United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-88/038
June 1968
Superfund
Record of Decision
Goodrich, B. F., KY
-------
""REPORT =~MEHTAnoN 11. REPORT NO~PA/ROD/:O~-88/036 --;.-u_-
Co TItle 8nd lubtltle
SUPERFUND RECORD OF DECISION
Goodrich, B.F., KY
First Remedial Action - Final
a. 1t8cI....,.... ~CCft"" No.
-- ,
-
-s. Re~th4/88
..
Authoffs)
.. P.rformfnc O"l8nlz8tlon R8tIt. No.
,. P8rfonnlnc OraanlZ8tfon H8me 8nd Add-
10. ~J8CtIT..klWo" Unit Ho.
-
11. Contr8ct(c} or Or8nt
-------
EPA/ROD/R04-88/036
Goodrich, B.F., KY
First Remedial Action - Final
16.
ABSTRACT (continued)
The company resolved the problem in June 1980. The site was placed on the NPL in
September 1983. The primary contaminants of concern affecting the soil, sediments and
ground water are VOCs including benzene, toluene and 1,2-dichlorethane (EDC), and other
organics including PAHs.
The selected remedial action fo.r this site includes: excavation and consolidation of
approximately 5,000 yd3 of contaminated soil and sediments within the dikes and around
the landfill from both the BFG and Airco sites, with onsite disposal in the former burn
pit area followed by construction of an organic vapor recovery system and a RCRA cap
over the burn pit; reconstruction of the dikes surrounding the landfill for flood
prevention; upgrading of the landfill caps and installation of a leachate extraction
system with onsite treatment of the leachate and off site discharge to the local river;
pump and treatment at the BFG plant site of ground water using air stripping and.
biological treatment or activated carbon adsorption, and discharge to the local river;
possible treatment of ground water with an oil/water separator if ground water contains
significant oil, and temporary onsite storage of oil with transport off site to an oil
recycling facility; access restrictions; and institutional controls to prevent
residential development. The estimated capital cost for this remedial action (including
all costs related to the Airco site) is $6,090,000 with present worth O&M estimated to
be $3,130,000. .
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RECORD OF DECISION
Remedial Alternative Selection
SITE NAME AND LOCATION
B.F. Goodrich
Calvert City, Marshall County, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the B.F. Goodrich Site, in Calvert City, Kentucky, developed in
accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Contingency Plan. The following
documents form the basis for slection of the remedial action:
Remedial Investigation Report, B.F. Goodrich Site
Endangerment Assessment Report, B.F. Goodrich Site
Feasibility Study Report, B.F. Goodrich Site
Summary of Remedial Alternative Selection
Responsiveness Summary.
Staff Recommendations and Reviews
DESCRIPTION OF THE REMEDY
This remedy is the first and final remedial action
The function of this remedy is to reduce the risks
exposure to contaminated on-site soils, sediments,
water.
for the site.
associated with
and ground
The major component's of, the selected remedy incluge:
Ground Water
Extraction of contaminated ground water
Treatment of extracted ground water.
Discharge of treated ground water through a currently
permitted KPDES outfall to the Tennessee River
Imposition of deed restrictions to prevent residential
development on the B.F. Goodrich-owned property
Soil
Excavation of contaminated surface soils around portions
of the landfill
Placement of contaminated soils in the former burn pit
area
Construction of an organic vapor recovery system and RCRA
cap over the burn pit.
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-2-
Landfill
Construction of a flood protection dike around
and north side of the landfill
Installation of a leachate extraction system
Upgrading of/the existing landfill clay cap
the west
DECLARA T ION
The selected remedy is protective of human health and the
environment, attains requirements that are applicable or relevant
and appropriate, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. However, because
treatment of the landfill was not found to be practicable, this
remedy does not satisfy the statutory preference for treatment as a
principal element of the remedy. Waste volume and the lack of
reliable technologies for site-specific contaminants preclude a
remedy in which potential landfill contaminants could effectively
be excavated and treated.
Because this remedy will 'resul t in hazardous substances remaining
on-site abovehealth~based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of.hum~n
health. and the environment.
JUN 2 4 1988
//;; it// t!';;J;"y/1
// ' f
iGree~'C. ~idwell
Regional Administrator
Date
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
B.F. GOODRICH SITE
CALVERT CITY, KENTUCKY
. PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION
REGION IV
ATLANTA, GEORGIA
AGENCY.
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
. U.S.
B.F. GOODRICH SITE
MARSHALL COUNTY, KENTUCKY
. PREPARED BY:
ENVIRONMENTAL PROTECTION
REGION IV .
ATLANTA, GEORGIA
AGENCY
-------
Section
TABLE OF CONTENTS
1.0
..............
2.0
3.0
4.0
5.0
'6.0
7.0
INTRODUCTION
. . . .
1.1 Site Location and Description. . . . . . .
1.2 Site History. . . . . . ~ . . . . . . . . .
ENFORCEMENT ANALYSIS. .
. . . . .
. . . .
. . .
CURRENT SITE STATUS
. . . . . .
. . .
. . . . .
3.1 Hydrogeologic Setting. . . . . . . . . . .
3.2 Ground Water Contamination. . . . . . . . .
3.3 Surface Water and Sediment Contamination. .
3.4 Soil Contamination. . . . . . . . . . . . .
3.5 Receptors. . . . . . . . . . . . . . . . .
CLEANUP CRITERIA.
. . .
. . . . .
.......
4.1 Ground Water Cleanup Criteria. . . . . . .
4.2 Surface Soil/Sediment Cleanup Criteria. . .
4.,3 Subsurface Soil Cleanup Criteria. . . . . .
ALTERNATIVES EVALUATION
. . . .
. . . . .
. . .
RECOMMENDED ALTERNATIVE
. . .
. . . . .
. . . .
6.1 Description of Recommended Alternative. . .
6.2 Operation and Maintenance. . . . . . . . .
6.3 Cost of Recommended Alternative. . . . . .
6.4 Schedule. . . . . ... . . . . . . . . . . .
6.5 Future Actions. . . . . . . . . . . . . . .
6.6 Consistency With Other Environment Laws,. .
COMMUNITY RELATIONS
. . .
. . . . . .
. . .
Page
1
1
4
5
6
6
9
11
12
14
16
16
21
21
23
37
37
45
46
46
46
46
48
-------
I~
Figure
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Table
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
LIST OF FIGURES
Site Vicinity. . . . . . . . . . . . .
Land Use Map. . . . . . . . . . . . .
Site Plan With Sampling Locations. . .
Site Alternative 3 .... . . . . . .
Ground Water Capture Zone. . . . . . .
Soil Remediation Areas. . . . . . . .
LIST OF TABLES
Page
.2
3
8
38
41
43
Page
Ground Water Organics Statistics. . . . 10
Surface Soil Organics. . . . . . . . . . 13
Indicator Chemicals. . . . . . . . . . . 15
Endangerment Assessment Summary. . . . . 17
MCLs and AWQC for Indicator Chemcia1s . . 19
Ground Water Cleanup Goals. . . . . . . 22
Technology Screening Summary. . . . . . 24
KPDES Standards for Indicator Chemicals. 40
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j-
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
B.F. GOODRICH SITE
MARSHALL COUNTY, KENTUCKY
1.0
INTRODUCTION
The B.F. Goo~rich site was included on the National Priorities List
(NPL) in September 1983, and has been the subject of a Remedial
Investigation (RI) and Feasibility Study (FS) performed by the B.F.
Goodrich Company and The BOC Group, Inc. (formerly Airco). The
B.F. Goodrich site and the Airco NPL site were merged and studied
as one for the RI/FS since they are located adjacent to each other
and share a somewhat common history of use. Regulatory direction
has been provided by Region IV throughout the RI/FS. The RI
Report, which examines air, sediment, soil, surface water, and
ground water contamination at the site, was issued March 15, 1988.
The FS, which develops and examines alternatives for remediation of
the site, was issued in draft. form to the public on March 15, 1988.
This Record of Decision has been prepared to summarize the remedial
alternative selection process and to present the recommended
remedial alternative.
1.1
Site Location and Description
The B.F. Goodrich site is located in Marshall County, Kentucky,
approximately two miles northeast of Calvert City, Kentucky near
the so~thern bank of the Tennessee River, 18 river miles upstream
of its confluence with th~ Ohio River (Figure 1) '. ,The. site is'
situated on the e~stern edge of a heavily industrialized area,
including seven major industrial plants, in north Calvert City that
was developed in the early 1950s. The site is bordered on the east
by the Airco NPL site; on the west by the B.F. Goodrich Company; on
the north by the Tennessee River; and on the south by State Route
1523. Calvert City, Kentucky is the only municipality within the
area that has a zoning ordinance. The B.F. Goodrich site is
located outside the zoned area of Calvert City. Figure 2 depicts
land use patterns in the vicinity of the B.F. Good~ich site.
The B.F. Goodrich landfill occupies approximately one acre directly
west of the Airco landfill. It is located in a former creek
channel made suitable 'for landfilling by the construction of dikes
on the north and west sides. An area south of the B.F. Goodrich
landfill was used to burn chlorinated hydrocarbons in pits.
Approximately 2.6 million gallons of liquid organics were burned
during the years 1965 tQ 1968. Another area adjacent to the burn
pit area was used to bury approximately 370 cubic yards of
salt-brine sludge during a one-time disposal event in 1972. A
'portion of the land beneath the B.F. Goodrich site was conveyed to
B.F. Goodrich by Airco in 1'964. B.F. Goodrich began using the
-------
~
BFGOODRICH/AIRCO SITE
CALVERT CITY, KENTUCKY
'?,....
FIGURE 1
SITE VICINITY
DAMES & MOORE
MARCH 1988
-------
~~~T~~ .~;~~~>:~~
,~~~,~'r;ll~?~>1~~ij~:: :::w
oJ, rfi' \ .. ~ -, ~ ~ - ~r 'b A. ~ C. Services
~~ ~ \ "~~J ~ Mrc~~.JLJ'w;lIftLA."IDi",","~~~, 13 Industrial
~Yf ~ " I .~ ~~~@&J ~ T.,,' ;;f '): ..p/~ ,14 Transportation,
: U) ~ i" .. ~ G V A J ~£l-!~i('~'II:'1 ~fr',=-, ~:t Communications,
~ '1 . ~~ ~ I;:, 1/~'v-5-~~., and Utilities
,J ~ ~ ~t' Co-'1 . /- ~
.. Hlm.1l1l".. fJil!'~ ~ ~~, - 0 } I' . ~~' ;: " 1 6 MIXed Urban or
~r ~ ,b5/~,' ai ~ .~~ :~LJ)). ~ (.. I. .;' !/J"r&'~\I;;t B~ilt-UP Land
., ... ) -J I~ ~.' \ ~ ~: i. \..
1 7 Other Urban or
Built-up Land
, ~ t:::\ 1/' "~ ..
-;.t:, , ~. ~ -<0:;1-"" ~ ~ £:7". '(9 "C'~~~ .-'~'. , I ~~CUL1URAl
-0;' '~ ~~e.,u ,l~ 21
~'~~..~s~~fi.~;:;
l"TE. AI"~~, - 'A~<:>; '.to ~ '~I" ~ n \ IJ'.~ ftP:.;
~ ...ICy " LVE'-.!... "-"'L-,."'I u_~ -~' 41
.. "'-? ~ '"'I'f"'~l ~. -~-, ..'
.iN '-7,r;.-<,,~:~ "'~\ i~ C!IY'L~, ~ a:: "yo.,},o" ~ - ,,~ ~:n'.,).' .~ ..-- -
..... -.. -.- ~rs~~.~ ~-\.,t, ;(,~ ~.EN1'~' \~~LAKI:; I'A
~~ :~";' ~ 0; y.-i'~ ~ ~~ o~(.~\''; 4...!..~ N."
~ -""'-r Y ,,'... ..... '~I . .' TE, '., ~ - .
).... - ~ ".K:1~"": -~ n., \
L1-.:::~!~~.D:' 6'~ "'. ~~U, ~ . CP.J) : -
~\~: ~ . fr-J.'~ \-J h~~1;,l&~i ~~ ~
~iE ~ . <~~,..~ . 211.:: ~ ~ ,- ...'" ~~.~\ r "':;., ~
::;: r: - ~.Jw :rc;,.. ~-' .',~L', . \~~~n -:; ~
~~~~~,. -! ~~_J !J{~~ ~r;---::" )~,,~;, '
LJ 'If '~J' -c:; ~I . ~ 1). A . ,
~~ ~ '. " ~'..t. J!' .~) (ot-! -~,.. ~ 76
~ " ~ ~j~~ "" L.W ,:-;J.~~ 1i I' ~. @ BFGOODRICH/AIRCO
~~el'.'~~~<~~~~~ SITE
--L-.o1'"J ~.. ~ ..{'i'~~.~ ~
SCALE: 1"= 4 MilES BFGOODRICH/AIRCO SITE
CALVERT CITY KENTUCKY
BASE MAP SOURCE:
USGS Lind Us. Ind Lind Cover,
Paducah, Kentucky; IIlInol8;
MIssouri; Indlanl, 1973 and
USGS Lind Us. and Lind Cov.r,
Dy.rsburg,T.nnlSs88; IIIlnol8;
Kentucky; Missouri, 1973.
LEGEN'C; ~--------:-, ;:,'/'->f'- -",~'r="7" ;"
r ~~gR BUlL T- ,
Cropland and
Pasture
I FOREST LAND
Deciduous
Forest Land
I WATER,
Lakes
I
I
I WE1tAND
Forrested Wetland
Nonforrested
Wetland
I BARREN
LAND
I
Transitional Areas
FIGURE 2
LAND USE MAP
DA'1ES & MOORE
MARCH 1988
-------
-4-
landfill in 1965. An approximate total of 54,000 tons of
construction-type waste and plant trash was reportedly disposed of
until 1973. The landfill was closed in 1980 with a clay cap and
vegetative cover in accordance with a State-approved closure plan.
1.2
Site History
From its start-up in 1965 until 1968, before Kentucky instituted a
solid waste management program, the B.F. Goodrich disposal area was
an unregulated industrial waste landfill. In August 1968, B.F.
Goodrich submitted an application to the Kentucky Department for
Natural Resources and Environmental Protection (KDNREP) for a Solid
Waste Disposal Permit. The application identified the types of
wastes that were to be disposed of in the landfill, and also
described the construction of a compacted fill dike between the
disposal area and the Tennessee River to prevent the flow of
leachate and erosion of the fill cover.
On April 15, 1969, KDNREP approved the B.F. Goodrich permit
application under the following conditions:
A drainage ditch was to be constructed on the south side
of the disposal area to divert rainfall runoff around the
site;
Disposal of refuse in the Tennessee River floodplain was
to cease; and
putrescible wastes were no longer to be disposed of at the
site.
