PB94-964013
EPA/ROD/R04-94/179
July 1994
EPA Superfund
Record of Decision:
Caldwell Lace Leather Site,
Auburn, KY
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CALDWELL LACE LEATHER
SUPERFUND SITE
RECORD OF DECISION
JUNE 30, 1994
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
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DRAFT RECORD OF DECISION
CALDWELL LACE LEATHER SITE
TABLE OF CONTENTS
Section Page
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY
1.0 BACKGROUND 1
1.1 INTRODUCTION 1
1.2 SITE DESCRIPTION 1
1.3 DEMOGRAPHY AND LAND USE 3
1.4 GEOLOGIC/HYDROGEOLOGIC SETTING 3
1.4.1 MOVEMENT OF WATER FLOW 5
1.4.2 GROUND-WATER RECHARGE/DISCHARGE 8
2.0 SITE HISTORY AND ENFORCEMENT ACTIONS 8
3.0 COMMUNITY PARTICIPATION HIGHLIGHTS 12
4.0 SUMMARY OF SITE CHARACTERISTICS 13
4.1 NATURE AND EXTENT OF CONTAMINATION 13
4.1.1 LANDFARM SURFACE SOILS 14
4.1.2 LANDFARM SUBSURFACE SOILS 14
4.1.3 LANDFILL SURFACE SOILS 14
4.1.4 LANDFILL SUBSURFACE SOIL 20
4.1.5 SOUTHWEST AREA SURFACE SOIL 20
4.1.6 SOUTHWEST AREA SUBSURFACE SOIL 20
4.1.7 WATER QUALITY DATA 20
4.1.8 SEDIMENT 31
4.1.9 LEACHATE 31
4.2 ECOLOGICAL STUDY 31
4.3 CONTAMINANT FATE AND TRANSPORT 34
5.0 SUMMARY OF SITE RISKS 35
5.1 HUMAN HEALTH RISKS 36
5.1.1 CONTAMINANTS OF CONCERN 36
5.1.2 EXPOSURE ASSESSMENT 36
5.1.3 EXPOSURE DOSE ASSUMPTIONS 39
5.1.4 TOXICTTY ASSESSMENT 40
5.1.5 TOXTCITY SUMMARY ON THE CONTAMINANTS OF
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DRAFT RECORD OF DECISION
CALDWELL LACE LEATHER SITE
TABLE OF CONTENTS
Section Page
CONCERN 41
5.1.6 RISK CHARACTERIZATION 41
5.1.7 UNCERTAINTIES IN RISK CHARACTERIZATION ... 44
5.1.8 RISK ASSESSMENT CONCLUSIONS 44
5.2 ECOLOGICAL RISKS 45
5.2.1 HABITAT AND BIOTA SURVEYS 45
5.2.2 SURFACE WATER 46
5.2.3 SEDIMENT 46
5.2.4 ECOLOGICAL RISK CHARACTERIZATION 46
5.2.5 ECOLOGICAL UNCERTAINTY ANALYSIS 47
6.'0 SCOPE AND ROLE OF RESPONSE ACTION 48
RESPONSIVENESS SUMMARY APPENDIX A
STATE CORRESPONDENCE APPENDIX B
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DRAFT RECORD OF DECISION
CALDWELL LACE LEATHER SITE
TABLE OF CONTENTS
Section Page
FIGURE 1-1 SITE LOCATION MAP 2
FIGURE 1-2 SELECTED MONITORING SITES 7
FIGURE 4-1 SAMPLE GRIDS 15
TABLE 4-1 CONTAMINANTS DETECTED IN SURFACE SOIL
LANDFARM AREA 16
TABLE 4-2 CONTAMINANTS DETECTED IN SURFACE SOIL
LANDFILL AREA 18
TABLE 4-3 CONTAMINANTS DETECTED IN SUBSURFACE SOIL
LANDFILL AREA 21
TABLE 4-4 CONTAMINANTS DETECTED IN GROUNDWATER 25
TABLE 4-5 CONTAMINANTS DETECTED IN SURFACE WATER 27
TABLE 4-6 CONTAMINANTS DETECTED IN SEDIMENT 32
TABLE 5-1 EXPOSURE SCENARIOS AND POTENTIAL EXPOSURE ROUTES . . 37
TABLE 5-2 EXPOSURE POINT CONCENTRATIONS OF CONTAMINANTS IN
GROUNDWATER „ 38
TABLE 5-3 CHRONIC REFERENCE DOSES 40
TABLE 5-4 TOTAL HAZARD INDEX USING RME CONCENTRATIONS 43
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Caldwell Lace Leather
State Highway 1039/Cemetery Road
Auburn, Kentucky 42206
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Caldwell Lace Leather Site,
located in Auburn, Kentucky. The remedial action was selected in accordance 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 Pollution Contingency Plan
(NCP). This decision document is based on the information contained in the Caldwell Lace
Leather Administrative Record.
The Commonwealth of Kentucky Department of Environmental Protection does not concur with
the selected remedy.
DESCRIPTION OF THE REMEDY
Based on the results of the Remedial Investigation, and the potential current and future risks
estimated in the Baseline Risk Assessment, no action is necessary at this Site to ensure protection
of human health and the environment. This remedy is the final action for the Site.
The Caldwell Lace Leather Site is approximately 56 acres in size. From 1972 until 1985, the
Site received sludge and solid wastes generated by the Caldwell Lace Leather tannery facility
located in Auburn, Kentucky. The Site is divided into two areas, one a landfill and the other
a landfarm. Tanning-sludges and cowhide scraps were landfilled in unlined trenches or lagoons.
The landfill area was closed in 1985 and covered with several feet of soil and vegetation.
Tanning sludges were disked into the soil between 1982 and 1985 in the landfarm area and was
never officially closed. The landfarm is currently being used as a pasture for grazing livestock.
Although EPA recommends that no Superfund action be taken, EPA does recommend that the
Commonwealth of Kentucky or the current landfill owner continue groundwater/spring
monitoring; and future land use restrictions be placed on the landfill property as well as
maintenance of the landfill cover to prevent land use activities that would expose subsurface
waste.
DECLARATION STATEMENT
Based on the results of the Remedial Investigation, and the potential current and future risks
estimated in the Baseline Risk Assessment, no action is necessary at this Site to ensure protection
of human health and the environment. Because this remedy will not result in hazardous
substances remaining on-Site above health-based levels, the five-year review requirement will
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_ DECLARATION FOR THE RECORD OF DECISION _
not apply to this action. EPA has determined that its response at this Site is complete.
Therefore, the Site now qualifies for inclusion on the Construction Completion List.
J^
Date John H. Hanttnson, Jr.
Regional Administrator
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
DECISION SUMMARY
1.0 BACKGROUND
1.1 INTRODUCTION
In June 1988 the Caldwell Lace Leather (CLL) Site was proposed for inclusion on the National
Priorities List (NPL). The United States Environmental Protection Agency (EPA) entered into
negotiations with the Potential Responsible Parties (PRPs) in September 1988 to conduct the
Remedial Investigation/Feasibility Study (RI/FS). The PRPs declined to conduct the RI/FS in
October 1989. EPA began the RI/FS in March 1990 (A) to determine fully the nature and extent
of any threat to the public health or welfare or the environment caused by the release or
threatened release of hazardous substances, pollutants, or contaminants at or from the Site; and
(B) to evaluate alternatives for the appropriate extent of any remedial action to prevent or
mitigate the migration or the release or threatened release of hazardous substances, pollutants,
or contaminants at and from the Site.
The RI Report for the CLL Site was conducted to meet the first objective above. The
investigation was conducted in accordance with Section 104 and other provisions of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),
42 U.S.C. Section 9601 et seq., as amended by the Superfund Amendments and Reauthorization
Act (SARA) (P.L. 99-499) and the National Contingency Plan (NCP), Part 300, Subpart E. The
FS was not conducted. EPA determined, based on RI results, that because the CLL Site does
not pose an unacceptable risk to human health and the environment an FS was not necessary.
The Commonwealth of Kentucky assisted EPA in the review of reports and site evaluations.
1.2 SITE DESCRIPTION
The CLL Site is located along State Highway 1039 (Cemetery Road), approximately 2.5 miles
northwest of the City of Auburn, Kentucky (Figure 1-1). CLL consists of two separate tracts,
Tract 1 ("landfill") and Tract 2 ("landfann"). Tract 1 consists of approximately 15.6 acres and
Tract 2 consists of approximately 41.2 acres.
Tract 1 was used for disposing of tanning wastes in unlined trenches and lagoons. The trenches
and lagoons were filled and covered with several feet of clay and soil. Tract 1 was vegetated
with a mixture of grasses and legumes. The ground surface is somewhat undulated due to
settling of the waste in the former trenches and lagoons. No buildings or structures exist on the
property. An access road from Cemetery Road traverses the property from the unlocked gate
to the southwest comer. The road is used by a local landowner to access his property located
south of Tract 1. Tract 1 is surrounded primarily by cropland and pasture.
Tract 2 received tannery sludges that were disked into the soil. Tract 2 is located adjacent and
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CALDWELL LACE LEATHER
SUPERFUND SITE
Landfill
Area
Landfarm Area
AUBURN
SITE LOCATION MAP
FIGURE 1-1
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Caldwell Lace Leather Site
June 30, 1994
to the east of Tract 1. Tract 2 was sold to a fanner who now uses the land as a pasture for his
cattle. The eastern portion of the property has a barn and a partially built house with an access
road that leads to the buildings. The owner has recently placed two mobile homes on the
property for his tenants. A water tank and an access road are on the western portion of the
landfarm. The landfarm is bounded on the north by Highway 1039 (Cemetery Road) and several
residences. Surrounding property is primarily woodlands.
1.3 DEMOGRAPHY AND LAND USE
The property is in a rural area a few miles northwest of Auburn, Kentucky. The Site is bounded
on the north by Cemetery Road and in the other directions by pasture, cropland and woodland.
Areas north of the road are principally woodland and farmland. The nearest residence is on the
landfarm area of the Site. Other nearby residences are along the north side of Cemetery Road.
Much of the site is now cropland and pasture. Cropland and pasture, and mixed forest are the
predominant forms of land use within a two-mile radius of the Site.
The town of Auburn, population approximately 1,500, is the closest population center and has
the nearest school. Auburn obtains its water supply from the Auburn Spring, which is located
on the south edge of town. At one time all residents in the Site vicinity obtained their potable
water supply from private wells, but many now obtain it from the East Logan Utility District,
which purchases water from Russellville. A majority of people living along Cemetery Road that
have been hooked up to the public water supply, continue to use well water for their livestock
and pets.
1.4 GEOLOGIC/HYDROGEOLOGIC SETTING
Nearly all ground water at the Site is present at relatively shallow depths. The Site lies along
the crest of an east-west trending ridge that is about 170 feet in elevation above the surrounding
valley floors. In the vicinity of the Site, the bedrock is overlain by soils and residuum that is
generally thin but variable in thickness. Soil depths range from 0 to 43 feet. The soils and
residuum, where present, are underlain by limestones, shales and sandstone of the Mississippian
age including, in descending order, (1) the Big Clifty Sandstone member of the Golconda
Formation, (2) the Girkin Formation and (3) the Ste. Genevieve Limestone.
Most of the Site is underlain by as much as 70 feet of the Big Clifty Sandstone, which is the
caprock for many of the ridges throughout the vicinity. The Big Clifty Sandstone is gray to light
brown, fine-grained, cross bedded and locally shaley.
The Girkin Formation underlies the Big Cliffy Sandstone and outcrops at the surface at the
eastern and western ends of the Site. The Girkin Formation underlies the highly developed karst
terrain lowlands that surround the Site. This Formation is approximately 170 feet thick and is
comprised mostly of limestone that is medium-light gray to pale-yellow gray, aphanitic to
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Caldwell Lace Leather Site
June 30, 1994
coarsely detrital, and oolitic. Discontinuous shale and sandstone units up to five feet in
thickness are present about 45 feet above the base of the Girkin Formation.
The Ste. Genevieve Limestone underlies the Girkin Formation. This limestone is light gray to
light brown in color, fine to coarsely detrital, and oolitic. The Ste. Genevieve Limestone is
approximately 200 feet thick in the vicinity of the Site and is the basal limestone in the area.
The nearest outcrops of the Ste. Genevieve Limestone to the Site are at Mud Spring, about four
miles southwest of the Site, and in the vicinity of the town of Auburn, located about two miles
southeast of the Site. Auburn Spring, used by the city of Auburn for municipal water supply,
is located near the outcrop of the Ste. Genevieve Limestone.
Ground-water hydrology in the vicinity of the Site is governed by the mature karst development
of the Girkin Formation. Locally, the Big Clifty Sandstone is only present in the immediate
vicinity of the Site and is not hydrologically significant with respect to the movement and
occurrence of local ground waters. The Big Clifty member provides only temporary storage of
infiltrated rain water that is relatively rapidly transmitted either to the underlying Girkin
Formation or to surface discharge points in the form of small seeps and springs. Underlying
the Girkin at considerable depth in the vicinity of the Site, the Ste. Genevieve Limestone is
unlikely to be significantly affected by potential contamination from the Site. While the Girkin
Formation undoubtedly transmits some recharge to the underlying Ste. Genevieve Limestone,
the bulk of ground water that reaches the Girkin Formation will be diverted to surface water
discharge points (springs) through discrete subsurface channel flow characteristic of karst
terrains.
The hydrologically significant aquifer underlying the Site is therefore the Girkin Formation. As
mentioned above, the Girkin Formation underlies the mature karst terrain of the areas
surrounding the Site. Mature karst terrains are characterized by the presence of sinkholes,
springs, disappearing streams and "karst windows", which are topographic depressions caused
by the subsidence of the land surface resulting in the exposure of an underground stream.
Ground-water flow in karst terrains is in turn characterized by conduit flow in subsurface
channels, such as cave streams and other enlarged solution channels in the limestone. In the
mature karst terrains such as those surrounding the Site, these conduits concentrate waters that
enter the subsurface at either discrete points, such as sinkholes and karst windows, or by
infiltration through overlying residuum or sandstone, into dendritic subsurface drainage patterns
reminiscent of surface drainage patterns (i.e., creeks, streams and rivers). These subsurface
conduits generally emerge to surface water discharge points in the form of springs.
Conduit flow in carbonate bedrock such as the Girkin Formation occurs in solution-enlarged
openings that range in size from less than one inch to cave-size, such as the cave-like opening
that forms Mossy Spring, a large volume discharge spring located approximately 2 miles
northeast of the Site. These conduits develop along horizontal and vertical open fractures an
bedding planes within the formation, resulting in the dendritic or trellised drainage network
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Caldwell Lace Leather Site
June 30, 1994
described above. Conduit flow predominates in the area surrounding the Site, and the
hydrologic significance of this mature karst development is the rapid introduction of excess
rainfall into the aquifer system, and subsequent rapid movement of ground water through the
aquifer system.
1.4.1 MOVEMENT OF WATER FLOW
The movement of ground water in the CLL Site vicinity is determined by the nature of the soil
and rock matrix associated with the different lithologic strata underlying the Site. The types of
ground-water movement range from laminar flow in the interstitial pore spaces of unconsolidated
media (e.g., in the soils and residuum overlying the bedrock in portions of the Site) to turbulent
flow in discrete conduits (e.g., flow in the solution-enlarged subsurface channels found in the
Girkin Formation).
Ground-water will always flow in response to hydraulic gradients present in the aquifers in
question. At the Caldwell Site, potentiometric equipotential lines radiate outward from the Site,
which is located at a topographic as well as a local potentiometric "high point" or divide. James
F. Quinlan, a professional geologist, in 1982 determined the potentiometric surface of the water
table to be "...an elongate, sausage-shaped mound that is concave northward...." In addition
to the determination of the potentiometric surface of the local water table, Quinlan conducted
a series of dye traces. The dye trace studies conducted by Quinlan identified routes of dye
movement to the southwest, towards the Mud River, from the old waste disposal areas. Other
routes of flow were identified to the north, from the landspreading operations area, towards
discharge points on the Gasper River, and flow routes to the west were inferred from the
hydraulic gradient data.
Ralph Ewers, geologist/hydrogeologist, in 1983 conducted additional dye-trace studies at the
Site. The results of this study were similar to those reported by Quinlan, and tend to confirm
those observations.
The United States Geological Survey also conducted dye-trace studies in 1992 at the Site. The
results of the USGS study tended to confirm those of Quinlan by identifying points of discharge
to the southwest and north. In addition, the USGS study confirmed the flow connection from
the Site to points of discharge to the west, into the Long South Fork/Wiggington Creek drainage
basin. The USGS study also confirmed the absence of a hydraulic connection between the Site
and the spring used by the City of Auburn for public water supply. For the purposes of further
discussion, the various springs used as monitoring points by Quinlan, Ewers, and the USGS will
be identified by the nomenclature used in the 1993 USGS report.
During the course of the three separate studies, dye was injected into eight different points of
entry to the subsurface conduit flow system either on the Site or in the immediate vicinity.
These eight injection points include swallets, sinkholes and other karst windows that are
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Caldwell Lace Leather Site
June 30, 1994
naturally occurring. Detectors were placed during the course of the three studies in wells,
springs, and surface streams surrounding the Site.
The results of the dye trace studies have delineated the movement of ground water in the karst
aquifer underlying the Site. Dye injected at most of the injection points was recovered at a
series of connected recovery points southwest of the Site leading to eventual discharge into the
Mud River surface water drainage. The dye recovery points along this pathway were springs
numbers 2, 3, 6 and 8 (Green Boiling Spring, Duncan Tile Spring, Coy Wright Blue Hole
Spring, and Mud River Spring, respectively). Mud River Spring (spring 8) is the final discharge
point for this subsurface system, and is located approximately four miles southwest of the Site.
Please refer to Figure 1-2, which has been reproduced from the USGS report, for identification
of some of the dye-recovery points. Dye-recovery points not indicated on Figure 1-2 may be
found in the RI Report. The dye-recovery points that are indicated on Figure 1-2 were used
for the ground water/spring monitoring locations as discussed in Section 4.1.7.
Dye injections were also recovered at springs 9 and 11 (Mossy Spring and Cemetery Road
Spring, respectively) and at surface water monitoring point 10 located in Long South Fork
Creek. Springs 9 and 11 discharge to Long South Fork Creek. These springs and the surface
water monitoring point are located approximately 1.8 miles northwest of the Site. This indicates
that the subsurface system of solution channels in the Girkin Formation draining towards Mud
River Spring and towards Mossy Spring is interconnected.
Dye was also injected into a location, which does not lie on the Site itself, but which is located
north of the former landspreading operation area. Runoff from the landspreading operation area
could enter the karst aquifer at this point. Dye injected at this location was recovered at springs
12, 13, and 16 (Barnett Spring, Barnett Karst Window, and Crawford Spring, respectively).
Spring 16 is the ultimate discharge point for this portion of the karst system, and is located
approximately 2.2 miles north of the Site. This spring discharges into Gasper River. These
results indicate that storm water runoff from the Site can enter the subsurface karst system and
be transported in a northerly direction, eventually discharging to Gasper River.
The rate of ground-water flow in subsurface karst conduits of the type present at this Site is
highly variable, dependent upon rainfall, antecedent moisture conditions, and time of
concentration. Rates of flow will increase dramatically in response to rainfall events, slowly
tapering off to base flow conditions thereafter. Subsurface flow hydrographs would look
essentially the same as surface water stream hydrographs following rainfall events; i.e., a rapidly
rising limb followed by a more gradual falling limb returning to base flow rates and volumes.
The USGS (1993) estimated flow rates from the Site to points of discharge at downgradient
springs to range from three to five days, and in the case of spring number 8 (Mud Spring) as
much as eight days. Eight days travel time to spring number 8 is approximately equal to an
average flow rate of two feet per minute. Flow rates in open solution channels in mature karst
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45'
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54'
52'JO'
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rnett Karst ffmdo
2 Gr^en Boiling^ Spring
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
systems can be as high as 200 feet per minute under high flow conditions (e.g., in response to
storm events).
1.4.2 GROUND-WATER RECHARGE/DISCHARGE
Ground-water recharge at the Site consists of infiltrated rainfall. Recharge occurs through the
overlying soils and residuum, downward through fractures in the Big Clifty Sandstone,
eventually reaching the open solution channels in the limestones of the Girkin Formation.
