EPA/ROD/R04-95/226
June 1995
EPA Superfund
Record of Decision:
Fort Hartford Coal Co. Stone Quarry
(OU 1), Olaton, KY
3/30/1995
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FORT HARTFORD STONE QUARRY NPL
SITE
OLATON, KENTUCKY
RECORD OF DECISION
REMEDIAL DESIGN/REMEDIAL ACTION
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TABLE OF CONTENTS
Section Page
I. Declaration. 1-1
n. Site Description, History and Summary of
EnforcementActiviti.es. 2-1
Investigations and Studies Completed to Date 2-3
m. Scope and Role of Response Action. 3-1
IV. Summary of Site Characteristics. 4-1
Contaminant Characteristics 4-1
Affected Media Characteristics 4-1
V. Summary of Site Risks. 5-1
Exposure Assessment 5-1
Toxicity Assessment 5-4
Risk Characterization 5-5
Environmental Risks 5-6
Remedial Goals... ....; 5-8
VI. Description of Remedial Alternatives. 6-1
Alternative 1 6-1
Alternative 2 6-1
Alternative 3 6-2
Alternative 4A 6-2
Alternative 4B 6-3
Alternatives 6-3
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-u-
TABLE OF CONTENTS (Continued)
Section Page
Alternative 6 [[[ 6-4
VJI. Comparative Analysts of
Alternatives. [[[ 7-1
Selected Remedy. [[[ 8-1
Performance Standards ........................................ . .......... 8-2
Compliance Testing and Monitoring ................. . ............... 8-4
IX. Statutory Determinations ................................................ 9-1
Protection of Human Health and Environment ................. 9-1
Compliance with ARARs .................................... . .............. 9-2
Cost-Effectiveness [[[ 9-5
Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technologies to
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-m-
TABLES
Number Title Page
4-1 Summary of Ground-water Background
Action Level Exceedancesjor
All Formations Monitored 4-6
5-1 Surface Soil
Contaminants of Concern 5-11
5-2 Surface Water Contaminants of
Concern 4-9
5-3 Summary of Ground-water
Contaminants of Concern 5-12
5-4 Source Material Contaminants
of Concern... 5-13
5-5 Sediment Contaminants of Concern 5-14
5-6 Assumptions/or Ingestion and
Dermal Exposure for Soil 5-15
5-7 Total Site Risk '. 5-16
5-8 Assumptions for Ingestion and Dermal Contact
Exposure to Sediment Contaminants of Concern 5-17
5-9 Assumptions Jor Ingestion and Dermal Contact
Exposure to SCFs Contaminants of Concern 5-18
5-10 Toxico logical Database Information for COCs 5-19
5-11 Summary of Carcinogenic Risk 5-21
5-12 Summary o/iYon-Carcinogenic Risk 5-22
5-13 Summary of Exceedances 5-24
5-14 Surface Water Remedial Goal Options 5-25
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-IV-
5-15 Ground-water Remedial Goal Options 5-26
5-16 Water from Reaction Remedial Goal Options 5-27
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Fort Hartford Stone Quarry NPL Site
Record of Decision
• Section I. Declaration
Pagel
I. DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Fort Hartford Stone Quarry Site
Olaton, Ohio County, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action
for the Fort Hartford 'Stone Quarry Site developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA) and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
This decision is based on the contents of the administrative
record for the Fort Hartford Stone Quarry Site.
The State of Kentucky concurs on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases from this Site, if not addressed by
implementing the response action selected in this Record of
Decision (ROD), may present an imminent or substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This final remedy addresses remediation of ground-water (and
hence spring and surface water) as well as air contamination by
eliminating or reducing the risks posed by the Site, through
treatment, engineering and institutional controls.
The major components of the selected remedy include:
Institutional controls (fencing, etc..) to prevent exposure
to ground wa^er and airborne ammc.aia;
Continued diversion of intruding mine water/ground water
away from salt cake fines (SCFs) via pumping with subsequent
treatment for ammonia content and discharge to the Rough
River;
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section I, Declaration
Page 2
Deed restrictions;
A ground-water, spring and surface water monitoring program
to determine the effectiveness of plume containment and
contaminant reduction;
Containment of night air emissions via portal doors;
An air monitoring program to determine effectiveness of
night containment of ammonia emissions; and
Forced ventilation of mine air to two dispersion stacks
should monitoring reveal night containment of air emissions
ineffective.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with federal and State requirements that
are applicable or relevant and appropriate to the remedial action
and is costreffective. This remedy also utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable, and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility
and volume as a principal element. However, because treatment of
the principle threats at the site was not found to be
practicable, this remedy does not satisfy the statutory
preference for treatment of all Site wastes as a principle
element.
Because this remedy will result in hazardous substances remaining
on-Site .above health'-based levels, a review will be conducted at
least every five years beginning no later than five years from
the date of commencement of construction of the remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment. Reviews may be
conducted on a more frequent bases as EPA deems necessary.
Date Richard D. Green, Associate Director
Office of Superfund and Emergency Response
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section H. Site Description...
Pagel
II. SITE DESCRIPTION, SITE HISTORY. AND SUMMARY OF ENFORCEMENT
AND COMMUNITY RELATIONS
A. SITE LOCATION AND DESCRIPTION
The Fort Hartford Stone Quarry site is located approximately
1.25 miles northwest of Olaton, Kentucky, in east-central
Ohio County. It is bounded to the north by the Rough River
and Davison Station Wildlife Management Area, to the south
by Davison Station Road (now Underwood Road), to -the east by
one residence and Caney Creek, and to the west by
'agricultural land and Cane Run Creek. Figure 2.1 gives the
general location of the Site.
The property encompasses approximately 850 acres with an
underground mine portion consisting of approximately 120
acres. The mine consists of two lobes. The first lobe, the
Rough River lobe has three primary entrances that were used
during mining operations. The second lobe, the Caney Creek
lobe, has five entrances.
From the late 1950s until about 1978, limestone was
excavated from the mine. The lower three-fourth, of th.3
limestone was mined with the remaining upper one-fourth left
intact to serve as the roof which is supported by unmined
limestone pillars.
.The Olaton/Ohio County area is situated in the east-central
perimeter of the Western Kentucky Coal Fields as shown in
Figure 2.2. This region is characterized by low, rolling
hills of Pennsylvanian age shales, siltstones, and
.limestones which are exposed as a result of normal and high
angle reverse faulting which has occurred within than zone.
The alluviated valleys comprise a small portion of the area
and have a general elevation of 380 to 420 feet; the hills
surrounding the site rise to a maximum elevation of about
625 feet.
The major recognized geologic units at the Site, from
youngest to oldest (going vertically downward) are:
Tar Springs Sandstone
Glen Dean Limestone -
Hardinsburg Sandstone
Haney Limestone
Big Clifty Sandstone
Beech Creek Limestone
Elwren Formation (sandstone)
Reelsville Formation (transgressive limestone)
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section JJ, Site Description...
Page 2
Sample Sandstone
A total of 21,765 residents live in Ohio County based upon
the 1980 census (Morris, 1980). The largest town in Ohio
County is Beaver Dam with 3200 people. A total of 19 other
incorporated communities are located in the county as well
as a number of unincorporated settlements. The principal
natural resources include oil and gas, coal, limestone, wood
products, and fire clay.
There are 56 residences within a one-mile radius of the
property boundary which includes the community of Olaton to
the south/southeast and portions of Davison Station Wildlife
Management Area to the north/northwest. Approximately half
of these residences have private wells for potable water use
with the remainder being on city water.
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Beginning in 1981, by-products of secondary aluminum
recovery, or salt cake fines (SCFs), were placed in the mine
by Barmet Aluminum Corporation .(Barmet) . In 1988, EPA
proposed that the site be added to the National Priorities
List (NPL) after receiving a mean hazard ranking score of
43.84. The site was ranked because of concern that ammonia,
chlorides, and possibly metals were posing a significant
threat to human health and the environment through air and
ground-water exposure pathways.
As a result, on September 20, 1989, an Administrative Order
on Consent (AOC) was signed between EPA and Barmet. The AOC
required Barmet to perform expedited response actions and an
RI/FS study for the site. The expedited response actions,
performed by Barmet and overseen by EPA were stated in the
AOC as follows:
To identify all areas where water was entering the mine
storage areas;
To identify all areas of SCF storage within the mine
where there was either a potential for water to contact
the salt cake fines or where the contact of water with
salt cake fines was occurring;
To isolate from water all SCFs in the mine by sealing
off water intrusion areas, diverting water away from
the SCFs and moving SCFs into dry parts of the mine;
and
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section n. Site Description...
Page 3
To take actions in accordance with a written health and
safety plan.
These actions commenced immediately after approval of an
Expedited Response Action Plan (ERAP) in May 1990.
Activities performed as part of accomplishing the above-
mentioned objectives included grading the site for drainage
away from SCF areas, repairing mine roof collapses which
were allowing water intrusion into the mine, permanently
closing 26 sinkholes which could allow water intrusion, and
obtaining a discharge permit from the KNREPC for controlled
discharge of site drainage into the Rough River.
After the expedited response actions were completed, the RI
at the Fort Hartford Site was conducted to determine the
nature and extent of any contamination. Field activities
began in December 1991 and concluded in September 1993. In
order to give an accurate depiction of site risks, samples
were collected and evaluated from several media at Fort
Hartford. The September 1994 Remedial Investigation (RI)
report gives greater detail on sampling locations and
methodology. Section IV of this document summarizes the
sampling results.
Samples were taken to characterize the source material
(SCFs) in the mine. Salt cake fines were sampled in the
fresh (least reacted) state, the pre-rod-mill (larger grain
size) state, the wet (partially or fully reacted) state, the
crusted (reacted) state, and in a dry state beneath crusted
material.
An Air Pathway Analysis was conducted to characterize the
nature and extent of contaminant air emissions from the
site. Meteorological data were collected on-site to .
determine length and height of contaminant dispersion.
Ammonia emissions were measured from.the mine portals as
well as in areas at the site fenceline and off-site. This
monitoring program was conducted over a 17-month period from
August 1990 through December 1992.
Soils were sampled surficially and in the subsurface to
determine if contamination was present. This sampling was
performed in August and September of 1992.
The Rough River, Caney Creek and Cane Run Creek were sampled
for surface water and sediment over a period of four
quarters from August 1992 to May 1993. Samples of water
exiting the mine (mine flumes) were also collected.
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Fort Hartford .Stone Quarry NPL Site
Record of Decision
Section O, Site Description...
Page 4
To determine the nature and extent of impacts to ground
water from SCFs within the mine, 17 ground-water monitoring
locations were selected throughout the site. An additional
monitoring well drilled before the RI was begun (MW 1) was
also sampled during the RI. Well locations were selected
based on proximity to the mine and source material, faulting
and impounded water within the mine. Wells were constructed
to penetrate vertically through all water-bearing zones. A
more thorough investigation of the geology beneath the mine
was also performed to discern contaminant migration pathways
as well'as structural stability.
In addition to chemical samples, ecological sampling was
conducted at the Fort Hartford Site. Sampling was in a
tiered approach developed and approved by the U.S. Fish and
Wildlife Service. Results from one tier determine whether
the next tier of evaluation is necessary. Activities were
conducted in two tiers: (1) contacts with natural resource
trustees and a literature review, endangered species
surveys, and terrestrial field assessments; and (2) acute
toxicity tests. Toxicity testing was performed for aquatic
and terrestrial organisms.
C. COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan (CRP) for the Fort Hartford Site
was finalized in September 1990. This document lists
contacts and interested parties throughout government and
the local community. It also establishes communication
pathways to assure timely dissemination of pertinent
information. Prior to assembling the CRP, community
interviews were conducted by EPA in June 1990 to gain
insight on the community climate.
EPA held a RI/FS kickoff meeting in December 1991 to
announce the beginning of the RI/FS to the public.
The RI and FS reports were finalized in September 1994.
These reports and all other documents concerning the Site
have been made available to the public in the Fort Hartford
Stone Quarry NPL Site Information Repository in the Ohio
County Record Clerk's Office in the Ohio County. Courthouse.
v .
The Proposed Plan was sent out 10 the public on October 31,
1994, and a public meeting to discuss the Proposed Plan was
held on November 17, 1994. This meeting was used to gain
insight on public opinion concerning the remedial
alternatives. Prior to this, community interviews were
conducted in August 1994.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section U, Site Description...
PageS
A public comment period was held on the Proposed Plan from
November 3 to December 6, 1994. Comments received have been
incorporated into the Responsiveness Summary (Appendix B) of
this document.
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Figure 2.1
PROPERTY BOUNDARY
UNDERGROUND MINE
WORKS
DWG DATE: 10/22/93 |DWG NAME:FORT12
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en
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rr
P>
oo
FT. HARTFDRD MINE SITE
PENNSYLVANIAN DUTCRHP
EDGE DF CDASTAL PLA1 \
Appalachian
£; Basin
Mississippi
Enbaynent
W, VA,
ARK
SDURCEi Hydrology and Geology of Deep Sandstone AqulFer of Pennsylvanian
Ape in Part of the Western Coalfield Region. Kentucky. 1974,
FIGURE 2.2
OAIL01/27/93
DWG NAMF FORTRFG1
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Fort Hartford. Stone Quarry NPL Site
Record of Decision
Section m. Scope
Page 1
III. SCOPE AND ROLE OF THE RESPONSE ACTION
The scope of this response action is to address remaining air and
ground water/spring and surface water concerns at the Site. As
discussed previously in Section II of this document, actions were
implemented beginning in May 1990 to identify all areas of the
mine where water was contacting SCFs and to divert this water
away and treat it before discharging to the Rough River. SCFs
were also relocated to drier areas of the mine.
During the development of the-EPA RI, areas of concern were
delineated for ammonia in the air and ammonia, chlorides and
aluminum in ground water (and hence in some springs and surface
water). These contaminants result from the reaction of SCFs with
moisture.
The FS determined that, the most effective method of addressing
ground-water concerns at the Fort Hartford Site is by continuing
to divert mine water away from SCFs and relocate them to drier
areas of the mine. Air will be most effectively addressed in a
contingency manner outlined in subsequent sections of this
document. The first part of the selected remedy requires portal
doors to seal off the mine during night hours. Doors would be •
opened during daylight hours when adequate turbulent mixing
conditions exist to disperse ammonia away from the ground into
the upper atmosphere. Should monitoring reveal that ammonia
levels are not being .reduced acceptably, portal doors will be
permanently sealed off and emissions will be ducted to high
stacks. 'These high stacks would inject air into the upper
atmosphere, a proven way of adequate dispersion.
A ground-water monitoring- program will be conducted both to
determine the effectiveness of the ground-water plume containment
as well as reduction in contaminant concentrations. Air
monitoring will be conducted to determine if the portal doors
being opened and closed are effective. Since wastes are
remaining on-site as part of this remedy,, ground-water and air
data will be evaluated in the five-year review to determine if
further action is required.
This selected alternative for the Fort Hartford Site will address
all known concerns at the Site. It is intended to address the*
entire Site with regards to threats to human health and the
environment posed by the Site, as indicated by the Risk
Assessment included in the September 1994 RI report. Findings of
the Risk Assessment are summarized in Section V of this document.
This is the only ROD contemplated for this Site.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
.Section IV, Summary of Site Characteristics
Page 1
IV. SUMMARY" OF SITE CHARACTERISTICS
A. CONTAMINANT CHARACTERISTICS
The primary constituents of concern at the Site are ammonia,
chlorides and aluminum. These are all by-products of the
reaction of SCFs with water. Chlorides and aluminum are
mobilized by water passing through the bulk material and
carrying them downward into subsurface formations via
percolation.
Ammonia is formed in the gaseous phase when SCFs contact
water. More details of the ammonia concentrations predicted
by the RI modelling are given below in this section.
If Site soils contained sufficient concentrations of these
constituents, the potential would exist for cross-media
transfer to underlying water bearing zones since these
contaminants would not sorb well on soil. Since Site soils
do not contain appreciable concentrations of these
contaminants, this is not a concern.
Due to the above-mentioned affinity of these contaminants
for the aqueous phase, no SCF-related exceedances were found
in the sediment of the streams around the site while a small
number of slight exceedances were found in surface water.
B. AFFECTED MEDIA CHARACTERISTICS
For site management purposes, the Fort Hartford site can be
divided into specific affected media. The following
discussion summarizes the characteristics of each media that
are relevant to the identification, screening and selection
of remedial technologies and strategies. For more detailed
information on sampling and results, refer to the Remedial
Investigation Report on file in the Adminiscrative Record
for the Fort Hartford Stone Quarry Superfund Site.
1. Soil
The EPA RI at the site took surficial and subsurface
(vadose) soil samples to characterize the nature and
extent of any soil contamination. Due to the size of
the site (over 850 acres), sampling efforts focused on
those areas most susceptible to site-related impacts.
Surficial samples were collected from 0 to 12" and 12
to 24" and composited. Discrete vadose samples were
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Fort Hartford-Stone Quarry NFL Site
Record of Decision
Section IV. Summary of Site Characteristics
Page 2
collected at 5 foot intervals until the water table or
bedrock was intercepted.
During the weeks of August 24, 1992, to September 10,
1992, 20 surficial soil samples were collected. Of the
20 locations, three were selected as offsite background
locations for comparison.
Vadose sampling was conducted from August 31 to
September 11, 1992. In all, 33 samples were collected
from 15 locations.
Low level exceedances were no.ted for various compounds
and analytes in both surficial and vadose zone samples.
Based on these exceedances, the following contaminants
were retained for further analysis in the Risk
Assessment. (See Section V of this document.)
Volatiles (VOAs) and Semivolatiles (PNAs)
Naphthalene 2-methylnaphthalene Phenanthrene
Fluoranthene . . Benzo(a).anthracene Chrysene
Carbazole Pyrene Benzo'(a) pyrene
Eenzo(g,h,i)perylene Acenaphthene Dibenzofuran
Benzo(k)fluoranthene Acenaphthylene Benzene
Anthracene Benzo(b)fluoranthene Fluorene
Indeno(1,2,3-cd)pyrene Dibenzo(a,h)anthracene
(These volatiles may indicate that the area is impacted by fossil
fuels. )
Inorganics/Wet Chemistry Parameters
Chlorides Ammonia Aluminum Arsenic
Sodium Potassium Barium Beryllium
Chromium Copper Cobalt Iron
Vanadium Zinc
Pesticides/PCBs
alpha-BHC 4,4'-DDT 4,4'-DDE Dieldrin
Methoxychlor gamma-Chiordane Endrin aldehyde Endrin
Aroclor-1260 Heptachlor epoxide
£'
(These chlorinated pesticides were also retained although the ^
source of these compounds was suspected to be non site-related.)
Five surface soil samples collected on-site were found
to contain chloride concentrations in excess of two
times background. Each of these locations (i.e. mine
entrances, mechanic shop) are associated with past Site
operations where Salt cake fines may have been released
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section TV, Summary of Site Characteristics
Page 3
to"the environment. One vadose sample was found to
contain elevated concentrations of leachable chlorides.
Surface soil leachable ammonia concentrations were
above the method detection limit at 10 locations.
These elevated concentrations were at locations
corresponding to elevated chloride levels. Three
vadose zone sampling locations showed samples with
elevated concentrations of ammonia.
Aluminum concentrations in all surficial soils were
below background levels. Two vadose samples had
elevated aluminum concentrations. These results did
not suggest a significant departure from naturally-
occurring levels and are not considered indicative of
site impacts, however, due to the association between
SCFs and aluminum, this parameter was retained for
inclusion in the risk assessment.
