Unrtod Sts.^ Off ice of
Snvitdnmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-90/069
September 1990
EPA Superf und
Record of Decision:
Lewisburg Dump, TN
-------
50272.101
REPORT DOCUMENTATION 1'~r'..o. . 12.
PAGE EPA/ROD/R04-90/069
.. TItle........
SUPERFUND RECORD OF DECISION
Lewisburg Dump, TN
First Remedial Action - Final
7. AuIIor(a)
3. A8dplenl'a Ac:c:eaalon No.
5. A8port Data
09/19/90
s.
8. Pilrfonnlng Organization A8pL No.
I. PiIrfonnkIg OrpInIzrion Name end Add....
10. Proj8c:tlTaalllWoril Unit No.
11. ContNct(C) tN Grant(G) No.
(C)
12. 8ponaorIng 0rpnIzaII0n Name and Addreu
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(0)
13. Type of Raport . P8rtod Coftl8d
Agency
800/000
14.
15. SuppIam8ntary No,"
18. Abatrac:t (UmIt: 20D _rda)
The 20-acre Lewisburg Dump site includes a 4-acre abandoned landfill developed in an
abandoned 6-acre limestone quarry in Lewisburg, Marshall County, Tennessee. Land in
the vicinity of the site is primarily used as farm and pasture land. There are four
public water wells located within one-half mile of the site. This municipally-owned
3nd operated site began landfilling operations between 1963 and 1969, and a variety of
esidential and industrial wastes, including solvents and metallic wastes were
landfilled on site. Some municipal waste was burned onsite, and the resulting ash was
placed in the dump. Soil samples taken from various test pits during State
investigations showed elevated levels of metals and organics on site. In addition, a
2-acre quarry pond was suspected to be contaminated when oil and other debris were seen
floating on its surface and gas bubbles were observed in the absence of any aquatic
life. In 1973, the State found that the old quarry was in violation of recent, more
stringent State environmental laws, and concluded that landfilling operations should be
discontinued. In 1975, the State approved plans for interim maintenance and final
closure of the dump. In 1977, the waste was covered with soil as part of the
preliminary closure activities. This Record of Decision (ROD) addresses the
(See Attached Page)
17. Docurn8nt AnaIyaIa .. OeacrIptora
Record of Decision - Lewisburg Dump, TN
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: organics (bis(2-ethylhexyl)phthalate)
barium, copper, manganese, zinc)
and metals (aluminum,
b. Id8nIlenlOpen-Endad Tanna
Co COllA n RelcUGroup
18. AVIDabIIty St8tement
II. SecurIty CI... (Thla A8p0rt)
None
20. SecurIty CI... (Thla Paee)
None
21. No. 01 Page-
230
22. Price
.
(See ANSI-Z38.18)
s..1".11uc:tJ~ on ,.-
72 (4-77)
(Formerty NTlS-35)
Department 01 Convnerce
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EPA/ROD/R04-90/069
Lewisburg Dump, TN
First Remedial Action - Final
Abstract (Continued)
contaminated soil and debris present at the site in the landfill and in the quarry pond,
and provides for protection of the ground water, pond water, and sediment from further
contamination. The primary contaminants of concern affecting the soil and debris are
organics including bis(2-ethylhexyl)phthalate (DEHP); and metals including aluminum,
barium, copper, zinc, and manganese.
The selected remedial action for this site includes removing landfill surface and quarry
debris and disposing of the wastes in one of the test pits at the site, an approved
sanitary landfill, or a hazardous waste landfill; replacing the plastic test-pit caps
with landfill cap material; regrading the landfill cap to stabilize site conditions and
to meet State and Federal regulations; revegetating the landfill; conducting long-term
ground water monitoring and analysis; and implementing institutional control$ including
deed restrictions to restrict site usage, and site access restrictions such as fencing.
The estimated present worth cost for this remedial action ranges between $791,512 and
$1,189,741 (depending on which of the three disposal options is implemented), which
includes a total O&M cost of $270,042 for years 0 to 5.
PERFORMANCE STANDARDS OR GOALS: No chemical-specific cleanup goals for soil or debris
were provided. Source treatment and removal should indirectly reduce the level of
ground water contamination. Chemical-specific ground water cleanup goals are based
primarily on the proposed MCL for DEHP 4.0 ug/l. The surface water cleanup goal for-
copper is 12.0 ug/l, which will be less than or equal to a hazard quotient of 1.0.
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LEWISBURG DUMP SITE
LEWISBURG, MARSHALL COUNTY, TENNESSEE
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION
REGION IV
ATLANTA, GEORGIA
AGENCY
-------
TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENT
DOCTORS BUilDING
706 CHURCH STREET
NASHVillE, TENNESSEE 37219
September 10, 1990
Mr. Douglas A. Bell.
Remedial Project Manager
Kentucky/Tennessee Remedial Section
North Superfund Remedial Branch
Waste Management Division
U.S. EPA
345 Courtland Street
Atlanta, GA 30365
Rt:".
....
Lewisburg Dump Superfund Site
Subject:
Revie~.' of the Draf t Record of Decis ion
Dear Mr. Bell:
Division of Superfund personnel have revieloled the Draft Record of Decision for
the Lewisburg Dump Superfund Site. The major components of the selected
remedy include:
*
Installation
restrictions.
of
a
security
*
fence
implementation
and
Removal of the submerged pond debris.
*
Removal of surface debris at the site.
*
Replacement of plastic test pit caps with clay and soil.
*
Upgrading of
requireaents.
the
landfill
cap
to
meet
all
and
State
We feel the selected remedy adequately addresses State concerns
appropriate for this site based on the existing known conditions.
Sincerely,
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,..\~£O s:"'...~
.;; r.s-
;; ft "G
~~Ta~
~<"~ "/
r~( ....o~<.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
SEP I 9 1900
Ol'FICEOF
SOLID WASTE AND el>.'ERGEr>.CY RESPONSE
MEMORANDUM
SUBJECT:
ROD Consultation, Lewisburg Dump Site, Lewisburg, TN
Sally Mansbach~'z?~~~
Acting Director, CERCLA Enforce~tlDivision
FROM:
TO:
Pat Tobin
Director, Waste Management Division
On September 27, 1990 Tim Mott, Linda Boornazian and Neilima
Senj alia of my staff and Douglas Bell, Region IV RPM, for the
Lewisburg Site discussed the proposed "containment only" remedy.
This memorandum confirms that the requisite consultation was
conducted and that the containment remedy for the landfill is
appropriate for this site.
. cc:
Bill Hansen, OERR
Doug Bell, Reg.IV
.'
Prinud ..J'
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RISK ASSESSMENT CERTIFICATION
The Region IV risk assessment staff has reviewed the PRP-
generated risk assessment for the Lewisburg Dump NPL Site,
Lewisburg, TN for compliance with current Agency health risk
guidance and policy. Comments were conveyed to the Potential
Responsible Parties (PRP) through the Remedial Project Manager
and appropriate changes/corrections have been incorporated into a
revised risk assessment document. In accordance with the
requirement of OSWER Directive No. 9835.15 (8/28/90), it has been
determined that the final risk assessment as summarized in this
Record of Decision conservatively conveys the upperbound cancer
and the systemic toxicity risks posed through all reasonably
likely current and future exposure scenarios by contaminants
identified at this site. Therefore, it is acceptable to the
Agency.
\6..L~ \A..). ~~ .~A9\...-
Elmer W. Akin ~
Health Assessment Officer
S-\~-<1o
Date
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RECORD OF DECISION
Remedial Alternative Selection
SITE NAME AND LOCATION
Lewisburg Dump Site
Lewisburg, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial. action for the Lewisburg
Dump Site in Lewisburg, Tennessee developed in accordance with CERCLA, as amended
by SARA, and to the extent practicable, the National Contingency Plan (NCP).
This decision for remedial action is based upon the contents of the
Administrative Record for the Lewisburg Dump Site.
The United States Environmental Protection Agency and the State of Tennessee
concur with the selected remedy.
ASSESSMENT OF THE SITE
Conditions at the Lewisburg Dump Site will continue to deteriorate thereby
increasing the potential for additional release of hazardous materials. Actual
or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this ROD, may present a current
or potential threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The final remedy implements remediation of the Site contamination by eliminating
or reducing the risks posed by the Site through containment and institutional
controls.
The major components of the selected remedy include:
o
Installation of a security fence and implementation of deed restrictions.
o
Removal of the submerged pond debris.
o
Removal of surface debris at the Site.
o
Replacement of plastic test-pit caps with clay and soil.
o
Regrading of the landfill cap to meet all State and Federal requirements.
-------
o
A five-year well monitoring and analysis program is provided to measure
the effectiveness of the remedial measures. This program will include a
dye-tracer study to effectively identify preferred/appropriate monitoring
stations.
DECLARATION
The selected remedy is protective of human health and the environment, complies
with Federal and state requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technology to the maximum extent
practicable for the Lewisburg Dump Site. However, because treatment of the
principal threats of this site was not found to be practicable, this remedy does
not satisfy the statutory preference for treatment as a principal element.
Since this remedy will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted within five years after
commencement of remedial action to' insure that the remedy continues to provide
adequate protection of human health and the environment.
q!)c/q('
. 1 I J . )
\ ".-"- 1),""7 ~-{.,,-----"t 1 L \
.7- 1-1- ~'"
Greer C. Tidwell
Regional Administrator
Date
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TABLE OF CONTENTS
Table of Contents
i
List of Figures
v
vi
List of Tables
1.0
2.0
3.0
4.0
5.0
4.2
4.3
4.4
4.5
Introduction
1
1.1
Site Name, Location, and Description
1
1.2
Site History and Enforcement Activities
4
1.3
Summary of EPA Involvement.
5
Highlights of Community Participation.
6
Scope and Role of Response Action
6
Summary of Site Characteristics.
8
4.1
8
Environmental Setting
Geology and Hydrogeology
8
Demography and Water Use
14
Land Use.
14
Climatology.
14
Nature and Extent of the Problem
5.1
5.2
5.3
5.4
14
Waste Identified On-Site
14
Surface Soil Contamination.
15
Groundwater Contamination
15
Surface Water Contamination
32
-i-
-------
TABLE OF COMTBHTS (CORT' D)
5.5
Pond Sediment Contamination
5.6
Fish Contamination
5.7
Air Contamination.
5.8
Sinkhole Contamination
6.0
Additional Analysis.
6.1
6.2
Residential Well Survey.
Fracture Trace Analysis.
6.3
Geophysical Survey
7.0
Potential Routes of Migration
7.1
7.2
7.3
7.5
Groundwater.
Surface. Water
Pond Sediments.
7.4
50il Ingestion.
Air Inhalation.
8.0
Summary of Site Risks
9.0
Human Health Risks
9.1
9.2
9.3
9.4
32
32
50
50
50
50
56
56
56
66
66
67
67
67
67
68
68
. 69
72
76
77
Selection of Contaminants of Concern
Exposure Assessment
Toxicity Assessment
Risk Characterization
10.0
Environmental Risks.
-ii-
-------
TABLE OF COHTERTS (CORT' D)
11.0
Description of Alternatives
Alternative 1 .
11.1
11.2
11. 3
11.4
11. 5
12.0
Alternative 2 .
Alternative 3 .
Alternative 4 .
Alternative 5 .
12.1
Summary of Comparative Analysis of Alternatives
Landfill Wastes and Groundwater.
12.2
12.3
12.4
12.5
12.6
12.7
12.8
12.9
Overall Protection of Human Health and the Environment
Compliance with ARARs
Reduction of Toxicity, Mobility or Volume
Long-Term Effectiveness
Short-Term Effectiveness
Implementability .
Cost.
State Acceptance.
12.10 Community Acceptance
13.0
Selected Remedy
13.1
13.2
13.3
13.4
Summary of Statutory Findings
Protection of Human Health and the Environment.
Compliance with ARARs
Guidance To Be Considered.
13.5 .Cost Effectiveness
-iii-
77
78
78
78
80
80
81
82
82
82
83
83
83
84
84
84
84
85
88
89
89
92
92
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13.6
13.7
14.0
TABLE OF CORTEH'l'S (OOHT' D)
Utilization of Permanent solutions and Alternative
Treatment Technologies or Resource Recovery Technologies
to the Maximum Extent Practicable
Preference for Treatment as a Principal Element
14.1
Responsiveness Summary.
Overview
14.2
14.3
14.4
Appendices:
Background of Community Involvement and Concerns
Summary of Major Questions and Comments During
the Public Meeting and the Public Comment Period,
and EPA's Responses to These Questions
14.3.1 Additional Comments on Behalf of the Lewisburg
Environmental Response Committee (LERC)
Written Comments Received During the Public Comment
Period and EPA's Responses to These Comments
Appendix A: Copy of the Proposed Plan Presented at the Public
Meeting: July 25, 1990, Lewisburg, Tennessee
Appendix B: Sign-In Sheets From the Public Meeting: July
25, 1990, Lewisburg, Tennessee
Appendix C: Repository Information for the Lewisburg Dump
Site
Appendix D:
Official Tran~cript of the Public Meeting
Proposed Plan for the Remedial Activities
Lewisburg Dump Site, Lewisburg, Tennessee
on the
at the
-iv-
92
92
93
93
95
95
101
103
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FIGURE
LIST OF FIGURES
1
"Location of the Lewisburg Dump Site
2
Map of the Lewisburg Dump Site
3
Generalized Map of Geologic Provinces in Tennessee
4
Map of the Regional Topographic Setting of the
Lewisburg Dump Site.
5
Groundwater Contour Map Considering Topographic Information
6
Cross-Section Across the Lewisburg Dump Site
7
Sampling Locations For Phase I & Phase II and
Topographic Features
8
Map of Approximate Extent of Pond Sediment
9
Map of submerged Pond Debris Distribution
10
Fracture Trace and Site Reconnaissance Results.
11
Landfill Magnetic Iso-Gradient Map
12
Pond Magnetic Iso-Gradient Map
13
Map of Proposed Fence Location
-v-
PAGE
. 2
. 3
. 9
. 10
. 12
. 13
. 16
. 39
. 40
. 62
. 63
. 64
. 86
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TABLE
LIST OF TABLES
1
Test-Pit Excavation Summary
2
Inorganic Analyses Results From Soil samples (Phase I)
3
Organic Analyses Results From Soil samples (Phase I) .
4
EP Toxicity Analyses Results From Soil Samples.
5
Water Sampling Summary
6
Groundwater Monitoring and Well Data (Phase I & II)
7
Groundwater Sampling Summary (Phase II)
8
Organic Analyses Results From Groundwater Samples (Phase I).
9
Inorganic Analyses Results From Groundwater Samples (Phase I) .
10
Inorganic Analyses Results For Groundwater and
Associated QA/QC Samples (Phase II)
11
Organic Analyses Results For Groundwater and
Associated QA/QC Samples (Phase II)
12
Organic Analyses Results From Pond Surface
Water samples (Phase !)
13
Inorganic Analyses Results From Pond Surface
Water Samples (Phase I)
14
Organic Analyses Results For Surface Water and
Associated QA/QC Samples (Phase II)
15
Inorganic Analyses Results For Surface Water and
Associated QA/QC Samples (Phase II)
16
Organic Analyses Results From Pond Sediment Samples (Phase I) .
17
Inorganic Analyses Results From Pond Sediment Samples
(Phase I)
18
Organic Analyses Results For Sediment and
Associated QA/QC Samples (Phase II)
-vi-
PAGE
17
18
19
22
23
24
25
26
29
30
31
33
36
37
38
41
44
45
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LIST OF TABLES (OONT'D)
19
Inorganic Analyses Results For Sediment and
Associated QA/QC Samples (Phase II)
46
20
Fish Collected From the Pond.
47
21
Organic Analyses Results For Fish and
Associated QC/QA Samples (Phase II)
48
22
Inorganic Analyses Results For Fish and
Associated QA/QC Samples (Phase II)
49
23
Inorganic Analyses Results For Air Samples,
Round 1 (Phase I)
51
24
Inorganic Analyses Results For Air Samples,
Round 2 (Phase I)
52
25
53
Sinkhole Sampling Summary
26
Organic Analyses Results For Sinkhole and
Associated QA,/QC Samples (Phase II)
54
27
Inorganic Analyses Results For Sinkhole and
Associated QA/QC Samples (Phase II)
55
28
Residential Well Survey Results
57
29
Organic Analyses Results From Residential
Water Wells and Spring (Phase I)
58
30
Inorganic Analyses Results From Residential
Water Wells and Spring (Phase I)
61
31
Summary of Potential Exposure Pathways
65
32
Summary of Chemicals of Potential Concern
7:
33
Summary of Chemical Concentration Values
at Receptor Locations.
7:
34
Parameters Used to Describe 'Exposure to
Site-Related Chemicals of Potential Concern
7':'
-vii-
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LIST OF TABLES (OONT'D)
35
Toxicity Values For Chemicals of Potential Concern
75
36
Summary of Modified Alternative 3 Including
the Three Disposal Options
87
37
Groundwater Criteria for Lewisburg Dump Site
90
-viii-
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SUMMARY
RECORD OF DECISION
OF REMEDIAL ALTERNATIVE
LEWISBURG DUMP SITE
LEWISBURG, TENNESSEE
SELECTION
1.0
INTRODUCTION
The Lewisburg Dump Site (the "Site") was included on the National Priorities List
(NPL) in September of 1983 with a Hazard Ranking Score (RRS) of 31.14. This HRS
score was developed after EPA's Region IV Field Investigation Team (FIT)
collected samples at the site in 1982. Any site with an HRS score above 28.5 is
placed on the NPL. Approximately 4.14 of the 20 acres at the Lewisburg Dump
Site was utilized from the mid-1960's to 1979 for the disposal of municipal
trash and industrial waste. Remedial Investigation/Feasibility Study (RI/FS)
activities were initiated in July of 1988 in response to the Site being listed on
the NPL. The City of Lewisburg and certain industries (Potentially Responsible
Parties) conducted the RI/FS after forming the Lewisburg Environmental Response
Committee and signing and Administrative Order with the EPA. The RI report which
examines the quality of soil, air, surface water, pond sediments, and groundwater
at the site was completed in June of 1990. The FS report which examines
alternatives for site remediation was submitted to the public information
repository with the RI Report in July of 1990.
This Record of Decision has been prepared to summarize the remedial alternative
selection process and to present the selected remedial alternative, in accordance
with Section 113(k)(2)(B)(v) and section 117(b) of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act (SARA-P.L. 99-499).
The Administrative Record for the Lewisburg Dump Site forms the basis for the
Record of Decision contained herein.
1.1
Site Name, Location. and Description
The Lewisburg Dump Site is located approximately 40 miles southeast of Nashville,
Tennessee (Figure 1). The Site, encompassing approximately 20 acres, consists of
the area located within the property boundary line depicted on Figure 2. The
Site also includes that southeast portion of the pond, encompassing approximately
0.14 acre, located outside such property boundary line depicted on Figure 2.
The Site is located among farms and pastureland, one-half mile north of
Lewisburg, Tennessee on Rock Crusher Road (Figure 2). The property where the
landfill is now located was formerly referred to as Rock Crusher Tract No.3 of
the Franklin Limestone Property (County Register, Marshall County, Tennessee,
1956). Prior to receiving wastes, the Site contained two separate bodies of
water. The body of water located in the southwestern portion of the Site is
presently completely filled with wastes and covered with dirt. Within the 20
acre site resides the northern abandoned 6.41 acre limestone quarry that contains
-1-
-------
Figure 1
-------
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a 2.27 acre pond. A 4.14 acre parcel (the western portion of the 6.41 acre
quarry) was used for the landfill operation which. ceased in 1979. A majority of
the Site is presently owned by the City of Lewisburg, Tennessee. Mr. George
Hazlett owns the 0.14 acre portion of the quarry pond. Mr. Hazlett leases
property, including such portion of the pond, to his son-in-law Mr. Michael
Fagen. Mr. Fagen presently operates a junkyard containing various automobile and
industrial metallic waste on the leased property which includes such portion of
the pond. Also in the vicinity, there are 10 homes or approximately 30 people
within a one-half mile radius of the Site.
Due to the disposal of industrial wastes at th~ site, federal. and State agencies
have raised concern regarding the potential environmental impact from the Site.
1.2
Site Historv and Enforcement Activities
The Lewisburg Dump began operations in the 1960's at the inactive limestone
quarry Site. Historical aerial photographs of the Site (EPA, 1987) indicate that
dumping operations were initiated between 1963 and 1969. The landfill was owned
and operated by the City of Lewisburg. The dump was open to all residential and
industrial dumpers who wished to use it, and city records note that several
surrounding co~unities may have hauled their wastes to Lewisburg. Much of the
municipal waste hauled to the Site by the City of Lewisburg was burned on-~ite,
with the resultant ash being deposited in the dump. The industrial wastes
reportedly placed at the dump include paint, paint strippers and solvents;
industrial plastic waste; pickle sump material (containing spent pickle liquor
with residual metals); alkaline cleaner; emptied containers of adhesives,
cements, lacquers and paints; and other industrial wastes including natural and
man-made shoe manufacturing scrap and various colors of pencil core scrap.
In the early 1970's, the State of Tennessee made its solid waste management
regulations more stringent. Representatives of the Tennessee Department of
Public Health (TDPH) visited the Lewisburg Dump Site in July, 1973 to prepare a
geologic review and obtain water samples. Study findings indicated that the old
quarry was an unfit location for a sanitary landfill since there was a lack of
soil as cover material and buffer zone for filtration purposes. Also mentioned
in th~ study was that large amounts of contaminated water may be entering
fractures in bedrock and eventually Big Rock Creek and/or wells that exist within
one-half to 1 mile or more away. Other information mentioned in the report was
that there was visible residue of burned refuse and raw refuse inundated by
water. Oil and other floating debris such as sawdust was observed floating on
the quarry pond. Gas bubbles were present in the water and there was no evidence
of fish or other aquatic life. TDPH concluded that this Site had no future use
as a sanitary landfill.
On August 21, 1973, the Tennessee Department of Public Health filed a lawsuit in
Marshall .County Chancery Court (Marshall chancery No. 4387) to bring the City of
Lewisburg into compliance with the Tennessee Solid Waste Disposal Act.
-4-
-------
The following month, another representative of TDPH inspected the Site to verify
reports of open burning at the dump. This burning was in violation of the State.
solid waste laws as well as the Tennessee Air Pollution Control Regulation. To
comply with the laws, the City subsequently proposed to TDPH a plan to build and
operate a solid waste incinerator on a permitted site. In early 1975, those
plans were approved by the State of Tennessee. The proposal also included plans
for interim maintenance and final closure of the dump.
Late in the summer of 1977, the City of Lewisburg reported having difficulties in
locating a suitable site for a new incinerator and landfill. Shortly thereafter,
the City began preliminary closure activities for the Lewisburg Dump Site by
applying a soil cover to the waste. In November, the state of Tennessee filed a
motion in the Marshall County Chancery Court requesting the court to order the
City to comply with closure requirements. From mid-1978 to mid-1979 the City
continued its attempt to find an acceptable landfill location while transporting
dirt and waste covering to the dump and the burning was discontinued. The dump
was finally closed in 1979. However, as of 1985, the dump was still allowed to
receive sawdust and brush refuse for disposal by open burning on the landfill
cap. It appears that this practice was discontinued just prior to the beginning
of the Remedial Investigation and there is no evidence that this burning of
sawdust and brush refuse has occured since that time.
1.3
Summary of EPA Involvement
EPA conducted a hazardous waste site inspection in March 1982. The resulting
report indicates the presence of organic and inorganic compounds, including lead,
toluene, PCBs, chlordane, and phenol. EPA added the Lewisburg Dump to the
Superfund National Priorities List of hazardous waste sites, issued in September
of 1983.
In the fall of 1985, EPA conducted a search for all companies, agencies, or
individuals who were potentially responsible for accumulation of hazardous waste
at the site. The types of waste deposited at the Site included: sawdust,
colored and black pencil cores, cosmetic powders, shoe linings, adhesives, paint
stripper, empty five-gallon pails coated with yellow lacquer, and metal cuttings.
EPA notified Potentially Responsible Parties (PRPS) in a letter dated January 28,
1986, of conditions at Lewisburg Dump, and of EPA's plans for an investigation of
the contamination. In May 1987, the City of Lewisburg and local industry formed
the Lewisburg Environmental Response Committee (LERC) to negotiate with EPA for
undertaking a Remedial Investigation and Feasibility Study (RIfFS). Phase I
activities of the Remedial Investigation began in October of 1988 and the RI and
FS Reports were completed in June and July of 1990, respectively.
The finding of the RI confirmed the presence of 32 organic and 20 inorganic
contaminants at the site. Of the 52 contaminants, 21 have been found to be of
"potential concern". Further analysis revealed that a total of 6 contaminants
are of significant concern due to frequency of detection or quantity.
-5-
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2.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The first public meeting at Lewisburg was held in August 11, 1988. This meeting
was held primarily to present the RIfFS Workplanand answer questions from the
community. The second public meeting to present the Proposed Plan concerning the
Lewisburg Dump Site was held at the City Administration Building in Lewisburg,
Tennessee on July 25, 1990. The Community Relations Plan (approved January,
1988) lists contacts and interested parties throughout government and the local
community that establish communication pathways to ensure timely dissemination of
pertinent information. The RIfFS and the Proposed Plan were released to the
public in July 1990. All of these documents were made available in both the
Administrative Record at the information repository maintained at the Marshall
County Public Library. A public comment period was held from July 25, 1990 to
August 23, 1990. All comments which were received by EPA prior to the end of the
public comment period, including those expressed verbally at the public meeting.
These comments are addressed in the Responsiveness Summary (section 14.0 of this
document) .
3.0
SCOPE AND ROLE OF RESPONSE ACTION
The scope of this response action is to address materials contained in the dump,
surficial debris, debris accumulations in the quarry pond, pond water &
sediments, and the protection of groundwater from additional contamination.
The final remedy for the cleanup of the Lewisburg Dump Site will address concerns
for public health and the environment by controlling exposure to Site
contaminants of concern through institutional controls as well as by reducing
potential migration of contaminants into soils, pond sediments, surface water and
groundwater. .
Well monitoring and groundwater analysis is provided as part of the response
action to insure that remedial activities are effective and .that groundwater is
protected (Several nearby water wells [one as close as 200 feet] could
potentially be affected by material at the dump site). Factors that may
determine the distribution of contamination are: 1) the amount of contaminants
contained in the dump, 2) the complex geology (i.e., Karst terrain that exhibits
numerous sinkholes) of the region, and 3) the hydrogeology of the limestone
aquifers that underly the Site. These three variables were analyzed to determine
the general flow directions of groundwater from the Site, and potential
receptors. Information generated for the RI indicate that groundwaters
originating from the site most likely flow towards the east- southeast adjacent
to the Site and eventually eastward into Big Rock Creek approximately 2000 feet
from the Site.
The selected remedy will specifically reduce the potential for the migration of
DEHP, copper, and other contaminants of concern from the landfill area to the
groundwater, to the quarry pond, and eventually off-site. Submerged debris in
the quarry pond will-be removed to reduce the potential additional contamination
-6-
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1-
of pond water and sediments. The landfill cap will be regraded to limit the
amount of water that may infiltrate the cap and reduce the potential for leachate
development. In addition, the EPA,selected alternative will limit access to the
Site by fencing the entire property and will prevent future use of the property
by imposing deed restrictions which will prevent the future installation of
private wells.
Informa~ion from the RI and other studies indicate that the landfill cap is
presently undulating (allowing water to pond on the surface) and has been
penetrated by small trees and other vegetation. Contaminants such as DEHP and
copper are likely entering the groundwater at the test-pit area and then
appear to enter the quarry pond where they may either be incorporated into the
pond sediments, pond waters, or migrate out of the pond through the complex
hydrogeologic network. Migration of groundwaters and contaminants through the
Karst system at the Lewisburg Dump Site is very complex and it is likely these
waters from the landfilled area do not have continuous flow. These groundwaters
may accumulate and be sporadically released to the quarry pond during significant
rainfall events, or when fractures or cavities become enlarged (intersect). This
indicates the' probability that significant volumes of contaminants may be
transported (mass-transport) through underground Karst networks, and that
leaching may not be the only mechanism for contaminants to escape the landfill.
Remedial actions such as landfill cap regrading are needed specifically to reduce
and to limit the amount of water infiltrating the landfill constituents. These
protective measures are to be taken so that the MCL for copper and the proposed
MCL for DEHP will not be exceeded in off-site wells. (The proposed MCL of 4.0
ppb for DEHP has been exceeded by 8.0 ppb in supplemental sampling in one of the
on-site monitoring wells).
This selected remedy will also address and reduce the potential for direct
contact with and the potential accumulation of landfill contaminants, and
contaminants associated with quarry pond debris by flora and fauna, (especially
aquatic life in the quarry pond).
The final remedy for the Site is intended to address the entire Site with regards
to the principal threats to human health 'and the environment posed by the Site as
indicated in the Risk Assessment, RI/FS Reports and Environmental Services
Division (ESD, 1990) data. Data will be collected during the five year review to
insure that the remedy continues to provide adequate protection of human health
and the environment. The findings of these data are summarized in a later
section of this document.
-7-
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4.0
4.1
SUMMARY OF SITE CHARACTERISTICS
Environmental Settinq
The Lewisburg Dump Site is located within the Nashville Basin (within the central
Basin) of Tennessee (Figure 3), which is bordered on all sides by the Highland
Rim. The Highland Rim (plateau) physiographic province which exhibits rock of
Mississippian Age retains little or no relief, except near major drainage areas.
This "Rim" is a very distinct and rugged scarp approximately 300 feet high and
almost completely encircles the Nashville Basin.
Rock types exposed throughout the Highland Rim are comprised of Limestone,
siltstone, shale, and minor amounts of interspersed sandstone. Also noted is
abundant bedded chert, cherty and dolomitic limestone, and silicastone throughout
the Mississippian section. A relatively thin bed of Devonian age Chattanooga
Shale underlies the previously mentioned Mississippian rocks. This Devonian
Shale is in turn underlain by older Ordovician rocks of the Nashville and Stone
River Groups.
4.2
Geoloqy and Hydroqeoloqy
Rock units exposed and beneath the site range from Ordovician to Cambrian. The
rock units of primary interest to the Site are Part of the Ordovician Stone River
Group (approximately 600-700 feet thick at the Site) and are described below:
o
Ridley Limestone: consists primarily of gray limestone that is locally
bluish or light brown. The beds are massive/ flat with thicknesses
ranging from 4 inches to 4 feet and a dip of less than 3 degrees in a
northwesterly direction. The total thickness of the Ridley Formation
varies from 80-125 feet. The limestone bedrock exposed at the Site is the
Ridley and exhibits vertical joints spaced laterally at 10-20 foot
intervals and trend north 20 to 50 degrees east.
o
Pierce Limestone: consists primarily of thinly-bedded, gray, and shaly
limestone. This unit is relatively minor in most areas of the state and
is approximately 25 feet thick (Brahana and Bradley, 1986).
o
Murfreesboro Limestone: consists of massive, dense, dark blue to
bluish-gray, cherty limestone. This Formation is generally large
approximately 425 feet thick (Brahana and Bradley, 1986).
and is
A hydrogeologic investigation of the Site was completed and included in the RI
report. The presence and abundance of Limestone in this location is evident as a
. sinkhole-type topography (Karst terrain) is typical throughout the northern half
of Marshall County, which includes the Site (Figure 4). The quarry is located
at the end of a topographically low area that resembles a small karst valley.
This area is finger-shaped and gently slopes towards the east for
-8-
-------
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-------
NO VERTICAL SCALE
HOR'ZONTAL SCALE
LEWIS3URG DUMP SiT£
^ TOPOGRAOHlC SETTING
4coc PEE
1 0.-
-------
approximately 2,000 feet where it terminates into Big Rock Creek. Groundwater,
for the most part appears to follow topography towards the east, eventually into
Big Rock Creek. However, the karst aquifer (Ridley Formation) is hydrologically.
complex and there appears to be evidence that local deviations in groundwater
flow occur at the southeast portion of the Site (Figure S). These local
deviations are evident in the form of springs (Old Distillery Spring) and
intermittent discharges (swallets) adjacent to a drainage ravine just southeast
of the quarry pond approximately 100-S00 feet. Under the EPA groundwater
protection strategy (EPA, 1986), the Ridley aquifer is classified as a Class II A
aquifer because it is used for drinking but alternate sources are readily
available and the groundwater is not ecologically vital.
Water from the site appears to flow toward the quarry pond (Figure 6) where the
level has been noted to remain constant in spite of severe drought. This
indicates that this quarry pond is groundwater fed by a constant and significant
source. Water appears to exit the quarry pond in the subsurface (through a
buried culvert local residents remember that went under Rock Quarry Road) and
most likely enters the subsurface drainage network where water only intersects
the surface during high rainfall events. For the most part, the water that flows
out of the pond remains subsurface in the complex drainage network and only
intersects the surface at Old Distillery Spring and several other of the larger
(unnamed) swa:lets and sinkholes adjacent and southeast of the Site.
Conceptual models proposed for the site range from one that treats the
groundwater flow as normal in an unconfined aquifer, to a model that presents the
aquifer as one that completely denies the existence of a groundwater table. It
appears that the groundwater regime may be the product of both of these models,
suggesting that they represent two end members in a sequential development of a
dynamic underground system. Initially, the groundwater behaves like that in an
unconfined aquifer, but as solutioningwater progressively weathers the fractures
and bedding planes, they become widened and eventually linked. Once these
features are linked, the water system begins to be controlled by the rock
structure.
The average hydraulic gradient across the site is approximately 0.010. Specific
tests have not been conducted at the site to measure the hydraulic conductivity
of the bedrock. The weathered bedding planes in this karst area suggest that
high flow rates are possible. Horizontal conductivity and porosity values based
on the above information would most likely be variable for the Site. Average
horizontal conductivity given by Morris and Johnson (1967) for limestone is 44
gallons per day (6.81 x 10 -S feet/second). Porosity values in limestone range
from 6.6 to SS.7 percent with an arithmetic mean of 30 percent. Groundwater
velocity within the Ridley Aquifer was calculated using an average thickness of
100 feet and an average hydraulic conductivity of 4.0 x 10-S feet/second. The
flow rate of 42 feet/year is a rough estimate given the complexity and
variability of the karst aquifer. This value is presented only as an estimate to
give an understanding of how fast groundwater may be travelling at the Site
assuming an effective porosity of 30 percent. The deepest monitoring well is
approximately 84 feet (measured from the ground surface) and the only aquifer
encountered was the Ridley Limestone.
-11-
-------
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FIGURE ')
Ground Water Contour MLlp ConccptuLlI lIIust
Considering Topogmphic Information
.
HI
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FIGURE 0
--- -----..--.---
lEWISI3URG DUMP SITE
LANDFill CROSS SECTION A - 13 . C
FROM GROUND WATER CONTOUn
MAP
T
Walel TalJle Elevalion
C:=J
Pond Sed/mell'! Auocla'ed wll" '''0
Lam'"l1 Mallillat
De8pel POItIon 0'
lheL8ndtlll
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TP.3
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-----------.. -- . -. - l
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-~~'\.~'\:~~""""~"-'\-"':~'\~- .'T.PO:III-
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4.3
Demoqraphv and Water Use
Marshall County is sparsely populated, having, about 20,000 people. Approx-
imately 9,000 people reside within the city limits of Lewisburg. Ten homes or
approximately 30 people are located within a one-half mile radius of the site.
Many people in the area have public water, but approximately 8 residents to the
immediate west of the site use private wells. Four of these wells are within
one-half mile of the Site (Blackwell et al., 1982). Most city residents are
connected to a public sewer system. Most county residents, however, have septic
systems. Many of these septic systems are of questionable efficiency due to the
thin soil layer overlying the bedrock.
4.4
Land Use
The majority of the Site at present consists of exposed bedrock and the quarry
pond. Only a small portion of the Site contains soil cover (the landfill area)
that could support agricultural uses. Crop farming in the immediate area is not
feasible due to the previously described conditions. Future land uses could
include industrial development. In this case, exposures characterized by current
land uses would also apply to future land uses, assuming the landfill itself is
left undisturbed. Thus, future potentially exposed populations are assumed to be
similar to current populations. This assumption is in fact conservative since
water lines are available to residents downgradient of the Site. Future
residents could rely on city water instead of ground water for their potable
water source.
4.5
Climatoloav
The annual mean temperature for the area is 57.6 degrees F., with January being
the coldest month with a mean temperature of 36.2 degrees F. July is the warmest
month with a mean temperature of 77.5 degrees F. The average rainfall is 54.2
inches with the greatest precipitation generally occurring during winter and
early spring. The average snowfall for the location is 7.5 inches. Winds within
the Lewisburg area are generally southerly (40 percent south, 10 percent
southeast, 10 percent southwest) and the average growing season cloud cover is
less than three-tenths on a time basis. Cloud cover may average as much as
seven-tenths during the wetter winter months.
5.0
NATURE AND EXTENT OF THE PROBLEM
5.1
Waste Identified on Site
The Lewisburg Dump Site was operated as
the mid 1960's until 1979 when the dump
still being used for authorized burning
some uncontrolled dumping that occurred
a municipal/industrial landfill between
was closed. Prior to 1987, the Site was
of sawdust, tree and brush refuse and
after closure., No precise inventory of
-14-
-------
the waste has been compiled but the following are typical of the wastes which
were disposed of at this Site:
5.2
o
o
o
o
o
household garbage
miscellaneous metallic waste
paint strippers and solvents
industrial plastic waste
pickle sump material
alkaline cleaner
emptied containers of adhesives,
shoe manufacturing scrap
pencil manufacturing scrap
drummed waste
fiberglass insulation
lacquers, cements, and paints
o
o
o
o
o
o
Surface Soil Contamination
Much of the area within the site boundaries lacks soil cover with direct
exposures of bedrock. However, within the landfill 13 test-pits were excavated
with a total of 16 soil samples recovered. Also to the southwest of the Site
approximately 800 feet, 1 background soil sample was recovered. Various data for
the test-pits and associated soil samples are located in tables 1 & 2. Test-pit
location are shown in Figure 7. The results show elevated organic and inorganic.
concentrations. High concentrations of bis(2-ethylhexyl)phthalate are especially
notable, which is indicative of plastics (one of the test pits noted 38,000
ppb). Metal concentrations are also elevated which is indicative of metallic
refuse and industrial waste. Generally, the highest compound concentrations are
found in soil samples 50-08, 50-10, AND 50-13 from test-pits 8, 10, and 13
respectively. Hydrocarbons (oils, fuels, waxes, etc.) were also detected. Data
from the soil analysis effort is listed in Tables 2-4.
5.3
Groundwater Contamination
Monitoring well and piezometer data is listed in Table 5. A complete summary of
groundwater monitoring well data and groundwater sampling data is presented in
Tables 6 & 7. All wells were sampled for Target Compound List (TAL) and Target
Analyte List (TAL) substances (Tables 8-11). Organic contaminants found in the
groundwater include: methylene chloride (4.4 ppb) and Bis(2-ethylhexyl)phthalate
(12.0 ppb). Toluene was found in minor concentrations and eliminated from the
list of contaminants of potential concern. Acetone was also found in elevated
concentrations in the pond sediments (it also was found in part to be a
laboratory contaminant). Inorganic contaminants of concern are: aluminum (1286
ppb), barium (145 ppb), iron (6077 ppb) , and manganese (207 ppb).