Operation of the B.F. Goodrich landfill continued under the permit,
as qualified, until 1973 when industrial waste disposal at the site
was curtailed. From 1973 to 1980, the B.F. Goodrich site was used
solely for the dumping of excavation dirt.
In 1978, the B.F.. Goodrich site was included on the Eckhardt List
of potential hazardous waste sites in the United States. KDNREP
and Region IV EPA personnel inspected the site several times in
1980. In a May 30, 1980 inspection, state personnel noted an
apparent "leaching problem" along the north (river) side of the
landflll, and instructed B.F. Goodrich personnel to correct the
problem. In June 1980, B.F. Goodrich used clay to seal the north
face and to cap the disposal area, and graded the site to promote
rainfall runoff drainage to the west and away from the Airco
property. In September 1980, the site was revegetated to control
erosion.
An area south of the B.F. Goodrich landfill (Figure 1) was used for
-------
-5-
the burning and burial of wastes. Approximately 2.6 million
gallons of liquid chlorinated organics were burned in pits between
1965 and 1968. Another area adjacent to the burn pit area was used
c to bury approximately 370 cubic yards of salt-brine sludge during a
one time disposal event in 1972. From 1970 to 1983, scrap lumber
and fuel oil were burned in this area two to three times per year
for fire-training. -
In 1984, the EPA's nationwide program to rank abandoned or
uncontrolled hazardous waste sites under mandate of CERCLA
initially ranked the site. As a result of that ranking, a RI/FS
was initiated to ascertain the potential threat to human health and
the environment posed by the B.F. Goodrich site. -
In June 1986, B.F. Goodrich and The BOC Group, Inc. initiated RI
field activities. Additional field work, as part of Phase lIb of
theRI, commenced in July 1987; completion of this phase coincided
with submittal of the draft RI report in January 1988. The draft
FS, final RI, and Endangerment Assessment reports were submitted in
March 1988. EPA, with the assistance of the Field Investigation
Team (FIT), the NUS Corporation, provided oversight for all RI/FS
tasks. .
2.0
Enforcement -Analysis
The B.F. Goodrich and Airco sites were included on the National
Priorities List (NPL) in September 1983 and September 1984,
respectively. EPA assumed lead responsibility for the sites at
those times. ..
EPA has determined that three potentially responsible parties used
the B~F. Goodrich/Airco site areas for waste disposal: the B.F.
Goodrich Company (B.F. Goodrich), Air Products and Chemicals, Inc.
(Air Products), and Airco Chemicals and Plastics Division (Airco).
Airco (now known as The BOC Group, Inc. [BOC]) and B.F. Goodrich -
elected to conduct ~nd finance the RI/FS, but Air Products declined
to participate. An Administrative Order on Consent was entered
into between B.F. Goodrich and BOC and EPA on November 27, 1985 to
conduct the RI/FS. The B.F. Goodrich and Airco sites were merged
and studied as one site for the RI/FS since they are located
adjacent to each other and share a somewhat common history of use.
Further, EPA has determined that a single RI/FS would be more.
technically and scientifically sound as well as cost-efficient.
Currently, EPA and BOC and B.F. Goodrich are in the final stage of
settlement negotiations on a Consent Decree for a Remedial
Design/Remedial Action (RD/RA) at the site. If agreement can be
reached, the Consent Decree will be signed by the parties shortly
after approval of this Record of Decision and wi.!l be submitted to
the appropriate federal district court for entry. Air Products has
declined to participate in the RD/RA.
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-6-
From 1971 to 1980, Air Products used the landfill to dispose of
approximately 14,000 tons (dry basis) of ashes from coal operated
boilers, off-grade or non-processible polyvinyl chloride solids,
ferric hydroxide sludges from a wastewater treatment plant, and a
small amount of non-combustible construction wastes. Air Product's
waste conta(ned low levels of arsenic, lead, zinc, silver, nickel,
copper, chromium, and cadmium which are hazardous substances under
CERCLA. Thus far, Air Products contends that the low levels of
inorganic compounds in the waste they disposed of do not constitute
CERCLA hazardous substances; for this reason, Air Products
contends, they should not be considered a potentially responsible
party. The RI detected inorganic compounds in ground water
downgradient of the B.F. Goodrich/Airco landfills that were
identical to those reported in Air Products' waste streams. Two
compounds exceeded the primary drinking water standards.
EPA has concluded that Air Products' waste contained CERCLA
hazardous substances.' EPA may issue an Administrative Order to Air
Products under Section 106 of CERCLA.
3.0
Current Site Status
3.1
Hydrogeologic Setting
The site is within the Jackson Purchase area of Kentucky, as
defined by the boundaries of the Ohio, Tennessee, and Mississippi
Rivers. ~he Purchase a~ea forms a distinct physiographic provirice
characterized by gently rolling uplands and wide shallow valleys of
low relief. '
The B.F. Goodrich/Airco site is located near the northern edge of
the Mississippi Embayment, a southerly trending syncline filled
with Cretaceous to Holocene-aged unconsolidated to partially
consolidated ~ediments. These sediments are underlain
unconformably by Paleozoic limestones, dolomites, cherts, 'and
shales which dip gen~ly northeastward, towards the Illinois Basin.
In the site vicinity, Cretaceous through Tertiary-aged sediments
have been partially or totally removed from the underlying Palezoic
rocks due, in part, to erosion by the Tennessee River. Previous
tectonic uplifting of the area has also allowed partial removal of
these sediments by continental-type erosion. - These combined
erosive forces have produced a bedrock surface which can be
characterized as very irregular on a local scale.
The area has a history of seismic activity. The New Madrid
earthquake of 1811-1812 was centered 80 miles southwest of Calvert
City. Since 1812, many minor earthquakes have been felt in this
region. These minor earthquakes are caused by movement associated
with faults in the bedrock, which are common in this region.
However, the New Madrid earthquake bas not beeri related to faulting
in the Calvert City area.
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-7-
Vertical and horizontal cavities within the upper zones of the
. bedrock (Warsaw Formation) have been noted to occur in the
Tennessee River valley region. A possible cavity was encountered
northeast of the B.F. Goodrich/Airco landfill on the floodplain.
This cavity, should it exist, is not in the path of contaminant
plume migration.and, therefore, should not serve as a conduit for
contaminant migration. The majority of bedrock, however, found at
the site is massive and unfractured.
The unconsolidated sediments found at the B.F. Goodrich/Airco site
consist of layers of sand, silt, clay, and gravel deposited by the
Tennessee River as it meandered over its floodplain. In
particular, the site rests upon a massive sequence of point bar
deposits, commonly found on the inside bank of meandering river
systems. The layers are laterally discontinuous across most of the
site except in the southern and northern-most areas. At the site,
these deposits are characterized in general as (from uppermost to
lowermost): Unit 1 - sandy and silty clays (ranging from 5-20 feet
thick); Unit 2 - interbedded clays, silts, and sand (averaging 15
feet thick); Unit 3 - silty sand and fine sand (averaging 40 feet
thick); Unit 4 - sand and gravel (averaging 35 feet thick); and
Unit 5 - a sandy or gravelly clay (averaging 10 feet thick)
immediately overlying the bedrock.
The uppermost bedrock units beneath the site are the Warsaw
Formation and the Fort Payne Formation, both Mississippian-age
limestones~ Numerous northeast-southwest trending normal faults
are noted to cross-cut these units in the region, although the
Warsaw and Fort Payne Formations appear to be structurally
undisturbed beneath the site.
The middle sand and basal sand and gravel units comprise the
uppermost aquifer at the site. In the terrace area, the aquifer
thickness ranges from approximately 80 feet near well GA-6 (Figure
3) to approximately 50 feet beneath the landfills. On the
floodplain, the.aquifer thickness decreases due to the absence of
the upper sand unit and an increase in bedrock surface elevation.
The upper sandy clay and interbedded sand, silt, and clay units
confine the groundwater, creating slightly artesian conditions in
most parts of the aquifer.
Estimates of hydraulic conductivity were made. from data. generated
during slug tests conducted in select wells. Based on the tests
that were conducted at the site, the mean horizon3al hydraulic
conductivity of the alluvial aquifer is 1.5 x 10- em/sec. The
primary direction of groundwater flow within B.F. Goodrich/Airco
property is north towards the Tennessee River. During flood stage
conditions, the aquifer beneath the site is recharged by the river
through bank storage. .
-------
-- -.~ ~~ ~/;,r;;<.::'-_""\. /
-:_-:.._--:.~.> \ ~ -- <~\~ '-- - '-. - -" -. - - -- - - /,,1'-
L~~~':~A~(L) ~~;:~fc:"~<:.~
. !(('<~12~ LMW'20~, i'rIGA.2.-GA'''-:'~;2'
~~/St:5~)i! _..~3A./ ,GA."
- - ~ 18 MW.23 GA-31 GA-~ - GA-18
'''; GA.34"e - -
'r::JZA'33". 'J'O~ 8 .0....4 .
t- J .I a1'1-.' . . G"'.3
. :BFGOOORICHJ.... 7
.G.A.36 2/ LAHDFIL1.R': "'" .
-~ ., , v'.:' "''''''''''''' .
II "~_GA.35 """ 2: -, . GA'18
r ",-- ""''''... I . r
11'- .~GA-12 ~CO -"" 'GA;17
I 11: 1 , \ ' ~ lANDFILL ") 1 0
BURN PIT AREA ,~' ,h3 GA"',4' "..,. ~ /,~
(APPROXIMATE) 7 ." :12-. GA-9 " GA-14 .:".:.~. ~2~ H ~
/ GA'1..Q:!::::'11'," GA 13 "'''''-. 1 . 1 ...."';;>..=-
,;' . '" - eo. ,.1 .... ~l...........~
, Ii 10 I GA'37..JZ", .... 2""""~ ~ ~
\ I Ii". : I ..... ~"- '-""::---'"
- ,': 8 GA-7~' 0"'38 "'''- -..;::-.. ....
00' -" .' .' - 9, "''', ..~~ '--..
SLUDGE /', :GA-~ -. . " ''''~':\.
BURIAL AREA ' -, '-4 7,' - '.... ',,::::..
(APPROXIMATE) I ..' '---' . ~ '" ---".. '::::
" I' . '"
~. -.... // 5 . '.....
~ "
I ,'/
0- ,.- ,',' 3 4
/ "'...... // /L
J9 '-.../, ~
~ . II
'", ~, " / 1.
'~, ,
',', ,
-~- , 1/-
-'~",' '/'
-'~" "
'~, , . LMW.21 "
'''''':..'... . /, "/-
',', : I . k"
-'--"""" " / /
""';:---.:::.:::.:::::-;~~~- // , '
--' \ ,/ /
, ~\~ - -~-
-------
-9-
An abundant source of ground water for municipal and industrial
purposes is available from the sand and gravel alluvial aquifer in
the Tennessee River valley. Reported yields for large-diameter
wells are 500 gallons per minute (gpm) and 2~0 gpm for
small-diameter wells. Ground water quality in the aquifer is
generally hard (121-180 mg/L carbonate) with high concentrations of
iron (as much as 36.0 mg/L).
The alluvial aquifer of the general area is recharged by flow from
adjacent aquifers in the highlands and infiltration and provides
water for municipal, industrial, and commercial uses in the
upgradient Calvert City area.
3.2
Ground Water Contamination
Numerous monitor well clusters were installed at the site to sample
ground water in the shallow and deep zones of the alluvial aquifer
and to define the vertical extent of the contaminant plume (Figure
3) .
Ground water monitoring wells were sampled on four different
occasions at the site during two different river stage conditions -
low stage and high stage. These sampling events revealed the
presence of contaminants in both the shallow and deep zones of the
aquifer. . ..
Samples from the upgradient wells at the site and. the Calvert City.
wells were not found to be contaminated during any sampling.
Approximately two - thirds of the downgradient wells indicate
contamination by. total VOCs ranging from 0.0012 mg/L to 4,017 mg/Li
semi-volatile compounds ranging from 0.002 mg/L to 7.8 mg/L; and
low levels of inorganics. The types of contaminants detected in
the ground water include aliphatic compounds (alkanes and alkenes),
aromatics, and PAHs. The detected compounds are generally similar
in all affected wells, although the concentrations vary
considerably. Table 1 summarizes those organic compounds detected
in the ground water along with minimum, maximum, and mean.
concentrations. Of the aliphatics, 1,2-Dichloroethane (EDC) is the
most commonly detected constituent and present at the highest
concentrations. Of the PAHs, naphthalene is the most commonly
detected constituent and present at the highest concentrations.
Of the inorganics detected in downgradient wells, two compounds,
cadmium and selefiium, exceeded the primary drinking water standard
of 1~ mg/L with concentrations of 11 ug/L and 14 mg/L respectively.
In order to relate the nature of contaminants to potential source
areas at the site, a review of background information regarding
historical waste practices was conducted in light of the findings
of the RI. This review indicated that approximately 124,000 lbs.
of EDC are present at the site.
-------
'I7IBLE 1
B.F. a:x:xJRIaw.m:o SITE
~ \oU\TER OlG.NICS STATISTICS
li!an /'Bx im.Jn Minirrun
tbrCer of Con::a'1tration Con:entratioo CorJ:entration
Otganic Carp:>ur1J D:!tections (~IL) (~IL) (~IL)
1, 2~ichloroethane (EIX:) 23 313,551 3,633,333 ID
1, l~ichlorc:ethane 23 15,356 U3, 003 ID
Q1lorofocn 16 U,224 133,003 ID
1; 1, 2-Trichlorc:ethane , 13 7,953 55,333 ID
Benzere 21 6,695 47,000 ID
Q1loroCenzene 23 3,752 34,303 ID
Vinyl chloride 15 2,765 33,033 ID
trans-1, 2~ichlorc:ethe.1o:: 17 2,548 23, 033 ID
CaI::bon tetrachloride 6 1,669 16,033 ID
Q1lorc:ethane 14 1,3134 15,033 ID
~ene 14 866 4,133 ID
Tr lchlorc:etl;ene 14 536 -- 4,633 ID
Tetrachloroethane 9 495 3,733 ID
1il,2,2-Tetrachlorc:ethane 4 337 5,233 ID
1, 2~ichloroebenz.en! U 284 1,933 ID
1, l~ichlorc:ethylene 1.3 242 3,330 ID
'Ibl \.II!n! 14 144 1,733 ID
bis(2~orc:ethyl) ether 13 142 943 ID
2..."2t.~1..na;i1thalene 11 85 713 ID
~t.~lene 7 55 543 ID
ihenant."1rene 5 41 380 I'D
Floorene 8 43 283 ID
1,4-i>ichlorobenza1e 13 20 71 ID
~t.'1ene 6 19 180 ID
1, 3~ichlorobenza1e 13 16 53 ID
2~orona;:nthalene 6 13 83 ID
Styrene 4 13 173 ID
Arit."1racene 4 12 153 ID
bis (2~thylhexyl) t:hthalate 2 11 153 ID
Pyrene 4 11 U0 tD
Ethyl benzene 8 10 77 ID
Flooranrhene 4 7 -80 ID
'Ibtal xylenes 2 5 97 ID
Carbon disulfide 1 3 73 ~
Benzo (a) anthracene 4 2 33 ID
C1rysene 3 2 27 ID
Benzo (1<) flooranthene 2 1 16 ID
Benzo (b) flooranthene 2 1 16 ID
cis-l,3-Vichloropropene 1 1 30 ID
Benzo (a) pyrene 2 1 . 14 ID
IsoP'x>rone 1 0.65 11 ID
1,2,4-1'richlorobenzene 2 3.53 i ID
Benzoic acid 1 3.25 4.2 ID
Ni trc.benzere 1 0.21 3.6 ID
"1, 1, I-Trichloroethane 1 0.21 5 ID
Pentac:hlorot:henol 1 0.23 3.4 ID
Di~lt:hthalat:e 1 0.18 3 ID
InJeno (1,2, J-aj) pyrene 1 0.12 2 ID
tD - BelChl stan::iard lnStrUTEnt deteC'tlon lJJ!llts
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-11-
Isoconcentration maps of the organics found in ground water samples
at the site all show the highest concentrations in shallow wells
north and northwest of the burn pit.
