United States
Environmental Protection
Agency
Office ol
Emergency and
Remedial Response
EPA/ROD/R04-86/01S
August 1988
Superfund
Record of Decision
Distler Brickyard, KY
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TECHNICAL REPORT DATA
/Pteue read Instructions on the rtvtne before completing)
1. REPORT.NO.
EPA/ROB/RQ4-8"6/015
2.
4. TITLE ANO SUBTITLE
SUPERFUND RECORD OF DECISION
Distler Brickyard, KY
7. AUTMORIS)
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
12. SPONSORING AGENCY NAME ANO ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. RECIPIENT'S ACCESSION NO. " ~
5. REPORT DATE
net- 1Q_ 1 Qflfi
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO
10. PROGRAM ELEMENT NO.
1 1 CONTRACT/GRANT NO.
13. TYPE Of REPORT ANO PERIOD COVERED
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
The Distler Brickyard site is located near the Ohio River, approximately one-half
mile south of West Point, Kentucky and about 17 miles southwest of Louisville. The
3-acre site is located on a 70-acre abandoned brick manufacturing plant property, and
portions of the site lie within the 50-year and 100-year flood plains of the Ohio
River. The site consists of the brick complex and associated buildings, and an open
field covered with grasses and shrubs. In 1976, Mr. Donald Distler leased the brickyaal
property from Mr. Thomas Hoeppner, the owner, and began disposing wastes from Distler'
Kentucky Liquid Recycling, Inc. firm. In December of 1976, KNREPC learned of the
disposal and conducted investigations at the site. These investigations led to Franklir
County serving a restraining order to Mr. Distler to discontinue disposal of wastes at
the site. Despite the order, disposal continued until January 1979, when KNREPC issued
an order to abate operations., A partial removal of drums occurred, leading to later
removal of 2,310 drums and visibly contaminated soil. Contents of the drums included
liquids, sludges and solids found to be corrosive, volatile and flammable. The RI/FS,
begun in April 1984, indicated soil and ground water contamination in the site area.
Primary contaminants of concern are VOCs including TCE, DCE, benzene and toluene,
naphthalene, bis ( 2-ethylhexyl ) phthalate, and heavy metals.
(See Attached Rhp#»t )
17.
a. DESCRIPTORS
KEY WORDS ANO DOCUMENT ANALYSIS
b. IDENTIFIERS. OPEN ENDED TERMS
Record of Decision
Distler Brickyard, KY
Contaminated Media: soil, gw
Key contaminants: VOCs, heavy metals,
TCE, DCE, toluene, benzene, base-
neutral compounds
18. DISTRIBUTION STATEMENT
19 SECURITY CLASS / Tins Ktporti
None
20. SECURITY CLASS p fin page/
c: COSATi Field. Crou;
82
22. PRICE |
EPA Form 2220-1 (Rev. 4-77) PMCVIOUS coi TION i > OBSOI.CTC
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EPA/ROD/R04-86/015
.Distler Brickyard, KY
16. ABSTRACT (continued)
The selected remedial action for the site includes: excavation and
offsite disposal of soils contaminated above background levels in areas A
and B; backfilling with "clean" natural granular soils; grading surface to
existing grade and revegetating; and extraction and offsite treatment of
contaminated ground water to background levels and reinjection into the
aquifer. Estimated present worth cost of the remedy is $7,500,000 with O&M
costs of $1,568,000 for years 1 and 2, and $44,000 for years 3-30.
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RECORD OF DECISION
""' — Remedial Alternative Selection
Sitet Distler Brickyard, Hardin County, Kentucky
Documents Reviewed:
-Distler Brickyard Remedial Investiqation
-Distler Brickyard Feasibility Study
-Summary of Remedial Alternative Selection
-Responsiveness Summary
-Staff Recoitmendation Reviews
Description of Selected Remedy;
- Excavation of contaminated soils to a depth where contaminant
concentrations are at background levels in areas A & B.
- Backfill with "clean" natural granular soils
- Grade surface to existing grade and revegetate
- Offsite landfill disposal
- Extraction and off-site treatment of contaminated groundwater to
background levels and reinject into the aquifer
- Mowing and maintenance of vegetation and repair of any erosion for
a period of one year
DECLARATIONS
The selected remedy is Consistent with the Comprehensive Environmental
Response Compensation, and Liability Act of 1980 fCERCLA), and the
National Contingency Plan (40 CFR Part 300), I have determined that the
excavation and removal of contaminated soils and pumping treating of
contaminated groundwater with reinjecting clean water alternative at the
Distler Brickyard site is a cost effective remedy and provides adequate
protection of public health, welfare and the environment. The Commonwealth
of Kentucky has been consulted and agrees 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.
I have also determined that the action being taken is appropriate when
balanced aqainst the availability of trust fund monies at other sites.
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In addition, the off site disposal is more cost effective than other remedial
actions and will provide protection to public health, welfare and
<"anvironment •
£f. -
0 f
Regional Administrator
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RECORD Or r>rCISION
Summary of Remedial Alternative Selection
DISTLER BRICKYARD SITE
Hardin County, Kentucky
Site Location and Description
The Distler Brickyard Site is located near the Ohio River, approximately
one-half mile south of West Point, Kentucky and about 17 miles southwest
of Louisville, Kentucky (Figure 1). It is located on a 70-acre abandoned
brick manufacturing plant property, which is divided by Dixie Highway
(l£,S. Route 60/31W). Waste storage activities have occurred within a
three-acre area ('Distler Brickyard Site1) on the eastern half of the
property, east of the highway. Portions of this site lie within both the
50-year and 100-year floodplains of the Ohio River and flooding may be
expected to occur again in the future.
The three-acre site includes the brickyard complex, which consists of
five brick kilns, a combined office/blower house, and a large warehouse
adjacent to the kilns (see General Site Plan, Figure 2). The balance of
the waste storage site, south of the brickyard complex, is an open field
covered with grasses and shrubs. The surrounding area is primarily
forested land. An unnamed tributory of Bee Branch receives run off from
the site. An Illinois Central railroad track runs through the site
parallel to the brick kilns. Several house foundations and an old barn
are situated about 300 feet to the east of the railroad. A dirt road
runs from the area of the foundations due west, across the railroad tracks
to the Dixie Highway. A chain-link fence parallels Dixie Highway, with a
gate at the dirt road; this gate is the main entrance into the property.
Other boundaries of the property are unprotected.
Site History
The Hardin County Brick and Tile Company operated the brick manufacturing
plant from the 1950's through the mid-1970's. Kentucky Liquid Recycling
Inc., founded by Mr. Donald Distler, leased the brickyard property from
'the owner, Mr. Thomas Hoeppner, and began transporting wastes to the site
in the fall of 1976.
KNREPC first learned of the waste storage activities at the brickyard
property in December 1976. In April 1977 the EPA and KNREPC conducted an
initial site inspection and sampled 28 drums. Later in April, the Franklin
Circuit Court served a restraining order on Mr. Distler prohibiting storage
or disposal of industrial wastes at the brickyard property. Despite the
restraining order, active storage operations apparently continued until
January 1979, when KNREPC issued an Order to Abate and Alleviate Operations.
This action prompted a partial removal of drummed wastes from the property.
Apparently no additional wastes were brought onto the property after that
time. Between January 1979 and December 1981 KNREPC issued several follow
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DISTLER BRICKYARD
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SITE LOCATION MAP
DISTLER BRICKYARD SITE
WEST POINT, KENTUCKY
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RQURE 1-1
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DR.-.?T
TABLE t*
SUMMARY OP REMEDIAL TECHNOLOGIES SCREENING
D1STLER BRICKYARD SITE
Retained for
Technology . Further Consideration
Surface Sealing/Capping Yes
Surface Grading and Revegetation Yes
Surface Water Diversion Yes
Leachate Collection Yes
Excavation/Removal of Contaminated Materials Yes
Hydraulic Dredging No
Landfill Disposal Yes
Land Treatment No
Incineration No
«
Solution Mining No
Microbial Degradation • No
Groundwater Extraction Yes
Plume Containment Yes
Water Table Adjustment No
In-Situ Treatment of Groundwater No
Engineered Impermeable Barriers Yes
Permeable Treatment Beds No
Groundwater Treatment Yes
Forced-Air Stripping Yes
Carbon Adsorption Yes
Precipitation, Flocculation and Sedimentation Yes
Filtration Yes
Biological Treatment Yes
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DRAFT
2- TABLE US 3
RESULTS OF REMEDIAL ACTION ALTERNATIVES SCREENING
DISTLER BRICKYARD SITE
Media
Description of Alternative
Retained
for Further
Consideration
Soil Contamination
Groundwater
Contamination
No Remedial Action
Surface Sealing/Capping Surface Grading and
Revegetation
Surface Sealing/Capping; Surface Grading and
Revegetation; Surface Water Diversion
Surface Sealing/Capping; Leachate Collection and
Onsite Treatment; Surface Grading and
Revegetation; Surface Water Diversion
Partial Excavation and Removal of Contaminated
Materials; Landfill Disposal Onsite; Surface
Sealing/Capping; Surface Grading and Revegetation
Partial Excavation and Removal of Contaminated
Materials; Landfill Disposal Offsite; Surface
Sealing/Capping; Surface Grading and Revegetation
"Total" Excavation and Removal of Contaminated
Materials; Landfill Disposal Onsite; Backfilling;
Surface Grading and Revegetation
"Total" Excavation and Removal of Contaminated
Materials; Landfill Disposal Offsite; Backfilling-,
Surface Grading and Revegetation
No Remedial Action
Impermeable Barriers; Plume Containment
Groundwater Extraction/Treatment; Plume
Containment; Impermeable Barriers
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
No
No
Groundwater Extraction/Treatment
Yes
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up orders to Mr. Distler for removal of the industrial wastes stored on
the property. No action resulted. In nscenter 19B1 KNRFPC requested
that the -EPA initiate an immediate removal action at the site.
In March, 19R2 the EPA removed 2,310 drums from the site. Of these, 850
were empty. The remainder contained various liquids, sludges, and solids,
which were found to be toxic, corrosive, volatile, or flanmable. All of
the drums and drummed wastes had been stored above-ground. During the
cleanup operation it became evident that some drum contents had been
released, and that soil contamination existed. Patches of contaminated
soils were also removed at this time. Small containers of wastes, found
in underground air passages in the five kilns, were also removed.
When all drums containing wastes, and visibly contaminated soils had been
removed, the principal remaining concerns regarding the site were possible
buried wastes, soil contamination, groundwater contamination, and the
potential for surface water contamination. In March 1983 the NUS Field
"investigation Team (FIT) under a Technical Direction Document(TDD)
contract with EPA Region IV, completed subsurface investigations,
installation of 10 aroundwater monitoring wells on or near the site, and
a groundwater sampling and analysis program. Offsite wells, surface
waters, and sediments were also sampled during this investigation.
The purpose of the FIT investigation was to determine whether groundwater
contamination had occurred as a result of past waste storage practices.
Vhile installing the monitoring wells, the FIT also explored suspected
drum burial areas that had been identified by a maanetcmeter survey
performed in February 1982. No buried drums were found.
From groundwater samples, the FIT investigation confirmed the presence of
contaminated groundwater, but the data were not extensive enough to
fully define the extent of groundwater contamination or the movement of
contaminants within the groundwater regime.
The RI, begun in Anril 1984, confirmed that the site did not contain
buried wastes. It also confirmed that contaminated soils and groundwater
are present at the site. Further investigations have confirmed that no
further significant site-related contamination has yet appeared in surface
water, site sediment, or residential wells outside the property boundaries,
Also, the RI has confirmed that airborne contaminants are not a problem
at the Distler Brickyard site.
NUS completed the RI site investioations in September 1984 and submitted
a Draft RI report to the EPA in September 1985. The RI assessed the
nature and extent of onsite and offsite contamination resulting from
the storage of hazardous wastes on the brickyard property, and evaluated
hazards to human health and the environment. The site was characterized
in terms of:
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-3-
* ° Geology and soils
°" Surface and aroundwater hydrology
0Hazardous substances present
0 Nature and extent of contamination
0 Contaminant mobility characteristics and migration pathways
0 Potential receptors
0 Human health and environmental concerns
Details of the remedial site investigation and laboratory analyses are
documented in the Draft Rentedial Investiaation Report submitted by NUS to
the EPA in September 1985. (A revised RI report, containing EPA review
comments and NUS responses, was submitted to the EPA in March
1986.)
Current Site Status
The hazardous substances in the form of source material are not present on
the site. Drum storage areas and some suspected spill locations have
been confirmed as being contaminated. These areas are considered to be
the likely sources of possible future releases of contaminants.
The site poses no threat to the public through airborne contaminants.
Organic vapor monitoring at various times since January 1982 has not
revealed concentrations above four parts per million.
Surface water and sediment samples showed little contamination, by either
organic or inorganic compounds, that could be attributed to onsite
contaminants.
The absence of substantial contamination of surficial soils by the more
mobile organic compounds indicates that volatilization or mass transfer
of chemicals into runoff and surface water does not constitute a miaration
pathway at this tiine.
The presence of the less mobile organic and inorganic compounds in surficial
soils indicates that erosion of contaminated soils could constitute
a migration mechanism. The absence of these substances in sediments and
surface water samples offsite leads to the conclusion that migration by
this pathway has not occurred to an appreciable extent in the past. Storm
events of unusual intensity or flooding could reverse this trend. Portions
of the site lie within both the 50-year and 100-year floodplains of the
Chio River and flooding may be expected to occur in the future.
Volatile, semi-volatile and trace element contamination of site soils has
been confirmed. Groundwater contamination by volatile and semi-volatile
contaminants has been confirmed.
Surface Water/Sediment Contamination
Chemical analyses have revealed little contamination of surface water or
sediment samples. Organic compounds were detected in surface water bodies
during 1984 sampling round.
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These compounds (Phthalate esters) have been detected at their highest
concentrations in surface water samples obtained upctre;jn of the site.
The possibility that these contaminants are site-related is considered
to be remote; their presence in the upstream sample may indicate that
their presence in samples obtained closer to the site might also be
attributable to another source.
The results of analyses of surface water samples for inorganic compounds
also indicate no definitive site-related contamination. The only trace
element detected above the National Interim Primary Drinking Water Standard
(NIPEWS) was manganese.
Results of chemical analyses on sediments also reveal little site-related
contamination. Organic contaminants have been identified in sediment
samples obtained during a 19*4 sampling round from the unnamed tributary
to-'Bee Branch just above its confluence with Bee Branch. These contaminants
may be site related as they were detected in other media at the site.
Comparison of inorganic analytical results for upstream and downstream
sediment samples reveal little site-related impact with one exception.
Lead, detected in samples taken near the site (18 mgAg and 37 mgAg) is
the only trace elejrent that differs substantially frcm the concentration
detected in an upstream sample (8J mgAg)« 'J1 is a laboratory qualifer
indicating the value is approximate.
Soil Contamination
Chemical analyses indicate that surface soil samples taken in the vicinity
of monitoring well EB-GW-11 contain volatile organic compounds. A
surface soil sample collected in the vicinity ot monitoring well EB-GW-04
contained Trichloroethene at a concentration of 6,600 ugAg (micrbgrams per
kilogram).
Contaminants of concern identified in the soil near DB-GW-11 include:
Trichloroethene, and 2-Butanone. With the exception of Trichloroethene,
none of these compounds was detected in other soil samples obtained at the
site. Trichloroethene was identified in one sample to the east of the
railroad tracks at a concentration of 6,600 uoAa. No other soil samples
contained this compound, except those collected near EB-GW-11.
Volatile contamination of site soils is thus confined to the south central
portion of the site surrounding nnr.i't-r-'—: v>?lls rv-W-'*- --•" ^-T-:-!! ,
and the area around monitoring wells D8-GW-04 and DB-W-03 (abandoned
homestead area) to the east of the Illinois Central Railroad.
