United Stales
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04.87/021
March 1987
Superfund
Record of Decision
Newport Dump Site, KY
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TECHNICAL REPORT DATA
iPleaie read Instruction! on the reverse before completing)
1. REPORT NO.
EPA/ROD/R04-87/021
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Newport Dump Site, KY
First Remedial Action
5. REPORT DATE
March 27. 1987
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME ANO AOORESS
10. PROGRAM ELEMENT NO
11 CONTRACT/OR AN T NO
12. SPONSORING AGENCY NAME ANO AOORESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT ANO PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Newport Dump site is located on the Licking River, a tributary of the Ohio River,
in the City of Wilder, Kentucky. The site was originally purchased by the City of
Newport in the late 1940's and was used by the City for the-disposal of residential and
commercial wastes from its opening until its closure in 1979. Trenching and area
filling of the waste were the most common methods used to dispose of waste at the site.
In 1968, the Commonwealth of Kentucky instituted permitting requirements for landfills.
The City of Newport received a permit in late 1969 to operate the site as a municipal
sanitary landfill. The site was closed in 1979 and ownership was transferred to the
Northern Kentucky Port Authority (NKPA) the same year. During the life of the landfill,
the City was cited on numerous occasions for operational violations and for handling
hazardous waste without a permit. The contaminated media includes: ground water, and
soil. The primary contaminants of concern include: metal, PAHs, solvents, and PCBs.
The selected remedial action includes: implementation of a multi-media monitoring
program; restoration and extension of leachate collection system; restoration,
regrading, and revegetation of existing clay cap. Further actions will depend on the
monitoring analysis results. The estimated capital cost for this remedy is $516,000
with estimated annual 05.M costs for the first 3 years of £63,000 and for years 4 through
30 of $35,000.
17.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Newport Dump Site, KY
First Remedial Action
Contaminated Media: gw, sediments, soil
Key contaminants: arsenic, barium, chromium,
nickel, benzo(a)pyrene, polychlorinated
biphenyls, toluene
T DISTRIBUTION STATEMENT
19. SECURITY CLASS I Tins Reporti
None
21. NO. OF PAGES
80
20. SECURITY CLASS iTIiispage/
!?. PTICE
EPA Form 2220-1 (R«». 4-77)
PREVIOUS EDITION IS OBSOLETE
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RECORD Of DECISION
Remedial Alternative Selection
SITE; Newport Dump Site
Campbell County, Wilder, Kentucky
DOCUMENTS REVIEWED:
- Newport Dump Remedial Investigation
- Newport Dump Feasioility Study
- Newport dnip Endangerment Assessment
- Responsiveness Sunmary
DESCRIPTION OF SELECTED REMEDY;
- Mai tilled! a Monitoring Program
- Restoration and extension of leacnate collection systen
- Restoration, regrading and revegetation or existing clay cap
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Declarations^
The selected remedy is consistent with the Comprehensive Envirornental
Response, Compensation, and Liability Act of 1980 (CERCLA), Superfund
.Amendments and Reauthorization Act (3.ARA)(PL 99-499, October 17, 1986)
and the National Continaency Plan (40 CFR Part 300). I have determined
that the monitoring, regrading, revegetation and leachate collection at
the Newport Dump site is a cost-effective remedy and provides adequate
protection of public health, welfare, and the environment. The State
of Kentucky Department of Environmental Protection has been consulted
and agrees that the approved remedy meet applicable relevant and
appropriate State standards and requirements. Future operations and
maintenance activities to ensure continued effectivess of the remedy,
will be considered part of the approved action and portions there of
may be eligible for Trust Fund monies for a period of up to one year.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies at other sites.
In addition, the monitoring, regrading and leachate collection is more
cost-effective than other remedial actions and is necessary to protect
public health, welfare and the environment.
Date ' Jack E. Ravan
Regional Administrator
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NEWPORT
DUMP SITE
CINCINNATI
NEWPORT
OHIO
SO 100 160
MILES
REGIONAL. INDEX MAP
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE 1
IMUS
CORPORATION
A HaJiibi irtnn Company
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flNKl flfii:
KINTON
COUNTY
WATIN
INTAKI,
/ /
IHCTHIC
TRANSMISSION
UNI
BANKLICX MOAD
AUTO PANTS
IAMOPILL
LIQINO
APPNOXIMATI
SITf IOUNOANY
JOU.I
JCC «10
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
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SITE LOCATION AND DESCRIPTION'
The 39-acre former municipal landfill is located at latitude 30° 3' 44"
and longitude 34° 30' 17" in the City of Wilder (population 633) in
CamDbell County, Kentucky (see Figure 1). The City of Wilder is located
about three miles south of the City of Newport, a suburb of Cincinnati, Ohio.
The main road leading to the site is State Road 9. Access to the site is
by way of Banklick Road, which terminates at the entrance of the landfill.
The site is bounded on the west by the Licking River, a tributary of the
Ohio River; on the north by a small industrial Park; on the east by
steep outcrops and State Road 9; and on the south by an unnamed stream
(see Figure 2).
The Newport Dump site is located on the Licking River, a tributary of the
Ohio River. Approximately 250 feet downstream of the site on the opposite
bank of the river is the main raw water intake for the Kenton County
Taylor Mill water treatment plant. The water plant withdraws up to 18
million gallons per day C1GD) from the Licking River and serves about
75,000 consumers in Kenton and Boone Counties. An unnamed stream forms
the southern boundary of the landfill and drains to the Licking River.
Flow in the stream is intermittent, with the greatest flow during periods
of high runoff.
The site is underlain by unconsolidated alluvial deposits. The alluvium
consists primarily of clay, silt, sand, and gravel in a downward coarsening
sequence. The thickness of the unconsolidated material ranges from 36
feet at the eastern end of the landfill to about 110 feet at Licking River.
Below the alluvial deposits is a shale and limestone bedrock reported to
be up to 250 feet thick.
The topography of the site consists of two distinct areas. The lower
river terrace occupies the areas adjacent to the river and is frequently
flooded. The second level is separated from the lower terrace by an area
of steep slopes and includes the landfilled portion of the site.
SITE HISTORY
The site was originally purchased by the City of Newport in the late
1940's and was used by the City for the disposal of residential and
commercial wastes from its opening until its closure in 1979. Trenching
and area filling of the waste were the most common methods used to dispose
of waste at the site.
In 1968, the Commonwealth of Kentucky instituted permitting requirements
for landfills; and after being in violation, the City finally received a
permit in late 1969 to operate the site as a municioal sanitary landfill.
The site was closed in 1979 and ownership was transferred to the Northern
Kentucky Port Authority (NKPA) the same year.
-1-
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During the life of the landfill, the City of Newport was cite-:! on nir^erous
occasions by the Kentucky Department of National Resources and Environmental
Protection (KDNREP) and other state agencies for oenit violations. The
nost freouent violations included: open burning at the landfill, absence
of daily cover, onsite oonding of water, uncovered refuse, inadequate
security, presence of leachate, lack of proper seeding, and erosion
problems due to lack of-vegetation. In addition to being cited for
operational violations, the City has also been cited for handling hazardous
waste without a permit.
Due to the inadequate management of the landfill, an Agreed Order, between
the City of Newport and the Kentucky Natural Resources and Environmental
Protection Cabinet (Cabinet) to prepare a final closure plan for the site
was issued on September 26, 1978. The final closure plan, however, was
never fully implemented and ownership of the landfill was transferred on
December 28, 1979 to the NKPA with the understanding that the NKPA would
remediate the site. Due to the transfer of ownership, the NKPA was
obligated to prepare a final closure plan. An .Agreed Order between the
Kentucky Cabinet and NKPA was issued on July 9, 1980, formally reouiring
th NKPA to properly close the former Newport waste disposal facility. In
an effort to coroly with the .Agreed Order, the NKPA installed a leachate
colletion system, regraded portions of the site, installed a clay cap
over the waste, and seeded the area with grass.
Lack of adequate funding, however, resulted in the NKPA not being able to
fully implement the July 9, 1980 Agreed Order. Cited violations against
the NKPA since the Agreed Order include: lack of .maintenance of the
leachate collection system and collection tank, lack of vegetation and
erosion of parts of the landfill, failure to install a methane gas vent
system, and failure to conduct a leachate monitoring program. Site
inspections by Kentucky DNREP personnel during the partial closure of the
landfill have noted the occurrence of several leachate breakouts leading
toward the Licking River.
Since the NKPA did not fully implement the Agreed Order, a new Agreed
Order was entered into by the Kentucky Cabinet and the NKPA on October 30,
1984. In accordance with the requirements established under CERCLA, the
Newport Dump Site was evaluated by EPA in 1982 utilizing the Hazard Ranking
System (HRS). The HRS was used to evaluate the relative risk or danger
factors existing at the Newport Dump Site, taking into account the population
at risk, the hazardous potential of the substances at the facility, the
potential for contamination of drinking water supplies, and for destruction
of sensitive ecosystems and other appropritate factors.
The Newport Dunp Site overall HRS score was 37.69, which ranked the site
number 359 in Group 8 on the National Priorities List (NPL). The site
received this ranking due to the close proximity of .the Kenton County
District One raw water intake located approximately 250 feet downstream
from the site on the Licking River, the observed release of leachate to
Licking River, and the oresence of elevated concentrations of lead,
chromium, and PCBs in leachate samples.
-2-
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The Renedial Action Master Plan (RAMP) was developed by Cam, Dresser,
and McKee, Inc., et al., in 1933 and MUS began the RI/FS in 1935.
MIS conpleted the RI site investigation in March 1986, and submitted a
draft RI/FS report in Nover.be r 1986. The RI assessed the nature and
extent of onsite and offsite contamination, and evaluated hazards to hunan
health and the environment. The goals of the data collection activites were:
0 Location of approximate fill boundaries through che application of
geophysical techniques
0 Assessment of the levels of groundwater contaminants and potential
pathways in the alluvial aquifer
0 Determination of levels of contaminants in surface and subsurface soils
0 Determination of levels of contaminants in the Licking River and
an unnamed stream south of the site and the potential for contamination
of surface water at the raw water intake
0 Evaluation of the effect of leachate on aquatic organisms
The major concern at the site was leachate migration to nearby surface
water bodies. These surface water bodies include the unnamed stream
forming the southern border of the site and the Licking River, a tributary
of the Ohio River, bordering the western edge of the site. The surface
water contaminant migration pathway was examined by collecting surface
water and sediment samples at six locations in the unnamed stream and
five nearshore locations in the Licking River. Many of these sampling
points were also paired with shallow groundwater sampling points to
evaluate the potential groundwater contribution to surface water. Details
of the remedial site investigation and laboratory analyses are documented
in the RI report.
CURRENT SITE STATUS
The approximate boundary of waste materials encompasses an area of 32.2
of the 39 acres that form the site. Based on disposal practices, this
area has been separated into an eastern and western section, broken by the
location of the culvert traversing the site. Since the majority of the
landfilling operations are conducted in the western section, the bulk of
the wastes and contaminated soil lies within this area.
Rough estimates of the volume of contaminated material suggest that
approximately 1,078,000 cubic yards of waste may exist and that 60 percent
of this material is constrjction rubble, scrap metal, and tires.
Investigations conducted during the RI indicated that the natural materials
beneath the landfill consist predominantly of low-permeability clays.
-3-
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Calculations based on data collected during the RI suggest that the
Horizontal groundwater flow velocity is 4.4 feet per year, while the
vertical flow velocity is only 0.05 feet per year.
The thickness of the alluvial aouifer at the site varies between 37 and
63 feet and thins toward the valley walls. Samples of the deeper
groundwater, collected during the RI from monitoring wells set directly
above bedrock, contained no significant levels of contamination. Samoles
of the shallow groundwater beneath the site contained metals, solvents,
and PAHs. The shallow groundwater is expected to be released as leachate
seeps or as groundwater discharge to Licking River.
The presence of leachate seeps has been noted throughout the life of the
landfill. Early attests to control the discharge of leachate to Licking
River and the unnamed stream resulted in the construction of collection
trenches or berms on the west and south landfill slopes. Most of the
effects of the past release of leachate have been eliminated as a result
of the regrading and capping performed by the NKPA during closure; but
the early collection trench along Licking River remains.
The NKPA also installed a leachate collection system on the west and
south banks of the landfill during the closure activities. However, this
system is not working properly either due to clogging or collapse as a
result of subsidence of the waste material. In addition, the NKPA
closure activities did not address the steep banks along the north slope
of the landfill just east of the Ceramic Coating Company. This area is
heavily vegetated, with erosion gullies and numerous active leachate seeps.
Shallow groundwater, not released as leachate seeps, is expected to
discharge directly to the Licking River. As part of the RI, the groundwater
dilution rate in the Licking River was calculated to be over 40,000 to 1
even under the lowest flow rate available for the river. Since a surface
water intake for the Kenton County Water District is located 250 feet
downstream of the site, surface water and sediment samples were collected
from the unnamed stream and the Licking River as well as two water samples
from the intake.
The results of the chemical analyses indicated that the levels of
contaminants in the water withdrawn from the intake were below all accepted
drinking water criteria, and that site contaminants did not appear to
have any affect on the quality of the water in Licking River.
The main receptors for contaminant releases from the site are the 75,000
residents served by the Kenton County water intake. Approximately, 1,200
individuals live within a one-mile radius of the site, but no private or
public drinking water wells were found within this area. The potential
receptors include those eating fish caught for recreation from the Licking
River. Public access to the site is currently uncontrolled; however,
there does not appear to be any recreational use of the site.
The. public health evaluation performed during the RI found no evidence of
any current public health or environmental concerns associated with the
Newport amp Site.
-4-
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The contaminant levels in the surface soils and in surface water and
sediment downstream of the site were below all accented health criteria;
while dilution of shallow groundwater contaminants as a result of discharge
to the Licking River is expected to reduce these contaminants to negligible
levels.
