PB94-964315
EPA/ROD/R07-94/077
February 1995
EPA Superfund
Record of Decision:
Obee Road (O.U. 1),
Hutchinson, KS
6/30/1994
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VII
726 MINNESOTA AVENUE
KANSAS CITY, KANSAS 66101
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KEMORANDPM
SUBJECT: Record of Decision for the Obee Road Landfill Subsite,
Obee Road Superfund Site, Hutchinson, Kansas
FROM: Michaer C^/sShderson, Acting Director
Waste Management Division
TO: Dennis Grams, P.E.
Regional Administrator
The attached Record of Decision presents the proposed remedy
for the final remedial action at the subject subsite. This
remedy will monitor the ground water at the Landfill Subsite on
an annual basis and includes a contingency for further action if
the monitoring indicates releases of contaminants above the Safe
Drinking Water Act Maximum Contaminant Levels-MCLs. The remedy. .
also provides for institutional controls to include access
restrictions and deed restrictions.
The selected remedy in this Record of Decision has been
coordinated with the Office of Regional Counsel, the Office of
Public Affairs, the Congressional and Intergovernmental Liaison,
the Agency for Toxic Substances and Disease Registry and the
Kansas Department of Health and Environment.
On December 27, 1990, the remedy selection authority for the
•Obee Road Landfill Subsite was delegated to you by Don R. Clay,
Assistant Administrator. I recommend approval of the proposed
remedy.
Attachment
RECYCLE .
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OBEE ROAD LANDFILL SUBSITE
OBEE ROAD SUPERFUND SITE
RECORD OF DECISION DECLARATION
SITE NAME AND LOCATION
Obee Road Landfill Subsite
Hutchinson, Kansas (Reno County)
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected final remedial action
for ground water monitoring, institutional controls and provides a
contingency for further action if the ground water monitoring
detects contamination and a containment and treatment system needs
to to be implemented at the Obee Road Landfill Subsite, Hutchinson,
Kansas, chosen in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Super fund Amendments and Reauthorization Act of 1986
(SARA), 42-U.S.C. Section 9601 et sea. . and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300.
This decision is based on the administrative record for the Obee
Road Landfill Subsite, Hutchinson, Kansas.
The United States Environmental Protection Agency (EPA) and the
Kansas Department of Health and Environment (KDHE) agree on the
selected remedy.
ASSESSMENT OF THE SITE
The actual or threatened release of hazardous substances at or from
this site, if not addressed through the implementation of the
response actions selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Remedial Investigation/Focused Feasibility Study (RI/FFS),
conducted by the Obee Road Potentially Responsible Party (PRP)
Group from March, 1990 to February, 1994 at the Obee Road Landfill
Subsite indicated essentially no risk at the site at the time of
the RI but historical data indicated the landfill was a source of
ground water contamination in the past and there may be a potential
for future releases by leaching unknown sources within the
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landfill.
The selected remedy for the subsite is Institutional
Controls/Ground Water Monitoring with a contingency for further
action. This alternative includes: ground water monitoring,
Landfill access restrictions, and Landfill deed restrictions with
a contingency for further action. Ground water monitoring is used
to detect contaminant presence and migration at the Site.
The ground water monitoring program would include annual sampling
for a five-year period with VOC analysis of the following
monitoring wells:
MW-9S (Upgradient) MW-5S (Downgradient)
MW-3 (Landfill) MW-6 (Downgradient)
MW-4 (Landfill) . MW-10S (Downgradient)
MW-5 (Downgradient) MW-10D (Downgradient)
A contingency for further action is also a part of the selected
remedy in the event that ground water contamination increases in
the future and is found to be migrating off-site at concentrations
above the current Maximum Contaminant Levels (MCLs) under the Safe
Drinking Water Act (SDWA) for aquifers which may be used for
drinking water purposes. The contingency would include the
evaluation of appropriate responses for the -containment and
treatment of the ground water to meet the ARARS. The remedy under
the contingency could "include extraction well(s) for containment
and air stripping tower(s) for treatment of the extracted ground
water. The effluent from the stripping towers would be governed by
the National Pollutant Discharge Elimination System Permit and any
additional treatment of exhaust vapors from the air stripper(s)
would be determined after monitoring the vapors at the start-up of
the air stripper(s). Access and deed restrictions include
minimizing Landfill access by trespassers and preventing future
development of the Landfill. These access and deed restrictions
would be implemented by the City of Hutchinson, who currently owns
the landfill property. This reduces the potential for contaminant
exposure from contact.with or disturbance of .the Landfill cover and
its contents. 'Fencing and access restrictions are already in place
at the Landfill.
The selected remedy will protect human health and the environment
by using ground water monitoring to detect future contamination of
ground water at the Site; by responding with additional action to
contain and treat the contamination if any is detected; and by
establishing deed restrictions which would prevent disturbance of
the Landfill cover and its contents.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
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solutions and because this remedy monitors the ground water so as
to detect any hazardous substances remaining on-site above levels
that allow for unlimited use and unrestricted exposure, a review
will be conducted no less often than every five years after
commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health .and the environment.
~, P. E s -•' w7 VT D&te
RegionalAdministrator
U.S. EPA - Region VII •
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RECORD OF DECISION
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OBEE ROAD LANDFILL SUBSITE
Hutchinson. Kansas
JUNE 1994
U.S. Environmental Protection Agency
Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
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TABLE OF CONTENTS
1.0 SITE BACKGROUND 1
1.1 Site Location 1
1.2 Physical Setting 1
1.3 History 2
1.4 Past Investigations and Remedial Activities 2
1.5 Highlights of Community Participation 4
1.6 Summary of the Remedial Investigation 5
1.6.1 Activities 5
1.6.2 Conclusions 6
2.0 SUMMARY OF SITE RISKS 7
2.1 The Baseline Risk Assessment 7
2.2 Contaminant Transport 9
2.3 Ecological Risks 10
3.0 SCOPE AND ROLE OF RESPONSE ACTION 10
4.0 SUMMARY OF ALTERNATIVES ' 11'
4.1 Screening and Formulation of Alternatives 11
4.2 Detailed Evaluation of Remedial Alternatives 11
5.0 EVALUATION OF ALTERNATIVES 12
5.1 Summary of Evaluation Criteria . 12
5.2 Evaluation of the Alternatives 14
6.0 SELECTED REMEDY 17
7.0 STATUTORY DETERMINATIONS IB
8.0 RESPONSIVENESS SUMMARY 21
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ATTACHMENTS
Attachment I -
Attachment II -
Glossary of Terms
Comment and Response Letters
FIGURES
Figure I - Site Location Map
Figure 2.- Obee Road Site Area and Land Use Map
Figure 3 - Monitoring Well Locations in Obee Road Site Area
Figure 4 - Analytical Results of Soil Samples From Landfill
Figure 5 - VOCs in Ground Water
TABLES
Table 1 - KDHE Ground Water Sampling Results
Table 2 - Estimated Costs for the Selected Remedy
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1.0 SITE BACKGROUND
1.1 SITE LOCATION
The Obee Road Landfill Subsite is a part of the Obee Road
Superfund Site located within the area of the former City of
Hutchinson Landfill east of Hutchinson, Kansas. The
approximate boundaries of the Subsite are defined as "the
eastern one-half of Section 10, Township 23 S, Range 5 W, Reno
County, Kansas, and those areas south of the eastern one-half
of Section 10 up to 100 feet south of 4th Street (see Figure
2) . The landfill area is currently covered with vegetation
and encompasses approximately 80 acres. The relationship of
the Landfill Subsite to the Obee Road Superfund Site is also
shown on Figure 2.
The Landfill Subsite is bounded by the Hutchinson 'Municipal
Airport along the north and west, Obee Road and a residential
area along the east, and residential/agricultural areas to the
south. The Obee School, an elementary school, is located
immediately south of the Landfill Subsite. A large area of
residences is located further south of the Landfill Subsite
and includes about 102 homes and 280 residents.
1.2 PHYSICAL SETTING
The Obee Road Superfund Site is located in -the Great Bend.
• Lowland within the Great Bend Prairie physiographic province.