Quantitative rates of recharge to the Girkin Formation (the primary aquifer of concern at the
Site) have not been determined, but as in all karst terrains the rate of recharge will be relatively
high, and the rapidity with which that recharge occurs will likewise be high. It is likely that as
much as 25 inches per year of rainfall eventually serves as recharge to the Girkin Formation in
the vicinity of the Site.
The priiriary points of discharge from the Girkin Formation were identified in the three dye trace
studies discussed above. Discharge was identified into three separate drainage basins; to the
southwest into the Mud River Basin, northwest into the Long South Fork Creek drainage basin,
and north into the Gasper River drainage basin. Recharge from the Site, or runoff from the Site
which is likely to enter nearby karst windows, will reach one or more of these discharge points.
2.0 SITE HISTORY AND ENFORCEMENT ACTIONS
The CLL Site is approximately 56 acres in size. From 1972 until 1985, the Site received
sludge and solid wastes generated by the Caldwell Lace Leather tannery facility located in
Auburn, Kentucky. Based on review of the collected records and interviews with knowledgeable
government officials, the Caldwell Lace Leather Company, Inc. (Caldwell), of Auburn operated
a tannery from the late 1800's until January 1985, when tanning ceased at the facility and only
leather cutting operations were continued. There was no indication of what disposal locations
were used for the tannery's waste streams prior to its use of the CLL Site in 1972. The Site and
tannery were owned and operated by Caldwell until 1983, at which time they were purchased
by a separate company named Lace Leather, Inc.
The tannery used a chrome-tanning process to tan cowhides which generated a wastewater sludge
containing chromium. Laboratory analyses performed on samples of the wastewater sludge in
1971 by the Tanners' Council Research Laboratory revealed that the sludge contained between
2,580 and 3,940 milligrams per liter (mg/1) of trivalent chromium. The wastewater sludge,
along with the tannery's other waste streams (cowhides, leather scraps, fleshings, cork, asbestos,
cardboard and paper) were taken to a 15-acre area of the Site (hereinafter "Tract 1" or "landfill
area") for disposal beginning in 1972. In general, the records revealed that Tract 1 contained
at least 25 shallow trenches covering approximately 10 acres. The trenches were variously
referred to as pits, lagoons, ponds, and basins in the Kentucky Department of Environmental
Protection (KDEP) records. For clarification, they will be referred to as trenches. Most of the
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Caldwell Lace Leather Site
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trenches were called drying trenches and were used to hold the liquid-based wastes until
evaporation took place. The remaining trenches were used for the disposal of solid refuse, and
according to KDEP inspectors, were not covered on any regular schedule.
During the years of Tract 1 operations, numerous inspection were conducted at the Site by
KDEP. Problems regarding the uncovered scrap leather trench, overflowing sludge-drying
trenches, and leachate running off of the Site property were constantly reported. Inspectors
described the Site as covering 10 acres, with no buildings and many trenches containing different
types of waste including hair, fat, dye, and rotten hides. Samples taken by the KDEP from the
scrap leather trench were analyzed and shown to contain between 5.9 mg/1 and 11.4 mg/1 of total
chromium. A sample taken by the KDEP from a run-off pool on neighboring property owned
by Mr. and Mrs. Bobby Reeves was analyzed and contained 13.2 mg/1 of total chromium.
Inspectors reported that remedial measures would have to be taken by Caldwell immediately to
stop contamination of ground water and surface water caused by run-off and leachate from the
unlined trenches.
In 1981, an adjacent 41-acre area (hereinafter "Tract 2" or "landfann area") was purchased with
the intent of using the property for landspreading, also referred to as landfarming in KDEP
records. A Site lay-out map is presented in Figure 1-2. In 1981, a sludge storage lagoon with
95,000 gallon capacity was constructed and was to be used when landspreading was impractical
due to frozen ground or other unusual conditions. Although the lagoon was constructed on the
Site, it is not clear whether the lagoon was constructed on Tract 1 or 2. In 1982, a construction
permit was issued for a second 95,000-gallon sludge storage lagoon at the Site for use when
landspreading was impossible due to freezing conditions. This lagoon was constructed along the
eastern boundary of Tract 1.
On July 13, 1982, a conditional permit was issued to Caldwell for landfarming chromium and
vegetable tanning sludge. This operation involved approximately 28.5 acres of Tract 2. On July
30, 1982, Caldwell was issued a Construction Permit for a third disposal area - a residential
landfill for disposal of solid waste (screenings, leather scraps, and gasket scraps) on
approximately 5 acres adjoining the old landfilled area of Tract 1.
On October 12, 1982, Caldwell was notified by the KDEP that the company had violated
numerous permit conditions at the Site. Some of the violations included: failure to submit a
ground-water study report; failure to submit a separate $10,000 surety bond for the residential
landfill; failure to maintain adequate landspreading records; failure to disk the sludge into the
soil deeply enough; and gross deficiencies between the actual ongoing construction of the
residential landfill and the construction permit. An Agreed Order was negotiated for several
months, but never became final.
»
A KDEP site inspection of the landfarming area was conducted on December 15, 1982. Some
corrections had been made, but problems still existed including continued use of inadequate
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equipment and lack of a field gridding system. In December 1982, Caldwell acquired two surety
bonds covering the residential area and the landspreading area. The company submitted to
KDEP a sludge application grid breakdown, which specified that 310,800 gallons per year of
sludge would be spread over 29.6 acres of the Site. Conditional operating permits were issued
for both the residential landfill (March 1983) and landfarming areas (February 1983).
On April 20, 1983, Caldwell (i.e., Caldwell Lace Leather Company, Inc.), changed its name
to Lace Leather, Inc. Lace Leather, Inc., sold its original name and all its assets to Auburn
Leather Co., Inc. On the same date, Auburn Lace Leather Co., Inc., incorporated by Mr. J.
Richard Hewlett and Mr. Harry Williamson, changed its name to Caldwell Lace Leather Co.,
Inc.
Additional transactions occurred regarding assets and liability - thereby confusing the issue of
the owner's true and correct name. Nonetheless, the title documents confirmed the sale of the
Site and,'by reference, the sale of the tannery to Caldwell Lace Leather Co., Inc. Therefore,
based on this information the owner and operator of the Site and tannery after April 1983 was
Caldwell Lace Leather Co., Inc. (Caldwell Lace Leather).
An inspection of the Site was conducted on March 18, 1983, by KDEP staff to investigate
reports that Caldwell had drained waste trenches. The inspector reported that Caldwell had dug
a ditch which allowed the contents of two of the trenches to discharge off the Site property. The
volume of discharge was estimated to be between 2,900 and 9,000 gallons.
On April 15, 1983, Caldwell Lace Leather was notified that the KDEP had approved certain
remedial actions. These included removal or covering of the remaining sludge in the two
discharged trenches; removal or covering of fleshings in the open trenches; and landspreading
of the fleshing liquid.
On April 29, 1983, Caldwell Lace Leather notified KDEP that the remaining sludge in the two
discharged trenches was being covered with a mixture of sawdust and earth, and that the
company had applied for a variation from the landspreading permit to allow for the spreading
of liquids collected in the old fleshing trenches and subsequent covering and compaction of the
trenches.
An inspection of the Site was made on April 30, 1983, following a complaint that fleshing
trenches were overflowing and that the leachate was running across Mr. Bobby Reeves'
property. The inspector reported that black material from the fleshing trenches was discharging
across the property and into a sinkhole. It was estimated that 100 gallons per minute were
discharging into the sinkhole. A similar inspection was made on May 15, 1983, following
another complaint and the inspector again reported that the fleshing trenches were overflowing
onto Mr. Reeves' property. The inspector noted that it was raining very hard on both occasions.
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On October 1, 1984 an Agreed Order was entered into between Caldwell Leather Company and
with the Commonwealth of Kentucky Natural Resources and Environmental Protection Cabinet
(KNREPC). As statements of fact, the Order listed numerous violations which had occurred at
the Site. It stated that the permit issued for the old disposal area in 1972 was revoked and
superseded by conditions of the landfarming and residential landfill permits. The Caldwell
Leather Company was ordered to maintain vegetation at the old disposal area in accordance with
an approved closure plan which had been submitted by the company on September 2,1983. The
company was also directed to perform quarterly sampling and analysis of water in the diversion
ditch below the old disposal area, to submit a complete leachate control system plan, to manage
leachate from the inert waste section of the area and to pay a civil penalty of $3,000.
On February 22, 1985, KNREPC Division of Waste Management approved a closure plan for
the old landfilled area on Tract 1. The closure plan stated that the area to be closed consisted
of 5.5 acres and that solid waste had been disposed of there continuously from 1972 through the
fall of 1982. The work was regulated by Solid Waste within the Division of Waste
Management. Closure and post closure activities were to include application of lime and
fertilizer, regrading and revegetation, and ground water/surface water monitoring. All phases
of the closure plan were not completed until late 1989. The landfarm area was never closed.
On February 28,1985, Caldwell Lace Leather was notified by KNREPC that a soil sample taken
from the landfarming area in October had been analyzed and shown to contain high
concentrations of total chromium (3,630 mg/1). The letter warned that such a high concentration
level suggested that the potential for off-Site contamination as well as local plant toxicity was
extreme. KNREPC requested that the company submit a testing plan including comprehensive
soil testing, sampling analysis of collected rainwater, and a study of vegetation cover both on
the landfarming area and on adjacent property to determine the effects of the toxicity.
In June 1985, Caldwell Lace Leather notified KNREPC that a leachate collection system had
been installed and was operational at the Site. Details on this system were not presented in the
KNREPC records. However, later inspection reports revealed that the collection system was
not effective and that leachate from the leather scrap pit continued to present a problem at the
Site.
An inspection of the Site conducted on March 21,1985, revealed that the residential landfill had
not been covered and was in poor condition. The inspector reported that there was still a
problem with a discharge from the old leather scrap trench.
In November 1985, the tannery and the Site were purchased by North Park, Inc., a subsidiary
of the Auburn Leather Co., Inc. Caldwell Lace Leather Co., Inc., has terminated the tanning
operations earlier in 1985 and North Park, Inc., retained only the leather cutting operation
which produced leather trimmings and scraps as its only waste stream.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
In December 1985, the KNREPC completed a Preliminary Assessment and recommended a low
priority for site inspection. Inspectors reported that the Site was unsuitable for the disposal of
any hazardous waste due to the topography and hydrology of the area. In October 1986, a
Hazard Ranking Score (HRS) package was prepared. The Site was proposed for inclusion on
the National Priorities List (NPL) in 1988 and became final in August 1990.
3.0 COMMUNITY PARTICIPATION HIGHLIGHTS
Public participation requirements in CERCLA §§ 113(k)(2)(B)(i-v) and 117 were met in the
remedy selection process. The Community Relations Plan (CRP) was finalized in June 1990
for the CLL Site. This document lists contacts and interested parties throughout the government
and the local community. The Plan also establishes communication pathways to assure timely
dissemination of pertinent information.
In June '1993, EPA issued a Fact Sheet Update describing the Superfund process and the RI
summary. The Fact Sheet also provided the opportunity for the public to participate in the
Superfund process and provided the opportunity for community groups to apply for Technical
Assistance Grants (TAGS). The Fact Sheet was sent to the local community and local, State and
Federal officials.
EPA established and maintained an information repository and Administrative Record at a
convenient and accessible location in the Logan County Public Library and the EPA Region IV
Records Center. The Administrative Record includes all information EPA used in developing
the proposed final action. The RI/FS Reports and Proposed Plan for the CLL Site were released
to the public on April 14,1994. These two documents were made available to the public in both
the Administrative Record and the information repository.
The notice of availability of these two documents was published in the Proposed Plan Fact Sheet
and in the Bowling Green Daily News. A public comment period was held from April 15, 1994
to May 16, 1994. An extension to the public comment period was not requested. In addition,
a public meeting was held on April 26, 1994 to present the findings of the RI and answer
questions concerning the Site. Those in attendance included one interested citizen,
representatives from Caldwell Lace Leather Company, the local press, and several local and
State officials. A transcript of the public meeting is in the Responsiveness Summary, which is
a part of this Record of Decision. No written comments were received during the public
comment period.
This Record of Decision presents the selected remedial action for the CLL Site, chosen in
accordance with CERCLA, as amended by SARA, and, to the extent practicable, the National
Contingency Plan.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
4.0 SUMMARY OF SITE CHARACTERISTICS
4.1 NATURE AND EXTENT OF CONTAMINATION
The CLL Site is a disposal area in which chrome-bearing sludge was either landfilled or
landfarmed between 1972 and 1985. A significant portion of the waste disposed of at the Site
is chromium-bearing sludge landfilled in the northwest section of the property between 1972 and
1982; and landfarmed between 1983 and 1985. Also landfilled at the Site were fleshings,
spoiled hides, screening, leather scraps and gasket scraps. The fleshings and screenings also
contained chromium contamination.
The following is an estimate of the wastes disposed of at the landfill based upon operator
records:
Landfill '(based on 10 years of operation)
Chrome-bearing sludge: 15,000 - 42,350 tons
Fleshings: 1,040 - 1,610 tons
Screenings: 780 tons - 810 tons
Dry Waste (paper and
cardboard): 162,500 tons
Landfarm (based on three years of operation)
Chrome-bearing sludge: 4,700 - 5,600 tons
EPA investigated the CLL Site because of the potential for ground-water contamination in the
vicinity of the Site based upon the fact that chromium-bearing sludge was disposed of in unlined
trenches and disked into the surficial soils. These disposal techniques, coupled with the karst
topography of the region result were considered a potential threat to the local ground water.
The location and extent of wastes within the landfill and landfann were defined during the RI
by both intrusive and non-intrusive methods. Non-intrusive methods were accomplished by
utilizing existing records and aerial photographic interpretation. An evaluation of the landfill
aerial photographs indicated that the trenches were first excavated in 1972 and were constructed
continuously until approximately 1982. All of the aerial photographs indicate that the trenching
occurred within the boundaries of the landfill. Intrusive methods involved boring through waste
and non-waste material and performing chemical analyses on samples collected from the borings.
The intrusive methods also confirmed the location of trenches. Evaluation of the landfann aerial
photographs provided the landfann boundaries and sampling and analyses confirmed those
landfarm boundaries.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
The following environmental media were sampled and analyzed as part of the RI:
• Surface soils
• Subsurface soils
° Surface water
• Springs/Ground water
• Sediments
4.1.1 LANDFARM SURFACE SOILS
Contaminants in the landfarm area were expected to be primarily in the first foot of soil. This
assumption is based upon knowledge of the disposal method and random grab samples collected
during the RI. Therefore, emphasis was placed on sampling surface soil, with subsurface soil
studied to a lesser extent. The extent of contamination was determined based upon a statistical
sampling approach utilizing a systematic grid sampling design. The area was divided into thirty
grids (H-l through H-30, Figure 4-1) each measuring 200 feet x 200 feet or approximately one
acre. The surface of each full grid area was sampled by collecting a composite of up to nine
aliquots each. Second samples were taken in select grids using an offset pattern to determine
variability of concentrations within the grids.
The results, presented in Table 4-1, indicate that surface deposition of waste material on the
landfarm resulted in no contaminant concentrations above preliminary remediation goals (600
nig/kg for chromium VI. The PRO development was based on the Review Draft Guidance for
Part B of the Human Health Evaluation Manual (Development of Preliminary Remediation
Goals). Results showed no organics or pesticides present above the minimum detectable limits.
4.1.2 LANDFARM SUBSURFACE SOILS
Subsurface soil samples from the landfarm area were collected from the centers of grids at a
depth of three feet. Subsurface soil sample results from the landfarm are not significantly
different than background sample results.
4.1.3 LANDFILL SURFACE SOILS
Surface soil samples were collected as random and systematic grab samples. Samples collected
from the landfill area showed chromium concentrations ranging from 5 - 5,600 mg/kg. Lead
concentrations ranged from 8.2 - 280 mg/kg. Mercury was found at concentrations from .07 -
0.46 mg/kg. Organic acids associated with tanning (i.e. pentadecanoic acid, hexadecanoic acid,
etc.) were detected at most surface soil sample locations in the landfill at estimated
concentrations ranging from 300 to 2,000 fig/kg. Some samples showed the presence of
polynuclear aromatic hydrocarbon (PAH) compounds at low concentrations. Results are
presented in Table 4-2.
-14-
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N
SAMPLE GRIDS
O
N.T.S.
APPROXIMATE SCALE
348 o 874 S4B
< IN FEET )
Inch =348 ft.
CALDWELL LACE LEATHER SITE
AUBURN. KENTUCKY
FIGURE 4-1
U.S. EPA, REGION IV
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-1
Caldwell Lace Leather Site
Contaminants Detected in Surface Soil
Landfarm Area
Surface Soils
Analyte
lT^\jjn^yA-Pfj^jA v
-t- f
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Si
Frequency of
Detection
, * > * - \ " %"; ,
34/34
30/34
33/34
22/34
1/34
34/34
33/34
33/34
33/34
33/34
32/34
34/34
33/34
15/34
34/34
32/32
te-Related Samples
Range of Detected
Concentrations
(mg/kg)
> •.;''''.''
5,400 - 20,000
1.6 - 18.0
32-160
0.5 - 1.5
0.6
320 - 10,000
7.4- 1,100
2.2 - 14
3.8 - 18
1,000 - 18,000
6.5 - 52.0
420 - 11,000
57.0 - 800
0.07 -0.11
3.5-25
340 - 2,500
Arithmetic
Mean
(mg/kg)
-- ; "-]-"
-------
Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-1 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Surface Soil
Landfarm Area
Surface Soils
Analyte
Site-Related Samples
Frequency of
Detection
Range of Detected
Concentrations
(mg/kg)
Arithmetic
Mean
(mg/kg)
Background*
Sample
(SLA-001)
(mg/kg)
'WW^wrAJJiCS- tC^^fwSijcpM.." •,"' & '.** f,$$,'r ? 3? ','*?"'*,??;.'£'*'"'',{''"'<> r '"•••;,;;• >•«'•; '^L^V '''''"•^^''"'^A,'^ •'"'••.'''
Sodium '
Strontium
Tin
Titanium
Vanadium
Yttrium
Zinc
3/34
32/32
3/32
32/32
34/34
32/32
32/34
110 - 120
4.9 - 32
2.6 - 26.0
86.0 - 190
11.0-33.0
2.2-27
15.0 - 270
113
11.2
12.3
141.6
20.7
6.2
31
22
NA - Not applicable
* - Only the detected contaminants are reported. Blank spaces indicate result was below the detection limit.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-2
Caldwell Lace Leather Site
Contaminants Detected in Surface Soil
Landfill Area
Surface Soils
Analyte
Site-Related Samples
Frequency of
Detection
Range of Detected
Concentrations
(mg/kg)
Arithmetic
Mean
(mg/kg)
Background*
Sample
(SLA-001)
(mg/kg)
INORGANICS ,: !-V\/V,\;'-, *\ :~ . •/ ^/'^/IJ^JVJ
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Mercury
Magnesium
Manganese
Nickel
Potassium
Strontium
Titanium
Vanadium
46/46
35/44
46/46
24/30
1/14
45/46
38/46
40/40
37/39
46/46
40/46
4/14
46/46
45/46
36/38
36/38
28/28
28/28
46/46
3,900 - 25,000
1.8 - 8.4
24.0 - 210
0.51 - 2.2
1.7
180 - 63,000
5-5,600
1.9 - 17
1.7-28
1,000 - 21,000
8.2 - 280
0.07 - 0.46
300 - 24,000
80 - 2,000
2.5 - 22
230 - 1,500
2.2 - 210
81 - 210
8.2 - 48
11,767
4.8
88
0.96
NA
3,483
167
7.5
9.1
9,847
30.9
0.183
4,224
473
9.6
745
14.3
160
24
13,000
52
1,100
4.2
6.4
1,100
14,000
100
8.5
530
22
-18-
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-2 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Surface Soil
Landfill Area
Surface Soils
Analyte
Yttrium
Zinc
Site-Related Samples
Frequency of
Detection
28/28
28/34
Range of Detected
Concentrations
(mg/kg)
2.2-20
9.4-200
Arithmetic
Mean
(mg/kg)
8.1
49
Background*
Sample
(SLA-001)
(mg/kg)
SEMI-VOL ATTUS QRGAMCS -' ; , '/'j; ; ,*"*, ;*,;' /;' '" - * 't?'Fi_ rJ^lVM
Benzo(a)anthracene
Beazo(b and/or k)fluoranthene
Benzo(a)pyrene
Chrysene
Fluoranthene
Phenanthrene
Pyrene
1/42
1/42
1/42
2/42
2/42
2/42
2/42
0.130
0.087
0.053
0.073 -0.14
0.076 - 0.23
0.11 -0.24
0.08-0.15
NA
NA
NA
0.107
0.153
0.175
0.115
NA - Not applicable.