FLOOD POTENTIAL
Following major floods, the Army Cores of Engineers measures the eleva-
tions of high water marks at various points along the river. Interpolating
from known elevations, the projected high water marks on the Licking River,
dating to at least 1875, are as follows (Army Corps of Engineers, 1986b):
Elevation
Flood (ft amsl)
January 1937 511
March 1964 500.5
April 1948 495
May 1961 491
Channel velocities during floods are on the order of five feet per second,
with local velocities of eight feet per second. Having never inspected
the study areas, and because the potential for erosion is site-specific,
the Army Corps of engineers offers no recommendaitons concerning the
erosion potential of the riverbank near the site.
Flooding near the study area is increased by backwater flooding from the
Ohio River. Therefore, the site benefits from flood reductions on the
Ohio River due to operation of 52 flood control reservoirs on the Ohio
River tributaries upstream from the Licking River.
Flooding of the Licking River is also reduced by operation of the Cave
Run Flood Control Lake, completed in 1975, which regulates a drainage
basin of 826 square miles. The .Army Corps of Engineers (1986) flood
elevations were used to illustrate the areas of the site expected
to be inundated by the 500-, 100-, 50-, and 10-year floodwaters. These
areas are shown in Figures 3 throuah 6, respectively.
NATURE AND EXTENT OF THE PROBLEM
As specified in the National Contingency Plan (NCP), the RI was designed to
define the nature and extent of the threat to public health and the
environment presented by the release of hazardous substances at or near
the Newport Dump Site. To accomplish this goal, waste and soil samples
were collected from several locations on or near the landfill. All
samples were analyzed for the hazardous substance list (HSL) of contaminants,
however, only the specific comoounds detected at least once in their
respective media are presented in the tables. Based on the results of
these analyses, an attempt was made to characterize the types and levels
of contaminants in the waste and leachate to determine whether migration
of site-linked contaminants has occurred or is likely to occur.
-5-
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The results of the chemical analyses of waste and soil sarples are presented
in this seciton. Sa^ole cole desciptions and field measurement data (pH,
specific conductance, and temperature) for all samples collected during
the investigation -nay be found in Appendix D of the RI/FS document.
WASTE SOURCE
During the .RI, samples of the waste material were collected and analyzed
to determine the chemical characteristics of the waste. The waste material
immediately beneath the clay cap and the subsurface soil below the waste
were sampled at four borehole locations within the landfill. The four
onsite and one offsite borehole locations are shown on Figure 7, and
the chemical characteristics of the waste are shown in Tables 2 and 3.
Data have been combined with the data from previous studies and the waste
thickness at each location is shown on Figure 8. The available waste
thickness shown in Figure 8 support the current understanding that the
depth of fill is extremely varied throughout the site. Since an approximate
volume of waste is necessary for costing purposes, the known depths of.
waste were used to provide an average waste thickness for each section of
the landfill. The estimated total waste volume is 1,078,000, based on
118,000 cubic yards in the eastern section plus 960,000 cubic yards in
the western section. This volume of waste should be considered as only
an approximation since the actual waste volume at the site is unknown.
WASTE COMPOSITION
The waste samples collected beneath the cap (SS-2A, SS-3A and SS-4A)
contained a wide variety of inorganic and organic contaminants. The most
common constituents consisted of metals, P.AHs, various solvents, and
PCBs. The highest concentrations were found in samples collected from
boreholes SS-3 and SS-4, west of the culvert. PCBs and ODD were the only
chlorinate hydrocarbons detected in the waste material, and they were
only observed in the waste sample (SS-3A) collected just west of the
culvert. Borehole samples taken below the waste material evidenced no
significant levls of contamination. It is reasonable to assume that very
little downward migration of contaminants has occured.
Additionally, no significant contaminant levels were detected in the
offsite subsurface soils but a low level of toluene was detected near the
Ceramic Coating Company. This indicates that the site contaminants have
not migrated significantly in the subsurface soils.
GROUNDWATER CONTAMINATION
A subsurface investigaiton was designed and implemented as part of the RI
for the Newport Dump Site. The design of the investigation included the
completion of 14 soil borings with the installation of 8 monitoring wells
and 3 piezometers in some of the boreholes (see Figure 9).
-6-
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FINAL GRAFT
tg
{'•::.'• ::?-:;Jj
"••"•?:>}/?•
/.•*•.••*•"/•/•/•
TMAMSMiSSlON
LINE
?!
sl
? s ?•%
LEGEND
AHIA INUNDATED §Y
800-YIAH FLOOD
1OLH
0 ISO 100 4»0
500-YEAR FLOOD LEVEL (510 FEET)
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
IMUS
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AMIA INUMOATED iY
100-TEAM PLOOD
100-YEAR FLOOD LEVEL (103.8 FEET)
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
r
—M .
IMUS
-
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Aft!A INUNDATED IT
SO-VIAN FLOOD
50-YEAR FLOOD LEVEL (500 FEET)
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
NUS
-------
/#::•"•::/••../*
/ * .. • * • * / •«•& •** /* , ' '
AMflA INUNOATIO IT
10-YEAR FLOOD
10-YEAR FLOOD LEVEL (402 FEET)
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
IMUS
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KINTON
COUNTY
WATt*
IHTAKI,
f .ICTftIC
TNA 4SMIMION
UNI
BANKLICK ROAD
, . UNNAMfO
, STftlAM
LEGEND
X SAUPLINa LOCATIONS
JCU.I
JO JOO OO 100
WASTE AND SUBSURFACE
SOIL SAMPLING LOCATIONS
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE 7
NUB
A HaHtourton Company
-------
KINTON
COUNTY
WATIM
INTAKE,
E .ECTftIC
TRA 4CMISSION
LINE
L2QEND
7 -WASTE THICKNESS IN FEET
XJU.I
0 '50' SCO' 410' 100'
WASTE THICKNESS
NEWPORT DUMP SITE
CAMPBELL COUNTY. KENTUCKY
FIGURE A
IMf
RATXDfN
A Halliburton Company
-------
KINTON
COUNTY
WATIft
INTAKI/
BANKLICK ftOAO
LEGEND
MONITORING WELL LOCATION
PIEZOMETER LOCATION
A SOIL BORING LOCATION
JCAtl
MO'
«00'
SOIL BORING LOCATIONS
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
NUS
A Hallih* irtort Company
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TABLE 2
INORGANIC RESULTS OP SUBSURFACE SOIL SAMPLES
ONSITB WITHIN WASTE MATERIAL
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
i-.,.
Offsite Control
Onsite Waste
PARAMETER (MG/KG)
SILVER
ARSENIC
BORON
BARIUM
BERYLLIUM
CADMIUM
COBALT
CHROMIUM
COPPER
MOLYBDENUM
NICKEL
LEAD
ANTIMONY
SELENIUM
TIN
STRONTIUM
TELLURIUM
TITANIUM
THALLIUM
VANADIUM
YTTRIUM
ZINC
ZIRCONIUM
MERCURY
ALUMINUM
MANGANESE
CALCIUM
SS-1A
5 FEET
11/85
_
UJ
NA
200J
1.7
-
^ f
* V
7.0
28
NA
61
15
R
-
R
NA
NA
NA
R
43
NA
97
NA
R
20,000
480J
21,000
SS-1B
10 FEET
11/85
—
11J
NA
88
1.4
-
\.i
18
19
NA
33
15
R
-
R
NA
NA
NA
R
27
NA
71
NA
R
14,000
580J
19,000
SS-1C
15 FEET
11/85
__
9J
NA
130J
-
-
K
R
22J
NA
26J
18J
-
-
NA
NA
NA
NA
R
22J
NA
70 J
NA
-
12.000J
R
15.000J
SS-2A
6 FEET
11/85
_
12J
NA
140
-
5
-
27
22J
NA
19
140J
R
-
31JN
NA
NA
NA
-
20
NA
160J
NA
0.29J
13,000
700
24,000
SS-3A
8 FEET
11/85
__
-
NA
390J
-
-
-
-
100
NA
57
340J
R
R
72J
NA
NA
NA
-
-
NA
540J
NA
0.76J
17,000
610J
5,500
SS-4A
6 FEET
11/85
_
10JN
NA
740
-
9
-
150
620J
NA
120
2,600
R
-
140JN
NA
NA
NA
-
-
NA
1.200J
NA
3.9J
10,000
870
76,000
SS-5A
11 FEET
11/85
_
-
NA
-
-
-
-
-
-
NA
46
21J
R
R
-
NA
NA
NA
-
-
NA
-
NA
0. 16J
21,000
790J
-
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TABLE 2
INORGANIC RESULTS Of SUBSURFACE SOIL SAMPLES
ONSITB HITBIN HASTE MATERIAL
NEWPORT DUMP SITE
CAMPBELL COUNTY, KEHTOOT
PAGE TWO
Offsite Control
Onsite Waste
PARAMETER (MG/EG)
MAGNESIUM
IRON
SODIUM
CYANIDE
POTASSIUM
Material was analyzed
J Estimated value
N Presumptive evidence
NA Not analyzed
R Data unuseable
SS-1A
5 FEET
11/85
9,800
35,000
99
-
3,200
for but not
of presence
SS-lfi
10 FEET
11/85
9,400
22,000
71
-
2,400
detected above
of material
SS-1C
15 FEET
11/85
3.600J
34,OOOJ
'80J
NA
1,600J
the ainiaua
SS-2A
6 FEET
11/85
7,200
34,000
-
-
quantitation
SS-3A
8 FEET
11/85
6,300
46,000
720
R
3,OOOJ
limit
SS-4A
6 FEET
11/85
15,000
69,000
-
l.OJ
1,500
SS-5A
11 FEET
11/85
4,300
33,000
-
R
3.300J
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TABLE 3
ORGANIC RESULTS Of SUBSURFACE SOIL SAMPLES
ONSITE WITHIN WASTE MAIERIAL
NEWPORT DUMP SITE
CAMPBELL COUNTS, KENTUCKY
Offsite Control
Onsite Waste
PARAJCTER
( MS/KG )
S3- LA
5 cEET
11/85
SS-iB
10 fEET
11/85
SS-1C
15 FEET
11/85
SS-2A
6 fEET
11/85
SS-3A
d fEET
11/85
S5-4A
6 FEET
11/85
SS-!
11 F
11/5
EXTRACTABLE AND MISCELLANEOUS
CCMPOUNDS
1, 2, 4 -TRICHLOR08ENZ END
2-METHYLNAPHTHALENE
ACENAPHENE
ALKANOIC ACID
\LKYL ACIDS/NO.
. .NTHRACENE
BENZO (E) PYRENE
BENZO (GHI) PERYLENE
BENZO( A) ANTHRACENE
BENZO( A) PYRENE
8ENZO(B AND/OR K) FLUORANTHENE -
BEZYL 8UTYL PHTHAIATE
BIS(2-£THYLHEXYL) PHTHAIATE
BUTYL 2-METHYLPRDPYL POTHALATE -
CARENE
C15 ALKENE 92 ISCMERS)
C3 ALKYLBENZ.ENE
ALKYLPHENANTHRENE
CKRYSENE
79J
5,OOUJ
190J
160J
26UJ
21UJ
490
290J
540
2,400 2,500
2,OOOJN
300JN
5UUJN
430
250J
-------
TABLE 3
JRGANIC r£Su!.rS _*' SUBSURFACE SOU SAMPLES
GNSIfE ..'IriTIN '.iASTE MATERIAL
NEiiPORT DUMP 5 ITS CAMPBELL. CGCNTY, KENTUCKY
PAGE 'MO
PARAMETER (,MGAG)
Offsite Control
Onsite Waste 5S-1A
SS-iB SS-1C SS-2A SS-3A SS-4A SS-5A
5 FEET 10 rEET 15 fEET 6 fEET 8 t'EtT 6 rEET li
11/85 11/85 11/85 11/85 11/85 11/85 11.
DIBENZOFUPAN
fLUORAWTHENE
FLUORENE
HEXAiNOIC ACID
IDENO (1,2,3-CD) Pyrene
ISOPHORONE
METHYLANTHRACENE
MAPfHALENE
PtTTROLELM PRUDUCf
PHENANTHRENE
PYRENE
UNIDENTIFIED /NO.
190J
480 1,1OOJ
240J
4,OOOJ
160J
110J
N
31UJ
_
44U
N
1,6UO
1,300
2,OOJN
1.20QJ/2
40U,OUOJ/2
-------
TABLE 3
'JRGANIC RESULTS OF SUBSURFACE SOIL SAMPLES
QNSITE WIHTIN WASTE MATERIAL
NEWPORT OLMP SITE CAMPBELL COUNTY, KENTUCKY
PAGE THREE
Offsite Control
Onsite Waste SS-1A
PARAMETER
'
(M3/KG)
S3-1A
5 FEET
11/85
SS-1B
10 FEEf
11/85
SS-1C
15 FEET
11/85
SS-2A
6 FEET
11/85
SS-3A
8 FELT
11/85
SS-4A
6 FELT
11/85
SS
11
11
PURGEABLE AND MISCELLANEOUS
COMPOUNDS
1,1,1 -TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
ACETONE
BENZENE
CARBON DISULFIDE
'HLOROBENZENE
CHLOROFORM
ETHYLBENZENE
ISO-OCTANE
METHYL BUTYL KETUNE
STYRENE
fOLUENE
TOTAL XYLENES
UNIDENTIFIED/NO.