-15-
-------
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LEWI~nURG DUMP 5ITE
SAMPLING LOCATIONS fOR PIIASE 11\ IT
AND TOPOGHA~I~ fEATURES
----
-------
TABLE 1
TEST-PIT BXCAVATION SUMMARY
sample Bedrock Sample Pit Dimentions (ft) Surface
Pit ' Number Elevation IntervalCft) L W D Elevationlft)
TP-1 50-01-1 <697.0 5.5 - 6.0 16.0 2.5 16.0 713.0
TP-2 50-02-1 <699.0 8.5 - 9.0 20.0 2.5 17.0 716.0
TP-3 50-03-1 -688.0 2.0 - 2.5 22.0 5.5 30.0 -718.0
TP-4 50-04-1 705.0 11.0 - 11.5 16.0 5.5 15.0 720.0
TP-5 50-05-1 690.0 13.0 - 14.0 9.0 6.0 15.0 705.0
TP-6 50-06-1 * 3.5 - 4.0 7.0 9.0 5.5 708.0
TP-7 50-07-1 <695.0 1.5 - 2.0 16.0 2.5 17.0 712.0
TP-8 50-08-1 -699.0 10.5 - 11.0 12.0 4.0 15.5 713.0
TP-9 50-09-1 -712.0 4.0 - 4.8 7.0 4.0 4.8 *
TP-10 50-10-1 688.0 14.5 - 15.0 17.0 6.0 15.0 703.0
TP-l1 50-11-1 691. 0 17.5 - 18.0 11.0 6.0 18.0 709.0
TP-12 50-12-1 710.0 2.5 - 3.0 18.0 4.0 3.0 713.0
TP-13 50-:3-1 691. 0 3.0 - 3.8 10.0 4.0 19.0 -710.0
Background 50il Sample:
50-14-1 * 0.3 - 0.8 N/A N/A N/A *
*
=
Data not obtained
Not applicable
N/A =
-17-
-------
,-
T J\OLE
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l£WISOUnG PIIJ\sr I: INORGJ\NIC I\NI\I YSrS IUSUI1S f nOM 5011- SI\MPI rs
,
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TARGrI ANAL Y 1£ O£J£CTlON
LI S' SUBS lANCES LlM"Sa 50-01-1 50-02-1 50-03' 1 SO-04.1 SO-05-1 SO-Of,'1 50-01-1 SO-OB.I 50.09 I SO-IO-I SO-II-I 50-17.1 SO-I3-1 SO-14-lb 50- 40 {
-'-------...---. --
A I unll ~um 19,800 13,100 1l.100 16,400 II ,600 11,400 13,300 20,"00 16,IiOO 16,900 15,700 13,1100 19,!lOO 16,800 11,000
d
Ant IAJny -- 9 98
Arsenic 4.1 3.4 8.1 2.4 1.5 5.8 1.9 11.2 10.4 9.0 S.li 1.4 4.2 15.J
8arlUII 116°.68 211°.6 186 3,180 161 "I 107°.6 898 2H 2,100 .663 l06 IS&0.6 13&0.6 l41
8eryll II.. 1.1 1.9 1.0 0.9 1.3 0./1 1.4 I /I 0.8 0.3 1.1 2.3 1.1 I 1
CadliUII 2 3 2 '1.1 2 I 14 2 31 U l I I I
Calcll. 11.10042 19,00042 3,68022410l,OOOl24 8,950274 2.440774 79,50042 61,500724 7,0110724 46,40077446,500724 12,10072421,00042 6,,'/!)4? 7, OOOl?4
ChrOlllIUIII 26 13 J) 84 20 9 l3 1,300 31 111 302 74 ('5 36 30
Cobalt 11 18 14 II 14 19 II 15 14 2) 26 16 18 16 Iq
Copper 223 41 31 448 3J 9 II 516 14 1,130 1,530 1.15 14 12 II
Iron 24,400 44 ,800 23,100 38,900 Z1 ,900 16,300 JZ, 100 15,500 56,100 146,000 78,400 38,100 48,100 43,900 !'?,OOO
, LUll 13 61 23.7 316 50 15.6 135 1,190 71.4 910 I. 320 51 17.4 54 IS.7
..... 1,4207 I. 3407 I. 13056 3,59056 1,23056 573'i6. I. 4007 3,830'>6 l1S'.6 4,26056 7,11056 1,27056 1 1]1' 83'}'>6
00 Magnesium l,filO
,
Manganese 115 1.010 510 938 I. 090 961 H2 911 OIS 912 783 1,410 318 912 6n
Hercurv 0.05 0.18 0.09 0.04 0.01 0.06 0.15 0.13 0.11 0.23 0.09 0 10 0.10 0 II
Nldel 11 11 16 21 13 8 IJ 52 l5 97 119 13 12 13 Z4
Pohulum 1.610 1.160 920 1,860 740 61l 864 I. 970 fd9 1,420 2,040 476 1119 lJ2 508
SelenlUIII 2.2
5 I her 30 47 25 40 31 t1 ]4 77 61 148 82 42 !l0 46 SI
Sodi \JIll SHB132 342132 699579 1,460519 1,030579 7].1519 182131 2,410519 796519 2,190519 3,320519 601519 J~9 132 I 7J 137 1',,"'>1'4
, ha I I I UIII 0 5
VanadlUIII 25 ]0 18 2S 20 10 24 . 11 !J4 II 31 3'i ('9 4J SO,
line 940 239 86 630 120 29 59 3,240 4'1 J,430 l,fiOO 9:1 119 116 411
Cyanide 1.1 0.10 1.6 0.116
'iAHI'U HIJHHIIIS
('ulIl;enl rdllOn~ '" e III ""I/~I' 11..""1
_._--- --.-------.-..---- - -------------- ..------ -----.-..-.-- _..
--. ...------"-------- --.- --.--. ------- --- ---------
a Quanlitdtlon 1I.lts not reported for soil samples due to their lIuidhlllty.
b SO-14'1 is a background s.mple.
c SO 40 1 is a duplicate sample of SO-09-1.
,I -- lIultc"les lIIorganle compounds that were nol dell!cled In IIII~ sdmlJle.
t' 1111111',"111 1\ dl,n pre!.pnt to the 14ho'-dtury hl...It" 1tu~ ~tJlI,~'-~c"'ptf~t' IIlImh,'.
Oell'ctlon limits ue dll"lIdhle Oil Ihe Cerillicdies of Alidlysis.
I', I he Idb bl"nk conel'lIl,
-------
TAOU
3
UWISOUHG PlIl\Sr I: OHGI\NIC I\NI\I YS[S IH~SUI IS fROM SOIl. SI\MPtr:S
I u/ J
- - -.-----.
-~-- ..- _.. ;,-- .. -- ...._--_._____.0____. -.- - ._-. -. ._-- -. ---.. .------- ... - - 0'-'
- ..--- .-.-_.
\AMPll HIJHIIIIIS
(lUIII.:elllldlluns dre in u;'0 6, 60u770 ~. JO(/ll .. .110(/" .\11.111111' II .IIIIU' . I,IIOU' . I. ',Oil 1411 1,.'1111
. ,," Il I)JIII 1,,'1111" t. t.
,. I, 100 I, ',111) 140
..,,,
1.111111 ,.
"
1,'11
"
',Hn
-------
1 "UU J
CON' I NUL\)
l tI' ,
--".--.. ------...---.
.-.- -_._---- ------..- ------ -----.-.- ....-. -.
. -- ._~. . .-_.. ..-...' - - .--
- .. .-- - -
SAMPLE NUMI!LRS
IConeenl,,,1 Ions are in ulJ/klJ 1""h)1
--- .. ....-.---.-....--
--- - --.-._..' ----...--.-.-- .-..
.- -- --- '---. ._.-.. --...-
.. --'-'.----.'.
10£NlIf1E0
ORGANIC COMPOUNDS
QUAHIIIAIIOH
LIMitS' SO-Ol-I SO-02-1 SO 03-1 50-04-1 SO-O~-I 500(;-1 SO-OI I SO-08 I 50091 50.10.1 50-11-1 50 17 I SO !J-I SO-14-lb
~o 40 1'-
-----'---"
-...- ---.-'--'--- -.--.--...--------...--------- -
-.--.--.
Heptachlor epo.lde
4,4' -000
.Ipha-Chlordane
CJamu-Chlordane
Aroclor 1242
Aroclor 1260
--'
120
32
~30
440
120
LIBRARY SEARCH COMPOUNDS
Polynuclear Ar~tlc
lIydrocarbons
Ketones
CarboMy11c acids
Esters
S.turatp.d Hydrocarbons
Unsatur~ted Hydrocarbons
Pheno\s
Alcohoh
furan, tetrahydro
01 ft. lone
1rl.ethyl Borane
2-.ethyl-trans-I,I'.
blcyclohe.yl-
OctacOSine
(Octacosane 1) Unknown
(l-tetracosanol 7)
Unknown
9-Octadecena.lde (l)
Benzene,I,I'-4-(J-
"henyl\lro\lyl)-I,1
3,1100 10,000 I, ~oo
!l20 SOD !I/O
1,110
8,200 6,000 340 SOO 1,000 10,000 S,200 6,100
54,042 5.162 8 9 12 16 IJ 9 10
5.500 8, ISO
'1.,140 '1.8,000 1,100
11 12
16
22
8
20,000
22.000
sa. 000
-------
1 J\ULE :)
CONllNUlIJ
3..t I
.-- ------ ._--- _._~-
'-'~,- . -- - - - ----.
-"-- -. ._- - ... -~- - - "--....-
.- . --. - -' - - .. -._-
. ~-_.__._.-..-.
SAHI'U NIJ4UlNS
(COIII;clltrclt IIIns MC III uy/Io.y (",,1,)1
-------_. ---- -------.-----..--. -- ------...--_.._------------
"-_0' --_.-
10lNIIFI£D
ORGANIC COMPOUNDS
QUAN'I TA' ION
, LlMUSa 50-01-1 50-02-1 So-OJ-I SO-04-1 So-OS-I SO-06-' SO-O/'I SO-06-1 SOO!! I So-IO-I SO-II-I SO 12-1 SO-I)-I SO-14-111
SO 40 I'
-_......
Unknown(satunted
hydrocarbon)1.total
Unknown(saturated
hydroclrbon).total
Unknown(hydrocarbon)1.
total
Unknown(hydrocarbon).
total
Unknotoin(HC and
col.... bleed)
Unknown semi volat lIes,
tohl
Unknown volatiles. total
251,000 104.000
42.300
48.400
131.000
1,820
I,J'IO
11,900
10,7.80
1,610
2S,200
14.440
4J,OOO
16,600 131,400
136,900
24,800
10,260
" ' SOO
I,IIIU
,
N
.....
,
13,200
11
4,600 J,SOO
1,/00 MIll
"
/,060 1. 230 SIO 2,SOO 12.000 1,400 4,400 4.400 I, '100 1.000 1.700 3,4/10
9 14
a Ouantltatlon 11.lt. not reported for .011 simple. due to their varIability- Applicable lImits are avallclble on the CertIficates of Analysis,
b SO-14-1 Is a background l.-ple.
c SO-40-1 Is a dupllclte s-.ple of 50-09-1.
d Compound I. 1\'0 present tn the \Iboratory blank. the superscripted number Is tl~ lab blank concentratIon-
e Reported concentrltlon II below the qUlntitation 11.lt.
f -- Indlclte. (;CRpOUnds that were not detec;ted.
-------
TABLE
I
N
N
I
4
L£WISOURG PHASE I: [P TOX IC ITY ANAt ysrs U[SUUS rnOM SOli. SAMPtrs
COMPOUND
Arsentc
lu "..
Cachlill
ChrOlll11ll
Lead
Mercury
Se I en II..
Silver
(ndrln
LI nd.ne
MetholCychlor
Jo..phene
2,4-0
2,4,5-T' (SllvelC)
.'------'------ ---- -- ---- ..-.. '..
O£J[CIIOH
lIHltS
(ppm)
SAHPll NIIHIIIRS
(r:onr.t'ntratlnns are in '"'1/11 ter (PI1II1))a
R£GUlATORY
SIANOAROSb
(ppm)
SO-05-1
SO-08-1
SO- 13-1
-..--------- --.--.
0.03
0.002
0.005
0.01
0.03
0.001
0.06
0.005
0.0001
0.0001
0.0001
0.0004
0.0002
0.0001
c
5.0
100.0
1.0
5.0
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
0.76
0.82
0.0711
O..l~
O. J4
. Pp8 - ~rts per .llllon (.'lllgrams/llterl
b In .ccord.nce with lennessee Ituardous Waste Hanagement Act. Rule 1200-1-11-.07, and RCRA
Regul.tlons defined under 40 erR Part 264.
c -- Indlc.tes co.pounds that were not detected In thIs sample.
-------
TABLE 5
~ SAMPLDIG S1JJDIARr
Well ID
Sample ID
Sampling
Date
Well
Depth
pH
Temp.
(oC)
Condo
(umhos/cm3)
Sample
Comments
RW-1 6-21-88 -100 8.35 17.3 70
RW-2 6-21-88 NR 7.02 NR 15
RW-3 6-21-88 -65 6.95 NR 2
RW-4 6-22-88 NR 7.36 NR NR
RW-5 6-22-88 225 7.20 NR NR
RW-6 6-22-88 250 6.77 NR NR
RW-7 6-22-88 84 7.25 NR NR
RW-8 6-22-88 -140 6.89 NR NR
RW-9 6-22-88 -125 7.35 NR NR
RW-10 6-22-88 40-50 6.64 NR NR
S-:l 6-22-88 NR 6.47 NR NR
MW-l GW-01-1 11-7-88 -77 6.76 18.6 1,590
GW-10-1 11-7-88 Duplicate of
GW-Ol-l
MW-2 GW-02-1 11-10-88 -62 7.10 18.4 1,200
MW-3 GW-03-1 11-8-88 -67 7.49 18.3 540
GW-03-2 11-8-88 Matrix spike
GW-03-3 11-8-88 Matrix spike
Duplicate
:...: -4 GW-04-: 11-10-88 -67 7.11 16.9 1,900
MW-S GW-05-1 11-7-88 -66 6.84 16.7 1,750
P-1 GW-21-1 11-7-88 47 NR NR .NR Partial sample
P-2 GW-22-1 11-10-88 -34 7.45 17.6 1,400
P-3 GW-23-1 11-10-88 35 NR NR NR Partial sample
P-4 GW-24-1 11-11-88 -45 NR NR NR Partial sample
SW-01-1 10-17-88 NA 8.34 23.5 57
SW-02-1 10-17-88 NA 8.15 22.7 78
SW-03-1 10-18-88 NA 8.18 17.4 57
SW-21-1 10-18-88 Duplicate of
SW-03-1
SW-04-1 10-18-88 NA 8.17 18.1 53
SW-04-2 10-18-88 Matrix spike
SW-04-3 10-18-88 -- Matrix spike
RW = Residential Well NR = Not Reported
MW = Monitoring Well NA = Not Applicable
P = Piezometer Well S = Renamed spring SK-Ol for Phase II
SW = Surface Water Note: All depths are recorded in feet
GW = Groundwater Well
-23-
-------
TABLE 6
GROUHDWATER HONI'l'OR.ING AND WELL DATA
Well
Total
De~tha
Total
De~thb
Depth
Extensionc
Total
Depthd
Borehole
Bottome
Groundwater
Elevationf
Surface
Elevat:ion9
MW-l 76.5 73.4 635.0 684.7 708.4
MW-2 61.6 59.0 641. 9 688.4 701.0
MW-3 66.5 63.7 641.8 684.7 705.3
MW-4 66.7 86.3 19.6 83.6 640.2 689.2 723.5
MW-5 66.3 64.1 657.6 693.2 721. 4
P-l 46.9 77.3 30.3 75.3 644.4 685.1 719.7
P-2 31.2 31. 6 665.6 677.3 697.2
P-3 35.0 58.8 23.8 56.3 667.2 691. 0 723.3
P-4 45.4 74.8 29.4 72.9 648.5 688.7 721.3
a) Total depth from top of casing, measured in feet (Phase I).
b) Total depth from top of casing, measured in feet (Phase II).
c) Depth extension of the 3 piezometers and 1 monitoring well during Phase II,
measured in feet.
d)
Total depth from ground surface.
e)
Borehole bottom elevation, measured in feet (Lowest elevation for both Phase I
and Phase II)
f)
Groundwater elevation average, measured in feet.
g)
Ground surface elevation, measured in feet.
All monitoring well borehole diameters are 2.97 inches
All piezometer borehole diameters are 2.40 inches
-24-
-------
1
TABLE 7
PHASE I I GROUNDWATER SAMPLING SUHKARY
Well
Sample
Number
Well
volumea
Purged Well
Volumesb
Sample
pH
Sample
Conduct.c
Sample
Temp.d
Sample
Comments
MW-1 GW-01-2 17.83 5.0 6.98 1,000 16.8 Strong Sulfurous
Odor
MW-2 GW-02-2 16.95 5.0 7.27 760 18.0 Sulfurous Odor
MW-2 GW-02-3 Matrix Spike
MW-2 GW-02-4 Spike Duplicate
MW-3 GW-03-4 15.30 9.2 7.64 778 16.4 No Odor
MW-4 GW-04-2 15.84 5.1 7.78 540 18.9 No Odor
I' MW-5 GW-05-2 13.22 5.3 6.81 1,600 17.2 Slight Sulfurous
Odor
P-l GW-21-2 10.80 1. 6e 7.11 3,800 15.5 Strong Sulfurous
Odor, Blk Tint
P-2 GW-22-2 2.7 3.7f 7.54 790 17.2 Slight Sulfurous
Odor
P-3 GW-23-2 3.7 3.5f 6.95 940 14.2 No Odor
P-4 GW-24-2 8.2 17.1 7.81 520 18.1 No Odor
a) Well volume measured in gallons
b) Purged well volumes in gallons
c) Sample conductivity in umho/cm3
d) Sample temperature in 0c
e) Purged dry and allowed to recharge prior to sampling
f) Purged dry twice and allowed to recharge prior to sampling
-25-
-------
T AUu 8 LlW I SBUI~G PIIASE I: OHGANIC ANAlystS IHSUl' S IHOM GHOllND WAil H SAMPI15
1 ..t .1
-- -----~-- ---_..-. . --_.. ---- ~.- ----_._.- - --"--._- -..-." -- -. - - H .. _. - -. -. -.. --~->-_. ~ -'n. - ._- ~_. - . ..- -
SAHPll HIJHIILIIS l(onl:clllrclllollS clre ill u'.I/lller Ipphll
_.- ---_._--------~-_.. - p--'------- ------,. - --.. .. 0" . .,.- - ---_. .. - -.---'._-- - -.._-.. .----..".
IO£NllfI(D QUANIIIAIION
ORGANIC COMPOUNDS LlMllScI (,\1-01-1 (,11-0"-1 611.0.1 I (,\I-04'lb (,\/ II~I' I l>\I- '0. ,e (,\1 11.,11 IJ\I.n.' l>w-n-,b (,\1- 74 ,It
-----_.--------.-------_._---_._----._---- -----_._---._-_.. -
IARG(1 COMPOUND LIST SUBSTANCES 23d 2' l 3' 31 -/
Melhylene chlor'de S e
48 24S 410S (j I
Acelone 10 " 48 '9 280 3. UUU'
C.rbon disulfide S
Chlorofona S 14 9 IS
I.I-Dlchloroeltline S
2-Bulinone 10 - -
I.I.I-Irlchloroethane S 2' I' z'
Bromodl chI oromethane 5 I'
Benlene 5 / ,,' S
4-methyl-2-pentanone 10 ,,' 4' z'
loluene S 2'
I
N Chlorobenzene 5
0- J' 4'
I £thy I benlene 5
Styrene 5 2' 2'
Iota I Xylenes 5
4-_thylphenol 10 NACJ NA NA
i' Benzoic .cld 50 NA NA HA
!
Naphthalene 10 HA NA NA
Acenaphthene 10 HA HA HA
Dlbenlofuran 10 NA HA NA
Olethylphtha,.le '0 HA NA leA
fluorene 10 HA NA NA
n-Nltrosodlphenylamlne 10 NA HA HA
Phen.nthrene 10 NA NA HA
Anthr.cene 10 NA HA /lA
D'-n-~ut~lphthal.te 10 NA NA HA
Fluoranthene 10 NA. HA NA
HA HA NA
pyrene 10
HA HA NA
Buty'benlylphthal.te 10 212 s' sl
J' 9" ," HA HA leA
bls(Z-ethylhe.yllphthalate 10
HA leA HA
dl-n-octy'phthalate 10
HA NA NA
Belliul b I f I uoullthene 10
NA NA A
lelllOl ~)' I uorclnthelle 10
1M NA
ICIILLJ(" )I'yrclle 10
-------
TADLE
R
CONT INUI f)
. IDEN'IFIED
ORGANIC COMPOUNDS
QUANri 'AriON
LlMltsa
SAMPlE NlJ4I1IAS
-~ ------- --.-. ----- _. ._-. --. - .-. .--
--. - ---. -- - ...
GW'OI-1
- -------------
GW-OZ-.
GW-OJ. I
Hept.chlor epoKldi
4,4'-000
alphl-Chlord.ne
94n111-Chlordlne
Aroclor 1242
Aroc lor 1260
LIBRARY,SEARCH COMPOUNDS
I
N
.....
I
Polynucle.r Ar08atlc
Hydroc.rbons
Ketones
Carboxylic acids
£Sters
S.tur.ted Hydroc.rbons
Unsatur.ted Hydroc.rbons
Pheno Is
Alcohols
fur.n, tetrahydro
01 ft. lone
'rl~thyl Hor.ne
2-methyl-tr.ns-I,I'o
blcyclohexyl-
OctacoSine
(Octacos.ne 1) Unknown
(I-tetr.cosanol 1)
Unknown
9-Octidecen"lde (l)
8enzene,I,I'-4-(J-
phenylpropyl)-I.l
0.05
0.10
0.5
0.5
0.5
1.0
e
-.. ----------
(Cullcelll, "l'uns
-------
TJ\OU
8
CON fI NUrD
.I o' I
.--- --_.
.. -----.---
-.- -., -------.-.----
.---- .__.- "-- .--.-- -_...
_. -"." --.._-- - --. . .
.. ".---.--"
, 51.""11
HtlHlH MS
(Com:en'rcltluns ue in uq/litcr h1v"l1
--- -- ----.' ---.-- ---"----- -- ------- ---.---- .--------------- .-. _.
IO[NllrILO
OR~AHIC COMPOUNOS
QUAHIIIAIION
lIMII Sa
(;11-011
(;11-02-1
(,11-03 -I
(ill- 04 -III'
611-05-1
611-10-lc
(;1I-21-11J
(;11-22-1
(,1I-23-lb
(;11-24 I"
-------
I
N
00
I
Unknown(saturated
hydroc.rbont1.tota'
Unknown(saturated
hydroc.rbon.tota')
Unknown(hydrocarbon)7.
total
UnkIlOlfn(hydrocarbon).
total
Unknown(He and
colUllf'l bleed)
Unknown semivol.tlles,
total
Unknown volatlles,total
-- e NACJ
NA NA
NA NA HI.
NA NA NA
HA HI. NA
NA NA HA
HI. NA NA
a Quantit.tlon 1181t. Ire not .ppllcable to Ilbr.ry search compounds.
b these simples Ire frC8 wells .hich were not adequately developed. Results from these wells do not represent actual gruund water quality
concentntlons.
c 6W-10-1 Is a dupllclte .~Ie 0' 611-01-1.
d Present tn the ...ple and the lib blank. 'he superscripted number is the blank concentration.
e "
-- Indlclte. orglnlc cOMpOUnds that were not detected In this sample,
r Reported concentration Is below quantitatlon 11.lts.
9 HA - Due to the nlilible slIIIPle volume, these samples were not analYled for these compounds.
-------
IAUU I). UW I SUURG PIIAS[ I: INUHGANIC ANAl YSIS IH.SUL lS f"ROM GIUJUNIJ WA lI.H SAM!'I.!. S
_. -,.. .-- ..-.. --. .-. - . --.-.-..-------- --'.-.-. - . _.---- -. ---. - ----.....- . .--. . ..--. . -
. ..0.. ... -...
~)AHI'II NUHlIlRS (<.ulI(;l'nl relt Ions .He In uy/ll t.l'r (""b"
----------------- .-_ . -- -- ----- --.----- " 0'."'. ... ~ _... --" -
1AA6£1 ANALYtE D£TECT ION _.----
LIST SUBSTANCES lIMI TS. 611 01.1 (i1l.Ol-1 (ill 03-1 (i1l-04 '1" (ill O~ I (ill. 10-1(; 611-21-11.1 (ill n'l !i1l-23-lb 611-24 Ih
------ ---- -- .._--- --,. ------------ ..- --
Alum i num 40 d 706 1,0"0 NAe
136 2,460 714 HA
Ant IlIIOny 30 NA HA
Arsenic 2 " 21 HA HA
Buium 2 .,64 164 4 44 604 138 "., 10 NA NA
lIery III UIII 1 HA NA
Calhlum 5 NA Ii"
Cellclum ]0 18],000 140,000 49.~OO 241. 000 191,000 136,000 3;'4,000 190,000 HA NA
Chromium 10 13 2" NA N"
ColJcllt 20 21 NA NA
Copper 10 I" 141 NA NA
Iron 10 24..,00 432 63 26..100 7",HOO 744 4",100 .,~~ NA NA
I
N leeld 3, 3 19 III NA NA
\0
I Melgnesi... 30 21 . 900 28.200 24,800 39.800 29.800 40.000 29.300 41. 400 NA NA
Mangelnese 2 114 341 ] 208 14" 49 66" 69 NA NA
Mercury 0.2-0.] NA HA
Nickel 20 24 39 NA ""
Pot IS slum 1,000 9,260 10,]00 ],400 28,200 9,900 13,300 3,930 2,440 NA NA
Selenll8 ]-10 NA NA
Silver !i 18 16 11 31 NA NA
Sodl... 200 !il,!iOO ]1,000 4,1."0 12,100 64,"00 61,600 8,9"0 39,100 NA NA
Thall 118 2-] NA HA
Veln.dtl8 10 HA N"
ltnc 10 910f 1310 910 46]10 .,10 810 1,/11010 1110 HA NA
Cy.nlde 10-20 HA NA
. Aelnges .re reported when detectIon lImits velry among sel~les.
b These SllIIples are fnD wells which were not eI.lequeltely develo"ed.
concentr.tlons.
1.\1 10 I Is a .t,,!!' Icale s.smple of LII 01-1.
III' suits frOlll these wells do not represent elel u.s I Ylu",,,' wdter qu.sllty
.1.'
I.... ,."t. I '8""~"'fI,J'.
11.,.1 .,'". ,,"I delc.I,'d In thl~ ~.\I"I'It~
'r ..,
..1 'r ,0', 'r ,.1..,... II.."... "d"'I'I,.., ".'Ie ""I .s",IIy,,,d lur this par.smeler.
",. '" "",,,,, I.I,.,,~ I"" ""I"'I~I.II"lt'd "ulI,lter Is the l.sll bl.sll~ llllll.l'"II..I,""
-------
TABLE
10
UWISBURG PUASE II:
J AAG£J ANAL Y IE
LIS' SUBSJAHC£S
O[J[CJlQN
LIMnS.
R82
I
w
o
I
A Itft I num
Ant IlIIOny
Arsenic
Bar II.
Berylll...
Cadinh..
Cdlclum
ChnJIIII um
Cubalt
Copper
Iron
lead
--c .
42d
I. 400
14112
1!l2
119
4
Mdgnesl...
Manganese
Mercury
Nickel
Potanll.
SelenlU8
Silver
SodlU8
tNI "U8
Vlnadll.
Ilnc
1,290
881
6!120
INORGANIC ANALYSES RESULTS FOR GROUNn WATER ANO ASSOCIATrO QA/QC SAHPI.rS
-- ...---.--.------..- ---.---.-----------.- --_..... -. ..
46!1
14
SAHI'U NUHIII US
".'----"
---- ~--_._--- .--..--------.. -.------
([uncenlrdtions are in u!lnller (ppb))
------- .---.-.- ------.-.-.-.-.---- --__-'-.0- ...-.
r02
133
40,'i00
43
3812
197
10
'in
011
[,11 0 I -7 [,11- 01-7
GII-0]-4
[,11.04-7
....---------------- ---
23
171,000
31,400
11
]4
18,100
41,100
12816
Br/
43
!I
98,800
I)
18
1'i011
18,100
1!I'i
32
II , 000
11,100
!llO
6'i
1112
6
97,000
44
7S 17
67011 S,3'i076
38,800
19
!I.930
16.000
6920
176
111
41
90,800
10
DOl7
,7
33,900
I
21
2,SI0
S,030
61"0
11970
'--.." .---- ---..--.-...- ---.,.-. ..'.
r,Il.0'i-7
r,Il-09-1b r,ll 71 'I
. ..--.--- .---------..
._-------
1)7
1i987
6992
GII-72-2 GW-2]-2 GII 74 7
81i
II
76
11,400
40
33,400
4120
42"0
..-----.-
4319
-- ..---- _._-
a Detection 1I...lts not reported 'or Ulllpies due to their varidl.. I It)'.
h GII'09-2 Is a dupllclte salllple 0' GII-O!l-2.
c -- Indicates Inorganic cOIIIpounds that were not rtelf'cted in Ihis Sdmple.
d Compound Is also presenl In the laboratory blank. Ihe supelsc.-iplf',1 nllmber Is Ihe Idb bldnk LonCt',,'r,tll'"1
1111 AIIISd'P. blank; RO<' Is 'or Ihe week 0' 10-19-1\9 dnd IS assocldl",l ..llh ellI 0' the 5o!Iqlles "" Ihls lell.le
"' 1...1,1 IlId"k, tlI'I IS lor the wl'ek 01 10-19 1\9 dIll I Is dssoCldlr',1 ..lth dll ul the ScIIIII,les un 1'"\ 1,1101"
11,,11 lid I.". IIIIS 15 a Sdmplf' "I I III! ..dler lise' I 1I1I11I1I11'''d'''' II,h'" "1 dclivlllf'S
S4
8
56
1911,000
191,000 499,00091 11],000.1]1,00091
18,10017
107
)),600
4S1
18,40011
4<'
3<',100
441
313,000
4
],300
11
28
!lIS
8,040
4620
10,400
21
19,200
71.100
Oetectloo limits dIe dv"ita!>1e on the ('ertllll:dl"s "I "ndlysls.
99,900
9S,600 110,000
110
fd ,000
II
9,100
9,490
10J!.!
101
15,4/J0
13
30
Ii
'lIi,700
11111
7',9
Illl
3, tHHlib
1\
7~,'illO
104
41
3,1110
8,010
]319
'I'l/lO
-------
TABl£
11
lLWIS8URG PItAS£ II:
ORGJ\NIC J\NJ\I.YS[S HlSUllS itm GHOUND WJ\nR J\Nn J\SSOCIJ\llU QJ\/QC ~J\MPLLS
([0111':1'111 I 011 lOllS .III! III UI,/Il 11'1' (1I1Ihll
JOlNl/rllO
OAGANIC COMPOUNDS
QUAIIT" A II ON
lIlns
-_.__._- - ----- - - - .. --" ."
. -'--", --..- --.-..-.------ ..
.. ." -- . -. ---.....
. .--. _A' .----_. .
...---.--.--.
~AHI'II HtlHUIH5
-----...--- -0 -_.- -.-"-...---.
-- - -...--- --- ._- _.
- _. .--
.-. .-- - ..
____do -.-.-.---- .
182
0\1 (,11-01-2 (,\1-0<'-2 GII-03 4 '.\1.04-<' (1\10').<' (;\1'09-<,<1 1,\1.<'1-2 GW.22-2 GW.23.2 (,II 24..
ROZ
102
1113
TARGeT COMPOUND lIST SUBSTANCES
I
w
.....
I
~ .
Methylene chloride
Acetone
Carbon disulf ide
Chloroform
I,I-Olehloroethane
2-Butanone
I,I,I-Trichloroethane
Brumodlehloromethane
Benlene
4-methyl-2-Pentanone
Toluene
Chlorobenlene
£thylbenlene
Styrene
Total Xylene5
I,I-Olehloroethene
S
10
5
!»
5
10
!»
5
5
10
5
5
5
5
5
5
'-'--------------.-.------ -
2e2b - - c 2e2 - -
320 430 . /3' 8J 23 5~0 '710 58 II ~O
13
3e 24
5
5
B
3e
5
- - .
-.------
...----- .---.-.-----' . - .,.-
a G\I-09-2 Is a duplicate sa~le of G\I-05-2.
b COIIIpound Is also present tn the laboratory blank. Ihe superscripted number is the Idb bl
-------
5.4
Surface Water Contamination
A total of 19 surface water samples were collected at the Site. Samples were
collected primarily in the quarry pond but a background surface water sample was
collected at the intermittent creek above the pond during a period of heavy
rainfall (as this stream is dry during periods of drought). The analysis
revealed only one organic contaminant (methylene chloride) that was identified at
low concentrations (3.6 ppb). Analysis also revealed inorganic contaminants of
concern contaminants are: aluminum (72 ppb), barium (148 ppb), copper (18 ppb) ,
iron (589 ppb) , and manganese (133 ppb). Nic~el at 31 ppb and zinc at 44 ppb
also appear to be elevated in the pond water especially at locations adjacent to
the landfill and the junkyard. A complete list of organic and inorganic
contaminants is listed in Tables 12-15.
5.5
Pond Sediment Contamination
The sediments in the quarry pond (Figures 8 & 9) which average 2.0 feet thick
were also sampled and analyzed for anomalous organic and inorganic compounds. A
total of 19 sediment samples were recovered and analysis revealed that 5 organics
and 12 inorganics were identified above background levels. The organic com?ounds
are: methylene chloride (44 ppb) , bis(2-ethylhexyl)phthalate (5672 ppb), acetone
(1899 ppb) , carbon disulfide (5 ppb) , and 2-butanone (10 ppb). The inorganic
contaminants identified are: aluminum (19850 ppm) , barium (183 ppm), chromium (37
ppm) , copper (70 ppm) , iron (40833 ppm) , manganese (2387 ppm) , zinc (618 ppm),
lead (59 ppm), vanadium (26 ppm) , silver (30 ppm) , nickel (17 ppm) , and cobalt
(13 ppm). Tables 16-19 summarize analytical data for both phase I and II of the
pond sediment sampling effort.
5.6
Fish Contamination
A total of 11 fish samples were retrieved from the quarry pond for analysis. 0:
the 11 samples, 8 were Golden Shiners (Notemiqonus crvsolencas) while the
additional 3 samples were Spotted Sunfish (Lepomis punctatas). Published studies
on age class distribution of the Golden Shiner (Pflieger, 1975) indicate that t~e
fish collected at Lewisburg were approximately 5-6 years old. The age class c~
the Sunfish is estimated at 3 years. The length to weight distribution for bc:~.
fish species is shown in Table 20. Analysis was performed on two fish fillets
and two composite fish samples (Tables 21 & 22). Several organics and inorga:-. ~.'.
were detected in the samples at concentrations higher than that found in other
media. No background fish data were available with which to compare sampling
results, nor were sampling efforts extensive enough to eliminate chemicals base:
on frequency of detection. Thus, all chemicals detected in one of the two f~5~
fillet samples were included on the list of chemicals of potential concern i~
fish. Organic contaminants found in the fish are: methylene chloride (18 ppt
acetone (905 ppb) , carbon disulfide (310 ppb) , toluene (33 ppb) ,
-32-
-------
1 AUl[
I/.
LlWISUUI{G 1'111\51" I: ()I{Gl\tHC AN7\'n'SI S RI:SUIIS IIHlM POND SUIU ACI WI\II I{ \I\MI'II~.
I .., .I
-------.---- -
~)AHf'11
,
HIIHIII", (Co'"_elllldiluns dlC 1111"1/111." (1'I'h) I
ID£NIIIIIO
ORGANIC COMPOUNDS
IARGEI COMPOUND LIST SUBSTANCES
I
w
w
I
Methylene chloride
Acetone'
Carbon disulfide
ChI oro for'll
I,I-Dlchloroethane
Z-Butanone
I,I.I-'rtchloroethane
Bromol.liehlorumethane
Benlene
4-methyl-Z-pentdnone
'oluene
Chlorobenlene
Ethylbenlene
Styrene
lotdl Xylenes
4-methylphenul
Benlolc acid
H.phthalene
Acenaphthene
Dlbenlofur.n
Dlethylphthal.te
fluorene
n-Nltrosodlphenylamlne
Phenanthrene
Anthracene
Ol-n-butylphthal.te
fIuor.nthene
Pyrene
Butylbenlylphthaldte
bis(Z-ethylhe.yl)"hlhdldte
111-0-01:1 ylphlhdldle
III'II/U(b)llwHdnllll'IIC
IICIII II ( k Illuur 01111 hclU~
11<:11/11 (d II'Y' "II.~
...-. - -- ...
QUANIIIAIION
lIMII~cI
--------.-- ----------- -. ----.-
~W'OI 1
SW'OZ-I
SW 04 I
~W 71 I"
SW-OJ-I
------
--------
----- --- -- -
5
10
5
5
5
10
S
!>
!>
10
!>
5
5
S
S
10
50
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
III
Zle
II
II
16
21
II
II
- .,
-------
TAUt[
1l
CON II NUl. I)
-_..~-
ID[Hllf/[D
ORGANIC COMPOUNDS
QUAH III A lION
lIHIISd
Hephchlor -poxl. .
4 . 4 ' - ODD
alptld-Chlord8ne
gdllllll-Chlord8ne
Aroclor 1242
Aroclor 1260
LIBRARY SEARCH COMPOUNDS
I
w
~
I
Polynucle.r Aromatic
Hydrocarbons
Ketones
C.rboxyllc acids
Esters
S.tur.ted Hydroc.rbons
Uns.turated Hydroc.rbons
Pheno I s
Alcohols
funn, tetr.hydro
01 H.lone
'rl~thyl Bor.ne
2-~thyl-tr.ns-I.I'-
blcyclohexyl-
Oc hcosane
(Oct.cos.ne 1) Unknown
(I-tetr.cos.nol 1)
Unknown
9-0ctadecen.mlde (I)
Bl!lllene,l,l' -4- (3-
phenylpropyl)-I.l
o.os
o 10
0.5
0.5
0.5
1.0
..-. ~._~.-._---- - '-'.-.-... --._- ..
~AHI'II
I of .I
NlJHIIUIS ((lInU~nlrdlions ale in UIJ/1111~r (",,"'I
-.-. _'0- "0_-
. .'.. -- - -.. -_.. -----.----------.-...-..... -_.
511- 01.1
511-02-1
511-03-1
511-04 I
-----
d
8
SII-21-lb
---'--.--
-------
TAUll
12
CONT INUm
3 IIf ]
. -- -----..- -----.. -------- ."-. --- -,- .. -.----. -
--- .-. . - -- - ~.
~AHI'Il NIIHIIIIIS ([UlII.enlrclllons d'l' in IHJ/lilt!" (11111.1/1
---_.-- ~-- - --- - -- .
-...- - -'--- --------- --.- ---.
IO(NIII"I(O
ORGANIC COMPOUNDS
QUANt I tAllON
LlHIISci
SW.OI.I
SW'OZ I
5\1 0]. I
S\I.04.1
S\I ? I . I Ii
---,--- ----
--.-. -- ._----
I
lv
V'
i
Unknown(situratid
hydroclrbon)?,totll
Unknown(satur.ted
hydrocarbon),tot.1
Unknown(hydroclrbon)1,
totll
Unknown(hydroc.rbon),
total
Unknown(HC and
col..... bleed)
Unknown semlvolatlles,
total
Unknown volatlles,total
d
8
61
28
30
a Quant Itatlon II-Its Ire not appl leabl e to "brary sear-cll compounds.
b SII-21-1 Is a duplicate s-.ple 01 SII-03-1.
c C~und Is present In the lab blank also. Ihe superscripted niJN>er Is the blank
concentration.
d -- Indicates orglnlc cu.pounds that were not detected. ,
-------
JAOlf
I
I,.)
0-
I
n
UWISDURG PtlAS( I: INORGANIC ANAlYSr:S IH:SULTS fROM !'ONU SUIHAC£ WAIU{ SAM!'I.I.S
--_._- ----------'-...
TAAG[f MAUl(
LI 5 T sues TAICES
D£1[(IIOH
lIHIIS"
",..Im8I
Antl8Or'lY
Arsenic
B.rIUIII
Beryl I I...
C.ibi...
C.lclUIII
ChrOllIUIII
Cob. It
Copper
Iron
Lead
Magnes I III
Manganese
Mercury
"Icke'
Potau I III
SeleniUIII
Silver
Sod hili
1tw" 1111
40
30
2
2
1
!I
34
10
20
10
18
4-5
JO
2
0.2
10-20
1.000
3-5
5
200
2-3
10
6
10
Van.dllll
llnc
Cyanide
---'--'--.-.. ._- .---'----".. .