A geotechnical investigation was also performed at the
Site. This study was used to gain additional
understanding of the subsurface environment and soil
and ground-water migration pathways. This report can
be found in the Information Repository for the Fort
Hartford site.
2. Surface Water and Sediments
Surface water samples were collected on a quarterly
basis from August 1992 to May 1993 (four quarters) in
order to account for seasonal variation in flow
conditions. Surface water samples included all aqueous
samples from i.nstream locations (Rough River, Caney
Creek and Cane Run Creek), natural on-Site spring
locations and the Rough River and Caney Creek mine
flumes. Figure 4.1 shows the location of all surface
water and sediment samples.
Mine flumes were evaluated based on the possibility
that they may have served as historical sources of
instream contamination. Evaluation of data in
.comparison to background concentrations in the streams
into which the respective mine flumes flow resulted in
the inclusion of potassium, sodium, ammonia, chlorides,
sulfates, barium, cadmium, calcium, chromium, copper,
magnesium, selenium and zinc on the list of possible
source-related contaminants.
Instream surface water results show that aluminum,
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Fort Hartford- Stone Quarry NPL Site
Record of Decision
Section TV, Summary of Site Characteristics
Page 4
potassium, ammonia, chlorides, barium, calcium, iron,
lead, magnesium, nickel and zinc were each detected in
at least one sample at a concentration greater than
background, although these were quite infrequent and
sporadic. This has led to the conclusion that the
observed exceedances do not show a pattern indicative
of continual influx of SCF constituents. In spite of
this fact, all of the above-mentioned constituents were
retained for inclusion in the risk assessment.
Spring data showed impacts for magnesium, potassium
sodium, selenium, chlorides, sulfates, ammonia,
cadmium, chromium, iron, manganese, vanadium and zinc.
Each parameter was retained for the risk assessment.
Sediment samples were collected during August 1992 and
February 1993, coinciding with the first and third
surface water sample delivery groups. These samples
were collected for contaminant analysis as well as
acute toxicity testing.
Sediments at locations BQ27, CBS6 and CQ37 showed signs
of historical SCF impacts. These locations were
predictably near mine entrances.
3. Groundwater
Figure 4.2 shows all ground-water monitoring locations
for the Fort Hartford site. Sixteen ground-water .
monitoring locations were selected to determine the
nature and extent of impacts to ground water at the
site (one of the original 17 locations came up dry).
Multiple samples were collected from discrete intervals
using the Westbay (Trademark) multi-level monitoring
system. The monitoring system and sample zones were
all approved by EPA. A total of 32 ground-water
samples were collected from July 27, 1993, to August
18, 1993. The slightly impacted and impacted zones
were determined to be:
Haney/Upper Big Clifty Contact at MW4 ^
Upper Big Clifty Sandstone at MWs 8, 9, and 10
Lower Big Clifty Sandstone at MW10
Beech Creek/Elwren Contact at MWs 9 and 18
Reelsville Limestone at MW7
Please refer to Section II of this document for a
description of the vertical location of each stratum.
Ground water at the following well locations shows
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section IV, Summary of Site Characteristics
Page 5
indications of possible site-related impacts: MW4,
MW7, MW8, MW9, MW10, and MW18. Based on the results
from the zones at each location, the parameters listed
in Table 4.1 were retained for inclusion in the risk
assessment. Inclusion of a parameter on the list does
not indicate its linkage to SCFs.
Residential Ground-water Sampling
Ground water was also sampled at off-site residential
locations in conjunction with the on-site sampling
efforts. Residential wells within a 2-mile radius of
the center of the Site were sampled. Figure 4.3 shows
these locations. All results were below drinking water
standards.
4. Air
An Air Pathway Analysis was conducted to characterize
the nature and extent of contaminant emissions in air
from the Site. It was revealed that the only
contaminant in significant levels was ammonia. For
more detail on the analysis, the Fort Hartford Site Air'
Pathway Analysis report, dated October 28, 1993, can be
found in the Administrative Record for the site.
The emission and meteorological monitoring program was
conducted during a 17-month period from August 1990
through December 1992. .Air monitoring locations, are
shown in Figure 4.4 of this document. Modelling was
performed with the data collected in this effort.
Based on the modelling, exceedances of the KNREPC 8-
hour ammonia standard of 0.4 mg/m3 were predicted along
the site perimeter with the greatest potential
exceedances along the north and northwestern sides of
the site.
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Ft. Hartford Stone Quarry Site
Table 4.1 '"
Section IV, Page 6
SUMMARY OF GROUNDWATER BACKGROUND ACTION LEVEL EXCEEDANCES
FOR ALL MONITORING FORMATIONS
FORT HARTFORD STONE QUARRY NPL SITE
OLATON. KENTUCKY
PARAMETER
ORGANICS
2 — Butanone
Benzene
Sjyrene
Xylenes
Toluene
Ethylbenzene
Phenol
2-Methylphenol
4-Methylphenol
Naphthalene
2 -Methylnaphthalene
4.4'~DDT
INORGANICS
Arsenic
Barium
Cadmium
FORMATION
HANEY/MaBC
UMaBC
LMoBC
BC/ELWREN
REELS vi LLE!
x -' '. •[
X
X I
X
X
X
X
X
1_ x
X
x i.
X
x i.
x 1
X i
i
<
x !
X
Calcium |l X
Chromium j! X
Cobalt t
Copper
Iron
1 Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Thallium
Zinc
Cyanide
Ammonia
Chlorides
1 Sulfates
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
i
1
1
x :
i
;
x ;•
ii
i
j
x !
i
i
X i
X
X
X
X
X
X
X
X
X
X
X
X
i
x f
x !
NOTES:
All organic parameters detected in impacted wells are listed.
Inorganic and wet chemistry parameters are listed if they exceeded the BAL for the formation.
HANEY/MgBC = Haney Limestone/Big Clifty Sandstone Contact
UMgBC = Upper Big Clifty Sandstone Formation
LMgBC = Lower Big Clifty Sandstone Formation
BC/ELWREN = Beech Creek/Elwren Contact
REELSVILLE = Reelsville Limestone Formation
Background (non—impacted) zone data is not presented.
-------
ROUGH, RIVER,,.
L B DAVISON WILDLIFE
MANAGEMENT AREA
©
LEGEND
- SURFACE WATER/SEDIMENT
SAMPLE
- SPRING SAMPLE
EXAMPLE:
NOTE: EACH QUARTER OF THE SYMBOL
REPRESENTS A QUARTER OF SPRING
SAMPLING BEGINNING WITH THE TOP
RIGHT QUARTER AND MOVING IN A
CLOCKWISE DIRECTION
® -1st QUARTER ONLY
$ - 2nd QUARTER ONI Y
•ft - 1st AND 2nd
QUARTER
® - 3rd QUARTER
A - 2nd AND 3rd
QUARTER
A - 1st, 2nd AND 3rd
QUARTER
9 - I3t AND 4lh
QUARTER
4> - 2nd, 3rd. AND 4lh
QUARTER
$ - 4th QUARTER
• - 1st, 2nd. 3rd AND
4th QUARTER
© - DRY; NOI SAMPLED
- MINE ENTRANCE
- ROAD (INIFRSECTION)
- BARMET PROPERTY BOUNDARY
INTERMITTENT STIHAM/SWALE
- - RIVER/CREEK
1000 0
SCAIE
1000
nit
2nd QUARTER
SOURCE: SURFACE/SEDIMENT
AND VADOSE/SOIL SAMPLE LOCATIONS
SURVEYED AND PROVIDED BY 0( DEN ENVIR
AND ENERGY SERVICES.
. Figure 4.1
.^.i.../-./^,.-.
(T)
O
rf
H-
O
3
(u
00
re
'
-------
CLff 'DEM QUARRY
RIVCR PORTAL
^
7'0"f^^ vy frO 6
CANCY CftffK LOBC
'u n^ or
r> **/s /
w
uoNimtifK HILL
MW4 • ^MWOMFP uamrotme Mil
MWl A INSfAttn MHM TO Kl
DWC DATC: 10/12/93 IDWC N«UI RIIMAC25
o
0
00
-------
2' 3
L B DAVISON WILDLIFE
RIVER MANAGEMENT AREA
\
LEGEND
- RESIDENCES
1 . - MR. JAMES A MILLER
2 - ABANDONED (NO RESIDENT)
3 ' - MR. H.L. BOWMAN
4 - MR. WILLIAM CRUME
S - MRS. JACKIE HOUSE
0 - UNKNOWN
(WEEKEND HUNTING CABIN)
7 - MRS MYRTYLE HARDER
• - MR JEFF CARTER
8 - MR. JAMES MARTIN
U - MRS. MARY PMILPOT
n - MR CECIL JACKSON
12 - MR. KEN BENNETT
-ft. - ROAD (INTERSECTION)
- — - INTERMITTENT STREAM/SWALE
= =- RIVER/CREEK
- BARMET PROPERTY BOUNDARY
2000
SCALE
2000
FEET
SOURCE: SURVEYED AND PROVIDED
BY OGt'EN ENVIR.
AND ENERGY SERVICES.
.Figure 4.3
DWG OATt: 10/07/83 |[)WC HAKE HUMACI?
CO
s
•
-------
\
ROUJ
L 8. DAVISON WILDLIFE
RJVE.R MANAGEMENT AREA ,-
^
LEGEND
ROAD (INTERSECTION)
INTERMITTENT STREAM/SWALE
RIVER/CREEK
BARMET PROPERTY BOUNDARY
to
n>
o
o
a
ROUGH RIVER PORTAL
ARENA HAULWAY
CANEY CREEK G--CUT PORTAL
CANEY CREEK A-CUT PORTAL
METEOROLOGICAL TOWiR
2000 0 2000
SCALE" FEET
SOURCE: SURVEYED AND PROVIDED
BY OGDEN ENVIR.
AND ENERGY SERVICES
Figure 4.4
OWG DATF 10/07/93 |PWC NAUC:RUMAM1
00
n>
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 1
V. SUMMARY'OF SITE RISKS
Air, ground water, surface water and sediments in streams around
the site, source material (SCFs) and soils were all considered to
have potentially complete current and future exposure pathways.
The risk assessment was performed for the matrices listed above
and can be found in the September 1994 RI report.
A_._ SELECTION OF CONTAMINANTS OF POTENTIAL CONCERN
The hazard identification involved the selection of contaminants
of potential concern (COPCs), detected contaminants which have
inherent toxic or carcinogenic effects that are likely to pose
the greatest concern with respect to the protection of public
health and the environment. Selected contaminants of concern
which were found to drive the Risk Assessment (or account for
approximately 90% of the risk) at the Fort Harford site include:
* Aluminum
* Ammonia
* Chlorides
Delineation of all COCs for each media can be found in Tables 5.1
through 5.5 of this document. Monitoring data from the RI report
were used to calculate exposure concentrations for the exposure
scenarios described below.
B^_ EXPOSURE ASSESSMENT
The objective of the exposure assessment is to estimate the type
and magnitude of exposures to the chemicals of potential concern
that are present at or migrating from-the site. The results of
the exposure assessment are combined with chemical-specific
toxicity and carcinogenicity information to characterize
potential risks.
Populations at greatest risk are those who would potentially
inhale gaseous contaminants emanating from mine portals and those
who would potentially use contaminated ground water from bedrock
aquifers. Inhalation is the primary route of exposure for the
air pathway. Ingestion (potable use'1 would be the primary
exposure route for ground water.
Exposure Point Concentrations
Exposure point concentrations were calculated for air, ground
water, surface water and sediments, source material {SCFs) and
soils. The reasonable maximum exposure (RME) point concentration
was calculated after testing the data's distribution. The 95%
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Fort Hartford. Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 2
Upper Confidence Limit (UCL) on the arithmetic mean was'
calculated for each COPC in each area. The RME was the lower of
the 95% UCL or the maximum detected concentration.
Because the exposure point concentrations (UCLs) tables are quite
numerous, they will not be included in this document. They can,
however, be found in Appendix I to the September 1994 RI report
for the Fort Hartford Site, Tables 1 through 17. Air, ground
water, surface water and sediment, source material and soil
(surface and subsurface) data from the RI were used to derive
exposure point concentrations. The RI report contains data for
samples taken for the COPCs for the time frames and locations
discussed in Section III of this document.
Some of the analytical results are reported as "non-detects°,
meaning the actual concentation of the contaminant analyzed for
is between zero and the detection limit. The risk assessment
calculations were based on assuming that all non-detect samples
were contaminated at a concentration equal to one-half the
detection limit. This makes the risk assessment more
conservative.
Exposure Dose Calculations
Average daily exposure doses (ExDs) were calculated for each
exposure pathway using standard assumptions in EPA Risk
Assessment guidance. Exposure scenarios and calculations with
assumptions will be summarized below. For cancer effects, doses
were averaged over a lifetime (70 years); doses for non-cancer
effects were averaged over the exposure period (U.S. EPA 1989a).
It is important to note that each exposure scenario is both for
present and future conditions. The scenarios have been evaluated
under current conditions (since they are more conservative in
these cases, ex. contaminant levels will dissipate with time),
but are evaluated for future conditions as well.
The results of the risk calculations for each of the following
scenarios are presented in the Risk characterization portion of
this section.
1. Soil Pathway (Direct Ingestion and Dermal Contact)
This pathway addresses the potential for intake of contaminants
through direct ingestion 'of contaminated soil and dermal contact
with said soil (and subsequent transdermal absorption). Figure
5.1 and Table 5.6, respectively, provide risk formulae and
risk/hazard assumptions applied for calculating soil exposure
point doses at the Fort Hartford site.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V. Risk Analysis
Page 3
2. Surface Water Pathway (Direct Ingestion)
The human exposure pathway for surface water was evaluated on the
basis of direct ingestion of surface water contaminants. Figure
5.2 presents the formulae with assumptions used to calculate
chronic daily intake and risk/hazard via the surface water
pathway. As stated previously, surface water includes all
streams adjacent to the site as well as springs and mine flumes.
3. Sediment Pathway (Direct Ingestion and Dermal Contact)
The sediment pathway addresses the risk/hazard based on the
potential for intake of contaminants through direct ingestion of
contaminated sediments and dermal contact with these sediments
(and subsequent transdermal absorption). Formulae and
assumptions are similar to those in the soil and surface water
scenarios and have been adapted from RAGS, Volume I, Parts A&B,
to account for site-specific conditions. More details on
calculations and assumptions for this pathway can be found in
Figure 7.3 and Table 7.13 of the September 1994 RI report. These
are identical to Figure 5.3 and Table 5.8, respectively, in this
document.
4. Ground water
The human exposure pathway for ground water was based, on direct
ingestion of ground-water contaminants. Exposure point
concentrations and subsequent risk calculations were performed on
a zone-specific basis for each of the following formations
beneath the Site: Haney Limestone/Big Clifty Sandstone Contact,
Upper Big Clifty Sandstone, Lower Big Clifty Sandstone, Beech
Creek/Elwren. Contactand the Reelsville Limestone. No specific
risk/hazard characterization was performed for the residential
wells sampled near the Site since no parameter was detected in
excess of any on-site background levels. Figure 7.5 and Table
7.21 in the September 1994 RI report give assumptions and
calculations used for exposure doses and carcinogenic as well as
non-carcinogenic risk. These have been adapted from RAGS, Volume
I, Parts A&B, to account for site-specific conditions. Figure
5.4 and Table 5.9, respectively, in this document, correspond to
these two cites from the RI.
5. Source Material (SCFs)
This pathway addresses the potential for intake of contaminants
through direct ingestion of source material and dermal contact
(and subsequent transdermal absorption) with the SCFs. Figure
7.5 and Table 7.21 in the RI report (Figure 5.4 and Table 5.9,
respectively, herein) provide formulae and assumptions for
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 4
calculating exposure doses and subsequent carcinogenic and non-
carcinogenic risks. Risk/hazard formulae are standard for
calculating recreational use exposures (through chronic daily
intake).
6. Air Pathway (Inhalation Pathway)
The air pathway encompasses both gaseous (i.e., ammonia) and
particulate-related exposures. For ammonia, the results of one
year of mine portal monitoring were compiled and reduced to
produce the input database for refined dispersion modelling.
Details on the steps taken in selecting the refined model and the
actual dispersion modelling exercise can be found in the Air
Pathway Analysis report on file in the Fort Hartford Information
Repository. Modelled values were compared to exposure criteria
and ARARs.
PM10 monitoring was conducted during August and September of- 1993
to determine if visible fugitive particulate emissions at the
site were presenting concerns to human health and the
environment.
C. TOXICITY ASSESSMENT
Under current EPA guidelines, the likelihood of carcinogenic and
non-carcinogenic systemic effects due to exposure to site
chemicals are considered separately. Criteria for evaluating the
potential of site chemicals to cause these two types of adverse
effects are described below.
Criteria for Non-Carcinogenic Effects
The Reference Dose (RfD) is an estimate of the highest human
intake of a chemical, expressed as mg/kg/day, that does not cause
adverse effects when exposure is long-term (lifetime). RfD
values are based on animal or human toxicity studies from which a
no-observed-adverse-effect level (NOAEL) is experimentally
determined. The NOAEL is the highest dose at which there was no
statistically or biologically significant adverse effect -f.
observed. The RfD is derived by dividing the NOAEL from the -\
selected study by an uncertainty factor. The uncertainty factor
consists of multiples of 10 to account for specific areas of
uncertainty in the available data.
The dose calculated from the exposure assessment is compared to
the RfD to determine whether adverse effects might occur. If the
predicted exposure dose is below the level of the RfD, no adverse
health effects are expected according to current EPA guidelines.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 5
Table 5.10 herein gives toxicological database information for
all potential contaminants of concern at the Fort Hartford Site.
Criteria for Carcinogenic Effects
EPA uses a weight-of-evidence system to convey how likely a
chemical is to be a human carcinogen, based on epidemiological
studies, animal studies, and other supportive data. The
classification system of EPA for characterization of the overall
weight of evidence of carcinogenicity includes: Group A - Known
Human Carcinogen; Group B - Probable Human Carcinogen; Group
C - Possible Human Carcinogen; Group D - Not Classifiable as to
Human Carcinogenicity; Group E - Evidence of non-Carcinogenicity
for Humans. Group B is subdivided into two groups: Group Bl -
limited human evidence for carcinogenicity; and Group B2 -
sufficient data in animals, but inadequate or no evidence in
humans.
For chemicals with carcinogenic effects, EPA calculates the
cancer risk associated with a given dose by multiplying the dose
from a given route of exposure by a cancer potency factor or
potency slope. EPA derives potency factors from the upper 95%
confidence limit of the slope of-the extrapolated dose-response
curve, which shows the relationshiop between a given dose and the
associated tumor incidence. As a result, the predicted cancer
risk is an upper-bound estimate of the potential risk associated
with exposure. Table 5.10 of this document gives the cancer
slope factors (CSFs) for all potential contaminants of concern at
the Fort Hartford Site.
D. RISK CHARACTERIZATION
The risks for each of the scenarios-presented in the Exposure
Assessment portion of this section are quantified in this section
and can be found summarized in Table 5.7. Table 5.7 is a
synopsis of tables 5.11 through 5.13. All of the added lifetime
risks for each scenario, as well as the total carcinogenic and
non-carcinogenic risks presented by the site are included.
For Table 5.7, more than one risk is presented under the surface
water, sediments, ground water, and source material headings.
