United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-90/068
September 1990
&EPA Superfund
Record of Decision:
North Hollywood Dump, TN
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50272-101
REPORT DOCUMENTATION i. REPORT NO. t
PAGE EPA/ROD/R04-90/068
4. TM* wtd Subtfflo
SUPERFUND RECORD OF DECISION
N h Hollywood Dump, TN
i c Remedial Action - Final
7. AuOortt)
•. Performing Orgainlatfon Nemo and Addma
t
M Spomoring Organiution Norm end Addreeo
U.S. Environmental Protection Agency
* 401 M Street, S.W.
Washington, D.C. 20460
\
X ReclpienTs Acceealon Now
i. Report Data
09/13/90
8.
«. Performing Organisation Rapt No.
10. Proiectnaak/Work Unit No.
11. ContnctO or Grant(G) No.
(Q
(0)
IX Type o« Report » Period Covered
800/000
14.
IS. Supplementary Note*
' 11 Atafract (Limit: 200 worda)
The 70-acre North Hollywood Dump site is an inactive, privately owned landfill in
Memphis, Shelby County, Tennessee, in the Wolf River floodplain. Directly beneath the
site is a contaminated aquifer from which ground water discharges directly to the Wolf
River. Adjacent to the site are an abandoned dredge pond, a beaver pond, and Oxbow
La^°, all of which were affected by the site. From the mid-1930s until its closure in
1! municipal and industrial refuse were disposed of at the site, which was operated
by ie city of Memphis. A precise description of the materials disposed of is unknown.
In addition, unauthorized dumping is- thought to have occurred during the 1970s. In 1979
and 1980, EPA and State studies revealed various contaminants both onsite and offsite in
soil, sediments, ground water, surface water, and fish. Commercial fishing activities
in the Wolf River ceased, and EPA required removal of contaminated soil, capping of the
landfill, and fencing of the sice. The RI/FS process identified buried drums onsite.
This Record of Decision (ROD) addresses all of the contaminated media by containing the
source areas, including the landfill and onsite surface water bodies, with provisions
for offsite surface and shallow ground water monitoring and treatment as necessary. The
primary contaminants of concern affecting the soil, sediment, debris, ground water, and
(See Attached Page)
17. Document Analytic a. Oeecriptora
Record of Decision - North Hollywood Dump, TN
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw, sw
Key Contaminants: organics (pesticides), metals (arsenic,
b. Mentfflera/Open-Ended Terma
lead)
C. COSAT1 FWtd/Croup
It. Bfekly Statement
19. Security Cli«» (Thi« Report)
None
20. Security Cilia (This Pigo)
None
21. No. of Page*
275
22. Price
(See ANSI-Z3».ia)
S«e Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-JS)
Department of Commerce
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EPA/ROD/R04-90/068
North Hollywood Dump, TN
First Remedial Action - Final
Abstract (continued)
surface water are organics including pesticides, specifically aldrin, endrin and
chlordane; and metals including arsenic and lead.
The selected remedial action for this site includes excavating buried wastes and soil in
easily eroded areas near the edge of the landfill and consolidating them in the landfill
area; excavating and characterizing waste within the buried drums; consolidating debris
in the landfill or, should contaminant levels warrant it, properly disposing of debris
as well as drummed wastes offsite; upgrading the existing landfill cover to be a total
of 24 inches thick; partially dewatering the surface impoundments; excavating the
contaminated sediment from the beaver pond and placing them within Oxbow Lake; covering
the contaminated lake and beaver pond sediments with a 36-inch hydraulic geofabric
cover, and infilling Oxbow Lake with clean fill; harvesting contaminated fish from the
abandoned dredge pond; hydraulically containing the contaminated dredge pond sediment
with geofabric and three feet of clean fill; refilling the pond with water and
restocking with unaffected fish; monitoring the shallow ground water, with provisions
for future pumping and treatment if necessary; conducting surface water (both onsite and
offsite), air, and biota monitoring; and implementing institutional controls to restrict
onsite land use and to prohibit well installation in the vicinity, and site access
restrictions including fencing. The estimated present worth cost for this remedial
action is $8,041,890, which includes a total O&M cost of $1,610,310.
PERFORMANCE STANDARDS OP. GOALS: Specific goals for ground water include arsenic 0.140
ug/1 (proposed State Water Quality Standard) and lead 3.8 ug/1 (CWA Water Quality
Criteria) at the point the ground water reaches the Wolf River.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RECORD OP DECISION
REMEDIAL ALTERNATIVE SELECTION
NORTH HOLLYWOOD DUMP
MEMPHIS, TENNESSEE
. PREPARED BYt
0.3. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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RECORD OF DECISION
Remedial Alternative Selection
SITE NAME AND LOCATION
North Hollywood Dump
Memphis, Tennessee
STATEMENT OP BASIS AND PURPOSE
This decision document presents the selected remedial action for the North
Hollywood Dump in Memphis, Tennessee developed in accordance with CERCLA, as
amended by SARA, and to the extent practicable, the National Contingency Plan.
This decision is based upon the contents of the administrative record for the
North Hollywood Dump Site.
The United States Environmental Protection Agency and the State of Tennessee
agree on the selected remedy.
ASSESSMENT OP THZ SITB
Actual or threatened releases of hazardous substances from this aite, if not
addressed by implementing the response action selected in this Record of
Desiaion (ROD), may present a current or potential threat to public health,
welfare, or the environment.
jESCRIPTION O? THE SELECTED REMEDY
This final remedy addresses remediation of soil, sediment, groundwater and fish
contamination by eliminating or reducing the risks posed by the site through
containment using engineering and institutional controls.
The major components of the selected remedy Include:
Install and maintain a 24 inch low-permeability soil cover over the
landfill area.
Consolidate contaminated soil near the surface water bodies under the
24 inch cover in the controlled portion of the landfill less prone to
flooding and erosion.
Monitor shallow groundwater contaminant levels to insure levels stay
below health based standards set to control groundwater discharges to
the Wolf River.
Should groundwater levels increase, extract groundwater and discharge
to the local sewer system.
Re-sample Oxbow Lake and the Dredge Pond sediments and fish to better
identify and define the contamination
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ji Install and Maintain a 36 inch hydraulic cover over the contaminated
sediments.
y
j Remove contaminated fiah and re-atock surface water impoundments to
2 maintain the environmental food chain of the area.
Install and maintain a fence around the entire site.
Impose land and groundwater use restrictions on the site.
STATORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource recovery)
technologies, to the maximum extent practicable for this site. However,
because treatment of the principal threats of the site was not found to be
practicable, this remedy does not satisfy the statutory preference for
treatment as a principal element.
As this remedy will initially result in hazardous substances remaining on site
above health-based levels, a review will be conducted within five years after
the commencement of remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
Date Greer C. Tidwell
Regional Administrator
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TABLE OF CONTENTS
SECTION
I. INTRODUCTION 1
II. SITE NAME, LOCATION AND DESCRIPTION 1
III. SITE HISTORY AND ENZORCEMENT ACTIVITIES 1
HISTORICAL LANDFILLING PRACTICES 1
INVESTIGATIONS AND STUDIES COMPLETED TO DATE 3
IV. HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
V. SCOPE AND ROLE OF RESPONSE ACTION 5
VI. SUMMARY OF SITE CHARACTERISTICS 5
GEOLOGY AND HYDROGEOLOGY 5
DEMOGRAPHY 7
LAND USE 7
NATURAL RESOURCES 8
CLIMATOLOGY 8
NATURE AND EXTENT OF PROBLEM 3
WASTE IDENTIFIED ON SITE 8
GROUNDWATER CONTAMINATION 20
SURFACE WATER CONTAMINATION 31
FISH CONTAMINATION 32
SURFACE WATER IMPOUNDMENTS 43
HEALTH ASSESSMENT 49
VII. SUMMARY OF SITE RISKS 49
SELECTION OF CONTAMINANTS OF CONCERN 49
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DOSE-RESPONSE EVALUATION 52
EXPOSURE ASSESSMENT 53|
RISK CHARACTERIZATION 56
ENVIRONMENTAL RISKS 53
UNCERTAINTIES. - 64
VIII. DESCRIPTION OF ALTERNATIVES 66
LANDFILL WASTES AND SHALLOW GROUNDWATER 67
ALTERNATIVE 1 - NO ACTION 67
ALTERNATIVE 2 - LOW PERMEABILITY SOIL COVER 67
ALTERNATIVE 3 - LOW PERMEABILITY SOIL COVER 6 HYDRAULIC
CONTAINMENT BY EXTRACTION WELLS 68
ALTERNATIVE 4 - LOW PERMEABILITY SOIL COVER & PHYSICAL
CONTAINMENT BY BARRIER WALL 68
ARARa 68
IX. SURFACE WATER IMPOUNDMENTS 69
ALTERNATIVE 1 - NO ACTION 69
ALTERNATIVE 2 - PERIODIC HARVESTING OF FISH 69
ALTERNATIVE 3 - DREDGE WITH CONTAINMENT ON EAST SECTOR
OF LANDFILL 70
ALTERNATIVE 4 - IN-PLACB CONTAINMENT WITH HYDRAULIC FILL 70
ALTERNATIVE 5 - IN-PLACB CONTAINMENT BY NATURAL DEPOSITION
AND RE-ROUTING OF WOLF RIVER 70
ALTERNATIVE 6 - EXCAVATE WITH CONTAINMENT ON EAST SECTOR
OF LANDFILL AND IN-PLACE CONTAINMENT WITH HYDRAULIC FILL 71
ARARa 71
X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 71
LANDFILL WASTES AND SHALLOW GROUNDWATER 72
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 72
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COMPLIANCE WITH ARARa 72
REDUCTION OP TOXICITY, MOBILITY OR VOLUME THROUGH TREATMENT 78
LONG-TERM EFFECTIVENESS AND PERMANENCE 78
SHORT-TERM- EFFECTIVENESS 78
IMPLEMENTABXI.ITY,. 79
COST 79
STATE ACCEPTANCE 79
COMMUNITY ACCEPTANCE 79
SURFACE WATER IMPOUNDMENTS 79
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 80
COMPLIANCE WITH ARARs 80
REDUCTION OF TOXICITY, MOBILITY OR VOLUME THROUGH TREATMENT 80
LONG-TERM EFFECTIVENESS AND PERMANENCE 80
SHORT-TERM EFFECTIVENESS 80
IMPLEMENTABILITY 87
COST 87
STATE ACCEPTANCE 88
COMMUNITY ACCEPTANCE 88
XI. SELECTED REMEDIES 88
LANDFILL WASTES AND SHALLOW GROUNDWATER 88
SURFACE WATER IMPOUNDMENTS 92
XII. STATUARY DETERMINATIONS 100
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 100
COMPLIANCE WITH ARARs 100
COST EFFECTIVENESS 101
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UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE
MAXIMUM EXTENT PRACTICABLE 101
PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT 102
XIII. DOCUMENTATION OF SIGNIFICANT CHANGES 102
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TABLE OF CONTENTS (Confd)
LIST OP FIGURES
FIGURE PAGE
1 SITE LOCATION 2
2 LOCAL ZONING ADJACEHT TO. SITE SA
3 OFF-SITE SOIL SAMPLING LOCATIONS 10
4 CAP SURFACE SOIL SAMPLING LOCATIONS 19
5 SAMPLING LOCATIONS 24
6 GROUNDWATER MONITORING LOCATIONS 25
7 REMEDIAL ALTERNATIVE 2 - LANDFILL WASTES AND GROUNDWATER 90
8 REMEDIAL ALTERNATIVE 4 - SURFACE WATER IMPOUNDMENTS 95
9 HYDRAULICALLY FILLED OXBOW LAKE 96
10 HYDRAULICALLY CONTAINED DREDGE POND 97
LIST OF TABLES
TABLE PAGE
1 SURFICIAL SOIL SAMPLES (ROUND 2) 11
2 SURFICIAL SOIL SAMPLES (ROUND 4) 14
3 SURFACE CAP SAMPLES (ROUND 4) 21
4 THE CONTENT OF VARIOUS METALS IN THE LITHOSPHERE AND IN SOIL 23
5 WOLF RIVER WATER SAMPLES (ROUND 1) 33
6 WOLF RIVER WATER SAMPLES (ROUND 2) 35
7 WOLF RIVER WATER SAMPLES (ROUND 3) 36
8 WOLF RIVER WATER SAMPLES (ROUND 4) 37
9 WOLF RIVER SEDIMENT SAMPLES (ROUND 2) 39
10 FIRST QUARTER WATER SAMPLES 44
11 SECOND QUARTER WATER SAMPLES 45
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12 THIRD QUARTER WATSR SAMPLES 45
13 FOURTH QUARTER WATER SAMPLES 4
14 SEDIMENT SAMPLE RESULTS . SO
15 APPROPRIATE STANDARDS Airs CRITERIA FOR HUMAN HEALTH 54
15 EVALUATION OF HEALTH RISK FOR CONSUMPTION OF FISH FROM
OXBOW LAKE ". 59
17 SURFACE WATSR EXPOSURE AND RISK ASSESSMENT FOR CONSUMPTION OT
FISH IN ON-SITS PONDS £0
13 SUMMARY OF GROUNDWATER MASS FLUX DATA £2
19 ESTIMATED INCREASED CONCENTRATION IN WOLF RIVER 53
20 CALCULATION C? GROUNDWATER CONCENTRATIONS FOR ACLs 55
21 SUMMARY OF DETAILED ANALYSIS OF ALTERNATIVES FOR
LANDFILL WASTES AND CRCUNDWATER 73
22 SUMMARY OF DETAILED ANALYSIS OF ALTERNATIVES FOR SURFACE
WATER IMPOUNDMENTS 31
23 COST ESTIMATE - LANDFILL WASTES AND GROUNDWATIR :• 1
24 ALLOWABLE CONTAMINANT LEVELS IN FISH 94
25 COST ESTIMATE - SURFACE WATER IMPOUNDMENTS 93
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - LETTERS FROM SUPPORT AGENCIES
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3UMMAHY 0? REMEDIAL ALTERNATIVE SELECTION
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
NORTH HOLLYWOOD DUMP
MEMPHIS, TENNESSEE
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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RECORD OF DECISION
SUMMARY OP REMEDIAL ALTERNATIVE SELECTION
NORTH HOLLYWOOD DUMP
MEMPHIS, TENNESSEE
INTRODUCTION
The North Hollywood Dump Site was included on the National Priorities List
(NPL) in October of 1981 as the State of Tennessee's Top Priority Site.