* - Only the detected contaminants are reported. Blank spaces indicate it was below the detection limit.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
4.1.4 LANDFILL SUBSURFACE SOIL
A variety of organic acids and alcohols associated with tanning, were detected in all the former
trenches sampled in the landfill area. Concentrated waste was encountered within three to four
feet of the surface in most of the former trenches sampled. The sampling results (Table 4-3)
indicated that wastes encountered in the areas of the former disposal trenches had significant
levels of chromium, lead, and mercury. The concentrations of these inorganics generally
increased with depth until such time as the soil boring penetrated the bottom soils of the trench,
at which time the concentrations were dramatically reduced to levels approaching background.
Background soils at the Site have characteristic concentrations of chromium (10-20 mg/kg), lead
(9-12 mg/kg) and mercury (0.10-0.12 mg/kg). Similar ranges for other inorganic constituents
such as aluminum, manganese, zinc, barium, iron, potassium, and magnesium can also be
established; however, such constituents were not characteristic of wastes encountered.
Subsurface soil samples were collected at strategic locations to further evaluate the potential for
downward migration of contaminants emanating from the trenches to determine the potential for
adverse impact to groundwater. A review of this analytical data indicates that inorganic
concentrations were more consistent with native soil levels than those observed for the various
wastes encountered.
4.1.5 SOUTHWEST AREA SURFACE SOIL
The area to the southwest of the landfill (Grids HV-1 through HV-8, Figure 4-1) was included
in this study due to the likelihood of contaminants deposited in the area by surface runoff from
the landfill. The grids in this area were sampled by collecting a composite sample from each.
The number of aliquots and the pattern of their collection was the same as that used for the
landfarm area. An offset sample was collected from each grid in this area to measure variability
of concentrations. The offset aliquot pattern used the same scheme as the landfarm.
Surface soil sample results from the landfarm are not significantly different than background soil
samples.
4.1.6 SOUTHWEST AREA SUBSURFACE SOIL
Subsurface soil within this area was sampled by collecting a grab sample from a depth of three
feet at the center of each grid in the same manner as the landfarm. Results of the analyses
showed metals (including chromium) to be at levels consistent with background conditions of the
area.
4,1.7 WATER QUALITY DATA
A unique aspect of ground-water characterization at sites where karst solution conduits dominate
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-3
Caldwell Lace Leather Site
Contaminants Detected in Subsurface Soils
Landfill Area
Subsurface Soils Analyte
(3-foot depth)
Site-Related Samples
Frequency of
Detection
Range of Detected
Concentrations
(rag/kg)
Arithmetic
Mean
(rag/kg)
Background*
Sample
(SLB-001)
(mg/kg)
iwnttfAi*r^« -' '' ^ -'"'"" J;/v"TJ-i.>^rv"s^<'' f; v< :!'\'. ' JK*^'''^J'^r^%^f~
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Strontium
Titanium
Vanadium
18/18
16/18
18/18
5/18
18/18
18/18
15/18
18/18
18/18
18/18
18/18
18/18
14/18
16/18
16/18
4/18
18/18
18/18
18/18
2,300 - 21,000
1.2 - 18
8.9 - 89
0.54 - 0.63
200 - 43,000
4.9 - 5,000
1.6 - 12
1.5 - 16
3,400 - 25,000
2.4 - 45
170 - 7,200
10-740
0.06-0.18
3.7 - 49
270 - 1,200
140 - 1,700
2.0-200
50-220
7.2 - 47
14,433
5.3
49.7
0.57
3,223
312
4.2
7.5
14,550
12.5
1,199
128
0.12
9.5
689
570
19.5
139
28.8
18,000
6.6
330
18
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-3 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Subsurface Soils
Landfill Area
Subsurface Soils Analyte
(3-foot depth)
Yttrium
Zinc
Site-Related Samples
Frequency of
Detection
16/18
18/18
Range of Detected
Concentrations
(rag/kg)
1.8 - 10
2.9 - 91
Arithmetic
Mean
(rag/kg)
4.1
24.6
Background*
Sample
(SLB-001)
(mg/kg)
^OiJsijj 0*4*1^^ xrfJ^?;^Y>
Acetone
o-ChloFO toluene
Ethylbenzene
Methyl Ethyl Ketone
Styrene
Toluene
(m- and/or p-)Xylene
o-Xylene
1/18
1/18
1/18
1/18
1/18
1/18
1/18
1/18
1.7
0.085
0.11
0.44
0.006
0.043
0.58
0.14
NA
NA
NA
NA
NA
NA
NA
NA
"4 , ; ' 's t-1 '" ' t ' "• ' "": >;%';• \" ' "^ -•>'•?* -•" -x" *'" •' •• •'•'< ,*'-- - > *"{-y ^"- •>• -, ,"'-.'*^-; "•'•'? ?""-, >-"-"/'' ' **" 1'jt'y^b' '''-.'"•"-
AJpha-Chlordane
Alpha-Chlordene
Chlordene
Gamma-Chlordane
Trans-Nonachlor
1/18
1/18
1/18
1/18
1/18
SEMI-VOLATILE ORGANTCS ' " ' - '^ " '/ ^
Bis(2-ethylhexyl)phthalate
1 ,2-DichJorobenzene
i ,3-DichJorobenzene
1/18
1/18
1/18
0.13
0.058
0.062
0.15
0.054
NA
NA
NA
NA
NA
% > ""••'.'< \ ,t --"J^," ,f -
42
3.9
0.042
NA
NA
NA
0.027
1* i,r>' "j '-.'-
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-3 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Subsurface Soils
Landfill Area
Subsurface Soils Analyte
(Moot depth)
1 ,4-DichIorobenzene
N-Nitrosodiphenylamine/
Diphenylamine
Site-Related Samples
Frequency of
Detection
1/18
1/18
Range of Detected
Concentrations
(mg/kg)
0.62
1.2
Arithmetic
Mean
(mg/kg)
NA
NA
Background*
Sample
(SLB-001)
(mg/kg)
* - Blank spaces indicate chemical was not detected above the detection limit.
NA - Not Applicable
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
subsurface hydrology is that ground-water quality is also considered to represent surface-water
quality. Since the dye-trace studies showed that ground water from the Site discharges at several
springs in the area, ground water was evaluated as potential surface water in the ecological risk
assessment. Surface water evaluations included water from the springs and their tributaries.
However, some of the surface water data collected does not represent ground-water quality
because some of the data was collected from man-made ponds.
Twenty-four chemicals were detected during the RI sampling and analysis of ground water
(Table 4-4); and twenty-six were detected in surface water (Table 4-5). Of these contaminants
aluminum, bis(2-ethylhexyl)phthalate, chromium, iron, lead, manganese, silver and zinc were
present in concentrations that were either above Maximum Contaminant Levels (MCLs) or
Ambient Water Quality Criteria (AWQC) for protection of aquatic life. These contaminants are
not present in concentrations that are significant from either an environmental or human health
perspective.
Aluminum
Aluminum was detected in ground-water samples taken from the springs used as sampling
points in concentrations ranging from 120 parts per billion (ppb) to 25 parts per million
(ppm). The higher concentration exceeds both AWQC and the EPA secondary MCL.
The AWQC for aluminum for protection of aquatic life from chronically toxic effects is
87 ppb, and the secondary MCL is 50 ppb. It should be noted, however, that the highest
concentration was in a sample taken in association with a rainfall event, when the
sediment load carried by turbulent flow in open solution channels is likely to have been
very high. In karst flow conduits, sampling during response to rainfall events yields
results analogous to sampling surface water streams in similar circumstances.
It should also be noted that samples taken from Duncan Tile Spring shown to be
unaffected by the Site during the dye-trace studies yielded comparable results when
analyzed for aluminum as those from the spring shown to contain the highest
concentrations. Samples taken from McPherson Spring on the same date as that taken
from Duncan Tile Spring which was shown to have 25 ppm of aluminum contained 5.5
ppm of aluminum. On another sampling date associated with rainfall events, Duncan
Tile Spring samples contained 5.1 ppm and samples from McPherson Spring contained
6.6 ppm of aluminum.
Samples taken from Green Boiling Spring, which is located in very close proximity to
Duncan Tile Spring and which was likewise shown to be in hydraulic connection to the
Site, on the same date as the sample found to contain 25 ppm, contained only 0.73 ppm
of aluminum. Finally, samples token from Duncan Tile Spring in January 1993, which
were not associated with a rainfall event were shown to contain only 0.51 ppm of
aluminum.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-4
Caldwell Lace Leather Site
Contaminants Detected in Ground Water
Ground Water
Analyte
Site-Related Samples
Frequency of
Detection
wpmAmts • , -~ :i;<: '-„/" *?\ T^X-'/f '
Aluminum
Barium
Calcium
Chromium (Total)
Chromium (VI)
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Molybdenum
Nickel
Potassium
Sodium
Strontium
Titanium
Vanadium
Yttrium
38/43
40/43
41/43
6/43
8/38
4/43
9/43
38/43
5/43
40/43
32/43
2/39
4/43
21/42
38/43
39/39
35/39
8/43
3/39
Range of Detected
Concentrations
(/tg/L)
~ * '•• \ ' *"\ '••?.&.'>' 4' ?'$ 't \sj \ jJ
56 - 25,000
5.3-960
2,700 - 100,000
6.1-22
1-10
2.7 - 11
3.8-92
52 - 21,000
5.9-20
1,100 - 31,000
7.5 - 4,200
5.3 - 10
11-22
510 - 8,300
1,200 - 770,000
62 - 3,700
10 - 350
2.9 - 42
12-21
Arithmetic
Mean
G*fi/L)
Background*
Sample
(McPherson
Spring)
£ fa f •>• \f & '''''4$. $•* % * '*'/" '£&'$ %%%,!?'& *
3,575
80
60,746
15
5.9
6.9
34
3,147
13.6
6,128
265
7.7
16.8
3,330
29,887
360
63
20
15.6
3,430
84
7,775
5,250
6.7
2,775
1,085
4,275
48
68
-25-
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-4 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Ground Water
Ground Water
Analyte
Zinc
Site-Related Samples
Frequency of
Detection
24/43
VOL AT1LE ORGAMCS -; \ * "" S
Bromomethane
Carbon Disulfide
Toluene
SEMI-VOLATILE ORGAMC5
Bis(2-ethylhexyl)phthalate
1/38
2/38
1/38
. , ;;, ';'•• * |"* c- '
4/37
Range of Detected
Concentrations
Gig/L)
5-710
, <* "„ "'^-\'"~'
0.56
1.3 - 1.7
1.0
'< "v"9r; * T' ::
14-59
Arithmetic
Mean
59
Background*
Sample
(McPherson
Spring)
14
I ^V/S?^®^
NA
1.5
NA
" "\-j', 'i
38
0.55
^^•f<;?^
NA - Not Applicable
Background data was averaged from four sampling events at McPherson Spring. Only detected
contaminants are repotted. Blank spaces indicate result was below the detection limit.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-5
Caldwell Lace Leather Site
Contaminants Detected in Surface Water
Surface Water
Analyte
Site-Related Samples
Frequency of
Detection
Range of Detected
Concentrations
G«g/L)
INORGANICS , - ^^^'^'^^i'^^j,;^^^',/^
Aluminum
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Strontium
Titanium
Vanadium
Yttrium
Zinc
36/38
36/38
38/38
5/38
2/38
1/38
36/38
3/38
37/38
28/38
3/38
20/38
35/38
29/37
26/37
6/38
1/37
18/38
84-25,000
28-380
8,900 - 95,000
6.1-710
11 -29
14
91 - 21,000
5.9-20
1,800 - 52,000
14 - 4,200
8-58
700 - 8,300
1,300 - 770,000
84-350
10 - 350
2.9 - 66
21
5-61
Arithmetic
Mean
0«g/L)
Background *
Sample
(McPherson
Spring)
(fg/L)
•" •" •. f, f ..(V^* jj f s>"v-ff$y*.
ff , '-. s £•• v-f-- f Jf-'f f,& tjyyf ySwVi
, , , , , ;^J •.', , ^ x,> ^*Cv%^
2,618
57
69,155
154
20
NA
2,294
12.6
5,908
319
29
3,143
27,202
210
60
25
NA
22
3,430
84
7,775
5,250
6.7
2,775
1,085
4,275
45
68
14
"vtvt vfft-'%£'ftiii>tt±^&urfi " *, '•"'', "''' < 'f'^''' ,''*", '/„,, - .1, ',' ' , ''"':*'•""'"'''•.'>
. V*Jt/AiJJUE<,^atl«af«V/» ; ' *, ',,; „!„ a;-,- ; ,, ,,i /ft ,f , • .' '--.-' ' , ., 4£,. »r . «?*»„ ,'•
Benzene
1/1
3.0
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-5 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Surface Water
Surface Water
Analyte
Bromomethane
Carbon Disulfide
Ethyl Benzene
Toluene
Xylenes
Site-Related Samples
Frequency of
Detection
1/38
1/38
1/1
1/38
1/1
Range of Detected
Concentrations
(ng/L)
3.0
1.7
2.0
1-0
7.0
Arithmetic
Mean
G«g/L)
NA
NA
NA
Background *
Sample
(McPherson
Spring)
dg/L)
0.55
$im'VO^jiL%';* !" ' -' "- "v^r^a* :, -- * rX
Bis(2-ethylhexyl)phthalate
Diethyl Phthalate
4/37
1/1
14-59
3.0
38
NA
NA - Not Applicable
* Background data was averaged. Only detected contaminants are reported. Blank spaces indicate it was below
the detection limit.
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Record of Decision
Caldwell Lace. Leather Site
June 30, 1994
A number of unaffected springs were sampled in February and May 1993. Aluminum was
detected in these springs at concentrations ranging from 330 ppb to 4.6 ppm. While the
concentrations are less than the maximum concentration observed in Duncan Tile Spring,
they are similar in magnitude and in the fact that they exceed regulatory criteria. Therefore,
even though the maximum aluminum concentration observed was in an affected spring,
comparison of aluminum concentrations from that spring with those from a number, or set,
of unaffected streams does not reveal a great discrepancy.
Bis(2-ethylhexyl)phthalate
Bis(2-ethylhexyl)phthalate was detected four times ((Mud River, Green Boiling, Lagoon, and
Barnett-Karst springs). The contaminant concentrations ranged from 14 - 59 ppb. The
primary MCL for bis(2-ethylhexyl)phthalate is 6 ppb. Now AWQC has been established for
the contaminant. Due to the infrequency with which this contaminant was detected, the
detections are more likely due to sampling or laboratory artifact than actual contaminant
presence.
Chromium
Samples taken from the springs used as monitoring points for the RI were sampled for both
trivalent and hexavalent chromium. Hexavalent chromium, the more toxic form, was
detected in concentrations ranging from 1 ppb to 10 ppb. All reported concentrations were
less than the AWQC for hexavalent chromium for protection of aquatic life from chronic
toxicity, which is 11 ppb.
Trivalent chromium was detected in concentrations ranging from 17 ppb to 21 ppb. All
reported concentrations were below the AWQC of 117 ppb for chronic toxicity resulting
from exposure to trivalent chromium.
The primary MCL for chromium is based on total chromium, without regard to its valence
state. The primary MCL for chromium is 100 ppb. All samples for either trivalent or
hexavalent chromium were below the primary MCL, and even adding the highest trivalent
result to the highest reported hexavalent result yields a combined concentration of only 31
ppb, also well below the primary chromium MCL.
Only one spring sampled for chromium by ESD contained 6.1 ppb of total chromium. Wells
sampled showed total chromium at 20 and 22 ppb.
Iron
Iron was detected in almost all ground water and surface water samples. Concentrations
ranged between 52 - 21,000 ppb. The AWQC is 1,000 ppb and the secondary MCL is 300
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
ppb. Two springs contributed to three of the highest concentrations observed, Duncan Tile
Spring and Runoff Spring. Unaffected springs average concentration was 220 - 8,900 ppb.
While the background concentrations are less than the maximum concentrations observed in
these two springs, they are similar in magnitude and in the fact they exceed regulatory
criteria.
Lead
Lead was detected five times in 43 ground water samples. Two of those five detections
occurred in the potable wells which were not demonstrated to be connected to the Site.
Positive results for lead were reported in three springs. Lead concentrations in ground water
ranged from 5.9-20 ppb. One of the springs (Duncan Tile Spring) and one residential well
exceeded the concentration established by CERCLA guidance for the protection of human
health via drinking water consumption (15 ppb). There is no numerical MCL for lead. The
chronic AWQC for lead as established by EPA is dependent upon the hardness of the water;
at 100 ppm hardness, the chronic AWQC is 1.32 ppb. Lead detected in the three Site-
related springs and in the background spring (McPherson Spring) did exceed the AWQC.
The reported lead concentrations should be considered to be naturally occurring in the
springs. The lead concentrations reported in potable wells is most likely due to household
plumbing.
Manganese
Manganese was detected in spring samples in concentrations ranging from 18 ppb to 4,200
ppb. The highest concentration was found in a sample obtained from Lagoon Spring. The
next two highest concentrations, 2,500 and 1,100 ppb were detected at McPherson Spring,
which is assumed to be unaffected by contaminant transport from the Site. In fact, in three
out of the five sampling events, the highest concentration of manganese was found in
McPherson Spring. Lagoon Spring and Duncan Tile had the highest manganese
concentrations in the other two sampling events.
No AWQC have been established for manganese for the protection of aquatic life. EPA has
established a secondary MCL of 50 ppb, which was exceeded by a number of spring samples
taken during the RI, including samples taken from Lagoon Spring, Mossy Spring, and
Barnett Karst Window, as well as McPherson Spring and Duncan Tile Spring. Of more
significance, however, is the fact that many of these samples also exceed EPA's health-based
criterion for the protection of public health via consumption of drinking water, which is 180
ppb, based upon an EPA-approved reference dose.
The set of unaffected wells sampled contained manganese in concentrations ranging from
nondetectable levels to 740 ppb.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Zinc
Zinc was detected in samples from potentially affected springs at concentrations ranging
from 6 ppb to 61 ppb. The chronic AWQC for zinc is 59 ppb, and the secondary MCL is
5 ppm. The highest concentration observed, obtained from Duncan Tile Spring in
association with a rainfall event, marginally exceeds the chronic AWQC for zinc.
The unaffected springs sampled by ESD contained zinc in concentrations ranging from 5 ppb
to 12 ppb.
4.1.8 SEDIMENT
Site sediment concentrations were compared to US EPA Region IV Waste Division sediment
screening values (January, 1992) which are based upon the National Oceanic and Atmospheric
Administration effects range values for sediment contaminants It should be noted these are just
screening tools and not standards.
Three contaminants of concern were identified based upon an exceedance of EPA Region IV
screening levels -- chromium, lead, and silver. Only sediment contaminants in Mossy Spring
exceeded sediment screening values. Chromium, zinc, and manganese were found at levels
more than twice levels found in the background spring. Although concentrations of some
chemicals in sediment were elevated near springs, the concentrations farther downstream were
generally at background levels and/or below screening levels. Results are presented in Table
4-6.
4.1.9 LEACHATE
A leachate sample was collected from an area adjacent to the leachate collection tank. The
results indicate a wide variety of organic and inorganic contaminants. Chromium and lead were
detected at estimated concentrations of 13 mg/1 and .44 mg/1, respectively. Also present were
mercury and cyanide at .002 mg/kg and .013 mg/kg, respectively. A number of organic acids,
alcohols and amines were detected at concentrations ranging from .01 - 1 mg/1.