When totalling site risk, the more conservative (higher) number
is used to obtain the total at the bottom of the table. In this
way, a worst-case scenario is presented for carcinogenic and non-
carcinogenic effects. As can be seen, the total site presents
unacceptable carcinogenic as well as non-carcinogenic risks.
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Fort Hartford. Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 6
An acceptable" risk is one which is less than 1 x 10"4 for
carcinogens and less than or equal to 1.0 for non-carcinogens.
As shown in Table 5.7, soils alone present no unacceptable risks.
Surface water in both springs and streams presents an
unacceptable non-carcinogenic risk. Of the five ground water
zones, all except one, the Beech Creek/Elwren are acceptable for
carcinogens, while all zones except the Reelsville are
unacceptable for non-carcinogenic risks. For the scenario
evaluated, source material provides no unacceptable risks,
however, water from reaction with source material poses
unacceptable non-carcinogenic risks.
The "N.A's" in Table 5.7 under the air.headings appear since air
was not evaluated in the way of a conventional risk assessment.
It was known that air would be the driving media for the Fort
Hartford Risk Assessment and a decision was made between risk
assessors and modellers to only compare modelled ammonia
concentrations to the EPA annual standard of 0.1 mg/m3 instead of
performing a Hazard Index calculation (ammonia presents no
carcinogenic risks). The decision was that if ammonia
concentrations exceeded the EPA standard, that the Hazard Index
would be considered greater than 1.0 (unacceptable). Figure 5.3
is an example of' the isopleths (modelled lines of constant
concentration) and how concentrations were determined at
different points on-site.
E^ ENVIRONMENTAL RISKS
An ecological evaluation was performed at the Site which was
detailed in the Ecological Assessment Summary Report as well as
Section 3.5 of the RI Report. A tiered approach was taken to
first identify the potential ecological stressors and receptors,
and secondly to evaluate the stresses (if any) on the ecosystem.
Various endangered species surveys were performed and no
endangered species were observed or identified as being a concern
on-site. Both aquatic and terrestrial surveys were performed, as
well as toxicity testing, to conclusively determine the effect of
the site on the aquatic and terrestrial habitats in the area.
Endangered Species and Critical Habitats ?
' <•.
1. Orange Pimpleback Mussel (Plethobasus cooperianus)
A report entitled Aquatic Mollusca of the Rough River in the
Vicinity of the Ft. Hartford Mine Site, Ohio County, Kentucky was
prepared by Dr. Mark E. Gordon of the Tennessee Cooperative
Fishery Research Unit. This report was submitted to EPA in July
1991. This report stated that the endangered mussel Plethobasus
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V. Risk Analysis
Page 7
cooperianus (not found in the Rough River or Caney Creek) was
typical of larger streams than those at the Fort Hartford Site.
Dr. Gordon did note depauperate fauna in Rough River just
downstream of the KPDES effluent discharge pipe location, but was
unable to conclude whether this was caused by former mining
activities in the area (i.e., limestone rock pushed into the
stream) or if the condition was site-related. Dr. Gordon
concluded that there was no evidence that the depauperate species
in Rough River at this location were site-related, however, he
could not rule out this possibility.
2. Indiana (Myotis sodalis) and Gray (Myotis grisescens) Bats
Dr. Michael J. Harvey of Tennessee Technological University
conducted the survey and prepared the report, Survey for
Endangered Indiana and Gray Bats at- the Ft. Hartford Mine Site,
Olaton, Ohio County, Kentucky. This report was also submitted to
EPA in July 1991. During the three day study at the site, none
of the endangered species bats were discovered. Dr. Harvey's
report concluded that due to the continuing presence of human
activity in and around the mine, that suitable habitat did not
exist for these species. He went on to state that, "It is quite
unlikely that operations/activities at the site would have any
negative impacts on Indiana or gray bats, or on other bat
species.".
Aquatic Effects
The authors of the aquatic survey .(Ecological Specialists, Inc.)
concluded that statistical data indicated no significant
difference in numbers between study sites (study sizes were small
which resulted in wide confidence margins). Also, several non-
point source discharges such as feed lot runoff (i.e., sewage and
farm wastes) and historical strip mining activities were
identified as potential significant ecological stressors to the
Caney Creek and Rough River.
The biotic indices determined by Ecological Specialists, Inc.,
indicate slightly better water quality in the distal upstream
Rough River sample. The biotic indices are equivalent for all
other sample locations which indicates that Caney Creek may have
an effect on the proximal upstream and downstream faunal species
of the Rough River. It was also found through biotic indices
that the upstream (background location CD showed a source
affecting Caney Creek other than the Ft. Hartford site.
In addition, Ecological Specialists, Inc. concluded that "the
lack of habitat, water depth, and poor water quality all
contribute to the low density and diversity of fauna throughout
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 8
Caney Creek." Due to Che low dissolved oxygen, high turbidity,
and resulting high biological/chemical oxygen demand, density and
diversity appear to be lower than expected in the Rough River.
Toxicity observed in upstream Caney Creek samples and the lack of
significant difference between sample locations in surface waters
associated with the site indicate no adverse, site-related
ecological effects.
Terrestrial Effects
The terrestrial survey identified stressed vegetation near
historical gaseous emission sources (i.e., former breakthrough
locations on the Rough River mine lobe perimeter) or a mine
portal. The stressed vegetation near the breakthrough locations
was found to be rejuvenating, and .the remaining stressed
vegetation was a result of timbering/logging that had been
historically conducted on-site. The terrestrial report, as well
as the aquatic report are included in Appendix F. of the September
1994 Remedial Investigation report for the Fort Hartford site.
FV REMEDIAL GOALS
In order to facilitate the FS process, remedial goals for each
impacted medium are necessary. Remedial Goals are those
concentrations of the COCs carried through in calculations for
each exposure scenario of the risk assessment. Remedial Goal
Options (RGOs) are pathway and medium specific, risk-based
remedial goals, calculated under the exposure scenarios used to
estimate risk and/or hazard. RGOs were calculated.for all
exposure pathways which were found to exceed-1 x 10"4 cancer risk
and/or a hazard index (HI) of 1.0. Pages 7-135 through 7-137 of
the Risk Assessment for the Fort Hartford Site give all remedial
goal options calculated. These RGOs can also be found in Tables
5,14 through 5.16 of this document.
The Remedial Goal for the air media at the Site is ammonia and it
is being addressed via diurnal containment of emissions with
venting in evening hours when favorable conditions exist for .
dispersion. The remedy contains contingency measures for ducting
to a high stack for proven dispersion should nocturnal venting*
fail to meet EPA's expectations.
The remedial goal for air at the Site is as follows:
Ammonia: 0.4 mg/m3 (8-hour Kentucky ARAR)
The RGOs for contaminants in ground and surface water will be
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section V. Risk Analysis
Page 9
monitoring parameters at the Site since these contaminants are
being addressed at the Site via source control, continued ground-
water monitoring, diversion, and natural attenuation.
G^_ UNCERTAINTIES
All estimates of risk are based upon numerous assumptions with
uncertainties. In addition to limitations associated with site-
specific chemical data, other assumptions and uncertainties that
affect the accuracy of the site-specific risk.characterizations
result from the extrapolation of potential adverse human health
effects from animal studies, the extrapolation of effects
observed at high-dose to low-dose effects, the modelling of dose-
response effects, and route-to-route extrapolation.
The use of acceptable levels (established standards, criteria and
guidelines) and unit cancer risk values which are derived from
animal studies introduces uncertainty into the risk estimates.
In addition, the exposure assumptions used in estimating
individual dose levels are often surrounded by uncertainties. As
such, these estimates should not stand alone from the various
assumptions and uncertainties upon which they are based.. -In •
developing numerical indices of risk, an attempt is made to
evaluate the effect of the assumptions and limitations on the
numerical estimates.
The uncertainty factors which are incorporated into these risk
estimates are believed to be conservative. As such, when they
are considered collectively, exposure and subsequently risk may
be overestimated. On the other hand, these risk calculations
were based on present conditions at the site, including present
concentrations of contaminants in the various sice media.
Additional risk could occur should the concentrations increase in
any of the site media.
Confidence in the computed risk and hazard values for source-
related pathways is low. The exposure pathways developed to
evaluate potential human health effects related to these media
would not be completed under most reasonable future site use
scenarios. Furthermore, the data used to compute risk/hazard are
not equivalent in quality to that produced for other media. Due
to the nature of the materials, the precision and accuracy of the.
analytical methods was reduced. Therefore, risk/hazard values
computed for source related media should be used for screening
purposes only.
H. CONCLUSIONS
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Fort Hartford. Stone Quarry NPL Site
Record of Decision
Section V, Risk Analysis
Page 10
Hazard Indices were unacceptable for surface water (springs and
in-stream), ground water (all formations assessed), and source
material (reaction water). The Beech Creek/Elwren aquifer had
only a slightly unacceptable cancer risk, which may have been due
to naturally-occurring petroleum chemicals.
An alternative approach was developed to address air risks since
the site media did not fit the conventional risk assessment mold.
Modelling produced isopleth diagrams depicting maximum 8-hour,
maximum 24-hour and annual average ammonia concentrations
resulting from mine portal emissions. Ammonia concentration
patterns were predicted for years 1993, 1998, 2003, and 2013. An
acute exposure standard of 0.4 mg/m3 (KNREPC, 8-hour) was
established for comparison with predicted 24-hour average
concentrations. A chronic standard'of 0.1 mg/m3 (EPA) was
established for comparison to maximum annual average
concentrations. Any exceedance of these standards is considered
to be equal for risk management purposes to a HI of greater than
1.0.
Between 1993 and 2013 the 0.1 mg/m3 annual average ammonia
concentration isopleth is predicted to retract significantly.
The 8-hour KNREPC standard of 0.4 mg/m3 is predicted to be
continually exceeded between the years 1993 and 2013 (HI greater
than 1.0) under baseline (no action) conditions.
Other than past stressed vegetation and currently stressed
vegetation in the immediate vicinity of -the mine portals, the
studies find no evidence of site-related ecological stress.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions in
this ROD, may present an imminent and substantial endangerment to
public health, welfare and the environment.
-------
Ft. Hanford Stone Quarry Site
Section V, Page 11
TabIfe-5.1
Surface Sol Contaminant* of Concern
Benzolalanthracene
Benzolb/lOfluoranthene
Benzolalpyrene
lndeno(1,2,3-cd]perylene
' Dibenzola.hlanthracene
Beryllium
Notes:
Compounds/parameters listed are those detected at concentrations in excess of the BAL
and which were projected to pose a significant potential individual risk/hazard
(carcinogenic unit risk > 1E-7 or hazard quotient >0.1).
Parameters which were not detected in any onsite soil sample at a concentration in
excess of the corresponding BAL are not listed.
Table 5.2
Surface Water Contaminants of Concern
Irntream Surfac* Water
Impacted Spring*
Aluminum (CC.CR)
Iron (CC.CR)
Lead (CO
Aluminum (1)
Cadmium (1)
Iron
Manganese (1)
Sodium
Vanadium (1)
Chlorides
Sulfates
Note*:
Compounds/parameters listed* are those detected at concentrations in excess of the BAL
and which were projected to pose a significant potential individual risk/hazard
(carcinogenic unit risk >1E-7 or hazard quotient >0.1) or had a maximum four quarter
average in excess of the corresponding ARAR.
Parameters which were not detected in any instream surface water sample at a
concentration in excess of the corresponding BAL are not listed.
(1) indicates parameters for which the exposure concentration used in the baseline risk
assessment was less than two times the four quarter background average in the
hypothetical receiving stream.
(RR) = Rough River; (CO = Caney Creek; and (CR) = Cane Run -- these designation
were used to show which stream produced samples with parameter concentrations in
excess of corresponding background.
-------
Ft. Haniurd Stone Quarry Sice
^ Section V, Page 12
TABLE 5.3 - SUMMARY OF GROUNDWATER CONTAMINANTS OF CONCERN
ON A FORMATION SPECIFIC BASIS
FORT HARTFORD STONE QUARRY NPL SITE
.OLATON, KENTUCKY
FORMATION
PARAMETER
ORGANICS
Benzene
Styrene
4, 4' -DDT
INORGANICS
Arsenic
Barium
Cadmium
Chromium
Iron
Head
1 Manganese
' Potassium
i Selenium
: Sodium
i Thallium
i Ammonia
; Chlorides
Su (fates
HANEY/MqBC
X
X
X
X
X
X
X
X
X
X
X
X
X
UMqBC
X
X
X
X
X
X
X
X
X
X
LMqBC
X
X
X
X
X
X
X
X
BC/ELWREN REELSVILLE
X
X
X
X
X X
X X
X X
NOTES:
Inorganic and wet chemistry parameters are listed if they exceeded the BAL for the formation.
HANEY/MgBC = Haney Limestone/Big Clifty Sandstone contact
UMgBC = Upper Big Clifty Sandstone formation
LMgBC = Lower Big C!if*' Sar^' •'- '-"nation
BC/ELWREN = Bet -
REELSVILLE = Ret —on
Background (non-impacteoi /.one data is not presented.
Only those parameters with individual unit risk >1E~7, hazard quotients >0.1 and/or that
were found to exceed an ARAR at the maximum two quarter average were retained as COCs.
-------
Ft. Hanford Stone Quarry Site
V, Pago 1
TABLE 5.4 - SOURCE MATERIAL CONTAMINANTS OF CONCERN
ON A SUBSAMPLE SPECIFIC BASIS
FORT HARTFORD STONE QUARRY NPL SITE
OLATON, KENTUCKY
PARAMETER
Aluminum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
.Iron
•Lead
: Manganese
Nickel
I Potassium
I Selenium
: Silver
•Sodium
Thallium
1 Vanadium
Ammonia
Chlorides
..Sulfates
AS RECEIVED
MATERIAL
X
X
X
X
X
'i
.
WATER FROM
REACTION
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
BASIS •
SMCL
HQ.MCL .
RISK.HQ
RISK.MCL,
HQ.MCL
HQ.MCL
SMCL !
MCL-TT '
SMCL i
MCL ';
HQ .
HQ.MCL i
HQ.HA :
HQ.HA i
HQ.MCL 1
HQ.RAL -.
HQ.HA . !
SMCL
SMCL ;
NOTES:
As received material COC were selected based on individual unit risk of > 1E-7
and/or hazard quotient in excess of 0.1.
Water from reaction COCs were selected based on individual unit risk > 1E-7
hazard quotient >0.1 and/or exceedance of ARAR
Basis indicates the reason the parameter was retained as a COC.
MCL = Maximum Contaminant Level; SMCL = Secondary MCL; HA = EPA Health Advisory;
MCL-TT = Treatment Technology Based MCL; RAL = Superfund Removal Action Level
HEAST-RfD = Specific Reference Dose Drinking Water Equivalent Concentration;
HQ = Hazard Quotient > 0.1.
-------
Ft. Hartford Stone Quarry Site
Section V, Page 14
Table 5.5
Sediment Contaminants of Concern
Instream Sediments
Arsenic (CR)
Beryllium (CR)
Iron (CR)
Benzo(a)pyrene (1)(CC)
Mine Flume Sediments
None
Notes:
Compounds/parameters listed are those detected at concentrations in
excess of the BAL and which were projected to pose a significant
potential individual risk/hazard (carcinogenic unit risk > 1E-7 or hazard
quotient >0.1).
Parameters which were not detected in any instream or mine flume
sediment sample at a concentration in excess of the corresponding BAL
are not listed.
(1) designates organic compounds which were detected at similar or
higher concentrations in corresponding background samples.
(RR) = Rough River; (CO = Caney Creek; and (CR) = Cane Run --
these designation were used to show which stream produced samples
with parameter concentrations in excess of corresponding background.
For instream sediment risk screening, the exposure concentration for
each inorganic parameter except chromium was below the BAL for at
least one other stream.
-------
Ft. Hanford Stone Quarry Site
Section V, Page 15
Table ^-.6
Assumptions for Ingeation and Dermal Contact Exposure to Soil Contaminants of Concern
•t th« Fort Hartford Stone Quarry She in Oiaton. Kentucky*
Exposure
Future Chid Resident
Future Adult
Resident
Current Adult Workers
ORAL
Daily soil ingestion level
Fraction of time onsite in
contaminated areas
portion of ingested
contaminant absorbed
Days per year onsite
Years onsite
Body weight
Lifetime
200 mg
100%"
100%
350 days
6 years
16 kg
100 mg
100%'
TOO%
35O days
24 years
70kg
Averaging time based on 30 years for non-
carcinogens, and 70 years for carcinogens (see
Soil Exposure Formulae Keyl
50 mg
100%"
100%
260 days
25 years
70kg
Averaging time based on 25
years for non-carcinogens, and
7Q years for carcinogens (see
Soil Exposure Formulae Key)
DERMAL
Skin area contaminated
Soil adherence per cm2 of
skin
Portion of contaminant
absorbed
. Days per year onsite
Years onsite
. Body weight
Lifetime
3730 cm2
1 mg
0.01 (Orgamcsl *
0.001 (Metals)
350 days
6 years
16kg
3500 cm2
1 mg
0.01 (Orgamcsl *
0.001 (Metals)
350 days
24 years
70kg
Averaging time based on 30 years for non-
carcinogens, and 70 years for carcinogens (see
Soil Exposure Formulae Key)
3500 cm2
1 mg
0.01 (Organics) *
0.001 (Metals)
260 days
25 years
70kg
Averaging time based on 25
years for non-carcinogens, and
70 years for carcinogens (see
Soil Exposure Formulae Key)
Notes: • References values from USEPA. RAGS. 1 2/89. OSWER Directive #9285.6-03, and USEPA, Region IV New Interim
Guidance (2/11/92).
" Uniform contaminant distribution over the entire site area is assumed. No fraction of time factor was utilized in
these calculations, uniform exposure to the entire site at average contaminant concentrations (conservative): only
analytical hits used to compute contaminant averages.
* 1.0% (Organicc) or 0.1% (Metals) dermal transfer assumed; includes consideration of soil matrix effect.
-------
Record of Decision
Section V, Risk Analysis
Page 16
Table 5.7
Total Site Risk
Cancer Effects
(Carcinogenic Risk)
Soils 3 x 1CT5
Surface Water
Springs
Sediments
Mine Flume 6 x 10"6
In-stream 2 x 10'5
Ground Water
Haney/
Big Clifty
Contact 6 x 10"7
Upper Big
Clifty 3 x ID'7
Lower Big
Clifty
Beech Crk/
Elwren 2.1 x 10'4
Reelsville
Air N.A.
SCFS
Material 1 x 1(T5
Reaction
Water 4 x 10'5
Total 3 x 10'*
Non-Cancer Effects
(HI)
0.4
1.1
1 Q
~L . 3
0.0
0.3
51
14.0
10.0
2.0
1.0
N.A.
0.6
11
64.6
-------
Ft. Hartford Stone Quarry Site
Record of Decision'
Page 5-17
TaMe SiB
Assumption* for Ingestion and Dermal Contact Exposure to Sediment Contaminants of Concern
Fort Hartford Storm Quarry Site, Ofaton. Kantucky*
Exposure
Chid Recreational U*er
Adult Recreational/ Commercial U«er .