There are two plausible scenarios for the source of contamination.
The source could theoretically be the landfills, with the
contaminants (which have a density greater than water) sinking
downward and spreading out radially. The separation of the deeper
plume around a bedrock high supports this scenario, as does the
radially symmetric shape of the shallow plume.
Alternatively, and more likely in light of the waste disposal
history, the burn pit could have been the source of contaminants.
The "slug" of contaminants thus introduced into the ground water
would be moving toward the river with the natural ground water
flow. The radial appearance of the plume could be due to the
effects of mechanical -dispersion, geologic heterogeneities, and
bank storage from t~e river during high water conditions.
The phenomenon of bank storage was studied with several years of
available ground water level data, and it was determined that-the
cont~minant plume movement is not affected except on a very
localized level; therefore, on-site contaminants should not create
a threat to the Calvert City wellfield.
- -
It is considered unlikely that migration of
river is occurring because the river seryes
which is fed by groundwater flowing towards
and south. -
the plu~e across the
as an hydraulic "sink"
it- from both the north
3.3.
Surface ~ater and Sediment Contamination
Three surface water features were investigated for releases related
to the site: the slough east of the Airco landfill, the drainage
ditch on B.F. Goodrich property, and a portion of the Tennessee
River adjacent to the site (Figure 3).
No organic contamination was found in any of the slough water or
sediment samples. A few inorganics were detected in the slough at
concentrations above background, but do not appear to be associated
with the site.
Drainage ditch water and sediments reflect some organic and
inorganic contamination. VOCs were detected in ditch sediment
samples at levels up to 28 mg/kg. A PAH compound was detected in
one ditch sediment sample at 0.682 mg/kg. The sample location is
far enough away from the site that it is unlikely that the PAH
presence is related to the landfills or former burning area. Ditch
-------
-12-
sediment samples contained PCB compounds at estimated
. concentrations of 4.520 and 0.186 mg/kg. The source of the PCB
compound is unknown. Elevated levels of metals (arsenic, chromium,
iron, mercury, and vanadium) were detected in one ditch sediment
sample. Cyanide was detected in low levels in all ditch sediment
samples. The p~esence of contaminants is most likely related to
the permitted storm water discharged from the B.F. Goodrich plant.
Traces of a few organic compounds were detected in the Tennessee
River sediment samples (Figure 3). Low levels of VOCs were.
detected in an upriver location and therefore do not appear to be
associated with releases from the site. Semi-volatiles were
detected in the sample where the ditch enters the river but were
not detected in any of the ditch samples. Therefore, organic
contaminants found in the river sediment samples do not appear to
be associated with the site.
Inorganics detected in the river samples are comparable to
background or reflect the influence of discharges from the drainage
ditch.
3.4
Soil Contamination
Airco landfill cap samples were described as orange-brown silty
claY_eo sandy silt. An average coefficient of permeability of 4.4
x 10 em/see was reported for the cap samples.
B.F. Goodrich landfill cap samples were de~cribed as brown clayey
to_~ilty sand. An average coefficient. of permeability of 8.6 x
10 em/see was reported. .
Contamination of the surface soil around the landfills was found at
the w~stern and northern boundaries of the B.F. Goodrich landfills,
and the northwestern edge and southeastern corner of the Airco
landfill (Figure 3). Table 2 summarizes statistics on the surface
soil contaminants. .
All of the detected VOCs are alkanes and alkenes except for toluene
and chlorobenzene, which are ~romatic hydrocarbons. All of the
semi-volatiles are aromatic or poly-aromatic hydrocarbons (PAHs).
EDC was the most prevalent organic compound and was also detected
at the highest concentration. Its presence c~n be associated with
the burn pit wastes. It is possible that some of the soils
surrounding the landfills became contaminated during the closure
activities in the early 1980s. Based on knowledge of the waste
types handled at the site and the types of contaminants found in
site media, the presence of a PCB compound in a single sample does
not appear to be associated with site activities. The source of
the PCB is unknown. .
-------
TABLE 2
B.F. G:x)[)RIQVAIRX) SITE
SURFACE SOIL ORG\NIC STATISTICS
Organic Catp:>urrl
N.Jrber of.
r:Etecticns
M3.xim.In
Corx:a1tration
(uy'kg)
1,2-Did1loroethane (m:)
h:enap,thene
Nap,thalene
1,1,2-Trid1loroethane
Fhenanthrene
2~thylnap,thalene
Fluorene
1, 1, 2, 2-Tetrachloroethane
Q1lorobenzene
Pjrene
Fluoranthene
Tetrachloroethene
Q1lorofoIIn .
2-a1loronap,thalene
Benzoic acid
1,2-Did1lorobenza1e
Acenap,thylene
Haxachlorobenza1e
Carbon tetrachloride
Toluene .
1,4-Dichlorobenzene
1, 3-Did1lorobenza1e
Anthracene
bis (2~thylhexyl) p,thalate
Benzo (a) anthracene
01rysa1e
Di-n-butylp,thalate
BJtyl benzyl p,thalate
5
2
1
1
4
2
2
1
1
4
3
1
1
1.
1
1
1
1
1
1
1
1
3
1
2
2
3
2.
360,000
329,000
262,000
250,000
159,000
121,000
65,800
57,000
54,000
28,800
23,800
23,000
22,000
18,500
16,800
16,000
12, 500
10,130
9,800
7,000
3,770
3,280
2,220
1,220
1,120
1,022
256
160
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""
-14-
The presence of elevated zinc concentrations in surface soil
samples north of the Airco landfill may be related to the operation
of the landfill. Zinc does not appear to be a problem in other
site media.
The following four areas were investigated for shallow subsurface
soil contamination:
Salt-brine sludge burial area
Liquid organics burn pit area
Area north of the B.F. Goodrich landfill
Area north of the Airco landfill
No evidence of the salt-brine sludge disposal area was found.
Mercury concentrations were comparable to background levels for the
area. .
Evidence of the liquid chlorinated organics that were burned in
pits, the oily sludge disposal, and the fuel oil used for
fire-training activities, was found in numerous samples. The
heaviest contamination was encountered in the burn pit area
borings.
The organics that were detected were very similar to those detected
in one of the surface soil samples: alkenes were found in higher
concentrations relative to the aromatics and PAHs.
~ perched water table in the vicinity of well GA 9/19 (Figure 3),
at approximate depths of l2.to 29 feet below the ground surface,
appears to be where most of the contamination is concentrated.
3.5
Receptors
Exposure pathways for potential receptors were evaluated" for two
land use scenarios - current use and future use.
Because the landfills are closed and most of the site is fenced,
access by the public is unlikely. However, unauthorized access is
possible, and therefore, potentially complete exposure pathways
under the current use scenario were defined as dermal and
incidental ingestion by exposures to the surface soils and
sediments at the site. Although also unlikely, a potential future
use scenario for the site was defined as possible residential
development in the area south of the landfills.
The Remedial Investigation identified 119 chemicals at the site.
Due to the large number of chemicals, indicator chemicals, those
that pose the greatest potential risk, were selected. Selection of
indicator chemicals was based on measured concentrations, toxicity,
mobility, and persistence. Table 3 presents the indicator
chemicals selected for the site.
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TABLE 3
B.F. GOODRICH! AIRCO SITE
INDICATOR CHEMICALS
l,2-Dichloroethane (EDe)
Carbon tetrachloride
Chloroform
l,l,2-Trichloroethane
Benzene
Polynuclear aromatic hydrocarbons
Tetrachloroethene
l,l,2,2-Tetrachloroethane
Trichloroethene
Chlorobenzene
l,l-Dichloroethane
bis(2-chloroethyl) ether
polychlorinated biphenyls (PCBs)
(PARS)
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-16-
Potential human health risks associated with current exposure by
ingestion of surface soil and ditch sedimeni conta~~nants at the
site are outside the target risk range (10- to 10 ) in
absence of remediation. The wor~3 case current-use scenario total
risk is estimated to be 2.3 x 10 . The primary contributors to
the worst case' risk are PAHs. The incidence of exposure to
contaminated surface soil and ditch sediments would increase if the
Airco-owned property immediately south of the Airco landfill were
used for residential development.
Although unlikely in light of Kentucky statutes that preclude
residential land use on floodplains, it was assumed that
residential development of a 40-acre area of Airco - owned property
$outh of the landfills could potentially occur. In this scenario,
exposure would be from domestic use of ground water for drinking,
bathing, and cooking should private ground water wells be installed
on the Airco - owned property. Potential human health risks
associated with futur~ exposure to ground water by ingestion at the
site are outside the target risk range.
The only private domestic wells in the area are lik~ly to predate
the present municipal supply system and are likely no longer in
use. . However, if any'of the wells are still in use, they are
located upgradient or lateral to the B.F. Goodrich/Airco site.
There are no known permi tted users of ground water for commerci.al
food preparation or agricultural irrigation in the immediate area.
Table 4 sum~arizes the findings and conclusions of the Endangerment
Assessment, providing total carcinoginic risk and the hazard index
forvari6us site media under the worst and most probable case.
4.0
CLEANUP CRITERIA
The extent of contamination was defined in Section 3.0, CURRENT
SITE STATUS. This section examines the relevance and
appropriateness of water quality criteria under the circumstances
of potential release of contaminants at this site. Based upon
criteria found to be relevant and appropriate, the minimum goals of
remedial action at this site have been developed. .
4.1
Ground Water Cleanup Criteria
Section l2l(d) of the Superfund Amendments and Reauthorization Act
of 1986 (SARA) requires that the selected remedial action establish
a level or standard of control which complies with all "applicable
or relevant and appropriate requirements" (ARARs).
At the B.F. Goodrich/Airco site, ground water discharges into the
Tennessee River and therefore beyond the boundaries of the site.
Applicable statutory language concernlng clean-up standards under
-------
~
TABLE 4
~ ASSES~ StM1ARY
B.F. rst M::>st W:>rst
OJrrent Use: PrOOable Case Probable Case
Drairtage ditch- 2.4Wr-<'J7 2. 2'P..-05 3 (] . vi. t~i:1 taqet risk rar'Be;
surf~ \tater 00 action require:1
se:1 iIrent 2.00E-09 1. 80E-06 0 0 Within target risk ran;e;
00 action require:1;. ~er
rarediation of
fCB-contaninata:3 se::!iIrents
will be p:rfonn::rl
SloU;h- 0 0 0 0 N:> irrlicator chemicals
surface \tater detecta:3; no action
require:1
se:J irca'1t 0 0 0 0 N:> in:Uca tor chemicals
detecta:3; 00 action
require:1
Tennessee Ri ver- 0 0 0 0 N:> irrlicator chemicals
surfaCe \tater detecteD; no action
require:1
se:1 irca'1t 1. 06E438 6. 40E-06 0 0 Wi thin target risk ran;e;
no action require::1
SUr fcce soil 9.90E-07 2. 20E-03 5.50E-37 6. 30E-04 W:>rst case excee:Js target
target risk ran;e;
remediation required
SUbsurfcce soil 0 0 0 0 t-I:> hLl1\aI1 ~e to sub-
sur faceso ils .
Future Use:
Grourrl\.ater 0.8 1 3.2 5.8 Both cases excee:1
target risk r~e;
remediation require:1
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-I
-18-
CERCLA is found in Section 121 (d) (2) (B) (ii) of SARA. The point of
human exposure may not be assumed to be beyond the boundaries of
the site unless:
There are known and projected points of entry of
contaminated ground water into surface water;
There will be no measured or projected increase of
contaminants from the ground water in the surface water at
the point of entry, and;
There are institutional controls that preclude human
exposure to the ground water
Section 121 of SARA does not allow any increase in contaminants in
off-site surface water. Since clean-up goals must be based on some
finite number, the reduction calculation that reflects the large
dilution factor in the Tennessee River is based on two criteria.
These are the water and fish ingestion Ambient Water Quality
Criteria (AWQC) and Maximum Concentration Limits (MCLs).
Development of ground water cleanup criteria involves
identification of specific contaminants of concern. . Of the 110
chemicals detected on-site, the potential number of contaminants
for which specifIc cleanup levels are needed ranges from one to the
total number present, depending on factors such as contaminant
concentration, distribution, and allowable levels for various
receptor scenarios.. .
The approach utilized involves an evaluation of contaminant
concentrations relative to available health-based standards. MCLs
and Ambient Water Quality Criteria ~or indicator chemic.als are
presented in Table 5. ..
To relate health-based standards for contaminant concentrations to
potential receptors, a current-use scenario was employed. Under an
evaluation of the current-use scenario, there are no direct
receptors of ground water downgradient of the site. Rather, the
closest potential receptors are associated with surface water use
at a location where affected ground water discharges to the
Tennessee River.
To calculate probable Alternate Concentration Limits (ACLs) for the
various contaminants in the ground water system, a relatively
straightforward mass-balance approach was used. The analysis
involves an initial assumption that observed levels of contaminants
will remain constant as ground water flows from the source area to
a discharge zone at the Tennessee River. This assumption is
considered conservative, in that dispersion, dilution, retardation,
adsorption, or other physical/chemical processes are not taken into
consideration. Such processes would generally act to decrease
-------
'maLE 5
.,.",
B.F. GX)[)RIQVAIR:O SITE
M:I.s AID ~ FOR INDICATOR CHEMlCAraS
Va11.l:! of
Cri terion
Criterion or StarDard
C1emica1 or Starrlard (ng/L)
1,2-Dichloroethane (ED:) M:L 0.005
~ *
Carbon tetrachlor ide M:L 0.005
~ 0. 0004.2
O11orofor:m** M:L** 0.1
~ 0.00019
1,1,2-Trichloroethene M:L *
;:.w:J:. 0.0006
Benezene M:L 0.005
~ 0.00067
Fb1ynoc1ear araratic M:L *
hJOrcx:arbons (PAHs). ~ 0.000031 .
