United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-86/011
August 1986
Superfund
Record of Decision
Distler Farm, KY
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TECHNICAL REPORT DATA
(Please retld Instructions on the revene before com"leting)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R04-86/0ll
4. TITL.E AND SUBTITL.E 5. REPORT DATE A
SuPERFUND RECORD OF DECISION August 19, 1986
Distler Farm, KY 6. PERFORMING ORGANIZATION CODE
7. AUTHORCS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental protection Agency Final ROD Repor t
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Wash ington, D.C. 20460 800/00
15. SUPPL.EMENTARY NOTES
16. ABSTRACT -
Distler Farm is loca ted in the southwest corner of Jefferson County, KY, .'
approximatel~'one mile' northwest. of West point, KY. The proper ty is bordered by -U. S.
Highway 60/31 W (Dixie Highway) on the nor thwest 1 Stump Gap Cr eek on the southeast1 and
by cultivated farmland on the northeast and southwest. The site is a three-acre area
approximately 1,000 feet from the Oh io River. The site was discovered in early 1977
during the development of an enforcement case against ~k. Donald F. Distler, owner of '
Kentucky Liquid Recycl ing, Inc. In an effort to locate sites that Mr. Distler may have
used for chemical waste storage or disposal, EPA personnel inspected the site in Apr il
1977. They reported approximately 600 drums of industrial waste stored on the ground
sur face. In December 1978 the Ohio River and its tr ibutar ies flooded, causing drums of
industrial wastes from the site to be scattered along the floodplain of the creek. The
Gover nor of Kentucky declared an environmental emergency and Region IV of the EPA
,supervised recovery and onsite storage of 832 drums containing chemicals characteristic
of paint and varnish industry. The drums were later removed by the Kentucky Natural
Resour ces and Environmental Protection Cabinet (KNREPC). Dur in g the cleanup effort U.S.
Army personnel located four dr urn bur ial sites. Between January 1979 and Apr il 1984, the
EPA conducted various surface water, gr ound water, so il, sediment, and well studies.
These studies confirmed the evidence of soil contamination and ground water contaminatic n
(See Attached Sheet)
17. KEY WORDS AND DOCUMENT ANAL. YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Distler Farm, KY
Contaminated Media: soils, gw, sediment
Key con taminan ts: metals, inorganics, organj cs,
ketone, radioactive materials, toluene, TCE, pCE
18. DISTRIBUTION STATEMENT 19. SECURITY CL.ASS (TlJis Reporr) 21. NO. OF PAGES -
None 26 I
20. SECURITY CL.ASS (TlJis page) 22. PRICE
None I
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EPA 'Ofm 2220-1 (ReY. 4-77)
P"IEYIOUS EDITION II OBIOl.ETIt
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EPA/ROD/R04-86/011
Distler Farm
16.
ABSTRACT (continued)
at the site. No significant site-related contamination appeared in surface
waters, sediments or residential wells outside the property boundaries.
Prior to the completion of the RI, contaminated soils was removed from the
site and transported to permitted hazardous waste disposal facilities;
airborne contaminants also are not a problem. Following the removal
operations, the pits were backfilled, and the entire affected area was
graded, cultivated, and sown with grass seed to control erosion. Hazardous
substances in the form of source materials are not present on the site.
Surface storage and burial areas have been confirmed as being contaminated.
These areas were considered to be the likely sources of potential future
re.leases of contamination. The primary contaminants of concern include:
VOCs, PCE, TCE, ketones, toluene, inorganics, radioactive material, and
metals.
The selected remedial action includes: excavation and removal of all
contaminated soils and offsite disposal in a hazardous waste landfill;
backfill with "clean" natural granular soils, extraction of contaminated
groundwater and temporary accumulation and onsite storage; transportation of
. contaminated groundwater to offsite commercial facility and treatment to
background levels; reinjection of uncontaminated water into the aquifer;
maintenance of vegetation, erosion repair, and ground water monitoring for a
one year period. The qapital cost is $11,138,400 with O&M in years 1-10 of
$113,600 and $20,000 for years 11-30. The Commonwealth of Kentucky will
assume O&M costs one year after the remedy is complete.
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RECORD OF DECISION
Remedial Alternative Selection
Site:
Distler Faun, Boon9, Jefferson County, Kentucky
DoCL~nts Reviewed:
- Distler Farm Remedial Investigation
- Distler Farm Feasibility Study
- Summary of Remedial Alternative Selection
- Responsiveness Summary
- Staff Recommendations & Reviews
Description of Selected Remedy:
- Excavate and remove all contaminated soils, dispose in an offsite
. pennitted hazardoos waste landfill
- Backfill with nc1eann natural granular soils, grade to existing
grade and revegetate
- Extract contaminated groundwater, temporarily accumulate and store
on site
- Transport contaminated groundwater to offs~te commercial facility,
treat to background levels
- Reinject uncontaminated water into the aquifer.
- Mow and rraintain vegetation and repair any erosion, and monitor
grounr4w3ter for a period of one year
Declarations
The selected remedy is consistent with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCIA), and the National
Contingency Plan (40 CFR Part 300). I have determined that the excavation
and removal of contaminated soils, pumping and treating of contaminated
groundwater, and reinjection of clean water alternative at the Distler Farm
Site is a cost effective ranedy and provides adequate protection of public
health, welfare, and the environment. The Ccmnonweal th of Kentucky has
been consulted and cqrees with the approved remedy. future operations
and maintenance activities, to ensure continued effectiveness of the
remedy, will be considered part of the approved action and eligible for
Trust Fund monies for a period of one year.
