropriate due to the types of wastes being managed and the
circumstances of the release.
Closure of the disposal areas will comply with appropriate
portions of the RCRA regulations affecting landfill closure.
Specifically, the site will be capped with a final cover designed
and constructed to provide long-term minimization of the
migration of liquids through the capped area, and to maintain its
integrity over time while functioning with minimum maintenance
(40 CFR 264.111, 264.228, and 264.310). In addition, the cap
will be designed and constructed to promote drainage and minimize
erosion of the cover. Consistent with the requirements of 40 CFR
264.117, long-term Operation and Maintenance (O&M) will be
conducted to monitor the ground water and surface water around
the landfill, and to ensure the integrity of the cap.
The RCRA minimum technology requirements are not applicable
to the capping alternatives, because the remedy does not involve
a new RCRA unit, a lateral expansion of an existing unit, or a
replacement unit. These requirements are relevant but not
appropriate because the Risk Assessment does not provide
justification for such controls. In addition, based on the
results of the Risk Assessment, leachate collection is not deemed
necessary by EPA or the state of Missouri. These two decisions -
RCRA minimum technology standards, and leachate collection and
treatment - will, however, be reviewed every five years or more
frequently if conditions such as surface water quality, ground
water quality, or local land use change.
.
37
-------
The EPA and MDNR have determined that ground water
monitoring is required for this site. In addition, EPA and MDNR
have determined that surface water monitoring is required for
this site due to the documented surface water contamination and
the associated potential health hazards.
ALTERNATIVE .I
Years to Implements:
Capital Cost: $ 0
Annual Operation and
Present Worth: $ 0
Not Applicable
Maintenance (O&M) Costs:
$ 0
CERCLA, as amended, requires that the "No Action"
alternative be evaluated at every site to establish a baseline
for comparison. No monies would be expended for monitoring,
control, or remediation of the site. Maintenance of the existing
cover over the disposal areas would not be required and
potentially would degrade to an unacceptable condition which
would expose the landfill wastes at the surface. Also,
monitoring of the contaminated onsite ground water and surface
water would not be required, thus potentially allowing the
contaminated waters to migrate offsite undetected. Existing deed
restrictions prevent construction of onsite residences and
installation of wells intended for personal use.
ALTERNATIVE II
Years to Implement: Less than 1 year to implement,
monitoring for the life of the
Capital Cost: $ 103,600
Annual O&M Costs: $ 40,200
Present Worth (30 years; 10%): $ 721,600
and
landfill.
A ground water and surface water monitoring program would be
implemented to provide for early identification of any changes in
ground water and surface water quality, and allow for timely
response if action is required. The ground water program would
monitor both the shallow and deep ground water below the site.
For the purpose of estimating costs, the FS report proposes a
monitoring well system composed of thirteen existing wells and
four new wells from which ground water samples would be collected
and analyzed on an annual frequency. Sampling four seeps in the
north ravine on a semi-annual frequency and analyzing for
volatile organic compounds (VOCs) is proposed in the FS report.
Offsite ground water quality and surface water quality would
be required to meet the appropriate criteria as defined in the
Missouri Water Quality standards (MWQS) 10 CSR 20-7.031 (5) (B),
Federal Safe Drinking Water Act (SDWA) and the Federal Clean
Water Act (CWA). Potential ARARs are liste~ in Appendix C for
38
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the indicator chemicals. The ground water and surface water
monitoring programs would define the points of compliance for the
offsite ground water and surface water quality standards. The
following new institutional controls would be required for the
Wheeling site property: (1) deed restrictions to prevent farming
of the disposal areas; and, (2) security signs and/or fences to
warn trespassers that the property is a closed industrial
landfill and to prevent farming in restricted areas.
Maintenance of the existing cover over the disposal areas
would not be required and, potentially, would degrade to an
unacceptable condition which would expose the wastes at the
surface.
Several existing onsite wells would be closed by filling the
wells from surface to depth with a material of low permeability
such as a concrete-type material called grout. The purpose is to
prevent wells of questionable design from acting as conduits in
allowing contaminated ground water to spread both vertically and
horizontally.
ALTERNATIVE III
Years to Implement: Less than 1 year to implement,
monitoring for the life of the
Capital Cost: $ 560,600
Annual O&M Cost: $ 42,000
Present Worth (30 years; 10%): $ 1,205,800
and
landfill.
This alternative is identical to Alternative II with the
addition of upgrading the existing disposal cover and providing
for maintenance of the cover. The site closed using conventional
methods, including soil cover of the various disposal areas. The
RI documented that the existing cover varies in depth from two to
five feet, and that infiltration through the cover produces a
leachate which surfaces a significant distance away in the north
ravines.
For cost estimating purposes, the FS proposes upgrading the
existing cover by placing an additional two feet of compacted
clay and six inches of top soil over the disposal areas, seeding
the disposal areas and grading the site to improve drainage.
This cap design complies with the technical requirements of the
Missouri Solid Waste Management Act of 1988. Upgrading the cover
would reduce infiltration and, subsequently, reduce leachate
production. Maintenance would reduce the potential of the cover
degrading to a condition which would expose the wastes to the
surface.
39
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SECTION 8.0
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
This section profiles the performance of the three
alternatives against the nine criteria which EPA and MDNR use to
evaluate alternatives. The nine criteria are divided into three
groups: (1) Threshold criteria - alternatives which do not
satisfy these criteria are eliminated: (2) Primary Balancing
criteria - these criteria are used to weigh major trade-offs
among alternatives: and, (3) Modifying criteria - these criteria
are taken into account after the public comment period.
Threshold criteria
- Overall Protection of Human Health and the Environment:
Alternative I, the "No Action" alternative, would not be
protective of human health and the environment. The contaminated
ground water and surface water would migrate offsite unmonitored
which presents future health risks to ground water users, and
future environmental risks to the unnamed north tributary and to
Mace Creek. Alternative I is not considered further in this
analysis as an option for this site.
Alternatives II and III would be protective of human health
and the environment by (1) monitoring onsite contaminated ground
water and surface water, thereby allowing for a timely response
action, if necessary, and, (2) preventing the potential exposure
to contaminated onsite ground water. with implementation of
either Alternative II or III, the possibility of someone being
exposed to the principal threat for the Wheeling site is
eliminated.