'etrachloroethene M:L *
;:.w:J:. 0.00088
1,1,2,2-Tetrachloroethane M:L *
~ 0.00017
Tr ichloroethene M:L 0.005
~ 0.0028
O11orobenZ81e M:L *
M:LG 0.060
1,1-Dichloroethane M:L *
AIC 0.0042
bis (2-Chloroethy1) ether M:L *
;:.w:J:. 0.00003
* N::>ne avallable
** 'Ibtal Trihalarethanes
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-20-
contaminant concentrations along ground water flow paths.
A second assumption is that contaminated groundwater enters the
surface water regime in the Tennessee River and undergoes a process
of dilution in a mixing zone. Mixing of the two sources of water
is assumed to occur instantaneously throughout the entire volume of
the mixing zone, resulting in an output flow and concentration that
can be calculated based on a continuity, or mass balance approach.
The average annual discharge in the Tennessee River is reported to
be on the order of 65,000 cubic feet per second (cfs), with an
average annual low flow of approximately 19,000 cfs. For this
conservative analysis, which considers the potential for long-term
exposure, it is assumed that the mixing zone is represented by
one-third of the total discharge in the Tennessee River under low
flow conditions. Thus, the volumetric flow rate of water entering
the mixing zone is estimated to be 6,333 cfs. It should be noted
here that the Tennessee Valley Authority (TVA) has no written
c'ommittment to maintain any given level of discharge if there is a
need to conserve water upstream and if navigable elevations ,in the
tailwater are being maintained by operation of Ohio River Lock and,
Dam 52 downstream. The use of an average low flow of 19,000 cfs
in the'dilution/ mixing zone calculations does take into
consideration the three percent of the time for the period 1958 to
1986 where discharge rates fell below 19,000'cfs and seven 2-day
periods or longer of zero discharge from Kentucky Dam. Therefore,
use of a 19,000 cfs. discharge rate is app~opriate.
Based on ground water analytical data obtained at the site during
the RI, it is apparent that the primary contaminants of concern in
the ground water are volatile organic compounds (VOCs). In
particular, EDC is present at the greatest concentrations and
occurs most extensively. "
As an example of the detailed ACL calculations performed on each
contaminant of concern, the following analysis utilizes'
concentration, distribution, and health-based standards associated
with EDC as a basis for developing probable 'ground water cleanup
strategies. Using this approach, the calculated ACL for EDC would
be:
5
ACLEDC = (1.7 x 10 ) MCLEDC
= (1.7 x 1(5) (0.005
= 850 mg/L
mg/L)
The value utilized h5re is the MCL for EDC, as defiried by the
NPDWR. The 1.7 x 10 multiplier contained in the above mass
balance equation was derived by dividing the total mixing zone
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-21-
volume (the sum of river mixing zone and ground water input to the
mixing zone volumes) by the ground water input to the mixing zone.
A one-hundredfold safety factor is then applied to the ACL for each
indicator chemical to include an allowance for other contaminants
(i.e., VOCs,' semivolatile organics), produce an additional factor
of safety in the analysis (aside from conservative assumptions
previously discussed), and to take into consideration the
uncertainties inherent in ground water velocity equations. Thus,
the ACL for EDC becomes 8.5 mg/L. ACLs for all indicator chemicals
are listed in Table 6.
4.2
Surface Soil/Sediment Cleanup Criteria
Contamination of the surficial soils surrounding the landfills was
found at the western and northern boundaries of the B.F. Goodrich
landfill, and the northwestern edge and southeastern .comer of the
Airco landfill. Low levels of PCBs were detected in ditch sediment
samples north of the landfills.
Since limited access is possible to the site, use of the field and
ditch area by trespassers may result in potential exposure. These
activities could result in exposure to ditch sediment and surface
soil contaminants.
Under the worst case-3valuati~n, the risk level from this po~~ntial
exposu~7 is 2.3 x 10 - outslde the target risk range of 10
to 10 .
Remediation of the drainage ditch north of the B.F. Goodrich/Airco
landfills will be removal of the contaminated sediments.
4.3
Subsurface Soil Cleanup Criteria
Remediation of subsurface soils of the burn pit area will be
accomplished by the stripping action of soil water with subsequent
collection and treatment of contaminated soil water. Therefore,
excavation of the subsurface soils of the burn pit area is not
necessary. The time required for this method of remediation was
taken into consideration in calculating the duration of the ground
water/leachate extraction and treatment system-as outlined in
Section 6.0, Recommended Alternative. -
Soil remediation strategies have been developed consistent with
ground water cleanup goals. The strategy for subsurface soil
remediation involved the use of an allowable EDC ground water
concentration of 850 mg/L. The allowable soil concentration was
calculated to be 139 mg/Kg.
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-J
TABLE 6
~ WATER ~ DRIQilAIR:O SITE
Iooicator O1eTIica1
lCL
. (In3!L)
Starrlard
(1TI3!L)
&xlrce
M:ix imLtTI Detected
.In Grol..Il"rlY.ater at
si te (rrg,IL)
1,2-Dichloroethane 8.5 0.005 M:L 3600
Carbon tetrach10r ide 8.5 0.005 M:L 16
C11orofoIJ11 0.32 0.00019 ~ 130
1,1,2-Trichloroethane 1.0 0.0006 PW;J:. 55
Eenezene 8.5 0.005 M:L 47
PAHs
Fl uoranth:!ne 8.5 0.042 ~ 0.08
A:enapthe!1e 8.5 0.020 PW;J:. 0.18
Tetrachloroeth:!ne 1.5 0.00088 ~ 3.7
1,1,2,2-Tetrachloroethane 0.29 0.00017 PW;J:. 5.2
Tr ichloroet:h2ne 8.5 0.005 M:L 4.6
C1lorobenZE!1e 8.5 0.060 M:I.G 34
1,1-Dichloroethane 8.5 4.2 AIC 120
bis(2-Chloroethyl)ether 0.051 3.0E-05 lH;l:. 0.9
M:L = M3.ximLtTI Con:entration Limit
M:LG = r-aximLtTI Correntration Limit Coal
PW;J:. = 1mbient Water. Q.Jality Criterion for hLtTlan health.
AIC = k'ceptable Intake Chronic val~
l'bte: ~ for carcin<:x:1en5 basErl on 10-6 Excess Carx:er Risk (EJ:R)
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-23-
5.0
Alternatives Evaluation
The purpose of remedial action at the B.F. Goodrich/Airco site is
to mitigate and minimize potential risks to public health, welfare,
and the environment posed by site soils, sediments, and ground
water contamination. The followin~ cleanup objectives were
determined based on regulatory requirements and levels of
contamination found at the site:
Contain the on-site contaminated ground water plume by
extraction and treatment;
Eliminate leachate production in the burn pit area;
Bring the landfills into compliance ~ith Kentucky statutes
regarding structures on a l00-year floodplain;
Protect the public health and environment from exposure to
on-site contaminated soils and sediments.
An initial screening of applicable technologies was performed to
identify those which best meet the criteria of Section 300.68 of
the National Contingency Plan (NCP). Following the initial
screening of technologies, potential remedial action alternatives
were iden~ified and ahalyzed.
Table 7 summarizes the technology screening process. Each of the
remaining alternatives for site remediation was evaluated based
upon cost, technical feasibility, implementabilityand reliability,
attainment of institutional requirements, and degree of protection
of public health, welf~re, and the environment. .
The following nine remedial action alternatives were considered:
Alternative I:No Action
Ground water monitoring
Alternative.
2:Ground water monitoring
Impose deed restrictions preventing residential
development and ground water use
Pump contaminated ground water plume and treat by
biological processing or air stripping
Place a clay cap over burn pit
Secure entire site
Alternative.3:Ground water monitoring
Impose deed restrictions preventing residential
development and ground water use
Construct a flood protection dike around landfills
Upgrade landfill clay caps
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--- - -
1ZC8NOI.CX; r sammc
I.F. CCODRl~ AIRCD SIn -
Surface Subaurf- GnIuzw.I
TecImology Wadf1ll. SOU SOU Vatu c-ntl
A. Iio kt1.oa bt be t\&lly evaluated
per 40 en 300.68
I. Land 11M Ra.tr1c:tiDaa
-Raltr1et dte access IIA IIA IIA DDauthar1zed .1te .c:c:e..
c:.an be prevented only for
eurhca IOU
_Deed res tr1c: t.1on IlIA IlIA BA Coutrol of future lad
- to prov14e loog-teno
1I1tegr1ty to ~1al
8C:tloo. Appl1c:.able only
to eurface IOU
_lAnd UN rutr1c:t.1coa No 110 80 110 Iio -uoc at lite
C. Lmd DUpoaal/Storage -
8off-s1ta d18poaal Iio 80 L1Ia1 ted ec:c.eptahW ty .
Surface 8ZId 8Ub8urface
cU.spolal ot IOU. MY be
8ppl1c:.abla to -U
.01-
-c:JD.11te UDdfW Iio No Ena1Aaered coota1aMot
c:ao be 4..~ for 101lI
*Laud appl1c:.at.1oa No No Iio No Oo8c.c:.eptahle for
415"".",; ..y be viAble
.. a tru~ alteroa-
t.1ft (- b1l1log1cal
trUtl8eat)
*Deep wU 1I1ject.1on No No No No c:JD.11ta ,eology oot
8U1tahle for 1I1jec:t1oa
D. Lucbate Coacroll
*c:.PPUl& IlIA H1A1a1ze ra1mo1ater 1Af1l-
trat.1on. lequirel
8Y8luatioo of cappiAg
..ter1al/.ya tell
-Coata1.illlent barr1en 1 No No NA Ray-be appl1c:.able for
laudfW depeDd1ag 011
depth to bedrock
*Subaurface c:.oUect.1on !IA Iio 'l1able 111 floodpla1.o
"'-re vater table 11
.haUov. Not..
atfect.1". .. extr8C:t.1oa
...ul for IT'OuaiI vater
coatrol
E. Air PoUut..1oa Cootroll
-Duat coatrol -.uuru !IA NA IDteria 8U8Ure only
4ur1Ag lite ~t.1oa
*Capping NA IlIA !IA NA
*VOC 8a1.aaJ.oa CODtrol - .... !IA 1 Hay be nquired 4apea41ac
GO tnaC88Dt 1ID1t1 UM4
P. Sul'fKe Vacar CocItroll . ltIy be nqu1Z'811 to
81A1a1ze the potmt.1al
tor ott-s1te tr&aaporc of
coata1A8Dta 4ur1q -
Itrw:t.1011 8ZId to p1"OY1.cle
lo.-tem aroaJ.oa pro-
C8ct.1all
*c:.PPiAI IlIA IlIA 114 Pmva ad atfect.1ve
tachaD10lY
*1qnd1Ag BA IIA .... ProveD ad at fec:t.1 ve
techoolocY to uaage
wter fl0W8 8ZId c:.ontrol
aradon
*i8vegetat.1all NA IlIA NA Used to .tah1l1ze caver
aurf- at eite. PruYen
8IIi:I atfect.1ve tedaJ1DIY
*0Iarmel. 8ZId vaterays IIA IlIA Cootrol. surface water
flov to Iss1st othec
r~ed1al tec~~c:'g~~s
.Flood protection NA SA Hay b~ 3PP~!CJb~e O~
fll>Odpial:1
-------
Tec:.baolDlD'
lADIUUls
(;. Cu /UaTat1CIID CCIIDtrola
*Or;aA1c npor recovery
B. Crouudwater CCIIDtrola
*Elttra.ct1OD
*Coo~..-fr-....r
burt&ra
lID
I. buvat10n 8Dd ""'81
ot Wute, SoU, 8Dd
SecUlaent
*!:I.ca9st1CllD UId r-.v81
!Io
J. lD 11 tu Trutz8Dt
*a-1cal tn&CaDt
~1Y818
R4
-oz14at1oa
N.\
-reduct1on
N.\
-solVeDt tlU8h.1og
NA
*Phys1cal trutllent
-soU beaUq
N.\
-soU t reez1ng
NA
-vitrif1cat1on
-Y8aAD G:tract1oa
114
-soU urat1CIID
HA
*Biological truORDt
HA
*Sol.1d1t1cat1CllD, St&&1Uut1c";J/
t~~n K~
K. Treatment ot Raaoved Wute S:reau
*I.aclnerat1on
K\
*GaaeowI ..... t e tru tllleDt
Nt.
114
N.\
Surface
SOU
N.\
No'
N.\
No
HA
!Io
2
2
IiA
Subsurface
SoU
HA
2
No
No
2
HA
114
Iio
N.\
No
NA
2
No
HA
Ground
Water
c:.-nta
HA
Applicabla trutDeDt to
burn pit ana vhea
CC8b1Ded II1.tb cappJ.aa
l:8oeraUy IIMd 10
COCIjunct1oa II1.tb cappiD&
UId trutaaDt
Utect1ft for tloor
-ut1cat1CllD
N.\
!edrock deptb 18 ~hly
Y8r1&ble; tbu8 deptb ot
bedrock key CoIIDDOt be
CODf1rwd
Ii4
tt.at be IIMd 10 =-
j UDC t1CIID or1 tb ci1apoMl
Gellarally lJm.ted by loor
801l pemeabWty
/fA
Gellarally DOt applicabla
to COD~te p~
No
AUphat1c bydroc:arbOaa
I-rally rea1.8tmt to 10
aitu ox1dat1oa
N.\
IioruUy lJm.ted to
c:hraa1.. treatment
HA
Watar C&D be IIMd for
801uble org&D1c:a aDd
1Daq8D1c:a. Procus
leDeratea laraa 901-
of water that require
turther treaQRDt
Ii4
tI.. ot ..t88I or r8dJ.o
frequency (IF) heating
to vapor1u org8D1c:a
RA
T8lpClury -.aaure U8 J.aa
refrigerant to treeze
80U aDd c:.ont&1D ...tea;
DO c_rc1&l. appUeat10a
HA
Develo~tal teclmolDlD'
u&1ng electricity thruo,qrh
conductive 8OUS.
Gont~ted aoU 1a
cODYened il1to durable
.laaa UId ...tea are
pyralyzed or c:ryataWzed
N&
Volac.Ua oq8D1c:a I'88Ned
by apply10g v- to
shallow ...u8
HA
V1able 01111 for valac.Ua
oq8D1c:a
pevelo~ tecbaalogy;
affect1ve tor s v1.da
r&QIa ot oq8D1c:a.