The Site lies on a low terrace approximately 5 miles north of
. the Arkansas River. The topography at the Site does not vary
greatly. Northeast of the City of Hutchinson and adjacent to
the northeast portion of the Site is a belt of sand dunes
which marks the boundary of the north side of the Arkansas
River Valley. The former landfill area is currently fenced
with chain-link fencing, and is heavily vegetated by brush and
trees with minor areas of subsidence apparently caused by
landfill operations.
Ground water in the region comes primarily from unconsolidated
alluvial deposits of Quaternary age. These deposits overlay
Permian bedrock in the Site area. The depth of the alluvial
deposits ranges from 28 to 66 feet; and the average depth to
ground water is 17 feet. The direction of ground water flow
in the alluvial aquifer at the Site is generally southeast,
although, there is significant variation in the northern site
area. In the northeast portion of the site, the ground water
flows to the southwest down the bedrock surface slope then
turns to the southeast.
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1.3 HISTORY
The now-closed City of Hutchinson Landfill was operated from
1953 to 1968 and was the only public disposal site in
Hutchinson during that time. Prior to closure, the landfill
received typical domestic wastes and unknown quantities and
types of industrial wastes. Disposal generally occurred on a
daily basis, with the wastes being placed in trenches
approximately 14 to 15 feet in depth. There was no
differentiation between the disposal of liquid or solid
wastes. No records or reports have been found to document the
design, use, or closure of the landfill.
As a result of investigations, which began in 1983, the Kansas
Department of Health and Environment (KDHE) proposed the Obee
Road Site for inclusion onto the National Priority List (NPL)
in August 1985. The Obee Road Site, which encompasses both
the Obee Landfill Subsite and the Airport Road Subsite (see
Figure 2), was placed on the NPL on July 22, 1987 by EPA
pursuant to its authority under CERCLA as amended by SARA. A
consent agreement between KDHE and the Obee Road PRP Group was
executed on March 27, 1990 to perform a Remedial
Investigation/Feasibility Study (RI/FS) for the Obee Road
Site.
The consent agreement was later amended in March of 1993 to
focus only on the Obee Landfill Subsite. The amendment was
made due to the division of the Obee Road Site into two
subsites following KDHE and EPA review of the results of the
Phase II investigation. The data from this investigation,
performed under the Obee Road Site RI, indicated that the
Landfill area could clearly be separated from the area of 4th
and Airport Road. The Landfill was not found to be a
significant .spurce of ground water contamination, but KDHE and
EPA determined that the 4th and Airport Road area required
further investigation.
1.4 PAST INVESTIGATIONS
KDHE has conducted periodic investigations and sampling
activities in the vicinity of the Obee Road Site since July
1983. These investigations were initiated as a result of a
citizen's complaint of disagreeable tastes and odors in a
domestic water well. KDHE's sampling of selected private
wells identified volatile organic compounds (VOCs) in the
aquifer, which at the time provided a ground water supply for
private domestic wells in the area. City water supply wells
are located upgradient and approximately two-plus miles from
the Obee Road site area.
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In August and September of 1983, KDHE sampled a number of
private wells in the site area. All of the ground water
samples were analyzed for VOCs. Several of the samples were
analyzed for inorganics, heavy metals, polychlorinated
biphenyls (PCBs)/pesticides, and/or acid-extractable and base-
neutral compounds. An expanded sampling effort of private
wells was conducted in January 1984, with the samples being
analyzed for inorganics, heavy metals and VOCs.
The results of the KDHE sampling of private wells in 1983 and
1984 indicated that VOCs were present in ground water in the
Site area. The following VOCs were detected at levels ranging
from detected (but not quantifiable) to 12 micrograms per
liter (ug/1) : vinyl chloride,. dichloromethane, 1,1-
dichloromethane, trans 1,2-dichloroethylene, trichloromethane,
1,1,1-trichloroethane, tetrachloromethane, trichloroethylene,
benzene, dibromochloromethane, 1,1,2,2-tetrachloroethylene,
toluene, and chlorobenzene. Many of these VOCs were detected
at levels greater than the allowable State (Kansas Action
Levels or KALs) and federal (Maximum Contaminant Levels or
MCLs) drinking water standards.
The majority of area residences and the Obee Elementary
School, which had previously used private water wells for
domestic purposes, have been connected to the public water
supply system. The remaining residents have been encouraged
to hook up to the system and KDHE is working with the county
health department to establish a monitoring program for
outlying residents still on private water wells. No
contamination above MCLs has been detected in any well water
currently being used by residents in the area.
In July and August 1984, KDHE installed eight monitoring wells
in the Site vicinity (see Figure 3) . Four wells were screened
in the intermediate portion of the aquifer and four wells were
screened in the interval just above bedrock. The KDHE
monitoring wells were sampled in August 1984, April and May
1985, and August. 1986 for.VOCs and/or.inorganics and heavy
metals. The results of the analyses of samples for the KDHE
monitoring wells confirmed VOC contamination in the ground
water (see Table 1). KDHE completed a Preliminary Assessment
(PA) on July 31, 1987. The results of the PA concluded that
the extent of ground water contamination had not been
sufficiently characterized and that the former Hutchinson City
Landfill was one of the potential sources of the ground water
contamination found in the area.
A shallow soil gas survey was conducted by Tracer'Research
Corporation in August 1986 under the direction of KDHE. The
purpose of the soil gas survey was to determine the
approximate extent and magnitude of VOC contamination in the
vicinity of the Obee Road site. The soil gas survey results
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were presented to KDHE by Tracer Research Corporation in a
report entitled "Soil Gas Survey of Five Kansas Sites", dated
August 1986. The results of the survey indicate that VOCs may
be present in the vicinity of the Landfill and near the 4th
Avenue and Airport Road intersection.
A separate investigation is currently underway at another
site, East 4th Street Facility (Cessna/Eaton), which is about
a quarter mile south of 4th Avenue and Airport Road on the
west side (Figure 2). Further investigation is necessary for
the Airport Road Subsite of the Obee Road Site and'the East
4th Street Facility Site, to determine the source(s) and
extent of contamination in these areas.
1.5 HIGHLIGHTS OF COMMUNITY PARTICIPATION '
Community participation was provided in accordance with
CERCLA, as amended by SARA and the National Contingency Plan
(NCP). Community participation highlights include the
availability of several key documents in the administrative
record, a public comment period and a public hearing.
A community relations plan for the Obee Road Superfund Sites
completed and approved in May of 1991. .This .document lists
contacts and interested parties throughout government and the-
local community and specifies the community relations
activities expected to be undertaken during the remedial
process. It also establishes communication pathways to ensure
dissemination of pertinent information.
The administrative record for Obee Road Site was released in
April of 1991. The records have been made available to the
public at the following addresses:
Kansas Department of Health and Environment
Bureau.of Environmental Remediation ' • •
Forbes Field, Building 740
Topeka, Kansas 66620-7500
913-296-3393
Hutchinson Public Library
901 North Main
Hutchinson, Kansas
United States Environmental Protection Agency
Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
913-551-7000
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A press release was issued on March 3, 1994 announcing the
release of the Proposed Plan, commencement of the public
comment period and notice of the Public Hearing for the Obee
Road Landfill Subsite.
The Public Hearing was held on March 31, 1994 to present the
Proposed Plan and to receive comments. At this meeting
representatives of EPA and KDHE were available to answer
questions and record comments concerning the Proposed Plan.
All comments received by EPA and KDHE throughout the comment
period are addressed in the Responsiveness Summary in this
Recprd of Decision.
1.6 SUMMARY OF THE REMEDIAL INVESTIGATION
1.6.1 ACTIVITIES
The objectives of the RI included: (1) the definition of the
nature and extent of contamination in ground water emanating
from the Landfill; (2) the definition of the nature and extent
of contamination in the surface soils at the Landfill; (3) the
identification of any possible sources of contamination; (4)
the characterization of the Site geohydrology; and (5)
evaluation of the Site's existing and potential threat to
human health and the'environment. •
The RI activities were divided into three phases. Phase I
included preparation of the Workplan and other planning
documents necessary for the implementation of the RI. The
KDHE monitoring wells were sampled in February 1991 (Phase I)
to aid in developing the scope for the RI/FS (see Table 1 for
results). Phase II included initial field investigation of
soil and ground water. Phase III included further field
investigation of soil and ground water and was necessary to
characterize contamination at the Site.