14J
14
1,OOOJ
5.4
R
35
1,300
6,900
1,6UU
700,
46
2UUJ/2
-------
TABLE 3
ORGANIC RESULTS Of SUBSURFACE SOIL r
uNSITE -VIHTIN WASTE MATERIAL
NEWPORT DLMP SITE CAMPBELL COUNTY, KENTUCKY
PAGE FOUR
Offsite Control
PARAMETER (MS/KG)
SS-1A SS-J.B SS-1C
5 FEET 1U FEET 15 FEET
11/85 11/85 11/85
Onsite Waste SS-1A
SS-^A
6 FEET
11/85
SS-3A
8 FEET
11/85
SS-4A S3-
6 FEET 11
11/85 11,
CHLORINATED PESTICIDES, PCBs,
AND OTHER CHLORINATED
COMPOUNDS
4,4'-ODD
4,4'-DDE
4,4'-ODT
DIELDRJN
PCB-1242 (AROCLOR 1242)
PCB-1248 (AROCLOR 1248)
PCB-1254 (AROCLOR 1254)
PCB-1260 (AROCLOR 1260)
22
730
290
- Material was nalyzed tor out not detected above the minimum quantitation limit
J Estimated value
N Presonptive evidence ot presence ot material
R Data unuseaole
-------
Mine Tenroorar/ -veil ooints were installed outside the waste boundary of
the landfill. The -veil points were primarily located along the Lickina
River and the unnamed stream with an additional two 'well points located
north of the landfill, as shown in Figure 10. '.veil points -were designed
to detect leachate production in shallow groundwater along the bank of
the Licking River.
In general, the alluvium at the site can be described as predominantly a
silty clay with sand occurring at greater depths and ranging in color from
yellowish-brown to gray. The thickness of the alluvium varies from 36 to
110 feet and thins toward the valley walls where bedrock eventually outcrops.
Note Figure 11 for a typical cross-section of the subsurface environment
and Figure 12 for the groundwater flow of the alluvial acquifer (Horizontal
Groundwater Velocity =4.4 ft/yr., Vertical Groundwater Velocity = .05
ft/yr, Licking River Dilution Rate = 40,000 to 1).
NATURE AND EXTENT OF GRCUNDWATER CONTAMINATION
The distribution and concentrations of groundwater contaminants were
evaluated to determine the nature and extent of groundwater contamination
at the site. The distribution of these contaminants is shown in Figure 13
Summary of the contamination is presented in Tables 4 and 5. (Please
note, the table list concentrations of the indicator chemicals only.) In
general, the deeper groundwater at the site has shown only low levels of
site related contaminants, primarily near the culvert. No significant
levels of contaminants were detected in the deeper groundwater offsite in
the floodplain. However, the shallow onsite groundwater both immediately
below the waste and at the banks of the Licking River and unnamed stream
contained significant levels of inorganic contaminants.
Shallow groundwater samples collected from four wellpoints installed
along the west bank of the site adjacent to the Licking River were
evaluated to determine the potential leachate contribution to the river.
Additionally, one wellpoint was installed along the north bank of the
landfill in order to monitor potential leachate migration to the floodplain
north of the site. Numerous inorganic contaminants were observed
in all shallow groundwater samples (WP-8, WP-2, WP-3, and WP-4) with the
sample from WP-3 near the center of the landfill containing the greatest
number and the highest concentrations. No contaminants -were detected in
the shallow groundwater sample (WP-1) from the wellpoint north of the site.
NATURE AND EXTQ1T OF SURFACE WATER AND SEDIMENT CONTAMINATION
The distribution and concentrations of surface water and sediment
contaminants were evaluated to determine the nature and extent of surface
water and sediment contamination at the site. Individual samples were
compared to the appropriate control samples to determine where concentrations
were elevated for specific site-related contaminants. The distribution
of these contaminants is shown in Figure 14 and a summary of the
contamination is presented in Tables 4, 5 and 6.
-7-
-------
• AM K LICK *OAO
0 'JO MO «*0 (00
WELL POINT LOCATIONS
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
IMLS
A HsHihurton Cftnpn
-------
>
•
O
• «0
SIS
• 10
SOS
4S«
4SO
47O
4SO
4SO
44O
~ 410
•
5 410
*w»
4OO
«
WELL
CLAY CAP
WASTE
• 30
• 10
• 10
•oo
480
4«0
470
4SO
4»0
44O
. * • ft
* * *
42O
41*
4«0
LEGEND
SILTV CLAY
SAND
SANO AND OftAVEL
CLAY AND QMAVEL SCALS
O
SHALE AND LIMESTONE
*••* OIIIOINAL LAND SURFACE
NOTf: FILL SOUND A NY ESTIMATED FHOM BOREHOLE DATA
AND OMIOINAL TOPOQRAF-HIC SURFACE
CROSS SECTION DW-6 TO DW-4
NEWPORT DUMP SITE
CAMPBELL. COUNTY, KENTUCKY
FIGURE
11
ML 3
-------
KfNTO*
COUNTY
WATIH
INTAKI,'
tLICTflie
TftANtMIStlON
UNI
— 4«O—
LEGEND
• IOMOCK MONITOftlNa WILL
AlTt WATIH TAILf ILIVATION
QROUNDWATiR FLOW OIAICTIOM
IQUIPOTINTIAL LINIS
KM.t
0 ' iSO' JOO' 4)0' tOO'
GROUNDWATER CONTOURS
ALLUVIAL AQUIFER (12-4-85)
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
IMUS
A HaHtojrtor
-------
KtNTON
COUMTY
WATIM
IMTAKI
I IBCTHIC
MSMIISION
UNI
• AMKUCK
Cu.Pb.Cr.cn.f-e
CMorob«nztnt
Naohthtltnt
Xy1«n«
!norg»nlcsi
Htthyltnt
Chloride
VINf tTPIIT
LEGEND
TIMfOIUHY WILL POINTS
PIMMANINT MONITOMINO WILLS
PIMMANINT
ICM.C
»oo
DISTRIBUTION OF
GROUNDWATER CONTAMINANTS
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE 13
UGPPORATON
-------
KINTON
COUNTY
WATS II
INTAKI,
LLICTtlC
TRANSMISSION
LIMi
• ANKLICK *OAO
U-8a.Pb,N1
S-8«,Cr,Pb.OOT
9«,Tii1u«nt
S-A$,Cu,N1
Pb.Zn
u
s
LEGEND
SUftPACI WATIN ANO SIOIMINT
SAMPLING LOCATIONS
WATIft CONTAMINANTS
SIOIMINT CONTAMINANTS
JCitl
0 » >OO
DISTRIBUTION OF SURFACE WATER
AND SEDIMENT CONTAMINANTS
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
CORPORATOM
A Halliburton Company
-------
TABLE 4
5ACXGSOUND CONCENTRATIONS
NEWPORT Da-IP SITE
CAMPBELL COUNTY, KENTUCKY
Indicator
Chemical
Arsenic
Barium
Chromium ( total)
Nickel
Behzo(A)Pyrene
Toluene
PCBs
Surtace Water
(mg/1)
MD
ND-0.079
ND
NO
ND
ND
ND
Groundwater
(mq/1)
ND-0.095
ND-1.04G
ND-0.254
ND-0.450
ND
ND-0.028
ND
Soil
(mg/kg)
ND-14J
89-200J
7.0-24
36-61
ND
ND-0.014
ND
Sediment
(mg/kg)
ND
ND-68
ND-10
ND-33
ND
ND
ND
ND Not detected
J Estimated value
-------
MEAN AND MAXL'llM OBSERVED CONCENTRATIONS
5-RrACc: -VAIER AND JROUNDWATER
.. EXPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
Indicator
Chemical (mg/1)
Arsenic
3ariun
Chrcmium (total)
Nickel
Benzo(A)Pyrene
Toluene
PCBs
Surface Water
Groundwater
Mean
NO
0.05
ND
ND
ND
O.OU04
ND
Maximum
ND
0.18
ND
ND
ND
0.0031
ND
Mean
Maximum
0.02 0.064
1.03 7.4
0.16 1.5
0.29 2.4
ND ND
0.0008 0.017
ND ND
ND Not detected
-------
TABLE 6
MEAN AND MAXIMLM OBSERVED CONCENTRATIONS
SOIL AND SEDIMENT
NCWPOKf DUMP SITE
CAMPBELL COUNTY, KENTUCKY
Indicator Surface Soil Subsurface Soil Sediment
Chemical (mg/kg)
Arsenic
Bariun
Chromium ( total)
Nickel
Benzo(A)Pyrene
Toluene
PCBs
Mean
5.8
1.7
14
2*
ND
ND
O.U07
\
Maximum
10
97
16
42
ND
ND
52
Mean
6.9
173
25.2
43.9
0,15
0.128
0.06
Maximun
15
800
150
120
2.3
1.6
1,020
Mean
1.6
66
3.6
24
ND
ND
ND
Maxim
8
120
14
37
ND
ND
ND
•
ND Not detected
-------
In general, only low levels ot inorganic contaminants Mere detected in
tne surface water and sediment samples collecteo trom tne unnamed stream;
nowever, toluene was detected in tne surtace water at tne aiscnarge trom
tne culvert and PAHs were detected in tne sediment at tne .noutn ot the
stream. Xo site-relatea contaminants were detected in tne sediment at
tne moutn ot tne stream. No site-related contaminants .were detected in
tne surtace water in Licking River and the water intake; and low levels
of arsenic and copper in samples collected at the downstream boundary ot
tne site were the only site-related contaminants in the sediments.
MATURE AND EXTENT OF SOIL CONTAMINATION
The distribution and concentrations ot soil contaminants were evaluated
to determine the nature and extent of soil contamination at the site.
Individual soil sample analyses were compared to the appropriate background
or control analyses to determine where concentrations were elevated for
specific site-related contaminants. Ihe distribution of these contaminants
is shown in Figure 15 and results presented in Tables 4 and 6. In general,
it appears that the surface soil at the western bank along the Lacking
River and at the steep northern bank near the ravine are the only surface
soil areas containing concentration of site-related contaminants.
BIOTA INVESTIGATION SLMMARY
A limited acute and chronic static bioassay was conducted during the RI
using water collected form the drainage culvert tnat bisects the site.
The test organisms were the tathead minnow and daphnia. The water was
not tound to be acutely toxic to either test organism and reproduction
was not impaired in the daphnia.
No species on the federally endangered or threatened species list have
been coserved at tne site.
PUBLIC HEALTH AND ENVIRONMENTAL ASSESSMENT
Througn a selection process outlined in tne draft Supertund Public Healtn
Evaluation Manual, several indicator chemicals were chosen
from the sample analysis results to represent the chemicals posing the
greatest health concern. This selection process was intended to simplify
the data evaluatin without seriously compromising the validity of the
conclusions wnich were drawn. Tne procedures employed in tne indicator
chemical selection process are described in Appendix L of the RI Report
and the resulting indicator chemicals include tne following contaminants:
0 .Arsenic
0 Barium
0 Chromium
-8-
-------
Un- r-
KINTON
COUNTY /
WATIP. '
INTAKI,
ELICTBIC
TRANSMISSION
LINI
SS-1 83-13.
X (OPP MAP)
LEGEND
COMPOSITI SUMPACI SOIL
SAMPLING LOCATIONS
3USSUMPACS SOIL
SAMPLINO LOCATIONS
QftAI SUMPACf SOIL
SAMPLING LOCATION
' 3CM.I
0 '50' JOO «!0 «00
DISTRIBUTION OF SOIL CONTAMINANTS
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
NUS
CJGRPORATOM
Company
-------
0 Nickel
0 Benzo(a)pyrene
0 Toluene
0 Polychlorinated biohenyls
TRANSPORT MEDIA
Contaminant migration is dependent on the onysiocheniical characteristics
of the contaminant combined with the specific migration pathways existing
at the site. The evaluation of contaminant transport in each medium,
based on the data collected during the RI, identified the migration
pathways and formed the basis for the evaluation of potential routes of
human exposure.
The waste material sampled beneath the clay cap at the Newport Dump Site
contained a wide array of chemical contaminants. The chemical groups
included metals, organic solvents, polycyclic aromatic hydrocarbons and
chlorinated hydrocarbons.
The chlorinated hydrocarbons found in the waste material (SS-3A) included
PCB-1242, PCB-1260, and 4,4'-ODD. These contaminants would be expected
to remain in place with little potential for migration due primarily to
their hydrophobic nature and adsorption to the subsurface soils or waste
material. Also, they would be expected to remain essentially unaffected
by biodegradation. During the RI, no PCBs or 4,4'-DDD were detected in
the subsurface soil beneath the fill material or groundwater beneath the
site. The wide variety of PAHs found in the waste material, primarily in
the area west of the culvert (SS-3A), have varying physical characteristics
which affect their environmental fate. The lower molecular weight PAHs
(less aromatic rings) such as naphthalene and pyrene, have higher vapor
pressures, higher water solubilities, and are subject to greater
biodegradation than the heavier PAHs (benzo(a)pyrene and benzo(ghi)pyrene).
In general, metals such as arsenic, barium, chromium, and nickel would
not be expected to migrate significant distances in predominately clay
subsurface soils. However, the silty clay soils at the site have low
cation exchange capacity (CEC) values which are not conducive for
attenuating these metals. Therefore, the metals would be expected to
migrate, to some degree, with the groundwater. Since the predominant
qroundwater flow direction at the site is horizontal rather than vertical,
the majority of these contaminants should be evident in the shallow
groundwater and leachate breakouts. As would be expected at the site,
elevated metal levels were observed in shallow groundwater and in leachate
samples. The deeper groundwater, however, showed only sporadic increases
in metal levels.
Compounds such as benzene anc toluene which were found in the waste
material (SS-3A and SS-4A), ire very volatile, soluble, and can be
biodegraded. Under the conditions at the site, they would be expected to
migrate in the groundwater and in the subsurface soils.
-------
Toluene was detected curing tne RI in tne suosurface soils oeneatn tne
waste (S3-4B) and in offsite suosurface soils (SS-1, S5-6, and 33-7).
Additionally, toluene was detected in ootn tne shallow and deep jrouncwater
witnin t.ne landfill (SW-2 and aV-2, respectively), and in the upgracient
groundwater (DW-1).
.PCBs were only tound in tne surface soil at one location at the site.