R4
ItIW8 are appl1cable to
both techn1ques; oq8D1C8
ara 80ra auited to
8OW1t1cat1oo (physical
trea~nt).
PrOVeD aDd effective
techaology tor organ1c:a;
1DeIfect1ve tor
1Dorgan1c..
Cueoua ....te trutl8eDt
may be req;dred 111 cO&-
junctiol1 with the
remed1.aJ. tecllDolog1ea
-------
TABU: 7 (CooUmoed)
Surface Subsurface CrowId
T8clIDology 1AB1!W. Sol1 Sol1 !ktn c-.nt8
. B.1olQ81c:.al treatment !L\ D8veloplll!11t8J. tedmology:
affective for c:eru1o
org8D1c: W8te .tre-.
.Light treatment
-cbm1c:.al IiA UfectiV8 tor 1DDrg8D1cs:
8a8a applic:atino for
org8D1c: WUt8 .tr88U.
-ph18ic:.al IiA Ceaerally appl1c:.able aDd
prvven .tfec:ti". to
org8D1c:.s and 1DDrg8D1c:.a.
.SOW. treatment
-dewater1Dg and. aol.1.d.8
b.and.l1.og III. IiA IiA IUt. Yall-4evalope4 techDalogy
L. Alt.native Water Supply
. Al tenati ft 4r1D1c1ng -ter
.upplies IiA NA NA 1iA !ID 4r1n1W1g _ter Deed
8Upplies remed1&t1On
!lDte: 1 . fea.sible and prac:tic:.a.l with high pr1or1ty for funher evaluation; 2 . feasible;
!ID . DOt viable; NA. DOt applicable, problem 40es DOt tetUt 10 tb1a operable IlUit;
-------
Alternative
Alternative
Alternative
-27-
Install leachate extraction system in landfills/burn
pit area
Pump contaminated ground water plume and treat by
biological processing or air stripping
Excavate surface and subsurface soils and place in
burn pit
"Install organic vapor recovery system in burn pit and
cover with a RCRA cap.
Secure entire site
4:Ground water monitoring
Impose deed restrictions preventing residential
development and ground water use
Construct a flood protection dike around landfills
Upgrade clay cap over landfills
. Install leachate extraction system in landfills/burn
pit area
Pump contaminated ground water plume and treat by
biological processing or air stripping
Excavate surface and subsurface soils and place in an
on-site (RCRA) facility.
Secure entire site
5:Ground water monitoring
Impose deed restrictio~s preventing residential
development an9 ground water use
Construct a flood protection dike around landfills
Upgrade clay capover landfills.
Install leachate extraction system in landfills/burn
pit a~ea .
Pump contaminated ground water plume and treat by
biological processihg or air stripping
Excavate surface and subsurface soils and treat by
biological processing or soil flushing
Secure entire site
6:Ground water monitoring
Impose deed restrictions preventing residential
development and ground water use
Construct a flood protection dike around landfills
Upgrade clay cap over landfills
Install leachate extraction system in landfills/burn
pit area
Pump contaminated ground water plume and treat by
biol~gical processing or air stripping
Excavate surface soils, place in burn pit, and treat
burn pit in-place by immobilization or soil
flushing/biological processing.
Secure entire site
-------
-28-
Alternative
7:Ground water monitoring
Vitrify landfills inplace
Pump contaminated ground water plume and treat by
biological processing or air stripping
Excavate surface and subsurface soils, place in burn
pit, and vitrify burn pit inplace
Secure entire site.
Alternative
8:Ground water monitoring
Impose deed restrictions preventing residential
development and ground water use
Construct flood protection dike around landfi~ls
Place a RCRA cap over landfills
Install leachate extraction system in landfills/burn
pit area
Pump contaminated ground water plume and treat by
biological processing or air stripping
Excavate surface soils and place in burn pit
Install organic vapor recovery system in burn pit and
cover with a RCRA cap.
Secure entire site
Alternative
9:Ground water monitoring
Imp6se deed restrictions preventing residential
development and. ground water use
Construct flood protection dike around landfill
Upgrade clay cap over landfills.
Install leachate extraction system in landfills/burn
pit area. .
Pump contaminated ground water plume and treat by
biological processing or air stripping .
Exc~vate surface and subsurface soils and place in an
off-site RCRA-approved facility
Secure entire site.
ALTERNATIVE 1
The Superfund Program requires that the "no-action" alternative be
considered at every site. Under the "no-action" alternative, EPA
would take no further action at the site to control the source of
contamination. The "no-action" alternative serves as a baseline
with which other alternatives can be compared-. Potential health
risks associated with current exposure by ingestion to surfac~ soil
at the site and potential future exposure to ground water by
ingestion at the site would remain; this alternative exceeds the
target risk range for all but the most probable current use.
This alternative does not attain ARARs.
mObility, or volume would occur.
No reduction in toxicity,
-------
-29-
Continued monitoring of ground water would be a satisfactory means
to determine levels of contamination; existing monitor wells would
be utilized. Monitor well sampling would not pose a threat to the
environment or health and safety of site workers. Present worth
cost of this alternative would be $115,000.
ALTERNATIVE 2
The B.F. Goodrich/Airco landfills would not be remediated.
Leachate production would be controlled by the ground water pumping
scheme implemented to contain the contaminant plume. Contaminated
subsurface soils in the burn pit area would be left in place;
leachate flow into the alluvial aquifer would be reduced by
installation of a clay cap over the area. Leachate would be
captured by the ground water pumping scheme. Requirements for the
protection of landfills located on a flood plain would not be met.
Ground water would be extracted at 100 gpm, treated to meet KPDES
requirements, and discharged to the Tennessee River. The ground
water extraction and treatment system would remain in operation
until the ground water clean-up goals, as specified in Tab~e 6, are
attained in quarterly analyses from all monitor wells for a period
of one year. Once this criterion is met, the extraction and"
treatment system would be shut down. Following shut-down,
quarterly analyses from all wells would. be performed for a period
of two years. There is potential for the water table to rise above
the base of the landfills during periods of high river stage,
creating leachate. There is, furthermore, the potential for
failure of the clay caps on the landfills during flooding events,
and opening of a leachate pathway to the ground water. These
events may occur in the long term after shut down of the ground
watertreatrnent plant. " .
Both the most probable and worst case exposure scenarios for this
alternative re~~lt in ~~timated total risks that are within the
target risk "10 to 10 range.
Although public health risks from exposure to contaminated site
media would be reduced to within the target risk range, absence of
landfill remediation from this remedy. does not satisfy" .
requirements for solid waste landfills located on a floodplain.
This alternative provides for no reduction "in toxicity, mobility,
or volume.
Ground water treatment would involve controls to prevent the
release of VOCS to the atmosphere~ health and safety plans would be
required for the treatment process plant to protect site workers.
This alternative would be implemented in a straight-forward manner
utilizing proven and reliable technology. Present worth cost for
this alternative is estimated to be $2.36 million for air
-------
,..3"-
stripping/carbon adsorption and $6.6 million for biological
treatment. It is anticipated that ground water clean-up goals
would be attained within 1" years of the start-up of the extraction
and treatment system. Once the criterion for attainment of ground
water have been met, monitoring of ground water quality would be
performed once. per year thereafter for a period of 3" years. If -
contaminant levels increase above clean-up goals at any time during
this 3"-year monitor period, the extraction and treatment system
would resume.
ALTERNATIVE. 3
This alternative would combine the components of Alternative 2 with
flood protection, a leachate extraction and treatment system,
together with an upgraded cap for the landfills, and a RCRA cap for
the contaminated soils. In addition, an organic vapor recovery and
treatment system would be installed to collect any vapor from
beneath the burn pit RCRA cap.
Upgrading the landfill caps would effectively minimize
infiltration. This, combined with a leachate extraction system,
would ensure the elimination of leachate migration potential from
the landfill. The flood dike would maintain the integrity of the
upgraded landfill cap. .
. .
Approximately 5,""" cubic yards of contaminated soils would be
excavated and then contained in tbe burn pit area under a RCRA cap;
leachate. would be essentially eliminated. Public health risks fro~
soils exposure would be reduced to. within the target risk range.
The organic vapor recovery system at the burn pit would remove and
treat any volatiles and thus reduce soils remediation time. The
leachate collection system at the burn pit would remove
contaminated ground water to prevent mixing in the aquifer.
Ground water would be extracted at 100 gpm, treated to meet KPDES
requ.irements, and discharged to the Tennessee River. Effluent will
be sampled to ensure compliance with the KPDES program. Operation
of the ground water extraction and treatment system would remain in
operation until the ground water clean-up goals, as specified in
Table 6, are attained in quarterly analyses from all monitor wells
for a period of one year. Once this criterion is met, the
extraction and treatment system would be shut down. Following
.shut-down, quarterly analyses from all .wells would be performed for
a period of two years.
Ground water treatment and soil excavation would involve controls
to prevent the release of VOCs to the atmosphere; health and safety
plans would be required for the treatment process and soil
excavation to protect site workers. .
-------
-31-
Inspection and repair of the caps and maintenance of the dike and
leachate collection system would be required. The ground water
treatment plant would require continuous operation and periodic
maintenance. Excavation of the surface soil for placement in the
burn pit must be closely monitored for airborne particulate
pollutants and. volatile organic compounds in order to protect the
health of the site workers. Dust emissions during construction can
be kept within regulatory limits by wetting down the soil.
Remediation of the landfills would satisfy requirements for
landfills located on floodplains; all ARARs would be attained. The
organic vapor recovery system, installed to collect and treat any
vapor from beneath the burn pit RCRA cap, in conjunction with the
elimination of leachate production, would address the requirements
of SARA by significantly reducing the mobility of
contaminants. All components of this alternative are proven,
reliable, and could be implemented in a straight - forward manner.
Seismic risk potential would be addressed in the. remedial design of
this alternative to provide for the long-term integrity of this
remedy. Earthquake engineering technology would be incorporated
for containment facilities to minimize potential residual risk
associated with potential seismic activity in the region.
Present worth cost for this alternatives is estimated to be $6.1
million. It would require one year to address the landfills,
suiface soi1~ and. subsurface soils. It is anticipated that ground
water clean-up goals would be attained within 1~ years of the.
start-up of the extraction and treatment system. Once the
criterion for attainment of ground water clean-up goals have been
met, monitoring of ground water quaiity would be performed once pe~
year thereafter for a period of 3~ years. If contaminant level~
increase above clean-up goals at any time during this 3~ year
monitor period, the extraction and treatment process would resume.
ALTERNATIVE. 4
This alternative would combine the components of Alternative 2 with
flood protection, a leachate collection and extraction system,
together with an upgraded cap for the landfills, and an on-site
RCRA facility for the contaminated soils.
Upgradinq the landfill caps would effectively minimize
infiltration. This, combined with a leachate extraction and
treatment system would ensure the elimination of leachate migration
potential from the landfill. The flood protection dike would
maintain the integrity of the clay caps.
Approximately 5,~~~ cubic yards of contaminated soils would be
excavated and then contained in an on-site RCRA facility, leachate
-------
-32-
would be essentially eliminated. Public health risks from exposure
to soils would be reduced to within the target risk range.
Ground water extraction and treatment would contain the contaminant
plume as described in Alternative 3.
Inspection and repair of the caps and maintenance of the dike and
leachate treatment system would require periodic operation and
maintenance. Excavation of the surface soil for placement in the
burn pit area would be closely monitored for air pollutants and
volatile organic compounds to protect the health of site workers.
Dust emissions during construction can be kept within regulatory
limits by wetting down the soil.
Remediation of the landfills would satisfy requirements for
landfills located on floodplains; all ARARs would be attained. The
organic vapor recovery system, installed to collect and treat any
vapor from beneath the burn pit RCRA cap, in conjunction with the
elimination of leachate production would address the requirements
of SARA by significantly reducing the mobility of contaminants.
Potential for release of VOCs during excavation and ground water
treatment would require implementation of air emissions controls.
All components of this alternative are proven, reliable, .and could
be implemented in a straight-fQrward manner.
Seism"ic ri.sk potential would be addressed in the remedial design of
this alternative to provide for the long-term integrity of this
remedy. Earthquake engineering technology would be incorporated
for containment facilities to minimize potential residual ri~k
associated with potential s~ismic activity in the region.
Present worth cost for this alternative is estimated to be $8.75
million without providing a greater degree of protection to public
health or the environment than Alternative 3. It would require 18
months to address the landfills, surface soils, and subsurface
soils. It is anticipated that ground water clean-up goals would be
attained within 10 years of the start-up of the extraction and
treatment system. Once the criterion for attainment of ground
water clean-up goals have been met, monitoring of ground water
quality would be performed once per year thereafter for a period of
30 years. If contaminant levels increase above clean-up goals at
any time during this 30 year monitor period, the extraction and
treatment process would resume.
ALTERNATIVE 5
This alternative combines the components of Alternative 2 with
flood protection, a leachate collection and extraction system,
together with an upgraded clay cap for the landfills and treatment
of contaminated soils.
-------
-33-
Upgrading the landfill caps would effectively minimize
infiltration. This, combined with a leachate extraction and
treatment system, would ensure the elimination of leachate
migration potential from the landfill. The flood protection
would maintain the integrity of the clay caps.
Ground water extraction and treatment would contain the contaminant
plume as described in Alternative 3.
dike
Contaminated soils would be treated either by biological
degradation, by composting, or by solvent flushing. These
techniques address the requirements of Superfund Law by
significantly reducing toxicity by treatment. Public health risks
from soils exposure would be reduced to within the target risk
range.
Soils treatment by composting is a proven technique that has been
commercially demonstrated on a variety of biodegradable wastes. .
Soils treatment by flushing is a developmental technique currently
being demonstrated at Superfund waste sites. Reliability of both
composting and soil f~ushing is unconfirmed for the application at
the site. Neither technique has been .tested using the site
contaminants. This step is of primary importance to assessing
performance and reliability.
Implementability of the soils treatment techniques would involve
excavation and transfer of all contaminated soils with the
associated safety and environmental concerns; these c~ncerns can be
alleviated by appropriate health and safety measures and by the use
of soils wetting to eliminate dust. Operation and maintenance
requirements of this alternative are great since the active
remedial measures use ~evelopmental techniques.
~emediation of the landfills would satisfy requirements for
landfills located on floodplains; all ARARs would be attained.
Present worth cost for this alternative is estimated to be $9.32
million for biological degradation and composting or $21.3 million
for solvent flushing. This remedy is not the most cost-effective
remedy; reduced reliability in.attaining ARARs would be associated
with the developmental nature of soils remediation. . Implementation
of the biological degradation/composting remedy would require three
years; solvent flushing would require three years to process all of
the soil. It is anticipated that ground water clean-up goals would
be attained within 10 years of the start-up of the extraction and
treatment system. Once the criterion for attainment of ground
water clean-up goals have been met, monitoring of ground water
quality would be performed once per year thereafter for a period of
30 years. If contaminant levels increase above clean-up goals at
any time during this 30 year monitor period, the extraction and
treatment process would resume.