- Compliance with ARARs:
Alternatives II and III would both be required to comply
with Federal and state regulations for offsite surface water and
ground water (Federal Safe Drinking Water Act and Clean Water
Act, and the Missouri Water Quality Standards) .
Alternative II would satisfy the closure requirements of the
Missouri Solid Waste Management Act of 1988 (MSWM). However, the
lack of site maintenance and the documented leachate surfacing in
the north ravine indicate that Alternative II would not satisfy
the RCRA landfill closure requirements for Operation and
Maintenance and for cover design, respectively. Alternative III
would satisfy the landfill closure requirements of both MSWM and
RCRA.
40
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Balancing criteria
- Long-term Effectiveness and Permanence:
Alternatives II and III depend upon deed restrictions to
prevent exposure to onsite ground water and to landfill wastes.
These deed restrictions are considered permanent in that they are
legally attached to the land and unaffected by changes in
ownership. In addition, the deed restrictions would require that
EPA and MDNR be notified of any attempt to change the land use.
Both alternatives also depend upon monitoring programs to
prevent future offsite exposure to contaminated ground water and
surface water. The monitoring programs would provide long-term
effectiveness given the facts known about the site hydrogeology
and the remoteness of the site.
In effect, the contaminated material remaining onsite will
be reliably controlled over time using either Alternative II or
III.
In addition, the upgraded cover and site maintenance
activities provided for in Alternative III would reduce the
volume of contaminated ground water (leachate) produced in the
disposal area and would reduce the likelihood of the existing
cover degrading to a condition which exposes landfill wastes to
the surface. The long-term effectiveness of Alternative III is
superior to Alternative II due to the benefits provided by the
cover-related activities.
- Reduction of Toxicity, MObility, or Volume Through Treatment:
The National contingency Plan (NCP) promotes the aggressive
use of treatment technologies to achieve reliable remedies while
acknowledging the practical limitations on the use of treatment.
This approach is tempered by practicability to ensure that the
remedies selected are appropriate and the program responds to the
threats posed by a site.
Alternatives II and III do not incorporate treatment -- deed
restrictions are considered to be institutional controls, and
cover upgrading and monitoring activities are considered
containment controls. However, the cover upgrading activities
provided for in Alternative III would reduce the mobility and
leachate volume from the disposal area. This, in turn, would
reduce the volume of contaminated ground water and surface water.
Also, the monitoring programs would alert the appropriate
parties, including EPA and MDNR, in the event that contaminated
ground water or surface water migrates offsite. At that time,
remedial action(s) may be warranted which could involve treatment
of contaminated ground water and/or surface water.
41
-------
- Short-term Effectiveness:
Implementation of Alternatives II and III would result in
low potential for unacceptable short-term risks to human health.
While monitoring activities would increase exposure to
contamination, all workers would be protected by use of
appropriate personal protective equipment. Environmental impacts
associated with these alternatives would be low as little
disturbance of the site would be necessary to implement these
alternatives.
- Implementability:
Implementation concerns for Alternatives II and III are low.
The equipment and materials required are readily available, and
the procedures to be followed are common. No special agreements
or permits would be required to implement these alternatives.
- Cost:
The estimated
$721,600. This is
alternatives. The
III is $1,205,800.
present-worth cost of Alternative II is
the lowest present-worth cost of the two
estimated present-worth cost for Alternative
MOdifYing criteria
- State Acceptance:
The Missouri Department of Natural Resources (MDNR),
representing the State of Missouri, has concurred that
Alternative III is the preferred alternative. A copy of the
State's concurrence letter is presented following the
Declaration.
- Community Acceptance:
The reservations, concerns, and supporting or opposing
comments of the community on the RIjFS, the Proposed Plan, and
other information in the Administrative Record were made known to
the EPA during the thirty day comment period and the public
meeting with the community on August 29, 1990. The pUblic's
comments will be addressed in the responsiveness summary, which
is a component of this Record of Decision for the site.
42
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SECTION 9.0
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, the
EPA has determined that Alternative III is the most appropriate
remedy for the Wheeling Disposal Service site near Amazonia,
Missouri. Alternative III includes upgrading the existing cover
over the disposal area, long-term monitoring of ground water and
surface water, implementing site maintenance activities,
installing security measures (warning signs and/or fences), and
closing certain onsite wells.
Specific details for each component of Alternative III are
not defined at this time. The remedial design will define the
. exact details to include, but not be limited to, the following:
Upgrading the Existing Cover
*
The areas requiring cover upgrading;
*
The design of the upgraded cover;
*
The type and source of soils to be used in the cover;
Long-term Monitoring
*
The number of ground water wells and surface water
sampling locations;
*
The design of monitoring wells which precludes filtering
of metals samples;
*
The depths screened by the wells;
*
The frequency of sampling the wells and surface water
locations;
*
The chemical analyses required for the samples;
site Maintenance Activities
*
The types of maintenance activities; and,
*
The frequency of maintenance activities.
Security Measures
The areas requiring security measures;
*
*
The type(s).of security measures;
43
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Closing certain Onsite Wells
*
The wells to be closed:
The technique to be used to close these wells:
As required by the NCP, compliance points for the ground
water and surface water monitoring programs will be located to
determine the long-term effectiveness of the selected remedy and
to provide an early warning before hazardous substances migrate
offsite and endanger human health or the environment. The ground
water monitoring system will monitor both the shallow ground
water at the loess/drift interface and the deeper ground water
extending to bedrock. Performance criteria will be developed and
based upon Applicable or Relevant and Appropriate Requirements
(ARARs) such as the Missouri Water Quality standards (MWQS),
Federal Safe Drinking Water Act (SWDA) and the Federal Clean
Water Act (CWA).
*
The performance criteria will be used to define whether the
selected remedy -will maintain protection of human health and the
environment over time. In the event that the monitoring program
indicates exceedance of the performance criteria, then additional
remedial activities may be required to protect human health and
the environment. These additional activities may include, but
would not be limited to, ground water and/or surface water
leachate collection and treatment.
SECTION 10.0
STATUTORY DETERMINATIONS
CERCLA requires EPA to undertake remedial actions that
achieve adequate protection of human health and the environment.