Botn PC8-1243 and PCB-1254 were detected at the surface sample S-2 in a
old trench used for leacnate collection. However, none was found in tne
culvert outflow, the unnamed stream, or the Licking River.
EXPOSURE POINTS
The Newport Dump is located in a mixed land-use area with uncultivated
farmland and an industrial development to the north, a small farm to the
east, and natural vegetation associated with an named tributary of tne
Licking River to the south.
The nearest dwelling is approximately 360 feet southeast of the site on
State Road 9. Other residences are located along Banklick Road to the
north and Vine Street to tne south, comprising an estimated total
population of 50 in the immediate vicinity of the site.
Because of its ready availability, the region relies to a great extent on
the Ohio River and its major triDutaries for its water supply, ftssident
of Kenton and Boone Counties are served by the Kenton County Water
District. The district, wnich regularly serves a population of 75,000
operates two water treatment plants: the Ft. Thomas plant, which draws
from the Ohio River, and the Taylor Mill plant which has its intake on
the Licking River 250 feet downstrean fran the site. Residents in the
immediate vicinity of the site are served oy the Campoeli County Water
District.
In contrast to surface water use, groundwater use in the site vicinity,
it it exists, is extremely limited. Discussions with local water
authorities, county extension agents, and other local officials, failed
to identify a single user of groundwater within a one-mile radius of the
site. A door-to-door survey of residents north and south of the site
confirmed that residents either utilize municipal sources or utilize
cisterns. Most residents utilize municipal sources.
Because no groundwater users could be identified, the principal human
exposure point associated with the site is the withdrawal of surface
water from the intake on the Licking River. This intake could be affected
by entering the river eitner through groundwater discharge or via surface
runoff. Such an eventuality would place the customer bases of the Kenton
and Campoell County t&tar Districts, or 90,000 individuals, at risk.
Possiole exposure route to suosurface soil contaminants may include
ingestion, inhalation, and dermal contact. Ingestion may take the form
of direct exposure through drinking or eating materials which are contami-
nated; Direct inhalation exposure results from breatning air which has
become contaminated through volatilization, release ot gas pnased conta-
minants, or entrairunent ot airoorne participates.
-------
Dermal Exposure may result from direct contact with, soil or other material,
or may involve indirect contact such as the transfer of contaminants to
clothing and furniture, and subsequent skin contact.
SURFACE WATER CONSUMPTION
The Licking River is one of two sources of drinking water for the
approximately 75,000 citizens of Kenton and Boone Counties served by the
Kenton County Water District.
At present, no data exist which demonstrate a relationship between
contaminants detected onsite and contaminants detected in the District's
water intake or in the Licking River. Of the seven indicator chemicals,
only toluene was detected in the raw water sample collected at the Taylor
Mill filtration plant. Thus, while exposure to hazardous materials
associated with the site via consumption of surface water is a potentially
complete exposure pathway, it remains as yet an undemonstrated public
health concern.
GRDUNDWATER CONSUMPTION
Although traces of five of the seven indicator chemicals were detected in
the groundwater from one or more of the permanent monitoring wells
installed as part of the RI, no active domestic or industrial wells could
be located within a one-mile radius of the site. Thus, consumption of
contaminated groundwater does not appear to represent a complete exposure
pathway.
AIR AND SUBSURFACE GAS INHALATION
Since volatile contaminants were not detected in the ambient air or in
offsite boreholes using filed monitoring equipment during the RI, it
appears that the entrapped gases beneath the cap are not being released or
migrating offsite. Certain remedial action alternatives may, however,
disturb the soil and create emissions of contaminated dust or free previously
trapped gases. The population at greatest risk of exposure would be
workers and observers onsite during the remedial action if adeouate safety
measures ware not observed.
DIRECT CONTACT
No quantitative data are available on the size of the population potentially
exposed to site-related contaminants via direct contact with contaminated
sediment or soil. However, because access to the site is not restricted
and because some of the contaminants which were detected, notably PCBs,
have known dermal penetration properties, accidental exposure could
occur.
-11-
-------
FEDERAL AND STATE APPLICABLE OR RELEVANT AND .APPROPRIATE REQUIREMENTS
The applicable standards and criteria are shown in Table 7. Most of the
indicator chemicals were detected in the shallow groundwater at the site.
Exposure to groundwater contaminants would have to be through groundwater
discharge to surface water and withdrawal of that water at the Taylor
Mill filtration plant. Therefore, in compliance with SARA Section 121(d)
(2)(A)(ii) alternate concentration limits (ACL's) have been presented in
Table 8. These limits are based on actual groundwater contamination and
ensure a safe baseline limit in deciding if any future remedial action
would be necessary.
As stated previously, the dilution rate for groundwater discharge to the
Licking River was over 40,000 to 1. Since land use controls could be
implemented to prohibit the installation of onsite drinking water supply
wells, it would be considered conservative if the alternate concentration
limits of contaminants in groundwater were set at ten times that which
would protect drinking water supplies as shown in the table. Finally
Subtitle D, RCRA; Managing Solid Waste will be the appropriate standard
governing the closure of this facility subsequent to the iitplementation
of the Remedial. Action.
As discussed previously, the possibility of direct contact with the
surface soil or sediment cannot be precluded. Since long-term contact
is not expected on a regular basis, conservative acceptable levels of
contaminants could be set at background levels. Since benzo(a)pyrene and
PCBs were not detected in offsite background samples, conservative acceptable
levels can be set based on the potential but unlikely ingestion of soil
or sediment. The acceptable levels of contaminants for surface soil or
sediment are shown in Table 9. These levels were based on maximum observed
concentration in offsite background soil and sediment samples and 10~*>
risk level of cancer for benzo(a)pyrene and PCS.
ENFORCEMENT ANALYSIS
Currently the only viable parties for some type of enforcement action are
the City of Newport and the North Kentucky Port Authority. Both parties
had acquired ownership of the site before the remedial investigation
ensued. North Kentucky Port Authority is the current owner of the site.
To date potential responsible party research indicates there are no
transactional records that identify users of the site. Since there was
no charge to durap at the site, then no dump tickets, invoices, etc., were
developed. Parking stickers may provide the only record of who had
authority to access the site. Research indicates that all Newport city
industry during the term of operation of the Newport dump would have used
the site to dispose of their waste. Due to the uncontrolled nature of
the site as evidenced by lax enforcement of the resident-only use policy
prior to 1972, it also is possible that other non-resident users existed.
With the onset of a stricter enforcement posture in 1972, it is possible
that previously unstickered site users would have obtained such stickers
in 1972.
-12-
-------
TAALE7
AQUATIC L« CRITERIA
NEWPORT DUMP SITE
CAMPBELL COUNTY. KENTUCKY
CLEAN WATER ACT
Indicator
Chemical
Arsenic «)
Barium
Chromium *l
Nickel (c)
Benzo(a)Pyrene
Toluene
PCB»
0.29
J*
KENTUCKY ADMINISTRATIVE REGULATIONS
O,u>UO.)
UAHIMUOI
21
1.100
b
17,100
A»)
lOO(ioulCr)
0.01*
0.001%
Not established
U) Water quality criteria established under provisions of the Clean Water Act ol 1977 (PL 9)-2l7).
published in Federal Register 79111-79)79, November 21. 1910.
(b) Kentucky Administrative Regulations. Title «OI. Chapter J, established under provisions ol
Kentucky Revised Statute* 224.020 and 221.040.
(c) tiasdncss equivalent to X) mg/l C*COj.
-------
TABLE 7
APPUCAALE STANDARDS AND CRITERIA
NEWPOftT DUMP SITE
CAMPBELL COUNTY. KENTUCKY
Applicable or Relevant and
Criteria. Advisories, and Guidance
CLEAN WATER ACT CLEAN WATtlTACT
KENTUCKY ADMINISTRATIVE WaUr Quality Criteria for Water Quality Criteria for
Indicator SAFE DfUMKMG WATER ACT REGULATIONS rtMtan H*aJ* - Ft* ft Human IWMk Adkated for
Oemtcal Maa^ipu^i CMilamlmm i-OTtit (a) Surlace Water Standaf 4f >ft) Dytnfctufl Water (c) PruAtoj Water
Arsenic M ug/l X)ug/l(l) 0 (2.2 ng/l) (e) 0(2.)
Barium 1,000 ug/l 1,000 ug/l (g)
Chromium «fc -
Chromium »J
Chromium (total) M ug/l X) ug/l (g) 100
Nickel - - I).* ug/l IJ.» ug/l
benzoiAlPyrene - - 0 (2.S ng/l) 0(1.1
Toluene
Polychlorinated
fttphenyls - t.tng/l(0 0 (0.079 ng/l) 0(12.6
(ai National Interim Priinaf y Dunking Water Regulations promulgated in accordance with the provision* ol the Sale Drinking W*ier At I, PL 9)-)21.
(b) Kentucky Administrative Regulations, Title Ml, Chapter », establitfted under provisions of Kentucky Revised Statutes 224.020 *nd 22%.OM).
(c) Water quality criteria established under providions ol the Clean Water Act ol 1977 , PL 95-217, publitned in ») Federal Register mil 79)79,
21, 1910.
(d) EPA, April 19ft). Guidance on Feasibility Studies under CERCLA.
(e) The criterion for all carcinogens is zero) the concentration given in parentheses corresponds to a carcinogenic ri* ol 10 A
(I) Warmwater aquatic habitat criteria.
(g) • Domestic water supply source criteria.
Not established.
-------
TABLE d
ACT'JAL AND PROJECTED
CONCENTRATION LEVELS
Indicator :-tewport Sited) ProposeaU) Heal en Basel 3) Projecced Dilute
.'hemicals Groundwater Concentration Alternate Concentration Criteria Tig/1 Concentration i
mg/1 Limits -ng/1 Licking River T
ARSENIC
BARILM
CHRLMILM
NICKEL
dENZO(a)PYRENE
TOLUENE
PCBs
.064
. 7.4
1.5
2.4
.017
.64
74
15
24
.17
-
.05(MCL)
KMCL)
.05(MCL)
.013(WQC)
-
.014(WQC)
'
1.6 x 1C
l.«5 x LG
3.75 x 10
6 x 10
-
4.2 x 10
"
(1) Actual concentrations ooserved in tne groUndwater discharge to the Licking River.
(2) These concentrations are ten times those presented in Column (1).
(1) AHAR's listed in Taole 7.
v4) Projected Concentrations Oased on 40,000 to 1 dilution of values listed in column (2)
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TABLE 9
ACCEPTABLE LEVELS OF CONTAMINANTS
SURFACE SOIL AND SEDIMENT
NhiVPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
Indicator
Chemical
Arsenic
Bariun
Chromium ( total)
Nickel
Benzo(A)Pyrene
Toluene
PCBs
Acceptable Level of
Contaminants (mg/kg)
14
200
24
61
1.00
0.014
2.1
Basis
dKGD
BKGD
BKGD
BKGD
Ingestion
BKGD
Ingestion
BKGD
Maximum observed concentration in offsite background soil or
sediment samples.
Ingestion Concentration calculated based on 10~6 risk of cancer from
ingestion of soil. See.Appendix M.
-------
It also is aooarent that former site ooerators ^ay recall the identity of
specific unauthorized site users. The other city officials interviewed
indicate previous site operators chat would be aware of the identity of
any such users.
ALTERNATIVE EVALUATION
The purpose of the remedial action is to mitigate contamination at the
Newport Dump site in order to remove potential risks to human health and
the environment.
Each remedial alternative developed for use at the Newport Dump site was
subjected to an analysis to determine its effectiveness in addressing
site problems. This analysis also included an evaluation of the public
health and environmental risks both during and after implementation.
Table 10 and 11 presents the six remedial action alternatives evaluated for
this site. Each of the six alternatives were evaluated based upon technical
consideration, institutional issues, environmental issues, public health
impacts and cost criteria. The results of the final evaluation are given
below.
Alternative 1: No Action
If this alternative were selected, no additional remedial activites or
monitoring would be undertaken at the Newport Dump Site. This alternative
would not require any operation and maintenance or the acquisition of
personnel and materials. The implementation of this alternative would
not address any impacts resulting from the site contaminants. Contaminant
migration could occur unnoticed and without means of control. Groundwater
discharge of contaminants above health based standards from the shallow
acquifer into the Licking River has been documented. This option does
not satisfy any currently applicable or relevant State or Federal (RCRA)
standartds for the closure of a site. Based upon the above consideration
of public health, this no action alternative has been rejected.
Alternative 2: No Action - Monitoring
All aspects of this alternative are the same as those described under
Alternative 1, with the exception of periodic sampling, analysis and
report preparation concerning groundwater quality, surface water and soil
contamination. Sampling analysis, and report preparation would be performed
semi-annually. Sampling and site visits would mean that the site and
groundwater will be monitored and not go unnc*:ice. Similar to alternative
1, no remedial action provides no additional protection to the public
health and environment. Based upon consideration, this no action
alternative has been rejected.
-13-
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TABLE 10
SUMMARY Of REMEDIAL ACTION ALTERNATIVES
NEVPOftT DUMP Sin
CAMPBELL COUNTY. KENTUCKY
Alternative
1. No At I ion
2. No Action - Monitoring
}. Monitoring, Leachale Collection,
and Regradmg and Revegelalion
4. Monitoring, Leachate Collection,
Regrading and Revegelalion,
Capping, and Cat Collection
5. Monitoring, Excavation, and
Solididcation/Stabiliialion
6. Excavation and Olfsile
Disposal
Public Health
Concern*
Release ol shallow
groundwaler as leachale
seeps; undetected
contaminant release.