Approximately 7.0 acres, North Hollywood received both municipal and industrial
waste and has been the subject of two Remedial Investigations (RI) and a
Feasibility Study (FS). The first RI/FS activities were conducted by a
Technical Action Group between 1980 and 1984. The need for additional data
prompted a second RI/FS between 1985 and 1989 which was conducted by a group of
Potential Responsible Parties (PRPs) under the direction of the State and EPA.
The Supplemental RI report which examines the quality of air, soil, surface
water, stream sediments and shallow aquifer groundwater at the site was
completed in April 1990. The FS report which examines alternatives for site
remediation was submitted to the public information repository with the RI
Report in June 1990.
This Record of Decision has been prepared to summarize the remedial alternative
selection process and to present the selected remedial alternative, in
accordance with Section 113(Jc)(2)(B)(v) and Section 117(b) of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act (SARA) P.L.
99-499). The Administrative Record for the North Hollywood Dump site forms the
basis for the Record of Decision contained herein.
SITE NAMH. LOCATION. AND DESCRIPTION
The North Hollywood Dump (hereinafter referred to as the Site) is located on
the floodplain and abandoned channels of the Wolf River in Memphis Tennessee
(Figure 1). The landfill was operational from the Mid-19308 to the mid-1960s.
During this period the Site was used primarily for the disposal of municipal
refuse; however, industrial refuse was also disposed of in the landfill. The
Site is divided into two separate areas of refuse disposal (East Sector and
west Sector) by Hollywood Street. Combined, the East and West Sectors
encompass an area of approximately 70 acres and have an average refuse layer
thickness of approximately 26.5 feet. The Site, comprised of lands owned by
the J. Curry family, E.G. Stephenson, E.A. Leone and E.J. Leone, was operated
by the City of Memphis.
Due to the disposal of the industrial and chemical wastes at the Site,
government agencies have raised concern regarding the potential environmental
impact from the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historical Landfillinq Practices
Records of the operation of the North Hollywood Dump during its active period
are not available to identify precisely the nature of material disposed of ac
the Site and the progression of the Site as it operated. The only information
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SITf OCA IK-I J
Hollywood
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available which provides some information as to how the landfill grew during
its years of active operation comes from aerial photographs of the Memphis area
for the period 1937 through 1979.
The aerial photographs show that in 1937, the Site was less than one acre in
size and was surrounded by woodlands and farmlands. Disposal of waste started
on the East Sector of the Site directly adjacent to Belmont Circle. By 1946
and 1948 the landfill waa expanding at a rate of approximately two acres per
year. The photograph* for these periods show no evidence of grading or cover
activities during these initial stages of operation. The 1948 aerial
photograph indicates that a portion of the landfill is flooded, thereby
resulting in floodwater infiltration of the waste. This is known to have
happened on a minimum of eight occasions prior to the closing of the Site.
During the early 1950s, the aerial photographs indicate that the landfill was
expanding at a rate of three to five acres per year and Site management/control
activities were in place. Site access was gate controlled, cover material was
being applied periodically, and the new expansion areas were operated in
lifts. By the mid 1950s, channelization projects undertaken by the government
and Site expansion had impacted the Wolf River, resulting in the severance of
one southward and two northward meanders. Active burning operations at the
Site are evidence in both the 1955 and 1958 aerial photographs. By the late
1950s, expansion of the landfill was primarily in a vertical rather than a real
direction. During 1958, the Site was covered and graded, active dumping was
occurring in the depression to the southeast of the landfill and an east-west
84-inch diameter sanitary sewer interceptor was installed across the Site by
the City of Memphis. By 1960, waste disposal in the depression to the
southeast had expanded to cover approximately eight acres and much of the area
covered in 1958 was again an active waste disposal area.
Expansion of the landfill occurred quickly in the early 1960s. Between 1960
and 1965 the landfill expanded from under 50 acres in size to over 70 acres.
In 1963 the Site was divided into the East and West Sectors by the extension of
Hollywood Street through the Site and across the Wolf River. By 1965 the
Site's East Sector had been closed and vegetated. In 1967 legal waste disposal
on the West Sector also ceased due to closure of the Site. Vegetation had
covered most of the Site by 1979 but several roads from Hollywood Street
permitted access to the East Sector where, during the 1970s, unauthorized
dumping is thought to have occurred.
Investigations and Studies Completed to Date
Investigative studies on the North Hollywood Dump were initiated by the USEPA
in May 1979. This initial study by the USEPA revealed the presence of
chemicals in samples of sediment and surface water collected from and adjacent
to the Site. On the basis of information available concerning the nature of
the waste disposed of at the Site, the USEPA believed that the contamination of
the sediment and surface water may have originated from Site-related
activities. In conjunction with the USEPA study, the Tennessee Department of
Health and Environment conducted a biota (fish) study in the Wolf River which
also indicated potential adverse impact from the Site.
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Aa a result of the 1979 USEPA study, the United States Geological Survey (USGS1
installed five groundwater observation wells along the northern perimeter of
the Site in 1980. During the same period, Memphis State University, on behalt
of the Memphis and Shelby County Office of Planning and Development, studied
the fish in the Wolf River as part of an environmental evaluation of the
Wolf-Loosahatchie River Basins. This study lead to the eventual closure of
commercial fishing activities in the Wolf River although the closure was not
solely based on contamination coming from North Hollywood. During 19SO, the
USEPA also completed a soil study at the Shannon Elementary School. Based on
the results of these initial technical studies, a Technical Action Group (TAG)
comprised of the United States Environmental Protection Agency Region IV
(USEPA); the Tennessee Department of Health and Environment (TNDHE); the City
of Memphis; Velsicol Chemical Corporation (Velsicol); and the Memphis/Shelby
County Health Department (MSCHD) was formed in December 1980. The objectives
of the Technical Action Group (TAG) were to immediately address the short-term
Site problems and the potential long-term environmental impact that the Site
may have on adjacent surface water courses and catchments, the underlying
groundwater,and on residents residing in the vicinity of the Site. Along with
the TAG investigations, numerous activities occurred at the site. These
activities Included an EPA immediate removal of contaminated soil, capping of
the site by the PRPs and fencing of the site. The TAG studies were complete in
1984.
A number of deficiencies in the TAG investigations were identified by the
USEPA; therefore, in February, 1985 the PRPs received a letter of notification
from the USEPA requesting that the PRPs respond to an offer made by the USEPA
allowing them to complete a Supplemental RZ/?S to augment the data previously
collected by the TAG. A group of PRPs agreed to prepare a supplemental RI/FS
under an amended Commissioner's Order from the State of Tennessee. The
Supplemental RI/FS commenced in the spring of 1985.
During the development stage of the final Supplemental RZ/FS work plan, the
PRPs completed a detailed sediment sampling program in the abandoned dredge
pond, the Oxbow Lake and the Beaver Pond. This sampling program involved the
collection of sediment samples from the base of these three surface water
bodies on a predefined grid both to confirm the data collected by the TAG and
to more clearly delineate the limits of sediment contamination. Based on the
new data and the existing TAG date, a conceptual design was prepared
("Conceptual Remedial Action Plan-Remediation of Abandoned Dredge Pond, Oxbow
Lake and Beaver Pond-North Hollywood Dump-Memphis, Tennessee", Conestoga-Rovers
& Associates, August 1985) to address remediation of the three surface water
bodies. The plan was approved by the TNDHE and PRPs; however, an agreement was
reached to defer commencement of remediation activities on the three surface
water bodies until the completion of the data collection phase of the
Supplemental RI.
The Supplemental RI was initiated in the spring of 1985. The draft
Supplemental RI was issued to the lead agency for comments, upon the completion
of the investigation. The state of Tennessee was the lead agency for this site
from 1985 until late 1988 when lead was transferred to USEPA, Region IV. The
State of Tennessee then became a support agency. The Supplemental RI was
finalized in April of 1990. The Supplemental FS was completed in May of 1990
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1IGHLIGHTS OF COMMUNITY PARTICIPATION
Ouring the early 1980'a, numerous community relations meetings were held to
address community concerns. After the immediate removal and during the
Supplemental RI/FS, community concern lessened and the community was informed
through the site repository data and a health assessment meeting held by the
Centers for Disease Control. For the Proposed Plan, a second community
Relations Plan was finalized on May 29, 1990.
This document lists contacts and interested parties throughout government and
the local community. It also establishes communication pathways to ensure
timely dissemination of pertinent information. The RI/FS and the Proposed Plan
were released to the public in June 1990. All of these documents were made
available in both the administrative record and the information repository
maintained at the Memphis-Shelby County Public Library. A public comment
period was held from June 28, 1990 to August 27, 1990. In addition, a public
meeting was held on June 28, 1990 to present the results of the RI/FS and the
preferred alternative as presented in the Proposed Plan for the Site. All
comments which were received by EPA prior to the end of the public comment
period, including those expressed verbally at the public meeting, are addressed
in the Responsiveness Summary which is attached, as the Appendix A, to this
Record of Decision.
SCOPg AND ROLB OF RZSPONSg ACTION
his scope of this response action is to address the remaining concerns and
^hreats at the North Hollywood Dump Site. As discussed previously, an
emergency removal of contaminated soil and a temporary soil cover were
performed to address the immediate health concerns at the site.
This selected alternative for the North Hollywood Dump will address all
concerns at the site. The remaining concerns include site soil contamination
should the temporary cover erode, contaminated fish and sediments in the
surface water impoundments next to the site, and shallow groundwater
contamination in the area beneath the site.
The final remedy for the site is intended to address the entire site with
regards to the principal threats to human health and the environment posed by
the site as indicated in the site risk assessment. The findings of the risk
assessment are included in the RI Report and are summarized in a later section
of this document.