During the Phase II investigation, six landfill soil samples
were collected in the upper 1 foot of soil cover and were
analyzed for VOCs, semi-volatile organic compounds (SVOCs),•
metals, and pesticides/PCBs. The purpose of the collection of
soil samples in the Landfill cover was to evaluate the level
of contaminants in the .surface soil to .determine their
possible effects on human health and the environment, and to
evaluate the physical integrity of the soil material covering
the Landfill.
During the Phase III investigation, six shallow soil samples
were collected from the Landfill and analyzed for PCBs.
Boring LB-1 (Figure 3), where Arochlor-1254 was detected in
the Phase II investigation, was resampled at a shallow depth
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and samples were also collected from four additional locations
in the vicinity of Boring LB-1. These samples were taken from
a depth of about two to three inches.
Eight monitoring wells were constructed during the RI to
screen different portions of the aquifer to determine the
vertical, as well as lateral, distribution of dissolved
contaminants. Six shallow wells and two deep wells were
constructed in addition to the three KDHE intermediate wells
and .two KDHE deep wells (see Figure 3). Three wells (MW-8S,
MW-9S, MW-14S, MW-7, and MW-14D) upgradient of the Landfill,
five wells (MW-5S, MW-10S, MW-17S, MW-5, MW-10D) downgradient
of the Landfill, and three wells (MW-4, MW-6, MW-3) underneath
the Landfill, were used to characterize ground water
contamination at the Site.
Two separate rounds of ground water samples were collected
from the monitoring wells constructed during the RI and the
five previously constructed KDHE monitoring wells (MW-4, MW-6,
MW-3, MW-5, and MW-7). These samples were analyzed for VOCs
during the RI. Phase II ground water sampling was conducted
.from September 18 to October 15, 1991, and Phase III sampling
was conducted from May 11 to May 14, 1992. Samples were
collected from wells MW-5S (downgradient) and MW-8S
(upgradient) and analyzed for PCBs, pesticides, SVOCs, metals
(filtered and unfiltered), and total suspended solids during
.the Phase II investigation. No samples were collected for
metals analyses during the Phase III investigation. In
addition, six water table borings were sampled and analyzed
for VOCs during Phase II (also indicated on Figure 3).
1.6.2 CONCLUSIONS
Tetrachloroethene (PCE) was detected in all Landfill soil
samples at levels ranging from 13 to 54 ug/kg. Levels of
metals detected in the Landfill cover material are within
established ranges of metals in uncontaminated soils. No
pesticides were detected in-any shallow Landfill samples. The
PCB, Arochlor-1254, was detected in the sample analyzed from
Boring LB-l at a level of 1200 ug/Kg. PCBs were not detected
in any other samples during the Phase II investigation. No
PCBs were detected in the Phase III soil samples. Figure 4
illustrates the locations and results of the soil samples.
RI results for PCBs in soil indicate that the presence of PCBs
in the soil cover at the Landfill is limited to an isolated
occurrence at a depth of greater than. 6 inches below ground
surface. Although the PCE detected in the soil is probably
evidence of past waste disposal at the Landfill, a pattern was
not apparent in the lateral distribution of PCE in the soil.
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The Phase II ground water sampling results indicated low
levels of the common laboratory contaminants methylene
chloride and acetone in six well samples, which included one
upgradient sample. Two trip blank samples also contained low
levels of methylene chloride and acetone. Benzene was
detected in samples from MW-4 and MW-3 at levels of 1 ug/1 and
3 ug/I, respectively. Chlorobenzene was detected in the
sample from MW-3 at a level of 4 ug/1. No other VOCs were
detected in any of the samples.
The SVOC, bis(2-ethylhexl)phthalate, a common laboratory
contaminant, was detected at low levels in both ground water
samples analyzed during Phase II. These levels were
considered insignificant and no further analyses for SVOCs was
considered necessary. PCBs and .pesticides were not detected
in ground water samples during Phase II. No further analyses
for pesticides were considered necessary. However, since PCBs
were detected in soil samples at the Landfill, further samples
were collected at wells MW-10S and MW-3 and analyzed for PCBs.
The Phase III ground water sampling results also indicated low
levels of the common laboratory contaminant methylene chloride
in three well samples. Vinyl chloride was detected at a level
of 2 ug/1 in upgradient well MW-9S. No other VOCs were
detected in any of the samples. Figure 5 illustrates the VOCs
detected in ground water samples during the RI. No PCBs were
dete'cted in the two samples analyzed during Phase III.
Some of the metals found in the unfiltered ground water
samples were at levels exceeding the KALs and MCLs for
drinking water. However, since these levels were present in
samples from upgradient and downgradient wells, it appears
that the Site does not significantly contribute to the metals
found in the unfiltered ground water samples. Laboratory
results for filtered samples were all below the KALs and MCLs,
indicating that sediment in the unfiltered samples contributed
significantly to the. findings.
2.0 SUMMARY OF SITE RISKS
2.1 THE BASELINE RISK ASSESSMENT
As part of the RI, a baseline Risk Assessment (BRA) was
prepared for the Site. The risk assessment was carried out to
characterize', in the absence of remedial action (i.e., the
"no-action" alternative), the current and potential threats to
human health and the environment that may be posed by
contaminants migrating in ground water, released to the air,
leaching through the soil, or remaining in the soil, or
bioaccumulating in the food chain.
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The baseline risk assessment is an evaluation of the potential
threat to human health and the environment in the absence of
any remedial action. It provides information to help
determine whether remedial action is necessary at the site.
A baseline risk assessment was conducted for this site to
determine the potential effects on human health and the
environment.
One of the chemicals of concern identified and evaluated for
the . Site included tetrachloroethylene (PCE) for soil.
Contaminant levels in ground water samples at the Site were
found to be within the State and federal drinking water
standards. Therefore, chemicals of concern for ground water
(vinyl chloride and methylene chloride) were evaluated using
ground water transport modeling to determine their potential
for migration.to off-site areas.
Pathways by which humans could be exposed to the chemicals of
concern at the Site were evaluated based on reasonable
assumptions about current and future land uses. Since access
to the Landfill/airport area is restricted by 8-foot fencing,
the number and types of people who may be directly exposed to
soil at the Landfill are limited. However, the potential for
trespassing was not eliminated entirely.
None of the chemicals at the Landfill were detected .in
surficial soil, and' since excavation by a trespasser was.
considered unlikely, dermal contact with or ingestion of
chemicals of potential concern were not considered as pathways
of concern. Dust generation at the Landfill is not considered
significant since the Landfill is well vegetated. Therefore,
inhalation of chemicals in dust particles was not considered
a likely exposure pathway.
The only pathway evaluated for the risk assessment
calculations was inhalation of volatiles escaping from
subsurface soil by the trespasser and resident scenarios.
These were evaluated according to current and future exposure
probabilities.
A Hazard Index (HI) was calculated for each pathway evaluated.-
A HI of less than 1 indicates that the noncarcinogenic risks
associated with that pathway are low. The hazard index
calculated for inhalation of PCE by a child trespasser is
0.0000002 (2x10-7) or 2E-7 in scientific notation. Since
there is no other suspected exposure pathway, this is also the
total HI. The HI calculated for a child resident potentially
exposed to PCE vapors migrating off site in the air is 6E-7.
Therefore adverse noncancer health effects for a child
trespasser or nearby resident are not expected since the HI is
well below 1.
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The carcinogenic risks were.'also calculated for all identified
pathways at the Site. The carcinogenic risk from exposure to
a chemical is described in terms of the probability that an
individual exposed for his/her entire lifetime will develop
cancer. Risk estimates are presented as excess cancer risk
per unit of population. For example, a risk estimate of 1 X
10-4 is equivalent to a risk of one excess occurrence of
cancer per 10,000 individuals in a given population.
