PB94-964009
EPA/ROD/R04-94/175
July 1994
EPA Superfund
Record of Decision:
General Tire Landfill Site,
Mayfield, KY
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GENERAL TIRE LANDFILL
SUPERFUND SITE
RECORD OF DECISION
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Region IV
October 1, 1993
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GENERAL TIRE LANDFILL SUPERFUND SITE
RECORD OF DECISION
TABLE OF CONTENTS
SECTION
PAGE
DECLARATION FOR THE RECORD OF DECISION
. . . . . . . . . . . . . . . . . . . . 111
DECISION SUMMARY. . .. . . . ... " . .... . . .. "" .. . . . .. . . . . .. . .. .
1
1.0 BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.1 Site Location. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.2 Site Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.3 Site History and Enforcement Actions. . . . . . . . . . . . . . . . . .
1
1
1
5
2.0 COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . .
8
3.0 SITE CHARACTERISTICS. .. """"""""" """" 9
3.1 Hydrogeologic Characteristics. . . . . . . . . . . . . . . . . . . . . . .. 9
3.1.1 Hydrogeologic Setting. . . . . . . . . . . . . . . . . . . . . . .. 9
3.1.2 The Effect of the Plant Wells .................. 10
3.1.3 Hydrogeologic Conclusions. . . . . . . . . . . . . . . . . . .. 12
3.2 Remedial Investigation Summary. . . . . . . . . . . . . . . . . . . .. 13
3.2.1 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
3.2.2 Swface Soil. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
3.2.3 ~ace Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 15
3.2.4 Sediment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 15
3.2.5 Groundwater: Sparta Water-bearing Unit. . . . . . . .. 15
3.2.6 Groundwater: Tallahatta Water-bearing Unit. . . . .. 16
4.0 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
4.1 Sn~~~f Human H:alth Risks. . . . . . . . . . . . . . . . . . . .. 19
4.2 Snntn'1W1";Yof the EcologIcal Assessment. . . . . . . . . . . . . . . .. 23
5.0 scoMf~ND ROLE OF THIS RESPONSE ACTION. . . . . . . . . .. 26
RESPONSIVENESS SUMMARY. . ... .. .. " . . .. . .. . " . .. . ., ...... .. 27
1
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TABLE OF CONTENTS
(continued)
TABLES
PAGE
Table 1 Plant Wastes Placed Into The Landfill And Their Approximate Weight
Percentages. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 5
Table 2 Summary of Enforcement History. . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
Table 3 Constituents of Interest in Site Media. . . . . . . . . . . . . . . . . . . . . . .. 17
Table 4 Summary of Potential Carcinogenic Risks and Noncarcinogenic Hazard
Indices (Current and Future No Action Scenario) . . . . . . . . . . . . . .. 24
Table 5 Summary of Potential Carcinogenic Risks and Noncarcinogenic Hazard
Indices (Future Site Development Scenario) . . . . . . . . . . . . . . . . . .. 25
FIGURES
Figure 1 Site Location Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
Figure 2 Landfill Layout. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
Figure 3 Site Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
Figure 4 Landfill Trench Profile. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 4
Figure 5 Site Profile. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11
APPENDICES
Appendix A:
Proposed Plan Public Meeting Transcripts
Appendix B:
Commonwealth of Kentucky Comments on the Proposed Plan
Fact Sheet and EPA's Response Letter
II
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
General TirelRubber LandfilJ
One General Street
Mayfield, Kentucky 42066
Statement of Basis and Purpose
This Record of Decision presents the selected remedial action for the General Tire LandfilJ
site, located in Mayfield, Graves County, Kentucky. The remedial action selected conforms
with the requirements of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous Substances
PolJution Contingency Plan (NCP). This decision document is based 00 the information
contained in the General Tire Landfill Administrative Record.
EPA has determined that its response at this site is complete. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
The Commonwealth of Kentucky Department for Environmental Protection does not concur
on the selected remedy.
Description of the Selected Remedy
Based on the data colJected in the remedial investigation, and the potential current and
future risks estimated in the Baseline Risk Assessment, no further action is necessary at
this site to provide additional protection to human health and the environment.
The Mayfield General Tire facility located next to the site operates SIX groundwater
extraction welJs that provide the facility with non-contact cooling water. These wells are
providing a significant level of protection to human health and the environment by
preventing migration of any contanllnants that have been or may be released into the
groundwater. However, in the future, should the groundwater extraction system be
discontinued, an evaluation of the groundwater would be necessary to determine the
landfilJ's impact on the shallow aquifer without the influence of the plant welJs. The
landfilJ does not pose a threat to the public health, welfare, or the environment provided
the plant welJs continue to operate.
~(Y)~.
Patrick M. Tobin
Acting Regional Administrator
/0-/-93
Date
111
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1-
DECISION SUMMARY
1.0 BACKGROUND
1.1 Site Location
The General Tire Landfill is located east of State Highway 45, approximately two
miles north of the town of Mayfield in Graves County Kentucky. Graves County is
located in southwestern Kentucky, in the south-central portion of the Jackson
Purchase region.
The landfill covers an area of
approximately 58.5 acres and is situated
approximately one-third of a mile
northeast of the General Tire
Manufacturing facility. As shown in
Figure 1, the landfill lies between the
Paducah-Louisville Railroad and Mayfield
Creek.
The landfill is bounded by farm land to the
north and southeast; vacant land to the
southwest; the Paducah-Louisville railroad
to the west; and a wooded area to the east,
between the landfill and Mayfield Creek.
The site lies approximately 450 to 500 feet
west of Mayfield Creek (see Figure 2).
1.2 Site Description
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The landfill was active between 1970 and
1984, and was used exclusively by General
Tire's Mayfield facility for disposal of
hazardous and non-hazardous plant
wastes. The wastes were disposed of in a
series of trenches excavated in a north-south orientation, approximately 1,300 feet
long, 40 feet wide and 30 feet deep (see Figure 3 and 4). The wastes included carbon
black, scrap rubber and tires, scrap hydraulic oil, lubricating oil, floor sweepings,
rejected product material, trash, wood, paper packaging, and cements containing
solvents. Table 1 shows the approximate weight percentages of the plant wastes
disposed of in the landfill. Based on historical aerial photographs and interviews
with plant personnel, the trenches were excavated in an orderly fashion from the east
side of the landfill to the west, and therefore, it can be assumed that hazardous waste
Figure 1
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TABLE
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Record of Decision
General Tire Landfill Site
disposal (between 1970 and 1979) probably occurred on the eastern half of the
landfill. However, there is no reason to believe that the wastes in the trenches are
locally homogenous, or that drums would have been buried in specific areas of each
trench.
Based on interviews with plant
personnel who were involved with
landfill operations, it was learned
that the wastes were randomly
deposi ted in the trenches and the
waste materials may not have been
containerized (i.e. drums were not
sealed prior to burial and some
tipped over in the process of
unloading and consolidation).
The landfill surface is generally flat
and graded with an average slope of
less than 3 percent. In accordance
with the final site closure grading
plan, the surface was vegetated with
a fescue-rye-crown vetch mixture.
1.3 Site History and Enforcement Actions
Plant Wastes Placed Into The Landfill
And
Their Appronmate Weight Percentages
Scrap rubber and tires
Trash, wood, and paper packaging
Rejected product material
Scrap hydraulic oil
Non-reclaimable lubricating oil
Waste cement mixtures
Carbon black
Floor sweepings
42.3%
40.8%
14.2%
1.6%
0.85%
0.14%
0.08%
0.05%
Table 1
In 1970, the General Tire Plant received approval from the Commonwealth of
Kentucky for construction and operation of a landfill at the Mayfield site. In 1979,
disposal of hazardous wastes ceased in accordance with the Resource Conservation
and Recovery Act (RCRA). However, the landfill continued to operate until 1984,
disposing only non-hazardous plant wa:5tes pursuant to a permit issued by the
Commonwealth of Kentucky, Department for Environmental Protection (KYDEP).
In accordance with section l03(c) of Comprehensive Environmental Response,
Compensation and Liability Act (CERCL\), General Tire submitted a Notification of
a Hazardous Waste Site on June 2, 1981 to the Environmental Protection Agency
(EPA).
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Record of Decision
General Tire Landfill Site
In late 1980, KYDEP required General Tire to implement a groundwater monitoring
program in the vicinity of the landfill. The program, beginning in 1981, included the
installation of ten monitoring wells (three monitoring well clusters and one shallow
well) surrounding the site. Initially, groundwater samples were analyzed for
numerous parameters, but in 1982, KYDEP agreed to reduce the number of
parameters to a specified list of indicator constituents and to collect samples on an
annual basis. The groundwater monitoring results were submitted annually to
KYDEP from 1983 through 1987.
In September 1984, General Tire submitted to KYDEP a closure plan for the landfill
consisting of a site drawing showing the proposed site contours and a description of
a proposed plan for erosion control. In the fall of 1985, a two foot soil cover was
placed over the landfill and the surface was seeded to prevent erosion. The Kentucky
Division of Waste Management conducted an inspection of the landfill and accepted
the site "as closed" in February 1987. However, in accordance with Kentucky
regulations, the site was subject to a post-closure monitoring period, in which
maintenance of the cover, including erosion prevention, settlement and revegitation,
was to be performed. The post-closure monitoring period ended on February 1989,
but because the site was being investigated by EP A for CERCLA enforcement actions,
final closure of the landfill was never granted by KYDEP.
In March 1989, EPA Region IV initiated negotiations with General Tire (the only
Potentially Responsible Party (PRP) at this site) to conduct a Remedial
InvestigationlFeasibility Study. By February 1990 the site was added to the National
Priorities List (NPL) with a hazard ranking score of 32.94. By December of 1989,
General Tire and EPA entered into an Administrative Order by Consent for
performance of the RIIFS. On October 22, 1990, after EPA approval of the Single Site
Plan (Work Plan), the RI/FS commenced. Table 2 summarizes some of the major
events in the landfill's history.
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TABLE 2
SUMMARY OF ENFORCEMENT HISTORY
GENERAL TIRE
MAYFIELD, KENTUCKY
1970
General Tire received approval from the Commonwealth of Kentucky for
construction and operation of the landfill at the Mayfield, Kentucky Plant.
1979
Disposal of RCRA-defined hazardous wastes ceased. KYDEP issued a
Waste Management Permit (No. 042.05) to General Tire for non-hazardous
solid waste disposal at the site.
1981
In compliance with CERCLA Section 103(c), General Tire provided EPA
with a Notification of Hazardous Waste Site.
A groundwater monitoring program was implemented at the site which
included the instalJation of ten monitoring welJs around the perimeter of
the landfill and analysis of groundwater and surface water samples.
1982
KYDEP authorized annual sampling of the monitoring wells for a limited
number of indicator parameters. This groundwater data was collected to
assure continued compliance with state environmental performance
standards and for the permit renewal application.
1984
Waste disposal ceased; the landfill was subsequently covered with two feet
of clean soil and seeded.
1987
Closure of the landfill was approved by KYDEP. A two-year post closure
monitoring period went into effect until February 9. 1989.
