United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-90/063
September 1990
&EPA
Superfund
Record of Decision
Howe Valley Landfill, KY
-------
50272-101
REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Reclpienl'. Acce..lon No.
PAGE EPA/ROD/R04-90/063
4. Ti.. end Subti.. -. 5. Reporl D.le
SUPERFUND RECORD OF DECISION 09/28/90
Howe Valley Landfill, KY
6.
First Remedial Action - Final
7. Author(.) 8. Performing Org.nlzation RepI. No.
I. P8rformlng Orgalnlzation Name end Add.... 10. Projec:tlT.8klWork Unil No.
11. Contrac1{C) or GrenI(G) No.
(C)
(G)
12. ~ Org.nIza1Ion Name end Addre.. 13. Type 01 Repol1l Period Co"""
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplemenl8ty No...
115. Abatr.c1 (Umll: 200 wont.)
The 11-acre Howe Valley Landfill site is an inactive landfill in Howe Valley, Hardin
County, Kentucky. A Class IrA aquifer underlies the site, but is not currently used as
a drinking water source. Ground water flow is southeasterly toward Boutwell Spring and
Linders Creek. From 1967 to 1976, 2.5 acres of the site were used for disposal of
refuse and manufacturing by-products. In 1974, a State inspection revealed that acidic
liquid wastes were being dumped directly into the landfill, in direct violation of the
solid-waste disposal permit issued. Although the permit expired in 1974, the landfill
continued dumping operations until 1976. In 1988, EPA required the removal of 9,150
full or partially filled drums containing metal plating sludge, caulk, flammable
silicone polymers, and paint-like pigments; 1, 621 empty drums; 6,000 smaller containers;
and 3,000 cubic yards of loose waste from the site. State investigations in 1987 found
that the potential migration of this waste posed a drinking water hazard. Contaminant
levels for the underlying ground water system cannot accurately be monitored because of
the karst topography at the site. This remedial action focuses on reducing the source
contamination. The primary contaminants of concern affecting the soil are VOCs
including PCE; and metals including chromium.
(See Attached Page)
17. Document Anelyel. L De.crlptore
Record of Decision - Howe Valley Landfill, KY
Second Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: VOCs (PCE), and metals (chromium)
b. Id8ntifieniOpen-Ended Terme
Co COSA 11 Reid/Group
18. Ave/I.blily Sl8Iernent It. Sec:wlty CI... (Thl. Report) 21. No. 01 Plge.
None 211
20. Security CI... (Thl. Pege) '22. PrIce
Nnnp
", 272 (4-77)
(See ANSl-Z3t.18)
See In6truclion6 on ~vente
(Formerly NTIS-35)
Depertrnent 01 Commerce
-------
EPA/ROD/R04-90/063
Howe Valley Landfill, KY
Second Remedial Action - Final
Abstract (Continued)
The selected remedial action for the site includes excavating approximately 100 cubic
yards of soil from the outlying areas of the site cqntaining elevated inorganic levels,
followed by disposal offsite; excavating approximately 7,400 cubic yards of soil with
elevated concentrations of organics, follow~d by aeration; performing a treatability
study to ensure that an onsite aeration process will reduce organic concentrations in
soil to acceptable levels; onsite disposal of the treated soil; onsite air monitoring;
installing water diversion ditches to prevent water from running onto the aerating soil;
covering the area with soil and installing a vegetative cover over the entire site;
monitoring ground water at Boutwell Spring and at additional springs or wells; and
implementing institutional controls, such as deed restrictions, to limit .the property
and ground water usage. If the treatability study indicates that soil aeration will not
effectively reduce contamination to protective levels, a proposed contingency remedy
would include excavating, stockpiling, and transporting approximately 7,500 cubic yards
of contaminated soil to an offsite RCRA-approved landfill for disposal. The estimated
present worth cost of the primary remedial action is $394,524, which includes a total
O&M cost of $42,625 for five years. The estimated present worth cost of the contingency
remedy is $3,852,000, which includes a total O&M cost of $42,625 for five years.
PERFORMANCE STANDARDS OR GOALS: Health-based soil action levels have been calculated
for the site-specific conditions, and include PCE 7.50 mg/kg and chromium (VI)
400 mg/kg.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
HOWE VALLEY LANDFILL
HOWE VALLEY, KENTUCKY
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION
REGION IV
ATLANTA, GEORGIA
AGENCY
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SECTION
II.
TAB~E OF CONTENTS
PAGE
I.
SITE LOCATION AND DESCRIPTION.................................1
LOCATION. . . .
TOPOGRAPHY.
......1
.............
......
.............
.........
................
......
......1
.............
SOIL. . . : . . . . . . . . . . . . . . . . . . . . .
........
......4
.........
SURFACE WATER AND SEDIMENTS..
GROUNDWATER FLOW.............
LAND USAGE........................
DEMOGRAPHY. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
GROUNDWATER RESOURCES..................
NATURAL RESOURCES......................
......4
.......
...........
.......
.................5
...........
............5
............5
...........
.........
..............5
.........
..............7
SITE HISTORY AND ENFORCEMENT ACTIVITIES.......................7
DISPOSAL OPERATIONS.........
EARLY INVESTIGATIONS........
REMOVAL ACTIVITIES..........
...........
......
......7
...........
......
... ........ ........ ....7
. . . . . . . . . . . . . . . . . . . . . .10
......
A.
B.
C.
D.
E.
F.
G.
H.
I.
BLUE-GRAY PLATING SLUDGE.................................. 13
SOLID SILICONE............................................ 13
SEMI-SOLID SILICONE...................................... .13
LIQUIDS. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
........
. . . . . . . 18
.......
INSULATION MANUFACTURING CHEMICALS........................18
COPPER-CYANIDE BEARING SLUDGE........................
OILY WASTE TRENCH....................................
NON-CONTAINERIZED SILICONE POLYMERS..................
DOMESTIC TRASH AND INSULATION PILE........................24
. . . . . 18
.....18
.....18
POST REMOVAL INVESTIGATIONS...................
DYE-TRACE STUDIES.............................
LOW-FLOW CONDITIONS........................
HIGH-FLOW CONDITIONS.......................
.............. .24
. . . . . . . . .. . . . . .24
. . . . . . . . . . . . . . .24
. . . . . . . . . . . . . . .31
A.
B.
ENVIRONMENTAL SAMPLING...........
AIR MONITORING................
SURFACE WATER.....................
...............
......
. . .31
...31
...33
...33
A.
B.
...............
......
...............
......
1-
2.
OFF-SITE SURFACE WATER..............................
ON-SITE SURFACE WATER.................................. 33
C.
SED IMENT S. . . . . . . . . . . . . . . . . . . . .
..................
..........33
D.
E.
1. OFF-SITE SEDIMENTS..............."......
2. ON-SITE SEDIMENTS......................
GROUNDWATER. . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .33
. . . . . . . . . . . .33
. . . . . . . . . . . . . . . . . . .34
. . .34
SOIL. . . . . . . . . . . . . . . .
........
......
........
.........
1. BACKGROUND SOILS................................
2. OUTLYING SOILS......................................
3. CENTRAL AREA SO ILS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SOIL AERATION PILOT STUDY...................................
. . .34
. . .34
.35
.35
-------
III.
VII.
VIII.
-2-
HIGHLIGHTS OF COMMUNITY PARTICIPATION........................42
IV.
SCOPE AND ROLE OF RESPONSE ACTION............................45
V.
. . . .45
. . . .46
. . . . . . . . . . . . . .46
. . . . . . . . . . . . . .46
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46
. . . . . . . . . . . . . . . . . . .46
. . . . . . . . . . . . . . .46
....46
..............47
....47
. ..... . .. . .. .. .. . ...47
SUMMARY OF SITE CHARACTERISTICS.................
A. NATURE AND EXTENT OF CONTAMINATION...........
B. SURFACE WATER................
1. ON-SITE SURFACE WATER.....
2. OFF-SITE SURFACE WATER..
C. SED IMENTS. . . . . . . . . . . . . . . . . . . . . . . . . .
1. ON-SITE SEDIMENTS...............
2. OFF-SITE SEDIMENTS..................
D.GROUNDWATER.............
1. BOUTWELL SPRING.....
2. PIRTLE SPRING..................
E. ON-SITE SOILS.....................
1. INORGANIC ANALYSIS................................
2. ORGANIC ANALYSIS.................................
3. CYANIDE ANALYSIS.................................
.......
......
......
............
.......
......
.........
.....47
.....47
. . . . . .52
......56
......
F.
SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. .... . . . . . . . . . . . . . ..56
VI.
PATHWAYS OF MIGRATION........................................ 68
SUMMARY OF SITE RISKS........................................ 68
IDENTIFICATION OF CONTAMINANTS OF CONCERN....................68
DOSE-RESPONSE EVALUATION..................................... 69
EXPOSURE AND TOXICITY ASSESSMENT.............................71
RISK CHARACTERIZATION........................................71
A. CURRENT SITE USE.............................
1. RISK FROM ON-SITE SURFACE SOIL.................
2. RISKS FROM ON-SITE SURFACE WATER.........
3. AIR EMISSIONS.................
B. FUTURE SITE USE.................. ....................73
1. RISKS FORM ON-SITE SOIL....... .....................73
2. RISKS FROM FUTURE ON-SITE DRINKING WATER WELLS.........79
ENVIRONMENTAL RI SKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
UNCERTAINTY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
........71
......
....72
....72
..........
...........73
. . . . . . . . . . . .82
HEALTH RISK SUMMARY...............
......
....82
....82
...........
......
SUMMARY OF SITE RISKS..............
........
.........
DESCRIPTION
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
OF ALTERNATIVES.................................. 82
ONE. . . . . .
......
. . . . . . . . . .83
..............
..........
TWO. . . . . . . . . . . . . . . . . . . .
THREE. . . . . . . . . . . . . . . . . .
FOUR. . . . . . . . . . . . . . . . .
..............
. . . . . . . . . . . .83
.............
. . . . . . . . . . . . .83
.........
. . .85
. . .86
. . . . . .
FIVE. . . . .
............
..........
SIX. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
..............87
-------
IX.
XIII .
-3-
APPLICABLE OR RELEVANT AND APPROPRIATE REQUlREMENTS..........87
. ACTION-SPECIFIC ARARs...... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .87
CONTAMINANT-SPECIFIC ARARs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .88
X.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ANALYSIS.....89
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT....... 89
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
. REQO'IREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.89
...........91
. . .. . . . . . .. .. . . . . . . . . . . . .91
.............................. .91
. . . . . . . . .. . . . . . . . . . . . . . . . . . . . . .91
COST. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
MOBILITY, OR VOLUME........
EFFECTIVENESS. . . . . . . . . . . . .
REDUCTION OF TOXICITY,
LONG-TERM
SHORT-TERM EFFECTIVENESS......
IMPLEMENTABILITY..............
STATE ACCEPTANCE.........................
......92
..............
COMMUNITY ACCEPTANCE..................
......93
.................
XI.
..... ............. ..... ...
. . . .93
. . . .94
THE PREFERRED ALTERNATIVE..
STATUTORY DETERMINATIONS...
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT...............95
COMPLIANCE WITH ARARs........................................ 95
COST EFFECTIVENESS........................................... 95
................... .
......
UTILIZATION OF PERMANENT SOLUTIONS AND
TREATMENT TECHNOLOGIES OR RESOURCE
TECHNOLOGIES TO THE MAXIMUM EXTENT
ALTERNATIVE
RECOVERY
PRACTICABLE. .
.........95
XII.
DOCUMENTATION OF SIGNIFICANT CHANGES.........................98
APPENDIX A - RESPONSIVENESS SUMMARY............................
ATTACHMENT A[[[
ATTACHMENT B[[[
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TABLE OF CONTENTS FOR FIGURES
SECTION
PAGE
FIGURE
l....~......
[[[ .2
FIGURE
2...................... .
........
............................ .3
FIGURE
3. -. . .
...................
................................ .6
FIGURE
4[[[ .8
FIGURE
5.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .11
FIGURE
6.....
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 12
FIGURE
7.....
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 27
FIGURE
8.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 24A
FIGURE
9.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 31A
FIGURE 10[[[ 32
FIGURE 11[[[ 33A
FIGURE 12[[[ 37
FIGURE 13[[[ 39
FIGURE 14[[[ 40
FIGURE 15[[[ 41
FIGURE 16[[[ 43
FIGURE 17[[[ 44
-------
-2-
FIGURE 28..
......
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
FIGURE 29..
. . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . .67
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,-
TABLE OF CONTENTS FOR TABLES
SECTION
PAGE
TABLE
1. . . . . . . . . .-. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 & 15
TABLE
2.....
.......
..................
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 & 17
TABLE
3.....
.......
..................
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 & 20
TABLE
4................................. .
.. .. . . .. . . .. . .. . .. . .. . . . .. . .. . .. .. . .. .. .. .. . . . .. .. . .. .. .. 21 & 22
TABLE
s.............
. . . . . .. . .. . .. .. . . . . . . . . . . .. . .. . . .. .. . . . . .. .. . .. . .. .. .. . .. . . . . . . . .. .23
TABLE
6......
. ... .. .. . .. . . . . .. ... . . . .. .. . .. . .. ... . . . . .... .. .. . . . . . .. .. . . . . .. .. .. .. . .. .25 & 26
TABLE
7.. . .. . . . .. . . . . .. . . .. . . . .. . . .. .. . . .. . .. . .. .. .. . .. .. . . .. . . .. . . . .. .. . .. .. . . . .. .. .. . . . .28 & 29
TABLE
8.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 30
TABLE
9.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. 36
TABLE 10[[[ 38
TABLE 11[[[ 4B
TABLE 12[[[ 49
TABLE 13[[[ 53
TABLE 14.....................
........
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
TABLE
15. . . . . . . . . . . . . . . . . . . . . . . . . .
. .. .. .... . . . . . . . . ... . . . . . . . . . . . . .. . . . .57
TABLE 16[[[ 64
TABLE 17[[[ 74
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HOWE VALLEY LANDFILL SITE
HOWE VALLEY, KENTUCKY
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Howe Valley Landfill Site
Howe Valley, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for the Howe
Valley Landfill Site developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based upon the contents of
the Administrative Record for the Howe Valley Landfill Site.
At this time, the United States Environmental Protection Agency (U.S. EPA) and
the Commonwealth of Kentucky do not agree on the selected remedy. The
Commonwealth believes that KRS 224.877 is not addressed in this Record of
Decision; nor does the Commonwealth feel that the selected alternatives remove
or treat a sufficient quantity of the contamination contained in the on-site
soils. EPA, however, has carefully considered the risks associated with the
on-site contamination and feels that both the primary and the contingency
alternatives will be protective of human health and the environment at a
reasonable cost.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF REMEDIES
The final remedies address the remediation and/or removal of on-site soil
containing low levels of contaminants by reducing and/or eliminating, through
treatment, engineering and institutional controls, the risks posed by the
site. The selected remedial action for the Howe Valley Landfill Site includes
both a primary remedy and a contingency remedy. The primary remedy, removal
and on-site aeration, will involve a preliminary bench-scale treatability
study. Should the results of this study indicate that the contamination in the
soil will not be reduced to acceptable. health-based levels or soil action
levels, then the contingency remedy will be enacted.
The major components of the selected primary remedy include:
Excavation and off-site disposal of approximately 100 cubic yards of
soils that contain elevated concentrations of inorganics from the
outlying areas of the site,
-------
I --
!
Declaration - Page 2
Replacement of removed soils with clean fill dirt,
Implementation of a bench-scale treatability study to ensure that an
on-site ~ration process will reduce organic concentrations in soils
to acceptable levels,
Excavation and treatment, via' on-site aeration, of approximately 7,400
cubi~ yards of central area soils that contain elevated concentrations
of organics,
On-site air monitoring to insure adequate protection of workers and
nearby residents,
Installation of water diversion ditches to prevent water from running
onto the aerating soils,
Spreading of topsoil and installation of a vegetative cover over the
entire site upon completion of the aeration process,
Five years of quarterly monitoring of Boutwell Spring and additional
springs or wells that lay along the ground water conduit between
Boutwell Spring and the site; and
Placement of restrictions on the deed to limit the usage of the
property and its associated ground water.
The major components of the contingency remedy include:
Excavation and transport to an off-site Resource Conservation and
Recovery Act (RCRA) approved landfill of approximately 7,500 cubic
yards of contaminated soil from both the outlying and central areas of
the site,
Installation of water diversion ditches to prevent water from running
onto the excavation areas,
Replacement of excavated soils with 7,500 cubic yards of clean fill
dirt,
Reseeding of site once clean fill dirt is spread across the site and
then graded,
Five years of quarterly monitoring of Boutwell Spring and additional
springs or wells that lay along the ground water conduit between
Boutwell Spring and the site; and
Placement of restrictions on the deed to limit the usage of the
property and its associated ground water.
-------
Declaration - Page 3
STATUTORY 9ETERM!NATIONS
The selected primary and contingency remedies are protective of human health
and the environment, comply with all requirements that are legally applicable
or relevant and appropriate to the remedial action, and are cost-effective.
These remedies utilize permanent solutions and alternative treatment
technologies to ~he maximum extent prac~icable, and satisfy the statutory
preference for remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element.
The karst topography associated with the Howe Valley Landfill Site makes
installation of wells to monitor ground water virtually impossible.
Confirmation that a well intercepts a ground water conduit would require
numerous dye-trace studies. Due to this fact there is a slight possibility
that ground water underlying the site could contain undetected contamination
that is associa~ed with the site which, in turn, could migrate off-site. To
ensure that any off-site migration does not become a threat to human health or
the environment, quarterly sampling of the water at Boutwell Spring and any
other springs or wells located along the ground water conduit between Boutwell
Spring and the site will occur for a period of five years. At the completion
of the five year period, a risk assessment for both the on-site soils and
off-site ground water will be conducted to ensure that the implemented remedy
continues to provide adequate protection of human health and the environment.
, J r - , r"
~-'-' \. ,~,' "'-'f'''' i.--.
I Greer C. Tidwell
Regional Administrator
-~ "
SEP 2 8 1990
Date
-------
HOWE VALLEY LANDFILL SITE
HOWE VALLEY, KENT~CKY
SITE LOCATION AND DESCRIPTION
Location
The Howe Valley Landfill Site, consisting of approx~ately 11 acres, is located
in Hardin County, south of Vertrees, Kentucky. It is 1.4 miles south of State
Road 86 at th~ end40f Tom Duvall Lane (Figure 1). The site lies' along the
boundary of the Constantine and Howe valley United States Geological Survey
(USGS) Quadrangle Maps at coordinates of 37.40'0~ N latitude and 86.07'30" W
longitude. The site consists of a sparsely vegetated field located in a
topographic basin. Between 1966 and 1976, approx~ately 2.5 acres of the site
were cleared for disposal purposes.
Topoaraphv
The topography of the site is characterized by gently to moderately rolling
uplands (rough in places) with lower-lying karst plains (Figure 2). The areas
north and northeast of the site are karst plains, characterized by sinkholes,
sinking streams, springs and solution features. Elevation of the karst plain
ranges between 640 and 730 feet above sea level. Topography throughout the
rest of the site is characterized by relatively steep-sided ridges and
valleys. The Cow Cliff forms a topographic ridge on the eastern and southern
borders of the site. Approx~ate elevation in the Howe Valley area ranges from
600 to 900 feet above sea level while the the site ranges from 600 feet to 710
feet above sea level.
Drainage from the site flows east into the on-site sinkhole; a large depression
approx~ately 150 feet long and 30 feet wide with the longer dimension trending
northeast to southwest. Several swallets, ranging from 10 to 15 feet in
diameter and 5 to 10 feet in depth, have developed within this sinkhole.
During periods of heavy sed~entation, the diameter of the swallet openings
have been as narrow as 2 to 6 inches. The site is located within a closed
basin, therefore no off-site sinkholes receive surface run-off from the site.
The underlying strata of the site are part of the Mississippian Plateau; a
large belt of alternating beds of sandstone, shale and soluble carbonates
extending northward into Indiana, west to Missouri and south to Tennessee. The
site is situated upon the Paoli Limestone, a light-gray, ledge-forming
limestone 50 feet thick. Underlying the Paoli is the yellowish gray to light
gray Ste. Genevieve Limestone. Both the Paoli and Ste. Genevieve L~estones
serve as aquifers. The formations overlying the Paoli L~estone in the
surrounding ridges include:
Hardinsburg Sandstone
Haney L~estone Member
Big Clifty Sandstone Member
Beech Creek Limestone Member
Reelsville L~estone
Sample Sandstone
( 5+
( 15
(100
( 15
( 20
( 30
feet
feet
feet
feet
feet
feet
thick)
thick}
thick)
thick)
thick)
thick)
-------
Determination - Pa e 2
o
I
15
I
I \
~
MIL..£S
N
I
OWENSBORO
SITE 0
~~
~~ \'~
~
N
I
EUZABETHTOWN
, a MILES
o
I
2
I
MILES
FIGURE 1
LOCATION OF HOWE VALLEY LANDF~LL
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I--
I
Determination - Page 3
(~2 )J;7'~)~ ~ ,/(i?)A\~JI) ~ L-/ ~(d;
~ Ifm~- \~J~~\(1 - \ ~/~?:
A -.N (/ - " ~ ,)" 680 f (- (..- .1
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~:~r~ ) \ l Vi r'~ :{.~ ;~ y' I~~~/ '
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~!.' '" ~~:/> -;/ })~2I VJ~)I ~~~t~~\ I JOGN .
~J~~~~'«~ ~~ ~ :)~ ~~ ~ -P ~ ~ ,\
/?/ ~~'2" ~ -'. ( ~'- .~ ~ J (~, ~ LEGEND
," ~~Jt ~~ )Y7--o...::z- ~ U Jj1~ /(X;(~;) .
,I. ~';S> k Il., ;!' - """,--I. 7'":!i'J 'I mE UN(
,~. '(l J~Tr~", ~/ ( J
1':" ~~ ;/'",~"" F- "
_1 \. ~~~ // / ~~ ~ /J , ,,:/ UNIUPROV£D ROAD
. ~~~~-~"-='~/ / 7- '\ ~ ~)
r-. ]~P (~::s:: ~\ ,,~~ I . CONfO,UlmM. . 2 fEET
- ~ ~ ~~ ~ If ~ E \ \\~ 81; GRID CEllS ARE 100' )( 100'
~v ~ ~~~ ~~ fd;~ ~ \~\\ (>~ roPOCRAPH~ SOURre TURNER ENGINHRING
FIGURE 2
TOPOGRAPHY OF THE HOWE VALLEY LANDFILL AND SURROUNDING AREAS
-------
Determination
Page 4
Beaver Bend L~estone and
Mooretown Formation
Paoli L~estone
Ste. -Genevieve
( 30 feet
( 50 feet
(170 feet
thick)
thick)
thick)
Strata dip to the southwest at approx~~tely 1 foot per 100 feet. Considerable
faulting has occur~d west of the site. The two major faults in that area are
the Pole Bridge Fault and the Mount Olive Fault. Both are thought to be
inactive and are located about two miles west of the site. The fault lines are
in a northeast-southwest direction. Minor faulting has occurred to the north,
northwest, southwest and south-southeast of the site. The closest minor faults
are found one mile west of the site and are oriented in a northeast-southwest
direction.
Soil
The soil in the vicinity of the site is of the Caneyville-Hagerstown
Association, which is comprised of moderately steep to gently sloping, well
drained soils and rock outcrops on hilly karst uplands. The Caneyville soil,
found on hillsides, is well drained and sloping to moderately steep. It has a
loamy plow layer and a clayey subsoil that is underlain by l~estone. The
Hagerstown soil, found on ridges and side slopes, is deep, well drained, and
gently sloping to moderately steep. It has a loamy plow layer and a clayey
subsoil.
Surface Water and Sed~ents
Surface drainage in the area of the site is intermittent and drainage ditches
are truncated by sinkholes. The site itself is located in a closed 450-acre
hydrologic basin which drains to the on-site sinkhole. Surface drainage
becomes more dense to the west and southwest of the site. In these areas
dendritic stream patterns can be found adjacent to the sandstone capped
ridges. Ground water discharged at Boutwell Spring moves towards Linders
Creek, the pr~ary local base-level in the region. Both Boutwell Spring and
Linders Creek are southwest of the site. Linders Creek flows into the Rough
River which flows to the Green River and eventually to the Ohio-River near
Henderson, Kentucky.
Karst windows, such as Stiles Spring and Roaring Spring, are located near the
site. These windows are topographic depressions in which ground water is
discharged via a spring, flows along the surface for a short distance and then
returns to the subsurface through a sinkhole swallet or cave opening.
All sed~ents migrating from the site are carried by surface runoff draining
into the on-site sinkhole. Based upon data collected during the dye-trace
studies, these sed~ents are discharged' at Boutwell Spring and eventually
travel to Linders Creek. Dye traces indicate that these sinks are not
connected to the site.
-------
Determination - Page 5
Ground Water Flow
Surface runoff in the karst plain, which includes the site, is intercepted by
numerous sinks. Ground water continuously tries to reach a base-level by
moving through discontinuous joints and cavities that characterize a karst
system. Linders Creek represents the p~imary base level toward which ground
water below th~ site moves towards. Dye trace studies were conducted at the
site and north of the site by the PRP's contractor and the USGS, respectively.
Results indicated that water leaving the site by way of the on-site sinkhole,
traveled southwest towards Boutwell Spring and Linders Creek. The USGS dye
trace study indicates the presence of a ground water divide to the north of the
site, between Pirtle Spring and the Howe Valley Landfill. Pirtle Spring serves
as the drinking water supply for the Howe Valley area. This ground water
boundary implies that ground water flowing from the site travels on the
opposite side of the divide, away from Pirtle spring; thus, a natural barrier
prevents the possibility of ground water from the site contaminating the public
drinking water supply.
Land Usaae
Much of Hardin County is farmland and pastures used primarily for the
production of corn, soybeans, hay and tobacco. There are no known industrial
facilities located near the site. The land immediately adjacent to the site
consists of hilly woodlands. According to nearby residents, these woods are
popular for hunters stalking deer, rabbits, and raccoon. There are 13
inhabited houses, approximately 50 residents, along the 1.4 mile length of Tom
Duvall Lane. The nearest structure is a 250-acre farm located approximately
800 feet north of the site. The farm is a cattle and hog raising operation
that grows corn and soybeans as feed for the livestock. The nearest occupied
residence, two residents, is located 2,000 feet north of the site at the
terminus of Tom Duvall Lane. The nearest residence not on Tom Duvall Lane lies
one mile west of the site.
Demoaraphv
The site is named for the unincorporated community of Howe Valley located
approximately two miles northeast of the landfill. Howe Valley proper, made up
of approximately 700 residents, centers around the intersection of Howe Valley
Road and Hardinsburg Road (State Highway 86). The site also lies in census
district 171 (Figure 3). The total population of this district is 1,890.
Elizabethtown, a city of approximately 16,000 people and the County Seat, is
located fifteen miles east of Howe Valley. This city is the nearest urban
center.
Ground Water Resources
Pirtle Spring, located near Vertrees, Kentucky, taps the St. Genevieve
aquifer. This spring is the public water supply for approximately 35,000
residents in the surrounding area, however many residents in the vicinity of
the site use private wells as their drinking water source.
-------
Determination - Page 6
SOURCE: CENTER FOR DEMOGRAPHIC
AND POPULATION STUDIES
UNIVERSITY OF UOUISVLLE
BOUNDARY
MARKER
9
3500'
I
SCALE
FIGURE 3
BOUNDARIES OF CENSUS DISTRICT 171
STATE OF KENTUCKY
-------
Determination - Page 7
Natural Resources
No National Parks,-National Wildlife Refuges, Indian Reservations or wetlands
occur in the immediate vicinity of the site. The primary habitat observed
around the site consists of mixed hardwoods and pines. Major tree species in
the Howe Valley area are black oak, red 'oak, poplar, yellow pine and cedar.
The site, whicn was cleared during disposal activities, is sparsely vegetated
and has only two major tree species; second-growth cedar and Scotch pine. The
pine trees were planted by the landfill operator sometime during the disposal
operations.
Two State and Federally listed endangered species are present in Hardin
County: the gray bat (Mvotis qrisescens) and the Indiana bat (Mvotis
sodalis). The nearest siting of the gray bat was recorded at Belt Cave, three
miles north of the site. No threatened species occur in Hardin County, however
the Henslow sparrow has been listed as a special concern by the Kentucky
Department of Fish and Wildlife. No fish species occur on-site. Frogs and
snapping turtles were observed in the on-site ponds, however, these ponds were
removed during the RIfFS. Other wildlife species observed on-site include:
box turtles, lizards, black snakes, copperhead snakes, deer, raccoons, opossum,
rabbits, squirrels, field mice, vultures, crows, red-tail hawks, screech owls,
r~ugh grouse and several species of smaller birds:
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Disposal Operations
Kentucky Industrial Services, Inc. (KIS) operated the Howe Valley Landfill Site
from 1967 to 1976 for the disposal of refuse and manufacturing by-products from
several Elizabethtown industries. To comply with new legislation passed in
1972 by the Commonwealth of Kentucky, KIS applied for and received a solid
waste permit to operate the site as an industrial landfill. Types of waste
reportedly disposed at the site consisted of manufacturing sludges, plating
sludges, galvanizing wastes, silicone polymers, insulation and insulation
by-products. Figure 4 depicts the areas used for disposal.
Earlv Investiqations
In May 1974, after a citizen complaint, the State Division of Waste Management
conducted a site inspection. The inspection report stated that acidic liquid
wastes were being dum~d directly into the landfill. This constituted a
violation since the state-issued solid waste permit did not allow the disposal
of liquid wastes at the site. At that time the permit did not differentiate
between hazardous and non-hazardous wastes. The permit officially expired in
1974, however the landfill was not closed until 1976. From that time until the
remedial investigation began, access to the site was limited but not
restricted.
-------
Determination - Page 8
PROBABLE -AREAS OF
BURIED DRUMS
TRASH PILES
CELOrOf PILES
RCPORTID LOCATION OF
o«.r WASTE
f ) PONDS
TOPOGRAPHIC SOURCE; TURNER
FIGURE 4
EXTENT OF WASTE PRIOR TO REMOVAL
-------
Determination - Page 9
A second site inspection conducted by the State Division of Waste Management in
1979 revealed that wastes from the site were killing on-site vegetation and
producing a foul od_or. The report also documented the death of three ponies
that grazed downslope from the site. Autopsies of the ponies revealed liver
abnormalities. These circumstances and the existing karst conditions prompted
the State to begin investigating the site and surrounding areas. Activities
included a dye-trace study to determine the direction of ground water flow and
surface water flow underneath and away from the site, off-site sampling of
nearby water sources to determine the extent of contamination and on-site
sampling of the soils and surface waters to identify waste components.
Sampling results suggested that contaminants from the landfill could
potentially migrate to Linders Creek and infiltrate the Green River Drainage
Basin. Travel time of the ground water, as determined by the dye-trace study,
was approximately 1,400 feet per day ( 1 foot per minute).
Upon request by the State, the U.S. Environmental Protection Agency's Field
Investigation Team (FIT), in 1984, completed a Preliminary Assessment and a
Site Investigation. As part of these studies, a geophysical investigation was
conducted to determine the down-gradient location of the solution channel and
to investigate the aerial extent of drum burial. As part of the attempt to
locate the solution channel, an electromagnetic survey and a dipole-dipole
resistivity survey were conducted. Interference from the materials buried at
the landfill and off-site topography prevented the identification of solution
features, however the resistivity survey did indicate an anomaly southwest of
the site. Unfortunately, it was not positively identified as a solution
channel and no additional attempt was made to further delineate or identify the
anomaly. A magnetics survey was conducted to identify the drum burial areas.
Results indicated that between 2,000 to 5,000 drums were buried in localized
po~kets in only 2.5 acres of the site.
Since the Howe Valley Landfill had the potential to contaminate the underlying
karst ground water system, the site was assigned a Hazard Ranking Score (HRS)
of 36.73. On June 10, 1986, (51 Federal Register 21106), the U.S. EPA proposed
that the Howe Valley Landfill Site be included on the National Priorities List
(NPL). The listing of the site became final on July 22, 1987, (51 Federal
Register 27623).
In September 1987, the U.S. EPA collected a subsurface soil sample from beneath
a partially buried drum and a sediment sample from an on-site pond. Substances
detected during analysis of the soil sample included cyanide and one organic
compound. The sediment sample contained a trace amount of cyanide and three
phthalate compounds. During this same time, water samples were collected from
Pirtle Spring, Bowe Valley Elementary School and five private wells in the
area. One well (Woodrow Stevens) initially tested high for lead and chromium,
however in a subsequent sampling both m~tals were below detection limits.
The potentially responsible parties (PRPS) for the contamination at the Howe
Valley Landfill Site were notified in writing of their possible liability via a
notice letter from the U.S. EPA dated September 4, 1987. The letter also gave
the PRPs the opportunity to conduct the Removal, the Remedial Investigation
-------
Determination - Page 10
(RI) and the Peasibility Study (FS) under u.s. EPA's supervision. Only two of
the nine identified PRPs agreed to undertake both the Removal and the RIfFS.
An Administrative Order on Consent between the u.S. EPA and two PRPs was signed
and put into effect on April 15, 1988. Work on these activities was conducted
by the PRPs contractor beginning in May 1988 and concluding in May 1990.
Removal Activities-
Based upon the number of drums that were buried on site and the possibility
that these drums contained hazardous wastes that were escaping into the
environment, the u.S. EPA felt that an immediate removal was necessary to
reduce any imminent and substantial danger to human health and the surrounding
environment. Removal activities were conducted by the PRPs contractor
beginning on June 7, 1988. The progression of excavation activities is shown
in Figure 5.
Drums were uncovered and transported to a staging area where each was recorded
in a drum log and the contents sampled. Run-on water entering the site was
diverted to a ditch constructed around the perimeter of the site and captured
in an on-site holding pond. This prevented the escape of exposed materials and
contaminants from the site by way of the on-site sinkhole. Figure 6 shows the
location of staging areas and diversion ditches. Excavation continued until
September 9, 1988 when the last drum was removed.
In total, 9,150 full or partially filled drums, 1,621 empty drums, 6,000
smaller drums and 3,000 cubic yards of non-containerized wastes were removed
from the site. Approximately 10,000 gallons of runoff water collected in the
holding pond were treated on-site with a two-stage mixed media and activated
carbon filtration unit. After the filtered water was analyzed and determined
to be clean, it was used for dust suppression and equipment cleaning.
Drums at the site were found buried in primarily two different fashions. Drums
in the central area of the site were haphazardly oriented, sometimes crushed
and without lids. Three to four layers of drums mixed with non-containerized
waste and soil were buried to depths of eight or twelve feet. Soil in this
area was typically dry with the exception of a few localized zones of perched
water around the wastes. Several thousand small containers, pint size to
5-gallon size, were uncovered along with the drums. These smaller containers
were filled with the same types of silicone polymers found in the larger drums.
In outlying areas surrounding the central area, drums were buried upright in
tightly packed groups. In some locations drums were stacked on rotting wooden
pallets loca~ed directly on top of bedrock. The majority of drums had lids and
showed only minimal traces of damage or rust. Excavations were generally
devoid of free liquids and ranged from ~our to eight feet in depth.
The following types of wastes were believed to be on-site prior to the removal:
*
Con~ainerized wastes placed above ground and covered with soil or
placed below ground in trenches. Included:
-------
npt~~in~tion - Pa2e 11
I ,.....
'DON
lOON
saOI
<400£
Lndl1'S 0 F
OUTLYING
AREAS
eOON
~
N
I
I5COK
<4OON
\/
1t.
~
CENTRAL
AREA OF
SITE
J
300N
LIMITS OF
OUTLYING
AREAS
200K
.
A CXCAVATCD vax O
-------
Determination - Page 12
1\' \i1~" ~ h-/J/~-- /A~ I /I//J"- :::::y/) ~fl~ J ,~W
1)}\1 l(r=-~<-'i~t~~\Q 'l (-----J './'1/ r~/~/ .
1/ r.. I -) /.'n~ - " ' /\. / I '80 \) \ ( i , \ ( r.
I~\\ I (r/.h /ioo\ ,-:r~;v~ ,,~ Ir:;;;~'<) 10.
\~~ ~ ..~ - -L rJ/~/: .r- / /)
\ \ ~) y '"' ~ ) \ J I /( r. V ---- Il/f '
~'~IoJ~~~I'Jf\\,>--. ~ {(!f' ~::f!JY j / ~ '~. 0 "00
~ ~ ~~It/ q/. )f ~~<~ ¥( rrt'J"'/ ~~;:://,,--\ \ t. ' sm,'
,'~~~ >~~. 2W.'l1~t~tr)~~~Irr!!fVfY?bV;;;~ LE~~ND
v,:-/~~ ~~h'\~. (~) C}~,~ 1 ~ - ~j J) (VO'-1~~ ~ SITElONE",,"""."S I
,'1 . ' ' ~~~- "~I ,,~i~~~~~ ~'/~f;'1~)~Y?'t.>x ~~~;I;;:i!'~;i~~~;:~"
N N~~~' ([,~~ J ~~, J ) ;>?( ~: (j) DECONTAMINATION lONE
~ ~~~~-''''''-C7r!:'1/- f\ ~ ~)() . ~:::::T.:~:f
~ ~~~~~~ ~<~ "'\ )~~~~\(\ ~\O . ~ :~;~;.~~":~;~;O.O
//j/ ~~~~~ifL~~ J.l500~ \ \6CH([\~,\",\.\ r°)'\~ ~ ~~:::~~GD~::
TOPOGlW'mC SOURCE: TUR~~'Gt--;'EERlN~~ (rj ././:,--, " \ \ (I)'" ~ CRUSHED/EMPTY DRUM PIU
FIGURE 6
REMOVAL OPERATING AREAS
-------
Determination - Page 13
- heavy metal (blue-gray) plating sludges
- silicone polymer wastes
- organic liquids associated with silicone
- insulation manufacturing chemicals
- non-hazardous refuse
polymer wastes
* Non-c9ntaiFerized, liquid "oily waste by-product" placed in a trench
* Non-containerized, silicone polymers buried in trenches
* Piles of insulation and industrial/domestic trash placed above ground
The various wastes that were actually found are briefly discussed in the
following paragraphs. Figure 4 shows the extent of each waste prior to
removal. Both the composition of the waste and the methods of final disposal
are presented. Detailed descriptions of site activities and disposal records
are contained in the July 1990 Remedial Investigation Report and the Removal
Monthly Progress Reports located in the Administrative Record. A copy of the
Administrative Record is kept in the Hardin County Public Library in
Elizabethtown, Kentucky and in the U.S. EPA's Region IV Office in Atlanta,
Georgia.
A.
Blue-Grav Platina Sludge
The blue-gray plating sludge was characterized as a solid to semi-solid
material. Three composite samples of the sludge were collected from 75 drums
(25 drums per composite) and analyzed in an off-site laboratory. The results
are compiled in Table 1. The plating sludges were consolidated and then sent
to the Chemical Waste Management Landfill near Ft. Wayne, Indiana and the
Chemical Waste Management Landfill in Emelle, Alabama.
B.
Solid Silicone
A total of 4,151 drums were found to contain silicone polymers in various
stages of curing. On-site analysis classified the polymers as flammable solids
with a flash point below 1408F; soluble in hexane and insoluble in water.
Results of the off-site laboratory analysis are presented in Table 2.
Initially, two tractor trailer loads of drums were overpacked and sent for
trial burns to the Thermal Kem incinerator in Rock Hill, South Carolina and the
Rollins Environmental Services incinerator in Deer Park, Texas. From the test
burn results, the Rollins facility was selected to receive the solid silicone
waste shipments, however the PRPs subsequently sent approximately one-half of
the solid silicone to the Chemical Waste Management Landfill in Emelle,
Alabama, with EPA's approval, due to high incineration costs.
Semi-solid Silicone
C.
A total of 513 drums contained semi-solid wastes such as partially cured caulk,
gel-like silicone polymers and thick paint-like pigments. A composite sample
-------
Determination - Page 14
TABLE 1
BLUE-GRAY PLATING SLUDGE ANALYSIS
CONTAMINANTS
Volatile Organics
,
Acetone
Benzene
Bromodichloromethane
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
l,l-Dichloroethane
1,2-Dichloroethane
l,l-Dichloroethene
1,2-Dichloroethene (Total)
1,2-Dichloropropane
cis-1,3-Dichloropropane
trans-l,3-Dichloropropane
D ibromoch 1 oroet hane
Ethylbenzene
Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
1, 1, I-trichloroethane
1,1,2-trichloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
Toluene
Vinyl acetate
Vinyl chloride
Total xylenes
f OF SAMPLES.
CONCENTRATION RANGES
(mg/kg)
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
16 - 51
.
Samples consisted of composites collected from 25 drums.
A total of 75 drums were sampled.
-------
Determination - Page 15
TABLE 1 continued
BLUE-GRAY PLATING SLUDGE ANALYSIS
CONTAMINANTS
t OF SAMPLES.
CONCENTRATION RANGES
'(mg/kg)
Inorganics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
ND - 5.51
1,790 - 11,900
129 - 163
ND - 106
ND - 2.13
24,200 - 40,400
ND
35.1 - 45.2
106,000 - 173,000
ND - 34.4
25,800 - 70,400
ND
ND
3,660 - 5,300
184 - 412
4,080 - 7,800
359 - 635
ND
ND
ND
ND
ND - 25.2
116,000 - 182,000
EP TOX
(mg/L)
ND
ND
ND
ND
ND
73.6 - 131
ND
ND
ND
0.275 - 0.335
ND
ND
ND
9.31 - 18.0
0.167 - 0.279
62.3 - 84.7
ND - 0.049
ND
ND
ND
ND
ND
18.4 - 25.7
.
Samples consisted of composites collected from 25 drums.
A total of 75 drums were sampled.
-------
Determination - Page 16
TABLE 2
SOLID SILICONE ANALYSIS
CONTAMINANTS
Volatile Organics
Acetone
Benzene
Bromodichloromethane
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene (Total)
1,2-Dichloropropane
cis-1,3-Dichloropropane
trans-1,3-Dichloropropane
Dibromochloroethane
Ethylbenzene
Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
1, 1, 1-trichloroethane
1,1,2-trichloroethane
1, 1, 2, 2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
Toluene
Vinyl acetate
Vinyl chloride
Total xylenes
CONCENTRATION RANGES
(mg/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
19 (J) *
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
320
ND
ND
570
ND
16 (J)
ND
ND
ND
* (J) indicates detection but below quantitation limit;
quantitation suspect
-------
Determination - Page 17
TABLE 2 continued
SOLID SILICONE ANALYSIS
CONTAMINANTS
CONCENTRATION RANGES
(mgjkg)
Inorganics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
ND
245
ND
ND
ND
ND
ND
ND
2.25
ND
1,090
ND
ND
ND .
6.36
ND
ND
ND
ND
ND
ND
ND
10.9
* (J) indicates detections below quantitation limit;
quantitation suspect
-------
Determination - Page 18
was collected from several drums and sent off-site for analysis. Results are
presented in Table 3. Drums containing the serni-solid silicone were overpacked
and sent to Therma~ Kern and Rollins for incineration and Petro-Chern Processing,
Inc., in Detroit, Michigan, for fuel blending incineration.
D.
Liauids
Liquids associated with the manufacturing of silicone polymers were found in a
total of 1,541 drums. A composite sample was analyzed in an off-site
laboratory. Table 4 summarizes the analytical results. overpacked drums
containing liquid wastes were sent to petro-Chern Processing, Inc. for fuel
blending incineration.
E.
Insulation Manufacturina Chemicals
A total of 138 drums, located in the northeastern area of the site, contained
solids, gels and liquids associated with the manufacturing of insulation. The
solid material was identified as a form of polyol while the liquids and gels
were identified as polyol and polymeric diisocyanate, respectively. The
manufacturing company provided detailed information regarding the drummed
materials, therefore off-site analysis was not conducted. All 138 drums were
sent to Petro-Chem Processing, Inc. in Detroit, Michigan.
F.
Copper-cvanide Bearina Sludae
A blue-black sludge was found in 31 drums located in the northeastern area of
the site. The material was identified as an unlayered solid, insoluble in
hexane, soluble in water and having a flash point above 140"F. Off-site
analytical results using u.s. EPA's Toxic Characteristic Leachate Procedure are
listed in Table 5. The sludge was bulked and sent to the Chemical Waste
Management Landfill in Emelle, Alabama.
G.
Oilv Waste Trench
Nearby residents reported that the landfill operator excavated a trench in the
western side of the central disposal area and placed in it at least one truck
load of a liquid oily waste. A composite soil sample (from two, three,
four, and five feet below the ground surface) was collected at each end of the
identified trench. Both samples were analyzed off-site. Results are presented
in Table 6. The final conclusion was that if oil dumping had occurred, it did
not result in detectable contamination of the soil.
H.
Non-containerized Silicone Polvmers
During the early phases of the landfill operation, non-containerized silicone
polymers were placed in trenches partially filled with accumulated rainwater.
-------
Determination - Page 19
TABLE 3
SEMI-SOLID SILICONE ANALYSIS
CONTAMINANTS
Volatile Organics
Acetone
Benzene
Bromodichloromethane
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene (Total)
1,2-Dichloropropane
cis-1,3-Dichloropropane
trans-1,3-Dichloropropane
Dibromochloroethane
Ethylbenzene
Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
1, 1, 1-trichloroethane
1,1,2-trichloroethane
1, 1, 2, 2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
Toluene
Vinyl acetate
Vinyl chloride
Total xylenes
CONCENTRATION RANGES
(mg/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
230 (J)*
ND
ND
ND
ND
ND
ND
ND
160 (J)
ND
ND
ND
ND
320
ND
ND
5,400
ND
490
ND
ND
890
* (J) indicates detection but below quantitation limit;
quantitation suspect
-------
Determination - Page 20
CONTAMINANTS
Inorganics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
TABLE 3 continued
SEMI-SOLID SILICONE ANALYSIS
CONCENTRATION RANGES
(mg/kg)
ND
73.8
ND
ND
ND
ND
1.12
ND
1.21
ND
177
ND
ND
ND
5.93
ND
ND
ND
ND
ND
ND
ND
8.83
-------
I-
I
Determination - Page 21
TABLE 4
LIQUID SILICONE ANALYSIS
CONTAMINANTS
.CONCENTRATION RANGES
(mg/kg)
Volatile
Organics
Acetone
Benzene
Bromodichloromethane
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
1,1-Dichloroethane
1,2-Dichloroethane
l,l-Dichloroethene
1,2-Dichloroethene (Total)
1,2-Dichloropropane
cis-l,3-Dichloropropane
trans-l,3-Dichloropropane
Dibromochloroethane
Ethylbenzene
Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
l,l,l-trichloroethane
1,l,2-trichloroethane
1, 1, 2, 2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
Toluene
Vinyl acetate
Vinyl chloride
Total xylenes
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
22,000
ND
ND
ND
ND
ND
ND
ND
ND
-------
Determination - Paqe 22
CONTAMINANTS
Inorqanics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Maqnesium
Manqanese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
TABLE 4 continued
LIQUID SILICONE ANALYSIS
CONCENTRATION RANGES
(mq/kg)
ND
ND
ND
30.8
ND
ND
16.8
ND
ND
3.12
10
ND
ND
ND
ND
ND
ND
195
ND
ND
ND
ND
14.4
-------
Determination - Page 23
TABLE 5
COPPER-CYANIDE SLUDGE ANALYSIS
CONTAMINANTS
Inorganics
Silver
Arsenic
Barium
Cadmium
Cobalt
Chromium
Copper
Nickel
Lead
Antimony
Selenium
Zinc
Sample
ND
ND
0.37
0.02
ND
ND
200
ND
0.12
ND
ND
3.3
Cyanide (in mg/kg)
CONCENTRATIONS
(mg/L)
1
580
Sample 2
ND
ND
0.43
0.02
ND
ND
200
ND
0.05
0.20
ND
3.2
2,400
-------
Determination - Page 24
The result was a marshmallow-like mixture of cured to semi-cured silicone, soil
and small containers. Figure 7 shows the area of disposal trenches.
An opening was excavated in a trench to allow collection of a composite sample
of the silicone material. The composite was taken from four locations to a
depth of one foot. The sample was the~ sent off-site for analysis. The
results are presen~d in Table 7. Approximately 3,000 cubic yards of the
silicone material and associated soil were removed from the site and disposed
of in the Chemical Waste Management Landfill in Emelle, Alabama.
I.
Domestic Trash and Insulation Pile
A total of 1,91B drums, the majority without lids, were found to contain rags,
paper, paint cans, empty plastic bottles, test samples and miscellaneous
debris. It appeared that the drums were sent to the landfill along with
industrial waste drums. Due to the nature of their content, these drums were
not analyzed. Initially, the drums were overpacked and sent to Rollins
Environmental Services in Deer Park, Texas for incineration, however in an
effort to be more cost-efficient, the drums were later sent to the Chemical
Waste Management Landfill in Emelle, Alabama.
Several non-hazardous, surface piles of domestic refuse were located in the
central area of the site. Each pile was loaded into a dump truck and sent to
the Hardin County Landfill near Elizabethtown, Kentucky. Approximately seven
loads were taken to the landfill.
In addition to domestic refuse, one large pile and two smaller piles of
insulation were found above ground in the central area of the site. Three
c;mposite samples were taken from the pile and sent off-site for analysis.
Results are presented in Table B. The corporation responsible for the disposal
of the insulation arranged to have the piles sent to the Hardin County Landfill
near E1izabethtown, Kentucky.
Post Removal Investiqations
Dve-trace Studies
1. Low Flow Conditions: In September 1988 after a significant dry period, a
dye trace study was conducted to identify points of ground water discharge
suitable for monitoring and evaluating the fate of water entering the on-site
sinkhole. A8 part of the study sodium fluorescein dye was washed into the
sinkhole with approximately 3,750 gallons of water for 15-minutes.