Env IroMten taJ
Concern*
Undetected
conlaminanl
release
Technical
Concern*
None
Other
Concerns
Community aiid
regulatory
disapproval
Release ol shallow Minimal
groundwater as leachale
seeps
Minimal ' • Minimal
Minimal Minimal
Release ol particulars Minimal
and toxic gases during
excavation
Release ol paniculate* Minimal
and- toxic gases during
during excavation
Minimal
Routine maintenance
ol leachate syilein
Routine maintenance
ol leachale and gas
syileins as well as cap
Design and operation
ol solidification/
stabilization process
Coordinating
transportation ol
excavated waste
Coimnufu I y
Prohibition ol
uniile potable
water supply
wells
Prohibition ol
onsite potable
water supply
wells
Proltibi 11011 ol
oiisile pulable
water supply
wells
Public peri_c|>iioc
uve ol oflsiie
disposal
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Alternative 4: '•Von i tor ing, Leachate Collection, Peorading and
Reveqetation, Capping, and Gas Collection
This alternative involves the placement of a multilayered cao over the
entire 39 acre site, repairing the leachate collection system and a gas
collection and treatinent system which would control gas migration and
its related hazards. Imolementation of this alternative would serve to
close the landfill in compliance with the requirements under RCRA 40 CFR
264. This alternative has been rejected because the installation of a
RCRA clay cap would not be cost effective (517,175,000). The amount of
surface contamination is minimal and a decrease in groundwater discharge
to surface waters can be affected by other means. The same affect for '
minimization of leachate generation can be accomplished with regrading
and revegetation and repair of the leachte collection system.
Additionally both the City of Newport and the Kentucky Port Authority do
plan some type of reclamation and construction work on the 39 acre site.
The RCRA cap is composed of artificial membranes that are not amenable
to the proposed land renovation planned by the local authorities. The
cap would not tolerate any type of heavy construction and its integrity,
design life and usefulness would be threatened to a substantial degree.
Also due to the minimal levels of organic vapor venting from the subsur-
face, a gas collection system is not warranted and premature at this
juncture of the remedial process.
Alternative 5: Monitoring, Excavation, and Solidification/Stabilization
Implementation of this alternative would require extensive excavation and
the use of a silicate-based solidification stabilization process. As a
result of these two procedures, separation of the waste material, backfilling,
and regrading and revegetation would also be necessary. A monitoring
program, would be instituted for the collection and analyses of groundwater
samples to determine the long-term effectiveness of the solidificaiton/
stabilization process.
The Newport Dump site covers an area of 39 acres and is estimated to have
a total volume of 1,078,000 cubic yards of waste and contaminated soil.
Based on lithologic logs of site boreholes and historical photographs,
approximately 1,509,000 cubic yards would have to be excavated. The
difference in volumes is accounted for by the cover that presently exists
at the site. The depth of excavation would vary widely at the site,
ranging from 5 feet in portions of the eastern section to 40 feet in the
western section of the landfill. The actual depth of excavation would be
determined visually with confirmation sampling at the base of the excavation.
Though SARA dictates pemanent on-site detoxification of hazardous
waste, the large amount of soil to detoxify would require extensive and
unwarranted waste handling practices during clean-up. The implementation
of this alternative would have the potential to significantly impact
public health. During the excavation procedures, the opportunity for
offsite migration of contaminants would be greatly increased. Pathways
for this migration would include airborne particulates, gas emisssion,
and.surface runoff.
-14-
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Receptors in tne area of tne site would oe susceptiole to innaiacion of
535 as -veil as contaminant-laden particulates, tne irxjestion ot participates,
and direct contact with wastes.
Another factor that could potentially Lnpact puolic nealtn would be tne
onsita storage of the waste material prior to tne solidification/staoiiization
process. Storing tne waste would increase the chance of contaminant loss
due to volatilization and surface runoff.
Implementation of this alternative should, in the long-term, eliminate
the puolic health concerns associated with the landfill. This -would De
achieved by solidification and staoilization of the hazardous materials.
rbwever, there could be potential adverse health effects associated witn
tne possiDle leaching of contaminants from the solidified and stabilized
wastes. The low levels ot contaninants presently in the groundwater would
continue to migrate oftsite until the site had been self-purged. Addi-
tionally this remedy would cost $40 million dollars to implement. This
expenditure cannot De justified based on the low level potential health
threat the site poses to tne community. Based on these considerations
this alternative is rejected.
Alternative 6: Excavation and Qffsite Disposal
The components of Alternative 6 would be •wfecavation witn separation of
the waste and disposal in an offsite landfill, backfilling, regrading,
and revegetation. The alternative would require disposal of the waste
material in an otfsite EPA-approved RCRA landfill. This would De carried
out concurrently with excavation, separation and backfilling.
Implementaiton of this alternative would result in the excavation of
approximately 1,509,000 cuDic yards of waste and contaminated soil. The
excavated material would be separated, and the 788,000 cuDic yards of
hazardous waste and contaminated soil would be transported offsite to an
EPA approved RCRA landfill.
There are presently two offsite commerical landfills in Region IV in
compliance with RCRA requirements. These landfills are in Bnele, Alabama
and Pine Wood, South Carolina. Transportation would be accomplished
using 20-cubic yard trucks and would require 39,400 loads cor completion.
The site would be backfilled with the separated nonhazardous material and
offsite soil and the regraded and revegetated.
Disposal in an offsite landfill is a permanent remedial action and would
provide a very high level ot environment and puolic health protection.
However, the alternative directly contradicts the intent of tne new SARA
mandates. SARA calls for the Agency to prefer remedies that use on site
treatment to permanently and significantly reduce the toxicity, mobility,
or volume ot wastes over remedies that do not use such treatment. In
addition, SARA requires that the Agency select a ranedy that utilizes
permanent solutions and alternatives treatment technologies, or resource
recovery tecnnologies,to the maximum extent practicable. Excavation and
oftsite disposal do not comply witn the intent ot the new Superfund
statutes.
-15-
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Receptors in tne area or tne sice would oe susceptiole to inna.lation JE '
^as as well as oontaninant-laden particulars, tne Lr»;estion oc parti::ulates,
and airect contact witn wastes.
Anotner nactor tnat couia potentially impact puolic nealtn would be tne
onsite storage ot tne -waste .naterial prior to tne solidif ication/staoiiization
process. Storing tne waste would increase tne cnance of contaminant loss
due to volatilization and surrace runotf.
Impianentation of tnis alternative should, in the long-tern, eliminate
tne puolic healtn concerns associated with tne landfill. This would oe
achieved by solidification and staDilization of tne hazardous materials.
However, there could oe potential adverse health effects associated witn
the possible leaching ot contaminants fron the solidified and stabilized
wastes. The low levels ot contaminants presently in the groundwater would
continue to migrate offsite until the site had oeen self-purged. Addi-
tionally this remedy would cost $40. million dollars to implement. This
expenditure cannot be justified oased on the low level potential health
threat tne site poses to the community. Based on these considerations
this alternative is rejected.
Alternative 6: Excavation and Offsite Disposal
The components of Alternative 6 would be excavation with separation of
the waste -and disposal in an offsite landfill, backfilling, regrading,
and revegetation. The alternative would require disposal of the waste
material in an offsite EPA-approved RCRA landfill. This would be carried
out concurrently with excavation, separation and backfilling.
Implementation of this alternative would result in the excavation of
approximately 1,509,000 cuoic yards ot waste and contaminated soil. The
excavated material would be separated, and tne"7d8,000 cubic yards of
hazardous waste and contaminated soil would be transported oftsite to an
EPA approved RCRA landfill.
There are presently two oftsite commerical landfills in Region IV in
compliance witn RCRA requirements. These landtills are in Emele, Manama
and Pine rtbod, South Carolina. Transportation would be accompiisned
using 20-cuDic yard trucks and would require 3^,400 loads tor completion.
The site would be backfilled with tne separated, nonhazardous material and
ottsite soil and the regraded and revegetated.
Disposal in an offsite landfill is a permanent remedial action and would
provide a very high level of environment and puolic health protection.
However, the alternative directly contradicts the intent of tne new SARA
mandates. SARA calls for the Agency to prefer remedies tnat use on site
treatment to permanently and significantly reduce the toxicity, mobility,
or volume ot wastes over remedies that do not use such treatment. In
addition, SARA requires tnat the Agency select a remedy that utilizes
permanent solutions and alternatives treatment technologies, or resource
recovery technologies,to the maximun extent practicaole. Excavation and
offsite disposal do not comply with the intent of the new Supertund
statutes.
-15-
-------
Additionally clue to trie ninuiai extent of contamination at tne site sucn
an expensive remedial action (179 Million collars) cannot oe justitiea.
3ased on tnese considerations this alternative has oeen rejectee.
Alternative 3: Monitoring, Leacnate Collection, •
degrading and Reveqetation
This alternative has oeen selected as the reccmnended alternative action
for the Newport Dump Site. This alternative selection does not fully
comply with certain portions of SARA S 121. SARA emphasizes remedies
that must utilize permanent solutions and alternative technologies or
resource recovery technologies to the maximm extent practicable. Since
1) Minimal contamination has Deen found in the surface soil and groundwater
discharge to the surface water, and 2) one million cubic yards of solid
and hazardous waste is ouried at the site, then this remedial action
selected is adequate to the "maximun extent practicable" for this site.
The selected remedy is protective and cost-effective, attains ARARs and
is a practicable .solution which substantially reduces the public health
and environmental threat to negligible levels. This alternative would
include tne following remedial action components:
1) MONITORING
The primary health'concern at the Newport Dump Site is that site contaninants
may migrate to the Licking River and enter the raw water intake 250 feet
tram the site. Since various contaminants were detected during tne Remedial
Investigation (RI) in tne groundwater and surface soil near the Licking
River Dank, there is a potential for these contaminants to discharge into
the Licking River. As a result of this concern,, both groundwater and
surface water would be monitored.
Six of tne groundwater monitoring wells installed during the RI would be
sampled to determine the levels of contaminants being released (see Figure 16)
The groundwater samples from location DW-1 and CW-3 would be used to
monitor tne groundwater quality upgradient of the site.. The samples from
DW-3 would also provide data on possiole contamination migrating under
the site fron the non-ferrous auto parts landfill. Groundwater samples
frcm locations SW-2/DW-2 and SW-5/DW-5 would provide information on
groundwater quality at two depths beneath the landtiil. The sampling
program for groundwater would include quarterly monitoring at the four
locations for three years to estaolish Daseline conditions and then the
program would be reevaluated cor changes in analyses and sampling frequency.
Surface water would oe -nonit^red at three locations adjacent to tne river
oank snown on Figure 16 to determine the effects, if any, ot contaminants
entering the Licking River. The surcace water at location LR-1 and LR-2
would oe used to monitor watsr quality at the fenton County Water Treatment
Plant intake. The sampling program tor surface water would include quarterly
monitoring for tnree years ,nd tnen the program would be reevaluated tor
changes in analyses and sanoiing frequency. Initially, the surface water
would be analyzed for the complete nazardous substance list.
-16-
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KINTON
COUNTY
WAT1M
INTAKI/
rucTmc
T* tMtMlttlON
UNI
• ANKUCK NOAO
COLLICTION TANK
I.IQINO
tUHPACI WATIN tAUPLIN* I OCATION
«AS MONITOMINC WILL
OMOUNOWATIM MONITOMINQ
MO
«OO
MONITORING LOCATIONS
ALTERNATIVES 2 AND 3
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
IMUS
A Ha*bufton Company
-------
A monitoring system to detect jas migration would oe instituted. ?*ro
nonitoring wells would oe installed along tne site's northern oocncary
to suppiy gas migration inrormation potentially affecting tne industrial
parx and residential area located north of the landfill. Since tne
-najority of waste was reported!/ deposited in tne western portion ot tne
landfill, a jas monitoring well along tnis border would provide infor.ntion
concerning the landfill potential for gas generation. An additional gas
nonitoring -veil would be placed on tne site's eastern ooundary to detect
any migration toward tne residence located adjacent to tne landtill (see
figure 16).
Gas monitoring along the site's southern Doundary was not considered due
to the Duffer zone supplied by the unnamed stream as well as the absence
of receptors. The sampling program tor gas would include quarterly
nonitoring for three years at which time the program would be reevaluated
for changes in analyses and sampling frequency.
Annually, the quarterly results of the sampling and analysis program would
De averaged and compared to tne acceptable levels of contaminants established
for groundwater and surface water in the public health evaluation. It
any of the indicator cnemicals exceed these acceptable concentrations on
an average annual basis, the proposed remedial action at the site would be
reevaluated by tne EPA. If any volatile gases are detected in samples
tram the gas monitoring wells, the need for monitoring ambient air would
then oe evaluated. The time and procedure for these evaluations shall be
done in accordance witn the statutory mandates of SARA.
2) LEACHATE COLLECTION
The effectiveness ot the present system which was completed in 1980, has
been of concern. This concern has been generated from the inability of
the system to fill tne holding tank located in the southwest corner of
the site (see Figure 17). It is also believed that a portion of the
leachate may be entering breaks in the 6U-incn culvert that runs trom the
natural drainage area north of the site to the unnamed stream along the
site's southern border.
Therefore under this alternative a properly operating systan for tne
collection of leachate would be provided. This would involve the repair
or replacement of the existing systan and the construction of additional
collection lines along the northeast border of the site. Figure 17 shows
the location of the existing system and the proposed expansion. This
collection system would prevent the migration of contaminated leachate to
the unnamed stream, Licking River, and the area north ot the site.
Included as part of the leachate collection system would be the installation
of a collection basin and punp to remove water from the natural drainage
area located northeast ot the site. Removal of this water would greatly
reduce infiltration into tne nortneast face of the landfill and suosequent
leachate formation. In addition, it is likely that subsidence or clogging
has impaired the ability of the leachate collection system to function
properly. To bring the present systan to standard, it would be accessed
and-flushed using hign pressure, jet-cleaning equipment. To access tne
system, permanent itiannoles would be installed at 500-feet intervals.