June 1988
EPA proposed that the landfill be placed on the National Priorities List
(NPL) as a Superfund site.
March 1989
General Tire received a "Notice of Potential LIability" in a letter from the
EPA
September 1989
General Tire submitted the Single Site Plan (Work Plan) for the RI/FS to
EPA for review.
December 1989
General Tire and EPA entered into the Administrative Order by Consent for
General Tire to conduct the RIfFS.
September 1990
EPA granted approval of the Single Site Plan.
October 1990
The remedial investigation portion of the RI/FS commenced.
July 1993
The RI/FS is completed.
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Record of Decision
General Tire Landfill Site
2.0 COMMUNITY PARTICIPATION
In accordance with the requirements ofCERCLA ~113(k)(2)(B) and ~117, a
Community Relations Plan (CRP) was developed to establish a framework for
community relations activities at the General Tire Site. The CRP was finalized on
April 30, 1990, and implemented throughout the Remedial Investigation and
Feasibility Study (RIfFS).
The CRP contains information gathered from community interviews conducted by
EPA in February 1990. Some of the information included in the document
concems community knowledge of the site, perceptions of the site, and other
issues and concerns related to the site.
Prior to the start of the remedial investigation, in April 1990, EPA issued a Fact
Sheet describing the Superfund process and the planned RIfFS activities. The fact
sheet also provided the opportunity for the public to participate in the Superfund
process, and provided the opportunity for community groups to receive Technical
Assistance Grants (TAG) to closely monitor the technical progress of the
investigation. The fact sheet was sent to the local community, and to local, State,
and Federal officials. EPA also established and maintained an information
repository and Administrative Record (AR) at a convenient and accessible location
in Mayfield, Kentucky. The AR includes all documents and information EPA used
as a basis for developing the proposed final action.
On May 15, 1993 EPA held an informal public information meeting in Mayfield to
answer questions about the RIfFS being conducted. A few interested citizens
attended.
Although EPA provided many opportunities for community participation and
involvement, public interest throughout the investigation was minimal. In
addition to EPA community relations efforts, several local newspaper articles were
published about the site, but little or no inquiries were made by the public.
In July 1993, EPA issued a Proposed Plan Fact Sheet to present the results of the
RI/FS and Baseline Risk Assessment. It also described EPA's proposed final
action for the site and announced the public comment period. The Fact Sheet was
sent to the local community, and to local, State, and Federal officials. The public
comment period began on July 15, 1993 and ended on August 13, 1993.
8
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Record of Decision
General Tire Landfill Site
On July 29, 1993, EPA conducted a public meeting to present the findings of the
remedial investigation; describe the proposed final action; and answer questions
concerning the site. Those in attendance at the meeting included: a reporter from
The Mayfield Messenger newspaper; a reporter from a local radio station;
representatives from General Tire; officials from the City of Mayfield; and
representatives from the Commonwealth of Kentucky, Division of Waste
Management. No concerned citizens attended the meeting. A transcript of the
meeting is included in Appendix A.
3.0 SITE CHARACTERISTICS
3.1 Hydrogeologic Characteristics
The hydrogeologic characteristics of the site were very important in determining
that no further actions are needed at the General Tire site. The specific
hydrogeologic characteristics of this site are important because exposure to
contaminated groundwater is the primary mechanism (i.e exposure pathwaylby
which the site threatens the health and welfare of the public and the environment.
Special hydraulic conditions beneath the site are being created by the six plant
wells operated by General Tire. The following sub-sections summarize some of the
results and conclusions of the hydrogeologic study performed.
3.1.1 Hydrogeologic Setting
Groundwater occurs primarily within two units beneath the General Tire
Landfill site. The shallower unit is an unconfined water table aquifer
within the Sparta Sand and partially extending into the overlying alluvial
gravel deposits. The deeper unit is a semi-confined aquifer within the
deeper Tallahatta Formation. These two aquifers are separated by the
basal silty clay unit of the Sparta Sand, which acts as a semi-confining
layer. The Tallahatta Formation is also confined beneath by the
predominantly silty clay Wilcox Formation. Deeper water-bearing units
at the site have little relevance to the site because they are hydraulically
separated from the upper water-bearing units (the Sparta and Tallahatta
aquifers) by the Wilcox Formation and the underlying Porter Creek Clay.
Monitoring wells were installed in the Sparta and Tallahatta aquifers at
various depths and locations around the landfill to collect groundwater
samples and define groundwater potentiometric levels. In addition, water
table piezometers were installed near Mayfield Creek, and staff gauges
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Record of Decision
General Tire Landfill Site
were installed in Mayfield Creek and Key Creek, to further define the
elevation of the water table surface.
Groundwater flow in both aquifers in the vicinity of the landfill converges
toward the six plant water supply wells, which have an average combined
pumping rate of approximately 10 million gallons of water per day. The
first two plant extraction wells were placed in operation in 1959 and the
remaining plant wells were in operation prior to 1970, with the exception
of plant well No.6 which began operating in 1972. Groundwater in the
Sparta and Tallahatta units has therefore flowed towards the plant wells
and away from Mayfield and Key Creeks long before landfilling
operations began.
3.1.2 The Effect of the Plant Wells
The groundwater potentiometric surface maps developed for the site show
that the influence of a cone of depression associated with these pumping
wells extends under and beyond the landfill in both aquifers (see Figure
5). The results of the study also indicate that water in Mayfield Creek is
at a higher elevation than groundwater in the Sparta aquifer, and
therefore, appears to be recharging the aquifer. Elevation data for Key
Creek suggest the same recharge condition. Near the landfill, water from
the creeks recharge the Sparta aquifer, along with direct infiltration of
precipitation. Beneath the landfili, the flow direction is west to
southwest.
The groundwater elevation data also show that throughout the
investigation area, water level elevations in the Sparta aquifer are higher
than those at the same locations in the Tallahatta aquifer. These data
demonstrate that a vertical hydraulic gradient exists across the confining
unit between the Sparta and Tallahatta aquifers. This vertical hydraulic
gradient influences groundwater flow by introducing a downward
component of flow from the Sparta aquifer to the Tallahatta aquifer.
Regionally, groundwater in the Sparta and Tallahatta aquifers generally
flows toward and discharges to surface streams. If pumping of the plant
wells ceased, groundwater beneath the landfill would be expected to
reverse its current flow direction, and upon reaching steady state,
groundwater would probably flow from west to east, discharging into
Mayfield Creek. Discharge to Key Creek may also exert some influence
on the flow direction under the no-pumping condition.
10
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~ U.S. EPA, Region IV
, , ,
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Record of Decision
General Tire Landfill Site
In JW1e and July 1991, four of the six plant wells were shut off for six
days for pump maintenance (the pumping wells were rotated during this
period). The average pumping rate during this period was approximately
600,000 gallons per day. To determine the effect of reduced pumping,
water level elevations were collected on July 5, 1991, the sixth day of
pump shutdown. Groundwater potentiometric surface maps for this day
for the Sparta and Tallahatta aquifers show that water levels rose 2 to 3
feet, and that the direction of groundwater flow had shifted from
generally southwestward to westward.
3.1.3 Hydrogeologic Conclusions
The hydrogeologic investigation revealed that the General Tire plant
wells have a significant effect on the direction of groundwater flow
beneath the landfill and in the vicinity of the site. These plant wells,
pumping at a combined rate of approximately 10 million gallons per day,
have reversed the natural flow of the groundwater and are capturing any
contaminants that may be released from the landfill. While the natural
groundwater flow is towards Mayfield Creek, the current groundwater
flow direction is towards the six plant wells located around the perimeter
of the General Tire facility. The landfill is entirely within the zone of
capture in both the shallow (Sparta) and deep (Tallahatta) aquifer. East
and south of the landfill the zone of capture of the Sparta aquifer
probably coincides with Mayfield and Key Creeks, both of which are
recharging the aquifer under current pumping conditions. The zone of
capture may extend beyond these streams in the Tallahatta aquifer,
which is not directly connected to these recharge sources. No water
elevation data are available west of the plant pumping wells. However,
based on the natural (prepumping conditions) direction of groundwater
flow, which was generally from west to east in this area, the zone of
capture is expected to extend radially around the plant pump field in both
aquifers.
Operation of the plant wells has significantly limited the migration and
potential human and environmental exposure to any contaminants that
may have been released into the groundwater from the landfill. Since
migration of contaminants through the groundwater is the primary
mechanism by which the landfill can impact human health or the
environment, the EPA believes that the plant wells are providing a
significant level of protection by capturing those contaminants released
12
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Record of Decision
General Tire Landfil1 Site
into the groundwater. There are no private or public water supply wells
within close proximity to the landfill which may be adversely impacted
under the current hydrogeologic conditions. Therefore, it can be
concluded that the landfill does not pose a threat to human health or the
environment provided the plant wells continue to operate. There is
currently no way to detennine whether future groundwater risks would
be significant as long as the plant wells are operating. Consequently, an
evaluation of the groundwater would be necessary in the future to
determine the landfill's impact on the shallow aquifer without the
influence of these wells.
3.2 Remedial Investigation Summary
The remedial investigation has demonstrated that the primary chemical
constituents which have been released from the landfill are low concentrations of
volatile organic compounds in groundwater. These compounds (or their
precursors) were contained in the 305,000 pounds of waste cement mixtures placed
into the site from 1970 to 1979. However, the waste cement mixtures comprise
only 0.14 percent of the total estimated weight of 221,705,000 pounds of total
waste material disposed (see Table 1 on page 4).
The location and extent of wastes within the landfill was defined during the
remedial investigation by non-intrusive methods (no confirmatory chemical
analyses were performed). This was accomplished utilizing existing records, aerial
photograph interpretation, and a surface geophysical survey. An evaluation of the
aerial photographs indicated that the trenches were first excavated on the eastern
portion of the landfill when the landfill began operation in the early 1970s, and
were constructed sequentially to the west until operations ceased in 1984. All of
the aerial photographs indicate that the trenching occurred within the boundaries
of the landfill. The results of the surface geophysical survey confirmed this
conclusion.
The following environmental media were sampled and analyzed as part of the
remedial investigation:
.
Air (Organic Vapor Analyzer (OVA) measurements)
Surface soils
Surface water (Mayfield Creek and site ditches)
Sediment (Mayfield Creek and site ditches)
Groundwater in the Sparta (shallow) water-bearing unit
Groundwater in the Tallahatta (deeper) water-bearing unit
.
.
.
.
.
13
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Record of Decision
General Tire Landfill Site
The following sub-sections summarize the findings of each of the media sampled.
Table 3 shows the constituents of interest found in each site media.
3.2.1 Air Quality
An air quality survey was conducted on and in the vicinity of the landfill
to determine the presence of volatile organic emissions from the landfill
and to determine the effectiveness of the soil cover. Approximately three
hundred and eighty (380) OVA measurements were obtained at the site.
All readings were obtained from a height of approximately one (1) foot
above ground level. Forty two (42) locations with detectable levels of
volatile organic compound (VOC) concentrations were detected above
background concentrations, and only five (5) locations were equal to or
greater than 5 ppm (based on a methane (100 ppm) calibration of the
OVA).