SUMMARY OF SITB CHARACTERISTICS
Geology and Hvdroqeoloqy
The Memphis area is located on the north-south axis of the Mississippi
embayment, which is a large structural geologic trough. In the Memphis area,
the trough is comprised of a thick and extensive sequence of unconsolidated
marine and fluvial sediments. Only the formations in the upper 1000 feet are
onsidered to be of environmental significance with regard to the North
Dump. From youngest to oldest, these geologic units include:
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i) recent alluvium which is comprised of heterogeneous
accumulations of clay, silt, sand and gravel;
ii) loess deposits of windblown silt;
iii) fluvial deposits which are laterally continuous and considered
to be remnant terraces of ancestral graded streams;
iv) Eocene clay formations containing minor lenses and interbeds
of fine sand or lignite;
v) the Memphis sand comprised of a fine to coarse quartz aand
which is the primary water source for the Memphis area; and
vi) the Wilcox group which consists of clays of the Flour Island
Formation, sands of the Fort Pillow formation, and clays of the
Old Breastworks formation.
The hydrogeologic investigations conducted during the original RI and
Supplemental RI confirmed the interpretation of the regional geology in the
vicinity of the Site. The data collected during the Supplemental RI
hydrogeologic study identified that four major stratigraphic units were of
significance in the immediate area of the Site. These four units include:
i) Disposed landfill waste;
ii) Upper Silt Unit (loess deposits);
Iii) Fluvial Sands (ancestral terrace deposits); and
iv) Lower Clay Unit (Eocene clay also referred to as the Jackson
Formation).
Within the landfill limits, the disposed waste is in direct contact with the
Fluvial Sands. For the area beyond the limits of the landfill, the Upper Silt
Unit is in direct contact with the Fluvial Sands. The Fluvial Sands are
underlain by the Lower Clay Unit which is continuous in the area of the Site
and has very low hydraulic conductivity (approximately 3.9 x 10-7 cm/sec). The
level of groundwater within the waste, where present, fluctuates directly with
the groundwater levels in the Fluvial Sand Unit.
The hydraulic conductivity in the Fluvial Sand Unit was confirmed to be
relatively uniform across the Site with an average value of approximately 3.75
x 10-2 cm/sec. The Fluvial Sand Unit and the Wolf River are directly
connected. The groundwater flow within this unit discharges completely to the
Wolf River with no component of flow beneath the river. During periods of high
river levels the groundwater flow direction was confirmed to reverse within an
area approximately 200 feet to 250 feet back from the Wolf River.
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The Lower Clay Unit, which is directly beneath the Fluvial Sand Unit, acts as
^the base of the groundwater flow in the Fluvial Sand Unit on the basis of the
sharp hydraulic conductivity contrast between the two units. Evaluation of the
hydraulic conductivities measured from the Lower Clay Unit confirmed that this
unit would effectively prevent the migration of contaminants from the Fluvial
Sand Unit through the Lower Clay Unit to the Memphis Sands. This was also
confirmed through a study completed by Graham and Parks (1986) in the Memphis
area. This ia significant since the Memphis Sand Aquifer is the major source
of water supply in the Memphis area.
The groundwater velocity within the Fluvial Sand Unit was calculated using a
hydraulic gradient of 0.006 ft/ft, a mean hydraulic conductivity of 3.75 x
10 cm/sec and an assumed porosity of 0.35. Using these values a velocity
of 6.4 x 10 cm/sec or 665 ft/year was calculated. Based on this
calculation any leachate entering the Fluvial Sand Unit la expected to flow to
the Wolf River in leaa than three years.
Based on the long travel times and the probable high attenuation capacity of
the Lower Clay Unit due to its clay content, the potential for the disposed
waste at the North Hollywood Dump to adversely impact the Memphis Sand was
determined to be minimal.
Demography
The North Hollywood Dump is located in a residential area of Memphis with homes
on Belmont Circle contiguous to the Site. The 1980 census for the area
/indicates a population of approximately 2,000 within a 0.25-mile radius of the
Site, and a population of 5,300.within a 0.5-mile radius of the Site.
Land Use
The Site is located in the northern part of the City of Memphis, Tennessee.
The northern boundary of the Site is bordered by the Wolf River, a meandering
tributary of the Mississippi River. Other surface water bodies are located in
the vicinity of the Site, including:
i) an abandoned dredge pond,
ii) an Oxbow Lake (former meander isolated after Wolf River
re-channelization),
iii) a Beaver Pond, and
iv) an active dredge pond.
The active dredging operation is located directly adjacent to the northwest
corner of the Site. Sands and gravels are dredged from an open pond for use in
the construction industry. Other areas of former dredging are located in the
vicinity of the Site, including the abandoned dredge pond referenced
previously, which have resulted in large open surface water bodies.
-------
-8-
The area immediately south of the Site is zoned a duplex residential district
with isolated areas of multiple dwelling zoning and local commercial zoning i*
the area. Areas of light and heavy industry are located directly adjacent to
the residential area. The majority of the lands to the east, west and north of
the Site are zoned floodway district and are essentially undeveloped.
Figure 2 illustrates the local zoning in the immediate vicinity of the North
Hollywood Dump.
• *
Natural Resources
Natural resources for the area around North Hollywood Dump are not abundant as
the area has been developed with a residential/industrial base. However, the
alluvial flood plan of the Wolf River does support a commercial sand and gravel
dredging operation. This is probably the best know natural resource for the
area.
Two valuable but less thought of natural resources in the area are the
•500-foot* and "1,400-foot" groundwater aquifers. These two aquifers, but
primarily the 500-foot aquifer, provide water to 26 industrial wells and a well
field for residential water supply comprised of 26 wells within a three-mile
radius of the Site. These two aquifers do not show evidence of being adversely
impacted by the Site. Samples collected from three production wells contained
detectable concentrations of three organic chemicals but, as these wells are
upgradlent of the Site, it is unlikely that the Site is the source of this
chemical presence. The data collected as part of this Supplemental RI/FS
further confirms this.
An additional natural resource in the area of the Site is the fish population
found in the abandoned dredge pond and Wolf River. Data collected to date
indicates that the fish in these surface water bodies may have been impacted by
the Site. These data have resulted in the banning of fishing in the area.
Even though fishing is officially banned, there are reported cases of local
residents fishing in these surface water bodies.
Climatology
Winds within the Memphis area are generally southerly (49 percent south, 12
percent southeast, 11 percent southwest) and the average growing season cloud
cover is less than three-tenths on a time basis but seven-tenths during the
wetter winter months. The annual mean temperature for the area is 61.3 degrees
F) with January being the coldest month (mean temperature of 39.5 degrees F)
and July being the warmest (mean temperature of 82.1 degrees P). The average
annual rainfall is 51.6 inches with the greatest precipitation generally
occurring during winter and early spring.
Nature and Extent of Problem
Waste Identified on Site
The North Hollywood Dump was operated as a municipal/industrial landfill
between the 1930s and 1969. No precise inventory of the waste has been
-------
HOU IM'WMAIION 1*111 Ml MUM
WIMTMtt IONIM* Oil I Hit I
LOCAL ZONING ADJACENT IO MM
North Hollywood Ut,,nf.
-------
-9-
compiled but the following are typical of the wastes which were disposed of at
this Site:
i) newsprint;
ii) glass;
iii) household garbage;
iv) wood;
v) miscellaneous metal wastes;
vi) metal drums;
vii) industrial and chemical manufacturing wastes;
viii) plastics; and
ix) concrete and building rubble.
Surface Soil Contamination
Surface soil sample* were collected from between the Site and the Wolf River,
and from the north bank of the Wolf River during the second and fourth rounds
of sampling. During the second round of sampling, samples were obtained from
sites ASl-86 through AS20-86 as illustrated on Figure 3. During the fourth
round, samples were collected from these locations and from ten additional
sites, AS21-86 through AS30-86, also illustrated on Figure 3. Analytical data
for the surface soil samples are discussed in the following sections.
The surface soil sampling identified an area of elevated concentrations along
the east side of the abandoned dredge pond (AS13-86 through AS17-36) and in the
lowlands between the Site constituents in the surface soil appeared to be more
wide spread between the East Sector and the Wolf River than between the West
Sector and the Wolf River.
A summary of the analytical data for the surface soil samples is presented on
Tables 1 and 2.
Volatile Oroaniea (VOCs)
The most prevalent VOCs encountered during the second round of sampling were
2-butanone and chloroform. The fourth round samples contained acetone, vinyl
acetate and methylene chloride as the most frequently occurring VOCs.
In both sets of soil samples, chlorinated hydrocarbons such as the
dichlorobenzenea were frequently present. These chlorinated hydrocarbons were
detected in concentrations as high as 4,600 ug/kg but concentrations less than
1,000 ug/kg were more frequent. During the second round the 6 to 12-in samples
for AS3-S6 and AS4-86 contained 1,2-dichloroethane in concentrations of 2,640
ug/kg and 4,600 ug/kg, respectively. The 6 to 12-inch sample from AS5-86
contained dibromochloromethane and bromofortn in concentrations of 1,350 ug/kg
-------
ABANDONED DHEDGE
POND
LEGEND
OFF -SITE SURFICIAL SOIL SAMPLING
LOCATIONS FOR SECOND ROUND SAMPLING
(APRIL I986)(HESAMPLED OCTOBER 1986)
OFF - SITE SURFICIAL SOIL SAMPLING
LOCATIONS ADDED FOR FOURTH ROUND
SAMPLING (OCTOBER 1986)
figure 3
OFF-SITE SURFICIAL SOIL
SAMPLING LOCATIONS
North Hollywood Dump
-------
TABLE 1
SUMMARY OF ANALYTICAL DATA
SURFICIAL SOIL SAMPLES (ROUND 2)
Compound Detected
A. Volatile Organics
Acetone
2-Butanone
Chloroform
1 , 2-dichloroethane
1, 2-dichloropropane
Bromodichloromethane
2-Chlotoethyl Vinyl Ether
Tetrachloroethene
Dibromochloromethane
Bromoform
1 , 3-Dichlorobenzene
1 , 4-Dichlorobenzene
1 , 2-Dichlorobenzene
3. Base Neutral/Acid Extractable
Naphthalene
Acenaphthene
Fluorene
Number of
Samples
Analyzed
39
39
39
39
39
39
39
39
39
39
39
39
39
40
40
40
Number of
Positive
Detections
2
38
26
10
1
3
1
4
1
1
3
4
1
1
1
1
Range of
Positive Detections
(ug/'
-------
TABLE
1
SUMMARY OF ANALYTICAL DATA
SURFICIAL SOIL SAMPLES (ROUND 2)
Compound Detected
B. Base Neutral/Acid Extractable
Phenanthrene
Fluor anthene
Pyrene
Benzo(a)pyzene
Benzo( b&k ) f luor anthene
C. Pesticides
Chlordane
Hexachloronorbornadiene
Heptachloronorbornene &
Octachlorocyclopentene
Total BHCs
Heptachlor
Aldrin
Isodzin
Heptachlor Epoxide
Alpha-Endosulf an
4, 4 '-DDE
Number of
Samples
Analyzed
(cont'd)
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
Number of
Positive
Detections
2
2
2
2
2
11
3
17
4
9
4
3
9
1
3
Range of
Positive Detections
1,491 & 2,401
5,288 & 3,796
1, 260 & 1,896
1,038 & 1,325
1,731 & 2,080
86.6 - 52,400
22.4 - 222
8.51 - 13,300
25.7 - 6. 130
13.3 - 67, 300
276 - 20,041
19.2 - 1,660
8.32 - 1,980
2,630
1,010 - 1,710
continued....
-------
TABLE 1
SUMMARY OF ANALYTICAL DATA
SURFICIAL SOIL SAMPLES (ROUND 2}
Compound Detected
C. Pesticides (cont'd)
Endzin
4,4'-ODD
4.4'-DDT .