The -total cancer risk associated with exposure for a child
trespasser for inhalation of vapor-phase PCE is 3E-12, which
is far below a level of health concern. The pathway and total
cancer risk (including the residential scenario) for
inhalation of vapor phase PCE is 1E-11, and is again well
below a level of health concern.
The findings of the baseline Risk Assessment for the site data
indicate that there are essentially no risks to human health
or the environment according to current Site conditions.
2.2 CONTAMINANT TRANSPORT
The potential source of contaminants is the area of the former
City Landfill where unknown types and quantities of waste were
disposed. There are many physical, chemical, and biological
processes which may affect the transport and fate of
contaminants in the soil and ground water. The RI evaluated
these processes for each contaminant of concern in order'to
determine the potential for migration of contaminants from the
Site.
PCE was detected at low levels in the Landfill cover soil.
These levels are expected to decrease in the future primarily
due to volatilization to the air. Leaching of PCE into ground
water may also occur. However, due to the low levels detected
at the Site, the rate of release is not expected to pose a
ground water or air exposure concern.
The PCB, Arochlor-1254, was detected under the Landfill soil
cover. However, follow-up sampling indicated that this
occurrence was isolated. The physical and chemical
characteristics for Arochlor-1254 include a very low
solubility in water and a strong tendency to adsorb to soil.
Therefore, this contaminant is not expected to leach into
ground water. The probable fate of Arochlor-1254 will be to
remain relatively immobile in the soil.
Vinyl chloride and methylene chloride were detected in ground
water at low levels. Although these compounds have medium to
high tendencies to volatilize to air, the relatively low
levels found in the ground water and in the fine-grained
material above the water table would limit the movement from
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the ground water to air. Since these soluble compounds are
relatively mobile in ground water, contaminant transport
modeling was performed to assess their potential occurrence at
downgradient locations. The closest potential receptor
location evaluated during the study was the Obee Elementary
School. The model results indicated that the levels of vinyl
chloride and methylene chloride would be insignificant
(undetectable) by the time the contaminant migrates to the
closest receptor.
2.3 ECOLOGICAL RISKS
A biological survey of the Site and adjacent areas was
conducted to describe the potential receptors and the
overlying ecology of the area. .The survey was performed by
walking the Site, recording plant and animal species present,
and making general observations on plant community
successional stages (range condition), soil series, and soil
condition. In addition, a review of pertinent literature was
made.
The primary contaminant threat to plant and wildlife species
at the Site are PCBs found in the soil. Although there is
very limited data concerning the effect of PCBs on plants and
wildlife, the general information indicates that the level and
isolated incidence of the contaminant would not threaten the
existence of the current plant and wildlife population.
All of the threatened or endangered species for the county are
migratory birds. These birds, most likely, would be present
in the vicinity of lakes, rivers, streams, and wetlands, of
which the Site contains only narrow, intermittent drainage
ditches. Further, the risk to aquatic life from contaminants
found at the Site is not of concern since there are no
apparent transport mechanisms that could account for movement
of significant quantities of the contaminants to nearby
aquatic communities.
3.0 SCOPE AND ROLE OF RESPONSE ACTION
As discussed in the Baseline Risk Assessment the conditions
existing at the time of the RI indicated that essentially no risk
exists at the site but the remedial response objectives were
developed for the following reasons:
/
Historical KDHE sampling data has indicated the Landfill may
have been a source of ground water contamination in the past.
Since the materials disposed of in the Landfill are unknown,
there may be a potential for future leaching from the
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Landfill.
Therefore the following remedial response objectives have been
established:
To monitor so as to detect future ground water contamination,
if it occurs, before it migrates off the Landfill site. If
contamination is detected a remedial response action will be
implemented to contain and treat the ground water
contamination.
To minimize public access and prevent future development of.
the Landfill, thereby minimizing disturbance of both the
surface soils and landfilled materials.
4.0 SUMMARY OF ALTERNATIVES
4.1 SCREENING AND FORMULATION OF ALTERNATIVES
The results of the Remedial Investigation (RI) indicated that
essentially no risk existed at the site at the time of the RI.
Since historical data indicated the landfill was a source of
ground water contamination in the past and there may be a
potential for future releases by leaching unknown sources
within the landfill, EPA and KDHE determined.that a Focused
. Feasibility Study (FFS), which examined a more limited range
of remedial alternatives, was appropriate for the Obee Road
Landfill Subsite. The FFS evaluates two response actions
which could be applied to the present conditions at the
Subsite. The response actions include: (1) no action; and (2)
institutional controls/ground water monitoring with the
contingency for further action if the monitoring shows
releases to the ground water. The screening criteria used for
the analysis included effectiveness, implementability, and
cost of the remedial action alternative.
The remedial alternatives selected for detailed evaluation are
presented below.
- No Action
Institutional Controls/Ground Water Monitoring with a
Contingency for Further Action
4.2 DETAILED EVALUATION OF REMEDIAL ACTION ALTERNATIVES
The two alternatives described above were evaluated and
screened based on the following three criteria:
- Effectiveness
Evaluate the ability of the process option to handle
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the estimated .areas of volumes of contaminated
media
Potential impacts on human health and the
environment during implementation of the process
Reliability of the process for the Site contaminants
Implementability
Technical feasibility of process
Administrative feasibility of process
- Cost
Capital costs
Operation and Maintenance (p&M) costs
Institutional controls/ground water monitoring will achieve
the remedial action objectives established for the Site. Both
selected general response actions have high potential
iitiplementability and are cost-effective approaches for the
level of protection offered by each. Both remedial options
will be evaluated further for this Site.'
5.0 EVALUATION OF ALTERNATIVES
5.1 SUMMARY OF EVALUATION CRITERIA
The following section presents a summary of the criteria used
to evaluate the remedial action alternatives. The National
Oil and Hazardous Substances Pollution Contingency Plan (NCP)
has established nine criteria to evaluate remedial
alternatives. These criteria serve as the basis for
conducting detailed analyses during the FFS and subsequently
are used to determine the appropriate remedy for the Site.
5.1.1. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion addresses whether or/not a remedy provides
adequate protection and describes how risks posed through
each pathway are eliminated, reduced or controlled
through treatment, engineering controls, or institutional
controls.
5.1.2. COMPLIANCE WITH ARARS
This criterion addresses whether or not a remedy. will
meet all of the applicable or relevant and appropriate
requirements' (ARARs) of other Federal, State or other
applicable laws and regulations. ARARs may be grouped
into three different categories. Chemical-specific ARARs
are standards which dictate clean-up levels for specific
hazardous substances. Action-specific ARARs are
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requirements which set standards for clean-up practices.
Location-specific ARARs involve the consideration of
site-specific geographic, topographic, or other factors
dealing with the physical characteristics of the site.
Potential ARARs are listed in Section 6.2.2.
5.1.3. LONG-TERM EFFECTIVENESS AND PERMANENCE
This criterion refers to the ability of a remedy to
maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
5.1.4. REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
This criterion reviews the anticipated performance of the
treatment technologies a remedy may employ.
5.1.5. SHORT-TERM EFFECTIVENESS
This criterion addresses the period of time needed to
achieve protection, and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period until cleanup
goals are achieved.
5.1.6. IMPLEMENTABILITY
This Criterion refers to the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
5.1.7. COST
This criterion evaluates the estimated capital cost,
operation and maintenance costs, and net present worth
costs.
5.1.'8. STATE AND SUPPORT AGENCY ACCEPTANCE
This criterion discusses whether, based on their review
of the RI/FFS and Proposed Plan, the agencies concur
with, oppose, or have no comment on the preferred
alternative at the present time.
5.1.9. COMMUNITY ACCEPTANCE
This criterion will be assessed in the ROD following
review of the public comments received on the RI/FFS
reports, the administrative record, and the Proposed
Plan.
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5.2 EVALUATION OF THE ALTERNATIVES
A detailed analysis of the remedial alternatives was
conducted, consisting of an assessment of the individual
alternatives against each of the nine criteria and a
comparative analysis that focused on the relative performance
of each alternative against those criteria. As a result of
this detailed analysis, KDHE and EPA have determined that the
Institutional Controls/Ground Water Monitoring with a
contingency for further action Alternative provides the best
balance among the alternatives with respect to the criteria.