. - -- - .--- - -. "---. -'-'..' --- _... ..
SAHl'll NUHIILRS
511-01-1
I!I./OO
C
J
909
9
280,00034d
50
20
160
J8.00018
156
25.000
3.220
19
22 ./00
e
4J
42,600
U
1.4406
------------_..__.--.-
511-02-1
8,340
661
8
294.00034
32
10
69
20,40018
105
24,100
2.820
O.J
IJ
Z2 , 400
II
44 .lOO
II
1,4006
_._._---~-
(LuIILt~nl loll iuns are 10 uy/ltter ("pb))
5\1.03. 1
134
15/
J6,50034
IJ
12518
16,/00
98
Z2 .100
45,500
ll6
. Rdnges dre repurted when tiel cd 100 limits vdry 01""'111.1 s
-------
TADLE .14 .
LEWISDURG PIIAS£ II:
OI{GAN IC ANAL YS£S HlSUi lS fOR SUIU AU WA IU{ ANI> ASSOC IAHIJ QA/QC SI\MI'LrS
-------.,.- -------_._-- .---- ----_._-~. -- "- - ..-- ._-_.
--..---.-.. -'-'--
SAM!'ll HIIMIII WS
Ilollcenlrdllolls dre III ulJ/lller (pI'b))
.---.----.--- .---- --_. --.- -_.. ------ -- '---
10[Nl1FI[0
ORGANIC COMPOUNDS
QUAIl ITAUOI
lIJlnS III-OS
S\I-O~!>d S\I.06
S\I 01 181
1181
IDI S\I-08-1 SW-09-1 S\I-IO-Id ~W-II-I
1114
11'-3
F8]
TARGET COMPOUND LIST SUBS lANCES
Methylene ~hloride S -- b ZeZc Ze2 ,e2 leZ
Acetone 10 21 34' 4e 21 III
Cdrbon disulfide S
Chlorofol'1ll S 11 2'l 18 19
I,I-olchloroethdne S
Z-Butanone 10 Ze "e
I I,I,I-Trlchloroethdne 5
\,.oJ
...... Bromodichloromethdne 5
I
Benlene 5
4-.ethyl-2-Pentanone 10
Toluene S
i Chlorobenlene 5
Ethylbenlene 5
Styrene 5
Total Xylenes S
I,I-olchloroethene 5
---- ----
a SV-OSS Is a duplicate s.-ple of SV-OS and S\I-IO-I Is d duplicdte sdmple of S\I-09-1.
b -- Indicates organic c08pOUnds that Nere not detected.
c C08pOUnd Is also present In the laboratory blank. Ihe superscripted number Is the lab blank concentration.
e Reported concentration Is below the quanti tat Ion limit.
TB Trip Blank; TBI Is for the week of 10-12-89, T84 Is for the week of 11-8-89.
RB Rlnsate Blank; RBI Is for the week of 10-13-89, RB) Is for the week of 11-8-89.
FB Field Blank; F81 Is for the week of 10-13'89, F03 Is for the week of II A 89.
'81, RBI, and F81 are associated with S4l11Jlles S[ -OS to SF -01.
1114. A8.1. amllB3 dre dSsocldteti with salllfiles S[-Oll 10 SI-II.
-------
lABLE
I r)
LEW I SBURG PtlAS£ II:
1ARG£T ANAL HE
LIST SU8STANCES
O[I(CIIOII
lIMIJS.
I
w
00
I
Ah..I",,,
Antimony
Arsen Ie
Bar I UIII
Beryl! "..
C cuh II..
CalcilD
Chromium
Cubalt
Copper
Iron
lead
""gnesiUIII
Manganese
40
30
2
2
1
5
30
10
20
10
10
2-4
30
2
0.2
20
1. 000
2-4
5
200
2
10
15
"ercury
"Ickel
PotuslUIII
SelenllD
Silver
SodlUIII
Thai I IUIII
VanadIum
line
.05
54.200
II ,800
161
41
9.420
18,900
INORGANIC ANAlY~)I'J RESULTS FOR SURFACE WATER AND ASSOCII\HO QA/QC SAttPl rs
---.-----..._U_----.----- .~._.. ..--- ---.-._-_. ..----.-.. . - --. -. -- -.----
5\1-0~~1I
--c
136
I
136
5\1-06
52
131
I
~I] , 900
24
]20
12,100
144
40
9,990
19,400
]116
--- - _.._-
SAHI'II NUHHI!lS
tCoru;elll r,,1 lOllS "re '" uy/llter I\'llhll
-----...._._--- .--,.-. -- .--- - ---..
5\1-01
101
ROI
511-08-1
SII.09.1
.-------...-.---- ..-..
].110
9~
(,1.100
28
II
].46038
6,820
101
0.2
1,1601010
10,900
61"
511-10.111
3.490
92
61,400
],500]8
10
1,460
114
8,4901010
11.800
49"
-. --.-..
511 '11-1
....._--"- --"-'---.'
f83
1/3
95
19,800
690]8
8,540
69
1.0101010
12,100
66"
~B3
4111
-.-------.--------.----------...---..-.----.. -.---
III"
5.210
146
2
35
54.300
35
331
355
3
59.600
£>8
11 , 400
12.000
156
32
9.810
19,300
1016
454
8110
25
5.340]8d
10
1,150
110
13,200
159
32
II. 000
I. 1901010
20,~00
]96
366
48]
6416
4~16
3915
4215
9~11
" Ranyes are reported when detection limits vary "lIIOng s"mples.
II '511.055 Is . duplicate sa,...le of 511-05 and 511-10-1 is a duplic"le sample 01 SII-09-1.
c - - In"Icates Inorganic compounds th"t were nol "etecled In Ihl5 s"""lIe',
01 I'r~5efll 111 Ihe s"mple and the I"h 1I1
-------
APPROXIMATE LIMITS
OF POND
— POND SEDIMENTS ASSOCIATED
WITH THE JUNKYARD
POND SEDIMENTS DUE
TO NATURAL DEPOSITION
POND SEDIMENTS ASSOCIATED
WITH THE LANDFILL MATERIAL
FIGURE
LEWISHURG DUMP SITF. AI'PROXIMATI
SCALE (APPROX.)
EXTFNT AND TYPES
IN THE POND
OF SEDIMENT
IOO FCET
-------
RUSTY STOVE
Fl DATING TRASH,
BOTTLES, STYROFOAM,
WOOD TIRES
/'AUTO . ,
/ APPLIANCES, /
CANS, Mlf.C .'
STYROFOAM,
BOTTLES, GLASS SEALED DRUM
IN WAI EH
2 DRUMS
c-or
3 DRUMS
POND ACCESS
APPROXIMATE LIMITS
OF PONO
STYROFOAM,
SCRAP METAL,
SCRAP
LEATHER
TRASH
;^-"-/;.-'. ••;:•' -.•.::.• -GLASS, TRASHT ;:<"•."• ,''V •.-.•••:.*> SCRAP " , ;
::\''-'':';'^\\':-.''r.:-''.^\\-f:',-:'':- : '•'. '•'/'/.
;>;' *'• v^'i:": LANDFILL MATERIAL'/:-^ ';.''.' • '.^•'•'':i''.^-':'^'':-''-:.:---:'.- '•':'• ;v.;- ':'.'
TIRES
FIGURE
SCALE (APPROX.)
0 5O IOO FEET
LEWIGOURG DUMP
oisiHiBunoN or
IN TML I'OND
SI HI
-------
TABLE 16
If.WISnUHG PIIAS[ I: ORGI\~ - ,\NAI.YSrS RrSlJ1 IS (HUM POND SrOIMINI SI\MPI.rS
1 01 :I
I DENT! F I ED
DRGAIII C COMPOUNDS
-----.
.'.------ ._-------
SAMI'I[ HIIHIIIM,) (Cullcellll"dllOIlS
-------
lADLE 16
CONI INUI n
IDEHllflEO
ORGANIC COMPOUNDS
tteptach'.r ..'c18
4,4'-DIID
.lpha-Chlordlne
g_-Chlordlne
Aroc:lor 1242
Aroclor 1260
lI8RARY S[ARCII COMPOUHDS
I
.t:--
tV
I
polynucle.r Aromatic
lIydrocubons
Ketones
C.rboxyllc acids
Esters
S.tur.ted Hydrocarbons
Unsatur.ted Hydrocarbons
Phenols
Alcohols
Furan, tetrahydro
0\ H.lone
'rl..thyl 80rane
2-..thyl-trans-I,I'-
blcyclohexyl-
OctacOSine
(Oct.cos.ne 1) Unknown
(I-tetr.cosanol 1)
Unknown
9-Oct.decenamide (i)
8enlene,I,I'.4-(3-
1I1M'lIyIIJr"I'yl) 1./
.....- --.- .--.--.. .--. ..-----..... - - -- --_.-... ..--"..
'l uf 3
SAM"I t NIJHIII.II~ ((UluoOentlell iUlls dll~ III IIIJ/klJ (1'J.l11))
- .. ~ - - .
QUAHlllAtlOH
LIMitS"
---.-.--. -'---'----.... -
S[ .01.1
51.03.'
«I
/80
22 , 000
39,100
,
- -- -...- -..- --_._--~_._-"-
5[041
--.. ---_._---
51 -11-1"
13 , 000
50,300
13,000
I, ~oo
40,000
Ii,JOO
-------
JABI.[
III
CON' 'NUl f)
.I h' I
_.---_.. ----
- - -. -... -- - . - . -. - --
~AMI'I.' NUMB' H~ (luru:elltr at !lIIIS M'e III ul)/~11 Ipphll
-.-.__._- ---- ~--~~_. -_..
ID£NIJrllD
ORGANIC COMPOUNDS
QUANIIIAIIUN
llHllSa
Sf - 01 I
S[-OJ-I
S['04 I
51.21-lh
-.---- --...---------------.-.
Unkno.n(..tur.ted
hydroc.rbon)7.total
Unknownl.aturated
hydrocarbon). total
Unknown I hydrocarbon) 7 ,
tattl
Unknown I hydrocarbon) .
tot. I
Unknown(HC and
coll8l bleed)
Unknown semivolailles,
lolal
Unknown volailles,loial
II
2,290
41,100
9,100
I S8, 300
3,300
2".000
490
14,200
].900
54,900
I
s:-
W
I
a Quanilialion limits oot reported for sedlmenl samples due 10 lhelr variability.
Delecllon II~lls are available on lhe Certificates of Analysts.
b S£-21-1 Is . duplicate sample of S£-03-1.
c C~und also present In the laboratory blank. . the superscrlpled number is the lab blank
concentration.
d .- Indlcales compounds lhal were nol delecled.
e Reporled c;oncenlraUon Is below quanillatioo limit.
-------
TABLE
I
.p-
.p-
I
17
LEWISBURG PHASE I: INOHGANIC ANALYS[S R[SULTS rROM' !'ONU stOlMENT SAMPLlS
~AHPll HUHlIlR~
-----_._-- ---.-.-. ---_._-_._~---
TARGU AllAun
LIST SUBSTAICES
DEI ((lION
LI"II~a
S[ -01-1
AI_In-
AntillOnY
Arsenic
Barl-
Bery)) I-
CaOlI-
Calcll8
ChrOllI-
Cot..lt
Copper
Iron
Lead
Magnesl-
Manganese
Mercury
Nickel
Potus""
Selenl-
Silver
SOOIIll
Thall "II
Vanadl-
line
Cyanide
I~,IOO
c
<'.J
143
1.0
I
8,460124d
I~
12
10
22 , 600
2!d
1,490~6
9~1.
0.01
9
1,210
24
163~19
21
!.6
-...------..-.---------- -".
(Concentrations df"e ill lTkj/ky ("pm))
S[-03-1
28.900
111
IJ
20.900124
10
1~1
116.000
116
3.000~6
111
O.~~
121
~.180~19
1. !l1I0
~[-04 .1
----_.-
~[-21'lb
8.300
244
68.100124
J2
91
11 , 300
65
2. 110'J6
1/0
0.20
2,010
14
3,810~19
111
----. --.-.--.. ."...--'-'.
1.110
12
81
8,300<'24
~1
160
80.900
141
1.16056
398
89
5,290'J19
Mi2
4 lIf'lection limlls 41e n..t ,,'podell lor se'''nlt~nt Sdrn"lt~s due to their ,,""ldlllllly. 11t~If'cllllll
1"'IIIs 41e dYdlldl,le Oil IIIe 1.",llllcdlo~'; 01 AII.dysls.
I, ',II'III\ddupIILdte~dlllpleot ~f'Uj'l.
II"',, dlo's IIIU ")" " II. CU"P"'IIIIts 111..1 ..e,,, ""I .".
o! 1""")411'1. h dls" prcsc,,1 III III,: Idl,o'dlul y hld"~. IIle su"..r.sLrll'lt'd ",,,,,I,," IS "". 1..10 I",'II~
I, In this Sdm"le.
1111111,,,11..1' '1111
-------
TABL£
18
UWISBURG PIIAS£ II:
ORGANIC ANALYSES R[StILTS rOR srnlMfNJ ANn ASSOCIAT[O QR/ijC SAMPIIS
-----------------_._-----~._.._------.._. -- . "-.-.- --_.
.__.~--- ..._--..-
.-.-._--
.---..-.---
~AH"II. IIIIHIIi HS
((ullcenl rd t I (JnS d '" In "'Ilkll (flph II
".------.-------- --_. .------ - -... --------- . _.- -----.
- ".- ------
ID[NTJFIfD
ORGANIC COMPOUNDS
QUAM' HAJlO"
1I1I II S. 5( -05
S[-OSSb 5[-06
5[-01
101
AOI
101 5[-08 I 5[-09-1 5f-10-lh 5[-11-1
'"4
1183
F83
.--
'ARG(' COMPOUN~ liS' SUBSTAIC£S
I
~
VI
I
Methylene chloride
Acetone
Carbon disulfide
Chlorofor-.
I.I-Dlchloroethane
2-8ut"none
1.1.1-lrlchloroethane
8romodlchlorometh""e
8enlene
4-.ethyl-2-Pent"none
'oluene
Chlorobenlene
£thylbenlene
Styrene
Iota I Xy1enes
I.I-Dlch10roethene
123c 183 10J 50J 2e2 -- d gP. ,e ge lie 2?e I?e 17e
2604 2204 2.6004 1.0004 13 69 55 110 /1 18
,e 4e
11 ?? I" 1'1
18 14e ,e ,e ?e 7f'
2e
..--
a Qu.ntlt.tlon 11.lt, not reported for 5011 s"mples due to their v"ri"bllity. Detection limits are available on
b S[-0~5 I. . dupllc.te ..-p1. of 5[-05 and 5(-10-1 Is a dupllc"te s"mple of 5(-09-1.
c Co.pound Is .Iso present In the 1aboratory blank. Ihe superscripted number Is the lab blank concentration.
d -- Indicates or9"nlc c~unds that were not detected.
e Reported concentration Is below the qu"ntltatlon limit.
18 'rip Ilank; 'BI Is for the week of 10-12-B9. 184 Is for the week of 11-8-09.
AB Rlns.te Blank; R81 Is for the week of 10-IJ-89. ADJ Is for the week of 11-8-89.
10 fie Id Blank: FBI Is 'or the week 0' 10-13 -89. 18.\ h 'or the week (Jf II 8 89.
101. A81. and rOI are associated with samples 5[-05 to 51-01.
1\14, An.!. anll IIn are associated ",lth samples 51 -UR 10 51-II.
the Certificates of Analysis.
-------
TAOLE
19
UWISOURG PIII\SE II:
INOnGI\NIC I\NI\IYSES R[SUUS rOR SWIMINT I\Nn ASSO(II\I[O QI\/QC SI\MPII.S
lARGU ANAL Y 1 [
LIS' SUBS'ANC£S
([oncenlrdl Ions Me '" IIIIJ/ky (I'I.n))
"------'-'---"---------- _.
. -.- . --------- --"-~-'-'--'--'-'---'--' - ..
5AHI'Il NtJHUI RS
--.----- .---.--..--.------- --------.. ---_.
OU(CTIOI
lIMUS.
RB)
fB]
.. -- . -- ---_.-._- -_._- - ... .--
S[-055b S[-06
S[-IO-Ib
5[-05
S[-OI
RBI
fBI
SE -08-1
~E -09-1
S( .11. I
I
-t-
V'
I
Alumina..
Ant llnony
Arsenic
Ba rllIII
Beryl I 1l1li
Ca!inlllll
Cdlclum
ChromIum
Cob.lt
(opper
Iron
lead
Mdgneslllll
Manganese
Mercury
Nickel
PotlSs 1l1li
Selenlllll
5 liver
SodlUIII
Ihalli.
Vanadium
line
004,003/1 0.17.00 UIU
0.001
19,800 2],100 ]2,300 14.100 c
1.1 2 3.3 --
168 146 199 161
1.9 1.2 1.6 I
I 5
13.900 10.600 13.S00 BI. 900 0.4',4
211d 221 311 S21
II 14 18 13
20 19 20 121
26.1002 22.0002 28.300" 34.1002
36 28 36 13
1,910 2.160 2.420 2.610
1,490 1.030 1.960 101
0.08 O.OS 0.10 0.24
163 113 23) 3SJ
1.510 1.990 ],050 I. 030
0.003
IS,400 1~,600 11.200 8.730
S. I 6 6 1.1 15.5
151 279 739 J55
14 11 0.9 0.1
1 .~)
16.500' 3/1,100 39.400 70./100
'II 711 26 20
12 II II 20
30 62 66 46
111,800 73.100 22.1100 41,1100
4J 46 51 50
1.110 7.260 2.320 1.1120
904 646 86} 2.lIO
0.13 0.14 0.18 0.16
10 14 IS 12
8B81114 1. 510 1.160184 995184
0.068
o 4112
o 04J
0.002
0.005
o . o~"
ISO 148 204 533 0.483 0.396 104~4 21054 19954 70ti54
]1 34 45 31 79 28 24 7.9
86,43 90 12B 1,090 0.0390015 0.0420015 100 111 116 ZII3 0.11,0.011 O.Otill) 1111
----..----..- --------..----- --- ~- - ----.
a Detection 11I.lts not reported for soli Sdqlles due to their variability. Detection 1IIIIlts are avadable 011 Ihe Cerllflcates 01 Alld1Y515.
b 5[-05~ Is a duplicate sdqlle o' S[-O~ arid 5[-10-1 Is a doplkale sdmplp. of S[-09.1.
c -- Indicates Inorganic cumpounds that were not detected In this sdmple.
d Present In the sample and the lab blallk. ]he superscripted lIomher 's the blank concentration.
Wit MlIlselle Bldllk; RBI Is for the week of 10-13-89 ami Is assoddled w,'h sdmples S[-O~ to 51.0/.
NUJ 's tor the week 01 11-8.119,allll is els50claled wi I pies 5[-08 to 5E II.
,eld Blank; IUI IS for the week of 10 13-8'1 dml Is assoclaled will les S(-05.to 5(-0/.
IU.lI~ 'ur Il,c wc('k 011111 WJ 4"d IS dS~OL'dh'd w.lI. ~d"'loIc5 51.011 10 51'1\
-------
'rABLB 20
PISH COLLECTED FROK THE QUARRY POND
S . a
peCl.es
Weiqhtb
Lenqthc
Golden Shiner
Golden Shiner
Golden Shiner
Golden Shiner
Golden Shi:1er
Golden Shiner
Golden Shiner
Golden Shiner
Spotted Sunfish
Spotted Sunfish
Spotted Sunfish
2.00
3.00
5.00
2.50
3.00
2.50
3.00
2.50
1. 50
2.00
1. 50
a) Golden Shiner (Notemiqonus crvsolencas)
Spotted Sunfish (Lepomis punctatas)
b) Weight of fish in ounces
C) Length of fish in inches
Note:
A total of 11 fish were sampled. Age class distribution data
the Go~den Shiners collected at Lewisburg are 5-6 years old.
distribution data for the Spotted Sunfish indicates that they
Lmately 3 years old.
-47-
6.50
7.50
8.50
6.50
7.50
6.50
7.00
7.00
5.00
6.00
5.25
indicates
Age class
are approx-
-------
TABLE 2 1
l£WISBURG PItASE
II :
ORGANIC ANAL I~LS HlSUtlS FUH r ISII AND ASSOLJATlO QA/QC SAMI'LLS
---.'.----- --.----- -.. --- -.. ---
SAHI'Ll NUHlJlRS
(Com;clltrdtluIiS .HC III UI)/I<9 (ppb))
- _._----~ -----------.--- --. -.---
IO[NIIFI(D
ORGANIC COMPOUNDS
QUA111 IJAI 118
LIMITS.
SP£CI-Fb SP£Cl-F
SP£CI-Ub SPlCZ-O
101
ROI
F81
'ARGO COMPOUND LIST SUBSTANCES
I
~
ex>
I
Methylene chloride
Acetone
C.rbon disulfide
Chlorofol'1l
I,I-Dlchloroeth.ne
2 -Buhnone
I,I,I-trichloroethane
Br~lchioromethane
Benlene
4.~thyl-l-Pent.none
loluene
Chlorot,enzene
243c 123 3403 J903 Ze2 - - d
5104 1,3004 IB,0004 1.90U4
140 480
11 2l
Je
54
12
It hy I benzene
Styrene
10tll Xylenel
I.I-Dichloroethene
3e
. Qu.ntlt.tlon II.Ih not reported for fish sa~Iel due to their variability. Detection limits are dvallable 011 the (ertdlcdtes of Ancllysls.
b F designates fillets ,nd 0 deslgn.tes t.rget organs.
c Compound Is ',Iso present In the I.boratory blank. Ihe superscripted nUlllber Is the lab bl.nk cOllcentrdtlon.
d .- Indlc.tes org.nlc cu.pounds that were not detected.
e Reported concentr.tlon II below the qu.ntlt.llon limIt.
IB Irlp BI.nk; IBI Is for the week of 10-1]-89 .nd Is .ssocldted with .11 of the samples on this tdble.
A8 A I nsete BI.nk; R81 Is for the week of 10- I] .89 .lId Is ISSOC I ated wit h a II 0' the sa""Ies on thl stable.
III I lId\! 014nk; IBI 1$ for the week of 10-1]'89 a 1111 Is .ssodated with dll of the lillpl.. on thts table.
-------
TABLE 22
UWISBURG PIIASE II:
INORGI\NIC AN/\L YSrS HlSUL 1~ ron !"ISII I\NU /\SSOCIAllU Q/\/{JC SI\MI'LI.S
-.-----. ---------- -..--"--- - - ----
SAHPlL NUHIURS {COIII.elllldtiol,s.sre In IIICJ/ktj ("pm))
-.------------------.-
J ARG£T ANAL YJ [ OU (CU.
II S J SUBS lANCES lIMIiS. $PECI..b SI'LC2- r SPICI'Ob SP£\:2'0 11111 181
AI umln\81 35 102 16 11i4 - - c
Antimony
Arsenic
Bar I IJI 1.3 4.6 28.9 19.9 0.00]
Beryllium
CalbiUIII 5.9 3.6
CalclUII 3,110 1,900 1,530 9.590 0.454 O.Ufitl
ChromiUIII 61
Cobalt
I Copper 10 8 14 18
~ 516?d SII2 I. II 02 1,1002
\0 Iron
1
lead 2 3.9 II
MagneslUIII 1,340 1,180 SS8 1.810
"clng..nese 4.6 4.1 19.1 184
Men;ury 123 113 i6J
Nickel
Potusl... 15,200 11 . 600 6.150 8,130
,
Selenl...
Siher
Sodium 1,240 1.510 2.410 3.6/0 0.483 0.396
JNIII...
Van.dlUIII 0.0390.015 ° 0420.015
line 2133 123 2413 2523
.-.--.------- .---.. - ---"---.-'--
. Detection limits not reported tor IIsh sclmples due tu their vdrlabillty.
b .. designates fillets .nd 0 designates target organs.
11..11. .Ics "'""I""IC coml'0ullds Ihdl wcre lIot deleele,l III 11115 5"'III'le.
. , . I " II" \."",Ip .",1 I h., 1.11 "I,,"k SUl'''' SLrI"I.." lIuonlll'l' is II... ",,,"k
Oetectlon Ilmils .Ire aVdtla"lc 011 Ihe CCII" ILd'es 01 Allalysis
concentration.
. . .. . II
. ,
t., II..' .... ,,' III II II" d,,,1 '\ d~.\II..,.III''' ",II, dll of tite sa"'llles 011 11115 'dlole
", .,.' I I" 1\ /1'1 ,,"" ", ,I'.'.,,, odl.'.1 ,,'110 .11 I "' Ihe Sdon\llt!s 011 IIII~ Idhl.,
-------
1,1-dichloroethene (3 ppb), and 2-butanone (3 ppb). Inorganic contaminants
identified are: aluminum (69 ppm), barium (6 ppm), cadmium (6 ppm), copper (9
ppm), iron (544 ppm), manganese (5 ppm), zinc (143 ppm), nickel (12 ppm), and
lead (2 ppm).
5.7
Air Contamination
I
A total of 6 air samples were taken throughout all phases of the RI. The first
round of sampling took place before test-pit excavation or drilling activities.
During this round, two 24-hour composite air samples were collected. In addition
to these 2 background samples, 2 downgradient samples and 2 duplicate samples
were taken. No contamination was detected in any of the six samples recovered.
Tables 23 & 24 summarize the analytical data for the analysis of air samples.
5.8
Sinkhole Contamination
In an effort to further characterize the groundwater/surface water interface,
three background and four downgradient samples within approximately a 1-mile
radius of the Site were collected (Figure 10). Sampling locations were chosen
based on the findings of the fracture trace analysis and site reconnaissance,
topographic gradients, and the speculative local groundwater flow direction.
Many of the sinkholes in the area contain household garbage and appliances and
these locations were not sampled since it would be nearly impossible to retrieve
a sample from a clogged sinkhole. A total of 7 sinkhole water samples were
collected and are described in the sinkhole sampling 'summary (Table 25). All
sinkhole water samples retained acceptable water quality. However, sinkhole
sample #2 (SK-02) did have elevated levels of metals and it was thought at the
time that this sample was downgradient. It is now thought that this sample
location is not in hydrologic connection with the Site and may indicate another
source of contamination close to Ellington Parkway. As for the sinkholes
adjacent and downgradient from the Site to the southeast, slightly elevated
metals were noted (average concentrations were calculated from data in Tables 26
& 27 such as chromium (27 ppb), copper (16 ppb), iron (93 ppb), manganese (20
ppb), nickel (25 ppb), zinc (38 ppb). The concentrations of contaminants
downgradient are in general, very low and at present are not considered a threat
to human health and the environment.
6.0
ADDITIONAL ANALYSIS
6.1
Residential Well Survey
The City of Lewisburg conducted a residential well survey of all wells within a
2-mile radius of the Site., A total of 210 property owners were contacted and
this information yielded that 70 out of 123 households are currently using a
-50-
-------
T I\OlE
I AAG£I ANALY J(
LIS' SUBS1AJlC(S
I
V1
.....
I
A II.. I",,,
Ant "nony
Arsenic
BarlUIII
Berylllwn
C.dlll8
C.lclUIII
ChrumlUIII
Cob..lt
Copper
Iron
le.d
"'gnes 118
"'ng.nese
Jllekel
Pot.ssh..
SeleniL..
Siher
Sod I 18
'ha 111111
V.n.dllll
line
TOTAL "[16HI
23
l£WISOURG PIII\S[ I: INOIU;I\NIC I\Nl\l.YSlS HtSUl.lS I"OH I\IH SI\M!'I rs, HOUND I
SAMPlE NUHULR
AA-OI-I
0.0005115
0.0000085 U
0.0000085 U
0.0000229
0.0000001 U
o. 0000011
0.0161612
0.00000]4
0.0000059 U
0.0002812
0.0010520
0.0000204
0.0008441
o . 0000411
0.0000059 U
0.000]661
0.0000114 U
0.0000013 U
0.0081805
0.0000085 U
0.00000]0 U
0.0000419
0.2191 g
--.'-. . '---")-'
(Concentr.tlons
-------
TJ\nLE 24
I AAGLI ANALY;[
LIS' SUBSTANCES
I
VI
~..)
I
A I uml n...
Antimony
Arsenic
Bar Ii..
Dery"''''
C.IbIUII
C.lch..
Chromium
Cob. I t
Copper
Iron
le.d
MagneslU8
M.ng.nese
"'eke'
Potass I um
Selenium
S I tver
Sodium
1ha" II..
V.n.dlln
line
10TAl WEIGH'
tlWISUUIIG PIIJ\Sl I: INOIIGJ\NIC J\NJ\I.V~;lS III: SUI IS rOil J\1It SI\MI'I [S, IWUNU 2
SAMPU "UM6lA
AA-01-2
0.0004610
0.0000066 U
0.0000066 U
0.0000154 I
O.OOOOOOl U
0.0000013 U
0.0020152
0.0000022 U
0.0000044 U
0.0000ll8 8
0.0001619
0.0000066 U
0.0004891 8
0.0000110
0.0000044 U
0.0006168 B
0.0000132 U
0.0000013 U
0.0101335
o . 0000066 U
0.0000022 U
0.0000463
0.0624
._--- - . -. 'J
(Com:.entr.l lOllS are III IIKJ/m I
AII-02-]
0..5111
0.0000080 U
0.0000080 U
0.0000212 I
0.0000003 U
0.0000053
0.0045190
O. 0000021 U
0.0000053 U
0.00003]4 B
0.0003665
0.0000106
0.0006418 8
0.0000202
0.0000053 U
0.0006041 8
0.0000159 U
0.0000016 U
0.0112445
0.0000080 U
0.0000021 U
0.0000461
0.0105
-.. .. . -"- --. - ...---
AA-02-4
0.0004416
0.0000062 U
0.0000062 U
0.0000186 8
0.0000002 U
0.0000025
0.0025405
0.0000021 U
0.0000041 U
0.00003Z1
0.0002188
0.0000099
0.0005015 B
0.0000108
0.0000041 U
0.000526J B
0.0000124 U
0.0000012 U
0.0099051
0.0000062 U
0.0000021 U
0.0000539
0.0615
SAMI'U HIiHUt II
----.---
-----."_w "----.
IlV"
AA-OI- 2
'--
I"en:enl ut !IV)
..- "'-"'-..---.-..-
0004611
---- --- --.------
AR-02'3
10
0.5
o 2
o 5
0.002
OO~
10
0.5
O.OS
0.2
5
015
10
S CUllNG
,
2 ([lUNG
0.2
01
5
O. ,
0.05
10
0.00.1081
0.020/51
0.013901
0.00n61
0.004891
0.000221
0.030841
0.202611
0.000461
0.005891
o 004241
OOIOliOl
o 045191
o 016101
0.00/331
0.00/011
0.006421
0.004041
0.0.10241
0.224891
0.0004/1
--------_. ----
. ILV - Ihreshold li~ll V.lue.
II r~lound.as analyted for bul nol detected. Ihe number Is the detectlun Ilmil for lhe sampLe.
" ..'.. '4,..11" \I..n '''e III\\'r._o' ,'elt'LtlO" Ilmll. lIul less tha" conl,aLI required quantllallull I.mll.
. ._~--_. .-
AH-Ol 4
o . 0044111
0.00.J/2X
O.OO~OOX
o Ol~411
D.Dlld~X
0.004381
O,00660X
0.00501X
O.OOOnl
o 02fi.J21
O.1981OX
o 00054X
-------
TABLB 25
SINKHOLE SAMPLING SUMMARY
Sample
Number
pH
Temp.
°c
Conduct.
(umhos/cm3)
Comments
SK-01 6.47 NR NR Background sample collected June 22,
1988 as sample No. S-11 during the
Residential Well Sampling Effort.
SK-02 7.34 17.8 260 Background sample near Ellington
Parkway. Aquatic insects and frogs
were present.
SK-03 6.91 15.2 400 Background sample from sinkhole/cave
in a cow pasture. Significant water
movement was not evident.
SK-04 7.12 16.7 480 Downgradient sample by a trash dump
south of the Site. Crayfish present
SK-05 6.85 16.1 380 Downgradient sample from Old
Distillery Spring.
SK-06 7.07 16.0 400 Downgradient sample from sinkhole
-- southeast of the Site. Fish present
SK-07 6.55 15.7 395 Downgradient sample from sinkhole
near Verona Road. Fish present.
SK-08 7.00 15.5 400 Background sample in a cave with
rapid moving water.
NR = Not reported
-53-
-------
TAUlE
26 .
l£WIS8URG PIIAS£ II:
OHGANIC ANAlYS£S \{[SUI.TS Fun SINKIIUU ANn ASSUCIAI[f) QA/QC SAMPlrs
---..---.-- -----...--.. -.-.."'--- - .__..._- --..
.-. ...-- - --.-
- -- ..n - ---.
- -.. --'-"'-
SAHI'L£ NUHUlAS
(Con\;~"lr..t'un~ ",e .n IHJ/I.ter (pph))
._-----._-----~._-- -------- .---.. ---"--'---.- --,." - -"'-. -
IDlHfI fJ [0
ORGANIC COMPOUNDS
QUAII'IIAlIC8
1IIUlS
SK-02-1 SK,03-1 SK 04-1 SK-05'1 SK-06'1 SK-Ol-1 SK-08-1
IUI
ROI
HII
_.__.._~--
..---
TARGET COMPOUND LIST SUBSTANC£S
Methylene chloride S __a 3e3h Ze?
Acetone 10
Carbon disulfide 5
Chlorofo". 5 11 n
I.I-Dichloroethane 5
2-Butanone 10
I.I.I-Jrlchloroethdne 5
Bromodlchloromethdne 5
I
VI Benlene 5
.&:-
I 4-methyl-2-Pentanone 10
Toluene 5
Chlorobenlene 5
Elhylbenlene S
Styrene 5
Total Xylenes S
I.I-Dlchloroethene S
.. -- Indicates organIc compounds thdt were not detected.
b Compound Is aha present In the bboratory bl..nk. 'he supers\;ripted number Is the lab blank coneentrat Ion.
e Reported concentration Is below the quanlilalion limit.
RB Rlnsale bbnk; RBI Is for the week of 10-13-89 and Is associated with all of the samples un this tahle.
FB Field blank; FBI Is for the week of 10-13-B9 ami Is assoclalert with all of the SllIIples on this t..ble.
10 Irlp Blank; IBI Is for the week of 10-13-89 and Is associated with all of the samples on this lable.
-------
lADL£ 27
LEW 1 SBURG PIIASE II:
INOnGI\NIC ANI\LYSI:S nL"SULTS run SINKIIOU: I\NU I\SSOCIAlI.IJ (JI\/QC SI\MPLIS
'ARG£T ANAL YJ [
LIS' SUBS'ANCES
O[JEcn.
LIMITS.. .
I
V1
V1
I
AilAlnu.
AntllllOny
Arsen I c
Barlu.
Beryl I Iu.
Cac.alu.
Calcl..
ChrOlllIu.
Cobalt
Copper
Iron
lud
Magnes I u.
Manganese
Mercury
Nickel
Pohnl..
Selenl..
Silver
Sodl..
IMIII..
Vanadl..
llnc
40
30
2
2
I
5
30
10
20
10
10
2
30
2
0.2-0.3
20
I. 000
2-3
5
200
2-4
10
15
--.-------. ._--
-----_.~ - . -. - . ---- ---.
SAHPI [ HUHtll.IIS
(Concentrations .100
4~4
68
25
401
11
14
14
186
91
90
19
3.210
29
2,580
5,;00
15
126
5,360
6
~,9jO
44
5,030
II
23
25
I. 560
I. 260
2,340
483
396
2.250
4.020
1,910
1981x
511'.>
3915
4115
,15
4115
391'.>
5115
'.>615
---.-----.----.-
a Ranges are reported when detection limits vary among samples.
b -- IndIcates Inorganic c~unds that were not detected In this s
-------
-
, ------
ground water well for domestic or livestock uses. No industrial or municipal
wells were found in the survey area. Three wells directly upgradient, 2 wells
downgradient, and 5 surrounding wells revealed no organic or inorganic
contaminants. A breakdown of the 70 wells is provided as Table 28, while
analytical data is included in Tables 29 & 30.
6.2
Fracture Trace Analysis
A fracture trace analysis was conducted in order to better identify bedrock
fractures that may have an influence on groundwater movement in the vicinity of
the Site. The Site reconnaissance was used to identify geologic and other
features within a l-mile radius of the Site. The measured fractures and joints
in the immediate vicinity of the Site primarily trend in a northeast-southwest
direction. Fracture densities around the Site appeared consistent with a spacin
of 10 to 20 feet where rock outcrops were discovered. Mapped fractures and
joints are identified in Figure 10. The largest fractures located near the site
are 300 to 500 feet northeast of the pond and also trend north-northeast. These
fractures do not appear to intersect the water level of the quarry pond.
6.3
Geophysical Survey
The area of the landfill and the pond were investigated utilizing a geophysical
survey. Proton procession magnetometers were used to identify areas of buried
material in the landfill or submerged objects in the pond which have a high
metallic content. This survey also helped determine test-pit excavation
locations and surface water/sediment sampling locations within the ,quarry pond.
The survey was also utilized to determine the lateral extent of the landfill.'
Readings were take~ at each node in a grid-system containing 10-foot centers.
The interpretation yielded a magnetic contour map depicting 5 distinct areas of
magnetic anomalies within the landfill labeled A-E (Figure 11). Also presented
is a magnetic iso-gradient map of the quarry pond (Figure 12). Magnetic
anomalies appear to be grouped within the landfill area in the southeast and
there are sporadic anomalies in the northwestern portion of the landfill. Withi
the quarry pond, there are only 2 general areas where anomalous readings were
identified These areas are in the eastern and western corners of the pond.
In all cases the areas that corresponded to the magnetic anomalies contained
metallic scrap or appliance waste and it appears that none of these anomalous
areas can be classified as "hot spots".
7.0
POTENTIAL ROUTES OF MIGRATION
Six potential ,routes of exposure have been identified by which landfill material
may move from the Site, through the surrounding environmental media, and to
points of human exposure. For each identified pathway, a reasonable maximum
exposure (RME) scenario has been developed. A summary of possible exposure
-56-
-------
Tajle
:8 , Residencial ~ell Survey Resul~s
~7:CN RE;)O~T:J W::~!.. LCCATiO" R::?C;(7D .:.:.
..~~= W::!..L us: ~:=":J r &: ~ lj'.;wS::::< W::~L US:: D::~." (&: \
Comes~',:, LIvestocK 61 35 Domes~1:. Llvestock. 13i
2 Comes:::. LIvestoCK 42 36 LI..estoclo; --
3 Domes!;::. LI..es~ock. H~a 37 Domes::: C"-.--
4 Domesti:. llvestoCI( ~50 38 Domesti:. LIvestock. 72
5 Domest1c 150 39 Domestl:. LivestocK HK
5 Domes:':. l1ves:ocic. 2~C 40 Domest:: ,,~
7 Domestic. L j vestocic. HR 41 Domes';1: ( 2 well s) ,,~
(serves two nomes) 42 lIvestock. 2:
8 Domest,:. l;ves:oclo; 52 43 Domestic II"
9 Domest:c >5': 44 Domesti:. LIvestock. II"
10 Oomestl:. Li vestocic. HR 45 Domest1:. LI..estock (2 .e 11 s) >:~
11 Domest': Nit 46 Domesti:. Livestock. H~
12 Domes';1'. Livestock 135 47 Domestic. LIvestock. 3CC
13 DomestIc. Llvestoclo; 50-90 48 Domestic. Livestocl( HR
14 l'vestock ~50 49 Domestic. Llvestocic. 83
L5 Danest,c 30 50 Domestic 83
15 lIvestock 50 51 Domestic. Livestock 175
L7 lIvestock 65 52 Livestock. HI<
18 Danest 1 c 50 53 Domestic 1::
l3 DomestIc 50 54 t i vestock IIR
~~ Danestlc. LIvestock. 60 55 DanestlC 86
~: Danestlc. Livestock. 70 56 Domestic 85
~2 Danestlc. Livestock. 50 57 Livestock. 80
!3 Canest;c. l1vestock 56 58 DanestlC HR
14 Danestic 200 59 Danestic Hit
!5 Danestic. Li vestock. 80 60 Danestic 50
~6 Danest1c 200 61 Danestic Hit
17 Danestlc HR 62 DanestlC 56
18 DomestIc HR 63 Danestic Nit
19 Domestic. livestock 94 64 Danestic Hit
10 Danestic 40 65 Danstic 210
!l Danestic 90 66 DamestlC 65
12 Domestic. L t Y8Stock. -50 67 Damestic Hit
13 Domestic HR 68 Danes tic Hit
14 Danestic. L tv.. tack. 160 69 Damestic 225
70 Danestic Hit
R - Hot reported.