3.2.2 Surface Soil
Ten surficial soil samples were collected from the landfill cover and from
adjacent farm fields to the north, south and west. Based on the
analytical results and screening and evaluation procedures in the
Baseline Risk Assessment (BRA), four constituents of interest were
determined to be present in the surface soil. These compounds are: 2-
chlorophenol, p-chloro-m-cresol, phenol, and benzene. Minimal amounts
of three acid extractable compounds (2-chlorophenol, p-chloro-m-cresol,
and benzene) were detected in surficial soils atop the landfill, but were
determined to be most likely attributed to fugitive emissions from an
adjacent creosote facility. Nonetheless, these constituents were retained
as constituents of interest in surficial soils for evaluation in the BRA.
Minimal amounts of three volatile organic compounds (benzene, 1,2-
dichlorobenzene, and l,4-dichlorobenzene) were detected in surficial soils
in the field north of the landfill, but were also determined to be most
likely associated with farming operations conducted in that field.
Benzene, however, was retained and evaluated as a constituent of
interest in surficial soils since it is a compound known to be present in
the landfill waste.
The concentrations of inorganics were well within or below the typical
background concentration ranges for native soils.
14
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Record of Decision
General Tire Landfill Site
3.2.3 Surface Water
Surface water samples were collected from ditches surrounding the
landfill and from Mayfield and Key Creeks. Results of the analyses
indicate that lead and zinc are constituents of interest present in water in
the ditches surrounding the site. Several other inorganics were detected
in surface water from Mayfield Creek and have been identified as
potential constituents of interest only because there was no background
data with which to compare them. These compounds include: aluminum,
antimony, cadmium, chromium, iron, manganese, and nickel. A low
concentration of l,l,l-trichloroethane (TCA) was detected in Mayfield and
Key Creeks, but was discovered to be coming from a source up-gradient of
the landfill.
3.2.4 Sediment
Sediment samples were collected from ditches surrounding the site and
from Mayfield and Key Creeks. Analyses of the sediment samples
revealed that lead, barium, and zinc were constituents of interest. Other
inorganic constituents of interest detected in the sediments include:
aluminum, arsenic, calcium, chromium, copper, iron, magnesium,
manganese, and vanadium. Benzene, found in one sample at a low
concentration, is the only organic constituent of interest.
3.2.5 Groundwater: Sparta Water-bearing Unit
Groundwater samples were collected from fifteen (15) monitoring wells
installed in the Sparta aquifer. Two separate samples were collected
from each well during two separate time periods to determine the
presence of landfill contaminants in the shallow groundwater.
Twelve organic compounds were identified as constituents of interest in
the Sparta water-bearing unit. These compounds include: acetone,
benzene, chloroethane, chlorobenzene, di-n-butyl phthalate, 1,1-
dichloroethane, 1,2-dichloroethane, 1, I-dichloroethene, (cis and trans)1,2-
dichloroethene, di-n-octyl phthalate, TCA, and trichloroethene.
The inorganics identified as constituents of interest include: calcium,
copper, iron, magnesium, mercury, potassium, sodium, and thallium.
Elevated concentrations of inorganics in two shallow wells up-gradient
15
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Record of Decision
General Tire Landfil1 Site
and south of the landfill were detected, but were attributed to an
unknown source(s) originating from the direction of Key and Mayfield
Creeks, and are not associated with the landfill.
3.2.6 Groundwater: Tallahatta Water-bearing Unit
Groundwater samples were collected from six (6) monitoring wells
installed in the Tallahatta aquifer, and the six plant wells (also screened
in the Tallahatta). Two separate samples were collected from each well
at different times during the investigation to determine the presence of
landfill contaminants in the groundwater.
The results of the groundwater analyses of the Tallahatta water-bearing
unit indicated that there were six organic constituents of interest. These
compounds include acetone, benzene, 1,1,1 trichloroethane, 1,1
dichloroethane, di-n-octyl phthalate, and di-n-butyl phthalate. The
inorganic constituents of interest include: aluminum, barium, cadmium,
calcium, copper, iron, magnesium, mercury, potassium, sodium, thallium,
and zinc.
A private drinking water well, closest to the landfill, was also sampled at
a residence approximately 0.9 miles north-northwest of the landfill.
Although not known, it is presumed that this well is completed in the
Tallahatta because the majority of the private wells in this area are
completed in this formation. The only contaminant found to be present in
the water was lead (0.0227 ppmL This lead value is considerably higher
than other lead values in the Tallahatta groundwater. However, because
the groundwater in the vicinity of the landfill is flowing toward the plant
wells and not off site, it was determined that the source of the lead is
most likely lead-bearing material in the well, piping, or the holding tank.
The laboratory results were shared \\ith the owner of the well and with
the Graves County Health Department.
16
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Acetone
Aluminum
Antimony
Arsenic
Barium
Benzene
.....
-.:J
Cadmium
Calcium
Chlorobenzene
p-Chloro-m-cresol
Chloroethane
2-Chlorophenol
Chromium (III)
Chromium (IV)
Copper
Di-n-butyl phthalate
l,l-Dichloroethane
l.2-Dichloroethane
1.1-Dichloroethene
cis-l.2-Dich loroethene
-"",
. .. ".
....... ....
. . ...
.'l'.t\aL£ 3
...
. .:::.:~:::"
:QONSTI'l'UENT$.PFmrER~ST IN SitE M~DIA~.'
. ...
..
"0"
.. .
.,'.',.. ','" ....,',,",",,",..,",,",
. . . .... ............
.
......
. . .. . .. . . . . . . .. . .
. . ..
i::::::~im~t:
;:;:\«Jree}t)
. ... .. ..
.. .. ..
'.:$e#im~n~II:
:'::~R"~~::':::::::
. . .. '"
. . . . . . . . . . . . . . . . . . . . . .
:Gr6iliidW~f':!:' i(?:Qr(jiMitw.~~K'::r::
::.'.:::.::::.:.'.~~f.~~:'.::::::!:i::::i .:::::::!ilil~~~~i;~:~illl~:i:i:..
. ........."".....
,",',",". .....',.,",
~ii~I..
}(Pi#~9~)\
.. .. ... ..
. ... ... ...
. ...
(SUffIiC~
:::.:::.::.:W!Yt~
{{?.(q!~e1t)
......
.."...
..",
x
x
X
X
X
X
X
X X
X X X X
X X
X X X X
X
X
x
X X
X X
X X X
X X
X X
X
X
X
-------
. ........ .......... ...,... ..
.........., ..................,. ......., ...........,...
...,.,..'..................'...... ....,.,.....,...," ",.,..,.,
::::::'.,::~a;t:::::::':i .::;.;;:I::.....~~~.:...:.
jl~lj:jl,~.jllll~III.lllllllijll:jlll. .:.:::.::.:.:...(~~~)..:.:..
. ......... ................
,.".....,...,............,.,..
.............. ...,...........
:.~~~~:.
:::~gr~I~..(.....
.'.,..,.'.,'.,.,.','.,.,...'.'......,.,..., ",','"'"'",,,,,,',',',,""""'''''...,'.,.,.'..
.,.i::.:,:,$ltffilt:ii.'.::ii: .'.:.i::WjrilMi8t::i:,: HHGrCiiffidWater .H
.illllllllfilr11iii1
x
trans-l,2-Dich loroethene
Di-n-octyl phthalate
Iron
x
X
X
X
X
X
X
X
X
Lead
X
Magnesium
Manganese
Mercury
x
x
X
X
X
X
X
~
00
Nickel
Phenol
Zinc
x
X
X X
X X X
X X
X X
X
X
X X X X
4 10 3 12 4 21 18
Potassium
Sodium
Thallium
1, 1,I-Trich loroethane
Trichloroethene
Vanadium
Total
. Summary of constituents in each medium evaluated in the baseline risk assessment.
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Record of Decision
General Tire Landfil1 Site
4.0 SUMMARY OF SITE RISKS
4.1 8ummary of Human Health Risks
Constituents of interest and associated environmental media that were identified
at the site during the RI were evaluated in the Baseline Risk Assessment (BRA) to
estimate levels of potential risk associated with various human exposure
pathways. Both carcinogenic and noncarcinogenic risks under current conditions
and possible future conditions were assessed.
Relevant exposure routes were quantified for site media for the current and future
exposure scenarios. Risk estimates for these routes are organized by site medium
(including Mayfield Creek water, Mayfield Creek sediment, site ditch surface
water, site ditch sediment, and surficial soils atop the landfill at 88-6) and are
summarized in Table 4. Exposure routes quantified for the current and future
scenario included dermal contact with each medium; incidental ingestion of
Mayfield Creek water, site ditch water and sediment, and surficial soils atop the
landfill; and inhalation of airborne constituents from surficial soils atop the
landfill. Populations evaluated for various media exposure routes included
recreational (adults and children), and occupational maintenance workers.
As shown in Table 4, potential carcinogenic risks were estimated to range from
2.7 x 10.9 for incidental ingestion of site ditch sediment by recreational children to
1.0 x 10.7 for dermal contact with site ditch sediment by recreational adults. All of
the individual carcinogenic risk estimates for these current and future potential
exposures were well below the lower limit of the acceptable carcinogenic risk
range of 10-6 to 10-4.
The estimated potential noncarcinogenic hazard indices for individual pathways
under the current exposure scenarios were estimated to range from
1.6 x 10-6 (incidental ingestion of surficial soils atop the landfill (88-6) by
occupational maintenance workers) to 2.1 x 10-2 (dermal contact with Mayfield
Creek water for recreational children). All of the total noncarcinogenic hazard
indices for current individual pathways were below the acceptable limit of 1.0.
Two future scenarios were considered for the site in addition to the baseline
scenario: (1) future site development with the cessation of pumping from the
General Tire plant wells, and (2) future site development in conjunction with the
continued operation of the General Tire plant wells. Under the baseline future
scenario, it was assumed that any current activities and use scenarios are also
relevant in the future. It was also conservatively assumed that concentrations in
site media will remain constant in the future.
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Record of Decision
General Tire Landfill Site
As mentioned in the previous section, groundwater in both the Sparta and
Tallahatta water-bearing units in the vicinity of the landfill currently flows toward
the General Tire facility because of the influence of the plant water wells. The
cone of depression associated with these wells extends under and beyond the
landfill in both the Sparta and Tallahatta water-bearing units. The landfill is
entirely within the zone of capture of the plant wells. Beneath the landfill, the
direction of groundwater flow is generally towards the west. If the first future
scenario were to occur (i.e., the General Tire plant wells ceased pumping)
groundwater flow direction beneath the landfill would begin to reverse, and upon
reaching steady state, groundwater would probably flow from west to
eastJnortheast and discharge to Mayfield Creek and would probably not reach the
closest municipal water supply wells at the Hickory and Hardeman districts,
located 1.8 and 2.7 miles from the site, respectively. With the cessation of
pumping of the plant wells, the vertical groundwater gradient from the Sparta
aquifer to the Tallahatta aquifer would be expected to be negligible, and therefore,
would substantially reduce the transport of constituents between the two aquifers.