4.2 ECOLOGICAL STUDY
EPA conducted three ecological surveys. Two of the field efforts were focused in a very
specific way on characterizing the biota of the Site and describing the communities which they
occupy. One of the field efforts took place during the dormant season constituting only a partial
accounting of species on Site. A subsequent survey was conducted to full assess the occurrence
of receptor organisms as well as threatened and endangered species during early summer.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-6
Caldwell Lace Leather Site
Contaminants Detected in Sediment
Sediment Analyte
Site-Related Samples
Frequency of
Detection
Range of
Detected
Concentrations
(mg/kg)
Arithmetic
Mean
(mg/kg)
Background
Sample
(SD-004)
(McPherson
Spring)
(mg/kg)
INORGANICS ' ' '\ - ';J£»&l»g. jh *JA££ %£" |4^
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 4-6 (Continued)
Caldwell Lace Leather Site
Contaminants Detected in Sediment
Sediment Analyte
Vanadium
Zinc
Site-Related Samples
Frequency of
Detection
10/10
6/10
Range of
Detected
Concentrations
(mg/kg)
8.6 - 59
38-77
Arithmetic
Mean
(mg/kg)
25.8
49.6
Background
Sample
(SD-004)
(McPherson
Spring)
(mg/kg)
25
NA = Not applicable. A mean cannot be derived from a single hit.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Tasks were formulated to identify general site and community boundaries and to determine
whether or not the various habitats had the capacity for supporting receptor species.
Field methods used during floristic and faunistic investigations employed both systematic walk-
through surveys and specialized habitat surveys. Quantitative information was also gathered in
order to generated comprehensive species and species abundance checklists. Habitat surveys
consisted of intensive visual screening of specialized habitats recognized as having the greatest
potential for supporting threatened and endangered species. At the CLL Site, these included
mesic limestone hillsides in boundary woodlands, small rock outcrops, sinkholes, moist
depressions, and pond margins. Informational needs in this regard were augmented through
literature reviews and contact with appropriate natural resource trustees.
The third field study focused on a habitat quality evaluation, ambient water quality
measurements, biosurveys and sediment toxicity tests. The eight springs included seven springs
shown by the dye-trace studies to be hydraulically connected to the Site (and thus potentially
affected by Site contaminants), plus one background springs not hydraulically connected to the
Site.
The following concluding statements summarize findings for ecological risk characterization:
• Many of the spring systems had only a limited aquatic habitat (e.g., intermittent stream,
no defined channel).
• Sensitive benthic macroinvertebrate species were found in spring systems that having
contaminated sediment (e.g., Mossy Spring).
• No toxicity was detected in any of the three sediment samples tested (i.e., Mossy Spring,
Mud River, and Lagoon Spring Pond).
The field efforts and sensitive species study enabled EPA to determine whether the CLL Site had
adversely impacted the environment. EPA determined that the species studied showed no
noticeable impairments. No rare, threatened, or endangered species were encountered on the
CLL Site or in conjunction with any outlying spring areas.
4.3 CONTAMINANT FATE AND TRANSPORT
The fate and transport of contaminants are related to the contaminants present, the soil type,
hydrogeologic features, and other site characteristics. The following discussion describes the
site-specific conditions that may affect contaminant transport.
The CLL Site was used for disposal of tanning wastes which were buried in the landfill area and
tilled into soils in the landfarm. As a result, the surface and subsurface soils were impacted.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Also, due to the karst topography of the area, it is probable that releases of the wastes in soil
have migrated to the ground water, surface water (springs) and sediments.
The Auburn, Kentucky area is typified by karst terrain involving underground streams,
intermittent springs, and sinkholes. These sinkholes and subsurface features result from solution
of channels which are formed by surface water percolating through the soil and eroding
sandstone and milestone formations, eventually allowing the permeable soils above to subside.
Most karst features are hydrogeologically significant because of their unique relation to the
ground-water system. They collect and discharge water into, store and transmit, or discharge
water from the ground-water system. Initially, flow diffuses through a large number of small
fractures. With time, a network of conduits begins to develop that carries an increasing
proportion of the flow. The development of sinkholes also contributes to the development of
the conduit system because surface water will begin to flow directly into the conduits. In a
mature karst system, runoff proceeds directly into tributary conduits and moves rapidly to the
spring or'springs at the downstream end of the basin.
Based on the physical and hydrogeological features present at the CLL Site, the potential exists
for migration of some of the more mobile contaminants already detected in Site ground water
and surface water. Due to the Site hydrogeology, chemicals entering the ground- water system
may be flushed from the ground- water system and discharged off-Site. The depth of the
ground-water table (30 to 40 ft.) in the area may help to slow the process of contaminant
leaching, and the extensive system of sinkholes and fractures helps dilute and disperse any
contaminant which does reach the ground-water medium. Important chemical factors in the
water such as the pH, redox potential, ionic strength of the water, and the concentration of ionic
complexes in the water all contribute to the fate of individual chemicals within the physical
terrain.
The pH of the soil, adsorption rates, organic content in the soil, redox potentials, and the
presence of sinkholes at the Site play significant roles in determining fate and transport.
Adsorption renders some chemicals relatively immobile, making transport unlikely. However,
the presence of sinkholes and/or fractures in the karst terrain may provide avenues for
contaminant migration into the ground-water medium as runoff waters feed into them.
Based upon the survey of the physicochemical, geological, and hydrogeological features at the
CLL Site, we would expect to find the majority of contamination to reside in the soil medium.
Most of the organics detected in Site soil are relatively immobile and have not migrated to
ground water or surface water. In addition, modeling indicated that chromium will not
significantly leach from Site soil, a conclusion supported by the fact that groundwater chromium
concentrators are well below MCLs. However, the potential does exist for some contaminants
to migrate into ground water through sinkholes, runoff and leaching.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
5.0 SUMMARY OF SITE RISKS
5.1 HUMAN HEALTH RISKS
A baseline risk assessment (BRA) has been conducted for the CLL Site and the results are
presented Volume 2 of the RI. The BRA was based on contaminated environmental Site media
as identified in the RI. It was conducted in order to provide an assessment of the resulting
impact to human health and environment if contaminated soils and ground water at the Site were
not remediated.
Based on the current and possible future land uses, four exposure scenarios were proposed:
current landfill trespasser, current landfann resident, future landfill resident and future landfill
farm worker. These scenarios represent the individuals with maximum potential exposure to
Site-related chemicals of potential concern. The four scenarios and their respective potential
exposure'pathways are listed in Table 5-1.
The CLL BRA concluded that the primary health risk posed by the Site is through ingestion and
inhalation of groundwater. Carcinogenic risks did not exceed 1E-4 and are therefore not
discussed in this ROD. The groundwater pathway posed a noncarcinogenic risk greater than
or equal to 1.0 for the current or future residential scenario.
5.1.1 CONTAMINANTS OF CONCERN
The selected contaminants of concern for ground water are shown include barium, chromium,
manganese, molybdenum, and vanadium. Of these, manganese was generally the most
frequently detected and found at the highest concentrations. Please refer to Table 5-2.
5.1.2 EXPOSURE ASSESSMENT
The objectives of the exposure assessment are to identify actual or potential exposure pathways;
characterize the potentially exposed populations; and to determine the extent of the exposure.
The results of the exposure assessment are combined with the chemical-specific toxicity
information to characterize the potential risks.
Ground-Water Use
The CLL Site is located in a rural part of Kentucky. The City of Auburn has not completely
developed the city water distribution in the Site area. Therefore, some individual residences
must have potable wells to draw ground water for their household needs. Under the document
entitled Guidelines for Ground-Water Classification Under the EPA Ground-Water Protection
Strategy (EPA, Final Draft December, 1986), the ground waters underlying the CLL Site are
classified as Class HA, i.e., a current source of drinking water supply.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 5-1
Exposure Scenarios and Potential Exposure Routes
Current
Landfarm Adult and Child Resident
• Incidental ingestion of surface water
• Dermal contact with surface water
• Incidental Ingestion of sediment
• Dermal contact with sediment
• Incidental ingestion of surface soil (landfarm)
• Dermal contact with surface soil (landfarm)
• Ingestion of groundwater
• Inhalation of groundwater volatiles while showering
• Ingestion of home grown produce*
On-Site Trespasser (Hunter)
• Incidental ingestion of surface soil (landfill)
• Dermal contact with surface soil (landfill)
• Incidental ingestion of surface water
• Dermal contact with surface water
• Incidental ingestion of sediment
• Dermal contact with sediment
Future
Landfill Adult and Children Resident
• Ingestion of groundwater
• Inhalation of groundwater volatiles while showering
• Incidental ingestion of surface soil (landfill)
• Dermal contact with surface soil (landfill)
• Incidental ingestion of surface water
• Dermal contact with surface water
• Incidental ingestion of sediment
• Dermal contact with sediment
• Ingestion of home grown produce*
On-Site Landfill Worker
• Incidental ingestion of surface soil (landfill)
• Dermal contact with surface soil (landfill)
• Incidental ingestion of subsurface soil (landfill)
• Dermal contact with subsurface soil (landfill)
* Potential pathway, but is recommended by EPA Region IV not to be quantitatively evaluated. See Section 3.2.2.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
Table 5-2
Caldwell Lace Leather Site
Exposure Point Concentrations of Contaminants
Detected in Groundwater
Groundwater
Analyte
Site-Related Samples
95% UCL of
Mean
Concentration
0*/L)
Maximum
Concentration
0«g/L)
Exposure Point
Concentration
0*/L)
*natt»f?*.iiatf* a '' •.-.'-' '' ^; •. ••* .. -r,c i'' -i*?,^ ' '; •• f-~*'"'%i:is":~<&-:£tii:& •!» 1'^':
INORGANICS , - , * - , 1- ,,. * £$&2v^ .. *i^$f;,Al f ^
Barium
Chromium
Manganese
Molybdenum
Vanadium
84.6
6.7
400
5.2
8.7
960
22
4,200
10
42
84.6
6.7
400
5.2
8.7
Land Use
The Site is located in a rural part of Kentucky. Land is used predominantly for livestock
grazing and farmland. Currently, a trailer home is located in the landfarm area. Also, the
potential exists for future use of the landfill area for cattle grazing or residential development.
Based on these current and possible future land uses, two exposure scenarios represent the
individuals with potential noncarcinogenic risk greater than 1.0. The two scenarios and their
respective potential pathways are listed below:
Current
Landfarm Adult and Child Resident
• Ingestipn of ground water
• Inhalation of ground water volatiles while showering
Future
Landfill Adult and Children Resident
* Ingestion of ground water
• Inhalation of ground-water volatiles while showering
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
5.1.3 EXPOSURE DOSE ASSUMPTIONS
Doses, expressed as chronic daily intakes in milligrams of contaminant per kilogram of body
weight on a daily basis (mg/kg-day), are calculated for each exposure route applicable to the
current residents and trespassers and the future residents and workers. For all the scenarios,
doses are averaged over the number of days of exposure (70 years of exposure x 365 days/year)
to evaluate chronic noncarcinogenic health effects.
The future resident scenario assumes that the Caldwell landfill area is converted to residential
use and that individual lives on the Site for 30 years. It is assumed that residents take two
vacations per year and therefore spend 350 days per year at home.
Three age groups are evaluated for the residential scenario: a child age 1-6, a child age 7-16,
and an adult. A body weight of 15 kg was used for the child age 1-6. A body weight of 45 kg
was used'for the child age 7-16 and was calculated from the mean (50th percentile) body weight
of male and female children reported for this age group. A body weight of 70 kg was used for
the adult future worker, adult trespasser and the adult current and future residents. The
exposure durations used in calculating ingestion of groundwater for the child age 1-6 was 6
years; the child age 7-16 was 10 years; and the adult was 14 years.
Drinking Water Ingestion
Drinking water ingestion is considered to be a potential exposure route for the current and
future adult and children residents. The drinking water ingestion rates used for children and
adult residents assume that all of his/her daily water intake occurs at home. The drinking
water ingestion rate for the child and adult resident is 2 L/day.
Inhalation While Showering
Volatile organic compounds (VOCs) may be released to indoor air through a variety of home
activities, including showering, cooking, dish washing, and laundering. Some researchers
believe that inhalation doses of VOCs through typical home water uses may be as great or
greater than doses from the ingestion of water. Based on experimental results for the
transfer of trichloroethene from water to air in the shower stall, McKone and Knezovich
(1991) report that inhalation exposures in showers could be equivalent to an ingestion
exposure of 1 to 2 liters.
Inhalation while showering is evaluated to account for that dose of VOCs received from non-
ingestion uses of water for the future adult and children residents. The dose from inhalation
of VOCs while showering is based on the maximum ingestion equivalent (2 liters) described
by McKone and Knezovich (1991). The ground-water ingestion model assumptions were
multiplied by the VOC concentrations in ground water to derive the VOC exposure rate.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
For the purpose of evaluating inhalation exposures, a VOC is defined as any organic
compound with a Henry's Law constant of IE-OS atm-m3/mole or greater and with a
molecular weight of less than 200 g/mole.
5.1.4 TOXICITY ASSESSMENT
The purpose of the toxicity assessment is to assign toxicity values (criteria) to each chemical
evaluated in the risk assessment. The toxicity values are used in combination with the estimated
doses to which a human could be exposed to evaluate the potential human health risks associated
with each chemical. Human health criteria (cancer slope factors and reference doses) developed
by the EPA were obtained preferentially from the Integrated Risk Information System (EPA,
1993b) or the 1992 Health Effects Assessment Summary Tables (EPA, 1992c). In some cases,
the Environmental Criteria Assessment Office (ECAO, 1992) was contacted to obtain criteria
for chemicals which were not listed hi IRIS or HEAST.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to contaminants of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals. Estimated intakes of contaminants of concern from
environmental media (e.g., the amount of contaminants of concern ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans).
Table 5-3
Chronic Reference Doses (RfD)
(mg/kg-day)
Chemical
Barium
Chromium (VT)
Manganese
Molybdenum
Vanadium
Oral RfD
7E-2
5E-3
5.0E-3 (Water)
5E-3
7E-3
Reference
IRIS, 1993
IRIS, 1993
IRIS, 1993
IRIS, 1993
HEAST, 1993
Inhalation
RfD
NC
NC
NC
NC
NC
Reference
—
—
—
—
—
ARAR
(mg/L)
2.0
0.1
0.05
(SMCL)
NA
NA
NC = Not of concern through this route of exposure.
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Record of Decision
Caldwell Lace Leather Site
June 30, 1994
5.1.5 TOXICITY SUMMARY ON THE CONTAMINANTS OF CONCERN
Barium - Very little is known about the human health effects of barium. The limited human and
animal data suggest that the cardiovascular system may be one of the primary targets of barium
toxicity. Cardiovascular effects include increased blood pressure, changes in heart rhythm, and
heart muscle damage. Evidence from case reports suggests that barium also may cause some
neurological effects.
Chromium - Adverse human health effects have been associated primarily with occupational
exposure to chromium (VI) salts from chromium plating manufacturing. These effects are
manifested by nasal irritation, pulmonary effects, contact sensitization, and kidney effects.
Evidence of contact sensitization reactions have been seen in both the inhalation and dermal
routes of exposure.
Manganese - The amount of manganese in a normal diet is about 2.5 to 5.0 mg/day. No cases
of illness from eating too little manganese have been reported in humans; however, in animals
it can interfere with normal growth, bone formation, and reproduction. Occupational exposure
to high levels of manganese results in mental disturbances, muscle pain, weakness, and lack of
coordination.
Molybdenum - Pastures containing 20 to 100 ppm molybdenum may produce a disease referred
to as teart in cattle and sheep. It is characterized by anemia, poor growth rate, and diarrhea.
Prolonged exposure has led to deformities of the joints. Hexavalent molybdenum compounds
were found to be more toxic. Gavage studies in rats showed fatty degeneration of the liver and
kidney. Another side effect of molybdenum exposure in toxic amounts is anemia due to
inducing copper deficiency. Molybdenum has also been shown to be a metal effecting the male
and female reproductive capacities by effecting spennatogenesis and embryogenesis,
respectively.
Vanadium - The inhalation of vanadium leads to vanadium pneumonitis and mild respiratory
distress including coughing, wheezing, chest pain, runny nose, and a sore throat. Renal and
gastrointestinal effects are common after ingestion of vanadium compounds.
5.1.6 RISK CHARACTERIZATION
The risk characterization is an evaluation of the nature and degree of potential carcinogenic and
noncarcinogenic health risks posed to hypothetical current and future residential receptors at the
CLL Site. EPA generally does not recommend remedial action when the cumulative site risks
at a site are less than 1E-4 and the noncarcinogenic hazard index is less than 1.0. The
carcinogenic risks are not provided in this discussion because they did not exceed 1E-4. Both
carcinogenic and noncarcinogenic chemicals are evaluated for potential noncarcinogenic effects.
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Caldwell Lace Leather Site
June 30, 1994
The potential for noncarcinogenic effects is evaluated by comparing exposure level over a
specified period (e.g., life-time) with a reference dose derived for a similar exposure period.
The ratio of exposure to toxicity is called a hazard quotient (HQ). By adding the HQs for all
contaminants of concern that effects the same target organ (e.g., liver) within a medium or
across all media to which a given population may be reasonably be exposed, the Hazard Index
(HI) can be generated.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RfD
Where:
HQ = Hazard quotient
GDI = Chronic daily intake (averaged over the exposure period) (mg/kg-day)
RfD = Reference dose (mg/kg-day)
Hypothetical noncarcinogenic risks that exceeded an HI of 1.0 were:
• Current landfarm residents
• Future landfill residents
Potential Risks Associated with Current Resident
The total hazard index for the current residents age 1 to 6 years old, age 7 to 16 years
old, and the adult were 12, 4, and 2, respectively (Tables 5-4). The majority of the risk
by chemical was due to manganese through ground-water ingestion. For 1 to 6 year-
olds, manganese contributed 10 of the HI of 12. For the youth (7-16 years old) the
hazard index for manganese was 3 out the HI of 4. The adult hazard index for
manganese was 2 of the 2 total. Only the ingestion of ground-water pathway exceeded
the HI of 1.0; all other pathways did not exceed the unity value.
Potential Risks Associated with Hypothetical Future Resident
The total hazard index for the future scenario 1-6 year-old child was 12 (Table 5-4)
through the ground-water ingestion pathway. Ingestion of ground water contributed 11
to the total (assuming that the child consumes 2 L/day of ground water). Of the total
hazard index, manganese contributed nearly all of the risk in the ground-water pathway.
The total hazard index for the 7-16 year old is 4 (Table 5-4). The ground-water use
pathway contributed nearly all of the total noncancer risk for this age group, with
manganese contributing nearly all of the risk.
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Table 5-4
Total Hazard Index
Using Reasonable Maximum Exposure Concentrations
Exposure
Medium
Groundwater
Surface Water
Sediment
Landfarm
Surface Soil
Landfill
Surface Soil
Subsurface
Soil
Total HI
Current
Resident
1-6 yr. old
Manganese - 10
Barium - 0.2
Chromium - 0.2
Molybdenum - 0. 1
Vanadium - 0.2
NE
NE
Arsenic -0.2
Chromium - 0.5
NE
NE
12
7-16 yr. old
Manganese - 3
None
None
None
NE
NE
4
Adult
Manganese -2
None
None
None
NE
NE
2
Future
Resident
1-6 yr. old
Manganese - 10
Barium - 0.2
Chromium - 0.2
Molybdenum - 0. 1
Vanadium - 0.2
NE
NE
NE
None
NE
12
7-16 yr. old
Manganese - 3
None
None
NE
None
NE
4
Adult
Manganese - 2
None
None
NE
None
NE
2
NE - Not Evaluated
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The total hazard index for the future adult resident was 2 (Table 5-4). The ground-water
pathway contributed a hazard index of 2 due to manganese.
5.1.7 UNCERTAINTIES IN RISK CHARACTERIZATION
The principal goals of the uncertainty analysis are to provide to the appropriate decision makers
a discussion of the key assumptions made in the risk assessment that significantly influence the
risk results and to assess the contribution of these factors to the under- or overestimation of risk.
The uncertainty analysis should show that the calculated risks are relative in nature and do not
represent an absolute quantification.
In recent months, the EPA has placed even more emphasis on the uncertainty analysis. In a 26
February 1992 memorandum from the Deputy Administrator to all assistant and regional
administrators, EPA provides additional guidance on explaining risks and all their underlying
data so that the strengths and weaknesses of the assessment become clear.
In the absence of empirical or site specific data, assumptions are developed based on best
estimates of data quality, exposure parameters, and dose-response relationships. To assist in the
development of these estimates, the EPA recommends the use of guidelines and standard factors
in risk assessments conducted under CERCLA. The use of these standard factors is intended
to promote consistency among risk assessments where assumptions must be made. Although the
use of standard factors no doubt promotes comparability, their usefulness in accurately predicting
risk is directly proportional to their applicability to the site-specific conditions.
The carcinogenic and noncarcinogenic risk estimates for the CLL Site were based on a number
of assumptions that incorporated varying degrees of uncertainty resulting from several sources,
including:
• Data evaluation.