ORAL
Daily soil ingestion level
Fraction of time onsite in
. contaminated areas
Portion of ingested contaminant
absorbed
Days per year onsite"
Years onsite
Body weight
Lifetime
200 mg
100%'
100%
1 40 days
6 years
16kg
1OO mg
100%'
100%
104 days
24 years
70kg
Averaging time- based on 30 years for non-carcinogens, and 70 years for
carcinogens (see Sediment Exposure Formulae Key)
DERMAL
Skin area contaminated
Soil adherence per cm2 of skin
Portion of contaminant absorbed
Days per year onsite
Years onsite
Body weight
Lifetime
3730 cm'
1 mg
0.01 (Organics) *
0.001 (Metals)
1 40 days
6 years
16kg
3500 cm'
1 mg
0.01 (Organics) •
0.001 (Metals)
104 days
24 years
70kg
Averaging time based on 30 years for non-carcinogens, and 70 years for
carcinogens (see Sediment Exposure Formulae Key)
Notes: f
• References values from USEPA, RAGS, 12/89. OSWER Directive #9285.6-03, and USEPA, Region IV New Interirrf.
Guidance (2/11/92).
* Uniform contaminant distribution over the entire site area is assumed. No fraction of time factor was utilized in these
calculations, uniform exposure to the entire site at maximum contaminant concentrations was assumed for conservatism.
' 1.0% (Organics) or 0.1 % (Metals) dermal transfer assumed; includes consideration of soil matrix effect.
' The lifetime weighted average exposure frequency is 112 days/year; individual life stage exposure frequencies were
applied per personal communication with Sally Wiley, KDEP, Risk Assessment Section, July 13. 1993.
-------
Ft. Hanford Stone Quarry Site.
Record of Decision
Page 5-18
Table 5. 9
Assumptions for Ingestion and Derma) Contact Exposure to
As Received Source Material Contaminants of Concern at the
Ft. Hartford Stone Quarry :jSrte: in Olaton, Kentucky*
Exposure
Future Child Resident
Future Adult Resident
ORAL
Daily source ingestion level
Fraction of time onsite '->
contaminated areas
Portion of ingested
contaminant absorbed
Days per year onsite
Years onsite
Body weight
Lifetime
200 mg
100%'
100%
1 40 days
6 years
16kg
100 mg
100%"
100%
104 days
24 years
70kg
Averaging time based on 30 years for non-carcinogens, and 70
years for carcinogens (see Source Exposure Formulae Key)
DERMAL
Skin area contaminated
Source adherence per cm2 of
skin
Portion of c>- "
absorbed
.' onsite
,1* onsite
!l Body weight
« Lifetime
3730 cm2
1 mg
0.01 (Organics) c
0.001 (Metals)
1 40 days
6 years
16kg
3500 cm2
1 mg
0.01 (Organics) c
0.001 (Metals)
1 04 days
24 years
70kg
Averaging time based on 30 years for non-carcinogens, and 70
years for carcinogens (see Source Exposure Formulae Key)
Notes:
• References values from USEPA, F1AGS, 12/89, OSWER Directive #9285.6-03, and USEPA, Region IV New
Interim Guidance (2/11/92).
b Uniform contaminant distribution over the entire site area is assumed. No fraction of time factor was utilized
in these calculations, uniform exposure to the entire site at average contaminant concentrations (conservative);
only analytical hits used to compute contaminant averages.
c 1.0% (Organics) or 0.1 % (Metals) dermal transfer assumed; includes consideration of soil matrix effect.
-------
Ft. Hartford Stone Quarry Site
Record of Decision
TABLE -: - TOXICOLOOICAL DATABASE INFORMATION
FORPOTENTIALCONTAMINANT* OFCONCCflN
_). 10 FORT HARTFORD BTONEQUARAYNr»L8rTE
OLATON. KENTypKY
.' .•;.'• '• '^f^^y^M
PARAMETER •••'? : : '.' -.: :^rf'.| v^^-'
'OUTlieS
2.2'-oiybl« (.-cHoropropiM)
Btnitnt
JfomomtMhiin*
2-6uunon»
CNotomcthsn*
Oimitrryl dii Jfld»
Ethylb«ni»n»
Mcthtn*
Styr*n*
Tolutn*
TricHorocthyUn*
XfUn*
W&mWfMiA'
SfivXiWCTORsari
;Sijw*wi«Ay)v:i_::-*;
NO
2.QE-02
NO
NO
I.3E-02
ND
ND
ND
9.0E-02
NO
I.IE-02
ND
..^•^:::^.JO^OCIKi'::•:S••?.•1%»WEH«tlC8s:^':.'::•."•^:••l:.«::^*•'S^.:!SS
f-::m6tMiw^mX^t;^s^:S9i^
•:-mmmrn\.mmmmmmmmmm.
i ' '•; >;?(uiirn.W!iyvSSS:s (iiS/k<«>ATii sv?;'s.«SS*SBi^*
NOTAPPUCABLE
1 NOT APPUCABLE
NOTAPPUCABLE
NOTAPPUCABLE
2 NOTAPPUCABLE
NOT APPLICABLE
NOTAPPUCABLE
NOTAPPUCABLE
1 NOTAPPUCABLE
NOT APPLICABLE
1 1 NOT APPUCABLE
NOTAPPUCABLE
ND
ND
0.0014
O.B
NO
ND
O.I
ND
0.2
0.2
O.OM
2
1
1
1
1
1
II
1
NO
ND
1000
9000
ND
NO
IOOO
ND
IOOO
IOOO
ND
100
::•£:::••::
SSSP
:
Anthr«o»n»
Btnr (>{•)• ntttccan*
B«mo(«)p)ri«n»
fi«nio(b}fluor«niri«no
B«niofo.M)p «¥'•"•
B«nlo(V)fiuoi*ntf»»n»
Bintolc add
Cub •id*
o-Ciiiol
p-Ct*iol
Chyscn*
Dlb«nto(t.h)iintNiio*n*
Otbtmofutn
Flvor«nth«n«
Fluor •n*
lnd*no( i ,*.3 - odjpymft*
2-Mithy.MphU.il*!.*
NaphthcUn*
NlkoiodlpfMOTtMrnln*
PrMf>«nirv«n*
Ph»r»t
PVtcn*
PESTICIDES
•lph«-BHC
QlfflfflA-CMOldBn*
M'- oor
4.4' -DOE
t>Hdrln
Er-doidftn 11
Endfin
Endrln AlcUryde
HtptBCNot
HtpUcNof •poiud*
M«irwr^cNot
NO
ND
ND
NO
7.3E.OO
7.9E.OO
7.3E.OO
NO
7.3E.OO
ND
20E-02
ND
NO
7.3E.OO
7.36.00
ND
NO
ND
7.3F..OO
ND
NO
45E-03
NO
NO
ND
0.9E«00
I.3E.OO
9.4E-OI
9.4E-OI
i.eE.oi
NO
ND
ND
4.36.00
e.ie.oo
NO
ND
NO
NO '
ND
3 I.OE-OI
1 ND
3 I.OE-OI
ND
.3 I.OE-OI
NO
2 ND
NO
ND
i I.OE-02
3 I.OE.OO
NO
ND
NO
3 I.OE-OI
NO
ND
1 ND
NO
NO
NO
NOT APPUCABLE
NOT APPUCABLE
NOTAPPUCABLE
NOTAPPUCABLE
NOTAPPUCABLE
NOTAPPUCABLE
NOTAPPUCABLE
NOT APPUCABLE
1 NOTAPPUCABLE
1 NOT APPUCABLE
NOTAPPUCABLE
0.01
0.09
ND
0.3
NO
NO
ND
ND
ND
4
NO
0.09
009
ND
ND
ND
0.04
0.04
NO
0.04
0.04
NO
0.03
o.a
0.09
0.0009
0.00000
00009
0.0009
000009
0.00009
0.0009
0.0003
0.00003
0000013
0.009
1
1
2
2
17
1
1
l»
2
19
f
=-L=
19
1
1
It
1
2
1
19
r
i .
i
1000
9000
ND
3000
ND
NO
NO
NO
ND
1
ND
IOOO
ND
NO
ND
NO
9000
3000
ND
NO
IOOO
NO
NO
100
9000
ND
IOOO
100
ND
100
3000
too
ND
3OO
IOOO
1000
t
1
ND
1
ND
ND
ND
NO
ND
1
NO
1
NO
ND
ND
ND
1
t
ND
ND
t
NO
ND
1
1
NO
1
1
NO
1
1
1
NO
1
1
1
O
ND
NO
D
B2
B2
B2
0
B2
O
a:
C
C
B2
B2
ND
0
0
62
ND
D
B2
•in
^
ND
B2
B2
B2
B2
NO
D
ND
82
B2
0
100
2100
ND
NO
O.t
o.a
0.2
ND
0.2
ND
ND
NO
ND
0.2
0.9
ND
NO
1400
0.4
• NO
100
NO
ND
0000
1100
NO
2
ND
ND
0.2
ND
9
o.a
0.4
SO
0.07'
ND
NO
ND
NO
0.0002
ND
ND
ND
NO
ND
ND
HO
NO
ND
ND
NO
ND
ND
ND
HO
NO
ND
ND
NO
O.002
ND
NO
NO
ND
0.002
O.OO04
0.0002
004
0.07
NO
ND
NO
ND
ND
NO
ND
ND
ND
NO
ND
ND
NO
NO
ND
ND
ND
ND
NO
0.02
ND
NO
4
ND
NO
0.002
NO
ND
O.OOO9
NO
0.002
O.OO3
00001
0.04
f
0
a
7
0
4
9
9
4
(U
00
n>
Ol
I
-------
Ft. Hartford Stone Quarry Site
Record of Decision
TABLE - TOXrCOLOOICAL DATABASE INFORMATION
5 1 0 FOR FOTENTULCONTAMINANn OF CONCERN
FORTMARTFORO»TONEOUARRVNPtSIT6 .
OLA TON. KENTUCKY
PARAMETER
INOROAMCS/WETCHEMBTRY
Aluminum
Ammoria
Antimony
Arianlc
Barium
Barylilum
Cadmium
Calcium
CNoildaa
Chromium III
Chromium VI
Cobalt
Coppar
Cyanlda
Iron
Laad
Magnailum
Manganaaa (lood)
Manganaaa ("ratal)
Malcury
Nrcfcal
Potaurum
Salartum
Sllvai
Sodium
SUtatal
Suindaa
Thallium (ai lutlata/cNorlda lall)
Vanadium
anc
PH
ILOPE
ORAL
02: aipoaura oone
Maximum Contaminant Laval ((MCL) (ol Tiaatmant Tadinology naiad MCL))
Ulallma Haalth AMaoiy tM 70 Ko adun
10 day HaalOi Advlaoiy tot 10 KO cNId
Drinking Walar EnuNalant Laval (DWELJ
Sacondary MCL (SMCL - aairhalo batad)
Inhalalonunttnulilnmlaogfama/cublomatar
MCL and RAL baiad on total Chromium.
Augmt 10. ig«9 eonaapondano* torn EPA
RID provtdad In USEPA ftaglon III Sol Scraartng Canoantalon Tabla. flril Quart*. 1904; aaa * 14.
RIO tor pyraM mod •• lurroQala. ta« 914.
Surrogata and/orprovlalond RID* augga«1a4by Kovln Koporac. USEPA Offloa ol Haalm Aitaiamanl, phona oonvaraalon 2/2/04.
RIO lor Eridrir) ut*d aa aurrogala, aa« 114.
RIO lor DOT appHad aa aunogata RIO tor ODE dua to atuctuial limilaiiy.
RIDIoro-Craioluiadaa aunogata. aaa 114.
RIO lor NapMhalana uaad (a aurrogala. taa 114.
RID lor gamma-BHC mad at aunogala; par 2/4/g4 phona oonvartatlon with Jim Holdar. USEPA Point of Contact lor BHC.
propoiad MCLa
- No data avail*)!*
- flamovalAcfon La»«l
• danola* Uncertainty Factor
H»nr.«-< flArfllilnn ftrlnt . '
intaflon* ara multfpllatf by tha TCF within rtsk/haiard lormulaa.
(u
do
n>
l
N>
O
-------
Ft. Hartford Stone Quarry Site
Record of Decision
Paee 5-21
TABLE J—1 A SUMMARY OF CARCINOGENIC RISK ASSOCIATED WITH EXrOSUHE TO
CONTAMINATED MEDIA
FORT HARTFORD STONE QUARRY NPL SITE
OLATON. KENTUCKY
MtUIUM/rAHAMt i tn
ASSOwlAl CD HISK
I ONSIIH !BACKGROUND LOCATIONS
B«nzo(b/k)fluorwith«n*
B*nzD(«)pyr«fv»
lnd«no(1 23 -cd)pyr«ne
Ar»«nic
B«ryflhnn
1.7E-O7
8.5E-07
2.4E-08
1.2E-07J
2.9E-07
2.3E-OS
7.SE-06
SoJ P«thw»y Total Hisk
SURFACE WATER
Not Aoplic«bl«
SEDIMENTS - IN STREAM 1 ON SITE I
RR
CC
CR
B«nzo(«)pyi«n«
Antnic
fl.SE-O7|
1.8E-05!
3.1E-08J
RA
1.4E-05
. NA '
1.0E-08
1JE-05
4.1E-08
NA
4.0E-08
NA
IniOMm S«dim«nt
Pathway Total Risk
2E-05I
tE-05
2E-05
4E-08
SEDIMENTS - MINE FLUMES! ONSlTt BACKGROUND LOCATIONS
Mine Flum* S«dim«nt
Patftwiy Total Ri»k
eE-08|
GROUNDWATER
ZONE1
BM12WW
Styrwi*
ONSITE BACKGROUND LOCATIONS
1.4E-07J
NA|
Zon« 1 GWPalhwtvRrek
6E-07I
2E-04'
ONSTTE BACKGROUND LOCATIONS
4.4'-ODT
An«nie
NA
Zon« 2 GW Pathway Rak
3E-07
6E-05ajg
ONSflE BACKGHOUNP LOCATIONS
NAT
Zen« 3 GW P«mw«y Rrak
NAI
I ONsiib BACKGROUND LOCATIONS
Afi«nie
8.7E-07
2.1 E-04
2on» 4 G W P«ttiw»y flak
2E-O4
I ONSITE BACKGROUND LOCATIONS
NAi
5.06-05
Zone 5 GW PHhwmy Ri»k
NAI
ASrRECElVEPSAL;rCAKE FIN ^NSITE BACKGROUND LOCATIONS
Ananie
B«rylBum
8.9E-08
1.7E-08
As R»e'd ToUl Pathway Rbk
IE-OS
SM Notes -"X,
WATcH rHOM HcAUIIOn
ONSITE BACKGROUND LOCATIONS
Ancnic
B«ry>• dolgnrtom RR. OC. «nd CR npraMM txekQiound loc»ODn nlun in Rough
Rlvw. Camy Craik «nd Cin* Rin. mp«ct««v.
Mint dunw Mdknvt iWc R»y b* oorvpvrad to V»l In noivirg n»«n> 10 provid*
iMlw horn
t%tUa hm oo«t«p«oaing
«i»r»nK 2D
- SMC*I OMHQmn CantKC ZONES - RMkwfl* Um«ion«.
-------
Ft. Hdnford Stone Quarry Site
Record of Decision
Page. 5-22 .
TABLE : 5V12 SUMMARY OP NON-CARCINOGENIC HAZARD ASSOCIATED WITH
EXPOSURE TO CONTAMINATED MEDIA
FORT HARTFORD STONE QUARRY NPL SITE
OLATON, KENTUCKY
MeDIUM/PAHAMETER
ASSOCIAI UJ HA^AMLJ
SOIL
II ONSITE
Arsenic
Iron
0.1
0.3
SoilPathway Total Hazard
0.5
BACKGROUND LOCATIONS
SURFACE WATEH—INSTHEAM I ONSITE
iron
Manganese**
0.3
1.6
Instream SW Pathway Total Hazard
1.9
HH
cc-
0.2
1.5
02.
0.9
0.3
1.7
1.1
0.3
SURFACE WATER-SPRINGS I ONSITE BACKGHOUNO LOCATIONS
Cadmium
Iron
Manganese
Sodium
Vanadium
0.4
0.2
0.2
0.2
0.1
Spring PatnwayTotal Hazard
1.1
0.4
0.4
0.1
0.9
SfcPIMfcNTS — INSIHbAM
ONSII h
Arsenic
Antimony
Iron
0.1
0.2
Instream sediment
Pathway Total Hazard
0.3
0.1 <0.1
0.1
0.2
0.1
.0.2
0.1
SEDIMENTS — MINE FLUMES II ONSITE BACKGROUND LOCATIONS
Not Applicable
Mine Flume Sediment
Pathway Total Hazard
0.0
See Notes
(jROUNPWATEH
ZONE1
ONSITE BACKGROUND LOCATIONS
Arsenic
Barium
Cadmium
Chromium
Iron
Potassium
Selenium
Sodium
Ammonia
0.5
0.7
0.1
0
1.1
0.2
24
23
Zone i GW Pathway. Hazard,
51
0.9
0.2
ZONE2
ONSITE BACKGROUND LOCATIONS
Arsenic
Baruim
Cadmium
Iron
Manganese
Sodium
Ammonia
2.1
0.3
0.6
2.7
5.9
2.4
Zone 2 GW Pathway Hazard
0.2 j^
-------
Ft. Hanford Stone Quarry Site
Record of Decision
Page 5-23
TABLE5.;;;i2(contiuned) - SUMMARY OF NON-CARCINOGENIC HAZARD ASSOCIATED
WTTH EXPOSURE TO CONTAMINATED MEDIA
FORT HARTFORD STONE QUARRY NPL SITE
OLATON, KENTUCKY
MEDIUM/PARAMETER
ASSOCtAI
ZONES
ONSITE BACKGROUND LOCAI IONS
Arsenic
Barium
Cadmium
Chromium
Iron
Manganese
Sodium
Ammonia
0.7
0.7
0.2
03
2.9
45
0.4
Zone 3 Gw Pathway Hazard
10
ZONE 4
I ONSITE
Arsenic
Barium
Sodium
0.9
0.5
0.9
Zone 4 GW Pathway Hazard
2
0.5
0.3
BACKGROUND LOCATIONS
ZONES
IT ONSTTE BACKGROUND LOCATIONS
Arsenic
Chromium
Iron
Sodium
0.1
0.1
0.1
Zone S GW Pathway Hazard
1
0-2'$£
0.6
AS RECEIVED SALT CAKE FINBI ONSIT& HAOKQHOUNU LUOAIIUNb
Aluminum
Arsenic
Iron
0.2
0.1
0.2
As Ree'g Total PatnwavHazard
0.8J.
WATER FROM REACTION
ONSITE BACKGROUND LOCATIONS
Antimony
Arsenic
Cadmium
Chromium
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Ammonia
0.5
0.1
0.2
0.2
0.8
0.1
0.1
5.7
0.1
0.4
3.1
Water from Reaction
Total Pathwav Hazard
See Notes
NOTES:
'X indicates parameter contributed to computed hazard index.
'XX indicates the primary contributors to the hazard index with hazard quotients greater than 1.
'•*' Indicates manganese was not detected in any instream sample above BALs.
Only parameters with hazard quotients in excess of 0.1 are Usted.
The designations RR. CC. and CR represent background location values in Rough
River. Caney Creek and Cane Run. respectively.
Mm fume sediment hazard may be compared to that in receiving streams to provide
• tarn* of reference. ,
Neither as received salt cake fines or water from reaction results have corresponding
background values. The computed hazard may be compared to background soil and
surface water or groundwater hazard, respectively.