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I have also determined that the action being taken is appropriate when
balanced against the availability of trust fund monies at other sites.
In addition, the off-site, transport, and secure desposition is more cost
effective than other remedial actions and is necessary to protect public
health, v.elfare and the envirorrnent.
AUG 1 9 1986
ffiTE
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Record Of Dac is ion
Summary of Remedial Alternative Selection
Distler Farm Site
Jefferson County, Kentucky
Site Location and Description
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The Distler Farm property, a 13.68-acre farmland tract, is located in the
southwest corner of Jefferson County, Kentucky, approxbnately one mile
northeast of V€st Point, Kentucky. The property is bordered by U.S.
Highway 60/31 W (Dixie Highway) on the northwest: Stump Gap Creek on the.
southeast: and by cultivated fannland on the northeast and south....est
(Figure 1-2, General Site Plan). It is situated about one mile northeast
of the Salt River and the Ohio River confluence at 38°00'40" north.
~ "":~:'1de ar.~ OC:;°55':I)" '~st longitude.
. Drums and containers of industrial wastes were buried and stored on the
surface within this property in an area of about three acres. This.
three-acre area, hereafter referred to as the "Distler Farm Site", is
adjacent to the tree line along Stump Gap Creek, and located about 200
feet fram the southwestern property line and about 1,000 feet fram the
. Ohio River (Figure 1). . .
Site History
The Distler Farm Site was discovered in early 1977 during the development
. of an enforcement case against Mr. Donald F. Distler, owner.of Kentucky
Liquid Recycling; Inc. In an effort to locat~ sites that Mr. Distler may
have used for chemical waste storCQe or dis[X)sal, 'BPA personnel inspected
the Distler Farm Site in April 1977. They re[X)rted approxUnately 600
drums of industrial wastes stored on the ground surface.
In Dacember 1978 the Ohio River and its tributaries flooded, causing drums
of industrial wastes fram the site to be scattered along the floodplain
of Stump Gap CI;"eek. The Q:)vernor of Kentucky declared an environmental
anergency and requested assistance fram the EPA. In January 1979 the EPA
Region IV Environmental Emergency Branch supervised recovery and onsite
storCQe of 832 drums containing chemicals characteristic of the paint and
varnish industry ~ The drums were later removed by the Kentucky Natural
Resources and Environmental Protection cabinet (KNREPC)to approved
hazardous waste disposal facilities. During the cleanup effort U.S. ArMy
personnel from Ft. Knox surveyed the area with metal detectors and found
four drum burial sites.
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Bet¥ken Ja.l"\uary and June 1979 the EPA, in coordination with the f.'l~£.FC,
took surface water and sediment samples fran Stunp Gap Creek, sa'C\;::>led
private wells in the area, and performed a 1 imited soil cori~ stu-jy. A.
private well and surface water sampling and testing program indicated
that these waters were not contaminated by chemicals fran the site. The
coring study showed evidence of soil contamination and probable groundwater
contamination in the area of drum burial pits.
In O::tober 1981 a hydrogeologic study was performed at the site by an EPA
Field Investigation Team (FIT). Eight soil borings were drilled to
depths of approximately 20 feet. Groundwater from three of the boreholes
and four private wells in the area \/.ere scrnpled ard tested. Results of
~C~~~ ~rformed on groundwater samples taken fram a downgradient borehole
showed signs of contamination, while all private wells were free of
'contanination.
In Septanber 1981, and February and July 1982, surveys were performed
to confirm buried drum locations ard to delineate the extent of a suspected
contaninant "J;X>OI" in the groundwater. Buried drum locations were mapPed
and the estimated extent of the suspected contaminant "lX'Ol" was docLlTIented.
The site was later ranked a;Jain, using an upjated MITRE rnooel, resulting
in a MITRE score of 34.62.
In April 1983 the NUS Region IV FIT installed 20 monitoring wells. These
wells were sampled by FIT during July 1983. Seven organic priority
pollutants, nine inorganic priority pollutants, and several ketone and
alcohol derivatives were rep:>rted in the collected_water samples. The
data gathered, however, were not extensive enough to fully define the
extent of contamination nor the movement of contaminants within the
groundwater regime. In September 1983 a remedial investigation was begun
by NUS to define the extent and movement of contamination at the Distler
Farm Site.
In February 1984 EPA halted the remedial investigation work for tv.o months
while accanpl ishing the ".rt3noval.'-ef buried drums and waste containers from
four burial locations. Approximately 120 fifty-five gallon drums and
2,620 smaller containers \/.ere unearthed and sampled. All wastes and
visibly contaminated soil were removed from the site and transported to
permitted hazardous waste disposal facilities. Chanical analyses revealed
that the wastes included toxic, volatile, ignitable, radioactive (l~~
packs) and reactive naterials. Following the renoval operations, the
pits were backfilled, and the entire affected area was graded, cultivated,
and sown with grass seed to control erosion.
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FIOURE 1 lIt.
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: A HaIIoburIc:n CoT'\pany
GENERAL SITE PLAN
DISTLER FARM SITE
JEFFERSON C'O.. K EN TUCK Y
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T,-.,: ra effort was resLnTled in April 1984, with enphasis redh-ected to the
potential for groundwater contamination. The investigation confirmed
that contaminated soils and groundwater \\ere present at the site. 1\0
significant site-related contamination had yet appeared in surface waters,
sediments, or residential wells outside the property boundaries. The RI
also confirmed that airoorne contaminants INere not a problem at the
Distler Farm Site.