In addition, section 121 of CERCLA specifically requires the
selected remedial action to comply with applicable or relevant
and appropriate environmental standards established under Federal
and state environmental laws unless a statutory waiver is
justified. The selected remedy also must be cost effective and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. Finally, the statute includes a preference
for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
10.1
Protection of Human Health and the Environment
The selected remedy protects human health and the
environment through deed restrictions which prevent any person
from establishing a residence on the site, using onsite ground
water and farming of disposal areas. In addition, the selected
remedy requires the cover to be upgraded and maintained over the
44
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disposal areas thereby eliminating potential exposures to
uncovered wastes. Further, the selected remedy will monitor
ground water and surface water to prevent offsite migration of
hazardous substances. No unacceptable short-term or cross-media
impacts will be caused by implementation of the remedy.
10.2
Compliance with Applicable or Relevant and Appropriate
Reauirements
The selected remedy will comply with all applicable or
relevant and appropriate chemical, action and location specific
requirements (ARARs). The ARARs are presented below.
Action-Specific ARARs:
Landfill closure and post-closure requirements defined in
Missouri Solid Waste Management (MSWM) Law of 1988
(Sections 260.200 to 260.245, RSMo, Supplement 1973),
and MSWM Regulations, 10 CSR 80 (Effective
December 29, 1988): and,
Resource Conservation and Recovery Act (RCRA) of 1976,
as amended by the Hazardous and Solid Waste Amendments
of 1984, 42 U.S.C. ~ 6901 et.sea.
Chemical-Specific ARARs:
Federal Maximum contaminant Levels for inorganic and
organics in drinking water supplies (40 CFR Part 141)
as defined in the Safe Drinking Water Act (SWDA) of
1974, as amended in 1986, 42 U.S.C. ~ 300f et. ~;
Federal Ambient Water Quality Standards as defined by
the Clean Water Act (CWA) of 1977, as amended by the
Water Quality Act (WQA) of 1987, 33 U.S.C. ~ 1251
et. ~;
State of Missouri water quality standards for inorganics
and organics in ground water and surface water
(10 CSR 20-7.031).
Location-Specific ARARs:
None
45
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10.3
Cost-Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs. The estimated net present worth for the selected remedy
is $1,205,800. The selected remedy is the most costly of
Alternatives II and III, but it provides a significant advantage
in long-term reliability due to the cover activities.
\
10.4
utilization of. Permanent Solutions and Alternative
Treatment Technoloaies QX Resource Recovery
Technoloaies to the Maximum Extent Practicable
The selected remedy provides a superior advantage based on
the comparative analysis using the nine criteria. specifically,
for the balancing criteria:
The long-term effectiveness of the selected remedy
is superior to Alternative II due to the cover and
maintenance of it;
Only the selected remedy provides a reduction
in mobility and volume of leachate due to the
cover-related activities;
Both Alternative II and the selected remedy provide
equal and acceptable short-term effectiveness;
Both Alternative II and the selected remedy provide
equal and acceptable degrees of implementability;
and,
The selected remedy is more costly than Alternative
II but provides superior long-term reliability
based on the previous four balancing criteria.
The state of Missouri is in concurrence with the selected
remedy. The EPA reviewed all written and verbal comments
submitted during the public comment period, including the public
meeting. Upon review of these comments, EPA has determined that
no signific~nt changes to the preferred remedy, as it was
originally identified in the Proposed Plan, is necessary.
10.5
Preference ~ Treatment Ae ~ Principal Element
The NCP states that the remedy selection process is founded on
the overarching mandate to protect human health and the
environment. The EPA emphasizes the statutory preference for
permanent solutions and use of treatment technologies. This
approach emphasizes solutions that can ensure reliable protection
over time. However, the approach is tempered by practicability
to ensure that remedies selected are appropriate. Further, this
process considers the full range of factors pertinent to remedy
46
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selection and provides the flexibility necessary and appropriate
to ensure that remedial actions selected are sensible, reliable
solutions for identified site problems. The EPA will always seek
to reduce hazards to levels that ensure that contaminated
material remaining onsite can be reliably controlled over time.
This remedy utilizes permanent solutions and alternative
treatment technologies, to the maximum extent practicable for
this site. However, because treatment of the hazardous
substances was not found to be practicable, this remedy does not
satisfy the statutory preference for treatment as a principal
element. Although treatment is not being selected, the selected
remedy activities do effectively reduce hazards. The site
hydrogeology consists in part of a loess/drift interface that
acts to control the migration of leachate from the disposal
areas. Thus, the migration of hazardous substances is limited
and can be effectively monitored to protect human health and the
environment. Upgrading and maintaining the cover in combination
with site security measures minimizes the formation and migration
of leachate, and prevents direct exposures to buried wastes.
Although not required initially, contingencies for future
collection and treatment of contaminated surface water and/or
ground water are provided in the selected remedy if performance
criteria are exceeded at designated points of compliance.
47
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APPENDIX A
48
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SUMMARY OF CARCINOGENIC AND NON-CARCINOGENIC TOXICITY VALUES
CANCER
NON-CANCER
CHEMICAL
GROUP
CARBON TETRACHLORIDE
B2
ORAL CPF
1. 3 X 10-1
RfD
7 X 10-3
(SUBCH~~NIC)
7 X 10
(CHRONIC)
1,2-DICHLOROETHANE
B2
9.1 X 10-2
1.1 X 10-2
NA
TRICHLOROETHENE
B2
ARSENIC
A
NA
NA
3 X 10-5
(SUBCHRONIC
AND CHRONIC)
6 X 10-5
(CHRONIC)
5 X 10-5
(SUBCHRONIC
AND CHRONIC)
1 X 10-3
(SUBCHRONIC
AND CHRONIC)
ALDRIN
B2
1. 7 X 101
CHLORDANE
B2
1. 3 X 100
DIELDRIN
B2
1.6 X 101
BARIUM
5 X 10-2
(SUBCHRONIC
AND CHRONIC)
1 X 100
(CHRONIC)
CHROMIUM (I I I)
LEAD
NICKEL
2 X 10 -2
(SUBCHRONIC
AND CHRONIC)
B2 - PROBABLE HUMAN CARCINOGEN
A - KNOWN HUMAN CARCINOGEN
CPF - CANCER POTENCY FACTOR (KG/KG/DAY)
RfD - REFERENCE DOSE- (KG/KG/DAY)
49
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APPENDIX B
50
-------
HAZAJU) INDICES FOR ADU1.T tRESPASSER SCENARIO
,
Chemical ~ . ~ical Case Vorst Case
Chromium Incution 4. 32dO-' 2.13xlO-'
Dieldrin lnaution 3. 68x10-' 1.06xlO-2
Deraal Contact 2. 09dO.' 5. 97dO-'
TOTAl.-Dielc1rin 5. 77dO.' 1.66xlO-2
Carbon Denaal ContAct* 1.4OxlO.' 1. 57dO-2
eetrachloride
Inhalation* 3 :24dO.' 3. 5lxlO-'
TOTAl.- CCl, * 1.72dO-' 1.92xlO-2
1.2-Dichloro- Dermal Contact ND ND
ethane
Inhalation ND ND
TOTAl.-1.2-DCA ND ND
Trichloro- Dermal Contac t ND ND
ethene
Inhalation ND ND
TOTAL-TCE ND ND
*Carbon tetrachloride Hazard Indices are calculated using oral chronic RfD.