In addition, lateral groundwater flow velocity (without the influence of the plant
wells) would be dramatically reduced thereby decreasing the rate of lateral
transport of constituents of interest. Constituents potentially present in
groundwater in the Tallahatta unit moving laterally from the site (which would
not discharge to the creeks) would be expected to decrease through attenuation.
Because the cessation of pumping of the plant wells would decrease the
groundwater flow and thus constituent transport, this future scenario is not
considered a worst-case scenario.
Conversely, the future scenario which considered nearby site development in
conjunction with the continued operation of the General Tire plant wells is the
worst-case scenario because of the significant vertical gradient induced between
the Sparta and Tallahatta units, and the subsequent transport of constituents
from the upper to the lower unit. Therefore, this potential future scenario was
considered the worst-case, and intakes and risks associated with this scenario
were quantified.
Site development was assumed to involve the construction of residential housing
in the vicinity of the site, not on the site. Residential development would not
reasonably be expected to occur within the limits of the landfill because of deed
restrictions already in place. Therefore, the future scenario involving the
continued operation of the plant wells will consider residential development north
of the landfill.
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Record of Decision
General Tire Landfill Site
Risk estimates for individual future exposure routes were quantified under the
potential future site development scenario and are summarized in Table 5 by
relevant medium: 8parta groundwater, Tallahatta groundwater, and surficial soils
north of the landfill (at 88-3). Exposure routes quantified for the future site
development scenario included dermal contact with each media, ingestion of
groundwater, incidental ingestion of surficial soils in the field north of the landfill,
inhalation of volatiles from groundwater, and inhalation of airborne constituents
from surficial soils in the field north of the landfill. Populations evaluated for
various media and exposure routes included residential adults, residential
children, occupational adults, including construction workers.
As shown in Table 5, potential carcinogenic risks were estimated to range from
8.4 x 10-11 (potential ingestion of surficial soils in the field north of the landfill
(88-3) by construction workers) to 4.1 x 10-5 (potential ingestion of 8parta
groundwater by residential adults)o The carcinogenic risk estimates for the
potential exposure of both adult and children residential populations to
constituents present in 8parta groundwater were primarily attributed to the
presence of 1,1-dichloroethene and benzene. The carcinogenic risk estimate for
potential exposure through dermal contact with surficial soils in the field north of
the landfill by the adult residential population (the only pathway addressing
exposure at 88-3 which exceeded the lower limit of the acceptable carcinogenic
risk range of 10-6) was attributed to the presence of benzene. All of the individual
potential carcinogenic risk estimates for future populations were within the
acceptable range of 10-6 to 10040
The estimated potential noncarcinogenic hazard indices for future site
development individual pathways were estimated to range from 709 x 1006
(inhalation of volatiles from Tallahatta groundwater by residential adults) to
5.1 x 10-1 (potential ingestion of Tallahatta groundwater by residential adults). All
of the total noncarcinogenic hazard indices for future individual pathways were
below the limit of 1.0.
The individual (i.e. single pathway) estimates of potential risk for current and
future receptors were combined, where appropriate, to represent the reasonable
maximum exposure (RME) expected for populations with the potential to be
exposed to site constituents by more than one exposure route. For all populations
and exposure routes potentially associated with the current scenario, combined
carcinogenic risk estimates ranged from 7.9 x 10-8 (recreational adult exposure to
Mayfield Creek media) to 1.7 x 10-7 (recreational children exposure to the site
ditches). Combined noncarcinogenic hazard indices for the current populations
ranged from 1.0 x 10.4 (maintenance worker exposure to surficial soil at 88-6) to
21
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Record of Decision
General Tire Landfil1 Site
4.5 X 10.2 (recreational children exposure to Mayfield Creek media). These ranges
of potential carcinogenic risks are well below the lower acceptable limit of 10-6,
and below the hazard index level of 1.0 for noncarcinogens.
In order to combine populations to evaluate multiple exposures under the future
site development scenario, a "worst case" and "best case" approach was determined
to be most representative. Potential exposures associated with site media which
were considered to be 'landfill-influenced" (i.e. water and sediment from the site
ditches, groundwater in the 8parta unit, and surficial soils from sample location
88-6) were combined to estimate a "worst case" estimate of potential future risks
for recreationaVresidential populations and the occupational maintenance worker
population; site media not believed to be landfill-influenced (i.e., water and
sediment from Mayfield Creek, groundwater from the Tallahatta unit, and
surficial soils north of the landfill at sample location 88-3) were combined to
estimate a "best case" for potential future recreationaVresidential populations and
occupational populations.
Combined potential carcinogenic'risk estimates for the potential future site
development scenario ranged from 3.7 x 10>8 (occupational construction worker
exposure to surficial soils at 88-3) to 6.6 x 10>5 (recreational/residential adult
exposure to landfill-influenced media). Noncarcinogenic hazard index estimates
ranged from 1.0 x 10-4 (maintenance worker exposure to surficial soil at 88-6) to
5.7 X 10'\ (recreationaVresidential children exposure to non-landfill-influenced
media).
All of the combined noncarcinogenic hazard indices for potential future
populations (assuming residential site development) were below the hazard index
value of 1.0. The highest carcinogenic risk estimate total for future populations
(6.6 x 10>5) was within the acceptable range of 10-6 to 10-4.
U sing the information presented in the BRA, risk-based concentrations of the
constituents of interest in site media were calculated which correspond to risk
levels of 10-4, 10-5, and 10.6 for potential carcinogens, and hazard indices of 1.0 and
10 for non-carcinogens. These risk-based concentrations were presented as
preliminary remediation goals (PRGS) in the BRA.
No PRGs were exceeded under current and future no action scenarios. There were
three cases where the level of a constituent used in the estimation of risk (i.e.
either a measured level such as at SS-3 or a calculated 95 percent upper
confidence limit for other media) exceeded the risk-based PRG. For the ingestion
of Sparta groundwater exposure route under the future site development scenario,
22
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Record of Decision
General Tire Landfill Site
the measured concentration of benzene (0.0096 mg/L) exceeded the 10.6
carcinogenic risk-based PRG for benzene (0.0029 mg/L), and the 1,1-dichloroethene
concentration (0.0053 mg:/L) exceeded the 1005 and 1006 risk-based PRGs (0.0014
mg/L and 0.00014 mg/L, respectively). For the dermal contact with surficial soils
exposure route (north of the site at SS-3), the measured concentration of benzene
(0.4 mglkg) just slightly exceeded the 1006 carcinogenic risk-based PRG (0.32
mg/kg).
4.2 Summary of the Ecological Assessment
Potential exposures to biota from constituents present at the General Tire site
were qualitatively evaluated in the BRA. In soils, potential biota exposures would
be expected to be restricted to primarily terrestrial animals and avian (bird)
species. However, as the surficial soils were not considered to have elevated levels
of constituents attributable to the landfill, surficial soils at the General Tire site
are not reasonably expected to present risks to either avian or terrestrial species.
Furthermore, there have been no signs of stressed vegetation within the vicinity of
the site and there have been no reports of visible adverse impacts to animal
speCIes.
As concluded in the BRA, the landfill is not thought to impact any.possible
wetlands during flooding events. Several "wetland" areas were identified within a
one-mile radius of the site on the National Wetland Inventory Maps, although
they do not represent field-verified wetlands for this area. In addition, the
operation of the plant process water supply wells effectively prevent the potential
for groundwater discharge to wetlands in the vicinity of the site.
A bioassessment survey was completed per the EPA's Rapid Bioassessment
procedures, in June 1991. Results of the survey indicated that both upstream and
downstream stations on Mayfield Creek had experienced adverse impacts to fauna.
However, because the upstream locations were affected, these impacts are not
believed to be related to the landfill.
23
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t\:)
~
TABLE 4
SUMMARY OF POTENTIAL CARCINOGENIC RISKS AND NONCARCINOGENIC
HAZARD INDICES (CURRENT AND FUTURE NO ACTION SCENARIO)"
Recreational Population Recreational Population Occupational Maintenance
Medium/Exposure Route Adult Children Worker Population
CRb HI' CR HI CR m
" . . .. ~ . )i':: ..' .'
... '¥~yfield C~ekWa~r'.
Dermal Contact NAd 3.7 x 10.3 NA 2.1 x 10.2 -- --
Incidental Ingestion -- . -- NA 6.7 x 10-3 --
--
;,>;,',;,:,;,;,:'.' ..... ... .. ... ... . ":.'.: <". H. . . .
... :')dJ~~idG~~k~edirnent .'.''''':.
......- ..
Dermal Contact 7.9 x 10'8 3.0 X 10'3 1.3 X 10,7 1.7 X 10.2 -- --
".:."::' Site Ditch Water
Dermal Contact NA 7.4 x 10,6 NA 4.1 x 10'6 -- --
-
Incidental Ingestion -- -- NA 5.1 x 10'6 -- --
Site Ditch Sediment
Dermal Contact 1.0 x 10' 2.4 X 10,4 1.7 X 10.7 1.4 X 10'3 -- --
Incidental Ingestion -- -- 2.7 X 10-9 2.1 X 10.3 -- --
.
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t\:)
C11
TABLE 5
SUMMARY OF POTENTIAL CARCINOGENIC RISKS AND NONCARCINOGENIC
HAZARD INDICES (FUTURE SITE DEVELOPMENT SCENARIO)8,b
Residential Population Residential Population Occupational Population Occupational Construction
Medium/Exposure Route Adult Children Adult Worker Population
CRt Hid CR HI CR HI CR HI
."", "".:~ Groundwater ',~ S~rta Unit "0,
. '" ,'." '
Dermal Contact 2.3 x 10'6 4.9 X 10,2 1.5 X 10.6 6.1 X 10.2 -- e -- -- --
Ingestion 4.1 x 10,6 5.0 X 10'1 2.1 X 10.6 4.7 X 10,1 -- -- -- --
Inhalation of Volatiles 2.0 x 10-6 2.8 X 10. 2.0 X 10.6 5.6 X 10'. -- -- -. --
--. Groundwater~ Tal1ahatta Unit
Dermal Contact 4,1> x 10,7 3.4 x 10 ~ 3.1 X 10,7 4.2 X 10'2 2.8 X 10,7 2.5 X 10.2 -- --
Ingestion 1.4 x 10.7 5.1 X 10'1 7.0 X 10'8 4.8 X 10,1 -- -- -- --
Inhalation of Volatiles 3.:') x 10'9 7.9 X lOG 3.5 X 10,9 1.5 X 10.5 -- -- -- --
Surficial Soils (S8-3 location, North of the Landfill)
Dermal Contact 1.2 x 10-6 NA1 9.3 X 10,7 NA -- -- 5.2 X 10,9 NA
Incidental Ingestion 6.7 x 10.9 NA 1.4 x 10'8 NA -- -- 8.4 X 10.11 NA
Inhalation of Airborne 4.1 x 10,7 NA 4.1 x 10.7 NA -- -. 3.2 X 10-8 NA
Constituents
. Future site development assumes tllat the area north of the landfill wuuld be developed into a residential area, and domestic wells placed in the Sparta unit could be used as the drinking
water supp,ly source; General Tire facility would continue to operate. Only the.additional routes evaluated under the future site development scenario are presented in this table.