-------
-34-
ALTERNATIVE 6
This alternative includes the components of Alternative 5, except
contaminated soils would be treated in-place.
Approximately 5,000 cubic yards of contaminated soils would be
excavated, placed in the burn pit area, and treated by in-place
immobilization or by soils flushing. Both techniques address the
requirements of Superfund Law: immobilization, by significantly
reducing mobility of the contaminants and soils flushing, by
removing and treating leachate contaminants from the soil. Public
health risks from soil exposure would be reduced to within the
target risk range.
Remediation of. the landfills would satisfy requirements for
landfills located on floodplains; all ARARs would be attained.
Implementation of both techniques would involve conventional
proven equipment. Site-specific testing of these techniques
be necessary to confirm site-specific parameters such as
applicability. of the process to the clayey soils at the site
the specific organic contaminants present.
and
would
and to
Implementability of the soils treatment techniques would involve
~xcavation and. transfer of all contaminated soils with the'
associated safety and environmental concerns; these concerns can be
alleviated by appropriate health and safety measures and by the use
of soils wetting to eliminate dust. Operation arid maintenance
requirements of this alternative are great, since the active
remedial measures use developmental techniques.
Present worth:cost for this alternative is estimated to be $19.25
million for the immobilization treatment remedy, $7.41 million for
soils flushing. Remedy implementation is estimated to be one year
for immobilization, ten years for soils flushing. It is
anticipated that ground water clean-up goals would be attained
within 10 years of the start-up of the extraction and treatment
system. Once the criterion for attainment of ground water clean-up
goals have been met, monitoring of ground water quality would be
performed once per year thereafter for a period of 30 years. If
contaminant levels increase above clean-up goals at any time during
this 30 year monitor period, the extraction and treatment process
would resume.
ALT.ERNATIVE ..7
This alternative involves treatment as a principal element for all
contaminated media. This alternative includes in-place
vitrification of soils and buried wastes, and the tr~atment of
contaminated ground water.
-------
-35-
Vitrification of approximately 238,000 cubic yards of soil and
waste would permanently immobilize any metals in the burn
pit/landfills and pyrolize or combust organic compounds.
Volatilization of organics is expected to occur. Organic vapors
would have to be captured by a specially designed hood placed over
the soil being. vitrified.
Contaminated surface soils would be excavated and moved to the burn
pit area using conventional earth-moving equipment. The burn pit
area would then be vitrified to the water table. In addition, the
landfills would also be vitrified in-place, including all buried
wastes.
All future potential for ground water contamination would be
eliminated. Similarly, this alternative would prevent any
contaminated leachate from leaving the landfill area. Any
variation in the water table beneath either the burn pit area or
the landfills would not cause additional migration of hazardous
substances. This alternative would break all contaminant migration
pathways including contaminated ground water release into the
Tennessee River and migration of landfill leachate. '
Implementation of this alternative would eliminate the mobility and,
toxicity of hazardous material in the soil through'treatment.
Vitrification is a permenent solution, since the obsidian-like mass'
is expected to last over 1 million years~ After approximately 9
months the vitrified mass would reach ambient temperature. The
final product would require little, if any, maintenance.
This alternative addressess the requirements of Superfund Law by
permanently and significantly reducing'the toxici,ty and mobility of
contaminants. This alternative as described exceeds all applicable-
or relevant and appropriate requirements and protects the public
health to within the target risk range. .Since vitrification is a
developmental technology, there are doubts about its reliability in
commercial application.
This emerging technology would require extensive feasibility
testing to determine its applicability and reliability to the
on-site organic contaminants of concern. The uncertainty of this
technology and recurring electrode failure at other sites could
seriously impair this remedy's ability to meet performance
standards. Emissions dur ing implementation would' require str ingent
and extensive controls for both dust and VOCs.
Estimated cost for this remedy is $107.1 million. Implementation
time is estimated at five years for the landfills, surface, and
subsurface soils. It is anticipated that ground water clean-up
goals would be attained within 10 years of the start-up of the
extraction and treatment system.
-------
-36-
ALTERNATIVE. 8
All components of this alternative are identical to Alternative 3,
except that the clay landfill cap would be upgraded to comply with
Federal standards. Implementation, operation and maintenance, and
reliability. are unchanged. This alternative would exceed
applicable or relevant and appropriate requirements for the
landfills, but is less cost-effective while not providing a greater
level of protection to public health or the environment.
Public health risks from contaminated soils would be reduced to
within the target risk range. Leachate from soils in the burn pit
would b~ eliminated. Ground water extraction and treatment would
contain the contaminated plume as described under Alternative 3.
The time required to address the landfills, surface soils, and
subsurface soils is estimated to be approximately one year. It is
anticipated that ground water clean-up goals would be attained
within 10 years of the start-up of the extraction and treatment
system. Once the criterion for attainment of ground water clean-up
goals have been met, monitoring of ground water quality would be
performed once per year thereafter for a period of 30 years. If
contaminant levels inc~ease above clean-up goals at any time during
this 30 year monitor period, the extraction and treatment process
would resu~e. Present woith cost of this alternqtive is estimated
to be $7.06 million. -
ALTERNATIVE 9
This alternative includes the components of Alternative 4t except
contaminated soils would be disposed off-site.
Approximately 57,000 cubic yards of soils contaminated with
hazardous substances would be excavated and removed to the nearest
RCRA-approved facility. Public health risKs from soil exposure
would therefore be mitigated. Disadvantages of off-site transport
involve possible release of contaminated dusts during excavation
and transportation of large volumes of contaminated soils.
Upgrading the landfill caps would effectively minimize
infiltration. This, combined with a leachate extraction and
treatment system would ensure the elimination of leachate migration
potential from the landfill. The flood protection dike would.
maintain the integrity of the clay caps.
This alternative isaless cost-effective means of mitigating the
risks to the public health, welfare, and environment. The
alternative meets all action-specific requirements, and relies on
proven technology. This alternative is not preferred, however,
because it is not in compliance with Superfund Law which states
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-37-
that the off-site transport and disposal of hazardous substances
should be the least favored alternative.
Present worth cost of this alternative is estimated to be $27.68
million. Implementation would be two years. It is anticipated
that ground water clean-up goals would be attained within 10 years
of the start-up of the extraction and treatment system. Once the
criterion for attainment of ground water clean-up goals have been
met, monitoring of ground water quality would be performed once per
year thereafter for a period of 30 years. If contaminant levels
increase above clean-up goals at any time during this 30 year
monitor period, the extraction and treatment process would resume.
6.0
RECOMMEN.DED ALTERNATIVE
6.1
Description of Recommended Alternative
The recommended alternative, Alternative 13 (Figure 4), for
remediation of contamination at the B.F. Goodrich/Airco site
includes the following components:
Ground water monitoring
Impose deed restrictions preventing residential
development .
Construct flood protection dike around landfills
Upgrade landfill clay caps
Install leachate.extraction system.
Pump contaminated ground water plume and treat by air
stripping
Excavate surface soils and place in burn pit
Install organic vapor recovery system in burn pit and
cover with a RCRA cap
Preserving the integrity of the remedial action is essential
towards providing long-term protection to public health and the
environment. Imposition of institutional controls (deed
restrictions) will serve as one measure to protect the integrity of
the remedy by preventing residential development and installation
.of drinking water supply ground water wells on the B.F. Goodrich
and Airco - owned properties bounded on the north by the landfills
and on the south by Highway 1523.
Fencing of the entire landfills/burn pit area serves as an
additional measure to preserve the integrity of the remedy by
preventing future access. Approximately 3,200 feet. of fence will
be constructed around the landfills/burn pit area. The fence will
be a 6-foot tall chainlink fence with three strands of barbed wire.
There will be four lockable gates to allow access to the area by
authorized personnel.
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SECURITY
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GROUNDWATER
EXTRACTION
LEACHATE
CONTOUR OF CAP
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-------
-39-
A flood protection dike will be constructed on the north, east and
west sides of the landfills. The elevation at the top of the dike
will be 346.1 feet msl, which is two feet above the l00-year flood
elevation of 344.1 feet msl. Contaminated surface soils will be
excavated prior to construction of the flood protection dike clay
core. Any contaminated soil remaining below the dike core would be
sealed by the overlying impervious material.
The dike will be constructed outside the edge of the landfill in
order to prevent inundation of waste from flood waters. Additional
landfill capping material may be utilized with a drainage outlet to
prevent ponding of runoff from the landfill inside the dike.
Approximately 120,000 cubic yards of fill will be required for dike
construction. A ditch that runs along the northwest corner of the
B.F. Goodrich landfill will be relocated to facilitate
construction.
The existing B.F. Goodrich and Airco landfill caps will be upgraded
by stripping approximately four inches of the existing vegetative
cover from the landfills, adding 2,700 cubic yards of compacted
cla~ ~ill to achieve ~h7 desired ~7ades on the lan~fill surface at
a mlnlmum cap permeablllty of 10 em/sec., coverlng the clay
with a l2-inch layer of vegetative fill, seeding and mulching the
area, and constructing drainage dit~hes to control runon.
A leachate extraction system will be installed on the western edge
of the burn pit area. Two sumps will be installed approximately
two feet into the sandy clay unit that occurs at approximately 25
feet below the surface of the burn pit. The leachate extraction
system will also involve the installation of six sumps in the B.F.
Goodrich/Airco landfills. Sumps will be driven to a depth of two
feet below the bottom of the waste~ . .
Collected. leachate will be stored in a hOlding tank, treated at the
ground water treatment plant if necessary, and then discharged to
the Tennessee River only after it meets KPDES standards as
specified in Table 8, as revised thereafter. Leachate samples will
be submitted to the appropriate laboratory for analysis and split
samples collected and analyzed by EPA prior to discharge.
The zone of contaminated ground water capture/treatment is
illustrated in Figure 5. The recovery system will employ five
production water wells, optimally spaced to fully capture targeted
ground water without excessive inflow of uncontaminated ground
water. Each recovery well will be installed at depths of 40 to 60
feet, each pumping at a rate of 20 gpm.
In order to achieve ground water clean-up goals it is estimated
that approximately 6,075,000 cubic feet of contaminated ground
water will be pumped to a ground water treatment plant located
-------
TABLE 8
B.F. GOODRICH! AIRCO SITE
KENTUClC'l POLLUTION DISCHARGE ELIMINATION SYSTEM (KPDES)
STANDARDS FOR INDICATOR CHEMICALS
Indicator Chemical
KPDES* Standards
(not using end-pipe
biological treatments)
KPDES* Standards
(using end-pipe
biological treatments)
1,2-Dichloroethane
Carbon tetrachloride
Chloroform
1,I,2-Trichloroethane
Benzene
PARs
Tetrachloroethene
1,I,2,2-Tetrachloroethane
Trichloroethene
Chlorobenzene
1,l-Dichloroethane
bis(2-chloroethyl)'ether
PCBs
180
142
111
32
57
19
52
N/A
26
142
22,
N/A
NiA
22
18
21
N/A
37
22
22
N/A
22
15
N/A
N/A
N/A
-
/
All concentrations in ug/L
N/A = information not available.
* 'Source: Federal Register Nov. 5, 1987,40 CFR Part 414.91,414.01 and based on discussions
with Kentucky Division of Wa~er at time of feasibility study.
-------
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A!ReO PROPERTY
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APPROXIMA rE sire
GROUNDWATER FLOW DIRECTION
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UMrT OF GROUNDWATER REQUIRING TREATMENT
COHTOUA INTCRVAL. 10 FEET
NOTES:
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CAPTURE ZONE OF INDIVIDUAL WELL
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COMBINED CAPTURE ZONE OF WELL FIELD
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SCALE IN FE.:1
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I
BFGOODRICH/AIRCO SITE
CALVERT CITY, KENTUCKY
~IQU"E 5
GROUNDWATER CAPTURE ZONE
SITE ALTERNATIVE
3
DAMF.S .. MOORE
IA...RCH 1995
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-42-
within the eastern boundary of the B.F. Goodrich plant site.
Ground water may contain significant quantities of oil requiring
treatment with an oi~/water separator. This floating light oil
will be stored for no more than three months in an oil storage
tank,' after which time it will be disposed in an oil recycling
facility. Oil-free water and water with possible trace amounts of
oil will be fed to an air stripping system and treated in keeping
with discharge limitations. It is estimated that the air stripping
system will remove 99.5 to 99.7 percent of volatile organic
contaminants. Semivolatiles will be partially removed by the air
stripper. The water and remaining contaminants will then be
polished using activated carbon adsorption or existing biological
treatment and discharged through a currently-permitted KPDES
outfall to the Tennessee River only after it meets KPDES program
standards as specified in Table 8, as revised thereafter.
Air leaving the air strippers is often permitted to discharge to
the atmosphere, but due to the initial levels of contamination, the
off-gas will be treated by adsorbing onto granular activated
carbon. The activated carbon will be regenerated on-site using
steam.
Preliminary designs on the air stripping system indicate that
carbon adsorption is a viable, proven.technology capable of
treating potentially contaminated off-gas. Carbon adsorption beds
will be employed to treat off-gas contaminants, as necessary,
however i.should the carbon adsorption emission control sys.tem prove
to be unsatisfactory towards attainment of emissions standards, an \
alternate emission control technology may be employed. Alternate
emission control technologies will be implemented only after
obtaining the necessary EPA and State approval.
Surface soil remediation will be accomplished by excavation of .
soils to a depth of approximately 1.5 feet in areas approximated as
an 80-foot-wide strip along the west side of the B.F. Goodrich
landfill, a 100-foot-wide strip along the north side of the B.F.
Goodrich and Airco landfills that extends from the northwest corner
of the B.F. Goodrich landfill to 50 feet east of sample location 7
and a 100-by 100-foot-square area around sample location 12
(Figures 3 and 6). The total volume of surface soil requiring
remediation is approximately 5,000 cubic yards.
Sediment remediation will be accomplished by removal of sediments
along the drainage ditch north of the B.F. Goodrich/Airco landfills
from ditch s~mpling point 1 to 3 (Figure 3).
Contaminated surface soils and sediments will be placed in the burn
pit area and covered with a RCRA cap. Necessary design
considerat'ions, as outlined in Covers; for. Uncontrolled. .Hazar.dous
Waste Sites, EPA/2 - 85/002, will be adhered to in development of
-------
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-44-
the RCRA cap design. EPA approval will not be granted until the
site-specific design has been submitted to EPA and reviewed for its
adequacy.