HAZARD INDICES FOR 6.9 YEAR 01.» CHI1.» TRESPASSER SCENARIO
Chemical ~ ~lca1 Cue Vorst Case
Dieldrin SoU Inl..tion 1.03dO.z 2. 9'dO-2
Demal Coneact 6.67:&10.' 1.91dO.z
TOTAL. Die ldrin 1.69dO.z 4. 87dO.z
Carbon Inhalation 9.07dO.' 9. .3dO.'
eetrachloride Deraal Contact 2.4lx10.' 2.13xlO.z
TOTAL-eCl, 3. 32xlO.' 3.llxlO.z
1.2.Dichloro. Inhalation am am
ethane Deraal Contact 1m am
TOTAL.1,2-DCA 1m ND
Trlchloro. Inhalation 1m ND
ethene Dermal Contact ND ND
TOTAL.TCE 1m ND
.
ND - Not Determined
-51-
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HAZARD INDICES FOR ADULT TRESPASSER IN SOUTH RAVINE SCENARIO
Indicator ~ Tvoical Case Worst Case
Aldrin S.di.ent Insestion 1.84xlO.2 0.41
Chlorc1ane S.di..nt insestion S. 72xlO.' 2. 85xlO.2
Dieldrin S.di..nt insestion 2. S6xlO-' 1.34xlO.2
Aldrin Denaal contact 1.04xlO-1 0.23
Chlorc1ane Denaal contact 3. 23xlO.' 1.62xlO.2
Dieldrin Denaal contact 1.45xlO.' 4.47xlO.2
Aldrin TOTAl. 1.23xlO.1 0.64
Chlorc1ane TOTAL 8. 95xlO.' 7. 60xlO.'
Dieldrin TOTAl. 4. OOxlO.' 2.10xlO.2
All TOTAl. 1.36xlO.l 0.67
HAZARD INDICES FOR 6.9 YEAR OU> CHIU> TRESPASSER IN S01J'I"H RAVINE SCENARIO
Indicator ~ Tvoic:a1 Cue Vorst Case
Aldrin S.d1aent ins..tion S . 17xlO-' 1.15
Chlordane S.di8ent ins..tion 1. 'OxlO.' 8. OOxlO-2
Dieldrin S.d1aent ina..tlon 7.16xlO-' 3. 76xlO-2
Aldrin Derul contact 3. )4x10.' 0.74
Chlorc1ane Deru1 contact 1.04xlO-J S.18xlO.'
Dlelcir1n Deru 1 contact 4. 6lxlO-J .2 . 44 xl 0-2
Aldrin TOTAL 5. 5OxlO-' 1.19
Ch1orcSane' TOTAL 2. 64xlO-J 0.13
Dle1cirln TOTAL 1. 18xlO.2 ,. 20xlO.z
All TOTAL t. 32xlO-z 2.08
-52-
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HAZARD INDICES FOR ADt1l.T ft!:SPASSEIl NEAll NORTH RAVINE
Indicator
~
~ical Case
Maxlmwr. Case
Carbon ~.~rachloride
1.2.Dichloroethane
Tr1chloroethene
Inhalation
Inhalation
Inhalation
3.69xlO.!
1ft)
1ft)
5. S6xlO.!
ND
ND
KAVJU) INDICES FOR CHIlJ) TIlISPASSEIl NEAR NORTH RAVINE
Indicator ~ ~ical Case Maximum Case
Carbon ~etrachloride Inhalation 1.03xlO-1 1.56xlO-1
1.2-Dichloroethane Inhalation ND ND
Trichloroethene Inhalation ND ND
-51-
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UPPER BOUND CANCER ..lSltS POI ADULT TIltSPASSER SCENARIO
Chemieal ~ Twieal Cue Worst Case
DIeldrin I'ftIutlon 1.29dO.8 1.llxlO.'
1>81'11&1 Contact 7. 28dO.1 6. 26xlO.8
TOTAL.DIeldrln 2. 02dO.8 1.74xlO.'
Carbon 1>81'11&1 Contact 7. 46dO.10 2. 51xlO.1
tetrachlorIde
Inhalation 1.29x10.10 5. 30xlO.1
TOTAL.eCl. 8. 7SxlO-10 3. 04xlO.1
1.2-Dichloro- Dermal Contact 1.03xlO.1C 3.37xlO.1
ethane
Inhalation 6. 26xlO.ll 2.57xlO.'
TOTAL-1.2.DCA 1.66xlO.1C 5.93xlO.1
Trichloro. Dermal Contac t 3. 39xlO.l0 1.10xlO.1
ethene
Inhalation 1.33x10.1C 5. 44xlO-'
TOTAL-TCE 4. 72xlO.1C 1.6"xlO.1
All Ingestion 1.29xlO.1 1.l1xlO.'
Dermal Contact 8. 49x10.' 1.19xlO.'
Inhalation 3. 25xlO-1C 1. 33x~O.1
TOTAL. All 2.17xlO.1 2.43xlO.'
-54-
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UPPER BOUND CANCER USKS FOR CHILD TJU:SPASSER
Indicator ~ TvtIical Case Vorst Case
Dieldrin Soil Inautlon 2.12dO.' 8. 06dO.'