Twenty-eight monitoring points, such as springs, wells, and streams, were
bugged with activated charcoal packets.' Bugged locations are marked in
Figure 8.
Thirty-four days after injection, dye was detected in Boutwell Spring which
forms the headwaters of the eastern branch of Linders Creek. Traces of dye
were also detected in the three bugs placed downstream in Linders Creek.
Boutwell Spring lies approximately 1.85 miles south of the site. Discharge
-------
^fe«?
SOURCES USCS TOPOC.WHC MAPS FOR
HC'*E VALLEY KNO CI
OLUORANCL£3 (7.J MINUTI S£?.ii)
:3. (1980)
FIGURE 8
1988 DTK-TRACE MONITORING LOCATIONS
Determination - Page 24A
-------
Determination - Page 25
TABLE 6
OILY-WASTE TRENCH ANALYSIS
CONTAMINANTS
.CONCENTRATION RANGES
(mg/kg)
Volatile Organics
Acetone
Benzene
Bromodichloromethane
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
l,l-Dichloroethane
1,2-Dichloroethane
l,l-Dichloroethene
1,2-Dichloroethene (Total)
1,2-Dichloropropane
cis-l,3-Dichloropropane
trans-l,3-Dichloropropane
Dibromochloroethane
Ethylbenzene
Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
l,l,l-trichloroethane
1,1,2-trichloroethane
1, 1, 2, 2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
Toluene
Vinyl acetate
Vinyl chloride
Total xylenes
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Above results are for both composite samples.
-------
Determination - Page 26
TABLE 6 continued
OILY-WASTE TRENCH ANALYSIS
CONTAMINANTS
Inorganics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
CONCENTRATIONS
(mg/kg)
Samt)le 1
ND
11 , 000
5.4
57
0.44
1,500
ND
ND
11
8.0
19,000
ND
500
600
980
26
7.0
15
ND
ND
ND
26
42
Samt)le 2
ND
10,000
5.7
45
0.58
1,500
ND
ND
13
7.5
19,000
ND
500
720
590
33
7.5
17
ND
ND
ND
20
34
Samples were comprised of composites collected at
four different depths.
-------
Dcterminat Ion - Page 27
I .
'f'% J:- ::::)r~D.-~~ / (;7// l::::YV) .~ )!~ ,_J,~O?'
I~ . 8001, ] [-;;!j;:o - \J}}(I(/ljfJ~ "- < #1 /u (7 (:~. .
\ \ ,I1tU, J (/ ---- "\ '/\~. 80 ) I !70 N /
lfi ( . /1 \~'fJ~L.l?;;:, ,,~I V'-?:::: --;j
, \ 0::- \\ .\' \~ :::J /'-0 U t.~ I ) , I / ~ V - ~
~~'ooJ\~~ k?,-/~~~/.I// \~ ~~~::;
~ ') \ lr1n;, :(Y I< ~~I\ Il!r.fiI~ N
~rjf2i/~/r)#',-v1' ~~~.~ '/~,~.
~/ /E~;' ~ '#- ~\ !J~fr/1k~~J~. '\\ .
" , V. ,;~1 ~ . II) ~ ~ 1
~ ~r:; /' tk J! ~,<) 7:~ I < ~0::::::\ '\.
:~ " ~ -~~ ~V~ 1 >1,? L2--V' r / 'Y: ~~ \
,/' ~~ ~I< \-1~n--£ .
Q 0...9() ~~.~ ,0\ t. '...., . j (
,:,<:5 ~::---. ~ ," L ~ (\"? I~'.
~~~~~P'"- >b:D" f\.~ '1~ "~.D SC,,",
/'~~~~~J ~Y5~ \\6~E ~,'\\\ r~~
I . ~ ~"h...- .. ......... ~ --. ......... ~l '/'j r--....' (' \ " TOPOCRAPHIC SOURCE: T\mNER ~CINEERIHC
FIGURE 7
LOCATION OF NON-CONTAINERIZED SILICONE WASTES
-------
Determination - Page 28
TABLE 7
NON-CONTAINERIZED SILICONE POLYMERS ANALYSIS
CONTAMINANTS
Volatile Organics
Acetone
Benzene
Bromodichloromethane
Bromoform
2-Butanone
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
l,l-Dichloroethane
l,2-Dichloroethane
l,l-Dichloroethene
l,2-Dichloroethene (Total)
1,2-Dichloropropane
cis-l,3-Dichloropropane
trans-l,3-Dichloropropane
Dibromochloroethane
Ethylbenzene
Hexanone
4-Methyl-2-pentanone
Methylene chloride
Styrene
l,l,l-trichloroethane
l,l,2-trichloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
Toluene
Vinyl acetate
Vinyl chloride
Total xylenes
CONCENTRATION RANGES
(mg/kg)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
52 (J)
67
ND
ND
ND
ND
ND
ND
ND
ND
ND
1,600
ND
ND
280
24 (J)
ND
ND
ND
ND
*
(J) indicates detection but below quantitation limits;
quantitation suspect
-------
Determination - Page 29
TABLE 7 continued
NON-CONTAINERIZED SILICONE POLYMERS ANALYSIS
CONTAMINANTS
,CONCENTRATION RANGES
(mg/kg)
Inorganics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
ND
110
0.26
1.5
ND
420
ND
ND
5.0
8.0
29,000
ND
ND
41
174
20
4.5
3.5
ND
ND
ND
ND
110
-------
Determination - Page 30
TABLE 8
INSULATION PILE COMPOSITE ANALYSIS
A total of three composite samples were' taken from trenches cut into the
insulation pile. The range of concentrations is presented below.
CONTAMINANTS
Ethylbenzene
1, 1, 1-trichloroethane
Total xylenes
Trich1oroflouromethane
Asbestos TyPes
Bis (2-ethylhexyl) Phthalate
Pentachlorophenol
Silver
Aluminum
Barium
Calcium
Chromium
Copper
Iron
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Vanadium
Zinc
Non-Asbestos Fibers (Cellulose)
Non-Fiberous Material
CONCENTRATION RANGES
(mg/kg)
ND - 7.0
ND - 3.0
14 - 79
23(J) - 390(J)
ND
1500 - 2400
ND - 3(J)
0.5 - 1.0
200 - 270
8.8 - 15.0
570 - 1500
4.0 - 5.0
5.5 - 52.0
140 - 200
37 - 82
91 - 240
9 - 20
26 - 96
ND - 2.0
15 - 22
ND - 3.5
32 - 120
25'
75'
-------
SCALE
TOPOGRAPHIC SOURCE: USG3
FIGURE 9
1990 DYE-TRACE MONITORING LOCATIONS
Determination - Page 31A
-------
Determination - Page 31
.
rates at the spring
movement during the
per minute).
varied from 526 to 1,110 gallons per minute. Ground water
dye trace was estimated to be 290 feet per day (0.2 feet
2. Hiah Flow Conditions: An additional dye trace study was conducted in
February 1990. The goal of the second study was to locate any ground water
resurgences that were not apparent durlng the low flow dye trace conducted in
September 1988: Again, f10urescein dye was injected into the on-site sinkhole
and flushed with 2,000 gallons of water for 15 minutes. A total of 31
locations were bugged with pouches containing activated coconut charcoal
(Figure 9).
Monitoring
monitoring
actual hit
the second
of bugged locations continued until March 1990. During the
period, dye was detected in only one location, Boutwell Spring. The
occurred within 24 hours after injection. Ground water flow during
trace was approximately 10,080 feet per day (7 feet per minute).
Environmental Samplina
The following section briefly discusses the field sampling activities conducted
by the PRPs contractor in 1988 during and after the removal. Additional
sampling was conducted in March 1990 to a8sess environmental conditions after
the removal and soil aeration project. A detailed discussion of the 1990
sampling is presented later in the Site Characteristics Section. Analytical
results for the 1988 sampling are contained in the July 1990 RI Report
contained in the Administrative Record.
Field investigations involving sampling of environmental media such as the air,
surface water and associated sediments, ground water and soil, were conducted
to evaluate the nature and extent of contamination resulting from the Howe
Valley Landfill. Figure 10 shows proposed and actual sampling locations.
Drought conditions prohibited collection of several water samples. The largest
portion of wastes disposed at the site were silicone polymers and plating
sludges. The primary chemical constituents of these wastes were as follows:
Silicone Polymer Wastes
- 1,1,1-trichloroethane
- 1,2-dichloroethene
- 1,1-dichloroethane
- tetrachloroethene
Plating Sludges
- zinc
- chromium
- copper
- cyanide
As a result, these compounds were targeted in sampling and analytical programs.
A.
Air Monitorina
Baseline air quality monitoring with a photoionization detector conducted prior
to site activities indicated a relative absence of detectable organic vapors at
the site. Regular air quality monitoring was conducted d~ing removal
-------
Determination - Page 32
K1rC@f------~Ii"~/~;~/I///;'\~LI) ~ J .--/~
I I (-- ~ .~, /Jj 7 ~ \ / f/
~ MO-N ;) r;;{f!o 1 \~~~~I\ ~~~ IN (' II ( I d "
IA ,~~ \ '--"[~rL£ A ,,~I lr?::: -g' /
\\ I ~ 1/ ~ .. ~
:', --,- \' ~ ~ ::J /l---0 U ~,-l[5,~~ ~,~ / U; ~~~ >
~J.)olr\ " ~ k~~/~~~~~v';: ~/ \ ( ~~~ V
~ ~ / ". . r u'" ~(,? «~~\ 10{j;~
~:i ~~~~~'~~ ", ". 7!~j'f. /~~N" N
:~0jt~~;;Ef /7 ~ ~~~~W. '\h ~ /~ ~7i:t~ ~ \
\ F~~FJ;;~/!!: t ~= ~ " IJ ) 1 ./~0~ ~N
/~~~~-~WT." ~V ~ :z.:=~~ ~~0~\\ \
/,~,/'"... ~~~\,\.!::~,:,~ ~ ~ -::-Ph I (A ~ lEGEND
, c...., '~.l ",,~i!i...,.:.3. ")/'2 -=",~ >(;' /A1~ \I ,/(X(~ .SfD'MfN7"
/l ~~~ ':({;"")n"' ~"""'-
-------
tS^nRTii * A &w)-f/w?sy.
—Tiivf?" U "%"' >9l I _.-{** '-Z*\J*jP* ' >/ ffJe~Sr^M
LEGEND
WELL SAMPLE
SPRING SJ.MPL5
A SURFACE WATER
• SEDIMENT
* irmiots IKOICAT! i« imoiirr r:
am me S-»»L; sue ro our
fois on «.*US^L
ow net.
FIGURE 11
OFF-SITE ENVIRONMENTAL SAMPLE LOCATIONS
Determination - Page 33A
-------
Determination - Page 33
activities. Downwind ambient air monitoring conducted with an organic vapor
analyzer at the site boundaries during excavation ranged from background to
about 5 parte per million (ppm) for organic contaminant concentrations.
Organic vapor concentrations measured with a photoionization detector during
central area soil sampling in the Fall of 1988 ranged from 22 to 450 ppm.
B. Surface Water
1. Off-site surface water: During the removal activities, samples were
collected from two locations in Linders Creek (LCW1 and LCW2, see Figure 11).
Both locations were down stream from Boutwell Spring. The samples were
analyzed for volatile organics, metals and cyanide. Toluene, the only organic
found, was detected in one of the samples at 0.007 milligrams per liter
(mg/L). Additional samples collected several months later did not show the
presence of toluene. This particular identification, although not a result of
field or laboratory contamination, did not appear to be related to the site.
If the surface water contained contamination from the site, more prevelant site
related contaminants would have been detected along with the toluene. Cyanide
was never detected and metals were within U.S. EPA's drinking water standards.
In the original RI Work Plan, samples were to be collected from off-site ponds
near the site. A severe drought during the summer months left these ponds
completely dry and prevented the collection of samples.
2. On-site surface water: In May 1988, prior to removal activities, a sample
(PW1) was collected from the on-site pond which at that time was the only
on-site surface water. The sample was analyzed for volatile organics,
semi-volatile organics, metals and cyanide. Only one semi-volatile,
4-methylphenol, was detected at 0.004 mg/L. Cyanide was not detected and all
detected metals were below the established Maximum Contaminants Levels (HCLs).
C.
Sediments
1. Off-site sediments: Five off-site samples were obtained in June 1988, four
from Linders Creek (LCS1, LCS2, LCS1(B) and LCS2(B» and one from a tributary
of Linders Creek (ITS1). Sample locations are shown in Figure 11, Each sample
was analyzed for volatile organics, semi-volatile organics, metals and
cyanide. A second set of samples collected from Linders Creek were analyzed
for volatile organics on the Target Compound List. In all three samples,
calcium concentrations exceeded those detected in the background soil samples
collected near the site. Cyanide was not detected in any samples. In the
intermittent etream sample, trichloroethene and di~n-butyl phthalate were
detected at concentrations of 1.0 ppm each. Since trichloroethene was not
detected at the site's ground water discharge point (Boutwell Spring) or found
in significant quantities on-site, it is suspected to be present at this
location from an off-site source such as farming/heavy equipment maintenance.
2. On-site Sediments: Sediments were collected from all three of the on-site
ponds in May 1988 (PS1, PS2, PS3, STS1, STS2 and STS3). On-going drought
conditions dried. up two of the ponds. As with the off-site sediments, samples
were analyzed for volatile organics, semi-volatile organics, metals and
cyanide. Neither volatile organics nor cyanide were detected. All-detected
-------
Determination - Page 34
metals, with the exception of potassium and manganese, were below
concentrations found in the local background soil sample. The following
semi-volatile org~ics were identified: di-n-butyl phthalate,
4-chloro-3-methylphenol, 4-methylphenol and bis(2-ethylhexyl) phthalate. Only
bis (2-ethylhexyl) phthalate, a chemical commonly found in plasticizers, was
identified in the on-site wastes. The other three compounds were suspected to
be from the domesti~ waste trash piled near the pond or from laboratory
contamination.
D.
Ground Water
Six wells (PWW1, PWW2, PWW4, PWW5, PWW7 and PWW8) and four springs (SPW1, SPW2,
SPW3 and SPW4) near the site were sampled during the ground water
investigations conducted throughout the RI process. Analyses included volatile
organics, semi-volatile organics, metals and cyanide. In all samples, cyanide
and organics were not detected and metals were within u.s. EPA's drinking water
standards.
Additional sampling was conducted at Boutwell Spring, the only discharge point
identified during the dye-trace studies. Samples collected in November 1988
were analyzed for volatile organics, semi-volatile organics, metals and
cyanide. The following organics were discovered:
1,1,1-trichloroethane
1,2-dichloroethane
diethyl phthalate
0.014
0.003
0.003
mg/L
mg/L
mg/L
S~nce diethyl phthalate was never found at the site in significant
concentrations, its presence in the sample was attributed to the latex gloves
worn by the sampler.
A second set of samples from Boutwell Spring were collected in December 1988
after a heavy rainfall. This time 1,1,1-trichloroethane was the only compound
detected at 0.005 mg/L and 0.006 mg/L. Both concentrations were below the Safe
Drinking Water Act MCL of 0.2 mg/L.
E.
~
1. Backaround Soils: Two background soil samples (BRWl and BRW2) were
collected outside the landfill area prior to waste removal activities. Only
one semi-volatile, di-n-butyl phthalate, was found in the background samples
[0.4 and 0.8 milligrams per kilogram (mg/kg)], however its presence was
attributed to laboratory contamination. Volatile organics were not detected.
The metals found in the background sampies are presented in Table 9.
2. Outlvina Soil: Extensive soil sampling was conducted outside the central
soil treatment area to establish the lateral and vertical extent of organic
compound and inorganic metal contamination. Locations of the two primary
wastes streams, heavy metal sludges and silicone polymers, were used to
establish the necessary analyses to be performed on the samples. Ar~as where
-------
Determination - Page 35
drummed plating sludges had been buried were sampled and analyzed for the
associated metals. Areas where drummed silicone polymers had been buried were
analyzed for the a!sociated organic compounds. These particular compounds of
interest were established using the frequency and magnitude with which they
occurred in the soil samples, their toxicities and their relative abundance in
the waste streams.
Areas surrounding the central area of the site were sampled to delineate places
requiring treatment after the removal of the waste sources. The outlying areas
were divided into 8 units and then sampled. A composite sample was collected
for each unit, combining all the sample locations within that unit. Each
sample location was also comprised of quilts taken at depths of 1, 4 and 7 feet
(when possible). Figure 12 outlines the sampling units and locations. Units
1, 2, 4 and 5 were found to contain concentrations of chromium, zinc and copper
above the background samples. Table 10 presents the metals results.
Several pockets of blue-gray sludges and copper-cyanide bearing sludges were
encountered during sampling activities. These pockets of sludge and
surrounding soils were removed with a trackhoe and eventually taken off-site
for disposal. The locations of the sludge pockets are shown in Figure 13.
All samples collected in the outlying areas for volatile organic compounds were
tested using headspace analysis. A portion of these samples were also tested
using laboratory analysis. A discreet sample was collected at each location,
compositing only the quilts collected at different depths. Figures 14 and 15
show sampling locations.
While all samples contained some traces of the volatile contaminants of
interest, only two samples, both collected in the same area, had concentrations
of l,l,l-trichloroethane and tetrachloroethene above the soil action levels
(SALS) of 7.72 mg/kg and >7.5 mg/kg, respectively. The determination of SALs
is discussed on pages 19 and 20 of this document. This outlying area underwent
aeration as part of the pilot aeration project which is described in greater
detail on page 42 of this document. A trench measuring 50 feet by 30 feet was
excavated through sample boring 4 and the soil was aerated. Volatile organics
were not found in samples that were collected after the project.
3. Central Area Soils: The central portion of the site contained most of the
contaminated soil due to the large amount of non-containerized waste buried in
this area. Composite samples collected in this area did not contain any metals
of interest above the background concentrations. The four volatile organics of
interest, 1, 1, l-trichloroethane, l,2-dichloroethene, l,l-dichloroethane and
tetrachloroethene, were present in the central area samples. Samples were
analyzed for volatile organics through headspace analysis and off-site
laboratory analysis during the soil ae~ation project. Analytical data is
presented in the July 1990 RI Report.
Soil Aeration Pilot Studv
To establish the effectiveness
from the central area soils, a
each containing 15 cubic yards
of aeration for removing the volatile organics
pilot study was conducted using thre~ test plots
of soil at varying depths: 6, 12 and 24
-------
Determination - Page 36
TABLE 9
BACKGROUND SOIL SAMPLE METALS ANALYSIS
CONTAMINANTS
CONCENTRATIONS
(mg/kg)
Inorganics
Silver
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cadmium
Cobalt
Chromium
Copper
Iron
Mercury
Potassium
Magnesium
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Thallium
Vanadium
Zinc
BRW1
ND
13,000
20
31
0.66
1,300
ND
ND
80
9.5
89,000
ND
420
670
270
24
17
29
ND
0.44
ND
54
62
BRW2
0.5
15,000
14
95
0.79
3,500
ND
ND
16
14
42,000
ND
580
1,200
370
40
18
25
ND
0.36
ND
29
63
-------
retermination - ~a£e 37
100"
700N
800M
SOON
-400H
:IOOH
lOOK
5002 .o0K
8 LIMITS OF
OUTLYING
82 AREAS
.
.
. 8 ~
N
I
lOOK
LnIJTS OF
OUTLYING
AREAS
o
I
SCALE
SAMPUNG LOCATIONS
. AUQUOT L.CCA110N
!Sa HOLE NUYBER
a
.
FIGURE 12
COMPOSITE SAMPLE UNITS AND ALIQUOT LOCATIONS
METALS ANAL YS IS
-------
Determination - Page 38
TABLE 10
METALS ANALYSIS OF SOIL SAMPLES
CONCENTRATIONS Cmq/kq)
AREA - TOTAL TOTAL
COMPOSITE ID CHROMIUM -ID!£ COPPER
1A 1300 1300 N/A
2A 840 880 N/A
3A 19 31 N/A
4A 350 360 N/A
4B 1600 1700 N/A
SA 180 240 2400*
6A 11 26 N/A
6B 16 48 N/A
7A 18 49 N/A
8A 18 35 22**
A = 1-foot centers
B= 4-foot centers
N/A = not analyzed
* Only area where copper containing drums were found.
** Location where copper-containing sludges were stockpiled.
-------
rp,prm;",,", - pa.. 19.
lOCT .
?OON
~ON
300N
ZOOK
5002
.OOE
SOON
.
I.IMI1'S 0 F
OUTLYING
AREAS
SLUDGE STOCKPILE
REMOVED TO
BEDROCK
tr
N
I
500K
LIMITS OF
OUTLYING
AREAS
tooH
o
I
SCALE
SAMPUNG LOCATIONS
. AUQUar L.CCA110N
56 HOl£ NUWSER
o
FIGURE 13
METAL SLUDGE POCKET REMOVAL AREAS
-------
Determination - Page 40
I
,
!
100W
700N
eOON
~OON
~OON
200N
lOON
3002
400E
LIMITS 0 F
OUTLYING
AREAS
~
N
I
LIWTS OF
OUTLYING
AREAS
o
I
.
o
SCALE
SAMPUNG LOCATIONS
A. HE)DSPACE ANALYSES
.. NW.YT1CAL AND HOOSPACE
ANALYSIS
17 HOLE NUMBER .
-
.
FIGURE 14 .
SOIL SAMPLE LOCATIONS FOR HEADSPACE ANALYSIS
OF VOLATILE ORGANIC COMPOUNDS
-------
Determfn.lt ion '- Page 41
H 'J~ !- ~ -;;:ji~~~/ (;rl)~~// ~ L---' ~~
~ * (- ~ - - w//~"'-/, ~ I ~/ ri
\1 1m:::; 690 \v0~~ 1('-?9, ~~ (r--I I I
, I 1Da..N I) (/..- '1 . /\ ~ 0) ) , 70 N
I:J\\ II \~~ ~~/~~ &~ I~ V?~g
,i ~:- \' ~ ~ :::r /'-0 V 7 ~ J ) I )f; ~ N
~0'~ ;1\' ~ k? '- /~~'i:~'~ ~> 1\ I ~~~ ~
C}~ ~ \ l~ r \~ < (l(' ?~ ~v (d" ) 0~
~:j~v~~~;L~, ~~~(~ /~~. N
~v /E~a) ~ ~ !a~~~~ '
\ ' I V v>;, / :1 D I ~
~ :. ~M.~"'~ 1. ~ ~. 'r; /" ,/~~h\ \.
:~- ~ ~~~~3: s~}'llt 'C?=~~ 11,1J!}(;i:dj;~, \\
/ //, ~~~~I)\ ~ ..yQ(~~T ~ (/ V .
II, ~ ~. r,. 1_. J ,<..--'- ~ r "A'~ ~
,: ~ ~~.\ ~~ )/"-- -~--~ K./ iA'/C'/ LEG END
, I\'~ /, ~ /. r- ~~~ I .
~ ,\ ~:~-- ~ // Yo"" k ". dO.. .
:::-.. ---.:;:: --':... I.... ~... 1>1/ v . .~ ,
~~~ ~~~~~b-l (~ ~ ~ I ~r ...., -.....,,-....-"""..
~<> / ~~ $0,....., ,\ .L 100 - I' ".... ........."..
~ l": -''V \~ ~. [;\ ~~ \~
.~ r----: t::::== roo- ~K7 ~ '" rl '~~ '1 \ t\ .
,'.. /j /--.::: ~ "~--'oo.t..~~-!?;~cuJ / ~ [ ) i/ ~OO,\ \ \6OQ, [~" 700\[\\ (0 \~ ? I~O'
TOPOGRAPIDC SOURCE: TIJRNER EtiGJNURING~, ',"---::--"" ~I /./1 ~ \ ".' \. SCJ.LE
FIGURE 15
SHELBY TUBE SAMPLE LOCATIONS
-------
Determination - Page 42
inches. composite soil samples were collected and analyzed both on and
off-site at the beginning and end of the study. A trackhoe rotated soils four
to five t~es daily. Surveys with a photoionization detector were used to
measure the volatile organics in the atmosphere. The PRPs contractor used
headspace analysis of composited soil samples to determine when the volatile
contaminants of interest were reduced to acceptable concentrations. As soon as
the contractor_felt the soils had been sufficiently remediated, they were
placed back into their original trenches.
Based upon the decrease of volatile organic contaminants in the 6 and 12 inch
deep plots, the pilot study was expanded to include the entire central area and
one outlying area where volatile contaminants of interest existed above
acceptable SALs. The treatment of contaminated soil began in late November
1988 and continued until mid-December 1988. Approximately 6,000 cubic yards of
soil were treated.
Initial steps involved the excavation of soil from trenches measuring 100-200
feet long and 15-50 feet wide (Figure 16). Depth of each trench depended upon
the depth to bedrock or undisturbed soil. Removed soils were then deposited in
a designated treatment area adjacent to each trench (Figure 17). Daily
roto-tilling of soil was conducted to promote aeration. Soils were redeposited
in their original trenches following headspace analysis but prior to off-site
laboratory confirmation. The trenches were flagged so that if reaeration was
needed based on the laboratory results, the trenches could be easily
identified.
It should be noted that subsequent soil samples from the central area,
collected in March 1990, contained concentrations of volatile organics above
the soil action levels. The presence of these volatile organics does not
dispel the effectiveness of soil aeration for treating the central area of the
site. Headspace analysis conducted by the PRP's contractor was not performed
according to the guidelines set forth by the u.s. EPA's Environmental Services
Division. Remaining contamination may have been a result of improper
procedures. The effectiveness of soil aeration will be determined during the
Remedial Design.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan (CRP) for the Howe Valley Landfill Site was
finalized on September 14, 1988. The CRP documents the concerns of individuals
and local officials in the Howe Valley area and describes activities selected
by the u.S. BPA to address these concerns. Specific information was gathered
during community interviews conducted in April 1988.
The CRP also establishes communication pathways to ensure timely dissemination
of pertinent information. In May 1988, a fact sheet overviewing the RI process
and removal activities was distributed to Howe Valley residents, local
officials and other interested parties. Three press releases, two in July 1988
and one in August 1988, reported the progress of removal and dye trace
activities. A general information meeting for the public was held in the Howe
Valley Elementary School in June 1988.
-------
r,.-
-------
(A)
'i"
-~
,,'
,
" "
", "
">'f
" "
-- ~ ".
;~ ,~
~----
'\" -
"
L', "
~"-~,,
,,, . , 1.,
"L,-
.
w
(B)
"
"
.'\
'.
, .
, ,
~ .
-.
. .
. '. , ;",' . :..' ~. . ,~ -,. :: '. i
'~ . . :', ~ :. ~.
~
".
..
(C) -
. .
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. .
, '.
, .
,. ..
." '.
. ".
"
",
.
. .
.
.
, . ,
.
. .
...,
~
FIGURE 17
SOIL AERATION PROCEDU~~
-------
Determination - Page 45
The RI/FS Reports and the Proposed Plan were released to the public in July
1990. These documents are available in the Administrative Record which was
placed in the Info~ation Repository in the Hardin County Public Library,
Elizabethtown, Kentucky. An official public comment period on the FS Report
and the proposed Plan was held from July 27, 1990 to August 27, 1990. To
promote public interest and to present the results of the Remedial
Investigation and Feasibility Study and the preferred alternative as discussed
in the Proposed Plan, a public meeting was held in the Howe Valley Elementary
School on August 2, 1990 .
All comments received by the U.S. EPA prior to the end of the public comment
period, including those expressed verbally at the public meeting, are addressed
in the Responsiveness Summary contained in Appendix A of this document.
Comments from the Commonwealth of Kentucky are addressed independently from the
Responsiveness Summary and are contained in the Administrative Record.
SCOPE AND ROLE OF RESPONSE ACTION
The response action for the site is intended to address the on-site soils that
still contain contamination above acceptable concentrations with regards to
human health and the environment. As discussed, Lmmediate health threats were
alleviated through the removal of wastes from the site. Investigations
conducted after the removal and soil aeration study revealed residual
contamination was still present in the on-site soils, primarily in several
distinct locations. Ground water and surface water samples established that
contamination had not migrated from the site in concentrations above safe
drinking levels, however the karst geology limited the ability to sample ground
water directly underneath the site.
The selected alternative for remediating the site will address the
contamination remaining in the on-site soils and contamination that could be
released into the ground water. The principal threat to human health and the
environment is from the possible ingestion or dermal contact with the
contaminated soils. A secondary threat would be from ingestion of contaminated
ground water. Currently, ground water samples taken at Boutwell Spring
indicate that contamination is below the MCLs or health-based levels. Ground
water conditions at the site could not be determined because of the karst
conditions. Risks from the site are included in the July 1990 RI Report and
are later summarized in this document.
SUMMARY OF SITE CHARACTERISTICS
Post-removal/post-aeration sampling of the site and Boutwell Spring was
conducted in March 1990. Results from 'this latest sampling round give the best
indication of current conditions at the site.
-------
Determination - Page 46
Nature and Extent of Contamination
Approximately 9,159 drums and containers of hazardous chemicals were disposed
of at the Howe Valley Landfill between 1967 and 1976. Residual contamination
left in the soil, primarily from leaking drums and non-containerized wastes
disposed at the site, appears to be the only remaining contamination. Analysis
of both on-sit~ and off-site soil, ground water, surface water, and sediments
indicates that contamination at the site is located in the subsurface soil from
1 to 9 feet in depth. Organics such as 1,1,1-trichloroethane,
1,2-dichloroethene, 1,1-dichloroethane, and tetrachloroethene along with
inorganics such as chromium, copper, zinc and cyanide are the primary
contaminants.
Surface Water
1. On-Site Surface Water: Surface water traveling across the site and into
the on-site sinkhole was calculated to be flowing at a rate of approximately
3.8 gallons per minute. Measurements were made less than 12 hours after a
major precipitation event. On-site surface water flow resulting from storms is
very short in duration, usually lasting less than 24 or 48 hours. Between
precipitation events there is no flowing or ponded surface water at the site.
Only one organic compound was detected in the surface water flowing to the
on-site sinkhole. Although 1,l,l-trichloroethane was below the detection
limit, the concentration was estimated to be 0.004 mg/L. The Maximum
Contaminant Level (MCL) for 1,1,1-trichloroethane is 0.2 mg/L. Analytical
results are presented in Table 11.
2. Off-Site Surface Water: Off-site surface water sampling was dependent upon
the March 1990 dye-trace study. Since dye was not detected in any off-site
surface waters, no samples were collected. Ground water samples were collected
from area springs and are presented under the Ground Water Section.
Sediments
1. On-Site sediments: Analyses of sediments in the on-site sinkhole did not
detect any volatile organic chemicals, semi-volatile organics, pesticides, or
PCBs, however copper was detected at slightly elevated concentrations. The
majority of metals in the sediment were iron, calcium, and aluminum, naturally
occurring metals in limestone and weathered clay. The cyanide concentration
was 0.6 mg/kg. Results of the analyses are presented in Table 12.
2. Off-Site Sediments: Off-site sedim~nt samples were collected at Boutwell
spring. This particular spring was determined, through three dye-trace
studies, to be the discharge point for water entering the on-site sinkhole. No
volatile organics, base/neutral extractable organics, acid extractable
organics, pesticides or PCBs were detected in the samples. The only exception
was phenol which was estimated to have a concentration of 0.2 ppm. The
drinking water health-based standard for phenol is 4.2 ppm. Metals
concentrations were below U.S EPA Drinking Water Standards. A cyan~de
concentration of 0.9 ppm was indicated in the spring sediment, however, cyanide
was also found in the field blank. Table 12 presents the -':results for the
analysis of the off-site sediment sample. .
-------
Determination - Page 47
Ground Water
Ground water 8ampling involved both Boutwell Spring, the only discharge point
discovered during the dye-trace studies, and Pirtle spring, the drinking water
source for the Howe Valley area.
1. Boutwell Sprinq: The results
detectable concentrAtions of acid
pesticides or volatile organics.
Drinking Water Standards.
of the Boutwell spring samples showed no
or base/neutral extractable organics, PCB,
All metal concentrations were within u.s. EPA
A trace amount of cyanide was detected at a concentration of 0.006 mg/L. This
sample, like the sediment sample, may have been contaminated by another source
since the field blank also contained cyanide at a concentration of 0.008 mg/L.
2. Pirtle Sprinq: Water from Pirtle spring showed no detectable pesticides,
PCBs, base/neutral or acid extractable organics, volatile organics, or metals.
On-site Soils
1. Inorqanics Analvses: Soil sampling for inorganics was undertaken in the
outlying areas of the site originally used for the disposal of drums containing
heavy metal sludges such as the blue-gray plating sludges and the
copper-cyanide bearing sludges. Figure 18 shows the location of the outlying
areas. Total size of these areas was approximately 45,000 square feet with
soil depths ranging from 1 to 3 feet. In order to accurately delineate
inorganic contamination, 23 samples were collected and analyzed for the
following contaminants of concern: copper, chromium, and zinc. Sample
locations are shown in Figure 19. These three metals were selected since they
were the primary contaminants in the sludges buried in the outlying areas. For
inorganics at the site, health-based cleanup levels can be established by
back-calculating soil ingestion risks to a hazard index of 1 for each
chemical. Assuming a 16 kg child ingested 200 mg/day of contaminated soil for
365 days/year, the following SALs for the contaminants of concern were
calculated:
Chromium VI
Copper
Zinc
400
2,300
16,000
mg/kg
mg/kg
mg/kg
Of the 23 samples, four were analyzed for u.s. EPA's Target Compound List (TCL)
of volatile organics, semi-volatile organics, PCBs, pesticides, metals and
cyanide. This was done to confirm that metals or organics, other than the
contaminants of concern, did not exist in the on-site soils.
Table 13 presents the results of the inorganic sampling and Table 14 presents
the TCL results. Locations where contaminants were found above SALs are shown
in Figure 20. Chromium was the only metal found to exceed the site SAL. This
occurred in two surface locations at concentrations of 680/690 mg/kg and
1,700/1,800 mg/kg. Coincidently, both locations had been previously selected
to undergo duplicate analysis.
-------
,-
Determination - Page 48
TABLE 11
TCL ORGANIC AND INORGANIC CHEMICAL CONCENTRATIONS
FOR ON-SITE SURFACE WATERS
- COMPOUND
FLOW INTO ON-SITE SINKHOLE (maIL)
1,1,1-trichloroethane
0.0044 J
Aluminum
Barium
Calcium
Iron
Copper
Potassium
Magnesium
Manganese
Sodium
Zinc
Cyanide
3.4
0.04
32
4
0.02
1.7
2.6
0.14
3.1
0.06
ND
*
J compound detected but below quantitation limit,
quantification suspect.
-------
Determination - Page 49
TABLE 12
TCL ORGANIC AND INORGANIC CHEMICAL CONCENTRATIONS
SEDIMENT SAMPLES
CONCENTRATIONS
(mg/kg)
BOUTWELL
CONTAMINANTS SINKHOLE SPRING
Phenol ND 0.2 J
Silver ND 0.9
Aluminum 10000 12000
Arsenic 5.7 0
Barium 50 260
Calcium 4200 6700
Cadmium ND 0.6
Cobalt 10 51
Chromium 46 85
Copper 35 10
Iron 15000 93000
Potassium 750 1200
Magnesium 830 1200
Manganese 630 5000
Sodium 57 120
Nickel 9 47
Lead 17 58
Selenium 1.3 ND
Thallium ND 9
Vanadium 16 36
Zinc 71 75
Cyanide 0.6 0.9
* Only chemicals detected are listed in table.
** J compound detected but below quantification limit,
quantification suspect
-------
Determination - Page 50
FIGURE 18
BOUNDARIES OF WASTE DISPOSAL AREAS
-------
Determination - Pa e -
A
100W
1 700N
2
3 eOOH
4
5
!SOON
8
7
..cON
e
9
10 300B
11
12 200N
13
14
lOON
1~
B
I
L
'H
c
D
G
K
E
J
F
300
o
o 10;';- ::-... 2001: B 4001
'-
(4 :\ I \ -/ POI ~AJ) I T,~ OF
1/
lr.- -A~
,[. I /io=G
\ l) \' "7 \/
- ft
I II
\ , ~. 'j
. )/
,(;
) W / N
/ ,," (
// I
I
/' ~ /n< I I
- / 1 \
'l \\ /
/' ". \\
/' '/ /'/ I \ \ / ~(
/. \\ t'-SINKH
A /./ II
, I J
~ .... ')...
,,, Y'/.:'/ .,' ~-... .,' ~ h)
I ~ /.~ 1"-..
- ~ - - .. .",
-
~- .-. II { ....
~ ~ ,/"-'.' ..... " ' ~
'l , ,, ~-
~I ~, II ~- --
/;/ , ~ I} -.
1/ 10 0 () 0 ~
- J I -~ I ~,
/// \ r ,4 OF
// OUu IU.I.'tG
""/ \ \ \ ,
/' - \ I ARE AS
- ~\.- ---..... ~ -..; \' .
~ . /!
' J
~ ~
. i ~ - 7- J;::'
~ 0 ./ ~
\ '
~, ..'" tI./ , ~
~~ ~ ~.- r ~ V ~;j
,, ~ ~-( l);:
~- .:::::: - / V
- - ~ ~
0 100" - -...:: ...;--- _.r / 7 )
--- - "'.... .' ~
I I " --/ 'l
SCALE --
------ -_ .../
( !7'
SAMPLING LOCATIONS /
. BrALS
0 ORCaNICS
.
.
I
~.!
OLE I
I
I
~
X TCL AHALTDS
FIGURE 19 .,
1990 ON-S~TE SOIL SAMPLING LOCATIONS
-------
1-
Determination - Page 52
2. Oraanics Analvses: Soil sampling for organics, with the exception of the
TCL samples in the outlying areas, was limited to the central area of the site
where silicone compounds had been disposed. Previous organic sampling was
conducted in the o~tlying areas and the only location found to exceed the SALs
was aerated. The approximate size of the central area is 50,000 square feet.
Soil depths range from 1 to 3 feet near the edges and up to 9 feet in the
middle. Twelve locations were selected'for sampling. Samples were taken at
the surface, at 3 reet and at bedrock (usually between 6 and 9 feet). In
total, 38 samples were collected and analyzed for the following organics:
l,l-dichloroethane, l,2-dichloroethene, l,l,l-trichloroethane and
tetrachloroethene. One location along the western side of the central area was
chosen to undergo TCL analysis for volatile organics, base/neutral and acid
extractables, pesticides, PCBs, cyanide and metals.
The four organics listed above were selected for analysis because they were
repeatedly found in waste samples and site samples more frequently and in
higher concentrations than any other compounds. All are slightly soluble, with
the exception of l,l-dichloroethane which is almost insoluble. Their primary
transport process is volatilization while the predominant environmental fate
determining process is oxidation. Persistence of these organics is fairly
low. When oxidation proceeds at a normal rate, a typical half-life can range
from several hours to two months. The only exception is for
~,l,l-trichloroethane which has a 'half-life of five months to 8 years. The
most toxic compound of the four is tetrachloroethane. It should be noted that
significant levels of tetrachloroethene concentrations still remained 16 months
after post-removal sampling, indicating that oxidation in the on-site
subsurface soils is proceeding at a very slow rate.
No Federal Applicable or Relevant and Appropriate Requirements (ARARs) have
been developed for contaminants in soil media. Action levels for soil cleanup
of organics at the site were established based upon MCLs and as a function of
the soil partitioning coefficient (Kd) values for individual compounds and
ground water concentrations resulting from the partitioning of these compounds
into the liquid phase. The Kd values were determined during soil column
tests.
Kd - Mass of Solute on Solid Phase/Unit Mass cer Solid Phase
Mass of Solute in Liquid Phase/Volume of Solution
A more detailed explanation is contained in Appendix C of the July 1990 RI
Report. The SALe calculated using the Kd data were compared with health-based
criteria and the more conservative value was implemented. The rationale for
this approach considered the fact that a Kd calculation is not representative
of ground-water flow in a karst terrain. The SALs were established to protect
human health and the environment. Safe Drinking Water Act MCLs and
health-based levels (when KCLs were not available) were used as cleanup
criteria for protection of ground-water. The SALs for the site are listed
below (l,l-dichloroethane does not have a drinking water standard from which to
calculate an SAL):
l,~,l-trichloroethane
1,2-dichloroethene
tetrachloroethene
117.30 mg/kq
7.72 mg/kg
> 7.50 mq/kq
-------
Determination - Page 53
TABLE 13
ANALYSIS OF OUTLYING SOILS FOR INORGANICS
CHROMIUM
CONTAMINANTS
COPPER ZINC
CYANIDE
SURFACE
I of hits 27 27 27 4
Cone. range (mg/kg) 11 - 1800 5.4 - 640 32 - 2000 ND - 3.6
i of hits above SAL 4 0 0 0
3 FEET (OR BOTTOM)
i of hits 21 21 21 4
Cone. range (mg/kg) 12 - 140 5.7 - 130 16 - 131 ND - 0.6
i of hits above SAL 0 0 0 0
> 3 FEET
i of hits 2 2 2 0
Cone. range (mg/kg) 12 - 19 2.1 - 7.2 14 - 43 ND
i of hits above SAL 0 0 0 0
Average depth> 3 ft. 6.0 6.0 6.0 5.5
where contaminants
were found
-------
Determination - Page 54
TABLE 14
SOIL TOTAL CONTAMINANT LIST ANALYSIS
SURFACE BOTTOM
CONTAMINANTS t of hits Ranqe t of hits Ranqe
(mg/kg) (mg/kg)
Silver 0 ND 0 ND
Aluminum 4 11000 - 15000 4 12000 - 18000
Arsenic 4 4 - 7.8 4 3.2 - 7.9
Barium 4 33 - 53 4 41 - 160
Beryllium 3 ND - 0.25 4 0.25 - 3.1
Calcium 4 1500 - 2900 4 1500 - 12000
Cadmium 0 ND 1 ND- 1.8
Cobalt 4 5.4 - 10 4 7.2 - 15
Chromium 4 16 - 170 4 11- 53
Copper 4 5.4 - 16 4 7 - 18
Iron 4 15000 - 22000 4 12000 - 27000
Mercury 0 ND 1 ND - 0.26
Potassium 4 160 - 1000 4 800 - 1900
Magnesium 4 660 - 1000 4 820 - 1600
Manganese 4 230 620 4 53 870
Sodium 4 68 - 130 4 80 - 120
Nickel 4 8.1 - 14 4 13 - 59
Lead 4 8.2 - 17 4 12 - 14
Antimony 0 ND 0 ND
.. Selenium 0 ND 1 ND - 2.4
Thallium 0 ND 1 ND - 6.8
Vanadium 4 15 - 21 4 4 - 25
Zinc 4 42 - 210 4 16 - 131
l,l,l-TCA 2 ND - 0.015 1 ND - 2.7
PCE 3 ND - 6.0 1 ND - 25
1,2-DCE 0 ND 1 ND - 0.62
Butyl benzyl
phthalate 0 ND 1 ND - 0.07 J
Diethyl phthalate 0 ND 1 ND - 0.10 J
2-methylnapthalene 0 ND 1 ND - 0.06 J
Napthalene 0 ND 1 ND - 0.09 J
Bis (2 ethylhexyl)
phthalate 1 ND - 0.3 J 0 ND
Trichloroethene 0 ND 1 ND - 0.69
1,1,1-TCA = 1,1,1-trichloroethane
PCE = tetrachloroethene
1,2-DCE = 1,2-dichloroethene
-------
Determination - Pa~e SS
I ':Oy B C
. 1 ?OON
D
E
F
G
H
I .
J
K
L
12 200M
~
13 ':::
I
,,~ I
1
" I
I
14
I
lOON 0 I
I .
15 SCALE I
--- --
SAMPLING LOCATIONS
,
. .. KlTALS I
o ORGAHICS I
I
o X TCL .uw.Y'SES !
LOOTS 0 F
o U'I1j. TING
ARtAS
I I
I A I
Irl
I I I I
I I I
I I
I SINKHOLE!
2
3 1500N
4
5
50QN
8
7
400N
8
9
0 0
10 300N
11
Surface
FIGURE 20 ..
SAMPLING LOCATIONS FOR INORGANICS
samples - Chromium concentration aDove SAL
. (mq/kq)
-------
Determination - Page 56
Results of the sampling are
Tetrachloroethene was found
concentration was SO mg/kg.
of the surface soil samples.
presented in Table 15 and are discussed below.
in one surface location above its SAL. The actual
The other three organics were not detected in any
Samples collected at 3 feet contained l,l,l-trichloroethane, 1,2-dichloroethene
and tetrachloroethane above their SALs. The broadest spacial distribution at
this depth was found for the compound tetrachloroethene. Only one sample taken
at 3 feet contained l,l-dichloroethane above its detection limit. For samples
deeper than 3 feet, primarily at 6 and 9 feet, l,l,l-trichloroethane and
tetrachloroethane were found above their SALs. Concentrations and locations
are presented in Figures 21 through 26.
3. Cvanide Analvses: Five locations, four in the outlying area and one in the
central area, were selected to undergo TCL analysis which included analysis for
cyanide. Out of a total of nine samples collected, four had detectable
concentrations of cyanide; three samples below 1 mg/kg and one at 3.6 mg/kg.
The calculated health-based soil action level for cyanide is 1,600 mg/kg.
Summary
Approximately 7,500 cubic yards of near-surface and subsurface soils deeper
than 6 inches are the primary contaminant sources remaining at the site.
Although two locations were found to contain total chromium concentrations
above the SAL, 1, 1, I-trichloroethane, tetrachloroethene and 1,2-dichloroethene
are the major contaminants at the site. These volatile organic compounds were
found in the central portion of the site where non-containerized wastes were
buried. Individual locations in the central area exhibited trichloroethene
concentrations from as low as none detectable to as high as 800 ppm (below 3
feet deep). It must be noted that samples analyzed for the Total Compound List
did show very low levels of inorganics in the central area and traces of
organics in the outlying areas, however neither the inorganics nor the organics
in these locations were found at concentrations that caused a health or
environmental risk.
Contaminated soil volumes were estimated using topographic survey data and an
overburden thickness map. Both an overburden thickness map (Figure 27) and a
cross sectional profile of the site (Figure 28) are shown on the following
pages. The extent of contamination remaining at the site is depicted in
Figure 29. The calculated volumes are presented below:
Metal Contaminated Areas
Area 1:
Area 2:
Total:
35 feet x 35 feet x 0.25 ~eet = 11 cubic yards
35 feet x 35 feet x 2.00 feet ~ 91 cubic yards
102 cubic yards of on-site soil
Oraanic Contaminated Areas
Area 3:
Area 4:
Area 5:
Total:
(0.5 x 205 feet) x 102 feet x 5.1 feet
102 feet x 102 feet x 4.5 feet = 1,734
102 feet x 170 feet x 5.8 feet = 3,725
. 7,434 cubic yards of on-site soi~
= 1,975 cubic yards
cubic yards
cubic yards
-------
Determination - Page 57
TABLE 15
ANALYSIS OF CENTRAL AREA SOIL FOR VOLATILE ORGANICS
SURFACE
t of hits
Cone. range (mg/kg)
t of hits above SAL
3 FEET
t of hits
Cone. range (mg/kg)
t of hits above SAL
> 3 FEET
t of hits
Cone. range (mg/kg)
t of hits above SAL
Average depth> 3 ft.
where contaminants
were found
1. 1. 1-TCA
CONTAMINANTS
1.2-DCE
PCE
1. 1-DCA
6
ND - 5.8
1 10 0
ND - 0.007 ND - 80 ND
o 1 0
4 9 1
ND - 20 ND - 400 ND - 13
2 7 0
o 6 0
ND ND - 800 ND
o 3 0
7.17
o
8
ND - 340
2
4
ND - 200
1
7.25
-------
Determination - PaQ:e 58 .
I ABC
100'"
1 ?OON
2
3 800N
4
5
GOON
8
7
.wON
8
9
10 :JOON
11
12 ZOON
13
14
lOON
15
a 10~ ...... 200
I (; '\ ( '\ 1/ Faf ~AD 1 1
,,/ LIMITS OF
. / ACC~
I. [70~~1G
_\: J \' 1'/ \/
II I I
I II
\' ]~ '7 I~I
- 1/
, I N I
) / W.
I I I I I
I
I
V v :v """......J<' I ! ~
- / r \
'l \\ /
~ 1,," \\ '-- "- \ SINKH
[7 V /'/ 1/ ...... 7
\\
/ / /.'/ 11
v'" ~ II
I., ~
'r'> Vh'/ ~, ---..... T] ~ h)
- I ~ ~9' ,.' '1-- -.. ~
~-- ..... " ', ( -
~ ~ /.'l'.~ -- I r ~ ~
'/ , I \ ~.
,-/ .' II ~. --
'/ , 170 }' ...
II
1/ 10 ~~ 0 ) () 0 '
I~'
- I I -~ I
......// ~, ," OF
I OUT! YING
.// ,
:// \. \ 3 0 I A1U AS
-. ,
- ~,- ..-_1 ~ "" "'" .
~ I V1
, -0 ! -'
~
.. ~ - - ~::
~ 0 /"" v- ~
\ '
~, ~, I '/.-'" ~
",:: ~ ~.- ~. -~ /' J P
~ ..... 'l-r ~~
... -.::::: ~ '- ,I
---. - - - -'" / Y )
0 100' - -- -" ~
I I ,,~ - - . ::~
SCALE . --
~----- ( IV
SAMPLING LOCATIONS V
. ~.wi I
0 DBC.\N1C9
.
o
D
F
H
K
L
I
. J
G
E
E
SC02
~OOE
01.£
:::::::.
.
X TCL ANALYSES
FIGURE 21
SAMPLING LOCATIONS FOR ORGAN~c~ ",
3 feet - 1,1,1-trichloroethane cone. above SAL
(mg/kg)
-------
Determ;n::lt";nn
,
- ?aQ'e ;\f.