-57-
-------
lADLE
29
l [W I snunG PIIAS[ I: OnGJ\N I C J\NJ\I YSr:S nrsuus flWM IH S 11)( N J 11\1. WI\ nn WI:! I S I\Nn SPIU NG
---.-----.- .
!D(NrrrI£O
ORGANIC COMPOUNDS'
QUANI (IAI JON
LINUS.
RW' (A
IAAfifT COMPOUND' 1ST SU8S1AIICfS
Methylene chloride 5 - - c
Acetone to
C.rbon disulfide 5
Chloroforll 5
I.I-Olchloroethane 5
2-Butanone 10
1.1.1-1r\chloroelhane 5
Bromodl chI oromethane 5
Benzene 5
4-~thyl-2-penlanone 10
I loluene 5
VI 5
i):I CM orobenlene
I 5
£lhylbenlene
Slyrene 5
10141 Xylenes 5
4111elhylphenol 10-11
Benlo\c .dd !l0-51
Naphl N I ene 10-11
Acenaphthene 10-11
Dlbenlofuran 10-11
Dlelhylphthalate 10-11
Fluorene 10-11
n-Nltrosodlphenyl..lne 10-11
Phenanthrene 10-11
Anthracene 10-11
Di-n-butylphthalate 10-11
rI uo r .1I1t18ne 10-11
Pyrene 10-11
8ulylbenlylphlh.lale 10-"
I., ~(? elhylhe.yl )phth.ldle 10-11
.1. II "' I vll''''hdld.e 10.11
tl, I.,..t'.\' ',,,)I dI,,'''..ne 10 II
t I IIdf "III '''~lIe JO II
"t L ,,,.,'t'ue 10 II
.-. ._- - ._--_._---_.---~-------_._- - _.--
.-.-.-.- -- '--."-.-. ...-..-...- ..-.
"..---..----
SAM!'I (
(Loncenl I . I inns d re III 1")/ II I I~ I (\lflh))
NIIHIIIRS
- -~.- - ~- - - -- -"'.-.---.--..-.--... ------ ...
.. -.- --- -' .-- ..' -- .
R\lllIh
R\ll
R\I 3
R\I 4
RII "
RII 6
RII I
RII "
RII.9
---." ------.-.
..- ._---_._---------_.--~._--- ..-.
I 01 .I
--.--.--.-----..
... -.-.------..
RII-IO
S II
.e
-------
Il\nt [ ~9
CONIINUlD
__,~4'__.__--------------_.
IO(N!lf 1(0
OAGANIC COMPOUNDS
QUANII (A( ION
LlHIISa
lIeptathlor epollide
4,4'-ODD
IIlphll-Chlordline
ga""",-Chlordllne
Aroclor 1242
Arod or 1260
IIDAAA' SEARCH COMPOUNDS
I
V>
\D
I
Polynuclellr Aromatic
Hydrocarbons
lC:etones
CarbollyllC IIclds
(sters
Sliturlited Hydrocllrbons
Unsllturllted Hydrocllrbons
Phenols
Alcohols
furlin, tetrllhydro
01 fhlone
Trl.ethy1 Borllne
2-.ethyl-trllnl-I,I'-
blcyclohexyl-
Oc t .coune
(Octlicolline 1) Unknown
(I-tetrllcosllnol 1)
Unknown
9-Octlidecena~lde 11)
8enlene,I,I'-4-(}-
phenylpropyl)-I.l
0.05
0.10
0.5
0.5
0.5
1.0
+_... - --.---. .----...---- - .. --.
SAHl'lr NlIHIIl1l5
-.-------... ------
AW.IA
IIW-IOh
..-.---- --- --._---.... -_._--_..-. .__.______e__. --,_.~-
II'" 9
t
84
11'1.7
. -. - -_. ----- -_.~. ---.-. ..-.
... .--- -.-..---- ._-.
Ironcentrallllns are In u!)" iler IIIVh))
- . .. .- - . ---.--.----- ---. - .
. 0__- .. - ..--
IIW-}
AW-4
11'1 !>
A"'-6
- - .
11'1 1
- ._- .. .. ... .
"'" II
10
7 .., I
_. -'-.."'"
11'1-10
~ II
10
-------
T I\Dl£ 'l.I:J
CON1INUI.U
1..1 \
----,._._~ -- -_...
_. .--..------.------.---- ---------.---.------- -.-. - -.. ...~-~..
.--....- .---. "- .
SAHPLE HIIHHI.RS
(I:oncenlrdtlons
-------
lABU 30',. L[WISBUHG PIIAS[ I: INOHGANIC ANALYSf~,II[SUUS IIWH RLSlUfNflAL WAIIR Wltl S ANn SI'IUNG
J AAGEI ANAL Yt [
LIST SUBSTANC£S
D[ I(CIIOI
LIMIIS'
11M- IA
I
0-
......
I
A I uml nUill
Ant IlIOny
Arsenic
8ar\UIII
Beryl I '\1m
CamlUIII
Calcium
(hromlum
(oll41t
(opper
Iron
Lead
Magnesium
M.ng4nese
Hen;ury
HILkel
Pot clSS I um
2,400
SelenlUill
Silver
Sodium
Iha" II.
V4nadlUill
llnc
Cyanide
40
30
4
2
I
~
]6
10
20
10
10
2-4
]0
2
0.2
20
1,000
]
!)
233
2
10
~
10
.~.- ,-- . -- .-*. - -- -- - - -- -~. ~ --.- ""'.'-.--- -~._._-~ -- ~ -<. - - - - ".--.
h - ."..-. - M- - ---
SAMPLE NUHUlf(S
(Concentr4t1ons .n-e iil uglliter ("ph))
---- --_._-- ,....-----.-
--------_.-
RIl-IOb
AII-!)
AII-2
AII-]
RII-4
RII-6
AII-'
.-c
11
I
16
!>9
10
28
- -
66,900]6d 6S,S0036 81,!>00]6 ".60036 66,20036 114,000]6 114,00036 81,900]6
35,600
20
40
]2
]
]4.800
41
]61
4
11 , 800
2
2!>6
-- . - - - ,- ,
1111-8
.---------" . .- ---..
1111-10
19
!;4,10036
45
26.800
10
],120
RII.9
10
!.8,JUOJ6
154
18
172
4
28,000
-.._~_...
S-II
60
59
94.UOOJ6 9J,HOOJb
26
11
9,000
3
03
8,920
6,910233 6.6802JJ 2,4202B S,2102JJ 8,290233 19,4002]] J,130lJ3 6,3102JJ 4,200233 J.'dO"JJ 2!;,IOo2J] 2!;,100lll
]12
6.210
4
24.400
29.300
4
13,200
11,400
0.2
0.2
2.140
2.610
1,610
1.8<'0
6]
4]
32
40
108
48
46
8
--- -_._- ---- ------
,-----'--'--'. . .--- .-
. .' -- .-.--- _._>_. -"-"-".'
4 Nanyes 4re reported when detect 1011 Ii.lts V41)' 4100119 54111plc5.
b AII.IB is 4 duplicate sample of AII-IA.
c -- Im.hc4tes inorY4nic compounds that were nut detedct! III Ihl5 54mple.
t! IntHI)4nic lS.also present ,n the 14hor4tor)' \l14nl<. Ihe 'iuperscriptc.llllullhcr 15 the 14b bI...nk Lun..:elltr.tt'un
.....- - M-. -
J,110
8
--.., . -. ---.,..- -...
11
J
!I,040
4
03
9,010
JO
II
-------
CAvt:
I INI 0 POND
CAVt W/UNUt K1.KOUND STREAM
N
- I. INI U POND
KttDIOKV)
LAHGC CAVt
SINKHOLL/CHLVASSl (1 HA;.M|
LAKGL CAVt(UCllKIS Fft.LLb.NO WATl H VIUIJI LI
MAYJVL I.IML01UNC
CAVC (WAltR)
blNMWATLK ULIOW MAT 0^
DUMPING u UUKNING OF TKASH a
$ CAVE l_J 11 wiSUJHG DUMI* bl
LA SPHINC
"N,. MAI'I'Ll) I KAl,IOI«Li
~* ' t UlbHI'j/ 1H*L,H DUMPlMCi
'.( AI i i".. nr.ii'
I U.IIKI '"
I hAl.lllKl. 1HACL AND
'Jill. KLL.ONNAII.L.ANCL MLU«fU
-------
POSITION NUMULR.FTLT
300 . 4OO
Jjt II.IM < ('
VAl 1 '! '. .Ill t )
O
MAI.NI IIL IHNKHIHS Itl i.AMMAU rt H MLltH
»MI A', f PNIAlMltK. & :,H,HM
U I«IKII 1> Ml IA1
AMUUNT
* MAUIt HC UAIA I'UINI
s-~"^
( (A) I llftOHtllC AMllMAH UbhtNAIlON
CONIHtTt ICHINUAIION (II IH.MKXISI4LII
MMIK. tUKLS
mill s_
I UJUIUIH INHRVAI U'.tD IS IIiO (.AMMft'j I'lHMl MR
', ( A I t
tll.UMl |t
I ANOI II L
MAONI IIC IjU OKAUII Nl
it MI'.IIUHO tlllMI' ^Illt
-------
HO
-•U)
80
m
I GO
2OO
flO
APPROXIMATE LIMITS
OF POND
<4O
40 BO l?0 MiO A*) i"10
POSITION NilMHE.it , I LF t
I I dl.NU
0
MAI,111 HI (.ONKHIHS IN
I.AMMAS I'LH Ml HH
MAI.MI III ANOMAI.r
Illliir AIIMG « SK.NiriCftN
AMdIINI OF 'jlllljlllll ALL
Mtl'U
MflL.'ll llC llAIA MUINI
in IIHIRVAI USED is
'.() (..II.IMft', I'lH Ml II H
r,l At f
HIO (til
riOUHE 12
MONO
MAGNt 1IC ISO-OHAOItwr MAP
i (*isminG uuuc sin
-------
1--
TABLE 311 SUMMARY OF POTENTIAL EXPOSURE PATHWAYS
Exposed
pocu::atior.
Groundwa<;er
All residents
Surface Water
All residents
Children
!2il.
Children
Bxposure
Pathway
Prob. of Exposure/
Inclusion in Risk
Assessment
Reason for
Selection/Exclusion
Exposure to contam-
inated water downgradient
of the Site from I
Drinking water wells
Beef ingestion
Other uses
Ingestion of chemicals
that have accumulated in
quarry pond fish
De~al contact with
chemicals while swimming
Incidental ingestion of
vater while swimming
Ingestion of soil
High/Yes
High/Yes
High/No
Low/Yes
Low/No
Low/Yes
Low/No
-65-
Groundwater is the sole source
of water for several residents
downgradient of the Site.
Current use occurs.
Livestock wells exist near the
Site. None presently exist
downgradient of the Site.
Generally only lipid-soluble,
nonionized compounds are
absorbed through the skin
during bathing: volatile
compounds may be inhaled during
showering. Since the chemicals
of potential concern are metals
these pathways will not be
evaluated
There is some physical evidence
that the pond is currently used
for fishing: however, access is
difficult, the City maintains
fishing areas, and trash in the
pond is unappealing.
Generally only lipid-soluble
non ionized compounds are absor-
bed through the skin during
swimming.
Access to the pond for
swimming purposes is poss-
ible, trash in the pond is
unappealing.
The landfill cap is highly
vegetated and offers no direct
exposure of contaminants. This
pathway will not be considered.
-------
pathways identified are described in Table 31. The pathways are: groundwater
ingestion, surface water/fish ingestion, beef ingestion, pond sediment contact,
soil contact, and air inhalation. Further'.analysis revealed 4 pathways that were
to be evaluated in the baseline risk assessment. The 4 pathways are:
o
Ingestion of drinking water
-0
Incidental ingestion of surface water while swimming
o
Ingestion of fish
o
Ingestion of home-produced beef
7.1
Groundwater
~aterials from the landfill may leach into the groundwater and migrate away from
the Site via fractures and channels in the limestone. The groundwater eventually
moves downgradient from the Site generally in an east-southeast direction,
through the pond on towards the Big Rock Creek drainage. Once materials migrate
into the groundwater, they may reach human receptors via private wells. Water
from these wel~s may be used for domestic purposes or watering livestock.
However, because the residential well survey did not indicate any contamination,
the home-produced beef and the ingestion of drinking water pathways were not
=onsidered viable at this time.
7.2
Surface Water
~andfill materials may reach the surface water of the pond by two methods.
~irst, via groundwater traveling under the landfill and to the pond. Secondly,
naterial may leach from the eastern boundary of the landfill directly into the
?ond. Once in "the pond, heavy inorganics are rapidly incorporated into suspended
ind bottom sediments. Little of the landfill material would remain dissolved in
~he water.
)nce in the pond, humans may be exposed to landfill materials via the following
routes:
o
Dermal contact while swimming
o
Incidental ingestion while swimming
o
Ingestion of fish exposed to contaminants in surface water
rhe present condition of the pond would tend to discourage swimming. The pond
:ontains abundant garbage and scum in present on a portion of the surface. Also
)n the eastern perimeter of the pond is a large algal mat. The pond is
lurrounded by steep 25 foot walls on 3 sides and the only open access is on the
f,.{1-
.andfill side which is lined with willow trees and weeds. There is no beach type
-66-
-------
area on the landfill side of the pond which would further discourage people from
swimming. The dermal contact with the pond water was not evaluated since the
metals do not readily partition across skin as do lipophilic substances.
7.3
Pond sediments
It is unlikely that humans could be exposed directly to the pond sediment because
no sediments are above the water and the pond remains full throughout the year.
Also, no well established drainage channel exists for sediments to migrate from
the pond. However, the buried culvert under Rock Quarry Road will release large
quantities of water from the pond during periods of high rainfall. It is likely
that at least small amounts of sediment are transported through this conduit
during significant rainfall events. Chemicals in the sediments may partition
into the water, but such transfers of chemicals usually occur in the opposite
direction. No pathway has been identified for exposure to pond sediments.
7.4
Soil Inqestion
The materials in the landfill are bounded on the sides and bottom by limestone,
and by an approximate 3-foot deep clay.cap on the top. Thus, little movement of
chemicals of concern from the underlying landfill material into exposed surface
soils is expected to occur. Also, no receptor to surface soils contamination has
been identified for the baseline risk assessment. Ingestion of any appreciable
amount of soil is limited to children under the age of six (EPA, 1989b). It
appears unlikely tha~ children would ingest soil at the site especially since
there is so little exposed soil. Where the soil is thickest, there is abundant
vegetation that would discourage any disturbance. However, the barbed wire fence
(2-4 feet, breached in areas) offers little resistance to anyone that may want tc
gain access to the site (especially adjacent to the soil cap next to Rock Quarry
Road) .
7.5
Air Inhalation
The air has been eliminated as a viable pathway because: 1) the major chemicals
are nonvolatile, inorganic compounds and do not readily partition into the air,
and 2) the clay cap over the waste should trap any volatiles in the landfill.
The two rounds of air monitoring (before and after test-pit excavation) at the
Site revealed that there were no contaminants being released into the air.
8.0
SUMMARY OF SITE RISKS
During the RIfFS, an analysis was conducted to estimate the health and
environmental problems that could result if the contamination at the Site was:
remediated. This analysis, commonly referred to as a baseline risk assessmen~ .
evaluated potential health effects from exposure to contaminated groundwater \'.'
direct c0nsumption; or indirectly through ingestion of beef from the cattle ~: .
have consumed the groundwater; also from exposure to contaminated surface wa~.
-67-
-------
via direct contact or ingestion of fish exposed to contaminants in the surface
water.
In addition to these pathways, there is a potential for future exposure through
direct contact with landfill materials if further deterioration of the landfill
cap occurs. This pathway was not quantified in the risk assessment.
Risk of long-term exposure to contaminants from the site were calculated based on
exposure point concentrations of the Site contaminants of concern in the media
which were considered to constitute a complete exposure pathway. In summary,
environmental information derived from the RI/FS indicate that there is the
potential for additional groundwater contamination and leachate generation if the
landfill cap is not regraded to prevent increasing infiltration and potential
additional migration of contaminants of concern. Also needed are Site access and
deed restrictions to prevent landfill cap disturbance and prevent any future
drilling or use of the groundwater. Site conditions may further deteriorate if
the surface and submerged garbage in and around the quarry pond is not removed.
9.0
HUMAN HEALTH RISKS
9.1
Selection of Contaminants of Concern
The findings of the RI confirmed the presence of contaminants in the landfill
material, in the soil samples taken from the test-pits, in the surface water and
sediments of the abandoned quarry pond, and in the shallow groundwater aquifer
beneath the site. The hazard identification involved the selection of
contaminants of concern (COCs), which are the contaminants likely to pose the
greatest threat to public health and the environment. Selected contaminants of
concern at the Lewisburg Dump Site are listed below:
ORGANIC CONTAMINANTS
*
Acetonel
Bis(2-ethylhexyl)Phthalate,
Carbon Disulfide
4-Methyl-2-Pentanone
Methylene Chloride
2-butanone
(DEHP)
*
INORGANIC CONTAMINANTS
*
Aluminum
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
*
Lead
Manganese
Mercury
Nickel
Silver
Zinc
*
*
*
*
1) Was found to be in part a laboratory contaminant
*) Contaminants frequently found or in elevated concentrations
-68-
-------
Table 32 contains the chemicals of concern in each media and the ranges at which
they were detected. Although sediments are not considered to be a complete
exposure pathway via the direct "contact route of exposure, they are a potential
source of groundwater contamination. For this reason, the sediment data is
retained with the chemicals of potential concern information. Table 33 contains
the concentrations of the Site contaminants of concern used to determine exposure
point concentrations. Also, the list of contaminants of concern has been
modified (from the list in the Proposed Plan) by omitting contaminants that had
relatively low concentrations. These contaminants were: chlordane, ethylbenzene,
xylene, PCB 1260, and strontium.
9.2
Exposure Assessment
This section presents the estimation of contact, or exposure, between a human or
environmental receptor and chemicals found at the Site. The following pathways
were considered to be potentially complete and were evaluated in the risk
assessment:
o
Ingestion of groundwater
o
Ingestion of beef from cattle which have consumed contaminated groundwater
o
Ingestion of surface water while swimming
o
Ingestion of fish
The groundwater pathway assumes that the receptor will consume all of his
drinking water from site-influenced wells and will eat home produced beef also
from cattle watered from site-influenced wells. The Karst nature of the
groundwater flow system in the area of the Site makes it extremely difficult to
predict groundwater concentrations via modeling. For this reason, actual well
data was used to represent exposure point concentrations for current and future
scenarios.
Within this assessment, the potentially exposed populations were studied within a
2-mile radius of the Site. There are approximately 275 residential properties
(including livestock farms) in this area and approximately 70 households use
groundwater for domestic purposes and about 40 percent utilize the water for
livestock. Data obtained from the residential well sampling and analysis
indicate that r~sidential wells downgradient from the Site have about the same
metals concentration as the wells upgradient. This indicates that the landfill
materials do not appear to be currently affecting nearby wells. The groundwater
in the surficial aquifer in this area is classified as a Class II A aquifer based
on EPA's Groundwater Protection Strategy.
The environmental characteristics of the quarry pond do not make it an attractive
spot for swimming or fishing. The sides are steep and the pond is filled with
trash and has scum floating on the surface. Although the pond is an unlikely
-69-
-------
Table 32
SUMMARY OF CBEKICALS .OF POTENTIAL CONCERN
Groundwater Surface Water Sediments Fish
Chemical (uq/l) (uq/l) (mq/kq) (mq/kq)
Organics
Acetone 0.033 - 7 0.51 - 13
2-Butanone 0.007 - 0.018
Carbon Disulfide 0.004 - 0.007 0.14 - 0.48
DEHP 12 1.4 - 25
Methylene Chloride 0.01 - 0.12
4-Methyl-2-pentanone 0.023 - 1.6
Inorganics
Aluminum 43 - 15,900 105 - 134 8,300 - 32,300 35 - 102
Barium 4 - 698 136 - 165 143 - 244 5 - 7
Cadmium 1 13 6
Chromium 15 - 70
Copper 12 - 120 13 - 35 10 - 157 8 - 10
Iron 45 - 25,800 320 - 880 17,300 - 116,000 511 - 576
Lead 26 - 116 2
Manganese 3 - 745 98 - 161 701 - 1,490 558 - 1,280
Mercury 0.07 - 0.55 5
Nickel 32 - 41 16 - 34 12
Silver 14 - 24
Zinc 21 - 70 56 - 1,580 72 - 213
-70-
-------
Table 33
SUMMARY OF CHKMICAL CONCENTRATION VALUES AT RECEP'l'OR LOCATIONS
Chemical
Groundwatera
(uq/1)
Surface waterb
(uq/1)
Fish Ingestionc
(mq/kq)
Organics
Acetone
Carbon Disulfide
13
0.48
Inorganics
Aluminum
Barium
Cadmium
Copper
Lead
Iron
Manganese
Nickel
Zinc
10,068 107 102
594 158 7
6
81 27 10
2
25,857 783 576
.749 157 5
39 12
62 213
a)
These values represent the upper 95% confidence limit on the arithmetic
mean of site-influenced groundwater concentrations. Sediment data are not
included on this table since no exposure pathway to sediments exists.
b)
These values represent the upper 95% confidence limit on the geometric
mean of al~ surface water samples. The geometric mean was used because of
the skewed nature of the data.
c)
Since only two samples were available, these values represent the maximum
concentration value found in fish fillet samples.
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1-
recreational area, the ingestion of surface water while swimming and fish
consumption scenarios were evaluated. The dermal absorption pathway was not
evaluated due to the low toxicities, low concentrations, and a low rate of
absorption of the surface water metals of concern through the skin. The
sediment exposure pathway is an unlikely pathway for the direct contact exposure
route because the quarry conditions are not conducive to wading (i.e., the walls
are steep and the pond has a depth of approximately four feet throughout the
year. However, the sediments are a potential source for groundwater
contamination. Soil is also an unlikely exposure pathway due to the three foot
clay cap with abundant vegetation over the landfilled area.
The major exposure assumptions used to calculate intake levels are contained in
Table 34.
9.3
Toxicitv Assessment
Toxicity values are used in conjunction with the results of the exposure
assessment to characte=ize Site risk. EPA has developed critical toxicity values
for carcinogens and non-carcinogens. The CPFs have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potenttally carcinogenic chemicals. CPFs, which are
expressed in units of (mg/kg/day)--, are multiplied by the estimated intake of
a potential carcinogen, inmg/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 underestimation of the actual cancer
risk highly unlikely. CPFs are derived from the results of human epidemiolog~cal
studies or chronic animal bioassays to which animal-to-hurnan extrapolation and
unce=tainty factor? have been applied. Although no carcinogens were considered
to be contaminants o! concern in the risk assessment for the two media
(groundwater and surface water) which have potential complete exposure pathways,
carcinogens in the landfill constituents & possibly the pond sediments (unlikely)
could potentially contaminate groundwater supplies in the future. The risk
assessment ruled out DEHP as a groundwater contaminant of concern because the
associated ~lank sample also contained DEHP. However, subsequent sampling by
EPA's Environmental Services Division (ESD) indicated that an on-site well (MW-~'
contained DEHP at the concentration of 12 ug/l. For this reason groundwater
cleanup criteria were derived for chemicals which were determined to be Site
contaminants to use for future groundwater monitoring. The CPFs for sediment
carcinogenic contaminants are contained in Table 35.
Reference doses (Rfds) have been developed by EPA for indicating the potentia:
for adverse health effects from exposure to chemicals exhibiting noncarcinoge~--
effects. RfDs, which are expressed in units ofmg/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
chemical ingested from contaminated drinking water) can be compared to the R!~
Rfds are derived from human epidemiological studies or animal studies to whic'
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uncertainty factors have been applied (e.g., to account for the use of animal
data to predict effects of humans). These uncertainty factors help ensure that
the RfDs will not underestimate the potential for adverse noncarcinogenic effects
to occur. The RfDs for the Site contaminants of concern are summarized in Table
35.
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Table 34
PARAKETKRS USED 'l'O DBSCRIBR BXPOSURB TO SITE-RELATED
CHEKICALS OF PO'l"KNTIAL CORCBRN
Exposure
Pathway
Chemical Concen.
in Media
Drj,nking Water
Upper 95% bound on
Arithmetic Mean
~
Meat Ingestion
Upper 95% bound on
Arithmetic Mean
Incidental
Ingestion
While
Swimming
Upper 95% bound on
Arithmetic Mean
Fish
Ingestion
Maximum Concentration
Where:
IR = Ingestion Rate
EF = Exposure Frequency
ED = Exposure Duration
BW = Body Weight
AT = Average Time
WIRc = Water Ingestion
Ff = Ingestion-to-Beef
FI = Fraction Ingested
CR = Contact Rate
ET = Exposure Time
. Exposure
Assumptions
IR = 2 1/day
EF = 365 days/year
ED = 70 years
BW = 70 kg
AT = 25,550 days
WIRC= 50 l/day
Ff= chemical specific
IR = 0.103 kg/day
FI = 0.75
EF = 260 days/year
ED = 70 years
BW = 70 kg
AT = 25,550 days
CR = 50 ml/hour
ET = 2.6 hours/event
EF = 48 events/year
ED = 8 years
BW = 49.5 kg (14 yr. male)
AT = 2,920 days
IR = 0.284 kg/meal
FI = 0.10
EF = 48 days/year
ED = 70 years
BW = 70 kg
AT = 25,550 days
Rate for Cow
Transfer Coefficient
from Contaminated Source
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. ----~
Table 35
TOXICITY VALUES FOR CBKKICALS OF POTmt-:lIAL OOBCERH
Chemical
Cancer Potency
Factor (CPF)
(mg/kg-day)-1
Reference
Dose (RfD)
(mg/kg-day)-1
Source
Acetone 0.1 IRIS
2-Butanone 0.05 HEAST
Bis(2-ethylhexyl) 0.014 0.02 IRIS
phthalate
Carbon Disulfide 0.1 IRIS
Methylene Chloride 0.0075 0.06 IRIS
4-Methyl-2-Pentanone 0.05 IRIS
Aluminuma
Barium 0.05 HEAST
Cadmium 0.0005 IRIS
Chromium
coppera
Leada
Manganese 0.2 HEAST
Mercury 0.0003 HEAST
Nickel 0.02 IRIS
Silver 0.003 IRIS
Zinc 0.2 HEAST
a)
There are no Agency verified oral toxicity values for these chemicals
IRIS = Integrated Risk Information System
HEAST = Health Effects Assessment Summary Tables
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9.4
Risk Characterization
Human health risks are characterized for potential carcinogenic and
noncarcinogenic effects by combining exposure and toxicity information. Excess
lifetime cancer risks are determined by multiplying the intake level with the
cancer potency factor. These risks are probabilities that are generally
expressed in scientific notation (e.g., lx10-6). An excess lifetime cancer
risk of lx10-6 indicates that, as a plausible upper bound, an individual has a
one in one million additional chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime under the ass~ed
specific conditions at the Site. The Agency considers individual excess cancer
risks in the range of 10-4 to 10-6 as protective; however, the 10-6 risk
level is generally used as the point of departure for setting cleanup levels at
Superfund sites. This approach is consistent with Agency policy for the
implementation of SARA.
Although the potential complete pathways do not have carcinogenic indicator
chemicals based on the RI sampling, the test-pits and sediment data indicate that
several carcinogens are present at concentrations that could impact groundwater
quality. In addition, DEHP was detected in an on-site monitoring well in
supplemental sampling.
Potential concern for noncarcinogenic effects of a single contaminant in a single
medium is expressed as the hazard quotient (HQ), or the ratio of the estimated
intake derived from the contaminant concentration in a given medium to the
contaminant's reference dose. By adding the HQs of all contaminants within a
medium or across all media to which a given population may reasonably be exposed,
the Hazard Index (HI) can be generated. The HI provides a useful reference point
for gaugeing the potential significance of multiple contaminant exposures within
a single medium or across media. A HI greater than 1.0 indicates that exposure
exceeds the protective level.
The estimated risk calculations were based on present conditions at the Site
including the existing cap and no major increases of contaminants in the shallow
Ridley Limestone aquifer which discharges into Big Rock Creek. The only
carcinogenic compound that recorded a value in the 10-4 to 10-6 risk range
for groundwater exposure is DEHP which was detected at a concentration of 12 ppb
in well MW-S during supplemental sampling. This concentration corresponds to a
increased cancer risk of SxlO-6 DEHP is a potential concern at the Site since
it has been identified in a test-pit at 38,000 ppb, in the groundwater at MW-S at
12 ppb, and in the pond sediments at 6,000 ppb. The proposed MCL for DEHP is 4.0
ppb. At the present time it appears that DEHP poses little threat to human
health or the environment while it is contained in the landfill, however,
detection of this carcinogenic compound in the test pit, monitoring well, and
pond sediment appears to indicate that-the contaminant possesses the potential
not only to migrate via the groundwater, but also to increase concentrations if
remedial measures are not taken.
Because the noncarcinogenic contaminants of concern affect different target
organs, the chemical specific HIs were not summed. However, the HIs for each
chemical were summed across pathways. The highest cumulative HI (0.347) was for
barium exposure. The summed HIs calculated for exposure to Site contaminants of
concern in the groundwater and surface waters at the site were all below 1.0 for
num~n health.
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10.0
ENVIRONMENTAL RISKS
Environmental receptors include fish in the quarry pond and other fresh water
aquatic animals. that inhabit the area, such as turtles and aquatic water fowl.
Because access to the pond is limited, it is not likely that many terrestrial
animals use the pond as a water source; however, ground water found in
downgradient sinkholes may be used as drinking water for small mammals. No
endangered species have been identified near the Site. (Brown, 1988).
The fresh water Crustacean Daphnia was used as an indicator species to assess the
aquatic toxicity of the quarry pond. Hazard quotients were derived for the
surface water contaminants of concern by dividing the surface water concentration
by the maximum acceptable toxicant concentration (MATC). Copper contamination in
the pond was determined to have a Hazard Quotient of 3.86. Since copper in
aquatic systems can be highly toxic, it will be necessary to reduce the amount of
this metal in the pond.
Also, since the time of the RI, additional (supplemental) data has been collected
concerning water hardness in the pond. In the RI a value of 100 mg/l caco3 was
assumed to calculate the aquatic based pond water cleanup levels for copper,
lead, nickel and zinc. Actual water hardness data was obtained in July (1990)
with a water hardness of 182 mg/l caco3. The different hardness values can be
attributed to a variety of factors which include: seasonal fluctuation in
rainfall amounts and frequency, size of the pond, flow into and out of the pond,
geologic factors, and others. Given that only one variable has been analyzed, it
appears that a comparison of only two hardness values and the resulting changes
in the pond water cleanup values, are inconclusive. Thus, the original values
presented in the RI will be utilized.
11.0
DESCRIPTION OF ALTERNATIVES
The landfill materials, surface debris, submerged pond debris, contaminated soil,
groundwater, and the quarry pond are under consideration for cleanup. A remedy
for the Site is proposed to protect public health and the environment by
controlling exposure to contaminated materials and reducing additional migration
of contaminants into surrounding soils, sediments, surface water and
groundwater. Currently, one on-site monitoring well exceeds the proposed MCL fo~
DEHP.
The following summary lists the five (5) remedial alternatives under
consideration for the landfill wastes and shallow groundwater at the Lewisburg
Dump Site. The FS Report contains. a more detailed evaluation of each
alternative.
All but one (Alternative 1) of these alternatives
and well use at the Site, upkeep of the fence and
assess the effectiveness of the remedy.
involve restrictions on lane
property, and monitoring to
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11.1
ALTERNATIVE 1: NO ACTION
Present Worth (PW) Cost: 133,082 (Amount presented
A dye tracer study for $60,000 is included as part
most effective sampling program can be' efficiently
of this method.
is for well monitoring only.
of well monitoring since the
obtained with the assistance
Years to Implement: 0 (up to 5 years if monitoring is elected).
CERCLA requires that the "No Action" alternative be considered at every site.
This alternative must be considered since: 1) it may be more harmful to human
health and the environment'to disturb contamination at some sites, and 2) it may
be"the only low risk, cost effective alternative. Under this alternative, no
soil, sediment, groundwater or debris cleanup, containment or treatment would
take place. The only reduction of contaminant levels would occur via natural
processes such as dispersion or attenuation. The only costs incurred would be
for monitoring the site.
11.2
ALTERNATIVE 2: DEED RESTRICTIONS AND SITE ACCESS RESTRICTIONS (FENCING)
Present Worth Cost: $185,000
PW Capital Cost: $127,000
PW 0 & M Cost: $57,000
Years to Implement: 0.3 (up
to 5 years if monitoring is elected)
; This alternative will insure that Site access is limited through installation of
a security fence (4,650 linear feet) while also establishing controls that ensure
proper maintenance of the Site through deed restrictions. This alternative does
not improve residual risks above baseline conditions. Any reductions in
toxicity, mobility, and volume are the same as those discussed for Alternative
1. Immediate or near-term compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) or Guidance To Be Considered (TBCs) cannot be achieved with
this alternative.
11. 3
ALTE~~AT!VE 3 (MODIFIED): INSTITUTIONAL CONTROLS PLUS: REMOVAL OF SURFACE
DEBRIS, LANDFILL CAP REGRADING, LONG-TERM WELL MONITORING AND ANALYSIS.
Present Worth Cost: $791,512 - $1,189,741
PW Capital Cost: $521,370 - $919,598
PW 0 & M Cost: $270,142
Years to Implement: 0.3 (to complete remedial action)
5 years for well monitoring
Due to several concerns raised during the Public Meeting and in the comments to
EPA's Proposed Plan submitted to the EPA on behalf of the Lewisburg Environmental
Response Committee (PRPS), the recommended alternative has been modified. This
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alternative is similar to the originally presented Alternative 3 with the
following modifications: 1) landfill cap "regrading", is stated instead of
"upgrading", 2) regrading of the cap (approximately 0.41 acres) will prevent
additional infiltration of water due to landfill cap undulation - which will meet
State and Federal requirements without cap "upgrading". This alternative
implements the institutional controls discussed for Alternative 2 and adds
several additional remedial measures that are designed to reduce potential
exposures or release of contaminants from the Site. Remedial measures include
the removal of submerged pond debris and Site surface debris, replacement of the
plastic test pit caps with clay and soil material (2.5 feet of ciay and 12 inches
of soil-188 cubic yards of clay and 50 yards of topsoil), and the regrading of
the cap to meet all applicable state standards for closure of sanitary
landfills. The landfill cap regrading will require approximately 670 cubic yards
of fill to add an additional 12 inch thick cover to the cap. Submerged debris
that may present a problem will be moved from the pond. Recyclable material will
be separated out and nonrecyclable material will be disposed in an approved and
permitted sanitary landfill. This may include the addition of extra clay or
soil, proper grading and surface drainage controls, removal of trees from the cap
area, and the establishment of adequate vegetative cover. In the event that a
suitable location cannot be found for disposal of this non-hazardous material, it
will be disposed of on-site before restoration of the landfill cap takes place.
Any hazardous wastes found will be disposed of off-site at an approved RCRA
disposal site. In addition, monitoring efforts and analysis are included to
measure the effectiveness of the remedial activities. A dye tracer study or
other acceptable method will be used to determine the most suitable groundwater
sampling locations for long-term monitoring. This will be implemented during the
Remedial Design Phase of the Superfund Program (Immediately follows the RI/FS).
Monitoring efforts will include the collection of surface water samples from the
pond and groundwater samples from specific on-site and off-site locations. This
alternative meets all NCP (National Contingency Plan) requirements and will be in
compliance with all ARARs. Unlike Alternatives 1 & 2 (which are unable to
achieve water quality-based ARARs) this alternative actively isolates the major
contributing sources which will allow compliance with environmental standards.
Modified Alternative 3 also provides three (3) options for disposal of submerged
pond debris and surface debris removal. The differences in cost between the 3
options are completely dependent upon the disposal of the wastes extracted from
the pond and the Site. While it is anticipated that the waste removed will be
non-hazardous and can be disposed of either at an approved off-site sanitary
landfill or by disposal on-site, the final option selection will take place
during the RD/~ phase of the project.
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11.4
ALTERNATIVE 4: INSTITUTIONAL CONTROLS PLUS: REMOVAL AND TREATMENT OF
MATERIAL FROM THE SITE AND ISOLATION OF POND SEDIMENTS
Present Worth Cost: $47,000,000 - $100,000,000
PW Capital Cost: $43,000,000 - $100,000,000
PW 0& M Cost: $270,000
Years to Implement: 2 for construction activities
. 5 years (total) for well monitoring
This alternative involves the removal, treatment, and disposal of all material in
the landfill and isolation of the pond sediments from the aquatic community.
Remedial actions associated with Alternative 3 are included with the exception of
test pit cap replacements. These actions include institutional controls,
submerged and surface debris removal from the quarry pond, and monitoring and
analysis of the groundwa~er. Extraction of the landfill material will require
approximately 9000 truckloads (or approximately 120,000 cubic yards) of material
to be shipped off-site. Also, this material will be treated by solidification/
fixation and dewatering processes. These actions will increase potential human
and environmental exposures to contaminants. Increased exposure of contaminants
or excavation accidents will also result in increased leachate generation that
may adversely affect human and environmental receptors in the vicinity of these
activities. Landfill material extraction satisfies the CERCLA statutory
preference as a principle element of the remedy. However, despite the long-term
effectiveness and permanence of this alternative, other serious short-term
impacts in addition to ones previously described are present. Isolation of the
existing pond sediments from the aquatic wildlife requires addition of new
substrate consisting of uncontaminated soil. Addition of the substrate material
will potentially create a thick cloud of suspended material that will reach all
areas of the pond and seriously or fatally impact many aquatic organisms.
Considering the application of the isolating soil layer in the pond, Section 404
of the CWA (ARAR) should be complied with by complying with permit standards for
the discharge of fill into waters of the United States. This can be accomplished
by contacting the Army Corps. of Engineers to get the standards information and
follow the regulations. However, it should be noted that it is not mandatory to
apply for a permit through the ACEs.
11. 5
ALTERNATIVE 5: COMPLETE REMOVAL OF LANDFILL MATERIAL. POND SEDIMENTS. AND
SURFACE AND SUBMERGED DEBRIS
Present Worth Cost: $47,000,000 - $100,000,000
PW Capital Cost: $47,000,000 - $100,000,000
PW 0 & M Cost: $23,000
Years to Implement: 2 for Construction Activities
5 for total well monitoring
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This alternative offers a long-term effective and permanent remedy. All
site-related contaminants will be removed. The security fence previously
discussed will be installed as part of this remedy. The purpose of the fence
will be to prevent junkyard activities from impacting the Site and to discourage
uncontrolled dumping. This alternative achieves the CERCLA statutory preference
for removal and/or treatment as a principle element of the remedy. This is
accomplished by extracting recycles where possible and treating contaminants as
described in Alternative 4 (extraction/solidification/fixation/dewatering/
disposal) with the exception that in Alternative 5, the pond sediments will be
extracted and treated. The short-term effectiveness and impacts of this remedy
can be considered identical to that discussed for Alternative 4. The short-term
impacts on the local aquatic community in the pond could be devastating. In
addition, short-term impacts associated with added leachate generation during
landfill excavation activities and remedial action related accidents could also
prove significant. Considering Section 404 of the CWA, the response is the same
as Alternative 4.