Groundwater ZONES are referenced as follows: ZONE1 - Haney Umestone/Big
CSfty Contact; ZONE2 - Upper Big CCtty Sandstone: ZONE3 - Lower Big Clrlty
-------
Ft. Hanford Stone Quarrv Site
Record of Decision
Page 5-24
• ABLE J.«-L-OSUMMAHYOF GROUNuWAItH. SURFACE. AND WAitM I-ROM REACTION CONCENI RATIONS THAT EXCEED A8AR
.FORT HARTFORD STONE QUARRY NPL SITE
;Ot-ATON. KENTUCKY
MfcliiUuVPARAMElEH
ARAB Ref.
fWG/LI
ON&Ilt BACKGROUND LOCATIONS
(MG/U (MGA.I
[uROuNljWAlm • ' •*•' ' ' * ••',*'•• f ._ ' > -- ' -- < . •• •• ' :
•ZONE 1
i Cadmium
'.Lead
•Sodium
j Thallium
'Chlorides
jSutfates
Ammonia
•; Aluminum
•ZONE 2
iBanum
jlron
'Lead
-Manganese
iSodium
;Chtorides
Ammona
ZONES
Caomium
'Iron
: Manganese
'Sodium
; Chlorides
! Aluminum
:ZONE 4
.Iron
j Sodium
'.Chlorides
! ZONE 5
'iron
•Sodium
! Chlorides
: SUHrACe WA 1 tH
. IN^IfiBVM
! Aluminum
•Iron
•Lead
iManoanese
;SPftlNGS
Aluminum
Iron
'Manganese
iCadmium
'Sodium
iVenadium
{Chlorides
Jsuffates
^WAICtl 1-tlOM REACTION
. 'Aluminum
: Antimony
•.Beryttium
iCadmum
'Chromium
itron
j Manganese
i Nickel
•Selenum
1 Silver
! Sodium
1 Thallium
1 Vanadium
i Ammonia
'Chlorides
Lsutotes
O.OOSMCL
0.015 TT-MCL
17 HA
0.002 MCL
2SOSMCL
250SMCL
30 HA
O.OS - 02 SMCL
2 MCL
0.3 SMCL
O.OtSTf.-MCL
0.05 SMCL
17 HA
250 SMCL
30 HA
0 OS - 0 2 SMCL
O.OOSMCL
0.3 SMCL
O.OS SMCL
I7HA
250 SMCL
O.OS - 0.2 SMCL
0.3 SMCL
17 HA
250 SMCL
0.3 SMCL
17 HA
250 SMCL
O.OS - 0.2 SMCL
0.3 SMCL
0.015 TT-MCL
O.OS SMCL
O.OS - 02 SMCL
0.3 SMCL
O.OS SMCL
O.OOSMCL
17HA
30 HA
2 SO SMCL
250 SMCL
ISv-SSt-SSWXWRS-xttWx1:.
0.05-0.2 SMCL
0.006 MCL
0.004 MCL
0.005 MCL
0.1 MCL
0.3 SMCL
0.05 SMCL
0.1 MCL
0.05 MCL
0.1 HA
17 HA
O.OOSMCL
0.03 RAL
30 HA
250 SMCL
250 SMCL
OJ3I
0.0205
234SO
0.014
48250
558.5
665
BOL
4.15
4.S5
O.O39S
0.304
5710
16640
67.1
BDL
BDL
0.0023
240 1
BDL
15.3
51.1
0.7
3.44 |
0.154
1.271
0.0021
0.0093
2921
7.9
0.7
1.951
1 .42 i BDL
2.43I 026
0.41 1 I 0.0077
4330I J68.SI
16680
BOL
O.63
912
1405
1.26
1060
403
12
0249)
0.63
5721
1405
0.029
S4S|
73
,;f, Jl^, •• *?„ ' •• '•*•.!' • • v
ONSIFt BACKGROUND
! CANEY CHEEK CANE RUN ROUGH RWEH
1.641 I.1SI 0.3031 1.31
2.77
0.021
0527
ONSITfc
1.56
1.73
1.631 0.3881 1.61
0.006 BDL 0.004
0.1331 0041 0.212
BACKGROUND
0.9441
O.B361
0.031 0.049
0.005
175.75
0.023
2603
4085
0.0051
4.69
0.023
5.8
20.6
x->:-:w:-rt.>ft-::>>ft-xviWra%ft*:^^^
RESULTING CONCENTRATION
5.61
0.06
0.02
0.03
026
0.76
0.15
0.52
0.18
0.17
62631
0.03
0.83
995
112281
634
NOTES:
— MCL refers to maximum contaminant level.
- SMCL is a secondary (usually aesthetic based) MCL.
- HA refers to Health Advisory.
- TT-MCXremreact>xl'COfic«itmliuiofat«Jlii««iilli«iiMi«ii|»liiil»ij)>n«ni. in lim tijiiiij»l ilnln ii|i|ily lullil nun tun
" m»soondgxi ARARi-
-------
Ft. Hartford Stone Quarry Site
.Record of Decision
TABLE ^ TASUHf'Ac^ WATER REMEDIAL GOAL OPTIONS
UNDER A RESIDENTIAL USER EXPOSURE SCENARIO
FORT HARTFORD MINE
OLATOH KENTUCKY
HAZARD-BASED; ;
'y.j'W':. '•'•' .?sS;-'.^:.:' •
PARAHcien • .?;• ...
WbHdANlCSAVbT CHtM |
Aluminum*
Cadmium
Iron*
Lead
Manganese
Sodium*
Vanadium
Chlctldes
Sulfctei
CARCINOGEN* PAS&D:
INOHQANICS^WET CHfcM |
Aluminum*
Cadmlitn
Iron*
LMd
Manganese
Sodium*
Vanadium
Chlorides
Sulhtes
REFERENCE
DOSE
ORAL
(MQ/KQ/DAY)
28
0.0005
0.3
NRV
0.005
34
0.007
NRV
NRV
SLOPE
FACTOR
ORAL
(MG/KG/DAY)- 1
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
HAZARD
INDEX
©4CTTRMAX
2.2E-02
3.8E-01
2.0E-01
NRV
2.1E-01
1.8E-01
1.IE-01
NHV
NRV
TOXICJTY
EQUIVALENCY
FACTOR
(UNITLESS)
Not APPUCAALf
NOI APnjCAAlf
NOT APPUCAALC
NOI APfUCABLf
NOT AmjCMLt
HOI AmjCULS
NOI AmjCABU
NOT AmJCABLJ
NorAmjCASur
MAXIMUM OTHER DRINNNQ
CONTAMNANT WATER REF,
LEVEL STANDARDS
(MO/L) (MQ/L)
NA
0.005
NA
NA
NA
NA
NA
NA
NA
CANCER
RISK
(3 4 QTR MAX
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
0.05
0.005
0.3
0.015
O.OS
20
NA
250
250
REMEDIAL
GOAL OPTION
RISK- 16- 4
(MG/L)
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
Reference
1
2
2
4
2
3
2.
2
REMEDIAL
GOAL OPTION
RISK- 1E-5
(MG7L)
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
SUPERFUND
RAL
IUQ/L)
NA
5
NA
30
200
NA
30
30
REMEDIAL
COAL OPTION
RISK- 1E-6
(MG/L)
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
NRV
REMEDIAL REMEDIAL
GOAL OPTION GOAL OPTION
HQ * 0.1 V:; HO. > 1
(MO/L) (MO/LI
8.25E+00 8.25E+01
1.42E-03 , 1.42E-02
853E-01 ' 8.53E+00
ARAR ARAR
1.42E-02 1.42E-01
0.B7E+01 0.07E+02
1.09E-02 1.09E-01
ARAR ARAR
, ARAR ARAR
E'XP'flSOR'E"*"'
POINT
CONCENTRATION
(MO/L) '
1 84E+00
5.40E-03
1.73E+00
2.10E-02
3.05E-02
1.78E+02
2.2BE-02
2.01E+02
4.0BE+02
REMEDIAL
GOAL OPTION
HQ« 10
(MQ/L)
a.2SE+02
1.42E-01
8.53E+01
ARAR
1.42E+00
S.07E-f03
1.89E+00
ARAR
ARAR
I
7PPOCABLE
SURFACE
WATERS
5.8
0
5.8
5
5.8
8
8
8
8
' 'EXPOSURE"' "
POINT
CONCENTRATION
(MG/L)
1.84E + 00
5.40E-03
1.73E + 00
2.10E-02
3.05E-02
1.7«El02
2.28E-02
2.81E + 02
4.00E+02
NOTES:
RtD and Slop* Faclw («.k.«. Cancw Potency Factw) valu« obUln*d from IRIS (September 1893 and February 1994) and/or HEAST 1993.
None of th« IdentMed turface watat contemhrnnla ol concern tuppoct« significant volallization (and Inhahtlon) ««potur« pathway.
The expoiure point concentrations referenced are from all onilte Ihttream surface water locationt; which Includes concentrations for
alumkium, iron, lead, and manganese; concentrations for all other parameters were obtained from spring surface water data.
Tables 3 through 6 In Appendix I contain additional exposure point concentration! for reference.
MCL « Maximum Contamhant Level; SMCL •» Secondary MCL; HA • EPA Health Advisory: MCL-TT = Treatment Technology Based MCL:
HEAST-RfO - Specific Reference Dos* Drinking Water Equivalent Concentration, RAL = Superfund Removal Action Level
NA Indicates no value was available, NRV Indicates no risk value (slop* factor or reference dose) was avalbble for the compound.
No hit greater than DAL was reported at any «prlng sampling location.
• - Indicates provisional RfOt wet« used takdevalop RQOs.
1 - Most conservative value of SMCL ranged 0.5- 0.2, SMCL
2 - SMCL
3 - HA
4 - Treatment Technology (TT) based MCL
5 — Applies to Insfream vurfaca water.
0 - Applies to surface watei in springs.
13
(u
OQ
n>
-------
Ft. Hartford Stone Quarry Site
Record of Decision
TABLE i.. R GROUNDWATER REMEDIAL GOAL OPTIONS
(UNDER RESIDENTIAL EXPOSURE SCENARIO)
FORT HARTFORD STONE QUARRY NPL SITE
OLATON, KENTUCKY
HA^RJJ-(*SED:
PARAMETER
REFERENCE
DOSE
ORAL
IMGXQJDAYI
HAZARD
INDEX
©2QTRMAX
MCL OR
OTHER ARAR
(MG/U REF
REMEDIAL
GOAL OPTION
HO - 0.1
(MG/L1
'REMEDIAL REMEDIAL APPLIES '
GOAL OPTION GOAL OPTION TO WATER -
HQ«1
(MG/L)
HO « 10 BEARING
IMG/LI ZONErf'S:
._ . .1 .-
EXPOSURE"
POINT
CONCENTRATION
(MG/U
INOrtGANICS/WET CHEMISTRY
Arsenic
Barium
Cadmium
Chromium
Iron*
Lead
Manganese
Potassium*
Selenium
Sodium*
Thallium
Chlorides
SuHates
Arnmonia*
CARCINOGEN -BASED:
eARAMETCa..
0.0003
0.07
0.0005
0.005
0.3
NRV
0.005
50
0.005
34
0.007
NRV
NHV
..... .!
SLOPE
FACTOR
ORAL
-(M
-------
Ft. Hartford Stone Qnuny Site
Record of Decision
TABLE 5.16- WATER FROM REACTION SOURCE MATERIAL REMEDIAL GOAL OPTIONS
UNDER A RECREATIONAL USER EXPOSURE SCENARIO
FORT HARTFORD STONE QUARRY NPL SITE
OLATON, KENTUCKY
HAZARD T BASED:
PARAMETER
INORGANICS/WET CHEM
Aluminum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Iron
Lead
Manganese
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Ammonia
'Chlorides
'Sullatea
; CARCINOGEN- BASE!
.. "• ' ••.'.•
PARAMETER
INlORGANICS/WET CHEM
Areenlc
Beryllium
REFERENCE
DOSE
ORAL
JMG/KG/DAY)
2.9
0.0004
0.0003
0.005
0.0005
0.005
0.3
NRV
0.005
0.02
50
0.005
0.005
34
0.0008
0.007
t
NRV
NRV
SLOPE
FACTOR
. ORAL
(MG/KG/DAY)-1
1.75
4.3
HAZARD
INDEX
@ 95% UCL
6.0E-03
4.7E-01
l.OE-OI
I.2E-02
1.9E-01
I.6E-OI
7.9E-03
NRV
9.3E-02
8.1E-02
8.4E-01
I.IE-Ot
1.1E-01
5.7E + 00
1.2E-OI
3.7E-01
3.1E+00
NRV
NRV
TOXIClfT'
EQUIVALENCY
FACTOR
(UNITLESS)
NOT APPLICABLE
NOT APPLICABLE
MCL OR OTHER
ARAR
(MG/L) . ._
ARAR
REFERENCE
0.05-0.2 SMCL
0.006
0.05
0.004
0.005
0.1
0.3
0.015
MCL
MCL
MCL
MCL
MCL
SMCL
MCL-TT
0.05 SMCL
0.1
NA
MCL
0.05 MCL
0.1
17
HA
HA
0.0005 MCL
0.03
30
250
250
CANCER
RISK
<§> 95% UCL
7.1E-06
3.5E-05
RAL
HA
SMCL
SMCL
REMEDIAL
GOAL OPTIONS
RISK= 1E-4
(MG/L)
—
REMEDIAL
GOAL OPTIONS
HQ « 0.1
(MG/U
935E + 01
1.29E-02
9.68E-03
1.61E-01
1.61E-02
1.61E-01
968E + 00
NRV
1.61E-01
6.45E-01
1.61E + 03
1.61E-01
1.61E-01
1.10E + 03
2.58E-02
2.26E-01
3.23E + 01
NRV
NRV
REMEDIAL
GOAL OPTIONS
R1SK = 1E-5
(MG/L)
REMEDIAL REMEDIAL 95% UCL OR MAX.
GOAL OPTIONS GOAL OPTIONS. WATER FROM RXN
HO- 1.0 HQ » 10.0 '
{MG/U (MG/U
9.35E + 02 9.35E-I03
1.29E-01 1.29E + 00
9.68E-02 9.68E-OI
1.61E+00 1.61E + 01
1.61E-01 1.61E + 00
1.61E + 00 1.61E + 01
9.6BE + 01 9.68E + 02
NRV NRV
I.61E + 00 1.61E + 01
6.45E + 00 6.45E + 01
1.61E + 04 1.61E + 05
1.61E+00 1.61E + 01
1.61E + 00 1.61E + 01
1.10E + 04 1.10E + 05
2.58E-01 2.58E + 00
2.26E + 00 2.26E + 01
3.23E + 02 3.23E + 03
NRV NRV
NRV NRV
REMEDIAL 95% UCLOR~MAX.
GOAL OPTIONS WATER FROM RXN
RISK=1E-6 CONCENTRATION
(MG/U (MG/U
0.01
0.02
CONCENTRATION
(MG/L)
5.6IE I 00
0.06
0.01
0.02
003
0.26
0.76
0.11
0.15
0.52
13600
0. IB
0.17
6i!631
0.03
0.83
995
112281
634
-IOTES:
RID and Slope Factor (a.k.a. Cancer Potency Factor) values obtained (torn IRIS (September 1993 and February 1994) and/or HEAST 1993.
The 95 % UCL means were used to compute risks and hazard quotients at maximum; the 95% UCL means and averages were computed using data presented in Section 4.1.
Th* maximum concentrations referenced are the maximum tour quarter averages representative p( all shallow monitoring wells.
No other carcinogens were reported flh which there are slope (actors; therefore, carcinogen—based RGOs can only be calculated (or arsenic and beryllium.
NRV Indicate no risk value (slope factor or reference dose) Is available.
MCL • Maximum Contaminant Level; SMCL - Secondary MCL; HA •= EPA Health Advisory; MCL-TT = Treatment Technology Based MCL;
HEAST-RID " Specific Reference Dose Drinking Water Equivalent Concentration, RAL = Superfund Removal Action Level
0)
TO
n>
I
NJ
-------
Ff. Hartford Stone Quarry Site
Section V, pag.e 28
Figure 3 .3.
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for Soil
Fort Hartford Stone Quarry NPL Site
Olaton, Kentucky
The following formulae for computing soil risk (carcinogenic and non-carcinogenic) were adapted from RAGS.
Volume I. Parts A and B to reflect Site-specific considerations.
Residential Scenario
Soil Ingestion Pathway
Age-adjusted Ingestion Factor (IF^,.,,)
IF^.a, (mg-yr/kg-day i =
UL
.,..,;.)!
where:
** *
age-adjusted soil ingestion factor (mg-yr/kg-day)
average body weight from ages I -6 (kg)
average body weight from ages 7-31 (kg)
exposure duration during ages 1-6 (yr)
exposure duration during ages 7-31 (yr)
ingestion rate of soil age 1 -6 (rag/day)
ingestion rate of soil age 7-31 (mg/day)
Default Value
110 mg-yr/kg-day
16kg
70kg
6 years
24 years
200 mg/day
100 mg/day
Dermal Contact Pathway
Age-adjusted Contact Factor
(mg-yr/kg-day) =
where:
AF
x AF x ED.,..^ -r SA,,.,.,, x AF x ED.,.,.,,
Dtl/ DM/
O ** Atft^t ' D"
age-adjusted contact factor (mg-yr-event/kg-day)
skin surface area available for contact (cmVevent)
skin surface area available for contact (car/event)
soil to skin adherence factor (mg/cm:)
exposure duration during age 1-6 (yr)
exposure duration during age 7-31 (yr)
Default Values
2600 mg-yr-event/kg-day
3730 cnr/evenf
3500 cmVevem'
1 mg/cm:
6yr
24 yr
-------
Fl. Hanford Stone Quarr\ Site
Section V, Page 29
Figure 5i-l(continued)
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for
Soil
Risk (Hazard Index) Based on Combined Daily Absorbed Dose (Ingestion + Dermal Contact)
Non-Carcinogens
Hazard Index =
kg/nig x EFR x ABS)/ATNr))/(RfD..xADJ1)
Carcinogens
Risk =
(C.x((.IF^1/lljixl0^1kg/mgxEF(,)/ATc))x(SF0) + (C.x(((CFv>,1,J
-------
Ft. Hanford Stone Quarry Site
Section V, Page 30
Figure 5. 2
Formulae for Calculating Carcinogenic Risk and Non-carcinogenic Hazard for
Surface Water at Fort Hartford Stone Quarry NPL Site, Olaton, Kentucky
The following formulae for computing surface water risk/hazard (carcinogenic and coo-carcinogenic) were adapted from
RAGS, Volume I. Parts A. and B to account for Site-specific considerations.
Residential Scenario
Chronic Daily Intake
Surface Water Ingestion Pathway
Age-adjusted Ingestion Factor (
(mg-yr/kg-day) =
ED.
where:
[Fy
BW
ajel-6
age-adjusted surface water ingestion factor (liter-yr/kg-day)
average body weight from ages 1-6 (kg)
average body weight from ages 7-31 (kg)
exposure duration during ages 1-6 (yr)
exposure duration during ages 7-31 (yr)
ingestion rate of surface water age 1 -6 (mg/day)
va.c7.ji ingestion rate of surface water age 7-31 (mg/day)
Risk (Hazard Index)
Non-Carcinogens
ED
ED
IR
Hazard Index =
Carcinogens
Risk=
/RfD,
xSF0
where:
C, Chemical concentration in surface water
EFR Residential exposure frequency
ATNC Averaging time (non-carcinogen)
ATC Averaging time (carcinogen)
RfD0 Reference Dose (mg/kg/day)
SF0 Slope Factor (mg/kg/day)'1
Default Values
1.1 1-year/kg-day
16kg
70kg
'6 years
24 years
1 liter/day
2 liter/day
Default Values
Chemical-specific
350 days/year
10,950 days
25,550 days
Chemical-specific
Chemical-specific
Notes:
' Reference: RAGS. Volume I, Pans A &. B, and Risk Assessment Guidance for Superfund, Volume I-Human Health
Evaluation Manual. Supplemental Guidance-Standard Default Exposure Factors-Interim Final, USEPA/OERR.