NUS completed the RI site investigations in September 1984 and submitted
a Draft RI retX)rt to the EPA in Septanber 1985. The RI assessed the
nature and extent of onsite and offsite contamination resulting fram the
stora;:Je of hazardous wastes on the farm property, and evaluated hazards
to numan health and the environment. The site was characterized in the
terms of:
o GeolOgy and soils
o Surface and groundwater hydrolQJY
o Hazardous substances present
o Nature and extent of contamination
o Contaminant mobility characteristics and migration pathways
o Potential receptors
-0
o Human health and environmental concerns
Details of the remedial site investigation and laboratory analyses
are documented in the IEmedial Investigation lEtX)rt. -
Current Site Status
Hazardous substances in the form of source materials are not present on
the site. Surface storcge and burial areas have been confirmed as being
contaminated. These areas were considered to be the likely sources of
tX)tential future releases of contaminants for the purtX)ses of - the
Feasibility Study. -
Investigations have shown that the site poses no threat to the public
through airborne contaminants. Organic vapor moni torifXJ durin;J the
remedial investigation has not revealed ambient concentrations above four
parts per million. Disturbance of soils beneath the ground surface
during remedial action may cause temporary increases in volatile
contamination of ambient air at the site.
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. .
The absence of contaminants in downstream sediments collected from
Stump Gap Creek demonstrates that site contaminants have not migrated
offsite. Lack of a downstream surface water monitoring statfon durirg
the remedial investigation hinders the understanding of the quality
of surface water downstrean fran the site.
Only one surface water sample, upstream of the site, could be taken
durirg the remedial investigation due to dry weather. Contaminants
of concern found in this semple, taken in July 1984, are summarized
below:
o ~~z~Ldous SUbstances List (HSL) Metals:
Chromium 6 to 7 ug/1 (microgram per liter)
o Total Dissolved Sol ids (TC6): 120 to 160 ng/l (milligram per liter)
o Total Organic Carbon (TOC): 4.9 mg/l
0 Total Organic Halogens (TOH): 22 to 27 ug/l
o Extractable Organic Compounds:
di-n-butyl-phtha1ate l2J ug/l (J: estimated value)
No Vblatile ~anic Canpounds (VOC), Festicides or FCB's were found
in this sanple. Contaminants of concern found in sediment samples
taken in July 1984 were chromium and lead.
Soils at the site are contaninated. The contaminants, however, do
not appear to have been trans[X>rted off the site, even thOl.gh the .
contaninated area is within the 10-yeat flood plain of the C11io River.
Surface water run-off could carry contaminated soils particles to
Stump Gap Creek adjacent to' the site. Available chemical test data
indicate that trans[X>rt by this mechanism has not occurred, or if it
has occurred, it has been diluted to a level approaching background
values of below laboratory detection 1 imits. .
Contaminants of concern found in soil samples taken fran within the
soil contamination area shown on Figure 2 are Chromium, Lead, Benzene,
Toluene, Trichloroethylene, Tetrachloroethylene, Napththalene, Bis
(2-Ethylhexyl) Phthalate, Di-n-Butyl Phathalate, lsophorone.
Test data indicated the contaminants have been released, distributed,
or have migrated to soil depths of six inches to four feet. The
soil samples for this testing program were taken in July and September
1984, several months after the excavation of drum burial pits in
March and April 1984. The drun burial pits are located within the
'soil contamination' area illustrated on Figure 2.
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Groundwater contamination has been detected beneath the site in a
" localized "pool". This "p0')I" of contamination has been contained on
site by virtue of tQpogra~hy, groundwater flow, and soil characteristics.
However, the potential for leakage into a deeper aquifer does exist and
could provide a possible migration pathway for contaminants-to move
offsite. The rate at which contaminants could migrate \oI1Ould probably be
impeded because of "barrier effects" in that aquifer (i .e. the effect of
the Ohio River). No consistent spatial relationship or distribution of
contaminants was found in the deeper aquifer or in offsite residential
wells downgradient of the site. AlthOLgh the "pool" is contained in a
relatively small area, its size is expected to increase gradually, through
lateral dispersion and molecular diffusion of the conta~inants involved.
I:'i.;'--'':~ 2 E! '--'':':~~':,?S t:~'? approximate location and extent of sail and
"groundwater contamination.
The most probable transport mechanism for migration of contaminants
from the site is through groundwater, although no groundwater
contamination has be~n shown to have migrated beyond the confines of the
site. Groundwater movement in the shallow aquifer is to the southeast
across the site in the direction of Stt.rnp Gap Creek. The groundwater flow
in the deeper aquifer is a direct hydrologic interconnection with the
Ohio River.
Contaminants of concern were found in groundwater sa'11.ples taken from
monitoring wells screened in the shallow aquifer and located within
the zone of groundwater contamination illustrated on Figure 2. The
contaminants found were Chromium, Lead, l,l,l-Trichloroethane 1,2 Trans-
Dichloroethylene, Toluene, Trichloroethylen; Vinyl Chloride; Bis (2-
Ethylhexyl) Phthalate; Di-n-Butyl/Phthalate, Isophorone; Naphthalene.
The extent of contamination and the mobility characteristics of
chemicals identified at this site provide the basis for identification
of a contaminant "pool" and migration mechanism.c;. occurrin1 at the
site. The areas identified as drun storage or burial locdtions have
been confirmed as contaminated and are considered likely sources of
potential future contamination for purposes of this discussion.