Deraa1 Contact 2. )6dO.' 6.IOx10.'
TOTAL.Dieldrin 5. lidO.' 1.49xlO.'
Carbon Inhalation 2. IldO.10 ). 04dO.10
tetrachloride 0.1'11&1 Contact 1.05dO.' 9. 24dO.'
TOTAL.CCl. 1.0IdO.' 9. S4dO.'
1.2.Dich1oro. Inhalation 1.37dO.10 1.4 7x10.'
ethane 0.1'11&1 Contac t 1.45xlO.' 1.25xlO.'
TOTAL.l.2.DCA 1.59dO.' 1.39x10.'
Trichloro. Inhalation 1.87dO.11 2.02xlO.u
ethene Oema1 Contac t 4. 74x10.10 4. 06x10.1
TOTAL.TCE 4. 93xlO.10 4. 26xlO.1
All All 6. 42dO.1 3. OblO.'
UPPER IOUND CANCER IlISKS FOR ADULT '1'Il!SPASSER IN SOUTH RAVINE
Indicator ~ TvtIic:al Cue Vorst Case
Aldrin S.d18ent 1uce.tion 4 .11d 0.' 3.4 7dO.'
Chlordane S.d18ent 1uce.tion 1.95dO.' '.69dO.'
Dieldrin S.d18ent 1nce.tion . . tldO.' 1.7IdO.'
Aldrin Demal contact 2. )3dO.' 1.96xlO.'
Chlordane Demal contact 1. l1xlO.' 2 :OblO.'
Dieldrin Demal contact 5.07&10.' 1.0b10.'
Aldrin Total 2.74&10.' 5.4)dO.'
Chlordane Toul 3. 06dO.' 5.7blO.'
Dieldrin Total 1.41dO.' 2. 7IxlO.'
All Total 2. 'ldO.' 5. 'blO.'
-55-
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UPPER aOUND CANCER ~ISKS FOR CHILD TRESPASSER IN SOUTH RAV~NE
Indicator ~ ~ical Case Worst Case
Aldrin Sediment ingestion 8. 96xlO" 1.99xlO.'
Chlorc:i&ne Sediment ingestion 4. 25xlO" 2 .12xlO"
Dieldrin Sediment ingestion 1.95xlO" 1.03xlO.'
Aldrin De mal contact 7. S/txlO" 1.68xlO"
Chlorc:tane De r1I& 1 contact 3. 58xlO" 1.78xlO"
Dieldrin De r1I& 1 contact 1.6/txlO.' 8. 6lxlO"
Aldrin Total 1.65xlO" 3.67xlO.'
Chlordane Total 7. 83xlO" 3. tOxlO.'
Dieldrin Total 3. 59xlO.' 1.89xlO.'
All Total 2. 09xlO" 3. tOxlO"
UPPER BOUND CANCER RISKS FOR ADULT nISPASSER NEAR NORTH RAVINE
Indicator I2J.J.U 'l'wical Cue Maximum Case
Carbon tetrachloride Inhalation 1.4 7xlO.' './tOxlO"
1.2.Dichloroethane Inhalation 7.1OxlO.' 4. OOxlO"
Trichloroethene Inhalation 1.5lxlO.' 8. 6/txlO.'
All Total 3. 69xlO.' 2.1OxlO.'
VPPER BOUND CANCER RISKS FOIt CHIL» nISPASSER NEAR NO~TH RAVINE
Indicator ImIU 'l'VDical Case Maximum Case
Carbon tetrachloride Inhalation 3. 2OxlO.' 4. 94xlO.'.
1.2.Dich1oroethane Inhalation 1.55xlO.' 2. 33xlO.'
Trichloroethene Inhalation 3. 28xlO.' 4. t5xlO.'
All Total '.03xlO.' 1.22xlO"
-56-
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HAZARD INDICES AND UPPD IOtJND CANCD IlISKS FOR Pt}!l1C WATER USERS
Indicator Hazard Index Cancer Risk
Carbon tetrachloride 8. 09xlO.t 7. 36xlO-u
1.2.Dichloroethane NA 3.19xlO.u
Trichloroethene NA 4. 9lxlO-11
HAZARD INDEX ANt) UPPER IOUND CANCER USK FOR IEEF INGESTION
Twical Case
Worst Case
Haurd Index
2.75xlO-Z
0.389
Cancer Ilisk
6. ?4dO.'
3.2?dO.!