OSWER Directive: 9285.6-03. March 25, 1991. Absorbed doses for ingestion exposure are assumed to be
the equivalent of administered doses (100% oral ingestion). Therefore,.no conversion factor is incorporated into
the associated formulae.
-------
Ft. Hartford Stone Quarry Site
Record of Decision
Page 5-31
Figure 5.3
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for Sediment
Fort Hartford Stone Quarry NPL Site
Olaton, Kentucky
The following formulae for computing sediment risk (carcinogenic and non-carcinogenic) were adapted from RAGS,
Volume I, Parts A and B to account for Site-specific considerations.
Recreational/commercial Scenario
Sediment Ingestion Pathway
Age-adjusted Ingestion Factor (IFJe
-------
Ft. Hartford Srone Quarry Sire
Record of Decision
Pago S-t2
Figure 5 . 3 (continued)
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for Sediment
Fort Hartford Stone Quarry NPL Site
Olaton, Kentucky
Risk (Hazard Index) Based on Combined Daily Absorbed Dose (Ingestion + Dermal Contact)
Non-Carcinogens
Hazard Index =
((C, x((IFMi/llljxl0^kg/mgxEFR)/ATNC)/(RfD0))) + (((CF^xlO^kg/mg x EFR x ABS)/ATNC))/(RfD0xADJ))
Carcinogens
Risk=
(C, x((IF«d/,djxl0^cg/mgxEFR)/ATc))x(SF0) + ((((CF^xlO^kg/mg x EFR x ABS)/ATc))x(SF0//ADJ))
where:
Default Values
C, Chemical concentration in sediment Chemical-specific
EFR Recreational exposure frequency (lifetime weighted average) 1 12 days/year
ATNC Averaging time (non-carcinogen) 10,950 days
ATC Averaging time (carcinogen) 25,550 days
ABS" Absorption factor (unitless) 0.01 (Organic Compounds)
0.001 (Metals)
RfD Reference Dose (mg/kg/day) Chemical-specific
SF0 Slope Factor (mg/kg/day)"' Chemical-specific
ADJC Administered to Absorbed Adjustment Factor 0.8 Volatiles
0.5 Semivolatiles
0.2 Metals
Notes:.
' Reference: RAGS, Volume I, Parts A & B, and Risk Assessment Guidance for Superfund, Volume I-Human
Health Evaluation Manual, Supplemental Guidance-Standard Default Exposure Factors-Interim Final.
USEPA/OERR, OSWER Directive: 9285.6-03, March 25, 1991.
b Absorbed doses for ingestion exposure are assumed to be the equivalent of administered doses (100% oral
ingestion). Therefore, no conversion factor is incorporated into the associated formulae.
c Dermal pathway adjustment factors provided by Mr. Glenn Adams, USEPA Region IV Risk Assessment Section,
personal conversation, July 13, 1993. Skin surface area values were provided by Ms. Sally Wiley, KDEP, Risk
Assessment Section, personal conversation, July 13, 1993.
Absorption factor assumes 1.0 percent of organics and 0.1 percent of inorganic contaminants present in adsorbed
soils will be absorbed by the exposed individual via the dermal contact pathway.
-------
Ft. Hanford Stone Quarry- Site
Record of Decision
Page 5-33
FigureS. 3 (continued)
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for
As Received Source Material
Risk (Hazard Index) Based on Combined Daily Absorbed Dose (Ingestion + Dermal Contact)
Non-Carcinogens
Hazard Index =
((C.x(aFMU«AdjxlO-6kg/mgxEF([)/ATNC)/(RfD0))) + (C,x((CFJOOTeA,jxlO-6kg/mg x EFR x
where: Default Values
C, Chemical concentration in source Chemical -specific
EFR Recreational exposure frequency (life stage weighted average) 112 days/year
ATNC Averaging time (non-carcinogen) 3,360 days
ATC Averaging time (carcinogen) 25,550 days
ABS" Absorption factor (unitless) 0.01 (Organic Compounds)
0.001 (Metals)
RfD Reference Dose (mg/kg/day) Chemical-specific
SF0 Slope Factor (mg/kg/day)'1 Chemical-specific
ADJC Administered to Absorbed Adjustment Factor . 0.8 Volatiles
0.5 Semivolatiles
0.2 Metals
Risk Formulae Notes
Figure '
Notes:
' Reference: RAGS, Volume I, Parts A & B, and Risk Assessment Guidance for Superfund, Volume l-Human
Health Evaluation Manual, Supplemental Guidance-Standard Default Exposure Factors-Interim Final.
USEPA/OERR, OSWER Directive: 9285.6-03, March 25, 1991.
b Absorbed doses for ingestion exposure are assumed to be the equivalent of administered doses (100% oral
ingestion). Therefore, no conversion factor is incorporated into the associated formulae.
c Dermal pathway adjustment factors provided by Mr. Glenn Adams, USEPARegion IV Risk Assessment Section,
personal conversation, July 13. 1993. Skin surface area default values were provided by Ms. Sally Wiley,
KDEP. Risk Assessment Section, personal conversation, July 13, 1993.
Absorption factor assumes 1.0 percent of organics and 0.1 percent of inorganic contaminants present in adsorbed
soils will be absorbed by the exposed individual via the dermal contact pathway.
-------
Ft. Hartford Stone Quarry Site
Record of Decision
Section V. Page 34_
Figure 5.4
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for As Received Salt Cake Fines
Fort Hartford Stone Quarry NPL Site
Olaton, Kentucky
The following formulae for computing source material risk (carcinogenic and non-carcinogenic) were adapted from
RAGS, Volume I, Parts A and B to account for Site-specific considerations.
Recreational User Scenario
Source Ingestion Pathway
Age-adjusted Ingestion Factor
(mg-yr/kg-day) =
where:
IB-^,*.,. x ED.
ED.
ate7-3l
i(e7-3l.
BW,
ije7-3l
age-adjusted source ingestion factor (mg-yr/kg-day)
average body weight from ages 1-6 (kg)
average body weight from ages 7-31 (kg)
exposure duration during ages 1-6 (yr)
exposure duration during ages 7-31 (yr)
ingestion rate of source age 1 -6 (mg/day)
ingestion rate of source age 7-31 (mg/day)
Default Values
110 mg-yr/kg-day
16 kg
70kg
6 years
24 years
200 mg/day
100 mg/day
Dermal Contact Pathway
Age-adjusted Contact Factor
(mg-yr/kg-day) = SA.r,^ x AF x ED.,.,^ + SA.^-,.,, x AF x ED.^-,.,,
BW,,
\tf\-6
BW,
where:
AF
age-adjusted contact factor (mg-yr-event/kg-day)
skin surface area available for contact (cmVevent)
skin surface area available for contact (cmVevent)
source to skin adherence factor (mg/cm2)
exposure duration during age 1-6 (yr)
exposure duration during age 7-31 (yr)
Default Values
2600 mg-yr-event/kg-day
3730 cmVevent
3500 cmVevent
1 mg/cm:
6 yr
24 yr
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VI, Remedial Alternatives
Page 1
VI. DESCRIPTION OF REMEDIAL ALTERNATIVES
In the previous section of this document, several risk scenarios
were developed. Of these scenarios, contaminated ground water
was unacceptable in every aquifer evaluated. The unacceptable
scenario for surface water (springs and in-stream) is thought to
be due to contamination exiting through seeps into the streams.
Water of reaction with salt cake fines is also an unacceptable
exposure route. Air was deemed to be an unacceptable exposure
route by the method of modelling and comparison with standards.
A total of six alternatives.were evaluated for remediating ground
water (and consequently springs and surface water), as well as
air. Some of these alternatives provided sufficient protection
from water of reaction of salt cake-,fines. With the exception of
Alternative 1 which involves no action, the alternatives are all
varying combinations of air containment; ground water diversion
from SCFs and discharge to Rough River; confirmatory monitoring
of air, surface water and ground water; and institutional
controls. Two of the alternatives involve excavation of the SCFs
from the mine. Alternative 5 involves treating the SCFs via a
proprietary process whereas Alternative 6 involves landfilling'
them. The alternatives are as follows:
Alternative 1; No Action
The National Contingency Plan (NCP) requires the development of a
no-action alternative as a basis for comparison of alternatives.
Therefore, remedial Alternative 1 consists of implementing no
remedial action at the site, including no restriction of future
access to the site and no site maintenance.
The Site would be left in its present condition and allowed to
deteriorate. Because no action would be taken, there are no
costs associated with this remedial alternative. There is also
.no implementation time.
Alternative 2; Institutional Controls & Deed Restrictions plus
Continued Diversion, Treatment & Discharge of Intruding Mine f.
Water ^
Alternative 2 consists of maintaining site security to prevent
accidental exposure by trespassers, as well as deed restrictions
to prevent future residential well installation. Diversion of
water from SCFs in the mine would be continued with subsequent
treatment and discharge to the Rough River. Treatment would
continue to be sedimentation and reduction of ammonia content.
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VI, Remedial Alternatives
Page 2
Discharge is-Bunder a Kentucky National Pollutant Discharge
Elimination System (NPDES) permit.
Because this remedy would 'also result in contaminants remaining
en-site, CERCLA requires a five-year review.
The present-worth cost of Alternative 2 ranges from 7.1 to 8.6
million dollars. Since Alternative 2 only involves continuing
what has been going on at the site over the past several years,
implementation time is considered zero.
Alternative 3: Alternative 2 plus Containment of Night Air
Emissions via Portal Doors
Alternative 3 consists of all measures employed in Alternative 2
plus containment of night air emissions with doors on mine
portals. Portals would only be open during daylight hours when
atmospheric conditions would enhance the dispersion of fugitive
ammonia emissions. Portal opening and closing would be on an
automatic basis with manual override. Based on air quality data
and emissions modelling, EPA feels that this measure should bring
ammonia concentrations into compliance with KMREPC's 8-hour
standard.
Continued diversion of ground water away from SCFs would ensure
no additional ground water (and hence surface water)
contamination or migration. This measure would also aid in
controlling ammonia emissions.
The five-year review described in Alternative 2 would also be
necessary for Alternative 3 since contamination would remain on-
site for this remedial alternative as well.
The present-worth cost associated with this alternative ranges
from 7.5 to 8.9 million dollars. Time to implementation is less
than one year.
Alternative 4A; Alternative 2 plus Forced Ventilation of Mine
Air to Two Dispersion Stacks
,'•
Alternative 4A consists of all measures employed in Alternative 2
plus permanently sealing off all portals to the mine and using
fans to force mine air through two tall stacks.- Emissions would
be released at a height in the atmosphere where turbulent mixing
would ensure adequate dispersion. Based on air modelling
conducted during the FS, EPA feels confident that this
alternative will meet KNREPC's 8-hour ammonia standard.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VI, Remedial Alternatives
Page 3
Continued diversion of ground water away from SCFs would ensure
no additional ground water (and hence surface water)
contamination or migration. This measure would also aid in
controlling ammonia emissions.
The five-year review described in Alternative 2 would also be
necessary for Alternative 4A since contamination would remain on-
site for this remedial alternative as well.
This alternative involves extensive and possibly hazardous
construction inside the mine. Workers would be at risk for
injury or possibly death due to possible collapses and oxygen-
deficient, high-ammonia content air.
The present-worth cost associated with Alternative 4A is between
8.9 and 10.3 million dollars. Time to implementation is four
years.
Alternative 4B: Alternative 4A plus Acid Gas Scrubbers
Alternative 4B is identical to Alternative 4A with the addition
of acid gas scrubbers to reduce ammonia emissions before
discharge to the atmosphere. While EPA is certain that this
alternative would comply with the KNREPC ammonia standard for
air, as well as ground-water requirements, scrubbers would be
unnecessary since amounts of ammonia projected to exit the stacks
would be well within acceptable limits. This alternative
involves the same hazard to workers as Alternative 4A.
Present-worth cost associated with Alternative 4B is between 13.7
and 15.2 million dollars. Time to implementation is four years.
Alternative 5; Alternative 2 plus Excavation of SCFs and
Treatment with NARTEC
Alternative 5 employs all measures in Alternative 2 with the
addition of excavation of SCFs and treatment with NARTEC, a
proprietary chemical process for converting SCFs into stable,
non-hazardous, and somewhat useful products. Ground-water anfl
intruding mine water diversion via pumping and discharge would4
continue until all SCFs were removed from the mine. A dry system
would also be employed to trap fugitive dust during excavation,
since water sprays would react with the fines to form ammonia.
The by-products of the NARTEC process are several salts of which
under 10% would be marketable. The remainder of the by-products
would have to be landfilled.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VT, Remedial Alternatives
Page 4
The same ris~k~s and hazards of work in the mine discussed in
Alternatives 4A and 4B would apply to this alternative.
This alternative would eventually meet all air and ground-water
ARARs. Since no contaminants would remain on-Site for this
alternative, no five-year review would be required under CERCLA.
The present-worth cost associated with Alternative 5 is 115 to
130 million dollars. Time to implementation is projected at 12
years.
Alternative 6; Alternative 2 plus Excavating and Landfilling the
SCFs at an off-Site Location
Alternative 6 employs all measures taken in Alternative 2 with
the addition of excavation and landfilling of SCFs. SCFs would
be taken to an off-site landfill. Ground-water and intruding
mine water diversion via pumping and discharge would continue
until all SCFs were removed from the mine. In all probability,
the large amount of waste at Fort Hartford would necessitate the
creation of its own landfill. A dry collection system similar to
the one in Alternative 5 would be employed for collecting
fugitive dust emissions.
This alternative would involve the same extremly hazardous
working conditions as those found in Alternatives 4A, 4B, and 5.
Since all of the SCFs would be removed from the site, all air and
ground-water standards should eventually be met. Consequently,
no five-year review would be required by CERCLA.
The present-worth cost associated with Alternative 6 is 75
million dollars. Time to implementation is 12 years.
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VII, Comparison of Alternatives
Page 1
VII. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
A detailed comparative analysis was performed on the six remedial
alternatives developed during the FS and the modifications
submitted during the public comment period using the nine
evaluation criteria set forth in the NCP. The advantages and
disadvantages of each alternative were evaluated in order to
identify the alternative with the best balance among the nine
criteria. Figure 7.1 provides a summary of the comparison
between these alternatives.
Threshold Criteria:
_A. OVERALL PROTECTION OF HUMAN HEALTH AMD THE ENVIRONMENT
This criterion addresses whether or not an alternative provides
adequate protection and describes how risks are eliminated,
reduced, or controlled through treatment and engineering or
institutional controls.
Alternative 6 is estimated to be protective for air since all
SCFs would be removed and hence, no more ammonia generated.
Ground-water, surface -water and 'springs are expected to be in
compliance with health-based levels for the COPCs within the next
year or two due to continued diversion, treatment and discharge
of mine water. Alternative 5 should theoretically provide the
same protection as Alternative 6 since SCFs will also be removed
for this alternative. As with Alternative 6, ground-water,
surface water and springs are expected to near health-based
levels within the next year or two due to continued diversion,
treatment and discharge of mine water.
Alternatives 4A and 4B will ensure that the applicable or
relevant and appropriate requirements (ARARs) for air are met and
consequently that human health and the environment is protected.
This will be done by sealing off the mine and ducting ammonia-
laden gas out high stacks where adequate.turbulent mixing and
dispersion can occur. Conservative modelling of ammonia
concentrations estimates that even Alternative 4A (without the
scrubber in 4B) will have no problems meeting these levels. It
is for this reason that Alternative 4B was dropped out early fn
the FS. Ground-water, surface water and springs will near s
compliance with health-based levels within the next year or two
due to continued diversion, treatment and discharge of mine
water.
Alternative 3 should be protective for the air pathway. Based on
air modelling conducted during the FS, EPA feels that the portal
doors could be effective, however, the performance of this
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VU, Comparison of Alternatives
Page 2
alternative would only be known upon implementation since all
estimates are based on models and the site conditions are quite
unique. The continued ground-water diversion, treatment and
discharge will work to make levels in ground water, surface water
and seeps come into compliance with health-based standards within
the next year or two.
Alternative 2 is not estimated to be protective for the air
pathway, since no air control measures are emplo/ed. As stated
previously, levels of ammonia and site contaminants in mine
flumes have decreased dramatically to near-compliance levels.
Ground water, surface water and seeps are nearly in compliance at
the present and are expected to near compliance for health-based
standards within the next year or two due to the continued water
diversion and fines relocation measures.
Alternative 1 is not estimated to be protective of human health
and the environment since it does not eliminate, reduce, or
control risks by treating contamination in the environment.
B. COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs)
This criterion addresses whether or not an alternative will meet
all ARARs or provide grounds for invoking a waiver. Each
alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific and location-specific ARARs.
For a complete listing of all ARARs and ."To be considered" (TBC)
criteria, refer to Section IX of this document.
ARARs exist for the air medium. The ARAR which is currently and
is projected to be continually exceeded if no action is taken is
the KNREPC 8-hour standard of 0.4 mg/m3. The ground-water,
surface water and seeps, the other unacceptable exposure routes
in the Risk Assessment (Section V of this document) , have no
ARARs, only TBCs, or health advisory levels as follows:
Ammonia: 34 mg/1 (health advisory level)
Chlorides: 250 mg/1 (secondary MCL)
Aluminum: .05 - .2 mg/1 (secondary MCL)
The actions taken in each alternative will cause Alternatives 4A,
4B, 5 and 6 to meet the KNREPC 8-hour air ARAR. Alterntatives 4A
and 4B involve containment of ammonia emissions with release at
adequate dispersion times. Since Alternatives 5 and 6 involve
removal of the SCF (source) material, air standards would also be
met.
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VU. Comparison of Alternatives
Page 3
Alternative T's containment of emissions with night dispersion
should meet the KNREPC air ARAR, but EPA can not be absolutely
certain about the effectiveness of the portal system. For this
reason, Alternative 4A has been combined with Alternative 3 as
part of the selected remedy.
Alternative 2 will not meet air ARARs since no actions to address
air are incorporated in this alternative. The same effectiveness
for the ground-water and surface water TBCs applies for this
remedy as does for Alternatives 3 through 6.
Alternative 1 will not meet air ARARs since no actions to address
air are incoporated into this alternative either. Since mine
flume diversion; treatment and discharge would be suspended for
the site under this alternative, it • is doubtful that TBCs for
ground water and surface water would be met either.
Since Alternative 1 involves no action, it is conceivable that
TBCs for ground water could be exceeded since the mine water
diversion and SCF relocation actions which have been ongoing
since the start of the RI would cease. However, as stated
previously, the TBCs listed above for ground-water and surface-
water should be met within the next year or two by continuing the
actions which have been ongoing at the Site. These actions would
be continued for Alternatives 2, 3, 4A, 4B, 5 and 6..
Primary Balancing Criteria:
C. LONG-TERM EFFECTIVENESS AND PERMANENCE
This refers to 'the ability of an alternative to maintain reliable
protection of human health and the environment over time, once
cleanup objectives are met.
Alternatives 5 and 6 are certainly the most effective in the
long-term since waste will be removed from the mine, thus
eliminating the source of, and hence, air and ground-water-
concerns .