5.2.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT
Although there were no current risks associated with the
Subsite, the No Action Alternative would not provide
additional protection of human health and the environment
should future releases occur. The Institutional
Controls/Ground Water Monitoring with a contingency for
further action alternative would provide an increased
level of protection of human health and the environment
by providing for detection, containment and treatment of
any future ground water contamination, thus preventing
future consumption of contaminated ground water. In
addition, overall protection of human health and the
environment ' would be achieved, by providing for
appropriate land use in the future, thus preventing
future contact with' the Landfill and its contents.
5.2.2 COMPLIANCE WITH ARARs
The No Action Alternative would not provide for any
compliance with any ARARs. The Institutional
Controls/Ground Water Monitoring with a contingency for
further action Alternative provides a method for
compliance with ARARs if additional containment and
treatment of the ground water is necessary. The primary
ARARs that would be applicable to the Obee Road Landfill
Subsite if further action is necessary and involves the
containment and tr'eatment of ground water would include:
1) Maximum Contaminant Levels (MCLs) as promulgated
under the Safe Drinking Water Act .are the relevant and
appropriate standards for remediation of contaminated
groundwater. MCLs are chemical-specific ARARs.
2) Effluent limitation guidelines as governed by the
Clean Water Act through the National Pollutant Discharge
Elimination System (NPDES) are ARARs for any discharge of
treated water resulting from site remediation activities.
NPDES effluent guidelines are also chemical-specific
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ARARS.
3) No specific ARARs, other than state reporting
requirements, currently exist for air emissions from the
ground water stripping towers. However, the preferred
alternative provides for air monitoring to ensure the
health and safety of any exposed population.
5.2.3 LONG TERM EFFECTIVENESS AND PERMANENCE
The long-term effectiveness of the No Action Alternative
would be unknown since any future leaching of
contaminants into the ground water or disturbance of the
Landfill cover would not be monitored. The Institutional
Controls/Ground Water Monitoring with a contingency for
further action Alternative, would provide long-term
effectiveness by continuous monitoring of the ground
water, and by providing for additional action for
containment and treatment of contaminated ground water
should any future releases by detected. The preferred
alternative also provides long-term effectiveness by
implementing deed restrictions.
The permanence criterion would not apply to the No Action
Alternative, since no action would be taken. The
Institutional Controls/Ground Water Monitoring with a
contingency for.further action Alternative provides 'a
greater degree of permanence by ensuring that any future
release of contaminated ground water will be detected and
that the extracted ground water would be treated to
remove the contaminants. The preferred alternative also
provides a relatively higher degree of permanence by
restricting land use in the Landfill area and by
restricting access to the property.
5.2.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
The No Action Alternative would not effect the reduction
of toxicity, mobility, or volume of contaminants since
contaminants are below levels of concern as demonstrated
in the RI report. The Institutional Controls/Ground
Water Monitoring with a contingency for further action
Alternative would only effect the reduction of toxicity,
mobility .or volume if contaminants are detected and
actions are taken to contain and treat the ground water.
Then the contingency action would reduce the toxicity of
the contaminants by .extracting the ground water and
removing the contaminants. In addition, the mobility and
volume of the contaminants within the ground water would
be reduced by the extraction of the ground water in that
the pumping action would prevent the contaminants from
migrating from the area (mobility) and reducing the
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volume of the contaminants by treating the extracted
water.
5.2.5 SHORT TERM EFFECTIVENESS
The short term effectiveness of the No Action Alternative
would be unknown since no ground water monitoring or
institutional controls would be in place to determine the
short term effectiveness of this alternative. The
Institutional Controls/Ground Water Monitoring with a
contingency for further action Alternative would provide
for short term effectiveness by immediately implementing
ground water monitoring and ensuring that contaminated
ground water will be detected, contained and treated. In
addition, deed restrictions and fencing provide good
short-term effectiveness in that the Landfill and its
contents'will not be disturbed. • '
5.2.6 IMPLEMENTABILITY
Both the No Action Alternative and the Institutional
Controls/Ground Water Monitoring with a contingency for
further action Alternative would be easily implementable.
The preferred alternative is somewhat more difficult to
implement but monitoring and (if necessary) containment
and treatment are well-proven technologies that have been
completed successfully at other-sites. •
5.2.7 COST
The No Action Alternative would have no associated cost.
The estimated cost of the Institutional Controls/Ground
Water Monitoring Alternative is $100,000 for five years
of monitoring. If the contingency to contain and treat
ground water is initiated then a additional costs would
be added to this estimate. The amount of any additional
costs would vary depending upon several variables,
including the number of extraction wells, air strippers
or other equipment needed to implement the contingency,
as well as the amount of time the system operates.
5.2.8 STATE AND SUPPORT AGENCY ACCEPTANCE
The KDHE and the EPA have support the preferred
alterative.
5.2.9 COMMUNITY ACCEPTANCE
Comments were received during the comment period and
reviewed. Summaries of those comments and EPA's
responses are in Section 8.0.
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6.0 SELECTED REMEDY
The selected remedy for the Site is Institutional Controls/Ground
Water Monitoring with a contingency for further action. This
remedy includes: ground water monitoring, Landfill access
restrictions, and Landfill deed restrictions with a contingency for
further action. Ground water monitoring is used to detect
contaminant presence and migration at the Site.
The ground water monitoring program would include annual sampling
for a five-year period with VOC analysis of the following
monitoring wells:
MW-9S (Upgradient) MW-5S (Downgradient)
MW-3 (Landfill) MW-6 (Downgradient)
MW-4 (Landfill) MW-10S (Downgradient)
MW-5 (Downgradient) MW-10D (Downgradient)
A contingency for further action is also a part of the selected
remedy in the event that ground water contamination increases in
the future and is found to be migrating off-site at concentrations
above the current Maximum Contaminant Levels (MCLs) under the Safe
Drinking Water Act (SDWA) for aquifers which may be used for
drinking water purposes. The contingency would include the
evaluation of appropriate responses for the containment and
treatment of the ground water to meet the ARARS. The remedy under
the contingency could include extraction well(s) for containment
and air stripping tower(s) for treatment of the extracted ground
water. The effluent from the stripping towers would be governed by
the National Pollutant Discharge Elimination System Permit and any
additional treatment of exhaust vapors from the air stripper(s)
would be determined after monitoring the vapors at the start-up of
the air stripper(s). Access and deed restrictions include
minimizing Landfill access by trespassers and preventing future
development of the Landfill. These access and deed restrictions
would be implemented by the City of Hutchinson, who currently owns
the landfill property. This reduces the potential for contaminant
exposure from contact with or disturbance of the Landfill cover and
its contents. Fencing and access restrictions are already in place
at the Landfill.
The selected remedy would protect human health and the environment
by using ground water monitoring to detect future contamination of
ground water at the Site; by responding with additional action to
contain and treat the contamination if any is detected; and by
establishing deed restrictions which would prevent disturbance of
the Landfill cover and its contents. Cost estimates for the
selected remedy are given in Table 2.
After five years, the appropriateness of the ground water
monitoring program would be evaluated by KDHE and EPA. If no
additional contamination above MCLs and/or KALs is detected after
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five years of ground water monitoring, EPA and KDHE would consider
ceasing the ground water monitoring program at that time. Landfill
access and deed restrictions would continue to remain in effect.
7.0 STATUTORY DETERMINATIONS
Under its legal authorities, the Environmental Protection
Agency's primary responsibility at Superfund sites is to undertake
remedial .actions that achieve protection of human health and the
environment. In addition, Section 121 of CERCLA establishes
several other statutory requirements and preferences. These
specify that when complete, the selected remedial action for this
site must comply with applicable or relevant and appropriate
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.
1. Protection of Human Health and the Environment
•
.The selected remedy will provide suitable protection of human
health and the environment by implementing institutional controls
to prevent disturbance of the surface soils and landfilled
materials and by monitoring the ground water to ensure that
contaminants that may be released from the former landfill can be
detected, contained, and treated to protect the ground water users
downgradient of the Landfill site.