~ Values represent the worst case risk estimates for the specified medium, fur the additional future populations (only) as presented in Tables A7.17 through A7-20 of the Baseline Risk
Assessment.
C Carcinogenic Risk
d Hazard Index
. -- (Dash) indicates pathway not quantified because it is not a rea80nable exposure pathway for the particular population.
, NA indicates that no constituenls were detecled in specified medium; tuxicily faclors not available; or no constituents exhibit that type of toxic effect.
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Record of Decision
General Tire Landfill Site
5.0 SCOPE AND ROLE OF THIS RESPONSE ACTION
EP A has determined that no further action is necessary W provide additional
protection to human health and welfare, or the environment. The results of the
RI and BRA indicates that there are no current or future risk from exposure w
soils, sediment, surface water, or groundwater, although the groundwater is a
possible future threat should the plant wells be shut down. However, there is
currently no feasible way w determine whether future groundwater risks would be
a significant threat to human health or the environment, as long as the plant
wells are operating. Consequently, an evaluation of the groundwater would be
necessary in the future w determine the landfill's impact on the shallow aquifer
without the influence of the plant wells.
Due to the uncertainty about the future of groundwater quality at the site without
the influence of the plant wells, ongoing groundwater monitoring is recommended
to detect potential migration of any contaminants. General Tire has provided a
commitment to the Commonwealth of Kentucky w perform operation and
maintenance activities at the landfill and implement a groundwater moniwring
plan. EPA cannot make a recommendation at this time for a remedy to mitigate
possible future groundwater conditions without supporting data to indicate that a
remedial action is necessary. However, in the event any ongoing groundwater
monitoring indicates the presence of a significant release at a level that poses an
unacceptable risk to human health and the environment, the site shall be restored
to the NPL without application of the HRS (40 CFR ~300.425(eX3». EPA could
initiate clean-up actions (i.e. conducting a groundwater investigation and
feasibility study, and/or performing an emergency response action) in the future
pursuant to CERCLA and in accordance with the National Oil and Hazardous
Substances Pollution Contingency Plan.
This Record of Decision presents the selected remedial action for the General Tire
Landfill Superfund Site. The selected remedial action was chosen based on the
results of Remedial Investigation and Baseline Risk Assessment and all other
documents and information contained in the Administrative Record. EPA makes
this determination pursuant to the requirements of CERCLA, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and w the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan.
EP A has determined that its response at this site is complete. Therefore, the site
now qualifies for inclusion on the Construction Completion List.
26
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Record of Decision
General Tire Landfill Site
RESPONSIVENESS SUMMARY
The public comment period was established from July 15, 1993 to August 13,
1993. No comments by the public were received by EPA on the recommended
proposed plan for the General Tire site.
As mentioned previously, EPA conducted a public meeting on July 29, 1993, to
present the findings of the remedial investigation; describe the proposed final
action; and answer questions regarding the site. No concerned citizens attended
the meeting. A transcript of the meeting is included in Appendix A.
Additionally, comments submitted to EP A by the Commonwealth of Kentucky
concerning the proposed plan is included for reference in this document, in
Appendix B. EPA's response to these comments are also included.
27
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GENERAL TIRE LANDFILL
SUPERFUND SITE
RECORD OF DECISION
APPENDIX A
PROPOSED PLAN PUBLIC MEETING
TRANSCRIPTS
-------
1
1
2
3
I~r;:: ~\,\r;
4
GENERAL TIRE LANDFILL
5
SUPERFUND SITE
6
7
8
9
10
PROPOSED PLAN PUBLIC MEETING
11
JULY 29, 1993
12
13
GRAVES COUNTY HIGH SCHOOL
14
HIGHWAY 121
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MAYFIELD, KENTUCKY
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REPORTED BY:
ELIZABETH MILLER, RPR-CM
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WEST KENTUCKY REPORTING SERVICE
P.O. Box 1583
Paducah, Kentucky 42002-1583
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PHONE:
FAX:
(502) 554-9205
(502) 554-2755
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APPEARING ON BEHALF OF THE
U.S. ENVIRONMENTAL PROTECTION AGENCY,
REGION IV:
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MR. HAROLD W. TAYLOR, JR.
Chief, Kentucky/Tennessee Remedial
North Superfund Remedial Branch
Waste Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
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MR. NESTOR YOUNG
Remedial Project Manager
North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
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MS. SUSAN H. MUNGER
Assistant Regional Counsel
Office of Regional Counsel
345 Courtland Street, N.E.
Atlanta, GA 30365
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Section
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(The hearing commenced at 7:10 p.m.)
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I'd like to welcome everybody
MR. TAYLOR:
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tonight.
My name is Harold Taylor, and I'm an
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employee of the United States Environmental
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Protection Agency.
My office is in Atlanta, Georgia,
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and I work for Region IV of the Environmental
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Protection Agency.
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We have ten regions scattered throughout the
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United States.
Region IV, we work the eight
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southeastern states:
Alabama, Georgia, Mississippi,
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Florida, Kentucky, Tennessee, North Carolina, and
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South Carolina.
I work in the Superfund Remedial
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We basically work on the 20 National
Program.
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Priority List sites in the Commonwealth of Kentucky.
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First of all, I'd like to thank everybody for
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coming tonight.
I know it takes a lot out of your
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time to come to meetings like this.
We appreciate
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you showing up.
For those of you who haven't been to
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the school before, the restrooms are to your right.
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The ladies' is over here.
The men's is toward the
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front.
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We're going to try to run through a brief
presentation and get to the question and answer
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period here tonight.
If I could, I'd like to ask you
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to hold your questions until the end of our
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presentation, and we'll stay here until we've
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answered all your questions.
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I'd like to introduce a few people.
We have a
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few elected officials here tonight.
We have the
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mayor, Arthur Byrn.
Graves County Judge
Arthur?
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Executive Tony Smith back there.
Appreciate you guys
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coming.
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If I can, I'll introduce the people that are
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here from Atlanta tonight first.
Nestor Young.
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Nestor is the Remedial Project Manager assigned to
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this site from Region IV.
He's basically responsible
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for the day-to-day activities of the site for the
Environmental Protection Agency.
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Over again to Nester's left is Sue Munger.
Sue
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is an attorney.
She works for the Office of Regional
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Counsel for the Environmental Protection Agency in
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Region IV.
And she's the attorney assigned to this
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site.
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We have a number of State people here.
I'll try
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to remember their names.
We have Larry
Rick Hogan.
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Moscoe with the Commonwealth of Kentucky Department
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of Law, Eric Liebenauer, and William Keel, all with
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the Commonwealth Superfund program, basically our
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I hope all of you signed in.
If you
counterparts.
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didn't, please sign in up front before you leave and
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take advantage of the handouts that we have up
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front.
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I'd like to remind everybody that this is not a
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formal hearing like a lot of meetings, perhaps, that
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This is basically a public meeting where
you go to.
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we're just going to present information to you, try
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and answer any questions that you may have.
And so
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we will answer your questions, not like a hearing
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where you just present comments.
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Again, tonight, we're going to basically go over
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-- I'm going to basically go over the Superfund
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Mr. Young is going to go over the site
process.
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background and remedial investigation that was done
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at the site.
He'll also go over EPA's recommendations
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for the General Tire site.
And Sue Munger will go
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over the enforcement activities for the site.
I will
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go over the community relations, and then we'll have
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the question and answer period at the end.
We do have a court reporter here to keep a
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record tonight of your comments, Elizabeth Miller.
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She'll do a good job, I'm sure, of getting a record
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so that we can formally respond to any concerns of
yours that we don't respond to sufficiently tonight.
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When we do get to the question and answer
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period, I'll ask that you state your name, and if you
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have a name that's difficult to spell, I ask that you
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spell your name so the court reporter can get it.
Again, we're going to try to run through this quick,
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since it is a fairly small crowd, and we'll try not
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to take a full hour.
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Real quickly, to go over what Superfund is and
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how it's funded, in 1980, Congress passed what's
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called the Comprehensive Environmental Response
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Compensation and Liability Act.
CERCLA is the
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People commonly refer to it as Superfund
acronym.
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because it's such a long name.
It gives basically
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the Environmental Protection Agency a broad range of
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response authorities to respond to what generally
people refer to as uncontrolled waste sites.
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All the money that's in the Fund is generated
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from taxes on the chemical and petroleum industry,
and together with what's called the Resource
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Conservation and Recovery Act, it gives EPA a pretty
broad range of control over disposal and handling of
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hazardous waste.
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The Trust Fund was authorized originally in 1980
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at 1.6 billion.
'86 amendments authorized the Fund
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And then in 1990, it was authorized with an
to 8.6.
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additional 5.1 billion dollars, current funding of
which lasts until 1994, at which time Congress will
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have to either reauthorize the Fund or, basically,
the Superfund will expire as we know it today.
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The two broad ranges of response authority that
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we have of the Superfund are the removal authority.
This is basically, classically, what people refer to
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as your emergency spills, your midnight dumps.
Somebody has taken waste and put it down on the
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surface of the ground somewhere, and people who corne
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in contact with it will be harmed.
We have the
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authority to go out and basically take action to
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either compel people to do that or spend Fund money
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to do it yourself.
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The second is remedial action, and that's
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generally more of a long-term problem of groundwater
problem, a landfill, something that's not easily
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addressed that generally will take years to address
properly and study properly, and it doesn't pose at
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least an immediate health threat.
And that's what
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the program that we're here really to discuss with
you tonight is what EPA's been working on with the
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General Tire site.
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Again, just to briefly go over the Superfund
remedial process, obviously, sites have to be
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discovered.
Typically, they're sites reported by the
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public to state agencies.
In most states, including
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the Commonwealth, the EPA has a grant to do
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preliminary assessments and site investigations.
And
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generally, after that, if the site so warrants, there
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will be a draft Hazardous Ranking Score and on to the
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NPL if a site scores high enough.
The next step -- this chart over here might help
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a little bit.
The next step after sites are put on
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the NPL is remedial investigation.
It's basically a
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study of pathways of exposures.
Typically, remedial
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investigations take two to three years to complete.
Enforcement actions can be taken basically at any
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time if there's an immediate threat that's posed.
And public involvement basically continues throughout
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the whole process.
After the remedial investigation,
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there's a Record of Decision, and ultimately, if so
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warranted, remedial design and remedial action.
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Again, just to go over site discovery,
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basically, anyone can discover sites.
I believe the
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General Tire site, if memory serves me, was --
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Companies that disposed of hazardous waste were
required originally when the Superfund was authorized
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to notify the Agency that there might be a potential
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of disposal.
I believe that was how that site came
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to the attention of the Agency.
And again, once the
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site is discovered, a preliminary assessment and site
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investigation is done, either by the EPA or the
State, to see if it warrants further study.
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A lot of people ask why an NPL and why an HRS.
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And basically, Congress required an HRS system
because of the vast multitude of sites and basically
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recognized there wasn't enough money to address all
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of the sites at one time.
So a Hazardous Ranking
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System was developed to prioritize the sites.