I A B C D E F G H
'1 100Y
?OON
2
3 eOON
.{.
5
600N
8
7
400N
8
I
. J
9
0 0
10 300N
11
K
L
400E
llYITS 0 F
o UTL. YING
I
ARIAS
I I
I A I
Irl
I I I
I I
I
I SINKHOLE
12 200N
~
~
13
""~
"
14 .:::::
100N 0
I .
15 SCALE
--- --
SAMPLING LOCATIONS
. K!:1'.AI3
0 ORCANIC9
0 X TCL ANALYSES
FIGURE 22
SAMPLING LOCATIONS FOR ORGANICS
> 3 feet - l,l,l-trichloroethane conc. above SAL
(mg/kg)
-------
Determi~~rio~ - Page 60
JAB C
I .
100Y
1 700N
2
3 eOOK
4
5
5CON
8
7
.wON
8
9
10 300K
11
12 ZOON
13
14
100N
15
. 10";:- - 200
C' \ r - '\ 1/ rei ~AI) T ~s OF
. 1,1-- - ACC!!::
/ "" 7ro~~G
I
'C J \' I, / \/
" I I
I II
\ ' AI, / I~I
-
I;
/ I N I
) W
/; / I' ..
I I' I I I
1
I
,/ Y:f ' I ~« I
- / // \
'l \\ /
./ fl' \\ I
/ /" /'/ I \\ /
/ ~ ~/ II I SINKH
/" II
~ ..
i/ , 7h" ~' ~........ .. I I ~ ~
I ~ ~9' "1'--
- ~.-- _1 .. .., -
.- " ( -
~ ~ -'l' 4 ...., , I ~ ~
'l , II ~.
.'
,./ II ~- --
/1 , II i
1./ 10 ~ s 0 J) () 0 '
- 1 1/ ~ I ~,
/// \ I ,~ OF
,// oun YING
;../ \ 15 20 \ , ARE AS
- \ ,
.. .,- -.",- ..... I ~...., \' .
~ I VIi
, ~ !
~ J'
- i ~ -- ~ ~::
~ 0 ./ ~
~" \ '
~, 1 :/-" '"<; -
..~ ~ ~..- " ~ / J ~::J
~ ~ 'l( /;,~
~ -.::::::--- -- /. :..-: V
...... :-- -'/ U )
0 100' ....... -- - '...... ..0
I I '~
SCALE --- -~
------ -- -
SAMPLING LOCATIONS ( V~
. WETALS
0 OBc.\N]CS
D
E
H
-J
. I
F
G
o
E
saO!
a
X TCL ANALYSES
FIGURE 23 {
SAMPLING LOCATIONS FOR ORGANICS
3 feet - 1,2-dichloroethene cone. above SAL
(mq/kq)
K
L
400£
OLE
~
-------
- PalZe 1)1
np~~rm;n:1,..il"\n
lOOT
~ 7QON
2
3 eOOH
4
5
600N
6
7
.OON
8
10 300N
11
12 200N
13
14
lOON
15
A
B
c
D
H
K
4QOE
o 10~' .......... 200E 50
C' :\ / '/ AC~~AD I ~s OF
I;
. /L
, '0 ~ 0UTItYING
\ J \~ "I \/ AREAS
" I I
I /}
,-' )1, I 14.1
- II . I I
".
) W
/ // N
/ / ~ I I I
;
I,'
/ ,/ o/:f I I ~~ I
- / '
// \\
./ '/ \\ I I
/' '/ /'/ / \\ /
-/ A "'::/ , I I SINKH
/" II
,/ ~ ...
''1. /" 7'.,. ~# ~........ .. I I ~ h)
I ~ ~ -' "1,..... .. .. "
- -- ~
~ eo - II { .....
~ ~ ~'.. '" " ' ~
'l' I \ ~.
,1 .' II ~- ..-
/1 , II ....
;1 10 ~:> 0 J (~ 0 '
/ 0,- J , I~'
- I
/// \ ," ~ S OF
I OUT] YING
,,/ ,
V/ \ \ I ARE AS
- \
~,... -",---1 \>;;T \\ . /!
' ~ .
!
~. ~ /'
- i' ~ - V"::: l~
~ 0 /" ~
\ '
~, ..' I ~~ ~
~ ..... ~-- r ~ '/ I f{
~ ..... ~-( W~
...~:-- - /. ~
- --- -" / / )
0 100" - --- -', ~
I I '.....: -- 1-::;:::'
SCALE -- ...
-- -- -- -(
SAMPLING LOCATIONS V
. lal'ALS
0 ORGANICS
G
F
I
.J
E
02
o
X TCL ANALYSES
FIGURE 24
SAMPLING LOCATIONS FOR ORGANICS
Surface samples - tetrachloroethene conc. above SAL
. (mq/kq)
L
OLE
--
'-
.
-------
1
lOOT
700N
2
A
B
.F
G
L..
H
C
1
K
D
E
,j
5002
4001:
I
P'OR1mK
ACC!39 ROAD
I
LOOTS 0 F
o UTIj. TING
ARtAS
I I
I !\ I
111
I I I
I I
I
I SINKHOLE
3 eOON
4
5
GOON
8
7
..oON
8 92
9
0
10 300N
11 38
12 ZOOM
13
14
100N
15
:"...
,,~
'"
,,~
"
o
I
SCALE
---
--
SAMPLING LOCATIONS
. Wln'ALS
o O~jt'S .'
CI .; ".' ""'" . i't:j.l'm~
. ... ..~" -..".. - - .'~:._~:~~:'.~.:_~~:....- -.~__1-'----_.
. FIGURE 25
SAMPLING LOCATIONS FOR ORGANICS
3 feet - tetrachloroethene cone. abdve SAL
(mq/kq) . "..
Determination - Page 62
-------
Determination - Page 63
I ABC
I
----
D E F G H I J K L
4002:
UMltS 0 F
O~~G
I I
I~I
I N I
I I I
I I
I
I SINKHOLE
lOOT
?CON'
2
3 eOON -
4-
5
500N -
e
7
.wON -
8
j
10 300N -
11
12 200N -
~
~
13
,,~
"
14
lOON -
o
I
.
15
SCALE
--
SAMPLING LOCATIONS
. Ja:1'JLS NS NOT SAMPLED DUE TO
o ORC.ANICS THIN son. COVER
o - X TCL ANALYSES
FIGURE 26
SAMPLING LOCATIONS FOR ORGANICS~
> 3 feet - tetrachloroethene conc. above SAL
. (mq/kg)
-------
Determina~ion - Page 64
TABLE 16
RESULTS OF PHYSICAL ANALYSIS ON SOILS COLLECTED
WITH SHELBY TUBES
Bulk Density
specific Gravity
Porosity
Volume
Dry Weight
Moisture Content
Organic Content
Hydraulic Conductivity.
Description
1. 935 gm/cm3
2.64
43.1\
271. 95 cm3
408.55 gm
28.95\
2.35\
3.1 x 10-9 cm/sec
Clay, Silty
Brown, Mottled
Physical data is presented as an average of the two
soil samples collected from the site.
.
Hydraulic Conductivity for
the limestone. This value
the hydraulic conductivity
Fetter, 1988.
clay overlying
is consistant with
for clay as shown in
-------
I Determination - Page 65
I
100'1'
700N'
SQOE
400S
lOOK
I..IMITS 0 F
OUTLYING
AREAS
~
SOON
~
400K
SOOK
200K
~ CENTRAL
~ AREA
~
~
~
~,
""'--...
-"
100'
I
a
I
SCALE
I I I I , SINKHOLE
A A' CROSS-SECTION UNE
- 4 - THICKNESS CONTOURS (FEEr)
a
. FIGURE 27
APPROXIMATE OVERBURDEN THICKNESS MAP
WITH CROSS-SECTION LINE
-------
I Determination - Page 66
A
700
690
685
680
,
, ,
,""
,
SAMPLE LOCATIONS
(See F1;ure 5-3)
9.SE
11, F.S
675
670
o
. . . . . .
. . . . . . . . . . . . . . .
. . . . . . . . . . . . . .
. , . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . SOIL. . . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
BEDROCK
1 0
700
200
400
500
600
300
a 100.
I I
HOR!ZONTA!...
SCALE
VERTICAL EXAGGERATION = 25 X
, 'J VERTICAL
o SCALE:
FIGURE 28
DIAGRAMMATIC SOIL CROSS~SECTION
-------
r,mic,::qn -
700M I
Page 67 '
1001t
o
SOOK
400£
AREA 1 ".'.'
LDm'S 0 F
OU1'L YING
AREAS
eOON
IA
N
I
~oaN
400H
'~OK
LOOTS OF
OU'l'L YING
AREAS
200H
o
I
.
SCALE
SAMPUNG LOCATIONS
8NETALS
o ORCANICS
.
o
.~
-- ----
FIGURE 29
AREAS WITH CONTAMINATION ABOVE
SOIL ACTION LIMITS (SALS)
-------
1-
Determination - Page 68
Pathways of Miaration
Exposure to air and warmer temperatures, causes the volatilization of organics
located near the surface of the site. The very small pore spaces in the clayey
subsurface soils prohibit rapid vOlatil,ization of the deeper volatile
organics. Only at ~ very slow rate over a period of years would these
compounds be able to diffuse through the soil and reach the surface where they
could escape into the atmosphere. Typically, such trapped organics undergo
biodegradation, however the process at this site is estimated to proceed quite
slowly.
Organic contaminants can migrate from the soil to the ground water beneath the
site as rainwater percolates downward through the soil column. Soil action
levels were back-calculated for 1,2-dichloroethene, 1,1,1-trichloroethane and
tetrachloroethene in order to protect ground water at the site. Due to the
lower concentration of 1,1-dichloroethane on-site and its insolubility in
water, a SAL for 1,1-dichloroethane was not calculated. The degree to which a
compound will tend to remain attached to the soil as water passes through the
soil can be described by its soil/water partition coefficient (Kd). The higher
the Kd, the more that compound tends to be retained by the soil. For the
compounds of concern present at the site, the Kd ranged from 1.47 for
1,2-dichloroethene to less than 20 for tetrachloroethene. Physical analysis of
the site soils (as shown in Table 16), indicate that the hydraulic ~onductivity
of the soil is low. Even though the site soils are relatively impermeable,
rainwater will still percolate down through the soil, dissolving contaminants
to a degree dependent on each contaminants' Kd. Eventually, the ground water
beneath the site, containing leached contaminants from the soil, will flow
through the underground conduits formed by natural dissolution of the limestone
bedrock towards Boutwell Spring and into Linders Creek.
An additional route for migration would be surface water running across the
site. Such water, although present only during and immediately after
precipitation events, could carry surface contaminants, either dissolved into
the water or adsorbed onto soil particles, into the on-site sinkhole or onto
property adjacent to the site.
SUMMARY OF SITE RISKS
A baseline ri.k a.sessment was conducted for the Howe Valley Landfill Site and
is presented in the Risk Assessment Section of the July 1990 RI Report. The
risk assessment consisted of the identification of chemicals of interest, an
exposure assessment, a toxicity assessment, and the characterization of
environmental and human health risks.
Identification of Contaminants of Concern
The identification of hazards at the site began with the selection of the
contaminants of concern. These contaminants were found in the environment
during the RI and have inherent toxic and/or carcinogenic effects that could
threaten the protection of public health and the environment. Three inorganic
-------
Determination - Page 69
metals, copper, chromium and zinc, and cyanide were considered potential
contaminants of concern due to the presence of drummed heavy metal plating
wastes buried at the site.
One acid extractable organic compound, 4-methylphenol, was detected in one
sample from the on-site pond. Since it ,was not detected in subsequent sampling
activities and ~eve~ detected in any waste samples, it was not considered a
contaminant of concern. Additionally, six base/neutral extractable organic
compounds were detected in on-site soil samples. Two of these compounds,
napthalene and 2-methylnapthalene were found in only one sample in
concentrations below detection limits, therefore they were discounted as
chemicals of interest. The remaining four base/neutral extractable organics,
di-n-butyl phthalate, butyl benzyl phthalate, d~ethyl phthalate and bis
(2-ethylhexyl) phthalate, were also discounted as contaminants of concern.
Di-n-butyl phthalate was suspected to be a result of laboratory contamination
since it was found in trace quantities in a majority of samples, including the
field and laboratory blanks. Butyl benzyl phthalate was also a result of
laboratory contamination, where as diethyl phthalate was a result of field
contamination from the sampler's latex gloves. Bis (2-ethylhexyl) phthalate,
which degrades fairly quickly and is almost insoluble in water, was found
in1988 in samples taken from the insulation pile and the underlying soil.
Since this compound was discovered in only one March 1990 soil sample
(estimated concentration of 0.3 ppm) it was not retained as a contaminant of
interest.
Three volatile organic compounds were repeatedly detected in significant
concentrations in the on-site soils. They were also the primary constituents
of the wastes found on-site, therefore they were selected as contaminants of
concern. Although 1,1-dichloroethane was detected in wastes removed from the
si~e and in samples collected in 1988, it was detected in only one 1990 sample
at very low concentrations. As a result, it was not considered a concern at
the site.
Selected contaminants of concern are:
Inorqanics
- copper
- chromium
- zinc
- cyanide
Orqanics
- 1,2-dichloroethene
- l,l,l-trichloroethane
- tetrachloroethene
Dose-Response Evaluation
The dose-response evaluation presented available human health and environmental
criteria for the contaminants of concern, and related the chemical exposure
(dose) to expected adverse health effects (response). An explanation of how
these values were derived and how they should be applied is presented below.
-------
Determination - Page 70
Cancer potency factor (CPFs) have been developed by the u.s. EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with
exposure to potentrally carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg/day)-l, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg/day, to provide an upper bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term
"upper bound" reflects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimating of the actual cancer risk
highly unlikely. CPFs are derived from the results of human epidemiological
studies or chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Reference doses (RfDs) have been developed by the U.s. EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of mg/kg/day, are
estimates of lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict the effects on humans). These
uncertainty factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur.
For noncarcinogens, the risk to human populations is determined by comparing
the RfD to the Chronic Daily Intake (CDI). The CDI is the long-term daily
concentration of a chemical to which an individual is exposed. A Hazard Index
(HI) of less than one typically indicates that there are no appreciable risks.
Noncarcinoaens:
CCDI)
(RfD)
- Hazard Index
The product of the CPF and CDI provides an estimate of lifetime cancer risks to
human populations.
Carcinoaens:
(CDI x CPF) = Lifetime Cancer Risk
The lifetime cancer risk is the probability that a specific adverse effect will
occur under the defined conditions of exposure. This particular method assumes
that cancer risks are additive so that the overall cancer risk can be
established by summing the incremental risks.
For carcinogens or suspected carcinogens, a quantitative risk assessment
involves calculating the risk levels considered to represent the probability or
range of probabilities of developing additional incidences of cancer under the
prescribed exposure conditions. The expressed risks are probabilities
generally expressed in scientific notation (e.g. 1 x 10-6). An excess
lifetime cancer risk of 1 x 10-6 indicates that, as a plausible upper bound
estimate, an individual has a one in one million chance of developing cancer
over a ?O-year lifetime as a result of site-related exposure to a carcinogen.
These calculated risk estimates should be evaluated against a target level.
-------
1-
Determination - Page 71
Risk levels of 1 x 10-4 to 1 x 10-6 can be used to determine the
"environmental significance" of the risk incurred and are used as a target
ranie for remedial~urposes (U.S. EPA, 1988). A risk level greater than 1 x
10- is considered to present an unacceptable risk with regard to human
-6
health in an environmental context, whereas risk levels less than 1 x 10
are considered acceptable by EPA. The term "insignificant" is not meant to
imply acceptab~lity; however, it puts numerical risk estimates into
perspective.
Exposure and Toxicitv Assessment
The exposure assessment identified potential pathways and routes for
contaminants of concern to reach the receptors and the estimated contaminant
concentration at the points of exposure. Contaminant release mechanisms from
environmental media were also presented.
At the Howe Valley Landfill, the current receptor population was identified as
limited to the residential community surrounding the site and persons that use
the site for hiking, hunting and riding dirt bikes or all-terrain vehicles.
The potential exposure pathways evaluated included the direct or incidental
ingestion of surface water and the inhalation of dust produced by dirt bikes or
all-terrain vehicles. Exposure to site subsurface soil deeper than 6 inches
was not anticipated to occur under current conditions or future-use
conditions. Future receptor populations could include residents living in a
house built on the site. Under such a future scenario, potential exposure
pathways would be the same as those previously mentioned but should also
include the direct contact and/or the ingestion of ground water.
Off-site pathways were not evaluated in the risk assessment because significant
contamination attributable to the site was not found off-site. During high
water flow periods, some surficial soil and sediments could be flushed into the
on-site sinkhole, however the dilution and spatial distribution off-site would
decrease contaminant concentrations to below detection limits.
Risk Characterization
In this risk assessment both the Probable Average Risk (PAR) and the Possible
Maximum Risk (PMR) were calculated for each group of chemicals. The PAR used
most probable exposure assumptions to estimate average risk. The PMR increased
exposure assumption values to estimate the maximum risk that would be expected
to be experienced by an individual.
A.
Current Site Use
The following scenario was based upon the assumption that an individual could
access the site either by foot or by vehicle. CUrrently, warning signs are
posted at the primary entrances, however the site is still accessable. The
risk assessment for current site usage assumed that a local individual could
access the site for a total of 55 years; as a child (6-11 years old).and as an
-------
-;
Determination - Page 72
adult (12-62 years old). Using information from the National Weather Service
in Louisville, Kentucky, it was also assumed that weather conditions would only
be favorable for children to play at the site 120-180 days per year. Of these
days, a child would only play at the site 67% of the time or 40-60 days. Older
children, above age 12, and adults were assumed to hunt on the site for an
average of 20.8 days per year (U.S. Department of the Interior and U.S.
Department of Commerce). For calculation purposes, the frequency was assumed
to be 20 days per rear for the PAR and 40 days per year for the PMR. For
lifetime usage, a 25-year duration was utilized for the PAR and 50 years for
the PMR.
Risk calculations assumed that a child between 9 and 10 years old would weigh
approximately 30 kg or 66 Ibs. The contact rate was established from the
estimated exposure surface area for the arms and hands of 1880 cm2 and a
contact rate of 0.5-1.5 mg/cm2. The resultant soil contact rate was 940
mg/day for the PAR and 2820 mg/day for the PMR. The average weight and years
of exposure for an adult at the site was assumed to be 70 kg and 70 years.
1. Risk from On-site Surface Soil: The soil ingestion rate for a child at the
site for the PAR and the PMR were assumed to be 100 mg/day and 200 mg/day,
respectively (U.S. EPA, 1989). The adult soil ingestion rate was calculated to
be 50 mg/day for the PAR and 100 mg/day for the PMR. Soil contact rates were
495 mg/day (PAR) and 1485 mg/day (PMR). Absorption percentages were 10% for
volatile organics and 0% for inorganics. When the risk was recalculated
assuming 1% dermal absorption of inorganics from soil, the risk was not
significantly increased (results not tabled). A summary of the risk assessment
criteria is presented in the Risk Assessment Section and Appendix G of the July
1990 RI Report.
Individual risks, calculated for each soil sample location, are presented in
Table 17. Figure 30 was included to show the sampling locations. The total
lifetime cancer risk associated with exposure to on-site soils at a specific
location ranged from no detectable increase in risk to a maximum risk of 1 x
10-6. The average risk associated with exposure was 1 x 10-9 and 5 x 10
-9 for the PAR and PMR, respectively. The total HI for noncarcinogens
averaged from 2 x 10-3 (PAR) to 7 x 10-3(PMR). Returning to the same area
for a lifetime could result in a risk with a maximum calculated HI of 0.4.
HIs were above 1, indicating risks are minimal.
No
2. Risks from On-site Surface Water: Although on-site surface waters are
ephemeral and shallow, for the risk assessment they were assumed to be 1 foot
in depth; deep enough for exposure to hands, feet and lower legs. The average
total body surface area for a 9 to 10 year old male child was 10,700 cm2.
The surface area potentially exposed to surface water was calculated to be
2,675 cm2. Duration of a child's exposure for the PAR and PMR were 30
minutes and 60 minutes, respectively. .Assuming hunters wore waterproof boots,
the duration of contact was 15 to 30 minutes. For adults standing in surface
water, the exposure area was 2,200 cm2.
Since ponds do not exist on-site and the intermittent streams only flow after
precipitation events, the risk calculations for surface waters included only
the one sample collected in March 1990. Actual concentrations in the sample
were used to calculate risks. No carcinogenic compounds were found. therefore
-------
Determination - Page 73
their risks could not be calculated. The HI for the noncarcinogens were 2 x
10-4 (PAR) and 1 x 10-3 (PKR). Results are presented in Table 18.
3. Air Emissions: The primary source of exposure to air contaminants is
through the dust generated or volatiles released by riding dirt bikes or
all-terrain vehicles across the site. Risk calculations were based upon the
model developed by ~CF Clements (1989). Emission rates and air concentrations
estimated from dust generation are presented in Table 19. The human health
risks associated with this source are presented in Table 20. The total
lifetime cancer risks ranged from 3 x 10-8 (PAR) to 7 x 10-7 (PKR). The
additional risk due to volatilization of contamination associated with dust
particles is minimal, since the PKR associated with PCE (the organic volatile
organic contaminant of concern) is only 6.6 x 10-13.
B.
Future Site Use
Under this scenario it is assumed that a house could be placed on the site.
The same potential points of exposure, i.e. air, intermittent streams and soil
would still exist, however the risk associated with air and surface water would
be much smaller than the risks associated with soil and on-site ground water.
Short-term exposure to volatile organics released into the atmosphere could
result from excavation activities if undertaken in the central area of the
site. Based upon air monitoring during the soil aeration project, total
volatile organics could initially be 300 ppm above the aerated soils, but would
fall below 50 ppm within an hour. OSHA's 8-hour time weighted average limits
individual organics to a range of 100 to 350 ppm, however, due to dispersion,
the concentration of volatile organics in the breathing zone of construction
workers would be considerably less than these values.
1. Risks from On-site Soil: The future use scenario assumed that a child
could dig down approximately 6 inches and be exposed to contaminated soil.
should be noted that, with regard to volatile organics, an individual would
have to dig down in different areas or to several different depths in the same
area each day to expose fresh soil surfaces to be exposed to compounds at
elevated concentrations.
It
For on-site residents, children's ages ranged from 2 to 12 years old with
average age being 7 years old. The average weight for such a child was
estimated to be 25 kg (U.S. EPA, 1989). The exposure frequency rate for the
PAR was 120 days per year and for the PKR 240 days per year. Adults would be
exposed for a duration of 25 to 50 years with 40 to 120 days of exposure each
year. Soil contact rates, absorption data and incidental soil ingestion rates
remained the same as those in the current use scenario. As with the current
use scenario, when risk was recalculated assuming 1\ dermal absorption of
inorganics from soil, the risk did not ~ncrease significantly.
Calculated risks for each soil sampling location are presented in Table 21.
Figure 30 shows each location. The total cancer risks ranged from none
detected to 1 x 10-5. The average cancer risk for the site was calculated at
7 x 10-9 (PAR) and 4 x 10-8 (PKR). The HI for noncarcinogens ranged from 5
x 10-5 to 2. The average HI for the PAR and PKR were 8 x 10-3 and 3 x
10-2, respectively.
-------
I -
Determination - Page 74
TABLE 17
SUMMARY OF RISKS ASSOCIATED WITH CONTACT AND INGESTION
OF SURFACE SOIL (6 - 10 inches)
(CURRENT SC~ARIO)
SOIL LIFETIME RISK ASSOCIATED HAZARD IND£X RISK ASSOCIATED
SAMPLING CANCER RISK CHEMICAL CHEMICAL
LOCATION PAR PMR PAR PMR
IF NA(l) NA - 2£-03 5£-03 -
IG NA NA - 42-03 U:-02 -
LSD NA NA - 6£-02 22-01 -
2D NA NA - 2£-02 61:-02 -
2F 6£-10 3£-09 - 1£-03 42-03 -
2G NA NA - 31:-02 9B-02 -
3F 9£-11 5£-10 - 11:-02 4B-02 -
3G NA NA - 11:-03 U:-O 3 -
31 NA NA - 2£-03 52-03 -
4G NA NA - 5£-03 22-02 -
41 NA !fA - 1£-02 32-02 -
SF NA !fA - 71:-03 2£-02 - .
5H NA NA 32-03 92-03 - .
-
51 NA NA - 6£-03 2E-02 -
6£ NA NA - 3£-03 9£-03 -
6H NA NA - 2£-03 52-03 -
7C NCC NCC - 92-03 32-03 -
7D NA NA - 1£-01 41-01 -
88., NA NA - 52-03 1£-02 -
8E 3£-07 1£-06(2 Tetrachlcrcethene 6£-03 22-02 -
8F.5 2£-09 8£-09 - 4£-05 1£-04 -
.8H 2£-08 1£-07 - 5£-04 2£-03 -
8L !fA NA - 1£-03 3£-03 -
9.5C.S 1£-09 7£-09 - 32-05 1£-04 -
9.5£ 2£-08 U:-01 - 31:-03 12-02 -
9.5F.5 NCC NCC - !fA NA -
9.5H NCC NCC - NA NA -
9.51.5 NCC NCC - NA NA -
112 62-10 3£-09 - 11:-05 52-05 -
111'.5 5£-09 2B-08 - 1£-04 4£-04 -
11H lice Nce - !fA HA -
12.5P.5 81-09 4£-08 - 2£-04 12-04 -
14J IIA irA - 22-03 51-03 -
151 NA IIA - 2£-03 6£-03 -
15J NA NA - 2£-03.- 52-03 -
-'...
- .
- -'
( 1 )
( 2 )
NA - Organics of
NCC - No ch~mical
Equals or exceeds
carcinogens and 1
inorganics not analyzed
of concern detected in the sample
target risk levels of 1 x 10-6 for
for noncarcinogens
-------
nprprmin~rion - Paie 7~
I I~O" B C
f 700N I
2
3 eaON
4-
5
!SOON
8
7
~ON
B
9
10 300N
11
12 200N
13
l'
100N
15
D
I
. J
B.
K
L
G
E
F
UYlTS OF
O~G
~.I
N
I
~
~
:::::::.
,,~
"
o
I
SCALE
---
--
a
SAMPLING LOCATIONS
. KJ:1'WJ
o o~cs
X TCL A!w.:m:s
i
FIGURE 30
ON-SITE SOIL SAMPLING LOCATIONS .,
1990
-------
Determination - Page 76
TABLE .l.~
RISKS FROM ON-SITE SURFACE WATERS
NCNCARCINOGEN:C RISKS (~:~£CT C9NTACT)
I : RfD I HAZ';RD r~IC:::::3
I CONC MAX CCNC
CHE~1!CAL (mgjL) (mgjL) : (:ngjkgjday) PAR I :::'!?
CHE.D ! \
I !
I
l,l,l-Trichloroe~hane 4.00E-03 4.00E-03 ; 9.00E-02 3.20E-08 I 9.5:'=:-:3
,
~;'.:ARD INDEX \ J.2=:-08 I 9.6E:-.J8
i
Po.Dt:L T I I \
I
I
l,l,l-T~ichloroethane 4.00E-03 I 4.00E-03 9.00E-02 I 7.06E-10 \ 2.32E-09
I ..
H';ZARD INDEX 7.1E-10 \ 2.9E-09
NONCARCI~ICGENIC RISKS (DIGESTION)
,
CONC MAX CCNC RfD HAZARD IND!CES I
CHEM!CAL (mgjL) (mgjL) : (mg/kgjday) PAR ! ??-!R :
;
CHILD I
I
I I
1,1,1-Trichloroethane 4.00E-03 4.00E-03 9.00E-02 1.62E-06 1.22:::-':6 I
Copper 2.00E-02 2.00E-02 I 2.90E-02 2.52E-05 1.89E-':" \
I I
Zinc 6.00E-02 6.00E-02 2.00E-Ol 1.10E-05 8.22£-05 I
Cyanide 6.00E-02 6..00E-02 ' 2.00E-07 1.10.E-04 8.2:2:::-C~ '
i !
HAZARD INDEX 1. 5E-04 1.1.£-03 ;
I
i
ADULT -'''.. I .' I
"".. - !
1,1,1-Trichloroethane 4.00E-03 4.00E-0~ 9.00E-02 8.70E-08 8.70E-07 I
Copper 2.00E-02 2.00E-02 2.90E-02 1.35E-06 1.J5E-C5
Zinc 6.00E-02 6.00E-02 2.00E-Ol 5.87E-07 5.87E-06 I
Cyanide 6.00E-02 6.00E-02 2.00E-02 5.87E-06 5.8;E-05 I
HAZARD INDEX 7.9E-06 7.9E-05 I
I
. I i
t .
i
TOTAL HAZARD INDEX - 1.6E-04 1.2E-CJ i
-------
Determination - Page 77
TABLE 19
ESTIMATED EMISSION RATES AND ON-SITE AIR CONCENTRATIONS
DUE TO DUST GENERATION BY DIRT BIKES
ESTIMATED EMISSION ESTIMATED AIR
RATB CONCENTRATION
SURFACE PROBABLE POSSIBLE
SOIL AVERAGE MAXIMUM PROBABLE POSSIBLE
CONCENTRATION RATB RATE AVERAGE MAXIMUM
CHEMICAL (mq/kg) (mq/sec) (mq/sec) (mq/m3) (mg/m3)
-
1,2-Dichloroethene 1.0E-01 1.7E-OS 1.0E-04 7.0E-11 4.2E-10
Tetrachloroethene 6.2E-01 1.1E-04 6.3E-04 1.4E-08 8.SE-08
1, 1, 1-Trichloroethane 2.1E-01 3.6E-05 2.2E-04 1.SE-10 8.9E-10
Chromium 5.1B+01 8.7B-03 5.2B-02 1.2E-06 6.9E-06
Copper 2.1E+01 3.6E-03 2.2E-02 1.SE-08 9.2E-08
Zinc 8.3E+01 1.4£-02 8.6E-02 5.8E-08 3.6E-07
Cyanide 8.7E-01 1.5£-04 8.9E-04 6.0E-10 3.7E-09
-------
Determination - Page 78
TABLE 20
R~SKS FROM DUS~ GENERATED ON-SITE
C.;'~C:3OGmc mKS
c:!~rC.\L
! :~,:3c:lor~e~~e~e
~::i~ i:9~l1al:n~!
or t:q/(qiO)
j
L2£.~2 I UE.~O i 3.3£-)3 i 2. ~E.~4
I !
7.:~.~0 ! 1.~£-)8 4.:::-01: Z.~::-;8
A~:: ::YC!:;~1~7:CY
(::q/:31
P.t~ I ?!'_~
?AR
P!l..~
C?:
:q/ ;
i :ta'~"/d i
I ./., ,
?!'3
I I 1
;.J2-~1 4.:E-~') : UhJ 1. :::- ~l 2.5£-02 i
I
I I
i 1.52-10 a.~£-~? :.OE2 u£-n i 3.02+01 I
I I
I 1.5£")8 i UE-')8 :.0£-:0 2.5£-)9 I 3.2£-)1 I
I
5.&2-08 i 3.5£-)7 UE-~O 9.8£-09 3.2E~1 I
! ! i
I \
6.0E-10 I 3. -!-.j9 ' L:E2 l.Q£-~O I 1.6£ +00 ,
I I
,
TOTAL !laRD :~IOEX: I
:,\:A.'.D :y~~:!.;
PU
. ~;_: 5
-' . - - !
3.1E4 I
I
3.:::-:0
I
~.1H9 !
2.~E-~2
l.5£-)9 I
:\I~
~.~E-~~
L ::: - ~J :
-. E-':?
J. ::: ..ja
. ",..-..
. ~.~~-.-
I
3.?!-';8
-------
Determination
Page 79
2. Risks from Future On-site Drinkina Water Wells: The risk associated with
future residents' drinking water from on-site wells was calculated utilizing
the organic chemic!ls. For calculations, it was assumed that a child would
drink 1 liter per day and an adult 2 liters per day. The exposure rates were
estimated at 5 days for 50 weeks per year for the PAR and 7 days for 50 weeks
per year for the PKR.
Results of the calculations are presented in Table 22. The calculated
carcinogenic risk ranged from 5 x 10-7 to 1 x 10-6. The total HI for the
noncarcinogenic chemicals ranged from 1 x 10-2 to 2 x 10-2.
Environmental Risks
Locations on the site that contain elevated contaminant concentrations could be
harmful or jeopardize the health of some plant and animal species. The primary
risks would be to animals that burrow into the contaminated soils and plants
whose root systems extend into the contaminated soils. At the present time,
only short rooted plants occupy the areas where disposal took place. Their
sparse distribution across the site may in part be due to the removal of top
soil rather than the actual contamination.
For the inorganic contaminants, hexavalent chromium concentrations over 240
mg/kg would present the greatest risk to burrowing animals. This value was
calculated from rat inge8tion rates. Concentrations above 240 mg/kg could
result in 10S8 of weight, increased liver and kidney weight and/or decreased
reproduction capacity. Extremely high concentrations could result in death.
Only two areas, approximately 100 cubic yards of soil, at the site are known to
c..ontain significant levels of chromium. Since it is unlikely that an animal
w~ll remain only in these areas, the risk associated with this type of exposure
is low.
Within the central area of the site, animals could be exposed to the volatile
organics remaining on-site. Based upon studies using guinea pigs, the exposure
limit for l,l,l-trichloroethane would be 500 ppm. For tetrachloroethene,
concentrations of 250 mg/kg/day produced increased liver weights in laboratory
mice. When concentrations were increased to 1,400 mg/kg/day the mice began
108ing weight however their livers increa.ed in weight. The central area was
found to contain tetrachloroethene between these concentrations, therefore
burrowing animals could suffer from impaired health.
Only trace contaminants were detected in the intermittent tributary draining to
the on-site 8inkhole. On-site streams and water occur only after precipitation
events, therefore biotic life would be limited to organisms such as bacteria,
phytoplankton and zooplankton that have very short lives. The streams do not
exist long enough to sUpPOrt fish species. Shallowness of the sediment on the
site does not provide enough moisture to prevent desiccation of amphibians and
reptiles. During sampling, both l,l,l-trichloroethane at 0.004 mg/L and
cyanide at 0.006 mg/L were found in the on-site water. Neither concentration
exceeds the acute toxicity value for l,l,l-trichloroethane (18 mg/L) nor the
free cyanide value of 0.052 mg/L.
-------
Determination - Page 80
TABLE 21
-
SUMMARY OF RISKS ASSOCIATED WITH CONTACT AND INGESTION
OF SURFACE SOIL (6 - 10 inches)
(FUTURE SCENARIO)
SOIL LIFETIME RISK ASSOCIATED 1iAZARD INDEX RISK ASSOCIATED
SAMPLING CANCER RISK CHEMICAL CHEMICAL
LOCATION PAR PMR PAR PMR
IF NA(l) NA - 5£-03 2E-02 -
IG NA NA - 1E-02 6E-02 -
l.5D NA NA - 2E-Ol 9£-01 -
2D NA NA - 8£-02 3£-01 -
"2F 4£-09 2£-08 - 5E-03 2£-02 -
2G NA NA - lE-Ol 4E-Ol -
3F 6E-I0 4E-09 - 5E-02 2E-Ol -
3G NA NA - 5E-03 2E-02 -
3I NA NA - 6E-03 2E-02 -
4G NA NA - 2E-02 7E-02 -
4I NA NA - 4E-02 2E-Ol -
5F NA NA - 2E-02 1E-01 -
5H NA NA - 1E-02 4E-02 -
5I NA NA - 2E-02 9£-02 -
6E NA NA - 1E-02 4£-02 -
6H NA NA - 6£-03 2£-02 -
7C NCC NCC - 3E-02 1E-Ol -
7D NA NA - 5£-01 2E+00(2) Chromium (VI)
88 NA NA - 2E-02 7£-02 -
8£ 2£-06 1£-05(2)Tetrachloroethene 2£-02 lE-01 -
8F.5 1£-08 7£-08 - 1£-04 7£-04 -
8H 2£-07 9£-07 - 2£-03 lE-02 -
8L NA NA - 4£-03 2E-02 -
9.5C.5 9B-09 5B-08 - 1£-04 6E-04 -
9.5£ 1£-07 8B-07 - 1E-02 5£-02 -
9.51'.5 NCC NCC - NA NA -
9.5H NCC NCC - NA NA -
9.5I.5 NCC NCC - NA NA -
llE 4B-09 2B-08 - 5E-05 3£-04 -
111'.5 38-08 2B-07 - 4£-04 2£-03 -
11H HCC NCC - NA NA -
12.5F.5 52-08 3B-07 - 7E-04 4£-03 -
14J NA NA - 6E-03 3E-02 -
.
15I NA NA - 7E-03 3B-02 -
15J NA NA - 6B-03 3£-02 -
( 1 )
NA. Organ ice of
NCC - No chemical
Equals or exceeds
carcinogens and 1
inorganics not analyzed
of concern detected in the sample
target risk levels of 1 x 10-6 for
for noncarcinogens
( 2 )
-------
Determination - Page 81
TABLE 22
FUTURE RESIDENT HEALTH RISKS FROM DRINKING GROUND WATER
CARCINOGENIC RISKS
CONC. CPF
CHEMICAL ~ (mq/kq/.day)-l ~ PMR
CHILD
Tetrachloroethene 0.001 5.1X10-2 -7 2.79XIO-7
1.20x10
ADULT
Tetrachloroethene 0.001 5.1X10-2 -7 9.98XIO-7
3.S6xlO
Total Cancer Risk 5 x 10-7 1 x 10-6
NONCARCINOGENIC RISKS
CONCA R!D
CHEMICAL ~ (mq/kq/day) ~ PMR
CHILD
1,2-Dichloroethene 0.003 2.0X10-2 4.11X10-3 5.75XIO-3
Tetrachloroethene 0.001 1.OX10-2 2.74X10-J J.84X10-3
1, 1, 1-Trichloroethane 0.001 9.0X10-2 3.04X10-4 4.26X10-4
ADULT
1,2-Dichloroethene 0.003 2.0X10-2 2.94X10-J 4.11X10-J
Tetrachloroethene 0.001 1.OX10-2 1.96X10-J 2.74X10-J
1, 1, 1-Trichloroethane 0.001 9.0X10-2 2.17XIO-4 -4
3.04xlO
Total Hazard Index 1.2X10-2 1. 7X10-2
-------
Determination - Page 82
Uncertainty
Risk assessment ha~ some inherent uncertainty due to toxicity extrapolations
and exposure estimations. A specific uncertainty for this site is the chromium
contaminated soil. Since analyses were not done to determine the quantity of
each form of chromium, it was assumed that all the chromium was in the more
toxic form. Another uncertainty arose from the ephemeral nature of the on-site
stream. Only one sample could be collected and thus the data used to calculate
the risk from exposure to this surface water were very limited. Overall,
conservative assumptions were used in the risk assessment in order to evaluate
the worst reasonable situation.
Health Risk Summary
The estimated average and maximum health risks are presented in Table 23. The
average risks for current conditions at the site are below the target level of
1 x 10-6 for carcinogenic risks and 1 for noncarcinogenic risks. The maximum
risks could occur if an individual repeatedly returned to a contaminated area
for several weeks a year over a lifetime. When considering a future use
scenario with residents livinq on the site, the cancer risk associated with
maximum exposure to the area with the hiqhest concentration of
tetrachloroethene is 1 x 10-5 Por an individual that repeatedly returns to
the outlying area where the soil is most contaminated with chromium, the
estimated HI is 2.0.
Summary of Site Risks
Actual or threatened releases of hazardous substances from the site, if not
addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OP ALTERNATIVES
The contaminated soils on-site are being considered for cleanup. All drums,
wastes, identified 81udge pockets and contaminated water were removed from the
site during 1988. The treatment alternatives presented are for the residual
contaminant8 18ft in the on-site soil. A remedy has been proposed to protect
public health and the environment by reducing contaminant concentrations in the
soil to level. that will be protective of ground water and reduce the risks
from incidental soil ingestion. The aquifer underlying the site was identified
as a Clas8 IIA, however it is not used ~s a drinking water source. The
determination of the extent of contamination in the ground water system
underneath the site was hampered by the karst system. Off-site contamination
in surface water, sediments and ground water, at the time of sampling, was
within the u.S. EPA's KCLs and health-based levels.
A total of six alternatives were evaluated in detail for remediating the
contaminated soils. Each is discussed in the following paragraphs. .
-------
Determination
Page 83
ALTERNATIVB 0IIlB:
NO ACTION
Present worth COst~
Capital Cost:
Operations & Maintenance Cost:
Time to Implement: 6 months
$ 215,700
$ 84,700
$ 131,000
CERCLA requires that the No Action alternative be con8idered at every site.
Under this alternative, eight wells will be installed on-site. Confirmatory
dye-trace studies will need to be conducted to insure that the wells actually
intercept ground water conduits. These wells, along with Boutwell Spring and
any other springs or wells that are located along the ground water conduit
between Boutwell Spring and the site, will be monitored quarterly for a period
of thirty years. No soil removal or treatment will be implemented. The only
reduction of contaminant levels will occur via natural processes such as
dispersion or degradation. The only costs will be for the initial installation
of wells and quarterly ground water monitoring.
Because this alternative will leave contaminants on-sit~, CERCLA requires that
the site be reevaluated every five years. If justified by the review, remedial
actions will be implemented at that time to remove or treat the soils.
ALTERNATIVE TWO:
INSTITUTIONAL CONTROLS
Present Worth Cost:
capital Cost:
Operations & Maintenance COst:
Time to Implement: 6 months
$ 307,125
$ 143,350
$ 163,775
Institutional controls will include measures to limit both human and animal
contact with on-site soils. Around the perimeter of the site a 3,000 foot
fence will be constructed and maintained. Signs that warn potential
trespassers of the hazardous nature of the site will be placed every 100 feet
along the fence. To limit future site usage, restrictions will be recorded on
the deed for both the property and on-site surface and ground water supplies.
This alternative will not involve removal or treatment of contaminated soils.
Components of the No Action Alternative will also be included in this
alternative. Bight on-site wells will be installed and monitored, quarterly
for 30 year.,~.long with Boutwell Spring and any other springs or wells that
are located along the ground water conduit between Boutwell Spring and the
site. Again~-.. with the No Action Alternative, contamination will be left in
place therefore a risk assessment will be required every five years.
ALTERNATIVE THREE:
AND DRAINAGE SYSTEM
RESOURCE CONSERVATION AND RECOVERY ACT ( RCRA) LANDFILL CAP
Present Worth COst:
Capital Cost:
Operations & Maintenance
Time to Implement:
Cost:
$ 839,460
$ 632,100
$ 207,630
18 months
-------
Determination - Page 84
TABLE 23
SUMMARY OF SITE HEALTH RISKS
EXPOSURE ROUTE LIFETIME CANCER RISKS HAZARD INDICES
PAR ~ ~ ~
CURRENT SCENARIO*
Surface Soil 1X10-9 5X10-9 (1)' 2X10-3 7X10-3
Surface Water None Detected 2x10-4 1X10-3
Dirt Bikes 3x10-a 7X10-7 2X10-9 4X10-a
FUTURE SCENARIO* '
Surface Soil 7X10-9 4X10-a(2) aX1o-3 3X10-2(3)
Residents' Groundwater 5X10-7 1X10-6 1X10-2 2X10-2
* If the individual returns to the same location day after
- year after year, for a lifetime, the possible maximum risk
be:
day,
could
(1) Lifetime cancer risk of 1X10-6 at aE due to PCE
(2) Lifetime cancer risk of 1X10-5 at aE due to PCE
(3) . Hazard Index of 2 at 7D due to cr+6
-------
Determination - Page 85
An on-site RCRA landfill cap will be constructed over the central area of the
site where the organic contaminated soils are located (approximately 1.5
acres). The outlying areas, which contain the two chromium contaminated
locations, will ba.excavated and used as fill in the central area. Since the
central area is situated in a basin, it is estimated that 10,000 cubic yards of
fill will be needed to provide a slope that will promote proper surface
drainage. The outlying area will contribute only 2,000 cubic yards of soil to
the central area. -
The cap will be constructed of a 2-foot thick layer of clay, a 20-mil synthetic
liner, a l-foot thick gravel drainage layer, a geotextile filter fabric and 2
feet of topsoil. The two feet of soil will protect the underlying structures
from winter frost. A run-on/run-off drainage collection system will be
constructed around the perimeter of the landfill to divert water to the on-site
sinkhole.
The capped area will be seeded and fenced. Since contaminants will be left
on-site, Boutwell Spring and any other springs or wells that are located along
the ground water conduit between Boutwell Spring and the site, will be
monitored quarterly for thirty years. A risk assessment will be conducted
every 5 years during the 30 years of monitoring. To limit future site usage,
restrictions will be recorded on the deed for both the property and on-site
surface and ground water supplies.
ALTERNATIVE FOUR:
OFF-SITE RCRA LANDFILL
Present Worth Cost:
Capital Cost:
Operations & Maintenance
Time to Implement:
Cost:
$
$
$
3,852,000
3,809,375
42,625
6 months
This alternative involves the excavation and transport ion of contaminated soils
to an off-site RCRA approved landfill. Approximately 100 cubic yards of soil
in the outlying area contain elevated concentrations of chromium and
approximately 7,400 cubic yards of soil in the central area contain elevated
concentrations of organics. A proportionate amount of clean fill dirt will be
brought to the site to replace the removed soils. These areas would then be
seeded to restore the natural vegetative cover. A run-on/run-off drainage
collection system will be constructed to divert water away from the areas of
activity.
Excavated soils will be stockpiled in a location that facilitates loading into
transport vehicles. A crushed rock road will be constructed across the site so
that trucks can access the stockpile. Approximately 500 cubic yards of
material will be hauled off the site each day. Both the excavated areas and
roadways will be wetted to control dust.
Although the contaminated soil will be removed from the site, there is a
possibility that some residual contamination may be contained in the underlying
karst system. Changes in the karst conduits could expose ground water to these
contaminants. To eliminate the possibility that trapped contamination may
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Determination - Page 86
migrate off-site undetected, quarterly monitoring of Boutwell Spring and any
other springs or wells that lie along the route between Boutwell Spring and the
Site will be conducted for five years. A risk assessment will also be
conducted at the end of the five year period. To limit future site usage,
restrictions will be recorded on the deed for both the property and on-site
surface and ground water supplies.
ALTERNATIVE FIVE:
OFF-SITE DISPOSAL AND ON-SITE AERATION
Present Worth Cost:
Capital Cost:
Operations & Kaintenance
Time to Implement:
Cost:
$
$
$
394,525
351,900
42,625
6 months
Outlying soil, approximately 100 cubic yards, containing elevated chromium
concentrations will be excavated and transported to an off-site RCRA approved
landfill. Assuming a typical truck can transport only 20 cubic yards, then the
removal will require approximately five truckloads. Excavated soil will then
be replaced with clean fill dirt.
An initial bench scale treatability study will be conducted to determine if
aeration will effectively reduce contamination to levels that are protective of
human health and the ground water. Once the treatability study indicates that
the process will effectively reduce organics then a full scale project will
begin.
Based upon the soil aeration previously conducted at the site, it is expected
that the central area soils will be excavated and placed next to their
unearthed trenches in 1-foot high lift. The soil will be mechanically mixed to
break up dirt clumps and promote volatilization of the organics. Periodic
sampling of soil, using the U.S. EPA Region IV Standard Operating Procedures,
will be conducted to ensure that clean-up criteria are being met.
Additionally, air monitoring for particulates and volatile organics will be
conducted along the site boundary. Prior to aeration activities, a
run-on/run-off collection system will be constructed to divert water away from
the aerating soils. Once organic contaminant concentrations are determined
through laboratory analysis to be within the acceptable soil action
concentrations, the remediated soil will be redeposited in the central area.
Upon completion, the site will be regraded, covered with topsoil and seeded to
restore the vegetative cover.
As with Alternative 4, this Alternative 5 will require quarterly monitoring of
Boutwell Spring and any other springs or wells that lie along the route between
Boutwell Spring and the Site for a period of five years. A risk assessment
will also be conducted at the end of the five year period. To limit future
site usage, restrictions will be recorded on the deed for both the property and
on-site surface and ground water supplies.
-------
1-
Determination - Page 87
ALTERNATIVE SIX:
OFF-SITE INCINERATION
Present Worth Cost:
Capital Cost:
Operations & Maintenance
Time to Implement:
Cost:
$ 19,001,800
$ 18,989,400
$ 12,400
6 months
Approximately 7,506 cubic yards of contaminated soils, from both the outer and
central areas, will be excavated and transported to a RCRA approved
incinerator. The incinerator will destroy the organic contaminants, however
residual ash will still contain inorganics and will be disposed of in a RCRA
approved off-site landfill.
As specified in Alternative 4, the soils will be stockpiled in an area that is
access able to transportation vehicles. A gravel road will be constructed
on-site to facilitate the removal activities. During excavation activities,
run-on/run-off water controls will be implemented to divert water. Soils and
roadways will be wetted to control dust. Clean fill dirt will be used to
replace the removed soil. Seeding of the site will restore the natural
vegetative cover.
Again, quarterly monitoring of Boutwell Spring and any other springs or wells
that lie along the route between Boutwell Spring and the Site will be conducted
for five years. A risk assessment will also be conducted at the end of the
five year period. To limit future site usage, restrictions will be recorded on
the deed for both the property and on-site surface and ground water supplies.
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
Section 131(d) of CERCLA, as amended by SARA, identifies the following three
categories of ARARs: containment-specific, location-specific and
action-specific. Location-specific ARARs do not apply to this site since it is
not within a 100-year floodplain, contains no wetlands or critical wildlife
habitats, and does not possess registered historical or archeological sites.