2. Compliance with Applicable or Relevant and Appropriate
Requirements ..
The Applicable or Relevant and Appropriate Requirements
(ARARs) are defined as clean-up standards, standards of control, or
other environmental protection standards that are used to address
problems or situations at a contaminated site. ARARs are
classified within three categories: 1) Chemical Specific
Requirements - health or risk .based numerical values, which
represent an acceptable concentration in the media of concern in
the absence of consideration of site-specific exposure conditions;
2) Location-Specific Requirements - limitations on allowable
concentrations of hazardous substances due to impacts in special
loca'tions, such as critical habitats; and 3) Performance, Design,
or Other Action-Specific Requirements - technology based
requirements or limitations or actions taken with respect to
hazardous wastes.
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The criteria that will be used in the monitoring of the ground
water to determine if ,the contingency of treatment will be
implemented are as follows:
Maximum Contaminant Levels (MCLs) as promulgated under the
Safe Drinking Water Act are the relevant and appropriate
standards for remediation of contaminated groundwater. For
compounds without a MCL, proposed MCL or state ground water
standard, a risk based cleanup level corresponding to an
excess lifetime cancer risk of 1 x 10(-6) will be calculated
using slope factors for carcinogens (Chemical-Specific).
If the monitoring indicates releases of contaminants above the
criteria listed above the contingency for the evaluation of
appropriate responses for the containment and treatment of the
ground water to meet-the following ARARs will be implemented:
Effluent limitation guidelines as governed by the Clean Water
Act through the National Pollutant Discharge Elimination
System (NPDES) are ARARs for any discharge resulting from site
remediation, such as pump and treat (Chemical-Specific).
There were no location or action specific ARARs.
3. Cost Effectiveness
The selected remedy provides a higher degree of overall'
protection than the no action alternative by monitoring for any
ground water contamination and providing for containing and
treating contaminated ground water, thus preventing the migration
of contaminated ground water from the area.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable.
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost effective manner for the
site. Of the alternative that is protective of human health and
the environment and comply with applicable standards, EPA has
determined that this selected remedy provides the best balance of
trade-offs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume achieved through
treatment (if needed), short-term effectiveness, implementability,
cost, and considering State and community input.
5. Preference for Treatment as a Principal Element
If needed the contingency for ground water treatment satisfies
the statutory preference for remedies that employ treatment of the
principal threat which permanently and significantly reduces the
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toxicity, mobility, or volume of hazardous substances as a
principal element.
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8.0 RESPONSIVENESS SUMMARY
8.1 In the proposed plan released for public comment, EPA and
KDHE presented a preferred alternative which set forth the
proposed final remedy for the institutional controls and
ground water monitoring with a contingency for further action
at the Obee Road Landfill Subsite.
After receiving public comments on the preferred
alternative, EPA has selected the alternative set forth in
this Record of Decision (ROD).
8.2 Summary of comments and 'questions received during the
Public Comment Period.
Comments received during the public comment period from
March 4,. 1994 through April 2, 1994 are summarized, below with
the EPA/KDHE response for each. Attachment II contains the
comment letters received in addition to a response letter from
KDHE to one of the commentors.
A. A comment letter was received from Mr. Dennis Clennan,
Director of Public Works & Engineering, City of Hutchinson
concerning the stated figures of number of homes and residents
located south of the.landfill in Section 2, Paragraph 2.1 of
the Proposed Plan. He stated that, based on a March 24, 1994
population study, there are 102 households and approximately
280 people in the area south of the landfill.
~ EPA Response: The correction was made in Section 1.0,
Paragraph 1.1 of the ROD.
B. Letters were received from two residents that live
east/southeast of the Landfill who feel that contamination
from the landfill has reached their private ground water wells
and that these residents will continue to have water quality
problems. One letter also contained a series of questions
about the nature of the contamination and the potential effect
of the contamination on humans and wildlife in the area.
Neither letter suggested any changes to the remedy proposed in
the ROD.
EPA Response: KDHE responded to the series of questions
with a letter which is included with this ROD as
Attachment II. EPA agrees with the responses contained
in KDHE's letter and incorporates those responses by
reference into this responsiveness summary. In response
to the concerns expressed in both letters about water
quality, EPA acknowledges that residents near the
landfill area may have had water quality problems in the
past that may have been caused all or in part by
contamination from the Landfill. However, at the time
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that the Remedial Investigation was completed, there was
no indication . of any continuing releases from the
Landfill. Based on this data, EPA and KDHE believe that
the plume of contamination has moved away from the
landfill area and has been subjected to natural flushing
and dilution within the aquifer. The periodic monitoring
of wells required in this ROD is designed to monitor the
ground water so that any future release that may occur
will be detected and a response action can be taken. In
addition, a sampling plan for a number of private ground
water wells owned by residents who are not hooked up to
the Rural Water District System is currently being
developed by the Reno County Department of Health and
KDHE in order to ensure that no contamination remains in
the area. If contamination of those private ground water
wells sampled is detected, then an appropriate action
will be determined by KDHE and EPA.
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ATTACHMENT I
Glossary of Terms
ARARS - Applicable Relevant and Appropriate Requirements - Clean
up standards of control or other environmental protection
requirements.
AR File - Administrative Record File - includes all pertinent
documents and site information which forms the basis for
selection of a remedial alternative.
CERCLA
EPA -
FFS -
KAL -
KDHE -
MCL -
NPDES -
NCP -
NPL -
PRP -
Comprehensive Environmental Response, Compensation and
Liability Act of 1980. The federal "Superfund" law.
United States Environmental Protection Agency - The
support government agency for the Obee Road Landfill
Subsite.
Focused Feasibility Study. The study used to evaluate
various alternatives to address potential risks to health
and environment.
Kansas Action Level is a concentration that could produce
chronic health effects after long term consumption of
water. If a contaminant is detected at or above the KAL
in a public water supply, the well must not be used for
drinking water purposes.
Kansas Department of Health and Environment.
government agency for the Site.
Maximum Contaminant Level - The maximum
contaminant allowed in ground water by EPA.
The lead
amount of
National Pollutant Discharge Elimination System - a
permit that sets standards for the discharge of
potentially contaminated ground water.
National Oil and Hazardous Substances Pollution
Contingency Plan. The procedures used to address the
response powers and responsibilities created by the
federal Superfund law.
National Priorities List. A list of most contaminated
sites as determined by the NCP.
Potentially Responsible Party - The party (or parties)
identified by EPA which is potentially responsible for
contamination.
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RCRA - Resource Conservation 'Recovery Act.
RI - The process which identifies site conditions, extent of
contamination, and site risks.
ROD - Record of Decision - The official document by EPA which
selects the remedy to clean up a Superfund site.
SARA - Superfund Amendments and Reauthorization Act of 1986.
The federal law which amended and extended authorization
of the original Superfund law (CERCLA).
SVOC - Semi-Volatile Organic Compound.
VOC - Volatile Organic Compound.
24
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ATTACHMENT II
25
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POST OFFICE BOX 1567: 67504-1567
TELEPHONE (316) 694-2644
FAX (316)694-2673
OFFICE OF: D- CLENNAN
RECEIVED
March 25, 1994
SPED
Ms. Rachel Miller
KANSAS DEPARTMENT of HEALTH and ENVIRONMENT
Forbes Field, Building 740
Topeka, Kansas 66620-7500
Reference: Obee Road Subsfte
Dear Rachel:
I would like to offer a comment on the Proposed Plan for the Obee Road Landfill Subsite.
In Section 2, paragraph 2.1, you state that there are 500 homes and 1900 residents
located south of the landfill. I believe your figures are in error. I am enclosing a copy of
a memorandum to me from our Associate City Planner which states there are 102
households and approximately 280. people.
i for your attention to this detail.
Sincerely,
CITY OF HUTCHINSON
Dennis M. Clennan, P.E.