The most probable transport mechanism currently causing migration of
chemical contaminants from the site is groundwater advection
(longitlrlinal transport attributable to the bulk flow of groundwater)
and dispersion (lateral and vertic spread of chemical substances
owing to groundwater convection ar: iiffusion of Irolecules). Various
- aspects of chemical test data obtained for groundwater samples is
,considered to indicate that a contaminant "pool" may be present at
the site and that contaminants have not migrated offsite through the
groundwater. A consistent spatial (both horizontal and vertical)
relationship or distribution of the majority of the contaminants was
not found.
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Although the known area of groundwater contamination is restricted to
the site, its size is expected to grow. In the case of the Distler Farm .
Site, additional data are warranted to further define the process of
groundwater movement vertically and horizontally.
Other comparatively minor routes of transport of contaminants from
the site incluje the following:
o Contaminated sediment transport via surface water run-off. Surface
water run-off. could carry contaminated soil particles to Stump Gap
Creek. Available chemical test data indicate that transport by
this mechanism has not occurred, or if it has occurred, it has been
~'!iluted to a level approaching background values or below laboratory
~~~P~~50~ li~its.
o Physical transport of site contaminants during flooding conditions
of Stump Gap Creek. Portions of the site are located in the IO-year
floodplain of the Chio River. DJring the lOO-year flood, the site
"'-Duld be inundated. .
o Evaporation of volatile organic constituents to ambient air with
contaminated air moving offsite. Available chemical data gathered
during the RI indicated that surface soils are not appreciably
contaminated with volatile organic contaminants. However, soil
disturbance during remedial action could increase concentrations to
sane degree.
o Direct contact ~th contaminated surface soils and other surface
materials.
Based on present site conditions and data gathered during the RI,
potential human and enviro!1"Oental receptors include the following:
o Nearby user.s of groundwater for drinking purlX'ses. ApproxiTT!~tely
30 hOi\t::S and an autanobile race track locatej v.it.Lin a l4i,ilc
radius of the site use private groundwater wells for their water
supply. In addition, well fields serving west POint, Kentucky
are located approximately four miles south and east of the site.
o Nearby users of groundwater for domestic purposes other than
drinking, such as bathing, food preparation, laundry, and lawn or
garden watering.
o Human contact with surface waters. Chemical test data available
for surface waters suggest that these waters are not now
contaminated by pollutants present at the site.
o Humans consuming game animals (fish, small ani~als) which have
been contaminated by ingestion of bioaccumulative contaminants.
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APPROXIMATE LOCATION AND
EXTENT OF SOIL AND
GROUNDWATER CONTAMINATION
DISTLER FARM SITE
JEFfERSON CO., KENTUCK Y
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o Third-party intrOOers who cane into direct dermal contact with
contaminants present at-the site.
o Onsite renediation \o.Drkers throu;:1h inhalation of ,elevated
concentrations of volatile organic contaminants during 'soil -
disturbance or by direct dermal contact with contaminated soils
and residual wastes. In practice, exposure will be l~ted by
health and safety procedures and equipment.
o Environmental receptors including aquatic biota, terrestrial
fauna, and vegetation that may be stressed.
R:>tential receptors represent those whan the site \o.Duld rrost likely
?~~0St in terms of acute and chronic health implications. Available
data does not indicate or confirm any significant past or present
- human exp::>sure.
ENFORCEMENT ANALYSIS
On November 12, 1985, EPA sent information request/notice letters to
approxi~tely thirty (30) potentially responsible parties (PRPs),
. including Donald Distler, the owner/operator of the Distler Farm
site. The letter requested any records, documents, etc. regardin;:j
business transactions with Kentucky Liquid Recyclers (KLR), informed the
PRPs of their potential liability at the site and offered them each
an opportunity to participate in the desiqn and implementation of
the remedial action plan and to contribute to any monitoring and
maintenance necessary after completion of remedial work.
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Only a small percentage of the PRPs expressed any interest in participating
in the RD(RA procedures and of those that expressed interest, their participation
was conditioned upon EPA providing them more convincing proof of their
l.iabilityat the site. The majority of the PRP responses ~re either
complete denials or professed no knowledge or belief that any business
transactions were conducted with (KLR) or Donald Distler.
A second round of letters to PRPs was issued by EPA on March 12, 1986.
These letters contained information which EPA had compiled that established
a connection betwaen ind ividual PRPs and KLR, provided a list of all
kn~ PRPs and a;;Jain requested copies of any material that pertained to
KLR and the Distler Farm site. The responses to the March 12, 1986,
letters provided additional information regarding several PRPs.
The PRPs have made same attempt to organize a steering ccmndttee in
order to engage in negotiations with EPA. However, to date, said committee
has not been formed and formal negotiations have not been conducted.
Accordingly, at the present time -it is difficult to predict the outcome
of such negotiations.
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The strategy emplo~d by EPA has been to use fund monies unless PRPs
'c.':>i1sent throUJh an enforceable agreement to the cleanup. The RD/RA
s~~tlon of the work remains open for negotiation.
EPA's overriding concern is to ensure that the selected remedy complies
with the National Contingency Plan. In this regard, there is little
flexibility for negotiations. Any technical differences in desi;n and
construction approaches used to achieve the remedy may be the subject
of negotiations. However, as a practical matter, the PRPs have presented
no alternative design and construction models and, therefore, no comparisons
can be made at this time.