Action-specific ARARs
Action-specific ARARs are those directed towards site operations such as
handling, storage, treatment, transportation and/or disposal of contaminated
wastes or materials. The following action-specific ARARs were delineated for
the site:
Federal
*
RCRA Hazardous Waste Requirements
Treatment, Storage and Disposal Regs
Land Disposal Regs
40 CFR 264 and 265
40 CFR 268
*
Clean Water Act
NPDES
PL 92-500
40 CFR 122 - 129
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Determination - Page SS
*
Clean Air Act
NAAQS
PSD
*
OSHA Requirements
Workers
*
DOT Regulations
TranspOrtation
*
EPA's Ground Water Protection
Strategy
State of Kentuckv
* SOlid/Hazardous Waste Requirements
Reporting and Standards
*
Air Quality
Fugative Emissions/Open Burning
* Water
Discharge of Wastes
* Occupational Safety and Health
Workers
*
Transportation
permits/Handling Procedures
Contaminant-specific ARARs
40 CFR 51
40 CFR 52
29 CFR 1910 and 1926
40 CFR 171 - 177
401 KAR 32, 34 and 35
401 KAR 63
401 KAR 5
803 KAR 2
601 KAR 1
Contaminant-specific ARARs set media concentration limits for specific
contaminants. They include the following regulations and/or guidance:
Federal
*
Safe Drinking Water Act
MCLs and MCLGs
*
Clean Water Act
Quality Criteria
*
Clean Air Act
NAAQS
*
OSHA
Air Contaminants: 8-hour Time
Weighted Averages (TWAs)
~
*
Water
Surface Water Standards
40 CFR 141 - 143
Section 304(a)(1)
40 CFR 50
29 CFR 1900
401 KAR 5
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Determination - Page 89
*
Air
Ambient Air Quality Standards
Toxic Emissions
401 KAR 53
401 KAR 63
Presently, with the exception of the land disposal regulations, there are no
contaminant-specific ARARs for volatile organic compounds in soil. Since
contaminants in the on-site soils pose a potential risk to ground water
resources, health cased action levels had to be calculated from data collected
during the sampling activities. The specific methodologies for establishing
the SALs were outlined in Appendix C of the July 1990 RI Report. The
calculated SALs for the site-specific volatile organic compounds of interest
were:
1, 2-dichloroethene
1,1,1-trichloroethane
tetrachloroethene
7.72 mg/kg
117.30 mg/kg
>7.50 mg/kg
For the inorganic chemicals of interest, health-based cleanup levels were
established by back-calculating soil ingestion risks to a hazard index of (1)
for each chemical. Utilizing a 16 kg (35 pound) child ingesting 200 mg/day of
contaminated soil for 365 days/year, the following SALs were calculated:
copper
chromium (VI)
zinc
cyanide
2,300 mg/kg
400 mg/kg
16,000 mg/kg
1,600 mg/kg
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives developed during the Howe Valley Landfill Site FS
were evaluated by the U.S. EPA using the following nine criteria. The
advantages and disadvantages of each alternative were then compared to identify
the alternative providing the best balance among these nine criteria.
1.
Overall Protection of Human Health and the Environment addresses
whether or not an alternative provides adequate protection and
describes how risks are eliminated, reduced or controlled through
treatment and engineering or institutional controls.
2.
Compliance with Applicable or Relevant and Appropriate Reauirements
(ARARs) addresses whether or not an alternative will meet all of the
applicable or relevant and appropriate requirements or provide grounds
for invoking a waiver.
3.
LonQ-term Effectiveness
alternative to maintain
environment, over time,
and Permanence refers to the
reliable protection of human
once cleanup objectives have
ability of an
health and the
been met.
4.
Reduction of Toxicitv. Mobilitv or Volume is the anticipated
performance of the treatment technologies an alternative may employ.
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Determination - Page 90
5.
Short-term Effectiveness involves the period of time needed to achieve
protection and any adverse impacts on human health and the environment
that may be posed during the construction and implementation period
until cleanup objectives are achieved.
6.
Implementabilitv is the technical and administrative
alternative, including the availability of goods and
to implement the solution.
feasibility of an
services needed
7.
Cost includes capital costs, as well as operation and maintenance
costs.
8.
Aaencv Acceptance indicates whether, based on its review of the
and Proposed Plan, the Commonwealth of Kentucky agrees on the
preferred alternatives.
RI/FS
9.
Communitv Acceptance indicates
alternative. This criteria is
Summary.
the public support of a given
discussed in the Responsiveness
ANALYSIS
The following is the nine criteria evaluation for the six alternatives. The
analysis assumes that any uncertainties associated with Alternative 5 will be
eliminated through the success of the treatability study.
Overall Protection of Human Health and the Environment
All alternatives presented in this document, with the exception of the No
Action alternative, are protective of human health and the environment. The No
Action alternative will allow humans, plants and/or animals to be exposed to
contaminants through contact with on-site soil, ground water, surface water,
dust particles or contaminants released into the air. Alternatives 2 and 3
will prevent on-site exposure, however, like Alternative 1, they will not
remove contaminated soils from the site thereby allowing the possible off-site
migration of contaminants which could create an increased risk to human
health. Alternatives 4, 5 and 6 will eliminate exposure of humans, plants
and/or animals to on-site contaminants and will prevent contaminant
concentrations from entering the ground water.
Compliance with Applicable or Relevant and Appropriate Reauirements
Alternatives 4, 5, and 6 will comply with all applicable or relevant and
appropriate requirements (ARARs). Alternatives 1, 2 and 3 will allow
contaminants to remain on-site at concentrations above acceptable levels
violates ARARs specified in the July 1990 RI report. However, under
Alternative 3 the contaminated soils will be capped.
which
-------
Determination - Page 91
Reduction of Toxicitv. Mobilitv. or Volume
Alternatives 4, 5, and 6 will result in a significant reduction in the
toxicity, mobility., and volume of soil contamination by removing it from the
site or by treating it on-site. Indirectly, a reduction in the mobility of
contaminants will occur for Alternative 3 due to the landfill cap reducing the
amount of water filtering through the soils and/or flowing off-site.
Alternatives i and-2 will not prevent or reduce the possibility of contaminants
migrating into the ground water, nor will they reduce contaminant toxicity or
mobility.
Lona-term Effectiveness and Permanence
Alternative 4, 5 and 6 will provide the greatest long-term effectiveness by
removing and/or treating the contaminated soils. Alternative 4 is slightly
less effective since the soils will not be treated, but rather sent off-site to
a RCRA landfill. Alternative 3 has a lower long-term effectiveness primarily
due to the unreliable nature of the karst terrain. Alternatives 1 and 2
provide the lowest long-term effectiveness.
Short-term Effectiveness
Alternatives 1 and 2 involve only a minimum amount of construction that could
increase the short-term exposure risks for on-site workers, nearby residents or
the surrounding environment. Alternatives 3, 4, 5 and 6 may produce dust from
either the removal or treatment activities, however any risks will be mitigated
through implementation of a health and safety plan. In addition, Alternatives
3, 4 and 6 will cause a temporary increase in truck traffic through the nearby
community. Under Alternative 5, on-site workers could be exposed to
volatilized contaminants. The prevention of excess exposure through inhalation
of or contact with the organics will also be addressed in the health and safety
plan. Alternative 3 provides the least short-term effectiveness since it will
take the longest to implement.
Implementabilitv
The implementability of an alternative is based on technical feasibility,
administrative feasibility and availability of services and materials. Each of
the discussed alternatives will require some construction, such as the
installation of monitoring wells, security fences, drainage collection systems,
landfill caps or the replacement of excavated soil.
Alternatives 1 and 2 will be extremely' difficult to implement because of the
karst conditions that occur beneath the site. To ensure that a monitoring well
actually intercepts a conduit that contains ground water associated with the
site, additional dye-trace studies will be required. Should a monitoring well
be installed in the wrong place, it will be removed and relocated. This
process may continue indefinitely until all monitoring wells are installed in
the proper locations. The additional requirements of Alternative 2 {i.e.
-------
Determination - Page 92
installation of a perimeter fence and deed restrictions) will be much simpler
to implement. The only problem may be in obtaining the necessary equipment and
materials.
Alternative 3 will require a substantial amount of construction material,
equipment and manpower. Because the karst area presents the opportunity for
sinkholes to develop, the structural integrity of the cap could be compromised
thereby reducing tne effectiveness of this alternative.
Part of the remedy for Alternative 5 will require the construction of a soil
drying and aeration system. Once constructed, the process will be simple to
operate and maintain. This alternative will also require excavation equipment,
transport vehicles and suitable backfill material. The same items will also be
needed for Alternatives 4 and 6. For such remedies, the implementability will
be limited by the availability of these items and the ability of the RCRA
landfill and incinerator to accept the soils.
Cost
The estimated present worth value of each alternative and option is as follows:
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Alternative 5
Alternative 6
$ 215,700
$ 307,125
$ 839,460
$ 3,852,000
$ 394,525
$ 19,001,800
Since contaminants will remain on-site under Alternatives 1, 2 and 3, their
PWCs include 30 years of Operations & Maintenance (O&M) with a risk assessment
conducted every 5 years. The PWC of Alternatives 4, 5, and 6 include the costs
for implementing 5 years of O&M which include deed restrictions and quarterly
ground water monitoring. Also, Alternatives 4, 5, and 6 are sensitive to
changes in the volume of contaminated soil to be handled. Consequently, their
capital cost could vary significantly once the extent of soils to be removed or
treated is defined in the Remedial Design (RD) phase.
State Acceptance
The KNREPC has reviewed and supplied comments to EPA regarding all reports and
data produced during the RI and FS. At this time, .the KNREPC is of the opinion
that the KRS 224.877 is an ARAR. Based upon their review of the primary and
contingent alternatives, the KNREPC does not believe that KRS 224.877 is being
addressed because they feel that the selected alternatives do not remove or
treat a sufficient quantity of the contamination contained in the on-site
soils. The u.S. EPA, however, does not agree that KRS 224.877 is an ARAR.
Nontheless, the u.S. EPA has carefully considered the risks associated with the
on-site contamination and feels that both the primary and the contingency
alternatives will meet the requirements set forth in KRS 224.877 and will be
protective of human health and the environment at a reasonable cost. The
conCerns raised by the State are discussed in the Responsiveness Summary
contained in Appendix A.
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Determination - Page 93
Communitv Acceptance
Community acceptance of the various alternatives is evaluated in the
Responsiveness Summary contained in Appendix A. The Responsiveness Summary
provides a thorough review of the comments received on the RI/FS Reports and
the Proposed Plan during both the public meeting and public comment period.
The public comments received by the U.S. EPA during the public meeting and
public comment period support the u.S. EPA's proposed plan of remediation. The
local community and PRPS agree that removal, combined with on-site treatment of
soils is the most effective alternative for protecting human health and the
environment.
The Preferred Alternatives
The primary alternative and contingency alternative - Alternative 5 and
Alternative 4, respectively- involve the removal and off-site disposal of
on-site contaminated soils. Alternative 5 also includes on-site remediation,
by aeration, of organic contaminated soils in the central area of the site.
Alternative 4 will be implemented if the treatability study in Alternative 5
indicates that aeration will not effectively reduce contamination to levels
that are protective of ground water and eliminate the risk from ingestion of
contaminated soils.
Both alternatives include a 5 year ground water monitoring program along with
deed restrictions to limit future site usage. Ground water associated with the
site will be monitored at Boutwell Spring and any other wells or springs that
lie between Boutwell Spring and the site. Quarterly samples will be collected
annually for five years. At least one set of quarterly samples, per year, will
be collected during a high flow event. Should contamination in either the
on-site soils or the ground water be detected above acceptable levels and/or
drinking water standards, then the U.S. EPA will reevaluate the effectiveness
of the alternatives.
Alternative 5 will involve the following specific activities:
*
Excavation and off-site disposal of approximately 100 cubic yards of
outlying soils that contain elevated concentrations of inorganics,
*
Replacement of removed soils with clean fill dirt,
*
Implementation of a bench-scale treatability study to insure that the
aeration process will reduce organic concentrations to acceptable
levels,
*
Excavation and treatment, via on-site aeration, of approximately 7,400
cubic yards of central area soils that contain elevated concentrations
of organics,
*
On-site ,air monitoring to, insure adequate protection of workers and
nearby residents,
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Determination - Page 94
*
Installation of water diversion ditches to prevent water from running
onto the aerating soils,
*
Vegetation of the site to restore its natural conditions,
*
Five years of quarterly monitoring of Boutwell Spring and additional
springs or wells that lay along the ground water conduit between
Boutwell Spring and the site; and
*
Placement of restrictions on the deed to limit the usage of the
property and its associated ground water.
Alternative 4, if implemented, would involve the following:
*
Excavation and
soil from both
concentrations
off-site disposal of approximately 7,500 cubic yards of
the outlying and central areas that contain elevated
of inorganics and organics, respectively,
*
Replacement of removed soils with clean fill dirt,
*
On-site air monitoring to ensure adequate protection of workers and
nearby residents during excavation activities,
*
Installation of water diversion ditches to prevent water from running
onto the areas of activity,
*
Vegetation of the site to restore its natural conditions,
*
Five years of quarterly monitoring of Boutwell Spring and additional
springs or wells that lay along the ground water conduit between
Boutwell Spring and the site; and
*
Placement of restrictions on the deed to limit the usage of the
property and its associated ground water.
STATUTORY DETERMINATIONS
Under its legal authorities, the U.S. EPA's primary responsibility at Superfund
sites is to undertake remedial actions that achieve adequate protection of
human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences. One of the
requirements specifies that when complete, the selected remedial action for
this site must comply with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be cost effective
and utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sections discuss
how the selected remedies meet these statutory requirements.
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Determination - Page 9S
Protection of Human Health and the Environment
Based upon the site risk assessment, long-term exposure to contaminants in the
on-site soils, prbmarily the three locations where chromium and
tetrachloroethene were found above the SALs, is the principal threat associated
with the site. This risk level was based on future conditions should a
residence be built on-site or the surface soil ingested.
The aeration of soils containing volatile organics and the removal of soils
containing inorganic contaminants protects human health and the environment by
reducing and/or eliminating the levels of contaminants to which animals, plants
or humans might be exposed. The cancer risk associated with the future use at
the site will be reduced to approximately 1 x 10-6 and the Hazard Indices
(HI) ration will be less than 1. For the secondary threat, aeration of soil to
SALs will ensure that ground water beneath the site is protected to MCLs for
the organic contaminants of concern.
The selected primary and contingent remedies will not pose unacceptable
short-term risks or cross-media impacts.
Compliance with ARARs
The selected remedies of off-site removal and on-site aeration or complete
off-site removal for the contaminated soils will comply with all applicable or
relevant and appropriate requirements (ARARs). All ARARs were previously
presented in the discussion of the nine criteria.
Cost Effectiveness
The selected remedies are cost-effective because they have been determined to
provide overall effectiveness proportional to their costs. Alternative 5 is
the least costly of Alternatives 4, 5 and 6 which meet all ARARs and are
equally protective of human health and the environment. Alternative 4, the
contingency alternative, is the second most cost effective of the remedies that
meet ARARs and protection guidelines.
Utilization of Permanent Solutions and Alternative Treatment Technoloqies or
Resource Recoverv Technoloqies to the Maximum Extent Practicable
The U.S. EPA believes the selected remedy represents the maximum extent to
which permanent solutions and treatment technologies can be utilized in a
cost-effective manner for the final remediation of the Howe Valley Landfill
Site. Of the alternatives that are protective of human health and the
environment and comply with ARARs, the U.S. EPA has determined that aeration of
the volatile organic contaminated soils satisfies the statutory preference for
remedies that employ treatment of the principal threats and provide the best
possible balance in terms of long-term effectiveness and permanence, reduction
in toxicity, mobility or volume achieved through treatment, short-term
effectiveness, implementability and cost while considering State and community
acceptance.
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Determination - Page 96
TABLE
24
ALTERNATIVE 5
OFF-SITE REMOVAL AND ON-SITE AERATION
Howe Valley Landfill, Howe Valley, Kentucky
A.
CAPITAL COSTS
Activitv
Present
Worth
Totals
Mobilization
Equipment/staff
Temp. Facilities
Site Preparation
Site Remediation
Excavate/Treat
Haul/Dispose (Metals)
Top Soil/Spreading
Vegetation
Monitoring
Engineering/Administration
$
5,000
2,000
3,000
148,000
25,000
30,000
3,000
50,000
40,000
$ 306,000
Operation & Maintenance
a. Ground water monitoring at Boutwell spring (quarterly for five years)
Personnel
Laboratory
7 hours at $50/hour
4 samples at $500 each
$
350
2,000
2,350
x 4
9,400
auarters
Annual Total
$
b. Risk Assessment (at end of 5 year period)
Personnel
Laboratory
20 hours at $50/hour
4 samples at $500 each
$
1,000
2,000
3,000
Total
$
Subtotal
Removal/Aeration Cost
Operations & Maintenance.
$ 306,000
37,065
343,065
51,460
Contingency (15%)
TOTAL COSTS
$ 394,525
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Determination - Page 97
TABLE 25
ALTERNATIVE 4
OFF-SITE REMOVAL
Howe Valley Landfill, Howe Valley, Kentucky
A.
CAPITAL COSTS
Activitv
Present
Worth
Totals
Mobilization
Equipment/Staff
Temp. Facilities
Site Preparation
Site Remediation
Excavate
Haul/Dispose (Metals)
Fill
Top soil/Spreading
Vegetation
Monitoring
Engineering/Administration
$
5,000
2,000
3,000
112,500
3,000,000
55,000
30,000
3,000
50,000
50.000
$ 3,312,500
Operation & Maintenance
a. Ground water monitoring at Boutwell Spring (quarterly for five years)
Personnel
Laboratory
7 hours at $50/hour
4 samples at $500 each
$
Annual Total
350
2.000
2,350
x 4
$ 9,400
quarters
b. Risk Assessment (at end of 5 year period)
Personnel
Laboratory
20 hours at $50/hour
4 samples at $500 each
Total
$ 1,000
2.000
$ 3,000
Subtotal
Removal/Aeration Cost
Operations & Maintenance
Contingency (15%)
$ 3,312,500
37.065
3,349,565
502.435
TOTAL COSTS
$ 3,852,000
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Determination - Page 98
Although the contingency alternative provides an equally good balance of the
above-referenced criteria, it does not satisfy the statutory preference for
remedies that employ treatment of the principal site threats. Due to the small
amount of material and the low levels of contamination present at the site,
this alternative can be implemented and completed more quickly and with less
difficulty than other technologies and'will also be protective of human health
and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The preferred alternative, Alternative 5, and the contingency alternative,
Alternative 4, were originally proposed to have O&M sampling conducted once a
year. Because karst systems can change rapidly, O&M sampling will be conducted
quarterly. This increase in sampling created an increase in the O&M costs and
capital costs for these alternatives.
-------
APPENDIX A
HOWE VALLEY LANDFILL SITE
RESPONSIVENESS SUMMARY
-------
This Responsiveness Summary is organized into the following sections and
attachments:
II.
III.
IV.
I.
RESPONSIVENESS SUMMARY OVERVIEW. This section outlines the pUrPOses
of the p~lic comment period and the Responsiveness Summary. It also
references the appended background information leading up to the
public comment period.
BACKGROUND
provides a
identified
RIfFS.
ON COMMUNITY INVOLVEMENT AND CONCERNS. This section
brief history of community concerns and interests
as part of the Community Relations Plan and during the
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
MEETING AND EPA RESPONSES TO THESE COMMENTS. This section summarizes
the oral comments received by EPA at the August 2, 1990 public
meeting, and provides EPA's responses to these comments.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSES TO THESE COMMENTS. This section contains the three letters
received by EPA during the public comment period, as well as EPA's
written responses to the letters.
V.
WRITTEN COMMENTS RECEIVED FROM COMMONWEALTH AND EPA'S RESPONSE. This
section contains the Commonwealth of Kentucky's comments regarding the
Draft Proposed Plan which were received during the public comment
period. The Commonwealth was given the opportunity to review the
Proposed Plan prior to its release to the public. The concerns set
forth in the letter were addressed in the Final version of the
Proposed Plan. In the Commonwealth's comments, it is stated that KRS
224.877 is an ARAR. EPA's response is also provided in this section.
ATTACHMENT A: Attachment A contains the Proposed Plan which was
distributed to the public during the public meeting held on August 2,
1990 and mailed to the information repository and persons included on
the mailing list.
ATTACHMENT B: Attachment B includes the sign in sheets from the
public meeting held on August 2, 1990 at the Howe Valley Elementary
School, Hardinsburg Road, Cecilia, Kentucky.
ATTACHMENT C: Attachment C includes the name, address and phone
number of the information repository designated for the Howe Valley
Landfill Site.
ATTACHMENT D: Attachment D includes the official transcript of
Public Hearing on the Proposed Plan for the cleanup of the Howe
Landfill National Priorities List Site located in Howe Valley,
Kentucky.
the
Valley
-------
Responsiveness Summary - Page 2.
I.
RESPoN'SIVENESS SUMMARY OVERVIEW
The u.S. Environmaatal Protection Agency (EPA) held a public comment period
from July 27 through August 27, 1990 for interested parties to comment on the
Remedial Investigation/Feasibility Study (RI/FS) results and the Proposed Plan
for the Howe Valley Landfill in Howe Valley, Kentucky.
The Proposed Plan, included in Attachment A of this document, provides a
summary of the site's background information leading up to the public comment
period. Specifically, the Proposed Plan includes the following sections:
Introduction, Site Background, Scope and Role of Response Action, Summary of
Site Risks, Summary of Alternatives, Evaluation and Analysis of Alternatives,
The Community's Role in the Selection Process, List of COntacts, Glossary of
Evaluation Criteria, and Glossary of Terms.
EPA held a public meeting at 7:30 pm on August 2, 1990 at the Howe Valley
Elementary School in Cecilia, Kentucky to outline the RI/FS and describe EPA's
proposed remedial alternatives for contaminants found in the on-site soils.
All comments received by EPA during the public comment period will be
considered in the final selection of a remedial alternative for the areas of
contamination at the Howe Valley Landfill Site.
The Responsiveness Summary, required by the Superfund Law, provides a summary
of the Commonwealth of Kentucky's and citizens' comments and concerns
identified and received during the public comment period, and EPA's responses
to those comments and concerns.
I.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Howe Valley Landfill was used during the years 1967 to 1976 as an
industrial waste landfill. The types of wastes deposited into the landfill
included by-products from silicone manufacturing processes, metal plating
sludges, various insulation and sealing compounds, and household refuse from
local residents.
Complaints from local residents about waste disposal activities at the landfill
prompted the initial site investigations conducted by the State of Kentucky
Division of Waste Management. The first complaint was filed in 1974 and
involved the unpermitted dumping of acidic liquid wastes into the landfill. In
1979, a complaint was filed regarding odors from an on-site pond. An
additional concern was created when several horses grazing near the landfill
died from liver abnormalities.
The level of public concern regarding the Howe Valley Landfill has been low,
except for residents living near the landfill. While the landfill was in
operation, residents witnessed the disposal of liquid wastes from a tanker
truck directly into the on-site pond. This incident increased the concerns of
those living near the landfill.
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Responsiveness Summary - Page 3
Several public concerns were expressed regarding the Removal and Remedial
Investigation activities. A general complaint concerning the landfill was the
increased truck traffic. Health concerns involved the effects of consuming
contaminated water-and direct contact with contaminated soil. Local residents
dependent on private wells for their potable water were concerned with the
quality of the ground water. Local officials were concerned with the potential
migration of contaminants into nearby streams and rivers, which could affect
the public water s~pply. Other concerns were expressed regarding surface water
contamination, such as ponds and streams, and the effects on animals consuming
contaminated water. Direct exposure to contaminated soils was also a concern
for citizens who used the landfill property for recreational purposes, which
include hunting, hiking, and motorcycles.
EPA conducted an information briefing and public information session for the
local community in June 1988, prior to initiation of the remedial
investigation. The major questions and concerns raised by the community and
the EPA responses are summarized below:
1.
One citizen asked how many drums are located at the site.
EPA Response: The contractor
drums have been placed inside
they are not corroded.
estimates approximately 5,500 drums. Some
larger drums. Most drums are in good shape;
2.
One citizen asked what types of materials are buried on the site.
EPA Response: Caulking wastes and plating sludges are the predominant
wastes known to date.
3.
One citizen asked how the drums, once uncovered, will be transported from
the site.
EPA Response: Samples are sent off-site for the treatability study;
however, the wastes may be initially treated on-site using such treatments
as chemical solidification and chemical fixation. If shipped off-site, the
contractor will most likely use a tanker.
4.
One citizen was concerned with the migration of contamination during drum
removal.
EPA Response: As far as officials know, no waste has flowed off the site
in any direction and the excavation process is not expected to cause
contamination to spread beyond the defined contamination zone. The
contamination zone is the site area designated for accommodating
contaminated materials. A berm was constructed and an impermeable liner
was installed to reduce surface runoff. The contamination zone is used for
the storage of drummed wastes and contaminated soil.
5.
One citizen asked if silicone is a toxic or hazardous waste.
EPA Response: As far as EPA knows, silicone is not a toxic or hazardous
waste. The properies of silicone are under examination.
-------
Responsiveness Summary - Page 4
6.
One citizen asked where non-hazardous wastes from the site will be
disposed.
EPA Response: EPA will discuss with the State of Kentucky where
non-hazardous wastes will be disposed.
Additional community relations activities conducted by EPA at the Howe Valley
Landfill to date include the following:
EPA conducted community interviews with the local community in April
1988
EPA prepared and distributed a fact sheet containing information on
the Howe Valley Landfill in May 1988
EPA established an information repository at the Hardin county Public
Library in June 1988
EPA issued a press release announcing the scheduled public information
session held on June 28, 1988
EPA conducted a briefing and public information session in June 1988
for both local officials and private citizens at the Howe Valley
Elementary School before remedial investigation activities began
EPA issued a press release, in July 1988, regarding the ground water
study conducted at the Howe Valley Landfill
EPA issued a press release, in July 1988, announcing the removal of
drums from the Howe Valley Landfill
EPA issued a press release, in August 1988, announcing the removal of
metal plating wastes from the Howe Valley Landfill
EPA prepared a community Relations Plan in september 1988
EPA released the Administrative Record for public review in July 1990
EPA prepared and distributed a Proposed Plan fact sheet in July 1990
A 3D-day public comment period was held for the community to express
any comments or questions on the Proposed Plan (July 27 - August 27,
1990)
EPA conducted a public meeting on August 2, 1990 at the Howe Valley
Elementary School to present the selected alternative and EPA's
Proposed Plan for remediation of the Howe Valley Landfill
-------
Responsiveness Summary - Page 5 .
III.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC MEETING AND EPA RESPONSES TO THESE COMMENTS.
Comments raised during the Howe Valley Landfill public meeting and public
comment period on the Proposed Plan are summarized below. The public meeting
was held on August 2, 1990. The comme~ts are categorized by topic.
A.
Selected Remedial Alternative
The following comments or questions were raised regarding the selected remedial
alternative:
B.
1.
One local official asked why Alternative 5, the selected remedial
alternative, was selected over the other five alternatives and whether
Alternative 5 includes monitoring of air, soil and water. The local
official concurred that Alternative 5 was the best choice for
remediation of the site.
EPA Response: EPA selected Alternative 5 because it complies with all
of the nine evaluation criteria used by EPA in choosing a cleanup
method, and was the most cost effective. In addition, the majority of
the soil will remain on-site and not fill other landfills with more
hazardous wastes. Alternative 5 will also include monitoring of soil,
air and water.
2.
In regard to Alternative 5, one citizen asked how often the site would
be monitored, who would conduct the monitoring, whether EPA would
collect split samples, and if any bio-monitoring would be conducted.
EPA Response: Monitoring of the site will be conducted quarterly by
the PRPs unless they decline to conduct the Remedial Action. If the
PRPs decline, EPA will conduct the monitoring. If the PRPs conduct
the monitoring, EPA will collect and analyze split samples. There are
no known biological risks associated with the site; therefore, no
bio-monitoring will be conducted.
General comments/Questions Regarding the Site and Associated Health Risks
1.
One citizen
distributed
site, while
majority of
wastes.
asked why the buried drums, prior to removal, were
only one drum deep and upright in the outer areas of the
the central area contained large stacks of drums, with the
the drums buried sideways, allowing more leakage of
EPA Response: The central area of the site has a deeper soil cover
down to bedrock, while the outlying areas have only a few feet of soil
cover to bedrock. For these reasons, more drums could be buried
deeper in the central area than in the outer areas.
2.
One citizen wanted to know the concentration of cyanide in soil
remaining on the site. This citizen did not feel that the health
risks associated with the site were of much concern.
-------
Responsiveness Summary - Page 6
EPA Response: The levels of cyanide in both the soil and ground water
on the site are below 1 part per million (ppm) , significantly less
than levels that would result in a human health or environmental risk.
3.
One citizen was concerned about the levels of contaminants in springs
surrounding Boutwell Spring. ,This citizen stated that he owned a farm
near Boutwell spring which contained several springs that were never
monitored.
EPA Response: Although previous sampling of Boutwell Spring indicated
that low levels of contamination were present, the concentrations were
well below the maximum concentrations set by EPA drinking water
standards. Because the location of the citizen's springs appears to
be between the site and Boutwell Spring, EPA will consider monitoring
these springs.
4.
One citizen employed with the local fire department was concerned with
the health risks to fire department personnel should a fire occur at
the site.
EPA Response: From the site data available and levels of
contamination found in on-site soils, there is no risk to fire
department personnel going onto the site property should a fire
assuming standard fire fighting practices are followed (e.g.,
approaching the fire from the upwind direction).
occur,
5.
One resident living approximately 1-2 miles northeast of the site was
concerned about future quality of ground water currently used for
drinking water purposes, the potential health risks from consuming
food grown in local soils, and the likelihood of increase cancer for
those living near the site.
EPA Response: The drinking water source for the Howe Valley residents
is located upgradient from the site, therefore the potential for
contamination of this water source is extremely low. Contaminants
were only detected in ground water south of the site, at levels well
below maximum levels allowed by EPA drinking water standards. The
extent of soil contamination is within the site boundaries. The
greatest risk of soil contamination is through direct exposure to
humans. Soils located off the site and used for agricultural purposes
should pose no risk to human health. The total individual lifetime
average carcinogenic risk associated with the site is lower than
applicable federal standards. The estimated risk of,an individual
developing cancer from on-site exposure is one in one billion.
IV.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
EPA'S RESPONSES TO THESE COMMENTS
Comments raised during the Howe Valley Landfill public comment period are
summarized below. The public comment period was held from July 27 to August
27, 1990.
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Responsiveness Summary - Page 7.
1.
ohe citizen proposed an additional method for site remediation. The
citizen suggested applying lime to the soil at the rate of 6 to 10
tons per acre at a depth of 1 to 3 feet. After approximately 2 weeks,
the soil ~an be prepared for reseeding using fertilizer and a mixture
of clover and grass seeds.
EPA Response: The lime application metnod suggested is used in
sewage treatment process to stabilize sludges and raise the pH.
process reduces odor and helps in the destruction of pathogens.
the nature of the wastes at the site such a process would not be
effective. The specific methodology for revegetating the site has not
been chosen. The soil type and climate of the area will be considered
before selecting a suitable groundcover; however, a mixture of grass
and clover will be considered as a groundcover alternative.
the
This
Given
2.
One citizen was not informed of the public meeting held on August 2,
1990, at the Howe Valley Elementary School. The citizen stated that
if she had known about the meeting, she would have attended because of
her concerns regarding the health and quality of life of nearby
residents.
EPA Response: Local residents were informed of the public meeting
through mailings and a public notice in the local newspaper, the
News-Enterprise. EPA regrets that this citizen was not notified.
Residents notified through the mail were on a mailing list developed
from a list of previous meetings attendees and from individuals
interviewed in 1988. This citizen will be added to the mailing list
to receive future information and notices.
3.
One Potentially Responsible Party (PRP) expressed their support of
EPA's Proposed Plan for the Howe Valley Landfill Site.
EPA Response: The PRP's opinion regarding the Proposed Plan and
selected remedies is appreciated.
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Responsiveness Summary ~ Page 8
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- . . . .
MAJUNG UST ADCmONS
If you want to' be placed on the mailing list to receiv~ info~tion on the Howe Valley landfill Site.
please fill out and mail this form to:
Mary Jo Penick
Remedial Project Manager
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
II D8er Ridg. F8nII
P. Y. Chart)on,..u
14734 58" River R08d
EasIVi8w. KY 42732
Name .f h I / /1 ~ V, L /; LJ,.. h D f) /) e 4 L,J
Address / ~ 7 3 ~I .5 t; Ii- R, ve r- f?d, E4o~-I V,e ~.
Telephone ,5" C 2 - ~6 2 - '3 Co It:
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Responsiveness Summary -
9
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UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
SEP 1 0 1990
Phillip Y. Charbonneau
14734 Salt River Road
East View, Kentucky 42732
Dear Mr. Charbonneau:
Thank you for notifying EPA of your concerns about the Howe Valley
Landfill NPL Site located in Howe Valley, Kentucky. EPA deeply
regrets that handicap access was not available for the Public Meeting
held in the Howe Valley Elementary School on August 2, 1990. Due to
the age of the school, air conditioning was only available in the
library located on the second floor, however we should have provided
access.
As for your suggestion for remediating the site by broadcasting slack
lime at the rate of 6 to 10 tons per acre, such a process is
typically used in the sewage treatment process to stabilize sludges
and raise the pH. This process reduces odor and helps in the
destruction of pathogens. Given the nature of the wastes at the site
such a process would not be effective. The organic contaminants
present in the on-site soils readily volatilize (i.e. go from a
liquid form into a gas form). Mixing the soils with a substance such
as lime would require essentially the same mechanical action,
rototilling, that will take place during the soil aeration remedy.
Rototilling and sunlight promote volatilization and the removal of
volatile organics without the addition of an agent such as lime.
Currently, a method for revegetating the site has not been chosen.
The soil type and climate of the area will be considered before
selecting a suitable groundcover: however, a mixture of grass and
clover will be considered as a possible alternative.
Thank you again for your concern regarding the Howe valley Landfill
Site. Should you have additional concerns, please feel free to
contact me or Suzanne Durham, Community Relations Coordinator, at
(404) 347-7791. .
7)T1Y, ,~~~
Mary J~ffU-"--
~emedial Project Manager
KY/TN Section
-------
Responsiveness Summary - Page 10
Ms. B. Allen
Page Two .
SEP 1 0 199Q
a risk assessment performed on data collected from the site, the only
threat to human health and the environment would be to persons and
animals that-act~ally lived on-site or visit the site on a regulqr
basis. You and your family, because none of you live close to the
site, are not at risk.
Again, EPA thanks you for your concern. So that you will remain
informed, your name has been added to the mailing list for the Howe
Valley Landfill Site. Should you have additional questions, please
feel free to contact me or the Community Relations Coordinator,
Suzanne Durham at (404) 347-7791.
7i!~ fJo 12v~ iG
Mary 30 plr/icf v
Remedial Project Manager
KY/TN Section
Enclosure
-------
Responsiveness Summary - Page 11
DOW CORNING
August 24, 1990 -
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Ms. Mary J0 Penick
Remecial Project Manager
U.S. EPA, Region IV
345 Courtland St.. NE
A~lar.ta, GA 30365
Re:
Howe Valley Landfill
Howe Valley, Kentucky
Proposed Plan Comments
Dear Ms. Penick:
On behalf of Dow Corning Corporation and Eagle-Picher Industries, Inc., I
am writing this letter in support of EPA's proposed plan for the Howe
Volley lrtr.dfill Site. It is our feeling and, based upon comments made by
the gen~ral public during the Public Information Meeting held at Howe
Valley on August 2. 1990, it is the feeling of the general public that EPA
has inde~d selected the m~st ~p~ropriate remedy for this site. Several
people from the Howe Valley area said they had independently selected the
SJme alternative after considering all of the evaluation criteria.
With regard to ARARs, it should be noted that the 1990 Kentucky Gp.neral
Assembly passed House Bill 893 which substantially amends K~S 224.877 and
should make the statute more consistent with CERCLA cleanup requirements.
Subsection 10 of the statute appears to authorize remedial action based
upon a risk assessment approach rather than "background levels". Assuming
this interpretation will be made by the KNREPC, Alternatives 4, 5 and 6
would also comply with all State ARARs.
The on-site incinceratior. alternative, which the State apparently indicated
was their preference, has a number of associated inherent problems. One
such prQbiem is EPA's newly proposed emission limits for incinerators. The
stricter rule, which was developed for fixed-base incinerators but also
applies to mobile units, appears to lower emission standards below
cur~ently attainable levels for mobile incinerators used at Superfund sites
and would thus prohibit their use (Superfund Report, August I, 1990). It
is possible, therefore, that this alternative would not be able to meet the
air ARARs at the Howe Valley Site. Furthermore, it would be less
protective of local human health and the environment, probably least
desireabie from a short-term effectiveness standpoint, would be the most
difficult alternative to implement, and be one of the most costly, if not
the most costly alternative considered.
DOW CORNING CORPORATION, MIDLAND. MICHIGAN 48686-0995
TELEPHONE 517 496-4000
-------
Responsiveness Summary - Page 12
Ms. Penick
August 24, 1990
Page 2
We offer these comments in support of EPA's proposed plan as well as EPA's
position that on~site incineration is not the most cost-effective remedy
for the Howe Valley Site.
Should you have any questions, please give us a call.
Sincerely,
~I:~! r( [, 1
l (x..".- 't.._-l. \ \ .. ,11:-_";" .....;{ ~
Edward C. Ovsenik
Sta ff Attorney
Dow Corning Corporation
ECO/slp/howeva12
-------
Responsiveness Summary - Page 13
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
SEP 1 0 iS~O
Ed C. Ovsenik
Staff Attorney
Dow Corning Corporation
Midland, MI 48686-0995
Dear Mr. Ovsenik:
Thank you for your statements regarding the Remedial Investigation
and Feasibility Study (RIfFS) and selected remedy for the Howe Valley
Landfill NPL Site located in Howe Valley, Kentucky. Your comments
will be incorporated into the Responsiveness Summary in the Record of
Decision (ROD) and the Administrative Record for the site.
Should you have additional comments or need information, please
contact me at (404) 347-7791. Thank you again for you interest in
the site.
Sincerely,
?2~~k~U~
Remedial Project Manager
KYfTN Section
-------
1-
Respons~veness Summary - Page 14
v.
WRITTEN COMMENTS RECEIVED FROM THE COMMONWEALTH AND EPA' S RESPONSE
Comments raised by the Commonwealth regarding the Draft Proposed Plan are
presented in the ~llowing letter. In compliance with the National Contingency
Plan (NCP), as revised March 8, 1990, the Commonwealth was given the
opportunity to review the Plan before ,it was released to the public. The final
version of the_ProBosed Plan addressed the Commonwealth's concerns.
In the letter, the Commonwealth contends that KRS 224.877 is an ARAR.
response follows the Commonwealth's letter.
EPA'S
-------
1--
CARL H. BRADLEY
SECRETARY
(1.!2 (CI-v':''''' 767(1,:) I-
II ~ (L:;,
WALLACE G. WILKINSO£ '
GOVERNOR
Responsiveness Summary - Page 1S
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
'DEPARTMENT FOR ENVIRONMENTAL PROTECTION
FRANKFORT OFFICE PARK
18 REILLY ROAD
FRANKFORT. KENTUCKY 40601
July 23, 1990
Mr. Harold Taylor
North Remedial Superfund
US EPA - Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Branch
Re:
Howe Valley NPL Site, Hardin County
Dear Mr. Taylor:
Attached are the comments to the draft Proposed Plan for the subject
site. Should you need clarification or additional information regarding
the comments, contact Bob Padgett or me in Frankfort at (502)-564-6716.
R~~.
Carl Millanti, Manager
Uncontrolled Sites Branch
CM/RBP/rbp
Attachment
cc:
Susan C. Bush
An :Qual Cpoonunity Employer M/FfH
-------
Responsiveness Summary - Page 16
COMMENTS TO THE DRAFT PROPOSED PLAN.
HOWE VALLEY NPL SITE, HARDIN COUNTY
SUBMITTED BY THE KENTUCKY DIVISION OF WASTE MANAGEMENT
JULY 23, 1990
1 )
General - The Commonwealth objects to the time frame in which the
Proposed Plan is being prepared. The NCP at 300.515(e)(1) states
that a' Prc1posed Plan will be prepared "at the conclusion of the
RI/FS". The Howe Valley plan is being prepared while the RI/FS is
still in a state of major revision. It is inappropriate for the
Proposed Plan to be discussing alternative selection when the RI/FS
has failed to fully characterize the vertical and horizontal extent
of contamination. The following items are submitted as
substantiation of the failure to characterize:
a)
No post-removal sampling was performed in the historically
recognized area of contamination defined as 13.5/F.5 on the
sampling grid used in the final round of sampling.
b)
Areas of bulking and overpacking from the original removal
action apparently were not sampled in the final round of
confirmatory sampling. Given the description of bulking
and overpacking activities, it is highly possible that
these areas are contaminated.
c)
The remainder of the site surrounding the historically
recognized area of contamination has never been screened.
There is a high possibility of contamination of this area
as evidenced by the background samples submitted by
Hatcher-Sayre. BRW-1, a sample allegedly indicating
background conditions, contained elevated levels of at
least arsenic, chromium, and vanadium while BRW-2 contained
elevated levels of arsenic and barium. These conclusions
are made by comparison with a background sample taken by
the Commonwealth at the same time as the final round of
sampling performed by Hatcher-Sayre. It should be noted
that laboratory data sheets were not submitted for the
Hatcher-Sayre background samples.
d)
Off-site contamination of sediments at the Boutwell Spring
is neither recognized nor addressed in the RI/FS or the
Proposed Plan. Constituents with apparent elevated levels
in the sample include aluminum, cobalt, chromium, nickel,
lead, and zinc. Identification of contamination remains
tentative because there was apparently no background
sediment sampling 'performed which would allow for a
comparison.
2).
General - The Commonwealth believes' it is imperative for the Proposed
Plan to clearly indicate what constituents are considered on the site
-------
Responsiveness Summary - Page 17
Howe Valley Comments
July 23, '1990
Page 2
in levels which are unacceptable to the EPA. Further, the plan
should clearly delineate the. level to which each of these
constituents will be remediated. This information is now masked in
discussions -of acceptable risks and hazard indexes. The public
should be informed as to the extent of contamination which is to be
left on-site.
3).
Pa~e 2 - The Commonwealth disagrees with the statement that sampling
has indicated contamination is dispersed in two distinct areas. As
far as Land Disposal Restrictions or other practical overview of the
site would dictate, there is only one area of contamination.
Further, it is inappropriate to discuss the contamination as being
segregated by type of contamination, i.e. organic contaminated area
and inorganic contaminated area. Two of the three post-removal
samples from the "metal contaminated area" analyzed for TCl indicated
organic contamination. The only post-removal sample from the
"organic contaminated area" analyzed for TCl indicated elevated
levels of metals. Without the full characterization discussed in
comment #1, the entire area should be considered to be contaminated
with both categories of constituents.
4).
Pa~e 3 - The Commonwealth disagrees with the statement that
post-removal sampling indicates contamination remains primarily in
defined locations or hot spots in the subsurface soils. As
previously discussed, Kentucky believes the area of contamination
encompasses at least the entire site for which characterization has
been completed. Post-removal sampling has found significant levels
of contamination from 12 inches to g feet. For purposes of
remediation, the Commonwealth views contamination in the context of
media such as soil versus water not depth such as surface versus
subsurface.
5) .
Pa~e 3 - The rationale for inclusion of contaminants on the list at
the bottom of this page as well as their definition as "major" is
unclear. Several of the listed constituents have been reported in
small quantities on the laboratory sheets. There are several other
soil contaminants reported in equal or greater concentration than
those listed. These other contaminants include barium, cadmium,
cobalt, mercury, and nickel among others. The list should include
all constituents found in levels exceeding the background. It should
include constituents found in the sediment at Boutwell Spring as
discussed in comment #1-d above. The Commonwealth is unable to
locate laboratory sheets indicating contamination from toluene or
xylene in the post-removal sampling. An explanation of their
inclusion on the list should be provided.
t
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Responsiveness Summary - Page 18
Howe Va11ey Comments
July 23, 1990
Page 3
6).
Paqe 4 - The Commonwealth believes the statement that contaminant
levels in groundwater were not found above MCLs is misleading. At
least two af the constituents (vinyl chloride and mercury) had their
detection limit set above the MCL. Another (cadmium) has its'
detection limit above the proposed MCLG and six others had their
detection limit at the same level as the MCL (benzene, carbon
tetrachloride, 1,2-Dichloroethane, 1,1,1-Trichloroethene, cadmium,
and lead). In the first instance, levels of contamination could be
above MCL without being detected. In the later instance,
contamination could be 99% of the MCL without detection. Both of
these could be serious situations, yet the public is being told that
there is no contamination above drinking water standards.
7).
Paqes 4. 5 & 6 - The risk assessment is still under review by
toxicologists within the Department for Environmental Protection.
8).
Paqe 7 - One problem which affects the analysis of all alternatives
under consideration;s the extent to which any alternative will clean
the media in Question. The proposed aeration will apparently reduce
organic contamination only to the soil action levels established in
the FS which do not attain state ARARs. Further, the Commonwealth
does not believe that the proposed alternatives intend to excavate
sufficient amounts of metal contaminated soils to reduce levels which
attain state ARARs.
The Commonwealth believes an insufficient number of alternatives is
under consideration. Specifically, Kentucky believes on-site
incineration and solidification are worthy of consideration.
Additionally, each alternative should spell out in detail those
features "common" to all actions. Wording in individual alternative
discussions make it unclear as to when fencing, monitoring wells,
deed restrictions, sampling programs, and periodic reevaluations are
required.
9).
Paqe 7. Alternative 2 - The use of the words "could involve" in
describing monitoring activities does not tell the reader what the
proposed action is for this alternative.
10). Paqe 8. Alternative 3 - The FS discounts the use of an on-site cover
due to the nature of the karst terrain, yet the alternative is still
considered as viable.
11). Paqe 8. Alternative 4 - This alternative would be acceptable to the
Commonwealth if sufficient amounts of soils would be removed to
attain state ARARs: Deed notification and groundwater monitoring
would also be required.
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Responsiveness Summary - Page 19
Howe Valley Comments
July 23, 1990
Page 4
12). PaQes 8 & 9.. Alternative 5 - Alternative 5 is unacceptable as
presented in the Proposed Plan. There is an insufficient amount of
details provided concerning the remedy. More information is needed
on the . proposal to contain and treat the particulate and gaseous
emissions. While the minute details can be worked out in the
Remedial Design phase, the reader needs to know some generalized
concept in order to properly evaluate criteria such as protection of
human health and the environment, attainment of ARARs, effectiveness,
imp1ementability, and other items mandated by the NCP.
The remedy apparently intends to treat and/or remove contaminated
s011s to the action levels specified in the FS. Therefore, it is
allowing soils with a given level of contamination to remain
on-site. CERCLA, SARA, the NCP, and state and federal ARARs mandate
numerous post-closure requirements when waste is left in-place.
Among such requirements are a multi-media final cover, groundwater
monitoring, and periodic reevaluation. These items are not included
on alternative 5 as presented.
13). PaQe 9. Preferred Alternative - The FS correctly concludes (Table
9-3, page 187) that capping is not appropriate for the site due to
the nature of the karst terrain. In its' analysis of on-site
incineration, the FS concludes that "residual management and
treatment costs" make the option unattractive. While the conclusion
concerning the management and treatment of residuals is correct, it
has applied the analysis to the wrong alternative.
On-site incineration of organic-contaminated soils will virtually
eliminate any residual contamination. It will treat soils to levels
which attain state ARARs, not just meet the soil action levels set by
the FS. Aeration of the soils will likely only reduce the
contamination to low levels which will require residuals to be
further treated and/or managed as discussed 1n comment _11. It is
this "residual management and treatment costs" which the FS finds
unacceptable.
It is assumed that in either alternative, inorganic-contaminated
soils must be excavated and disposed of off-site. Therefore, in
order to attain state ARARs, achieve a more permanent remedy,
significantly reduce or eliminate post-remedial operations and
maintenance, and protect human health and the environment, the
preferred remedy of the Commonwealth is on-site incineration of
organic contaminated soils and excavation and off-site disposal of
inorganic-contaminated soils. The remedy should also include a deed
notification and groundwater monitoring program.
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Responsiveness Summary - Page 20
Howe Va11ey Comments
July 23, 1990
Page 5
14). Paqe 9. Analvsis - The FS does not agree
will prevent groundwater contamination.
installatio~ of a cap is not protective
karst terrain.
that an on-site RCRA cap
In fact it says that
due to the nature of the
15). Paqe 10. ComDliance with ARARs - No alternative in the proposed plan
will attain State ARARs. The primary ARAR in question is KRS 224.877
which was not discussed in the ARARs section of the FS. A principal
requirement of KRS 224.877 is to restore the environment to the
extent practicable. It always has been and continues to be the
position of the Commonwealth that the tenm practicable is defined as
technically feasible.
The 1990 session of the Kentucky General Assembly revised KRS 224.877
to allow the state to consider cleanup to an alternative level, based
upon several human health and environmental criteria. The baseline
risk assessment is still being reviewed to detenmine if it meets the
criteria set forth in the amended KRS 224.887. Regulations for
implementation of the revised statute are to be promulgated within
180 days of enactment of the bill. That process is now underway but
is unlikely to be completed by the time of ROD signature. In lieu of
an established process to implement the revised statue, the best
professional jUdgement of Division of Waste Management staff is that
the levels established in the FS are not acceptable. Therefore,
unless the soil action levels are changed, additional rationale for
their establishment is forthcoming, or the completed review of the
risk assessment indicates otherwise, the statute makes it clear that
restoration to the extent practicable is required under state ARARs.