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The Hazardous Ranking System basically ranks
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sites according to potential risk.
Sites are scored
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anywhere from a zero to one hundred points based upon
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three factors:
contaminants released into the
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environment,
concentration of toxicity and quantity
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of the waste on-site, and people and sensitive
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environments affected.
Right now, sites that score
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above 28.5 are added to the National Priority List.
This will give you a brief overview, and I know
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this map is hard to see.
But there are basically 19
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-- or actually 20 sites now on the National Priority
List or proposed for the priority list in the
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Commonwealth of Kentucky.
The Paducah site, which is
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just north of here, was added just a few months ago.
The majority of the sites, if you had to see
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where they're clustered, are clustered around the
Louisville area, obviously where there's a lot of
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industry.
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I'll just go over basically what remedial
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investigation is for.
It's basically to identify the
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nature and extent of contamination at a site.
After
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remedial investigation is done, there's a risk
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assessment which is conducted to evaluate and qualify
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the risk posed by specific chemicals found at the
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site and to identify pathways of exposures.
To sort of bring this to a conclusion about the
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Superfund process, after the RIfFS is complete, the
agency will issue a proposed plan, which if you
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haven't already gotten one, there are copies up at
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the front.
We'll have a public -- 30-day public
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comment period on the proposed plan.
We generally
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hold a public meeting, as we're doing tonight, to
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review the proposed plan and address any concerns or
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questions that you may have.
And then we'll document
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the final choice for remedy in what's called a Record
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of Decision.
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I believe with that, I will turn it over to
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Mr. Young, who will basically explain what we've been
doing the last few years at the site as far as
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investigation.
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Thank you, Harold.
My name is
MR. YOUNG:
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I'm Remedial Project Manager for the
Nestor Young.
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site.
I was responsible for making sure that the
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investigation being conducted by General Tire was
conducted within EPA protocol and was sufficient to
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EPA standards.
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I'm going to run through that investigation,
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starting with the site background.
Copies of my
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overheads are up front.
If you didn't get a copy,
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you may want to do so.
I'm going to be running
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through essentially these overheads.
I'm not going
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to get into much detail.
If you have a copy of the
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proposed plan fact sheet, that gives you a little
more detail than what I'm going to be presenting
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tonight.
If you have any questions, if you can ask
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towards the end, during the question and answer
period, I'd appreciate that.
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Let's get started.
Let's start off by talking a
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little bit about the background of the General Tire
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site.
General Tire, if you don't know, produces
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automobile tires, as well as tractor and truck
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tires.
They operated a landfill to dispose of plant
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wastes from about 1970 to 1984.
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During the early years, some hazardous wastes
were disposed of, and that ceased in approximately
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1979.
Between the years of 1979 and '84,
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nonhazardous wastes were disposed of at the landfill,
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comprised mainly of just general plant waste, packing
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material,
scrap rubber, things like that.
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Wastes were buried in trenches that are
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approximately 1,300 feet long, 40 feet wide and
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approximately 30 feet deep.
Some of the trenches lie
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below the groundwater level, approximately ten feet
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under.
Some other trenches, I think we believe that
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they're completely dry, above the groundwater.
EPA included the site on the Superfund list in
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1990, again because of the potential threat to the
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nearby municipal water supply wells.
We had
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hazardous and nonhazardous waste disposed of at the
landfill, wastes that were sitting in groundwater,
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and a municipal water supply well that was
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approximately two miles away from the site.
So that
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potential threat existed.
The groundwater pathway
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potentially contaminated groundwater getting to the
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public.
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We'll just throw up a site plan so that you see
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what the site looks like.
The landfill is located
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approximately a third of a mile northeast of the
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plant itself.
As you can see, the trenches are
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oriented in a north-to-south direction.
It's
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approximately 500 feet from Mayfield Creek, and the
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land around it is basically farmland.
To the west,
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there's a railroad; generally, a vacant area just
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full of trees between the landfill and Mayfield
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Creek; and farmland to the south and to the north of
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the landfill.
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Again, the potential threat was to the two
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municipal water supply well fields that were located
within three miles of the site, both the Hickory
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water well field and the Hardeman.
There's also one
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residential drinking water well located approximately
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one mile from the site.
The well was tested and
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found not to be contaminated from any contaminants
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from the site.
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The plant operates six water supply wells that
are adjacent to the facility, and they pump
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approximately ten million gallons a day.
The water
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is basically pumped from the ground and to the plant,
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and it's used as noncontact cooling water.
Then the
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water is discharged to the rear of the facility into
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Key Creek.
We tested the water corning into the plant
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from the plant wells and did not detect any
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contaminants.
Essentially clean.
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Since this is a landfill and it was being
addressed through the State, in 1987 the landfill was
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approved for closure by the Commonwealth.
The
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landfill closure consisted of monitoring the site for
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a period of two years and installing a landfill cap.
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The cap consisted of approximately two feet of clean
soil.
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And I have a visual that will give you an idea
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of what that looks like.
Again, the trenches are
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about 40 feet wide, 30 feet deep, and it's got two
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feet of clean soil over the top.
And as I mentioned,
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some of the trenches on the eastern side of the
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landfill we believe are below the water table.
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These diagrams that I'm showing you are located
in the back of the copies if you want to refer to
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them.
I think I may have missed -- EPA's
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investigation of the landfill began in October of
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1990.
And the investigation, along with a
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preliminary feasibility study -- there's a couple of
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letters missing here -- and a Baseline Risk
Assessment was completed in May of this year.
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The investigation consisted of the following.
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Aerial photographs were reviewed, and that was
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basically to get a chronology of events.
Several
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photographs representing several years from the past
were reviewed to take a look at the progress of the
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landfill, when the trenches were dug and what
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sequence the trenches were dug, things like that, and
to what extent the landfill encompassed.
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We conducted a surface geophysical study, which
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is essentially an electromagnetic device that --
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basically, we used the device to determine what the
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extent or the outer limits of the landfill was.
It
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detects metal, metal objects in the ground, and we
just wanted to confirm what we already knew, which
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was the outer boundaries of this landfill.
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We did an air quality survey, which consisted of
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taking samples all throughout the surface of the
landfill and wanted to find out if there was any gas
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escaping through the surface and if that was a
potential threat.
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There were some surface soil samples taken,
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surface water, sediment samples, groundwater
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sampling.
We also evaluated the groundwater flow and
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the geology underneath the landfill to determine if
there were any contaminants escaping from the
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landfill and what direction they would be flowing.
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There was also an ecological assessment conducted to
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determine if there were any impacts to the local
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environment.
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These are the number of samples that we
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collected.
As you can see, there are a few surface
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soil samples, surface water.
Surface water consisted
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of both samples from the Mayfield Creek, from Key
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Creek, and also from ponding of water in ditches
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around the site.
That's also true for the sediment.
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Sediment samples were collected along both creeks and
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along ponding ditches.
There were also groundwater
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samples collected.
There are numerous monitoring
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wells that are located around the perimeter of the
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landfill, both shallow monitoring wells and deep
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monitoring wells, and a number of samples were
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collected.
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There were two sampling rounds that were
completed, two different times of the year, and that
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was basically to confirm the results that we were
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getting.
And as I mentioned, there were samples of
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the air to detect any gases being emitted from the
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landfill.
And we had approximately 390 samples that
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were collected throughout the top of this landfill.
These are the type of compounds that we were
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finding.
In the surface soils, you can see we found
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four organic and no inorganic compounds, mainly
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metals and all that.
When I say number of compounds
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found, I'm talking about.compounds that were detected
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and that were determined to be possibly from the
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landfill.
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These compounds were essentially looked at,
background concentrations or existing standards, EPA
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standards, and if they exceeded EPA standards, then
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they were retained as compounds of interest.
And if
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they exceeded background concentrations, they were
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also considered compounds of interest.
80 we essentially sampled for a wide range of
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compounds, both metals and organics.
And we went
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through a screening process to determine or to more
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closely look at those compounds that could
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potentially be coming from the landfill.
After the
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screening process, we essentially carried these
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contaminants forward onto the Baseline Risk
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Assessment and determined their potential health
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risks.
And as you can see, 12 compounds were found
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-- 12 organic and 12 inorganic compounds were found
in the groundwater.
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Essentially, what we found is that there were no
significant levels of contaminants in the shallow
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aquifer or the deep aquifer.
There were no
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contaminants from the landfill found in Mayfield
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Creek or Key Creek.
wells were affected.
No residential drinking water
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No levels of contaminants were
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found in surface soil sediments.
And we didn't find
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any gas being emitted from the landfill.
Nothing
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that would be harmful to human health or to the
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environment.
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We also found that the plant wells being
operated by General Tire were significantly impacting
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the local groundwater.
Those wells are essentially
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reversing the natural groundwater flow.
The natural
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groundwater flow is basically towards the northeast,
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towards Mayfield Creek.
And these wells are
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basically reversing that groundwater flow and pulling
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or sucking groundwater towards the plant.
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Pull up this visual again.
Essentially, the
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flow of groundwater is naturally towards Mayfield
Creek, and Mayfield Creek flows towards the north, so
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the natural groundwater flow is essentially towards
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the northeast.
And as you can see, the facility
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operates six plant wells located around the north
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side of the facility.
It's creating a very
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significant depression in the groundwater, and what
that does is if there were any contaminants that were
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escaping or being leached into the groundwater, they
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would be getting sucked up into the plant wells.
And
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again, we're not finding any contaminants in the
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plant wells at all.
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Let me show you what the effects of the plant
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wells are, essentially.
We believe that these plant
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wells have such a significant effect on the ground
water that it's actually sucking water out of
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Mayfield Creek.
It's that significant.
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That's an important point to note.
This is
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basically one of the reasons why we're proposing what
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we're proposing tonight is the fact that we're not
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finding anything in the groundwater and the fact that
these plant wells are operating such that if there
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were anything to be released from the landfill, the
plant wells will capture those.
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And the groundwater is the primary mechanism by
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which the local population would be affected.
The
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landfill has a cover on it, so there's no direct
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contact with the waste.
So the only way the
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contaminant can find its way into the community is
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through the groundwater, is through drinking
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contaminated groundwater or corning in contact with
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contaminated groundwater.
And because these plants
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wells are operating and because they're significantly
affecting the local groundwater, these contaminants
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can't escape.
They can't escape the power of the
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wells.
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Based on the data that we collected during the
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remedial investigation and the screening of the
contaminants that were found in some of the
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monitoring wells and some of the media that were
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sampled, we went on and did an estimate of health
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risks that may pose to the local community and to the
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environment.
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There are basically two ways of looking at
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health risks.
There are carcinogenic risks, which
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are essentially compounds that cause cancer.
We
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looked at the risks of contracting cancer from
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exposure to those compounds.
And we also looked at
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noncarcinogenic risks, meaning exposure to compounds
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that do not cause cancer but that are either toxic or
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have other adverse health effects.
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We looked at both of those types of health
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risks, and we found that the carcinogenic health
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risks are within EPA's acceptable range.
It was
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either below the acceptable range or within it.
Thereby, we have concluded that the carcinogenic
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compounds do not pose a health threat.