-57-
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APPENDIX C
58
-------
FEDERAL HEALTH ADVISORIESl
CHEMICAL
ONE-DAY
(UG/L)
0.3
0.3
TEN-DAY
(UG/L)
LONG-TERM
(UG/L)
ALDRIN
0.3
ARSENIC
BARIUM
5,000
5,000
5,000
CARBON
TETRACHLORIDE
4,000 (C)
70 (C)
300 (A)
0.5 (C)
0.5 (A)
200 (C)
CHLORDANE
60 (C)
60 (C)
CHROMIUM
(TOTAL)
1,000
200 (C)
800 (A)
0.5 (C)
2 (A)
1,000
DIELDRIN
0.5
0.5
1,2-DICHLOROETHANE
700
700 (C)
2,600 (A)
700
LEAD
NICKEL
1,000
100 (C)
600 (A)
1,000
TRICHLOROETHENE
(C)
(A)
DENOTES VALUE DEVELOPED FOR CHILD
DENOTES VALUE DEVELOPED FOR ADULT
LIFETIME
(UG/L)
5,000
100
100
(1)
DRINKING WATER HEALTH ADVISORIES; OFFICE OF DRINKING WATER,
U.S. ENVIRONMENTAL PROTECTION AGENCY; APRIL 1990
59
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SUMMARY OF FEDERAL DRINKING WATER ARARSl
CHEMICAL
MCL
(UG/L)
PROPOSED MCL
(UG/L)
ALDRIN
ARSENIC
50
BARIUM
5,000
CARBON TETRACHLORIDE
5
CHLORDANE
CHROMIUM (TOTAL)
DIELDRIN
50
100
1,2-DICHLOROETHANE
5
LEAD
50
5
NICKEL
100
TRICHLOROETHENE
5
(1)
DRINKING WATER REGULATIONS; OFFICE OF DRINKING WATER;
U.S. ENVIRONMENTAL PROTECTION AGENCY; APRIL 1990
60
MCLG
(UG/L)
o
5,000
o
o
120
o
o
100
o
-------
FEDERAL SURFACE WATER QUALITY CRITERIAl
AQUATIC LIFE
HUMAN HEALTH FRESHWATER
WATER/FISH FISH ACUTE CHRONIC
CHEMICAL CUG/L) CUG/L) CUG/L) CUG/L)
ALDRIN 0.00013 0.00014 3
ARSENIC 0.018 0.14 360 190
BARIUM
CARBON 0.25 4.5
TETRACHLORIDE
CHLORDANE 2.4 0.0043
CHROMIUM (TOTAL) 170 3,400 1,700 210
DIELDRIN 0.00014 0.00014 2.5 0.0019
1,2- 0.38 99
DICHLOROETHANE
LEAD 50 82 32
NICKEL 510 3,800 1,400 160
TRICHLOROETHENE 2.7 81
(1) FEDERAL WATER QUALITY CRITERIA; CLEAN WATER ACT;
U.S. ENVIRONMENTAL PROTECTION AGENCY
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MISSOURI WATER QUALITY STANDARDSl
AQUATIC LIFE DRINKING GROUND WATER
CHEMICAL (UG/L) (UG/L) (UG/L)
ALDRIN 0.000079 0.000074 0.000074
ARSENIC 20 50 50
BARIUM 1,000 1,000
CARBON 5 5
TETRACHLORIDE
CHLORDANE 0.00048 0.00046 0.00046
CHROMIUM (TOTAL) 190 (CHRONIC) 50 50
280 (ACUTE)
DIELDRIN 0.000076 0.000071 0.000071
1,2- 5 5
DICHLOROETHANE
LEAD 29 (CHRONIC) 50 50
190 (ACUTE)
NICKEL 770 (CHRONIC) 200
6,900 (ACUTE)
TRICHLOROETHENE 5 5
(1)
MISSOURI WATER QUALITY STANDARDS; 10 CSR 20-7.031
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RECORD OF DECISION
THE RESPONSIVENESS SUMMARY
WHEELING DISPOSAL SERVICE COMPANY LANDFILL
AMAZONIA, MISSOURI
Prepared by:
U.S. Environmental Protection Aqency
Reqion VII
Kansas City, Kansas
SEPTEMBER 1990
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RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
PAGE
1.0 OVERVIEW 1
2.0 BACKGROUND 1
3.0 SUMMARY OF COMMENTS RECEIVED DURING
PUBLIC COMMENT PERIOD
A. REMEDIAL ALTERNATIVE 2
PREFERENCES/QUESTIONS/CONCERNS
B. REMEDIAL INVESTIGATION 6
QUESTION AND COMMENTS
C. PUBLIC PARTICIPATION PROCESS 8
D. COST/FUNDING ISSUES 9
4.0 COMMUNITY RELATIONS ACTIVITIES 9
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RESPONSIVENESS SUMMARY
WHEELING DISPOSAL SERVICE COMPANY LANDFILL
AMAZONIA, MISSOURI
1.0
OVERVIEW
In the Proposed Plan released to the public, the
Environmental Protection Agency (EPA), with technical concurrence
from the Missouri Department of Natural Resources (MDNR), made a
preliminary selection for the preferred alternative. The EPA's
recommended alternative addressed all contamination in all media
at the site. The preferred alternative involved upgrading the
existing cover over the disposal units, long-term monitoring of
ground water and surface water, implementing site maintenance
activities, using deed restrictions to prevent farming on certain
areas and to prevent drinking onsite ground water, installing
security measures, and closing certain onsite wells.
The comments received from the public during the public
comment period focussed on two main topics: disposal practices
during operation of the landfill and the landfill's impact on
property values. Most comments were presented by residents
living adjacent to the site. No comments were presented which
required modifying the preferred alternative.
The Potentially Responsible Parties (PRPs) submitted several
written comments. The PRPs disagree with certain details in how
the state of Missouri's Solid Waste Act closure procedures should
be considered an Applicable or Relevant and Appropriate
Requirement (ARAR). The PRPs supported the preferred
alternative.
2.0
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Wheeling Disposal Service Company
Landfill (site) dates back to the early 1970's. Due to severe
odor problems associated with the disposal of tannery waste at
the site, the local residents filed complaints with MDNR, state
representatives and congressmen. In 1975, the community
submitted to MDNR a petition with several hundred signatures
asking MDNR to stop the disposal activities at the site.
In 1986 and 1987, several citizen complaints were submitted
to MDNR and to Missouri Department of Health (MDOH) concerning
water quality in private wells.
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3.0
SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
Comments received during the public comment period on the
draft Feasibility study (FS) and Proposed Plan are summarized
briefly below. The comment period was held from August 13 to
September 11, 1990. The comments are categorized by relevant
topics.
A.
Remedial Alternative Preferences/Questions/Concerns
1.
One local resident stated that the selected remedy is
inadequate for closure. The resident believes that the
ground water is contaminated as proven by pesticide
contamination in his private well.
ResDonse
The selected remedy will comply with both EPA and MDNR
landfill closure regulations. These regulations are the
technical standards by which all landfills are closed.
Secondly, risk assessment analysis indicates that the
selected remedy will be protective of human health and the
environment.
The shallow ground water is contaminated onsite. However,
results from the remedial investigation document that the
site has not contaminated offsite ground water at this time.
No pesticide contamination was detected in offsite private
wells during the remedial investigation.
2.
One commenter stated that all onsite water should be kept
onsite. The commenter recommended including onsite dams to
keep the surface water onsite.
ResDonse
Technical justification is required to support each remedial
activity. Remedial investigation results do not indicate
contamination of offsite ground water or surface water due
to the site.
Several stagnant, onsite "seeps" in the north ravine are
contaminated: however, no contamination has been detected
leaving the site in the north ravine. The seeps are, in
fact, stagnant and would require a rainfall to move offsite.
Risk assessment analysis does not indicate unacceptable
risks due to the site's surface water condition.
The selected remedy includes monitoring of both surface
water and ground water, and developing performance criteria
for both media. Remedial activities will be conducted when
monitoring results exceed performance criteria. These
activities may include collection and treatment of surface
water and/or ground water.