There are several areas of contaninatio" containing base/'1-•>•:*•'•*! an-* .= -id
extractable compounds. As with the volatiles, surface soil samples
obtained from an area immediately southeast of DB-GW-11 contained semi-
volatile compounds. Surface soil samples obtained from the former drum
storage area between the kilns and the Illinois Central Railway were also
contaminated. Semi-volatile compounds detected in these areas and
identified as contaminants of concern include napthalene and Bis (2-
Ethylhexy1)Phthalate.
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Several pesticides were also identified in site soils. Samples obtained
from the area around CB-GW-11 and from the drum storage area behind the
kilns were found to be contaminated. Several other surface soil samples
obtained from the drum storage area to the south of the warehouse and east
of the railroad tracks opposite frcn the kilns reportedly contained either
chlordane or DDT at concentrations ranging up to 97 ugAg- The contaminated
area is about 7 feet in depth.
To determine the extent of trace element contamination in the soil,
attention was focused upon Arsenic, Chromium, and Lead, which were
detected in groundwater samples above the primary drinking water standards.
The toxic nature of these compounds and their presence in groundwater
makes their occurrence of primary concern. As with organic contamination,
trace elements were identified in former drum storage or spill areas.
The occurrence of arsenic, chromium, and lead in site soils is discussed
below.
Arsenic contamination is evidently confined to two areas of the site.
Arsenic concentrations reached up to 75 mgAg in the former drum storage
area between the kilns and the railway. Arsenic was also identified
near the old homestead area. This sample was obtained near monitoring
wells EB-GW-03 and CB-QW-04, an area where a spill was identified in 1977
and where a magnetometric anomaly was identified during the hydrogeologic
investigation. Arsenic was not found above detection limits in the
background sample.
Chromium and Lead were identified in test pit and surface soils samples
obtained in the drum storage area behind the kilns and the spill areas in
the northern, eastern, and southern portions of the site. Chromium was
also detected in surface soil samples obtained from the former drum storage
area to the south of warehouse. Lead and Chromium concentrations reached
values as high as 122 mgAg and 16 mgAg, respectively.
Groundwater Contamination
The nature of the past waste storage operations at the site leads to the
conclusion that possible sources of groundwater contamination are confined
to spill or drum leakage onto surface soils, with subsequent migration to
the water table.
.Chemical analyses have revealed that aroundwater in the vicinity of
nor. i tor ing v«ll CB-G'.'-li is the nx^st h-iyhly contaminated at the site.
Organic contaminants detected in groundwater obtained from this well,
and identified as contaminants of concern, are 1-1 Dichloroethene,
1-1,2 -Trichloroethane, Trichlorothene, 2-Butanone, Benzene, Toluene, and
'••.->v '•-••<
Organic contaminants of concern identified in other monitoring well
samples are 1-1-1 Trichloroethane, Benzene, Toluene, and Pis (2-Ethylhexyl)
Phthaiate.
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Trichloroethene (TCE) was found in two surface soil samples (1.8 uoAa -
6600 uq/kq) and seven monitoring well samples (4-200 uq/1). TCE was not
found-above detection limits in subsurface soil, surface water, sediment,
or residential well samples.
Trace elements identified in site groundwater above the drinking water
standards are Lead, Arsenic, and Chromium. Chemical analyses reveal no
apparent pattern of trace element contamination in groundwater at the
site.
In the residential well sampling and chemical analyses program, toluene
was identified in three of the five wells sampled. The concentrations
reported for all three wells were 2 ua/1.
Lead and Chromium were also identified in the residential wells. Chromium
was identified in a sample obtained from the City Hall well (6 uq/1).
This well is located farthest from the site. No conclusive evidence that
this occurrence is attributable to site contamination can be offered.
Lead was identified in water'samples obtained from a residential well,
located about 3000 feet to the west and 6000 feet to the southwest of the
site, at levels of 13 uq/1 and 2.2 uq/1, respectively. Aqain, no clear
link to site contamination can be identified. Note that none of the
trace element concentrations identified in residential wells is above
drinking water standards with the exception of iron and manganese identified
in the City Hall well. The direction of flow is in a southwesterly
direction and is at an approximate depth of 25-50 feet.
Migration Pathways
The major contaminant transport pathway impactinq on potential human and
environmental receptors is the movement of groundwater under the site.
A suspected groundwater contaminant plume has been identified onsite.
Contaminants could be transported via groundwater which discharges to the
Ohio River.
Other comparatively minor routes of transport of contaminants from the
site include the following:
0 Contaminated sediment transport via surface water run-off. Surface
water run-off could carry contaminted soil particles to the unnaned
tributaries of Bee Branch, located north and south of the site.
The available chemical analytical data does not indicate that
transport by this mechanism has occurred.
0 Physical transport of site contaminants durinq flooding conditions
of the Ohio River. Portions of the site are located in the 50-
year floodplain of the Ohio River. During the 100-year flood,
most of the site would be inundated.
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ENFORCEMENT ANALYSIS
On November 12, 1985, EPA sent information request/notice letters to
approximately thirty (30) potentially responsible parties (PRPs), includina
Donald Distler, the owner/operator of the Distler Farm site. The letter
requested any records, documents, etc. regarding business transactions
with Kentucky Liquid Recycler, informed the PRPs of their potential
liability at the site and offered them each an opportunity to participate
in the desian and implementation of the remedial action plan and to
contribute to any monitoring and maintenance necessary after completion of
remedial work.
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 convincina
proof of their liability at the site. The majority of the PRP responses
were either complete denials or professed no knowledge or belief that any
'business transactions were conducted with Kentucky Liquid Recvlers (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 between individual PRPs and the KLR, provided a list of all
known PRPs and again requested copies of any material that pertained to
the KLR and the Distler Farm site. The responses to the March 12, 1986,
letters provided additional information regarding several PRPs.
The PRPs have made some attempt to organize a steering committee in order
to engage in negotiations with EPA. However, to date said comittee 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.
The strategy employed by EPA has been to use fund monies unless PRPs
consent to enforceable agreement for the cleanup. The RD/RA section 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 design
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 mitiqate and minimize contamination
in the soils and groundwater and to reduce potential risks to hunan health
and the environment. The objectives in developing remedial action at the
Distler Brickyard site were:
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-8-
0 Surface Contamination:
•• ••• -jr_
Source control
Reduce concentration of contaminants
Control potential migration of surface and subsurface contaminants
resulting from contaminated soils
Prevent or minimize surface erosion and consequent contaminant
runoff, including environmental hazards associated with potential
flooding of the Salt River and/or Ohio River
Prevent, minimize, or eliminate the onsite potential for exposure
... by direct contact; the onsite potential for airborne releases; the
potential for contaminant migration by surface water pathways and
0 Groundwater Contamination:
Management of migration
Prevent increase of contaminant concentrations
Reduce concentrations of contaminants
Prevent or minimize further migration of contaminants (plume control)
An initial screening of applicable alternative technologies was performed
to select those which best met the criteria specified in Section 300.68
of the National Contigency Plan (NCP). Following initial screening of
technologies, potential remedial action alternatives, shown in Table 2,
were identified and analyzed. These alternatives were screened and the
most promising were retained and were developed further. Table 3 summarizes
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
surmary is presented in Table 4. The results of this final evaluation
are given below.
Alternative 1; No Remedial Action
Under the 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 contamination. Contaminants have been present in surface
materials for about eight years. Some might have volatilized and will
continue to do so, decreasing in concentration. Others, especially the
less mobile compounds, would remain as they are now. Some would continue
to migrate into groundwater by infiltration. Although the site is not
considered to be an immediate threat to potential receptors, the potential
for future migration of contaminants into air, surface water and groundwater,
and by direct contact, would continue to exist since any leachate generated
by precipitation, or wind-caused migration could occur unchecked into
these pathways.
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Regulatory requirements and strategies in connection with protection of
g«roundwater regimes exist. The aquifer underlying the site could be
classified as Class I, which indicated that it could be a sole source of
drinking- and domestic water supplies for downgradient communties.
Regulations require that such aquifers not be degraded or contaminated.
Available data indicate that receptors are not presently exposed to
significant levels of contaminants and are not exposed to an immediate
health risk. However, receotors could be exposed at some future time if
migration of contaminants were to occur-specifically, through ingestion
or dermal contact with surface waters and surface materials, and groundwater,
Alternative 2 Soil Contamination: No Remedial Action
Under Soil Contamination
Groundwater contamination: Extraction/Treatment/Injection
Witlvresoect to groundwater contamination this alternative involves
extraction of groundwater and its contaminants using "deep" well
technology. Contaminated groundwater would be extracted from the aquifer
by pumping from wells, and treated at an onsite water treatment plant.
Treated groundwater would be injected back into the aguifer through
injection wells. The objective of this remedial action is to reduce the
concentrations of contaminants in the groundwater to levels where potential
risks to human health and the environment are also reduced to acceptable
levels.
No remedial action with respect to soil contamination would mean that
potential contamination releases and associated pathways would remain
unchecked. Contaminated soils would continue to be potential sources of
groundwater contamination. No remedial action on contaminated soils will
not satisfy any currently applicable or relevant state or federal (RCRA)
standards for the closure of a site containing hazardous materials and
wastes. This alternative is unacceptable on an environmental basis.
Atlemative 3 Soil Contamination: Surface Capping;
Surface Grading and Pevegetation; Fence Around Capped Areas
Groundwater Contamintion: Extraction/Treatment/Injection
This alternative involves the placement of a seal, or cap, over contaminated
areas. Contaminated soils and materials would remain in place and be
covered by the cap. Contaminated groundwater would be extracted throuah
pumping wells, treated at on onsite water treatment plant, and injected
back into the aquifer. The cap would be constructed by placing 2 feet of
compacted clay and 2 feet of topsoil (loam) on the area to be capped.
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 the potential for contaminant migration via surface water,
qroundwater, and air pathways. To achieve this purpose a cap would be
constructed over areas of contamination which would act as a barrier by
isolating the contaminants and would minimize infiltration. Contaminated
groundwater would be extracted, treated and injected back into the aquifer.
Details of groundwater remediation were described under Alternative 2.
-------
The same strategies would also be used in Alternative 3.
Part'of the site is in the 100-year floodplain. However, it is assumed
that 'as 'it is in the periphery of the 100-year flood level, that
flood velocities there would be relatively low, and that the cap can be
designed and constructed in a manner to resist the effects of flooding.
This option reduces the risks to human health that currently exist at the
site. Capping isolates contaminated materials from exposure to atmospheric
conditions, and eliminates the risk of direct contact by the public, thereby
reducing the risk to public health.
Alternative 4 Soil Contamination: Surface Capping ("RCRA Cap")
Surface trading and Revegetation; Pence Around Capped Areas
Groundwater Contamination: Extraction/Treatment/Injection
This alternative involves the construction of a seal or cap over contaminated
"areas. Contaminated soils and materials would remain in place and be
covered by the cap. Contaminated groundwater would be extracted and
treated at an onsite treatment plant. Treated groundwater would be
injected back into the aquifer.
This alternative is identical to Alternative 3 in almost all respects
related to capping and groundwater treatment. The only difference in
Alternative * is that the surface seal would have a more stringent design
consideration, and would meet RCRA goals; and that groundwater remediation
would be to MCL and PPCL Levels, which would also meet RCRA closure
reguirements.
•
Alternative 5 Soil Contamination: Excavation to Seven Feet-Backfilling;
Surface Capping ("RCRA Cap"); Surface Grading and Revegetation;
Onsite Landfill Disposal; Fence Around Capped Areas
Groundwater Contamination: Extraction/Treatment/Injection
This alternative includes partial excavation and removal of contaminated
soils and materials and their disposal in a landfill to be constructed on
the site. The excavations would be backfilled and surface cap would be
constructed along with grading and revegetation. Groundwater would be
extracted, treated onsite to recommended levels, and injected back
into the aguifer as described in Alternative 2. The depth of excavation
is the depth to which we have proven contamination exists.
This is an effective alternative in terms of permanently reducing the
volume of currently uncontrolled contaminated materials. In combination
with backfilling the excavations and installing a "RCRA cap" over the
renaining contaminants in the excavated areas, the overall performance of
this option is estimated to be highly effective in providing a barrier
between the remaining contaminants and the environment. Since this
alternative will remove a significant portion of the source of hazardous
contaminationr along with providing the protection of a cap, it would
provide a higher degree of reliability in reducing onsite and potential
offsite migration of contaminants as compared to alternatives where
excavation is not performed. The landfill will be constructed in full
-------
-11-
• compliance with all requirements for landfill ing and will be placed or.-
sit& outside the 100 year floodplain, in an area where surface and/or
groundwarter contamination has not been encountered. The landfill will
include liner, final cap over the filled area, leachate collection and
groundwater monitoring system.
Alternative 6 Soil Contamination: Excavation to Backcjround Levels
or Groundwater-Backfilling; Offsite Landfill Disposal;
Surface Grading and Revegetation
Groundwater Contamination: Extraction/Treatment/Injection
This alternative represents a more comprehensive remedial measure than
the preceding alternatives as nearly all contaminated soils would be
removed fron the site and disposed of in an offsite permitted hazardous
waste landfill. The Quantity of wastes to be landfilled is greatlv
increased in this alternative, as is the cost of excavation and disposal,
since all areas of contamination would be removed.
Since the contaminated soils will be excavated, the source of contamination
will he removed and, therefore, a seal or cap will not be required under
this alternative. Excavations would be backfilled; "clean" native aranular
soils would be suitable for this purpose. The final surface of backfill
would be graded to converge with local topography, and revegetated.
Under this alternative, contaminated soils would be excavated to depths
where groundwater is encountered, about 25 feet below the ground surface.
Groundwater would be extracted, treated and injected back into the aquifer
as described for Alternative 2. Cleanup criteria under Alternative 6
would be to recommended levels.
This alternative represents a substantial site remediation effort. Risks
of potential future contaminant migration would be minimized or eliminated
under this alternative.
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 impacted 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.
Alternative 7 Soil Contamination: Excavation of contaminated soils to
a depth where contaminant concentrations are at background
levels (expected to be seven feet or less as is reguired
to rsnove contaminated soil areas A & B); Backfilling;
Surface Grading and Revegation; Offsite landfill disposal;
extraction and on-site treatment of contaminated groundwater.
Groundwater will be cleaned to background levels and
reinjected into the aquifer.
-------
This alternative includes excavation of contaminated soils to a depth
where contaminant concentrations are at backaround levels. The depth
.is expected to be seven feet or less. Groundwater would be extracted,
treated*pnsite to "background" levels, and injected back into the
aquifer through injection wells. The objective of this remedial action
is to reduce the concentrations of contaminants in the aroundwater to
levels where potential risk to human health and the environment are also
reduced to acceptable levels.
The contaminated soils would be removed from the site and disposed of
in an offsite permitted hazardous waste landfill. Since the contaminated
soils will be excavated, the source of contamination will be removed
and therefore, a seal or cap will not be required under this alternative.
Excavations would be backfilled; "cleai" native granular soils would
be suitable for this purpose. The final surface or backfill would be
graded to converge with local topography and revegetated under this
alternative, contaminated soils would be excavated in areas identified
during the RI/FS to depths of about seven feet below ground surface.
This depth was selected for discussion and costincj purposes as wells as
due to insufficient data to establish depths where background levels
would be reached in the soil profile. Depths of excavations could be
less (or more) based on additional investigations that would be needed
before finalizing plans should this alternative be selected for
impl ementat ion.
Guidelines will be established to determine the-depth and extent of
the excavations. A drilling and sampling program will be established
to obtain representative samples from the soil profile. Complete analyses
of these samples will performed at an EPA approved laboratory. Background
levels for the contaminants will be designated before excavations begin.