16). Paqe 10. Lonq-tenm Effectiveness - The FS does not agree that capping
in a karst terrain will provide long-tenm effectiveness or
penmanence.
17). Paqe 11. State AcceDtance - It is critical that this section
thoroughly and accurately state the position of the state as outlined
in these comments. The Commonwealth does not believe that state
ARARs are being attained. The Commonwealth does not believe the
preferred alternative selected by EPA is. protective of human health
and the environment. The Commonwealth does not believe the preferred
alternative selected by EPA satisfies the nine criteria for remedy
evaluation as outlined in the NCP. The Commonwealth prefers on-site
incineration of organic contaminated soils and off-site disposal of
inorganic contaminated soils. Any selected remedy should also
include deed notification, groundwater monitoring, and periodic
reevaluation.
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Responsiveness Summary - Page 2~
EPA Response
CERCLA and the National Contingency Plan prescribe that remedial actions must
attain requirements under state environmental laws which (i) specifically
address a hazardous substance, pollutant, contaminant, remedial action,
location or other circumstance found at aCERCLA site or which are determined
to be relevant and.appropriate, (ii) are promulgated, (iii) are more stringent
than federal requirements, and (iv) are timely notified to the President or EPA
("ARARs"). KRS 224.877, as amended, is not an ARAR. The substantive
provisions of KRS 224.877 which could arguably be applicable or relevant and
appropriate requirements are contained in Sections 5 and 10 thereof. As
described below, neither Section meets the eligibility criteria for ARARs
provided in CERCLA or in the National Contingency Plan.
Section 5 of the Kentucky statute states that persons having possession or
control over a hazardous substance, pollutant, or contaminant being released or
who caused the release must take "actions necessary to restore the environment
to the extent practicable and minimize the harmful effects from any release
into the air, lands or waters or the Commonwealth." Such restoration and
minimization merely constitute a general goal or legislative intent about a
desired outcome or condition rather than a specific requirement.
Moreover, said provision is not a binding requirement as it only applies in the
event a particular remedial action does not meet the criteria set forth in
Section 10 of the statute. Such a relationship between Section 5 and Section
10 is confirmed in paragraph 15 of the attached letter which states that the
Commonwealth may "consider cleanup to an alternative level, based upon several
human health and environmental criteria." As KRS 224.877(5) is a general goal
which does not set out a specific, enforceable cleanup standard and which is
not a binding requirement, it is not a cleanup ARAR.
Section 10 of KRS 224.877 states that remedial actions "shall protect human
health, safety and the environment" considering certain factors outlined
therein as appropriate. Section 10 does not constitute an ARAR either because
the protection obligation is not more stringent than federal requirements which
are relevant to remedial actions. For example, Section 121(d) of CERCLA
provides that remedial actions shall attain a degree of cleanup which, at a
minimum, assures protection of human health and the environment. Section 121
of CERCLA, in addition to a multitude of other federal requirements governing
remedial actions, is equivalent to or more stringent than the mandate contained
in KRS 224.877(10).
In summary, KRS 224.877 does not contain any specific, enforceable requirements
that are more stringent than provided by federal law and thus is not a state
ARAR. Nonetheless, the U. S. Environmental Protection Agency has complied with
the requirements of KRS 224.877. According to Section 10 of KRS 224.877, "the
remedial action shall protect human health, safety, and the environment
considering the following factors as appropriate:
(a)
The characteristics of the substance, pollutant, or contaminant,
including its toxicity, persistance, environmental fate and transport
dynamics, bioaccumulation, biomagnification, and potential. for
synergistic interaction and with specific reference to the environment
into which the substance, pollutant, or contamin~nt has been released;
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Responsiveness Summary - Page 22
(b)
The hydrogeologic characteristics of the facility and the surrounding
area;
(c)
The proximity, quality, and current and future uses of surface water
and groundwater;
(d)
The potential effects of residual contamination of potentially
impacted surface water and ground water;
(e)
The chronic and acute health effects and environmental consequences to
terrestrial and aquatic life of exposure to the hazardous substance,
pollutant or contaminant through direct and indirect pathways;
(f)
An exposure assessment; and
(g)
All other available information."
If a proposed remedial action is protective of human health, safety and the
environment taking the above factors into consideration, then the remedial
action is in compliance with the Kentucky statute. The remedy for the Howe
Valley site proposed by EPA met the requirements of KRS 224.877(10) through the
performance of a Remedial Investigation (RI), a Feasibility Study (FS) and a
baseline risk assessment.
According to the National Contingency Plan (NCP), as revised March a, 1990, an
RI/FS shall be undertaken at all National Priorities List (NPL) Superfund sites
to determine the nature and extent of the threat presented by the release and
to evaluate proposed remedies. Specifically, the RI is performed to collect
data necessary to adequately characterize a site for the purpose of developing
and evaluating effective remedial alternatives. Characterization activities
include:
identification of important surface features, soils, geology,
hydrogeology, meteorology and ecology;
assessment of the air, surface waters and ground water;
assessment of wastes (including quantities, state, concentration,
toxicity, propensity to bioaccumulate, persistance, and mobility),
identification of contamination sources;
identification of exposure pathways through environmental media;
identification of actual and
routes (i.e., inhalation and
frequency and duration; and,
potential human or environmental exposure
ingestion) along with their magnitude,
assessment of other factors that pertain to the site or support the
analysis of potential remedial action alternatives.
AS the State of Kentucky is aware, an RI was conducted, in accordance with the
NCP, for the Howe Valley Site. The RI activities include~, but were not
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Responsiveness Summary - Page 23
limited
wastes,
project
to, a characterization of wastes buried on-site, removal of these
pre- and post-removal environmental sampling, a soil aeration pilot
and a hydrggeological characterization of the Howe Valley area.
Data collected during the RI was used in a baseline risk assessment. According
to the NCP, a baseline risk assessment. is conducted to characterize the current
and potential ~hreats to human health and the environment that may be posed by
contaminants migrating to ground water, releasing to air, leaching through
soils, and bioaccumulating in the food chain. For the Howe Valley site, the
results of the RI and the baseline risk assessment indicated that very low
levels of residual contamination, specifically chromium and tetrachloroethene,
remain in the on-site soils and pose a potential risk to human health and the
environment. Primary routes of exposure to humans would be through the
ingestion of soils and/or ground water associated with the site.
In addition to the RI, an FS was conducted for the site. This is required by
the NCP to ensure that appropriate remedial alternatives were developed and
evaluated using EPA's nine criteria analysis. Each alternative was assessed to
determine whether it would adequately protect human health and the environment,
in both the short- and long-term, from unacceptable risks posed by hazardous
substances, pollutants, or contaminants present at the site. During the Howe
Valley FS, six alternatives were selected and evaluated. These six were chosen
based upon their applicability at the site and effectiveness for reducing the
risks associated with the site. Of the six, one alternative, soil aeration
combined with removal, was selected as the final remedy. This particular
alternative, upon the success of the treatability study, will meet the
requirements of the nine criteria and reduce the site risks at a much lower
cost than any of the other alternatives. Additionally, the contingency remedy,
removal of contaminated soil, should it be implemented, will also meet all
requirements and reduce site risks.
The RI describes the characterization of wastes buried on-site, including the
characteristics set forth in KRS 224.877(lO)(a). Additionally, the
hydrogeological assessment for the site, as required by KRS 224.877(lO)(b), was
accomplished during RI activities. The hydrogeologic characteristics of the
Howe Valley area were determined through four separate dye trace studies.
Three of the traces, conducted at the site, indicated that ground water travels
southeast from the site and surfaces 1.8 miles away at Boutwell Spring. The
additional trace was conducted by the U.S. Geological Survey to find an
alternate water source for the Howe Valley area. This study indicated the
presence of a ground water divide north of the site, between the site and
Pirtle Spring. This particular spring serves as the drinking water source for
the Howe Valley area. The implication is that ground water leaving the site
flows on the opposite site of the divide from Pirtle Spring; thus, a natural
barrier exists against possibly contam~nated ground water reaching the water
supply. Along with the dye traces, the RI activities also included the
examination of the proximity, quality, and current and future uses of surface
water and ground water, as described in KRS 224.877(lO)(c). The results of
these examinations are discussed in greater detail in the RI Report.
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Responsiveness Summary - Page 24
The potential effects of residual contamination, chronic and acute health
effects, environmental consequences and the exposure assessment, also required
by KRS 224.877(10), were determined during the baseline risk assessment. As
stated earlier, tH-e site poses a very low risk to individuals or an~als that
ingest on-site soils or ground water. Furthermore, the remedies, both the
pr~ary and contingency, proposed in t~e ROD will lower the risk associated
with the site ~o l~vels acceptable to EPA and in compliance with the NCP. The
potential effects of residual contaminants on ~pacted surface and ground water
was a pr~ary factor in the development of soil action levels (SALs). The SALs
calculated for the site take into account the potential for residual
contaminants to leach from the soil into the ground water. The final
concentrations for SALs, as stated in the ROD, will be protective of both
surface and ground water.
All other available information
of these reports were presented
additional copy is contained in
was incorporated in the RI/FS reports.
to the Commonwealth for their review.
the Howe Valley Administrative Record.
Copies
An
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ATTACHMENT A
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Attachment A - Page 1
-
SUPERFUND FACT SHEET
PROPOSED PIAN
Howe Valley Landfill Site
Howe Valley, Kentucky
~
~
EPA
REGION IV
July 1990
INTRODUCTION
This Proposed Plan is being issued to describe
the alternatives that the U.S. Environmental
Protection Agency (EPA) has considered for the
remediation of the Howe Valley Landfill
National Priorities List (NPL) Site (also referred
to as the Howe Valley Site) located in Howe
Valley, Kentucky (see Figure 1). This plan
presents an evaluation of possible remedial
alternath-es, including the alternative that is
preferred by EPA. Each alternative is described
in greater detail in the Remedial Investigation
(RI) "and Feasibility Study (FS) Reports which
are available, along with the Site Administrative
Record, at the Information Repository located in
the Hardin County Public Library, 201 West
Dixie Highway, Elizabethtown. Kentucky.
A Removal and an RI were conducted and an FS
was prepared by several Potentially Responsible
Parties (PRPs) under an Administrative Order
between the PRPs and EP A. The Kentucky
Natural Resources and Environmental Protection
Cabinet (KNREPC), Division of Waste
Management acts u a support agency for this
Site.
The alternative preferred by the U.S.
Environmental Protection Agency represents a
preliminary decision, subject to public comment.
Section I 17(a) of the Comprehensive
Environmental Response, Compensation and
Liability Act (CERCLA) of 1980, as amended
by the Superfund Amendments and
Reauthorization Act (SARA) of 1986, requires
publication of a notice and brief analysis of a
Proposed Plan for Site remediation. This plan
provides background information on the Site,
describes the remedial alternatives, provides the
rationale for identification of the preferred
alternatives, and outlines the role of the public
in helping EP A make a final decision on a
remedy.
EPA encourages the public to submit written
comments on all alternatives presented in this
plan. Public comments may result in selection
of alternatives other than the ones preferred by
EPA for the Site.
SITE DESCRJPTlON AND BACKGROUND
The sparsely vegetated, eleven (11) acre Howe
Valley Landfill Site is situated at the end of
Tom Duvall lane, approximately 1.4 miles south
of State Road 86 within the Towns of Cecilia
and Vertress. Kentucky. The nearest
community is the unincorporated area of Howe
Valley.
MARK YOUR CALENDAR
July 26 - August 24, 1990:
Public comment period on the
remedial alternatives
August 2. 1990:
Public meeting at the
Howe Valley Elementary School
Hardinsburg Road. Cecilia. Kentucky
at 7:30' p.m.
Page I
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Attachment A - P~ge 2
AGURE 1 - SITE LOCATION MAP
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15
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N
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i
OWENsaORO
SiiE 0
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~~ ~ ~'f.
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Page 2
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Attachment A - Page 3
"
Beginning in 1967, Kentucky Industrial Services,
Inc. (KIS) used the Howe Valley Site as an
industrial waste landfill. In 1972, the
Commonwealth of Kentucky passed a law
requiring operating permits for solid waste
landfills. The KNREPC's Division of Waste
Management. granted a permit allowing KIS to
continue accepting solid wastes but not
hazardous wastes. The landfill operated under
the State-issued solid 'waste - permit until June
1976, when the Site officially closed.
In response to a 1980 Federal mandate requiring
States to identify open dumps, the KNREPC
conducted a site inspection of the Howe Valley
Landfill and found that wastes being released
from the Site into the underlying karst terrain
could potentially migrate to Linders Creek and
infiltrate the Green River Drainage Basin.
Karst terrain is land that consists of
rolling terrain underlain by limestOne
and marked by depressions Or sinkholes
that form as the limestone weathers.
Irregular underground paths, which
form when limestOne dissolves, make it
difficult to predict where and how fast
water will travel underground. Ground
water in karst terrain can travel at a rate
of several hundred feet per day.
Upon the State's request, EPA conducted a
Preliminary Assessment (PA) and Site
Investigation (51). Results confirmed that water
flowed towards Linders Creek and that between
2,000 to 5,000 drums were buried at the landfill.
The collected data were evaluated under the
Hazardous Ranking System (HRS). Since
contamination on-site had the potential to create
a risk to public health and possibly migrate off-
site, the Site was assigned an HRS score of
36.13. In compliance with CERCLA the Site
was proposed for inclusion on the NPL in June
1986 and finalized in July 1987.
Under an Administrative Order between EPA
and two of the PRPs for the Site, the PRP's
contractor conducted a removal and an RI. The
removal, conducted in the Summer of 1988,
involved a total of 9,150 full or partially filled
drums, 1,621 empty drums, 6,000 small
containers and 3,000 cubic yards of non-
containerized waste. Wastes found on-site, both
containerized and non-containerized,
consisted of:
- silicone pOlymers;
- organic liquids associ:1ted with silicone
polymers;
- heavy metal plating sludges; and
insulation manufacturing chemicals.
All wastes and highly contaminated soils were
sent off -site for permanent disposal in Resource
CODservation and Recovery Act (RCRA)
approved landfills or for treatment at RCRA
approved incinerators. Water contained in an
on-site pond was treated with a portable, water
filtration unit containing activated carbon.
After the filtered water was tested and found to
be clean, it was used for dust supression and
equipment 'cleaning.
Samples collected during the removal indicated
that contamination was dispersed in several
distinct areas of the Site (see Figure 2). The
outer area of the Site predominantly contained
metal bearing sludges while the central area
predominantly contained volatile organic bearing
wastes.
As a way to address soil contamination
remaining on-site after completion of the
removal, the PRP's contractor conducted a soil
aeration project in the Fall of 1988. Soils from
the central area of the Site were spread out in 1-
foot liftS and roto-tilled to promote
volatilization of the organic contaminants. The
PRP's contractor decided to stop the project
once they determined that soil contaminant
levels had decreased.
Due to the karst geology associated with the Site,
the PRP's contractor had to define ground water
flow patterns before any ground water samples
could be collected and analyzed for
contamination. In September 1988, during
drought conditions, a dye-trace study was
conducted. ResultS indicated that water entering
the on-site sinkhole traveled to Boutwell Spring,
approximately 1.85 miles south of the Site at a
rate of 290 feet per day. Samples collected at
Boutwell Spring showed traces of the same
contaminantS that were known to be at the Site.
In January 1989, a draft RI report and draft FS
report were submitted to EPA for review and
approval. Information in the reportS was
incomplete and not conclusive enough for EPA
to base a decision upon. In response to the
reportS, EPA submitted commentS to the PRPs.
In order to eliminate data gaps in the reportS,
EP A requested that the PRPs have their
contractor conduct additional iqvestigations so a
final Site remedy could be selected.
Page 3
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Attachment A - Page 4
AGURE 2 - AREAS OF CONTAMINATION
loeT
700S I
500E
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/,L-- AC:z..sS ROAD
OOOS
500N
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:roON
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o OUTL YING AREAS
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illil'!S OF
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OUTLYING
AREAS
Page 4
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Attachment A - Page 5
Post-removal/post-aeration sampling was
conducted in March 1990 to locate and assess the
Quantities of contamination still remaining on or
off -site. The findings of the supplemental
sampling indicated that contamination remained
. in the on-site subsurface soils, primarily in the
central area and two outlying hot spots.
Since the first dye-trace study was carried out
during extremely low flow conditions, it was
decided by EPA, the PRPs and the U.S.
Geological Survey (USGS), that a second dye-
trace should be conducted under maximum flow
conditions. In January 1990, the additional trace
confirmed that water entering the on-site
sinkhole flowed directly to Boutwell Spring, but
this time at a rate of approximately 10,000 feet
per day. Water samples collected in March 1990
from the spring did not show any contamination
above the EPA's Drinking Water Standards.
The chemicals listed below represent the Site
related contaminants detected above background
in the on-site environmental samples collected in
March 1990:
looraanies: Chromium
Copper
Zinc
Cyanide
Oraanics:
1,2-dichloroethene O,2-DCE)
l,l-dichloroethane ( 1,1- DCA)
l,l,l-trichloroethane 0,1,1 TCA)
tetrachloroethene (PCE)
trich10roethene (TCE)
Base/Neutral
Extractables: di-n-butyl phthalate
The Proposed Plan addresses two identified areas
of concern associated with the Site. The first
area addressed includes the soils in the outer
area of the Site known to still contain metals,
primarily chromium. The second area includes
the soils from the central area of the Site that
contain significant levels of organics, especially
tetrachloroethene (PCE). In both these areas the
contaminants are located within the near-surface
(l to 2 feet deep) or subsurface (3 to 9 feet
deep) of the Site.
SCOPE AND ROLE OF RESPONSE AcnON
The soil at the Howe Valley Landfill Site is now
under consideration for cleanup. Currently, the
Site is unoccupied and has no specific function.
The property is occasionally used by hunters or
by people riding all terrain vehicles (A TVs)
and/or dirt bikes. Neither the ground water
flowing from the Site to Boutwell Spring nor the
surface water associated with the intermittent
on-site stream are used as drinking water
sources. In addition, contaminant levels in the
ground water were not above drinking water
standards. For these reasons, a remedy for only
the on-site soils is being proposed to protect
. public health and the environment by
eliminating the possibility of exposure to or
migration of contamination into the ground
water. The preferred alternative will use a
combination of technologies to remediate both
areas of soil contamination (i.e., outer and
central areas).
The remedial alternatives under consideration
are presented later in the fact sheet. The FS
Report presents a more thorough description and
evaluation of these alternatives. The
Administrative Record, which contains the FS
Report along with other documents and
correspondence that are the basis for choosing a
particular Site remedy, is available for public
review at the Site information repository located
in the Hardin County Public Library, 201 West
Dixie Highway, Elizabethtown, Kentucky.
Based on new information or public comments,
EPA in consultation with the KNREPC, may
modify the preferred alternatives or select
another remedial alternative presented in the
Proposed Plan and the FS Report. The public is
encouraged to review and comment on all
alternatives identified.
SUMMARY OF SITE RISKS
During the RI/FS, an analysis was conducted,
using several potential contamioants of coocero
to estimate the health or environmental risks that
may result if contamination at the Site is not
remediated. The analysis, commonly referred to
as a baseline risk assessment, focused on the
health effects from both short-term and long-
term exposure to contaminantS as a result of
contact or ingestion of Site surface soil, surface
water and/or ground water. Exposure could also
occur through inhalation of stirred-up dust
particles or contaminantS released from the soil
by yolatilization.
Page 5
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Attachment A - Page 6
The potential contaminants of concern used for
the risk assessmt;nt were: .
T etrachloroethene
1,2-dichloroethene
1,1,1- trichloroetha.11e
Cyanide
Chromium
Copper
Zinc
Ground water from the Site nows directly to
Boutwell Spring and is not .4:urrently used as a
drinking water source. Therefore, there should
be no direct pathway for exposure to
contaminated ground water near the Site. Also,
ground water samples have not indicated that
contaminant levels are above drinking water
standards. To prevent the use of shaJIow ground
water beneath the Site or surface water on-site,
restrictions will be placed on property deeds. In
addition, regular monitoring will be conducted
at Boutwell Spring and any existing or future
wells installed along the ground water route
between the Site and the spring.
The potential risks of long-term exposure to
contaminants from the Site were calculated
based on the chosen potential contaminants of
concern detected at the Site, which include both
human carcinogens (cancer causing chemicals)
and non-carcinogens. Carcinogenic risks are
expressed as the chance a person has of
Cieveloping cancer as a result of a lifetime of
exposure to contaminants at the Site. For non-
carcinogens, the EPA evaluates the risk by
determining a Hazard Index (HI). The HI is a
num!>er that renects a comparison of the
calculated exposure level for a contaminant at
the Site to an exposure level that would not
cause harm from daily exposure over a lifetime
(i.e., the reference dose (RfD». An HI greater
than 1.0 indicates that exposure exceeds the
protective level. All HIs, with one exception,
calculated for exposure to non-carcinogens in
the on-site soil were less than 1.0 indicating that
contaminants at the Site are below levels that
should cause significant concern. A location in
the outer area of the Site known to contain
elevated chromium levels was found to have an
HI of 2.0. Additionally, exposure to
carcinogenic compounds through soil contact
was also determined not to be a health concern
except in several locations within the central
area. These particular spots contain elevated
levels of tetrachloroethene which creates a
slightly higher risk in these locations. However,
the total individual lifetime carcinogenic risk
associated with current ixposure to on-site soil
was found to be I x 10- which is less than the
Federal guideline of I x 10-6. The total
individual lifetime carcinogenic risk associated
with exposure to contaminated soils was
Page 6
estimated to be that an individual would have
one additional chance in one billion to develop
cancer.
Since there are no longer any ponds on-site and
the intermittent streams only now after
relatively heavy precipitation events, the risk
calculations for Site surface waters involved the
. only stream sample collected in March 1990
after a rainstorm. No carcinogenic compounds
were detected, therefore no carcinogenic risks
could be calculated. The HI was well below the
Federal guideline of 1.0 indicating no substantial
threat. from exposure to contaminants in the
surface water at the Site.
The Site is currently popular for riding dirt
bikes and all terrain vehicles. Such recreational
vehicles stir up contaminated dust particles or
cause the direct volatilization (release) of
contaminants into the air. Direct contact or
inhalation of dust or volatilized chemicals is a
route of exposure and increases a person's
chance of developing adverse health effects.
Based upon the risk assessment, it was
determined that the lifetime cancer risk from
exppsure to contaminants in the air was 3 x
10- which is less than EP A's guideline of I x
10-6. In this instance a risk of 3 x 10-7 means
that a person's chance of developing cancer as a
result of long-term inhalation of Site related
contaminants increases by one additional chance
in 3,300,000. The HI for the non-carcinogenic
contaminants was less than the guideline of 1.0.
Since the Site is currently unoccupied and no
one uses ground water from the Site as a
drinking water supply, the risk to the public
health is minor. However, there is a possibility
that future conditions could alter the risks.
Should a residence be established on-site, the
estimated chance of the residents developing
cancer from exposure to contaminants in the
soil, primarily in the areas with elevated
tetrachloroethene concentrations, is increased by
one chance in 500,000. And in particular areas
where chromium was found in high levels, the
HI is tWice the standard or 2.0. Should a
drinking water well be placed on-site or along
the route between the Site and Boutwell Spring,
an additional assessment will need to be
performed to determine the risks from contact
with or ingestion of the ground water.
Since most of the chemicals found at the Site are
not known to accumulate in plant or animal
tissues, there is little possibility that
contaminants at the Site may have adverse
effects on both plants and animals. Only in the
.~
-------
I-
I
Attachment A - 7
areas of the Site that contain-the highest
concentrations of contaminants is there a
possibility that plant growth or health would be
inhibited or that small burrowing animals may
be affected.
Actual or potential releases of contaminants
from this Site, if not addressed by the preferred
alternative or one of the other active measures
considered, may endanger public health,
welfare, or the environment.
SUMMARY OF ALTERNATIVES
The following are the Remedial Alternatives
under consideration for the contaminated soil.
The FS Report contains a more detailed
evaluation of each alternative.
1.
No Action
.,
-'.
Institutional Controls such as access
limitations and/or resource-use deed
restrictions
3.
Containment by capping the
contaminated portion of the Site
4.
Removal and off -site disposal of
contaminated soils associated with the
Site
5.
On-site treatment of the contaminated
soil through the implementation of an
EP A approved technology
Off-site treatment of contaminated soil
6.
All the alternatives, with the exception of the
"no action" alternative, will require that
resource-use restrictions be stated on the
property deed. For all the Alternatives perioqic
monitoring of the Site and associated ground
water be conducted to assess the effectiveness of
the chosen remedy.
ALTERNATIVE ONE: NO AcnON
Present worth Cost
Capital Cost
Operations & Maintenance (O&M)
Cost based upon 30 years
of monitoring:
Time to Implement 6 months
CERCLA requires that the No Action alternative
be considered at every site. Under this
alternative, up to eight on-site wells will be
installed and monitored along with Boutwell
S 215,700
84,700
131,000
Spring. No soil removal or treatment will be
implemented. The only reduction of
contaminant levels could OCcur via natural
processes such as dispersioD or degradation. The
only costS will be for the initial installation of
wells and periodic ground water monitoring.
ALTERNATIVE TWO: INSTTTUnONAL CONTROLS
Present Worth Cost:
Capital Cost
O&M Cost for 30 years):
Time to Implement: 6 months
S 307,125
143,350
163,775
Implementation of institutional controls will
involve not only the monitoring activities
proposed in the No Action alternative, but will
include construction and maintenance of a 3,000
foot fence along with placement of warning
signs around the Site. Also, usage restrictions
will be recorded on the deed for both the
property and on-site surface and ground water
supplies. This alternative will not involve
removal or treatment of contaminated soils.
ALTERNATIVE THREE: RESOURCE
CONSERVATlON AND RECOVERY AGT (RCRA)
LANDRLL CAP AND DRAINAGE SYSTEM
Present Worth Cost
Capital Cost
O&M costS for 30 years:
Time to Implement 18 months
A RCRA landfill cap will be constructed over
the central area of the Site where the
contaminated soils are located. The outer areas,
containing inorganic contamination, will be
excavated and transported for disposal in the
central area. The landfill cap will be
constructed of clay and synthetic liners. A run-
on/run-off drainage collection system will be
constructed around the perimeter of the landfill
to divert water to the on-site sinkhole. In
addition, the Site will be seeded and fenced.
S 839,400
632,100
207,300
Since contaminantS will be left on-site, ground
water will be monitored annually for 30 years.
A risk assessment will be conducted every five
years during the 30 years of monitoring.
ALTERNATIVE FOUR: OFF-SITE RCRA LANDALL
Present Worth Cost
Capital Cost
O&M Cost (5 years):
Time to Implement 6 months
S 3,821,200
3,808,800
12,400
Page I
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Attachment A - Page 8
ALTERNATIVE SIX: OFF-SITE INCINERATION
Soil in the outer area (approximately 100 cubic
yards) and the ceqtral area (approximately 7,400
cubic yards) will be excavated and transported,
following all applicable RCRA Land Disposal
Restrictions (LDRs), to an off -site RCRA
approved landfill. Both excavated areas and
roadways will be wetted to facilitate dust
control. Berms and ditches currently around the
Site will be upgraded to divert run-on/run-off
away from Site activities. "to replace excavated
soils. approximately 7,500 cubic yards of fill
material will be spread over the Site and then
seeded. A five year ground water monitoring
program will involve annual sampling of
Boutwell Spring and any current or future wells
installed along the route between Boutwell
Spring and the Site. Also. a risk assessment will
be conducted at the end of the five year period.
AlTERNATIVE AVE: OFF-SfTE DISPOSAl AND
ON-SfTE AERATION
Present Worth Cost:
Capital Cost:
O&M Cost for 5 years:
Time to Implement: 6 months
$ 364,300
351,900
12.400
Soil from the outer area will be excavated and'
transported to an off-site RCRA approved
landfill. Central area soils will be excavated and
placed next to the excavated trenches in I-foot
high lifts. The soil will be mechanically mixed
to break up dirt clumps and promote
volatilization of the organics. Periodic sampling
of soil will be conducted to ensure that clean-
up criteria are being met. Additionally, air
monitoring for particulates and volatile organics
will be conducted along the Site boundary.
During aeration activities run-on/run-off water
will be collected in the ditches along the
perimeter of the landfill. Once organic
contaminants are within the acceptable
concentrations, the remediated soil will be
redeposited in the central area. Clean fill will
be placed in the outer areas to replace the
excavated soils. Upon completion, the Site will
be regraded, covered with top soil and seeded to
restore the vegetative cover. Ground water will
be monitored for five years at Boutwell Spring
and any current or future wells installed along
the route between Boutwell Spring and the Site.
At the completion of the five year period, a risk
assessment will be conducted. Deed restrictions
will limit and/or prohibit the use of both the
property and on-site surface and ground water
supplies.
Present Worth Cost:
Capital Cost:
O&M Cost for 5 years:
Time to Implement: 6 months
$ 19.001,800
18,989,400
12,400
Contaminated soils, in both the outer and central
areas, will be excavated and transported to a
RCRA approved incinerator. The incinerator
will destroy the organic contaminants, however
residual ash will still contain inorganics and will
have to be disposed of in an approved off-site
landfill. During excavation activities, run-
on/run-off water controls will be implemented
as specified in Alternative 4. To replace the
removed soils, clean fill dirt will be brought to
the Site and revegetated. A 5-year monitoring
program, risk assessment and deed restriction. as
stated under Alternative 5, will also be
implemented. All activities will comply with
RCRA LDRs.
EVALUATION OF ALTERNATIVES
The preferred alternative for soil remediation at
the Howe Valley Landfill Site is Alternative 5.
This alternative involves the removal of soil
from the outer area of the Site along with on-
site remediation of the soils in the central area.
An initial treatability study will be conducted to
determine if the aeration technology proposed in
Alternative 5 will work for soils at the Site. In
the event the treatability study determines that
the aeration technology is inadequate, then
Alternative 4 will be used as a backup remedy.
With the exception of the No Action, each
alternative will involve deed restrictions to
regulate on-site residences and future ground
water use along with ground water monitoring at
Boutwell Spring and any wells that may
be installed along the ground water path
between the Site and the spring. Effectiveness
of the selected remedy will be reevaluated
should contaminants in the spring or well rise
above acceptable concentrations.
Based upon current information, these
alternatives provide the best balance among the
nine criteria that EPA uses to evaluate
alternatives. The following section provides an
analysis of the alternatives under consideration
for the Howe Valley Landfill Site along with a
glossary of the nine evaluation criteria.
Page 8
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Attachment A - Page 9
ANALYSIS
Overall Protection of Human Health and the
Environment
All alternatives presented .in this document, with
the exception of the No Action alternative, are
protective of human health and the environment.
The No Action alternative will allow humans,
plants and/or animals to be exposed to
contaminantS through contact with on-site soil,
ground water, surface water, dust particles or
contaminantS released into the air. Alternatives
2 and 3 will prevent on-site exposure, however,
like Alternative I, they will not remove
contaminated soils from the Site therebyallowing
the possible off -site migration of contaminants
which could create an increased risk to human
health. Alternatives 4, 5 and 6 eliminate
exposure of humans, plants and/or animals to
on-site contaminants and control
contaminant concentrations from entering the
ground water.
Comoliance with Aoolicable or Relevant and
Aoorooriate Reauirements
Alternatives 4, 5, and 6 will comply with all
Federal applicable or relevant and appropriate
requirements (ARARs). Alternatives 1, 2, and 3
will allow contaminantS to remain on-site at
concentrations above acceptable levels which
violates Federal ARARs specified in the
Remedial Investigation report. However, under
Alternative 3 the contaminated soils will be
capped.
The Kentucky Natural Resources and
Environmental Protection Cabinet (KNREPC)
has identified KRS 224.877 as a State ARAR
and contends that KRS 224.877 requires cleanup
of the soil to naturally occurring background
levels. EPA and KNREPC have disputed the
interpretation and application of this
requirement at other NPL sites. Under the
KNREPC's interpretation of KRS 224.877, none
of the proposed Alternatives would meet this
standard. In contrast, however, EP A has
carefully considered all requirements of KRS
224.877 and is of the opinion that Alternative 4
and 5 do comply therewith. Should EP A and
the KNREPC not come to an understanding on
KRS 224.877, and should EPA select Alternative
4 or 5, or a combination thereof, as proposed, it
may be necessary to invoke a waiver under
Section 300.430(0 (1) (ii) (c) of the NCP.
Reduction of Toxicitv. Mobilitv. or Volume
Alternatives 4, 5, and 6 will result in a
significant reduc~ioD in the toxicity, mobili ty I
aDd volume of soll contamination by removing it
from the Site or by treating it on-site.
Indirectly, a reduction in the mobility of
contaminantS will occur for Alternative 3 due to
the landfill cap reducing the amount of rain
water filtering through the soils and/or flowing
off-site. Alternatives I and 2 will not prevent
or reduce the possibility of contaminants
migrating into the ground water, nor will they
reduce contaminant toxicity or mobility.
Lon2-term Effectiveness
Alternatives 4, 5 and 6 will provide the greatest
long-term effectiveness by removing and/or
treating the contaminated soils. Alternative 4 is
slightly less effective since the soils will not be
treated, but rather sent off-site to a RCRA
landfill. Alternative 3 has a lower long-term
effectiveness primarily due to the unreliable
nature of the karst terrain. Alternatives 1 and 2
provide the lowest long-term effectiveness.
Short-term Effectiveness
Alternatives I and 2 involve only a minimum
amount of construction that could increase the
short-term exposure risks for on-site workers,
nearby residentS or the surrounding
environment. Alternatives 3, 4, 5 and 6 may
produce dust from either the removal or
treatment activities, however, any risks will be
mitigated through implementation of a health
and safety plan. In addition, Alternatives 3, 4
and 6 will cause a temporary increase in truck
traffic through the nearby community. Under
Alternative S, on-site workers could be exposed
to volatilized contaminants. The prevention of
excess exposure through inhalation of or contact
with the organics will also be addressed in the
health and safety plan.
Alternative 3 provides the least short-term
effectiveness, since it will take the longest to
implement.
Imolementabilitv
The implementability of an alternative is based
on technical feasibility, administrative feasibility
and availability of services and materials. Each
of the discussed alternatives will require some
construction, such as the installation of
monitoring wells, security fences, drainage
collection systems, landfill caps or the
replacement of exc.avated soil.
Page 9
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Attachment A - ~age 10
Alternative 1 will be extremely difficult to
implement because of the karst conditions that
occur beneath the Site. To ensure that a
monitoring well actually intercepts a conduit
that contains ground water associated with the
. Site, additional dye-trace studies will be
required. Should a monitoring well be installed
in the wrong place, it will be removed and
relocated. This process may continue
indefinitely until all monitoring wells are
instal1ed in the proper- locatIons. Alternative 2
will be simple to implement. The only problem
may be in obtaining the necessary equipment
and materials.
Alternative 3 will require a substantial amount
of construction material, equipment and
manpower. Because the karst area presents
theopportunity for sinkholes to develop, the
structural integrity of the cap could be
compromised thereby reducing the effectiveness
of this alternative.
Part of the remedy for Alternative 5 wiU require
the construction of a soil drying and aeration
system. Once constructed, the process will be
simple to operate and maintain.
Alternative 5 will also require excavation
equipment, transport vehicles and suitable
backfill material. The same items will also be
needed for Alternatives 4 and 6. For such
remedies, the implementability will be limited
by the availability of these items and the ability
of the RCRA landfill and incinerator to accept
the soils.
~
The estimated present worth cost (PWC)
associated with Alternative 1 is S 215,000. The
estimated PWC of Alternative 2 is S 307,125.
Alternative 3's estimated PWC is S 839,400,
Alternative 4's PWC is S 3,821,400, Alternative
5's PWC is S 364.300. and Alternative 6's PWC is
S 19.001.800. The PWC's for Alternatives 4, 5
and 6 are based upon a contingency cost of 15%,
whereas the costs in the FS are based upon a
contingency of 10%. Therefore, the cost of
these three alternatives. as stated in the Proposed
Plan, are higher than their costs in the FS.
Since contaminants will remain on-site under
Alternatives 1. 2 and 3, their PWCs include 30
years of Operations &. Maintenance (O&M) with
a risk assessment conducted every five years.
The PWC of Alternatives 4, 5. and 6 include the
costs for implementing five years of O&M
which include deed restrictions and ground
water monitoring. The costs for the five years
of monitoring were not included in the FS. but
were calculated by EPA based upon information
in Appendix H of the FS. Also, Alternative 5 in
this fact sheet includes S 30,000 for the cost of
adding top soil to the Site. this was not factored
in the FS cost. Alternatives 4, 5, and 6 are
sensitive to changes in the volume of .
. contaminated soil to be handled. Consequently,
their capital cost could vary significantly once
the extent of soils to be removed or treated is
defined in the Remedial DesiKD (RD) phase.
State AcceDtance
The KNREPC has reviewed and supplied
comments to EPA regarding all reports and data
produced during the RI and FS. Based upon
their review of the selected alternatives, the
KNREPC does not believe that State ARARs, as
outlined in KRS 224.877, are being addressed.
Nor do they feel that the selected alternatives
are protective of human health and the
environment or satisfies the nine criteria for
remedy evaluation. The KNREPC prefers on-
site incineration of organic contaminated soils
and off-site disposal of inorganic contaminated
soils. EPA, however, has careful1y considered
all requirementS of KRS 224.877 and feels that
the preferred Alternatives 4 and 5 do comply
therewith. Additionally. EPA does not believe
that on-site incineration is the most cost
effective remedy and that the proposed
alternatives provide an equal level of protection
at less cost.
Community AcceDtance
Community acceptance of the various
alternatives will be evaluated during the public
comment period and will be described in the
Record of DecisioD (ROD) for the Site.
The Preferred Alternatives
The preferred alternative - Alternative 5 -
involves the removal and off -site disposal of the
outer area soils along with the remediation. by
aeration. of the central area soils. This
alternative also includes a 5-year ground water
monitoring program along with deed restrictions
to limit future Site usage. Alternative 4. which
will be implemented if the treatability study in
Alternative S indicates that aeration will be
ineffective, will involve the complete removal of
contaminated soils for off -site disposal in a
RCRA approved landfill along with off -site
ground water monitoring; Both Alternatives 4
and 5 will reduce contamination in the Site soils
to levels that will not present a'threat to human
health or the enviJ:9nment. Additionally, the
Page 10
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Attachment A - Page 11
estimated costs for these Alte.rnatives are
contingent upon the amount of soil removed or
treated. Ground- water associated with the Site
will be monitored on a routine basis. Should
contamination in either the on-site soils or the
ground water be detected above acceptable levels
and/or drinking water standards, then EP A will
reevaluate the effectiveness of the alternatives.
Summarv of Statutorv: Find}n2s
In summary, the preferred alternative represents
the best balance among the criteria used to
evaluate remedies. Based on the information
currently available, EPA has determined that the
preferred alternative will be protective of
human health and the environment, will attain
Federal ARARs, will be cost-effective and will
utilize permanent solutions employing
alternatives or resource recovery technologies to
the maximum extent practicable.
THE COMMUNrTY'S ROLE IN THE SELECTION
PROCESS
EP A solicits input from the community on the \
cleanup methods proposed for each Superfund
response action. EPA has set a public comment
period from July 26 through August 24, 1990 to
encourage public participation in the selection
process. The comment period includes a public
meeting at which EPA will present the RI/FS
Report and Proposed Plan, answer questions,
and l'eceive both oral and written comments.
The public meeting is scheduled for 7:30 p.m.,
August 2, 1990, and will be held at the Howe
Valley Elementary School, Hardinsburg Road,
Cecilia, Kentucky. Comments will be
summarized and responses provided in the
Responsiveness Summary section of the
Recordof Decision (ROD). The ROD is the
document that presents EP A 's final selection
for cleanup.
The public can send written comments to or
obtain information from:
Mary Jo Penick
Remedial Project Manager
U.S. EPA, Region 4
345 Courtland Street, N.£.
Atlanta, Georgia 30365
(404) 347-7791
EPA is soliciting public comments regarding the
most acceptable way to remediate the Howe
Valley Landfill Site. The Proposed Plan and the
RI/FS Report have been placed in the
Information Repository along with the
Administrative Record for the Site. The
Administrative Record includes all documents
such as work plans, data analysis, public
comments, transcripts, and other relevant
material used in developing the remedial
alternatives for the Howe Valley Landfill Site.
These documents are available for public review
and copying at the following location:
Hardin County Public Library
201 West Dixie Highway
Elizabethtown, Kentucky 42701
(502) 769-6337
Contact: Brenda Macy
TECHNICAL ASSISTANCE GRANTS
EPA is providing communities with the
opportunity to apply for Technical Assistance
Grants (TAGs). These grants of up to $50,000
(per site) are designed to enable community
groups to hire a technical advisor or consultant
to assist them in interpreting and commenting on
Site findings and the planned cleanup. There is
a limit of one TAG per site. Citizens who are
interested in the TAG program may obtain an
application package by calling or writing the
EP A TAG coordinator under the list of contacts.
UST OF CONTACTS
Mary Jo Penick
Remedial Project Manager
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-7791
Suzanne Durham
Community Relations Coordinator
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-7791
Carl Millanti
KNREPC
Division of Waste Management
Frankfort Office Park
18 Reilly Road
Frankfort, Kentucky 4060 I
(502) 564-6716
Denise Bland
Technical Assistance Grant Coordinator
345 Courtland Street, N.E:
U.S. EPA, Region IV
Atlanta, Georgia 30365
(404) 347-2334
Page II
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Attachment A - P~ge 12
GLOSSARY OF TECHNICAL
TERMS
GLOSSARY OF EVALUATION CRITERIA
Compliance with ARARs _: Addresses whether
or not a remedy will meet all applicable or
relevant and appropriate requirements of other
environmental statutes. and/or provide grounds
for invoking a waiver.
Community Acceptance -- Will be assessed in
the Record of Decision following a review of
the public comments received on the RI/FS
Report and the Proposed Plan.
Costs -- The price for implementing a remedy,
includes capital costs along with operation and
maintenance costs.
Implementability -- The technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement the chosen solution.
Long-term effectiveness -- The ability to
maintain reliable protection of human health and
the environment once cleanup goals have been
met.
Overall Protection of Human Health and the
Environment -- Addresses whether or not a
remedy provides adequate protection and
describes how risks are eliminated, reduced, or
regulated through treatment, engineering, or
institutional controls.
Reduction of toxicity, mobility, or volume --
The anticipated performance of the treatment
technologies a remedy may employ.
Short-term effectiveness -- The period of time
needed to achieve protection from any adverse
impacts on human health and the environment
that may be posed during the construction and
implementation period.
State Acceptance -- Indicates whether, based on
its review of the RI/FS and Proposed Plan, the
State concurs with, opposes, or has no comment
on the preferred alternative.
GLOSSARY
Administrative Order -- A legal document
signed by EPA directing an individual, business,
or other entity to perform specific tasks, take
corrective action or refrain from an activity.
Administrative Record -- A file containing all
the information used by the EPA to make its
decision on the selection of a remedial action
under CERCLA. This file is required to be
available for public review and a copy is to be
established at or near the site, usually at an
information repository. A duplicate file is
maintained in EPA's Region IV Library located
in Atlanta, Georgia. - .
Aeration -- A process which promotes the
breakdown of certain chemicals, primarily
organics, by exposing them or the material they
are contained in to air and possibly low levels of
heat.
Applicable or Relevant and Appropriate
Requirements (ARARs) -- Federal and State
requirements that an EPA selected remedy must
attain. For example: contaminants in a drinking
water supply must be below drinking water
standards as outlined in the Safe Drinking Water
Act.
Baseline Risk Assessment -- An evaluation of
the potential threat to human health and the
environment.
Carcinogen -- Any substance that produces
cancer.
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) --
A Federal law passed in 1980 and modified in
1986 by the Superfund Amendments and
Reauthorization Act. The Acts created a special
tax on petroleum imports. The money goes into
a special trust fund, commonly known as
Superfund, that is used to investigate and clean
up abandoned or uncontrolled hazardous waste
sites. Under the program, EPA can pay for site
cleanup when the responsible parties cannot be
located or are unwilling or unable to perform
the work. In such instances, EP A may take legal
action to force responsible parties to clean up
the site or reimburse EPA for the cost of
cleanup.
Dispersion -- A process by which chemicals are
broken up or scattered in different directions.
Dye-trace Study -- A test used to determine
ground water flow paths and/or to identify
point-to-point connections such as sinkholes,
sinking streams, springs or wells.
Ground Water -- Underground water that fills
pores in soils or openings in rocks to the point
of saturation. Unlike surface water,
groundwater cannO,( clean itself by exposure to
Page 12
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Attachment A - Page 13
sun or rapid aeration. Ground water is often
used as a source of drinking water via municipal
or domestic wells.
Hazard Index (HI) -- A number that is
calculated from data collected during sampling
activities. It indicates the risks that non-cancer
causing contaminants at a site pose to human
health and the environment. A value less than
1.0 indicates that very little risk is associated
with the site. .-
Hazardous Substances -- Any material that
poses a threat to pUblic health and/or the
environment. Typical hazardous substances are
materials that are toxic, corrosive, ignitable,
explosive or chemically active.
Hazard Rankinl System (HRS) -- The principle
screening tool used by EPA to evaluate risks to
public health and the environment associated
with abandoned or uncontrolled hazardous waste
sites. The HRS calculates a score based on the
potential of hazardous substances spreading from
the site through the air, surface water, or ground
water and on other factors such as nearby
population. This score is the primary factor in
deciding if the site should be on the National
Priorities List and, if so, what ranking it should
have compared to other sites on the list.
Incineration -- A treatment technology
involving destruction of waste by controlled
burning at high temperatures.
Information Repository -- A file containing
current information, technical reports and
reference documents regarding a Superfund NPL
site. The information repository is usually
located in a public building that is convenient
for local residents, such as a public school, city
hall, or a library. As the site proceeds through
the Superfund Remedial Process, the file at the
information repository is updated.
Inoreanic Chemicals -- Chemical substances of
mineral origin. Their structure is not based on
carbon.
Landfm - Disposal sites for hazardous wastes.
They are selected and designed to prevent the
release of hazardous substances into the
environment.
Monitorinl -- The continued collection of
information about the environment that helps
determine if a cleanup action is working
properly.
National Priorities List (NPL) -- EPA's list of
the most serious uncontrolled or abandoned
hazardous waste sites identified for possible
long-term remedial action under Superfund. A
site must be on the NPL to receive money from
the Superfund. The list is based primarily on
the score a site receives from the Hazard
Ranking System. EP A is required to update the
NPL at least once a year.
Orlanic Chemicals -- Any compound who's
structure is based on carbon.
Potential Contaminants of Concern --
Chemicals that are site-related and whose data
are sufficient quality for use in the quantitative
risk assessment
Potentially Responsible Parties (PRPs) --
An individual, a company or a group of
companies who may have contributed to the
hazardous conditions at a site. These parties
may be held liable for costs of the remedial
activities by the EPA through the CERCLA
laws.
Preliminary Assessment -- The process of
collecting and reviewing available information
about a known or suspected waste site or release.
Proposed Plan - - A fact sheet summarizing
EPA's preferred cleanup strategy for an NPL
site, the rationale for the preference and reviews
of the alternatives presented in the detailed
analysis of the Remedial Investigation/
Feasibility Study.
Record of Decision (ROD) -- A document
released to the public to explain which cleanup
alternative will be used at a NPL site and the
reasons for choosing that cleanup alternative
over other possibilities.
Reference Dose (RfD) -- The EPA's preferred
toxicity value for evaluating non-carcinogenic
effects resulting from exposures at Superfund
Sites.
Remedial Alternatives -- A list of the most
technologically feasible alternatives for a site
cleanup.
Remedial DesilD (RD) -- The remedial design is
a plan formulated by either the PRP and/or
EP A to provide the appropriate measures to
remediate a hazardous waste site.
Remedial IDYestieatioD/Feasibility Study --
Two separate but related studie~ normally
conducted at the same time. These studies are
Page 13
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Attachment A - Page 14
conducted to define the natur;~ and extent of
contamination at a site (part of the RI) and to
evaluate appropriate, site-specific remedies
necessary to achieve final cleanup at the site
(part of the FS).
Removal Action -- Short-term, immediate
actions taken to address releases of hazardous
substances. For exa~ple: the removal of drums
that contain hazardous chemicals; or the cleanup
of a gasoline spill on a highway.
Responsiveness Summary -- A summary of
verbal and/or written public comments received
by EPA during the public comment period.
Resource Conservation and Recovery Act
(RCRA) -- A Federal law that establishes a
regulatory system to track hazardous substances
from the time of generation to disposal. The
law requires safe and secure procedures to be
used in treating, transporting, storing, and
disposing of hazardous substances. RCRA is
designed to prevent new, uncontrolled hazardous
waste sites from forming.
Site Investigation -- The collection of
info.rmation from a Superfund site to determine
the extent and severity of hazards posed by the
site. It follows and is more extensive than a
Preliminary Assessment (PA). The purpose is to
gather information necessary to score the site
under the Hazardous Ranking System (HRS) and
to determine if the site presents an immediate
threat that may require a prompt removal actIon.
Solid Waste -- Non-liquid, non-soluble
materials ranging from municipal garbage to
industrial wastes that contain complex, and
sometimes hazardous, substances. Solid wastes
also include sewage sludge, agricultural refuse,
demolition wastes, and mining residues.
Superfund Amendments and Reauthorization
Act (SARA) -- Modifications to CERCLA
enacted on October 17. 1986.
Treatability Study -- Laboratory or field tests
designed to provide critical data needed to
evaluate and ultimately, to implement one or
more treatment technologies.
VolatilizatioD -- A process involving the passing
of an organic from its liquid phase into its gas
phase.