Alternatives 4A and 4B are highly effective in the long-term for
air, even though source material will not be removed from the s
Site. Ducting.ammonia-laden air to high stacks which will exit
in the turbulent mixing layer of the atmosphere is a proven
effective way of producing air which complies with ammonia ARARs.
Alternative 3 should be effective in the long term for air ARARs.
Again, this method of air protection is not as proven as those in
Alternatives 4A and 4B.
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VZJ, Comparison of Alternatives
Page 4
Alternatives I and 2 are not effective in the long term (or even
the short term) for air concerns since neither includes measures
for addressing this media.
Alternatives 2 through 6 are all effective in meeting and
maintaining health-based TBCs for ground water and surface water,
as explained previously in this section. Since Alternative 1
involves discontinuing current mine flume diversion from SCFs,
treatment and discharge, it would not be effective for either
obtaining or maintaining health-based TBCs.
D^ REDUCTION OF TOXICITY, MOBILITY OR VOLUME THROUGH TREATMENT
This section discusses the anticipated performance of the
treatment technologies an alternative may employ. The degree of
reduction of toxicity, mobility or volume through treatment
varies depending on the methods of contaminated air handling and
water diversion from SCFs involved.
For the air media, Alternatives 5 and 6 will halt the entry of
any ammonia gas in the air by removing the source, thus reducing
mobility and volume of gaseous emissions from the Site.
Alternatives 4A and 4B will and Alternative 3 should disperse the
ammonia to a height where acceptable isopleths are created, thus
reducing the mobility and volume of contaminated gas.
Alternatives 1 and 2 do not reduce the toxicity, mobility or
volume of ammonia in the air.
For ground water and hence springs and surface water,
Alternatives 2 through 6 will halt the spread of any ground-water
contamination and gradually bring levels to those acceptable
under health advisories. Alternative 1 will not act to decrease
the toxicity, mobility,'or volume. In fact, by ceasing the mine
flume diversion and treatment, ground-water, spring and surface
water concentrations could again increase.
E^ SHORT-TERM EFFECTIVENESS
This involves the period of time required to achieve protection
and any adverse impacts on human health and- the environment that
may be posed during the construction and implementation period
until cleanup objectives are achieved. The following factors
were used to evaluate the short-term effectiveness of each
alternative: protection of the community during remedial
actions, protection to workers during remedial actions,
environmental impacts from implementation of alternatives, and
the time until remedial action objectives are met.
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VH. Comparison of Ahematiues
Page 5
With respect'to the community, Alternatives 3, 4A and 4B do not
pose additional risks or nuisances to the community.
Alternatives 1 and 2 pose no risks over those that already exist.
The excavation involved in Alternatives 5 and 6 would undoubtedly
result in a large amount of fugitive dust generation which even
if controlled could be a community concern. Alternatives 5 and
6, especially Alternative 6, would involve frequent truck traffic
from the site through residential areas for an estimated 12 years
each. This would be expected to create an extreme nuisance to
the community.
Short-term protection for. Alternatives 5 and 6 is not good since
they take 12 years to implement. Potential for ammonia emissions
will still exist during this time, along with fugitive dust.
Alternatives 4A and 4B are better in that they only take four
years to achieve protection and fugitive dust should not be a
problem. If Alternative 3 performs adequately, which EPA feels
it should, protection will be achieved in one year. Short-term
protection is a good balance with time and effectiveness for
Alternative 3. While protection is only partial and non-existent
for Alternatives 2 and 1, respectively, their objectives could
each be met with no implementation time.
Risks to workers for Alternative 1 are non-existent, minimal for
Alternative 2, more so for Alternative 3 and appreciable for
Alternatives 4A and 4B. Alternatives 4A and 4B would involve
extensive and possibly hazardous construction inside the mine.
Alternatives 5 and 6 are both extremely dangerous for workers.
Injuries and even fatalities would not be uncommon due to
conditions under which imminent collapse could occur and low
.oxygen, high ammonia air.
F. IMPLEMENTABILITY
This is the technical and administrative feasibility of an
alternative, including the availability of goods and services
needed to implement the solution.
Alternatives 1 and 2 are very feasible since they involve no
action and continuing what is currently working at the Site. f.
While Alternative 3 will involve fitting doors to irregular mine
portals and installing an automated system for closing and
opening them, it should not present any difficult implementation
problems.
Alternatives 4A and 4B would present implementation problems. As
a result of the hazardous mine working conditions, workers would
be required to wear Level B protection. Work could be quite
-------
Fort Hartford. Stone Quarry NPL Site
Record of Decision
Section VU, Comparison of Alternatives
Page 6
difficult under these conditions. In addition to everything
mentioned previously, the mine is dark and has many limestone
blocks to trip a worker and make it inaccessible to vehicles and
equipment. Workers would have to be tethered to the outside of
the mine with air supply lines as potentially fatal levels of
ammonia exist inside the mine.
Alternatives 5 and 6 are both equally dangerous and more so than
4A and 4B since SCFs would have to be excavated from every remote
corner of the mine. More man-hours would be spent in the mine
under conditions of even greater hazard.
G.
COSTS
Cost include capital costs as well as operation and maintenance
costs and is presented in 'present value. This evaluation
examines the estimated costs for implementing the remedial
alternatives. The estimated present-worth value of each
alternative is as follows:
Alternative 1:
Alternative 2:
Alternative 3:
Alternative 4A:
Alternative 4B:
Alternative 5:
Alternative 6:
$0
$7.1 to 8.6 million
$7.5 to 8.9 million
$8.9 to 10.3 million
$13.7 to 15.2 million
$115 to 130 million
$75 million
Modifying Criteria:
H^ STATE ACCEPTANCE
This indicates whether, based on review of the RI report, FS
report, and Proposed Plan, U.S. EPA and KNREPC agree on the
preferred alternative. EPA and KNREPC are in agreement on the
selected alternative. Appendix A of this document contains a
letter of concurrence from KNREPC.
-------
Fort Hartford Stone Quarry NPL Site
Record of Decision
Section VH. Comparison of Alternatives
Page 7
I. COMMUNITY ACCEPTANCE
This indicates the public support of a given alternative. This
criterion is addressee in the Responsiveness Summary, Appendix B
to this document. The community accepts the selected remedy.
-------
Figure 7.1
Comparative Analyst of Remedial Alternative*
^•'f
Overel ProUollon of Human
Health and the Environment
— Diracl Contact/SCF* Ingaation
— Groundwater Ingestion by
Future Onsfte Residents
!
— Exposure to Airborne Ammonia
Emlitlon*
AJt»inattv» 1
Vy.jk AbtMlv .
Not protective.
Nol prolsclive.
Not protecliva.
Alternative 2 .
ln*tttutton*1 Controta/ Pump.
Treat intruding Water
Inititutional controls
effectively aliminata tha risk
of direct human contact
with SCF*.
Protective. Exposure is
prevented until restoration
of groundwater can occur.
A small area offsite carrlei
the potential for acuta
exposures to ammonia in air
for 10 to 20 yaara.
Alternative 3
Institutional Control* and
Containment of Night Air
Emlaalonf / Pump, trait
Intruding Water
Same aa Alternative 2.
Same as Alternative 2.
Protective.
Alternative 4a
Forced Ventilation of Mine
AW Pump, Treet Intruding
yVe'er
Same aa Alternative 2.
Same as Alternative 2.
Same aa Alternative 3.
Alternative 6
Excavate, Treet SCFe with
NARTEC Process/ Interim
Engineering Control* on Air
Emission* end Qroundweter
Risk of direct human contact
with SCF* and Ingeatlon of
SCF* dutt It Incteaaed
during tha 10-12 year
period of excavation and
removal of SCFs Irom tha
mine. After treatment,
contact with oxides
raaiduala la prevent through
institutional controls.
Same as Alternative 2.
Same as Alternetlve 3.
Alternative 0
Excavate, Landfill SCFs at
Offsite Location/ Interim
Engineering Control* on Air
Emissions end Oroundwatar
Risk ol direct human
contact with SCFs and
ingeation of SCF* dust Is
Increased during the 10 •
12 year period ol
excavation and removal ol
SCF* from the mine. After
the material Is landtilled.
the risk associated with
direct contact with SCFs Is
eliminated as long as (he
landfill is maintained.
Same as Alternative 2
onsite. Tha landfill will
prevent the contamination
ot groundwatar as long as
It is maintained.
Rlak of fugitive ammonia
and dust emission* al tha
landfill.
lot**:
.CFi -
vRARl
:L -
ON =
IH3 -
Salt C*ke Fine*
Applicable or Relevant and Appropriate Requirement*.
chloride
aluminum nitride
ammonia
Operation and maintenance
to
(B
o
rt
H-
O
3
0)
00
rt
-------
Fort Hartford Stone Quarry NPL Site
Record, of Decision
Section VIET, Selected Remedy
Page I
VIII. SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of alternatives and public and State
comments, EPA selected a remedy involving source control, ground-
water diversion, and air containment for the Site. At the
completion of this remedy, the risk associated with this Site has
been calculated at 10-6 which is determined to be protective of
human health and the environment. The total present-worth cost
of the selected remedy, a combination of Alternatives 3 and 4A,
is estimated at 8.9 to 10.3 million dollars. Costs will be at
the higher end of this range should measures for Alternative 4A
(discussed below) be necessary.
A_._ SOURCE CONTROL
Source control will address the SCF material remaining in the
mine. Since the source material at Fort Hartford only can
migrate when reacted with water, the main objective for source
control at Fort Hartford is keeping the SCFs as dry as possible.
The selected remedy includes continuing surveillance in the mine
to determine new areas of moisture such as new breakthroughs,
etc.. Any new breakthroughs or sinkholes would quickly be
repaired. It also includes SCF relocation measures to dryer
areas and water diversion within the mine away from the SCFs.
These measures have been ongoing since 1990 and have been quite
successful in containing the source material and the spread of
any of its related constituents to the ground-water (and hence
springs and surface water) or air pathways.
The plan for source control is to continue what has been done
ever the past four years with a few enhancements to make it even
more effective. Although the majority of SCFs have been moved
from high-moisture areas, SCFs will be moved on an as-needed
basis 'to prevent contact with moisture, including high humidity.
The water diversion pumping system used in the past will be
upgraded to a more permanent, automated system which has the
feature of being accessible from the outside of"the mine. This
is due to new sumps being installed from the ground surface to
natural low points of the mine floor. It is anticipated that
approximately six to eight sump pumps will be necessary to remove1
water from various areas of the mine. The exact locations of the
sumps will be determined during in-mine surveys conducted during
remedial design.
Treatment and discharge will be under a new KNREPC permit.
Treatment will be for ammonia and sediment suspended in the mine
-------
Fort Hartford Stone Quarry KPL Site
Record of Decision
Section VXZT, Selected Remedy
Page 2
flumes. Discharge will be to the Rough River, as in the past.
B_._ GROUND-WATER REMEDIATION
Source control is expected to nearly eliminate reaction of SCFs
with water, thereby allowing natural attenuation processes to act
in reducing contaminant levels in the ground water (and hence
springs and surface water) to health-based TBCs stated in Section
IX of this document.
Treatment of diverted mine flumes will continue to be for ammonia
via an air stripper or some other type of ammonia reduction
system if a better one is developed prior to RD. This would be
followed by sedimentation.
Monitoring will be performed semi-anually for ground-water,
surface water and springs to gauge the progress of attenuation
and restoration.
Performance Standards
1. Monitoring Locations and Parameters for Assessing
Effectiveness of Reduction to Health-based Levels
Parameters: Full TCL/TAL list
Locations: - SCF-impacted ground-water
monitoring wells used in
the RI with supplementary
sampling at other RI wells
SCF-impacted seeps used in
the RI plus supplementary
• sampling at other RI points
. - SCF-impacted surface water
points used in the RI plus
supplementary sampling at
other RI points
selected residential wells
monitored in the RI
2. Treatment Standards
Treatment standards for the mine flumes before discharge to
the Rough.River are specified in the KPDES permit.
3. Discharge Standards
Discharges from the ground-water and seep treatment system
shall comply with all ARARs, including, but not limited to,
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Fort Hartford Sterne Quarry NPL Site
Record of Decision
Section VTET, Selected Remedy
Page 3
requirements of the National Pollutant Discharge Elimination
System (NPDES) permitting program under the Clean Water Act,
33 U.S.C. {1251 et sea.} and all effluent limits established
by EPA, as well as Kentucky Surface Water Quality Standards.
4. Design Standards
The design, construction and operation of the treatment
system shall be conducted in accordance with all ARARs.
Design will also be performed in an effort to minimize all
environmental impacts to terrestrial and aquatic habitats in
'the area.
5. Other Standards
Section IX of this document lists all other Applicable or
Relevant and Appropriate Requirements (ARARs) and "To Be
Considered" (TBC) health-based guidelines pertaining to this
remedial action at the Fort Hartford Site.
C. AIR REMEDIATION
As stated previously in this section, the selected remedy
involves a combination of Alternatives 3 and 4A from the FS.
Should the portal doors in Alternative 3 fail to meet EPA's
expectations, the measures in Alternative 4A (i.e., sealing off
the mine-and ducting emissions to high stacks) will be employed.
While EPA feels confident that the measures in Alternative 3
should work, it chose to combine Alternatives 3 and 4A so that if
the five-year-review shows that the portal doors are not
performing to EPA's expectations, the mine will be sealed off and
emissions ducted via a forced air ventilation system to high
stacks as stated in Alternative 4A. As stated in' Section VII
(Comparison of Alternatives) of this document, while the
effectiveness of the high stacks can be guaranteed, the
construction involved for Alternative 4A is extremely hazardous
to workers. Hopefully, contingency measures will not be
necessary, thus avoiding the unsafe worker conditions inherent in
Alternative 4A.
Performance Standards
I. Ambient Air Standards
KNREPC 8-hour standard: 0.4 mg/m3
EPA 24-hour standard: 0.4 mg/m3
EPA annual (chronic) standard: 0.1 mg/m3
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section Vm, Selected Remedy
Page 4
2. Design Standards
The design, construction and operation of the portal
door system and the high stack and forced air system
shall be constructed in accordance with all ARARs.
Design will be performed in an effort to minimize
impacts to terrestrial and aquatic habitats in the
area.
3. Monitoring
Monitoring will be conducted semiannually and will
consist of 24-hour ammonia monitoring for a 30-day
period.
4. Other Standards
Section IX of this document lists all other ARARs and
TBCs pertaining to this remedial action at the Fort
Hartford Site.
D. COMPLIANCE TESTING AND MONITORING
No later than five years from the date of commencement of
remedial construction, a five year review will be completed for
the Fort Hartford Site since waste remains on-Site. Five year
reviews regularly occur after the first five-year-review at
intervals of no greater than five years.
Semi-annual ground-water, seep and surface water monitoring will
be performed for -the parameters listed above under Monitoring
Locations and Parameters for Assessing Effectiveness of Reduction
to Health-based Levels (page 2 of this Section) beginning with
the date of construction completion. If EPA is satisfied that
concentrations have come into compliance with health-based levels
and have been maintained for an acceptable time, EPA may decide
that it is permissible to conduct monitoring on a less frequent
basis. Air monitoring will also be performed on a semi-annual
basis to insure that levels of ammonia in the ambient air are
compliant with those set forth under Air Remediacion, Performance
Standards, Ambient Air in this Section. When levels reach
acceptable values, it will also be at EPA's discretion to
decrease monitoring frequency.
At the time of the first or any five-year-review, EPA will
evaluate semi-annual air and water monitoring, along with all
ARARs and TBCs in part IX of this document. This review will be
conducted to determine if the source control component and
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Fort Hartford Stone Quarry TiPL Site
Record oj" Decision
Section VZZ7, Selected Remedy
Page 5
natural attenuation are functioning effectively to reduce
contaminants iia ground water, seeps and surface water to
acceptable health-based levels and also to insure that these
contaminants a^re not migrating to nearby residences. The first
five-year review will also determine if the portal doors for
Alternative 3 are functioning effectively enough to reduce
ammonia levels in ambient air to those ARARs discussed earlier
and in Section IX.
EPA will evaluate five-year reviews for ground-water, spring and
surface water concentrations to insure that they are not
increasing or moving close to residences in the area. Should a
five-year review reveal any other inadequacies for the Source
Control component of this section, EPA will reevaluate the
effectiveness of the source control component and may make
recommendations to improve its capabilities.
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Fort Hartford. Stone Quarry KPL Site
Record, of Decision
Section IX, Statutory Determinations
Page 1
IX. STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that-achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this Site must comply
with applicable or relevant and appropriate environmental
standards established under federal and State environmental laws
unless a statutory waiver is justified. The selected remedy must
also be cost-effective and utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable. Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly
reduces the volume, toxicity or mobility of hazardous wastes as
their principle element. The following sections discuss how the
selected remedy meets these statutory requirements.
A_._ PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment by
preventing moisture from contacting SCFs inside the mine. This,
together with natural attenuation, prevents migration of any
contaminated ground water in the plume beneath the surface or in
springs and surface water.
The selected remedy also contains two measures for containing
ammonia-laden air coming from the mine. The first measure
involves installing doors to seal off the portals during night
hours and open them during day hours when adequate dispersion and
mixing conditions exist to move emissions from ground level into
the upper atmosphere. Should this first measure not produce
compliant isopleths (lines of constant concentration) for ammonia
about the site and surrounding areas, then a contingency measure
in the remedy will be employed. The secondary or contingency
measure in this ROD for air involves permanently sealing off the
portal doors (keeping the doors continually closed) and using
forced ventilation to duct mine air to two dispersion stacks
which would inject emissions into upper mixing layers of the
atmosphere where adequate dispersion would definitely produce
ambient air compliant with State and federal regulations
previously outlined in this document.
Institutional controls and monitoring into perpetuity will insure
that the public is not affected by the Site at a future time.
Implementation of the selected remedy should not pose' any
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section IX, Statutory Determinations
Page 2
unacceptable sljiort-term risks or cross-media impacts to the Site,
the workers or•the community. Should the high-stack measures in
this remedy be | required, extreme caution will be taken while
workers are in;the mine as provided for in an EPA-approved Health
and Safety Plan. Risks to the environment will be minimal.
B^ ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS OF ENVIRONMENTAL LAWS
The selected remedy of source control via water diversion and
fines relocation with discharge to Rough River as well as
containment (and possibly ducting to a high stack) of air will
comply with all applicable or relevant and appropriate chemical,
action and location-specific requirements (ARARs). ARARs are
presented below.
Action-Specific ARARs:
* Clean Water Act Discharge Limitations NPDES Permit 40
CFR 122, 125, 129, 136; Pretreatment Standards 40 CFR
403.5. Prohibits unpermitted discharge of any
pollutant or combination of pollutants into waters of
the U.S. from any point source, including storm water
runoff from industrial areas. Applicable.
* Clean Water Act Wetlands Regulations, Part 404, CFR
230. Controls the discharge of dredged or fill
materials into waters of the U.S. Applicable.
* Occupational Safety and Health Standards (OSHA) 29 CFR
1910.1200. Employee right to know; information to on-
site workers regarding chemicals they must work with.
Applicable.
* Department of Labor, Mine Safety Regulations, 30 CFR
11.150. Mining safety requirements regarding safety
and health of personnel performing activities within
the mine. Applicable.
* 803 KAR Chapter 2. Kentucky supplement to OSHA "right
to know" regulations. Applicable.
* 401 KAR Chapter 30. Solid waste general administrative
procedures. Applicable.
* 401 $AR Chapter 47. Solid waste facility performance
standards for protection of human health and
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section IX, Statutory Determinations
PageS
environment. Applicable.