Samples for field screening analysis can be obtained from pre-set
increments of material being removed from the excavations. This
sampling/removal approach allows filed action decisions to be made
within an appropriate amount of time and also permits cleanup activities
to proceed at an acceptable rate. When contamination in the samples from
the excavation reaches "background" levels, removal of materials would
cease. At this point samples from the excavation limits would be taken
and analyzed at an EPA approved laboratory. This complete analysis would
determine whether or not removal of contaminant to background levels has
been achieved.
Groundwater treatment will be accomplished in a two phase system. Inorganic
contaminants would be removed in the first phase, and organic treatment
would follow in the second phase. Inorganics treatment would be accomplished
by the precipitation coagulation, and clarification of dissolved metals.
The final treatment step would be dedicated to the removal of organic
contaminants. Since all of the critical organic contaminants are
volatile ccmpounds, air stripping was determined to be the most effective
treatment process.
-------
Community Relations
The surrounding connunity has concern about the condition of their
"drinking water. The level of concern was not high as a result of the
puhl ic. ipeeting which was attended by 40 + people, and written comments
were received frcm one private citizen, and two attorneys for PRPs. The
Louisville Vbter Company expressed interest in supplying water to
these residents.
Consistency with other Environmental Laws
It is EPA policy to give prime consideration to remedial actions that
attain or exceed applicable or relevant federal environmental or public
health standards. State and local standards also should be considered;
however, State standards that are more stringent than Federal standards
may be 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:
-The Toxic Substances Control Act (TSCA) does not and is not expected to
apply to the final site actions for Distler Brickyard.
-The Clean Water Act (CWA) Does not presently apply to final site action
based on Section 4 of the RI/FS. Section 4 reveals that surface water
contamination is not attributed to the site.
-The Resource Conservation and Recover Act (RCRA) will apply to final
action at the site if clean-up remedy alternatives are selected that
reguire excavation and offsite landfill disposal.
-Floodplain Management Executive Order 11988 (E.O. 11988)
Floodplain management is a concern at this site since it is partially
within the 100 year floodplain. Any action taken at the site as proposed
in the feasibility study would not adversely affect the floodplain. This
is the floodplain of the Chio River and is a vast area.
-Groundwater Protection Strategy (GWPS)
The GWPS is an applicable standard for this site. The cleanup of the
groundwater to level recommended by Region IV Office of Groundwater
Protection would reguire two years to accomplish. The selected alternative
will guarantee clean water for users of groundwater,
-Occupational Safety and Health Administration (OSHA)
Any applicable OSHA reguirements 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 reguirements.
- Other
There are no other known applicable and relevant Federal Laws or
regulations which apply to the site.
-------
FLDODPLAIN ASSESSMENT
The Distler Brickyard Site is located near the Ohio River and the Salt
River. The Ohio River Division of the U. S. Department of the Army Corps
of Engineers has determined, throuqh frequency studies, water surface
elevations for various flood conditions (Wright 1986):
Frequency Elevation
10 - year 431.8 feet
25 - year 436.1 feet
50 - year 439.9 feet
100 - year 442.9 feet
500 - year 449.0 feet
The ground elevations at the Distler Brickyard Site range between 418 to
451 feet. Ihe brickyard complex is at an elevation of approximately
444 feet. East of the complex toward the old homestead, the elevation
increases to 451 feet. The areas prone to flooding are along the
northeast and southwest portions of the site. Occurrence of a 100 year
flood would inundate the majority of the site, except the brickyard
complex and the old homestead area.
At the Distler Brickyard Site, potential remedial action(s) would be
desiqned, constructed, operated, and maintained to prevent washout of
any hazardous materials by a flood event.
The area of the site affected by potential remedial action(s) would be
less than three acres. This is quite small, even insignificant compared
to adjacent areas in the 100-year flcodplain. potential remedial action
would not be expected to have any calculable effect on flood levels or
flood volumes.
Since surrounding area is within the 100-year flcodplain, present land-
use is not expected to change from its predominately rural status. Thus,
potential remedial action(s) would not lead to further development that
would create additional floodplain impact.
Recommended Alternative
In compliance with the National Oil and Hazardous Substances Pollution
Contingency Plan (40 CFR) 300.68) the alternative recommended in this
decision document will eliminate contamination of the qroundwater and
will eliminate any future contamination of the groundwater as well as any
exposure to'any remaining contamination. It is a permanent solution to
the environmental problems at the site, and is the most cost effective
alternative.
-------
This alternative includes excavation ot r ;.tsninated soils (Areas A & B)
where contaminant concentrations are at backaround levels. The depth is
expected to be seven feet or less. Groundwater would be extracted, treated
onsite to-"background" levels, and injected back into the aquifer throuah
injection wells. The objective of this rer>edial action is to reduce the
concentrations of contaminants in the groundwater to levels where potential
risk to hunan health and the environment are also reduced to acceptable
levels.
The major costs for this alternative are the three (3) million dollars to
excavate the contaminated soil at the site and haul it to Ohio for
disposal. It will cost approximately four and one-half (4 1/2) million
dollars to clean up the groundwater at the site to background levels. The
combined cost of this remedial action alternative is approximately seven
and one-half (7 1/2) million dollars. These costs represent Baseline
Present Worth values and are summarized in Table 1. Attachment A presents
the/costing detail for the soil alternative. Attachment B does the same
"for the groundwater alternative.
Operation and Maintenance (O&M)
This remedy will reouire 2 years to accomplish. The operating cost will
be for pumps, maintenance of these pumps injection devices and site
maintenance as well. When the remedy is completed O & M will be required
to maintain the site, mowing and reparing erosion gulleys which might
occur in the restored areas.
In order to haul the contaminated soils that will be excavated, preparation
of access roads might be necessary to establish a durable wearing surface
that could withstand the anticipated truck traffic. It is estimated that
about 8,000 cubic yards of material would be excavated from areas A & B
combined.
It is recommended that this site be funded at 90% federal funds and 10%
Commonwealth funds with a one year period of 0 & M to commencing after all
remediation has been completed and the site restored.
Schedule
The planned schedule for caroletion of the clean up at the Distler
.Brickyard site is as follows:
August 20, 1986 Record of Decision The Commonwealth has indicated that
they do not have the required 10% matching funds available at this time.
A schedule for continuation of remediation at the Distler Brickyard site
is contingent upon the availability of both Federal and Commonwealth funds.
Ten (10) months will be recrjir^d for design; six (6) months is required
to select a contractor, after which 2 years of activity at the site will
culminate in a full remediation of the contamination at the site.
-------
Future Action
As part Of- the desian, additional studies will be performed to completely
define the areal extent of contamination in the groundwater and establish
depths where background levels would be reached in the soil profile.
Depths of excavations could be less (or more) based on additional
investigations that would be needed before finalizinq plans for the
implementation of this alternative.
This is an effective alternative in terms of permanently removing the
source of contamination. In combination with backfilling the excavations
and reveqetatinq the area, the overall performance of this option is
considered to be very effective in protection the environment.
-------
TABCE"ZL-3
SUMMARY OF POTENTIAL REMEDAL ACTION ALTERNATIVES
DISTLER BRICKYARD SITE
Groundwater Contamination
Alternative
Soil Contamination
Method
Cleanup Criterial
No Remedial Action
Groundwater Extraction/Treatment/Injection
Groundwater/Ext ract ion/Treatment /1 n ject ion
1 No Remedial Action
2 No Remedial Action
3 Surface Capping ("CERCLA
Cap"); Surface Grading and
Revegetation; Fence Around
Capped Areas (Areas A and B)
4 Surface Capping ("RCRA Cap"); Groundwater Extraction/Treatment /Injection
Surface Grading and Revegetation;
Fence Around Capped Areas
(Areas A and B)
5 Excavation to Seven Feet; Groundwater Extraction/Treatment/Injection
Backfilling; Surface Capping
("RCRA Cap"); Onsite Landfill Disposal;
Surface Grading and Revegation; Fence
Around Capped Areas (Areas A and B)
6 Excavation to Background Levels Groundwater Extraction/Treatment/Injection
or to Groundwater; Backfilling; Offiste
Landfill Disposal; Surface Grading
and Revegetation (Areas A and B)
Excavation to Depth where soil
contaminants are at Background
levels (Expected to befSeven
Feet, Areas A & B); Surface
Grading ami Kevegetation (Aroas
A & B); Offslte Ivuvlfi)I Disposal
Extraction and Onsite Treatment of
contaminated Groundwater; Groundwater
will be cleaned to Background levels and
Reinjected.
PPCL
PPCL
MCL, PPCL
Background Levels
Background Levels
Background Levels
PPCL: Preliminary Protective Concentration Limit (Rased on ICT6 Unit Cancer Risk)
MCL: Maximum Contaminant l/?v
-------
TABLE 4-4
COST SUMMARY OF POTENTIAL REMEDIAL ACTION ALTERNATIVES
DISTLBR BRICKYARD SITE
Remedial Action
Alternative
1
2
3
4
5
6
7
Baseline
Capital
Costs
—
1,389
1,587
1,686
2,728
27,442
—
Operating
YearO
—
44
44
44
44
44
A A
and Maintenance
1&2
—
1,568
1,570
1,571
1,587
1,568
I.SfiR
Coats
3-30
—
44
46
47
63
—
4/i
Low
—
4,258
4,444
4,525
5,485
23,480
—
Present Worth Range
Baseline
«
4,474
4,711
4,819
6,013
30,206
7,'tft'l
High
—
4,689
5,011
5,165
6,750
33,027
—
ALL COSTS IN THOUSANDS OP DOLLARS (OOP's)
-------
TABLE" 1
REMEDIAL ACTION ALTERNATIVE 7
ESTIMATED COSTS
(BASELINE VALUES)
Soil Contamination: Excavation to Depth Were Soil Contaminants are at
Background Levels (Expected to be ^ Seven Feet, Areas A &
B); Surface Grading and Revegetation (Areas A & B); Offsite
Landfill Disposal
Groundwater Contamination: Extraction and Onsite Treatment of Contaminated
Groundwaten Groundwater Will be Cleaned to
Background Levels and Reinjected.
Media
Soil Groundwater Total
PRESENT WORTH ($) 2,993,000 4,474,000 7,467,000
CAPITAL EXPENDITURES 2,980,000 1,369,000 4,349,000
ANNUAL OPERATING COSTS ($)
YearO 265 44,000 44,265
Year 1 and 2 1,360 1,568,000 1,569,360
Year 3-30 1,360 44,000 45,360
TOTAL OPERATING COSTS FOR
30 YEARS 41,000 4,412,000 4,443,000
-------
TABLE 1— Q
CONCENTRATION VALUES U8RD TO CALCULATE
GROUNDWATRR TRRATMBNT
TIMK KCTIMATRS
DI8TLRR BRICKYARD fRTR
Concentration (ug/1)
Contaminant
1,1,1 -Trlchloroethane
Benzene
1,1-Dlchloroethene
Trans-l,2-Dlchloroethene
Toluene
Trlchloroethene
2-Butanone
Maximum
143
200
50
6,000
SI, 000
61
.9,000
Average
28
18
62
579
3,754
8
1,113
PPCL
(Uft/0
21.9
0.673++
0.283
270*
15,400
1.84
TOO**
MCL
(UK/I)
200
5
NR
NA
2000***
NR
NR
Background
(UR/IH
5
5
5
5
5
5
5
* Health Advisory Limit
** Allowable Daily Intake
**• Recommended Maximum Contaminant Levels
PPCL Preliminary Protective Concentration Limits
MCL Maximum Contaminant Level
NA Not Available
NR Not Reported
+ Detection Limit was used as Background Value
4+ Ambiant Water Quality Criteria for Drinking Water, not PPCL (PPCL Not available)
-------
TABLE 3 - C>
BACKGROUND CONCENTRATIONS FOR CONTAMINANTS OP CONCERN
DISTLER BRICKYARD SITE
Contaminant
1 , 1 , 1-Tr ichloroethane
Benzene
1,1-Diohloroethene
Trans-l,2-Dichloroethene
Toluene
Triehloroethene
2-Butanone
Naphthalene
bis(2-ethylhexyl)
phtcJste
Arsenic
Chromium
Lead
Soils ue/l
2.5
2.5
2.S
2.5
2.5
2.5
100
10
10
20R
Detection Limit
Detection Limit
Groundwater
ue/l
5
5
5
5
5
5
S
20
20
4.9
4.4
5
Note: Background values are actually the detection limits (i.e., compound was
analyzed for but not detected). This is true for all compounds except
Arsenic in soils.
R
Laboratory qualifier indicating result is a false positive.
-------
TABLE 1-2 O
CONTAMINANTS OP CONCERN
DISTLER BRICKYARD SITE
D
Contaminant
Media
Benzene
CAS No. 71-43-2
1,1,1 -Trichloroct hane
CAS No. 71-55-6
1,1-Dichloroethene
CAS No. 7f>-35-4
•
Trans-1,2-dichloroethene
CAS No. 156-60-5
Toluene
CAS No. 108-88-3
Trichloroethene
CAS No. 79-01-6
2 Uulononc
CAS No. 78-93-3
Naphthalene
CAS No. 206-44 0
His (2-clhylhexyl)
plithaluto
CAS No. 117 81 7
Monitoring Wells
Surface Soils
Monitoring Wei •
Monitoring Wells
Monitoring Wells
Monitoring Wells
Residential Wells
Surface Soils
Monitoring Wells
Subsurface Soils
Monitoring Wells
Surface Soil
Subsurface Soils
Monitoring Wells
Surface Soil
Subsurface Soils
Monitoring Wells
Concentration
Range
3 - 200 ug/1
9.4 ug/Kg
4-143 ug/l
3 - 50 ug/1
5 - 6,000 ug/1
2 - 58,000 ug/1
2 ug/1
1.8 - 6,600 ug/Kg
4-61 ug/1
3,200-300,000 ug/Kg
3,089 - 9,000 ug/1
750 - 2,400 ug/Kg
2,000 - 8,700 ug/Kg
20 ug/1
6 - 3,200 ng/Kg
400 - 5,700 ug/Kg
2 - 28 ug/1
Observat ions/Nip mber
Samples
5/22
1/22
4/22
4/22
8/22
7/22
3/5
2/22
4/22
4/7
4/22
3/22
5/7
1/22
fi/22
7/7
t5/22
ufcd)
-------
TAI1I.R 1-2 (CONTINUKD)
CONTAMINANTS OP CONCERr.'-
DISTLKR IIKICK YAIID SITU
PAGE TWO
Dl
Contaminant
Media
Arsenic
CAS No. 7440-38-2
Chromium
CAS No. 7440-47-3
head
CAS No. 7499-92 1
Surface Soils
Subsurface Soils
Sediment
Monitoring Wells
Surface Soils
Subsurface Soils
Sediment
Surface Water
Monitoring Wells
Residential Wells
Surface Soils
Subsurface Soils
Sediment
Surface Water
Monitoring Wells
Residential Wells
Concentration
Range
5.3 - 75 mg/Kg
2.7 - 8.0 mg/Kg
5.1 - 16 mg/Kg
20 - 1,600 ug/l
5.5 - 15 mg/Kg
6.25 - 14.5 mg/Kg
6.9 - 12.8 mg/Kg
7-14 ug/l
20 - 2,000 ug/l
6 ug/l
1.4 - 122 mg/Kg
7.26 - 22.5 mg/Kg
6 - 37 mg/Kg
13 ug/l
10 - 1,000 ug/l
2.2 - 13 ug/l
Observations/Number
Samples
22/22
16/16
13/13
19/31
22/22
Hi/Hi
7/13
3/7
13/31
1/5 •
22/22
IG/lfi
13/13
1/7
25/31
3/5
Notes: (I) CAS No. - Chemical Abstract Service Number.