12.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives developed during the Lewisburg
evaluated by U.S EPA using the following nine criteria.
disadvantages of each alternative were then compared to
providing the best balance among these nine criteria.
1.
2.
3.
4.
5.
6.
Dump Site FS were
The advantages and
identify the alternative
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.
Compliance with Applicable or Relevant and Appropriate Requirements
(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.
Long-term Effectiveness
alternative to maintain
environment, over time,
and Permanence refers to the ability of an
reliable protection of human health and the
once cleanup objectives have been met.
Reduction of Toxicity, Mobility or Volume is the anticipated performance
of the treatment technologies an alternative may employ.
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.
Implementability is the technical and administrative feasibility-of an
alternative, including the availability of goods and services needed to
implement the solution.
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7.
Cost includes capital costs, as well as operation. and maintenance costs.
8.
Agency Acceptance indicates
technical documents for all
Proposed Plan, the u.s. EPA
Environment (TDHE) agree on
whether, based on its review of the
aspects of the Site investigation, and the
and the Tennessee Department of Health and
the preferred alternative.
9.
COmmunity Acceptance indicates the public support of a given
alternative. This criteria is discussed in the Responsiveness Summary.
12.1
Landfill Wastes and Groundwater
The following is the evaluation of the five (5) alternatives for the landfill
wastes, quarry pond, and groundwater using the nine criteria.
12.2
Overall Protection of Human Health and the Environment
All the alternatives considered above with the exception of the No Action
Alternative (Alternative 1) and Alternative 2 would be protective of human health
and the environment. Alternatives 1 and 2 are not protective because they allow
bioaccumulatior. of contaminants by wildlife at the Site and in the quarry pond.
Also, failure to maintain and regrade (restore) the landfill cap may result in
migration of unacceptable levels of contaminants to the quarry pond and
eventually into Big Rock Creek. Other possible consequences are human or animal
exposure to contaminants through soil or sediment contact. Alternative 3 would
prevent human or animal exposure to on-site contaminants through the
implementation of institutional controls, landfill cap restorations, removal of
surface debris and submerged debris in the quarry pond, and well monitoring and
site maintenance. Alternatives 4 and 5 would also be protective of human health
and the environment by removing all of the Site contaminants but have.serious
short-term effectiveness and implementability problems.
12.3
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 1 is not in full compliance with ARARs for the closure of sanitary
landfills and would allow for possible direct contact or exposure to hazardous
substances. Alternative 2 while limiting possible direct contact or exposure,
does not provide a sufficient reduction of contaminants to meet all ARARs.
Alternative 3 is in full compliance with all ARARs. Alternatives 4 and 5 will
meet all ARARs with the possible (unlikely) exception of the Clean Water Act
(CWA) provisions concerning fill operations in u.S. waters. However, as was
discussed previously, it appears that following the permit regulations provide;
through the Army Corps of Engineers should be sufficient to meet this ARAR.
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12.4
Reduction of Toxicitv. Mobilitv or Volume
Alternatives 1,2 and 3 do not involve the treatment of the landfilled wastes,
there will be no direct reduction in the toxicity, mobility, or volume of
landfill contaminants. Indirectly, Alternative 3 will reduce the mobility of
landfill contaminants by reducing infiltration in the landfill cap and potential
additional migration of DEHP and copper into the groundwater, the quarry pond,
and eventually off-site. Alternative 3 will also reduce the threat of erosional
. problems by landfill cap regrading and the addition of 670 cubic yards of fill.
Alternatives 4 & 5 do involve removal and treatment of contaminated materials,
soils, and pond sediments (Alternative 5 only), and would provide a significant
reduction first by complete removal of contaminants, and second, by the reduction
of toxicity and mobility through treatment. The treatment process involves
solidification/fixation of fines. and associated dewatering processes for 120,000
cubic yards of landfill contaminants, and for Alternative 5 only, the extraction
of 4,000 cubic yards of pond sediments by vacuum dredging and treatment as
above. However, due to the excessive amount of materials at the Site (126,025
cubic yards), it is not feasible to remove and perform treatment since: 1) the
majority of materials do not possess high levels of contamination, and 2) the
costs would be exorbitant.
12.5
Lonq-Ter~ Effectiveness
All of the alternatives except for the No Action Alternative and Alternative 2
provide long-term effectiveness and permanence. The No Action Alternative
assumes that baseline conditions will not change (no controls will be in place to
prevent changes) even though leachate with low levels of contamination is present
in the landfill area. Alternative 2 establishes controls required to prevent
some changes from baseline using deed restrictions and a security fence. No cap
restoration is recommended on Alternative 2 leaving the possibility open for
further landfill cap deterioration. This could allow more infiltration of water
into the landfill resulting in increased leachate formation. Alternative 3
removes a suspected major contributor of contamination in the pond and
groundwater (submerged pond debris) and implements deed restrictions and
eliminates Site access to maintain improvements. The long term effectiveness and
permanence would be sufficient to protect human health and the environment. This
is similar to Alternative 4 except that the effectiveness and permanence
increases due to additional removal. Alternative 5 will remove all on-site
contamination and will provide the greatest long-term effectiveness and
permanence.
12.6
Short-Term Effectiveness
All of the alternatives with the exception of the Alternative 1 would immediately
eliminate the two exposure pathways: ingestion of surface water and ingestion of
pond fish. Alternative 2 will offer no changes in risks from baseline
conditions, therefore, unacceptable risks (such as continued leaching of metals
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into the pond, increasing infiltration through the landfill cap and Site access)
will still exist. Alternative 3 will have reasonable short-term effectiveness
concerning the quarry pond (removal of submerged debris), upgrading of the
deteriorating landfill cap, and the previously mentioned exposure pathway
elLminations. Alternative 4 will result in significant risk associated in
leachate generat10n, remedial worker exposures and accidents, traffic accidents,
and sedLment suspension in the aquatic environment. Alternative 5 will be
identical in this respect to Alternative 4 except, pond sedLment will be removed
instead of being covered. Short-term consequences for Alternatives 4 and 5 may
be catastrophic for the aquatic community of the quarry pond and have significant
risks in the short-term.
12.7
Implementability
The Lmplementability of an alternative is based on technical feasibility, .
administrative feasibility and availability of services and materials. All of
the Alternatives are readily implementable. Alternatives' 1 and 2 that consist of
no action or minor application of institutional controls will not have any
Lmplementation problems. For Alternatives 3,4, and 5 there will be little or no
implementation difficulties since only standard construction techniques will be
utilized. The only item of concern will be the resolution of Site ownership
issues as needed for the construction of the security fence and the removal of
debris from the pond.
. -'
12.8
Cost
Alternative 1 contains only the cost for well monitoring and has a present worth
value of $133,082. The present worth value represents the total cost of the
remediation expressed in today's dollars. The estLmated present worth cost for
Alternative 2 is $176,000 - $193,000. Alternative 3 (Modified) has a present
worth cost of $791,512 - $1,189,741 while Alternative 4 has a present worth cost
of $43,000,000 - $ 100,000,000, and Alternative 5 at $47,000,000 - $104,000,000.
Alternatives 4 and 5 are not cost effective for present Site conditions since
contaminant concentrations do not warrant extensive excavations at the Site, and
little additional protection would be achieved over Alternative 3.
12.9
State Acceptance
The State of
evaluations.
approval for
Tennessee has assisted EPA in the review of reports and Site
The State has reviewed the Record of Decision and submitted
the selected remedy at the Lewisburg Dump Site.
their
12.10
Community Acceptance
Community response to the alternatives is presented in the responsiveness summary
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(Section 14.0) which addresses comments received during the public meeting and
the public comment period.
13.0
SELECTED REMEDY
The selected remedy for the Lewisburg Dump Site is Modified Alternative 3
involving Site access restrictions, deed restrictions, replacement of the
test-pit caps with landfill cap material, regrading the landfill cap, removal of
Site surface debris, removal of submerged debris i~ the quarry pond, and
long-term monitoring and analysis.
The selected remedy will include the following activities:
i)
ii)
iii)
iv)
v)
vi)
vii)
Implementation of institutional controls which include a security fence
and. deed restrictions;
Removal of all Site surface debris and disposal in either: 1) one of the
test-pits at the Site, 2) an approyed sanitary landfill, and 3) a
hazardous waste landfill;
Removal of the debris in the quarry pond and disposal in of the 3
locations described above;
Replacement of the plastic test-pit caps with landfill cap material;
Regrading the landfill cap to stabilize conditions ~nd to meet State and
Federal regulations;
~ong-term well monitoring and analysis;
Landfill cap re-seeding and maintenance.
The extent of the security fence at the Site is presented in Figure 13.
EstLmated costs for the remedial procedures are shown in Table 36.
The implementation of the remedial measures for the selected remedy will take a
maxLmum of 3 months. However, in order to fully determine that the remedial
actions taken have effectively reduced the threat to public health or the
environment, a 5 year well monitoring and analysis program will be Lmplemented.
Modified Alternative 3 can be readily Lmplemented and has the lowest degree of
short-term Lmpact that employs both institutional controls and actively removes a
likely source of contamination. This cost of Lmplementing this alternative
ranges from $791,512 - $1,189,741 which is approxLmately 56 times less than
Alternatives 4 or 5 that will have devastating short-term impacts for the Site
(especially on the aquatic life in the pond).
-85-
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lEWISBURG DUMP SITE
lOCA nON OF PROPOSED
FENCE
.QETAI~
NOT 10 sc., (
-------
nBLB 36
COST ESTIMATE AND
DESCRIPTION OF MODIFIED ALTERNATIVE 3
Task
Disposal Options
Option 1a Option 2b Option 3c
Security Fence
Total capital Costs:
$9,130 $9,130 $9,:.130
$117,815 $117,815 $117,815
$299,119 $462,189 $371,025
$22,221 $22,221 $22,221
$73,085 $308,243 $58,126
Present Worth O&M Costs:
$57,493 $57,493 $57,493
$133,082 $133,082 $133,082
$79,567 $79,567 $79,567
Deed Restrictions
Submerged Debris Removal
Test-Pit Cap Remediation
Surface Debris Removal
Deed Restrictions
Groundwater Monitoring
Surface Water Monitoring
Estimated Cost
of Modified Alternative 3:
$791,512
$1,189,741
$848,459
a)
Implementation of Disposal Option 1 includes disposal of submerged and
surface debris to an approved offsite sanitary landfill
b)
Implementation of Disposal Option 2 includes disposal of submerged and
surface debris to an approved hazardous waste landfill
C)
Implementation of Disposal Option 3 includes disposal of submerged and
surface debris in one of the 13 test-pits located on-site (within the 4-4 -. ..
landf ill)
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Maintenance activities for the selected remedy will include:
i)
ii)
iii)
iv)
v)
Periodic inspection of the security fence (conducted semi-annually);
periodic inspection of the landfill cap (conducted semi-annually);
Mowing of the landfill cap (4 times a year);
Re-establishment of vegetation over distressed areas;
Monitoring Activities for the selected remedy will include:
periodic repair of areas eroded by surface water runoff.
i)
ii)
iii)
iv)
Initial study utilizing a dye-tracer analysis to determine preferred well
monitoring/sampling locations;
Periodic sampling and analysis of groundwater from the preferred well
monitoring locations;
periodic sampling and analysis of the surficial waters from the quarry
pond;
periodic sampling and analysis of the fish from the quarry pond.
The remedial activities for the Site will effectively reduce the levels of
contamination to effectively meet the cleanup levels for contaminants of concern
are presented in Table 37. Stabilizing the landfill cap will be fundamentally
important so that potential for increasing flow through the contaminated material
is reduced. This will intern reduce the amount of contaminants such as copper
and DEHP that are entering the groundwater, quarry pond, and pond sediment from
the landfill.
13.1
Summary of Statutory Findinqs
Under its legal authorities, EPA's primary responsibility at Superfund sites is
to undertake remedial actions that achieve adequate protection of human health
and the environment. In addition, section 121 of CERCLA establishes several
other statutory requirements and preferences. These specify that when complete,
the selected remedial action or this site must comply with applicable or relevant
and "appropriate environmental standards established under Federal and State
environmental laws unless a statutory waiver is 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
volume, toxicity, or mobility reduction of hazardous wastes as their principal
element. The following sections discuss how the selected remedy meets these
statutory requirements.
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13.2
Protection of Human Health and the Environment
Modified Alternative 3 will prevent human or animal exposure to on-site
contaminants through the implementation of institutional controls, landfill cap
restoration, removal of surface debris and submerged debris in the quarry pond,
well monitoring and Site maintenance. The contaminants will be contained so that
plant and animal life will no longer come in contact with and bioaccumulate the
contamination. The cancer risk associated with the site will be around lxlO-6
and the Hazard Indices (HI) will be less than,1.0.
There will be no unacceptable short-term threats or cross media impacts
associated with the selected remedies that cannot be readily controlled since
only minimal contact with or movement of the wastes will occur.
13.3
Comnliance with ARARs
The selected remedy will comply with all Applicable or Relevant and Appropriate
Requirements (AJUL~s). The action specific, chemical specific, and location
specific ARARs are presented below:
Action Specific:
o
State of Tennessee Solid Waste Processing and Disposal Facilities in
Tennessee (TCA68-13-1 et. sea., Rule 1200-1-7)
o
State of Tennessee Solid Waste Processing and Disposal Facilities in
Tennessee (Ru~e 1200-1-7.01 through .07)
o
Occupationa~ Safety and Health Act (29 USC 651,29 CFR1904,19l0, and 1926)
o
Resource Conservation and Recovery Act (42 USC 6901, et.sea., 40CFR264.
Chemical Specific:
o
Safe Drinking Water Act (42 USC 300f, et. sea.)
o
Clean Water Act (404, & 33 usc 1313, et. sea.)
Location Specific ARARs:
None
RCRA Land Disposal Restrictions (LDRs) are not applicable since the remedial
. activities concerning the landfill cap will not require any movement of
contaminated materials. However, if during the removal of debris from the pond
hazardous waste is encountered, it will be managed in accordance with RCRA
requirements including LDRs.
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Table 37
GROURDWATBR ClUTBIUA PaR LBWISBURG DUMP SID
Chemical
Groundwater
Criteria
(uq/l)
Basis
Organics
Acetone
2-Butanone
Bis(2-ethylhexyl)
phthalate
Carbon Disulfide
Methylene Chloride
4-Methyl-2-Pentanone
700 RfD
350 RfD
4 PMCL
700 RfD
5 PMCL
350 RfD
Inorganics
Aluminum
BariurT'
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Silver
Zinc
50
1000
10
50
1000
300
15
50
2
100
50
5000
PSMCL
MCL
MCLa
MCL
SMCL
SMCL
IAL
SMCL
MCL
MCLG
MCL
SMCL
A)
Proposed MCL is 5.
RfD = Reference Dose. Criteria is 'based on the lifetime ingestion of 2 liters of water
by a 70 kg individual. This number allows a 20 percent relative source contribution by
the Site groundwater route.
MCL = Maximum Contaminant Level
PMCL = Proposed MCL
PSMCL = Proposed Secondary MCL
MCLG = Maximum Contaminant Level Goal. NCP states that non-zero MCLGs should be used
as criteria. If the MCLG is zero, the MCL is used.
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Table 37 Cont'd
IAL = Interim Action Level. The interim action level for lead was recommended
in a memorandum from Henry Longest (Director of the Office of Emergency and
Remedial Response) to Patrick Tobin (Director, Region IV Waste Management
Division), June 21, 1990.
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13.4
Guidance To Be Considered (TBCs)
o
Reference Doses (RfDs) from the EPA office of Research and Development
o
Carcinogenic potency factors (CPFs) from the EPA Environmental Criteria
and Assessment Office, EPA Carcinogen Assessment Group
o
SMCLs under the Safe Drinking Water Act (42 USC 300f, et. seq.)
o
Proposed National Primary and Secondary Drinking Water Regulations of May
22, 1990 (54FR22062)
o
State of Tennessee Solid Waste Processing and Disposal Facilities in
Tennessee (TCA 68-13-1 et. seq., Rule 1200-1-7)
13.5
Cost Effectiveness
The selected remedy is cost effective
overall effectiveness proportional to
least costly of Alternative 3,4 and 5
health and the environment.
because it has been determined to provide
its costs. The selected remedy is the
which are equally protective of human
13.6
Utilization of Permanent Solutions and Alternative Treatment Technoloqies
or Resource Recoverv Technoloqies to the Maximum Extent Practicable
U.S. EPA and the State of Tennessee believe 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 remedy at the Lewisburg Dump
Site. Of the alternatives that are protective of human health and the
environment and comply with ARARs, U.S. EPA and the State have determined that
the selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility or vol~e achieved
through treatment, short-term effectiveness, implementability, and cost
(also considering the statutory preference for treatment as a principal element
and considering State and community acceptance).
The selected remedy for the containment of the dump wastes can be implemented ar.d
completed quickly with less difficulty,and at less cost than treatment
technologies due to the low levels of contamination present at the Site. Also,
the Site contaminants are disseminated throughout the landfill making excavatLc~
and treatment of specific contaminants such as DEHP and copper unrealistic give~
the large amoun~ of materials (126,025 cubic yards).
13.7
Preference for Treatment as a Principal Element
In selecting the remedy for the Lewisburg Dump Site, EPA considered the use of
treatment -technologies to the maximum extent possible. As stated previously, ~.'
to unrealistic costs and implementation problems for treatment, it not conside~~-
as an eff~ctive option for the Site. However, as compared to treatment, the:-..
would be no significant changes in risk levels if containment is implemented.
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14.0
RESPONSIVENESS SUMMARY
A responsiveness summary is required by Superfund policy to provide a summary of .
citizen comments and concerns about the Site, as raised during the public comment
period, and the responses to those concerns. All comments summarized in this
document have been factored into the Final decision of the preferred alternative
for cleanup of the Lewisburg Dump Site.
This responsiveness summary for the Lewisburg Dump Site is divided into the
following sections:
I.
Overview: This section discusses the recommended alternative for
remedial action and the public reaction to this alternative.
II.
Backqround on Community Involvement and Concerns: This section provides
a brief history of community interest and concerns regarding the
Lewisburg Dump Site.
III. Summary of Maior
EPA's Responses:
submitted during
these comments.
Questions Received Durinq the Public Comment Period and
This section presents both oral and written comments
the public comment period, and provides responses to
IV.
Written Comments Received Durinq the Public Comment Period and EPAs
Responses to These Comments: This section contains a summary of the one
letter received by EPA containing written comments, as well as EPAs
written response letter, and response to written comments submitted on
behalf of LERC.
Appendix A: Contains the Proposed Plan that was presented to the public
on July 25, 1990. This document was also placed in the information
repository and mailed to those on the mailing list.
AppendixB: Includes the sign in sheets from the public meeting held on
July 25, 1990 at the City Administration Building in Lewisburg,
Tennessee.
Appendix C: Includes the name, address and phone number of .the
information repository designated for the Lewisburg Dump Site..
Appendix D: Contains the official
the Proposed Plan for the remedial
Site in Lewisburg, Tennessee.
transcript of the Public Hearing on
activities for the Lewisburg Dump
14.1 (I)
Overview
The United States Environmental Protection Agency (EPA) and the Tennessee
Department of Health and the Environment (TDHE) established a public comment
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period from July 25th to August 23, 1990 for interested parties to comment on
EPA's Proposed Plan (Appendix A) for the remedial ~ctivities at the Lewisburg
Dump site. A public meeting was conducted by EPA on Wednesday, July 25, 1990 at
the City Administration Building in Lewisburg, Tennessee. The meeting summarized
recent RI/FS studies conducted at the Site and presented EPA's preferred
alternative in the Proposed Plan which contains the following sections:
o
o
o
o
Introduction
Site Background
Scope and Role of Response Action
Summary of Site Risks
Summary of Alternatives
The community's Role in the Selection Process
List of Contacts
Glossary of Evaluation Criteria
Glossary of Terms
o
o
o
o
o
The preferred remedial alternative (Alternative 3) presented at the Public
Meeting held on July 25, 1990 consists of:
o
Implementation of institutional controls which include a security fence
and deed restrictions;
o
Removal of all Site surface debris and appropriate disposal in either:
1) one of the test-pits at the Site, 2) an approved sanitary landfill,
and/or 3) a hazardous waste landfill;
o
Removal of the debris in the quarry pond and disposal in one of the 3
locations described above;
o
Replacement of the plastic test-pit caps with landfill cap material;
o
Regrading the landfill cap to stabilize conditions and to meet State and
Federal Regulations;
o
Long-term well monitoring and analysis;
o
Landfill cap re-seeding and maintenance.
A complete discussion of the preferred alternative is presented in section 13.
Overall, the community favors the selection of the recommended alternative -
Alternative 3. However, due to several concerns raised during the Public Meeting
and 1n the Comments to EPA's Proposed Plan submitted to the EPA on behalf of the
"Lewisburg Environmental Response Committee (PRPs), the recommended alternative
has been modified as follows: 1) landfill cap "regrading", is stated instead of
"upgrading", 2) Regrading of the cap will prevent additional infiltration of
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water due to landfill cap undulation - which will meet State and Federal
Requirements without cap "upgrading", and 3) three options are presented for
disposal of submerged pond de:~ris which change the cost range and estimates for
Alternative 3 (Modified).
14.2
Backqround of Community Involvement and Concerns
The community of Lewisburg has had relatively few comments since the Lewisburg
Dump Site came under scrutiny in the early 1970's by the State of Tennessee
Department of Health and the Environment. Of the two Public Meetings held at the
City of Lewisburg (August 11, 1988 and July 25, 1990), the meeting on July 25,
1990 recorded the most response to the recent activities of the Superfund
process. By far, the majority of the response at this Public Meeting was by
potentially responsible parties (PRPs). Also to respond (with the exception of
the Public Meeting) was the Lewisburg Environmental Response Committee (LERC)
which was formed in May 1987 to negotiate with EPA for undertaking a Remedial
Investigation and Feasibility Study (RI/FS). A complete summary of these
responses is contained in section 14.3. .
14.3
Summary of Maior Questions and Comments Durinq the Public Meetinq and
the Public Comment Period, and EPAs Responses to These Questions
This section summarizes major questions and comments that the EPA received during
the public meeting and during the public comment period. The vast majority of
questions were recorded during the Public Meeting and are contained in their
entirety in the Meeting Minutes/Official Transcript (Appendix D).
Comment:
Response:
Comment:
I
A PRP wanted to know how the EPA goes about identifying"PRPs (i.e.-
what is the process?)
Identifying PRPs is a continuous process that can vary from site to
site. A potentially responsible party (PRP) under the CERCLA
statute is anyone who owned or operated the Site, as well as anyone
who generated or transported waste disposed of at the Site. An
attempt is made to gather whatever information that can be
obtained. In this case, the State sent out some questionnaires on
potential generators at the Site. The EPA reviewed the information
and sent out information request letters asking the PRPs if they
have any records of waste disposal at the Site.
A PRP questioned if an individual or company receives a PRP letter,
and they supply information to indicate that there is no way
possible that they could have been a RPi what's the process of not
being a PRP anymore?
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Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
EPA compiles the list of PRPS and if your name remains on the list,
we feel that we have some evidence that makes you a PRP. If we do
not have enough evidence to eliminate a PRP from the list or if we
have not made the decision (at this time) for a variety of reasons,
the PRP remains on the list. All companies (PRPs) on the list have
received notice letters at this time to give PRPs a chance to
participate in the process.
A PRP was interested in knowing hypothetically, if they
receive correspondence from the EPA informing them that
eliminated as a PRP (would a letter be forthcoming?)
would
they were
It's is generally,
indicate that with
a PRP, then such a
not Agency policy, however, if circumstances
certainty that the individual or company is not
letter could be given.
A PRP indicated that if once an individual or company is a PRP,
then they may be a PRP until they are dead, and then maybe their
ancestors will still be PRPs.
If the potential liability remains, yes.
A PRP questioned the reasoning behind transporting the submerged
pond debris to a sanitary landfill when it could be buried at the
Site.
EPA stated that if it is more reasonable to bury it at the Site and
we can do so with the least possible complication, by the
regulations, then it is a viable option. It appears, however, that
hauling the material somewhere else seems at this point to be the
least disruptive option.
A PRP questioned the EPAs justification for removing anything since
they believe it has not been determined that there is any hazard to
the health and the environment. They want to know what is the
necessity of removing anything if the levels of contaminant aren't
such that they pose a problem?
The levels of contamination are not, across the board,
significantly high, but we do have two contaminants of concern out
there, and one of them is copper, and the toxicity of copper is
high. And we do have copper in the pond. The second contaminant
of concern is DEHP, and it is found at the Site frequently. It is
a component used in plastics and has reasonably low levels of
maximum contaminant levels for drinking water standards. DEHP is
found in the test-pits (38,000 ppb), monitoring wells, and pond
sediments. It is important that we implement the
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Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
site access restrictions, and do remove the materials out of that
pond. If we are going to monitor the Site and try to insure that
it is cleaned up we need to get those two contaminants of concern
down to reasonable levels (must be evaluated over a long period of
time). EPA is concerned that the Site will continue to further
deteriorate, especially the landfill cap. Presently the cap is
penetrated by some small trees and various other plants, and it is
undulating so that water can actually pond on the top, and it is
.getting into the landfill, to cause further deterioration. That is
a concern at this time. The Site may not be the worst in the
nation, but it certainly has the potenti~l to continue to
deteriorate, and the EPA wants to try to eliminate that
possibility.
A PRP wonder€d if there was any record of any health problems
within the community, because of the Site.
ATSDR conducts an independent evaluation of basically, the RI data
to see if, based on the data, there warrants a full-blown health
study or assessment. They have reviewed the data and believe that
the data presented indicates that this Site does not require that
kind of in-depth study.
A PRP was wondering where the DEHP could have come from?
The EP~ does not have a definite, pin-point source for DEHP in the
Lewisburg Dump Site at this point. However, DEHP can be leached
out of commonly found household waste such as plastic containers,
etc.
A PRP mentioned that they were as concerned about
and people's health as anyone else. They did not
they need to spend a million dollars to take care
based on the information that has been presented.
the environment
feel t.hat the
of this site,
The EPA struggles with these kind of concerns frequently. The EPA
recognizes that the Site is not the worst in the country, however,
we do recognize several concerns at the Site that do need to be
addressed. We are being conservative. We believe that it is
better to be cautious and go ahead and stabilize the Site and do
the remedial steps now, rather than take that chance that it mig~~
get worse.
A PRP commented that Elmer Akin (EPA - Risk Assessment) mentionec
the plastic found is in normal household disposal. It looks like
every resident of Lewisburg should be on the PRP list because we
all put plastic in there, instead of just a few selected compan~e~
like myself and a few others in here.
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Response:
Comment:
Response:
Comment:
Response:
Comment:
The City of Lewisburg is a potentially responsible party, as being
the owner-operator of the Site. So, in a way, everybody in
Lewisburg may pay through the City's responsibilities as being the
owner and operator of the Site.
A citizen wanted to know what the applicable and relevant
requirements were for the Site. In some of the alternatives, it
was mentioned that some of the alternatives do not meet those
(~~s) and some do. Does it relate to having to put a particular
type of clay cap on the Site that meets the ARAR or a bunch of
ARARs, what are they?
ARARs are some fairly standard Federal and State requirements. One
requirement that was mentioned several times was the State landfill
requirements for the closure of sanitary landfills. This landfill
was closed a number of years ago and there were standards in place
for closure of landfills at that time (meaning the landfill was to
meet the State and Federal requirements at the time it was
closed). We are saying that we need to review the present
condition of that cap and see what measures need to be upgraded, if
any, to bring that cap back into standards with the State
landfill. We have also identified some water quality criteria fo~
copper, as a State ARAR, and that is basically a standard that is
set for fresh water aquatic life. It is a standard that EPA thinks
is protective of the fish and ecosystems. We have also looked at
the ARARs for groundwater, specifically the maximum contaminant
limits. The Clean Water Act also has requirements (for dredging
and filling the waters of the United States) that must be met
concerning the quarry pond.
!;
A PRP stated, "It would seem simpler
clean water in that pond, or keeping
lid on it, and it's gone. You don't
the fish in another pond".
to me, rather than worry about
it clean, to fill it up, put a
have to worry about it. Put
Some people or some commentors have already basically suggested
that. And it warrants looking into. closing or sealing the pond
certainly is a possibility. However, it may add more cost. If you
actually want to relocate the fish, fill up that two-a~re hole, and
fill it in, it will get fairly expensive. The existing aquatic
community appears healthy and with an established ecosystem, it may
actually be beneficial to leave that (the pond) in place, and work
to help prevent any type of changes out at the Site that could
result in changes in the environment.
A citizen wondered if the intermittent stream that runs above the
quarry pond can flush the pollutants out of the pond during wet
weather.
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Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
. Response:
It is difficult to quantify whether that would be enough water to
actually flush the pond. The most significant source of water for
the pond appears to be the groundwater, not the intermittent
stream (because a 24 hour pump test conducted during dry conditions
recorded not change in water level for the pond).
A citizen wanted to know if it was safe to drink the water in the
surrounding area (within approximately 200 yards; the citizen
indicated that there were good places at some sinkholes to drink
the water).
There is quite a lot of garbage in the sinkholes near the Site
(given the amount of garbage in the sinkholes, it would not be
to drink from them). The study does not look at bacterial
contamination of the wells so we really can not call the water
even if we found no contaminants.
good
safe
A citizen inquired about contamination or groundwater flow to the
west or east of the Site.
It appears that from the previous remedial investigations that have
been conducted that the water flows to the east or southeast. Then
the water takes a local deviation once it gets out of the pond,
possibly to the southeast. We do not know exactly, because the
aquifer is very complex. One thing we know for sure is that the
water eventually heads toward Big Rock Creek. We believe the
overall direction of groundwater flow is to the east-southeast.
According to the EPA and the State of Tennessee, this is one of the
2Ca most dangerous sites in the Country, right?
No.
There are currently over 1000 sites on the NPL.
A citizen inquired - if we had these test results in 1986, would
the Site have been placed on the NPL?
That is a question that really does not have an answer. Sites are
placed on the NPL uniformly, without this kind of information.
That is the whole reason for putting them on, so that you will find
out which sites are the big problem, which sites are a little
problem, and which sites are no problem.
The PRP contractor wanted to know how the list of significant
contaminants was determined?
The EPA thought it was important for the
range of compounds identified in several
"significant contaminants" has different
public to know the whole
studies. The term,
applications in the
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Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Proposed Plan as compared to the Risk Assessment.
A PRP wanted to know what the levels of DEHP and copper are in
other landfills. They believe that these are strictly household
by-products and think we should not be spending 1-2 million dollars
to cleanup household waste.
We have identified hazardous substances at the Site. This combined
with the complexity of the Karst aquifer and the receptors is why
Lewisburg was identified as a Site early on. We 'can not say
anything about other sites in comparison to Lewisburg since each
been evaluated independently.
A PRP asked why Lewisburg has to spend the money to cleanup their
Site while other towns with a sanitary landfill do not?
The State of Tennessee recommended the Lewisburg Dump for the NPL.
These other towns may eventually have their sites listed if
conditions warrant it.
A citizen wonders why we need to clean the Site up if there appears
to be no damage to the ecosystem and we do not have a degree of a
situation that would warrant further remedial action?
There is enough information concerning the levels of contamination
at the Site to warrant remedial activities. This plan we have put
forth to you tonight is based on all of the input we have
received. We believe that the Plan is adequate, conservative, and
deals with the problems at the Site.
Has a dye-test been run to tell whether the pond is leaking or not?
There has not been a dye-tracer done.
A citizen mentioned that they would not like to see Alternative 1
selected (No Action). They would like to have an option between
one and three, with monitoring and institutional controls, but
possibly with less emphasis on the cap and submerged debris
removal.
One of the reasons that we are choosing Alternative 3 or proposing
Alternative 3, is again, to meet State and Federal requirements.
There is some contamination in the pond, now, that is above some of
the State and Federal statutes. There are hazardous constituents
in the landfill, and there is a cap with, right now, 13 test-pits
that have been dug into it, and there is only PVC or a thin layer
c~vering the cap. We also need to insure that the cap drains
properly, and we must remove the trees that may penetrate the
cap.
-100-
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14.3.1
Comment:
Response:
Comment:
Response:
Additional comments on behalf of the Lewisburq Environmental Response
Committee CLERC):
Upgrading the entire landfill cap to meet the current State of
Tennessee landfill cap requirements will be both expensive and
potentially harmful to the environment. Th~ estimated cost for
this effort is approximately $400,000. Extensive cap upgrading
efforts could have a deleterious impact on the delicate biological
system that exists within the landfill. The alteration of this
system could result in the sudden development of a harmful leachate
plume which would be very difficult to contain due to the
hydrologic setting of the Site and the location within the
fractured limestone quarry.
The selected remedy for the Site [Alternative 3 (modified)]
proposes to "regrade", not to "upgrade" the landfill cap. The cap
is in reasonably good condition considering it is almost 12 years
old. However, in order to prevent additional cap deterioration as
well as additional infiltration of water, the vegetation (including
small trees) will have to be removed and the presently undulating
cap regraded. This will be a reasonably conservative and less
costly approach that will meet the State and Federal requirements
at the time of landfill closure. The before mentioned problems
with the cap are allowing water to infiltrate at increasing rates
which potentially could create a harmful leachate plume. We feel
that this approach to cap remediation will serve to prevent a
leachate plume from developing.
The August 8, 1990 Monthly Report showed that the copper level in
the pond (18.4 ppb) is below the aquatic-based cleanup level (19.7
ppb). Since the copper level in the pond is not as great of
concern as it originally appeared to be, it seems appropriate to
reduce the effort associated with debris removal from the pond.
The water hardness sample was obtained without EPA notification
(EPA notification is required by the Administrative Order) or
oversight in July (1990) and the resulting analysis (in a report
dated August 8, 1990) revealed a water hardness of 182 mg/l Ca
C03. In the RI a value of 100 mg/l caco3 was assumed to
calculate the aquatic based pond water cleanup levels for copper,
lead, nickel and zinc. The different hardness values can be
attributed to a variety of factors which inc~ude: seasonal
fluctuation in rainfall amounts and frequency, the ability and
length of time for the quarry pond to equilibrate after rainfall
events, size of the pond, flow into and out of the pond, geologic
factors, and others. Given that only one variable has been
analyzed, it appears that the resulting changes in ~he pond water
-101-
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cleanup values, are inconclusive. The very small sampling effort
can not be considered since it has not been determined whether or
not the sample is representative of the average hardness value for
the quarry pond. Thus, the original values presented in the RI
will be utilized.
Another reason for the Agency to rely on the approved RI data is
that the data acquisition performed in July 1990 was done without
EPA notification or oversight and can not be considered as part of
the RI data or results.
Even if the new data was acceptable, the copper values are still
not considered to be in the acceptable risk range and the cleanup
level in the RI (12 ppb) will be utilized. Since copper in aquatic
systems can be highly toxic, it will be necessary to reduce the
amount of this metal in the pond. Modifications to Alternative 3
most likely will not include any significant reduction of submerged
pond debris removal since this is not only one of the likely
sources of contamination (besides the landfill constituents) but
also the most obvious.
-102-
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14.4
Written Comments received Durina the Public Comment Period and EPAs
Responses to These Comments
This section contains a summary of the one letter received by EPA containing
written comments, as well as EPAs response letter.
Summary:
A citizen asks, why after all of the~e years do you go back to the
people who. used it (the landfill, with permission) and make them
clean it up? If anyone should clean it up it should be the City of
Lewisburg. Where was the Environmental Protection Agency when this
dump started?
Response:
Letter dated August 31, 1990 is on following page.
-103-
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
August 31, 1990
Mr. Jimmy Hobby
P.O. Box 1751
Lewisburg, TN 37019
RE: COM¥~NTS SUBMITTED TO THE ENVIRONMENTAL PROTECTION AGENCY
CONCERNING THE LEWISBURG DUMP SUPERFUND SITE, LEWISBURG,
TENNESSEE
Dear Mr. Hobby:
Thank you for sending your comments concerning the Lewisburg Dump
Superfund Site in Lewisburg, Tennessee. In your letter you were
wondering why after all of these years, are we making the people who
used the dump (with permission) clean it up? The dump began'
operation approximately in the mid-1960's and just a few years after
it opened, the State of Tennessee investigated the Site and
determined that it was not a suitable place for a landfill. It took
the City of Lewisburg from the early 1970's tq 1979 to finally close
the landfill. Even after it was closed, there was unauthorized
(illegal) dumping since there was little stopping anyone that wished
to dump materials at that location. We want the potentially
responsible parties (PRPs) to cleanup the site. However, the City of
Lewisburg as one of the PRPs also represents the people of Lewisburg
which means that the local citizens will also be saddled with a
portion of the cleanup responsibilities at the Site.
You had also mentioned that if anyone should clean it up, it should
be the City of Lewisburg. As a matter of fact, the City of Lewisburg
as the present owner (of a majority of the property) is responsible
for their share of the cleanup.
.~
In reference to your third question (Where was the EPA when this dump
started?), we started to take action after the Site was referred to
us by the State of Tennessee. The State began investigating the Site
in the early 1970's and we reviewed the information when the State
submitted it to us, then the Site was listed on the National
Priorities List (NPL) in the early 1980'8. It can be a long
to investigate and take action on these Superfund sites. We
that our involvement with the State concerning the Lewisburg
process
feel
Dump
Printed Of" ;;.~ . r." .,-
-------
Site has been effective, and we feel the proper steps are being taken
to clean it up.
Thank you again for your response.
Sincerely,
D~~ A. /3~
Douglas A. Bell, P.G.
Remedial Project Manager
Kentucky/Tennessee Remedial Section
North Superfund Remedial Branch
Waste Management Division
-------
APPENDIX A
Copy of the Proposed Plan Presented at the Public Meeting:
July 24, 1990, Lewisburg, Tennessee
-------
SUPERFUND
u.S. ENVIRONMENTAL PROTECTION AGENCY
PROPOSED PLAN PACT SHEET
-------------------------------------
LEWISBURG DUMP SITE
LEWIS BURG, TENNESSEE
-------------------------
July 1990
----------------------------------------------------------------
INTRODUCTION
The Proposed Plan is issued to describe the alternatives that the
U.S. Environmental Protection Agency (EPA) has considered for the
cleanup of the Lewisburg Dump National Priorities List (NPL) Site
(the site) located in Lewisburg, Tennessee (see figure 1). This
plan presents an evaluation of cleanup alternatives, including the
alternatives preferred by the EPA.The alternatives summarized
are described in greater detail in the Remedial Investigation (RI)
and Feasibility Study (FS) Reports which are available, with the
site's Administrative Record, at the information repository
located at the Marshall County Memorial Library, 310 Farmington
Pike, Lewisburg, Tennessee. .
The City of Lewisburg and other potentially responsible parties
(PRPs) have formed the Lewisburg Environmental Response Committee
(LERC) to conduct the remedial investigation/feasibility report
(RI/FS) for the site. LERC carried out the investigation work
with the direct oversight of EPA and under terms of an
Administrative Order on Consent with EPA which was signed on
December 31, 1987.
The alternatives EPA prefers represent a preliminary decision,
subject to a public comment period. Section 117(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, decribes the remedial alternatives, provides the rationale
for identification of the.preferred alternatives, and outlines t~\!
role of the public in helping EPA 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 resu~.
in selection of alternatives other than the ones preferred by E;.!
for the site.
-------
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Lewisburg
Dump Site
Figure 1
-------
SITE BACKGROUND
The Lewisburg Dump Superfund Site (Figure 2) occupies an
approxLmately twenty (20) acres on Rock Crusher Road. Within the
site resides an abandoned six (6) acre limestone quarry that
contains a two (2) acre pond. Approx~ately four (4) of the
twenty (20) acres (the western portion of the quarry) were used
for the landfill operation which ceased in 1979. The site is
located among farms and pastureland, one-half mile north of
Lewisburg, Tennessee. Ten homes are located within a one-half
mile radius of the site. Many people in the area have public
water, but residents to the immediate west of the site use private
wells.
The Lewisburg Dump began operations in the late 1950's at the
inactive limestone quarry site. The landfill was owned and
operated by the City of Lewisburg. The dump was open to all
residential and industrial dumpers who wished to use it, and city
records note that several surrounding communities may have hauled
their wastes to Lewisburg.