Chiordene
D. Metals
(D
Arsenic
Beryllium
Lead
Nickel
Zinc
Strontium
Copper
Bar iua
Chromium
Cadmium
Aluminum
Mercury
Vanadium
Number of
Samples
. Analyzed
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
Number of
Positive
Detections
1
1
21
7
36
32
38
33
34
30
29
39
2
38
40
2
23
Range of
Positive Detections
(ug/kg)
16
25
16.3
8.32
.4
.048
1.0
1.2
3.4
4.0
2.5
2.4
6.11
.007
6.690
.028
5.5
.8
.7
- 62.7
- 160,000
- 13.9
- .980
- 51.0
- 35.7
- 136.6
- 29.6
- 71.9
- 1,330
- 17.9
- .64
- 16, 100
- .041
- 47.2
(1) Range of metal concentrations given as mgAg
-------
TABLE 2
SUMMARY OF ANALYTICAL DATA
SURFICIAL SOIL SAMPLES (ROUND 4)
Compound Detected
A. Volatile Organics
Acetone
Vinyl Acetate
Methylene Chloride
2-Butanon«
Carbon Tetrachlor ide
Tolune
Tetrachloroethene
B. Base Neutral /Ac id Extractables '
Naphthalene
Acenaphthene
Fluorene
Phenanthrene
Fluor anthene
Pyrene
Benzol a) Pyrene
Benzo(b&k) floor ant hena
4-Chioro-3-Methylphenol
Number of
Samples
Analyzed
27
27
27
27
27
27
27
28
28
28
28
28
28
28
23
28
Number of
Positive
Detections
27
14
21
3
3
1
1
1
1
1
2
2
1
2
2
1
Range of
Positive Detections
(ug/Vg)
506 - 1,200
515 - 648
141 - 906
502 - 529
425 - 1,050
592
2,370
265
203
98.7
667 & 2,410
422 & 1,770
971
251 & 1,540
237 s 2, 300
231
cont inued....
-------
TABLE 2
SUMMARY OF ANALYTICAL DATA
SURFICIAL SOIL SAMPLES (ROUND 4)
Compound Detected
B. Base Neutral/Acid Extractables
4-Nitrophenol
Anthracene
Benzidine
Benzo( a) anthracene
Bis(2-ethylhexyl ) phthalate
Chcysene
Di-N-Octyl Phthalate
Benzo( g,h, I JPerylene
Diethyl Phthalate
Di-N-Butyl Phthalane
C. Pesticides
Chlordane
Hexachlotonotbornadiane 6
Heptachloronorborene
Octachlorocyclopentene
Total BHCs
Heptachlor
Aldrin
Number of
Samples
Analyzed
(cont'd)
28
28
28
28
28
28
28
28
28
28
28
28
23
28
28
28
Number of
Positive
Detections
1
1
1
1
6
1
3
1
1
10
14
2
2
7
15
4
Range of
Positive Detections
(ugAg)
158
633
494
2,300
473 - 16,300
2,320
935 & 6, 350
31 1
316
166 - 596
38. 1 - 210. COO
8. 18 - 109
16.5 - 15, 300
8. 15 - 2,417
18.5 - 75, COO
12.0 - 9, 100
cent inued....
-------
TABLE 2
SUMMARY OF ANALYTICAL DATA
SUWICIAL SOIL SAMPLES (ROUND 4)
Compound Detected
C. Pesticides (cont'd)
Isodzin
Kept ach lor Epoxide
Endz in
4, 4 '-DOT
Chi or dene
Oieldzin
D. Metala(1)
Arsenic
Lead
Nickel
Zinc
Strontium
Copper
Bar ium
Chromium
Alumi num
Mercury
Vanadium
Number of
Samples
Analyzed
28
23
28
28
28
28
28
28
23
28
28
28
28
23
23
23
28
Number of
Positive
Detect ions
3
9
5
1
8
4
28
23
22
28
28
27
28
27
23
4
23
Range of
Positive Detections
(ug/'
-------
-17-
TABLZ 2
SUMMARY 0? ANALYTICAL DATA
SURFICIAL SOIL SAMPLES (ROUND 4)
Compound Detected
C. Peat ic ides (cont'd)
laodrin
Heptachlor Epoxide
Endrin
4, 4 '-DDT
Chlordene
Dieldrin
C. Metals
Arsenic
Lead
Nickel
Zinc
Strontium
Copper
Barium
Chromium
Aluminum
Mercury
Vanadium
(rag/kg)
Number of
Samples
Analyzed
•d)
28
• 28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
Number of
Positive
Detections
3
9
5
1
a
4
28
23
22
28
28
27
28
27
28
4
28
Range of
Positive Detections
fug/kg)
11.1 - 192
12.1 - 28,000
42.9 - 671
55.4
15.1 - 18,000
26.5 - 329
1.62 - 47
1.25 - 158
5.00 - 44.4
4.41 - 376
1.46 - 34.6
0.82 - 47.6
11.5 - 191
2.60 - 24.4
1,290 - 11,400
0.10 - 1.54
1.58 - 33.9
-------
-13-
and 2,00 ug/kg, respectively. The fourth round soil sample from AS28-86
contained carbon tetracholoride and tetrachloroethene in concentrations of
1,050 ug/kg and 2,370 ug/kg, respectively.
Base Neutral/Acid Sxtractablea (BNA1
Only one of the round 2 soil samples contained detectable concentrations of the
targeted BNAs with fluoranthene detected in the greatest concentration in the 6
to 12-inch sample (8,796 ug/kg). Other BNAs detected and their maximum
concentrations were benzo(a)pyrene (1,325 ug/kg), naphthalene (90 ug/kg),
acenaphthena (117 ug/kg), fluorene (103 ug/kg), phenanthrene 2,401 ug/kg),
pyrene (1,896 ug/kg) and benzo(bsk) pyrene 2,080 ug/kg).
Round 4 samples were analyzed for the SNA compounds on the revised indicator
parameter list. Phthalates were frequently detected with bis(2-ethylhexyl)
phthalate the most commonly detected at concentrations as high as 16,300 ug/kg
AS12-86).
Pesticides
The results of the pesticide analyses showed large variations between the two
sampling rounds. For the second round 4,4' -DOT was the most frequently
detected pesticide. In general, most of the pesticides were detected in
relatively low concentrations. Sites AS16-86 and AS19-86 were the two
locations which contained the greatest concentrations of pesticides. At
AS16-86 concentrations as high as 160,000 ug/kg of chlordene were detected at a
depth of 6 to 12 inches. Other pesticides detected at elevated concentrations
were chlordane, heptachlor, and heptachloronorbornene and
octachlorocyclopentene.
The round 4 analytical results showed fewer sites containing pesticides with a
much broader range of pesticides detected. Sites AS8-86 and AS20-86 contained
the largest concentrations of pesticides. Chlordane, with a concentration of
210,000 ug/kg at AS8-86 and 17,400 ug/kg at AS20-86, was the pesticide found in
the highest concentration during the round 4 sampling.
Metals
Metal concentrations for the two rounds of soil samples were generally
consistent with those expected for alluvial soils.
Site Surficial Cap
Ten samples of the Site surficial cap were collected during the fourth round to
confirm the effectiveness of the cover placed over the Site as part of the 1984
remediation. The locations of these samples were illustrated on Figure 4.
Analysis of collected samples indicated that the cover placed on the West
Sector had been generally effective in containing surficial contaminants at the
Site. The cover over the East Sector was found to contain pesticide
contamination. These areas of contamination in most cases occurred at areas
that had experienced erosion problems and subsequent cap repairs.
-------
-19-
CSS-01
figure 4
FINAL COVER CONTOURS AT COMPLETION
OF PHASE I REMEDIAL ACTION
CAP SURFACE SOIL SAMPLING LOCATIONS
CAP SURFACE SOIL
SAMPLING LOCATIONS
North Hollywood Dump
-------
-20-
Few volatile organics were detected in the surface cap samples. Acetone, vin*
acetate and methylene chloride were detected but these parameters are
laboratory contaminants. Toluene was the only other VOC detected and this was
found only at site CSS1-86.
The BNAs detected were primarily diethyl phthalate, di-n-octyl phthalate and
bis(2-ethylhexyl) phthalate. Bis(2-ethylhexyl) phthalate was found in
concentrations up to 37",900 .ug/kg at site CSS5-86. Hexachlorobenzene was the
only non-phthalate SNA detected in the cap samples, detected in sample CSS4-86
at 1,240 ug/kg.
Pesticides in the cap samples were primarily present on the East Sector. Only
one sample from the West Sector contained any pesticides and these
concentrations did not exceed 90 ug/kg. All five cap samples from the East
Sector contained pesticides with site CSS4-86 containing the greatest pesticide
concentration (1,810 ug/kg of chlordane).
The concentrations of metals in the cap samples were uniform and within the
concentration range expected for alluvial soils.
Table 3 presents a summary of the cap soil analytical data. For perspective,
Table 4 presents a listing of the contents of various metals in the lithosphere
and in soils.
Buried Drums
During the excavation of an access road for the installation of monitoring well
OW14a, b, an area of buried drums was uncovered north of the West Sector of the
covered area of the site. The approximate location of the buried drums is
shown on Figure 5.
Five samples of the drum contents were collected and analyzed for the priority
pollutant list. The sampling and analysis of the drums was not conducted as
part of the Supplemental RZ program. The sampling and QA/QC protocols outlined
in the Work Plan were not followed; however, approved analytical procedures
were used. Since much of the required QA/QC data validation was not conducted
and method detection limits were not provided, these data can only be used for
qualitative purposes. The analytical data for the drum contents showed mostly
low level contamination like that of the rest of the landfill waste, i.e. some
metals, pesticides and VOCa. The drums did contain high levels of nickel.
Groundwater Contamination
A total of 39 groundwater monitoring wells were sampled for selected indicator
parameters during the four sampling events. Of the 39 monitoring wells
sampled, ten were the original monitoring wells installed during the study
completed by the TAG and 29 were new monitoring wells installed under the
Supplemental HI. Figure 6 illustrates the location of all monitoring wells.
The seven leachate wells were dry during the four rounds of sampling and,
therefore, were not sampled.
-------
TABLE 3
SUMMARY OF ANALYTICAL DATA
SURFACE CAP SAMPLES (ROUND 4)
Compound Detected
A. Volatile Organica
Acetone
Vinyl Acetate
Methylene Chloride
Di-N-Octyl Phthalate
Diethyl Phthalate
Hexachlorobenzene
C. Pesticides
Chloidane
Hexachloronorbornadiene
Heptachlornorbornene &
Octachlorocyclopentana
Total BHCs
Heptachlor
Endr in
Chlordene
Dieldr in
Heptachlor Epoxide
Number of
Samples
Analyzed
10
10
10
itactables
ithalate 10
1 10
10
10
10
, ene 10
i & 10
»na
10
10
10
10
10
10
Number of Range of
Positive Positive Detections
Detections (ug/kg)
10 1,125 - 2,990
2 534 & 543
1 142
4 1,550 - 37,?CQ
3 224 - 6, 120
1 275
1 1,240
3 164 - 1,910
3 15.2 - 75.3
3 26.9 - 174
1 14.0
3 41 .5 - 1. 2CO
1 234
5 12.2 - 73. 1
1 203
2 85/2-2::
ccr.:
-------
TABLE 3
SUMMARY OF ANALYTICAL DATA
SURFACE CAP SAMPLES (ROUND 4)
Compound Detected
0. Metals
(1)
Arsenic
Lead
Nickel
Zinc
Strontium
Copper
Barium
Chromium
Aluminum
Vanadium
Number of
Samples
Analyzed
10
10
10
10
10
10
10
10
10
10
Number of
Positive
Detect ions
10
10
10
10
10
10
10
10
10
10
Range of
Positive Detections
9.20 -
3.75 -
6.25 -
12.4 -
1.78 -
2.10 -
16.4 -
11.7 -
3,560 -
11.4 -
25.9
11.3
18.8
62.5
20.9
15.8
124.0
31.3
9,980
28.7
(1) Range of metal concentrations given as mgAg
-------
-_ J-
TABLE 4
THE CONTENT OF.VARIOUS METALS IN THE LITHOSPHERE AND IN SOILS
Element
Content In
Lichosphere
(tog/kg)
Common Range
for Soils
(mg/kg)
Selected Average
for Soils
(mg/kg)
Arsenic.