(2) Analytical Results from the NUS FIT Investigation (March, 1983) and
the NUS Remedial Investigation (May, 1984 - September, 1984).
(3) ug/l - micro gram per liter.
-------
TABLE 3-3B PAGE I OF I
METALS AND CYANIDE IN SURFACE SOIL
DISTLER BRICKYARD SITE, WEST POINT, KY
SAMPLED BY NUS CORPORATION (5/85)
RESULTS PRESENTED IN mg/Kg
SAMPLE NO. DB-SS
Traffic Report No.
Sample Type
P.P. No.
lit
115
117
118
119
120
l'2l
122
123
124
125
126
127
128
301
MDC-136
BACKGROUND
CAS No.
7000-36-0
7010-38-2
7000-01-7
7000-03-9
7000-07-3
7000-50-8
7039-92-1
7039-97-6
7000-02-0
7782-09-2
7000-22-0
7000-28-0
7000-66-6
7029-90-5
7000-39-3
7000-70-2
7000-08-0
7039-89-6
7039-95-0
7039-96-5
7000-09-7
7000-23-5
7000-31-5
7000-62-2
Contaminant
Toxic Metals
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide, Total
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Aluminum
Barium
Calcium
Cobalt
Iron
Magnesium
Manganese
Potassium
Sodium
Tin
V.inadium
Moisture %
20R
203
213
003
90003
160003
050
21
atory <|n.ilifi<»r iiylic.it inp, result is approximate.
-------
STATF RECOMMENDATIONS
-------
OCV«««NO«
COMMONWEALTH
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT: FOR ENVIRONMENTAL PROTECTION \
••BDOSE PLAZA
IB.RiiLivROAO -ERRR/RAS
F*ANKFO<*T. KlNTUCKV 40601
August 7, 1986
Mr. Richard D. Stonebraker, Acting Chief
Emergency and Remedial Response Branch
U. S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30363
Dear Mr. Stonebraker:
The purpose of this letter is to comment on the proposed alternative remedial
actions and Records of Decision at the Distler Brickyard and Dlstler Farm sites.
These actions were recently revised by EPA in light of the State comments
forwarded to you in my letter of 3uly 3, 1926. The comments for each site are
given below.
DISTLER BRJCKYARD SITE
The proposed remedial action components described in Alternatlvt 7 are
acceptable to the State. This alternative includes the following! Excavation of
soils to a depth where contaminant concentrations are at background levels
(expected to be seven feet or less as is required to remove contaminated soil areas
A and B); backfilling) surface grading and revegetation; offsite landfill disposal}
extraction and onsite treatment of contaminated groundwater (groundwater will be
cleaned to background levels and reinjected into the aquifer).
Two additional issues are relevant to the Brickyard Site: (1) Cleanup levels,
and (2) Operation and Maintenance. First, the State understands that there will be
no additional cost to the State in Alternative 7 to cch'eve bowkgrou- :' c.'^anup
levels In the soil and in the groundwater. Second, it appears that O and M costs for
the surface covering ($i,360/yr) would be unnecessary after the first year since
surface contaminants have been removed and there is no "cap" to be maintained.
Also, the O and M costs for groundwater monitoring ($«MOO/yr, which are shown
in the cost estimates but not mentioned in the revised ROD narrative) may not be
necessary 2 to 3 years after cleanup of the groundwater is achieved. The State
-------
Page Two
Mr. Richard D. Stonebraker
August 6, 1986
suggests that the frequency and duration of the groundwater monitoring be
established at the end of the first year of O and M. \
The State understands that the total present worth cost of Alternative 7 has
been estimated to be $?,<<67,000. The elimination of the O and M costs mentioned
above would slightly lower the estimated total present worth cost to $7, 203,000.
DISTLtR FARM SITE
The proposed remedial action components described in the revised
Alternative 6 are acceptable to the State. This alternative includes the following
components t excavation of contaminated soils to a depth where contaminant
concentrations are at background levels (expected to be 11 feet or less in depth))
backfilling! surface grading and revegetation; offsite landfill disposal; groundwater
extraction; offsite groundwater treatment/disposal; reinjection of uncontaminated
water (if this is necessary beyond natural recharge of aquifer).
Two additional Issues are relevant to the Oistler Farm Sitet (1) Cleanup
levels, and (2) Operation and Maintenance. First, the State understands that there
will be no additional cost to the State in Alternative 6 to attain background
cleanup levels In the soil and In the groundwater. Second, the 0 and M costs for
the surface covering (not estimated in the cost summary but described in the
revised ROD) -would be unnecessary after the first year of 0 and M, since surface
contaminants were removed and there is no cap. Also, the O and M costs for
groundwater monitoring ($20,200/yr, which are Included In the cost estimates but
not mentioned In the revised ROD), may not be necessary 2to 3 years after cleanup
of the groundwater 1$ achieved. The State suggests that the frequency and duration
of groundwater monitoring be established at the end of the first year of O and M.
The State understands that the total present worth cost of Alternative 6 has
been estimated to be $11,996,000. This cost would be slightly lower with the
reduction oi the Oand M costs mentioned above.
ADDITIONAL COMMENTS
In a July 2, 1986, letter from Secretary Baldwin to Mr. Ravan the State
requested the lead on these two sites. To date, we have not received a reply from
EPA on this important matter. It Is important to finalize the "lead" issue as soon
as possible so that appropriate project planning and scheduling can be established.
The State does not concur with the schedule shown in the revised RODs.
Second, the State Hazardous Waste Management Fund contains $627,000,
which would be insufficient to fund the 10% State Match requirements on either of
-------
Page Three
Mr. Richard D. Stonebraker
August 6, 1986
these sites. Approximately $140,CTO per year is generated by the Fund. In order to
proceed on either site, it wiii be necessary to clarify when the State will need to
submit matching funds to EPA. It will also be necessary for the State to obtain
sufficient matching funds.
With these comments, the State understands that EPA may proceed with the
completion of the RODs. Please contact me if you have any questions or require
Jjru-.tr information.
fcr, Director
of V'ute Management
3AB/lm
cct Mike Helton
Caroline Patrick Haight
Barry Burrus
-------
UNITED STATES ENVIRONMENTAL PROTECTION
REGION IV
J45 COURTLAND STREET
196L ATLANTA. GEORC.A ,0,65
REF: 4WD-ER
Mr. J. Alex Barber
Commonwealth of Kentucky
Natural Resources and Environmental
Protection Cabinet
Department for Environmental Protection
Fort Boone Plaza
IS Reilly Road
Frankfort, KY 40601
Dear Mr. Barber:
In your letter dated July 3, 1986, you stated that the Common-
wealth could approve a remedial alternative for the Distler
Brickyard site containing the following components:
1. "Excavation of contaminated soil to depth where contaminant
concentrations are at background levels (expected to be
less than 1 feet depth). The excavated soil could be
either transported off-site to a permitted hazardous waste
disposal facility or treated on-site to render it nonhazardous.
The resulting treated soil would then need to be delisted
under RCRA so that it could be left on-site. Excavated soils
would be replaced by clean soils, and the resulting site
regraded and revegetated.
2. Extraction and on-site treatment of contaminated groundwater.
Groundwater would be cleaned to background levels and rein-
jected into the aquifer.*
During the Remedial Investigation/Feasibility Study and since the
preparation of the draft Record of Decision, the EPA contractors
have evaluated and considered several Remedial and Advance Techno-
logies. The Technologies are Microbial Degradation, In-situ
Treatment of Groundwater, In-situ Toxic Waste Detoxification, Terra
Vac Process, On-site destruction (using a Rotary Kiln incinerator)
and Solution Mining. None of the technologies listed above were
retained for further consideration. One of the alternatives is
considered a proven, reliable technology. The other five (5)
alternatives, are considered experimental, unproven technologies.
The cost to excavate 8,000 cubic yards of contaminated soils and
on-site decontamination of the organic constituents by a Rotary
Kiln incinerator is $10,700,000. The Removal of contaminated
-------
ATTACHMENT A
COSTING DETAIL
FOR SOIL REMEDIATION
(ALTERNATIVE 7)
NUS
-------
Soil Alternative No. 7: Capital Expenditures
^an«* 1 Of 1
BRICKYARD
SOIL ALTERNATIVE NO 1
(DBPEXON)
Item
Clear and Grub
Excav. Contam. Soil
Backfill W /Compact ion
Grade Area
Topsoil
Revegetate
Transportation
Disposal
Q«y-
1.2
8.000
6,860
970
1,1*0
53
1)6,000
10,800
Unit
ACRE
CY
CY
CY
CY
MSP
Ml
TON
Unit Coat
StaS. Mat. Labor
390.00
.28
1.50 1.20
.39
).X> 1.20
2*. 60 ).60
*.oo
110.00
Total Coat .
Equip. OUD. Mat. I^Bnr
820.00
.))
2.81 10,290
1.59
2.81 6,270
*.*) 1,30*
62*, 000
1,188,000
- -•• »n IV ft*
*68
2,2*0
8,232
378
1,368
297
it «tl
EouiD.
"T*'r—
98*
«,*00
19,227
1.5*2
3,203
236
M.M2
Total
Direct
Coat
l,*)2
6,6*0
37,799
1.920
10,8*1
1,837
62«,000
1,188,000
1.872.489
Comments
.«;
i
20 cy truck
CECOSLandlil
390 miles
Subtotal I
Working Level
C/Norm = .2)
Burden @ 13% ol Labor
Cost
Labor @ I)% ol Labor
Cost
Material @ )% ol
> Material Cost
I Subcontract @ 10% ol
M Sub. Cost
1,112,000
10,6)6
893
181.200
6,229 37,0)2
2,119
2,*«)
1,883,1*)
2,119
2,**)
893
181.200
17 O17
Indirect* @ 75% ol
Total Direct Labor
Cost
Profit @ 10% Total
Direct Cost
IJ.J95
Health ft
Monitoring @ .0*
Total FleW Coat
Contingency @ 20% ol
Total Field i
2.069,802
l),)9)
206.980
2,292,377
91.69)
2,38*.077
*76.8I*
Engineering @ )% of
Total Field Cost
TOTAL COST FOR THIS PAGE
-------
DISTLER BRICKYARD
O&M COST
ALTERNATIVE NO: 7
SURFACE COVERING
Item
Mow Grass
Replace Topsoil
Revegetate
-SfiL
53
97
5
Unit
MSP
CY
MSF
Unit
5.00
9.51
34.65
Item
265
922
173
Frequency
0-30
1-30
1-30
Notes
Slope &
level
areas
10% re-
placement
Total Annual Costs
(first year)
Total Annual Costs
(1-30)
265
1,360
A-2
-------
Co«t Component
I. C*plttl Cotl'
I. O&M Cotti
3. Annual Co»\t
4. Annual Dlieounl Rat«=IO%
Present Worth *
Oft M Cost •
Annual Discount R»te=IO%
Present Worth =
OftM Costs
Annual Discount Rate=10%
Present Worth =
"toil Alternative No. 7: Present Worth (Paoe 1 of
DtBTLKR BRICKYARD '
SOIL ALTRRNATIVR NO. f
PRR8RHT WORTH ANALTSIB (BA8BUNR)
'\
COST/THAR COST OCCURS (tOfTO
_•_
s.ooo
0.20S
1
2,000
It
1.4
.Sit
.4
24
1.4
.101
1
1.4
.tot
1.3
13
1.4
.21
.4
ts
1.4
.OtI
t
1.4
' .020
1.2
14
1.4
.203
.4
SO
1.4
.004
3
1.4
.751
1.1
IS
1.4
.239
.3
S7
1.4
.070
4
1.4
.083
1.0
10
1.4
.210
.3
SO
1.4
.000
t
1.4
.011
.0
IT
1.4
.100
.3
St
1.4
.003
0
1.4
.S04
.1
II
1.4
.10
.S
II
1.4
.057
T 1 • II .<
1.4 1.4 1.4 1.4' 1.4
.SIS .407 .424 .300 .35
.1 .T .0 .S .5
It SI SI SS S3
1.4 1.4 1.4 1.4 1.4
.104 .140 .135 .123 .112
.S .2 .2 .2 .2
.1
.1
.1
.1
.Ot
.00
TOTAL PRE8KHT WORTH (MOO'S) I,tt3
-------
ATTACHMENT B
COSTING DETAIL
FOR GROUNDWATER REMEDIATION
(ALTERNATIVE 7)
-------
Grd .water Alternative No. 7: Capital Expend jre (Page 1
Grtxindtfriter Extraction/Injection
Alternative* f^Q y
I to*
Otr Unit
Bub.
Unit Co*I
Hat. Iobor Equip<
Total Cost
Nat. Labor Equip.
Total
Direct
Co»t C
CO
I
Hobtll/aUan of Driller
lirlll wall* 417* 41*. >
a. Itoll Screen (A* •••. >
b. Itoll Ca«»nq (4* •••. I
c . Or. iv«r I rath
d. Oront S*«l
». tmvvlua Itoll*
Moll Ihiatf (pttl*M unit)
a. SubMrctbl* fu*^* (23
b. Hi««r Pip* <2* tfia.)
V-itv** 12 • »o. w«ll>
n-mtrold flptnq (4* PVC>
V.ilv« Vault
Working L*v*l
IB
EA
2OOO.OO
I5OOO.OO
EA I9OO.OO
200O
133000
•000
f
IO9O
f
LOCB
tF
tft
40O.OO
*.»3
1973.00
• IIX of Labor Co«t
l..ibor • I3X of Labor Co*I
n-ttortal • 3X of N«t*rtal Coat
Subcontract • IOX *f Bub. Coat
lotal Direct Coat
lndtr*ct* • TUX of Total Direct Labor Coat
Profit • IOX Total Dlract Coat
Itoalth I Safety Monitoring • .1
Total Field Co*t
Conttiigancy • 2OX of Total field Coat
Engineering • 3X of Total Field Coat
TOIM. COST THIS PrVOE
2OOO
I33OOO
9OOO
340O 3AOO
7298 729U
17773 177/3
174*73 O O O !74A/:i
O O O
174473 O O 0 I74A73
O O
O O
0 O
I74A7 I74A7
I92I4O O O O I9214O
O O
19214
2111134
2II3S
232489
4*498
IIA24
?906II
-------
Groundwater Alternative
A Ctt.1. l_.V\
•V»*.<_ \ I U VJ V
IU8TLER M4ICKVAMO
OronndMator fr««UM*t Plant
Alternative No. 7
ItS*
PIPIMO
8ilp.
2IOO
•400
40O
409 ••
9700
2100
400
1000
AOO
AOO
20O
Total
Direct
Cost Cc^
'AOOO
240OO
tooo
1319
14200
AOOO
tooo
3000 ,
3400
44OO
1400
V7
Cd
i
N)
ELECTRICAL
Motor 8t«rt»r •!
Utbconn«ct BMltch
TransfotMr
Conduit t C«kl»t Control
Hl«c
CV
CA
CA
I tA
29 CA
1 LOT
t LOT
2OO.OO 379.OO 29.OO
29
4
00O.OO
OOO.OO
250O.OO
492.OO
200.0O
200.0O
OOO.OO
AOO.OO
400O.OO 400O.OO
VOOO.OO VOOO.OO
IV4OO 3A379
2OOOO 9OOO
3200 000
2900 OOO
11300 19000
4OOO 4OOO
VOOO VOOO
2429 98200 liic.