-17-
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OOCCICTIOW «Y«T1I*
PtO»«9l» HACMATI
COkLlCTION •Ytnil
• XI«TIM« LIACWATt
COI.LICTIOH SYtTIH
CONTOUH INTIMVAU • • FliT
...... APPNOXIIIATI SIT! •OUNOAMT
SOO' «SO' »00
EXISTING AND PROPOSED
LEACHATE COLLECTION SYSTEM
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIQURF
i =»AT :i
A Halliburton Compar
-------
failed portions of the system «oula oe excavateo ana new a collection
line retrofitted. To eliminate tne potential loss ot leachate to tne
oG-incn corrugated metal drainage pipe, tne culvert *oulo oe sealed at
eacn ena witn a concrete oentonite .tuxture. The collection system
extension along tne nortneast oorder on tne lanatill would consist ot
1,UUO teet on line ana an aaaitional 5,UUU-:jallon fioerglass tank. The
system would oe constructed oy digging a trench 2-zeet. wide and 9-feet
deep and placing a 4-incn perforated polyvinyl cnloride pipe on a 4-inch
oed of sand. A 2-toot drainage layer of gravel '-cold De placed over tne
pipe and covered Dy a 6-inch layer ot graded sand. Finally, tne trencn
would Oe backfilled to grade with contnon fill (see Figure 18).
The system would be placed along the 515 foot (amsl) contour at a slope
ot 2 percent. Both ot tne leachate collection tanks mentioned above
would be equipped with pumps to lift the leachate to a 20,uOO-gallon tank
located on tne surface of the landfill. With this arrangement, inundation
oy tlood waters would be eliminated and access would be available year
round. If analyses results determine that leachate treatment is necessary,
an appropriate treatment scheme would be determined oy conducting a pilot-
scale study. If treatment is not necessary, the leachate would be punped
to trucks and transported to a nearby treatment plant.
Storm drainage would De controlled by installing a precast 1,000 gallon
concrete tank at the toe of the landfill's northeast face. If necessary,
minor grading would be done to promote drainage to this tank. A centrifugal
punp with a float control valve would be used to remove the water from
this tank and transport it through a 6-inch pipe across the top of the
landfill with discharge to the unnamed stream.
j) RLGRADING AND REVEGETATION
In order to stabilize and prevent further erosion of the northeast landfill
oank, regrading would be necessary. In addition, to provide protection
against infiltration into tha banx, two feet ot clay would oe included
as part of the bank stabilization process.
Presently the terrain is extremely variable with sane steep eroded areas.
The final slope would be reduced to a constant 5 to 1 change in elevation.
Revegetation would oe required following regrading in order to stabilize
the area. Alterations to the bank would be completed at the same time
that the extended leachate collection system lines, are being installed.
Local materials would oe used for rough correction ot the slope prior to
the application of the clay layer and to supply the final cover for the
establishment of vegetation. Figure 19 shows a cross section of the
existing grade and tne amount of material that would be necessary to
achieve the constant grade.
4) SUBTITLE D; Municipal Waste Landfill
For the Newport Dump site a distinct .separation ot RCRA Subtitle C
(Hazardous Waste) and Suotitle D (Municipal Waste) is difficult to
-18-
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• • . I o P l - T
'-
PfftPOIIATID
U*?Vr!;.<
V^*-v
u »T -•'«.• r-»« —•- « - '—.*«. « ^-
COMMON PILL
VARIABLE OtPTN
IAMB
2* QUAVIL
4' SANO
•- 1'
CROSS SECTION FOR DESIGN OF
LEACHATE COLLECTION SYSTEM
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
FIGURE
Ml IS
= ATOM
A HaHibyrton Company
-------
110
130
1SO
1SO
CROSS SECTION OF NORTHI-AST BANK
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
N! IS
A Halliburton
-------
ascertain since trie site contains ootn surtace and subsurtace soil conta-
nination which is similar to trie contanination corrnoniy couna in nun 10; pal
waste (see Table 1). me regulatory traneworx estaolisned under Subtitle
C (4U CFR Parr 260-267) was resigned to protect numan nealtn and tne
environment tram tne etrect oc anpermitted disposal resulting in tne
improper management ot nazardcus waste. However, due to tne .ninimal
amount ot surtace contamination and .migration of hazardous waste oftsite
and since the remedial alternative selection does comply witn SARA § 121
to the "maximum extent practicable" tnen any closure or post closure
requirement can be determined oy Subtitle D "Criteria tor Classification
of Solid Waste Disposal Facilities and Practices", commonly referred to
as the "Subtitle D Criteria" (40 CFR Part 257).
The Criteria are used as a (1) set of minimum technical standards witn
which all Federal and non-Federal solid waste disposal facilities must
comply, and (2) a means of determining if a solid waste disposal facility
is an open dump. The criteria cover eight areas: Floodplains, Qxiangered
species, surface water, groundwater, waste application limits for land
used in the production of food cnain crops, disease transmission, air,
and safety. These criteria snould De examined and implemented during and
after the completion of the remedial action. The State of Kentucky
Department of Environmental Protection nas been delegated this responsibility
and snould adhere to the regulations under 40 CFR Part 256.
PUBLIC HEALTH EVALUATION
0 Implementaion Phase
There would be risks involved with the construction of the ieachate
collection system and the regrading ot the northeast slope. Ihe hazards
would include tne potential inhalation ot volatile contaminants during
construction of the Ieachate collection system and the ingestion ot contaminated
dust generated from surface regrading activities. Remedial personnel
digging the trenches and installing the Ieachate collection system might
be required to wear level B respiratory protection (seltcontained breathing
apparatus). Surface contamination is expected to be minimal and would be
restricted to relatively small, isolated portions of the landfill.
Additionally, the period of exposure would be restricted to the construction
phase, which is expected to be only 10 weeks. During this period,
workers could be protected from significant exposure through the use of
readily available and accepted control technologies.
The potential for exposure by offsite public receptors would be minimal,
since no material would be removed from the landfill. Construction
equipment moving otfsite would be decontaminated at the site exit, thereby
eliminating transport of contaminant material offsite by this mechanism.
0 Residual Risk
In terms of its residual etfect on tne public health, implementation of
tnis alternative would eliminate the risxs associated with the discnarge
ot leacnate to the Licking River and eventually to tne raw water intaxe
downstream ot the site. This alternative would result in stabilizing a
-------
cownstrean of the site. This alternative would result in staoilizing a
presently steep and eroding slope, wnile preventing tne possioiiity oc
waste exposure and reducing infiltration.
Implementation of tnis alternative would also provide an early warning
system (monitoring or gas and water) should site conditions change.
ENVIRONMENTAL EVALUATION
0 Implementation Phase
The alternative would require minor excavation and surface activity, out
any impact on the regional environment from this action should be negligible
if good work practices are employed.
0 Residual Risk
A significant decrease in the risk associated with the site would De
achieved with the implementation of this alternative. Sensitive environ-
mental receptors in the unnamed stream and Licking River would De relieved
of the potential stress resulting frcm the discharge ot leachate.
INSTITUTIONAL EVALUATION
The institutional requirements for monitoring are snown in Table 7 and
ACLs are shown in Table d and 9. Implementation of this alternative might
require that the leachate be pretreated prior to discharge to a local
sewage treatment plant. There are federal and state guidelines concerning
maximum slopes for landfill banks that would De met during tne regrading
process.
The City of Newport and the North Kentucky Port Authority do plan to
renovate and construct on the site. Regrading and revegetation will be
adaptable to any type of future work at the site as opposed to a RCRA cap
installation. However, at tne same time, heavy construction and earth
moving can and will reduce the design lite of this remedial action after
the implementation phase. Therefore, future renovation activities will have
to be delayed for 3 years, after the remedial action has been implemented.
After 3 years when monitoring does reveal innocuous levels of contamination,
then some type of agreements, orders or covenants will have to be established
among the local and state governments, and EPA to establish and maintain
Limits and standards to the type of land renovation the site can tolerate
and remain stable. Also the local authorities must- promulgate urmediately
a mandate on permanent land use restrictions i.e. prohibiting the drilling
of any type of groundwater well or subsurface equipment. The Kentucky
State Department ot National Resources and Environmental Protection shall
be responsible in ensuring that all municipalities comply with the 3 year
moratoriun on future land use atter remedial action is completed.
-20-
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COST EVALUATION
Capical coses for cne installation oc end -jas monitoring wells, cne leacnace
collection system, and regradinq and reve;ecacion would oe S5I6,uuu.
Operacion and maintenance costs would include routine inspections of cne
Leachace collection system, all landfill slopes, ana cne -nonicorirxj.
Ihis would result in annual operation and maintenance costs for cne first
j years oc S63,UQO and tor years 4 chrougn 30 of 535,000.
Tne present worch value for cne operation and maintenance costs for 30
years at a 10 percent discount rate would oe 5398,000 while the total
costs would be S914,000. Costs necessary tor personnel, equipment, and
laboratory analyses can be found in Appendix R of the RI Repore. The
capital costs for Che leacnace collection system would consist of materials,
equipment and labor, engineering, and nealth and safety. A sensitivity
analysis was performed on tne installation of tne leachate collection
system with 20 percent variation in Che materials and labor to upgrade
the present system causing Che capical costs co vary from $74,000 co
5110,000. A sensitivity analysis was also performed on the volume of
material required tor regrading. A 10 percent variation in che volume
would cause the capital costs to vary crora 5375,UOO to 5459,000. Adding
these factors co tne sensicivicy analysis would cause Che cotal present
worth costs to vary trom 5820,000 to 51,008,000. The costs and sensitivity
analysis are summarized in Taoles 12 and 13. However, these costs can be
reduced it leachate collection, regrading and revegetation are accomplished
by tne immediate .removal section (ERCS contract) of Region IV, EPA.
ALTERNATIVE SUGGESTED ttt PUBLJC AT PUBLIC MEETINGS
Ihe majority of che parcicipants at che meeting deferred to che judgement
ot both tne Federal, and Local officials who were undecided. The alternative
recommended oy several residents of Campoell County was Alternative 1.
Alcernacive 1 is both environmentally and politically unacceptable because
it -would not meet che cleanup criteria established by the EPA or State of
Kentucky.
CONSISTENCY WITH OTHER ENVIRCtMENTAL LAWS
It is EPA Policy to give priniary consideration to ranedial actions that
attain or exceed applicaole or relevant Federal environmental or public
health standarda.
State and local standards should also be considered, however State
standards that are more stringent than Federal Standards may form basis
for che remedy only it cne resale is consistent witn che cost effective
remedy based -on Federal standards. Tne State may also pay the addicional
cost necessary to attain cne State standard(s).
-zl-
-------
.TABLE //
COST SUMMARY OF REMEDIAL ACTION ALTERNATIVES
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
1.
2.
3.
4.
5.
6.
Alternative
No Action
No Action-Monitoring
Monitoring, Leachate Collection,
and Regrading and Revegetation
Monitoring, Leachate Collection,
Regrading and Revegetation,
Capping, ana das i~oiiecuon
Monitoring, Excavation, and
Solidification/Stabilization
Excavation and Offsite Disposal
Time to
Implement^)
-
4 weeks
10 weeks
1.3 years
3.2 years
3.2 years
Design
Life
30
30
30
*
30
30
-
years
years
years
years
years
Capital
7,
516,
15,727,
39,048,
178,836
0
000
000
000
000
,000
04 M
Cost ($)(2)
264
398
1,448
150
0
,000
,000
,000
,000
_
Total
Cost ($)(2)
271,
914,
17,175,
39,198,
178,836,
0
000
000
000
000
000
(I) Time reflects the use of a unit crew.
(2) Costs are shown in present worth dollars for comparison.
-------
TABLE U
COST SUUUARY - ALTERNATIVE 13
NEWPORT OUUP SITE
CAMPBELL COUNTY. KENTUCKY
Estimation of
Time to Capital O A M CosU ($)
Alternative Components
Monilui tug
Leachaie Collection
Regrading and Kevegetation
Total CosU
B. Present Worth Analysis
Alternative Components
Monitoring
Leachate Collection
Regrading and Revegetation
Total Present Worth
Construct Costs ($) Period (Yr.)
1 mo. 7,000 1-3
4-30
10 wki. 92.000 30
1U wks. •*»/ ,i»uu 30
•»
„ 516,000
Capital Costs ($) O A M CosU <$)
7,000 339,000
92,000 55,000
417,000 4,000
516,000 391,000
Annual ($) Total ($)
57,160 171,000
28,360 766,000
5,800 174,000
it I I {. ,UU
1,639,000
All costs are rounded to the nearest 1,000 dollars except ual O & M.
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TABLE 19
SENSITIVITY ANALYSIS - ALTERNATIVE 13
NEWPORT DUMP SITE
CAMPBELL COUNTY. KENTUCKY
o
i
ro
A. Sensitivity Factors
Alternative Components
Monitoring
Leachate Collection
Regrading and Revegetalion
Sensitivity Factor
Number of samples
Materials and labor
to upgrade system
Volume of soil
B. Cost Variation (Present Worth Costs)
Alternative Components _
Monitoring
Leachate Collection
Kegrading and Revegetalion
Capital Costs ($)
10%
,20%
10%
3ustilication lor Range
Contamination may spread
or lessen
Condition of existing
1} UIIKIIUWII
Volume to achieve necessary
grade was estimated
0AM Costs ($)
Total Variation ($>
' ,~' ' ' • —. . —.*—.—
Hijch
7,000
110,000
459,000
Low
7,000
74,000
375,000
High
373,000
55,000
4.000
Low
305,000
55,000
4,000
High
380,000
165,000
463,000
Low
312,000
1 29 , 000
379,000
Total Alternative Variation
576,000 156,000
432,000
364,000
1,008,000
820,000
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The environmental or public health laws which ^ay be relevant or aoolicaole
to the site are:
- Resource Conservation and Recover/ Act (RCRA)
The RCRA requirements for groundwater cleanup levels will apply
to final action at the site. Any requirements for soil removal
and disposal are not applicable.