Lead
Nickel
Zinc
Strontium
Copper
Barium
Chromium
Aluminum
Vanadium
5
16
100
80
150
70
430
200
81,000
150
Values extracted from Table
1-50
2-200
5-500
10-300
50-1,000
2-100
100-3,000
1-1,000
10,000-300,000
20-500
1.1, Page 7-8, ia Chemical
5
10
^
40
50
200
30
430
100
71,000
100
Equilibria in
Soils, by Willard L. Lindsay, John Wiley & Sons, Inc., 1979.
-------
omi«w»inm win. (HOUNDS 1.1, Ml
SOU SAUftINC SIU | HOUNDS I. 4 1
SOU SAMPIHM fill | HOUND 4|
i »nof 111 msit nun MI, sin IOUMMC
mvm ••UK i*Hi«Misioiu(Hi ittii
UttH. tOUl * VUVIM) Silt IMUMO 4|
uuir or «*s IE
- - SAMIMI StwlX
r . I'p AfPNOIIIMJIII tOCAIION nf BIIHKO OMUMMtO IMSIt
NUK • SIK 1 UC/klKJNS «PmOHH*IC
MSIM.IMIINSI
sin
liquie 'i
SAMF t LOCAriON',
North ywood /'
-------
-25-
!*«••
M/f$ •ill. SlKS
O* • «HOUNO«MUH UUNI1UOIMQ
I * - ICACMAIf MONIKWMC "III
M««- NfMUUJUC HOMIMMa MLL
1M
• umi or »»iu
*MMIMI stem
NUIt IAU Hill IULAIMMS
\
figure It
GROUNDWATER MONITORING WELL
Hollywood /'
-------
-26-
Por the purpose of discussing the groundwater analytical results, the
monitoring well network has been divided into three zones, which are:
i) monitoring wells upgradient of the Site;
ii) monitoring wells completed beneath and adjacent to the disposed waste;
and
iii) monitoring wells downgradient of the Site..
Monitoring Wells Uooradient of Site
Fourteen monitoring wells are located hydraulically upgradient of the Site
(Figure 6). These upgradient monitoring wells include Wells OWla, b, c; OH2a,
b,c; OW3a, b, c; OW4a, b; TAG 80; TAG 93 and TAG 10B.
Monitoring well nest OWla, b, c, even though located hydraulically upgradient
of the Site, has been shown to have levels of contamination slightly higher
than the other background wells and in the same range as the monitoring wells
downgradient of the site. The reason for this contamination was never defined;
therefore, data from these wells have been disregarded in the following
discussions on the next several pages.
The analytical data for the remaining upgradient wells form the basis for the
following subsections.
Volatile Orpanics (VOCal
Groundwater samples collected upgradient of the Site generally contained low
levels of VOC parameters with an inconsistent and irregular detection pattern
between sampling rounds. VOCs detected during the four rounds of sampling in
upgradient groundwater samples included:
i) Acrylonitrile
- Round 1 (OW2b; OW3a)
- Round 3 (TAG 80)
ii) Benzene
- Round 1 (OW2b)
- Round 3 (TAG 80)
iii) 2-Butanone
- Round 1 (OW3a; OW3c; OW4a; OW4b; TAG 80; TAG 10B)
iv) 1,2-Dichloroethane
- Round 3 (OW2a; OW2b; OW2c; OW3a; OW3b; OW3c; OW4a; OW4b; TAG 80;
TAG 9S; TAG 10B)
v) Tetrachloroethene
- Round 4 (OW2b)
-------
-27-
i) Toluene
- Round 4 (OW2b)
vii) Trichloroethene
- Round 4 (OW3b)
viii) Vinyl Acetate
- Round 4 (TAG 108) -
ix) 1,1-Dichloroethene
- Round 3 (TAG SO)
x) Carbon Tatrachloride
- .Round 4 (TAG 80)
Baae Neutral/Acid Bxtr^c*r*h\ee fBNAV
The analytical data for the four rounds of upgradient groundwater samples
indicated that the BNA group of analytes were generally not present in the
upgradient groundwater samples or were detected at generally low levels.
Phenols were detected in all sampling rounds except round 4. Concentrations
ranged from a low of 1.66 ug/L (OW4a) during the third round to a high of 41.2
ug/L (OW3c) during the second round.
Pesticides
Bhly four pesticide compounds were detected in more than one round of sampling
of the upgradient groundwater monitoring wells. These compounds included 4,4'
-DOT (TAG 93); dieldrin (OW3c); heptachlor epoxide (OW3c, TAG 93); and
chlordane (OW4a, OW3b). Of these four compounds detected, chlordane was the
most prevalent with concentrations ranging between 0.253 ug/L (OW4a; round 2)
and 0.083 ug/L (OH2c; round 2). Chlordane was not detected at any of the
upgradient sampling locations in round 3. Heptachlor epoxide was identified in
three monitoring wells (OW3a, OW3c and TAG 93) with concentrations ranging from
0.179 ug/L (TAG 93); round 2) to 0.02 ug/L (TAG 93: round 3). Dieldrin was
found only at OW3c in samples from rounds 2 and 3 at concentrations of 0.251
ug/L and 0.062 ug/L, respectively. Five monitoring wells (OW2c, OW3a, OW4a,
OW4b and TAG 93) contained 4-4' DOT at concentrations from 0.168 ug/L (TAG 9S:
round 2) to 0.035 ug/L (OW4b; round 2).
All remaining pesticides with the exception of hexachloronorbornadiene,
heptachlor, isodrin and chlordene, were detected only once or only during one
round of sampling of the upgradient monitoring wells. The remaining four
pesticides indicated above were not detected in any of the upgradient
groundwater samples collected.
Metals
All of the targeted metals were generally detected at anticipated background
concentrations with the exception of aluminum (Al) and arsenic (As).
tectable concentrations ranged from 0.07 to 50.8 ug/1 Al and from 0.002 to
.033 ug/1 As. Metal concentrations detected at each monitoring well were.
relatively consistent between rounds.
-------
.28.
Monitoring Walla within Confines of the Site
Eleven of the RI monitoring wells are situated within the physical confines o
the Site, and include OWSa, b; OW6a, b; OW7; OW8; OW9a, b; OW10; OW11; and TAa
4S. These monitoring wells are constructed to monitor groundwater quality
within the Fluvial Sands immediately beneath the Site.
volatile Orqanies (VOCi
Few VOCs were detected in the groundwater samples collected from the monitoring
wells situated within the confines of the Site. The VOCs detected were
generally at low concentrations and within the same range of concentrations as
identified in the background wells. The VOCs detected included:
1) Chloroform
. - Round 3 (OWSa; OWSb; OW6a, OW6b)
ii) 1,2-Dichloroethane
- Round 3 (OW6a; OW6b; OW8, OW9b; OW10; TAG 4S)
iii) Chloromethane
- Round 2 (OW6a; OW6b; OW7)
iv) 2-Butanone
- Round 1 (OHSa; OW9b)
- Round 2 (OW7)
The four VOCs outlined above were detected in concentrations less than SO ug/L
except for 2-butanone which .was detected at a concentration of 500 ug/L during
the second sampling round at OW7.
Base Neutral/Acid Bxtraetables (BNA1
Few SNA compounds were detected in the groundwater monitoring wells situated
within the Site.
Phenol was detected during the first two rounds of sampling but not in
subsequent sampling rounds. The concentrations of phenol were low, ranging
from 2 ug/L at OW7 during the second round to 7.3 ug/L at OWSa during the first
round.
Phthalatea were not included in the analytical program for the first two
sampling rounds but were included for rounds 3 and 4.
Pesticides
With the exception of alpha endoaulfan, all pesticides analyzed for were
detected in at least one of the sampling rounds. Generally, pesticides were
more routinely detected in samples from the East Sector of the Site.
Three pesticide or pesticide-related species were detected at one or more
monitoring wells within the limits of the waste for all three monitoring
rounds. These compounds included chlordene (TAG 4S), total BHCs (OW-6a;
OW-6b), and heptachloronorbornene and octachlorocyclopentene (OWSa; TAG 4S).
-------
-29-
Three pesticides were either not detected at all or were detected on a maximum
of only two occasions during all sampling rounds. These compounds included
alpha-endosulfan (not detected during any rounds); dieldrin (OW9b; Round 2,
0.042 ug/L and OW7; Round 4, 0.63 ug/L); and hexachloronorbonadiene (TAG 4S;
Round 1, 0.089 ug/L).
The most prevalent pesticides were Total BHCs and heptachloronorbornene and
octachlorocyclopentene. The OW11; round 2 concentration of 29.1 ug/L for total
BHCs was the highest pesticide concentration detected in the groundwater
samples obtained from within the Site.
Metals
All of the targeted metals were generally detected in the four rounds of
samples collected from the monitoring wells beneath the Site. As with the
upgradient wells, metal concentrations were consistent from round to round with
aluminum and arsenic present at elevated concentrations. The aluminum and
arsenic concentrations in the monitoring wells within the confines of the waste
were identified to be within the same range of concentrations as the background
monitoring wells. Detectable concentrations ranged from 0.41 to 39.6 ug/1 Al
and 0.002 to 0.089 ug/1 As.
Monitoring Wells Downaradient of Site
Twelve of the monitoring wells utilized for the Supplemental RI were located
hydraulically downgradient of the Site and include Wells OW12a, b; OW13; OWi4a,
b; OW16a, b; OW17; TAG 10; TAG 23; TAG 3D; TAG SS; TAG 60; and TAG IS. Two
additional wells, OW16a and OW16b were situated on the north side of the Wolf
River to determine if contaminant underflow of the Wolf River had occurred.
(Results were negative). The 12 downgradient wells were located to ascertain
if contaminants were migrating from the site toward or into the Wolf River.
(Results were negative).
Volatile Oroanica (VOCl
Methylene chloride and acetone were detected in most of the groundwater
samples. These parameters are believed to be laboratory introduced
contaminants.
Nine other VOCs were detected including:
i) 1,1-Dichloroethene
- Round 1 (TAG ID)
ii) Trichloroethene
- Round 1 (TAG 23)
- Round 4 (OW12a, TAG 2S)
iii) Chlorobenzene
- Round 1 (OW14a)
- Round 2 (OW14a, TAG 6D)
- Round 4 (OH14a, OW14b and TAG SS)
-------
-30-
iv) 2-Butanona
- Round 1 (OW17 and TAG SS)
v) 1,2-Oichloroethana
- Round 3 (OW12a, OW12b, OW13, OW14a, OW14b, OW16a, OW16b,
OW17, TAG ID, TAG 30, TAG SS and TAG 75)
vi) Chloromethane - ,
- Round 3 (OW14a, OW14b, OW17 and TAG SS)
vii) Benzene
• Round 3 (OW16a)
viii) Acrylonitrile
• Round 3 (OWl4a, OW14b, OW17, TAG 2S and TAG 5S)
ix) Vinyl Acetate
- Round 4 (TAG 73)
All of the VOCs detected were within the same range of concentrations as the
wells within the confine* of the waste and the background wells.
Base Neutrals/Acid Extractablae (BNA1
The monitoring well samples downgradient of the Site, as in all other
monitoring well samples, contained phthalates as the primary BNA component.
Phthalates were added to the indicator parameter list following round 2.
The round one sample collected from monitoring well OW12b contained detectable
concentrations of three PAH species, namely benzo(a)pyrene (IS.6 ug/L),
chrysene (17.8 ug/L) and benzo(b 6 k) fluoranthene (S.2 ug/L). The PAH species
were not detected during any other sampling rounds.
Other BNA compounds detected included:
i) Naphthalene
- Round 3 (TAG 73 - 3.1 ug/L)
- Round 4 (OW13 - 230 ug/L)
ii) 2,4-0 ichlorophenol
- Round 4 (OW13 - 126 ug/L)
iii) Phenol
- Round 2 (TAG 10 - 1.7 ug/L)
Peaticidea
Pesticides were detected in groundwater samples obtained from the observation
wells located downgradient of the Site during all three sampling rounds with
the majority of positive detections occurring during the second round. The
round one pesticide analytical results were deemed invalid and are not included
in this discussion.