• Selection of exposure pathways, input parameters, algorithms, and scenarios.
• Confidence in lexicological data used to estimate cancer potency factors and
reference doses.
5.1.8 RISK ASSESSMENT CONCLUSIONS
The ingestion of ground-water pathway for current and hypothetical future residents exceeded
the HI of 1.0; all other pathways did not exceed the unity value. For the following reasons,
EPA has determined that the CLL Site does not pose unacceptable risk to human health.
Manganese is primarily responsible for the elevated ground-water hazard indices in the risk
characterization. Consistent with EPA guidance, manganese is not eliminated from the chemical
of concern list because its maximum detection (4,200 /tg/L) exceeded two times background
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Caldwell Lace Leather Site
June 30, 1994
(1,085 jtg/L, Table 4-4). However, the exposure point concentration (Table 5-2) for manganese
in ground water is 400 pg/L which is less than background. Even though the hazard index
calculated with the exposure point concentration is above unity, it is also indicative of the hazard
indices that could be generated with the background concentration for manganese. Manganese
concentrations observed during the RI are likely to be naturally occurring. Manganese is often
enriched in carbonate sediments. The enrichment of manganese in limestones, sandstones, shales
and clays is most likely accounted for by manganese substituting for similar ions, like calcium.
Chromium is another metal contributing to the elevated ground-water hazard indices in the risk
characterization. There are many uncertainties associated with toxicity values, especially those
that are derived from studies in laboratory animals. The form in which a metal occurs can
greatly influence it toxicity potential (e.g., hexavalent chromium is more toxic than trivalent
chromium). Data collected during the RI did not show detections of chromium VI in any
samples except for one ground water sample (10 ug/1). Also, chromium VI is not typically
associated with tanneries and their waste streams, but in the CLL Risk Assessment EPA Region
IV conservatively assumed that all chromium is in the hexavalent form.
For a risk to exist, both significant exposure to the pollutants of concern and toxicity at these
predicted exposure levels must exist. The lexicological uncertainties primarily relate to the
methodology by which carcinogenic and noncarcinogenic criteria (i.e., cancer slope factors and
reference doses are developed. In general, the methodology currently used to develop cancer
slope factors and reference doses is very conservative, and likely results in overestimation of
human toxicity (e.g., reference doses are estimates with an uncertainty spanning perhaps an
order of magnitude or greater).
5.2 ECOLOGICAL RISKS
5.2.1 HABITAT AND BIOTA SURVEYS
Biologists conducted field investigations (walk-through surveys) of the CLL Site consisting of
qualitative inventories of occurrences and extent of major community types, presence of surface
water and associated drainage patterns, potential wetlands, and signs of gross surface
contamination. The field investigations included the CLL Site and eight off-Site springs which
dye traces indicated might be impacted by the CLL Site.
From the ecological perspective, the CLL Site is typical of most culturally impacted areas within
the Western Escarpment Physiographic Province. Land use practices have resulted in a wide
range of disturbance regimes that span all stages of successional development. Community
associations therefore contain elements characteristic of each of these successional types. The
purposeful and accidental introduction of exotic plant species has also had a profound influence
on regional floristic diversity.
The varied plant life observed at the Site offers the indigenous fauna many habitat opportunities
and a bountiful food supply. The numerous mast, browse, seed, and forage species signals a
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Caldwell Lace Leather Site
June 30, 1994
potentially complex pollutant pathway.
No rare, threatened, or endangered species were encountered on the CLL Site or in conjunction
with any of the Springs.
5.2.2 SURFACE WATER
The most likely pathway for contaminants to migrate is via natural springs and the karst geology
in the vicinity. To qualitatively determine whether surface water contaminants might pose a risk
to aquatic life, site concentrations were compared to the Ambient Water Quality Criteria
(AWQC) and the Kentucky surface water standards. After comparing surface water
concentrations to Region IV chronic screening values, several contaminants exceeded the values
suggesting a potential adverse effect on aquatic biota.
Five chemicals of concern for surface water exceeded the surface water quality values:
aluminum, chromium, iron, lead, and bis(l-ethylhexyl) phthalate. Aluminum exceeded acute
standards by two-fold in all eight springs. Chromium exceeded screening values only if
chromium VI is considered, and then only slightly in three springs. Iron exceeded chronic
screening values in six springs and acute screening values in Mossy Spring and Lagoon Spring.
Lead exceeded chronic screening criteria in three springs. Lead exceeded chronic screening
criteria in Duncan Tile, Mossy Spring, and the Runoff Spring. However, Duncan Tile Spring
has a poor stream structure and the Runoff Spring is an intermittent spring, thus indicating that
chronic effects related to lead in surface water would be limited. Bis(2-ethylhexyl) phthalate was
detected in four springs and in all instances exceeded the chronic screening value indicating a
low to moderate risk to aquatic life. Most of the surface water samples which exceeded AWQC
or state surface water standards were either within two times the concentration found in the
background spring (i.e., McPherson Spring) or were found in springs having a poor physical
aquatic habitat (e.g., poor stream structure of Duncan Tile Spring; intermittent nature of Runoff
Spring).
5.2.3 SEDIMENT
Site sediment concentrations were compared to US EPA Region IV Waste Division sediment
screening values (January, 1992) which are based upon the NOAA effects range values for
sediment contaminants. It should be noted these are just screening tools and not standards.
Only sediment contaminants in Mossy Spring exceeded sediment screening values. Lead
exceeded the NOAA (Effects Range-Low) ER-L while chromium and silver exceeded both the
ER-L and the (Effects Range-Median) ER-M screening values.
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Caldwell Lace Leather Site
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5.2.4 ECOLOGICAL RISK CHARACTERIZATION
The following concluding statements summarize findings for ecological risk characterization:
• No threatened or endangered species were observed at the site or in the spring
systems.
• Many of the spring systems had only a limited aquatic habitat (e.g., intermittent
stream, no defined channel).
• Although concentrations of some chemicals in sediment were elevated near
springs, the concentrations farther downstream were generally at background
levels and/or below screening levels.
• Sensitive benthic macroinvertebrate species were found in spring systems that
having contaminated sediment (e.g., Mossy Spring).
• No toxicity was detected in any of the three sediment samples tested (i.e., Mossy
Spring, Mud River, and Lagoon Spring Pond).
• Most of the surface water samples which exceeded AWQC or state surface water
standards were either within two times the concentration found in the background
spring (i.e., McPherson Spring) or were found in springs having a poor physical
aquatic habitat (e.g., poor stream structure of Duncan Tile Spring; intermittent
nature of Runoff Spring).
5.2.5 ECOLOGICAL UNCERTAINTY ANALYSIS
Ecological risk assessments, like human health risk assessments, are subject to a wide variety
of uncertainties. Virtually every step in the risk analysis process involves numerous assumptions
and unknowns which contribute to the total uncertainty in the final evaluation of potential risk.
In general, the main sources of uncertainty can be attributed to the following areas:
• Environmental chemistry and sampling analysis
• Environmental parameters (i.e., pH, TOC, flow rates, etc.)
• Exposure assumptions
• Interpretation and application of toxicological data
Two major sources of uncertainty in an ecology risk assessment are the interpretation and
application of toxicological data in the toxicity assessment. Frequently, data from literature
sources are inadequate and regulatory criteria for many chemicals are unavailable. In addition,
regulatory criteria are based on the general protection of animal and plant life, and can not be
considered as distinct levels of toxicity for aquatic life in all situations. Variations in species
sensitivity may differ due to some of the following factors: dose-response behavior (toxicity),
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Caldwell Lace Leather Site
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tolerance thresholds, symptomatic behavior, delayed response behavior, and metabolic
differences.
6.0 SCOPE AND ROLE OF RESPONSE ACTION
EPA has determined that no action is necessary to provide protection for human health or the
environment. The results of the RI, including the Risk Assessment, indicate that there are not
current or future risks from exposure to soils, sediments, or surface water. However, there is
currently no feasible way to determine whether future ground-water risks would be a significant
threat to human health or the environment because of the unpredictability of karst topography.
Consequently, EPA is recommending that the Commonwealth of Kentucky or the current landfill
owner continue spring monitoring because this is the primary pathway by which the landfill
portion of the Site could potentially impact human health or the environment in the future. The
current landfill owner has expressed his intentions to improve the landfill area for wildlife.
Several management practices can be incorporated into ongoing land management activities that
would enhance the property for a wildlife habitat. Regardless of the proposed wildlife habitat,
EPA recommends mat future land use restrictions be placed on the landfill property, as well
maintenance of the landfill cover, to prevent land use activities that would expose the subsurface
waste to human contact or the environment. Since EPA is not proposing to take a cleanup
action, these land use restrictions would be voluntarily implemented by the landowner, or put
in place by the Commonwealth of Kentucky or local government. The land-use restrictions
would further reduce any potential future risk connected with the CLL Site.
EPA will continue to review information from the Commonwealth of Kentucky or any other
entity to ensure acceptable health or environmental standards are maintained. In the event any
monitoring indicates levels that pose unacceptable risk to human health or the environment, the
Site shall be restored to the NPL without application of the HRS (40 CFR §300.425(e)(3)). EPA
could initiate cleanup actions in the future pursuant to CERCLA and in accordance with the
NCP.
The Record of Decision is the only Record of Decision contemplated for the CLL Site. EPA
has determined that its response at this Site is complete and therefore recommends the Site for
inclusion on the Construction Completion List.
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APPENDIX A
RESPONSIVENESS SUMMARY
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
PUBLIC INFORMATION MEETING
FOR THE
CALDWELL LACE LEATHER
SUPERFUND SITE
APRIL 26, 1994
7:00 p.m. C.D.T.
FIRE HALL, AUBURN, KENTUCKY
REPORTER: SANDRA SMITH SHERRELL
513 East 10th Street, Suite A1C
Bowling Green, KY 42101
(502)-782-1096
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The following is the
PUBLIC INFORMATION MEETING FOR THE CALDWELL LACE LEATHER
SUPERFUND SITE held on April 26, 1994 at 7:00 p.m. Central
Daylight Time at the Fire Hall in Auburn, Kentucky pursuant
to Public Notice in the local newspapers.
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APPEARANCES
MS. SUZANNE DURHAM:
Community Relations Coordinator
for the Caldwell Lace and Leather
Site in Auburn, Kentucky with the
U. S. Environmental Protection
Agency, Region IV, Atlanta,
Georgia.
MS. BETH BROWN:
Remedial Project Manager for the
Caldwell Lace and Leather Site in
Auburn, Kentucky with the U. S.
Environmental Protection Agency,
Region IV, Atlanta, Georgia.
MR. HAROLD W. TAYLOR, JR:
Chief of the Kentucky/Tennessee
Section of the North Superfund
Remedial Branch with the U. S.
Environmental Protection Agency,
Region IV, Atlanta, Georgia.
MR. RICK HOGAN:
Commonwealth of Kentucky
Superfund Program.
Natural Resources and
Environmental Protection Cabinet
Frankfort, Kentucky
MR. WILLIAM M. HILL:
Commonwealth of Kentucky
Superfund Program.
Natural Resources and
Environmental Protection Cabinet
Frankfort, Kentucky
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INDEX
NAME
MS. DURHAM
MS. BROWN
MS. DURHAM
MS. BROWN
and
MR. RICK HOGAN
TEXT PAGE
Introduction and Welcome 4-5
Presentation 7-20
Community Relations 21
Questions & Answers 22-26
Robyn Minor
Todd Bratcher
Certification
28
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INTRODUCTION AND WELCOME
MS. SUZANNE DURHAM: Good evening. My
name is Suzanne Durham. And, I'm the Community Relations
Coordinator for the Caldwell Lace and Leather Site, here in
Auburn, Kentucky. I am with the U. S. Environmental
Protection Agency out of Atlanta, Georgia.
The purpose of
tonight's meeting is to tell you about EPA's long term
investigation which we've conducted here over the past
couple of years, to tell you exactly what we have found, and
then what we're proposing to do at the site.
But, most
importantly, we are here to hear from the community and
those who are most effected by the site.
Before I go any.
further, I'd like to introduce the EPA and Commonwealth of
Kentucky staff who are here with us.
On the front row
here is Beth Brown. She's the Remedial Project Manager who
handles the day to day technical activities at the site.
And, you've, probably, seen her in your community for the
last couple of years.
To her right is
-------
Harold Taylor. He's Beth's supervisor as well as mine.
He's the Chief of the Kentucky/Tennessee section of the
North Superfund Remedial Branch, also, in Atlanta, Georgia.
To my right, I have
Rick Hogan and Billy Hill, who are both with the
Commonwealth of Kentucky Superfund Program.
And, with us
tonight, we have the local Magistrate and someone from the
Solid Waste Program here in Logan County.
We thank all of you
for coming.
Again, we're going
to keep the presentation short so that you all can get right
on into your questions and answers.
I had a seventeen
(17) minute video to show the Superfund Program from site
discovery through the decision making process, but, I think,
we're just going to cut that out and let Beth go right on
into her investigation, what she found, and what we're
proposing to do.
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PRESENTATION
BETH BROWN: Okay. I'm Beth
Brown, and I'll be presenting what EPA has done the past few
years at the Caldwell Lace Leather Superfund Site.
If you have any
questions during my presentation/ I'll try and answer them
if they are a brief answer. Otherwise, I may wait until the
end to try and address your questions.
Okay. The site's
located about two point five (2.5) miles northwest of the
city of Auburn.
The reason why EPA
became involved at the site was we had concerns about the
nature of the waste that was disposed at the site, the
volume of the waste that was disposed at the site, and the
potential for the waste to migrate to ground water or
surface water and effecting those who might drink from
groundwater or surface water.
All the information
that I'm going to be presenting this evening can be found in
the Administrative Record that's located either in
Russellville, or you can contact EPA Region IV in Atlanta.
I've, also, brought
-------
some material if you're interested after the meeting, the
maps of dye traces that we've done, a summary of the
investigation that we've done, and some aerial photos.
Okay. The reason
why the site is here in Auburn is because the tannery that's
located in downtown Auburn. The tannery was in operation
from the late 1800's until, approximately 1985, when they
changed their tannery operation and are no longer producing
or tanning. They're actually just doing leather cutting.
We don't know where
the disposal locatipns are prior to 1972 for the waste that
was generated from the facility.
But, we're concerned
with the Caldwell Lace Leather Site that's north of town.
The waste stream
consisted of cowhide scraps, fleshings, and the sludge.
And, it was disposed of in two (2) methods. It was either
landfilled or it was landfarmed. And, I'll discuss that in
more detail later on.
The site was placed
on EPA's National Priorities List in 1990, which made it
eligible for EPA to expend Superfund money.
Again, the reason
why we were concerned about investigating the site was the
8
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potential for the waste to migrate to groundwater or surface
water.
And, also, there is
someone that lives on a portion of the site that we were
concerned about/ him living there, what would happen. He,
also, grazes cattle, what would happen to the cattle or if
he sold the cattle for subsequent cow's milk.
So, those were the
questions we wanted to answer, so we performed a Remedial
Investigation which consisted of defining the nature of the
waste and the extent of the waste.
REPORTER'S NOTE: (During the
presentation Ms. Brown indicated on and referred to visual
aids continuously.)
Okay. If you
remember I referred to the landfill. It was — actually,
had several different time frames that the landfill operated
in. But, it's primarily this portion of the site.
Okay. And, the
other method of disposal was landfarming where basically
they took the waste water sludge and disked it into the soil
with a tractor and a plow. And, so this is this portion of
the site.
-------
Okay. And, lastly,
we were concerned about the landfill and potential migration
of waste on the surface onto this portion of the site, and
we refer to that as the southwest area.
Now, what these
symbols mean is, this is, basically, a sink hole. These are
trees. Here's another sink hole. And, here's another sink
hole on the southwest quadrant of the site.
Okay. So, in
summary, here are the areas that we are concerned about.
The old landfill area that operated from '72 to '82, and
then a portion of that landfill area they coined it or
termed it a "Residential Landfill," and at that time, that
was basically only receiving the cowhides and the scraps.
It was not receiving the sludges.
But, the residential
landfill is on the older part of the landfill. All that
area is in this circled area.
With the landfill
portion of the site, it actually was closed in 1985, and
they put a surface soil, about two feet (2') surface soil,
clay type of material, and they, also, vegetated that area.
We weren't real
concerned about the surface soil because they used clean
10 .
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soil to put — to place on top of the landfill.
We were, however,
concerned about the subsurface contamination, and its
potential to migrate down into the ground water and into the
springs.
The landfarm area
because of the method of disposal was basically disking, we
were only concerned about, probably, the top foot (!') of
soil. We didn't expect it to migrate or to have been
disposed below a foot (!').
The southwest
quadrant of the site, again, we were concerned with the
surface soil because that was the area that surface water
from the waste would leach onto that part of the property.
Okay. And, when I'm
referring to surface soil, or I'm sorry, the ground, surface
soil, we look at the top twelve to eighteen inches (12"-
18"), approximately a foot (1').
And, subsurface
samples were collected from about a foot (!') down to a
depth of about sixty feet (60') in some locations.
Okay. For right
now, I'm just going to discuss the landfarm and the
southwest quadrant because those were similar because we
11
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were only really concerned about surface soil, although we
did take some subsurface samples.
So, here's the land
farm. Here's the southwest quadrant.
As you can see, we
divided the site up into grids that basically were about one
(1) acre in size. And, the landfarm, we basically took nine
(9) samples out of each grid.
We, also, selected
some of the grids that we suspected received some of the
most contamination or, I'm sorry, most chemicals of concern
due to their disking method. And, that was primarily in
this area. So, in this area, we took subsurface samples
down to a depth of about three feet (3').
The southwest
quadrant, we took, again nine (9) samples, surface soil
samples, in each grid.
And, we, also, took
one (1) subsurface sample in the center of each grid.
Okay. Now, I'll
talk about the landfill. The landfill, we took a lot of
subsurface samples located in the trenches because we wanted
to get an idea of the nature of the waste that was put in
the trenches. So, those would be this actual — the hatched
12
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areas actually represent the areas that were trenched.
And, these trenches
were unlined so, they were, basically, the waste was,
basically, a pit was dug and the waste was just placed in
those trenches. So, again, here are some more trenches in
the hatched area.
All these little
hatched or circled areas represent a soil sampling location.
If you'll, also,
notice, we did take samples that were not located in the
trenches. We wanted to get an idea of whether or not waste
from those trenches was migrating out of the trenches. So,
that would be the purpose of locating those or locating
those soil borings out of the trenched areas.
To give you an idea
of what we found in the landfarm portion of the site, I'll
just give you an idea of some of the chemicals that were
detected, the frequency at which they were detected, and the
range of the concentrations.
The parts per
million expresses a very low concentration of that chemical.
For instance, one point six (1.6) part per million of
Arsenic. Well, a part per million can be represented as
like one (1) ounce of say Arsenic in one million (1,000,000)
13
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ounces of water.
To even give you a
better idea, we're talking about one (1) drop of that
chemical in a swimming pool, that would be one (1) part per
billion (1,000,000,000) of that chemical.
So, there in your
handout on the front table there are more tables of the
contaminants that were detected. So, I'm just going to go
ahead and skip through these, and if you have questions
about what we detected, we can talk about those later during
the question and answer period.
To understand
whether or not we had groundwater contamination we had to
have an understanding of the geology and the hydrogeology.
Most of you are
pretty familiar with the area and, probably, can tell me
more about it than I can tell you.
It's what we call a
karst geology regime, which is basically characterized by
sinkholes, springs, streams. And, the basic geology are
sandstones and limestones.
The site actually is
on an east/west trending sandstone, that forms a groundwater
divide. And, let me go ahead. What we did was to
14
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characterize groundwater flow was we conducted a dye trace.
And, I think, most
of you are, probably, familiar with the dye trace because
you've probably seen the fluorescent dyes they use to
determine which way the groundwater flows.
And, basically, they
— the United States Geological Survey performed the dye
trace for us. They placed bugs or detectors that had
charcoal filters in them all over the site area. They then
on several locations on the site, which I'll show you in
just a minute, injected dye.
So, wherever that
dye flowed from the site they detected it in the springs.
So, to give you an
idea, we had several injection points on the site and just
off-site.
And, what we found
was the groundwater flowed to the northwest and to the
southwest eventually discharging into Mud River.
To the northwest, it
eventually, the groundwater, eventually discharges into
Wiggington Creek, to the Gasper River.
So, what we wanted
to do was monitor those locations that we knew were in the
15
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direct flow path from the site should anything migrate out
of those trenches.