- Floodplain Management Executive Order 11988 (E.O. 11988)
The purpose of this chapter is to implement Executive Order 11988, May 24,
1977, 42 F.R. 26951 entitled Floodplain Management.
This Order requires the evaluation of potential effects of actions taken
in a floodplain to reduce the risk of flood loss, to minimize the impact
of floods on human safety, health and welfare, and to restore and preserve
the natural and beneficial values served by floodplains.
- Clean Water Act (CWA)
The action proposed at the site by this document will comply
with the requirements of the act since there is no surface water
contamination attributable to this site.
- Occupational Safety and Health Administration (OSHA) requirements.
Any applicable OSHA requirements will be addressed during the
detailed design phase of the selected alternative. OSHA
requirements address such concerns as on-site worker safety and
health. All alternatives can be designed to be in full compliance
with OSHA requirements.
- Groundwater Protection Strategy (GWPS)
The GWPS is an applicable standard for this site. The levels
recommended by the Region IV office of Groundwater Protection are
found in Table 8 of this report.
- Department of Transportation
DOT requirements for movements of hazardous wastes, will address any
leachate collected above the alternate concentration limits listed in
Table 8.
- Other Applicable Laws (see Table 7)
OPERATION AND MAINTENANCE (O&M)
This remedy will require at least 10 weeks to implement with a design
life of 30 years. This time limit depends on the design, and operation
of the operable units and future activity at the site. The operating
costs will be for the implementation and the operation of the leachate
-22-
-------
collection, regrading, revegetating, and rrcnitoring wells and maintenance
of these units. After the remedy is i.-rplenented (10 weeks) the cost required
will be to maintain the restored site, arid oeriodic monitoring to insure
the oermanence of the remedy.
.As required by CERCLA, 1C4 (c)(l) amended by SARA (PL 99-499),
("the State will pay or assure payment of ...(ii) 50 percent
(or such greater amount as the President may determine
appropriate, taking into account the degree of responsibility
of the State or political subdivision for the release) of any
sums expended in response to a release at a facility, that
was operated by the State or a political subdivision...."]
Response has been defined in SARA as a "Remedial Action" as including all
construction and implementation activities until site remediation is
completed. Activities required to maintain the effectiveness of the remedy
following completion of the remedial action is considered operation and
maintenance (O&M). If surface water or groundwater treatment is part of
the remedy, only the first ten years of such treatment will be considered as
remedial action; the remaining period of treatment will be a part of O&M
activities. The State is required to pay 100 percent of all O&M following
completion of the remedial action. EPA and the State may enter into an
agreement whereby EPA would fund 90 percent of O&M costs, for a period
not to exceed one year, during which the remedy is determined to be
operational and functional.
SCHEDULE
The planned schedule for completion of the cleanup at the Newport Dump
site is as follows:
March 27, 1987 Record of Decision
September 30, 1987 Remedial Design Completed
December 1, 1987 Remedial Action Commences
This schedule is contingent upon the simultaneous availability of both
Federal and State funding. At which time, 6 months will be required for
design and to select a contractor, after which approximately 10 weeks of
activity will culminate in a full stabilization of the waste source and
groundwater contamination at the site.
FUTURE ACTION
As part of the design, additional investigation will be performed to
completely define the extent of contamination. This action is not a
complete cleanup remedy and any future action will depend on the monitoring
analysis results. Subtitle D closure activities should commence after
the operable units are constructed and implemented at the site.
-23-
-------
rmuni-y ReJ.aci.ons .Responsiveness
T JCMP SITE
Campoeii County
Wilder, Kentucky
Introduction
For tne puolic record, tais summary documents questions and comments raised
during tne puolic meeting and comment period on tne Newport Dump Remedial
Action/Feasibility Study. Concerns raised during tne comment period from
Marcn 3, to Marcn 24, were responded to by the Remedial Project Manager of
the Newport Dump Site.
At the March 3, Newport puolic meeting the Campbell county residents and
local administrators were interested in the final results of the investigation.
The information respository was placed at the Campbell County Puolic Library,
Newport, KY. Several notewortny comments made at the public meeting were:
1. One resident stated that from 1976 to 1979 former employees at the
site ooserved numerous trucks dumping sealed barrels at the site on
a regular basis. The question was raised whether the investigation
was extensive enougn to realize the implications the Durial of drums
might have five or ten years hence.
RESPONSE: The subsurface area in question was in the western section of
tne site. Several wellpoints were drilled in that area and
any leaching material frcm the deteriorating drums or snallow
acquiter was pinpointed in tne groundwater sample analysis.
Subsequent remedial design work, will explore this area further
using EM survey equipment and drilling boreholes.
2. Another resident named a possible eyewitness to sane of the illegal
dumping that transpired before tne site was closed in 1980 (see Court
Reporter Transcript).
3. Public administrators of the City of Newport and Northern Kentucky
Port Authority raised concerns over some ot the more expensive alter-
natives i.e. solidification and excavation that were recommended in
the feasibility study. They indicated tnat any remedy costing as
much as one million collars would be impossiole to meet considering
the present financial status of the municipalities.
-------
Aside from tne presentation jive cy £?A, tne acove : a merits were t..e ::j_s
ot Discussion during tne question anc answer perioc. :.-.e :jrnric:it ::eri_d
cor tne site went rro.n '-Varcn 3, L^d7, tr.ru .March 24, I*d7, one Better -.as
received from a concerned citizen. This letter nas .oeen jopie-j a no attached
to tnis reoort.
Letters and Responses addressing Conmunity Concerns
1. Fecnter and Sailer, Attorneys at Law residing in Cincinnati, Chio wrote a
letter to tne EPA concerned witn former employees of tne Newport Dunp
Site ooserving the durping of sealed oarrels at the site trom 1976 to
1979. Ihese individuals noted that tne dumping occurred in tne western
portion of tne site nowever tney nad no knowledge as to the content of
tne barrels. The author of tne letter, Mr. Lewis Seiler felt that the
remedial investigation made no attanpt to discover the location and
etfects of tne possiDle leaking of deteriorating druns oelow tne surface.
It is Mr. Seller's opinion tnat a selection ot an alternative would be
premature at this point until a careful investigation is made ot areas
wnere the alleged drums -were ouried.
RESPONSE
Curing the investigation wellpoints were placed in the area where the
drums were presumably ouried in tne suosurface. Any discharge tram the
ouried material was observed during the sampling ot these wellpoints. No
narmtul effects of tnis leaching material was noted in the surtace water
or the Kenton County intake. Further investigation and monitoring of
this area will take place during the remedial design and remedial action
phase.
Remaining Concerns
Other issues involve the future land use of tne site proposed by tne City of
[Newport and the NKPA, and Kentucky State funding cor the selected remedial
alternative, Alternative *3. The main concern is that any proposed land
renovation and reclamation at the site could curtail tne design life of the
remedial alternative selected and affect the staoility of tne site. A puolic
healtn and environmental evaluation would be necessary anter the remedial
action is implemented and before any turther construction and land renovation
takes place at the .Newport Cunp Site.
-------
Finrn-R & SEILF.R
A — ~"'.£.'<5 * ' _.'• A
J'..^. i.\s| I I(N V. !.M I!
1 ;si ;\v \ 'I. ( in I' i i^j'i'J
nnm;«
Li'\ns ii sr.ii.cu
Mr. Dennis Mar.~ar.ie . A o
Emergency & Remedial Response Branch
L'.S'. Environmental Protection Agency
345 Court land St. N.E.
Atlanta, GA 30365
RE: Newport Dump Sit.e
Wilder, Campbell County, KY
March 3, 1987
Dear Mr- Manganieilo:
I am writ. ing to you in my capacity as the attorney for two
former employees at the Newport Dump Site. These individuals have
advised me that during their employment at the site between the
years of 1976 and 1979 they observed numerous trucks dumping
sealed barrels containing liquid at. the site on a regular basis,
and further that said trucks belonged to t.he King Wrecking
Company of Cincinnati, Ohio. My client. s advised me that the
dumping of such barrels occurred at least several times a week,
and although said dumping was by no- means localized that
generally occurred in the western portion of the dumpsite in t
areas just north of the unnamed stream and further along the
western edge of the site While my clients had no knowledge as to
the content, of the barrels which they observed, this information
is clearly cause for concern, given t.he proximity of the site to
the intake inlets for the Kenton County Water System.
I have carefully reviewed the Remedial Investigation and
Feasibility Study of Alternatives regarding the Newport Dump Site
prepared for the EPA, and this review only has created further
concern on my part. The study concentrates its attention on
determining the -nature and extent of the contaminant. s presently
leaching from the dump site. However, 'it is f righteningiy
evident. that, the study made no. attempt to ascertain what is
actually on site, but not yet leaking. An example of such
material would be toxic wastes in barrels which are deteriorating
with age but which have not yet. started to leak.
Electromagnet, ic readings were taken along the perimeter of
t.he sii-.e in order to ascertain the site's probable boundaries
(See -Study page 3-10). The Electromagnetic Study (EM study)
indeed die reveal an area along the southern perimeter of the
site and right adjacent to t.he unnamed stream which flows into
the Licking River, which contained higher than expected EM
readings. This area was designated as "Area C" in the stuc5
which drew t.he following conclusion regarding the area:
-------
"Area 2, located acu'h be* ween the landfill and the ur.r.a.Ted
stream is an a n c ~ a i c u 3 -area c ; r. i g r. and lew ~ c n d u c 11 •/11 v values
with respect to off site background ccndi
that t h i s. ancrraly is representative
materials,
suspected
^ i
b u r i a d
ferrous
• &/~ *
chemical c c r. s t i" u e r. t s
at cage 3-13)
a solid,
•="_ ; a , or a_ n i g n concentration
cuid, or sludge form.
(Studv
In other words, it. is suspected that this area may contain
barrels, or high concentrations of potentially dangerous
chemicals. Yet amazingly enough, this area was not excavated,
nor even bored into in order t.o ascertain the nature of the
material located in Area C. A review of the soil borings
performed (See page 4-12, Figure 4-3) reveals t.hat NO borings
were taken in the anomalous area, and indeed the Appendix at page
3-7 indicates that EM readings were generally used in order to
avoid striking buried ferrous object.s.
Interestingly enough, the. EM findings are entirely
consistent with t.he facts provided to me by my clients, namely
that they observed barrels being buried in and around "Area C".
It is the opinion of the undersigned and my clients that a
careful investigation must be made as to the nature of.the buried
before an appropriate treatment plan can be determined
site. If indeed there are a large number of buried
on site which contain hazardous materials, there may
a much greater danger to the surrounding community and
Kenton County Water supply than is presently realized.
This issue should be fully and carefully addressed before a final
alternative is'selected.
material
for t.he
barrels
we 11 be
to t.he
-------
* \1 '' UNITEDS7A-E3 EN V ! =C N VENTAL = PC":7:CN AGENCY
'v •.--'•'" PEG ION :v
*[ BOO1*'
3 j 5 c o 'j s 7 L A ;s 3 5 7 = E E: -
A7LA NT A ^eoRG'A j::ss
REF: 4WD-ER
Fichter & Seller
Attorneys at Law
2056 Eastern Avenue
Cincinnati, Ohio 45202
Dear Mr. Seiler:
I am writing to you in. response to your March 3, 1987, letter regarding
the situation at the Newport Dump site. During the investigation well-
points were placed in the area where the drums were presumably buried in
the subsurface. Any discharge from the buried material was observed during
the sampling of these wellpoints. Mo harmful effects of this leaching
material was noted in the surface water or the Kenton County intake.
Further investigation and monitoring of this area will take place during
the remedial design and remedial action phase. The implementation of the
remedial action will take place within the year. Based on. the EPA findings
and the upcoming remedial action I believe that the determination of a
remedy prior to performing- any additional monitoring was a reasonable and
necessary decision and in the best interest of the public welfare.
The Newport Dumo site Record of Decision will be made available for review
at the Campbell County Public Library and City Clerk's office located in
Newport, KY. Your letter and this response are considered as part of the
Record of Decision. If you have any questions about this response or the
decision, please call me at (404) 347-2234.
Sincerely, , /V/
Hanged ello
Dump Site Project Manager
Emergency and Remedial Response Branch
-------
JEFFREY J. HARM ox
ATTORNEY AT LAW
2OO8 GAREW TOWER
Or COUNSEL TO CINCINNATI. OHIO -432O2 TELEPHONE
JOSEPH R.JORDAN ,313] 891-4-+3S
24 March 1987
Mr. Dennis Manganiello
Emergency and Remedial Response Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE» Newport Dump Site
Campbell County, Kentucky
Dear Mr. Manganiello»
I have enclosed for your review comments on the
proposed remedial alternatives for the Newport Dump Site in
Campbell County, Kentucky. i am submitting these comments
on behalf of the City of Newport, Kentucky and the Northern
Kentucky Port Authority. I understand from our telephone
conversation of Thursday, March 19, 1987 that your receipt
of these comments after March 24, 1987 will still be
considered timely and the comments will be incorporated into
the formal record.
If you have any questions concerning the comments, do
not hesitate to contact me.
Thank you very much for your cooperation in this
matter. I look forward to receiving your response to the
comments and the ultimate decision on the selection of the
appropriate alternative for remedial action.
Very ,truly yours,
fj. Harmon
JJH/lr
-------
COMMENTS REGARDING
SELECTION OF REMEDIAL MEASURES
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
Submitted to:
Mr. Dennis Manganiello
Emergency and Remedial Response Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Submitted by:
Jeffrey J. Harmon, Esq.
2008 Carew Tower
Cincinnati, Ohio 45202
(513) 891-4455
on behalf of:
City of Newport
Fourth and York Streets
Newport, Kentucky 41071
and
Northern Kentucky Port Authority
400 Licking Pike
Wilder, Kentucky 41071
-------
COMMENTS REGARDING
SELECTION OF REMEDIAL MEASURES
NEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
I. Introduction
The City of Newport, Kentucky (Newport) and the
Northern Kentucky Port Authority (NKPA) jointly submit the
following comments regarding the selection by the U.S.