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3.
One commenter stated that the local soil is a loess/loam
type which will wash away easily and, thus, not serve
adequately as the cover material.
Response
The source of the cover material has not been determined at
this time. The feasibility study proposes using onsite
soils for the cover material, but the EPA has not approved
of this proposal. The federal and state landfill closure
laws require that the cover minimize infiltration and
maintenance.
4.
One commenter stated that the south, unnamed ravine usually
has flowing water except during the last two years due to
the drought.
Response
5.
Drought conditions existed during the entire remedial
investigation which prevented taking surface water samples
from the south ravine. However, the surface water
monitoring program will be flexible such that surface water
sampling will be conducted in the south ravine if and when
it begins to flow.
A group of PRPs, referred hereafter as the Wheeling Trust,
provided the following comment:
"The preferred alternative designated in any Proposed Plan
is driven by the baseline risk assessment conducted for that
particular site. Public review of any proposed plan will no
doubt produce a wide variety of comments some of which may
propose a more extensive alternative than justified by the
baseline risk assessment.
The Proposed Plan for the Wheeling Disposal site adequately
addresses the risks determined in the site baseline risk
assessment. Some comments concerning the Proposed Plan may
be justified and should be incorporated into the Proposed
Plan. However, other comments which present alternatives
more protective to human health and the environment but are
not justified based upon the risks presented in the baseline
risk assessment should not be incorporated into the Proposed
Plan."
Response
For the Wheeling site, the EPA has followed the remedy
selection process as defined in the National Contingency
Plan. This process is based upon using risk assessment
methods to justify the need for remedial activities. The
selected remedy for the Wheeling site satisfies all risk-
based requirements and protects human health and the
environment.
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6.
The Wheeling Trust provided a comment that it does not
consider the Missouri Solid Waste Management Act (MSWM) to
be an ARAR for the site, and the Wheeling Trust urges EPA to
reconsider their position. Specifically, the Wheeling
Trust's principal objection is that the regulations contain
a discretionary component requiring that landfill closure
plans contain, if not already present at the site, methane
control systems, leachate collection systems, and/or ground
water monitoring wells if deemed necessarY by MDNR. As a
result, if the MSWM regulations are selected as ARARs, in
effect, EPA will be rewriting these regulations to
substitute EPA's iudqement over the MDNR for the
discretionary component of the regulations.
Response
In order for a state law, standard, or regulation to become
an ARAR, it must be applicable or relevant and appropriate
and more stringent than a federal law, standard, or
regulation. State ARARs were included in CERCLA for the
purpose of achieving the higher level of protectiveness in
states where the state standard is higher than the federal
standard. When EPA adopts a state ARAR, it is adopting the
substantive requirements of the state law, standard or
regulation. The procedural requirements of the particular
state law, standard or regulation are not relevant to the
level of cleanup and are therefore not adopted. The thrust
of the Wheeling Trust's objection is that the procedural
requirements of the state ARAR will not be followed. This
objection is simply not relevant. The EPA is adopting the
substantive requirements of state law by requiring the
state's regulations on landfill closure be implemented.
Since these regulations requiring leachate collection
systems and ground water monitoring, if necessary, are
stricter standards than the federal standards which do
impose such requirements, EPA is achieving the desired
of implementing the law that requires the higher level
protectiveness.
not
goal
of
7.
In response to EPA's statement that Wheeling Disposal
Service did not follow closure procedures that subsequently
became law, the Wheeling Trust provided a comment that the
Wheeling Disposal Service did follow procedures addressed in
the MSWM, except for the submittal of a formal closurejpost-
closure plan. The disposal units at the site were covered
with clayey soil and vegetation was established to help
minimize erosion, control drainage, and provide a pleasing
appearance.
Response
The MSWM states that to prevent a solid waste disposal area
from being a blight on the land, a hazard to health and
safety, an air pollution problem or a source of pollution to
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any water course, the owner/operator of any solid waste
disposal area shall obtain approval of the method of closure
prior to closure. Placement of cover and establishment of
vegetation in such a manner as to minimize erosion, control
drainage and provide a pleasing appearance is but a part of
the closure procedure. Also, if deemed necessary,
installation may be required for a methane control system,
leachate collection system and/or a ground water monitoring
well system. Finally, post-closure plans shall include
maintenance and monitoring activities to be performed.
8.
The Wheeling Disposal Service did not submit a closure or
post-closure plan. As a result, post-closure monitoring of
the site was not implemented by Wheeling Disposal Service
and, in effect, human health and the environment were not
protected as hazardous substances were allowed to migrate
potentially undetected.
The Wheeling Trust commented that EPA has incorrectly
described the monitoring of ground water and surface water
as a requirement under the MSWM. Review of the MSWM shows
that this is not the case. The monitoring of ground water
is an activity which may be implemented if deemed necessary.
Surface water monitoring is not even considered in this
regulation.
Response
9.
Factually, the Wheeling Trust's comment is correct and the
Record of Decision reflects the change in language regarding
the MSWM ARAR. However, this change does not affect the
selected remedy. Both MDNR and EPA deem ground water
monitoring to be necessary at the site. Also, the MSWM
states that the method of closure for a site shall prevent a
solid waste disposal area from being a hazard to health and
safety, among other things. Due to the documented surface
water contamination in the north ravine, both MDNR and EPA
deem surface water monitoring to be necessary to prevent the
site from being a hazard to health and safety.
The Wheeling Trust commented that the Proposed Plan
inaccurately summarized the monitoring program presented in
the Wheeling Disposal site Feasibility Study. The Proposed
Plan failed to mention that two surface water samples were
proposed in the monitoring program in addition to the two
seep water samples.
Response
The Wheeling Trust's comment is correct and the Record of
Decision reflects this change in description. However, this
change does not affect the selected remedy in that a
detailed surface water monitoring program has not been
approved by the EPA at this time.
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11.
10.
The Wheeling Trust commented that although none of the
alternatives presented in the Proposed Plan address
conventional treatment technologies, they do possess
treatment of mobility through natural attenuation. During
ground water movement through the subsurface, contaminants
will adhere to the soil particles reducing their mobility in
the ground water.