-------
-31-
•eaticides were detected in the downgradient monitoring wells on a regular
asis with the exception of hexachloronorbornadiene, (detected once at TAG 6D
during Round 2); alpha endosulfan (not detected during any round); dieldrin
(detected once during Round 2); 4,4' -ODD (detected three times during Round
2); and endrin (detected five times during Round 2). Generally, the
downgradient pesticide data showed a marked increase in concentrations from the
upgradient data. Specifically, iaodrin, heptachlor epoxide and chlordene were
consistently detected at' a higher- concentration in the downgradient than in the
upgradient wells.
Metals
All of the metals analyzed were found in concentrations similar to those
present in the upgradient wells. Barium showed the greatest difference from
upgradient to downgradient; but even this increase, compared to the MCL of 1000
ug/1, is not significant. The ranges of selected metals are presented below:
Detectable Values in ug/1
Oporadient Range Downgradient Range
0.07-50.8 0.07-11.7
0.015-0.078 0.007-0.132
. 0.002-0.033 0.002-0.052
0.028-0.686 0.094-2.24
Surface Water Contamination
Wolf River
The Wolf River, a tributary of the Mississippi River, flows past the Site in an
east to west direction. la order to determine the impact that the Site has or
may have had on the Wolf River and its aquatic life, river water samples were
obtained during each of the four sampling rounds and samples of river sediment
were collected during one sampling round. The locations of these sampling
stations are illustrated in Figure 5.
The round 1 upstream water sample contained numerous VOCa but they were
generally found in low concentrations. The VOC detected in the highest
concentration was toluene at 68.4 ug/L. Few SNA species were detected in the
Wolf River water samples. The majority of the metals analyzed for were
detected in at least one round of Wolf River water samples. There was no
variation in metals concentrations from upstream to downstream of the Site.
This would indicate that the Site is not a source of metal contamination in the
Wolf River water.
-------
-32-
Tablea 5 through 8 present the analytical data for the Wolf River Water
samples.
During the second round of sampling, sediment samples-were collected from the
Wolf River and analyzed for the selected indicator parameters. As with the
Wolf River water samples,. sediment composition downstream of the Site was not
significantly different from that upgradient or adjacent to the Site. A
summary of the analytical results- for the Wolf River sediments showing only the
positive detections is presented on Table 9.
Pish Contamination
State of Tennessee Fish Study Data Assessment
The State of Tennessee conducted a fish study along the Wolf River in 1981 in
an attempt to determine whether the North Hollywood Dump had impacted the fish
in the Wolf River directly adjacent to the Site. The study included the
collection of various fish types in the Wolf River at a select number of
locations upstream, downstream and directly adjacent to the Site. The
collected fish were analyzed for a predefined parameter list which included
pesticides commonly known to exist at the Site.
The analytical data collected generally indicated low levels of pesticide
contamination in fish flesh* with chlordane being detected at levels
approximately one order of magnitude higher than the other pesticides. The
concentrations of chlordane were slightly above the action level set by the
Pood and Drug Administration. Problems that were identified with the data
included:
i) higher concentrations in fish upstream than in fish downstream
of the Site suggests a potential source of contaminants other
than the North Hollywood Dump; and
ii) variability in collected data made it difficult for comparison
of data because of the large migratory potential of fish.
Subsequent to completion of this study, the North Hollywood Dump was remediated
by placing a vegetated soil cover over the limits of surficial contamination.
This work eliminated most contaminated sediment loading to the Wolf River.
MSCHD Fiah Study Data Assessment
The Memphis and Shelby County Health Department (MSCHD) sponsored a study to
determine the status of contamination in the fish of the Wolf River. The study
was completed by Christian Brothers College and Memphis State University
between June and November 1985. The study included the collection of various
species of fish in the Wolf River from the Mississippi River to a point
approximately 35 miles upstream. The fish collected were analyzed for twelve
pesticide compounds.
Results of the study showed that the mean concentration of pesticides in the
fish along the entire 35-mile stretch of the Wolf River were below the Food and
-------
-33-
TABLE 5
SUMMARY OF ANALYTICAL DATA
WOLF RIVER WATER SAMPLES (ROUND 1)
Sample Locations (See
Compound Detected WR1
Midway Past
A. Volatile Organica
Chloromethane
Chloroethane
Acetone * )
1, 1-Dichloroethane
Trans-1 , 2-Dichloroethene
Carbon Tetrachloride
Benzene
Trichloroethene
Bromodichloromethane
Toluene
Tetrachloroethene
Chlorobenzene
Ethyl Benzene
1, 1-Dichloroethane
Dump
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
WR2
Upstream Edge
o< Dump
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
WR3
Downstream
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
Figure 5)
WR4
Upstream
12.3
7.33
42.5
7.18
10.8
3.10
6.52
8.43
19.4
68.4
6.69
19.2
28.4
21.2
B. Base Neutral/Acid Extractablea(2)
continued.
-------
Con pound Detected
C. Pesticides
D. Metals(4)
Copper
Barium
Strontium
A1 on i nun
Zinc
{3)
TABLE 5
SUMMARY OF ANALYTICAL
WOLF RIVER WATER SAMPLES
• _ WR1
DATA
(ROUND 1)
Sample Locations
WR2 WR3
Midwav Past Upstream Edoe Downstream
\
WR4
Upstream
• - Dump of Dump
0.024
0.024 0
0.023 0
0.260 0
0.004 0
ND ND
.025 0.023 0
.024 0.026 0
.376 0.200 0
.007 0.005
ND
.029
.027
.310
ND
Notes;
1) QA/QC evaluation concluded that positive detections are due to laboratory
contamination
2) No Base Neutral/Acid Extractables were detected in the four samples analyzed
3) Pesticide data not used frcm round 1 due to lack of confirmation and elevated
concentrations in blanks
4) Range of positive detections for metals shown are mg/L
-------
TA3LE 6
SUMMARY OF ANALYTICAL DATA
WOLF RIVER WATER SAMPLES (ROUND 2)
Coneound Detected
A. Volatile Organtcs*1*
WR1
Midway Paat
•Duma
Sample Locations
WR2 WR3
Upstream Edge Downstream
of Dump
WR4
Upstream
B. Base Neutral/Acid Extractables
(2)
C. Pesticides
Chlordane
Heptachlor Epoxide
NO
NO
0.121
NO
NO
NO
NO
0.022
D. Metals(3)
Barlun
Strontiun
Aluainun
Arsenic
Lead
Mercury
Zinc
0.032
0..031
1.624
NO
0.002
NO
0.026
0.031
0.035
2.059
0.005
0.002
0.0006
0.017
0.034
0.035
1.826
0.005
0.002
0.0003
0.015
0.0:9
0.031
2.071
0.303
o.:o:
o.: • •
Notes;
1) No Volatile Organics were detected in the 4 river water samples
2) No Base Neutral/Acid Extractables were identified in the 4 river wat
analyzed
3) Range of positive detections for metals shown as mg/L
-------
-36-
TABLZ 7
SUMMARY OF ANALYTICAL DATA
WOLF RIVER WATER SAMPLES (ROUND 3)
Compound Detected
A. Volatile Organics
Acetone< 1 )
Methylene Chloride^1)
1 , 2-Dichloroethane
B. Base Neutral/Acid Ex tract ables
B is ( 2-Ethy Ihexyl ) phthalate
C. Pesticides<2)
D. Metals(3)
Aluminum
Arsenic
Nickel
Lead
Mercury
Zinc
Vanadium
Sample Locations
WR1 WR2 WR3
Midway Past Upstream 'Edoe Downstream
Dump of Dump
17.0 13.3 12.3
22.7 4.56 25.4
10.7 3.93 3.47
NO NO ND
1.23 1.03 1.11
0.008 ND O.OOS
ND ND ND
0.004 0.005 0.006
ND 0.002 0.003
0.006 ND 0.006
0.023 0.022 0.071
WR4
Upstream
ND
30.8
5.2
37.1
1 .26
0.003
0 .003
0.003
0.003
NO
•0.027
Notes;
1) QA/QC evaluation concluded that positive detections are due to labcrai:
co ntamination
2) Pesticides were not detected in the 4 river water samples analyzed
3) Range of positive detections for metals shown as mg/L
rv
-------
-j/J-
7A3I2 8
SUMMARY OF ANALYTICAL DATA
WOLF RIVER WATER SAMPLES (ROUND 4)
Compound Detected
A. Volatile Organica
Sample Locations
WR1 WR2 WR3 WR4
Midway Past Upstream Edoe Downstream Uo at ream
. .• Dump of Dump
• • ^^•^^••^^^^•^iW
(1)
Acetone 15.2 81.4 149.0 121.0
Methylene Chloride^) 3.17 MO 6.39 5.87
Trichloroethena NO 9.11 NO 2.07
B. Base Neutral/Acid Extractables
Di-N-Butyl Phthalate
C, sticides<2)
D. Metals/3)
Copper
Barium
Strontium
Arsenic
Aluminum
NO 4.16 NO ND
. 0.004 0.004 O.OOS 0.006
0.029 0.029 0.027 0.022
0.022 0.024 0.021 0.022
0.302 0.452 0.592 0.536
^0 ND ND O.:03
continued..
-------
Compound Detected
D. Metal£(3)(Cont'd)
Nickel
Lead
Zinc
Vanadium
Cyanide
-33-
TABLE 8
•
SUMMARY OF ANALYTICAL DATA
WOLF RIVER WATER SAMPLES (ROUND
Sample
4)
Locations
WR1 WR2 WR3
• Midway Past Uostream Edae Downstream
Dump of
0.001
0.002
0.011
ND
ND
Dumo
0.001
0.003
0.023
ND
MO
0.004
0.001
0.020
NO
0.002
WR4
Uostream
ND
0.001
0.019
0.015
0.005
Notes;
1) QA/QC evaluation concluded that positive detections are due to laboratory
contamination
2) Pesticides were not identified in the 4 river water samples analyzed
3) Range of positive detections for metals shown are mg/L
-------
-39-
TABL2 9"
SUMMARY OP ANALYTICAL
WOLF RIVER SEDIMENT SAMPLES
DATA
(BOUND 2)
Sample Locations
COB pound Detected
A. Volatile Organics
Acetone
2-Butanone
Chlorofonn
Toluene
3. Base Neutral/Acid
,'
C. sticldes
Heptachloc
Heptachlor Epoxide
4,4'-DDT
D. Metals(2}
Arsenic
Beryl liun
Lead
Nickel
WS1
Hidwav Past
Jump.
420/NS
6300/NS
280 /MS
ND/NS
Extractables(1)
NO/US
ND/NS
ND/NS
5.9/NS
0.491/NS 0
13.5/NS
9.6/NS
WS2
Upstream
of Dump
ND/UD
3800/2900
260/260
370/450
ND/ttD
NO /MO
ND/ND
12.5/0.9
.452/0.477
10.4/10.7
7.9/8.6
WS3
Edge Downstream
ND/ND
5600/5200
260/320
670/350
NO/14.2
NO/14. 0
ND/24.8
8.4/8.7
0.440/0.461
8.4/9.5
8.7/9.4
WS4
Upstream
ND/ND
4900/3100
280/ND
ND/^D
ND/15.8
23.7/ND
26.0/44.4
4.2/0.6
0.420/0.50
18.3/6.0
7.9/9.5
continued. . . .