So, those locations
are indicated here. There were eight (8) locations that we
monitored.
We did not find that
the Auburn Spring was connected to our site in any way.
It's actually in a totally different hydrogeologic regime.
We monitored those
eight (8) springs for about one (1) year, consisted of five
(5) sampling events, two (2) of which were related to
rainfall.
If we had a
significant rainfall event, we wanted to find out when the
rain hit the waste whether or not you would have any
significant flushing of chemicals into the groundwater. So,
we did that twice.
And, we, also, did
three (3) other events over that year.
Chemicals that we
detected consisted of Chromium, Manganese, Barium, Vanadium,
and Beryllium.
To give you an idea
of the concentrations that we detected, again, I've prepared
16
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a table of the chemicals that we detected, frequency with
which we detected them, and then I compared them to drinking
water standards. There are Federal standards that EPA sets.
As you'll see, we
have an exceedance. Twenty (20) is above the drinking water
regulation of fifteen (15). And, we, also, have an
exceedance of this Phthalate.
Now, let me explain
the lead. We sampled several residential wells, and two (2)
of those, we were concerned that they had elevated levels.
So, immediately we went back and resampled those wells and
did not find lead contamination.
In older homes
because they use soldering you can often find lead because
of the plumbing. You can find lead in the tap water.
We notified those
residents that there was a potential problem. However, we
do not feel that they are site-related.
As far as the
Phthalate concerns, often in the laboratory analysis,
chemicals can be introduced into the samples, and because we
only detected it four (4) times we didn't feel like the
Phthalate was related to the site.
Because these
17
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springs can, also, be accessed by wildlife, we compared it
to Federal standards but take into consideration those
wildlife and what would happen to their systems if they
would ingest these concentrations.
We found we wanted
to look more closely at the Aluminum, the Chromium, the
Lead, Manganese, and the Phthalate.
Because there were
eight (8) springs, only three (3) of these had exceedances.
So, our ecologists or our biologists went to those three (3)
springs, the Mossy Spring, the Lagoon Spring, and the Mud
River Spring, and studied those springs to see whether or
not the levels of concentrations we were seeing were
effecting those bugs and critters. We determined that there
was no affect.
We had very
sensitive species living in those springs. It's kind of the
canary in the coal mine. These species would, if they exist
in those springs, would mean that there wasn't any effect or
any impairment to those, to the wildlife.
Also, as part of our
ecological study, we did surveys and actually walked the
site and spent several days in the spring and, also, in the
winter to get an idea of what kind of wildlife and what kind
18
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of plants were in the area.
We didn't find any
endangered species in the area.
And, again, we
detected sensitive species in that spring, in those springs.
And, we did not
detect any toxicity.
After we collect all
that data we want to find out whether or not anybody exposed
to those concentrations would suffer any adverse affects.
So, we looked at
someone living on the site, both the landfarm, and the
landfill, if it was a child, if it were an adult.
We, also, looked at
someone that is actually working on the land.
And, what we found
was because Manganese was detected at elevated
concentrations in some of those springs, someone drinking
from them might suffer adverse affects.
So, what we did was
we, also, looked at what we call the background spring, a
spring that wasn't related to the site.
And, what we found
was, the Manganese was just as high in that background
19
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spring as it was in the site-related spring.
Well, what we know
is because of the limestone, which is in this area,
Manganese is in limestone. So, we do not feel that the
elevated concentrations are necessarily related to the site
or pose any adverse affect.
So, to summarize, we
took samples in privates wells; we performed ecological
studies; we took soil samples both surface and subsurface;
we sampled the springs both water and the sediment in those
springs, and then we performed our Risk Assessment.
And, our conclusion
is that the Caldwell Lace Leather Site does not pose an
unacceptable risk.
Because you have
waste left in place, EPA is recommending to the State or to
the current landfill owner that they continue to monitor the
springs, that they place future land-use restrictions on the
landfill so that the waste won't be disturbed and no one
will be exposed to it, and lastly, EPA will review any of
this information that the State collects or any other
individual and we'll review it and, if necessary, we'll
visit the site again.
20
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SUZANNE DURHAM: Lastly, I want to
tell you all that the public has thirty (30) days to come in
over to comment on EPA's Administrative Record which is here
in the Logan County Public Library and to comment on our
proposed plan of action.
If you need
additional time, we can grant an additional thirty (30) day
extension.
We will keep you
informed through fact sheets and notices in your local
paper. After the final decision is made I will publish a
notice here in the local papers for you.
And, now, I think
we're ready to move right on into the question and answer
period. I will ask that you stand, state your name, spell
it if it's an unusual spelling.
I will, also, ask
that each person only ask two (2) questions each or two (2)
comments, and then we'll move onto someone else and then
come back. I promise we'll answer each and every question
before the night is over.
First question?
Surely someone has a question or a comment.
21
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QUESTIONS AND ANSWER SESSION
ROBYN MINOR
DAILY NEWS:
My question is about
health risk assessment. Was there any kind of survey done
to any people living near the area as far as any/ you know,
asking them if they've had any particular health problems or
anything like that?
BETH BROWN: No, ma'am. And, the
reason for that is because we didn't find any chemicals at
concentration that caused us concern that would lead us to
do those kind of studies.
ROBYN MINOR: What about the
chromium levels? You didn't say too much about that, but
they seemed quite a bit higher than background levels on
both the soil and the water?
BETH BROWN: Okay. We did find
Chromium at elevated concentrations in the subsurface waste
which is to be expected in the landfill.
In the surface soil,
however, we did not detect the Chromium at concentrations
22
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that caused us concern.
ROBYN MINOR: How much money has
the Federal Government spent on this site investigation so
far?
BETH BROWN: To the best of my
knowledge, I don't have a number for you. But, I feel
comfortable in saying we have not spent five hundred
thousand ($500,000.00).
If you're interested
in a more accurate number, I can get back to you on that.
23
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MS. DURHAM: Are there other
questions?
TODD BRATCHER
LOGAN COUNTY HEALTH DEPARTMENT
In regards to the
recommendation on future land use restrictions for the
landfill property, what did you specifically have in mind?
BETH BROWN: Well, we prefer not
to see any building of houses or any weight bearing
structures because the nature of the waste is not solid so
that you could have some subsidence. And, we don't want any
pressure being put on that, the waste, because it could be
exposed to the surface then.
TODD BRATCHER: Who is the current
owner of the property?
BETH BROWN: Mr. Joe Hewlett, I
believe, is the current —
TODD BRATCHER: A single owner?
BETH BROWN: It may be through a
24
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corporation.
TODD BRATCHER: Well, do they — are
they aware of this recommendation?
BETH BROWN: Yes, sir, they are.
And, they have
expressed their willingness to continue monitoring and to
emplace some kind of future land use restrictions.
TODD BRATCHER: Okay. So, the
current owner or corporation has, at least, accepted to
continue to monitor?
BETH BROWN: Yes, sir.
And, they will
pursue that or actually the State of Kentucky, we believe,
is going to pursue that through some kind of order.
TODD BRATCHER: Are you aware of
that?
RICK HOGAN: Yes. That's
correct.
25
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TODD BRATCHER: Okay. And, what
would that be, or do you know what type of order you'll be
delegating to who?
RICK HOGAN: We would hope to
accomplish an Agreed Order which would be a written
agreement between the responsible party and the State of
Kentucky which would commit them to, among other things,
continue to monitor the site and to place some sort of deed
restriction on the property which would prevent any
intrusive activity.
TODD BRATCHER: Thank you.
26
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BETH BROWN: Anybody else have
any questions? If not, we'll stay afterwards, too, if you
want to come up and talk to us.
SUZANNE DURHAM: Anybody else?
Well, if not, we
thank you all for coming tonight.
We want to
officially thank the City for the use of the Fire Hall and
the local school for the use of their audio/visual
equipment.
Thank you all, and
good night.
27
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STATE OF KENTUCKY )
)
COUNTY OF WARREN )
I, Sandra Smith Sherrell, a Notary
Public in and for the State of Kentucky at Large, do hereby
certify that the forgoing Public Information Meeting was
taken by me at the time, place, and for the purposes
mentioned in the caption; that said Public Information
Meeting was taken by me in shorthand notes and by tape
recording and thereafter reduced to a typewritten transcript
under my direction; that no request was made by any party
that the transcript of said Public Information Meeting be
submitted to anyone for reading and signature; that said
transcript is a true and accurate Record of said taking to
the best of my ability.
Given under my hand on this May 4,
1994.
SANDRA SMITH SHERRELL, NOTARY PUBLIC
State of Kentucky at Large.
My Commission expires: 10/14/97.
28
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APPENDIX B
STATE CORRESPONDENCE
-------
ENUIROfENTAL PROT.
564 2705 06-27-94 12:04PM
[35] 82
PHILLIP J. SHEPHERD
SECWETAHV
BRERETON C. JONES
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT »-OH ENVIRONMENTAL PROTECTION
FRANKFORT OFFICE PARK
14 REILLY ROAD
FRANKFORT KENTUCKY 4O601
June 24,1994
Ms. Beth Brown, RPM
North Superfund Remedial Branch
Waste Management Division
United States Knvironmental Protection Agency
345 Courtland Street, N.K.
Atlanta, .Georgia 30365
Re: caldwell Lace Leather Superfund Site
Draft Kecord of Decision
Dear Ms. Brown,
The Commonwealth of Kentucky, Division of Waste Management, has
reviewed the Draft Record of Decision for the Caldwell Lace Leather
Site and finds it to be a complete and accurate representation of
the investigative activities which have occurred there. However, we
believe the data generated by that investigation do not support
EPA' a determination that no remedial action is necessary. To the
contrary/ the Remedial investigation Report concludes that the
additional cancer risk to future residents is 3 in 100,000, which
is significantly in excess of Kentucky's de minimus risk level of
1 in 1,000,000 and which should trigger remedial action and/or risk
management .
Kentucky, therefore, does not concur with the "selected remedy."
We hope that you reconsider this decision and will be glad to meet
at your convenience to discuss alternative solutions.
Sincerel
Caroline P. HaightT4"Director
Division of Waste Management
Printed on Recycled Paper
An Equal Opportunity Employer M/I-/D
-------
Caldwell Lace Leather Superfund Site
EPA Response to KYDEP Comments on the
Baseline Risk Assessment
GENERAL COMMENTS
KYDEP COMMENT #1: Too little investigation has occurred in each media of this
property and in areas off-site (USEPA, 1989, December).
Response: The EPA Office of Health Assessment (OHA) and Waste Management Division
(WMD) considered the sampling performed as the basis for this baseline risk assessment to
be adequate. Comments received from KYDEP Division of Waste Management apparently
do not agree with the KYDEP Risk Assessment Section, because no mention was made of
too little investigation. Also, it is important to note, that during the three and one-half years
that the RI was conducted, KYDEP never made this comment. KYDEP's Risk Assessment
Section representatives were asked to attend Site visits, agreed to attend the Site visits and
then would not attend.
What would KYDEP consider an adequate investigation in each media? Where would
KYDEP suggest samples be taken, what kind of samples should be taken and how often?
Please provide clarification so that EPA may respond.
KYDEP COMMENT #2: Potentially completed pathways appear to have been excluded for
the soil exposures based on too few sampling points.
Response: It is not clear to which "potentially completed pathways" the KYDEP is
referring. How does KYDEP define too few sampling points? Please provide clarification
so EPA may respond.
KYDEP COMMENT #3: Risk for certain receptors would likely result from a combination
of exposures from both the landfill and landfarm, yet exposures have been considered to
come from one or the other.
Response: It was assumed the two land areas were of sufficient size to support two separate
residential populations and there would not be a need to combine exposures. Also, because
KYDEP had approved landfill closure, which consisted of placing "clean soil" over the
landfill, the landfill surface soil was not considered to be a problem. However, the landfarm
was considered to potentially have contaminated surface soil.
KYDEP COMMENT #4: Groundwater investigation included little data from on-site and
the off-site data was generally treated as if it were att equally representative of the Caldwell
site. Most of the wells and all springs sampled were located off-site, yet results from att of
them appear to have been grouped together to obtain a site mean.
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 2 of 31
Response: The exposure point concentrations for ground water were developed following
Region IV guidance. The lessor of the 95 % upper confidence limit (UCL) of all Site-related
samples and the maximum detected concentration was used. Data from springs hydraulically
connected to the Site and those possibly Site-related were grouped together to develop the
exposure point concentration. The springs, although off-Site, are representative of
groundwater quality from the CLL Site. Please refer to the RI Section 5.0 and Appendices
A and C which explain the groundwater investigation. Appendix D of this document
provides groundwater ingestion risks based on individual springs.
KYDEP COMMENT #5: Chemical background values where generated from a single off-
site source atypical of sources sampled elsewhere. The McPherson Spring appeared to
reflect conditions characteristic of a stagnant pool or small wetland.
Response: Although McPherson had lower pH and conductivity values, the flow was not
atypical of other springs observed in the Site vicinity. Chemical concentrations from
McPherson were not statistically different for most of the chemicals of concern. McPherson
is a spring that does not always have flow, which is not uncharacteristic of karst topography.
U.S.G.S made the recommendation that this spring be considered as background because it is
not Site-related. A number of private drinking water wells and springs, not established as
being hydraulically connected to the Site, do provide control data for comparison with Site-
related springs.
KYDEP COMMENT ft6: Numerous chemical of concern (COC's) were eliminated from
consideration based on unacceptable methods (e.g., iron because it is an essential element;
manganese because its concentration is less than two times the background; and lead via
the "Lead Model #5".
Response: All methods of selection of chemicals of potential concern listed are acceptable
based on Risk Assessment Guidance for Superfund (RAGS) and Region IV Guidance
(Appendix A). Manganese has been added to the COC list.
Please see response to General Comment #s 10 and 16 for discussion of the two-times rule
and Lead Model.
KYDEP COMMENT #7: Means calculated for use in determination of intakes and risk
values were not clearly defined and almost certainly represent an underestimation of
chemical concentrations likely to exist in specific exposure pathways. Because of the
minimal sampling that was performed, the maximum concentrations probably should have
been used.
Response: Reasonable maximum exposure (RME) point concentrations were used as
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CLL Site
EPA Response to KYDEP Comments
June 17, 1994
Page 3 of 31
described in Section 3.4 of the Risk Assessment to quantify risk. The lessor of the 95%
UCL or the maximum detected concentration was used as the exposure point concentration
input in the RME calculation. Arithmetic means were provided for data summary purposed.
KyPEP COMMENT #8: Data from groundwater and surface water samples were
inappropriately combined to obtain site-wide means. From the tables of data, it is unclear
exactly what samples went into calculation of the averages.
Response: The ground water/surface water data are taken from the documents listed in
Section 1.3 of the Risk Assessment and presented in their entirety in the CLL RI. Please
refer to Appendix B of this document.
KYDEP COMMENT #9: Tables frequently provide "ranges" of data, but the individual
components of those ranges and/or means were generally omitted from the risk assessment.
The data from which the ranges are extracted should at least be referenced (e.g., Volume
U, Page 14).
Response: Complete data tables are included in the RI report (Volume I). Please refer to
Appendix B of this document for list analytical data used in calculating the means.
KYDEP COMMENT #10: Several assumptions (i.e., default values) and methods for
treating data were used that are not acceptable by the KYDEP (e.g., Two times the
background rule; elimination based on nutritional criteria; grouping of dissimilar samples).
Response: All assumptions, default values, and method for treating data are in accordance
with Region IV and/or EPA risk assessment guidance. The purpose of the two-times
background rule is to provide a conservative estimation of whether a chemical is significantly
different than background. EPA recognizes KYDEP's concerns and would prefer a statistical
comparison, like a T-test, but have found that statistical comparisons often eliminate more
chemicals of concern. The two-times rule is a more conservative method. EPA Region IV
is currently developing conservative guidance to deal with this issue.
KYDEP COMMENT #11: The ecological investigation reflected an apparent neglect of
aquatic organisms such as fishes in the waters capable of supporting them and of other
species that would likely exist below the surface in burrows or caves. Subsurface
exposures could be significant within and below the landfill and other potential hot spots.
Response: The primary goal of the supplemental field effort at and in the vicinity of the
CLL Site was to identify general site and habitat boundaries and determine whether or not
the various habitats have the capacity for supporting both receptor and indicator species. As
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 4 of 31
such, aquatic sampling was outside the scope of the investigation. However, ecologists did
confirm the presence of fish at two of the off-Site locations (8C Runoff and Mud River
Spring) and identified those species that were observed.
The studies performed included chemical analyses, toxicity testing, and
benthomacroinvertebrate community studies. Had any of these studies indicated problems,
the next step would have been a more detailed ecological investigation. See also response to
Specific Comment #46.
KYDEP COMMENT #12: Efforts to obtain relevant information on threatened and
endangered species of the area appeared to be virtually non-existent. Apparently, since no
site-specific study had been conducted previously, local regional studies were not
considered, important to the site's characterization.
Response: EPA believed the best and most productive way to gather site-specific
information would be the on-Site surveys conducted by WESTON ecologists familiar with
flora and fauna of Kentucky's Highland Rim and Shawnee Hills Sections. EPA did contact
Mr. Al Westerman, Risk Assessment Section of the KYDEP to attend on-Site surveys. The
U.S. Department of Interior (DOI), Fish and Wildlife Service office in Cookeville,
Tennessee was also contacted and invited to attend the on-Site surveys. Both parties agreed
to attend the surveys, but neither party attended. Throughout the RI, and especially during
the determination of what type of ecological studies should be performed, KYDEP and DOI
participated in the development of .those Site studies.
EPA did review the Environmental Assessment of the Headwaters of the Mud and Gasper
Rivers in the Vicinity of Auburn. Logan County. Kentucky prepared by KYDEP Division of
Water, 1987.
KYDEP COMMENT #13: Seemingly, very little information generated from previous
investigations was considered in the assessment. What efforts were made to research state
or federal agency records or to communicate with others regarding flora and fauna in the
area?
Response: See response to General Comment #12.
KYDEP COMMENT #14: Hexavalent chromium is likely to present significant risk via
groundwater ingestion, due in part to the presence of manganese oxide.
Response: The hexavalent chromium data were suspect so risk associated with its presence
was not quantified. However, as a conservative method, the total chromium data are
quantified using CrVI toxicity values. (Section 4.3.4.1). This procedure should have well
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 5 of 31
estimated any risk as the mean concentration for total chromium is greater than the CrVI
data.
KYDEP COMMENT #15: Azo dyes, many of which are carcinogenic and were used during
(he era of this tannery operation, (Brown, 1993), have apparently not been considered in
this assessment. They may not be present at the Site, but should be addressed.
Response: EPA suggests that if KYDEP is concerned about the presence of azo dyes, then
any sampling KYDEP conducts in the future, should include nitrates and nitrites. However,
nitrate in the drainage basins may be high because of fertilizer and cattle present in the basin.
SPECIFIC COMMENTS
KYDEP COMMENT #1
Section 1.2, pp. 1-8: Lead and chromium were detected in two drinking water wells during
February of 1991, but subsequent testing in May of 1991 did not
detect either chemical.
Different concentrations of these contaminants could result as
water levels and weather conditions change. Several samples taken
over a long period should be analyzed.
Response: These wells were not demonstrated to be Site-related, but EPA did provided all
private well owners of the sampling results. EPA suggests that if KYDEP has concerns
about these wells, that KYDEP continue to sample them.
KYDEP COMMENT #2:
Section 1.2, pp. 1-12: Figure 1-7 shows grids of the site with dimensions of 200 feet by 200
feet.
Grids of such large size would unlikely be sufficient for surface or
subsurface soil sampling in areas containing narrow trenches and
other potential spots of high contamination. They should be
further subdivided into smaller sections and each of the smaller
sections sampled. Several options for selection of sampling points
are provided in EPA document (USEPA, 1985).
Response: Apparently, there appears to be some confusion regarding the use of grids. EPA
did not just use grids, but also collected biased samples from areas of known trenches and
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 6 of 31
"hot spots". Please refer to RI, Section 3.6 which explains in detail the rationale for the size
grids. Section 4.1.3.2 provides the results with an explanation of the statistical confidence
that was achieved for this sampling pattern. These explanations should clarify your concerns
with regard to subdividing into smaller sections. The selection of sampling points were
selected based on statistically developed performance constraints utilizing various
representative sampling method guidance documents more appropriate for this Site than the
PCB spill cleanup guidance document to which KYDEP refers.