In the early 1970's, the State of Tennessee. made its solid waste
management regulations more stringent. Representatives of the
Tennessee Department of Public Health (TDPH) visited the Lewisbur~
Dump Site in July, 1973 to prepare a geologic review and obtain
water samples. Study findings indicated that the old quarry was
an unfit location for a sanitary landfill.
The following month, another representative of TDPH, inspected the
site to verify reports of open burning at the dump. This burning
was in violation of the State solid waste laws as well as the
Tennessee Air Pollution Control Regulation. To comply with the
laws, the city subsequently proposed to TDPH a plan to build and
operate a solid waste incinerator on a permitted. site. The
proposal included plans for interim maintenance and final closure
of the dump.
Late in the summer of 1977, the City of Lewisburg reported having
difficulties in locating a suitable site for a new incinerator and
landfill. Shortly thereafter, the city began preliminary closure
activities for the Lewisburg Dump Site by applying a soil cover to
the waste. In November, the State of Tennessee filed a motion in
the Marshall County Chancery Court requesting the court to order
the city to comply with closure requirements. From mid-1978 to
mid-1979 the city continued its attempt to find an acceptable
landfill location and the burning was discontinued. The dump was
finally closed in 1979.
-3-
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PRELIMINARY EPA INVOLVEMENT
EPA conducted a hazardous waste site inspection in March 1982.
The resulting report indicates the presence of organic and
inorganic compounds, including lead, toluene, PCBs, chlordane, and
phenol. EPA added the Lewisburg Dump to the Superfund National
priorities List of hazardous waste sites, issued in December 1982.
In the fall of 1985, EPA conducted a search for all companies,
agencies, or individuals who were potentially responsible for
accumulation of hazardous waste at the site. The types of waste
deposited at the site included: sawdust, colored and black pencil
cores, cosmetic powders, shoe linings, adhesives, paint stripper,
empty five-gallon pails coated with yellow lacquer, and metal
cuttings.
EPA notified Potentially Responsible Parties (PRPs) in a letter
dated January 28, 1986, of conditions at Lewisburg Dump, and of
EPA's plans for an investigation of the contamination. In May
1987, the City of Lewisburg and local industry formed the
Lewisburg Environmental Response Committee (LERC) to negotiate
with EPA for undertaking a Remedial Investigation and Feasibility
Study (RIfFS). Phase I activities of the Remedial Investigation
began in October of 1988 and the supplemental RI and FS Reports
were completed in June and July of 1990, respectively.
The finding of the supplemental RI confirmed the presence of
contaminants at the site, in the shallow groundwater aquifer
beneath the site, and in the abandoned quarry pond. The most
commonly detected or significant contaminants found are listed
below: .
ORGANIC CONTAMINANTS
Methylene Chloride
Bis(2-ethylhexyl)Phthalate,
4-Methyl-2-Pentanone
2-butanone
Carbon Disulfide
Toluene
(DEHP)
Chlordane
Ethylbenzene
Xylene
PCB 1260
INORGANIC CONTAMINANTS
Copper
Aluminum
Iron
Manganese
Barium
Zinc
Chromium
Arsenic
Lead
Strontium
Mercury
-5-
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SCOPE AND ROLE OF RESPONSE ACTION
Material contained in the dump, surficial debris and waste,
contamina~ed groundwater, debris accumulations in the quarry pond,
surficial pond water, and contaminated pond sediments are under
consideration for cleanup. A remedy for the site and underlying
surficial groundwater is proposed to protect public health and the
environment by controlling exposure to contaminated materials and
controlling migration of contaminants into surrounding soils,
sediments, and surface water. Several nearby water wells (one as
close as 200 feet) could potentially be affected by material at
the dump site. Factors that may determine the distribution of
contamination are: the 1) the amount of contaminants contained in
the dump, and 2) the complex geology (Karst terrain that exhibits
numerous sink holes) of the region, and 3) the hydrogeology of
the limestone aquifers that underly the site. These three
variables were analyzed to determine the general flow directions
of. groundwater from the site, and potential receptors. Results of
the Remedial Investigation indicate that groundwaters originating
from the site most likely flow towards the east-southeast adjacent
to the site and eventually eastward into Big Rock Creek
approximately 2000 feet from the site. A remedy for the cleanup
of the Lewisburg Dump Site is proposed to protect public health
and the environment by controlling various organic and inorganic
contamination. The preferred alternative will specifically:
address and eliminate the ingestion and accumulation of
contaminants by flora and fauna, (especially aquatic life in the
quarry pond) through removal of all surficial and pond debris. The
EPA selected alternative will also reduce the threat of dermal
contact with contaminants, restore and upgrade the landfill cap,
and will limit access to the site by fencing the entire property,
and finally, will prevent future use of the property by. imposing
deed restrictions.
The remedial alternatives under consideration are presented
below. 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 used to decide the site remedies, is
available for public review at the site information repository a:
the previously listed address.
£UMMARY OF SITE RISKS
During the supplemental RI/FS, an analysis was conducted to
estimate the health and/or environmental problems that could
result if the contamination at the site was not remediated.
T~.. ;
.~
-6-
-------
analysis, commonly referred to as a baseline risk assessment,
focused on the health effects that could result from long-term
direct exposure to high concentrations of the contaminants as a
result of dermal contact with the soil or surface water.
Information included in the RIfFS indicates that although
contamination levels are not high, there are a wide variety of
organic and inorganic contaminants which have the potential to
become exposed by: 1) further landfill cap deterioration, and 2)
by open access to the Site and disturbance of landfill
constituents. Therefore, the potential exists for the landfill
materials to become exposed which will allow further contamination
at the Site.
Risk of long-term exposure to contaminants from the site were
calculated based on major contaminants detected at the site which
included potential human carcinogens. Carcinogenic risks are
expressed as the probability of additional cancer risks resulting
from a lifetime of exposure. For non-carcinogens, the Agency
evaluates the risk by determining a Hazard Index (HI). The HI is
a number that reflects 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 for a lifetime i.e., the
reference dose (RfD). A HI greater than 1.0 indicates that
exposure exceeds the protective level. These estimated risk
calculations were based on present conditions at the site
including the existing cap and no major increases of contaminants
in the shallow aquifer which discharges into Big Rock Creek.
The HI calculated for exposure to non-carcinogens in the soil and
surface waters at the site were all below 1.0 except for copper
for a variety of aquatic life in the pond. The fresh water
Crustacean Daphnia used as an indicator identified copper
contamination in the pond has a Hazard Index of 4.7. Since copper
in aquatic systems can be highly toxic, it will be necessary to
reduce the amount of this metal in the pond.
In summary, environmental information derived from the RIfFS
. indicate that there is the potential for additional groundwater
contamination and leachate generation if the Site does not
restrict access through institutional controls and deed
restrictions. Site conditions may futher deteriorate if the
surface and submerged garbage in and around the quarry pond is not
removed, and the landfill cap is not upgraded to prevent
infiltration of water.
~-
-7-
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SUMMARY OF ALTERNATIVES
LANDFILL WASTES AND SHALLOW GROUNDWATER
The following summary lists the five (5) remedial alternatives
under consideration for the landfill wastes and shallow
groundwater at the Lewisburg Dump Site. The FS Report contains a
more detailed evaluation of each alternative.
1)
2 )
3 )
No Action;
Deed Restrictions and Site Access Restriction (Fencing);
Institutional Controls plus: removal of surface debris,
landfill cap upgrading, long term well monitoring and
analysis;
5)
The above actions plus complete removal and treatment of
material from the site and isolation of pond sediments
Complete removal of landfill material, pond sediments and
submerged debris.
4 )
All but one (Alternative 1) of these alternatives involve
restrictions on land and well use at the site, upkeep of the fence
and property, and monitoring to assess the effectiveness of the
remedy.
. "!
ALTERNATIVE 1: NO ACTION
Present Worth (PW) Cost: 133,082 (Amount presented is for well
monitoring only. A dye tracer study for $60,000 is
included as part of well monitoring since the most
effective sampling program can be efficiently obtained with
the assistance of this method.
Years to Implement: ° (uP to 5 years if monitoring is elected).
CERCLA requires that the "No Action" alternative be considered at
every site. This alternative must be considered since: 1) it may
be more harmful to human health and the environment to disturb
contamination at some sites, and 2) it may be the only low risk,
cost effective alternative. Under this alternative, no soil,
sediment, groundwater or debris cleanup, containment or treatment
would take place. The only reduction of contaminant levels would
occur via natural processes such as dispersion or attenuation.
The only costs incurred would be for monitoring the site.
-8-
-------
1--- --
ALTERNATIVE 2: DEED RESTRICTIONS AND SITE ACCESS RESTRICTIONS
(FENCING)
Present worth Cost: $185,000
PW Capital Cost: $127,000
PW 0 & M Cost: $57,000
- Years to Implement: 0.3 (uP to
5 years if monitoring is elected)
This alternative will insure that site access is limited through
installation of a security fence while also establishing controls
that ensure proper maintenance of the site through deed
restrictions. This alternative does not improve residual risks
above baseline conditions. Any reductions in t~xicity, mobility,
and volume are the same as those discussed for alternative 1. It.
is assumed that natural processes would reduce most well
established contaminants to safe levels. Immediate or near-term
compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) or Guidance To Be Considered (TBCs) cannot be
achieved with this alternative.
ALTERNATIVE 3: INSTITUTIONAL CONTROLS PLUS: REMOVAL OF SURFACE
DEBRIS, LANDFILL CAP UPGRADING, LONG-TERM WELL MONITORING AND
ANALYSIS.
Present Worth Cost: $815,000 - $870,000
PW Capital Cost: $545,000 - $571,000
PW 0 & M Cost: $270,000
Years to Implement: 0.2 (to complete remedial action)
5 years for well monitoring
This alternative retains the institutional controls discussed for
Alternative 2 and adds several additional remedial measures that
are designed to reduce potential exposures or release of
contaminants from the site. Remedial measures include the removal
of submerged pond debris and site surface debris, replacement of
the plastic test pit caps with clay and soil material (2.5 feet of
clay and 12 inches of soil), and the upgrading of the cap to meet
all state standards for closure of sanitary landfills. . Submerged
debris will be moved from the pond. Recyclable material will be
separated out and nonrecyclable material will be disposed in an
approved and permitted sanitary landfill. This may include the
adjition of extra clay or soil, proper grading and surface
.drainage controls, and the establishment of adequate vegetative
cover. In the event that a suitable location cannot be found for
disposal of this material, it will be disposed of on-site before
restoration of the landfill cap takes place. In addition,
monitoring efforts and analysis are included to measure the
-9-
-------
effectiveness of the remedial activities. A dye tracer study or
other acceptable method will be used to determine the most
suitable groundwater sampling locations for long-term monitoring.
This will be implemented during the Remedial Design Phase of the
Superfund Program (Immediately follows the RIfFS). Monitoring
efforts will include the collection of surface water samples from
the pond and groundwater samples from specific on-site and
off-site locations. This alternative meets all NCP (National
Contingency Plan) requirements and will be in compliance with all
ARARs. Unlike Alternatives 1 & 2 (which are unable to achieve
water quality-based ARARs) this alternative actively isolates the
major contributing sources which will allow compliance with
environmental standards.
ALTERNATIVE 4: INSTITUTIONAL CONTROLS PLUS: REMOVAL AND TREATMENT
OF MATERIAL FROM THE SITE AND ISOLATION OF POND SEDIMENTS
Present Worth Cost: $47,000,000 - $100,000,000
PW Capital Cost: $43,000,000 - $100,000,000
PW 0& M Cost: $270,000
Years to Implement: 2 for construction activities
5 years (total) for well monitoring
This alternative involves the removal, treatment, and disposal of
all material in the landfill and isolation of the pond sediments
from the aquatic community. Remedial actions associated with
Alternative 3 are included with the exception of test pit cap
replacements. These actions include institutional controls,
submerged and surface debris removal from the quarry pond, and
monitoring and analysis of the groundwater. Extraction of the
landfill material will require approximately 9000 truckloads of
material to be shipped off-site. These actions will increase
potential human and environmental exposures to contaminants.
Increased exposure of contaminants or excavation accidents will
also result in increased leachate generation that may adversely
affect human and environmental' receptors in the vicinity of these
activities. Landfill material extraction satisfies the CERCLA
statutory preference as a principle element of the remedy.
However, despite the long-term effectiveness and permanence of
this alternative, other serious short-term impacts in addition to
ones previously described are present. Isolation of the existing
pond sediments from the aquatic wildlife requires addition of new
substrate consisting of uncontaminated soil. Addition of the
substrate material will potentially create a thick cloud of
suspended material that will reach all areas of the pond and
seriously or fatally impact many aquatic organisms. Application of
the
-10-
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isolating soil layer in the pond may violate Section 404 of the
CWA (ARAR) that regulates the discharge of fill into waters of the
United States.
.ALTERNATIVE 5: COMPLETE REMOVAL OF LANDFILL MATERIAL. POND
SEDIMENTS. AND SURFACE AND SUBMERGED DEBRIS
Present Worth Cost: $47,000,000 - $100,000,000
PW Capital Cost: $47,000,000 - $100,000,000
PW 0 & M Cost: $23,000
Years to Implement: 2 for Construction Activities
5 for total well monitoring
This alternative offers a long-term effective and permanent
remedy. All site-related contaminants will be removed. The
security fence previously discussed will be installed as part of
this remedy. The purpose of the fence will be to prevent junkyard
activities from impacting the Site and to discourage uncontrolled
dumping. This alternative achieves the CERCLA statutory
preference for removal and/or treatment as a principle element of
the remedy. This is accomplished by extracting recyclables where
possible and treating contaminants as necessary. The short-term
effectiveness and impacts of this remedy can be considered
identical to that discussed for Alternative 4. The short-term
impacts on the local aquatic community in the pond could be
devastating. ~n addition, short-term Lrnpacts associated with
added leachate generation during landfill excavation activities
and remedial action related accidents could also prove
significant. As previously stated in Alternative 4, addition of
the isolating soil layer in the pond may violate Section 404 of
the CWA (ARAR)..
EVALUATION OF ALTERNATIVES
The preferred alternative for the remediation of the Lewisburg
Dump Site is Alternative 3. This alternative appears to represen~
the overall best remedy for the Site. While Alternatives 1 & 2 do
not the achieve the preference (NCP Requirement) for reduction o~
toxicity, mObility, or volume through treatment, Alternative 3
does meet this requirement. Alternative 3 meets the objectives
to protect the health and environment and maintains significantly
lower costs than either of the two remaining alternatives that
also meet the requirements (Alternatives 4 and 5). Alternative]
removes a suspected major source of contaminants, associated wit~
the aquatic wildlife and human health risks posed by the Site.
In addition, this alternative allows for a readily implemented
-11-
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long-term management plan that limits the possibility of future
impacts from the Site (i.e., upgrading the existing cap, removal
of metals and garbage from the pond, monitoring program).
ANALYSIS
Overall Protection of Human Health and the Environment
All the alternatives considered above with the exception of the No
Action Alternative (Alternative 1) and Alternative 2 would be
protective of human health and the environment. Alternatives 1
and 2 are.not protective because they allow bioaccumulation of
contaminants by wildlife at the Site and in the quarry pond.
. Also, failure to maintain and upgrade the landfill cap may result
in migration of unacceptable levels of contaminants from the
quarry pond eventually into Big Rock Creek. Other possible
consequences are human or animal exposure to contaminants through
soil or sediment contact. Alternative 3 would prevent human or
animal exposure to on-site contaminants through the implementation
of institutional controls,.landfill cap .restorations, removal of .
surface debris and submerged debris in the quarry pond, and well
monitoring and site maintenance. Alternatives 4 and 5 would also
be protective of human health and the environment by removing all
of the Site contaminants but have serious short-term effectiveness
and implementability problems.
1-
Compliance with Applicable or Relevant and Appropriate
Recruirements
Alternative 1 is not in full compliance with ARARs for the closure
of sanitary landfills and would allow for possible direct contact
or exposure to hazardous substances. Alternative 2 while limiting
possible direct contact or exposure, does not provide a sufficient
reduction of contaminants to meet all ARARs. Alternative 3 is in
full compliance with all ARARs. Alternatives 4 and 5 will meet
all ARARs with the possible exception of the Clean Water Act (CWA)
provisions concerning' fill operations in U.S. waters. Pond
isolation filling activities might require a waiver based on
guidelines in this regulation.
Reduction of Toxic~tv. Mobilitv or Volume
Alternatives 1,2 and 3 do not involve the treatment of the
landfilled wastes, there will be no direct reduction in the
toxicity, mobility, or volume of landfill contaminants.
Indirectly, Alternative 3 will reduce the mobility of landfill
-12-
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contaminants by eliminating excessive infiltration and erosion
problems. Alternatives 4 and 5 do involve removal and treatment
(solidification and associated treatment/dewatering processes) of
contaminated materials, soils and/or pond sediment, and would
provide a significant reduction first by complete removal of
contaminants, and second, by the reduction of toxicity and
mobility through the treatment processes described above.
Lona-Term Effectiveness
All of the alternatives except for the No Action Alternative and
Alternative 2 provide long-term effectiveness and permanence. The
No Action Alternative assumes that baseline conditions will not
change (no controls will be in place to prevent changes) even
though leachate with low levels of contamination is present in the
landfill area. Alternative 2 establishes controls required to
prevent some changes from baseline using deed restrictions and a
security fence. No cap restoration is recommended on
Alternative 2 leaving the possibility open for further landfill
cap deterioration. This could allow more infiltration of water
into the landfill resulting in increased leachate formation.
Alternative 3 removes a suspected major contributor of
contamination in the pond and groundwater (submerged pond debris)
and implements deed restrictions and eliminates site access to
maintain improvements. The long term effectiveness and permanence
would be sufficient to protect human health and the environment.
This is similar to Alternative 4 except that the effectiveness and
permanence increases due to additional removal. Alternative 5
will remove all on-site contamination and will provide the
greatest long-term effectiveness and permanence.
Short-Term Effectiveness
All of the alternatives with the exception of the No Action
Alternative would immediately eliminate the two exposure pathways:
ingestion of surface water and ingestion of pond fish. Alternative
2 will offer no changes in risks from baseline conditions,
therefore, unacceptable risks (such as continued leaching of
metals into the pond, increasing infiltration through the landfill
cap and site access) will still exist. Alternative 3 will have
reasonable short-term effectiveness concerning the quarry pond
(removal of submerged debris), upgrading of the deteriorating
landfill cap, and the previously mentioned exposure pathway
eliminations. Alternative 4 will result in significant risk
associated in leachate generation, remedial worker exposures and
accidents, traffic accidents, and sediment suspension in the
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aquatic environment. Alternative 5 will be identical in this
~espect to Alternative 4 except, pond sedLment will be removed
instead of being covered. Short-term consequences for
~lternatives 4 and 5 may be catastrophic for the aquatic community
)f the quarry pond and have significant risks in the short-term.
[mplementabilitv
rhe Lmplementability of an alternative is based on technical
Eeasibility, administrative feasibility and availability of
5ervices and materials. All of the Alternatives are readily
Lmplementable. Alternatives 1 and 2 that consist of no action or
~inor application of institutional controls will not have any
Lmplementation problems. For Alternatives 3,4, and 5 there will
)e little or no Lmplementation difficulties since only standard
:onstruction techniques will be utilized. The only item of
:oncern will be the resolution of Site ownership issues as needed
:or the construction of the security fence and the removal of
iebris from the pond.
:ost
~lternative 1 contains only the cost for well monitoring and has a
)resent worth value of $133,082. The present worth value
~epresents the total cost of the remediation expressed in today's
iollars. The estLmated present worth cost for Alternative 2 is
;176,000 - $193,000. Alternative 3 has a present worth cost of
;815,000 - $870,000 while Alternative 4 has a present worth cost
)f $43,000,000 - $ 100,000,000, and Alternative 5 at $47,000,000 -
;104,000,000. Alternatives 4 and 5 are not cost effective for
)resent site conditions since contaminant concentrations do not
Tarrant extensive excavations at the site, and little additional
>rotection would be achieved over Alternative, 3. .
;tate Acceptance
~he State of Tennessee has assisted EPA in the review of reports
lnd site evaluations. The State has reviewed and tentatively
19rees with the proposed remedy for the Lewisburg Dump Site and is
lwaiting public comment before final concurrence.
:ommunity Acceptance
:ommunity acceptance of the various alternatives will be evaluated
-14-
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1-
,
during the public comment period and will be described in the ROD'
for the site.
The Preferred Alternative
The preferred alternative - Alternative 3 - involves site access
restrictions by installation of a security fence, prohibition of
future site use by deed restrictions, r~places the test pit caps
with landfill cap material, removes surface and submerged debris
(in the quarry pond), and includes a dye tracer analysis or other
appropriate methods and well monitoring program. Alternative 3
can be readily implemented and has the lowest degree of short-term
impact that employs both institutional controls and actively
removes a likely source of contamination. This cost of
implementing this alternative ranges from $815,000 - $870,000
which is approxi~mately 56 times less than Alternatives 4 or 5 that
will have devestating short-term impacts for the site (especially
on the aquatic life in the pond). "
Summary of Statutory Findinas
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 would be protective of human hearth and the
environment, would satisfy the requirements of all ARARs, and
would be cost effective. "
THE COMMUNITY'S ROLE IN THE SELECTION PROCESS
EPA solicits input from the community on the cleanup methods
proposed for each Superfund response action. EPA has set a public
comment period from July 25 through August 23, 1990 to encourage
public participation in the selection process. The comment period
includes a public meeting at which EPA will present results of the
RIfFS Reports and the Proposed Plan, will answer questions, and
receive both oral and written comments. The public meeting is
scheduled for 7:30 pm, July 25, 1990, and will be held at the City
Administration Building, Ellington Parkway, Lewisburg, Tennessee.
Comments wil"l be swmnarized and responses provided in the
Responsiveness Swmnary section of the Record of Decision (ROD).
The ROD is the document that presents EPA's final selection for
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cleanup. The public can send written comments to or obtain
further information from:
Douglas A. Bell
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-7791
EPA is soliciting public comments about the most acceptable way to
clean up the Lewisburg Dump Site. The Proposed Plan and the RIfFS
Reports have been placed in the information repository and
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 Lewisburg Dump Site.
These documents are available for public review and copying at the
following location: .
Marshall County Memorial Library
310 Farmington Pike
Lewisburg, Tennessee 37091
(615) 359-3335
Contact: Charlene Nicholas
Copy Facilities Available: 10 cents letter, 15 cents
le<;al.
LIST OF CONTACTS
Douglas A. Bell
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
-16-
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1-
Robert Powell
Tennessee Department
Customs House
701 Broadway
Nashville, Tennessee
(615) 741-5940
of Health and Environment
37203
Ronnie Bowers .
Tennessee Department
Customs House.
701 Broadway
Nashville, Tennessee
(615) 741-5940
of Health and Environment
37203
GLOSSARY OF EVALUATION CRITERIA
Overall Protection of Human Health and the Environment:
addresses whether or not a remedy provides adequate protection and
desribes how risks are eliminated, reduced, or .controlled through
treatment, engineering controls, or institutioal controls.
Compliance with ARARs: addresses whether or not a remedy will
meet all of the appl~cable or relevant and appropriate
requirements of other environmental statutes and/or provide
grounds for invoking a waiver.
Long-term effectiveness and permanence: refers to the ability to
maintain reliable protection of human health and the environment
over time once cleanup goals have been met.
Reduction of toxicity, mobility, or volume: is the anticipated
performance of the treatment technologies a remedy may employ.
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 goals are achieve~.
1mplementability: is the technical and administrative.
feasibility of a remedy, including the availability of'materials
and services needed to implement the chosen solution.
Cost: includes capital and operation and maintenance costs.
State Acceptance: indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, opposes, or has
.no comments on the preferred alternative.
-17-
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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.
GLOSSARY
Administrative Record: A file which is maintained and contains
all information used by the lead agency to make its decision on
the selection of a response 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 a central location,
such as a regional EPA and/or state office.
Aquifer: Rock or sedLments in a formation which is saturated and
sufficiently permeable to transmit economic quantities of water to
wells and springs.
ARARs: Applicable or Relevant and Appropriate Requirements.
Refers to the Federal and State requirements that a remedy that
EPA selects must attain. These requirements may vary from site to
site.
Baseline Risk Assessment: An assessment which provides an
. evaluation of the potential threat to human health and the
environment in the absence of remedial action.
!
Bioaccumulated: The escalating accumulation of toxic materials
that Occurs within the food chain of an ecosystem.
Bis(2-ethylhexyl)phthalate (DEHP): A member of the phthalate
esters, a compound used in plastics.
Carcinogen: Any substance that produces cancer.
Chlordane: A chlorinated, highly poisonous, volatile oil used as
an insecticide.
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 that goes into a trust fund, commonly known
as Superfund, to investigate and cleanup abandoned or uncontrolled
hazardous waste sites. Under the program, EPA can either pay for
site cleanup when the responsible parties cannot be located or are
-18-
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unwilling or unable to perform the work, or take legal action to
force responsible parties to cleanup the site or reimburse EPA the
cost of the cleanup.
Groundwater: Underground water that fills pores in soils or
openings in rocks to the point of saturation. Unlike surface
water, groundwater cannot clean itself by exposure to sun or rapid
aeration. Groundwater is often used as a source of drinking water
via municipal or domestic wells.
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.
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
throught he Superfund Remedial Process, the file at the
information repository is continually updated.
Monitoring: The continued collection of information about the
environment that helps gauge the effectiveness of a cleanup
action.
Potential
a company
hazardous
for costs
laws.
Responsible Parties (PRPs): This may be an individual,
or a group of companies who may have contributed to the
conditions at a site. These parties may be held liable
of the remedial activities by the EPA through CERCLA
Preferred ~ternative: After evaluating and examining the
various remedial alternatives, EPA selects the best alternative
based on relevant cost and non-cost factors.
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.
Resource Conservation and Recovery Act (ReRA): A Federal law
that established a regulatory system to track hazardous substances
from the tLme of generation to disposal. The law requires safe
-19-
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and secure procedures to be used in treatin, transporting,
storing, and disposing of hazardous substances. RCRA is designed"
to prevent new, uncontrolled hazardous waste sites.
Record of Decision (ROD): A public document that explains which
cleanup alternative will be used at a National Priorities List
site and the reasons for choosing that cleanup alternative over
other possiblities.
Remedial Alternatives: A list of the most technologically
feasible alternatives for a remedial strategy.
Remedial Investigation and Feasibility Study (RIfFS): Two
distinct but relatied studies, normally conducted together,
intended to define the natur and extent of contamination at a site
(RI) and to evaluate appropriate, site-specific remedies necessary
to achieve final cleanup at the site (FS).
Responsiveness SnMmary: A summary of oral and/or written public
comments received by EPA during a comment period.
Superfund Amendments and Reauthorization Act (SARA):
Modifications to CERCLA Enacted on October 17, 1986.
" ~
TECHNICAL ASSISTANCE GRANTS
Community groups interested in interpreting the technical
information presented in the RIfFS and other studies may be
eligible for one grant of up to $50,000 in Federal funds. The
purpose of the grant is to provide technical assistance for
community residents seeking to understand site documents.
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EPA MAILING LIST ADDITIONS
To be placed on the mailing list to receive information on
the Lewisburg Dump Superfund Site, please fill out and mail
this form to:
Suzanne Durham, Community Relations Coordinator
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-7791
Name:
Address:
Affiliation:
Telephone:
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APPElm:rx B
Sign-in Sheets From the Public Meeting:
July 25, 1990, Lewisburg, Tennessee
~
-------
U.s. El'JVIRONMENTAL PROTECTION AGENCY
LEWISBURG DUMP
SUPERFUND SITE
PUBLIC
INFORMATION MEETING
\\"ED:-.t.SDA Y. TL1- Y 25.1990
7:30 P.M.
CITY ADMD\lSTRA TION BUILDING
505 ELLn-;GTON PARKWAY
LE~1SBURG.~~SEE
The purpose of this meeting is to provide interested members of the
community with updated infonnation on the Remedial Investigation
and Feasibility Study. A question and answer session will follow EPA's
presentation.
-------
UNITED STATES ENVIRONMENTAL PIlOTECTION AGENCY
REGION IV
PUBLIC INFORMATION MEETING
FOR
LEWISBURG DUMP SITE
. Meeting Attendees
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REGION IV
PUBLIC INFORM/\ TION M[[:TIr\JG
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Repository Name:
Address:
Phone Number:
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APPEiIDIX C
Repository Information for the Lewisburg Dump Site
Marshall County Memorial Library
310 Farmington Pike
Lewisburg, Tennessee 37091
(615) 359-3335
Charlene Nicholas
-------
APPElIDIX D
Official Transcript of the Public Meeting on the Proposed Plan
for the Remedial Activities at the Lewisburg Dump Site,
Lewisburg, Tennessee
-------
THE UNITED STATES
EV\-7RONAfE\TAL PROTECTION AGE!\"CY
(/'.1eeting at) LEWISBURG, TESSESSEE
IN RE: RUFS PUBUC
MEETING CONCERNING
THE LEWISBURG DUMP
SUPERFUND SITE
i\
,
,
I
,
Beporter'8 omclaJ Traaacript
A PVSUC MEE77NG
Volume 1 of 1 - July 25, 1990
Apf('Jranccs for the Em iron menraI Protection Agent~\.:
Mr. Douglas Bell
Mr. HaroJd TayJoT
Dr. Elmer Akin
Mr. M, Michael Henderson
Mr. Bill Bush
Mr. Miles Bolton
ORIGINAL
James Leonard Hobby
Official Court Reporter
365 Holly Grove Road
Lewisburg. Tennessee 37091-2905
615-3594455 : 615-359-1658
I
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10
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It.
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IN RE:
Lewisburg Dump Superfund site
Page 1
1
LEWISBURG, TENNESSEE ------------------------- JULY 25, 1990
2
3
4
000
5
6
7
(A public meeting concerning the Lewisburg Dump
Superfund site, held at the Lewisburg City
8
9
Administration Building, 505 Ellington Parkway,
Le~isburg, Tennessee, beginning at 7:30 P.M.,
conducted by the United States Environmental
Protection Agency.)
000
MR. TAYLOR:
If we could -- I think there is a little
confusion about the time we were going to start.
I think
three out of the four things said 7:30, and one of them said
7:00, so I apologize for any inconvenience welve caused.
Weill try to get started, and if a few people drift in after
or at 7:30, we may repeat a little bit of it, but I appre-
ciate y'all's patience, so far.
My name is Harold Taylor.
Can everyone hear
Original
EPA RIfFS Public ~,
July 2=-,
-------
United States Environmental Protection Agency
Region IV
Public Information Meeting
for.
LEWISBURG DUMP SITE
000
J.4eeting Attendees:t
Charles \Vest, Mayor, City of Lewisburg
Robert O. Binkley. City Attorney
Robert P. Hopkins, Lewisburg Scott Thomas, !\ashville
Jean Meredith. Lev.;sburg Henrv White, Lewisbura
~ . ~
John Stansbury. Benton Harbor, MI Keith Holman, Nashville
Wallace Cathey. Lewisburg Henry White, Lewisburg
Robert McCullough. Lewisburg Pat Cron, Brentwood
Tom Leonard, Lewisburg Mike Smith. Lewisburg
John \\',.llace. Lewisbur£.: Wayne Gre~!OrY. Hermita~e
...... .. ........ --
Edward Potts. Lewisburg Frank Dearman, Belfast
Johnny Graves. Lewisburg Margaret Crosswhite. Lewisbur~
John Cook, Chapel Hill EI Sharp, Lewisburg
Goerge T. Hazlett, Lewisburg Ray Brooks, Lewisburg
Leonard Jett, Lewisburg John F. Rawe, Lewisburg
Genie Sanders, Lewisburg Randall Hammack, Lewisburg
James Leonard Hobby, Lewisburg (Reporter)
t Taken from handwritten sign-in sheet from meeting.
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IN RE:
Lewisburg Dump Superfund Site
Page 2
1
me pretty well? (No response.)
2
I work for the United States Environment
3
Protection Agency in Atlanta, Georgia, and I work in the
4
Superfund program there.
And out of the Atlanta office, we
5
work the eight southeastern states.
6
I'm in charge of the remedial program for
7
Superfund in Tennessee and Kentucky.
We have -- in
8
Tennessee and Kentucky, we have 29 -- right now -- non-
9
Federal National Priority List sites, like the Lewisburg
site, that we work on.
And we have nine remedial project
managers in that section that are responsible for overseeing
either potentially responsible party at NPL sites, or ac-
tually working with our contractors who work on National
Priority List sites.
First of all, I would like to thank the City
for providing this meeting place for us, tonight.
I think
we've got just enough room.
If we get very many more
people, we'll have to move into the larger auditorium, but
we thought this room was a little bit cozier, so we thought
we'd start out here.
If I could, I'll take a minute or two to
introduce a few of the people that are here, tonight.
I
recognize the mayor, Charles West.
I'm sure you all know
Charles.
We appreciate him coming tonight.
I'll sort of work my way around the room.
I
i
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This is Dr. Elmer Akin, and Dr. Akin is our regional risk
2
assessment manager.
He basically works in our on-day every-
3
day RCRA, or hazardous waste program for many on-going
4
hazardous waste facilities.
And he works in the Superfund
5
program, where we try to clean up abandoned hazardous waste
6
sites.
7
At the very front of the room, you see Michael
8
.Henderson.
Michael is our community relation coordinator,
9
and he'll be telling a little bit more, tonight, about
co~munity relations and how you can get involved, if you
have comments, or want to get involved and a little bit
about the pro~ess.
Over here is our court reporter, James Hobby.
James has basically been hired by the agency to produce a
~ritten record of the meeting, tonight, so that we can
basically hear your concerns, basically go back over them,
see where we didn't answer your questions properly, or see
where we need to spend a little more time, et cetera, so
we'll have a written record.
Doug Bell, sitting right here, is going to
work the projector, there, for a minute.
Doug is the rerned-
ial project manager, who works on the Lewisburg site.
Doug
also works on the Rigley Charcoal site, presently.
That's
also in Tennessee.
And he -- I'm trying to think of your
I
I
other site, Doug, and it's slipped my mind.
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MR. BELL:
Tri-Cities, Kentucky.
2
MR. TAYLOR:
Tri-Cities, in Kentucky.
3
Over. in the corner, so to speak,
-- raise your
4
hand, Bill .- we have Bill Bush.
Bill is an attorney in our
5
Office of Regional Counsel, and Bill basically provides
legal guidance to the program and Superfund.
6
7
Sitting up front, Miles Bolton.
Miles,
raise
8
your hand.
Miles is with the I.T. Corporation, and ~iles
9
was the project manager for the remedial investigation and
feasibility study that was conducted and we're here to dis-
cuss the results of, tonight.
Miles company was hired by a
group of potentially responsible parties, the Lewisburg
Respons8 Committee, to do this study, and they did that ~n-
der a consent order with E.P.A.'s oversight.
Let me go over a few things
Out.
real
quick.
front, you'll see there's three different handouts.
One is
the proposed plan or the fact sheet, and if you are on O~C
mailing list, you have already received it, but if you
haven't, please get a copy.
There is also a copy of the overheads we')'
use tonight out front.
Does everyone have copies, or doe~
anyone need a copy of the document?
We'll be glad to.get
for you.
(No response.)
There is also an. envelope out there, in ca~e
you want to send us your comments or send us anything In
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IN RE:
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writing.
It's postage paid and addressed to Doug, and it'll
2
get right to us.
So, please pick up a copy of that.
3
What we're going to do tonight, basically,
looking at the agenda, we're going to try to accomplish
4
5
everything but the last bullet you see there in about an
hour, and then open the meeting up for questions and
6
7
answers.
8
since we do have a court reporter here to-
9
night, I'd like you, when you do have questions, to tell the
court reporter what your name is, so that he can provide a
record of that, and then just clearly state your question.
I ~ould ask you, if at all possible, to hold your questions
until we have gotten through this presentation, and I prom-
ise you that if there is anything that we go over too fast,
that you have a question about, we'll CODe back to it.
So,
please don't worry about that.
The real purpose of the meeting tonight -- and
I hope it's evident to everyone -- we're here to discuss the
Lewisburg dump site, and that's a National Priority List
site in the Superfund program.
It's -- we'll go over the history in a minute,
but it's basically been on the NPL since about 1982.
Just
recently, in 1987, a group of potentially responsible par-
ties did enter into a consent agreement with the Region IV
of the Environmental Protection Agency to do what we call
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remedial investigation and feasibility study.
The purpose
2
of that study is basically to identify the extent of
3
contamination, if any, at the site, and to corne up with some
4
alternatives to correct any problems that are identified.
5
What we're here tonight 'is, basically, that
6
study's been going on; the work's been going on for about
7
two-and-a-half years, now, and we basically feel confident
8
that we have identified the problems at the site.
We've got
9
a pretty good grip on their extent, and what needs to be
done to remediate it.
And we are basically here tonight to
present the proposed plan that E.P.A. thinks will correct
those problems at the site.
The reason we're doing that is
because we basically haven't made a selection, yet, but we
want to tell you what the agency feels is the proble~, what
we think would correct the problem, and get input frOE you,
if you have any input, or would like to tell the agency ~hat
you want to do.
We're going to go over, basically, a little
bit about community participation.
We're going to go over
the.site history and current status.
We're going to have
Michael tell us a little bit about community relations.
Doug Bell is going to go over the remedial investigation
summary.
Dr. Elmer Akin is going to go over the risk as-
And then we're going to finish up with Doug going
sessment.
over the feasibility study relates, and proposed remedial
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alternative.
2
Again, all of the slides that we'll be putting
3
up, today, you have a copy of.
So, if you can't see or you
4
have a problem reading the overheads, please refer to your
5
Let's go to the administrative record.
handouts.
6
, The E.P.A. has established an administrative
7
record for the Lewisburg dump site, and what that basically
8
is, is the documents that we have relied upon to come today,
9
and present the proposed plan to you.
It's -- how many volumes, Doug?
Four or five
volumes of three~ring binders?
r-1R. BELL:
Approximately five.
MR. TAYLOR:
And those are available just down the
street at the Marshall County Memorial Library.
If you ask
the licrarian, they're out on the tabletop.
We went dov;n
and looked at them, today.
They are technical documents, and what we're
trying to do, tonight, is basically present to you, in as
clear a picture as we can, without getting into as many
technical words and technical processes, what those records
say.
But if you want any additional detail, please feel
free to go to the library.
So anyway, if you would like to review the
record, it is available.
We will be adding documents to it
as' we go through this process, so please feel free to look
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at it.
2
And again, if you have questions on the admin-
3
istrative record on the fact sheet, there is Doug's name and
4
phone number.
There is -- certainly, you can reach me at
5
the same phone number, and Michael or Susanne Durham in
6
community relation will be glad to help you.
7
Let's go over the Superfund process a little
8
bit.
I just put this up to kind of show you where we are.
9
Those of you that dory't know the Superfund process, it may
be a little strange.
But back about in 1980, the Federal
government came up with a site discovery program, under tne
Superfund program, to basically identify all potentially
hazardous waste or hazardous substance repositories through-
out the nation.
And that is our site discovery process.
Rig:-.t
nov..' ,
in the state of Tennessee, they do most of that work
for us.
They go out to respond to citizen's complaints,
look at old records, et cetera, et cetera, et cetera.
And
they come up with a list, and there are literally thousands
of these across the country.
We go out and basically try to evaluate these
sites, to see which sites warrant further attention from the
Federal Government.
We weed, from thousands of sites, do~n
to basically hundreds of sites, that warrant Federal atten-
tion.
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In Region IV, in the eight southeastern
2
Southern states that we're talking about, there are approxi-
3
mately 150 NPL sites at present.
After we had basically
4
identified sites, and had identified sites that present a
5
potential problem, we do what's called a PRP search.
And
6
that's a potential responsible party search, to identify any
7
generators, transpo~ters, owners, operators of those sites
8
that may be responsible under the statute to either pay
9
E.P.A. for what it's done, or to actually go out and do the
v.'Ork for E.P.A.