18OOO solid
2SOOO
4OOO
3JOO
2A30O
eooo
IBOOO
Uurkln« L«v«l 0 - .19
»>irtf*n • I3X of L«kor Co«t
L.ikar • I9X of L*»or Cost
n.it*rt«l • 9X of Itatorlal Cost
6u»cujitrsct • I OX of Bub. Cost
lotsI Direct Cost
Inslrocts • 73X of Totsl Dlroct Lssor Cost
Profit • IOX Totst »tr*ct Cost
Hat I In t Safsty Nonltorln« • .1
total Flslil Cost
ItVOlO V2OOO 2429 233119
I3V32 344 I42VA
ItVOlO 104812
270V 24/411
I3OOA
IA022
9WI
'• 1000
11884
14022
3V9|
18OO
IVOOO I29OOI I3A7IV
102940
27OV 2B3IOV
102940
28311
4IAI3V
41414
4377/3
I ontti»««n< v O 2OX of Total H»H Co«t
li«<|tii««rinq • ^X of Total I Isl4 to«l
Illlnt i:il!il IHIH
-------
HlfiltCM MUCKVAMi
Uruuno'iMtor Treat**
Altai-native i>Jo. 7
I to*
LOUIPHCMT
Grou| >ter Alternative No. 7: Capital Expend!to k> (page 3
Olr Unit
Unit Coat . Total Coat
Bua. Hat. labor Equip. 8uoA Hat. Laaar Equip.
to»..lv
btrart
Coat
W
I
U)
Equalization 1«nk I EA
Trot. Supply Puaaa 2 EA
Faa4 8y«t»o ' I EA
F-olyoar Foatf Sy«to» I EA
Forrtc Kulfato foM ftV*taa> I EA
Ltoa Food 8yat«» I EA
Btatit HlH«r I EA
HtMln« Tank I EA
Mt:«*r I EA
Hoc Tank I EA
Hoc lank HlM«r I EA
Clarlftcr I CA
Ban4 Flliars 2 EA
».>ckMa*l» lank I f A
fcackwasn Puapa 2 EA
Sl««» tirlpplna I EA
Blrlppar Supply Pu*pa 2 EA
Plat«/Fro»a fIItar Pr*«a I EA
Blu«a» Holdlna tonka I EA
•lua«« F*a4 Puapa 2 EA
Uorklna, Laval D - .IS
»>irdan • I3X of Laaor Coat
l-iaor • I3X of tokor Coat
H..lartal • 9X of Hatcrlal Coat
B»ibcantract • IOX of Bua. Coat
Total blract Coat
InaI roct> • 73X of Total Direct Laaor Coat
rroflt • IOX Total ftlract Coat
rW-tllh t B«r«ty MonitorIna • .1
lot-il Flaltf Coat
i:ontt«»aancy • 2OX of Total f laltf Coat
titutnaarlng • SX of Total Flaltf Coat
IOIAI. COS I 1HI9 PAOC
•00.OO
2OO.OO
4OO.OO
4OO.OO
1000.OO
3000.00
200.OO
aOO.OO
30O.OO
•OO.OO
300.OO
49VOO.OO II9OO.OO
2OOOO.OO 2OOO.OO
90OO.OO
9300.00
31000.OO
3300.OO
IOOOO.OO
7OO.OO
7000.OO
3000.OO
400O.OO
4300.00
I3OOO.OO
14000.OO
IOOO.OO
1700.OO
2700.OO
I20O.OO
2300.00
330O.OO
IOOO.OO
300.OO
3AOO.OO
4OO.OO
1000.00
3OO.OO
200.0O
7OOO
4OOO
400O
43OO
13000
laOOO
IOOO
I7OO
2700
I2OO
2300
43*00
4000O
300O
11000
91000
70OO
10000
700
7OOO
•00
40O
400
4OO
3OOO
3000
20O
•OO
30O
•00
300
11*00
4000
IOOO
•OO
3*oo
•00
IOOO
300
400
7BOO
*4(>O
440O
4VOO
leooo
I900O
12OO
230O
SOOO
I BOO
2 BOO
97BOO
4400O
•OOO
IIAOO
34AOO
7BOO
11 OOO
IOOO
740O
• 21*200
33400
904O
O
o
272OOO
3O4O
21t2OO
11*40
3021
07*4
27784O
3023
37»4
lt*40
O
• 291IM 4*49*
370*4
10041*
17094
10042
347774
34778
404333
•OVIt
70228
303AVI
-------
Groundwater Alternative Nc. 7; O & M Costs (Page 1 ot 2.
MUCKtAftD
o a N cost
ALUNMMIVC NO. I
OMMNUUMfcR TM-ATNENT
PL AMI
HEN
O1V UNI1 UNIT • I1CN •
rflCOUCNCV
NOtCO
Utilities
o. Ctoctrtcsl
to. ruol
CHtNICM-t
•• BodlM*
MrpocMotto
to. Polys*'
c. Forric •wir«t«
«. LtM
NAINTENAMCC
Butototol ««509,40O»
LAMM
Operators
M)ILEH RCHTAt.
200000
•7400O
94t
f«t
BLUIKK HMIOLIMO
to. blssos«l
NONflS-V BAMtt 1MO I
MMLVBIB
10
Li
13.J Tl
19
.07
.•7
1.09
1.90
110.00
40.00
I4OOO
742I2O
1O44O
1039
2 vrsi
2 vrs<
2 yrs.
2 yrs*
2 yrs.
2 yrs.
1
12
EA
NO
290OO.OO
900OO.OO
ISI4O
79OOO
9 LPO IOOO.OO 9OOO
7O TONS 99.OO 443O
12 NO 1000.00 12000
2 yrs*
2 yrs.
2 vrsi
2 rrs.
2 yr><
total Anouol Casts (first r»«rl
lot*I Anntial Costs (2 yr«.) . •
O
IS24O3O
-------
Gj bdwater Alternative No. 7: O & M Costs * ge 2 of 2)
w
Ul
1*1611 tM MilCKYAftD
O i H COS!
ALIfHNAIIUC NO. I No . 7
HOMITORINO ft AMAI.V8IB
ITCH
UNIT UNIT • 1TIN •
rMEOIKMCV
MOICB
Honliur
Uollccttun ByaiMi
Bo*f>I« Nontiartng Itoll*
N/A IB
M/A LB 2400
U C* 1000.00 32000
Report tn«
N/A L«
Total Annual Cost*
-------
mt.ciuui.tvu wo.
til til ftlBUffl MICKVMIU
M IKKNAIIVC NO. I 7
4474
MM!
•MMtt.Bf NT MONTH AMALYBIBlM
CUBI/VtAR COOT OCCUR! (tOOO'Ot
2 I 4 5 4
10
1. CAM I At. CIWI |J«*
2. O I h CO91S 44 ISA* ISAM
3. MINIMI COttlt I4IJ ISA* 1MB 44
4. ANNUM. BISCOUNf NMC-IOX I .,»O» .«2A .791
HIEKMt UOMIH » I4IJ 1425 I29S 31
44
.Ml
44
.*2I
27
44
.3*4
29
44
.an
21
44
.447
21
44
.424
'»
I*
44
.1M
17
12
II
14
19
I*
17
If
21
22
DIM COS1B
M4NIW. MBCOUNf MATE»IOX
MOMIH -
44
.11*
14
44
.29
II
44
.241
12
44
.219
II
44
.21*
10
44
.!*•
44
.10
44
,144
44
,14V
44
.ua
44
,121
24
29
24
27
2O
29
TOTAL
O I H COBTB 44 44 44
ANNUAL III MOUNT NATE* I OX . IOI .092 .004
FftCOENT MOftTH -444
44
.074
44
.049
44
.041
44
.097
MONTH
«000'O»
4474
-------
TABLR f-4 :.
COST SUMMARY OF POTENTIAL REMEDIAL ACTION ALTERNATIVES
DISTLBR BRICKYARD SITE
Remedial Action
Alternative
1
2
3
4
S
6
Baseline
Capital
Coats
~
1,369
1,587
1,686
2,728
27,442
Operating
YearO
—
44
44
44
44
44
and Maintenance
1 ft 2
--
1,568
1,570
1,571
1,587
1,568
Costs
3-30
«
44
46
47
63
~
Low
~
4,258
4,444
4,525
5,485
23,480
Present Worth Range
Baseline
«
4,474
4,711
4,819
6,013
30,206
HlRtt
—
4,68'
5,01
5,165
6f750
33,02',
ALL COSTS IN THOUSANDS OF DOLLARS (OOP's)
-------
TABLR 1 - 3
R8TIMATE8 OP TIMR ON TBARS) TO THAT
CROUNDWATKR TO DR8IRRD CONCRNTIATION UMITB
DI8TLRR BRICRYARD 8ITR
PPCL Levels
MCL Level*
Background Level*
Contaarinairt
1,1 , l-Trlchloroethane
Beneene
1,1-Dlchloroethane
Trane-l,2-Dlehloroethene
Toluene
Trlchloroethene
2-Butanone
•t Majriauiai
Concentration
2.0
i.5**
15.8
T.f
7.)
7.3
2.1
•t Average
Concent rat Ion
t.3
4.3**
13.6
l.t
NCI
3.1
1.4
•t MulBun
Concent t*tt t KNI
NC3
S.4
NC3
NC3
16.1
NC3
NC3
•t Average
Coficcnlmt Ion
NC3
2.0
NC3
NC3
0.4
NC3
NC3
•t Mulraum
Concentration
3.6
5.4
NC2
17.6
50.6
NC2
6.4
•t Average
Concentration
1.9
2.0
NC2
11.6
34.9
NC2
4.73
PPCL Preliminary Protective Concentration Limits
MCL Mailmum Contaminant Level
NCI Not Calculated, Average Concentration Is below PPCL
NC2 Not Calculated. PPCL Is lower than background
NC3 Not Calculated, MCL not reported or not available
*+ Ambient Water Quality Criteria for Drinking Water, Not PPCL (PPCL not available)
-------
TABLETS
SUMMARY OP POTENTIAL REMEDIAL ACTION ALTERNATIVES
DISTLER BRICKYARD SITE
Groundwater Contamination
Alternative
1
2
3
Soil Contamination
No Remedial Action
No Remedial Action
Surface Capping ("CERCLA Cap");
Surface Grading and Re vegetation;
Pence Around Capped Areas
(Areas A and B)
Surface Capping ("RCRA Cap");
Surface Grading and Revegetatlon;
Pence Around Capped Areas
(Areas A and B)
Excavation to Seven Peet;
Backfilling; Surface Capping
("RCRA Cap"); Onsite Landfill Disposal;
Surface Grading and Revegation;
Pence Around Capped Areas
(Areas A and B)
Excavation to Background Levels
or to Groundwater; Backfilling; Offsite
Landfill Disposal; Surface Grading
and Revegetntion (Areas A and B)
Method
No Remedial Action
Groundwater Extraction/Treatment/Injection
Groundwater Extraction/Treatment/Injection
Groundwater Extraction/Treatment/Injection
Groundwater Extracton/Treatment/lnjection
Groundwater Extraction/Treatment/Injection
Cleanup C
PPC
PPC
MCL, P:
Backgrourt<
Background
PPCL: Preliminary Protective Concentration Limit (Based on 10 G Unit Cancer Risk)
MCL: Maximum Contaminant Level
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-2- —
soils to a permitted oisposal facility is estimated around
$3,&00,000.
•/.
A depth of seven feet was used in the Feasibility Study, this
depth was selected for discussion and costing purposes due to
insufficient data to establish depths where background levels
would be reached in the soil profile. Depths of excavations
could be less (or more) based on additional investigations that
would be needed before determining the exact amount of contaminated
soil to be excavated. Guidelines will be established to determine
the depth and extent of the excavations.
A drilling and sampling program will be established to obtain
representative samples from the soil profile. Complete analyses
of these samples will be performed at an EPA approved laboratory.
Background levels for the contaminants will be designated
before excavations begin.
Samples for field screening analysis will be obtained from pre-
set increments of material being removed from the excavations.
This sampling/removal approach allows field action decisions to
be made within an appropriate amount of time and also permits
cleanup activities to proceed at an acceptable rate. When
contaminations in the samples from the excavations reaches
•background" levels, removal of materials would cease.
Alternative 7 will consist of the following:
• Excavation of contaminated soils to a depth where contaminant
concentrations are at background levels (expected to be seven
feet or less as is required to remove contaminated soil - Areas
A & B); Backfilling; Surface Grading and Revegation; Off-site
landfill disposal; Extraction and on-site treatment of contam-
inated groundwater. Groundwater will be cleaned to background
levels and reinjected into the aquifer.
This alternative includes excavation of contaminated soils
to a depth where contaminant concentrations are at background
levels. The depth is expected to be seven feet or less.
Groundwater would be extracted, treated on-site to "background"
levels, arid injected back into the aquifer through injection
wells. The objective of this remedial action is to reduce
the concentrations of contaminants in the groundwater to levels
where potential risk to human health and the environment are
also reduced to acceptable levels.
It will cost approximately 3 1/2 million dollars to excavate
the contaminated soil at the Distler Brickyard site and haul it
to Ohio for disposal. It will cost approximately 5 million
dollars to cleanup the groundwater at the site to background
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-3-
levels. The combined cost of this remedial action alternative
is approximately 8 million dollars. Background levels will
be shown on enclosed tables.
Please consider this alternative and by return electronic mail,
no later than Monday, July 28, 1986, let me know the Commonwealth
decision.
Sincerely yours,
Richard D. Stonebraker, Acting Chief
Emergency & Remedial Response Branch
Enclosure
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-Te E. BALDWIN < " £ MAOTHA LAVNB CC.LM»S
COMMONWEALTH OF KfNTUCKV
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
FO*T BOONE PIAZA
1 B REIUY ROAD
Juy 3, 1986
mr. Richard D. Stonebraker
Emergency and Remedial Response Branch
U. S. Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30365
Dear Mr. Stonebraker:
The purpose of this letter is to comment on the proposed remedial action
alternative for the D is tier Brickyard site in West Point and Dlstler Farm site in
southwestern Jefferson County, Kentucky. The State could approve of a remedial
action alternative containing the following components:
Dtetler Brlofcyard
a
1. Excavation of contaminated soils to a depth where contaminant
concentrations are at background levels (expected to be less than 7 feet
depth). The excavated coil could be either transported off-site to a
permitted hazardous waste disposal facility or; treated on-site to render
it non-hazardous. The resulting treated soil would then need to be de-
Usted under RCRA so that it could be left on-rtc. Excavated soils
would be replaced by clean soils, and the resulting site regraded and
revegetated.
2. Extraction and en-site treatment of contaminated rroundwater.
Groundwater would be cleaned to background levels and reinjected into
the aquifer.
As previously communicated to your staff, It would not be acceptable to
construct an on-sitc RCRA landfill at this site, nor is it nesossary to cover the
excavated soil areas with a RCRA cap as proposed in the draft Record of Decision
which we received in June, 1986.
Dirtier Farm
1. Excavation of contaminated soils to a depth where contaminant
concentrations are at backcrour.d leveb (expected to be leas than 11 feet
depth). The excavated soils could be either transported off-»ite to a
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a.
permitted hazardous waste disposal facility or treated on-«ite to render
it non-hazardous. Excavated soil would be replaced by clean toils, and
the resulting site regraded and revegetated.
Extraction and off-qite treatment of contaminated groundwgter.
Ground water would have to be cleaned to background levels under
Kentucky requirements.
Kentucky presently has $627,000 In the Kentucky Hazardous Waste
Management Fund which could be used for the State match on these two projects.
While in kind services could mitigate some of the State match, Kentucky could not
project a complete 10% match with the fund it now has set aside. Approximately
$140,000 per year is generated by the Kentucky Hazardous Waste Management
Fund.
cc: Mike Helton
Pat Haight
Barry Burrus
Sincerely,
x Barber, Director
n of Waste Management
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• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
., J4S COUHTLAND STHECT
ATLANTA. GEORGIA 30JI5
JUN 1 2 1386
Date:
Subject: Reviev.' of Aquatic Impacts on Streams Mear the Distler Fam site
and the Distler Brickyard Site
Frcn: Chief, Ground-Water Technology Unit
To: Nancy Redgate, Chief
KY, NC, TJ Unit
. . Remedial Action Section
The attached reviews were conducted at the request of the Office of Grourri-
Water Protection (now the Ground-Water Technology and Management Section).