Alternatives Evaluation
The purpose of the remedial action is to mitigate and minliTIize
~onta~ination in the soils and groundwater, and to reduce potential
risks to human health and the environment. The objectives in developing
remedial actions at the Distler Farm Site were:
o Soil Contamination:
- Source control
- Reduce concentrations of contaminants
- Control potential migration of surface and subsurface
contaminants resulting fram contaminated soils
- Prevent or minimize surface erosion and
runoff, including environmental hazards
flooding of StLrnp Gap Creek, as well as
C11io River
consequent contaminant
associated with potential
the Salt River and/or
'. r. ;. I minimize, or eliminate the (,~sit8 !)()tential for
e"~.., '.~ by direct <::r:mtact; the onsitr~ IY)!.-..,~!tial for airborne
releases; the potential for contaminant migration by surface water
pathways; and the migration of contaminants to groundwater.
o Groundwate~ Contamination:
- Management of migration
- Prevent increases of contaminant concentrations
- Reduce concentrations of contaminants
- Prevent or minliTIize further migration of contaminants ("lX'Ol"
control)
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An initial screening of applicable alternative technologies was
performed to select those which best ~t the criteria specified in
Section 300.68 of the National Contingency Plan (NCP). Following
initial screening of technologies, potential remedial action alternatives
were identifed and analyzed. These alternatives were screened and
the most promising were retained and were developed further.
Table 3 sLmTlarizes the results of the screening process. Each of the
six remaining alternatives was evaluated based upon technical.
considerations, institutional issues, environmental issues, public
health aspects, and cost criteria. A cost summary is presented in
Table 4. The results of this final evaluation are given below.
Alternative I:
No Remedial Action
TMoAr this no-action alternative, remedial activities would not be
performed. Soil and groundwater contamination would be left in their
current conditions. As it exists, the site would continue to be a
potential source of future contamination. Contaminants have been
present in surface materials for about eight years. Same might have
volatilized and will continue to do so, decreasing in concentration.
Others, especially the less mobile compounds, would remain as they are
now. Sane would continue to migrate into groundwater by infiltration.
Contaminated groundwater could eventually migrate offsite. Private
wells downgradient from the site might be affected by the contaminant
"pool" at some future time, if no remedial actions are performed on
the groundwater.
Regulatory requirements and strategies in connection with protection
of groundwater exist. The aquifer underlying the site could be
classified as Class I, which would indicate that it could be a sole
source of drinking and domestic water supplies for downgradient
conmnunities. Regulations require that such aquifers not be degraded
or contaminated. This option does not satisfy any currently applicable
or relevant State or Federal (RCRA) standards for the closure of a
site containing hazardous mater.ials and wastes.
Available data indicate that potential receptors are not presently exposed
to signifcant le'lels of contaminants and are not exposed to an imnediate
health risk. However, potential receptors could be exposed at same future
tLme if migration of contaminants were to occur specifically, through
ingestion or dermal contact with surface waters and surface materials,
and groundwater. Based upon the above consideration of public health,
this no action alternative has been rejected.
Alternative 2:
Soil Contamination: Surface Capping
Surface Grading and Revegetation
GrOlmdwater Contamination: No Remedial Action
This alternative involves the placement of a seal, or cap, over contamined
areas. Contaminated soils would remain in place and be covered by the
cap. There is no remedial action with respect to groundwater contamination,
and the contaminant "pool" is left in its current state. The purpose of
this alternative is to reduce the impact of contaminants in site soils by
reducing risks associated with direct contact and by reducing potential
of contaminant migration via surface water, groundwater and air pathways.
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-10-
The expected design life of such a sealin;;1/capping system is about 30
}ears. '!his is based on the performance of other caps of sirrlilar desigl"\.
This alternative, by the installation of a cap, would reduce threats to
air, surface water and groundwater pathways that currently exist at the
site. As a source control option, capping would reduce contaminant
migration due to infiltration, which would reduce the contamination that
would otherwise reach the underlying groundwater.
This option would mitigate further degradation of groundwater but not
migration of contaminants in the groundwater. Contaminated groundwater
would continue to move in its current southeast direction. This alternative
has been rejected because other alternatives exist which provide much
;~~a~er ~~~~==~:~~ ~f public health and the envirorment.
AI ternati ve 3: Soil Contaminat ion: Surface Capping:
Grading and Revegation
Groundwater Contamination: Extraction/Injection
Offsite Treatment/Disposal
This alternative involves the placement of a seal, or cap, over
contaminated areas. Contaminated soils would remain in place and be
covered by the cap. Contaminated groundwater would be extracted throLQh
pumping wells and t~eated or disposed at an offsite permitted commercial
facility. Uncontaminated water would be injected into the aquifer.
The objective of this remedial action is to reduce the concentrations of
contaminants in the groundwater to levels wher~ potential risks to human
health and the envirorunent -are also reduced to acceptable levels.
Groundwater remediation criteria intended for this alternative is the
Preliminary Protection Concentration Limits (PPCL) based on 10£-6 Unit
Cancer Risk.
The movement of the groundwater may be relatively slow and the induced
drawdown can be large within this aquifer because of the low hydraulic
conductivity. Therefore, the "flushing" action of water extraction fran
the aquifer could be relatively localized. In order to decrease the size
of the possible "dead zone" (area outside the drawdown zone) and to
increase the "flushing" effect within the aquifer, the canbined use of
extraction and injection wells was considered to be more effective in
comparison to using extraction wells only.
This alternative has been rejected due to design considerations which
were not inclLrled in the Feasibility Stlrly. '!he Distler Farm Site lies
in the 10-}ear flood plain of the Ohio River. During a flood event, an
impermeable cap would fail due to an upward vertical hydraulic gradient
in the groundwater. The frequency and high probability of such floods
precllrle the use of an impermeable cap.