About the same time, we use what is called a
hazardous ranking system.
It's a numerical to basically
compare one site against the other, and the threats that it
may potentially pose.
And using ~hat system is basically
ho~ ~e narro~ the sites down to the few hundred that ~e are
actually looking at, now.
Where we were, about two-and-a-half years ago,
we were at the remedial investigation and feasibility study
stage, that I've discussed with you.
And we notified, at
that time, the potentially responsible parties that we felt,
at that time, could be potentially liable for work that was
done at the site.
Through that process, we did identify
some potentially responsible parties tha~ came forward and
negotiated a consent agreement with the agency, and have
,undertook, under the E.P.A.'s oversight, the remedial
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investigation feasibility study.
That has been done at the
2
site, so we are basely to the RFS stage.
3
We have -- and that's a part of what we're
4
here to discuss tonight -- come up with a proposed plan that
5
we want to solicit public comments from.
6
And now, we'll move to the next stage, which
7
is the ROD, there; the record of decision.
What that will
8
say is that it will be the ultimate decision by the agency
9
on what needs to be done to remediate that site.
After today, what we would like to do is have
a public comment period, or what we're going to do is have a
public comment period.
And we're going to solicit your com-
ments.
After we receive them, we're going to evaluate them
and see ~hat you think about the remedy.
Ke'll discuss those comments, write a respon-
sive summary to those comments, and the regional ad~inistra-
tor of E.P.A., Greer Tidwell, will actually sign a record of
decision saying this is what the agency feels needs to be
done to the site.
I hope to be at that process in this
site, in about a two month period.
I would like to get
through and basically come to a final record of decision.
When we get to that stage, we'll be at RD/RA,
which is remedial design and remedial action stage.
And
again, we'll go through what we did at the RFS stage.
We'11
identify the potentially responsible parties that we feel
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may have potential liability at the site, and give them an
2
opportunity to carry out the remedial design or remedial
3
action.
That typically takes around 120 days to negotiate
4
with the potentially responsible parties.
5
And then the site will either go one of about
6
three ways.
We'll either enter into a consent order that
7
will actually be filed in a Federal District Court, as a
8
consent decree, with the potentially responsible parties,
9
for the~ to carry out the work that's in the record of deci-
sion.
Or ~e'll issue those potentially responsible parties
an administrative order, basically ordering them to carry
out those actions.
Or we'll undertake what's called a fund
response, ~here the Federal Government will actually just
pay the money,
hire a contractor, go out and do the work,
and then ~e'll enter into cost recovery action against a~l'
potentially responsible parties.
So, we are abou~ right
before the ROD stage with this site.
I'll go over a little of the history, and a
lot of you here tonight probably know the history as well as
anyone.
According to the records that we had, the dumping
began at the inactive six-acre limestone quarry site in the
mid-1960's, and it was used until about 1979, for municipat
and industrial waste.
As with a lot of municipal trash sites, then
were industrial wastes taken to the sites, and the thin9
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IN RE:
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that we've identified so far are things like paints, paint
2
strippers, solvents, cements, lacquers,
cleaners, shoe
3
material scrap, pencil manufacturing scrap.
Basically, the
4
waste you would anticipate from the area's industries that
5
they generate.
6
In 1973, the Tennessee Department of Public
7
Health, basically, became concerned about the site, because
8
they didn't feel it was in a suitable location for a sani-
9
tary landfill.
They also were concerned about some open
burning that was going on at the site.
And there was, basically, talk between the
Department of Public Health and the City about closing the
landfill, and there was some interim maintenance measures
taken at the site.
In late 1977, the City of Lewisburg began pre-
liminary closure activities for the site, and basically, the
site was finally closed in 1979, as far as actually recei-
ving waste materials.
It did -- as a lot of you know, it
was used for, I think, the burning of sawdust up until about
1987.
In 1982, an E.P.A. contractor-went out and, as
a part of the site discovery process identified early on,
collected some environmental samples.
And as a result,
largely of the samples that they collected, the site was
ranked, using the hazardous ranking system that I described
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earlier, and the site was placed on the NPL; National
2
Priorities List in September of 1983.
3
Again, in December of 1987, the City of
4
Lewisburg and certain industries formed the Lewisburg
::
Environmental Response Agency, and signed an administrative
6
order with the E.P.A. to conduct a remedial investigation
7
and feasibility study.
8
Again, the site is currently inactive, and
9
there is a little bit of unauthorized dumping of trash, fro~
time to time, but other than that, it's closed.
I guess with that, we are ready to turn it over
to Michael Henderson next to talk about community relations,
if you could.
XR. HENDERSON:
My name is Michael Henderson, and I
work with the community relation aspect of the progra~..
What normally happens when we have a site
identified as a National Priority List site, is the first
thing we try to do is to develop a plan to find out what the
community concerns are.
So we do what we call, establish a
community relations plan.
We get our contractors or one of
the people on our staff to come to the community and talk to
the community about what are their concerns regarding the
program; whether they have economics concerns; whether there
is, you know, monitory concerns; whether health concerns.
Anything that they think that may have affected them beca~~.
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of the site in the~r area.
2
We use this information to develop strategies
3
for trying to keep you informed of what's going on.
Whether
4
we use fact sheets, such as our proposed plan, here, to tell
5
you exactly what alternatives we are considering for
6
We use press releases of putting stories in the
clean-up.
7
We use public notices that notify you of meet-
newspaper.
8
ings.
We also do things
We have public meetings like this.
9
like we call availability sessions, in which it is more of a
one-on-one situation, in which we'll set up in a library, c~
somev,'here,
and say,
'well, between 8:00 and 4:00, you can.
corne in, on your own time, one-on-one, and talk to us.
These are some of the things that we try to do
in terms of trying to keep you aware of what's going cn.
We are at the stage now in the process, as
Harold had mentioned before, where we have the public meE~-
ing.
The law requires that, when we corne to the end of tr.e
remedial investigation and feasibility study, we have to j:
a public meeting.
The basic idea of the remedial investigati::
itself, is to determine what is at the site, how much is
there, and what we call characterizing the site.
The fe, -
ibility study, they take the information from the remec.
investigation, and use this to develop alternatives fo~
cleaning up.
We are at that stage now, and we are supr
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IN RE:
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to bring the alternatives to you, and let you know what we
2
are considering.
3
You have a 30-day public comment period to
4
write or ora~ly tell us,
'What do you think about these al-
5
Whether you think they'll work.
Whether you
ternatives?'
6
think it's not going to work.
Whether you have better sug-
7
gestions.
8
The way the decision is made on the record of
9
decision is to take the information from the public comments
periods, comments we receive from the State on the situa-
tion, and our own information, and combine all of this in-
formation to come up with the decision that we are going to
propose to our regional administrator.
After this is done during the process, we have
to continuously keep you aware of what is going on.
\';e try
to do that by what we call -- we have the administrative
record, but there is also portions of it, which we call in-
formation repository.
When we get sample results, and
things like this, they are put in the library, that you
don't necessarily always have to write us or call us for
information.
You should be able to go to your library, and
look through these volumes of information, or whatever, and
see exactly what you need.
If you can't find it there, do call us.
That's what your taxes are for.
You pay us, so you call us.
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You may not like some of the answers we're going to give
2
you, but I know if you call me, 11m going to find you an
3
That's my job, and 11m going to do my job.
One of the things that we have created -- that
answer.
4
5
the Congress has created, in the interim, in the last two or
6
three years of the program is called the technical ass is-
7
tance grant.
What this grant does is it allows a community
8
group to apply for a grant to get fifty -- up to $50,000.00,
9
to hire their own technical advisor to interpret what E.P.h.
is doing.
It is only one grant per community.
What gen-
erally happens is if you've got three or four different corn-
munity groups that want to apply for it, the first thing we
try to do is to try to get the groups to consolidate and
apply as one group.
If not, then we have to evaluate all
four groups, or whatever, and we can only pick one.
The $50,000.00 grant is £or the life of the
site.
There are certain qualification.
certain groups
canlt have it.
Municipalities or governments, they cannot
apply for it.
Educational institutions can It apply for it.
National environmental groups cannot apply for it.
It has
to be a local group or a local community group that is con-
cerned with that specific problem.
You canlt say, for
example, apply for it, and try to take the money and use i:
for other environmental problems.
It has to be for that
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particular site.
2
These are some of the things that are going
The pUblic comment period starts today, and will end on
3
on.
4
August 23.
As mentioned earlier, there are some envelopes
5
outside.
If you have any questions or have some comments,
6
make sure you pick up one of those envelopes.
All you have
7
to do is write your comments down and stick it in the mail.
8
It's postage-paid already, and you won't have any problems
9
with it.
I will be around to answer any other questions, if
anybody have any questions later on.
Thank you.
MR. TAYLOR:
Thanks Michael.
If we could, we'll get Doug Bell to tell us a
little bit about the remedial investigation summary and a
little bit about the investigation.
MR. BELL:
Thank you.
I am Doug Bell, as Harold just mentioned, and
I'm the remedial project manager for th~ Lewisburg dump
site.
And what I would like to do is just touch on some of
the main points of the remedial investigation, and try to
summarize this in a pretty concise manner.
First, some general information.
E.P.A.'s
Region IV field investigation collected samples back in
1982, and they samples were used to develop a hazard rankin~
system, an HRS score, of 31.14.
Any site with a score above
28.5 would be placed on a National Priorities List.
That's
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why we conducted the remedial investigation.
It was in
2
response to the Lewisburg dump site being placed on the NPL
3
in September of 1983.
The RI was initiated in July of 1988,
4
and has been recently completed in July of 1990.
5
The objectives of the remedial investigation
6
were to first determine the nature and extent of contamina-
7
tion on and adjacent to the site.
Also, determine and de-
8
scribe the on-site and off-site features that could affect
9
the methods of containment and clean-up.
To determine to
what extent the site poses a threat to the public health or
environment.
Also, characterize the areas of investigation
and che~icals of concern.
And to assess the environmental
conditions and the setting of the site.
In order to accomplish our goals with remedial
investigaticn, we had to conduct a fairly extensive sarnFling
effort, and that consisted of five monitoring wells, four
piezoweters, 11. residential wells, seven surface water sa~-
pIes, 17 soil samples, seven sediment samples, six air samp-
les.
And then, there were 12 additional surface waters
samples, an additional 12 sediment samples, 11 fish samples,
seven of the sinkholes in the surrounding area were sampled,
where water samples were taken and analyzed, and four of our
wells were deepened.
The conclusions of our remedial investigatio~
were that we found 32 organic and 20 inorganic contaminants
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that were identified at the Lewisburg dump side.
out of the
2
total 52 contaminants, 10 organic and 11 inorganic contarni-
3
nants are of potential concern.
Of the 21 contaminants of
4
potential concern, only copper and a substance; a compound
5
used in plastics, called DEHP, and it stands for
6
Bis(2-ethylhexyl)phthalate.
It is a phthalate ester occur-
7
ring in plastics.
These are the only two that appear to
8
occur insignificant frequency or levels of potential con-
9
cerns.
The other contaminants were found in suffici-
ently low concentrations not to warrant removal activities.
The site, at present, does not pose an eminent
hazard to the public health or the environment.
But, we at
the E.P.A. do feel that this terminology is inappropriate at
this time because of the following reasons:
One, the. site
conditions do pose a potential threat if allowed to further
deteriorate.
Number two, there is no guarantee that ~ite
conditions will remain stable, at this time.
Also, it is important to note that there is
submerged debris in the pond, and it is a contributor to the
contamination in the pond and the groundwater.
There are physical features that could affect
the remedial measures, and they are, one, the complex geol-
ogy and hydrog~ology of the area.
The area is underlain by
~imestone, and as many people know, limestone develops
I .
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solution cavities, and a typical type of topography called
2
karst, and this is very difficult to characterize.
3
Also, there is thin or absent soil around the
4
site.
And, especially around the pond, there were very high
5
bedrock walls, which make access difficult, except for one
6
side and that's on the western side of the pond.
7
Also it is important to note that the landfill
8
materials are below the water table.
This occurs in the
9
western portion of the site, near monitoring well five, and
small amounts of leachate are forming in this location.
That concludes my very brief summary of the
remedial investigation.
Now, I believe Elmer Akin will be
briefing you on the risk assessment.
DR. AKIN:
This will be rather brief, and we would
hope if you have any questions about the evaluation of the
site from the standpoint of the risk or health concern, that
you would ask those questions during that time.
The risk assessment is really a process that
the agency uses to -- it's really a structured method or
process; it's rather a rigorous process to evaluate the
effects of the environmental contaminants that have been
f~und in those samples that Doug mentioned to you that were
collected at the sites.
It is called the characterizatio~
of the sites, and that's the first step, really, that feeds
into the risk assessment, because everything that we do,
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relative to the hazard that might be posed from the site is
2
based on what we've found to be present in the contaminants
3
that might be located there.
4
And then, after we have characterized -- used
5
the data from the characterization, then the risk assessment
6
basically asks these questions:
How bad is the site, from
7
the standpoint of hazards to the people or to the environ-
8
ment, itself.
We are charged with protecting the ecosystem,
9
fish and wildlife that might be impacted by the contaminants
from the site.
And then, how bad could it become, if nothing
were done to correct it.
We are charged with looking at the
current ~isks, if you will, posed by a site, as well as the
risk that might be posed in the near future, based on
changes in the site, or exposure that could happen in thE
future.
And then, is this site really bad enough to
warrent taking some corrective action or remedial action to
clean it up.
And then, the more specific questions, how
much should be cleaned up, and what would be the results of
that process.
In this case, the risk assessment was condu~~-
ed by a contractor to the PRP, the potentially responsible
parties, and E.P.A. provided the oversight review of tha~
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process for the final document that was produced as a result
2
of that.
My staff has provided that function.
3
In your handout, the one called Proposed Plan
4
Fact Sheet, there is a brief description on page six of the
5
risk assessment and the findings of that process.
We -- or
6
rather, the risk assessors did not find any currently com-
7
plete exposure pathway where risk would be significant to
8
the public or to people or to the environment currently.
9
There are some conditions that we are con-
cerned about, possibly, in the future, if the site is not
stabilized.
But currently, there were no pathways -- and by
pathways, I mean, any way by which someone might be conta~i-
nated, either through eating fish out of that pond, or
groundwater being contaminated and moving out to somebody
that's got a well, or soil from the site, either as dus~ or
kids got over there and got soil in their mouth.
All of those pathways that we could think of,
the agency requirements are that each of those that are
possible be looked at and evaluated from the standpoint of
the risk.
And that process has been done.
And as I stated,
we haven't found anything that posed a current health prob-'
lem, without one of these future scenarios.
The 'what if'
question.
We always ask the 'what if' question, because we
want this thing to be protected 10 years from now, or 20
years from now, as well as tomorrow.
I
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I'll be happy to answer any qu~stions when
2
that time comes.
I'd like for you to feel free, because we
3
want you to be sure that you leave here understanding what
4
you want to understand about this site, and what risks that
5
we see it poses.
Thank you, Doug.
6
MR. BELL:
Well, we'll finish up with a review of the
7
feasibility study and the proposed remedial alternatives
8
that the E.P.A. would like to present.
9
First, I will summarize for you the feasibil-
ity study.
The purpose of the FS, or feasibility study, is
to develop, screen, and analyze all viable alternatives, and
provide selection -- or provide support for the selection of
the most appropriate remedy at these Superfund sites.
The
feasibility study that was conducted by the contractor
identified five possible remedial alternatives that we have
to evaluate.
Alternative one is called the 'no-action al-
ternative' .
The present worth cost of the no-action alter-
native would be $133,000.00.
The reason this figure is pre-
sented, even though it appears that for no-action you would
have no cost, is that if we elected this no-action alterna-
tive, we would still want to monitor the site, and make sure
that there was no hazardous exposures of any contaminants;
that no contaminants were leaving the site; that anything
was just as we wanted it:
Safe.
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The years to implement this, of course, would
2
be zero.
There would be no construction activities: how-
3
ever, if monitoring is elected, it would take five years to
4
monitor this site effectively.
5
Included in the monitoring is a die tracers
6
study.
As I mentioned before, this is in an area of lime-
7
and it makes it very difficult to evaluate where to
stone,
8
take the sa~ples.
If we wanted to evaluate this effective
9
for five years, we would want a little bit more information
to take the samples where they would be most appropriate.
The Superfund requires that this alternative
-- the no action alternative -- be considered, since it may
be more harmful to disturb the contamination at some sites,
or actually, the no-action alternative may be the only lc~-
risk, cost-effective alternative that we may select.
Thc.~'~
why it is present.
For the Lewisburg dump site, this alternative
cannot be elected, since it is not in compliance with ap-
plicable or relevant and appropriate requirements; basica:-
ly State and Federal relation that we call ARARs.
The second alternative would consist of deed
and site access restrictions, and these are termed instite-
tional controls.
The present worth cost of this would be
$185,000.00.
Present worth operating and maintenance c05l
would be approximately $57,000.00.
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Years to implement would be approximately
2
point-three years, or three-and-a-half months.
If monitor-
3
ing -- well monitoring is elected,it would be five years,
4
total.
5
.
This alternative insures site access is limit-
6
ed by installing a security fence.
That also prevents any
7
further uses of the property.
That is important, if we want
8
this site to be maintained in the proper way.
And if we
9
",'ant
to limit the disturbance of landfill constituents and
the site, we would have to implement deed and site access
restriction.
However, alternative two is very similar to
alternative one, in that it can't be selected, because it
doesn't meet the ARARs.
It doesn't meet the State and
Federal requirements.
No....',
the third alternative consists of insti-
tutional controls, plus removal of surface debris.
Also not
printed at the top, here, is removal of submerged debris in
the pond.
It's fully described in my discussion, but I
wanted to mention it to you, because .it is included.
Also, this consist of landfill cap~upgrading,
long-term well monitoring, and analysis.
Present worth cost
is approximately 815 to $870,000.00.
Present worth operat-
ing and maintenance cost is approximately $270,000.00.
Years to implement, again, would be approximately point-
three, or three-and-a-half months to complete all of the
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remedial action, and five years for the well monitoring.
2
The remedial efforts included would be insti-
3
tutional controls presently described, as well as removal of
4
the submerged pond debris and the surface site debris.
No.",,',
5
what we'll do when we remove this debris is we will separate
6
out the recyclables, and of course, recycle them, and for
7
the the nonrecyclables, we will try -- we will attempt to
8
locate a suitable place for them in a sanitary landfill.
9
if that is not a option, we will bury it back in
However,
one of the test pits at the site, before we upgrade the cap.
Next is replacement of the plastic test fit
caps with clay and soil to insure they are stable.
Also
upgrade the cap, as previously mentioned, to meet all the
State and Federal requirements.
This alternative does meet
all requirements for security, closure, and maintenance of a
sanitary landfill.
Now, the fourth alternative, institutional
controls plus removal and treatment of materials from the
site and isolation of the pond sediments.
Present worth
cost is exorbitant.
It's 47 million to $100 million.
Pre-
sent worth, operating, and maintenance cost again is about
$270,000.00.
Years to implement this alternative would be
two years for construction activities, and five years for
total monitoring.
Remedial measures for this alternative woul:
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IN RE:
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include institutional controls previously described, remov-
2
aI, treatment, and disposal of landfill materials, isolation
3
of the pond sediments by actually depositing a clay layer
into the pond, and thereby separating the contaminated sedi-
4
5
ments from the water and the aquatic life.
6
This alternative removed the source of the
7
contamination, but it will fail to meet section 404 of the
8
Clean Water Act, as it will severely impact the aquatic life
9
in the pond.
And the fifth alternative, this will consist
of co~plete removal of landfill material, the pond sedi-
ments, and the surface and the submerged debris.
Basically,
the removal of everything.
Present worth cost, again, is
from 47 million to $100 million.
Present worth operating
and ffiaintenance costs would be $23,000.00.
The years to
implement would be, again, two for construction activities.
If all of the materials from this dump are removed from the
site" the five years for well monitoring may not be needed;
however, that has not been decided at this point.
The remedial measures include all site-related
contaminants removed and the institutional controls would be
utilized, as we previously discussed.
Alternative five removes the source of the
contamination, but the short-term impacts, just as alter-
native number four, are very significant.
It will not,
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again, meet the requirements -- the ARARs -- Section 404 of
2
the.Clean Water Act.
3
I would like to briefly summarize our
Now,
4
selection rational for the selected remedy.
The selected
5
remedy was chosen because it meets the following nine
6
criteria in accordance with CERCLA -- with the Superfund.
7
These criteria are:
Overall protection of
8
human health and the enforcement; compliance with the ARARs,
9
as I mentioned before; long-term effectiveness or perma-
nence.
Reduction of toxicity, mobility, or volume of the.
contaminants at the site; short-term effectiveness; imple-
mentability;
cost;
and it must be accepted by the State anc
the community.
No..; ,
our conclusions for our selected remedy
for the Le~isburg dump site, the E.P.A. selec~s alternative
number three as their preferred alternative for the follow-
ing reasons:
Institutional controls will be implemented.
That's definitely needed in order to maintain stability at
the site.
If we are to upgrade the cap, if we are to remove
the contaminants, the submerged debris from the pond, if we
decide we want to keep people out, and make sure that we
have restrictions on the future use, is what I'm saying.
This alternative will meet the state and
Federal requirements.
Also, a long-term monitoring program is
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provided.
That's important to make sure that nothing is
2
leaving the site and potentially impacting our recipients,
3
down from the site in the watershed or toward the creek,
4
down below.
5
Also it removes the source of contaminations;
6
the main source of contamination, the submerged pond debris.
7
The short-term impact of remediation will be
8
minor.
We will not be severely impacting the aquatic life
9
in the bond, and again, the length of time for the remedial
activity will be short.
The alternative is cost effective.
Alternative number three is 56 times less than alternatives
four and five, which are exorbitant, we feel.
So we feel
that this is the only cost-effective option that actually
meets the ARARs, and is not exorbitant in cost.
It also prevents further deterioration of the
landfill cap, which has been previously been mentioned.
And that will summarize the feasibility study
and our preferred alternative.
Now, I'll turn the meeting
back to Harold Taylor, who will open the meeting for ques-
tions.
MR. TAYLOR:
Let me kind of summarize what we have
said here, tonight.
~asically, we've said that we feel that
,adequate data has been collected to characterize the
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IN RE:
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Lewisburg dump site.
A series of alternatives have been
2
reviewed and analyzed for the impacts that we have seen.
3
And ~e feel, basically, that upgrading the cap at the site,
4
putting up a fence to isolate the site and restrict access
to the site, conducting five years of monitoring to make
5
6
sure that those remedial actions have been effective, is a
7
preferred alternative for the site.
8
We feel that anything less is not adequate to
9
protect either the public health or the environment.
And we
feel that anything more than the alternatives that we de-
scribed are really not cost-effective methods to clean up
the site.
What we would like to do -- we have presented
a lot of data that has taken about two-and-a-half years to
collect, and presented it in a fairly brief fashion.
Khat
we'd like to do is open it up now for questions.
Again, what I'd like for you to do is, since
we do have a court reporter here to record what your con-
cerns are, if you could, before you ask a question, state
what your name is, and try and clearly present your question
to the court reporter, so we can get a record of what your
question is or what your concern is.
Then I will either,
a,
answer the question, or direct it to one of my associate,
here, who can adequately give you a description of what you
need to know.
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IN RE:
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So, if we could, I'll open it up.
Yes, sir?
2
If you'll state your name.
3
My name is John Rawe, spelled R-a-w-e.
MR. JOHN RAWE:
4
First a couple of questions for you, Harold.
5
How do you go about identifying PRPs?
What is the process?
6
Well, it is almost a continuous process,
MR. TAYLOR:
7
to be honest, and it varies from site to site.
8
For the Lewisburg site.
Let's be spe-
MR. JOHN RAWE:
9
cific.
That's the one we're talking about.
MR. TAYLOR:
A potentially responsible party -- and
again, I want to emphasize the word, . 'potentially responsi-
ble', because the agency has a basic duty to notify anybody
that we ~hink is potentially responsible of their liability
We, basically, again, for those of you who
don't know -- I think some of you know more than others.
But basically, any generator that took waste to the site,
any transporter that transported the waste to the site, C~
any owner-operator of the site is potentially liable undec
the Superfund statute.
We conduct -- in fact, I think I was the pro-
ject manager, back, several years ago.
We basically hired b
contractor to go in, study all of the State records, stydy
all of the historical records that we could find, and co~e
up with a list of people who mayor ... may have a chance
having done one of those three or four things; either
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IN RE:
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generate it, transport it, or owned or operated the site.
2
And then, we basically tried to gather whatever information
3
we could, whether they were records that State inspector had
4
been out and seen somebody, or whether the City had records
5
of a transporter.
6
The next step is generally -- and I think it
7
was done in this case.
I think even the State had sent out
8
some questionnaires on potential generators at the site.
We
9
reviewed that information, and sent out information request
letters, basically, asking those potentially responsible
parties if they had any records.
And under our law, we have
the authority to ask them if they have records, and they are
to provide the~ if they do.
That is, you know, kind of in a nutshell
"hat's done at the site.
MR. JOHN RAWE:
Okay.
I can accept that, I guess.
If an individual or a company receives a PRP
letter, and they supply information to indicate that there
is no way possible that they could have been a RP, what's
the process of not being a PRP any more?
MR. TAYLOR:
If I could, I may direct that to our at-
torney, Bill Bush.
Maybe he can answer that question more
appropriately?
MR. JOHN RAWE:
Okay.
MR. BUSH:
What we do is compile a list, and
,
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IN RE:
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Page 33.
1
basically, if you are still on the list, we either feel we.
2
have some evidence that makes you potentially a responsible
party -- we really don't make any decisions at this point -- .
3
4
or we don't have enough evidence to eliminate you from that
5
list.
And it could be that, in a particular case.
6
The reason that companies might have gotten a
notice letter, at this time, was really to give you the op-
7
8
portunity to participate in this process.
Like Harold said,
9
we are sort of obligated to give you notice of your poten-
tial liability.
I want to stress that, at this point.
Really, when we get down further into the pro-
cess of getting a record of decision, special notice letters
will be issued at that time, where we actually, I think,
more fully determine that you are liable and would poten-
tially be requested to perform the remedial design: the
remedial action at the site.
But I would say at this point -- and I stress
the potential of the word,
'PRP', and really are pursuing
y'all to participate in the process, so that we can either
get more information from you with respect to your potential
liability, or so we can eliminate you from out list, and we
may need further information.
MR. JOHN RAWE:
If an individual company, or whateve~,
was eliminated, would they receive correspondence from
E.P.A. so stating?
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MR. BUSH:
Like I said, at this point, I don't think
2
we have actually made decisions to -- for sure, that people
3
are liable or they are not liable.
Like I said, I don't
4
think that that decision has been made at this point.
5
MR. JOHN RAWE:
If it was made, would a letter be
6
forthcoming?
7
Well, you proceeded the question with a
MR. BUSH:
8
, if I ,
and I'm saying that hasn't occurred yet.
9
Okay.
But it will, eventually.
MR. JOHI. RAKE:
~R. BUSH:
Right.
MR. JOHN RAWE:
Taking the time to make that decision,
will a letter be forthcoming at that point?
MR. BUSH:
Stating that you are not a PRP?
r-:R. JOHU RAKE:
Right.
l.:r:. B:;SH:
It's generally not our policy to do t~=~.
MR. JOHN RA\.;'E:
So, how does one know whether they a~e
still considered a PRP?
If E.P.A. has decided that they
aren't, how do they know that they aren't any more, and not
liable any more?
MR. BUSH:
I said, in circumstances that evidence
prbves to us that -~ with certainty, that you are not a
potentially responsible party, then such a letter could be
given.
But usually, the agency would not like to put o~r-
selves in that position because new information can alWb~S
be obtained that leads us to your potential liability.
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IN RE:
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we have already given you a letter saying you're not, then
2
we'd have to, you know, take that back.
3
So, basically, what you're saying is,
MR. JOHN RAWE:
4
once you are a PRP, you're a PRP until you're dead.
And
5
maybe then your ancestors will still be PRPs
6
Well, if your potential liability is still
MR. BUSH:
7
there, I guess.
8
What the agency doesn't want to do is get
MR. TAYLOR:
9
in a position of telling you that you're not a PRP, and an-
other group of PRPs corne forth in doing the work.
And then.
they turn around and sue you, and get you in a court of law,
and, basically, they have evidence that --
MR. JOHN RAWE:
I'm assuming that everything .is done
aboveboard, everything is correct, and that that is not a
possibility.
MR. T~.YLOR:
We have sent out, in the past, letters
stating that we have identified you in the past, and based
upon the records we have currently, we don't believe that
you are a potentially responsible party.
The most frequent
way we do it is, basically, we'll send out a second set of
letters, or whatever, and your name will either be on it or
it won't, and that will give a pretty good clue as to whe-
ther the agency feels you're still potentially liable.
MR. JOHN RAWE:
You may have figured that I'm speaking
specifically of a company that I'm associated with.
In '86,
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EFA RI/FS Public Meetin~
July 25, l~=:-
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we got the first letter, responded, got another letter, re-
2
sponded further, got no more letters.
We assumed from that,
3
we were not considered as PRPs any more, since we did not
4
get any further correspondence.
This week, we got another
5
letter saying that we were, again.
6
MR. TAYLOR:
Well, what may have happened -- and
7
again, I can't speak for any individual company.
But what
8
may have happened there is that actually, as you are aware,
9
in '86, we sent out ~etters, and it did result in a consent
agreement with a group of potentially responsible parties to
do the remedial investigation and feasibility study.
At that point, there is really nothing to con-
tinue negotiation on, or continue notifying potential re-
sponsible parties about.
We, basically, had someone that
was willing to do the work, and basically, we dropped it.
And now, the recent set of letters that was sent out was to,
basically, tell everyone that was still on our list, that,
'Hey, you're still on our list.'
MR. JOHN RAWE:
Start the process allover, again.
THE COURT:
'We are going to have a public meeting,
you'd better reconsider your position, and at least be awa~E
that we're having meetings, and get involved, and know
what's going on.
MR. JOHN RAWE:
That sounds fine.
I've got a couple
of more questions, if it's okay.
Doug?
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Original
EPA RI/FS Public Mee:.
Jul y 25, :
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MR. BELL:
Sure.
2
MR. JOHN RAWE:
In alternative three, you mentioned
3
that debris would be removed from the pond.
If the unrecy-
4
clable material could not be put in a sanitary landfill at
5
another location, it would be buried at the current site.
6
Why go to the expense of trying to find and
7
transport it somewhere else, if it is permissible to be
8
buried at the current site in the first place?
9
If it is more reasonable to bury it at the
MR. BELL:
site and we can do so with the least possible frictioh, by
the regulations, then I think that's a viable alternative.
If it becomes a real problem, and we face a great deal of
difficulty, trying to get one of the test pits open, and
trying to bury the debris in there, then we would look at
another alternative.
MR. TAYLOR:
I think what we're saying there is prob-
ably the least disruptive alternative is to haul material
somewhere else and not go in and start digging around in a
site that has been closed since 1979; however, if that's
just an impossibility, we would like to have the alternative
of doing that and of exploring, finding an area, digging a
hole, and extending the cap over that area.
MR. JOHN RAWE:
Okay.
Another question for Doug.
It's my understanding of the information that
I've read, that currently, it has not been determined that
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there is any hazard to the health and the environment, based
2
on the site, as it stands now.
Why take anything away, if
3
there isn't a problem, and obviously, the dump has been
4
there for many years: many more years than I have been in
5
the area?
What is the necessity of removing anything, if
6
the levels of contaminant aren't such that they pose a
7
problem?
8
The levels of contamination are not, across
MR. BELL:
9
the board, significantly high, but we do have two contami-
10
nants of concern out there, and one of them is copper, and
11
the toxicity of copper is very high.
And we do have copper
in the pond.
That's number one.
Number two, the compound, DEHP, is found out
there,
And as I mentioned before, it is a com-
frequently.
ponent used in plastics.
And it has reasonably low levels,
. maximum contaminant levels for drinking water or standards.
And we do find a quantity in the test pits of 38,000 parts
per billion.
And we do find some DEHPs in one of our moni-
19
toring wells, and we do find it in the pond sediments.
I do think think that it's important that we
implement the site access restrictions, and do remove the
materials out of that pond.
If we're going to monitor the
site and try to insure that it's cleaned up and get those
two contaminants of concern down to reasonable levels, where
we can start evaluating them, over a long period of time.
Original
£PA RI/fS Public M~et:: .
July 25, 1:-:'
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If we can't do that at the present time, we
are concerned that the site will continue to further deter-
2
3
'iorate, and especially, the landfill cap, at this time, is
4
now penetrated by some small trees and various other plants,
5
and it's undulating so that water can actually pond on the
6
top, and it's getting into the landfill, to cause further
7
deterioration.
8
That is a concern, at this time.
So the site
9
may not be a Love Canal, but it certainly has the potential
to continue to deteriorate, and we want to try to eliminate
that possibility.
MR. JOHH RAi-.~E:
Okay.
I've got one more question, and
I don't know who can answer this, but is there any record oj
any health pro~lems within the community, because of the
site.
MR. TAYLOR:
We'll let Elmer pick up on this, but we
have the Agency for Toxic Substances and Disease Registry.
That's a big long name, --
MR. JOHN RAWE:
I'm aware of that.
MR. TAYLOR:
but they are an independent agency.
Most
of the people came out of the Centers for Disease Control,
and it's more familiar to people as Centers for Disease
Control, but it is actually A.T.S.D.R.
They conduct an independent evaluation of,
,basically, the data that is in the RI to see if, based on
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the data, there warrants a full-blown health study or as-
2
sessment.
And basically, they've reviewed that data, and to
3
date, they don't think that that data that is presented re-
quires that kind of in-depth study of the area.
4
5
Elmer, do you have anything?
6
DR. AKIN:
Not unless that doesn't satisfy you.
7
No, I hadn't heard anything.
I didn't
MR. JOHN RAWE:
8
think there was.
I just wanted to know if there was some-
9
thing that may be on-going, or whatever.
HR. TAYLOR:
Based on the levels that we have
No.
found, so far, at the site, we don't think that it warrants
that kind of an effort; that there is potential for that
kind of problem.
XR. JOHN RA\\E:
You mentioned the DEHP is used in
" .. .
pl.as...1.cs.
MR. BELL:
Yes.
MR. JOHN RAWE:
I'm wondering how it could have gotten
there from the people that I see in this room, or from any
of the other industries in town.
I'm not that aware of that
much -- if any -- plastics manufacturing in the area.
I'In
sure there have to be other uses for the products, otherwise
there are some PRPs that haven't been found yet.
Because I
don't know that, you know, there is that much plastic manu-
facturing done here that would use that product that would
allow it to get out there, unless there are other specific
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Page ';1
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uses for the product.
2
THE COURT:
Elmer, are you aware of any other?
3
DR. AKIN:
Well, we haven't really determined the
4
source of that, yet.
Most household waste has enough plas-
5
tic containers that you would get some leaching of these.
6
It could be from that source.
You don't really know if it
7
is.
It's not an uncommon contaminant of landfills to find
8
You don't necessarily have to have, you know, a
DEHP.
9
manufacturing concern that is used that product to find it.
LO
Okay.
I would like to say that I
MR. JOHN RAWE:
II
think we need to do something.
I'm as concerned about the
L2
enforcement and people's health as anyone else.
My o'wn
L3
feeling is that I don't think we need to spend a millio~
L4
dollars to take care of this site, based on the information
L5
that you've presented.
I just think that's also exorbi~a~~.
L6
since there doesn't appear to be any health cr
l7
environmental problems, at the present time, and based O~
L8
the 11 years since it's been closed, and the 30 years sin=c
19
it was first used, that there have been no problems,
and
~O
that the problems really, from data that I saw, back in t~~
~1
early -- well, even. before 1979, the contaminant levels a~e
~2
lower now than they were then, which tells me that over the
D
last 11 or 12 years, that the site is becoming cleaner on
~4
its own, without doing anything.
I just have a severe problem with spending
!5
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IN RE:
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lot of everybody's money to fix something that really
2
doesn't need fixing, at this point.
3
MR. TAYLOR:
Again, you know, we at E.P.A. struggle
4
with those kind of concerns, quite frequently.
5
As I think we ~ave said tonight, the site, by
6
is no Love Canal.
And I think that the informa-
no means,
7
tion that's been presented, we're not trying to present that
8
tonight.
9
All we're basically saying is that we have
concerns.
There are not only some contaminants that we have
identified as potential -- that we already see at least some
evidence of potential concerns, but there are hazardous con-
stituents in the landfill.
We just can't -- at this time,
we don't thin}~ it's conservative, from our conservative. per-
spective, that it's the proper way to just walk away and say
the site, there is no future problems.
MR. JOHN RAWE:
I don't think it is, either.
I don't
think it should be walked away from.
I just think there are
probably, within your framework of alternatives, a method to
take care of the site without spending a million, million-
and-a-half, two million dollars.
MR. TAYLOR:
The costs that were presented in the
study, of course, are not -- you know, it may not be the
actual cost.
.It may not cost that much; it may cost more tc
implement.
Those are sort of guesstimates, based upon wha:
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we think it will cost, today.
2
The actual cost would be determined at the
3
remedial design stage and then, when a contractor is selec-
4
ted by the PRPs or the E.P.A., that's when we'll actually
5
know how much it will cost to do the actual clean-up at the
6
site.
7
MR. JOHN RAWE:
I've got another question, then.
8
Can I comment on that, too?
DR. AKIN:
9
MR. TAYLOR:
Sure.
DR. AKIN:
One of the trade-offs the agency has to
~ake in that regard is we tried to characterize the site.
We don't know everything possible about a site, obviously.
We have a limited number of samples of all the media.
But
it turned out we have to consider this.
If we didn't do
anything but just monitor, and then there was a groundwater
flush, for example, that kind of got away from us, then the
cost of cleaning it up or stopping it comes to many-fold
greater.
So it's almost like an ounce of prevention
idea.
We don't know everything.
We do have a little bit iri
some fish that were taking out of there.
We know there are
some contaminants in the groundwater, that haven't moved
particularly far, now.
We assume that they may not, but
they might.
So, that degree of unknown, I think, it is j~s:
a step of caution to go ahead and stabilize it and do thesE
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things
now,
rather than take that chance that it might get
2
worse.
3
MR. JOHN RAWE:
Are the five alternatives that were in
4
the study the -- are they set in stone?
Could the eventual
5
solution be a combination of some of those, or are those the
6
only choices which the PRPs have to rectify the site?
7
There, you know, again, we get into these
MR. TAYLOR:
8
discussions, and I think the Superfund process, itself, ap-
9
pears so~ewhat cumbersome to a lot of people.
It is cumber-
some to myself at times.
Frequently, we'll come to a record of deci-
sl.on,
negotiate a consent decree, or hire our own contractcr
and get ~ut in the field, and we'll find cheaper ways to do
things.
The ROD pretty much will say that these are our
goals and these are our objectives and these are the things
that we're going to use to meet our objectives.
. And it...; ill
describe them in fairly specific terms, but broad -- general
enough that there is a little bit of leeway.
If we get out in the field -- if,
say, the
E.P.A. or the PRPs hire a design contractor and we get Q~t
and discover that we could get by with a little bit less
than was actually in the ROD, then there are mechanisms ~.
could use to go back and do an explanation of significan\
differences, if it was that large, and inform the publIC
that we have altered the plan in certain ways.
Original
EPA RI/FS Public I"..
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IN RE:
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We could also go back, if we really wanted to,
2
and change the ROD, say, new information has corne to light.
3
We are changing this alternative.
Either we're going to
4
upgrade it and it's going to cost more, or we're going to
5
add another technology, or we are going to do something a
6
little bit less.
So, there's flexibility.
7
But we really want to have comments, now, and
8
if there are other alternatives that people think are vi-
9
able.
We want those to be presented, so we can study them,
now, so if we get a process going, we can kind of continue
throughout without stopping and starting.
So, there is some flexibility, but really, the
time to get out and discuss these things is now.
MR. HENDERSON:
One of the things I would suggest is
if you do have an idea of a better way to do it is to send
it in as a comment.