And we didn't
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find, also, any health threats associated to
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noncarcinogens.
Those health risks were also below
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EPA's acceptable limit.
Hand in hand with the health
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risks, we also evaluated the risks to the local
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environment, and we found that landfill did not pose
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a risk to the environment or to local wildlife.
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Based on all that, EPA's proposing tonight to
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not take any further action at this landfill.
We
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feel that the landfill, as it exists today under
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current conditions, does not pose a health threat and
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does not impact the environment.
Again based on the
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data that we collected and based on the fact that
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those plant wells are operating, we feel that the
plant wells are providing a significant protection
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against anything that may be released from the
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landfill.
The visual outlines the basis for our
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decision and pretty much summarizes the results of
the remedial investigation.
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I think that pretty much covers everything that
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I want to talk about.
Again, EPA's recommendation is
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no further action.
And by that, we mean the way the
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landfill exists, you know, that the conditions at the
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site as it currently exists are acceptable.
not finding any threats to the environment.
We feel
We're
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that the plant wells are providing a significant
protection.
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If you have any questions, I'll be glad to
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answer them during the question and answer period.
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Don't be shy.
If I can't answer them, I'm sure we
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can get an answer here for you tonight.
And that's
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it.
I want to pass it back to Harold.
Or actually,
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I want to go ahead and let Sue come up.
And she's
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going to talk about what's next in the process.
Now
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that we've pretty much completed the RIjFS, or the
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Remedial Investigation/Feasibility Study, and have
concluded that the landfill doesn't pose a threat,
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what's next?
And Sue will
Where do we go from here?
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answer that question for you.
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MS. MUNGER:
I have just some very brief
In situations like this where the
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comments to make.
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EPA and the State determine that a site is protective
of human health and the environment based on the
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remedial investigations that have gone on for the
past couple of years, further remedial action is not
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appropriate. In these cases, EPA can delete a site
from the National priorities List if, again, it
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determines that further response is not required to
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protect human health.
One point I wanted to make especially this
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evening is that deletion of the site from the
National Priorities List will not preclude its
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eligibility for later fund-financed or PRP-financed
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action.
If it's determined that the site should be
20
returned to the NPL, for example, because we think
21
there may be a threat to human health and the
22
environment in the future, then it can be reinstated
23
on the NPL without ranking again on the Hazard
Ranking System.
24
25
And all that means is, for example, if the plant
-------
23
1
wells stop pumping sometime in the distant future,
the site can be placed back on the National
2
3
Priorities List in what is essentially an expedited
4
It can get re-ranked very quickly and you
manner.
5
don't have to go through what can sometimes be a
fairly significant time period before it's back on
6
7
the NPL.
And that is a quick version of what we can
8
expect in the future on the site.
Are there any
9
questions about deletion from the NPL or anything
10
related to enforcement activities?
I'll take those
11
now or take those later.
12
(No response).
13
Okay.
I'll turn it back over to Harold.
Thanks.
14
MR. TAYLOR:
Again, this is the last part, and
15
we'll get to the question and answer period.
I was
16
just going to briefly go over the community relations
17
or participation in the Superfund.
Suzanne Durham,
18
who is our Community Relations Coordinator for the
site for EPA, is sick tonight, so she was unable to
19
20
attend.
I believe you'll see her name on page 6 of
21
the proposed plan, her name and address.
And you'll
22
see that we're now conducting a 30-day public comment
23
period that runs from July the 15th to August the
24
13th.
We'll accept public comments or written
25
comments that we receive that are postmarked by
-------
~ -
24
1
August the 13th, 1993.
You can send your comments to
2
Suzanne Durham at the address on page 6 of the
3
proposed plan.
We're also taking any verbal comments
4
that you have tonight.
Another thing I'd like to just point out, the
5
6
administrative record for the site, which is what EPA
7
based its decision on for the proposed plan, is
8
located in the Graves County Library in Mayfield.
9
It's there.
It's, I guess, about eight volumes of
10
documents.
Any comments that we receive tonight or
11
in writing by August the 13th we will respond to in a
12
responsiveness summary which will be included in the
Record of Decision for the site.
13
14
With that, I think we'll get to probably what
15
you're here for is the questions and answers.
And
16
again, what I'll try to do is take any questions that
17
you may have.
Again, please speak loud and state
18
your name so that the court reporter can get an
19
accurate record of your question of concern.
Address
20
your concern to me, and I'll either try to answer it
or ask someone here tonight to answer your questions.
21
22
So with that, are there any questions?
I think
23
I've talked to just about everybody but a few in the
24
room tonight already.
So -- Tony?
25
MR. SMITH:
I really don't have a question to
-------
25
1
answer or anything.
I just want to make a
2
I'm Tony Smith, and I met with you folks,
statement.
3
of course, this morning, on the information that you
4
provided for us on this meeting and also tonight.
feel confident that the information that you have
I
5
6
provided for us, the work that's been done, I feel
7
good about the site at General Tire.
And after
8
listening to the experts, I feel confident that the
9
water supply, of course, is safe, and I don't have
10
any problems.
Thank you.
11
MR. TAYLOR:
Thank you.
Yes, ma'am.
12
MS. AGNEW-THOMAS:
Julie Agnew-Thomas.
I have
13
one question.
Are the wells at the plant being
14
monitored for possible contamination, or is there any
15
continuing monitoring going on?
Is that --
16
MR. TAYLOR:
Go ahead.
17
MR. YOUNG:
No, the plant wells are not
18
currently monitored on a frequent basis.
They're not
19
monitored at all.
We sampled the wells on two
20
occasions during this investigation and found both
times that none of the wells contained any
21
22
contaminants.
50 essentially, the wells are pumping
23
clean water.
24
If, however, at some point in the future the
25
wells would pump some contaminated water -- and by
-------
26
1
"contaminated," I mean basically organic
2
contaminants that would probably be in the water.
3
Like I mentioned before, the water is used as
4
noncontact cooling water, so if the contaminants get
5
into the plant, they will be essentially destroyed by
6
the high temperatures that the water encounters in
7
the plant.
And I feel fairly confident that the, you
8
know, that those contaminants would be destroyed
9
within the plant and not discharged into Key Creek.
10
You've got to keep in mind also that the
landfill comprises just a very small portion of the
11
12
total radius of influence of the plant wells, so the
13
plant wells are pumping a lot more clean water than
14
they are any contaminated water.
That's one of the
15
reasons why we're not finding anything.
Another important point to note is that the
16
17
plant is supplied by City water.
So all the potable
18
water within the facility is supplied by the City and
19
not by the plant wells.
The plant wells are strictly
20
used for the manufacturing process and not for
21
drinking.
So the employees are not exposed to
22
potentially contaminated water from the plant wells.
23
The discharge of that water, of
MR. TAYLOR:
24
course, is discharged under a permit from the State.
Of course, they don't monitor all the time for all
25
-------
27
1
constituents, but there is monitoring that goes on of
2
the discharge of the water from the wells.
3
Point of information.
I'm Arthur
MR. BYRN:
4
Byrn, Mayor of the City of Mayfield.
The water --
5
the drinking water is provided by Hickory Water
6
District, not by the City of Mayfield.
7
MR. YOUNG:
I stand corrected.
8
If there aren't any other
MR. TAYLOR:
9
questions, I certainly appreciate everyone coming out
10
tonight.
And if you do have anything you'd like to
11
talk to us about while we're straightening up the
12
room, we'll be glad to.
Thank you very much.
13
(The hearing was concluded at 7:46 p.m.)
14
15
16
17
18
19
20
21
22
23
24
25
-------
28
1
C E R T I F I CAT E
2
3
I, ELIZABETH MILLER, Registered Professional
4
Reporter, CM, and Notary Public in and for the State
5
of Kentucky at Large, hereby certify that on the 29th
day of July, 1993, I attended and reported the
6
7
proceedings as set out on page 1 of this transcript,
and that the foregoing is a true and correct
8
9
transcription of my stenographic notes thereof.
10
Dated this 9th day of August, 1993.
11
12
13
1', - \ r
I ,'"' ! J )', I' .I ~
"/ --', ' ." !', I r-- \ i, I I r.
/ . J-. . ~ t ,. """" '. _.' '.' '.. , . \
ELIZABETH'MILLER, RPR-CM
Notary Public, Kentucky at Large
14
\
15
16
My commission expires January 9, 1996.
17
18
19
20
21
22
23
24
25
-------
GENERAL TmE LANDFILL
SUPERFUND SITE
RECORD OF DECISION
APPENDIX B
COMMONWEALTH OF KENTUCKY
COMMENTS ON THE
THE PROPOSED PLAN FACT SHEET
AND
EPA'S RESPONSE LE'ITER
-------
'::>: "J~' ...~"
BRERETON C. JONES
PHILLIP J. SHEPHERO
\J - -' ':". ..:
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
FR,o.NKFORT OFFICE PARK
14 REILL{ ROAD
FRA~4KFORT KE'JTlJO,.{ 40601
August 11, 1993
Mr. Nestor Young
North Superfund Remedial Branch
United States Environmental Protection
345 Courtland Street, N.E.
Atlanta, Georgia 30365
IPA - RIGICIIIV
ATLANTA,QA
Agency
RE:
General Tire Landfill Superfund site
Graves County, Kentucky
Dear Mr. Young:
The Commonwealth of Kentucky Division of Waste Management
(KDWM) has reviewed the proposed plan of action regarding the
subject site. Based upon the investigative work completed to date
the Commonwealth takes issue with the Environmental Protection
Agency's preliminary decision to require no further action at the
General Tire site. Our concerns have been communicated in previous
comments on the Remedial Investigation/Feasibility study and the
baseline risk assessment. Summarily, our principal concerns are as
follows;
1.
site characterization efforts of the landfill were
insufficient to provide a basis for a full assessment of
the feasibility of source treatment.
2.
The occupational, recreational and environmental effects.
of withdrawing groundwater from beneath the fill and
discharging to Key Creek were largely discounted in the
risk assessment.
3.
Cessation of plant production will lead to migration of
contaminated groundwater off-site. This would be a
totally unacceptable situation, particularly since the
cone of groundwater influence of the Hickory Water
District wells may encompass the landfill.
t~ Printed on Recycled Paper
V An EQual Opponunity Employer M/F/H
-------
Mr. Nestor Young
Page Two
August 11/ 1993
The KDWM strongly recommends a reconsideration of EPA's no
action proposal. We are committed to working with EPA in resolving
our concerns in this matter and wish to express our willingness to
dedicate our rp-sources to the maximum extent practicable in this
regard. We feel it plausible to explore the possibility of the EPA
acquiring a commitment from General Tire to address plant closure
or any possible sustained production well shut down scenario and a
continued surface and groundwater monitoring plan.
Again we urge Ef'A to reconsider it's "no action" proposal and
r8iterate our willingness to contribute in any way we can. Should
EPA find a reconsideration not workable, the KDWM finds it
necessary to take the position of nonconcurrence. As always, we
will be glad to discuss the issues with you should you desire.
Sincerely,
y~uJ~~.