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1-
SCALE .. FEET
SrTE LOCATION MAP
DISTLER FARM SITE
JEFFERSON COUNTY. KY
FIGURE ES-1
GNU~
LO CORPORATON
o A Halliburton Company
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-11-
.'\l<:ernati':E:' 4: Soil CC'r,tamination: Surface Capping ("ReM Ca~");
Grading and Revegetation
Groundwater Contarnination: Extraction/Injection:-
Offsite TreatmentjDisposal
Surface
This alternative involves the construction of a seal or cap over cont~inated
areas. Contaminated soils and materials would remain in their existing
place and be covered by the cap. Contaminated groundwater would be
extracted and treaten/disposed at an offsite permitted commercial
facility. Uncontaminated water would be injected into the aquifer.
Tnis alternative is identical to Alternative #3 in almost all aspects
reiaL~ LO capping dlill groundwater remediation. The only differences in
Alternative #4 are that the surface seal would be a RCRA type cap, and
-that groundwater remediation would be to Maximun Contaminant Levels (MCL)
and Preliminary Protective Concentration Limit Levels (PPCL).
This alternative has been rejected due to the frequency of flooding at
the site. As with Al ternative #3, vertical hydraulic gradients during
floOOing would cause failure of the impermeable cover.
- AI ternative 5: Soil ContaMination: Surface Capping ("RCRA Cap"):
Grading and Revegetation
Groundwater Contamination: Extraction/Injection;
Offsite TreatmentjDisposal
Surface
This alternative was rejected, as ~re Alternativ~s #3 and #4, because of
cap failure due to flooding, groundwater would be cleaned to background
levels.
AI ternative 6:
Soil Contamination: Excavation to Background;
Backfilling; Offsite Landfill Disposal;
Surface Gr:1:J 1 nq ,o,:d Re',' -, :.-~'tation
Groundwater Contamination: Extraction/Injection:
-t Offsite. TreatmentjDisposal
This alternative represents a more comprehensive cleanup alternative
than preceeding alternatives as nearly all contaminated soils would be
removed fran the site and disposed in an offsite permitted hazardous
waste landfill. lliring excavation, periodic sampling will assure
that when "Background" Levels as shown in Table A are reached,
excavation will cease. For estimating purp:>ses, this depth was assUl'!1ed
to be eleven feet (11'). Since contaminated soils would be excavated,
sources of potential future contamination would be removed: therefore,
a seal or cap is not called for in this alternative. Excavations
would be backfilled; "clean" native granular soils v.ould be suitable
for this purpose. The final surface of backfill would be graded to
converge wi th local to};X)graphy, and revegetated.
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-12-
Groundwater would be extracted, temporarily accumulated in onsite storage
tanks and transported to an .offsite cammercial treatment/disposal facility.
Uncontaminated water would be injected into the aquifer. Groundwate~
remediation criteria under this alternative would be to backgrouDd levels.
Maintenance of the restored surface and monitoring to insure the
quality of the groundwater will be continued for a period of time
which will be adequate to assure the permanence of the remedial measures.
This alternative was selected since it is the only alternative proposed which
is consistent with other environmental laws.
Alternative Suggested By Public at Public Meeting
( Public)
The City of west Point offered to extend water service to the residents of the
areas surrounding Distler Farms which might be Lmpacted by migration of
contaminated groundwater. The same offer was made by the Louisville Water
.Company which included serving the City of west Point for about $700,000.
Although this alternative would assure all residents of high quality water
supply, it would permit the. contamination to remain on site and would be the
same as the no action alternative with the addition of public water.
This alternative is environmentally unacceptable since all receptors continue
to be exposed, except for those who consure groundwater. Since the contaminated
groundwater will remain a threat to the Ctlio River, as would be perceived by
~io River Sanitation Coornission (ORSANCO), the alternative is both environmentally
and politically unacceptable.
Alternative Technology Alternative
The possible use of bianass at the site was investigated and r~viewed. In order
to determine the feasibility and Umplementabilityof the technique, a three (3)
month stooy would be required, after which a public meeting and the concanitant
ccmnent period would be required. This alternative had not been presented to
. the puhlic at an earlier date. This is an unproven technology over the long
term, and the dependability factor is questionable. For this reason and the
need for at least a six (6) month delay, this alternative was not considered
further.
Community Relations
The surrounding ccmnunity has concern over the condition of their drinking water.
The level of concern was not high as a result of the public meeting held to
present the findings of the RIfFS. The meeting was attended by 30+ people, and
written oamments were received from one private citizen, two attorneys for PRPs
and the Louisville Water CaTlpany in which they expressed interest in supplying
water to these residents.
The Carm:mwealth of Kentucky also supplied written camments. In general, of
those commenters addressing the alternative selection, alternatives #5 and
#6 were preferred.
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CONSISTENCY WITH OTHER ENVIRONMENTAL lAWS
It is EPA Policy to give primary consideration to remedial actions that
attain or exceed applicable or relevant Federal environmental or public
health standards. .
State and local standards should also be considered; however State standards
that are more stringent than Federal standards may form the basis for the
remedy only if the result is consistent with the cost effective remedy
based on Federal standards. The State may also pay the additional cost
necessary to attain the State standard(s). The environmental or public
health laws which may be relevant or applicable to the site are:
- "P?S0'..:rce Conservation and Recovery Act (RCRA)
The Resource Conservation and Recovery Act (RCRA) will apply to final
action at the site since the selected alternative requires excavation
and offsite landfill disposal. Therefore the disposal site will be
required to be in compliance with RCRA requirements, by either having
interim status or being fully permitted. .