It has happened before that a community
has changed the record of decision, and carne up with one
that would be better and cheaper~
Not necessarily in this
region, but it has happened before in another region.
It
can happen.
MR. TAYLOR:
Yes, sir?
state your name.
MR. RAY BROOKS:
Yeah.
My name is Ray Brooks.
The good doctor stated that the plastic found
is in normal household disposal.
It looks to me like that
every resident of Lewisburg should be on the PRP list,
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IN RE:
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because we all put plastic in there, instead of just a few
selected companies like myself and John and a few others in
2
3
here.
4
MR. TAYLOR:
Well, again -- and I don't want to get
5
into too much about potentially responsible parties, but the
6
City of Lewisburg is a potentially responsible party, as
7
being the owner-operator of the site.
So, in a way, every-
8
body in Lewisburg is a potentially responsible party,
9
through the City's responsibilities as being the owner and
operator of the site.
So, if this were to go fund lead, and this
were a municipality, and the Federal Government had to spend
money, the State would have to come up with a 50 percent
cost share, theoretically, for this site, if it were to go
fund lead.
So, one way or the other --
MR. RAY BROOKS:
Our tax dollars.
MR. TAYLOR:
-- your tax dollars are working for you.
(Laughter. )
Another question?
I know we have more ques-
tions than that.
MR. JOHN RAWE:
I can't believe I asked them all.
MR. TAYLOR:
This is where I get up on the table
and
do a tap dance, if you don't have any more questions.
MR. HENDERSON:
I do have one comment, though.
If anyone is interested in that technical
assistance grant program, the young lady they should
_.- - - -----4
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EPA RI/FS Public Mec:.
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IN RE:
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contact's name is Denise Bland, B-l-a-n-d.
She is the tech-
2
nical assistance grant specialist at E.P.A., and she would
3
be in our Region IV headquarters, at 345 Courtland Street,
4
northeast, Atlanta, Georgia 30365.
5
MR. TAYLOR:
Yes, sir?
MR. SCOTT THOMAS:
Scott Thomas.
What are the applic-
7
able and relevant requirements for this site?
In some of
8
your alternatives you showed that some alternatives don't
9
meet those and some do?
Does it relate to having to put a
particular type of clay cap on the site that meets the ARAR
or a bun of ARARs or ... what are they?
THE COURT:
Basically there are some fairly standard
Federal and State requirements.
I think one that we men-
tioned several times. was the State landfill requirements for -
the closure of sanitary landfills.
This was landfill was
closed a nu~ber of years ago.
There were standards in place
for closure in landfills at that time.
I'm not -- as far as the cap, I'm really not
saying that the cap has to be closed with, you know, so many
inches of clay, or such a grade, or whatnot.
I'm saying
that what we need to do is review the present condition of
that cap and see what measures need to be upgraded, if any,
to bring that cap back into standards with the State land-
fill.
We have also identified, I think, some -- as
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IN RE:
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far as the copper.
We've identified some water quality cri-
2
teria for copper, as a State ARAR, and that's basically a
3
standard that is set for fresh water aquatic life.
It is a
4
standard that E.P.A. thinks is protective of the fish and
5
That is a standard.
ecosystems.
6
We have looked at the groundwater, of course,
7
with -- mostly with the MCLs: maximum contaminant limits.
I
8
could go on and on and on with ARARs, perhaps.
9
Obviously, if we get in there and start dredg-
ing or playing around with the sediment of that pond, we
have to meet the Clean Water Act requirements for dredging
and filling the waters of the united States.
Can you think of any other large standards?
Miles, can you think of any standard.
r-~R. BOLTO!~:
No the Clean Water Act and the aquatic
water quality criteria would be the main ones.
MR. TAYLOR:
Yes, sir?
MR. JOHN RAWE:
Another comment.
It would seem sim-
pIer to me, rather than worry about clean water in that
pond, or keeping it clean, to fill it up, put a lid on it,
and it's gone.
You don't have to worry about it.
MR. TAYLOR:
Well, that is a -- you know, I'm glad you
brought that up.
MR. JOHN RAWE:
Put the fish in another pond.
MR. TAYLOR:
Again, perhaps --
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MR. JOHN RAWE:
That isn't one of your alternatives.
2
MR. TAYLOR:
Some people or some comrnentors have al-
3
ready basically suggested that.
And I think it warrants --
4
I'm certainly going to look into it, in the next few weeks.
5
I think Miles may have some insight.
He may have already
6
looked at that alternative, a little bit.
7
Miles, on that question, did. you look into
8
feasibility of filling that pond?
9
Closing or sealing the pond certainly is
MR. BOLTON:
a possibility.
It adds more cost.
If you actually want to
relocate the fish, and then fill up that hole, it is a two-
acre pond, with 20-foot walls that we would have to fill in,
so that gets fairly expensive.
Another thing is the existing aquatic comrnun-
ity is healthy, at this point in time.
We don't see any
impact to the fish and wqatnot, and the turtles and whatnot.
And with an established ecosystem, it may actually be bene-
ficial to leave that in place, and work to help prevent any
type of changes out at the site that could result in changes
in the environment.
MR. TAYLOR:
You know, again, I think we need to look
at that.
I think that.'s a good comment, but I've got some
technical concerns.
I mean, obviously, if groundwater re-
charges that area, the implementability of pumping that site
~ut and trying to fill it in, while you're keeping the water
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IN RE:
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out, and what actually happens, once you fill it in with
dirt, whether you are going to have sort of a quagmire out
there of soft, mushy soil, at least that's a question to me,
and I think we need to look into that before we consider
2
3
4
5
that alternative.
6
Another commentor stated, basically, you know,
7
if we do, indeed, do that, it may necessitate building a
8
pond somewhere else that would match this pond, as far as
9
the role in the enfQrcement that it's playing, now.
That
might be a pretty expensive endeavor in that area in that
you've got some fairly shallow soil~ and rock that's subject
to karst formation underlying itself.
That alternative may
be quite expensive, for the benefits that you seek from
doing it.
Yes, sir?
MR. LEONARD JETT:
Yeah, I'm Leonard Jett.
I just
wondered, at certain times of the year, wet weather and all,
we've got a stream running off in there.
It runs under the
railroad track.
It goes off in there, and it goes back down
and runs out the other end.
Now, is this enough to flush
that, or is there enough pollutants that are in there, you
kno'w, to mix.
MR. TAYLOR:
Doug, -- are you referring to the stream
that comes basically out of the --
MR. LEONARD JETT:
Wet weather.
MR. TAYLOR:
Wet weather.
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IN RE:
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MR. LEONARD JETT:
It -- I've seen some in there, you
2
know.
3
MR. TAYLOR:
It goes into a sink and disappears and --
4
MR. LEONARD JETT:
No, it runs in there.
5
MR. TAYLOR:
You are talking about --
6
MR. LEONARD JETT:
It recharges.
7
MR. TAYLOR:
From the top of --
8
MR. LEONARD JETT:
From the railroad.
9
You're talking about across from the
MR. TAYLOR:
railroad --
MR. LEONARD JETT:
Under the railroad.
(M:. Taylor, Mr. Jett, and another gentleman were
advised that if they talked at the same time, the
reporter could not understand what was said.)
MR. LEONARD JETT:
It is surface water.
Wet weatheY",
you know.
I've seen big streams go out there, and go out
the other end.
MR. TAYLOR:
Miles?
MR. BOLTON:
He's talking about the intermittent
stream?
MR. BELL:
That's correct.
MR. BOLTON:
Yeah.
The stream cuts across the rall-
road tracks; under the railroad tracks, and flows on tcp of
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IN RE:
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a very flat surface of limestone.
It goes through a few
2
cavities, and eventually makes its way into the pond.
Fror..
3
that point, it may appear that once it reaches the pond, it
4
goes out into a drainage ravine, down in the south, south-
5
east.
6
However, at this time, it is difficult to
7
quantify whether that would be enough to actually flush that
8
pond, because even in dry conditions, they tried to pUIT.p
9
that out once, to see if there was any change in water
level.
This was several years ago.
They pumped it for 24
hours, and there was absolutely no change in water level,
and there was no water coming in from the intermittent
stream, whic~ seems to indicates that there is a great deal
of groundwater recharge cOIT.ing into that pond from other
areas.
So, I'm sure that, in times of wet weather,
that is a significant source.
But I think there is a even
greater source from the ground, from underneath the rock.
And also, there is a flow coming from the
landfill area, itself, into the pond.
MR. LEONARD JETT:
That's what I was thinking, because
I walked across that place when it didn't have no water in
it, many years ago.
It's got a ditch up against that far
bank, there, that they drained it through the drainage ditch
to the sinkhole.
And I'm saying, you know, in wet weather
Original
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July 25, l~'.
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it has got a pretty good flow of.water through there.
2
MR. TAYLOR:
Mr. Jett, what change in conditions -- do
3
you know what made the pond fill up with water?
4
MR. LEONARD JETT:
Oh, yeah.
A number of years ago,
5
they used to have drainage ditch sticking up in the front
6
yard. [ ? l
They had cross ties across there, and you walked
7
across it.
And I've been out in there when there was no
8
water.
9
But over the years, they've tried three dif-
ferent times to block that water to get a lake, there.
And
they halfway succeeded the last time, but it still reaches
the water level --
MR. BELL:
So they blocked up that drainage ravine?
MR. LEONARD J.ETT:
Right.
Yeah.
l':E. TAYLOR:
Okay.
Thank you.
DR. AKIN:
So, if you move that blockage it would dry
that pond out?
MR. LEONARD JETT:
Yeah, it sure would.
It would go
into a sinkhole, and where it goes then, who knows.
East.
It used to be completely empty.
Right there, where Mr.
Hazel's house is, they blocked it, there.
They filled it
in.
They even made a concrete dam down there, one time, and
that still didn't stop it. It's a small concrete dam, I
guess, about four feet high. It didn't stop it.
MR. BELL: After years of being filled with water,
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EPA RI/FS Public Mee"
July 25,:
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IN RE:
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there is a possibility that it could have opened up another
2
small conduit for the groundwater.
And they did that pump
3
test for 24 hours, and that was a pretty good indication
4
that we now have another source coming into that pond.
5
How much sediment is in the bottom
MR. LEONARD JETT:
6
of it, now?
I remember it used to be 18 a number of years
7
back, before the dam was put there.
About 18 inches of
8
sediment.
9
MR. BELL:
Well, Miles may be able to correct me on
this, but I believe about two feet; is that correct?
MR. BOLTON:
It was 2.5 feet.
MR. LEONARD JETT:
It hasn't gained that much.
And
that's 25 or 30 -- could be 40 years ago, for all I kno~.
A PERSON:
Me and him both 'swimrned' there when it ~a~
boys.
MR. LEONARD JETT:
Oh, I've waded across there.
A PERSON:
Waded across.
DR. AKIN:
Does anybody fish in that pond, do you
know?
MR. LEONARD JETT:
I've eat a many or
Many years ago.
fish out of there. .
DR. AKIN:
But not currently?
MR. LEONARD JETT:
Even the sinkhole.
No.
Huh-uh.
Is it safe to drink any water in the surrounding area?
W~en
you say -- about 200 yards, there's places out there whe~
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you can get as cold a drink of water as you'd ever want.
2
MR. BELL:
Well, a lot of the sinkholes, now -- and
3
I've been out there -- are full of garbage and various
4
there's various trash that has been deposited' in some of
5
those sinkholes.
And when it rains heavily, one of them
6
will get stopped up, because the flow will go to the sink-
7
hole, and it will collect all of that garbage, and it will
2
stop up and then the flow gets to another one.
So, on
9
various different occasions, you would have flow back and
forth between those sinkholes.
That would be difficult for me to tell you, at
this time, g~ven how variable the situation is and how much
garbage is going toward the sinkholes, and how much rain
there is.
}~R. BOLTON:
I think it is also fair to state th2~
this process doesn't look at bacterial contamination and
other things, so we really can't call the water safe,
even
if we find absolutely no contaminants present in this type
of investigation.
MR. TAYLOR:
This investigation mostly focused on the
people's wells.
MR. LEONARD JETT:
How about to the west of the area?
Or is it all to the east?
I mean, you've got water just
like that out there, all in that area.
To the east and
west, south.
You know, any way you want to go, you've got
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water.
Is it all.running the other way, to the east?
2
MR. TAYLOR:
Doug, you might want to tackle that ques-
3
tion.
4
MR. BELL:
It appears that from the previous remedial
5
investigations that have been conducted that the water flo~s
6
to the east or the southeast.
It takes a local deviation
7
~.1ce it gets out of that pond, possibly to the Southeast.
8
We don't know exactly, because the limestone aquifer -- the
9
rocks that are holding the water -- are very complex at the
site.
This has been a point of concern, not only for the
contractor, but for the E.P.A.
One thing that we do know for sure is that it
heads toward big Rock Creek, so it eventually heads east and
gets into the creek.
We do believe that the overall direc-
tion is east-southeast.
MR. TAYLOR:
Of course, our contractors for the PRPs
has looked at it, the E.P.A. as looked at it, the U.S.G.S.
has looked at it.
I think we all tend to agree that it
eventually flows east-southeast.
As you well know, as you
walk that area, that there is a lot of underground water:
springs.
MR. LEONARD JETT:
Hundreds of them.
All the way tWQ
miles to the north.
MR. TAYLOR:
And again, that's sort of the variables
out there, and because of the unknowns where the groundwater
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flows.
That's why we want to be cautious in whatever remedy
2
we select out there, because there is some unknowns about
3
the groundwater flow.
Yes, sir?
4
MR. TOMMY LEONARD:
Tommy Leonard.
According to the
5
E.P.A. And the State of Tennessee, this is one of the 200
6
most dangerous sites in the country.
Right? .
7
No, sir.
You have have heard that --
MR. TAYLOR:
8
that may have been early on, when the site, I think, was
9
originally proposed, it was one of the initial set of sites.
But actually, I think -- and somebody in the back may cor-
rect me -- but there is probably 1,500 or 2,000 NPL sites,
noV.' .
Close to 2,000, now.
And the number increases every
time we -- we basically have a continuing process to add
sites to the National Priorities List.
}~R . TO}j}~Y LEONARD:.
The impression, when this site "as
first put on that, that the State of Tennessee turned it in
to E.P.A. as being one of the worst sites in the state.
MR. TAYLOR:
They use the hazardous ranging system,
that I've described earlier.
It's a numerical system that
says so many people live around the sites, people use drink-
ing water, there are certain contaminants at the site.
And
you use that numerical. model to compare sites.
And using
that, the State of Tennessee did submit, I believe, the
draft package. And we, basically, after we reviewed it, put
it on the National Priorities List, because it was above the
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28.5.
2
MR. TOMMY LEONARD:
No doubt, if we had the results of
3
the RI/FS, do you feel like this site still warrants that
4
distinction?
5
MR. TAYLOR:
The site -- what we're trying to do, to-
6
night, is go through a plan that would ultimately take the
site off the National Priorities List.
7
8
I think the average Superfund site, now,
in
9
the nation is costing approximately $25 million to remedi-
ate.
The plan we discussed, here, tonight is in the range
of $800,000.00.
So, if you just look at dollar figures
about what it cost to remediate, obviously, this site is on
the low scale, as far as sites that are on the NPL, in the
actual work that it's going to take to remediate those
'....
SlL.es.
The site is still on the NPL, and will con-
tinue to be on the NPL until the E.P.A. has addressed the
concerns that have been identified, the site is remediated,
and monitoring is done for five years to show that those
actions have been adequate.
MR. TOMMY LEONARD:
If we had had these test results
in '86, would this have been placed on the NPL list?
MR. TAYLOR:
That's a question that really doesn't
have an answer, because sites are placed on the NPL uniform-
ly, without this kind of information.
And that's the whole
Original
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July 25, lS'~'.
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process; the whole reason for putting them on, so that
2
you'll find out which sites are a big problem, which sites
3
are a little problem, and which sites are no problem.
4
DR. AKIN:
They are put on there, based on the poten-
5
tial, and as Harold said, you really don't know until you
6
study it a little more.
This just triggers Federal funds to
7
be able to be used to study the site.
8
I've had sites that we had on the NPL for
MR. TAYLOR:
9
a nu~ber of years, we thought they were low priority and
we've gone in and done the remedial investigation and feas-
ibility study and it turned out that there's a lot different
problems than we thought.
I don't think this site is in that category.
I think -- the RFS has been done.
We're not saying it's a
Love Canal.
Ke're not saying it's the worse site in the
nation.
We're saying that these minimum requirements are
necessary to properly remove this site from the National
Priorities List.
If I could, if there ar~ no more questions --
MR. BOLTON:
I just had one question that I wanted to
ask.
I was somewhat surprised to see the list of signifi-
cant contaminants identified in the proposed plan, and I was
curious how that list determines, since it is based on ris}:
assessment, didn't identify many of these same contaminants,
here, and indeed, some were only tentatively identified.
Original
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July 25, L'
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MR. TAYLOR:
We thought, Miles, that basically, this
2
-- as you know, terms of frequently used different, depend-
3
ing upon their application.
We thought it was important for the public to
4
5
identify, basically, the compounds -- the wide range of
6
compounds that have been identified.
As you well know,
7
there have been a number of studies.
There was the study to
8
rank the site.
There was a study that was one, I think, as
9
There was a remedial investigation
a fOllow-up to that.
feasibility study that was done.
And ESD has done some work
in relation to the remedial investigation feasibility study.
50 I don't think that word,
'significant contaminants', as
far as the proposed plan, and the 'significant contaminants'
as far as the risk assessments are the same terms.
I think
the application is different.
We just wanted to inform the public that,
'Here is the broad range of contaminents that have been
identified in the past.
Not necessarily in the remedial
investigation feasibility study, but here is a wide range of
contaminants.
It may be important to identify those for
several reasons.
One, as you well know, we have a large
number of potentially responsible parties, here, tonight,
and we may go out to that site five years from now, and take
a sample and find something a little bit different.
Original
EPA RIfFS publ ic Mee':::- :
July 25, l~-'
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IN RE:
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But we just wanted to give a broad range of
2
contaminants that had been found and identify that to the
3
public.
4
Yes, sir?
5
MR. JOHN RAWE:
If
Again, a hypothetical question:
6
you went to Nashville, Memphis, Jackson, Columbia,
7
Fayetteville, Pulaski, Shelbyville, and tested their sani-
8
tary landfill, what kind of levels do you anticipate you
9
would kind of the two most hazardous and the highest levels
that you found in this site, being copper and DEHP, which
Dr. Akins stated is going to be there because of household
plastic waste.
DR. AKIN:
Could be.
MR. JOHN RAWE:
Could be.
Most likely is.
I:
Okay.
it's
in one
household waste, it's in all household wastes.
Why do we need to spend a million, two ~illic~
dollars on the Lewisburg site, and not spend it in every
other community that's got a sanitary landfill?
In the
original comments, out of the 21 chemicals, organic and
inorganic, that were identified as present in significa~~
amounts, only two were in a large enough quantity to war: :: .
clean up:
How can you justify it, th~.
Copper, and DEHP.
you only have to do that in Lewisburg?
MR. TAYLOR:
I don't think that is really what we':
saying.
Lewisburg was identified, early on, as at leas:
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potential, based upon it's location, the receptors around
2
it, the people using water, the karst topography.
It was
3
identified that there were receptors that were at risk.
4
We've identified hazardous substances at the site.
The
5
other sites -- at the same time, you know, to be quite
6
honest with you, there were other sites that were being
7
evaluated.
Somebody in the back may again correct me, but
s
there are actually thousands of sites in our inventory back
9
in the Region, and w~ only have 150 or so on the National
Priorities List.
Excuse me, Mike?
MR. HENDERSOl;:
On the surplus list.
MR. TAYLOR:
Yeah.
There are literally thousands of
sites that the State goes out and evaluates, or an E.P.A.
Contractor goes out and evaluates.
We may, in the future,
be talking about, you kno~, adding additional thousands cf
sites to the National Priorities List.
I guess the only real thing I can respond to
is based upon the conditions that we evaluated, and based
upon the place in time that we are, today, we are talking
about Lewisburg as opposed to -- back at the end of June, I
was' in North Hollywood in Memphis, and we were talking about
a sanitary landfill, there.
I'm going next week to Kentucky
to Elizabethtown, to Owl Valley site, which was an indus-
trial landfill.
MR. JOHN RAWE:
I know that you are limited with the
Original
EPA RI/FS Public Meet.:
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number of people to be able to do all of these investiga-
tions, but what my question is, based on the statements that
2
3
the group of you have made this evening, the Lewisburg site
is probably no worse in what is in it than any other site
4
5
that has accepted household waste, as far as the two pri-
6
marily contaminants.
Why does Lewisburg have to spend the
7
money to clean theirs up, and every other community that has
8
a sanitary landfill not have to do the same thing?
It just
9
doesn't seem just or fair or equitable, or any of those
words that you want to use.
It's on the list --
MR. HENDERSON:
The State of Tennessee recommended it.
MR. JOHN RAKE:
-- because it was suspected by the
State of Tennessee that there was a problem.
But that still
doesn't,
in my mind, justify the citizens of the city of
Le~isburg spending the money, when their neighboring cities
don't have to, because somebody did not say,
'Go look at
their site.
MR. TAYLOR:
Again, the site was ranked, based upon
" the criteria that was available to the agency, based upon
the mandate that Congress passed down to the Environmental
Protection Agency --
MR. JOHN RAWE:
What does it require to get you to in-
vestigate all of the other landfills within a hundred miles
of Lewisburg?
MR. HENDERSON:
It would have to be recommended by tr..-
Original
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State.
That's one of the things -- back to what you said
2
earlier.
One of the ways we find
We don't have the staff.
3
out about sites that are proposed are either through com-
4
plaints from citizens or by complaints from the states,
5
counties, et cetera', because we don't have the staff.
Maybe
6
if there were complaints from people in Memphis or com-
7
plaints from people in Nashville, and they complained to the
8
state, and the State or County Health department found prob-
9
lems and recommended it to E.P.A., then we would corne out
and look at it.
That's the only justification I can give
you for it, because we don't have the people to go around
and do it.
MI<-. TAYLOR:
We are in the process, as you may well
knov; ,
of mOdifying the hazardous ranking system that was
used for Lewisburg dump, and again, the stories vary so~e-
what from time to time, but there may be -- I know in the
Memphis area, we have estimated there may be 40 or 50
National Priority List sites that may rank, due to the ne~
hazardous ranking system.
We are here today, talking about Lewisburg,
and it's sort of like, you know, aSking the Tennessee St~te
Patrol why you got a ticket when you were going 75, when
there's people passing you going 75 while he writes you a
ticket.
Well, he generally tells you, you're the one that
he caught today, and he's here to correct the problem here
Original
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with you, today, and he'll catch the next guy tomorrow.
2
And that's generally, I think, what I'm here
3
to tell you today.
We have identified this site as a poten-
4
tial concern, we've addressed it, and these are the a1ter-
5
natives that we have corne up to address the problems that
6
we've found.
Yes, sir?
7
Edward Potts.
I have a couple of
MR. EDWARD POTTS:
8
questions.
I've tried to just stand and listen.
I'm
9
learning something new, here, and certainly agree with the
prospect that we hope that if we are going to have a better
world tomorrow; we won't mess it up.
But something does not
totally connect.
I'm hearing you say at one point that the pone
may be good for the whole site, because there has been no
damage to the ecological system in the pond.
In your report
you did not identify or address any carcinogenic risks in-
volved.
You did use the hazard index.
You did do that.
And I'm also understanding -- and I may be incorrect, here,
and please correct me if I am -- but that based on 11 years
of nonuse, we really don't have that degree of a situation
that would warrant further remedial action.
I'm hearing don't pump the pond out, because
it might be good to leave it there.
Something doesn't make
sense.
The fish are fine.
The fish are doing well.
50
apparently the copper is not hurting them~
Am I wrong?
Ar..
---------.---.------
uriginal
EPA RI/FS Public Mee~:~-
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I right?
2
MR. TAYLOR:
Well, again, I may solicit some help from
3
behind me, here, about the hazardous index on the question
4
you had earlier.
But I think what you are saying is that
5
you're asking the agency to, basically, -- the E.P.A:; the
6
United States Environmental Protection Agency -- to ignore
7
levels of contamination that we've found in past studies
8
are, in fact, detrimental to the environment or ecosyste~.
9
If we were to just say, well, we found these levels, and
we're just going to say nothing needs to be done, and we're
just going to clean our hands and walk away from the site --
MR. EDKARD POTTS:
Excuse me for interrupting, but I
don't believe anybody here is really suggesting that you
just ~alk a~ay, but yes, I'wouldn't want my children or my
grandchildren or the kids next-door, or whatever, going out
there and playing and digging.
Don't misunderstand
No, no.
that.
I'm not saying that, at all.
But what I'm hearing here is that, basically,
we have not found anything leaving the site.
It is staying
where it is, after 11 years, and the ecosystem in the pond
is okay, right now.
It's fine.
Eleven years later, it's
fine.
So why do we need to go through and stir it all up?
That's a puzzle to me.
It seems almost like we've got a
paradox here:
Yes, we ought to, because of the levels basej
on past history somewhere else are higher than norm.
That's
-- -.--"""
Original
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IN RE:
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probably what it amounts to.
Higher than norm.
Higher than
2
you like to see it.
Right?
3
THE COURT:
Elmer, could you answer that?
4
DR. AKIN':
Well, it's a little bit on the ecosystem.
5
We don't claim we've done a thorough evaluation of the
6
effects on the ecosystem in there.
There aren't any fish in
7
the lake, currently, other than just small fish.
Now, why
8
is that?
Is it that it was just never seeded, or is there
9
o
something -- there are indication that the copper may be
there in some concentration that could cause some problems.
The measure we use for effect would not be
killing fish, but some chronic effect on the fish.
So, the
copper may be there in concentrations that could have some
chronic effect on fish.
We have some real safe, conserva-
tive evaluations.
But r.ight now, we'll say, from our data we
have now, it is not enough to indicate that that ecosystem
is in really any dire circumstances.
Whether the site is stable or not: whether it
is as bad as it's going to get, I think, is really an open
question.
We don't know, really, how the contaminants that
are in that site that might leach out and be toxic to fish
are packaged, or if they would be, at some point in time,
rusted-out drums, or whatever.
You don't really know what's
going to or might create a change in the concentrations tha~
Original
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IN RE:
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might corne to that pond.
2
I think it's just that unknown, there, and the
3
fact that there are a few contaminants.
This DEHP, there is
4
some question on whether it's there or not, because it can,
5
as we've said -- well, I don't guess we have, but in the re-
6
pository of the full report, there, that may require some
7
additional verification that that compound is there.
That
8
compound is a cancer-causing agent.
You mentioned that we
9
don't have any carcinogens.
It is a carcinogen for animals,
if you have a~ ingestion over time: over a long period of
time.
So, there are just enough unanswered questions
that, being the conservative agency that we are required to
be, that we don't want to walk away from the pond and leave
it.
You said, yourself, you didn't want us to do that.
So
where would you feel that the -- where does it fall?
MR. EDWARD POTTS:
I think I'm back to another comment
that was made somewhere earlier, that maybe there's a point
in between number three and number one, especially with the
monitoring system.
I don't think anybody is trying to walk
away, here.
I mean, it's a situation that we all want to do
what's best for us, all the way around, because you don't
live here.
We've got to live here.
And we want it to be
safe.
But 'may be' and 'could be' and 'might be',
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and all of the words that we use to describe a situation in
2
the future that mayor may not happen, are not terribly --
3
Harold, would most of the costs be with
DR. AKIN:
4
stabilizing the landfill, itself?
Would
I guess, the cap?
5
that be where most of that cost will be; not in the pond,
6
itself?
7
No, that's not correct.
Most of the cost
MR. BOLTON:
8
is with the pond removal.
9
The pond removal?
Just getting that debris
DR. AKIN:
out of the pond?
MR. TAYLOR:
What we've identified is -- and if you've
been out there, or you can go out and look at the pond
debris.
There's a wide variety of things.
MR. ED"ARD POTTS:
I've lived here all my life.
THE COURT:
There is everything from appliances to
Styrofoam to empty drums, perhaps.
You know, we could spend
an awful lot of money out there investigating every little
drum tha~'s out there, to see if there is anything else in
it that's going to rust away, and get into the water.
We've
spent a lot of money out there, trying to excavate the sed-
iments and move them somewhere else.
We could spend a lot
of money filling that pond it.
things to do.
I mean, there's a lot of
.We are just here, and that is the alternative
that we've recommended.
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MR. EDWARD POTTS:
Well, as I understood it -- and
2
excuse me for interrupting, again, but as I understood it,
3
this was the purpose of this meeting was to elicit comments
4
from the public.
5
That's what I was just about to say.
The
MR. TAYLOR:
6
purpose -- I mean, we haven't selected a final plan.
7
Right.
MR. EDWARD POTTS:
8
We've just said that this is the plan
MR. TAYLOR:
9
that the E.P.A. Thi~ks is a combination or sort of a ...
considering everything that we could do, we think it's the
pro?er thing to do.
MR. EDWARD POTTS:
Who finally decides.
MR. TAYLOR:
The regional administrator of the E.P.A.,
Greer Tidwell, will sign a record of decision.
MR. EDKhRD POTTS:
I mean, does he decide or does he
just sign the record; the final document?
MR. TAYLOR:
We'll go up and brief Mr. Tidwell on all
of the concerns, and he'll weigh those.
MR. HENDERSON:
Your decision is made through an eval-
uation of the oral comments, here.
The written comments.
There is a 30-day public comment period, which started today
and it ends on the twenty-third of August.
You take those
comments, comments from the State, comments from anybody who
is interested in this site, and you put all of those toge-
ther with the information that we presently have, and you do
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an entire evaluation of all of it, and then you make a re-
£
commendation to the regional administrator.
3
MR. EDWARD POTTS:
You put it altogether?
Who is the
'you'?
5
MR. HENDERSON:
The remedial project manager, Douglas
6
Bell.
7
Okay.
He puts it all together, and
MR. EDWARD POTTS:
8
he makes a selection, and he recommends it?
9
He makes a recommendation to, basically,
MR. TAYLOR:
myself, and I carry that up my chain to my supervisor, and
we brief his supervisor.
It is about four or five levels
that it will go through, before it gets to Mr. Tidwell.
DR. AKIN:
Howard, you might mention the trustee's
role.
I~R. TAYLOR:
There are a number of -- you kno~, ~itt~~
the E.P.A., there's a number of, even outside, agencies
that
will review the decision that we make, and one of those is
the Fish and Wildlife Department of Interior.
I'll be h~:-.-
est.
They are concerned with that pond, and what we are
selecting for the pond.
MR. EDWARD POTTS:
I'm glad we didn't know about t:-..
when I was a little kid, swimming in it.
That's just
terrible.
MR. TAYLOR:
You know, all I'm trying to say is t~.:.
we are trying to balance a number of inputs from diffe~. . .
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and sundry people, and all of them are not saying that this
2
is conservative enough.
Some are actually saying, you know,
3
you need to go in and fill that pond in.
You need to go in
4
and pull the sediments out.
You need to solidify the sedi-
5
ments, and bury them somewhere else.
6
This is -- you know, the plan that we've put
7
forth to you tonight is just based upon all of the input
8
we've received.
It's what we think is adequate to continue
9
on with the site.
It's not the most conservative thing that
we could think of or that has been put forth to us.
It is
not the most liberal.
It's not -- you know, it's not just
ignoring the fact that it's there, and walk away.
We just
. .
think that, based upon the conditions that we've seen, it's
the most reasonable alternative to select for the site.
MR. HENDERSON:
And at this point, it's not written in
stone.
This is why we have the comments.
MR. TAYLOR:
Comments may be that more needs to be
done at the site, and that's what will be in the record of
decision.
Some comments may be that there's less that needs
to be done.
Yes, sir?
Your name, please?
MR. WALLACE CATHY:
Wallace Cathy.
I have one ques-
tion.
Has a dye test been run to tell whether the pond is
leaking or not?
MR. TAYLOR:
There has not been a dye trace done.
I
,mean,
obviously, the pond -- based upon what I've heard and
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the evaluations that have been done, the pond stays at a
2
fairly constant water level, now.
It doesn't fluctuate
3
greatly, from day to day, which would indicate to me that
4
there is, you know, a conduit for the water to leave that
5
pond, since it does have infiltration from the surface
6
during heavy rains.
7
There has not been a dye trace study done.
That's one of the things that we are proposing that should
8
9
be done so that we can properly locate monitoring stations,
so that we don't have to run around and sample all of-those
sinkholes and all of those potential conduits.
It is just
another mechanism to try and find effective monitoring
points.
MR. RAY BROOKS:
Can I make one comment, please?
NR. TAYLOR:
Yes, sir.
Your name, please?
MR. RAY BROOKS:
Ray Brooks.
I agree with what the
other fellows are saying here.
We've got a thing that's
setting there for 11 years.
Nobody's got sick, to my knowl-
edge.
Nobody's died.
The fish seems to be very healthy.
And a lot of people are going to get hit in the back pocket
for -- I don't know -- something that just seems to don't be
bothering nobody.
I may be wrong, but I don't know of any-
body that's got sick.
I don't know of anybody that's died.
And if you didn't know it was out there, you know, you woulj
think it was just another fishing pond.
i
'..
\1
,
/1
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MR. TAYLOR: . Well, that's more of a comment than it is
2
a question.
3
MR. RAY BROOKS:
It is a comment.
4
Again, we think that, based on the condi-
MR. TAYLOR:
5
tions that we evaluated, that it is more conservative; it's
6
a safe thing to do to go out and take measures to remove
7
what we think are potential problems with that pond.
8
One of the reasons that this is done
MR. HENDERSON:
9
is, if you look at a'lot of studies, when they talk about
cancer,
or whatever, they'll say,
based on you, say,
,
. . .
smoking so many pack of cigarettes and you're doing this'
over a period of 70 years, it'll cause you cancer.'
E.P.A. i~ basically a preventative agency.
We're saying that if something says if you do this "X"
amount of years, it will kill you, or it will do this,
we're
saying that we can't take the chance to wait 70 years to
find out if you die.
That's basically what we are; a
preventative agency.
We can't take the chance.
MR. BELL:
Also, I would like to add one comment to
that.
The contaminants may have been there for 11 years and
they may have not been causing, let's say, the pond or dow~-
graded receptors any harm.
But the condition of the land-
fill is deteriorating.
And as time goes on, if somethin9
isn't done, more and more water will get into that landfil1
at an increased rate, and there is a potential for increased
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leaching.
So there is that potential that we could increase
2
the number or the quantities of contaminants coming out of
3
.that pond.
There, again, that's something that, in order to
4
be conservative; in order not to take the risk, something
5
should be done to upgrade the condition of the landfill.
6
Yes, sir, Mr. Potts?
MR. TAYLOR:
7
A comment to your statement:
MR. EDWARD POTTS:
8
Wouldn't that be the purpose of the monitoring wells to see?
9
Well, we have already identified, in many
MR. BELL:
test pits out there and many soil samples and many ground-
water samples, that we've got the contamination.
In order
to do the die trace --
MR. EDWARD POTTS:
I think you misunderstood.
MR. BELL:
Okay.
MR. EDWARD POTTS:
You are saying in order to keep it
from deteriorating further, where the levels migrated off-
site, you would take the conservative road, now, rather than
take a chance on that it might happen.
And what I was say-
ing is that not the purpose of the monitoring wells, so that
you can see if that is happening, and then come back for
more remedial action?
DR. AKIN:
Wait and see.
Monitor and wait and see is
what you are saying, rather than doing something now?
MR. EDWARD POTTS:
Well, once again, I'm not saying
don't do anything; don't just totally ignore it.
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MR. TAYLOR:
I think what we said with the monitoring,
2
I think you're right.
I mean, E.P.A. has said that general-
3
ly -- if we were to choose a no-action alternative or even
4
the action that we're choosing, today, and we are still go-
5
ing to leave hazardous constituents on-site.
There's no --
6
we're not suggesting that we remove those and incinerate
7
them or remove them and stabilize them or remove them and
8
haul them off, somewhere else.
So we are saying that, real-
9
ly, at a
minimum,
yes, you would have to monitor for five
years to see, you know, what -- if we did choose the no-
action alternative, we would have to monitor for a minimum
of five years to make sure that was a wise decision.
Basically, with any of those alternatives that
wouldn't remove the constituents, we would have to monitor
it.
if tha":
And that's one of the alternatives.
You kno..;,
is your comment, that you'd like to see alternative one
chosen,
I would like to hear that.
MR. EDWARD POTTS:
I would not like to see alternative
one,
no action.
I'm not saying that, and that's what I
tried to impress a while ago.
I'm trying to say that there
is .something in between one to three, with monitoring and
the institutional controls, certainly.
I think it needs to
be an enclosed area.
But perhaps not completely capped and
removing all of the debris.
MR. TAYLOR:
Again, let me -- and I think there is
Original
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IN RE:
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some debate, here, obviously, amongst the group.
But one of
2
the reason we are choosing alternative three or proposing
alternative three, tonight, is again, State and Federal
3
4
requirements that we need to meet.
There is some contamina-
5
tion in the pond, 'now, that is abova some of the State and
6
Federal statutes.
There is hazardous constituents in the
7
landfill, and there is a cap with, right now, 14 test pits
that have been dug into it, and there is only PVC or a thin
8
9
layer covering the cap.
There is some spots in the cap that
we need to evaluate to make sure they are draining properly"
and I think remove some of the trees that may penetrate the
cap.
So again, I think we're saying that just alternative
two is not adequate to meet those standards.
That we do
need to go a little bit further.
MR. EDWARD POTTS:
Let me clarify, one more time.
I'm
saying there is something between one and three, and that
doesn't necessarily mean two.
okay?
You haven't addressed
a particular remedial action that I'm saying, and I'm not
saying that I know everything there is to know about land-
fills. Certainly, I do not. But it appears to me that
there is something less than three. Let's put it that way.
THE COURT: Miles, if you could?
MR. BOLTON: Yeah. I could mention that the Lewisburg
Environmental Response committee is also thinking along
those same lines, as well.
Some new evidence has come in
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that indicates that the copper may not be as significant an
2
environmental impact as previously thought, and so, there is
3
at least some consideration that maybe something along al-
4
ternative two, which would also include upgrading the land-
5
fill cap, and including monitoring.
That type of thing.
6
And that is between one to three.
That is being considered.
7
MR. TAYLOR:
And we are open for those suggestions,
8
and I mean, we haven't closed our mind, and that's the
9
purpose of the meeting tonight is to solicit those from
PRPs, from citizens, from environmental groups,
from anybody
that would like to submit comments, and we will consider
those and respond to those~
And if be find a good alterna-
tive that we think will be protective of the public health
and environment and meet the State and Federal requirements,
then we would select that alternative.
MR. HENDERSON:
Before you go, make sure, if you
haven't, sign the sign~in sheet, and get those envelopes, if
you want to send comments.
The postage has been paid.
I
mean, the stamped self-addressed envelopes are back there.
They. are for your use.
Make sure you get them.
MR. TAYLOR:
If there are no further questions, I ap-
preciate you coming tonight, and if anybody has a question
or would like to talk to us, we'll be. here for a while.
(The meeting ended at 9:19 P.M.)
[DOCUMENT ENDS]
Original
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Jul¥~f5, 1990
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" REPORTER'S CERTIFICATE - CIVIL
STATE OF TENNESSEE
ss.
COUNTY OF MARSHALL
I, the undersigned, James Leonard Hobby, C.C.R.,
Official Court Reporter for the Twenty-Second Judicial
District, Division II, do hereby certify that the foregoing
is a true and accurate Reporter's Transcript of the proceed-
ings had in the matter of:
RI/FS PUBLIC MEETING CONCERNING THE
LEWISBURG TENNESSEE DUMP SUPERFUND SITE,
during said Public Meeting, held by the US-EPA in Lewisburg,
Tennessee on the twenty-fifth of July, 1990.
I do further certify that I am neither of kin nor
counsel to any party hereto, nor do I hold any" financial
interest in the outcome of this matter.
WITNESS my hand and seal this fi st of August, 1990.
original
EPA RI/FS Public Mee::~:
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