Page 14
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Attachment A - Page 15
~ ... ~-------------------------------------------------------------------------------------------------~
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: MAJUNG UST ADCmONS :
I I
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: If you want to be placed on the mailing list to receive information on the Howe Valley Landfill Site. :
: please fill out and mail this form to: :
. I I
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I I
I Mary Jo Penick :
: Remedial Project Manager :
: U.S. Environment(\1 Protection Agency :
I I
: Region IV :
: 345 Courtland Street. NE :
: Atlanta. GA 30365 :
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, I
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I I
I I
I Name :
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I Address I
I I
: Telephone :
, I
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: ~~~ :
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~-------------------------------------------------------------------------------------------------------~
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ATTACHMENT
..
B
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ATTENDEES HOWE VAllEY SUPERFUND SITE
PROPOSED PlAN PUBUC MEETING
AUGUST 2, 1990
Sheet 1 of 3
NAME ADDRESS W.O. BOX) CITY STATE ZIP REPRESENTING
Bartlett. Beverty 525 W. Broadway Louisville KY 40202 Louisville Courier -Journal
Boone,Ron P.O. Box 2087 Ellzabethtown KY 42701 WASE-FM
Cochran, Rachel 260 Peachtree Street, Suite 950 Atlanta GA 30303 PRC Environmental Management, Inc.
Coogle, Carroll W. 760 Hodgenville Road Ellzabethtown KY 42701 Dow Corning Corp.
Dalton, Glen D. Ellzabethtown KY 42701 Hardin County Judge
Dickerson, Brooke F. 345 Courtland Street, NE Atlanta GA 30365 U.S. EPA, Region 4
Dlckons, L.M. 306 Red Bud Drive Ellzabethtown KY
Goodman, Douglas A. Hardin County, District 7, Magistrate
Goodman, Raymond 300 Scott Goodman Lane Cecilia KY 42724
Green, Peggy S. 611 Foxflre Road Ellzabethtown KY 42701 Celotex Corp.
Gun. Larry
Haggard. Tammy P.O. Box 517 Ellzabethtown KY 42702 WQXE-FM
Hale, James Hardin County Rescue
Henderson, H. Michael 345 Courtland Street, NE Atlanta GA 30365 U.S. EPA, Region 4
Jones, Jennifer Dow Corning Corp.
Mclaughlin, Doug Hardin County Environmental Council
Mull, Donald S. "Woody. Louisville KY USGS
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AITENDEES HOWE VALl.rY SUPERFUND SITE
PROPOSED PLAN PUBUC MEETING
AUGUST 2, 1990
~
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Sheet 2 of 3
~
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NAME
Nickles, Jeanne
Ovsenlk, Edward C01242 Midland MI 48686-0994 Dow Corning Corp.
Penick, Mary Jo 345 Courtland Street, NE Atlanta GA 30365 U.S. EPA, Region 4
Pletrosewlcz, Chuck 345 Courtland Street, NE Atlanta GA 30365 ATSDR
Rosenbarker, Damen CPO 1514 Berea KY 40404
Ross, Jeff 303 East Wacker Drive, Suite 500 Chicago IL 60601 PRC Environmental Management, Inc.
Samsel, Gene Hatcher-Sayre, Inc.
SilVerstein, Evan 408 W. Dixie Avenue EJizabethtown KY 42701 News-Enterprise
Smith, Tom State Senate
Smith, Wayne P.O. Box 267 Elizabethtown KY 42702 B.I.C.S
Stewart, Jeff P.O. Box L Elizabethtown KY 42701 WIEL . WKMO Radio
.(
Sutherland, Mickey 125 Chnders Court EJizabethtown KY Hardin County landfill
Taytor, Harold W., Jr. 345 Courtland Street, NE Atlanta GA 30365 U.S. EPA, Region 4
Thomas, Randall Kentucky Div. Waste Management
Will, Woodrow W. 46 N. Sunset Avenue Ellzabethtown KY KY 86 Fire & Rescue
Williams, Bobby Hardin County, District 3, Magistrate
ADDRESS (P.O. BOX)
CITY
STATE
ZIP
REPRESENTING
-------
NAME'
Wischkaemper, Kay
Wise, Charles
ADDRESS (P.O. BOX)
345 Courtland Street, NE
P.O. Box 485
ATTENDEES HOWE VAU£Y SUPE;RRJND SITE
PROPOSED PLAN PUBUC MEETING
AUGUST 2, 1990
Sheet 2 of 3
CITY
STATE
GA
ZIP
30365
Atlanta
Ellzabethtown
KY
42702
>
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REPRESENTING
w
U.S. EPA, Region 4
,
District 8, Magistrate
-------
ATTACHMENT
C
-------
INFORMATION REPOSITOR'Y"
HARDIN COUNTY PUBLIC LIBRARY
201 West Dixie Highway
Elizabethtown, Kentucky 42701
(502) 769-6337
>
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ATTACHMENT
D
-------
Attachment D - P18P 1
l.
'3
PiJ; L IC t1EETIi:r;
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HOWE V~LLE.i
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L':"~;~FILL
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Priorities List Sit~
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23
Rowe
V~lj,.ey Ej,.~mentary
SC~.j\)Oj,.
24
H~rdinsville R08d
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t::entucky
-------
Attachment D - Pa
4
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2
_~rI'?Si"!'It;:lt:;(Jr>.<;
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-;
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In t. r C1 () 11 c; t i (I n
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?.=tCJF><;
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~E'lcomE' and Introduction of ?articip~nts
1.r~;.tina ~I.lrpo$E'
*
I<
S i 1 P ~ r fun (1 ? roc E' S s
Site $tf!~U~
03.nd Community ?~rt:i~ip~tion
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St~t~ Involvpment
~.03.n(ly ThoJT11'! '5
20-21
14
Dy;?-Tr~cE' St.udi;?s
woody Mull
21-26
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Environmental ?rotectiun
~1'?!,ri?'5",nt.ativ;?s
of ':3-';;;
Answ,::,r
19
20
tnos i ng
. . . . . . . . . .
H;:I r y ;; t)
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?o?nic:': ;:Inc:1
Hi"nderson
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23
24
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Attachment D - Page 3
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Coor<:'li n.=!. t or
EPAi
Comi711.m i t.y
Ri?L~tion~
...
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i(..:Inciy Th(J~'.:I!,;:
~ p !; 0 '.1 r (: E' !:; -=I 1'1 n
~~n~ucky ~~p.:lrt~pnt of N~tur;::;1.
Environm~nt~l Prot~c~ion C.=!hin~~
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C<)rpor~tion
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Chuck ?iE-tro~.:-wicz:
Dic;e~c;~ !(.~0istry
j:..0I-?ncy
for Toxic Substancpc;
"'In<.i
i. ;
;ro0~e Dick~r!:;0n:
E?;";
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ao .:;ver
that
in A. minute.
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h~~~c~al1y the three
purposE'S of the
a
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We
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will
sti'lnd up.
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wit:h th~ Co~monw~;::;lth
o f K r:- n t: 1.: ~ I< y ;
divisiop of
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O;::v~rvhndv
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And ::oony h"l5 1)~~n
with t.ill?'
,:jt thl'?
1-1 r? 1 pin a E r ;:..
11'pn 1 ,)r,v
- . - '--
site and rl?'vi~wina
the wor~ th~t's bel?'n done to
d-'\te.
And Woody h;::;s aot
a littl@ ~respntion
j'l e . 11 ~ ;::; I< e 1 ~ t e r
on -'\oout t.hat.
K.:IY wisr.h~;::;e~p~r, ~~y is
~~~ ;-~. ~~~~
-- ;::;aain,
th~ i<.~aional 4 of:icl'? in Atl~nt;::;,
",no sh~'c:;
with our Ground Water Technology Unit.
.:Iaain,
And,
she
is her~ to
J'TIight h~vr:-
ql1l?'s~ions you ;::;11
a)-,oq"'.
-'\ns..~r the
a -r 0 1.1 n d 101 ;::; t F? r 0 r
hel'?n don~
~i~~.
s t 1.1 d i ~ s t j', "'I t
i!.:ive
,:j t t:j"l;:>
LI:'1:.'s
who ",m ! leavina o~t
see,
~... .,
~., £..:ir.
!'Vp. aot
eVl:'rybndy hut Mich~el here.
Hich;::;;:>l
lienderson is wit.h our Comm1.1nity Relations
'?roara~"
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. - J. ~ !i .::t P. J. 1 $ $ O!'" '.,
of subst.itl.Jt.ina.
I t.hinl< ho?
101;::;5 up
hf'>r~
a fe~N Yl?'~rs ;::;an
!!1€"eting.
Bi.l i:. he's
whl?'n
W~ 11;::;0
anot.her
ho:>re to
havl?' '" little. prf:!spnt;::;tion anont
-- .::Inn hp'll
how t.r!~
~ -.1 P I?' r f q.n d an ri
~ O":'r.;.1l.E1 i ':" Y
~an be involved in
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:ninllte.
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If I could; r'll gn ov~r th~
4
~genn<'l
I hOpF -- Thf?re
r.ht:' w~y;
rr 1) i (' i< 1 y
r<':!<'Il
here.
By
s
sign
;::>veryone ~ignec
~ hopf?
in shl?'?t
up fron~.
!,,;"as ;:;..
;:,
i1'"\.
printed
n~!TIe
-- prinren it <'1'5
;nd I
hope you
YOIJ.r
i
legiblt? or
we
legibly ~s possibl~; bec~use
wrot,=. it ~s
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W CJ 1) ~
~;e h~vF> ~
here
court stenogr"r~er
to b~si('~]ly ~o~plete <'I
record
of t.he rr.e@tir!!J.
;'.nd wh.; t
we're
going to do -- ~s
... ..
you Wl.L.l
see from the ~genda
- t ~ ..
.L .!.-'-
gn over it
minute
-- O\.l.t we ~rl?
. .
gOl no '.0
in
. ..
.JUS. ~
s~ve
t 1"1 E' rr 1.1 o? !'; t i 0 T1. '5
to the l~st;
i f w € C «'.1 .." d .
,:;no ~nswers
~: -=- w1.!_"1
pr~sentation~ in
(.i:-~. t.o ~;.i(~ ()1]~
~.n 1-iOl.i r or
less.
And if we could;
when you do h~vl? questions; if
you could basically stand up or co~e forw~rd
so the
court st@nogr"l.pher c~n he~r you
~~d '5tatl?
"Ino s~e you;
ynur name.
?r@fer~bly/
th~ first question you
""~K; if
you could spell your
l~st n~me, we would appreciate it.
B.::tsic.::t.lly;
throl.1gh an
--~rod1.\ct.ion ~I1ci
:::'11 cr€'t.
!1 i c h ~ I? 1 in
-3 ~ i n :.1. ~. r;.
welcome;
to go over the co~~unity relations
tIe'll
talk
process.
about
Randy --
if you have any
State involv@!TI€'nt.
questions -- will b~
hl:'r@
t.o answer those.
;;~~lt.h
if V01.\'::
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~ss,=.ssment.;
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Attachment 0 - Page 9
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30,.
WE' will j '.1 S t
it tonight.
uno'\b~.;>
t (J m ~ !< e
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ffitv~ to
h~vl?
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try "Inei "In!;':wer
that
Bob rn"y
4
b~en o'\hle
to o'\nc;:w~!",
~ bit
lo'\ter on.
5
. ~.Joo~~y !-!1J::
!"!I") nv?y th~
..,. . - - . -- .
. . .
w:,,~.l.
Ei
~tl1ciies t1I.:1t
~ill an
,"7~: [ ~.('.; c;.
(;y,;,-tr.::lce
were d('ln~.
-
,
-'!ctivitii'?s.
?I?nic~ c;o
I'll h"tve
thE- sitl?
!r!~ry ,)'0
OV!?I-
,..
<:\
th~ propos Ad rem~dial ~lternatives.
;. n d t :1 E' !"! 'N ~
over
s
wil:
turn it over for qups~ions
h'\c;:ii::~lly
"tnd o'\nSW!?rc::; a~
till? enn.
Ag"tin,
there were a number of
h"tndouts at th~ f~o~t.
I hop*?
ever~"()nF:- c;ot 0'\
copy of
"t11 the h~ndouts..
~nd they do
1!~ ve ,=t ~opy C) 1: ~ 1!~
. . ..
rr.~ J 0'"( 11..Y
w;::.'~l
h'? lJS~'..:!0
of ~t ~-?3~t t.ht?
()\i~!"1-. .:.;:;::i.::;
tonight.
Yeah,
. ..
J I.1S '.,
ll?t me go over thAt
real hri~fly because
-- We've aot an overhead about the
. .. . ....
P 1.1 (\ .!. 1 C COin m t'> n '.
£')~rio(~?
;:'g;:dn,
we're holding a formal
;nn 5t started July 27th,
~.nd it's
.~a to last through AUg'ust. thi? 25t'r1.
~~_l of
YOI.1r
public CO!'!lTl1ents
will be sent to
~r wrjtten cornme~t$
~.! a r y
;;0 ?enick.
And I'd like to
~nd therl?'s
her address.
say,
E'ach of you should get a h~"dout,
is .:I
and th...re
Cc1PY
nf !1~ ry
tjo's
~dd.re~s nn those.h"tndouts.
~
-------
Attachment D - Pa e 10
LV
1:
~ '"
.L,c,
~ ~
2. ..i
- .
...
~5
1~
..,
L7
~ A
.!.."
~:I
2C1
..~
~..!..
22
23
'" .
,. ..
~r;
L
j 1.1 ~ t lJ C-, CJ V ~ r
rf?=;~
~ri~":.y
~Ie=-t m~
..
,c,
..!fht?r~
W~ ~r~.
A$ ;[01.1 -"Ili
!II':;Y Know,
$il~"'r fund W':;$
3
star7:d l~ L?3~ wh~n COn0r~$S
. . . .
1'Nr~l~:1 l~
!>;::tc;$f?c1 C:::~.c:~~-;
4
Compr~h~nsiv~ Environrn@nt~l R~~pons@:
Co~p~ns~tion ~nr.
r;
T,:""hi":itv
- -., - - - -.
~r:-:~r!"~~.
r ("')~. .., .J n . V
. . ...-.
;"ct;
~o ~~::; ~'~r>~r:1jnd.
h
T(; i $ ~ it:.;;
i ~
j 1.1 5 t (') n ~
. . .
.l.~!f;:;'
- .
.l. .J~
..
,
m~ntion~d to you.
'I'h~r~'s aOI).ut.
I) Ii ~ ;FJ. n d r i? (). " n 0
3
fift.y-eial"lt. ~l~~t"
~@0i("')n 4 .:!lon.::-.
on in
W.;; , r @ ',J () r !< i n 0
..
:5 i t ~ '5 i;t r'"? pi:" t. 0 n
th~ ~?L eith~r by th~ ~tate's aoincr 0:~~
and invi?stig~t~~g
Mnd ~ollr:-cting n~t,:;
;:; r~ c~ ~ -(" (; v i (; i n 0
t.l~1 A t
data to E?:",
or E?A goes out or E?A
and its contr~ctor5
go out
and aS$~SS
an inv~ntory of pot~ntially
h.:!'Z~rdou$
W<'lst~ sit;:,s.
7~-1~::. an f:l1r01.10(i W~1':' t.' 5
c ~ 1 1 ,;. ~~ ~ T'.
'.8IIio.
r.. r LJ
ranking5 prOC~5~
that':::;
wh~r~ oasic~lLY t~w d<'lt,:;
g"'l t11~r@ci
is used
h~z"'lrc;ous
r,:;ni:0 i..T ,:; t ion ~ :
thos~ that.
Itioriti@s List.
T1)~ Rowe VRlley ~ite
jus:-:
()!"! r?-
is
of thos~ sit.~s;
on~ of
seVi?~t.~~!"!
in i\~t1t1Jcky.
Aft..;r ~ sit.~
....~. -
I~. .1~
go~s on th~
i~?L ;
first ph<'ls~ o~ E?;'s
th~ R~m~dial
involv~rnE-nt is
~nv",stig~t.ion --
11. blor.k four
which
is tili?
t. ~1 err? ;
9
-------
.
---- ""~-
nLCa.'-dillc::rl~ I.J - ~~~c: l.L.
I
-
2
)
4
.s
,.
<:I
7
8
9
. ~
~ ~.'
.. ..
.1..1.
12
13
14
15
16
. ...
.1. I
i.8
.. ....
.1. :I
.......
~\)
.....
Gl.
22
23
.... .
G~
~';
l
I
F~.:I<::ibi:it.y
- .....
.l.n I_.n:i.~
.L '.
St.udy.
!,.::i r t i ~ 1.11 "" r
(,~~i" -- Ani"1
can go
eit.hf?r
nn~ of two w~y~.
E?~ (':~rl
!1otl:':l
-. ~.
c!. ...:1~r
''':~tiit?
'?ot.ent.i",,:i.1y ?,p.C::;f\oTl..ib1,.,. ?.:Irti",a; w!tO eithpr
s and
no the ?.f"o!TIi?d i "'11
I!"!vt?~tifj;;t: :)r"!
and Fi?a~ibi1ity Stu~y.
~nd t.hey
~an (,O!T11? fort-), .:;.!on
..i'J!1
a C ,)1", c;: e n t
~0rpe!TIl?nt with E?~ .:Ind do
--.. . -
!::r .-. ~
th~ wor~ wit.h
oversiGht.
..... -...... . . . '-
I., r ~ r:- l'\ (' .::! n n 1 r I'! 1 '., sow n
contr.:l~to~ A~~ aG
nut
~ £1 n ,; (j t. h p:a
itself.
s t 'J0.Y
Now,
in t.hi!'; parti~I.~.ar ~al'e;
~.
'., !le
Ho~;:> 7alley si~~;
of PRPs did ~ome forward,
s i. 0-;;
a ~rol\p
.;
~on~r?r!t"
.;bo:.lt
~~-! ~ t. ~
t~o ye~~5 ~go wi~l)
;;Gree!TIt;nt
EF.~ .
;;'Ja(~~~;;.:"}~
~).=;~.i.r:;:;~-~y
t hi? S t :.10 y
. '"
SF\~~~
t.::~t
t.hey '11 do
a~~orijinG
t.0 E?~ st.and.::ird operating pro~eeds
ann th"tt.
they will
do it with E?~'s oversight.
Basic"tlly,
thEy'll do it in
1 i f?1) 0 f E? A
doinG the
study.
;'.nd
th;;t'!'; basici'\lly
at thf? sitp.
wh"'t's heF,n
done
t.;~ ~e~
blod< nU!T!b!?r
~ as public comm!?~t,
~nd that.'s whi?re WI?
are tonight.
Wt?'ve
sent. -- I ho!,!? i'\l~
o ~ y r".j
hav!?
rec!?iven
1.t thrnugh
pi~I
the altern.::itiv~s t.h~t
. '"
~ .1
-------
Attachment D - Page 12
.
...
F'e;;l5 i'bi :i. i. ty
S t 1] c-; y
~nn i~'~ pr~pns~d
,'?I s-?l~~tio~
~f ~n"?
...
G
of th\)~~ ~l~~~n~~iv~~.
Th~t'~
wh"'lt
w ~ r ;:t ~ '";. t. :-1 .:-
prnpnSF"n
...
)
pl""!2'
Ti!-?lt'~ b~F?I1 ~t?nt out.
t Q ~;.~.
of Y~t1
~~l.
~ !'1 (~ t h I?
4
purp~s@ we ~re he~e tonicrht is to.
~g~in,
~~ over wh~t
c;
''';;;1 S don~
-- 7.1.,", Ro?~edi.;l: :nv@c;:~:..:~':i('Jn "n(~ Ft'?,:;si1;:.l:.~::'
,:;
s ~ 1:.\iy
aron .,r,~-";I'>r ~TiV CTlIF-c:::;t.i C'\T,\" 'nll havl'>.
. - -- - - - -. ." - - . -' . - .
"'lT10 t-t1,::.n. tn
..
,
st03.rt
t.ho? proc€'s<; ~f
soliciting y~u~ co~~ents.
8
Once
we h~ve cr~tt~n your
:1
c~JT1:nent":s.
we' ~:
r i? v:i ":' '';
~- (I 11 r
r..,)!'T'mi?n t.s
-"crai!'lst tho?
. ....
.l \)
propns;:.d p:i.~n th"t's in that h~ndout
or f;::,ct
sheet
we've
11
given
you.
w,?'ll
t"i?spond;
in ~t.ht?r
w~rns, we'Ll. ~nswer
12
or ~ddress
~ll of
your
concerns.
~nci..
if n.::>edr?d,
w~'ll
. ..
.I. .'
~ ~~ ;:; fl a ~ t :: ! ~
rt?Tj\~c1Y
t.1'J~ t
Wi-"V@ selt?cti?d.
~nd t.h.=-n.
t11P
. .
.L~
. ~ ... ~ -
r~0.1.ona~ ;;IO~lnlScr"'l,Or
at. t.~lf? rpai,.,n~l
office
. , .
~..J 1 .L ...!.
..; (,H'!
- ---
1'5
W!1-"t.'s C.::lll~d a
record decision.
16
TIle p1lblic
comment perion i.. for
....
... I
thirty days.
so t.ilerr? won't. be
~ny dr?cision rnan~
.. . ,
1.1n '.,~.I.
. ..
.I. .~
we h~v~ receiv~d your
com~@nts.
19
;;fter that
the cleanup plan or
~o
desi~n
will
bt?gin.
;;gain. I'd li~i?
to tell you that
21
before
that
corn;T'l';:1"}c~s
t":ht:"rl? wil.l.
bl? an<)thf"or
set of
22
not.ices
letters Goirig out to the
Pot~ntially Responsiblt?
2.3
Parties
-- t.he generaters,
transporto'?-rs,
owners o~
24
orr?rators -- criving them the opportunity to cos~ in ~nd
- -
!!,. ")
do th~ remedial desicrn and remedi"'ll
act. inn' w 0 r '"
II ;-!~,.:> r
. .
1. .:.
-------
Attachment D - Pa e 13
. ,..
~ '.'
. .
.1..1.
. ...
.1. -',
1)
. .
, -
1:;
~6
. -
.1. I
. ...
.1. 1-,
19
.......
~ \)
~1
......
<..~
G3
... .
-'.-
2'5
.
,
E?-~' s (~..~v.;.rs~.(.:.(~:-..
.- -
.. ~ C M n CJ t? '.
...
t"
it you i.i~,:..
.":'£
-.. .
~I.';' '. .-
b;;,sic;;,:i.:i.~' ,
.)
sixt.y-d~y
p~rior1
to ~ake ~ good faith off~r
-J:
..Ll..
4
t.hey don't.,
wi:l
then E?~
c:
..'
cOhtr.:rctors
() -r t.~ ~ ~ 0 t. i"i e r
111to
~ littl~ ~O~~ ~~~~i~
thE! PR?s w'~:'i. be
aivp?n ~
t.o E?~..
go ~he;;,d ;;,nd hire
tr.~ir
e!1forci?::\er..t.
-J:
.1. -
~ 1~~::"
~e '" c;; 1.1 res.
,.
n
'-.o:I~e '" gOO<1
f~1t~ o~~~~ i~ ~j~ty n~y~.-
. . .
TJlil ~.:.
t t-.'=-T} ~,,~ r t=-
7
b~ annth~r ~ixty-d~y p~riod tn ~ctually
negot:ia.te 03
,..
"
dd~ral
reCOl.1p our
again~t
rnor,,,,:!
- . . .
~ ;::; r '.. :L ~ S .1. n
a c::01.lr~ of
l;::;w.
.8tual
design W()ri<
will st.art
Will COT!!!T!F.-nce.
.A n (1 ;;, f t. e r
be sorn~ ~ort of
go out and hire our own
~oney ;;,nd then basically
t.ho~e
?oto:>ntially Ro?~pnnsible
So,
after all of t.h;;,t occ1trs t.ho:>
and the remE'diaL ar.tion
the clean up work
therE' wil:
l. 0 n g -.t e r m In 0 nit. 0 r i n g 0 f
t.hE' ~i to'? to m~.kE'
sure the remo:>dial
~ction wa~ efficient..
.{ () 11 . 11 n (".. t e "'; ~ a r ~
Th;;,t's basicall:! wh",re we
;;, ',~ ~ .
bo3Sic;:\l::'~' on
.c .
l.J.VE'.
;:"nd ,...",' "v-';' got
. ...
.1.':'
-------
Attachment D - Pa e 14
. '"
~ '.I
. .
J.. .L
12
13
. .
. ..
15
16
17
13
19
.?'O
. 21
22
2.3
24
25
;; 00 \) t '. ;,;:j :. f
of th~
~
~
. -
'~':
'--
3
..~ \1 P I?;}" f 1J n d :
: "'1m
.
..
sh!? will
ao ov,",r a
:1
YCI.:. .
Ei
-
,
8
!1"'1ro'Ld sAid, m::-
:I
? l C) j ;:. (t !.T"'I n .:; a I? r
sort. of
~iVI?
this point toniaht.
riaht
!,r(',c.:ac:;~ to iJn.
~: i ~. r! t h ~ t.
hrief intro~\.)~ti0n
o~
00ing
t 0 ~ ~J r nit
o v t? r t 0 ~.~ ,; r y I) 0 :
'Inr.
lit.tle bit
of thl? sitl? history for
HS.
Th.:>ni<
;:-.'5
?E7~:::Ci\: :
Y01i, F..:;rold.
I1affi!?
i 5 ~'! ;:t r y
;;nn :! .:~ t~.::-
... - ...
'.11" ,.. en J. C 1\ ,
for til~
V.:illi?Y
L.:iT1l'ifil~ Site:-.
!iOAi~
tlh.:; ~ =
wO'.1'l.n
likl? to do is just
~'ou .:i
~ "
r!?"'I.I. I'!U1C::K
of how WI? got to
synopsis
1: .::tm not
aoina to CJIi
int.o rlt?tail$
nc:.w .;!n1Jt t"l? Re!1'\,:.l'ii~l !nvestig;;tion.
But" l;:;~.;r nn
~ood~-
i1u 11
frG0
contr;;c::tor
will
activitii?S
t:h,;( t.
..-,.. -
'.' ~.., \.'9 ..,
~r!''i :7.:..~f
(-) \J ~ Y" ~ ::. <: ~~ ~
~.o~c; fro0 t";-.~
give. you
'iT-or!?
de.tails about the:-
took pl.::tcl? duri"cr thosi?
prOCI?SSi?C:: .
For ti-,osi? of Y01.1
who don't know
C.::tn everyo"~ s~e th"'lt?
or .;!r~"'t f.::tmiliar --
glare.
Th!? How!?
aJUt 0 f
~O]'l\ Di.\v;;l
south of
7 h;:;.vi? .::t
Vall!?y ~andfill Site is loc::at!?d ~t th!?
L~nl?,
whi~h is a~proxi~.::ttl?ly 1.4 m~:e~
-~ .
.I. '.. lS
~n ~li?ven-~crl? si~~:
St.ate Highway ~.;.
which at. thi~ time is v~ry spars!? r!?sidl?ntial ar!?;;.
Beginning in
1967 ~nd running
indust.rial
l.mtil1976,
thl? sit!? w;;s used as an
j,;:;ndfi.ll.
wastl?
tirt:' it
1.lno~>:,
.:i 5t~tr?
op~rate.d
And .::tt. that
. ,
I .'
-------
Attachment D - Pa
.L
,..
,t,
J
4
5
h
i
,..
"
i:j
:~
11
12
.:..
. .
..
..~. :;
. ~
.l.n
. ..
.L I
18
13
20
....
~. .t
.....,
"''''
...~
~.)
~.;
25
.. . .. .
~ I) ..I. .L " .,w.::t c::; o. i?
rJr?r~ it.
;r:><]in;;in0
in t"h~
r:-.::tr:;;'
.. - "",... I
~~n\l ~
un~-r r! -=--~':>""'_. .._,,~~..~
- '.t ~ .; .. - ~ t.o . .- ':1 ~ t" ':". 1 C 4. ~ I.- r:: ;
th~ State of ~~ntu~ky b~a~n
inv~st:.i r I? n t £1 ;; t.
t".1 ~ ~ ~.
.. .
'..';';1~ ~ro
A5t.im.::;t,=", two
t.:~-rr? Nt:!'.r~ ;::. ~
thou5~nd to five thous~nd drums
cont~ininG w~ste at the
. ..
S:i. '..p.
U[J('}!1 t.1-!~ pot.~T!t.i.~lly t.ilreat.
o.:;seo
t". L i'I t".
1:'. 11 t? ~ e
dru!:"oc; h~d of
r.c::nt;:;!n~iH\t ing
t~~:!
n ~ t-: i (~ ~ ,;
r:-,~ ~nvir('l~:"r~nt "
t.() r.~n~ i~. or.
t 1-1 ~ ?= ~ f: i (") rt ~ ~.
;:,. ~ c:: ~ ~ ~ ~
'?!'l()riti.~s
.' ..
~ 1:; I. .
5it~ i'lct.ua:~y
that :'ist
j n ,j' \J 3. y . n f
~~~;.
went
e . ~
!.~n~.i. on
Once it went fini'll on
that. list
~t wag ;:.~igible for
a Federal
fundina to conduct
either
f.urther invl?st.igi'ltions,
or t. 1"1 e r "=' to; a $ t ~ ! e n r> P 0 r h.l n i :: 7,;' to
allow the Potentially
Responsibl& rarti~5 to fund t"h~
kyestia;:;tions.
~;h ~ t
W~ did is WI? sent out:. notific~tion
~e~ters to all th~ ?o~Antii'llly
?artio?5.
;:'.Y1~
~~5ponsihi.p
;:;fter
th~ part.ies ;:;grt?t?d t~ <]0
thl? neaotia~iohs,
two of
ahead ~nd
~~~edial Inv~5~iga~ion
fund;'! r/?-TI1ov;:;J.
and a
F't?asibi:'ity
S t '.1 0 Y .
... ~
""!t;::ll..
they nin
hiren ;;
is
t. h r!y
. .
.1.~
-------
Attachment D - Pa e 16
. ..
'- \J
.'. J.
12
i 3
:4
:5
. ,.
.L"
. ..
J.'
18
. '"
. .L::1
- '"
.~\.J
-.
. ~!..
--
~t!,
23
2';
- ~
~:')
c:: ("I '11". r ~.(~ t. n !
.. .
I. \J (').,-,
rh~ wnr~ for th~~:
-
...
their
~r.tiviti;:.s -3nd
t11~n ~ost r~(:nv~r
,.,' - - -
'. I:'. '-:-1"':'"
:...to OVi?rSi?t;>
..
eXDi?T'lS;::S.
. -
4
t.he sr.:ig~
So,
5
y;;'.,. , \;.?
wastE'S
h;:;v~
:-.;:>1?n rE'rT\()vi?~.
7~ ~ ::" ".-.::- ~ r-?
0ottr?n -- t1"iF?
h
r~Y'110V;::r'I
in 198~.
;'nc1 now 'N;::' re 03 t
~n,i -:::?:. '.i::;~.: ~!i~;'-~:_:'i0
W.:?'ri? .;.t
riO'," :;.!';
t. ~1 ~ P (J 1. n t.
~.Ai~~~'<"~ ~;;.
7
finish!?cl t.h.:-
~~~~dial !nvesti0a~ion ~n~ ~h~
ha"'i?
..
.,
Fp?a~i1-lilit~.
Qi'!t..:i .:iD(')1Jt. ;.;h~t
S (. :J (: Y ;
r..:\V~
9
t !--! e c; ~- t p ;
~n~ WP'Vi? i?Valuo3tprl sevpr~l
i~ r.;.r.~in'"Ln0 -?t!-
alt;:>r~~~iv~~ f0~
rp:r.pr'li::ttina t.it'"'"
. ..
S 1. '. ~ .
Anc~ then 1~ter on tonia1~~ !':l
prpspnt tho~!? alt~rnativ!?s
and thpn pr!?sF?nt E?;'s
prE'fF?rrF?o ~ltE'rni'!tive.
{oih.:it I
woulrl :i.i"'~
t.n 00 ~\~""J
:.. \,n
. -.
~_!.!~,;(j ~nci ti.1rr..
~ i 1 f? f j. (') l' r
(lv,:,r
1:. (I ~.. L (' 11 ~. ~ :
.:::r, r.oo?
can tal'o<
C0TT1)'n1.1ni ty
rE'lations.
~ D011 t
~.!~. .
nE~~DE~.SOi; :
back
a lit.t.lf?
becausF? if :::
furt.her,
~hey
SE'i? in/? <)Vf:or
hE'rE'.
50 I'm
can't.
everybooy -- wh~rp I
F?verybody.
('an 8E'!?
!i ~ f'. (": - ~: ~ () r-~
I . m ('J (') in,";
.. -' -
to st:~nci
st."\nd over
this w.:,y;
!Joina
to try
tr. 0;:>t
On!? of
t.hF? thina~ I would
1 i"'.;:. t ()
.. ~.. .
'., f? .!..!. yo 1.1 1. S
I thini<
t.he handout. has a grE'en COVE'r.
:f
Y01l havE'
a probj,~:n
. ..'
Wll..f1
t.he slic:i~8,
copi;::-s or
~ . ~
SJ..L\J~
usina --
~"'ch
w~tr~
t.hose should be
is in
t~l1 P? h ~ rl ~ \-:' : l ~
! 15
-------
Attachment D - Page 17
.
L
';N ~ t :1
tl1r:-- 4Jr~~n.
cOV~'t' .
Ann. ;
~IJ",,-in;
f0!'" sor~ 0E :In:1
T,.;~(j
2
carne in
lat.r:-; i,)~C;;l;.S....
iNFo ':;Yr:' usinlJ
t l! ~ r () I i .~- 7"
?";'!ir.r7r?~ --
~
.)
p~rticu:'~rly
i f Y (J I) ;; r '='
~itt.i~
. -. -.. - -."
~o th~ fr~nt w~~r~
thf'? Court:
Report~r Ci't!i
~
<:I
s,:~ you "Inn
~~tu~l:y tte~r your
,!1JE'stion;
whr:'n c::.)'r:'
r: C);=> s
'7
..
1... .
t.nd the fir~t
t i pI~ Y01.1
do it;
ple;\sE';
. .
~pr:-~~
yo;!r
R
:.:;~t n~me f,')r ~J~r.
9
7he r~8son we use
"I Co 1.1 r t R ern!," t e !'
.1.\1
is
t.r!... l~w
req1):' re s
8t thi~ p;;rticular
~nd of our public
. .
.1....
cO!T\;7",ent perio~
that. w~
do wh~t
is c::~lled ~
12
r,::osponsivE'ni?ss
su;';'!rnary.
;:'.nd wh;;t
it is --
it does --
. ~
-'- .J
nne p.:;.rt
,J: .:.
0.. J.'..
is what
w,=,nt.
OD at this mE'~tin0;
th~
. .
.l~
r () Tn 7ii r:- n t s
you !'1~dr:';
;;nd it .:;.:'so
i'i~~ to irlr::':jd~ ~'!(J:"i .N~
. ~
!..:)
r€'sponded to
yn1.lr comments.
And to ,:;ccuri'tt@ly lJ~t this;
1Fi
we h~ve to
have tht? correct.
inform~tion f!"orn
t :1 e Co 1.1 r t
17
"R.E'porter.
4 ...
.1.0
j:.nd;
ag;:;in;
as I s.,i<1;
;ro,y n.=.rne is
1~
Michael nenderson;
~nd I wor~ with Community R~lations.
20
7h.=> b.:isic
i<;ea
of COmm1.1!1 i ty
....
"...
KeIatlons with
5up.=>rfund ;;nd EPA
is a
t.wo-fold
procE'ss.
22
It's an idea of
us ntinging
information
to you
to ~~t
~3
you know what.'s
g'oinlJ on at
;:;. haz~rdous
wast~ sitE! in
... .
.(.~
yo ':l r
are~.
~nd it's ~lso tht? ide~ of you providinlJ us
"'~
e.: .J
with
your infor~;:;.tion.
.. ~
~t'"
-------
Attachment D - Page 18
--. ~.
r:.:r/"'\ ~:':'
~ r~ t.iJt?r
s:n~:'~
.:!c:J~!i\-:Y ;:;n(~
..,
t!,
P 0"1 r t: i c 1.11 0"1 r 1. y ;
f t) r ~ :' ~ TT". P ~ ~ :
in 01.1r
r~
wl!~~ W~
~;:;:~ ;:;
Co~:nuni~y Rel-"\tions
?l;:\!1
,:-'"r .;
. .
'. ":-
c::; ~ y;:; ~ ;:;'~"J
. . - . . .--
.:1 ~ t 0 1!o~
VOll'rF>
- .. -.
goi!'1~
7h~t
16
you're doing,
17
You
-------
Attachment D - Page 19
4
Wf?J....Li
IJ. '.n
p;o.npl.;.
liv~
in t~r?
- -
.)
c:ommlJ nit y ,
t :-11"' ~,.
r:'<'Ir! provid,;.
. ...,
1.1 S w 1 "_.! 1
t.llic;
typ~ of
4
infor!!l;:;tion.
:;
,it? develop <'I.
pl<'l!1
i'lnd TNe r:-::' ":n
n
i 11 (~ ~- 1 ; d ~
;n
tho:;:. ,.. ~ ;~: i;' .:I. C1 S
~nd ii~t.hoo~
nf how
Wf"o i:'Ire
a.~.._r..:
7
to keep ynl.l
informed.
,ie 1I5r? fi:'lct
~1.!t?~t s
51.1("'\ '"IS t;,,.:.
...
':'>
Orno()!';,:.r; oian
. - .- - ... - - . -.
hf'or~.
t; p? 1.\ S Eo P II. b 1 i c
m€-F:.t:!1a~
~ ~.i. en;;. ~
9
.... .
'-.11 1.5.
wi r? 1) 5 i"'
prl':'ss
rl':'le<'l51':'5,
neW5p~p;::>r
"'I.nn pl1hlic
- ...
.l. ':
notic;::>s.
.- . . ~ ... ~ . - .
~~ no'\ve "'I.V"'l.1~aC1~1~y ~e5S10ns
sometimE'S.
ft.:-
, 4
-...
may set up in
a libr"'l.ry or somet.hing and say, you can
12
coml':' o'\nd talk
to. us on I':'
on on!?,
likE',
from four to eiaht
4 ...
f. ....'
in til~ .=.ft,:;.rnoon or
50rr.ethina
~ . . ~".
.L 1 J< e . ,-! 1 S .
~'l t? ! '1 ~ V ~ 1j $ r:- (1
. .
..!..~
infor~~l m~~tin05 of visiting
grnups
ir! rhEoir homE-'; ,
4 ..
.I.')
just. on a 1nC<'I1 cnmmunity bi'lsis.
,;e ~ncn1J.r<'l0';'
penple to
16
write
us or to c"'l.1l us.
Tn"'l.t's
whi:'lt
your tax money is
17
for.
Tl!at' s wlH~t' s
p<'lyina ~y g~1ary.
Tip" t. and thf?
4 ,.
~ r.
ot.hE-r
fa~t of expl~i~ina t~~ way 5tlp~rfund work~; whi~h
:9
is a sp.lf-rr.-p1enisl1ina fund -- that eight.y-s>:!ven p~r<:r:>nt
2Ci
.~
.,-\(;)
of thf? mon!?y in Superfund co~!?s from th!? tax on
"4
~.:.
c:ffernical
manllfact.1Jr~rg.
~ no t 1.tt=. r
t.hirteen p~rc~nt.
(~ ;1~)
22
comp.$
from t.he af?neral
fl.mo,
23
Onp. of t.h~ interestina thinas
... .
G-
that h~s b~!?n done with t.hE' Sup;::>rfund
!lroar~m
is in
~5
1.9~6, wh~n
::;iip':;' r [1.md W;:j s
ri?authorizen
thp.r;;,.w;:j5 a
4 ,.
..!.. I'
-------
Attachment D - Pa
20
J.
prooi. ;:;'";71
c:'!':;",'-A:opt?n
~ri~lec:l
tIlE? 7~g (';r~nt or "'!'r?~i.r:':t("~I~
2
Assist.<'\nr:,",
~..-
Gr<'\n::~.
wh~t
t 1-~ i s
dO~5 is ~~low th~
:;
cO!T\!T\!lnity
to t.031
-------
Attachment D - Pa e 21
~ ...
~ '1
~ ~
...J.
12
~3
~ .
. -
~ ~
.!..,
16
~ -
.J.. I
~ ...
J.. .~
~ ...
~='
......
.6 ./
....
~l.
22
23
~4
...~
~. :')
~
,
~p:.,r(-Jv~n
it. (;t?ve~opr?~ it
r~-::-~,4y ~Jl(1
...
~
specific~ti.')r.$
1")"0.1 t:. c;
.=i n ,i .::I t~ t U ~ ~ :: y
.:...~---
-'
.1:oI"TE-ther.
- -
j n ti?r"':",c; ()f
th.:: wbol~ thin:
.
":!
rt lot
of thi~ infor~~t:i()~
i c; ::1-, 0=- :-.
5
..J~ .~- t ~,; ~
~ ~
C.::tJ..- ou:-
i;"\ f (',rrn"'l t i O!'l
repo:;.l.~ory:
i .~
,
n
n;:;si~~:tly
anot'b~!"
:-.1"! i rltJ WE-
1) e; e .
It's
i
y\)i.i r ~()!'!"rr.11 nit y
w!-J;;-rE- e;"'Irnpl;:.
ri?sliltc;,
8
Reme~i,::jl Invec;tig~tion,
~ll
pl.=iI1,
...
~
~"?~~r~l:y
':'n ~
:.ibr~ry.
~oc~~
p 1 ~ C E- (~
aciministr-"ltiv;;.
rpcorci ie;
thE-reo
~c1rninie;tr~tivi?
. ..
J.e; '.0
e;how you
r!?cord
the c1ecie;ions
t11.:1t Wi?re "''''Ide,
-"In~ on
W£-1:1-:-h
~- ~ ('j(~;:; t.i<)r"t. w':t ~~) i ~
c()piE-c;
of thr?-
'A<"'r'r.
t.1-! i sir. f c ~!!1'; t i (" i'\.
:~ <;
~j!~-t ;:,r'
Tho=- idea
(', :: 7 r1 ~
step by
step
on .::Ill
t0~ s1':rt?ngt:"!
e;upplil?d,
;n ~ k e 0 '.I r
~ . ~ .. . .
...~n~J. o.;;.('~c;~n;"\.
71- :. ~
~ () h E- ~ ~ i.~ ~
e;hoi11d be
in y(")ur
:oc~:
3.ibr,;ry
~O~;1tr?O
id;:.~
YOi) from h"'lving
to not "'I1w<'lye;
. ..
~s 1..0
k':>F-O
. . ..
write 1.1S for
her-=-,
.::'.nn
~~-7
c;:;::
us n!,
ti"le in f orm~ t ion.
~t shou1~ b~ ~v.:lil-"lb1~
"'I1c;0 in your
10c"'l1
'..
cornmunl'Y.
..... .
.LnlS J..e;
Co~munity Rel~t:ione;
in .,
qui ck nu tsi1E' 11.
! will b~ around if you h~ve any
!!IIt.1es t ions dl.1r i ng
the
-------
Attachment D - Page 22
.
J.
h~ T.J.l.x'l
t;:;:~
t () yon
~ t,C i j t. t ~ F.- ~ t" a ~ ~ .
?
.~
~.r~.. 7nv~.!j;S:
B;:;sic.:llly,
$t:at:'?
4
involVf?!'TIl?nt
in .::!.
~~m~ni~l I~v~stia~tion ~nd ?~~~ibility
5
5 t tHl Y
c~:..l~
for .:I St;:;tf?
CERrL~ st~ff provi0i~a
tec!1ni<:"'9:
,
n
r~vi~w Mnd cO~!'TI~nt
on M.
~~m~di~l 7nv~~t~0~ti0~ ~n~
7
Fo'?~sibility Study.
And ~lso
I.lnner CERi.L~.,
j-' -
,11.,.
8
p ~ ~ ~ i r-: '.i :. ;;\ r ~ t.;; ~ e
s h :) ;.1 : (~
~nd is requirf?d to
sh.::!.rl';- i~ ::;,~'.!
:;
~nnet~ry expf?nditur~s,
if !ii?Cf?SS.:lry.
B;;sicrllly:
th~t's
. ~
.l. II
... . .. .. ....
Lc 1n a nu~sn~CL.
il
1~
THE CHAIF.!1AH:
Woody,
I all~SS
l.3
i ~. . s
~~!r.e f.~r ::~on.
tn ~;:jl~ ~bout th~
dye-tr~CE- st1.1~Y.
. .
.;.. ..
On~ tiling t.!Jo'\t
WI;; miaht fI('d:"~t QI)t,
1.5
th~ inform~tlon rl?pository th~t Michaf?l mention~d is th~
16
H~rdin C01Jnty Public Libr;:;ry,
which is on
201 wt?st ulxi~
17
r11 IJ h w ;:j Y 1. r,
E~iz~b~thtown.
It. consists of
about
~li?ve!1
18
\J 0 1 ;.1 !To e s ,
I a1.l~SS,
l"1,nw i1"l ;r;;tt?rial.
And it's
in .:;
. ...
.!.:1
binder.
Writ,=, t(')
tho'? lib~.:;ry; who
will
show
you whl?r~
20
at. is.
Tf any of you w~nt to go and look ~t thf?
.21
reports,
the corrf?sponnence,
t?t cF.'tera,
it's
in th~
22
n~r0in County Libr.:lry.
~3
24
HR. !.mLL:
}:'~.l ~ n k
'lOll,
ii" r 0 1,; .
;''5
25
i1~
o;"id,
mv n.:lT:'lp
.. -.. - -
is woony ~'!ull.
~ am with
.t-.rl~ ~:~t.c:-r
..~
~-
-------
Attachment D - Page 23
~
!.
2
.,
4
~ ...
~ \1
~ ~
..L.!.
12
~ ~
l J
14
15
16
1'7
~ ...
.!.. c'*'i
19
~n
F. i? 5 G 1 :. r ~ Eo ~ i \t ~ !=; .:~ ~ n 0 f 7 ~1 to?
~e01otJi~~~
S :.i. r .J i? Y b .:1 ~ ~ ,--: ~ r'.
~.: . .':' .
",~ouisvill~,
~;:>nrl,J~',.;Y .
Our i_nvolvi'?TT1~nt
wi t.h t.il i s nC-'~~
Valley sitl? is
to provid~ an ov~rsigh~
.:'Inn t.E'chnic-3:
:;
ri?vi.;?W
for E?~
for thE' dye-~r~~E'
componE'nt
of t.he
6
. ~ . .- .
1. n v I=' s '" 1. g -3 ., 1. 0 n '
DYE'-tr~cing is .:t
c~t.ch-~11
t.erm th.::lr'!"
..
I
1.ist?d to d.:-<;,-r:be
powE'rful
tool for idE'ntifyi~:
a very
,..
...
disch~rg'" potnts
fro;T1 a
potenti~lly -- from a
1 ann f '~ ~. :.
9
s 1. t e - - i r~ t: ~ r :; t
.. .
'. err :=I. 1 n .
i'arst terrain is
a tE'rm 1.1SE'r1
t \) c1 e s c r i h E' t 1', .:'I t
t~rrain th~t's develGp~d on limE'ston~
~ ~.. . ....
~ n c:t c:t 0 .L 0 rr. 1 ',. e .
I~.' s
unique
in the fiE'ld of hydrology
bl?c.::iI.1C::~
it. h~c::
1Jniq1.\,",
characteristi<"'s;
;nainly
v;:''Y'v
. --
bE'causE' of
thE' solution fe3t.ures th~t:
n~v~~_op
i!1 1:h;:>
li~E'stonl'?
?ri~~rily I g1.1E'SS the ~ost
outst.anding
fact --
that in contrasting to granular
~,!l1if~rs
or unconsolidatE'd
sand and gravE'l, ground water
can move
vE'ry rapidly through the
solution opening to
limestone; much more r~pidly than in thE' sand and gr.::ivel
'~ifers and from much grE'ater distances.
~1
Typi.cal
ratl?s of movemE'nt in
sann
?~
and gravel mi~ht be 'in thE' vicinity of,
fe!?t
say,
a --
... ~
G.)
In the limestont?
aquifer,
you might be
per year.
.. .
~~
l.oo~intJ at
f~E't
per minutE';
and ,!uitt?
often are.
....
~")
So,
thE' rl?.::ison
for .l.oin~ t~~
......
-------
Attachment D - Page 24
. ...
.1.\1
11
12
. ...
1. )
14
15
:!.6
. ..
.I. '
1~
19
~(i
21
22
2.3
24
25
.
>,
dY"'"-tr~r.ir!0
is
- - ~ t t 1", i 5 [1 a r ~ i t~ i 1 -: r. r c; i :- t? - - v-; ~ ~ :- ('
...
6
~~~en t ~ fy
for 0~01\:1n -.:;;t-.~r rlr;:;l.r.i.::-.:
t h r:- (i i s c h ~ r 0 r:-
!,oiT'1ts
.)
-from- t h '?
B~c~usp thes"," ~re
t: 1 ~ t? ro"") c; ~ ~ r? .::1 c; 0 ~! ,:; :-J ~- ~
si t.~ .
t,
and th~ ~05t loai~~l. plaGe~ to dn
..,
~ny ~onit(')~in0;
5
t ("I i (1 ~ n ~ i f Y
~,:;y "..=.
ornf?r
7h"" <1'.1-31i ty of
t i-, ~ w'; ( f? r
~. ;.~ ~ t
6
n ' .
r"'l.!.r!lna
fro~'
t'i~ ~i(1?
...
I
I i'l ~ v f?
~ !1~,(jr on
3() ..
t.h~ ""'~r.
8
it.'~ not
VF-rv
. - .
hF?rr:-.
-:- .::InC"',inn;7F-:
- . - . - - -- - . .
lE'aiblF?,
B 1.1 t !1 ;:;. r 1-) '" p s
,..