- Floodplain Management Executive Order ll988(E.O. 11988)
Floodplain management is a primary concern at this site since it is
completely within the lOa-year flood plain and partially within the 10-
year flood plain. -Although the placement of a cap would not adversely
effect the floodplain, the fact that the site is within the floodplain
ensures that even the placement of an Uffipermeable cap would not,
necessarily, preclude the 'infiltration of floOd waters which would
percolate through the contaminated soil and thereby perpetuate
contamination of the groundwater which renders alternatives 1-5
unacceptable on a environmental basis.
Clear \'!3ter Act (CWA)
The action proposed at the site by this document will comply with the
requirements of the act since there is no surface water contamination
attributable to this site.
- Occupational Safety and Health Administration (OSHA) requirements.
Any applicable OSHA requirements will be addressed during the detailed
design phase of the selected alternative. OSHA requirements address such
concerns as on-site worker safety and health. All alternatives can be
designed to be in full compliance with all OSHA requirements. .
- Groundwater Protection Strategy (GWPS)
The GWPS is an applicable standard for this site. The cleanup of the
groundwater to levels reccmnended by Region IV Office of Groundwater
Protection would require 13 years to accomplish. The selected alternative
will guarantee clean water for user of the groundwater.
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-14-
- ::Epartment of Transportation
DOT requirements for movements of hazardous wastes will be carefully
observed during any transportation of materials for the site.
- Other
There are no other known applicable or relevant Federal laws or r~Julations
which apply to this site.
FlOODPIAIN ASSESSMENT
The Distler Farm Site is located near both the Ohio River and the Salt
::~.-.:..;.-. The Ohio River Division of the u.S. ~partment of the Arlny, COL-f'.3
of Engineers, has determined, through frequency studies, water surface
-elevations for various flood conditions (Wtight 1986):
Frequency
10 - year
25 - year
50 - year
100 -. year
500 - year
Elevation
431.8 feet
436.1 feet
439.9 feet
442.9 feet
449.0 feet
The Distler Farm site lies at elevations between 400 feet and 425 feet.
Occurence of a 100-year flood would inundate the majority of the site.
At the Distler Farm site, remedial actions woulq be designed, constructed,
operated, and maintained to prevent washout of hazardous materials by a
flood event.
The area of the site affected by any proposed remedial action will be
less than three acres. This is quite small, even insignificant, compared
to adjacent areas in the 100-year floodplain. Any proposed remedial
action would not be expected to have any calculable eff8ct on flood levels
or flood vol~s.
. Since the surrounding area is within the lOO-year floodplain, present
. land use is not expected to change from its predominately rural status.
The Planning Commission of Louisville and Jefferson County has designated
the area in which the Distler Farm site lies as being unsuitable for any
new residential developnent. Thus, any proposed remedial action would
not lead to further development that would create additional floodplain
impact.
EPA Feasibility Study (FS) evaluated remedial alternatives are described
in the FS and briefly summarized in the April, 1986 Fact Sheet. Although
some suggestions recommending alternatives have been communicated to EPA
verbally, written recommendations have not been received to date, from
either the public or the PRPs.
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-15-
Recommended Alternative
In compliance with the National Oil and Hazardous Substances Pollution
Lontingency Plan (40 CFR 300.68), the alternative recommended in this
document is an alternative which will resolve the environmental problem
at the site and will adequately protect the public health and welfare.
The Do-action alternative does not adequately ensure that the ptblic
health, welfare and the environment w~uld not be degraded further. The
alternative which would implement installation of a cap with no
remediation of the groundwater was removed fram consideration because
groundw3ter is the primary exposure route and would not prevent further
degradation and migration of the contaminated groundwater. The third
alternative which proposed installation of a cap and groundwater remediation
to oreliminary protection concentration limits (PPCL) did not offer
. adequate reduction of groundwater contaminants. This, and the continuing
_proba~ility of the percolation of floodwaters through the contaminated
soits which would remain onsite made this alternative unacceptable
environmentally. The fourth alternative proposed a "RCRA" cap and reduction
of groundwater contamination to maximLrn contamination limits (MCL) and
PPCL levels. Once again the frequency of flooding at the site would
most likely cause failure of the impermeable cap and the floodwaters
would percolate through the contaminated soils under the cap. For these
reasons this alternative was also judged to be environmentally unacceptable.
The alternative suggested by-the public meeting which suggested extending
water service to the residents was considered to be environmentally
unacceptable since the contaminated groundwater would continue to migrate
and would eventually enter the Ohio River. Table 4 indicates that the
baseline capital costs for the recommended alternative is $11,138,400, and
o & M in years 1-10 of $113,600 and years ll-30-l)f $20,200, which results
in a present worth baseline of $11,996,000.
Operation & Maintenance (0 & M)
~'hi~ ':,dy will require 13 years to accomplish. The operating costs
'.vi 11 ;).: for palNer. for pLrnps, maintenance of these punps and injection
devices and site maintenance as well. When the remedy is completed, the
only 0 & M required will be to maintain the restored site by mowing and
repairing erosion gulleys which might occur in the restored areas and
continued monitoring to insure the permanence of the remedy.
The Commonwealth will not be responsible for 0 & M until one year after the
remedy is completed and will be responsible for mowing of ground cover
and repair of eroded areas and monitoring at that tline. The Oammonwealth
will fund its portion of this remedial effort fram it's own "Superfund"
and 0 & M and legislative allocations as needed.