In order to separate EDC and other volatile organics from
contaminated s~il, an organic vapor recovery system will be
installed over the soils in the burn pit area. A 6-inch layer of
gravel will be installed over the soils along with a network of
perforated pipe on 50-foot centers. The pipe system will be
connected to several vacuum blowers which will extract volatile
organics as they are released by the soils. Released gases will be
blown through a carbon adsorption bed, if necessary.
The recommended alternative uses proven technologies that are
immediately available. Landfill construction and ground water
treatment (air stripping) technologies are well established. The
remedy can be designed to meet all appropriate state and federal
requirements, thus reducing delays that newer technologies might
encounter during implementation. While soil flushing,
immobilization, and vitrification (Alternatives 5, 6, and 7) are'
effective in significantly reducing the toxicity and mobility of
wastes, they must rely upon scarce technological resouices, which
delays their implementation and reduces their ability to ~chieve
required performance standards.
Alternative 3 is the most cost-effective alternative that
effectively provides ,protection to public health and the,
environment and'att~ins all ARARs. . Alternative 2 does not prevent
long-term threat to the ground water. The off-site disposal
alternative (Alternative 9) is less cost-effective and presents
more risks, due to the need to transport the waste. Alterna~ives 4
and 8 are less cost-effective without providing a greater level of
protection to pUblic health or the environment. Alternative 7
(vitrification) is an emerging technology with a lesser degre~ of
reliability. Extensive feasibility testing would be required to
determine vitrification's reliability and applicability to on-site
organic contaminants; instances of electrode failure are recurrent
at other sites.
Public health risks from soil and ground water exposure will be
reduced to within the target riSk range under Alternative 3;
earthquake engineering technology will b~ incorporated for
containment facilities during the remedial design to minimize
potential residual risk associated with potential seismic activity
in the region. All applicable or relevant and appropriate
requirements for the remedy will be attained.
Alternative 3 provides for the treatment of contaminated ground
water/leachate via an extraction and 'treatment system. Volatile
organics will be removed from soils in the burn pit via an organic
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-45:"
vapor recovery system and treated if necessary. With time, the
stripping action of soil water will treat remaining contaminants in
the burn pit area. Ground water extraction and treatment will
remain in operation until ground water clean-up goals have been
achieved. Following attainment of clean-up goals, a 39-year period
of monitoring will be performed to. ensure clean-up goals are being
maintained.
Ground water treatment and soil excavation will involve controls to
prevent the release of VOCs to the atmosphere; health and safety
plans plans will be developed for the remedial action to protect
site workers. No negative impacts on the community or environment
are anticipated during the implementation of Alternative t 3.
Thus, EPA believes that Alternative 3 presents the best balance
among the effectiveness, implementab.ili~y, and cost factors for
this site. Further, this remedy meets all applicable federal and
state standards.
6.2 Operation and Maintenance
Overall implementation of this remedy is estimated to take 19
years, fol.lowing design and contract award. The time required to
address the landfills, surface soils, and subsurface soils 1S
estimated to be approximately 1 year. Ground water extraction and
treatment will continue until the ground water achieves the
.clean~up goals. It is anticipated that these clean-up goals will
be met within ten years of the initiation of the extraction and
treatment system. Following completion of the landfill and soil
remedial action, operation and maintenance (O&M) will be performed.
Virtually all of the contamination will be removed from the ground
water before reaching the Tennessee River. In the event any
contaminant escapes the zone of influence of the extraction wells,
it will be diluted to below Maximum Concentration Limits (MCLs)
when mixed in the Tennessee River. This should have a negligible
effect on water quality in the river, but regular monitoring of
ground water and river water will indicate the need to increase
pumping rates or to install additional wells. periodic maintenance
of all mechanical and electrical parts associated with the leachate
extraction and ground water recovery wells will be performed. The
leachate collection system should have an effective life of over 15
years and would require replacement at that time, or when
appropriate. Annually the air stripping system will be shut down
to allow for acid washing of the tower packing.
A 39-year monitoring program will be developed and implemented to
meet. the RCRA requirements :~r capped areas that contain hazardous
materials. This program will consist of regular inspection for
erosion and subsidence, periodic mowing of the vegetative cover,
and a ground water monitoring program.
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6.3
Cost of Recommended Alternative
The present worth cost of this remedy is estimated to be $6.09
million. The capital cost will be approximately $2.96 million.
The total present worth of the operation and maintenance costs is
estimated to be $3.13 million.
6.4
Schedule
The planned schedule for remedial activities at the B.F.
Goodrich/Airco site is as follows:
Summer 1988
Approve Record of
Decision/Consent Decree Signed
Fall 1988
Consent Decree Entered/Initiate
Remedial Design
8 months after
Consent Decree entered
Complete Remedial Design and
Begin Mobilization
20 months after
'Consent Decree entered
Complete landfills, surface
soils, and subsurface soils
remediation
10 yea~s £ollowing
initiation of Remedial
Action
Complete ground water
remediation
6.5
Future Actions
Following completion of ground water remediation, long-term
operation and maintenance will be performed, as described in
Section 6.2, to ensure that the integrity of this remedy is
maintained. .
6.6
Consistency With Other Environmental Laws
Remedial actions performed under CERCLA must comply with all
applicable or relevant and appropriate requirements (ARARs). All
alternatives considered for the B.F. Goodrich/Airco site were
evaluated on the basis of the degree to which they complied with
these requirements. The recommended alternative was found to meet
or exceed the following ARARs, as discussed below.
Resource~onserv~tion.and.Recovery.Act
The recommended remedy includes the construction of a RCRA cap over
the burn pit/disposal area and upgrading of the existing clay caps
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-47-
on the B.F. Goodrich/Airco landfills. All substantive regulations
governing closu~e of solid waste management units and the design
and construction of RCRA caps will be met, as defined in 40 CFR
Section 264.310 of RCRA and as outlined in Gove~~-f~--UR~~t~~-1eQ
Ha~~Q()u.s-Wa.s-t-e..S-:i-t-es, EPA/2 - 85/002.
Two plausible scenarios exist as to ground water contaminant
source. One scenario identifies the landfills as a potential
source. Both landfills, for some period of time, operated under a
Solid Waste Disposal Permit and were operated accordingly. This,
in conjunction with the uncertain nature of landfill contents,
precludes the need for a RCRA cap on the landfills. Additional
remedial measures, such as leachate extraction sumps in the
landfills and flood protective dikes, take into account the
uncertainty involved. Should future site monitoring or discovery
of new informatIon reveal the presence of hazardous waste in the
landfills, the remedy. will be reevaluated to determine its
effectiveness.
G1-ean- -Wa te~- -Act/Sa Ie- -D-~ i nk-i-Rg.. Wa-ter- -AGt
Ground water cleanup criteria involved an evaluation of contaminant
concentrations relative to availa~le health-based standards. Such
standards (ARARs) include drinking water Maximum Concentration
Limits (MCLs) and Maximum Concentration Limit Goals (MCLGs), and
federal Ambient Water Quality Criteria (AWQC) as defined by the
Safe Drinking Water Act (SDWA) (40 CFR Parts 141 and 142) and the
Clean Water Act respectively. For the B.F. Goodrich/Airco site,
Alternate Concentration Limits (ACLS), based on MCLs, or Ambient.
Water Quality Criteria in the absenc~ of MCLs, in the mixing zone
of the Tennessee River, were employed to relate contaminant
concentrations in ground water to those at the point of use.
Applicable statutory language concerning clean-up standards and the
application of Alternate Concentration Limits). under CERCLA is
found in Section 121 (d) (2) (B) (ii) of SARA.
~1~pla~~-Re~1at~4Rs
Remedial action requirements for the landfills address corrective
measures to ensure compliance with regulations regarding landfills
located on a 100-year floodplain.
!)e pa-r..tmentr.~ f -- -T-r-aRspo-~ ta-t-i-oR
Transportation of hazardous substances is regulated by the
Department of Transportation (DOT). If residual material results
from the ground water treatment system, it will be shipped to an
off-site disposal facility. If tests on the material indicate the
need for disposal in a hazardous waste facility, DOT regulations
governing its shipment will be followed.
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Occupational.Safetyand Health Administration
A Health and Safety Plan will be developed during remedial design
and will be followed during field activities to assure that
regulations of the Occupational Safety and Health Administration
(OSHA) are followed. .
National .Pollution.Discharge Elimination. System
Discharge of treated ground water is part of the recommended
remedial alternative. This discharge will meet effluent limit
requirements of the National Pollutant Discharge Elimination System
(NPDES) .
Endangered. Species Act
The recommended remedial alternative is protective of species
listed as endangered or threatened under the Endangered Species
Act. Requirements of the Interagency Section 7 Consultation
Process, 50 CFR, Part 402, will b. met. The Department of
Interior, Fish and wildlife Service, will be consulted during
remedial design to assure that endangered or threatened species are
not adversely impacted by.implementation of this remedy.
Ambien t. Ai r; . Qual i ty. Standards
The ground water treatment system will be designed to assure that
air -emissions meet all State and. Federal standards.
Comm.unityRelations
7.0
Community relations activities have remained an important aspect
throughout the RI/FS. On May 28, 1986 a public information meeting
was held at the City Hall in C~lvert City, KY to inform concerned
citizens within the community of the Remedial
Investigation/Feasibility Study. Prior to the May 28 meeting,
pUblic notices, fact sheets, and press releases were issued.
Throughout the RI/FS, correspondence remained open with various
citizen and environmental groups.
On October 16, 1987, EPA established an Administrative Record for
the B.F. Goodrich/Airco site at the Marshall-County Public Library
in Calvert City. On March 15, 1988, the final RI, draft FS, and
final Endangerment Assessment reports were submitted to
repositories in Calvert City, and Benton, KY. A public meeting was
held at the Calvert City Elementary School in Calvert City on March
29, 1988 to present the findings of the RI and EPA's preferred
remedial alternative. Prior to the March 29 meeting, EPA issued
press releases, .public notices, fact sheets, and a proposed plan.
Following the March 29 meeting, a public comment period was opened
for 30 days, ending on April 28, 1988.
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-49-
The majority of comments received during the comment period were
from citizens concerned that the recommended alternative
(Alternative 3) focused primarily on the potential for
earthquake-induced failure of the remedial action .and the
possibility of Kentucky Dam failure upstream, with subsequent
failure of the. remedy. Comments during the public meeting and
those received during the comment period favored Alternative 7,
vitrification of the landfills and burn pit/burial area over the
recommended alternative.
A responsiveness summary has been prepared to summarize community
concerns and to provide a response to those documents received. A
transcript of the March 29, 1988 RI/FS public meeting is available
for review in the Administrative Record.
-------
RESPONSIVENESS SUMMARY
B.F. GOODRICH/AIRCO SITE, CALVERT CITY, KENTUCKY
This community relations responsiveness summary is divided into the
following sections:
SEX:TION I. Overview: 'Ibis section discusses EPA I S recoomer1ded
alternative for remedial action and public reaction to this alternative.
SEX:TION II. Background on Camtunity Involvement and Concerns: This
section provides a brief history of community interest and concerns raised
during remedial planning activities at the B.F. Goodrich/Airco sites.
SEX:TION III. Surnmary of Major Catments Received During the Public Ccitment
Per iod .and EPA Responses to Those Ccmnents: Both the cooment and EPA I S
response are provided.
SEX:TION IV. Remaining Concerns: This section describes remaining
community concerns that EPA should be aware of in conducting the remedial
design and remedial action at the B.F. Goodrich/Airco sites.
I.
OVERVIEW
Prior to and at the time of the RIfFS public meeting in March 1988, EPA
presented its preferred remedial alternative to the public. This
alternative addresses soil, sediment, and ground water contamination at
the sites. The recommended alternative sPecified in the Record of
Decision (ROD) includes: ground water monitoring, ~sition of deed
restrictions preventing residential development on B.F. Goodrich- and
Airco-<>wned property imnediately south of the landfills, construction of a .
flood protection dike around the landfills, upgrading of the landfill clay
caps, installation of leachate extraction sumps in the landfills and burn
pit area, extraction and treatment of contaminated ground water,
excavation of contaminated surface soils and sediment with subsequent
placement of these materials in the burn pit, placement of an organic
vapor recovery systan and RCRA cap over the burn pi t..
The communi ty, in general, does not favor selection of the recarrnended
alternative. A preference for the vitrification alternative was
expressed.
BACKGROUND ON Ca-1MUNITY INVOLVE1'1ENT AND COOCERNS
II.
The B.F. Goodrich/Airco sites are located on the eastern edge of a heavily
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-2-
industrialized area approximately two miles northeast of Calvert City,
Kentucky. Seven major industrial plants are located in the vicinity of
the sites. Ccmnunity interest at the B.F. Goodrich/Airco sites is strong
and became apparent when the sites were placed on the National Priorities
List in the ~arly 1980's. Community concerns, as expressed during the
public meetings, cooment period, and RIjFS, seem to center around
area-wide health concerns. The issue of air emissions by the local
industries was of particular concern to the community. Additional
concerns centered around the possibility of failure of the upstream
Kentucky Dam and potential seismic acti vi ty in the region and what effect
these would have on the integrity of the recommended alternative.
At the writing of this Responsiveness Summary at least one citizen's group
intends to apply for EPA's Technical Assistance Grant to receive
assistance in interpreting the conclusions and findings of the RIjFS.
III.
SUMMARY OF PUBLIC COMMENTS REX:EIVED DURING THE PUBLIC Ca-1MENT PERIOD
AND THE EPA RESPONSES TO THE COMMENTS
1. Several commenters stated that the public has been deprived of the
right to participate in the remedy selection process that is guaranteed by
Congress and EPA statutes. .
EPA Response: The assertion that the public has been deprived of the
right to.participate in the selection process is not correct. Prior to
release of the Remedial Investigation (RI), Feasibility Study (FS), and
Endangerment Assessment (EA) reports to the repositories on March 15,
1988; EPA maintained an open line of communication with various citizen
and environmental groups. A public meeting was held on May 28, 1986 prior
to commencement of the RI field work. In October 1987, EPA established an
Administrative Record in the Calvert City, KY repository. This
Administrative Record contains all progress reports, correspondence, etc.
used towards preparation of the Record of Decision. On March 29, 1988,
EPA held a public meeting on the RIjFS and preferred remedial al ternati ve
at the Calvert City Elementary School. This initiated the Public comment
period which ended on April 28, 1988. The Public was provided with the
opportunity to review the RI, FS and EA reports for 44 days prior to
closing of the public carment period, more than twice the required minirntm1
public comment period of 21 days (3 weeks) as specified in the current
National Contingency Plan (tCP). The Administrative Record was available
for review for six months prior to closing of the public cooment period.
2. The Citizen's Clearinghouse for Hazardous Waste made the comment that
there was an insufficient number of background samples collected and
analyzed.