~,
co~/? up l~t;:;.r Or! in the
Y01.1. (: (') 1.1 l ('~
rn~~tin0.
; ~ t : , a : :.~. :
thE' t;,re,=,
bpen done f~om th~ Hnw;:;. J~l~ey
d:::",~-~.r;.cr:--;;
h.::lv,=>
site.
ThE' firc;;t
w~.s cion/? by
r.[1~ ::\trlt.P;
I bf?i.ieve,
in
19i~.
Th.:-rF? w~s
~ qu~i.it.::ltive trace which
bF?a~n in .:;'une
on which dye w;;;::;
i.nj~cten on th;:;. si t.e show!! i'1y thE'
5t~r
~n ~11~ to~ographi~
Eight o~y~ l~t~~ oy~
frc')T!",
th;;,t
0~rJ .
inj~~~ion w~~ r~cov~r?rl
in some of the strE'~ms,
in
Lind~~~ Cre~k; on~
of th~ st.r~ems dr~inina to
t:'o? south
anc; sOl1t.hwest. :rom t.he sit.e.
;rJproxi!-na t.;:.iy
t.wo,
two anc;
a h~lf miles fro~ t.hF? site.
n.id not
Th~t, }-IowE'ver;
identify where
the act.u~l aroun0 w~ter resurgenr.e w~s
ftOm the
site.
rt did not idF?ntify thF? -- in this casE'
-- the
s!1rina;
which was
the primary disch~rae point of
aro1Jn~
the l~ndfill sit."".
w~ter moving
fro~
To bett.er define that the ?R?s
did a i.nw-flow
.. - "'""'
.!. ::", C\ .
nye-trace in 5eptemh~r of
'i'hey
i nj ~c ~.E'n ;;
ci,Yf=' by
t. ~ F? n ~ 111 F? ,"'I f
nonE'-toxic
fluorescent.
-------
Attachment D - Page 25
f~uor;::,~'("pi ~,
i i1 to. ('t t 1'. ~
opo:>n
swa'!.i?
rE-cpiving
;To 1.1 (' h <) f
i:n~
:2
..:~ur f a c ~
d'rainaQ'o?
fro;:;
thi? sit;:>.
3
Atte~pt~ ~(~ Ye~nV~r t~~ dy~ or
~
~
monitoring
tnF? dYF? was
done at a number of
'...
Sll..e~ '.
'5
i !1 C i 1.1 d i 1 ! tJ
surf;:;(";:-
spring:;,
stre~rHS
A.no 'N';'~:c;;
. . ~
[, r l ~ ~ ~ l "~"
.s
~G th~
southw'?st
-'!T'1d south
of thF? sit;::..
~:i~o
;:; ~~".~.,,,
- ..,. .. - -'-
..
,
th~t's used [or a public w~t;::.r supply,
?irt.:;"e
SprinQ'<; --
...
(\
I.U:;~0 by
Rardin
County Wat;::.r ~ictrict Number 1 as th;:>ir
-
..,
.r d. :'\ .:IX Y
sOl1rco:> of
W-'!ter -- W.:IS monitored
du:c-inQ' t11.:;.t
.I. \.
tr~CF? .:;.no al: the
subsequent
traCF?s.
~ ~
.L~
As I said,
thp dye was injected
~ -
J. L:
$~Dtemb~r th~ 19th.
Th~ first
r;::.covery of th;::. 0Y~
~ ':I
J.. .~
.:I~~",;:;r'='(l
. ... e" . . - . .
-- :.;~ <;: oh~",'(v~('
t ~! i r t y - f 0 U r d a ::- 5
1 ~ t ~ )~ ~ t
~ .
..L~
B n 1.\ t. ow f? 1 i
5pr iZ1g~. ;
-3 ~. '-j ~J. t
.. ...-
.L . t:. ')
. .. .. ..
IT 1 .!. e s .:I.L m 0 S '.
d~Jp:-
";01; t~
. -
...
::"5
th~ 5i~~.
:6
EXCE-rt
for addition.:!.l
r;:>cov~rii?5
.. ..
~ !
in 5trE-a:!-lS,
whic~1 w~re
fed by
that c;it~,
that basiC'ally
.. -
~~
W035 the only
c;ianif:c.:!.n:: dye
recovery from t11;:;t
19
injection.
7!1e:r~ w"t.<; a
possible
recovery .=It
"t WE-::::;' very
~o
ae.ar this
sit.!?,
b 1,] tit.
w,;~ :~tf?r
.=Issl1med "tnd decided
.21
that t.hat
w.=.s proh.=!hly
"t spurious rF?cov~ry,
some
~:')r~~
22
cont."imin"itinn,
"" n (') not
re~::;'ly "ts a result of
th!? nYE-
23
moving from t.he
. ..
5-,-'~
t:o the northw~st.
That.
w.:!.s th~
:4
low-f::;'ow t.r"ice.
2~
70 het:ter
(i.~f~_n~
whF?thec
o!- not
- .
!:.,.-
-------
Attachment D - Page 26
10
1 .
J.j.
. ....
.!."
1 -
.!. )
. .
~~
115
16
17
18
19
-,..
~\J
.....
;.. J..
....-
~. &j
23
.... .
6~
.... ...
-6:')
.
tj'!E-r~ -'Wf'"ro:>
of w.::!t:~:-
an~.i t iCJr\-31
out.pu~s of th~ ~ye ~n~
....
It.
tro~ the sit~ durinn- hiah-flow condi~inns,
~~ - .
;;\ hi Of' tr,e
i
other spring5' were
season~l high-f~nw
runnina -"It
R
conditions-
9
In ~~~ition to t~l~ ~j~~~
tlBt
h~v~
be!?':! !T1or.:torE'd
ci.uring
th~ low-flow tr~ce;
addition~l
sit~~
03dd.".o,
p~rticul.::!r:y to thE-
hav"," he!'?n
c;olJthE-~st:: and
to thE? !:,~c;t.
sit!:'''' haVE- b~i?n
;... f€'w
d i S con tin 1.1 t:' ri .
Additional sites h-"ld
~lso he~n ~dd~~ to
~te ~est <'I~ri south to better d€'fine
wh~th~r ~~ ~G~ ~~
1:1.:\0 r.:\dial floW' from the si t.€' llncier
h i g j'! - f low
conditlons.
Tl-.t:' injection
occurr~d ~t 1~:3~
in thp .,ftern~on,
Twenty-~our hours
lat.~r. th... fi rc:;~
detec tor tila t
from t.be
B 0 1) t w E? 1. 1 s p r i 1"1 a
wa s recovo?r~("i
,eve
of dye.
Th-'!~
. ~ .
pos ~ 1,,1. v..
indic.,tion of
the pres€'nc~
~~S the only site
had positive dy~ r~covery
fro,-
that
th::\t tr::\c€'.
Basic"'lly,
those
two tr",.c,",s
confirmed that th.. prim~ry dir~ction of
ground
wa't~!"
!!!OVe1T;l?!Jt
from thp site w~s
t nth E? S n 1.1 t 11 Wi €' S t
r.o R 0 1.1 7. -,.; ~ :. ~
2~
-------
Attachment
D - Page 27
I
"
~
.
$ P r i r, ;; ~
j" ~ c; : ~ ~::,.;.. ~ ("" ,=.
- -. ".,'."-
2
,for ground
~oving 'off the sit~-
wat.:-r
")
I rnight ;'!'If?ntion
very briefly th~t
.
...
thE' aspect of
dye-t.racing
. .L.. ~ ~
:l ~ e sse n " 1 a .1. .!. Y
.:\ ci ,.; i rllJ a 1" n i ..~; 1 i?
5
c07!lpound
~nd ~onit.oring for
~~: ~ ;; r ~ p ~ r ~~! .~ ~
to f.h€
w,:;tE'r
,.
...,
0: t~;;t cor;,pol.1.nd ,:;t s~l<:;po?cted re<:;urg"'n('~
In ~~.:.;
sit~~.
..
,
c.=Ic;e; most -- t~l~ twn dy;=.s conducted by the ?RFs
~..:-.....~
2.
iN "'I S n"")n~ toxi <::
:r,,:;ti?ri"'l.}...
I! ~ -
~-,-lIore5('ei.n..
as I
m~n~ i\")r!~~..
'"
:"
.=I<::tiv;;t.;=.d ('nconut charco,:;l;
w1!i~i! ic::
It's r~rov;=.red on
. ...
.... I)
pl~ced in ~:l th~
v"'l.rious resurgencE' point~-
And thE'
~ ~
1....
ch"'lrcoal th;::.n..
i.c:: testec1 nr
is i'ln"'llyzed for t.he presence
. '"
~ ;!
of t.h~ oy~.
1")
7!"! ~ t 1, ~ ~ i ~ &11 y
is a r':'<:;1111"
() f t.:l~
~ .
, -
(1y~ - t. .c~\".i rllJ .
defirlto:' th"lt we h"'lve <::nn;)I;;"
r" ..-
.!.. .: "..,
it. \-1or:-~
~'5
-...
Sll,.~ -
p"'l r t j. r 1.1 1.=1 r 1 y the
fr00 t.h~
And it. illust.r"'ltes --
. ,.
1.""
hiah-flow tract?
rapid movement. of IJround water
-- very
:i
in the k"'lrst t.errain-
. ...
.1."
19
T11ank
~-loody -
.!.
THE C'\AIRHAN:
Y01.! ,
... '"
~\.J
:8l.ess,
could gE't Jeff to present. a
Iitt.:~ bit.
now,
if w~
...
.!!J ~
rf'a.mov~l action
~nd of th~
'of his
overo:;iaht. of tho;
.. ...
~ .(..
Rerne~ial rnvE'o:;t.ilJ~tion th~~ ~~s
don;::..
23
..~
Ci -
Hy n~me is .')o;ff
j\os~.
Hi<, - i
-------
Attachment D - Page 28
. ...
- \.J
. .
.LJ.
. '"
.1.,,-,
~ ":I
- .'
. .
.I.~
15
. ~
.1..,
...
.L I
. ...
l.~
19
"'...
,!, ,~
.21
2~
23
24
25
,70 -::Ind"
rlAr():.~
:-, -3 v.,.
wh~t wt?
~:-:!,lainF.lotex inSI1~-"Ition is usen typic
:;'-"Ip
t. (') ~1.1 ~
-..,
~,
-------
Attachment D - Page 29
:1.
.. ;#0J.- -
$ () t! I ~ I: .1 C ~ rl
~oint:
o 1i t w h .. r e t h ~ .. ;;:. f.. -"\ t 1.1 r '"' S .'I r P ,
..... .
~ .11 '5
2
~s .=\ dt""Iwina
of th~
~it~ ..un~ri~Dnse~ np ~ tnnnnY~r.~:~
- -. - .. . -. -. - - -' ".' -
)
°m",p, - T(,:r. 1)1.1 v;,.ll ~~n,:.;
which I
h~vo? ~oint~ei 01lt
4
initi"\lly;
runs "\lon~ the sit~
here,
Th~ sit~ is
5
loci'ltecl to
thr? ~~~t.
of T('i!t1
D 1.1 'J ~ 11 L ~ n ~ .
~
r:>
Th~ ('~l0t~X ~il~
w11 i c-~! I
~ ~ 1 ~ ~
- 0 .
-
J
.5h0WP?O YOIJ W<'!S 09
r"'lther l.=\rcro?
hn
-------
Attachment D - Palle 30
1
~
£,
-'
.
~
!:;
n
i
,..
"
9
. ~
~\I
, ,
12
13
. .
, -
...
15
ln
~:
. "
..!-o
19
.20
,2~
22
~...
G "
~ .
~~
2.5
h.::-ri?
... ;;"!(~
on-,:;i~,:.
$\.lrf~~~ ~~t~r r~.~~
i) f f r,; .~ i.: ~ \~.
f ~ ;)~~.; ~ ,")
7.n r? r!
-. ~ ..
.!. il.
be o::ho'..inQ' yo;)
-; .:-:;-. r?
~ ~
/, ..,
'"" i? r i? h 1.1 r i ~ 0
- ...
,., ,
,th~t. on-si t~ si~1'r(110l.:>.
photOQ'r-9[\i:~ of
~~~t
sin;";,n:,""
:~t~r.
0: di,:;~i:!:~7
;; l- r:- :; ~
.." . ~
" n e s 1. " i? :
th~re
Thl? ci r1)J'!1S wh i ~h
we!';::.
re-9:l;;'
t.'.0070 id nd
~~ff?rrirlg to.
o!)~ is c~~~~d t~l~
st'rip r!~!"~:
~ ~. ~- c;
W [1 j (" ~; ~':' l 0 t? en
nq~iyin("'J
- - . -,. -
~,ri?;:\5 .
And th<'lt
..' .
10" 11 1. '5
ril th(".si?
~r,.;.;;:;
.:;r~;:; ~nd
thE'n some
'...101.1:£1 bf?
of th~ p(,~k~ts her~.
t 11 ~ d r '.1 rn s w,? r ~
~ . ~ --
'. y P 1 C ;:\ .L 1. Y
i) n d i? r
.=tnywh;::.r,""
tW() \.,f soil to
mAyhe two or
~hri?e f~et nf soil.
7h>:>y
Wi?re
I.IpriCJht ::\nd
~'(,Y',
~ n -~ n '-:- ~! ~:>rs -- ~nd ~ust
. .. .:
S n !oJ i? P 1 C '. 1.1 r r:> c:: n ~
kif'ld of t.he
drums froTT" the
i?<,!11. i P;:1i?!1 t
th~t
thi?ri?
'..7 i? r r:> d r 1.1 !!I ~
.:Ilc::O bl?
~howina you
which was ~ shov~~
vehicl'?
That W<'IS USi?O to
h~5ir;~11y
~nd t.h~!1 ~
dntrr. t2rappl-:-r:
which
ser.:l.p
wa.:::t.f? .
-,..~
1. ......
thr\t.
oper~tion th::\t w~':;
siti?
'There
Wf?ro:. ~WO
Werl? used to do th;:\t:
at.t.achl?d to
.:I, tr.:lct.
1.1.ncove!"
~ h .:- d r 1.1 r: .::; .
I'l:
summarize
1i'5.:-d ~o removf?d the
pri~~ry pll?CI?S of
A traci< hOi?;
-------
Attachment D - Page 31
1
r. n 1.1 ~. n
...
~rt.i..:-:ij_---~7~ i:~
three
h;.indrf;o~ ~nd
s i :~ 7::. ~- t? G r r;- €- s ~
A
G
.~'1.1ld be
1) '5 '"" ci
to pi<::k tbe
(irU;TI'5 lip <'Ic:;
thE' ~.
w~r~
I
I.
I
I
~
unccn~'r;;od .
4
Also
inthi'5 ~hotoaraph YOD c~n
:;
c:;f;oe in
the b~r.kgrouT!d
th~ ~:ct?~
w h .:> red r ".; ;;. '5
TN~r~ ~.1-lt?n..
;:.
h;='.=5 i (' ~ ~::~. ..
rJ~;1Cf?'~ or
'5tager. once they werE'
reI'!'1ovec:.
:. n.~
7
this is
~ w,::;ter t,::;nk
which w,::;'5 b,::;sic,::;lly
u5.:>d to :":ee~
"
t 1"1 ~ (h) ~ t.
do~~ on the c:;ite
iN 1.. i 1 ~
they
WerE' ',Jorking;
so
9
t 11 ~ ~
thA-!"€-
wo;;:'Gn't. be a.
l,:>t of
fuaitive duc:;t emis5innc:;.
. A
1. \)
Tld.c:; C:;i.1~~ariz>?c:; :':ind of t1!F
. .
J..l.
...'
oper.:!. '.1 on.
If the drums WerE' in poor c:;h,::;pe
or t}'1;:.v JT\.:!'1
- - ... .. ....
12
have be>?n leaking;
the druC".c:; were pi r.i drums were bl1ri;,>o anywhere from.:! fpw
i n C" :-1 ~ ~
19
to a few fee~ deepi were aener~lly int,::;ct
.::tnd st~ci<:<:,d
20
;elite deep.
You can see here
-- is an upright dr1l;:-;.
... ~~...-
~t':"':~
.....
.~ .L
are the ,::;ctual buried dru~s
covered hy c:;ome soil
22
rn03t:eri05.1.
;"nd you c~n
sp;:. th,::;t
they're
exposE'd her~ ~.;..
2.3
the tops.
;"nd they're covered by dirt,
but th€'y're
24
uprig~t and th~y're
aener.:!:'ly in~~ct.
...~
-', ."
This is ,::;
pict.1.lre
.
wh i cr,
!'"P?s.p.;..-~~
~...
-------
Attachment D - Pa e 32
1.(:
J.J.
12
. .
. -
::;
. ,..
.I."
. ..
.I. I
. "
..!.. '-1
~9
~r.
...
.. G J..
....
:~:""i?d
..
:"I
t.hE' front.-I:'nci lo~.<:~~r,
Ar.,.;::>c;:.
thE'Y werl:'
t-?lr-E'n
to st-=lging
"';
;'.DO t.h i!5
-?lri?~.
Tn.::- drl)!,:":c;
ex~~p1~ of ~ stAging
is ~n
"
"
pl~c::~d
on.=. ''';'; ~
on A plAst.ic linE'r,
.:Inn th~n E'A~h
... - y .
w.-....~
..
giv~n ~!; lci~ntifi("A7jon
p-"li.;1~i?d
oC!
~t '",;:; 5
number.
sprAY
ttlP n1~tside of t~)e
7r,i!'; wAS oon;:::
so t:il.:l t
Aft~r
o r- 1)]'11 .
th~t
dr1.1T!1s ("01.1l.n hI:'
;"nd whl?t.hpr
E'.,~h
of t.hE'
SAYT1plE'ci.
1:. h e '.1 <\ 5 t e
T!1-?1teri""ls IN':'!:'"t?
:-~,t=-V w~r~
'.... - .
!; 0 1 i c:1 0 ;~
whptnt?r
.>
!": .:> ITo i ~ i) 1 }. G 0 r
: i C! '.1 i ci ,
;:.vP""-;
. . - ....
" :., t ;:; i n ~ 0. fro m
~ s~~.p~~ w;:;s
:;iIiQl~
ci r'jj:': .
rn
tl1is inst~n~,:>,
A gl.=;ss
ic;
t.his
tubE'
c.,lle~ A kolew~c;.:I
(?honetic)
<\nd it: ~"'!';
s;::Irr,pl i?r,
used
of A liquid
-- 1i<111id
~aste.
1:.0 t.=l~~ .=I s<\rnp1e
;ft~r th~ w~st~ w~~
~hi!lract.erizE'n ,
..... . ~
,.n~n 1. '.
w~!'; ciisposl:'d of.
Tliis show.", t;1f~
~.dina ramp whE're t.h~ drums WE'rE' brought. up t.o
~ont.ain~r t.rl\rr-S,
W;.l i eh Wl?re
t.ilen
1:..:ikE'n away.
ThE' two genE'r~l w~stE' crroup~
wili ~h
t.herE' WE'rE' wE'r~ 0asi~~11y solid-t.ypE' wastE'S and
then,
li~e,
]'!I ~ t e:" .i ~ :;. ~ ..
W-"Ist.E-S li1<1?
drl1~
s~rap
scr~p
part!'; .
~t. CE'te.r-?l.
7ho!":~ wast.E'S in t.he
init.ial
pc;r~in'n
~.
, .!.
-------
Attachment D - Page 33
. -
.:.lJ
.. .
..!.J..
.. ...
J.. ~.
13
.. .
...~
15
.. ,.
J.."
.. -
.1.1
.. ...
J..t:'
.. ...
.J..':7
2~
.....
.:..1.
22
23
... .
~~
23
..
.I.
of th~~.r~~ov~l wpr~ t~~~n
.:!.!"IO i;] th,:.
~nd incin~r.:!tl"o;
...
<:,
later part of t~~ r~~ova:
';.?'~'.
'~~!'"e (i.ls!,o~t?o- of
in a
I'ler!"!~ni?n t.
h-3Z':'!"~01.1~
W.;:j'5t.~ :;:jnclfill.
4
ThE' ot.h~r
-~ - -
g~n~ral !YPi? of wast;:.<;:
5
li'111id
. ~. ~
Seml~O.Ll(. ;
'5 i ~ i cor.;;> P 0:;:-'::' ~ r ~ .
~nd
w;:::.1::"e
w,,~t.e'5 or
..
"
.. ..
Tn;; I. ~!" 1 ~. .;. c:;
wi?rE' all t.aken t.o a pe~0it.ten
trlOSr?
-
,
incin..-rator
for treatment and disposal.
3
Tho~~ two groups of
..aste
:-.~~;:; ~ -
...
~J
:1.1st
described o;:j'5ically were
t.he silir.ol1e
have
po:~"~~r5 .
Th,=.re were othi?r wast~s at
the sit,:.;
inc:'l1Joing
metal plating ~ludges.
And thi~ is -- h~fore
:i: gf?t to
tha t;
this is
of t.hat solid
an €-xampli? of
SO]'l1I"
silicone
tl1at I t;::.lt.:f?<;
"bollt e;:;,:,,:i,:.i..
n("Jlv""'~r W;:jo::r.p
." - - -. - - . - e -
: ~ . s
.. . ~
~ .'. n Q ()-
.. . .
'. .:. 1'\ t?
~~l~ina m~teri~1.-
Thf?~~ are the metal-bei!'l.ring
plating sludg;:-s
were found on-sit.E'.
And they
w;:-r..-
t~la t
basically taken
the Y 107 ere bIll k e (1 ;
SG
areA wliere
t.o an
t 11 a" t h ~ d r ') ,p '5 w ;:. r E' t;:;:" ;:::. n - -
t.he plating sludgps w~r~
removed from the drums;
thf?T1 mixed with
limE- .=tnci
some
8ime soil to 1'1<:,~p dry out th€' 51ut1!;!e!;.
'1'hf".n
t.~!(")$~
8ludges were
t~ken
t.o .=t. ~I"rm"\n en t
tr.3nsport~d "In,)
hAzardo1.1.~ wa~tf".
l"\ndfill.
In the cent.r"\'1
area of thE- site;
.::;.i.nr.~
1l!1cont.ainerized wa~te I
~omt:! 0: t.hat.
there "'''1'5
7"Aterial was
t.l! t'? !1 ~ : i £:'1 }"! ~ r a :
:;r~a
~h~n tak~n to kind of
- ...
, Co
-------
1-
Attachment D - Pa e 34
.. A
. "
.. ..
1. .l
.. ....
.!.. ~
.. A
.l .)
.. .
.!...~
15
.. ,
.In
.. .,
.l'
L8
19
. ~:J
.....
. ..:, -'
22
:n
... .
~~
~5
~
oft i ! ~ (~F T1 t r ;:; 1 I10 r ~ ion 0 f t i 1 0:'- ~ i t i?
. . ..
:;~! r' ~--?::
-'I!1n !"Ii '..,..>r. 11~,
....
"
-1 i k ~ t r!.~ ~ .
~ ~ :... ."":.~: ~ ..
th.:l~ material wa~ :0arl~~ 0~~~
7hpn
'3
and .:ho::T1
~t?r~,;;n~T1t"
t.~k~!i 7\-, ~
t})~t ~ateria: W~5
~lso
.
..
h a z a r Ii 0 1.1 S
waste
l.=mdfill.
5
:!:n f1.do.it"ion to
t-hr? ~;;~~.~
SO~t? of
,
I')
on-si..~t?,
on-sit!?
~n(~ riii1-0T!
also som~
~(>nds.
th'?c~ Wer!?
7
.::I n d r 1) !1 - n f f d i. v e r s ion s t n.1 c:: t 1J r ,::, s w 0:'- r e p 1.1 t
t.o«]i7-t:!e"""
8
during th~ ~ours~
tr~i?tt w~t.~r ~;:;_5
of E~.I..
and SO!711=' of
9
also ~oljt?r:tt?!1
wA't.=-l.- w-=\!; t:J,:.n
in thesl=' ponns.
7~.1 e !1C rl(l
t-ransf~l"ri?d
holciing tanK,
w1:1ic~ ''''a<;
tre3t~~.
th.,.n
to a
knd it
was a t....o-st.:iCJe
t-rF>at:nE'T"\t.,
. . ..
w n e r !? 1 '. ran
through a JT!lxec:i
whic::h
~!?~ia-typl=' filter,
consist-ec:i of
s.::l!"!d
ann \jravel;
a 1"1,1
L' -
1..d~!.1
,;:~(")
r ;::; nth r ('.1.1 a h
a ~ar:'on
filtration.
in~o
That mati?rial was thF>n put
anotht?r holdinCJ
which WriS t:1en
to !;~,:> if
tank,
t~ste.;
any hazardous
c::onst.itue!1ts
remaineci.
And when jt- was
found that it
wat~c IN.:IS us~d
to w.:Ish
wasn't.,
t.hen th.:lt
off sorno'" of
. ..
~ C! l.t 1 p;n en,..
~-;11~t
.::! n ~ 1.< S F. d for
t. ~1 F? Ii, Eo ;=t V Y
~uppressio" on th~
. ..
51.':>.
B!?fore
just
tao
to th.=;t.;
! get
poin t 011 ~ .:I
C/i11p~e of
t.hings
! was t~l~ina about ~0~in.
Once again,
the sit!? W.:lS ther~,
t.h!? c::ent.ral
.:Ire a of
wh~r~ there was
uncont.:linerized wast.e,
.:Ind th~ outlyinCJ
.:Ir€'a5
wher!? th!? dr1.1:11s
.t: . ~
!.al.r.!..y
orderly packed.
7h!?
W!?re
on-site pon0~
~ ..'
.Loea, F><1
W!' ic::h !
. ..
"l!=: ..
w. .
t.<'Il!
-------
Attachment D - P
...
.;
~
.
..
:;
,;
..
,
...
"
-J
A ...
~\I
.L l
A ...
.i ~
. ..
! )
A .
...~
...
:S
1':;
.. ..
~ I
A ..
1 I~
A ...
,.,
... ...
~\I
....
.:!. ~
"''''
Gt!.
......
L ,)
... .
G'"
25
~-I ~ c ~
. .
.=11-!""~ .n ~ r ~ .
~ft-~r
the r~~ov~l activiti~~.
which
i~ th~ summ~r of 1988;
TN;:> r e r. 0 n Ii ~) c t ~ d
thf?ii in r~r:-
.t: ....
L.=tJ.J.
of 1.988;
st1_toy W,::U5
.; pilot
test
conducted to se~
'..:. ~.t: +-' -
:! '-' 'N e -'- -'- e c:: '-- 1 v <:"
. ..
.:;Ol.LS
r~:r;c":Ji r".:
''; (': 1.1 -: d b ~ : <) ~
fier:;t.5-riJ tl-lr:::
So;'T!~
(') f t 1.1 ~
c::ont~~ini'\t:i(>n.
!1 i ~ ~ :.1 r ~ G:
org-anir.
"'.. .
.!. ill ~
is ""
thrE-t? Gf
the plots;
whi~h w~r~ b~sic~lly
: (',.(
:""id ont
th.:tt pilot
So~e cont~min~~~o snils
[ r () T" t: : ~ ~
!';t1.1CY.
centr:=.l
~r~.=t of the !';i~~ were l.=tid out in t~r~e
r:';~;; of
v ;:; r i 0 '.I S
thickn;:-ss to G~termin~ wh~Lch
woul<5 Df:'
thic::kn~ss
most-
eff~ctive for
rer.1ovin w.:t!';
loc.=tted.
,.. .- -
!. ~ ! ...
0;:; t: ~ r i ;:;:. w;:; s r e 1':': 0 V .. d f 1" 0 ;11 t 1'1 .:> !'; i? t r i':' n c 11 e !'; '" n ci t ;-j ~ n
. ~ .
l; ~l. .'. ~ (1
up .:tdj.:tr.ent to the~ in
approxim.=tt~ly one-foot high
ai_rt!';.
t l! ~ t ~ at,=. r i .;. l
using
w."!.'5 03l?r."!teci;
Then{
tr.=tctor!';
with ho~ .=ttt~ch~~nt:~:
. ..
'502....
~~1 i c:::'
would break up thp
;"T103t~-r-i.=tls ;
+:0 mor~
03ir and
""f?r03te th~
f?:
-------
Attachment D - Pa e 36
. ~
~ \,
11
. ~
l.~
13
. .
. -
1';
. ..
..."
. ..
.!.. I
. ~
.!..i)
. ...
.l.":1
2v
....
~ ~!..
~2
23
~4
~';
:i.
wen t. n.: (" ~ 01.1 +-
~:;-I1~~.7"".\:
~ I) c1i, SO",;;>
t n ~. :--1 ~ ~ i 1:..:--
.:! d G :. ~ ~ \~., ;:> ~
...
.{.
~ both
.=. rr:--?t 13 t.""'I
in t~!t? o\.1t.ly:n0
th~ rentc~~ ~re~~ Ancl
.
"
r1 e t t? r_"':\ i jl E'
wh<'lt
cnnt<'l~in<'ltion still r~r-~ineci i~ ~~~
4
on-sit.",
!':oil.s.
'5
...' .
.:.!11,!,
is h<'l!':ic<'Illy ~ photoa~~~h
h
'L(")nkinCJ
sit;:. t::\ft~r
)"" ~ t'''': ~ ~ i' .=. ~ .
- . .. - '.
i t. h~d
~crn!':s the
(:-. f70 E*!"i
€,:1~t
-
I
<'1ft"?':"
ti'IO=- re;nov~ 1
-. . - .
.:; c '., 1 V 1 ' ::.. '" s '
':':
The site w~~ then -- b.:!sic.:;::~
=I.
:;
grici w.:!s 1.:;id out: on ~h~ site <'Ind
w~!""~
t"A"....=.n
.
SM:0!1..L":-::;
~lc:;r~0
arid !1oint~.
;'nd Y01.1
prob.:;hly c.:;n't s;:>;:>
i~ re;;:
well.
th~se r;:>n fl.:;gs represent
grid points,
$n!'!1e of
':'hase
arid points
011 this
T.-1h i c h
dio'\ar<'l~;
,;hnw
up b;:>tti?r
h i5 !5 i (~~ :. : y i 5
., .
,(~ T'"o\l
~h,", one
you s;:;.w i'1efori?;
() f <'I
blmo111p of
sl-i::-,....;inlJ 'tr'~
whE'rr::-
t h '" (,1.1 r i E'd d r~):':" S
"'.,Jr:::~~
"'ll
:-I.=.r~
;;r~"'s
loci?tt€,'1.
The outlying are <'IS WE're
grid~ci
in
-- t.wE'nty-three points werE' sampled;
primarily for
metals.
SincE' th.:;t's prim.:;rily
where the ~et~~-h",arina
{)latin~
loc<'lted.
sl.lldgl?~ were
The central .:;re~; which
t~ sho-.rn
in this
in Ii epE'C' ~ F::l ~.
d ark h .:; c h '.1 r i? ;
there werE' tw~lvE'
~~~plin~ loc.:;tion~.
;'nd thn~o=- ~ere prim.:;rily sa~pl~ci
for organics,
sincE:
wh~re most of the org~ni~
t.hat's
wastes were
loc<'lte0,
The point!':
wr, i ch
}'!.:IV~
n 1.1 ~ b ~ r 3
. -
, ""\
-------
Attachment D - Page 37
I
-
2
3
4
5
I;
7
8
9
10
, 4
-.I.
4 ~
loci
4 ..
1. .)
4 .
J ..
1'5
4 ,..
J.O
4 ..
.i.'
18
13
... ...
~\.I
....
." l.
22
23
24
'.5
n~xt t~ th~~ ~n this dia~r~~ arp In~~~i('n~ ~~ w~i~h ~~~
conc~ntr~tions of ~ith~r ~~t~~s or
or0~nics
,:;t t11",t
P '" r t tc 111", r 1 0 (": "I t ion €' x c e E- de d
t~e soil ",ction l~vel,
which h~d
be~n set-
for cle~n up for tho? site.
$0,"
tht?L~ WE-rt?
l~
t.W(') l('h-::;:;tions
tho? outlyinlJ
",n~ one rilJht up ~t
t I"! ~
are", -- one here
top -- where
chrcmiu~ exc~eded the soil ftction
:~V~: ~..
t"h,;r
pi'lrtic1j~,:;r
::'f')c~1:.ion.
there
In th~ centr~l ~~t?,:;
~~r.::-
~or€' loc~tions which
exceed~d the soil
,;~tion
l~v~:s th~t were set.
)nd there were three individu~l
co~pounds in which the
. ~ .... . ~ --
SOll. ~C~lon ~eve.l.s were
cii?t;:.r"T11.ned for
tetr~chloroptD~~i?.
T;,.o!';~ :oc,:;t-io..-,,;
PCE.
~ reo j 1.1 $ t ~l-!owrl
!Ni t £1
7h~ ~()i 3.
~ction :ev€'l
tho? n '.1 ~: b ~ r s .
was set at.
i.5 p~r~~
per million
at so!"'E'
",no you can Si:"1?
individu~l
the concentr~tions
10c031:.ions
WerE'
si0~ific~ntly hi~hE'r
t.han
that:.
A1':. --
Additional
COJTI!H)I\r',ds in
Wh.i.C:l t.h8 soil acti01'1
WE'rE' hi~hE'r was for
lE'vels
~,111-trichloroE't.hi'lnE',
~bbrE'viated
7CA -- ,:;t the~~ t.~~~e
locations.
~nd l,2-dichloroE'thenE' "'t
this lo('ati(~n.
This show!'; thE'
on-sit.e run off.
You can
a hE'avy rainfall you aE't somE'
seE' that aftE'r
surfacE' water runoff,
is runnin~ tow~r~s th~
and t11is
on-si~e
E'arli~r ~~d ~~i('h
sin'. ,..,
j
I
I.
I
I
I
I
!
I
I
I
-------
Attachment D - Page 38
w~s ri~s~r~h~~ hy
:;(')(~n::.
.. f .....
~': 1.1 - .:. .
2
Tr, ~ c:: is
-3 Ii hot: \')0 r;:; f,1 ~ 0 f t r! ~
~
.>
"!:.~
=Sinkho:i. .,.
.. "'J:
J. I. ~~ L. ~ .
-t;') 1.1. C ~ 1! !; i? ;::.
t ~1 ;; t
~~~r~'~ o~~~in~~
:. :'"'. .. ~
4
the sw~lE'
whE'rE' w~t.,.r c~n run
. ..
In,..O.
1n ~hi~ p~rtic1.1~~~
'5
~~sE'_th~r~'s wa~~r
f~~wi~0 :~~o ~~E'
o~e 0;;r:-!1::::;.
Ii
- ... ... . .. .
.!. n ;; (~ ~ ~ I. 1 0 n
to t.estin:7 ~he
s('.::c::,
"7
t h ~ 'N' ~ t f?!'" wr~ i. ~ h
i'I:SO
flow,:.n
into thi?s;:,
or/~ni!10C; ~~::.
"
"
~ t=i ~n p L r? (-j ~ T} (1
t.=ost..;:.o.
And t!!E'
only
orgi'lnic
(,:0!7p01~~(.: ~~I.:t:-
,..
.,
~~~ G~t~~t~~ ~~ 1;1:1-trich:oroeth~n~:
i'lr f,')u):"
p~~~~ r..=.!"
j,;)
bi ~_lion:
w ~ ! ~. (" 1 !
is V;.7!ry lot.;
r. 0 n c .,. n t. r ~ t. }. I) n .
711~ E?;;
- -
'- .l.
st""nd~rd
for 1/1;1-trichloroeth~nE'
. ...
lS '. WI')
hundr€'d !"P'Irts
- ....
1.1£:
!1i?r
billion.
13
;:.,. n d t :! i:5 [i n ~ 1. s 1 ; ci ,;. ~ ~ 1 ~ r. ~ 11 (J w.;; .
- - . . - . .
- .
~~!'""~~-~
;:;0~'::.n ..
;::j
!,i("~1)r.=o nf
~~~ ~ite dilrirHJ thp? s~0~~inS'
- ~
1."J
for -- "'It
tl!~ inc1ividu031
:oc~tions;
showing
sorr.~ of tl!~
lli
s~m!11ing
equip~ent th~t w~~ us~d.
~ power ~ucr€'r;
which
. ..
l. ;
is oppr03t.i?O oy iJ~lld;
w ~ S 1) "" ~ d t n d rill do w n t 11 r 0 I.U] h ~ ~'j e
. ,..
.l.C>
surface to oedroc~.
S~T!1plo?s were
t~ken ~t
the )5 1.1 r f .::I C E'
19
at
thre.=o fE'et and then just. ~bove hE'rlrock.
;.. n d t 11 ~
~o
~Du!t)f? 5 t. ;; r P '"
on tho? sit.E' w~s ~bout ~ine fi?~t.
Some
.....
.::;.!..
.~NS of t~.I;:'
- : ~ -
~.L '.r:':
Weri?
only ~
fi?w inchE's -- hi?forE' th€'y
22
got to hedrock.
"'...
~ J
50;
that pretty
much
summ~rizE's
24
the activitiE's t.h"'lt
went. on durincr
t [I e r i? m 0 v'" 1 ~ n 0
215
c1urinC] t.hE'
s",~~l :'l'lC]
which followE'd
tilE' ri?mn.v;; 1 .
... ..
-) ,
-------
Attachment D - pafe 39
1
...
'"
,......- ,...., --.....
i !'l r:, \ 0" n. !"\ .L ~.!.! !'\ ! ~ ;
7h~nk YOU;
--&&
'-' ~ ~ ~ .
t:'"'
3
havo?_h-'\d
~ n,""w
CO;T)o?r; T..71-;(") w~
wi:::" d*=,:i.-'\y
.. . ~
;In '. 1 ~
th~ ~;:;~~..
.
I,!
Chuck Pietrosewicz; with tho?Ag~ncyfor
Toxic
5_1.1 (> ~ t -5 !: C i? ~
t=
-
-'\nd DisE--'\sE-
RelJistry
here.
;;
Flr~t.;
we will h~ve Mary ~0 :~
..
I
over the ro?~edi~:
-3:to?rni'\tiv"?s -'\nd
the prOrOSE-o.
r~"n f.')r
,..
f".
rerr.,",oi"'ltinlJ
..." . ~ ...
'. n. ,:. SOl.l. i'I'..
th,:. site.
...
::1
. ,..
.L\i
i.~~ .
--..- --
!'!:J1II..L\..f\. ~
Wh-'\t r'd
first.
~ . .. ...
.l.::.><:e /.0
. .
LJ..
do is sort of reiter"'lt.e wh-'\t
Jeff h-'\s s"'lid about thp
12
i'I'Ce-3s
.1..'", .L
'..Ha '.
_.~~
s '. 1 .L .L
cont.ain
contarn.in-"lt.ion.
13
';<)ain;
this is ~
sit,:. 1,:;y~1t7.
;5
. .
, -
\) ~ f f ~1 ,; (1
s~id..
t11~ ~ottpd ~r~~~ ~er~ wh~r~ ~h~ ~~t~ls
15
WerE-
burieo.
And then tDe central heavy
dotteo are,:; was
16
where t.hl?
org.=.nic
c::ont"'linina
wastes Wl?re
b I) r i e (i .
. -
, .
B-"Is~d
upon thE- dat-'\ th-'\t was
. ...
~ r.
s~ler.t~d (iuring tids
s03mrlilig in !-larch,
a 0-"150:' ~_in,:.
ri<1{
. ...
.!.:1
assessment was conducted to determine what threats
these
2n
~tamin-'\tes would p(")se t.o hU1'!'i'ln he-'\lth and the
..,.
.~.I.
~hvironynent.
B-"Ised uron the findings of
that ri~~
22
~sse~sml?nt;
there w,:;s
~. .
~lve prlrnary ~reAS
where
23
contamination DOSes -'\ risk.
And this risk would
be to
... .
c:.<:
someone who were to fre~uent
th~ sjte,
such ::IS ':;,
h 1.1 n t e r
~5
or someone
~-"Iyb~
rici5na -'\
~inibike: who
could.
cO!T',e in
,~
-------
Attachment D - Pa e 40
-
A
~
:-
.
..
~
6
7
,..
'"
9
"
..!..u
1:
A
, ~
1 ,..
-'
- ~
..
15
16
- -
I
1 ...
.,
19
~O
...-
o!. ...
......
~ ~
... ,..
'" .)
A.
:!t~
f
... ~
~')
cont;;\-<-;t with
~h~ '::oil..
r 1.1 t 1.1 r o? w 0 1.1 l. n
build a
mentionl?d,
~r!? till?
.?lev~tl?d lE'vf?~'::.
Or C:::O~E-O:1~ wr,o
:n~::-~~ i ~ t h~
rE'sir1!?ncE'
on t-h€-
~ite.
~r~~5 onE' ~nd two,
;;\5 .JE'ff
~rl?;;\':: whl?re chromium w~,:: found at
;'.nd then <\rE'~C::
f 01.1 r '" n d f i "'- 07
thrE'e,
werl? ~here org~nics -- prt~~rily
w<\s fou~d in el~v~ted
using
this
inforTI'i'\tion,
~nd thf?Y WerE' ev~lu~tE'd
will juc::t bril?fly run
t~t:-i=4~~!lo~n~1:1~~.t"'.~ --
ll?vl?lc::.
LiiJrinc:;
to.p:- F~~sibilit:t..
Stud~- ;
six ",ltern<\tiv~s w~rl?
!)rnpo'::ed.
u~ing
ninE'
i~ow.. I
. .. .
c r. 1 '. E' r 1 ~ .
OVf?r thl?C::l?
rompliancl? with ~pplicable or
rel.E-v~nt <\nti
~pproprti'\tE' requirement,:: or AR~~s.
B~~ic~lly Wl1at ~h~t i~
th<\t a reml?dy co~plie'::
is ~n ev",lu~tion to makE'
sl)r.=.
with other environmental
st<\t1.1tes,
such as
air levi?ls,
w~tf?r
l!?VE'ls,
<\ny otni?r
Federal,
stat!?;
loc."!l
c::t.<\tutf?S tn<'lt
usu~lly tend tn go with the one that is
:'night be in
pl<\(~f?' .
lla:Vmcing
crij-,;>r:~.
other criteria and you
alt.ernativf?s
arl? aoina
coc::t f?ffective.
C::03fe drinking
Cost is primarily used
as ""
r.ncE' you h""ve
ev~lu03ted
~11 t~,::.
~.;y find that sever~l
to achieve the s"".m~ resl]l ts;
YOii
aoina
tn be
mor.=.
Imn1 prnfo>ntahi ~ ~ tv ~~. hnw
0...- - ... - ." - - - . - .- - ...
€-~~i:y
<'I
3?
-------
Attachment D - Pa
-;
4
~
;,
-
.
'"
t:'
9
4 '"
.J.lJ
4 4
.I..J.
. ...
.l:t:
:;'3
. .
..L~
:5
4 ,..
.J."
17
4 ...
I. ,,,\
4 ...
.1.':7
... ...
1','1
... .
~J..
2~
""...
t!, .)
... .
.:;~
~'5
r ,- r";-!1 ~. .~. \::;; n 1),;.
.
()O~~ .
wona-t~rm ~ff~ctiveness ~nd
shor~-ti?r~.
~ff~,..t-ivr:-n~~~ ~rr:-
f~irJy ~tr~igh~foL.~r~.
Over<'l,ll
p1:'otection of hUffi<'ln he:;:'t;~
~nd the environ~ent,
th~t.'~ tr1 r:1~~f?
S'-lr~ yo~-~ -..:i l :.
r:ll'"tll"l'':v
.. . .-. - --.
t1li? cont~min.:!te~
,; ~;:;,. r-. ('";
reduce
to l~'Jt?l~
t ~-~ ~ ~
longF?r
:::I ris~.
Reduction of toxicity, ~o~i~i~J
or volume;
~nd th~n
Stat~ acc::ep1-"InC::F:-
and c:: 0 Tn ,:l1,tn i 1- Y
r:lc::c::;:.~t<'lnC::i?
Now;
th~'5':'
last two .:!r~
uS11.:!1:'y c::onOIII"' t eo
or e v i'I 11.1 ", t e d
durina the
public::
j:..s E?A
c::omrnent period.
r~ceives comments;
we evall1<'1te
them and ;;:Iddress
th...m.
;r;n ~s
.. .. .. - . ~ .. .
naroJ.Q ~en~loneo e~r.J.l~r,
0: t~~
they bi?c::o~e p~rt
re~ord
of dec::isi~n in the
~~~
responsiven~ss ~u~~~ry.
in st?veral
instanc::es
thi?Y
have actually provided i~'5iCJh~
for EPA,
selected
another r:llti?rnAtiv~ or
and we
h~vi?
~odifii?d an alternative that we oriainally
n'l"'C"H,)(,\C;Pr. .
. - ..- . . - ..
For this
... . ..
p ~ r " 1. C 1) J. ;;:I r
.c;it.i? w~'r..::-
primarily loo~ina at contamination
that's located i~
those ar...as within the first few
inches, up
to nine
f;.~t"
'dep.p.
around wat~r and surface water
!5;;~r~.:-~ di..;
Since
not indic~t.,=.
4- . .. . .. - .. 1:
any con~amlnaGlon ~nr:lG W<'IS r:lOOVi? sr:I..e
drinkina water
it's not. Gon~ider~d a probl~0 ~t
levels,
this site.
nOW"='V81:',
Oil4=? t.o
t.Di?"i\",rs7
. '"
~II
i
I
I
I
I
I
I
I
I
-------
Attachment D - Page 42
conditions, you ~~n'~ tot~l~y @li~inat~ th~ p055ibi~i~y
A
that th~re ~~ght b~
co~taGination in th~ ground wat~r.
:3
So, wii
will addrt:'5!".
t: !1 .; t
in a S~n51? of !TIoni torin~ tj,,.;>
4
gro1J.nrt
TN;; t I? r, bl.1 t
not in
tryina to r~m~diate it.
15
So, pri;:-.ari:y
w~'re looking at
~
n
rl?r:'F?6iation of
thos!?
f1V~ ;;r~~s O~ ~D~ sit~.
i
Th!? six alternatives that
were
8
~val1j.::lt;?c1 "ooIi='re:
Number onl?,
th~ nO-.::Iction
a:tr:-rn~ti.v~;
c;
'Nh~'(F Dc-,thing is
donI?
~:xc~pt
. . ~ ..... . .
ITa n 1 m.::l J. a c '., 1 v 1 '. 1 e ~ .
;"nci
. A
1. ~ I
~.:: ao oVF?r ~~ch onl?
of tt~s~ in ~o~~ d!?tail.
.. ..
.1. .1.
A:ternativl? nU!TIber two, which is institutional
cont.rols;
12
nu~b@r thr~~, cont..::Iinment by installing
a 1<. eRA
cap over
1,)
th~ contaminat~d areas.
N;u"ber four is
tile rr:rncJv~~ ~!1f~
. .
.1"
~ ~ . ... -
o L .!.. - ~ .!. I. ~
disposa: of thF?
c~~~a~tn;;t@d soils
in ~n
15
~nn":(,)VF>c1
" . . - .
landfill.
Numb~r fiv~ is th~
on-sit~
t.rl?at.m~nt
16
of thl? cont.aminat~d
soi15 in th~ CF?ntr.::l: ar~a,
which
17
h.::lve tIle organics,
and t.he
off-site
dispos.::ll of th~
. ..
l."
m~t.al-("ontaminat~d
soils.
And then
finally is th;?
. ...
1.:J
off-site incineration of the contaminated
soils.
2.0
Alt@rnative number one, thl?
6.1
no-action,
is re('!1.1ired
by C:~.CLA to
be evaluated
a.t all
22
Sup e r f 1.m Ii
sit~s.
;'.t thic;
site it involves the
23
installation of eight on-site monitoring wells.
And
24
th~n' thosl? w~lls,
along with Boutwell Springs, wou:d be
215
periodically monitored for ~ period of thirty
Yr?~rr::..
;:
-------
Attachment D - Page 43
.
-'-
;. not: ;-, ~ n
r: -v- r? i.'" Y
~ .
J i V;;.
yeAr~ ~ ri~~ ~s~e~R~~n~ wnu:~ bl?
...
.-done t.o en~t.;l-~
th,:;t
no cont~~in~ti0n wa~
h.;. i ri 0' !'" r? :. ~ ~- c; ~ 1-~
-'
from-tho:;>
~it:,::..
.
..
;'lto:;>rn.::ltivl?
nlJIT,bf?r two i ~
5
institutionAL
controls
w;! i c h
w 0 iJ l (1
:i~it
~ 11 t? ~ C ~~ ~ .; s ~ ~.! ~ ~.
,.
I:'>
h1.i.1"1<'1r.~
"Ind ':;'!1i;n.::l:'~ h<'ld
to th€ cont<'l~in;:;tio~ on-s~~~.
r:.
WE-ils..
the periodic
. .. .
'0on 1. ,..or l na .
But. thi~
t ~r..I~
- .. '- .... - .
~- . !:. "","f"""
I
I
I
I
7
Aa.::lin;
i two 1.1 1 d
i nvol ve t.he
eiaht on-site
. .. .
rr. 0 n ~ '. 0 r :. n a
...
:'
t :-10 lj ~ "" n d
foot fenc:'i?
'01'(':.1110 bf"o
inst.::lllleo
<'Irou"cl th",
. A
. "
perim€t.~r of th€ site;
<'11('):'1('7
. - . ..-
. ..'
Wl' !l
wArnir!s .;;isns.
. - ~
/"'.. ,: ! ~. j-
. .
.1 .L
then restrictions wOllld
be p~~ced on the de~d li~iting
- -
th€ us,::. of
t n ,:> T'HO f") T'H:' T" t. -"
.. - .-- ".' ---.
.:;.nd the ~ssoci;:;t€n
around w-"\,er.
3.3
Alternative
n 1.1 m h F' r
tkrE'€
i~ ;=,
. .