-------
Concound Detected
D. Metals(2)(cont*d)
Zinc
Strontiua
Copper
Bariun
Cadniun
Aluninun
Mercury
Vanadiun
TA3LE 9
SUMMARY OP ANALYTICAL DATA
WOLF RIVER SEDIMENT SAMPLES (ROUND 2)
Sample Locations
WS1
WS2
Midway Past Poatream
• Dump of Dump
36.1/NS
11.2/NS
1S.4/NS
107/NS
0.38/NS
8S20/NS
NO/MS
20.6/NS
34.2/33.7
10.4/11.7
15.3/19.6
90.1/148.0
0.21/0.19
6530/8020
NO/ND
12.8/14.0
WS3
Edge Downstream
29.4/34.7
1 1 .3/ND
13.4/10.0
141.0/88.0
0.20/0.27
6770/7340
0.050/0.026
26.0/13.1
WS4
Uo3tream
29.4/26.9
8.5/9.3
14.6/15.3
81.0/83.3
0.19/0.16
5250/6320
ND/ND
14.3/22.2
Notes:
1) Base Neutrals/Acid Extractables were not detected in any of the 7 samples
2) Data reported in mg/kg
3) NS - Not Sampled
4) Data presented for 0-6"/6"-12" sediment samples.
-------
TABLE 9
SUMMARY OF ANALYTICAL DATA
WOLF RIVER SEDIMENT SAMPLES (ROUND 2)
Conpound Detected
A. Volatile Orpanics
Acetone
2-Butanone
Chlorofonn
Toluene
B. Base N«utra I/Acid
C. Pesticide*
Heptachlor
Heptachlor Epoxide
4,4'-ODT
D. Metal3(2)
Arsenic
Berylliai
Lead
Nickel
<•
WS1
Midway Past
Dump
420/HS
6300/NS
280/NS
ND/NS
Extractables(1)
ND/NS
NO /US
ND/NS
5.9/NS
0.491/NS 0
13.5/NS
9.6/NS
S ainpl*
WS2
Locations
WS3 WS4
Upstream Edge Downstream Upstream
of Dump
ND/ND ND/ND ND/ND
3800/2900 5600/5200 4900/3100
260/260 260/320 280/30
370/450 670/350 NO/NO
NO/NO NO/14. 2 NO/15. 8
\
NO/NO NO/14. 0 23.7/ND
NO/NO NO/24. 8 26.0/44.4
12.5/0.9 8.4/8.7 4.2/0.5
.452/0.477 0.440/0.461 0.420/0.507
10.4/10.7 8.4/9.5 18.3/6.0
7.9/8.6 8.7/9.4 7.9/9.5
conti rued.. ..
-------
TABLE 9
SUMMARY OF ANALYTICAL DATA
WOLF RIVER SEDIMENT SAMPLES (ROUND 2)
Con pound Detected
D. Metals2 *( co nt'd)
Sample Location*
WS1
Midway Past
Dump
WS2
Upstream Edge
of Dump
WS3
Downstream
WS4
Upstream
Zinc
Strontivn
Copper
Barivn
Cadnita
Altai nun
Mercury
Vanadiun
36.1/NS
11.2/NS
15.4/NS
107/HS
0.38/NS
8520/NS
ND/NS
20.6/NS
34.2/33.7
10.4/11.7
15.3/19.6
90.1/148.0
0.21/0.19
6530/8020
ND/ND
12.8/14.0
29.4/34.7
11.3/ND
13.4/10.0
141.0/88.0
0.20/0.27
6770/7340
0.050/0.026
26.0/13.1
29.4/26.9
8.5/9.3
14.6/15.3
81.0/83.3
0.19/0.16
5250/6320
NO/NO
14.3/22.2
Notes:
1) Base Neutrals/Acid Extractablas were not detected in any of the 7 samples
2) Data reported In ag/kg
3) NS - Not Sanpled
4) Data presented for 0-6"/6"-l2* sediment samples.
-------
-43-
Drug Administration (FDA) action levels established for pesticides. For the
twelve pesticides analyzed, chlordane was most regularly detected and generally
at the highest concentration. Of the 98 fish samples collected along the
35-mile study area, and chemically analyzed, only 17.3 percent contained
chlordane concentrations above the FDA action level.
The study concluded that concentrations of pesticides, particularly chlordane,
in the fish found in the Wolf River have dropped since 1981 and in moat cases
are below the FDA action life. The study further showed that the
concentrations identified in the fish are within the same range as would be
expected in other agricultural based areas of the southeast region of the
United States.
Surface Water Impoundments
The surface water impoundments located adjacent to the North Hollywood Dump
were not investigated as part of the Supplemental RI. The only information
available regarding the nature and extent of contamination of these surface
water bodies predates to the 1983 TAG studies presented in E.C. Jordan's Data
Interpretation Report (DIR) and the studies completed by the PRPs during the
development stage of the final Supplemental RI/FS work plan; consequently the
findings of these studies may not be representative of present conditions.
The surface water impoundments located adjacent to the Site includes
i) the 40-acre abandoned dredge pond;
ii) the Oxbow Lake;
iii) a Beaver Pond; and
iv) an active dredge pond west of the Site
The primary contaminants identified by the DIR in the surface water
impoundments consisted of pesticides and related chlorinated compounds.
Pesticides identified in surface waters included:
i) Oxbow Lake - heptachlor, heptachlor epoxide, chlordene,
1-hydroxychlordene; and dieldrin;
ii) Beaver pond - heptachlor, heptachlor epoxide, chlordene, and
1-hydroxychlordene;
iii) Abandoned Dredge Pond - heptachlor, heptachlor epoxide, chlordene,
endrin ketone, and dieldrin.
The data used in the DIR are presented on Tables 10 through 13 for compounds
detected in surface waters. The concentrations of total pesticides and related
compounds were identified to generally be less than 1 ug/L. Elevated values
were attributed to sediments which were not filtered from the samples and to
the collection of runoff from a residual surficial soil contamination area.
-------
-44-
Barium
Chromium
Srontium
Titanium
Vanadium
Zinc
Aluminum
Manganese
Calcium
Magnesium
Iron
Sodium
Cyanide
FIRST QUARTER
NORTH
Oxbow Lake
NHOB-1
0.130
ND[3J
0.120
0.033
ND
0.013
1.300 .
0.440
26
9.7
l.S
IS
0.002K[4]
TABLE
10
WATER SAMPLE ANALYTICAL RESULTS (MG/1)[1]
HOLLYWOOD DUMP,
MEMPHIS, TENNESSEE
Beaver Pond Abandoned Dredge Pond
NHBP1 NHADP-1 . NHADP-1
(•plit)
0.094
ND
0.080
0.063
0.010
0.130
2.500
0.120
22
9.9
2.1
17
0.002K
0.068
ND
0.082
0.013
ND
0.017
0.400
ND
19
10
0.3
16
0.002K
NR[2J
NR
. NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
0.002X
NOTES:
[1] This data was obtained from TAG 1983 studies and has not been verified
or reviewed for quality assurance.
[2] NR - Not Reported
[3] ND - Not Detected
[4} K - Actual Value is Known to be Less Than Value Given
-------
TABLE 11 Page 1 of 1
SECOND QUARTER WATER SAMPLE ANALYTICAL RESULTS (MG/LHll
NORTH HOLLYWOOD DUMP, MEMPHIS, TENNESSEE
Oxbow Lake Beaver Pond
NHOB-1
NHBP-l
Abandoned Dredge
Pond
NHADP-1
Cll Alkylbenzene
Acetone .
Heptachlor 0.00021
Heptachlor Epoxide 0.00033
l-Hydroxychlordene
Chlordene 0.00007J[21
Endrin Ketone
Hexachloronomadiene (HCNBD)
Heptachloronorbomene (HCNB)
Boron
Aluminum
Manganese
Iron
Barium
Zinc
Lead
Copper
Cadmium
Cyanide 0^027
0.00047
0.00090
0.00006J
0.013
0.034
0.00067
0.00030
0.001 A [31
0.00006JA
1.200
0.420
0.160
0.81
0.200
1.1
0.920
0.120
1.1
..
1.400
0.290
0.420
0.42
• •
0.024
NOTES:
[1] This data was obtained from TAG 1983 studies and has not been verified or reviewed for
quality assurance.
[2] J - Estimated value
[31 A - Average value
-------
TABLE 12 Page 1 of 2
THIRD QUARTER WATER SAMPLE ANALYTICAL RESULTS (MG/L) [1]
NORTH HOLLYWOOD DUMP, MEMPHIS, TENNESSEE
Beaver Pond Oxbow Lake Abandoned Dredge
Pond
Ambient Ambient Ambient
Water Water Water
NHBP-1 NHOB-l NHADP-1
Benzene
Chlorobenzene
D&P-Xylene (mixed)
1,4-Dichloroben2ene
Naphthalene
Acenaphthene
2-Methyl Naphthalene
1-Methyl Naphthalene
Dimethyl Naphthalene (2 isomen)
Petroleum Product
Acetone — .
1-Hydroxychlordene 0.00043 0.00055 0.00045
Cyanide
Gamma-Chlordane/2
Chlordene/2 . -.. ••
EndrinKetone
Heptachlor
Dieldrin
Endrin
Heptachlor Epoxide
Barium — ...
Chromium
Copper
Strontium
Vanadium
Yttrium
Zinc -- 0.020 0.012
Aluminum 0.500 0.430 0.470
Manganese 0.200 0.300 0.190
Calcium
Magnesium
Iron 1.2 1.5 0.35
Sodium
Lead - 0.010
Boron 0.230 . 0.225 0.240
Cadmium
-------
-47-
' . TABLE 12 Page 2 of 2
THIRD QUARTER WATER SAMPLE ANALYTICAL RESULTS (MG/L) [1]
NORTH HOLLYWOOD DUMP, MEMPHIS, TENNESSEE
Beaver Pond Oxbow Lake
Hardness
Alkalinity
Ambient
Water
NHBP-1
n
79
Ambient
Water
NHOB-1
92
110
Abandoned Dredge
Pond
Ambient
Water
NHADP-1
70
77
NOTES:
(11 This data was obtained from TAG 19S3 studies and has not been verified or reviewed for
quality assurance.
-------
-48-
TABLE 13
FOURTH QUARTER WATER SAMPLE ANALYTICAL RESULTS (mg/L) [1]
NORTH HOLLYWOOD DUMP, MEMPHIS, TENNESSEE
Abandoned Dredge
Pond
Ambient
Water
NHADP-1
Oxbow Lake
Ambient
Water
NHOB-1
Beaver Pond
Ambient
Water
NHBP-1
Ambient
Water
NHBP-1
Split
Endrin Ketone
I -Hydroxychlordene
Heptachlor
Heptachlor Epoxide
Oteldrin
1 Unidentified
Chlorinated Compound
Cyanide
3 Unidentified
Chlorinated Compounds
Chlordene/2
Isodrin
4,4'-DDD (P,r-DDD)
Endrin
Trans-Nonachlor/2
Benzene
Chlorobenzene
o&p-Xylene (mixed)
1,4-Dichloro benzene
2,4-Dinitrotoluene
Pyrene
2-Chlorophenol
Phenol
4-Chloro-3-Methylphenol
0.00017N121
0.00029
0.00009
0.00048
aooootjoi
0.00006
0.00075
0.00008
0.00004JS
0.00038S
0.0053
0.000092N
NOTES:
[1] This data was obtained from TAG 1983 studies and has not been verified or reviewed for quality
assurance.
[21 NaPresumptive evidence of presence of material
[31 /"Estimated value
-------
-49-
Peaticidea and related chlorinated compounds were identified in sediments
llollected from the surface water impoundments during the TAG study. The
available sediment analytical results from the TAG study are shown on Table
14. Chemical compounds which were identified in the Beaver Pond, Oxbow Lake,
and abandoned dredge pond include aldrin, chlordene, 1-hydroxychlordene,
gamma-chlordane, and alpha-chlordane.
Within the abandoned dredge pond, the DIR reported that the concentration of
total pesticides were highest adjacent to the landfill, decrease in the. central
portion of the pond and increase at the southeast end of the pond.
Zn sediments studies completed by the PRPs, the pesticides which were detected
in the upper portions of the sediment samples included aldrin, 4,4-000,
4,4'-OD8, 4,4'-DDT, dieldrin, endosulfan-alpha, endoaulfan-beta, endosulfan
sulfate, endrin, endrin aldehyde, heptachlor, and heptachlor epoxide.