These reviews assumed that contaminated ground water would discharge to the
streams downgradient from the site. On close review of the available ground-
water data, neither Stump Gap Creek downgradient of the Farm Site nor Bee Bran-1
down-gradient of the Brickyard Site is expected to receive discharge frcn tSe
contaminated aquifer. Therefore, no impact on these surface waters is expected
to occur as a result of ground-water discharge. However, ground-water data is
limited and if high water-table conditions occur such that discharge to the
streams occur, the expected affect is discussed in the attached memos.
The proposed selected alternatives which extract and treat the contaminated
ground-water will eliminate the threat of impacts on the downgradient stream.
Gail Mitchell
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DATE: JUN 12 1SE£
Selection of an Appropriate Remedial Action Alternative for the Distler
•JECT. Farm Site in Jefferson County, Kentucky and for the Distler Brickyard
Site in Hardin County, Kentucky
Chief, Groundwater Technology Support Unit
Nancy Redgate, Chief
TO: Kentucky/North Carolina/Tennessee
Remedial Action Section
THRU: E. Stallings Howell, Chief
Groundwater Technology and Management Section
Jin Kutsnan, Chief
Groundwater Protection Branch
The March, 1986, draft Feasibility Studies for the Distler Farm Site and
the Distler Brickyard Site have been reviewed. Based on the information
provided and evaluated in these reports and the support documents, a
remedial action alternative can be selected for each site that should
satisfactorily remediate the groundwater contamination problems.
Recommendations
Distler Farm Site:
To prevent offsite migration of contaminated groundwater through the
fine-grained alluvial aquifer and to prevent or mitigate downward leakage
into the sand and gravel water-supply aquifer, it is recommended that
contaminated groundwater be extracted through a system of production/
injection wells. This contaminated groundwater will be temporarily
stored in on-site storage tanks and then transported to an off-site
treatment/disposal facility such as the Louisville/Jefferson County
Metro Sewer District treatment plant. Contaminated soils are to be
excavated to background levels or to the water table and disposed of
off-site. The excavated area is to be backfilled, graded and revege-
tated. (Alternative 6, Distler Farm Site Feasibility Study)
Distler Brickyard Site;
To prevent the plume of contamination in the sand and gravel aquifer from
migrating farther from the site and ultimately to private domestic wells
downgradient, a groundwater recovery, -treatment and infiltration system is
recommended. Recovered ^rt.ar.inated gro-.in^wa^er will, after treatment, be
allowed to infiltrate bo-* into the aquifci as an a^janc^ to precipitation
in flushing contaminants from the soil column. The most contaminated soils
are to be excavated and disposed of in an on-site landfill. The excavated
area will be backfilled, covered with a cap that meets RCRA design standards,
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graded and revegetated. (Alternative 5, modified, Distler Brickyard
Site Feasibility Study)
Background for Selection of Proposed Alternatives
Distler Farm Site
The selection of an appropriate remedial action alternative for the Farm
Site was driven by two (2) important factors: (1) the site is within the
ten year flood plain of the Ohio River and based on recent history is
inundated more than once every ten (10) years; and (2) the sand and
gravel aquifer underlying the site provides drinking water to residents
living no more than 1000 feet downgradient of the site.
Groundwater Contamination
A "pool" of contaminated groundvater has been identified at the site. The
available data indicates that this contaminated groundwater is restricted to
the fine-grained alluvial aquifer. In the immediate vicinity of the site,
this aquifer is not a drinking water supply aquifer, but it is directly
connected to the underlying sand and gravel aquifer which supplies drinking
water to residents living along the banks of the Ohio River, 1000 feet down-
gradient from the Farm site. The available data indicates that a vertical
hydraulic gradient exists that will transport contaminants downward into the
sand and gravel aquifer. Any contaminants that reach the sand and gravel
aquifer are expected to migrate to these private domestic wells and also
into the Ohio River.
A lateral hydraulic gradient in the fine-grained alluvial aquifer towards the.
southeast also exists. It appears that the water table of this aquifer does
not intersect Stump Gap Creek and, therefore, should not effect this stream
via groundwater discharge. However, the discharge area for this aquifer is
unknown based on the available data and, therefore, the effects of continued
migration of contaminants can not be fully evaluated.
Based on the potential for endangerment of a water supply aquifer, the
groundwater extraction/injection renedial action proposed in Alternative 6
is recommended. As acknowledged in the Feasibility Study, a detailed
hydrogeologic investigation including a calibrated groundwater computer
model and leachability or "batch" tests will be needed to finalize an
effective design for the extraction/injection system.
The Feasibility Study proposes to use the Preliminary Protective Concentra-
tion Limits (PPCL) which are based on the 10~6 unit Cancer Risk as the
groundwater remediation criteria (remedial action clean-up goals). Alter-
nate groundwater clean-up goals are proposed and presented in the Jane
5, 1986, memo (attached) from Kenneth Orloff, Regional Toxicologist. Tnese
clean-up goals are based on existing and proposed drinking water standards.
After clean-up of the fine-grained alluvial aquifer to the drinking water
standards, any leakage of contaminants into the underlying sand and
gravel aquifer should result in concentrations far below the drinking
water standard at any downgradient water supply well.
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extracted groundwater is to be treated ajnd disposed of at an off-site
treatment/disposal facility. As discussed in the May 16, 1986, memo to you
from Stagings Howell, a waste treatability study may be necessary to
assure that an appropriate facility is selected to treat and dispose of
the extracted contaminated groundwater.
The Feasibility Study states that a permit from EPA will be needed for the
injection wells. Vtells that inject water free of hazardous constituents
into an underground source of drinking water are considered to be Class V
injection wells under the Underground Injection Control Program implemented
by Region IV in Kentucky. These wells are authorized by rule and no permit
for the injection wells will be required.
Soil Contanination
Significant levels of soil contamination were detected both at the surface
and down to four (4) feet in depth. The most significant levels of
oontanination may occur at greater depths in the soil column (between 9
and 20 feet) where the waste materials were buried and subsequently
released. No soil samples were collected from these depths to establish
the level of contamination.
Because the site is located in the ten (10) year flood plain and frequently
inundated, any capping alternative as proposed in the Feasibility Study
(alternative 2,3,4 and 5) may not be effective .over the long term in
mitigating the transport of contaminants into the groundwater system.
Neither a "RCRA Cap" nor a "CERCLA Cap" can prevent infiltration of water
through the cap during periods when the cap is inundated. During flooding
events infiltration would occur that would eventually move through the
contaminated soils and transport contaminants towards the water table.
in addition, the water table may fluctuate seasonally through contaminated
soils releasing contaminants to the water table aquifer which are then
available for transport with the groundwater system.
The emplacement of a cap may alter the groundwater hydraulic relationship
between the fine-grained alluvium and the sand and gravel aquifer and
slow the rate that contaminants are transported to the sand and gravel
aquifer. But over the long term a release of contaminants into the sand
and gravel aquifer would be expected that might endanger the health of
those residents who obtain their drinking water from nearby, downgradient
wells.
To protect the sand and gravel aquifer from contamination after the
extraction/injection operation is completed, it is recomended that the
sources of contamination (i.e., the contaminated soils) be removed and
disposed of off-site in an appropriately designed landfill as proposed
in Alternative 6_. Removal of these soils from the site will assure no
future threat to the the groundwater system at this site.
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The soil removal remedial action will require additional soil sailing
and 'quick turn-around analysis" to establish the depths and lateral
extent' of soils to be removed. A detailed protocol for the soil renoval
operation2will need to be established to assure that the remedial action
is cost effective and environmentally sound.
Distler Brickyard Site
Groundwater contamination has been detected in the sand and gravel aquifer
that supplies drinking water to residents of West Point, Kentucky, located
approximately 2500 feet downgradient of the site. Contaminants present
in the sand and gravel aquifer are projected to exceed the EPA existing
and proposed drinking water standards at the private domestic supply
veils and, therefore, will pose a health threat if not remediated. Also,
the discharge area for this aquifer downgradient from this site is the
Ohio River.
_/
Groundvater Contamination
To prevent contaminants from reaching the private domestic supply wells
downgradient from the site, it is reccrartended that groundwater be extracted
from the aquifer with the use of punping wells as in Alternative 5. The
recovered groundwater is to be treated for contaminant renoval at an
on-site treatment plant then returned to the aquifer. The Feasibility
Study recommends the use of injection wells to return the treated water
to the aquifer to provide additional hydraulic head to drive the contami-
nated groundwater towards the recovery wells. Because the selected
alternative provides for only partial removal of contaminated soils (to
be discussed below), we are recommending a modification to the design
proposed in the Feasibility Study. By returning treated groundwater to
the aquifer through infiltration trenches or basins which overlie suspected
contaminated soils that are to be left in place, additional leaching of
contaminants will occur while the groundwater recovery system is in
place. This will provide better long-term protection for the sand and
gravel aquifer from contaminants leaching from the overlying fine-grained
alluvium.
The Feasibility Study recommends the use of the Preliminary Protective
Concentration Limits (PPCL) which are based on the Unit Cancer Risk
(10~6) as the remedial action clean-up goal for treated groundwater. The
«ame alternate ground-water clean-up goals are recommended for the Brickyard
Site as are proposed for the Farm Site. (See attached memo from Kenneth
Orloff, Regional lexicologist.) These clean-up goals are based on the
proposed and existing drinking water standards. While we are proposing a
consistent approach at both sites, the treatment process proposed in the
Feasibility Study should be capable of reducing most contaminants in the
groundwater (mostly volatile organics) to below detection limits through
an air stripping process.
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As~acknowledged in the Feasibility Study, a detailed hydrogeologic
investigation including a calibrated groundwater computer model will be
necessary *o design an effective recovery system. Additional dcw^graci
monitor wells may be necessary to determine the downgradient extent of
the plane which has not been established with existing data. The design
of the recovery system should take into consideration the removal of a
floating organic film that may exist at the water table underlying part
of the site.
In the event that the final design includes injection wells, injection
wells associated with a CERCLA groundwater clean-up effort are considered
to be Class V wells under the Underground Injection Control Program
implemented in Kentucky by Region IV. A permit would not be required.
Soil Contamination
-/
It is reocnrended that to mitigate the potential for long term continued
release of contaminants into the sand and gravel water-supply aquifer
that the most contaminated soils be removed. These contaminated soils
are not expected to occur at depths below seven (7) feet; however, this
will need to be verfied by sampling and analysis during or preceding the
•oil removal operation.
Following the excavation of the most contaminated soils, a trench or
basin will remain. It is recommended that prior to backfilling the
excavated area and during the groundwater recovery/treatanent operation
that the treated groundwater be allowed to return to the aquifer by
infiltration through these trenches or basins, if conditions will
allow. This would provide for leaching of contaminants from soils
that are to remain in place. The final Feasibility Study should evaluate
this modification based on the available data. The permeability of the
•oils nay be too low to allow for successful implementation of this
recomendation.
Following the contaminated soil removal and after groundwater clean-up
is completed the site is to be backfilled, covered with a cap that meets
the RORA design standards, graded and then revegetated. Part of the site
to be capped is in the 100 year floodplain; therefore, the cap should be
specially designed to bring the capped areas above the 100 year floodplain
elevation. Tnis should mitigate the potential for further release of
contaminants to the sand and gravel aquifer over the long term.
The excavated soils are to be disposed of in an on-site landfill located
above the 100 year flood plain and properly designed with liners, leachate
collection, capped and monitored for grounawater contamination. Tnis
should assure adequate protection for the groundwater system at the site.
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Discussion
The sand and gravel aquifer underlies the Distler Farm site at approximately
30 to 40 feet below surface and occurs at 10 to 40 feet below surface under-
the Distler Brickyard Site. This aquifer is a current source of drinking
water for residents on private domestic wells downgradient from both sites.
In addition, residents of the City of West Point, Kentucky are supplied
drinking water through wells that produce from the sand and gravel aquifer.
These wells could potentially be impacted by contamination from the Brickyard
Site if not remediated. Given the current use of this aquifer, it meets (at
a minimum) the Class II criteria for classification under EPA's Groundwater
Protection Strategy. The selected alternatives which provide for grountjrfater
clean-up and long tent protection of the aquifer by removal of contaminated
soil source materials are consistent with the Groundwater Protection
Strategy's guideline that Class II aquifers be cleaned-up to background
levels or to the drinking water standards.
We are aware that the City of Louisville, Kentucky has proposed to provide
the residents of West Point, Kentucky with an alternate source of drinking
water supplied by the Ohio River (upgradient from both Distler Sites) by
extending their distribution system to West Point. While we acknowledge
that this proposal would meet the performance goal of providing long-term
public health protection for the residents on the public water system,
there are presently residents living downgradient of both sites that are
not supplied by the existing public water system. These residents would
not be protected by this proposed alternative. Also, any decision to
allow the groundvater to remain contaminated would result in a discharge
of contaminated groundwater to the Ohio River.
. *
Both the Farm Site and Brickyard site could impact waters that are under
the jurisdiction of ORSANCO (Ohio River Sanitation Commission). Any
action taken by EPA with regard to the two sites should consider the
possible .impact on the surface waters and the need to avoid any controversy
with ORSANCO regarding the clean-up of these sites.
Gail Mitchell
Attachment
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r UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
. ., 345 COURTLANO STREET
ATLANTA. GEORGIA JOJ65
r*te: JUN 5866
Subject: Simary of Recommended ACI-s at Distler Farm Site anl Distler
Brickyard Site
Frm: lexicologist
Ground-Vteter Technology Unit
To: E. Stallings Howell, Chief
Ground-Water Technology and Management Section
•The following recommended ACLs should be considered in conjunction with my two
previous memos (Kay 16 and 2R, 1^961 to you on the above sites. These AfL.«
would be applicable to ground water surrounding the site if it were being used
as a source of potable water.
Distler Farm site
The following contaninents of concern from Table 1-3 of the FS were selected
for possible ACL development.
Chenical Recommended "ACL"(D Basis
1,1,1-Trichloroethane 200 p MCL
1,1-Oichloroethene "7 p MCL
trans-l,2-Dichloroethene 70 p
Toluene 2,ooo p
Trichlomethene 5 p MCL
Vinyl chloride 1(2) p MCL
Chromium " SO (3) MCL
Lead 50 (A) . MCL
p MCL - proposed Maximum Contaminant Level
p RMCL - proposed Recommended Maximum Contaminant Level
(1) water concentration in ug/1
(2) Although vinyl chloride may not have been an original contaminant at
the site, it may have been formed by reductive dehalogenation of
other chlorinated hydrocarbons by soil microrganisms.
(3) A revised, proposed RMCI of 120 iig/1 has been announced.
(4) A revised, proposed RMCL of 20 ua/1 has been announced.
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TX»-T cf t-vt-chemicals in Tanle 1-3 of th<-> PS were identi'ie^ cnl, in soil
samples at the site (r.e., benzene, tetrachloroethene, and naphthalene).
Therefore, no ALCs are offered for these compounds.
Two phthalates were detected at low concentrations in ground-water sampler fro-.
the site (bis(2-ethylhexyl)phthal*te: 2-R ug/1 and dihutylphthalate: 1-2 ug/1).
These compounds have relatively large log Koc values and would be expected to
hind to soil particles, thereby impeding their migration from the site.