..!..~
l~n<1fill C~.~; ~~
; s"lid earli€r;
OVf=or t:,.::-
<:: ,"' n t i=t r~~ i Tl ~ t ~ ~~
1:;
-"\re;:;.s.
It would involve thl?
excav~tion and tT"An~pnrt of
:;'6
the metal contaminat€d soils
into th~ c,::.ntral ar~<'I to
j,7
con!';olidate ~.ll
the soils.
And then a clay and
. A
~"
syntho:-tic linf?r
-- or excusl? me;
a clay c;:;p
-- ;:; c."!p
j,9
~ade out of clay and synthetic
liner~ -- woulo bF'
... ...
C::.\J
anstalled over this are~.
And then
sj:,f?dt=:'~.
.....
~..L
~n -'\odition;
sin ,~ €
~ont~TT\in"ltion
22
woulf h~
still
on-site,
a f~n~e
would be -- the sit,::.
2.3
would b~
fenced
to limit. ~~cess.
~~
;:'aaii1; pl?riodic
monitorina
w r:J 1.1 ~ ~j
25
be r,onoltctF'd.
T11i!':
ti!'!'1F' ~t
Bout.wl"11
.
Sp-rinas;
sinC',::. W~
, ...
-------
Attachment D - Pa e 44
.. '"
.l "
.. ..
.L.1.
12
i3
~~
.. ..
...")
16
.. -
.1. ,
.. ..
.1."
.. ..
.L:>
,20
.~1
22
23
24
~?
..
i'lr", nc)t
on 1: j,..;.
~i.t"~.
rn n n ~. to'!'" ; r,!] to;?~. ",. ~
!lropo~ i !'!]
p1\t:t:.in<]
...
~
~lte!"n~ti".~
1:he \.,ff-c;i~;:.
four is
'3
1!is!lQS-'ll c-.f ti',,,,
cont:~min~t~d ~oils.
invnlv~
This w01.11d
.
..
th~ px~~vation of th~se soi:1s and the transport
to "I;'
c;
~pproved :~nGfill.
D :,: r i n g t L r: 0 p ~ -: ~ t ion s r t; n - 0 n ;:; it c:i
,..
"
r- 1.1 rl - r) f f
WOI.!:1 c1
be controlled by
.
,::j ~ ,-:
rhese di.~,~h,,="~
w~~~r
-
I
h;;r:ns,
..
"
The out1yin!] Rre~ - AreR on~
.:;no
,..
..,
~~~\} -- t:.o::.~~
~ r. ~; r ::: ,,: i r:1;:; t i? 1 y
n"~ hundred cubic yards:
wh~r~ the cencrR: RreR ~s ~pproxirnRtely sev~nty-four
hundred cubic yards.
Sinc~ soils
are beina remov~d, w~
'.1 0 It 1 d b r i n :,
trf:,ateo on-sitr?
;'n~ it
a TI\et.hod
. . ~ ..
s ~ ;n ~ ... a r '. 0
would be
wh~t Jeff show~~ you
...=IS don.:; b~fore.
The soils would be ex~avated in
t.renches
.=Ind put in nne-fnot lifts and
then rotortilled.
';nd once
it w~s
t.hat.
~he ortJ.:!nic~
h030 b,,=,~n
c1eter!!1ined
. ~
.. ,
-------
r- -
Attachment D - Pa e 45
:n
11
. ...
..L~
13
. .
.!.~
...
1'5
16
. ...
J.. I
18
15
......
i£. ')
... .
.~ .L
22
.. ...
I!. .)
24
:'5
.
,
r~m0v~d~0 th~ :~vels that no
lonGer
pres~nted a ~is~,
...
c.
they would
.:.. n r1 t 11 e n <) T1 ~ e
h~ r~pl~c~o in th~
tTench~s.
...
..'
that
the e!'1~ir~
sitE' wn1.lld 1;;:.
~o'tJt?rr:-\4-
cor:-;plet"pc1,
-w~.s
4
with
VE'g"?'tatE'Q.
t.op soil "'Ino
'5
;'ga1n,
t. 1'1 ~. ~ ':,J e
did:1't"
to ensurE'
6
rT".isc;
w~tr?r
we would do fiv~ years
;; n ..., :- 1-, ; !': r! .
'--... -.. -". - .
of IJ r ,)i.1I1d
7
moni~oring at Boutwell Sprinss
.=;nd pl.:tc~
d~~n.
....
~
-rl?st"rictions on
thr? prljpt?rt;{.
9
fin a 11 y "\ 1 t e r i"' .:t t. i v 0:-
;n<1 ~.(l~n
W (! i c r1
t~~ off-sitE' in~ineration.
Si;":'\il~r
is
t.o w1iat w.:!c;
proposE'd
altE'rnativ~ four.
the excavation and
in
transport; hut
this timE' instead of
tt: a l~nnrijl.
going
it W()i1.~d CJO to
incinE'rator.
an approvE'd
" .. ..,
~n('". J. '. S vpr~'
hare'! to h.:ln(;l~
rn r? r i=i : $ t 1-j ~ t
".J;;>,Y.
So;
t-C) ~n~l.lr~ t!1~t ,:,.j~
didn't ~iss anything
all thE' r~sidua: ash
that time;
from thE' incin~rator woul~ bE' disposed of in an approvee'!
landfill.
~g,;in;
as in t.he
othE'r
alternativE's; soil would h~ brought in.
see(~r?d .
Th~
aonitorin~ would go on 03t Bout-wE'll Sp-rings.
And then
deed restriction~ would be ~lac~d on the
prr:~~erty .
Once these
propo~ed -- I'll ~ut
t.his hac'\{ up so you
can loo~ at it. again --
7rli?y'rf:?
F.'ValU03.ting usin
-------
Attachment D - Page 46
. A
~ l)
11
. ...
.L~
:;'3
. .
~;
16
:;'7
. A
..L~
. '"
l."
... ...
~ \1
,..
~; L
... ...
~. -!.
23
24
.....
<..,
l.
'.
thf? envirnr.f"e;",!t.,
r.r.-.vi'1>" ~(,
- -
th~ altern~tiv~ onl? w001d
...
t:,
proto?ct.ion.
~t would leavE cont~~in~tion
,=t r: r: ~ s 5 i :; ~. -
3
and, -'there fore,
~:~poc;~~ ~;)
you couldn't control
Wf10 wi3.~
4
it.
:;
~l~erDativ~s two ~nd thr~~
h
provide
~ :it.t.:t? ;r.ori?
protec:ion,
be~~usl? th~J'~ ::~~~
7
t}',ey do allow
cont~minates to r~~~i~
.:'Icces.s.
iiowc?ver,
A
....
nn-site,
~igrate off-site ~~~
T.7h i ch ('01.11r1
pv""ntl1"1~ly
9
ris~.
pr~~~r~t
~ n ex!' 0 S :.1 r e
Alternatives
fivp
;::;n~ six
fourt
arp the opst.
at prot.pct.ina hu~an healt.h in t~e
environrnl?nt,
becausp t.hpy do remove wastf?S
fro~ t.hr:>
, ...
~:; , e.
~s for reduction nf tnxi~:ty.
mobility "Ind volume,
aaain,
and two
alternatives one
provide no reduction
in any of th05P criteria,
Alternative thr~E reduces mobility,
, . .
oecaus;:- lJ:
!1r~\,'"':-T,~~
the infilt.ration of Ground wat.er,
w h i ,~ n can
carry
contaminates off-site; however,
it. does
not. reduce th;:-
¥-oxicit.y or the
;oain,
four,
~:'Jt?
alt€'rnativ,::>s
voll.1me.
and six achievE'
criteria.
;,.' '
'.. :-.1 s
~i1 or t t. erm
effecti.vene~s,
alternatives one and two would be bf?st, because
th~y
W01.1lci nt? onne in
a f.:'lirly r"lpid amount of ti~e,
A1t;:arn~tive
....)1; 11'1 pr0'::><=ibly
lon~~,;t.
n.- r.:; '.: :; oo?
bl? the
~h~=?f?
-
I
!
I
i .
-------
Attachment D - Page 47
J.
"
J. ~ TeN 0 U : (~
r I? q :.1. i r ~
~0~1'1~
of th~ mo~~ int~nsiv~ ~ons~r~~~~~n
""
-E...
a.t. t.hF? site.
;-,"~':;IlSF?
y 0 1) .. 0 I , '1 :,i h ", v ~ ;: 0
bri,,~
in t: ~.!.-?
~
-'
mat;:,I'"i,,} and
the liner~r
and "" 10~
of "='01]; 1i""lr:.n t 1.1(")\1 ~ ..:;
... -.".- . .. . ..-
4
need t.o hF?
involvF?n.
.~lt~!"n.:;tivec;:
four;
fiv-," and six
I)
r E- q~.I i r I?
so;,"e
c:' 0 n s t r'.1 c tic n
~.nd. h ~~. V~l ~q1j -: ~Ger~~.; b,.~ t
,..
n
tl-1f?Y' ~F?
!';ort:
c. f i !! t: 11 >:>
0id(:'::i.~
of ""lterI1.:;,t:.v~s
(") n ~ ~ ii ~-~
7
two and
three.
8
~;nli~r 5hnrt--t.t=-~:n
eff~~t.i'v.~n~:;-3- ..
,...
:'J
.. . .
" n ~ r E' ~ S
A r,r,c:;... i n~ ~ -; tv
.. . . . -'. - - - '..
tho?~. workerc; "nd
ne-"!rby r/?!';ino?!1ts
1. ,)
COI1LCi 0e
f?xp0sed.
But ",nything th~t ~~y happen wou:d b~
.!..L
"'Iddressf?d
in
the he"'llth and s"'Ifety
plan that
would
bf? in
. ....
.LG
operAt.ion
d 1.1 r in IJ
any a~t.ivities "'It. the site.
1.)
.::-s for lonIJ-t;:,rrr.
t?ffF?~tivt?nl?s~;
~4
A 1 t ~ T r~ t3 ~ "'. v ~ ~ f v'.. r ;
five and six achi~v~
t.11~ ~)r?5t
. ..
l.')
eff~r.tiveness be~ause they do remove contaminat>:>5
from
16
t.he site;
while on 0:> ,
two and three leave ~ontaroin"'ltion
. ..
.J. I
on-gite.
. ...
1-1:\
:mp~~0entA~ility,
~.lter!1~.tiv~'5
19
one and two are rather
difficult tn
imp'1~m~nt. in reG~rr.s
,20
to thF? crround warpr wells.
Bec::",lIge
1.1~ ",r~ o~alina wi~h
....
. ~ J.
a ~arst.
sit.uation.
WhF?rl YOI.\ t.ry t.o
put '"
. ... .
mon1. ',or~na
......,
,£,G
wpll in
!J~olo!JY of
that sort;
you lHlve t~ o~
sl?ver",:'
... ~
G .~
dye-trac~ st.udi8g to ma~f? sure that you have put in a
2';
c~nduit that contains around wat.er that
ig i'\ssociateo
25
w j th
t.h~ site.
'i'l1E-rr:-'s '"
..::h",n~E'
r h~ t we co.u'1d be
. .
..,...,
-------
Attachment D - Page 48
.
J.
tluttin6 WE-~:C:;
ir:;
r i1 n n i n I]
~y@-tra~E- ~tudiE-~.
h .=\ ~.j :... :-t .:; ~ r.
~
t:.
move w~~~s
~ro1J"d. ,
~rlc.~ ~:-l,;t c;nulrl
hr:-cofl'~
v~ry ~~bor
.3
i n t. e ~'5 i 'v @ .
~
Alt@rnative thre~ is ~150
5
diffiGl11t
QUr:-
~o tr~~
Karst sit1Jation.
7h~ actua}.
I;
con~truGtion w~u:~ not be
d iff i r. 1.11 t. .
nOT.Nt:?\"~r ;
due to
.,
/
the
faGt th~~ ~inKholes
c01ild dev@lop
0n-~it:~..
i t W(/~.l: .::.
~
0~ v~!.y
h~ rd t.o
'n 1) i ~.<:: i'I r. -3 pSI) t h.:l t.
~ f"1 ~ i n ~ ~ a O( i t Y
W(')1) }_\.~
;
pot b~ d~~.,tJ~d.
.'5 h () 1.1 1 d
the !3in!{hole
oT"len i):I.
." . ."
11,
Alto?rn03tiv@
four,
fivt?
""fld six
. .
J.J.
o?rl? Ok03Y.
But thr:-Y
will rl?qu~re so~e
equip]'T1@nt
bl?inl]
12
nroul]ht in.
In addition1
it wo 1.11 c'! h €
dl?penc:1t?nt
on th@
13
abi~ity
of tr!~
landfi~l 03nci th~
incint?r~tnr t~ ~er.~~v~
. .
.:~
tho?ir
W;::I.stI?S
r"'1~ en
we pr~par~d to transport th~m.
1.5
Complianct? with ~RARs.
.. '"
1.1')
Alternatives four1
five and
six meet all Federal ARAR~:
17
whereas1
on~,
two and
three
leavl? contamin~tion
on-sit,,=,
. ...
J.I)
anc'! do not comply with Federal ARARs.
13
;'s for cost.s;
alt,,=,rnativl? onE',
~n
-~ and five or fairly
inexpensive;
whereas;
031t.ernative
....
:',J.
thref:> is
moder~t~~y
high d~~ t.o the materials
th"tt. ~ro?
22
needl?d And
the construct.ion
costs.
;'nd then
23
alternat.ives four and six are extremely high,
due to t.he
24
t.ran5port ~05ts ~PO
the c'!ic:;posal
cost.s.
25
~s : said
eo::l.rlier;
st;;lt~
...
.. /
-------
Attachment D - Page 49
10
. .
J. ~
. ...
.,L r ~ f t? r r ~ d by
E?~ is
.:!It''?r~ativ~ nu~ber fi~~.
~nd ~r~:..~
.,
in c 11.1 des
the off-sit~ ~is~osal
of t.he ~etal C::0nta~i~;;~~~
7
soLi.
wit.h aeratio<1
of t.h~
on-sit.e
and thE'
trE'at.TIlent
"
.,
orQ'.:Inic
soi~.
a~tern""tivo?
We sel*="ct;::>~ this
COT'\ t.::l!nin.:!t:'ed
9
a majo-cit.y of
the ~iD~ c::-citeri~;
ht:'cause
it ~oec; meet
~ .-... ..
.:;no 1. 1S '..11~ mos...
cost. effE'ctive.
Riaht now we don't know how the
co;nmunit.y or thE' St..:'Ite
feel .:!bout this, but we will by
the end of
the public comment period.
... . ~ ..
~no w~ W1.L.'-
,3cJdres~ it.
.. Ii:" . .
recoro O.L OeC1$10n.
i.n t.h.::-
7he way WE' would
0'0 about
i!'!'lplementina
five is w*=" would beai.n wi tit .=I.
.:!lterT1i"1tivi?
0ench scale treat.abi~~ty
study to ensure that this wi:l
"Ictl1ally wor~;
rather than aoina out. there .:!nd spendina
~oney and then finding out
that it will not achiev~ th~
;8Mls
that we nepo it to.
Should
we have 03. prob1.e!T', which
would be hi~hly
~.~ 1. "t ~ \... . ~
lln.l'li(F.' y, oec~use 1... n03S peen snowCl '."
be fairly
so far, should W~ wind
eff~ctive at t.h~ site
up -- or,
excuse me, should the
treat.03hility
st1.1ci.y !".how
th~t this
(')ver.
;.fr~~ ~1!r-
!T'iaht
-- ~~t T'!11?
<;~i'!rt
not no:.
48
-------
Attachment D - Page 50
t r ~ ~ t..~ ~) ~ ~. i t Y
:; t "11:"1::" ;
if';' t ~ ~l (, '", ~
t ~1 ~. ~ i 7" t c; !' 0 t
0~~~0 ~8
'"
~
..>. wor/{ ,
wh.:it Wi::
would
t1-.
-------
Attachment D - Pa e 51
. '"
2,,\1
11
12
. ~
. .
J. ~
15
16
:7
. ,..
1."
19
20
,.. .
-G .l
22
,.. ...
~ .)
'" .
~.~
G5
.
.::\$ it r~:!..~tl?;;:
to h~z~r~o~;;: w~;;:t~ ;;:ite;;: ~n~ Sup~rfun~ ~"d
'"
~
Si'lv~ t.(!t? bl1:!..i< of
goinCJ
this o?veni!"!<::;
wh~.t
1-0 do
WI? ~rE'
3
for ~ny qUI?$tio~~ y~u
~ll miCJht. ~~Vl?
.;
I don't
work for EPA,
I wori{
with
5
Public H~'tlth
1-.nd if you h~ve
rf?~d the
tho?: U:::
SerV~,-Cf? .
n
1 f? CJ i !=; i ~ t ion <) n S 11 P f? r f 1.1 n d, you' 11 fin d
th~t whf?n
..
,
Superfund Wi'l$ crf?~t~d hac~ in 1980,
,!\., :~ :. r:-
th~ ACJf?ncy for
...
(\
:::; 1.1 h $ t: .:! n c f? s
~nn ~i$ea~~ ReCJistry was
intl?ntion",.lly
5
wor~ with E?A ~$ a sep",rate but para::~:
C"rf?~ted to
hei'll t.L "Geni:~' to interpret ,,11 tho?
di'lta th~t. cn~f?S forth
fro~ the C"ontamin",tion
and risk
assessments
assessmf?nts
and stuff -- that Mary Jo h~s al1ude~ to -- to try to
.; ':"'I t ;:>""'[")'1'"':'7
-. - . -.- - . .
the re~l time public
'he~:~:-,
the d~t~ for
t~!~~at. i~plic.;.tions.
function
~ s ~ c () n s 1) : t '" 11 t:
So; ',.1t?
~nd also ~s ~ hf?i'llth advisor to EPA.
I represent.
my ~CJency in
RI?(!inn
.
~.
And hl?hind us
of M.D. '$ and Ph.D. 's
we h~vl? a lot
.::\~d toxicoloCJists
and that sort of stuff.
\le'r.:> in
Atlanta.
The sister agency to us is the Cf?nter For
;is~i'lsf? Control, which you may have hl?ard of --
a bOil 7.
five thousand peop1f?
Thf?y're expertise is in
infpctiolls disei'lsAs; while ours is
in the environ~ent.:!~
public hei'llth as it relates to the chemicals in the
Anviron7nt?n t..
I wanted to sharA th~t:
~i'I~r.~'J
... -.. -..
!::'"
."
-------
Attachment D - Page 52
1
O..;-I":Al.1S>i? 03.5
p;;r:--
of t.b~
p~oc~s~ thAt M~ry ~o
:.t~.~ ,:; ~ -:''Ir1~..-1
,t,
to - and that is risk
assessment, whi~h E?~
1.1$;;:-$ 03.5 0"1
..
-'
bpn~~ mar~, or w~y to try
to d~ti?rmine how to clean 0"1
4
hazardous waste site up.
We do something similar, but
'3
(n:f~rent,
in a
parallel
fashie.n.
~t's c.:illo?G
.;i. h~;-: th
,
n
aS~~S$!:1~nt.
..
,
On~ thing Mary Jo din
not JT1er.tion
...
I">
'..:,F:-n
c:;(,e o"Innrv
.0- '-
~ ...
..!. \J
O,;c:;pn.
.' ... .
is t.h~
~0del that E?~ ~'oosps
assuroes
th"'lt
peoplo?
'1 ,.
.:;r~ i?xposed
to cprtain
~oncent:r~tinns pvprv nAV
. ... . ..
of their
~ ...
J.~
life for s
alluded to, as was
alluded to earlier
ano 0"11: thFo
19
inves t i!J'a t ioo.s
that
hav~
been done -- that indicate
20
_hether or not additional health-related
t " ~ F>
. -. -
wor'k: :IF:-eds
...~
6.1.
to br:! done.
"..,
4",
. Q1Iici
-------
Attachment D - Pa e 53
~ ,..
.i.\:
~ ~
~~
..L£:
~ -'
~ .
~~
~ -
.1':'
~ ~
1."
17
~ ,..
.l. r:.
~ ,..
J..'='
20
...~
.~..!.
.....
~ !ft..
... ~
t!J .J
... .
~~
2S
~
E?~ ~n~ tt~ ~~.~~~.
we }.oo~ ~r
~:l tht? i~_~:)r-~..=t~i.")[.:
...
"
that's ~v~il~~):~ on thp ~ite;
rCi 1001<
~~.iri:~" if
trying
-;
-- wb.a t
ar~ ~h~ ~apulatio~s at most ris~ of ~xpoc;ure.
4
this particular site,
f9r the corn~Ql.Inds and thl? -
?-"nd for
5
co~centrations th~t wer~ id~ntifi~d -- at
~::'r~c:~. (:C71~~C~
..
"
ic; c;r;in contact:
- - IT. ;::i. ~1 ~'
wi t1! thf?
co)"".ponn,i
- - t" ~-l ~ t
7
nr fo:'~c;
!-,av~
and that sort
chilnren
011 ';',../.' 50
nf thing --
,..
"
a <:11 n::'<~ t
wit ~.~ t- 11 €'
-- is th~
;:-05r
'rp;=;-:_ic;7': ~;"
~oil
cont."lct
...
:1
s,-::e!:erio that
exist.
e~":!1o c:; 1.1 r r?
On~ o~ the outcornl?c; of
t ~1 I? :1 ,;> .;I. 1 t h
asc;l?s~~l?nt -- for
those of you
rl?lat.ivl?
that a~e hl?re,
to CCincernc; ~bout health
-- is
it saf~ to live in the
~O~JTli)n i. t.y;
tCi (~rink
c; or t.
.: e., J:
.J.. c; l '. S a 1. f?
the water
a n ('~ t r! ~ ~
of tr,:.r'!J.
h.:ls:c.;lll~'
.; n (j t. 11 at' ~
w1~~ t
t!! ":"' b ~.=t :. t ~'i
assessr.",ent
is Sl.1ppos!?d
to determine;
which is '..;hat
w~
try to 00.
Th~ outcome
of wh.;lt we 'VI?
donI? so
far;
avail;:;bli:";
is "oJe
based on all th~ data WI? have
really don't c;e!? any indic.:Ition that there's ~ny
:.ignifican~ rl?al time human health
threat ~osen tn ~h~
arl?a citiz~ns in
~ ...
r e .l. a,.. 1 v e
to thi~ parti~ul~r
Cr?cilia,
sit!?
on!? of
th!? things
that th!? he=l~ t~-
rf ther!? wer!?;
ass~s8!'!!ent. do~s
i~ recommend additional health studies
and fol~ow-up to be
I?x-....orkerc; or
done o~ populations or
such in t~!? aeneral
co;n!!1u~ity.
5:
-------
Attachment D - P~e 54
.
~t:'!3 n~si('.;:;ll:: -'I 1'';>-'l1t.o study:
'"
~
and .:>:-:~o S 11 r F:' 0:: 1.i):V~y .=I r> d t: i103 1: ~ 0 r t
of ~hin~ th~t
01.ir
..
.'
~edi('~~ fo1~~ i~
~on~;:>rt. wi1:h
~~p ~pp.=lrtmF:'nt of
-. ~ ... ~
11€'-'I.L'~
4
Resources, Hu~~n
RF:'sourceo:: in
Fr~nkfort co1:~horatp. on
'5
to try
to cJ.~~1 with
th<\t:.
6
:,t ::~is
poi.nt
in 1:i~p.: b-'l~pc:1 ~r>
-
I
-'Ill the d-'l1:-'I
woO"ve
!';;:>en:
ther;:> is no
il'ldici'l1:ion
th~. t
~
"
th;;t sort of
~ surveyor or h~031th
$ t 'J ~~ y
i<; W03!"rant€'G.
:;
But as ~~~itio~~~.
info!"mation ~o~e!3 i'lv;;il03ble.
either
. '"
.1.\1
fro~ the Stat;:> or
EP~: workinG A<; we do ;;s ~ ('on5ult03n1:
11
~nd 03dvisor to E?A on the health side, we would be able
. '"
l.~
to try to
int€'rp!"et <\0:: best
we can wh<\t cJ.o~s it me<\n to
. ..
.L ,
~ ~1 ,=. f ('.1 ~ s
in t:~2 co~munity.
. .
.1..,.
. I:
~ .'
':'nE CHA:i:Rr1AN:
Than~ you: Chu~~.
16
~~'re through now
with our formal present.ation, whic~ I
17
know will please all of you in this hot room.
Uh.=lt I
. ~
~"
would like to do now is
try to answer any
'1 i.l ~ S t. ion s
th;;t
19
you ::niaht h~ve.
Ifp~rter here, I'd like
~..
~.
-- ~om.:> up tn the front
Again,
since we do have a Court
20
you to -- to the extent you can
:21
~ f t ~1 e
rnom,
state your
name,
22
spell your
last naf.1e
the firo::t
time you ask a ~uF:'o::tionr
2.1
dirpct your question to me,
and I will attempt to
answ;:;.r
'" .
~. -
it: or I'll dire~t it
to one
of tht::' people up
from E? ~~
~ -
~ .:,
t ~'1 d t. r:: ~ Tn r=' 1.1 !1
t 0 11 f? 1 [,
1.1.'5 nut:.
tonigi1t.
e:;)
-------
Attachment D - Pa e 55
~ .;
.. ..
l.-,
12
.. ...
-L .J
.. .
.!..~
...
:s
lEi
17
.. ,..
l."
19
2n
.2 j.
22
23
24
..,~
G"
1
-
~. ...
. ~ 1. r ~ '.'
:5 () ;
qUE!~t-:Oi1.
"
.
~
:.
Ei
-
I
it off here.
to c;;t;;rt
...
"
s
Bn'o.
So,
. ~ , ..
!. '. ~ o"Il. W 0"1 Y '5
sl('lw gf:o~ ~ -in,:! :-;',.:.
.. -..... f -
J. r:" '. :~
~f:o'" who ~;::jn
~:L~1 ~~r:- ~~iz~.
THE H;'.YOR:
t.!~.. w3:~TJIA1~iS:
THE C~; IRr.r';i~ :
i'!R.. ~;~:W:LIAM$:
;;-I-L-'W-I-~-~!-$ .
I'm m;;gistrate nf
~ r..i \)n you r
~ominlJ
in you have -- prob;::jbly
th~ nn-~it~ or off-~ite di5po~al,
the rf:oasoning h@hind
-- th~t c;;orne of your
basically
this"
Is
pror.G'5als
a monitor of thl"
. ..
:5',).l.l.,
:I\oes t.his
Here's
my big ta1kE-:.
Oko"lY.
:'m 1Jn
.. -
1":0'0' r ~
Thanks,
I'm Bobby
"'- . ~ .. .
"'1.l.l.1~mS
Liistri~t
3 hr:>r~.
5 i j\ i; 'I~ (1 r) 0 S ,; ~. ~ i
- ..' . ,
..!. '.-11 ~ n r\
indir@ctly -- ho"lVf:o ~hosr:>n
numbAr
five.
Wh,:j t. ' '5
maybe one
of thl?
reaso;"l<;;
- ...' '"
l. nO'.lC'::>O
j 1] S t
inclu<1,",o
~om,=, of them the
Wo"lt.;.~.
t;::jk@ in 0"111 threE':
Soil, wo"It.er,
o"Ii~ -- ;::jll
three -- the monitoring?
could.
THE Cr:~~~.i.I~i,.:
Ho"Iry ,jo,
if you
I
I
I
-'
I
i
I
I
I
I
I
I
1
I
~.:
-------
Attachment D - Page 56
~.jS .
?Ei;I~~ :
1.
,:;~. sorry 7
. .
~l::;~~n
2
- _th~
v~ry
. I:
,:;>nQ 0,-
::,. C) 1.1 r q i i ~ 5 t. i () n .
..'
~
, M~. WILLIA!15:
Y01.1r
diff!?rl?nt
:;
p1:'"i)pi)~a: .:;
-- v ()",! :"nn...
. -. - .
Y"'1.. "( f i v ~ (1 r
~T n lj r
six d.iff~E.'"':':-'~
f5
prnpn~.:ils.
j T"\ntice you
recomm.=-noed --
YOll ..Fr;::-
..
.
rl?comjT\E! i c k y
and I talked about before
WF co;n~ i. n ;
rei'ldins
1. )
it over;
tid", wc,iJl(i
h~'CJ~
prob~:")1~- h..;..r=:-r;
. . -
'Cll~ onr:- 2.
fN\'"):) ~d
. .
, ..
~1 ~. 'l e c ~! ,') ~ ~ :1
too.
; ... (~ a 1.1 s !?
~.h~ rf?a ~or-! 1:
. .'
o.:=\s-':-'", ~'-~-
.:. ~ ;;":~ ".:.
1S
go into
more of ::-'01.ir air
-- you
know;
!T1nnit'nrinG ti"Jto?
;;lr
. ..
1."
and monitoring
t.he water.
And also
the soil.
. . .
~~L
thr!?e
. ...
.!,.
of tho?se
natural
resources here.
. ,.,
~ .:'\
But what is
the reason hehind
19
mayb~ why you all chose this one?
... ...
. ~\.J
... .
.. ~J..
i1S.
?EiJICi\ :
~h@n I ~ut Dp th~
7::':1,:;>
~z
. .. .
c r 1 '., e r l a ;
we had
comp"lred
all of
the alt.ernat.ivies 11.sing
2.3
those nine criteria.
And alt.ernatives four,
fivE:'
,:;no
24
six ar~
fairly
clos~ in
rnt?;.:>t.ing all
.-. ".-'
'., n e r. r 1 '. e. r l.:i .
2'5
However;
if you notice;
.:iltern.:;tive
nl.lJT10er fivp;
. 't. -
I. ;~ ~
~ ~
.., ..,
-------
Attachment D - Pa e 57
. f"
.LIJ
.. ..
). .L
12
13
.. .
2..":!'
15
.. ,
.Lt:!
17
i;
19
... ...
~.J
21
2~
23
... .
~~
25
1
,-
pricio?- is
;;;0't'"t
And t.~i~t. w,;::;
<'I lot ...low~r.
...
I!.
bt"e"'lk-t.hf:'-b.=tc:::-:
cri tp~i~..
(~ f t h ~
-'
>;hf:'n
YO!I h<'lv.=. "! 1 t .=.rn"!. t ivies nl"'17
4
are going to reach th~
same _go_al~,
it' 5 hard t.o
justify
5
spending nint~~~
do~l.=trs, wh~n you
!.~1i: l iort
;;
somf?thing th"'lt'~
a ~illion dollars.
;lndE-r
h.::lv-::
7
And a1tf:'rn~t.ivp five will be
(\
e . - .,
,"'I-,r,V nI1lr:"
- - - - .. <- ...
t.oo;
which w.=ts anoth~r
P ll.1 ~ in
.... ... ....
'..{) 1 "'1'.L emen '.,
9
its ["'I'lor.
TiiE C:jiAIR_H~N:
Ann, Bobby,
alternative nu~b.=.r
~. ..
~lVe a.!.so,
since we
~~ least the ~AjGrity of the
rnat.;.rii'lls
t~~~ up ~ny room fnr incineration of rnor~
~ ...
m a". e r 1. .:I .L S ,
it won't.
fill up our landfills with
l~ss
toxic m.=tterials.
Again,
we thought
the t.echnologi~~;
it's
probably
the best
try it in,
at the low levels of 50i1 --
i-tR.. wrLLIA!.!S:
Well,
will be treating
. ~
on-81', e,
it: won't
toxic
-- looi
-------
Attachment D - Page 58
. I
.
...
'"
3
.
-
6
;
...
"
:;
. ...
.L \.1
. .
.L 1...
12
. ~
, '
. .
.l.~
. ..
..L ?
. ,
.Lr')
:l.;
1~
:i.9
20
.... .
G.l.
... ...
G.6
:2)
24
:5
- -~-~- ------------------ ---
,.
fig 1.1 r ,;.
fi".J~
tori?;:>
~ nF:i~vto?:
relat.inn t.n -- nn~ nf vnl1
- -. . -. - . - .. .
h€'rE',
~ forSi?t ~h~rh on~ -- Stev€';
thE' nnE' na~ed St,;.Vi?:
. M$. PENICi\:
.jOF? .
HR. ~j~uLI;'_H$:
.joe.
~;~'!~n Y0lt
aiv.::
out thE' topog~~phy of thF? land and
so forth,
on somF? of
thE' cor,t;;,iner!'; on-~~t.;:.,
~nQ some of t~F?~ WE'~F.
i 1'1 011';' h 5. C!
pil~
p.:.riodiC"::\liy
!;C::~.t t.~r;:-d.
in thi?
. 1 .. ~
TI'"11. 0. '-:".. ~ t:-
~nd !,;O!'"'o?
Wf?r;.:-
i"Iround,
. . ..
11 r'I"", ("J n '. .
. .. - -.. - -
~ny re.:;soning
;:i" Y(1) think th~re' s
behinci this?
Or why these w~re distribut~d in this
area?
so~e of the~; YOD know;
t. he in d i v i d lB 1
You :o n,:.ver Wi:>T1
.. ,.
1."
not.hing
in my
life.
17
18
!~E C::-i~IRi1AH:
i; o?)C t (!I-I t? 5 t ion (
19
please.
... ""
4 \.1
. ~ l.
1'011 ~i'!ITR:
Tom Smith,
S-!-!-I-7-R.
......
~4
I've got a question
on what parts per ~i:'lion cyani~~ is
... ...
~ .)
-- t.il':' t . s left thp.re.
24
... ~
4:)
iv!3. ~ENIcr:::
'00 yC":1.1
know
t:;-!~~ c)!1~
C:""
. 1'\
-------
1-
Attachment D - Pa e 60
. "
1..\}
, .
12
:3
1~
...
15
~ ,.
l.~
~ -
.!. I
.!..t')
l.9
..,..
c.:d
..~
.~.!.
22
23
24
~5
.
.l
-.
off th.- top
of Y01;.r
2
..
.)
1-I~.::td?
T!iE CnA~F_!'!~.i;:
,J E' f f, p E' r h .:t P !':
. .
~O:: I."
~
you -- I thin~ thE' ~uestion is: he
w~nts to Know in
~
..'
p~rt~ p~r ~i:.li0~
6
on-s::'tp i"tro?
7
3
"
:>
-- ~'d h~vp to ~h~c~
the 1.ev~js
of cy.;tnide
on-site
~h;::\t
t~1~ l~v~~s of ry~ni{~~
.. - 1:.
l.~~ '.-
MR. F: (j ., ~ :
~~ f~r AS 7 ~nnw
.t~~ .
t 0 be c:: ;,. !:' t Air! - -
C)ltt :;: b~li~.,;.t? ~:l
Are bi"!.OW O1"1e
!'Ji'lrt
~ . -
per ]'T\ j. 11 ion
in both soi1s .:tnd ~ny
w~tE-r
that w;:;c;
tested.
should be noted is
One of the thincrs th.=tt ;:;lso
that thE-re was
.. - ~ ~
SO~i" .lOW C~V'-IS 0.
\~y~~id~ ~~~t~ct~d in w~ter.
51.1 t t 1"1 t? '5 ~ ~ Z' 1 ~ '3 t 1"1 ~ t
w~r~
a1.so ta~en th.=tt were b;:;si~.::tlly blanks,
samples.
which are
control
~nvironm~ntal sAmples,
So,
they wi"ren't
WE-re control samples
y01l. c"ln't. positivE-ly
t.h~y
-- also cont.ained cyanid~.
$() trt~t
st..:It.e that. the
cy;::;.nide ic;
r fJ fi? r Eo
bec;:;us~ of the sit.e and th~ water.
But it ~ay be
. ..
, 11 ~ .
- . - .
.~e t.o l~.bora tory con t~mini'l tion.
and what I've he~rd
any concerns ~s f~r
-------
Attachment D - Pa
....
'"
.
~
,.
.,
...
/
,..
:->
~ ...
1. i..l
...l.
12
Yo 3
~ .
J.."
15
16
17
18
1"
='
20
.....
. '" .1.
22
... .
~..J
2?
25
3
:;
""
1'\
("C)n~o?rn .
.thf:' T'I"Irts
- .
- -
uno~~:stooc'J
ri~',(
'Nol.ild
- . .
\..:;0 ~ :-! 1. ~. f?
po?r :nilli0i1.
t.h~ ri:;~:5..
"'-'1.0:; thE'
C)Dr? 7
r,: ;:;. 5 w.; (') n d ~ r ~- ':"1 .:
- -. -' ~
...., ,", .:,.
THE CRA~~.l.!~-j~:
t.l-1 ~ r ;:. ~ }.
ri,:,'r
-------
Attachment D - Page 62
2
THE \~!i;7!t.~~1;!';:
P;;:orh.::lnc::. .';n0 (h-
". - . .' 40
..
J
gue~~ you ;:;r..:-
r~f~rrina to ~~y
springs in o~tN~~n t~~
4
site i'\nd
Boutwell SDrings?
s
6
R;;'j\;~.t G\~0~!.!;i;:
Yes.
T1!r?:--~'C; A
,..
''I
dnZE'D i').'~ r. k t.heri? .L . Vi? (Tnt. "" f::\r!T\ b::\~k t)1~ri? ~.;nh,,(": v
.. . . . ,..
npv.,.r ~1.::1 v,=. . . . l:~le;;, -3110 :i: t.CJ 1 ("j t j!
-------
[ -"---.-
I
Attachment D - Pa e 63
. ,..
~\J
.1.-'-
. ...
.I."
1.)
. .
'- ..
~5
~h
1.7
:8
19
20
..,.
~.l.
......
t:,,t,
G3
,.. .
~~
~5
.
...
/-
3
4
southwO?st.
Th~re
'5
tot 11 t?
springs.
,.
'='
7
"
.,
;outwO?l~ Sr-rings~
,..
:"
tll?t
monitorf?n
WerE'
th~m and the cr~f?k.
t1~. 0 ~,!~-j:..: w :
~l!irj! (i-ir~\...tio:'i?
~.~;;~r.r
G t)('j Li ~.! ~ i'~ :
~. 1 it:' t 1 ~ t: i ny
":Nell;
would b~ a str~icrht lin~
through t;'1i?r.::.-
t1R. HULL:
Bl?tw~p.n thO?
sitl? .:Inn
F.~i;Di. i-::CJvD!,!;i..r:
Yp.:I_h.
t~!~., !.!777..J t. :
Tho?rl? ar~ some- sites
s01.1th--o?st.
R;"i..DY GOODH~N:
"It?a £1 ;
~'(Hi mon i t-orpn
i"!F.. ~~i.~l..'!J:
Ann thf?rf? ~pre- so~~
f~rther sites ~onitor~d farther to the west.
As far ac:;.
s.tsrincrs betwef?n -- Gir~~t1y north,
between BoutwP?li
Springs
and thO?
J'T1onitored.
5i te to
I havp? no re~ord that those-
wpr;;>
R_~HDY GOODrvI.:"i~:
No;
t;-, f>V
. ~. .-
w"'lsn't.
-------
Attachment D - Pge 64
.
...
..-
~.!~. I
r.!~;w ~ :
" i.l t 0 f ~!. 1 t h f?
r t;> rr. 0 r1 i tor", (; ,
.:I'J.:Iin,
the nnly ~ite
th,;;t.
~it-hf?r
)
. und~ low-flow or hig~-flow
~ondition!; --
tn,;;t.
hi'\:1 ;:\
4
po!;itive show of dve was Boutwell Surinn~.
.. , - .. .
~
~
;'nd act.ually
thE-rE- arE-
:o;.1r
.;
spring!"
f, e ,:; r t h ,.:;>
B 01.1 t w e 11 sit ~ .
i
~
R;'NDY GOOD!-!.:;':;';:
I've got .:I f.;tr':"1;
....
:J
r.VE-
got f ('d.l r
spring~ out. ther~ -- between there.
10
. .
.L.i.
Hi'.. !.!!jL L :
I don't know.
If there
~ ~
~~
are springs
thE-re --
tha~. the
field investigators
. .
.!... J
p~rh,:;ps ~j~n't loc,:;r~ thos~.
. .
.L..
~5
TRE Cn;' :;:~.H;'i'; :
o.loody:
bi'\!':ed upon
1.6
the water that's flowing into the sin~hole on-site, if
17
there were springs in between
BoutWf?ll SprinG!"
~. n c1 t. ~) e
. ..
~ r.
site,
would there he a need for concern?
19
20
L'!R. i.!ljL L :
With01lt
act1.1.=!lly h.:'lv~n
-------
Attachment D - Pa e 65
.. ,..
J.. \J
.. ..
.!..l.
.. '"
1..:.
13
.. .
~~
...
:5
16
17
18
15
20
.21
22
23
24
25
:l.
$ .;. t.:- . ,.
'"
~
3
THE r!i~ I~.!'!A;~:
.;
and show us aft~r
the m~eting wh~re
If you will co~~ up
you ar~
talking
';
;:! bOI.! t: t
try tn
l00~ into it: fer YOD.
. , ..
W.::- W1J..L
6
7
-.....-...
~ -~!... ':..1 !
C:O\iDI.!;'t~ :
,..
,..
.,
THE C~;'-~F.Mrti~:
fOI.1.r.
MIC~Y S~THERLAND:
5 ..1 t h f'? r 1 and t
$ -Tr-T-R-E-~. -L- ~ -i';-D .
:n r~p()rt nU;1'1bA~
O~ay,
... ..'
~I.1>;>S '. Ion
n1J~b;.;>r
Micky
fi ~.,~;
i n y ('11.1. r
proposal
fiv~; you
~tat~d you would monitor th.::-
nU;;1Dp.r
wells regularly -- or
the !;prings.
"r~gular:;'y"?
Monthly, quarterly or
r-r s. ? E~: i' C r: :
What
me.::1n by
do YOI.1
y~arly"
"'" . ~ .. . - ,
.:. y p 1 C a .L 1. Y 1 '. S
~arterlYt which would be oncp. evpr thr~e months.
MICKY
S(.;THERLAi~u :
th~ samples?
HS.
--..- --
r" ~'.d ~ \.- r\ :
Who wOI.1.1d t.aj(e
,.. - .. ~
~" to:': 1. J.. ;
.
it 0ep~nric:;.
,
'1
I
I
!
i
I
I
I
I
I
I
I
I
I
I
I
i
I
I
I
I
,
,. .
..,-
-------
Attachment D - Pa~e 66
. ..
)..\1
. .
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22
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2'5
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Wi?' II '0 o?
into ;1F.'aoti~t"i.ons with tito? ~.>-:,:o:;pons~.';;~,.;:.
00ing
..
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2artio:-s
aaain.
th<\1: they w~:'~
t hi? 0 P P 0 r t 1.1 r, :i. t. Y
'P1 e ~ i? i s
'3
go a1~ad ""nd fini'ln('e
thp. rF.'~i?di""l do?sign
~. nQ rE-~~("'i i;:a ~
4
alti?rnat.ive.
then thi?Y would hiri? a
Shoulq that occur,
5
~nd th""t cont~actor
wo!.!l r.
hE' respo!'lsib:1?
contractor.
6
for carryina out
thl'? monitori.ng,
""long wit~ thl'? ri?mF.'di<\l
7
alt;;,rn~tivo?
;:.
On the f~ip 5io~:
should tht7
9
81\ .. ~ - .a. .
~~spODS~J)L~ ~ar,_.2~~
d~~lin.~:
then E?;; wO!lld go O.,j ~ an,~
hiT'" a cont.ractnr who would then be rF.'sponsibl.=-.
MrC~Y S~;7nERw~ND:
t.lould t.here Oi?
th~ pn~sibi:ity of
split. s;:;r.-pll'?s?
HS. ?Ei.TC~:
W@ would -- If thl'?
?~.?s 00 hiri? ~
then loll? hirp .:'In
oversight
cont.ractor,
contractor
.:'Ind we alw~ys split. samples.
Aro? you
talking about
sorn~or'Fo ;
as
a ~rivate citizen?
HrCKY
$ ~JTRER L ;; N'D :
Yl?s.
H$. PEi~rCt\:
We ",,11ow that.
op~ortunity too.
l.;sually what we
havi? thF.'!m do is
prov1..ie q.:;
thi? DottlF.'s and
t:ho?n -- do wP
.".
1J!;IJ;;.:' :'y
with
- .
-------
Attachment D - Page 67
,
i
run ::.;/0"'''''' f(lr
2
3
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actually
goincr
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loll
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at thE' timE' w,,=,
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1:. (1~!!1 ,
or 00 1:.ht?Y --
T~E (,:R~_IF.l1AN:
If t:hE'Y w~ro?
to split: ~
!;ampl~,
WE' --
thE'n
MIC~Y SUTHERL~ND:
Wr; w~nt
to r~_1~~
!.!$, PEi..IC7':
I ~ h 0 1.1 1 ('1
~sr:pd
~1;:; VE'
THE CHA IF.I1AN:
We split the sa~plo?s
co:l~~t
tht?;":'\ and <]i vr:, YC)U
yo~~r 5 ;
.=.~:6 Y()j.~
(", f Y('dJ r
MIC~Y SUTHERL~ND:
~;h ~ 1:. .::! 001.1 t
~ ..
...,
bioIDonitoring; would
that be involvE'Q in this?
j.1;
19
MS. PENICK:
Not at this
timE'.
~()
bepartrnent of thE' IntE'rior has done a natural
r ;:;. s 01.1 r c e s
.21
survey, and they have dE'tE'rmined that therE' arE' no
- ,.,
~L.
risks,
and thE're's no ne~d to do
2.3
,., .
:!t~
-r::
~ .'
. . . ~ .
any Dloroonl~orlng,
'30
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ThE'
HICC\"t
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-------
Attachment D - Page 68
-
THE Cn;:'.:LR1'fr;.r~:
.t~!5- ..
s:i~;
<1 I) .,. <;: t: i ('. n
3
numtw?r
six.
4
c:
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i-!y n.;JT1e
i c::; ~7("')()~ .,t ::':; ~ .
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r,; - ~ - It - L .
T' i. ~r1';"
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(:r!if?f of
;')e~r! r tJT1e!", ~
:i~ Fi~:. .=11;\1
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The ~rea proposen
is p~rt- \)f niir
r p ~ 1) () I1 !5 ~ ;;, r ~..; .
!'d lik~ ~0~~bc~y ~o ~~:l !~~ th~~
t;-.t?r~
. "
.lIJ
i ~ nor ~. ~ ~ t- G
~y rd?r~onnr?!..
shou}~ we have to
fi ~ ~ :. -L
~::~ th;;7 :: c<'In
~~~'::
~y ~~O~-~ ~n
th,;;.~~
. .
.' ..
wi 7h confidFrH~:"
t :-.'~ t
tn~r'?';:;
:10 t G 0 j nO'
to c-lr? ~.
~ 1- 0 :-. :: ~ ~~ .
15
. ~
.!."
THE C:RAiRH;'.i;:
Perh~ps;
c: h 1.t C i<; yo 1.1
17
could -- ! thin~ the
question is whether therl?'s a
18
n~nG~~ tn firF ~ersonnel;
<;h01.11.;
t:llo?rr:> Dr:> ~
'n r 1.1 s h fir e
19
or so~ethin~ liki? th~t at
the site.
2n
." :.
!.!((. .
?-::E7~.v5EWJ:C:Z :
;.'I.s~d on thE-
22
0~t~ that W~ h~ve~o far;
the ~nncentr~tion~ are not at
23
levels
that wou:!.n.
pose '"
risk
to firemen or ri?sponoE-rs;
24
~h01.11 d
~ fir e 0 ~ C :H" .
2'5
t.; r:- ,~ " a
-.... -
.l.O I ,"')~
w,)r~
~N; ~ 11
fir~t
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-------
! '
Attachment D - Pa e 69
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resporldo?r~
~nd f~r~:"",:on
t1-irn1.i ~ :, ten t
-- t.o
that.
::;011. C01.1 Id --
~OODY ;;I'LL:
Under tn.:ll:
circumstance, that.
would b~ no danIJer to my personnel~
MR. ?!E~ROSE~ICZ:
sir, not
No,
based on the d~ta we have seen so far.
If t.here
',Jere,
we certainly would have factored that into the scenario~
wI':" "ojE' disc1.lsseci.
- ...
'-I
I
-------
Attachment D - Page 70
-
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~'lt:JO~"1 -;;T;~iJ:
Very Good.
THE CHA:L:RN;;r;:
r:e:
-------
Attachment D - Page 71
I f ~\)I:'<;::~')n~
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r)~..~ on: f?
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th~ l~t1y
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-- ij,;o?r n<\me is DE'!'1isE-:
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,,- .!..J - t""'.. - ~... - '-' .
.
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ShE"S ~ TE'chnic~l Assist~ncE' (.rants
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Speci"llist with E?;
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in ';tl""nt~.
~t will b~
th~ S~~~ <\ddr~ss;
345 (:01)::-~~,3.r.d
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Str~~t ;~ortheast;
Atl~.n.t~..
(.i?org-i<\ .:H)16'5.
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...
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THE: CnA i:RH;'.r: :
I ~ 11 P r .:? (~ i ~ t..:- ~. <":,1 : ,
s
FI.ll C(")!7'~':';"HJ
t()'nigh~
;:; n ~ fJ ~.~ ~ tin
-------
Attachment D -
.20
1
Page 72
-I. STATE OF KENTUCKY
2
SS.
3
-
COUNTY OF HARDIN
4
I, BETH HEADLEY, a Notary Public, within and
5
for th€'
Large: do hereby c€'rtify that th€'
$ti'\te at
6
for€'going Public Meeting, was taken before me at the
7
time and place and for th€' purpos€' in the caption
8
stated; that the Public Meeting was reduced to shorthand
9
writing; that the for€'going is a full, tru€': and corr€'ct
10
transcript of the said Public Meeting so given.
11
12
1.3
WITNESS MY SIGNATURE this 27th day of August, 1990.
14
My commission expires August 3, 1993.
15
16
17
NOTARY PUBLIC
State at Large, Kentucky
10
19
.....
~u.
22
23
24
G5
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