Environmental Protection Agency (EPA) of the appropriate
remedial measures for the Newport Dump Site (the Site)
located in Campbell County, Kentucky. Newport and NKPA are
submitting these comments in connection with the public
comment process which the EPA is conducting with respect to
the Site.
These comments are based primarily upon a review of the
report of the Remedial Investigation and Feasibility Study
(RI/FS) conducted for the Site: discussions with current or
former representatives of Newport and the NKPA concerning
the Site; information obtained at the public meeting
conducted by the EPA on March 3, 1987 at the Campbell County
Courthouse; and the review of the Closure Plan prepared for
the Newport Landfill approved by the Kentucky Department for
Natural Resources and Environmental Protection and related
agreed orders.
-------
II. Reservation of Rights
In submitting these comments neither Newport nor NKPA
concedes that it is a "responsible party" under the
Comprehensive Environmental Response, Compensation and
Liability Act, 42 U.S.C. Sections 9601, et seq. (CERCLA), or
a "person" under the Resource Conservation and Recovery Act,
42 U.S.C. Sections 6901, e_t aeq^ (RCRA), in connection with
the Site. In addition, Newport and NKPA deny any liability
under CERCLA, RCRA, or any other statute, regulation, or law
governing the use and disposal of hazardous waste,
pollutants, contaminants and substances.
In submitting these comments neither Newport nor NKPA
conducted an independent inquiry into the accuracy or
completeness of the findings and conclusions in the RI/FS.
Therefore, Newport and NKPA reserve all rights to challenge
the selection of remedial measures by the EPA to be
-implemented at the Site and the findings and conclusions in
the RI/FS and all related documents and studies. These
comments should not be interpreted as a commitment to expend
any fund* in connection with the Site.
-------
Ill. Summary of Recommendation
Because the RI/FS reveals that the Newport Dump Site
poses no present threat to human health or the environment
and will not likely pose such a threat for a considerable
period of time, if ever, Newport and NKPA submit that, at a
maximum, Alternative 3 involving monitoring, leachate
collection, and regrading and revegetation should be
selected for the Site.
IV. Comments
The selection of Alternative 3 set forth in the RI/FS
would be consistent with both CERCLA and current EPA
guidance on Superfund selection of remedy. Therefore,
Newport and NKPA recommend that the EPA, at a maximum,
choose Alternative 3 as the appropriate remedial measure
alternative for the site. However, Newport and NKPA further
contend that the remedial measures called for in Alternative
2 requiring a multimedia monitoring program would adequately
protect human health and the environment under the
circumstances.
Consistent with CERCLA and EPA guidance, the remedial
action contemplated by Alternative 3 will: 1) protect public
health, welfare and the environment; 2) attain federal and
state public health and environmental requirements; and 3)
be cost-effective.
-------
Protective of Public Health and Environment
The document entitled,"Superfund Program Fact
Sheet, Newport Dump Site, Campbell County, Kentucky" which
the EPA Region IV made available at the March 3, 1987 public
meeting regarding the Site designates Alternative 3 as the
"Alternative that Protects Public Health, Welfare and the
Environment." The RI/FS clearly supports this position.
Alternative 3 calls for a number of remedial
measures at the site including:
- a multimedia monitoring program
- repair of the leachate collection system
and its expansion to the northeast slope
- installation of a collection batin and
pumping system
- regrading and revegetation of portions
of the site.
The RI/FS makes it eminently clear that these remedial
measures will properly secure the Site and protect human
health and the environment.
-------
These measures are consistent with work which the
NKPA has voluntarily conducted at the Site in connection
with the Closure Plan prepared for the Newport Landfill
approved by the Kentucky Department for Natural Resources
and Environmental Protection and related agreed orders
entered into respectively on July 9, 1980 and October 30,
1984.
It appears that at least some of the work called
for in Alternative 3 may have been completed in connection
with closure of the Site or preparation of the RI/FS. For
example, a number of monitoring wells are in place at the
Site and can be used to implement the multimedia monitoring
program. Also, a substantial amount of regrading and
revegetation has taken place at the Site. The NKPA has
expended approximately $600,000.00 towards closure of the
site to date, which represents efforts to secure the Site
which largely will not have to be duplicated.
The single overriding reason that the Newport Dump
Site received a score on the Hazard Ranking System which
appeared to justify its inclusion on the National Priorities
List is the close proximity downstream of the Kenton County
District One raw water intake. (RI/FS, 1-6) In the absence
of this factor it is doubtful that the Site would have been
placed on the NPL.
-------
The RI/FS substantiates the fact that the Newport
Dump Site does not pose a threat of contamination of the
water intake. The primary reasons are: 1) the release of
only negligible levels of contaminants from the site? and 2)
the dilution rate in the Licking River of 41,667 to 1. The
study indicates that no harmful levels of contaminants were
found near the water intake which Kenton County District One
monitors continuously in any event. In fact the study
states, "No site-related contaminants were detected in the
surface water in (the) Licking River." (RI/FS, 5-37) With
periodic monitoring taking place at the Site, it appears
that there will be more than ample safeguards against the
undetected release of harmful levels of contaminants which
have any chance of reaching the water intake.
Another factor which demonstrates the absence of a
long or short term threat to human health or the environment
is that the primary contaminants at the Site appear to be
heavy metals which are relatively immobile. There also
appears to be some contamination at the Site of PCBs and
PAHay however the analysis strongly suggests that adjacent
properties may be the ultimate source of these contaminants.
The proper remedial action for these contaminants would
address the source.
-------
The RI/FS substantiates the fact that the Newport
Dump Site does not pose a threat of contamination of the
water intake. The primary reasons are: 1) the release of
only negligible levels of contaminants from the site; and 2)
the dilution rate in the Licking River of 41,667 to 1. The
study indicates that no harmful levels of contaminants were
found near the water intake which Kenton County District One
monitors continuously in any event. In fact the study
states, "No site-related contaminants were detected in the
surface water in (the) Licking River." (RI/FS, 5-37) With
periodic monitoring taking place at the Site, it appears
that there will be more than ample safeguards against the
undetected release of harmful levels of contaminants which
have any chance of reaching the water intake.
Another factor which demonstrates the absence of a
long or short term threat to human health or the environment
is that the primary contaminants at the Site appear to be
heavy metals which are relatively immobile. There also
appears to be some contamination at the Site of PCBs and
PAHs; however the analysis strongly suggests that adjacent
propert.ie« may be the ultimate source of these contaminants.
The proper remedial action for these contaminants would
address the source.
-------
It is important to note, as the RI/FS did, that
the Site is not currently developed and does not serve as
the drinking water source for anyone. Therefore, in situ
management of the waste at the Site is appropriate. So long
as the waste is contained at the Site, human contact with
the waste will be negligible. With the proper capping and
vegetation, there is no reason that this Site cannot be
developed in a manner that would not jeopardize human
health.
In addition the muddy Licking River experiences
minimal recreational use so that even in the unlikely event
that harmful levels of contaminants reached the Licking
River, there is little chance for human contact with the
contaminants. Also, the impact of any such contact would be
rendered negligible by the dilution factor mentioned above.
The RI/FS substantiates that the risks of
migration of contaminants from the site through the
groundwater are minimal. With the horizontal groundwater
velocity at the Site calculated to be 4.4 feet/year and a
vertical velocity of 0.05 feet/year, the groundwater does
not pose a threat of contaminating the Licking River or the
surrounding area. Perhaps this is most dramatically
demonstated by the calculation in the RI/FS that it would
take 472 years for groundwater travel time from the
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upgradient boundary of the landfill to the Licking River.
The RI/FS notes that "the impact of groundwater discharge to
the river is expected to be negligible." (RI/FS, 4-50)
In short, the RI/FS supports the proposition that there
is no evidence of release of harmful levels of contaminants
through any medium from the Site, and the chances of such
releases in the future are minimal. The remedial measures
called for in Alternative 3 would further secure the Site
and therefore meet the standard of protecting human health
and.the environment.
Attainment of Federal and State Standards
The RI/FS states:
"The public health evaluation performed
during the RI found no evidence of any current
public health or environmental concerns associated
with the Newport Dump Site. The contaminant levels
in the surface soils and in surface water and
sediment downstream of the site were below all
accepted health criteria; while dilution of shallow
groundwater contaminants as a result of discharge
to the Licking River is expected to reduce these
contaminants to negligible levels." (RI/FS, 1-12)
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Cost-Effective Remedy
The RI/FS attributes an estimated cost to
Alternative 3 remedial measures of $914,000. In contrast,
Alternative 4 involves the estimated cost of $17,175,000.
The additional remedial measures called for in Alternative 4
simply are not necessary for the protection of the public
health or welfare or the environment. This quantum leap in
expenditures with no corresponding benefits to human health
or the environment are not necessary and therefore not
mandated by CERCLA. To choose Alternatives 4, 5, or 6 would
be inconsistent with criteria of cost-effectiveness of the
remedial measures. Considerations of cost-effectiveness
therefore support the selection of Alternative 3 as the
maximum remedial measures for the Newport Dump Site.
V. Conclusion
The Newport Dump Site does not pose any current threat
to human health or the environment and is not likely to pose
such a threat in the future. The remedial measures called
for in Alternative 3 would properly secure the Site and
permanently contain any contamination in a manner protective
of human health and the environment. Therefore, at a
maximum the EPA should select Alternative 3 for the remedial
measures to be implemented at the Site.
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UNITED STATES E.*«'VI rC WEN'-* L PPC'ZITIC'- AGENCV
*.,( aor,l-;- -EG:C:; :v
A T i_ A N T a :, E: D = c' A ::: 5 5
REF: 4WD-ER
Jeffrey J. Hannon
Attorney at Law
2008 Carew Tower
Cincinnati, Ohio 45202
Dear Mr. Harmon:
This letter is in response to your correspondence and review cements
of March 24, 1987, on the Newport Dump site investigation and proposed
remedies. I concur with your position that Alternative 3 of the
Newport Feasibility Study would be a cost-effective remedy that will
attain appropriate, relevant and applicable public health and environment
standards. The EPA has selected this alternative as the remedy chosen
for remedial design and remedial action at the Newport Dump site.
Your comments are in accordance with the EPA findings presented in both
the Remedial Investigation and Endangerment Assessment reports. You
will be able to find a copy of the Newport Dump site Record of Decision
at the Campbell County Public Library, and City Clerk's office located
in Newport, Kentucky. Your comments and this response are considered
as part "of the Record of Decision. If you have any questions about
this response or the decision please call rr,e at (404) 347-2234.
Dennis J^/Manganielj
Newport *T)ump Site Project Manager
Emergency and Remedial Response Branch
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MARY HELEN MILLER
MARTHA LAYNE COLLINS
C3MMO.NV.EAi.-r- Of .<£\"^ C
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•'.'• ',.
— r
m
f i.i
j'.'lTEO STATES ENVIRONMENTAL PROTECTION AGENCY
=? E G IC N IV
MS COURTLANO STREET
ATLANTA. GEORGIA 30355
F£B 2 * 1997
Sijbiect' 0;=vi ov rrrTvnt.s - v!ewrort rnjrn Site °.. The selected alternative complies with the reouirements of 512Kb) of SARA.
SAPA emnhasizes destruction or detoxification of hazardous waste bv emnlovina
treatment technologies which reduce toxicitr.v, mobilitv or volume rather than
nrotection achieved throuah. prevention of exposure. However, the costs and
notential adverse effects to human health and the environment associated with
excavation, transportation and treatment Far outweio^ the benefits of a remedial
alternative that destroys or detoxifies wastes In the dtno. r'te concur with
the re~dia.l alternative recommended in the Feasibility Study.
3. The hvdrooeo Ionic and contamination data collected durinn the RI indicates
that the ronuiroments i"or Altcrnati? Concentration Mm its (ACLs) under
^1.21(d) of SARA mav/ ho net flt this site. The RI report contains most of the
information rocuif^d to ilovplop AOLs, ar.d therefore moets the ARAP.'s under
4. Qd of RC
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.•'""I.
DEPARTMENT OF HEALTH & HUMAN SERVICES Ay 'Vlox c
^A»— 3s*3S* ReciW
' Memorandum
Date -March 31, 1987
From Public Health Advisor
ATSDR-EPA Liaison
Subject Newport Dump NPL Site;
Covington County, Kentucky
To Dennis Manganiello, Project Manager
EPA ERRB RAS
As requested, the draft Record of Decision, Remedial Alternatives Selection
has been reviewed for its public health adequacy.
The ATSDR's Health Assessment for this site concluded that the present and
any potential future health threat posed by this site is minimal. As such,
we concur with you that the proposed alternatives of monitoring, regrading,
revegetation and leachate collection provide sufficient public health threat
protection for this site.
Chuck Pietrosewic
cc: file
ATSDR/OEA
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ic ACLs cor ?ach contaminant wore ^t included as oart cc t1"3
nrooram in t'^e reccmended alternative. ','» reccrr^n^ r.^at the r?
u^ revise^ co incl';rip tr.os*3 A"r,s. TK° "v^ipt-. of ^xrosurt? should S? ccnsi^ered
t'".e Mckina "i^er, -end "'ne -HL'.it0^ concentration of = estinatod .^t tv^e historical lew clow in the river. T-c these
conc°ntrations in the ••iver do not exceed acuatic toxicitv criteria, ACLs
For each hazardous constituent-, pav tv» determined based on dilution in surface
water and attenuation in the aouifer prior to discharae.
The alluvial aoui.^er is classified as 113, a potential source of drinkina
water under the National Hround-V.'ater Protection Strateov, and should
therefore receive the baseline \»vel of protection reouired under CFD-CLA.
Joe Muohart,
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