Furthermore, the low concentrations detected in ground w*ter are far he low th<=>
Ambient water Oiality Criteria (AUrO for these compounds (IS,000 ug/1 and
34,000 ug/1, respectively). Therefore, no ACLs are offered for these compounds,
Isophorone was detected in a single ground-water sample at a low concentration
(2* ug/1). Since this concentration is far helow the AVTXT (lS,nnn ug/1), no
ACL is offered for isophorone.
Distler Brickyard Rite
» ^»^»»««^^«i^^«^^^w«^»""^^B^^
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naphthalene and bis( ?-«thylhexyl)phthalflte would he expected to bind to sell
.particle* whic>-> would imped* their migration in groun^ water from the site.
'-Furthermore /--the low concentrations of bis(?-*thylhexyl)phthalate in wat-?'-
fanpl<»« (2-">ffl iig/1) were far N>low t*e Avnr standard (lS,non ug/1). Therefore,
-"no ACLR are offered for th»se compounds.
the w*ter sa"pl«»s were collect«»d, they were not filtered prior to
acidification. Therefore, the reported net*] concentrations (arsenic,
lead) may he anomalously high. ACLs are offered for these metals, but it
be recognized that the ACLs apply only to dissolved metal ion concentrations.
In developing the above ACLs, additive effects were not taken into consideration
for the following reasons:
1. Ttie ACLs were primarily based on drinking water regulations. The application
" ' of -drinking water regulations to public water supplies does not require
consideration of potential additive effects.
2. Scientific information on toxic interactions between chemicals is extremely
limited. It would not be possible to scientifically document the an
assumption of additivity of toxic effects for the chemicals in the tables
above. Antagonism or synergism of toxic effects is also possible.
3. If additivity of toxic effects were assumed, then the ACL for a chemical
would be dependent on the relative concentrations of other chemicals present.
Since every well would have different proportions of chemicals, a specific
ACL for each chemical at each well would be required. Furthermore, the
relative proportions of chemicals would change with time. These considerations
would make it impossible to offer specific and permanent ACLs.
4. As a related issue, it should be noted that most of the contaminants of
concern are volatile organic chemicals (VOC) which can he removed by the
same treatment technologies. Therefore, if treatment were instituted to
reduce th«» concentration of one vnc, it would simultaneously reduce the
concentrations of all the vncs present. This would result in a reduction
in the total VOC-mediated risk, as well as reducing the risk for an individual
vnr.
Kenneth G. Orloff
cc: toil Mitchell
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(&}
*+,. .f
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*>« ..f REGION IV
> •*;•*
S4S COURTLAND STREET
ATLANTA. GEORGIA 30355
• v _
MAY 161988
Date:
Subject: Distler Farm site - Revised Draft Remedial Investigation (Rl)
and Feasibility Study (FS) Reports, March 1985
Fran: E. Stallings Howell, Chief
Office of Ground-water Protection
To: Nancy Redgate, Project Officer
Emergency fc Remedial Response Branch
As requested on May 6, 1986, we have conducted an expedited review of the
subject reports. In general, we have found the reports to be technically
well developed. They also appropriately identify deficiencies in the data
base and data needs for the design of a remedial action.
Based upon our review, we recommend that the selected remedial alternative
include excavation of all contaminated material. This recommendation
will be based upon the site being within the 10-year flood plain (see
comment number two on the FS report).
Also, the selected remedial alternative should either provide for clean-
up of contaminated ground water to the levels specified in Kenneth Orloff's
memorandum dated May 13, 1986 (attached) or provide for an alternative
water supply to the residents in the undefined area of potential impact
of both the Distler Farm and Brickyard sites. The mission of our Office
is to protect ground water; therefore, we recommend that ground water be
restored to these levels. However, we are cognizant of the requirement
that alternatives be considered with respect to technical performance and
ability to meet other cost and non-cost criteria. .
Thus, we suggest that the following facts be considered in the final
recommendation for remedial action:
1. The Louisville Water Company distribution system is approximately
three miles, northeast of the farm site and the source of water for
this system is the Chio River. Funrts diverted from ground-water
restoration at the farm and brickyard sites could support the construction
of the extension of the service area to include the west Point ccmunity.
2. Tentatively identified ccnpo'.irvl conta-inztior. of t-jree resi :.--.tia!
wells were reported in the RI report. Extension of the distribution
system would provide a secondary benefit not specifically related to
remedial action at either site.
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-2-
3. Arv alternative surface water supply would satisfy the performance
goal of reliably providing long-tein protection and reducing
potential risk to human health. Also, it would permanently protect
the significant health-risk related exposure pathway (ingestion of
contaminated ground water).
4. If ground water was not restored to an acceptable level, contaminated
ground water could eventually enter Stump Gap Creek, Pond Creek, the
Salt River, and the Ohio River. This could result in adverse aquatic
and terrestrial ecological impacts on particularly the creeks. Also,
recreational impacts could occur. Finally, the concern for potential
dermal contact with contaminated surface and ground water would not
be alleviated.
Attached, for your information, is additional comments on the reports.
Please direct any questions concerning these Garments to Lloyd Vbosley of
my staff at x7501.
HowAl
E. Stallings
Attachments
cc: Al Smith, WT> (with attachments)
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Cements of the Office of Grouno-Aater j
on the Revised Draft Remedial Investigation an-3 Feasibility
Study Reports-, Date^ torch 1<*B6, for the Distler Farr, Site
Jefferson County, Kentucky
May 14, 19B6
'*-.
Feasibility Study Report (FSR)
1. Action 1.4, Objectives of Remedial Action, page 1-31 -
As state-!, the State of Kentucky is considering the development of a
ground-water classification system as part of its ground-water protection
strategy. The final strategy is scheduled to be released later this
year. However, the FSR must address the appropriate ground-water
classification under the EPA Ground-Water Protection Strategy (40 CFR
Part 3Cn.68(e)(2)(v)). While cur guidelines for implementing the
classification system are now being considered by the Assistant
Administrator, it may be several months before they are finalized. In
the interim, we are attempting to incorporate the differential
protection policy reflected in the classification system into regional
actions. The following Interim conclusions can be made based upon
the information provided:
A, Ground water at the site does not appear to feed an ecologically
vital area.
B. Ground-water supplies near the site are replaceable by either
drilling deeper (assuming no interconnection with the contaminated
or potentially contaminated alluvium aquifer) or extending the
Louisville Water Company distribution line, which is now serving
the cou'iunity of Kosmosdale, located approximately three miles
northeast of the site. The Louisville system obtains its raw
water from the Ohio River.
C. The alluvium aquifer at the site is somewhat vulnerable to
contamination.
Given this information, the alluvium aquifer could be classified a* being
either Class I or Class II. We concur that for the purposes of the FSR,
a worse case 'Class I" assumption is appropriate. This assumption is
based solely upon the ground water being vulnerable to contamination.
2. Section 2.1, Surface Sealing/Capping, page 3-6 -
The "Environmental and Public Health Criteria" discussion should
acknowledge that surface sealing/capping has another major limitation
with respect to sites located in the flood plain. During a flood
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event or when the water table is seasonally high, the contaminated
"material would come in contact with ground water. Vhile this occurrence
may. happen infrequently, the result could be the creation of a new
volurevof contaminated ground water. The level and significance of
this contamination would be unknown due to the short exposure time and
the characteristics and persistence of the contaminants at the tine
of contact.
This limitation as noted should be incorporate'! into the alternatives
discussion in the FSR.
3. Section 4.4, Alternative 3, page 4-2P -
A. The Kentucky Ground-Water Section has recently implemented a
water well regulatory program (KSS 223.400-223.460, 223.991).
This program regulates ail wells constructed for the removal of
... water for any purpose except agricultural. Detraction wells
would be subject to the construction practices and standards
found in 401 KAR 6:310. It is currently unclear whether monitoring
wells are also subject to these regulations.
B. Wfe question the ability of the Metro Sewer District (MSD),
to accept the recovered contaminated ground-water (2|600 gpd,
240 dpy, 4 yr.) without the results of waste treatability studies.
Depending upon the potential toxicity of the ground water, the
MSD may require pre-treatment or controlled, slow release to their
system. Either case could significantly alter current capital
and O & M cost estimates. Further contact with the *SD is
suggested to obtain more specific guidance on the systems' ability
to adequately handle the quality and quantity of contaminated
ground water.
Note that the duration of pumping extends beyond four years for
alternatives number four (eight years), and five and six (13 years).
This should also be discussed with the MSD.
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-3-
^investigation Report (P.I°.)
1. Section 3.3.1, Regional Ground water, page 3-T5 -
Tne RIR acknowledges that the limestone underlying the site may have
large solution channels yielding about 50 gallons per minute to wells
penetrating these channels. However, based upon limited information,
it appears that such solution activity does represent a threat to the
integrity of the shale bedrock specifically at the site.
2. Section 3.3.4, Detent of Ground-Water Contamination, page 3-1H2 -
-fhe limited ground-water quality data reveals some tentatively
identified compound contamination of three residential wells. Wiile
a source-to-receptor relationship between the site and the wells
cannot be inferred, the source of contamination could be septic
systems or past chemical spills.
3. Section 3.3.5, Summary and Recommendations, page 3-147 -
We generally concur with the recarrrendations provided for further
study of the site, however, revisions may be needed to more appropriately
reflect the selected remedial action. Also, it is assumed that the
samples collected during site borings will be analyzed for a select
list of constituents.
4. Appendix F -
The title should read "Distler Farm Site".
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SATI:
jgCT "ACLs" for Remedial Activity at Distler Farm Site;
Jefferson County, KY
«
" ~~ Toxicologist
! Drinking Water Section
TO Stallings Howell, Chief
Office of Groundwater Protection
The RI/FS study at the Distler Farm Site identified groundwater contamination
as the most significant route for human exposure to chemical contaminants
fron the site. Although groundwater contamination is presently confined
to the site, potential off-site migration could lead to contamination of
private and public drinking water wells. The chemical contaminants of
concern were listed in Table 1-3 of the FS (page 1-38).
The above premises were accepted, without evaluation, and served as the
basis for the following ACL recommendations. It will be assumed that
ingestion of drinking water containing the chemicals is the sole route of
exposure. Other routes of exposure, such as inhalation of VOCs during
showering or dermal absorption during bathing, will not be considered
since there are insufficient scientific data to quantitate these potential
exposures.
The following ACL recommendations refer to chemical concentrations at the
point of human exposure. If the point of compliance monitoring is at the
dumpsite, it may be possible to ammend the ACLs by factoring in dilution
of the chemicals as they migrate from the site, adsorption onto soil
particles, biological and chemical degradation, etc.
The following recommended ACLs do not consider any potential effects on
aquatic or terrestrial life forms exposed to contaminated groundwater.
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. 1
1
I
-2-
Chemcal Recomnended "ACL'd) Basis
Benzene 5 p MCL
1,1,1-Trichloroethane 200 p MCL
1,1-Dichloroethene 7 p MCL
trans-l,2-Dichloroethene 70 p RMCL
Tbluene 2,000 p RMCL
Trichloroethene 5 p MCL
Tetrachloroethene (see footnote 2)
Vinyl chloride 1 p MCL
Naphthalene no health-based goal available
Cibutylphthalate 34,000(3) AWCC
bis(2-ethylhexyl) phthalate 15,000(3) AVQC
I sophorone 5 , 200 AWQC
Chromium 50(4) MCL
Lead 50(5) MCL
p MCL - proposed Maximum Contaminant Level
p RMCL - proposed Recommended Maximum Contaminant Level
AWQC - Ambient Water Quality Criteria
(1) water concentration in ug/1
(2) The draft proposed MCL for tetrachloroethene was 10 ug/1. A subsequent
study by the National Toxicology Program provided additional animal .
carcinogenicity data on the compound. The public is being given time
to comment on this study prior to the announcement of a proposed MCL.
(3) . The AWCC recommended standard is based on non-carcinogenic toxic effects.
Since the AWCC number was released (1980), a study by the National Toxicology
Program identified bis(2-ethylhexyl) phthalate as an animal carcinogen.
This finding may result in downward revision of the reccmnended
standards for phthalates, but no revised figures are yet available.
(4) A revised, proposed RMCL of 120 ug/1 has been announced.
(5) A revised, proposed RMCL of 20 ug/1 has been announced.
Kenneth G. Orlof f
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TO:, WILLIAM ANDERSON
"PEC - HOUSTON
FROM: R. VAN TASSEL
SUBJECT: INCINERATION ALTERNATIVES
OISTLER FARM AND BRICKYARD SITES
JULY 14, 1986
D. SENOVICH
A. McCLURE
H. D. TRIMBATH
A. BQNBERGER
A. FINKE
Enclosed are draft text, phone memos, and cost estimates for the
incineration options for the two sites. These Items are being sent
to you as early as possible so you can respond to EPA-Region IV
requirements.
The costs are estimated as follows:
Site
Distler Brickyard
Distler Farm
Distler Farm and
Distler Brickyard
c
Costs *
$ 10.700,000
$ 36.200,000
$ 46,500,000
Cost estimated for onsite construction/remediation.
•• /
// fc •'.TI - •;. if.'> ;• i s .. v r r'e >i i ./ . •' . , ,
The draft text should be reviewed and completed by your staff and then
put 1n the format required for this response.
Also enclosed are copies of vendor's brochures for in situ volitllization
processes. These processes Incorporate accepted principles for removing
hydrocarbon compounds from soils. However, widespread experience for
these in situ processes are not available, and the equipment/procedures
are considered to be in developmental stages.
RLV:vlp
Enclosures
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6^iUi*KD SITE
SOILS INCINERATION ALTERNATIVE
Incineration and Onslte Disposal
Technical Discussion
An alternative consisting of onslte decontamination of the organic
constituents 1n the near surface soils by an Incineration process is
discussed 1n this section^ The excavation of 8,000 cubic yards of
contaminated soils, to a depth of *7 feet, could be processed through
a mobile Incinerator, backfilled Into the excavated cavity, covered
with 2 feet of soil and re vegetated.
MoMle incineration equipment could be mobilized to the site.
Commercially produced units are available and consist of tractor-trailer
mounted components Identified as follows:
t Rotary kiln Incinerator
• Incinerator feeding system
t After burner trailer
• Heat recovery trailer
• Quench and scrubber trailer
• Control room and laboratory
A supply of fuel, Industrial electric power, and boiler grade water
supply are required to support the Incineration process. The fuel supply
1s required to augment the BTU value of the csr.tsr.i rated soil materials
because of the low content of hydrocarbons in the soils, about!
•6.61 percent by weight. The Incinerated soils, with heavjT metals
concentrations at about background levels, could be placed on site 1n
the excavated cavities. Residue from the scrubber system may require
disposal In a permitted offsite disposal or treatment facility. Waters
used 1n the scrubbing and/or cooling processes might require treatment
1n accordance with the applicable discharge requirements.
The Implementation of this alternative will require local, state and
federal approvals for the construction and operation of the incinerator,
onslte earthmovlng activities, disposal of the Incinerated soils,
dispostion of the scrubber wastes, treatment and discharge of process
and cooling waters, monitoring and maintenance of air quality, and
transportation of waste materials off site. The agencies primarily
Involved 1n regulating these operations are discussed under "Institutional
Issues".
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OISTLER BRICKYARD SITE
SOILS INCINERATION ALTERNATIVE
(Continued)
Technical Considerations
The destruction of the organic constituents 1n waste materials by
Incineration 1s an accepted technology. In general, organic and
hydrocarbon compounds can be safety destroyed 1n an Incinerator that
1s appropriate for the waste stream and 1t 1s operated properly.
The rate of processing soils 1n a mobile Incinerator may be on the order
of 4-tons per hour and the equipment can be operated on a 24 hour basis.