KYDEP COMMENT #3:
Section 2.1, p. 2-1: Chemicals of Concern listed in summary tables include only those
positively identified in at least one sample from a given medium.
This procedure assumes that all detection limits are low enough to
assure detection of chemicals at levels sufficient to create excessive
risk. The type and level of each detection limit used should be
clearly provided with results of analyses.
Response: The detection limit is included in the RI Appendices.
KYDEP COMMENT #4:
Arithmetic means were used.
It is unclear if arithmetic or geometric means have been used
throughout the assessment. From data provided, it seems likely
that a normal distribution does not exist, therefore, a log normal
would be used to calculate the upper Confidence Limits of means.
However, it appears that too few samples of any given medium or
location have been analyzed, (i.e., a minimum of 16 representative
data points are required).
Response: Please refer to Section 3.4 of the Risk Assessment which describes and provides
the calculation used to determine the reasonable maximum exposure (RME); the arithmetic
mean is not the RME. (It should be noted that at least 16 data points were used in
determining the arithmetic means).
KYDEP COMMENTS:
Means were calculated using the detected concentrations only.
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 7 of 31
This may be acceptable provided the non-detects are also excluded
from the number of samples composing the denominator of the
fraction: total contamination over number of samples. However,
elimination of non-detects when determining the background
concentrations is not acceptable, as it would likely result in a high
background level to which contaminants elsewhere are compared.
Response: This is a true statement and non-detects were also excluded from the
denominator. In the calculation of the 95% UCL, one-half the detection limit was included
in the calculation for all non-detects.
KYDEP COMMENT #6:
Screening of chemicals -was achieved by comparing the detected
concentrations to two times the background.
What is the technical basis for the two-times background
exclusion? The two-times background procedure is not accepted by
KYDEP. Often, background concentrations themselves are high
enough to present significant risks. Such a procedure might be
considered when determining the extent of remediation required,
but not for calculating the baseline risk.
Response: The comparison of site samples to two-times average background is consistent
with Region IV guidance. Please see response to General Comment #10. It should be noted
that the objective of Superfund remediation is not to reduce risk below background levels,
therefore risks from background concentrations of chemicals are not included in the
CERCLA process.
KYDEP COMMENT #7:
Tables 2-1 through 2-6 reflect calculations of means from ranges of
detected concentrations involving up to three orders of magnitude
difference.
If non-detects were included, the order of magnitude would
increase to five for some chemicals. This would likely reflect very
large variances of data, perhaps even larger than the man. A large
variance is an indicator of the need for additional sampling,
particularly in the vicinity of hot spots. Tables need to include the
exact values used in calculation of the means, including the
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 8 of 31
individual sample concentrations, variances and standard
deviations. It is likely that additional characterization is needed to
find hot spots and their boundaries.
Response: The individual data points for the calculation of the means is included the RI
Report. When the variance of a sample set is high, the 95 % UCL will typically exceed the
maximum detected concentration and therefore, result in the use of the maximum detect
concentration as the exposure point concentration.
KYDEP COMMENT #8:
Tables indicate that backgrounds are based on one surface soil
sample from the landfarm, one surface soil and one subsurface soil
sample from the landfill, five surface water samples (one sample per
each of five different events) from the McPherson Springs, and an
unspecified number of groundwater samples from four McPherson
Wells.
Background sampling should be done off-site at least in an area of
minimal contamination and in sufficient amounts to produce
statistically sound results. Too few samples have been collected
from each medium to allow its characterization. Only the water
samples are from off-site, and it is not certain if these sources are
impacted by the Caldwett site contamination. As mentioned
previously, non-detect values should be included in calculations for
the background means.
Response: Soil samples were collected in areas suspected of minimal contamination and in
sufficient amouts to produce statistically sound results. Please refer to Section 3 and 4 of the
RI. For clarification, there are no McPherson wells, only one spring. Only those springs
hydraulically connected to CLL were used in developing the RME. The McPherson Springs
was used as a background to Site-related springs. For comparison purposes, other wells and
springs may be used as control samples. Please refer to 5.5.3.1 of the RI. Non-detect
values (one-half the detection limit) were included in calculating the background means.
KYDEP COMMENT #9:
The "Frequency of Detection" column of the tables provides the
number of samples in which contaminants were detected and also the
total number that were used to calculate site means.
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 9 of 31
# appears from locations and/or events have been combined when
they should be considered individually or in small groups
segregated from the site as a whole. Grouping of non-
representative data lessens the likelihood for hot spot detection.
Response: Please see response to General Comment #3 and Specific Comment #s 2 and 36.
Also, It should also be noted that the landfarm area design was based on the smallest area
within which exposure could be limited under the most conservative, reasonable, future use
scenario (residential development).
KYDEP COMMENT #10:
Section 2.7, pp. 2-15: Surface soil samples were collected 0" -18" and subsoil samples at
3'.
KYDEP generally considers surficial soils where mixing has
occurred as those within the top 12" of the surface. Subsoil
samples should be taken at various depths below the surficial soils.
Since "clean " soil was placed over contaminants to a depth of 3 or
4' in certain trenches and lagoons during past remedial efforts,
subsoil sampling should include soil below that depth. In most
locations, sampling should continue to bedrock, to the groundwater
table, or to a depth below that expected to provide exposure to
receptors through contact with the soil or through leaching of
contaminants into surface or groundwater.
Response: EPA also considers surface soils as those within the top 12" of the surface. EPA
collected 90 surface soil samples, nine of which were the top 18" and 81 were the top 12".
Fifty-nine biased samples were collected from the landfill including samples from trenches
and lagoon. When possible, two-man power augers (Little Beaver* variety) were advance
through the waste down to native soils. An all-terrain mobile drill rig was later used at the
landfill to drill nine boreholes to down to depths determined by auger refusal or 60 feet. The
purpose of these 17 samples was to gain a better understanding of possible migration of
contamination from the trenches in the vadose zone and if possible the saturated zone.
KYDEP COMMENT ill:
Section 2.2.1.2, pp. 2-16: A detection frequency of less than 5% was used in conjunction
•with other considerations to eliminate chemicals of concern.
Due to minimal sampling, this procedure is not acceptable. A
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CLLSite
EPA Response to KYDEP Comments
June 17, 1994
Page 10 of 31
single detection could represent a significant hot spot that
would contribute excessive risks. It is unclear what specific
chemicals were eliminate based on this method.
Response: Please refer to Section 2.2.1.2 in the BRA. No chemicals were eliminated by
this method.
KYDEP COMMENT #12:
The "two-times rule" was applied to att inorganic chemicals for
which there was data. The maximum on-site concentration had
to be at least two-times greater than the average detected value
of the respective background samples (non-detects within
background analyses were dropped).
As mentioned previously, this procedure is not accepted by
KYDEP. The application of the two-times rule is especially
flawed when used with background values that are too high
due to incorrect treatment of data, as is likely the case in this
assessment.
Response: The comparison of site samples to two-times average background is consistent
with Region IV guidance. Non-detects are included in the calculation of average background
values.
KYDEP COMMENT #13:
Section 2.2.1.3, pp. 2-21: Any non-carcinogenic potential chemical of concern that
contributed less than 1% of the total risk was deleted.
This approach seems reasonable for this site, since chromium
and manganese were not eliminated via this method. However,
the actual calculation of total risk values for att potential
chemicals of concern was not provided. Therefore, it is
difficult to confirm the accuracy of results leading to
elimination of other chemicals. Obviously, the individual risk
and total risk should be pathway specific for each medium and
receptor. Calculations supporting this approach should be
provided as part of the baseline risk assessment.
Response: The toxicity-concentration screen was performed consistent with RAGS guidance
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EPA Response to KYDEP Comments
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(Chapter 5.9.5). Also, please refer to Section 2.2. 1.3 of the Risk Assessment which explains
the exact procedure used in deleting chemicals from the potential chemicals of potential
concern. With this information, it is possible to duplicate the calculations supporting this
approach. Supporting calculations can be provided if needed.
KYDEP COMMENT #14:
Section 2.2.1.4, pp. 2-24:
Essential nutrients were dropped from the list of chemicals of
concern if less than two times the background.
Even essential nutrients may present risk. Elimination on the
basis of the two-times rule is not acceptable, particularly in
tight of how the background data was treated.
Response: The elimination of essential nutrients is consistent with Region IV guidance.
KYDEP COMMENT if 15:
Section 2.2.2.1, pp. 2-24: McPherson wells were used to determine background for the
groundwater.
Analyses of water from these wells alone are unlikely to
provide a representative value for groundwater in the area of
Logan County and the Caldwett Lace Leather site. Additional
groundwater samples in the area beyond potential impact by
the Caldwett Lace Leather contamination should be used to
expand the confidence of the background mean. Since
determination of background concentrations is important when
selecting remediation methods to be used at a Superfund site, it
seems strange that so little effort was applied to determining
the background concentration of contaminants.
Response: Please see response to General Comment #5. Also, it is important to note that
before determining possible remediation methods, potential risk should be determined. If
risk above 1E-4 is determined, a remedial action may be warranted. At this point, the clean-
up number will be established, and in groundwater it is usually the MCL, unless the
background exceeds the MCL.
KYDEP COMMENT
Since toxicity information for lead is not available, lead
concentrations were investigated via the Lead Model.
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EPA Response to KYDEP Comments
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Page 12 of 31
The Lead Model is not acceptable as a method for evaluating
risk to receptors in a baseline risk assessment. Some toxicity
information for lead is available through various sources.
EPA's IRIS, in 1986 listed an oral cancer slope factor ofl.4E-
03 (mg/kg/day)'1 and an inhalation cancer slope factor of
4.3E-04 (mg/kg/day)'1. IRIS, 1989, listed an oral cancer slope
factor ofl.OE-03 (mg/kg/day)'1. Though EPA has since pulled
the listings from IRIS for further review, they have recently
printed an oral cancer slope factor of 7.7E-03 (mg/kg/day)'1
for use when calculating cardnogenicity of compiles mixtures
(Office of Pollution Prevention and Toxics). KYDEP currently
uses the latter for calculation of risk due to lead ingestion.
KYDEP generally requires that soil contaminated with lead be
cleaned to a level of about 20 mg/kg. Groundwater has an
action level of 15 ug/L. Tetraethyl lead, if present, may
present significant systemic risks at very low concentrations.
The oral RfD is l.OE-07 mg/kg/day (IRIS, 1994). Obviously,
lead in any form may be of concern. It is likely that lead
contributes significant risks both on and off the Caldwett Lace
Leather site and cannot be eliminated from quantitative
consideration in this assessment.
Response: The purpose of the using the EPA's biokinetic model for lead exposure is because
it better estimates potential adverse effects, than the outdated slope factors. EPA believes
that the available studies to not provide sufficient quantitative information. Although lead is
currently classified as a B2 carcinogen, EPA considers the noncarcinogenic neurotoxic effect
in children to be the critical toxic effect in terms of health-based environmental cleanup. In
absence of lead health criteria, the Lead Uptake/Bioldnetic Model (Version 0.5) is the best
approach to predict mean lead blood levels in children. Region IV recommends the use of
the Lead Model.
KYDEP COMMENT #17:
Section 2.3, pp. 2-29: Chemicals that were quantitatively assessed are listed in Table 2-7.
Those chemicals -without health criteria were assessed qualitatively.
The list of Chemicals of Concern is deficient due to the improper
elimination of chemicals via the two-times background rule,
essential element consideration, etc. Furthermore, several of the
chemicals assessed qualitatively do have sufficient information in
literature and other sources to enable quantitative assessment.
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EPA Response to KYDEP Comments
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Response: The elimination of chemicals of concern were based on EPA Region IV
protocols. If there ate sources for lexicological values we have overlooked, please provide
them for possible inclusion.
COMMENT #18:
Section 3.1.1 The Caldwett Lace Leather site has both a topographic and
groundwater divide. Two distinct groundwater basins discharge to
two rivers (Mud River at 4 miles SW and the Gasper River at 2.4
miles NE).
Despite having this knowledge, groundwater sample results of both
basins were combined when calculating means. Minimally, data
from well and/or sprigs of each basin should be considered
independent of each other. It is likely that sample locations should
be further segregated to include only those wells and/or springs
that hydrologicatty connected to a specific part of the Caldwell Lace
Leather site (i.e., specific source of specific contaminants).
Response: Why should they be considered separately, would the receptor know the
difference between one basin or the other? For your information, we calculated the risks
from individual springs. The results indicate one spring (Lagoon) had an increased hazard
index and all the others were decreased. Please see Appendix D of this document for
individual spring ingestion risks.
KYDEP COMMENT #19:
Section 3.2, p. 3-3: The landfill was capped with two feet of clean soil.
Information on when this took place, evidence that the soil was
clean, and the actual area covered has not been provided. Also,
the "clean " soil could actually have become contaminated since it's
placement on the site. Sampling of these soils should be completed
as part of the investigation.
Response: EPA suggests that KYDEP review their own records because KYDEP approved
Caldwell' s closure plan for the disposal area in February 1985. The landfill surface soil was
sampled as part of the RI. Please refer to RI Sections 3 and 4.
KYDEP COMMENT
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EPA Response to KYDEP Comments
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Section 3.2, p. 3-4: Current and future land uses proposed in the risk assessment were:
Landfill Current Trespasser
Future Resident
Future Farm Worker
Landfarm Current Resident
Additional land use scenarios should include:
Landfill Current Farm Worker
Future Resident
Landfarm Current Trespasser
Current Farm Worker
Future Trespasser
Future Resident
Future Farm Worker
Response: The future scenarios do not assume attenuation of contaminants. Therefore, the
requested "current farm worker" would be identical to the future farm worker in the landfill.
For the landfarm, a current resident was evaluated because a family currently resides there.
More over, any risk to any other populations would be less than the risk of the resident since
its assumptions are more conservative.
KYDEP COMMENT
Section 3.2.1, pp. 3-5: Inhalation ofvolatiles has been considered onfy in groundwater used
for showering.
Several volatiles and semi-volatiles (e.g., acetone, bromomethane,
carbon disulfide, o-chlordane, 1,2-Dichlorobenzene, ethylbenzene,
toluene, styrene, xylene, etc.) have been detected in either the
groundwater and subsurface soil. Granted, most concentrations
detected thus far are relatively low, but hot spots are possible.
Through tillage of the soil and accumulation ofvolatiles in
dwellings, receptors may be at risk from vapors. Additional on-site
soil, water and air sampling and monitoring should be conducted,
particularly in the vicinity of the landfill.
Response: The levels of volatiles detected in soils was not sufficient to warrant development
scenarios associated with volatiles in outdoor air.
KYDEP COMMENT #22:
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EPA Response to KYDEP Comments
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Section 3.2.2, pp. 3-8: The age range defaults used for exposure durations of residents are:
Child resident of 1-6 years of age and child resident of 7-16 years of
age.
Appropriate residential defaults should be:
Child <7 years of age = 6 years
Child 7-18 years of age = 12 years
Adult (Rural) 19-40 years of age = 22 years
Adult (Total) = 40 years
Adults living in a rural area tend to stay in one location longer
than those in urban settings. The total adult exposure is the sum
of exposures encountered as a child, adolescent, and adult.
Response: The default values used exposure durations consistent with EPA guidance.
KYDEP COMMENT #23:
Section 3.4, pp. 3-12: Exposure point concentrations for use in calculating intakes were
derived using the 95% Upper Confidence Limit (UCL) of the
arithmetic mean. However, if the 95% UCL was greater than the
maximum concentration detected, the maximum concentration
detected was used.
This is the proper procedure, however, since the derived means are
suspect, little confidence can be placed in the calculated 95% UCL.
Even the maximum concentration detected to date may not be the
true maximum, since too few samples have been collected and
analyzed.
Response: The procedure for development of exposure point concentrations is consistent
with EPA guidance.
KYDEP COMMENT #24:
Section 3.4 Tables 3-5 through 3-7 contain exposure point concentrations
pp. 3-17,18,19 detected.
These tables, just as others mentioned previously, exclude certain
chemicals that have been inappropriately eliminated as chemicals of
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EPA Response to KYDEP Comments
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concern via two-times background rule, etc.
Response: The selection of chemicals of potential concern is consistent with EPA guidance.
KYDEP COMMENT #25:
Section 3.5 Narrative and tables provide models and assumptions (defaults) used
pp. 3-20 through 35 for determining exposure.
Several assumptions are not consistent with those used by the
KYDEP:
Table 3-8 Incidental Ingestum of Soil
Used in the Risk Assessment KYDEP
IR=SO mg/day for Future Worker 480
EF=45 days/yrfor Trespasser 140
ED=10 yrs for Current Child 12
-14 yrs for Adult 22
The future worker is likely to be a farmer who tills the soil,
therefore, his ingestion of soil would be similar to construction
workers. .
Table 3-9 Dermal Contact with Soil
Used in the Risk Assessment KYDEP
SA = 2125 cm3 Chile 1-6 yrs 3730
(50% of events) (100%)
4397 cm2 Child 7-16 yrs 7400
4145 cm1 Adult Resident 3500
(50% of events) (100%)
1980 cm3 Future Worker 4700
AF = lmg/cm3 2.7
ABS = 0.01 Organic Compounds 1
0.001 Inorganic Compounds 1
EF = 45 days/yrfor Trespasser 140
ED = 10 yrs for Current Child 12
14 yrs for Adult 22
Dermal contact with soil by a resident would be expected to involve
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EPA Response to KYDEP Comments
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100% of the events, however, a case could be made to use 50% of
events for trespassers. The ABS should be chemical specific and
appropriate values related to the chemical of concern may be used.
Table 3-10 Ingestion of Groundwater
Used in the Risk Assessment KYDEP
ED - 10 yrs Child 12
14 yrs Adult 22
Table 3-11 Incidental Water Ingestion (Water)
Used in the Risk Assessment KYDEP
EF = 45 days/yrfor Child (7-16) 140
45 days/yrfor Adult 52
ED = Omission of Child <7 yrs 6
10 yrs for Child (7-16) 10
14 yrs for Adult 22
Table 3-12 Dermal Absorption (Wader)
Used in the Risk Assessment KYDEP
SA = Omission of Child <7 yrs 3730
4397 cm2/day Child (7-16) 7400
4145 cm2/day for Adult 9300
EF = Omission of Child <7 yrs 140
45 days/yrfor Child (7-16) 140
45 days/yr for Adult 52
ED = Omission of Child <7 yrs 6
10 yrs Child (7-16) 12
14 yrs for Adult 22
Table 3-13 Incidental Ingestion of Sediment
(The EF and ED should be the same as the corrected values in
Table 3-8, including child < 7 years and adult resident, trespasser
and worker).
Table 3-14 Dermal Contact with Sediment
(The SA,AF, ABS, EF and ED should be the same as corrected
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EPA Response to KYDEP Comments
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values in Table 3-9).
Response: The assumptions used in the risk assessment are consistent with EPA default
values. It is a agreed that a more representative soil value for a farmer would be 480
mg/day for the percentage of time spent tilling soils. However, if 480 mg/day were used for
the entire exposure period the risk levels would still remain in the acceptable range. Please
see Appendix C of this document for landfill surface and subsurface soil ingestion and
dermal contact risks based on an IR of 480 mg/day for a farmer.
KYDEP COMMENT #26:
Section 4.0 Narrative and Table 4-3 provide toxicity information on potential
pp. 4-1 ihrM 23 chemicals of concern.
Again, certain chemicals have been omitted due to inappropriate
screening techniques.
Response: The selection of chemicals of potential concern is consistent with EPA guidance.
KYDEP COMMENT #27:
Section 4.3.2.1 Lead is considered to be a potential carcinogen through the
p. 4-23 oral route, but EPA does not have a Cancer Slope Factor available.
EPA did list a CSF of l.Ofmg/kg/day)'1 in 1989, but have since
removed it for further review. KYDEP has calculated a similar
value and therefore continues to use it in assessment of risk from
lead intakes.
Response: EPA no longer considers the CSF for lead to be valid.
KYDEP COMMENTS #28:
Section 4.3.2.2, 4-23 There are no volatiles chemicals of potential concern in
groundwater.
Some VOCs have been detected in soil on-site. Groundwater on-
site has not been sufficiently characterized to permit this
conclusion.
Response: The selection of chemicals of potential concern is consistent with EPA guidance.
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EPA Response to KYDEP Comments
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KYDEP COMMENT #29:
Section 4.3.2.3, 4-24 Dermal slope factors were derived by dividing the oral slope factor
of volatile organics by 0.8, semi-volatile organics by 0.5, and
inorganics by 0.2.