DIRECTOR OF PUBLIC WORKS & ENGINEERING
DMC/rh
Enclosure:as noted
PRINTED WITH]
SOYINKI
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PLANNING AND DEVELOPMENT DEPARTMENT
125 EAST AVENUE B; P. 0. BOX 1567
HUTCHINSON, KS 67604-1567
(316) 694-2639
DATE: March 24, 1994
TO: Dennis Clennan, Director of Public Works and Engineering
FROM: • T1m Truesdale, Associate City Planner
SUBJECT: Obee Road Population Study
Area of Interest: the following five quarter sections in Clay Township:
1) S/N 11,
2) N/W 14,
3) S/W 14,
4) N/E 15,
5) S/E 15.
Background: A previous study indicated that this area contains 500 households
and 1900 people. This number seemed high.
Clay Township: The entire township of approximately 34 sections contains 2878
persons in 1047 households.
Rough estimate of households in study area: 102 households
Rough estimate of persons in study area: 280 persons.
Method—Taking the Official 1990 Rural Directory, pencilling off the
affected quarter sections, counting the number of households, and
multiplying by the 2_.75 persons/household found in Clay Township.
Another method would be to use Census data at the block level. At this point,
we can't find this data anywhere in Reno County. It was ordered today, and
should be available within the next ten days. I will refigure when this data
is available. In general, the census method tends to be more accurate.
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RECEIVED
4PR1 4 |994 Apri I 2. 1994
DearRacnel. ENVfRONAMENTAL APR
REMEDIATION Hrn
My name is Victor L Wilkinson, my address is 5011 Frank Road SFf-D
which is .5 mile south of Obee school and .25 mile east on Frank Road.
I have several questions I would like answered about the
contaimination in the Obeeville area.
I. Is the EPA and KDHE onlv interested in contaimination that is
. a carcinogen?
2. Are the test well deoths comparable to residential well depths?
Z. I know a person who was raised in the house across the road from
me during the 1950s, he said the water was not rusty or
odoriferous then.
A. Is the dump the source of the excessive rust present in the
well water? •
B. Is the dump the source of the odor associated with the well
water?
4 My two dogs drink some pretty disgusting water wh.en on hunting
trips, but they often refuse to drink the well water from their water
bowl. Also, after filling their bowls with water, the surface
appears to have an iredescent film floating on it similar to
gasoline on water.
Is this film dangerous to animate or humans, and what is it?
c
I have noticed foliar damage, stunted growth, and anemia to
certain plants and trees from watering with the well water.
A. Are there chemicals present in the ground water
contaimination that are causing this?
B. Are these chemicals making the soil more alkali, and how is it
corrected?
C. Are the homeowners expected to carry the burden of cost to
correct their damaaed soil?
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6. The water quality varies (color, rust, odor) from house to house
within my neighborhood. Often, the poor water quality seems to be
damaging appliances of those who's homes are hooked up to well
water.
A. Does the ground water take different paths, travel at different
rates, and" possibly pool up and stagnate underground?
B. If a homeowner feels his water is damaging his landscaping,
water related appliances, clothes, or threatening the health of
family members can his water be checked by the EPA/KHDE at
no cost?
C. Is the cost of appliance replacement, clothing replacement,
water damaging property figured in the in the clean up costs?
Can the residents expect any reimbursement from the PRPs?
7 A. I fish in a sandpit in the area that has depths to 50 feet, will
the larger.and older fish in this-water accumulate ... • -^
contaiminates in their tissues over the years?
B. Have any of these larger fish been tested?
C. Will bottom feeding fish (catfish, carp, etc.) be affected
more than preaators (largemouth. crappie. flat heads)?
D. Will federally protected fish eating birds such as ospreys. bald
eagles, canvasbacks, etc., that feed on the sand pit during
seasonal migrations be affected?
How about resident fish eating birds?
Thank you so much for answering my questions.
Victor L Wilkinson
P.S. Any person who doesn't believe the ground water is contaiminated is
welcome to come to my house for fresh glass of well water.
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State of Ka nsas
Joan Finney, Governor
Reply To: (913) 296-1673/ PAX (913) 296-1686
Bureau of Envinnm
Fofbet Field. Biddi* 740
Topdu, KS 6662M001
Department of Health and Environment
Robert C. Harder, Secretary
May 23, 1994
Victor L. Wilkinson
5011 Frank Road
Hutchinson, Kansas
RE: Obeeville area
Dear Mr. Wilkinson:
This letter responds to your letter of April 2, 1994, containing
questions regarding environmental concerns in the Obeeville area.
We are providing responses to your questions in the following
paragraphs.
Question 1. Is the EPA and KDHE only interested in contamination
that is a carcinogen?
Response. In the interest of protecting human health and the
environment, EPA and KDHE are concerned with any contaminants which
are known _to be a- possible threat to. humanvi^al;th;..and.v^e
environment. These contaminants would include both"'carcinogens and
noncarcinogens.
Question 2. Are the test well depths comparable to residential
well depths?
Response. The monitoring wells constructed for investigations in
the area under KDHE oversight have been constructed in both the
upper aquifer zone and the lower aquifer zone. Therefore, the
answer to your question is "yes", there would be monitoring wells
constructed at depths comparible to residential well depths whether
they are screened in the upper zone, the deep zone, or both.
Question 3A. Is the dump the source of the excessive rust present
in the well .water?
Response. There is no evidence which has shown that the landfill
is a source of iron in the ground water. Water well and test hole
data collected during a Kansas Geological Survey (KGS) study
completed in 1956 indicate that high iron concentrations in water
in this area are not uncommon in naturally occuring ground water.
Landon Stata Offica Bulling. To'peka. 66612-1290 • Forfaas Field. Building 740, Topaka. 66620-0001 • Mill* Building. 109 SW 9th. Topeka, 66612
Printfd on Rtcyeted A>per
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Mr. Victor L. Wilkinson
May 23, 1994
Page 2
Question 3B. Is the dump the source of odor associated with the
well water?
Response. Since contamination in ground water due to the landfill
was shown to be very limited and non-detectable outside the
landfill area, it is unlikely that the landfill is a source of odor
in the veil water in your residential area. There are -many
possible causes of odor from well water which might be attributable
to the structural condition of the well and/or the natural ground
water chemistry. The water should be tested to determine the
possible source of the objectionable odor.
Question 4. Is this film (irredescent film floating on well water)
dangerous to animals or humans, and what is it?
Response. The well water should be tested to determine the cause
of this "film". Hardness in water, a high dissolved solids
content, and a high iron content, can often cause a film to be
present on water.
Question 5A. Are there chemicals present in the .ground water
contamination that are causing this (foliar damage, stunted growth,
to certain plants and trees from watering with the well
Response. The well water should be tested to determine whether
there are chemicals which might cause damage to vegetation.
Question 5B. Are these chemicals making the soil more alkali, and
how is it corrected?
Response. The well water should be tested to determine whether
there are chemicals which might cause the soil to become more
alkali. Water which is hard is generally associated with high
alkalinity.
Question 5C. Are the homeowners expected to carry the burden of
cost to correct their damaged soil?
Response. Again, the well water should be tested to determine
whether there are chemicals present which might cause the soil to
become damaged. A determination should be made as to whether the
chemicals are attributable to the natural ground water or to a
specific source of contamination.
Question 6A. Does the ground water take different paths, travel at
different rates, and possibly pool up and stagnate underground?
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Mr. Victor L. Wilkinson
May 23, 1994
Page 3
Response. The ground water flow direction and rate of flow is
relatively uniform throughout the Obeeville area. This type of
flow is not characteristic of stagnant conditions. See the
attached map showing the ground water flow direction in the area.
Question 6B. If a homeowner feels his water is damaging his
landscaping, water related appliances, clothes, or threatening the
health of family members, can his water be checked by the EPA/KDHE
at no cost?
Response. KDHE will sample and analyze your well water for
volatile organic compounds (VOCs) to determine if any' of these
contaminants are present in your water. VOCs are not naturally
occuring constituents found in ground water. However, the well
owner is responsible for the testing of well water for potentially
naturally occuring chemicals. This would include testing for
hardness, iron, other inorganic constituents, and bacteria. We
have enclosed information concerning laboratories available to test
your water for inorganics and bacteria. KDHE and EPA, in
cooperation with the Reno County Health Department, will be
performing, sampling of residential wells in your area for VOCs
within the next few months. We will contact you to set up a time
to sample your well.
