PB94-964315
                                 EPA/ROD/R07-94/077
                                 February 1995
EPA  Superfund
       Record of Decision:
       Obee Road (O.U. 1),
       Hutchinson, KS
       6/30/1994

-------
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                REGION VII
                          726 MINNESOTA AVENUE
                         KANSAS CITY, KANSAS 66101
                           i | !,.;••   ' • " ,\
                          U \..: i '•• • ; •  : ':J 0 *
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 .

-------
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

-------
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

-------
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 •

-------
         RECORD OF DECISION
                   %



     OBEE ROAD LANDFILL SUBSITE

         Hutchinson. Kansas

              JUNE  1994
U.S. Environmental Protection Agency
             Region VII
        726 Minnesota Avenue
     Kansas  City,  Kansas  66101

-------
                    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

-------
                           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

-------
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.

-------
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.

-------
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

-------
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

-------
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

-------
 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.

-------
     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.

-------
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.

-------
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

-------
     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

                                10

-------
     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

                               11

-------
                 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

                               12

-------
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.
                      13

-------
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

                           14

-------
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

                     15

-------
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.
                     16

-------
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

                               17

-------
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.

                                18

-------
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

                               19

-------
toxicity,  mobility,   or  volume  of   hazardous   substances  as  a
principal element.
                               20

-------
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

                               21

-------
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.
                     22

-------
                           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.
                                23

-------
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

-------
ATTACHMENT II
    25

-------
                                                        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

-------
                      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.

-------
                           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?

-------
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.

-------
                                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

-------
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?

-------
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.

-------
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.

-------
  f line. £.nv Kerneo lat ion


PosHf brand fax transmmoi m»mo 7671
                      INO
&/*> f57-
                                         flpr  7,94 15=29 No.009 P.01
                               DECEIVED
                                _   OUKSAU or
                                ENVIRONMENTAL
                                 REMEDIATION

                                                              o
                                 I

-------
KDHE Env Remediation   TEL No. 913-296-
1686
                                                 Rpr  7 , 94  15 =29 No . 009 P. 02
                                                                 0W .*-
                            s&p.

-------
78
                         FIGURE   1    OBEE ROAD LANDFILL SUBSITE LOCATION MAP

-------
                                  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

-------
             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

-------
                                    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

-------
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

-------
                              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

-------
                              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.

-------