Wastes can be processed through the equipment about 75 percent of the
time. The 8.000 cubic yards of soils to be Incinerated are estimated
to weigh about 10,800 tons. This volume of soil could be Incinerated
1n about 150 days or 6 months. A waiting time of about 12 months for
an Incinerator and the time required to obtain all necessary approvals
must also be considered for this alternative.
1.35" 1%
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DISTLER BRICKYARD SITE
SOILS INCINERATION ALTERNATIVE
Institutional Approvals
Some druntned waste materials on this site were removed 1n 1984 and the
Waste Management Division of KY-DNREP considers this site a RCRA facility.
Accordingly, operations and/or alterations at this facility should fulfill
State RCRA requirements and approvals obtained from the Waste Management
Division.
In addition,' the Division of Water, of the KY-DNREP, may require
compliance with KY-NPDES regulations for any process/cooling water
discharges as well as approvals for grading and alterations to the surface
runoff characteristics of the site. Any transportation of wastes from
or to an offsite location should consider State Transportation Department
requirements.
Approvals by the A1r Pollution Control Division of the KY-DNREP will
be required for the construction and operation of an Incinerator within
the «;tate. In addition, approvals by the Air Pollution Control Division
shc-'c be obtained for onsite construction and grading operations with
respect to fugitive, participate emissions requirements.
Construction, grading and operations within the flood plain will require
approvals by the U.S. Army Corps of Engineers and compliance with the
Clean Water Act. Other Federal regulations which should be considered
in the design, construction and implementation of the remedial action
Include CERCLA, RCRA, Safe Drinking Water Act. and Clean A1r Act of
EPA and OSHA of the Department of Labor and Industry. Any off site
transportation of hazardous waste should comply with Federal DOT
requirements.
At the local governmental level, county and local ordinances regulating
construction, grading, and onsite operations should be fulfilled and
appropriate approvals obtained.
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i
£ UNITED STATES ENVIRONMENTAL PROTECTION
•y . '
'*'«* •»3*c<" REGION IV
J4S COURTLANO STREET
v • ATLANTA. GEORGIA JOJ85
JUN 1 2 Q88
Date:
Subject: Review of Aquatic Impacts on Streams Near the Distler Farr, site
and the Distler Brickyard Site
From: Chief, Ground-Water Technology Unit
Tt>: Nancy Redgate, Chief
KY, NC, T»3 Unit
Remedial Action Section
The attached reviews were conducted at the request of the Office of Ground-
Water Protection (now the Ground-Water Technology and Management Section).
These reviews assumed that contaminated ground water would discharge to the
streams downgradient from the site. On close review of the available ground-
water data, neither Stump Gap Creek downgradient of the Farm Site nor Bee Branch
downgradient of the Brickyard Site is expected to receive discharge from the
contaminated aquifer. Therefore, no impact on these surface waters is expected
to occur as a result of ground-water discharge. However, ground-water data is
limited and if high water-table conditions occur such that discharge to the
streams occur, the expected affect is discussed in the attached memos.
The proposed selected alternatives which extract and treat the contaminated
ground-water will eliminate the threat of impacts on the downgradient streams. •
Gail Mitchell
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Region IV - Atlar.ia, Georgia 30.it5
DATE: June 9, 1986
SUBJECT: "bistler Brickyard Site, Harden County, Kentucky
FROM: Chief
Wetlands Section
TO: Gail Mitchell, Unit Chief
Groundwater Technology Support Unit
Surmvary
The potential for adverse impacts to biological resources in surface
waters from contaminants on the Distler Farm site is low. This is due
to limited biotic ccrmunities in Stunp Gap Creek and Pond Creek and to
the large dilution effect of the Ohio River. Stump Gap Creek is a snail
intermittent stream, and Pond Creek is severely degraded by industrial
pollution. The Ohio River does contain significant biological resources.
*
At least four groundwater contaminants (toluene, arsenic, lead and
chromium) are present at concentrations reported to be acutely toxic to
aquatic life. In addition, phthalate esters are present at levels eight
times greater than EPA's criterion for freshwater aquatic life.
Limited information indicated that the biological cximunity of Bee Branch
is not presently degraded. If contaminated groundwater were to contribute
substantially to the stream's flow, significant degradation to stream
biota would occur.
Contaminated groundwater reaching the Ohio River through the coarse-
grained aquifer could detrimentally affect the macroinvertebrate coiminity
living on or in the sediments at the aquifer-river interface, but dilution
should limit these effects to the discharge area. All contaminants
reaching surface waters will be added to the "pool" of existing water
column and sediment toxins and, ultimately, to the aquatic food chain of
the Ohio River which contains a recreational fishery.
William
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Effects on Biological Resources
f ^
Surface Water Biological Resources
Bee Branch"and two of its tributaries (unnamed) receive surface water
runoff from the Brickyard Site. Bee Branch discharges to the Salt River
a short distance upstream from its confluence with the Ohio River. A
course grained aquifer (sand and gravel) underlying the site intersects
the Ohio River bed and Bee Branch to the northwest and may be the primary
avenue of contaminant migration.
Almost no information on the biological resources of the surface waters
adjacent to the Brickyard Site is available. Information from the U.S.
Fish and Wildlife Service, based on casual observations, indicates that
Bee Branch dees not appear to be degraded and contains a warm-water fishery.
Aquatic biota in the intermittent tributaries to Bee Branch, primarily
attached algae and benethic macroinvertebrates (insect larvae, crustaceans
and worms), would be restricted to the wet season or to remnant pools
during drier periods of the year. During backwater flooding fron Bee
Branch, the lower reaches of the tributaries would be utilized by fish as
foraging or breeding areas.
The Ohio River contains both game and non game fisheries. Portions of
the Brickyard Site lie below the 50-year flcodplain. Floodwaters from
the Ohio River will allow fish to forage and breed in the soils and
vegetation on the site.
Contaminant Toxicity
Approximately 64 organic and inorganic contaminants have been found on
the Brickyard Site, including 33 in the groundwater. At least four
contaminants are present in the groundwater at concentrations reported as
being acutely toxic to aquatic life. These include toluene (LC50-13 to
44 mg/lh arsenic (LC50-1.1 "to 60 ng/1); chromuim (LC50-2 to 113 aig/1) and
lead (LC50-0.33 to 75 mg/1). The groundwater.also contains phthalate
esters at levels eight times greater than EPA's Criterion for freshwater
aquatic life (3 ug/1). Additive effects of groundwater contaminants
present in sublethal levels individually can contribute to acute toxicity
to aquatic life. Bioassays conducted on selected samples of the groundwater
would be needed to better assess acute toxicity, especially additive
toxic effects. Chronic exposure to low levels of toxic chemicals in the
water column or in sediments can affect behavior, reproduction, and
physiological processes of organisms.and ultimately be lethal, especially
during sensitive life cycle stages.
Potential Biological Effects
.The primary, route for movement of contaminants fron the Distler Brickyard
Site to surface waters is via groundwater to Bee Branch or to the Ohio River.
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-2-
Minoir rfcutes involve the transportation of contaminated sediments by
surface runoff to Bee Branch or its tributaries or by floodsters fron
the Chio River.
The projected rate of groundwater discharge to Bee Branch frcrn the course-
grained aquifer ranges front 190 to 24,700 ft3/day. No flow data are
available for Bee Branch. If, during dry periods, groundwater discharge
constituted a significant portion of the stream's flow (i.e. greater than
10%) at least moderate impacts to stream biota are anticipated. These
probably vculd be limited to sublethal chronic effects and/or avoidance
reactions, though sensitive species in the cormunity tray be more severely
affected. In addition, sediments and detrital natter would be contaminated
and continue to affect the aquatic ociinunity during subsequent hydroperiods
when surface water constitutes most of the stream's flow.
During Chio River flood events, game and non-game fish will follow the
floodwater onto the Distler Brickyard Site to forage and spawn in the
vegetation and soil. Some potential exists for contaminants to be ingested
by fish as they feed on invertebrates (insects, worms, etc.) or plant
matter on the contaminated soil. Eggs or larval fish on the site would
be more susceptible to toxicants than adult fish.
Contaminated groundwater reaching the Quo River through the course*
grained aquifer could detrimentally affect the macroinvertebrate conrunity
living on or in the sediments at the aquifer-river interface, but dilution
should limit these effects to the discharge area.
All migration routes to surface waters will eventually carry contaminants,
some persistant, into the Chio River to be added to the existing "pool"
of toxicants in the river. Accumulation and bicmgnification of materials
such as lead, naphthalene and pthalate esters may occur in a water body
containing a recreational fishery.
Because of the large dilution effects of the Ohio River the potential
for significant deleterious impacts to aquatic resources in the river is
low. However, at least a moderate potential exists for significant
adverse impacts to the biotic community of Bee Branch from groundwater
contaminants.
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UNITED STATES BJVUOWEOTAL PROTECTION AGENCY
Region IV - Atlanta, Georgia 30365
•'• '•' •?.
EftTE: Jane 9, 1986
SUBJECT: Distler Farm Site, Jefferson County, Kentucky
FRCM: Chief
Wetlands Section
TO: Gail Mitchell, Unit Chief
Groundwater Technology Support Unit
Sjrtmry
*r •
The potential for adverse* impacts to biological resources in surface
waters from contaminants on the Distler Farm site is low. This is due
to limited biotic comunities in Stunp Gap Creek and Pond Creek and to
the large dilution effect of the Chio River. Stunp Gap Creek is a •nail
intermittent stream, and Pond Creek is severely degraded by industrial
pollution.
All but one of the groundwater contaminants found on the site are below
levels reported to be acutely toxic to aquatic life, although at least
four contaminants are present in concentrations which exceed EPA's Quality
Criteria for aquatic biota. If contaminated groundwater from the fine-
grained aquifer discharges to Stump Gap Creek, the small existing aquatic
community in the stream could be severely degraded or destroyed, especially
if groundwater comprises most or all of its flow. The aquatic community
in the lower reach of Pond Creek, which is already limited to pollution
tolerant species, vould be exposed to additional toxins; however, since
the projected groundwater discharge rate is low (2500 ft3/day), impacts
to the aquatic community will probably not be measurable.
Contaminated groundwater reaching the Chio River through the coarse-
grained aquifer could detrimentally affect the imcroinvertebrate community
living on or in the sediments at the aquifer-river interface; however,
it is probable that dilution should limit these effects to the immediate
discharge area. With either transport route, contaminants, some of which
are persistent, will be added to the existing "pool" of toxins in the
water column and sediments. Ultimately, these toxins will be incorporated
in the aquatic food chain of the Chio River which includes a sport fishery.
William L. Krzynski
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Distler Farm si1:e, Ae'i)-cuu<>
Effects on Biological Resources
Surface Water Biological Resources
•' '«.
Stump Gap Creek is an intermittent stream and tributary to Pond Creek. It
receives all surface water fron the site and is a discharge area for the
fine-grained aquifer that presently contains contaminated groundwater. No
biological information is available for this stream. Because it is inter-
mittent, aquatic biota, primarily attached algae and benthic macroin-
vertebrates (insect larvae, worms and crustaceans), would be restricted to
the wet season or to remnant pools during the drier periods of the year.
During backwater flooding from Pond Creek, the lower reaches of Stump Gap
Creek would be utilized by fish from pond Creek as a foraging and/or
breeding area.
Available information fron the Kentucky Department for Environmental
Protection indicates that Pond Creek is a perennial stream and tributary to
the Salt River and supports a poor assemblage of aquatic organisms. The
Creek drains a heavily industrialized section of Jefferson County. Three
landfill sites and over 160 point source discharges are located in the
watershed. Much of Pond Creek has been channelized or cleared, leaving
little habitat for fish or macroinvertebrates. Toxic concentrations of
heavy metals nay already be present in the sediments. The water column
contains higher than normal levels of chromium, lead, cadmium, zinc and
mercury. A limited fishery exists and consists primarily of sunfish,
rough!ish and minnows. The macroinvertebrate community is composed
primarily of pollution tolerant species. The crayfish, Orconectes
jeffersoni, an endangered species, has been reported to be located along
Pond Creek.
No information is available on the biotic community of the lower Salt
River, although discharges of polluted water from pond Creek have probably
degraded aquatic resources to some degree.
The Ohio River contains both game and non-game fisheries. The Distler
Farm site is within the 50-year flood plain of the Ohio River. During
flood events, game and rough fish from the River will move onto the site
to forage and breed in the vegetation and soil.
Contaminant Toxicity
No toxicity bioassays have been conducted on samples of the groundwater.
At least one contaminant, iron, is present in the groundwater in concen-
trations reported in the literature as being acutely toxic to aquatic
life. Iron has been reported to be acutely toxic to freshwater fish at
concentrations of 0.9 to 2 mg/1 (LC50) and to invertebrates at 0.32 mg/1.
Cadmium, chromium, iron and phthalate esters are present at levels which
exceed EPA's.Quality Criteria for aquatic life (cadmium - 1,2 ug/1;
chroaium - 100 ug/1; iron - 1 mg/lj phthalate esters - 3 ug/1)
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-2-
*• Additive effects of these and other groundwater contaminants present in
sublethal levels individually can contribute to acute toxicity to aquatic
li'fe.^ Bioassays conducted on selected sanples of the groundwater would
be nelded to better assess acute toxicity, especially additive toxic
effects. Chronic exposure to low levels of toxic chemicals in the water
colam or in sediments can affect behavior, reproduction, and physiological
processes of organism and ultimately be lethal, especially during sensitive
life cycle stages.
Potential Biological Effects
The primary route for movement of contaminants from the Distler Farm site
to surface waters is via groundwater to Stunp Gap Greek and eventually
Pond Creek, or to the Quo River. Minor routes involve the transportation
of contaminated sediments by surface runoff to Stunp Gap Creek or by
floodwaters from the Ohio River.
.^'
The projected rate of groundwater discharge from the fine-grained aquifer
to Stunp Gap Creek is 345 to 3520 ft 3/day* During dry periods, groundwater
my constitute most or all of the flow of the small creek. Biota renairong
in the creek could be subject to a mixture of toxicants Which would
degrade water quality and could destroy all aquatic life in the creek. Even
at sub lethal levels, organisms may exhibit an avoidance reaction and migrate
cut of the stream to avoid toxicants. In addition, sediments and detrital
natter would be contaminated and would affect aquatic life during subsequent
hydroperiods when surface water constitutes most of the creek's flow. Pond
Creek's biological ccmrunity, already degraded by pollution from upstream
sources, would be subject to additional contaminants being discharged
from Stunp Gap Creek. However, because of the small discharge rate and
the fact that the conrunity is already comprised primarily of pollution
tolerant organisms, little measurable effect would be expected to occur.
During Chio River flood events, game and non-game fish will follow the
flcodwater onto the Distler Farm site to forage and spawn in the vegetation
and soil. Some potential exists for contaminants to be ingested by the
fish as they feed on invertebrates (insects, worms, etc.) or plant matter
on the contaminated soils. Eggs or larval fish en the site would be
more susceptible to toxicants than adult fish.
Contaminated groundwater reaching the Olio River through the course-
grained aquifer could detrimentally affect the macroinvertebrate ccrmonity
living on or in the sediments at the aquifer-river interface, but dilution
should limit these effects to the discharge area.
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-3-
All water routes will eventually carry contaminants, some persistent, into
the. Ohio River which would be added to the existing "pool" of toxicants
in the--River. Accumulation and biomagnificatien of materials such as
lead, naphthalene and phthalate esters may occur in this water body.
Since the River supports a recreational fishery, the potential exists to
contaminate people.
In summary, because of the limited biological resources of Stump Gap
Creek and Rand Creek and the large dilution effect of the Quo River, the
overall potential impact to surface water biota by this individual source
of contaminants is expected to- be low. However, this potential source
may add to the cumulative effects of pollutants which are measurable and
deleterious to aquatic life in the surface waters under consideration.
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