Question 6C. Is the cost of appliance replacement, clothing
replacement, water damaging property figured in the clean up costs?
Can the residents expect any reimbursement from the PRPs?
Response. Again, the water should be tested and a determination
should be made as to whether chemicals found in the ground water
are the cause of the above cited damages. If these chemicals are
determined to be the cause of such damages, then a .determination
should be made as to whether or not they are naturally occuring.
Clean up costs do not generally include personal damages such as
those cited above. If reliable evidence can be shown to indicate
a specific PRP is responsible for a resident's contamination
problem, the resident may seek reimbursement from the PRP.
Question 7A. Will the larger and older fish in this water
accumulate contaminants in their tissues over the years.
Response. Sampling of water and sediment in a sand pit in a nearby
area of contaminated ground water did not indicate the presence.of
VOC contamination. Therefore, we would not expect contamination to
be present in fish in these waters.
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Mr. Victor L. Wilkinson
May 23, 1994
Page 4
Question 7B. Have any of these larger fish been tested?
Response. No, since no contamination in surface water or sand pit
sediment was found, fish were not tested.
Question 7C. Will bottom feeding fish (catfish, carp, ect.) be
affected more than predators (largemouth, crappie, flat heads)?
Response. Thus far, there is no indication that any fish will be
affected by VOC contamination in the ground water.
Question 7D. Will federally protected fish- eating birds such as
ospreys, bald eagles, canvasbacks, etc., that feed on the sand pit
during seasonal migrations be affected? How about resident fish-
eating birds?
Response. There is no indication that contamination is present in
sand pit sediment, surface water, or fish in the area.
I hope your questions have been adequately addressed and encourage
you to contact me at 913-296-1676 if you have further questions or
concerns. You may wish to contact Helen Tinson at 913-551-7343 of
the EPA Office of Public Affairs to inquire into your ability to
obtain a Technical Assistance Grant (TAG) for the purpose of
performing your own investigation into some of these problems which
might relate to the Obee Road Superfund Site.
Sincerely,
Rachel Miller
Environmental Geologist .
Remedial Section/Superfund Unit
Bureau of Environmental Remediation
RM/jdh
Rick Bean—>file
Kyle Parker - SCDO
Ken Rapplean - EPA
Helen Tinson - EPA
Judy Seltzer - Reno County Health Dept.
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-------
KDHE Env Remediation TEL No. 913-296-
1686
Rpr 7 , 94 15 =29 No . 009 P. 02
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78
FIGURE 1 OBEE ROAD LANDFILL SUBSITE LOCATION MAP
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OBEE ROAD
LANDFILL SUBSITE
LEGEND
NOTE.
AJRPORT PROPERTY BOUNDARY BOUNDARIES SHOWN ON THIS FIGURE ARE APPROXIMATE.
INFORMATION TAKEN FROM THE RENO COUNTY ZONING MAP
AND THE HUTCHINSON MUNICIPAL AIRPORT LAND USE MAP
RESIDENTIAL
:NDUSTRIAL
AGRICULTURAL [~£J SCHOOL
FIGURE 2 OBEE ROAD SITE AREA AND LAND USE MAP
SOURCE: Remedial Investigation Report
Obee Road Subsite; November 1993
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Obee Road
Supertund Site
Boundary
! \ ^
•» OBEE ROAD MONITORING WELLS X
• KOHE MONITORING WELLS
A OBEE ROAD PIEZOMETERS A AIRPORT BORINGS
• WATER-TABLE BORING ° LANDFILL BORINGS
SHALLOW SOIL
SAMPLING AREA
i
!> ( A I f IN I I | 1
SOURCE: Remedial Investigation Report
Obee Road Subsite; November 1993
FIGURE 3 MONITORING WELL LOCATIONS IN OBEE ROAD SITE AREA
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APPROXIMATE
LANDFILL
BOUNDARY
UTCHINSON AIPOR
SO A LB-3E
Obeeville
SOILBORINGS
) CONCENTRATION OF TETRACHLOROETHENE
• 110J«fltsaiS(2-ETHYLHEXYL)PHTHALATE
JT 1 200 X*w*sAROCLOR- 1254
(N.S) NOT SAMPLED
Notes: J - Estimated value less than contract required
quamitation limit.
X - Value was manually calculated!
500
1000
_
SCALE IN FEET
SOURCE: Remedial Investigation Report
Obee Road Subsite; November
FIGURE 4 ANALYTICAL RESULTS OP SOIL SAMPLES FROM LANDFILL
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NOTES: / /
1. MONITORING WELLS SAMPLEw
MAY 1992 EXCEPT WHERE
INDICATED.
2. WATER TABLE BORINGS
SAMPLED SEPTEMBER 1991.
3. SEE APPENDIX FOR /
EXPLANATION OF DATA
QUALIFIERS. / /
APPROXIMATE
LANDFILL
BOUNDARY
Maihylene 1J ug/L
Chloride
Vinyl 2J ug/l
Chloride
Obeeville
4THAVENUE
75/2
WT-4
• KDHE MONITORING WELi
® NEW MONITORING WELL
©WATER TABLE BORING
soo o
1000
S C A L = IN .= = = T
SOURCE: Remedial Investigation Report
Obee Road Subsite; November 19£
FIGURE 5 vocs IN GROUND
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TABLE 1
XDHE MONITORING WELL RESULTS
OBEE ROAD SITE
HW-1
MW-2A
MW-2B
HH-3
MW-4
HW-5
MW-6
MH-7
YEAR SAMPLED
1984
1985
1986
1990
*1991
**1991
1984
1985
1986
1990'
*1991
**1991
1984
1985
1986
1990
*1991
1984
1985
1986 .
*1991
**1991
1984
1985
*1991
1984
1985
1986
*1991
**1991
1984
198.5.
•1986
*1991
**1991
1984
1985
1986
*1991
TOTAL VOC3 (uafl)
1660
5024
9290
193.2
124
166.5
17
22.5
9.7
59.1
25
38.5
10
9.8
10.5
59.1
44
19.1
25.3
17.7
ND
ND
24.4
7
ND
16.1
109.4
7.7
ND
1.9
16.8
22.9
17.1
9
ND
ND
ND
ND
5
SUBSITE AREA
Airport Road
Airport Road
Airport Road
Landfill
Landfill
Landfill
Landfill
Landfill
ND - Not Detected
* - Samples collected during Phase I Remedial Investigation
(2/26/91); Burns & McDonnell sample
** - Samples collected during Phase I Remedial Investigation
(2/26/91); KDHE split sample
All other samples were collected by KDHE
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TABLE 2
ESTIMATED COSTS FOR THE PREFERRED ALTERNATIVE
SOURCE: Focused Feasibility Study Report
Obee Road Subsite; January 1994
Item . • .
1. Groundvacer Monitoring
Analytical $ 4,000
Field Labor 5,000
Expenses 3,000
Report Preparation • 6.000
Total Item 1 Estimated Annual Cost $18,000
Total Item 1 Estimated Present Vorth Cost* $ 82,440
2. Fence Maintenance
Labor $ 500
Materials 500
Total Item 2 Estimated Anr.uai Ccst ' $ 1,000
Total Item 2 Estimated Present «orth Cost" $ 4,580
3. Deed Restrictions
Lump sum for costs associated vith
attorney fees, city review, and
filing with County Records Office • $ 1, OOP
Total Item 3 Estimated Cost 1,000
Total Item 3 Estimated Present Vorth Cost $ 1,000
4. Subtotal . $ 88,020
5. Contineencv (15 percent^ $ 13.203
'ALTERNATIVE 2 ESTIMATED TOTAL PRESENT WORTH COST $101,223
USE: $100,000
Present worth cost is calculated for a 5-year period at a 3 percent net
interest rate (6 percent interest rate less 3 percent inflation) with the
present worth factor = 4.580.
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