EPA Response: Collection of additional background samples is not
necessary. Background samples collected as part of the Remedial
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Investigation corresponded with regional soil and water background levels.
3. The Citizen's Clearinghouse for Hazardous Waste commented that the
issue of bank storage during flood events was not sufficiently analyzed.
EPA Response-: 111is assertion is not correct. An extensive program was
conducted to examine historical water level data, including analysis of
wells during the 1982-83 flood event, in conjunction with a detailed
evaluation of water level data in numerous recently-installed monitor
wells.
This data concluded that the aquifer beneath the B.F. Goodrich/Airco site
is recharged by the Tennessee River during flood events through bank
storage. It was determined that contaminant plume movement beneath the
site is not affected by bank storage except on a very localized scale
(tenths of a foot) and thus, should not create a threat to the upgradient
Calvert City wellfield.
4. The Tennessee Valley Authority carmented that it should be noted in
the Final RI Report that the Kentucky Dam is operated for navigation and
- flood control and, to the extent consistent with these primary purposes,
for proouction of power. It should also be noted that TVA has no wr i tten
cammittment to maintain a 20,000 cfs discharge if there is a need to
conserve water upstream and navigable elevations in the tailwater are
being maintained by other mechanisms.
EPA Response:
It will be so noted.
5. The Citizen's Clearinghouse for hazardous waste commented that EPA
failed to establish whether the landfills were "leaking" and that there is
no technical basis provided in the RI report for establishing the burn
pits as the primary source of ground water contamination.
EPA Response: The RIreport does provide a technical basis for
establishing the burn pits as the primary source of ground water
contamination. A review of background information regarding historical
waste practives was conducted in conjunction with a review of the findings
of the remedial investigation. The conclusions of these reviews are
presented in Section 5.5, Nature and Extent of -Ground Water Contamination.
A second plausible scenario for ground water contamination source is also
presented in Section 3.2, Ground- Water Contamination of the Record of
Decision which identifies the landfills as a contributing source of
contaminationh although minor in comparison to the burn pit area.
6. TVA comnented that the possibility of contamination of the deep
aquifer in the Mississippian limestone bedrock beneath the alluvial
deposits has not been addressed.
EPA Response:
Two fairly distinguishable plumes of contamination in the
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alluvial aquifer beneath the site were identified during the RI, a deep
and shallow plume. '!be shallow plume is much more concentrated than the
deep plume. 'Ihe RI data indicates that the deep contaminant plume is
situated above the limestone bedrock with little if any vertical
migration. Figure 35 of the RI Report presents a vertical cross-section
of the EDC contaminant plume. The possible solution channel noted at
moni tor well GA-22 is northeast of the landfills/burn pit area on the
floodplain and not in the direction of contaminant plume migration
(north-northwest).
The Mississippian-aged Warsaw Formation (limestone bedrock bnmediately
underlying the alluvial aquifer) was intersected by nine boreholes during
the RI. Visual observation of rock cores taken at four different borings
concluded that the rock is hard and massive. In 1962, a deep boring into
the limestone bedrock underlying the Warsaw Formation, the Fort Payne
Formation, described this rock as a massive crystalline limestone free of
joints and solution cavities.
Figure 7 of the RI illustrates the location of ground water and surface
water users within a 3~ile radius of the site. All users are located
upgradient or lateral to the site; bank storage during flood conditions
does not induce contaminant plume migration beyond site boundaries.
7. TVA carmented that differences in analytical data between laboratories
should be discussed in Section 9.0, Quality Assurance/Quality Control of "
the RI report. . .
"EPA Response: Section 9.0 of the RI Report discusses the OA/rt::. that went
in to the sampling procedures, sample chain-of-custody, laboratory data
quality, and data management on samples used towards preparation of the
RIfFS project reports. It is neither relevant nor appropriate to dicuss
the rejected sample data in the RI report. All samples were collected and
prepared in accordance with EPA Region IV Standard cperating Procedures;
EPA or its representatives provided oversight during this collection and
preparation of samples. All data used in preparing the RIfFS reports
underwent extensive OA/rt::. checks by EPA's Environmental Services Division
and was deemed adequate for use.
8. TVA ccmnented that i 2 should be noted in the RI report that the
drainage area of 710 mi. referred to on RI page 6-2 is for the
Tennessee RIver below Kentucky Dam20nly. '!be drainage area of the river.
upstream of the site is 40,200 mi. . Also, it should be noted that
Wilson Dam on the Tennessee River in Alabama was closed in 1924; flows at
this site were not regulated until 1944 with closure of Kentucky Dam.
EPA Response:
It will be so noted.
9. Two carmenters inquired if the number of surface water and sediment
samples collected from the Tennessee River was adequate.
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EPA Response: 'ft1e importance of the Tennessee Ri ver as a source of
navigation, danestic water supply, primary and secondary contact
recreation, and wam water aquatic habitat is realized. The RI
conclusively detemined that the contaminant plume has not reached the
Tennessee River. 'ft1e remediation of the drainage ditch north of the
landfills demonstrates the recognition of the river's many uses. 'ft1is
di tch contained low levels of a PCB canpound of unknown origin. 'ft1e
Endangerment Assessment concluded that these sediments were within the
target risk range; however, the di tch will be remediated due to the
bioaccumulationpotential of PCB. .
In light of the absence of ground water contaminants entering the
Tennessee River, additional s~1ing of the river- is not necessary.
10. One citizen carmented that the monitor well spacing at the sites was
inadequate towards reaching the conclusion that the contaminant plume had
not reached the Tennessee River.
EPA Response: The current number of monitor wells is sufficient for
defining the extent of the ground water contaminant plume. Aside fram
installing monitor wells every foot (technically impossible) assumptions
have to be made in developing plume contours between well points.
11. T'VA inquired about the differences in EPAaoo Contract Laboratory
analytical data for a Tennessee River sedUnent sample. .
EPA Response: SD-TR2A and SD-TR2B, in Table 58,. Sed Unent. Sample .Results -
Semi-Volatiles of the RI report, are duplicate 'samples; neither sample
detected 2-Methylnaphthalene. EPA's split sample detected an estimated
concentration of 0.170 mg/L. The average concentration of .
2-Methylnaphthalene in ground water at the si te was less than one part per
billion; the high~st concentration was less than one part per million. A
discrepency in split sample data concerning a prevalent site contaminant
would be sufficient reason to resolve the discrepency by resampling;
however, this was not the case. .
12. TVA inquired about the preparation of surface water aoo sedUnent
samples as outlined in Appendix D to the RI report, Technical Memorandum:
Task 14 - Surface Water and Sediment. sampling and Analysis. Was EPA
Method 624 followed during collection of samples?
EPA Response: Yes. 'ft1e appendix will be revised to state that sediment
samples for VOC analysis were collected and prepared in accordance with
EPA Method 624. An "approximate 10 percent air space" was not left in
sediment samples collected for VOC analysis.
13. T'VA questioned the appropriateness of the State's regulation of
discharges to the Tennessee River independantly versus assessing the
cumulative Lmpacts of all discharges to the river.
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EPA Response: The State is currently addressing the c\m\ulative impacts
issue and reviewing the KroES program.
14. The Citizen's Clearinghouse for Hazardous Waste questioned the
appropriateness of using Alternate Concentration Limits for establishing
ground watet clean-up goals. It was suggested that Ambient Water Quality
Cri teria or f'CLs be applied at the site versus in the mixing zone of the
Tennessee River.
EPA Response: Applicable statutory language concerning clean-up standards
under Superfund Law can be found in Section 121 (d) (2) (8) (ii) of the
Superfund Amendments and Reauthorization Act (SARA). Section 121 of SARA
does not allow any increase of contaminants in off-site surface water.
Since clean-up goals must be based on sane finite number, the ground water
model used to develop clean-up goals reflects the large dilution factor in
the Tennessee River and is based on Ambient Water Quality Criteria or .
Maximlml Concentration Limits not being exceeded in the river. AWa:; or
MCLs are not applied at the site because there are no users of ground
water at the site or downgradient of the site. Deed restrictions on the
sites and Kentucky statutes precluding residential development on
floodplains prevent future users of the ground wa~er at or downgradient of
the site. Therefore, applying MCLs or AWr;j:. at the site is not
appropriate. ----
15. One commenter stated that excavation alternatives were not considered
in the remedy selection process and went 0t:1 to suggest that contaminated
soil be excavated one "cell" at a time.
EPA. Response: Excavation of source areas was considered during the
evaluation of alternatives. Off-site disposal is a least favored remedy
that merely relocates the contaminants. The remedy in the Record of
Decision involves containment of the waste in the burn pit area. Treatment
of the contaminants will be accomplished via organic vapor recovery system
and the stripping action of soil water over time.
16. The Citizen's Clearinghouse for Hazardous Waste stated that the
indicator chemicals selected do not accurately reflect the most common
toxic contaminants found at the site.
EPA Response: There is no pre-determined number of indicator chemicals
appropriate for all sites. Between 5-19 chemicals would be a manageable
number. However, if a very large number of chemicals has been detected at
a si.te, it may be wise to select more indicator chemicals. The number and
identity of indicator chemicals selected is a site-specific
determination. Thirteen indicator chemicals were selected for the B.F.
Goodrich/Airco sites; this adequately reflects the large number of
contaminants detected. The canpounds that the carmenter suggested be
included in the indicator chemical list (vinyl chloride,
l, 2-dichlorobenzene, l, 2-transdichloroethene, chloroethane, and toluene)
were evaluated during the indicator chemical selection process. It was
determined that the indicator chemicals selected are the most appropriate.
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17. Several cannenters, during the publ ic meeting and carment period,
stated that the evaluation of remedial alternatives failed to take into
consideration the proximity of the sites to Kentucky Dam and the potential
for Kentucky Dam failure - what Lmpact this failure would have on the
integrity of. the remedy.
EPA Response: Consideration of the potential failure of the Kentucky Dam
is beyond the scope of a reasonable evaluation of remedial alternatives in
light of the fact that there is no reason to question the structural
integri ty of the Kentucky Dam.
18. Several cannenters, during the Public meeting and c
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offered. EPA and the NUS Corporation provided oversight. to RI/FS
activities conducted by Dames & Moore and B.F. Goodrich and The BOC Group,
Inc. (Airco). Nlmerous other parties within EPA revi~ the RI, FS and
Endangerment Assessment reports and conclusions and interpretations
contained there~n that were prepared by Dames and Moore. It is the
conclusion of this Agency that Dames and Moore conducted the RI/FS at the
B.F. Goodrich/Airco sites in a technically sound and professional manner.
21. The Citizen's Clearinghouse for Hazardous Waste commented that the FS
only considers one permanent remedy for cleaning up the site. The
Clearinghouse went on to suggest that".. .other permanent treatment
technologies exist that were not considered that may be appropriate for
use at this site. Several candidates include infrared incineration...,
Advanced Electric Reactor (AER)..., and certain biological treatment
systems...". .
EPA Response: A wide range of technologies, permanent or otherwise, was
considered during the technology screening process, including incineration
and biological treatment. Incineration was discarded due to the
associated potential air pollution problems and cost-effectiveness. The
remedy provides for the possibility of using biological treatment as part
of the air stripping process. Permanent solutions are to be employed to
the maximum extent practicable. The remedy's treatment and containment
canponents provide. protection to pub1.ic health, welfare, and the .
environment. Numerous. measures are incorporated to ensure the long-term
integri ty of the remedy. An extensive monitoring program will be
implemented over a 30-year period to continuously evaluate the remedy's
adequacy. Should it be determined during this period that the remedy is.
not attaining the required perframance criteria, the Record of Decision
may be revised to incorporate technology that will meet the performance
criteria. If revisions to the Record of Decision. are necessary, the
public will have an opportunity to comment on the proposed revisions prior
to their implementation.
22. One commenter stated that no provisions were made for treatment of
heavy metals in the leachate.
EPA Response: The Remedial Investigation identified organic compounds as
the most prevalent compounds requiring remediation, although inorganic
canpounds (metals) were detected in the ground water, two of which
exceeded the primary drinking water standards. Though the remedy centers
primarily around the treatment of organics, leachate analyses will include
scans for metals prior t~ treatment and disposal.
23. One cammenter stated that rainfall in the diked area (surrounding the
landfill) would increase flow to the aquifer due to hydraulic pressure.
This would result in an unrealistic amount of treatment capacity for
removal of rain water.
EPA Response:
The landfill caps will be upgraded and contoured to divert
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rain water off and around the landf!J,lS to prevent ponding. With the
required min~um permeability of l~ cm/sec for the landfill clay caps,
the majority of rain water will not penetrate the landfills.
24. One commenter felt it would be appropriate to place warning signs on
the fence s~rr~unding the landfills.
EPA Response:
This ccmnent will be incorporated in the remedial design.
25. Air Products catmented that they should not be considered a
potentially responsible party at the Airco site since they did not dispose
of hazardous wastes or materials at the site.
EPA Response: 'Ihe waste Air Products disposed of contained hazrdous
constituents; therefore, Air Product's status as a potentially responsible
party remains. .
26. Air Products coomented that the Airco site and B.F. Goodrich site
must be considered separately by EPA in deciding on appropriate remedial
measures and for other purposes.
EPA Response: 'Ihe Airco and B.F. Goodrich sites are Separate sites on the
National priorities List; the sites were studied as one because of their
proximi ty and it was determined that one study would be more technically
and scieritifically sound as.well as cost-efficient. Two Records of
Decision have been written, although the remedy is the same. . EPA has an
administrative need for two RODs; no statutes exist that preclude EPA from
selecting one remedy for two sites.
IV.
REMAINING CONCERNS
The coomuni ty' s concerns surrounding the B. F. Goodr ich/Airco sites
be addressed in the following areas: community relations support
throughout the Remedial DesignjRemedial Action, incorporation of
comments/suggestions in the Remedial Design.. .
should.
Catmunity relations support during the Remedial DesignjRemedial Action
should consist of making available final dOCllnents (i.e. Remedial Design
Work Plan, Remedial Design Report, etc.) in a timely manner to both local
repositories and issuance of fact sheets to those on the mailing list to
provide the communi ty with project progress and schedule of events. 'Ihe
coomuni ty should be made aware that the design of the selected remedy will
incorporate design criteria to ensure long-teen integrity of the remedy.
At any time during the remedial design, remedial action, or for 3~ years
thereafter, if new information is revealed that could affect the
implementation of the remedy or, if the remedy fails to achieve the
necessary design criteria, the Record of Decision may be revised to
incorporate new technology that will attain the necessary performance
criteria.
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Community relations activities should remain an active aspect of the
Remedial Design;Remedial Action phase of this project.
During the Remedial Design, the appropriate earthquake engineering
technology shoul~ be employed to the maximum extent practicable. The
technology incorporated should be appropriate for containment facilities
for potential seismic risk of the region.
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