Though this procedure has apparently been recommended by
Region 4, EPA, and may be reasonable, the KYDEP has not
received supporting information from EPA. We have seen it used
elsewhere and would like to see the science behind it use. KYDEP
continues to use the oral slope factor as the dermal slope factor
except when chemical specific information is available.
Response: These default values are used when sufficient data is unavailable for development
of chemical specific values. It should be noted that use of the oral slope factor as the dermal
slope factor is less conservative than use of the default oral absorption factors.
KYDEP COMMENT #30:
Section 4.3.4, 4-28,29 Table 4-4 list 1,3 dichlorobenzene, aluminum, and tin as not having
the toxicity data available.
Oral RfD'sfor the above chemicals, in order as listed, are 0.089,
2.90, and 0.600 mg/kg/day (U.S.EPA, 1994a). Obviously, these
chemicals should be included in the quantitative risk assessment.
Response: The RfD for tin is included in HEAST and should have been included in the
document. However, the RfDs for 1,3-dichlorobenzene and aluminum are from sources
other than IRIS or HEAST.
KYDEP COMMENT #31:
Section 5.3, pp. 5-6,7 Table 5-1 and 5-2 indicate that Current Landfarm Trespasser, Future
Landfarm Resident, and Future Landfarm Worker scenarios were not
evaluated for surficial soil ingestion.
Each of the above scenarios appear to present risk via potentially
completed pathways, therefore, each should be included in the
assessment.
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EPA Response to KYDEP Comments
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Response: Please refer to Comment #20 response.
KYDEP COMMENT #32:
Sediments were eliminated from evaluation because no carcinogens
were detected.
Sampling of sediments has not been sufficient to eliminate them as
contributors of risk. In fact, lead was detected in the sediments
and that in itself is reason enough to perform the risk calculations.
Response: Please refer to the RI Sections 3.8, 4.2.2.1, and 7.3 which supports the selection
of the sediment sampling locations. Habitat quality evaluations, ambient water quality
measurements, biosurveys, and toxicity tests were performed at those springs which had
sediment screening value exceedances (RI Section 7.3).
KYDEP COMMENT #33:
Section 5.3, pp. 5-8: Table 5-3 and 5-4 present the Hazard Quotient and Hard Index for
current and future residents of different age groups, current
trespassers andfiaure workers.
The actual calculations have not been provided. It is unclear if
child intakes and risks have been added into the adult scenario for
residents. Also, future trespassers and current workers should be
included in the tables.
Response: Section 5.2 provides the equation which incorporates the exposure dose intakes
combined with the toxicity data to generate the HQ and HI. The values are provided in the
Risk Assessment Appendix A and B. Child and Adult risks were not summed.
KYDEP COMMENT #34:
Section 5.3.2.1 The cancer risk for future residents is 3E-05. Since no pathway
pp. 5-13 exhibits risk greater than 1E-04, there are not specific chemicals of
concern as carcinogens.
The risk value after making corrections and adjustments (i.e.,
expanding the list of chemicals of concern, revising calculations of
exposure and intake, and inclusion of risk from carcinogens
previously omitted) will almost certainly reflect a greater total risk
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EPA Response to KYDEP Comments
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level for various pathways. Furthermore, a risk oflE-04 is not the
point of departure. All risk specific to an exposure pathway greater
than 1E-06 should be addressed via, remediation and/or
management.
Response: The risk assessment follows EPA Region IV protocols. Therefore, the total risk
for the future resident is as stated.
KYDEP COMMENT #35:
Section 5.3.2.2: The potential non-carcinogenic risk for a child resident 1-6 years of
pp. 5-14 age via groundwater ingestion is a Hazard Index of 11. Through
surface soil ingestion it is a Hazard Index of 0.8. The Hazard Index
for a future worker is 0.09.
The adult risk must include the total of that accrued over the
period of being a child as well as the portion attributed to the years
of exposure as an adult. It is unclear if the adult risk has been
calculated correctly. Reported risk levels likely are an
underestimate of reasonable maximum exposure risks due to
exclusion of certain chemicals of concern and perhaps to improper
calculations.
Response: The noncarcinogenic risk for a child and adult are not summed.
KYDEP COMMENT #36:
Section 5.4.2, pp. 5-16: Groundwater lead levels averaged 13.6ug/l at the Caldwell site.
It is unclear what specific samples were included in calculations of
this mean. Were the samples from wells and/or springs? Were
they from on-site and/or off-site. EPA has established an action
level for lead at 15 ppb. With a mean of 13.6 ppb, it is likely
specific sample locations exceeded the action level. It is also
probable that the individual locations of sample should be
considered separately rather that grouped together.
Response: Please refer to Appendix B of this document for specific samples included in
calculations of the mean. The complete data package is in the RI for KYDEP to evaluate
whether exceedances of 15 ppb occurred. EPA already identified in the RI the two
exceedances that occurred.
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KYDEP COMMENT #37:
Section 5.5.2, pp. 5-20: Use of the 95% UCL may have resulted in conservative estimates of
the dose values.
Possible, but on the other hand, if the intakes are based on UCL's
derived from improperly derived means, as appears to be the case
with this assessment, the doses (i.e., intakes) may actually be
underestimated.
Response: The risk assessment was completed according to EPA Region IV protocols and
the arithmetic means were based on the data presented in the RI.
KYDEP COMMENT #38:
Section 5.5.2, pp. 5-22: Manganese was eliminated as a chemical of concern because it's
exposure point concentration was calculated to be 400 ug/l which
was less than the background.
The maximum manganese concentration detected was 4200 ug/l.
Even at 400 ug/l, it presents risk greater than a de minimis level if
ingested in drinking water. Again, the grouping of groundwater
sample from such diverse sources as represented by this mean is
not appropriate. Certainly, exclusion of manganese on the basis of
the two-times background rule in this case borders on the
ridiculous. The MCL for drinking water is 50 ppb.
Response: Manganese is now included in the Risk Assessment. Currently, there is now
federal MCL for manganese, but EPA recognizes the Kentucky MCL for manganese.
KYDEP COMMENT #39:
Section 6.2.1, p. 6-2: For assessment of ecological risk, aluminum, magnesium and
vanadium were eliminated as chemicals of concern via the two-times
background rule. Also, calcium, iron, potassium and sodium were
eliminated due to low toxicity.
As with the assessment of risk to Human Health, the two-times
background rule is not acceptable. As for elimination of chemicals
due to toxicity, justification via peer reviewed literature or other
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EPA Response to KYDEP Comments
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studies should be provided. While it is likely that calcium,
potassium and sodium concentrations are acceptable, iron at
concentrations detected exceed the Kentucky Chronic Water Quality
Aquatic Health Criteria ofl mg/l.
Response: Please see response to General Comment #10.
KYDEP COMMENT If 40:
Section 6.2.2, p. 6-2 Eight springs were determined to be hydrologicalfy connected to the
Caldwell Lace Leather site.
It is not clear which of the springs are actually connected to the
same source of contaminants at the site. It is unlikely that they all
are being impacted by the same contaminated sources, therefore,
only those springs known to be part of the same underground
conduit and draining from the same area of contamination should
be grouped together for averaging data. It is likely that each
spring provides for averaging data. It is likely that each spring
provides for separate exposures to different receptors (e.g., aquatic
organisms in one spring are not likely to be exposed to chemicals
in another spring). The risk from chemicals of concern at each
spring should probably be evaluated independent of others.
Response: The springs were evaluated separately for the ecological assessment.
KYDEP COMMENT
Section 6.2.2, p. 6-7 McPherson Spring was used as the (surface water) background. The
essential elements calcium, iron, magnesium, potassium and sodium
were eliminated because they are essential nutrients of low toxidty.
The background for surface water should include data from several
other locations around Logan County. Both iron and magnesium
were detected at levels presenting significant risk to some
organisms.
Response: Please see response to General Comment #5.
KYDEP COMMENT #42:
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EPA Response to KYDEP Comments
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Section 6.2.3 Tables 6-2 and 6-3present surface water and sediment data.
pp. 6-8 thru 6-10
For comparison purposes, units within a table should be consistent.
Either ug/l or mg/l should be used throughout the table. Also, the
range data does not provide the individual entries from which they
were derived. The tables should be expanded to show att data used
in obtaining the ranges.
Response: The Tables 6-2 and 6-3 have been revised to include ug/l units only.
KVDEP COMMENT #43:
Section 6.3.1.4, p. 6-20 Only three of eight springs and seeps investigated appeared to
contain perennial water/low levels sufficient to support fish. They
•were Mossy Spring, Mossy Spring Runoff, and Mud River. Despite
intensive search from the bank, no fish were found.
It appears that either the waters are too toxic for fish to live or the
investigation was not sufficient to detect aquatic fauna. Either
way, it is obvious that more investigation of at least the three
springs mentioned above is warranted.
Response: Ecologists did confirm the presence of fish at two of the off-Site locations (8C
Runoff and Mud River Spring) and identified those species that were observed. The studies
performed included chemical analyses, toxicity testing, and benthomacroinvertebrate
community studies. Had any of these studies indicated problems, the next step would have
been a more detailed ecological investigation. See also response to Specific Comment #46.
KYDEP COMMENT #44:
Section 6.3.2.2, p. 6-33 The Mud River Spring consists of two separate springs that
converge approximately ten meters downstream.
It is unclear where samples were taken at this location. The point
of convergence would be fine for surface water samples, but
groundwater samples should be collected at the point of origin for
the two separate springs. These two springs are likely to represent
different underground conduits. Either of which could be
hydrologically connected to the Caldwett Lace Leather site.
Response: During collection of samples from Mud River Spring, careful attention was paid
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EPA Response to KYDEP Comments
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to collecting samples from the Mud River Spring origin. A U.S.G.S. representative was
onSite to assist in identifying the correct location for sampling Mud River Spring.
KYDEP COMMENT if 45:
Section 6.3.2.3 The summary states that no rare, threatened or endangered species
pp. 6-34, 35 were encountered on the Caldwett property or off-site at the spring
locations.
Has statement may represent the findings, but the investigation was
obviously limited. It appears that the aquatic organisms have
received minimal attention, particularly the fishes. Also, the
subsoil has been virtually ignored in this assessment. Burrowing
animals would potentially be exposed to high concentrations of
some chemicals. Insects and other small organisms exposed to
toxic chemicals in soil or water would likely be involved in the
bioaccumulation of some chemicals at higher trophic levels.
Response: KYDEP's statement refers to endangered and threatened species, but the
comment focuses on other topics. Therefore, it is uncertain what KYDEP's concern is.
Here are possible responses to the points mentioned in the comment:
a) What do KYDEP consider to be aquatic organisms? Only those that live in the water
column? Benthic macroinvertebrates were included in the biosurvey, and other biota such as
fish were noted. Some of the spring-fed streams surveyed did not provide appropriate habitat
for fish (e.g., low flow, intermittent flow). Also, little surface water and sediment
contamination was found above background levels.
b) Although few possible burrowers were observed, some of the habitats found onSite might
be appropriate for burrowing animals. Most exposure would probably be limited by fur,
etc.) or possibly incidental ingestion if the animals eat underground. This exposure is
expected to be limited. Also, the ranges of contaminant concentrations found in surface soil
in the landfill and landfarm areas are similar to the ranges for subsurface soils, except for
nickel.
c) Insects and small organisms might bioaccumulate some of the surface soil contaminants,
but it is not expected that the contaminants would biomagnify along a food chain (e.g., no
pesticides detected in surface soils, and mercury found at only low levels).
KYDEP COMMENT #46:
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EPA Response to KYDEP Comments
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Section 6.3.3.3, p. 6-38 The Water Quality measurements are summarized in Table E-14.
The range of results for most parameters appear to justify the need
for evaluating each exposure source independently:
Ph 5.5-7.4.
Temperature 13.5-26.4°C.
Oxygen 2.50-19.8 mg/l.
Conductivity 50-499 uohm.
Salinity 0.0-0.2.
Alkalinity 17-178 mg/l CaCO3 (3 samples). Hardness 16-
211 mg/l CaCo3 (3 samples).
Response: The springs were evaluated separately for surface water and sediment chemical
analyses, habitat quality, and biosurvey. Sediment toxicity tests were conducted for those
springs having sediment contaminant levels above sediment screening numbers, to check for
Site-specific toxicity.
KYDEP COMMENT #47:
Section 6.3.3.3, p. 6-39 Testing of three sediment samples detected no toxicity. Lab bench
sheets are in Appendix B of this report. Poor performance of control
animals and those from the Lagoon Spring Pond may be attributed to
starvation.
Three sediment tests are too few for any conclusive statements
about sediment contamination on or off-site. Where is Appendix
B? What poor performance? This section needs much more
development.'
Response: a) Sediment toxicity tests were conducted on sediments showing the highest
levels of Site-related contaminants (i.e., mainly those exceeding sediment screening levels).
If no effects were noted at those levels, no effects would be expected for sediments
containing lower levels of contaminants, b) Either the appendix letter missing or the
appendix was not attached in the Risk Assessment. Appendix B (referenced in the Risk
Assessment and RI) is the "Short-term Chronic Toxicity Test - Amphipod Survival Test." If
the test is missing from the Risk Assessment, please refer to RI Section 7.0 tables.
c) "Poor performance" refers to mortality control and Lagoon Spring Pond test organisms.
The comment might be answered once KYDEP sees the the appendix.
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KTDEP COMMENT If48:
Section 6.3.3.4, p. 6-40 Impairment of spring fed aquatic systems of Mossy Spring and Mud
River Spring do not appear to be from the Caldwell site-related
chemicals.
What impairment does this comment relate to and what is the basis
for the conclusion that the Caldwell site is not contributing to the
problems?
Response: a) It would have been better for the text to state that the two spring-fed aquatic
systems did not appear to be impaired in relation to chemical contaminants from the CLL
Site. The low diversity found in these two aquatic systems is characteristic of a stenothermal
environment. (Also, stream headwaters often have lower diversity as mentioned in the
KYDEP Environmental Assessment Report, 1987.) b) Also, Mossy Spring samples
contained contaminants at levels higher than those at Mud River Spring, yet the sediment
toxicity tests showed the high survival rates for both locations, and sensitive species were
found at both locations.
KYDEP COMMENT #49:
Section 6.3.4.1, p. 6-43: No site-specific information on threatened or endangered species
was available from Kentucky or the U.S. Fish and Wildlife Service.
Threatened and endangered species in the area of Mammoth Cave
(geographically similar and near the Caldwell site) have been
investigated and are likely recorded •with the U.S. Park Service
and/or Western Kentucky University. Also, the Kentucky Nature
Preserves Commission, the Kentucky Department of Fish and
Wildlife Resources, and the Kentucky Department for
Environmental Protection's Division of Water all investigate and
monitor populations of various species within the state. Were these
resources contacted? It appears that little effort has been made
toward acquiring this information. Information on species of the
general area should be used to guide the site-specific investigation.
Response: Ideally, endangered species information should have been obtained from the
Commonwealth of Kentucky and from U.S. Fish and Wildlife Service. However, KYDEP
and USFWS personnel have been kept informed throughout the investigation and were
invited to visit the Site. During the RI, trained ecologists conducted detailed survey of the
Site and spring areas in two different seasons, especially focusing on habitats where
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EPA Response to KYDEP Comments
June 17, 1994
Page 28 of 31
endangered and threatened species might be expected; no endangered or threatened species
were found.
KYDEP COMMENT if 50:
Section 6. 3. 4. 1 Tables 6-4 and 6-5 provide exposure point concentrations of
pp. 6-45, 46 contaminants detected in surface soil at the landfarm and landfill.
The separate entries from which the 95% UCL's have been derived
should be provided. Also, the exposure point concentrations of the
two parcels should be considered both separately and combined
with the entire site for comparison purposes since some receptors
would likely receive exposure in both locations.
Response: Please refer to response to General Comment #7. EPA suggests that KYDEP
perform the comparison to determine the merit of this comment.
COMMENT #51:
Section 6.3.4.1, p. 6-47 Table 6-6 provides State Water Quality values for Warm Water
Aquatic Habitat Criteria based on hardness of 170 mg/L calculated
from average surface water calcium and magnesium concentrations.
A hardness average derived from a single sample of locations
would be of low confidence, especially when the springs are not
even hydrologicatty connected and are located great distances
apart. The hardness measured during various events over time at
each location should be used for calculating a spring-specific mean
that would then be compared to the water quality criteria.
Response: The hardness measurement was calculated using the average value for calcium
and magnesium for Site-related samples. Did KYDEP determine that exceedances occurred
using the suggested approach? If so, were the exceedances any different than exceedances
already identified?
KYDEP COMMENT #52:
Section 6.4.1.1, p. 6-53 Some inorganic chemical concentrations were calculated using a
hardness value of 50 mg/l.
It is unclear which chemical concentrations were calculated using
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EPA Response to KYDEP Comments
June 17, 1994
Page 29 of 31
this or other hardness values. Use of spring-specific hardness data
should be used to calculate potentially toxic concentrations in
individual springs, especially when lower than the SO mg/l
(exceedances of Kentucky Water Quality Standards).
Response: This has been corrected so that all hardness-dependent chemicals were calculated
using 170 mg/l.
KYDEP COMMENT #53:
Section 6.4.2.2, p. 6-59 Organic matter within -water -will eventually reduce Cr(VI) to
CrfHI). Residence time of chromium in lake water is from 4.6 to 18
years.
The organic matter in most of the springs would be expected to be
minimal, therefore, residence time would not likely be reduced
significantly due to organic matter's reducing capability. Also, the
influx of chromium from the Caldwett site is likely to continue well
into the future (e.g., leachate). The presence ofMnO2 in natural
waters will oxidize Crflll) to Cr(VI) and the CR(VI) will remain
relatively stable (Bodek, et, al., 1988).
Response: EPA will agree that various literature on oxidation and reduction of suggests
chromium valence states may go either way. For this reason, EPA assumed toxicity values
of Cr(VI) rather than total chromium.
KYDEP COMMENT if 54:
Section 6.5, p. 6-64 U.S. EPA Region TV Waste Division freshwater surface water and
sediment screening values were used to determine if chemicals
presented risk in these media.
Use of these values may be acceptable, but KYDEP has not
received this information from Region IV. Obviously, such values
could not be less stringent than criteria required elsewhere (e.g.,
Ambient Water Quality or Kentucky Water Quality Criteria).
Provide a copy of these values and a table showing site-specific
comparisons.
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EPA Response to KYDEP Comments
June 17, 1994
Page 30 of 31
Response: This is true statement. Please refer to Appendix E of this document for a copy
of Region IV screening values.
KYDEP COMMENT #55:
Section 6.5.1, p. 6-65 Five chemicals of concern exceeded surface -water criteria in one or
more location. They are aluminum, chromium, lead, manganese and
bis(2-ethylhexyl)phthalate.
The list of chemicals should be expanded to include chemicals that
were inappropriately excluded (e.g., iron).
Response:. The Risks Assessment follows EPA Region IV protocols.
KYDEP COMMENT #56:
Appendix D, D-1,2 Remediation goals -were developed for carcinogenic chemicals with
risks > 1E-06 where the pathway risks exceeds 1E-04.
Goals for remediation and/or management should be developed for
each chemical that is predicted to present systemic risk greater than
a Hazard Quotient of 1 or carcinogenic risk to human health
greater than 1E-06 through any pathway.
Response: Presentation of remediation goals is consistent with Region IV guidance. See
also EPA OSWER DIRECTIVE 9355.0-30 which clearly points out that when cumulative
carcinogenic risk is less than 1E-04, action is generally not warranted.
KYDEP COMMENT #57:
The pathway of drinking -water from wells in the area reflects a
Hazard Quotient ^ 1 and a carcinogen risk oflE-04for the future
scenario.
The same risk would appear to exist for current use of the
groundwater. Also, the risk from drinking water from these wells
is likely to be much greater since the risk values are based on a
mean of results from all well samples combined. Each drinking
water source should be considered independent of the other. It is
unlikely that a resident would drink equal volumes of water from
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EPA Response to KYDEP Comments
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Page 31 of 31
each source! Media other than groundwater likely require some
remediation or at least some management of risk.
Response: The hazard quotient for manganese exceeds one, however, the carcinogen risk
listed in this comment is incorrect. Calculation of risks from individual wells or springs
would result in only one spring (lagoon) with an increased hazard index and all others would
be decreased. Please refer to Appendix D for calculation of risks from individual springs.
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