* 401 KAR 51, New Source Requirements relating to
emissions from the mine during remediation.
Applicable.
* 401 KAR Chapter 63:022. Regulates new (installed after
11/11/86) sources (other than NESHAPS) emitting toxic
pollutants, including ammonia. Applicable.
* 401 KAR Chapter I. Regulates transportation of
hazardous materials. Applicable.
* 815 KAR, Chapters 7, 10, 15, 20 and 35. Kentucky
building codes applying to construction of on-site
structures. Applicable.
* 401 KAR Chapter 4. Requirements for water withdrawal
from and construction in streams. None anticipated,
but applicable.
* 401 KAR Chapter 5. KPDES requirements and water
quality standards. Applicable to discharge of
intruding mine water to the Rough River.
Location-Specific ARARs:
* Fish and Wildlife Coordination Act, 16 U.S.C. 661,
742a, 2901. Requires action to protect fish and
wildlife from actions modifying streams or areas
affecting streams. No. stream impacts expected, but
applicable. • '
* Clean Water Act, Section 404 Pertaining to Wetlands, 33
U.S.G. Section 1251 et seq. Prohibits discharge of
dredged or fill material into navigable waters without
a permit. Applicable.
* KRS 149, various chapters, 402 KAR Chapter 3. Forestry
statute and regulations pertaining to on-site
silvacultural activities. Applicable.
Chemical-Specific:
* Safe Drinking Water Act MCLs, 40 CFR Sections 141.11 -
141.16. MCLs have been set for toxic compounds as
enforceable standards for public drinking systems.
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Fort Hartford Stone Quarry NPL, Site
Record of Decision
Section IX, Statutory Determinations
Page 4
Secondary MCLs (SMCLs) are unenforceable goals
regulating the aesthetic quality of drinking water.
Relevant and appropriate as standards of protection for
ground water that is a source or potential source of
drinking water.
Safe Drinking Water Act, MCLGs, 40 CFR Sections 141.50
- 141.51. MCLGs (Maximum Contaminant Level Goals) are
non-enforceable concentrations that are protective 'of
adverse human health effects and allow adequate margin
of safety. Relevant and appropriate since this ground
water is a potential source of drinking water.
Clean Water Act (CWA) Water Quality Criteria. Criteria
used by the State, in conjunction with a designated use
for a stream segment. These are non-enforceable
criteria both for protection of aquatic life and human
health, by direct ingestion, or ingestion of aquatic
organisms. Applicable to the quality of site surface
water, especially discharges of metals, ammonia, and
chlorides to the Rough River.
Clean Air Act (CAA) National Ambient Air Quality
Standards (NAAQS), 40 CFR, Part 50.6. Sets primary and
secondary standards for protection of public health
from exposure to the "criteria pollutants," among which
is respirable particulate matter, PM10. Applicable to
particulate matter emissions from the mine.
Method for Determination of Particulate Matter, 40 CFR
50, Appendix J. Determination for the presence of
particulate matter. 'Applicable.
USEPA Regulations on Ambient Air Monitoring, 40 CFR
53.22, 40 CFR 53.34. Test procedures for ammonia and
particulate matter in air. Applicable to discharge of
air contaminants and gaseous and particulate emissions
from the mine.
KRS 224.320 and 330. Maintain a reasonable degree of
purity of the air resources; limits the contaminants
that may be emitted into the air in contravention of
the emission standards or ambient air standards.
Applicable.
401 KAR 63:021. Regulates existing (as of 11/11/86)
sources emitting toxic (other than NESHAP) air
pollutants including ammonia gas. Applicable.
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Section IX, Statutory Determinations
Page 5
* 401 KAR Chapter 53. Regulates particulate emissions.
Ambient air quality standards; particulate emissions
from the mine.
* Kentucky Water Quality Standards, 401 KAR 5:031. Water
quality criteria for protection of aquatic life,
including free ammonia, chlorides, arsenic, and other
metals. Applicable to Rough River discharge.
* KRS 224.01-400. Regulates releases of hazardous
substances (including ammonia) into the environment.
Applicable.
* 401 KAR Chapter 8, 401 KAR 5:037. Concerns ground-
water protection. Applicable.
Other Criteria To-Be-Considered:
* Executive Order 11988, Floodplain Management Policy.
Sets forth policy for the protection of floodplains.
* Executive Order 11990, Wetlands Protection Policy.
Sets forth policy for the protection of wetlands.
Applicable although wetlands on and adjacent to the
Site were not shown to be impacted by Site
constituents.
* .USEPA Ground-water Protection Strategy. Sets forth
policy for the protection and classification of ground
water regarding potential use as a drinking water
source.
* USEPA Drinking Water Health Advisories. Advisories
based upon current understanding of toxicology of
contaminants.
C. COST-EFFECTIVENESS
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness propcrtionai to its
costs, the net present worth value being between 8.9 and 10.3
million dollars. Other alternatives such as £5 and #6, which
were determined to meet ARARs, were much less cost-effective. In
addition to not meeting ARARs for the Site, the other
alternatives are only partially protective.
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Fort Hartford. Stone Quarry NPL Site
Record of Decision
Section IX, Statutory Determinations
Page 6
D. UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE
MAXIMUM EXTENT PRACTICABLE
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
Fort Hartford Stone Quarry Site. Of those alternatives that are
protective of human health and the environment and comply with
ARARs, EPA has determined that the selected remedy provides the
best balance of tradeoffs in terms of long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability,
and cost, also considering the statutory preference for treatment
as a principle element and community input.
The selected remedy should be fairly easy to implement with the
lowest cost and least risk to workers of the scenarios which
would be protective of human health and the environment.
E. PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT
The remedy provides for treating water diverted from the mine for
ammonia and sediment before discharge to Rough River. Five-year-
reviews are also included. These provisions insure that the
remedy will be evaluated at intervals of no less than five years
starting from the date of construction commencement and, if it is
not meeting the standards set forth in this Record of Decision,
the remedy will be upgraded to meet those standards.
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Appendix A
Letters from Support Agencies
-------
PHILLIP J. SHEPHERD /i/^&lf^xllv BRERETON C. JONES
SECRETARY Isl Sfi< \=l GOVERNOR
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
FRANKFORT OFFICE PARK
14 REILLY ROAD
FRANKFORT. KENTUCKY 4O601
March 20, 1995
Harold W. Taylor
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta GA 30365
RE: Revised Draft Record of Decision
Fort Hartford Stone Quarry NPL site
Ohio County, Kentucky
Dear Mr. Taylor:
The Kentucky Division of Waste Management (KDWM) has reviewed
the above document. Substantial changes have been made, and KDWM
appreciates USEPA's demonstrated willingness to explore these areas
and achieve mutual agreement. In view of these changes, KDWM
concurs with the remedy this ROD proposes with the following
reservations:
1) Concerning ecological risk, KDWM's interpretation of the
data presented for the Rough River is different than that of
USEPA. While USEPA has concluded that no additional risks are
present due to site contaminants, KDWM does not agree with
this interpretation. In addition, KDWM remains concerned that
ground-level releases of air with high ammonia concentrations
could impact the Davidson Wildlife Management Area. While
USEPA has stated that the selected remedy does not add any
additional risk to this area, KDWM suggests that Barmet be
required to perform limited air sampling and ecological study
to insure that such damage does not occur.
2) While it is clear that USEPA does not feel that soil sample
methodology has biased the results of the site's Risk
Assessment, KDWM feels that this should be confirmed through
further sampling. It is possible that the act of compositing
soil samples from a greater depth has had a dilution effect on
whatever contaminants are present, potentially masking the
effect this pathway might have on human health. The potential
effect on site workers and possible future residents is
unknown. While Barmet has stated their intent to restrict
future development of this site, it is not clear that such
intent constitutes long-term assurance that no development
.CO. Printed on Recycled Panor
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Mr. Taylor
Page two
March 20, 1995
will take place. It is also unclear exactly what mechanism
will be used to insure that the site remains undeveloped. If
such assurances cannot be provided, it may be necessary for
KDWM to obtain restrictions as may be applicable under KRS
224.01-400.
While KDWM does concur with USEPA regarding the necessity of
the actions proposed in this ROD, we feel that the above
reservations need to be addressed. To accomplish this, USEPA may
wish to consider the creation of an additional Operable Unit for
this site. KDWM feels that these issues could be addressed in a
manner that is not time- or cost-intensive, one that could
eliminate further environmental and human health concerns.
Thank you for your consideration of these comments. If you
have any questions or concerns, please feel free to call Eric
Liebenauer at (502) 564-6716.
Sincerely,
A
Caroline P. Haight P.E., Director
Division of Waste Management
c: Jeff Pratt
Rick Hogan
Randy McDowell
CPH/JP/RH/EL/el
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Appendix B
Responsiveness Summary
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Fort Hartford Stone Quarry ffPL Site
Record of Decision
Appendix B, Responsiveness Summary
Pagel
APPENDIX B
FORT HARTFORD STONE QUARRY NPL SITE
RESPONSIVENESS SUMMARY
A. OVERVIEW
When the public comment period began, EPA had selected a
preferred alternative for the Fort Hartford Stone Quarry Site in
Olaton, Kentucky. EPA's preferred alternative addressed the air
and ground-water/spring and surface water contamination problems
at the Site. The preferred alternative involved continued
diversion of intruding mine water away from SCFs., SCF relocation
to dryer areas of the mine, and treatment of mine flumes with
subsequent discharge to Rough River. Air was to be addressed in
a two-phased approach. Containment of air from the mine would be
achieved at night via portal doors which would open during the
daytime hours when conditions for adequate dispersion exist.
Should phase I not be effective, the remedy called for
permanently sealing off the mine and ducting the air via forced
ventilation to two high stacks.
Judging from the comments received during the public comment
period, the residents and city officials of Olaton would support
the continued mine water diversion and treatment measures with
two phased air containment, as outlined above and in the body of
this document. In a letter dated December 13, 1994, the PRPs for
the Fort Hartford Site expressed concern that the type of
treatment for the mine water before discharge to the Rough River
not be specified since technologies for ammonia removal are
currently being reevaluated to ascertain which would be best for
the Site. EPA feels that this is a practical suggestion and has
only specified in the ROD that treatment be for ammonia and
sediments, as it has been in the past.
These sections follow:
* Background on Community Involvement
* Summary of Comments Received During the Public Comment
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Fort Hartford Stone Quarry KPL. Site
Record of Decision
Appendix B, Responsiveness Summary
Page 2
Period and Agency Responses
Part I: Summary and Response to Local Community
Concerns
Part II: Comprehensive Response to Specified
Legal and Technical Questions
* Remaining Concerns
* Attachment: Community Relations Activities at Fort
Hartford Stone•Quarry
B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community concern about the Fort Hartford site has been minimal.
Most concerns center around obtaining access to city water lines.
In the past, some citizens were interested in the stressed levels
of vegetation from ammonia gases coming from the Site as well
ammonia odors. Expedited response actions beginning in 1990
included water diversion, repairing all breakthroughs which were
allowing ammonia to escape and other actions. These actions
coupled with community outreach have eliminated these concerns.
The majority of citizens and local officials in the area are
aware of the Site, but have not expressed undue concern.
During interviews, residents and local officials expressed
concern for private wells in the area, since approximately half
of the residents in the area do not have access to city water.
The homeowners would all like city water if hookups were
available. It should be noted that contamination has not
impacted and is not projected to impact any residential wells.
Although everyone interviewed knew about the Site's existence, no
one except a few close neighbors considered the Site to be a
problem. One neighbor not in the immediate vicinity of the Site
was concerned about his well water since his infant had
experienced intestinal problems. The water was tested, showing
all levels within the acceptable range. It was determined that
the child's problems were not Site-related.
City and County officials wanted to be kept informed about Site
findings, as did the Site's neighbors.
The major concerns expressed during the remedial planning
activities at the Fort Hartford Stone Quarry Site focused on the
possible health effects from contamination at the Site. These
concerns and how EPA addressed them are described below:
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Fort Hartford Stone Quarry KPL Site
Record of Decision
Appendix B, Responsiveness Summary
PageS
1. Several citizens living nearest to the Site expressed
concerns about using their well water. Citizens questioned
Barmet's contractor performing tests on their wells.
EPA Response: ;EPA informed citizens of past sampling events
overseen by EPA which had revealed no impacts to residential
wells in the area. Citizens were reassured that EPA would be
overseeing Barmet's contractor in the field as well as evaluating
all sampling results.
2. Local citizens were concerned about the effect the Site was
having on property values.
EPA Response: EPA sympathized and said that it hoped that
remedial activities at the Site would help bring the property
values up.
3. Citizens expressed concerns about odors and stressed
vegetation caused by ammonia gases emanating from the Site.
EPA Response: These conditions were corrected during expedited
response actions which took place before the Remedial
Investigation ever began. All known sinkholes and breakthroughs
connecting to the mine (32 total) were repaired, while some
portals were permanently shut. Water was diverted away from SCFs
inside the mine. SCFs were also relocated to dryer areas of the
mine to prevent ammonia formation. These actions coupled with
community interviews as well as che RI kickoff meeting and fact
sheet served to eliminate these concerns.
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES
The public comment period on the proposed plan for the Fort
Hartford Stone Quarry NPL Site was held from November 3, 1994, to
December 6, 1994. EPA held a public meeting on November 17,
1994, to present the proposed plan to the public. Comments
received during this time are summarized below. Part I of this
section addresses those community concerns and comments that are
non-technical in nature. Responses to specific legal and
technical questions'are provided in Part II.
Part I - Summary and Response to Local Community Concerns
Comments Made During the November 17, 1994, EPA Public Meeting
For the detailed transcript of the public meeting, please consult
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Fort Hartford. Stone Quarry KPL, Site
Record of Decision
Appendix B, Responsiveness Summary
Page 4
the administrative record for the Fort Hartford NPL Site.
1. A citizen requested that EPA define deed restrictions. He
also wanted to .know how to get in touch with EPA in the
future.
EPA Response: EPA stated that deed restrictions varied from site
to site but that here they would include statements placed on
deeds at the local Courthouse. These statements would inform any
potential buyer of the Site and related waste. EPA also stated
that legislation could also be passed by the County forbidding
wells to be installed on certain properties. EPA gave the
gentleman a toij.1 free number to call to speak with EPA personnel.
2. Several citizens and one local official stood up and
expressed:concern that ground-water contamination from the
Site could be impacting their potable domestic wells.
Another local official questioned if EPA had the funding or
the authority to require the PRPs to pay for a water line
for the area.
EPA Response: EPA's hydrogeologist, Bill O'Steen answered this
question and showed several visual aids on the overhead projector
in doing so. He stated that contamination had net migrated
vertically to the depth of the residential wells. More
importantly,, residential wells are located sufficiently away from
the Site laterally. He explained how EPA knows the velocity of
the ground water and by the knowing the distance to the nearest
home, a conservative time to reach residences could be
calculated. This amount of time would be several hundred years
if nothing was done in the remedial action. Mr. O'Steen also
explained that no ground water would migrate past the Rough River
to the north since the Rough River is a low point for the area.
Because no ground-water threat exists, EPA stated that the
Superfund laws could not pay for or obligate PRPs to pay for a
water line for the residents around the Site. Glenn Adams of EPA
did, however, give some information on other programs within the
agency which could possibly help the residents attain a water
line.
3 . • A citizen questioned how EPA would know whether or not the
air and ground water plumes were being contained and reduced
in concentration and what would be done if they were not.
EPA Response: EPA stated that the ROD included monitoring
measures biannually for ground water and air. EPA also explained
the five-year review process: that since wastes were remaining
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Fort Hartford Stone Quarry NFL Site
Record of Decision
Appendix B, Responsiveness Summary
Page 5
on-Site, EPA would be required to conduct a review at least once
every five years beginning with the date of construction
commencement. EPA stated that if the five year review revealed
the need, the forced air ventilation and stack system would be
installed and other ground-water measures could be employed.
4. A citizen asked whether or not dye traces could be used to
ascertain pathways of ground-water contamination.
EPA Response: Mr. O'Steen stated that while dye traces are
helpful in karst terrains and where faults and fractures exist,
the effectiveness at Fort Hartford would be minimal since the
areas in question are too deep and the dye would move too slowly.
He also stated that an inordinately large amount of dye would
have to be used at Fort Hartford.
5. A local official inquired whether any metals had been found
in the ground water.
EPA Response: EPA responded that the only heavy metal found in
somewhat high concentrations was arsenic which is a human
carcinogen. All levels, however, were within acceptable
standards.
6. Citizens asked who owned the Site and who the PRPs were.
EPA Response: EPA explained that Barmet was the main PRP and
that they had entered into an agreement with Alcoa and the Bank
of Louisville for financing Remedial Design and Remedial Action
(RD/RA) at the Site.
7. A citizen expressed concern that the plan to contain ammonia
emissions from the mine was only a temporary solution or
"band aid".
EPA Response: EPA stated that at the current time the known
alternatives were based on current technologies and the risks at
the Site. Keeping the water away from the material and
containing emissions is the best alternative technically and
based on risks to workers.
8. A citizen asked about the NARTEC process in remedial
alternative #5.
EPA Response: EPA explained how NARTEC worked and that it had
been used mainly in Europe. The two places in the states where
it was being tried did not have any definitive results in yet.
The places in Europe were successful for NARTEC, however, based
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Fort Hartford Stone Quarry NPL Site
Record of Decision
Appendix B, Responsiveness Summary
Page 6
on their rates, cleanup of Fort Hartford would take 20 years and
be very costly. EPA also explained that about 80% of NARTEC's
by-products would still need to be landfilled.
Part II: Comprehensive Response to Specified Legal and Technical
Questions
Comments Made By PRPs in the December 13, 1994, Letter to EPA
The only legal and technical question received was in the
December 13, 1994, letter to EPA from Barmet Aluminum. This
letter can be found in the administrative record for the Fort
Hartford Stone Quarry Site.
The PRPs agreed with EPA's selected remedy for the Site but
wished for EPA;to not specify the method of treatment for ammonia
for the intruding mine water before discharge to Rough River.
The FS specified a particular treatment system, namely air
stripping in a packed aeration tower. Treatment is to assure
that Ambient Water Quality Criteria (AWQC) for ammonia will not
be exceeded in the Rough River from the discharge of the
intruding mine water.
Barmet hoped that EPA would not specify the type of technology,
thus allowing extra time before Remedial Design (RD) for more
treatability studies to determine the optimal ammonia removal
technology.
EPA recognizes that ammonia's chemical and physical properties do
not render it easily removed by air stripping. Different types
of air stripping, chlorinatiqn, and ozonation, along with other
treatment technologies are being examined to determine the best
method of ammonia removal in the mine flumes before RD. Should a
technologiy prove more effective than air stripping, EPA will
utilize it.
D. REMAINING CONCERNS
EPA is unaware of any remaining concerns.
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Fort Hartford Stone Quarry fiPL Site
Record of Decision
Appendix B, Responsiveness Summary
Page 7
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES AT MURRAY OHIO DUMP
SUPERFUND SITE
Community relations activities conducted for the Fort Hartford
Stone Quarry Site have included:
* Distribution of an RI/FS kickoff fact sheet (December 1991)
* Community interviews (June 1990 and August 1994)
* An RI/FS kickoff public meeting (December 1991)
* Distribution of a proposed plan fact sheet (November 1994)
* A proposed plan public meeting in Olaton to record comments
by the public, including potentially responsible parties
(November 1994)
* Phone-calls to various members of the community throughout
the RI/FS to address their various concerns
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