C. Patrick Haight, Director
Kentucky Division of Waste Management
CPHjJPjpkb
-------
;-
".Or
- .. .
f ~.~. ~ ~
. .
:~ ~~
'. .~-
. ".. ;)I:I.~'\.-
UNITED STATES ENVIRONMENTAL PROTC:CTICN :"'GC:~.CY
REGION IV
345 COURTLAND STREET "'< E
ATLAI'o,A. GEORG:. 3C3cS
August 24, 1993
C. Patrick Haight, Director
Division of Waste Management
Kentucky Department for
Environmental Protection
Frankfort Office Park
18 Reilly Road
Frankfort, Kentucky 40601
RE:
General Tire Landfill Superfund Site
Mayfield, Graves County, Kentucky
Dear Ms. Haight:
This letter is in response to your correspondence concerning EPA's proposed plan for
the General Tire Landfill Superfund Site. EPA has made it's recommendation of "no
action" after careful consideration of the data collected during the remedial
investigation, and based on the risk assessment performed. It has never been EP A's
position that the site should not be monitored long term to make certain that the
landfill would not adversely impact human health and the environment in the future
-- especially when the plant wells cease operating. This concern is clearly stated in
the proposed plan fact sheet, which was sent to the Kentucky Division of Waste
Management (KDWM) and to the local community.
EP A believes very strongly that the site does not currently pose a threat to the public
or to the environment. Since the waste lies below the ground surface in trenches, and
your agency previously required a two foot soil cover over the waste, the only
exposure pathway to the public or to the environment that may reasonably cause an
unacceptable risk would be via the groundwater. The only conclusion that could be
reached, based on the results of the investigation, is that the plant wells are, and
have been, mitigating any groundwater problems that may have been produced by
the landfill. The investigation shows that the groundwater poses no unacceptable
risk to the public or to the environment.
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) allows EPA to take any necessary action consistent with the National
Contingency Plan (NCP) to protect the public health or welfare, or environment from
any hazardous substance release or substantial threat of a release. There is
-------
Ms. Haight, Director
Kentucky Division of Waste Management
August 24, 1993
Page 2 of 6
currently no evidence to show that a potential for a future release from the landfill
when the plant wells shut down may endanger the public or the environment.
Therefore, since there exists no current or future substantial endangerment to the
public or environment, from any release or threatened release, the EPA has no
authority (under CERCLA) to enforce a remedial action at this site.
This complicated issue was brought to your staff's attention over a year ago, when the
first draft of the remedial investigation report and baseline risk assessment was
submitted for review. At that time EPA acknowledged a concern for the future of the
site, but based on the results of the investigation, and specifically the baseline risk
assessment, EP A could not enforce an action to protect the public health without a
basis for implementing such an action. EP A believes that the long term monitoring
of the site would be more appropriately addressed through the Commonwealth of
Kentucky solid waste regulations, particularly since the landfill has not yet been
granted final closure by your agency.
Prior to the proposed plan public meeting on July 29, 1993, EP A, and Mr. Rick Hogan
and Mr. Larry Moscoe of KDWM met with representatives of General Tire. During
this meeting General Tire verbally agreed to implementing a long term monitoring
plan that would be acceptable to KDWM. General Tire committed to submitting this
plan to your staff in the near future.
On several occasions during the development of the RI Report and Risk Assessment
Report, EP A and your staff have discussed the Commonwealth's concerns, and on one
occasion your staff had an opportunity to communicate these concerns directly to
General Tire and their consultant. EP-A believes that most of these issues have been
adequately addressed in the submittal documents, and perhaps a better
understanding of the issues from EPA's perspective may bring us closer to an
agreement about the proposed plan. The following narrative is provided to
specifically address your principal concerns, enumerated in your letter:
1.
Site characterization efforts of the landfill were insuffzcient to provide a basis
for a full assessment of the feasibility of source treatment.
EP A response: Site characterization typically involves collecting
environmental samples from every media that may be impacted by the site to
develop an understanding of the problems associated with the site, and
subsequently develop appropriate remedial alternatives. At the General Tire
Landfill, every environmental media was sampled except for subsurface soils.
Since a complete inventory of the waste placed in the landfill was provided by
General Tire, the need for a subsurface soil sample was not necessary.
-------
Ms. Haight, Director
Kentucky Division of Waste Management
August 24, 1993
Page 3 of6
Knowing the types and quantities of hazardous substances disposed of was
sufficient to determine the potential environmental problems attributable to
those constituents and determine possible treatment alternatives to be
considered in the feasibility study. Additionally, monitoring wells positioned
around the landfill were used to determine the 'leachability" of the waste or
migration of contaminants through the groundwater.
Contamination of subsurface soils at this site would have been likely caused
by lateral migration of the contaminants through the side walls of the
trenches. If we assume that this scenario has occurred, the consequences of
leaving contaminated subsurface soil in place would not be worse than the
consequences of leaving the waste in place, since the exposure pathway
(groundwater) is the same in both instances. The fact that the soils
surrounding the waste may be contaminated is not a concern as long as there
is no exposure pathway associated with those contaminants. Therefore, there
is no informational value gained by sampling subsurface soils in this case.
EP A believes that a complete site characterization of the site was conducted,
and that the data gathered is sufficient to formulate our decision.
2.
The occupational, recreational and environmental effects of withdrawing
groundwater from beneath the fill and discharging to Key Creek were largely
discounted in the risk assessment.
EP A response: Groundwater is pumped by six plant wells into the General
Tire facility, where it is used as non-contact water for the cooling and
hydraulic system, and as boiler make-up for the powerhouse. After the water
is utilized in the facility it is discharged into Key Creek through six approved
KYPDES outfalls. Key Creek is an intermittent stream that flows mainly in
response to the General Tire discharge. Key Creek then discharges into
Mayfield Creek. The following points should clarify your evaluation of the
risks associated with exposure to groundwater being pumped into the facility
and subsequently discharged into Key Creek.
i)
Occupational Exposure
The only time employees of the facility would be exposed to the extracted
groundwater is when maintenance is being performed on the closed loop
system containing the water. Potable water at the facility is provided by the
Hickory Water District municipal wells -- not the plant wells.
-------
Ms. Haight, Director
Kentucky Division of Waste Management
August 24, 1993
Page 4 of 6
The plant wells were sampled on two separate occasions during the
investigation. Both sets of results for each well indicates that none of the
constituents of interest are present in groundwater being pumped to the plant.
Therefore, under current site conditions, the occupational exposure scenario is
not considered to be reasonable (since there are no contaminants to be exposed
to). However, since some constituents of interest were present in the shallow
aquifer and since these contaminants would be captured by the wells, a future
dermal exposure pathway was nonetheless considered in the risk assessment.
ii)
Recreational and Environmental Exposure
Although recreational use of Key Creek was not specifically addressed, current
use and future no action scenarios for recreational use of Mayfield Creek was
considered in the risk assessment. Additionally, an aquatic assessment was
conducted on Mayfield Creek where it was expected that ecological impacts
would have been observed. Sample locations up-gradient and down-gradient
of the confluence of Mayfield and Key Creeks were used. Since Key Creek is
an intermittent stream, which flows mainly because of General Tire's
discharge, it is not reasonable to assume that the creek would be used
recreationally or that it would support the types of organisms needed to
determine chronic toxicity effects. Moreover, as mentioned above, analytical
results of the groundwater entering the facility did not show the presence of
any contaminants of interest -- the results were all below detectable limits.
iii)
Hydrology
The plant wells are producing a significant hydraulic gradient encompassing
the entire landfill area. This gradient is so significant that both Mayfield and
Key Creeks are recharging the shallow aquifer, and the plant wells have
reversed the natural groundwater flow direction in the surrounding area. The
plant wells extract groundwater from the deeper Tallahatta aquifer, which was
found to contain very few contaminants of interest (no organic compounds).
As mentioned before, water samples from each of the six plant wells were
collected and analyzed. The results showed no detectable concentrations of any
contaminants of interest. This result is not surprising since the data shows
that the Tallahatta aquifer beneath the landfill has not been significantly
impacted, and since the influence of the plant wells extends radially outward
in all directions and therefore captures proportionately more "clean water"
than "contaminated water".
-------
Ms. Haight, Director
Kentucky Division of Waste Management
August 24, 1993
Page 5 of 6
In summary, the risks associated with exposure to groundwater being pumped
to the facility and discharged to Key Creek are insignificant since there are no
contaminants in the water from the landfill to be exposed to.
3.
Cessation of plant production will lead to migratwn of contaminated
groundwater off-site. This would be a totally unacceptable situation,
particularly since the cone of groundwater infllU!ru:e of the Hickory Water
District wells may encompass the landfill.
EP A Response: The future condition of the groundwater at the site when
the plant wells shut down is an issue that also concerns EP A. However, there
is currently no way to determine if there would be a groundwater problem in
the future or that the health and environmental risks would be unacceptable.
At this time EPA can only recommend that a future evaluation of the
groundwater be conducted when the plant wells cease operating. If and when
new information indicates that the site poses an unacceptable risk to the
public or to the environment, EPA is committed to re-evaluating the site for
possible actions under the authority of CERCLA and the NCP. According to
the NCP (40 CFR ~300.425(e)(3» "All releases deleted from the NPL are
eligible for further Fund-financed remedial actions should future conditions
warrant such action. Whenever, there is a significant release from a site
deleted from the NPL, the site shall be restored to the NPL without application
of the HRS."
Finally, your suggestion to acquire a commitment from General Tire to shut down the
plant wells for period of time to study the groundwater under that scenario is not
feasible for numerous practical reasons. For instance, shutting down the plant wells
will effectively shut down the plant, and it is estimated that it would take a
substantial period of time for the groundwater to reach it's natural equilibrium state.
As mentioned previously, General Tire has committed to implementing a long term .
monitoring plan and address groundwater issues when the plant wells are shut down
in the future. EP A has strongly encouraged General Tire to cooperate with KDWM
and address these long term concerns. EP A believes that KDWM is in a better
position to enforce long term monitoring of the site since final closure of the landfill
has not been granted, and as stated earlier, EPA has no authority under CERCLA
to issue an enforcement action at this site.
Regretfully, I must advise you that EPA's position has not changed. Our "no action"
proposal is not motivated by a lack of willingness to implement a long term solution,
but rather, it is a position we must accept based on our understanding of the
conditions at the site. EPA cannot recommend a remedial action for future site
conditions without supporting data to indicate that such actions are warranted.
-------
Ms. Haight, Director
Kentucky Division of Waste Management
August 24, 1993
Page 6 of 6
After your careful review of this letter, we would like to suggest a meeting with you
and your staff to discuss these issues further and hopefully reach an agreement or
develop a better understanding of our respective positions. We are currently
completing the first draft of the Record of Decision. Our intention is to issue a
decision document that would in no way inhibit your agency from initiating any
enforcement action in the future.
Please call me at your earliest convenience to schedule the meeting if you feel it
would be beneficial. We would be glad to meet in Frankfort at your office.
Sincerely,
Nest oun
Remedial Project Manager
Kentuckyffennessee Section
North Superfund Remedial Branch
pc:
Harold Taylor, EPA
Rick Hogan, KDWM
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