This mobility treatment through natural attenuation is
discussed in the EPA responses to the NCP comments. In
their response, EPA has recognized the benefit of natural
attentuation as a treatment for mobility, especially in
circumstances involving excessive time periods for
conventional treatment such as pump and treat.
ResDonse
Clearly stated in the NCP preamble (55 Federal Register No.
46, March 8, 1990, Page 8701), CERCLA's preference for
achieving protection is through the use of treatment
technologies that destroy or reduce the inherent hazards
posed by wastes and result in remedies that are highly
reliable over time. The purpose of treatment in the
Superfund program is to significantly reduce the toxicity
and/or mObility of the contaminants posing a significant
threat wherever practicable and to reduce the need for long-
term management of hazardous material.
The selected remedy for the Wheeling site does not reduce
the toxicity of the contaminants and does not significantly
reduce the need for long-term management of hazardous
material; in effect, the selected remedy for the wheeling
site does not involve treatment as defined in the NCP.
However, the Wheeling selected remedy does reliably protect
human health and the environment over time through effective
use of institutional and containment measures.
B.
Remedial Investiqation Questions and Concerns
Many comments were provided by various residents living near
the site concerning the disposal practices during operation
of the site. In essence, the nearby residents suspect that
unpermitted disposal practices were conducted by Wheeling
Disposal Service such that unpermitted wastes were disposed
at the site and that unpermitted disposal units were used.
ResDonse
Types of wastes and disposal areas were defined by the MDNR
permits for the site. MDNR conducted two inspections before
the site was permitted, 22 inspections during the years the
site was in operation, and two post-closure inspections.
These inspections identified several violations of the
permits such as inadequate daily coverage of wastes with
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12.
13.
clay, improper construction of new disposal trenches and
improper disposal of wastes. Also, EPA conducted several
inspections and conducted an aerial photography study of the
site. Finally, during the remedial investigation, a
magnetometry study was conducted to identify the locations
of disposal units: results from this study did not indicate
unknown disposal units. The net effect of these inspections
and studies confirms that the locations of disposal units
are well known for this site.
The selected remedy includes a surface water and ground
water monitoring program. This program will detect all
contaminants - permitted or unpermitted - which are
migrating from this site. Relative to the permitted wastes
known to have been disposed at the site, the EPA does not
expect that an unpermitted waste, if detected, would change
the risk assessment and, subsequently, to require modifying
or changing the selected remedy.
One commenter asked how the remedial investigation found the
offsite ground water to be uncontaminated when a 1987 State
report determined that the site was contaminating offsite
ground water.
ResDonse
In response to several citizen's concerns with ground water
quality around the site, the Missouri Department of Health
(MDOH) conducted a ground water and surface water study in
the vicinity of the site during 1987. The MDOH study
concluded that ground water and surface water in the area
exceeds aesthetic drinking water criteria for several
metals, but did not determine that the site was the source
of the contamination. In agreement with the MDOH study, the
remedial investigation found that ground water in the area
would exceed drinking water standards for several naturally
occuring metals if the wells are not effectively filtered.
Several commenters inquired if a cancer cluster study and
thyroid disease study had been conducted for the area near
the site.
ResDonse
The Missouri Department of Health (MDOH) has reviewed the
health status of the population living near the site. A
review of mortality and natality rates for the zip codes
around the site showed no rates statistically significantly
higher than the site rate. In addition, MDOH conducted
health interviews with the twenty families living closest to
the landfill. No discernible patterns of illness were
detected.
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15.
14.
Several commenters expressed concern that the remedial
investigation reports are biased since they are written by
the Potentially Reponsible Parties (PRPs).
ResDonse
The PRPs signed an agreement with the EPA to conduct the
remedial investigation (RI) and write the RI and Feasibility
Study (FS) reports. This agreement specifies that the PRPs
are required to conduct the study and write the reports in
compliance with the National Contingency Plan (NCP). All
workplans for the study were reviewed by the EPA and MDNR.
The EPA and MDNR conducted oversight of all field
activities, including sampling. Quality assurance
procedures were taken by the EPA such as taking split
samples and analyzing the samples at a different laboratory
than the laboratory used by the PRPs. All reports were
reviewed by the EPA, professional consultants under contract
to the EPA, MDNR and MDOH. In effect, the EPA considers the
RI and FS reports to be accurate, factual and of acceptable
quality upon which to base a decision.
c.
Public Participation Process
During the public meeting, many questions covering many
different topics were asked. The EPA, MDNR and/or MDOH
answered most of the questions in the public meeting. These
questions and responses were documented in the transcript
for the public meeting which has been included in the
administrative record for the site.
One commenter asked how the State could permit the Wheeling
site without community involvement.
ResDonse
MDNR personnel involved with the site at the time of
permitting did not recollect any public involvement or
participation regarding the permitting of the landfill.
There were no regulations in effect at that time that would
have required such participation.
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D.
cost/punding Issues
16.
Several commenters inquired as to who is going to reimburse
the residents for lost property value.
ReSDonse
The Superfund law authorizes specific funds to be used for a
specific purpose and that purpose is to investigate and
cleanup hazardous waste around the country. Devalued real
estate due to hazardous waste sites is a problem: however,
the Superfund law does not include authority to address this
problem.
4.0
COMMUNITY RELATIONS ACTIVITIES
community relations activities conducted at the Wheeling
Disposal Service Company Landfill site during the remedial
investigation have included:
The EPA conducted interviews with residents near the site in
April 1988. The interviews were used in developing a
community relations plan for the site.
The EPA released a fact sheet to interested citizens and to
local newspapers in February 1989 which described that a
remedial investigation eRI) had begun and what the RI would
involve.
The EPA met with the city councils of Savannah and Amazonia
on July 9, 1990 to present the results of the RI and to
inform them of the upcoming ROD process and schedule.
The EPA released the administrative record, which included
the Proposed Plan for public review and comment on August
13, 1990. Public notices of this event were placed in local
newspapers.
The EPA and MDNR held a public meeting at the Clasbey
Community Center in Savannah on August 29, 1990 to describe
the RI/FS and the proposed plan, and to respond to citizen's
questions. Approximately 50 people attended, including
citizens, an elected official, and technical representatives
of the PRPs. A transcript of this meeting will be placed in
the administrative record.
The 30 day pUblic comment period ended on September 11, 1990
without a request for an extension.
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