It is recommended that this site be funded at 90% federal funds and 10%
Oammonwealth funds, with a one year period of 0 & M to commence after all
remediation has been completed and the site restored.
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-16-
Schedule
--
The planned schedule for completion of the cleanup at the Distler Farm
Site is as follows:
August 20, 1986
Record of Decision
The Commonwealth has indicated that they do not have the reQ~ired 10%
matching funds available at this tLme. A schedule for cont~nuation of
remediation at the Distler FaDm Site is contingent upon the si~ultaneous
avail abil i ty of both Federal and Ccmmonweal th fund ing. At such time, ten
(10) months will be required for design; six (6) months is required to
~o'p~~ ~ con~r~r~0r: ~fter which 13 years of activity at the site will
culminate in a full remediation of the contamination at the site.
Future Action
As part of the design, additional studies will be performed to completely
define the areal extent of contamination in the groundwater. There will
be no need for any further action at this site. The proJX)sed remedy is a
permanent, complete remedy of the contamination at the site.
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.
TABLE A
BACKGROUND CONCE!\'TRATIONS FOR ecNrA~INANTS OF CONCERN
DISTLER FARM SITE
GROlJt\rrJ.VATER
CONTA!-1INN\1T SOILS UG/L UG/L
l,l,l-Trichloroethane 2.5 5
Benzene 2.5 5
] .1-Dichloroethene 2.5 5
_TranS-l,2,-Dichloroethene 2.5 5
Tolt.ene 2.5 5
Trichloroethene 2.5 5
2-Butanone 100 5
Naphthalene 10 20
bis(2-ethylhexyl)
phtalate 10 20
Arsenic 20R 4.9
O1ranillT\ cetect ion Limit 4.4
Lead cetection Limit 5
." ..". -
Background values are actually the detection limits (i.e., canpound was
analyzed for but not detected). 'l11is is true for all canpounds
except Arsenic in soils.
Note:
R
Laboratory qualifier indicating result is a false positive.
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TABLE 3
SlfttMARy OF EOrENTIAL REMEDIAL ACrION ALTERNATIVES
DISTLER FARM SITE
Alternative
Surface Contamination
1
No JeneSal; Surface GraHng.
and Revegetation
Puhlic
No Jane
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~--- -... -..-- "-- -.-
-
. TABLE 4
COST SlMMARY OF IUfIoNrIAL RFMEDIAL ACTION ALTERNATIVES
DISTLER FARM SITE
ALL COSTS IN nIOUSANOO OF OOLU\RS ($OOO'S)
Remedial Action Alternative
1 2 3 4 5 6 Publ ic
Baseline Capi tal 65.0 192.9 387.2 387.2 11 , 138. 4 700
Costs
Total ?Perat i net
and MaIntenance
Costs
Year 0 0.2 44.6 44.6 44.6 44.4
l-~O 1.2
1-3 114.9
4-30 21.5
1-6 114.9
7-30 21.5
..
1-10 114.9 113.6
11-30 21.5 20.2
Present \'brth
Range
High 318 705 1,075 1,245 14,770 N/A
Baseline '309 671 1,040 1,210 11,996 700
Low ~02 638 934 1,104 9, 780 N/A
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TABLF. 3
SUMMARY OF rofENTIAL R~"MEDIAL ACTION ALTF.:RNATIVF.S
DISTLER FARM SITE
Surface Contamination
Alternative
PPCL:
~1CL:
No Remedial Action
I
2
Surface Capping ("CERCI.A Cap");
Surface Grading and Revegetation
3
Surface Capping ("CERcrA Cap");
Surface Grading and Reveqetation
4
Surface Capping ("RCRA Cap");
Surface Grading and Revegetation
5
Surface Capping ("RCRA Cap");
~;urface GrJding and Revegetation
6
Excavation to Shallow Groundwater;
Backfillinq; OfEsite Landfill
Disposal; Surface Grading
and Revegetation
Pub 1 ic
No Remedial Action
Groundwater Oontamination
Method
No Remed ial Action
No Remedial Action
Groundwater Extraction/Injection;
Offslte Treatment/Disposal
Groundwater Extraction/Injection;
Offsite Treatment/Disposal
Groundwater Extraction/Injection:
Offsite Treatment/Disposal
Groundwater Extraction/Injection;
Offsite Treatment/Disposal
No Remedial Action
Pr,~l iminary Protective Concentration Limit based on 10-6 Unit Cancer Risk
Maximum Contaminant level
Remed ia t ion
Criteria
PPCL
MCL, PPCL
Background Levels
Drinking Water
Standards
None
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TABLE 4
COST SlMMARY OF roTENTIAL RFMEDIAL ACTION ALTERNA' '!-VES
DISTLER FARM SITE
AU.. COSTS IN THOUSANDS OF DOLLARS ($OOO'S)
Remedial Action Alternative
1 2 3 4 5 11 Public
Baseline Capital 115.0 192 . 9 387.2 387.2 1l,138.4 700
Costs
Total Operating
and ~1aintenance
Costs
Year 0 . 0.2 44.6 44.6 44.6 44.4
1-30 1.2
1-3 114.9
4-30 21. 5
1-6 114.9
7-30 21.5
1-10 114.9 113.6
11-30 21.5 20.2
Present \-k)rth
Ranoe
Hilfh 318 705 1,075 1,245 14,770 N/A
RaseJine 309 67] J,040 ],210 ]1,996 700
Tow 302 018 C) 34 I, 104 g,7HO N//\
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