Pesticides which were detected in the middle portions of sediment samples
included aldrin, 4,4-DDO, endosulfan-alpha, endosulfan-beta, endrin, heptachlor
and heptachlor epoxide.
Health Assessment
The MSCHD with assistance from the Centers for Disease Control (CDC) conducted
a cross-sectional study of residents of Bollywood and a comparison area of
Memphis, Tennessee in 1985 (Soil pesticide levels for a variety of pesticides
were higher in the Bollywood area than in the comparison area). However, only
'or serum hexachlorobenzene and adipose tissue heptachlor epoxide were there
icreased pesticide levels in Bollywood residents compared with residents in
-he comparison area. There was-no evidence of increased health effects among
persons in the Bollywood area based on data from questionnaires, physical
examinations, and blood pressure, liver enzyme, and urinary porphyrin tests.
Zn summary, there was no evidence of increased health effects among persons
living in the Bollywood area that could be attributed to the Bollywood Dump.
SUMMARY OF SITB RISKS
A baseline risk assessment wae conducted for the North Bollywood Dump and is
presented in the RZ (Supplemental Report) in the Public Bealth Evaluation
section. The risk assessment consisted of hazard identification, a
dose-response evaluation, exposure assessment and risk characterization.
Selection of Contaminants of Concern
The hazard identification involved the selection of contaminants of concern
(COCs), detected contaminants which have inherent toxic/carcinogenic properties
that are likely to pose the greatest concern with respect to the protection of
public health and the environment. Selected contaminants of concern at North
Bollywood included:
Inorganics
Arsenic Copper
Barium Zinc
Nickel Vanadium
Lead
-------
-50-
TAMLf 14
MUMINT SAMIti ANALVT1CAL lttUlTS l»*«|l III
NOIIH ItOUYWOUO OUMr. MEMntl* TENNISUE
OXBOW lAKf HAVII KtND AIANOUNID DUDCi KtMD
MMOI-I MMOI I MNOI-J NMIf-l NM*f-l MM4Of-l NM4Or-l WM4OF-I MH4OP-I NM40f-4 NM4Of-l MM4UP-t NM4OP-7 N(44UP«
mnaott
A Una
AlplU
lUyutkku
• 02]
•AM
ooa
•art
• •!•
NO
NO
NO
NO
• IM
•Ml
•.220
• 4M
007*
NO
NO
NO
NO
•OH
• Ml
• Ml
• IM
• Ott
NO
NO
NO
NO
• IM
• 4*0
• 211
•«M
• IM
^ NO
NO
NO
NO
• IM
• 2M
•Jit
• »M
• IM
NO
NO
NO
NO
2400N
4 WO
7 MO
MOOD
7000
i 21000
•^ooj
NO
NO
Nl
Nl
Nl
Nl
Nl
Nl
• 100|
•3001
Nl
• 410
• MO
NO
1.000
• 220
NO
NO
NO
NO
• MO)
•.MO
NO
• WO
•0*7
NO
NO
NO
NO
• II*
• 2M
•DM
• 140
• Oil
NO
NO
NO
NO
•Ml
AIM
• 0»l
• IM
• 024
NO
NO
NO
NO
NO
•CIO
• 01*0
• 270
• Ok7
NO
NO
NO
NO
07UO
IJOO
NO
• UO
•270
NO
NO
NO
NO
0710
•7UM
Nit
SMI
2 Ml
Nit
2JUUI
JJoo
Mat IN
oniuoiCANics
NO »OJO|N NO NO NO NO Nl NO NO NO NO NO NO NO
NO NO NO NO »OM|N- MOQO|N- ISOQ0|N- NO NO NO 1000 |N- I«0|N SOQO|N- $WJ|N
NO NO NO NO NO IIOOII IWOUO UNI •WOJ NO NO NO NO X*UI|
NO NO NO NO NO UOO|N- »000|N- NO NO NO NO NO NO NO
|TiltU'— T"-*
Mtihyl Pyndln*
CJ Alkyl kiu.M O
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
samp*
ijaa|N
ioaa|N
loao IN
iiaaaiN
NO
NO
NO
NO
NO
NO
loao IN
Nl
1000 |N-
Nl
11400 |N*
Nl
Nl
Nl
Nl
Nl
Nl
NO
NO
NO
NO
NO
••I»|N
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
SOOO|N
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
> 000(14
JOOOJN
iiiaajN-
NO .
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
•.WIN
•AH) |N
NO
Nit
Nil
NO
I4000J|N
NO
NO
Nil
Nit
NO
NO
Uiuuibyl I
Uaulud CUiHUuud
NO NO NO NO NO NO Nl NO NO NO NO NO UDOIN NO
-------
TA.U
Noam IKMIV wuuo ouur. MtMrttii. TINNSSME
OnOWLAKI _ _ __ HAVII W)NO __ AIANIM»lfDUIUDCt MIND
4 Ub
INUIOANICS
ll
&uunauai
lluiuuia
YIBIUIK
/Jot
bui
NMOI 1
NO
NO
NO
NO
NO
NO
NO
IM
IJ
IS
II
IS
12
110
U
t
41
11400
ISO
1.400
|JfeQQ
I&JUO
II
NO
0.2 It
MMOI 1
NO
NO
NO
NO
NO
NO
NO
170
It
2>
21
27
It
Ml
4S
14
II
»,uuo
*M
2.100
1.IUO
21400
20
NO
03 K
NMOI J
NO
NO
NO
NO
NO
NO
NO
110
II
1*
11
II
11
110
2»
I*
SI
11400
MO
•.mo
IJMO
I74U)
11
NO
02K
MHir-l
NO
NO
NO
NO
NO
NO
NO
2UO
as
2*
11
44
II
MO
4*
1*
100
21.0UO
110
2 JO)
IX)
21.0UO
12
• 27
UK
WMIfl NMAOr-l NH40P-I HMAOf-l MM4DP 1 NN4OP-4 NM4UP-S NM4UF * NU4OP-7
Cipllll
NO
NO
NO
NO
NO
NO
NO
200
21
U
11
M
It
170
S2
U
n
27.000
270
2JUO
l.MU
1S4UO
2S
Oil
02K
NO
NO
NO
NO
NO
• UM|
• Oil
**D
2J
17
47
140
24
2*0
V
12
1*0
I1.0UO
V)0
1JU)
1.100
17.000
21
OJ4
• 2 It
Nl
Nil
Nl
Nl
Nl
Nl
• 014
N*
Nl
Nl
Nl
Nl
Nl
NK
Nl
Nl
Nl
Nl
Nl
Nl
Nl
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• 2K
NO
NO
NO
NO
NO
NO
NO
IW
24
M
12
41 .
24
1*0
41
20
IW
14.000
1.100 •
1.100
4.0UO
1.700
12
• 24
IJt
NO
NO
NO
NO
NO
NO
NO
240
17
2*
22
17
II
120
40
IS
M
244UO
740
2.VJU
1.010
2».OUO
2S
• 17
•2K
NO
NO
NO
NO
NO
NO
NO
IW
20
U
1*
11
U
2M
40
11
11
2I.UUO
•00
2.200
2.7uO
XJ.UUO
22
01*
02K
NO
NO
NO
NO
NO
NO
NO
»2
Nl)
12
10
20
II
140
20
71
4S
t.4UO
4V)
I.7UO
I.JUO
II.UUO
10
NU
• 2K
Nf/
NU
NO
NO
NO
Nl)
NU
M)
Nl)
t
?*
IW
7
200
10
41
14
4.700
1*0
1.100
7X1
S.MW
»2
Nl)
02K
NO
NO
NO
NO
Nl)
• UM|
oiui
IM)
IS
U
20
Ik
1*
IM
1*
11
u
II.UUO
740
2.2UO
2.*00
2I.UJO
21
OU
0*4
NM40,..
IIOUU)
SIOUJN
I2000|N
Nl)
Nl)
Nil
OOuO
2M
It
Ju
11
A)
2U
IV)
M
1*
IVl
27.0UU
VAi
1.7U)
1JUU
ll>uu>
ft
041
OIK
NDIli
III I l.i J«u MM U4
-------
-52-
Pesticidee
Chlordane Aldrin
Oialdrin Total BHC
Heptachlor 4,4' DDT
Heptachlor Epoxide . Bndrin
Doae-Reaponae Evaluation "
The dose-response evaluation presented available human health and environmental
criteria for the contaminant* of concern, and related the chemical exposure
(dose) to expected adverse health effects (response). Included in this
assessment are the pertinent standards, criteria, advisories and guidelines
developed for the protection of human health and the environment. An
explanation of how these values were derived and how they should be applied is
presented below.
Cancer potency factor (CPFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg/day)'1, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg/day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level. The term
"upper-bound* reflects the conservative estimate of the risks calculated from
the CPF. Use of this approach makes underestimation of the actual cancer riak
highly unlikely. Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which animal-to-human
extrapolation has been applied.
Reference doses (RfOs) have been developed by SPA for indicating the potential
for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of mg/kg/day, are
estimates of lifetime) daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be
compared to the RfO. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict effects of humans). These uncertainty
factors help ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.
The sources for standards criteria and guidelines used for this assessment
were:
i) EPA AMBIENT STANDARDS AND CRITERIA FOR SUPERFUND REMEDIAL SITES. Table
5-2, Page 5-9, Guidance on Feasibility Studies Under CSRCLA. (June
1985)
ii) EPA SOPERFUND PUBLIC HEALTH EVALUATION MANUAL
(October 1986)
-------
-53-
•Exhibit 4-5, Applicable or Relevant and Appropriate Ambient
Requirements.
•Exhibit 4-6, EPA Ambient Water Quality Criteria (WQC) for Protection
of Human Health
•Exhibit 4-7, EPA Drinking Hater Health Advisories
iii) 45PR 79310 November 1980, 49FR 4SS1 February 1984 52 PR 2S690 July
1987. ...
The standards, criteria and guidelines for each of the indicators chemicals
identified are summarized in Table 15. Evaluation of these criteria indicated
that the 1/10 96-hour LC/50, which is the criteria established by Tennessee
under the Tennessee Hater Quality Criteria is in all cases much higher than the
Federal numbers.
In addition to comparing the exposure point concentrations to the criteria
presented in Table 15, total increased additive lifetime cancer risk was
estimated for exposure to on-Site soils, exposure to surface waters by swimmers
and the consumption of fish from potentially contaminated surface water. In
the Federal Register publication (FR Vol. 52, No. 130, page 25700) in which EPA
promulgated MCLs for certain VOCs, it is stated that "the target reference risk
range for carcinogens is 10 to 10 and the MCLs EPA is promulgating in
this notice generally fall in this range. EPA considers additional risk no
greater than this range to be protective of public health. The target range of
10 to 10 was used in this assessment to evaluate the acceptability of
-------
-54-
TABLE IS
APPROPRIATE STANDARDS AND CRITERIA FOR HUMAN HEALTH
Chemical
INORGANICS
Arsenic
Barium
Copper
Lead
Nickel
Vanadium
Zinc
Chromium
ORGAN I CS
Aldrln
Total BHC
Chlordane
Toxlcological ( 1 ]
Claaa
PC
NC
NC
NC
NC
NC
NC
NC
PC
PC
PC
Representative* '
Concentrations Water ^ ^
in Ground water Quality
| Quality Criteria
lua/Lt f uq/Ll
•
20.88 0.025
396 1,000
•i
30 1,000
55 50
26 15.4
42 NA (4)
124 5,000
58 ' 50
0.34 7.9xlO"3, 7.9xlO'4, 7.9xlO~5
3.78 3.1; 0.31| 0.031(10)
1.7 4.8xlO~2, 4,8xlO"3, 4.8xlO~4
Aquatic
^l°<&)
310
40,000
300
140
400
480
190
500
1.8
6.4
4.1
s Criteria
EPA (3)
(uq/Ll
190
1,400<5'
5.6<5>
3.8<5>
96<5>
NA
320<5>
0.29^>
1.9xlO~3
0.08(7>
4.3xlO~3
Continued
-------
TABLK
APPROPRIATE STANDARDS AND CRITERIA FOR HUMAN HEALTH
Chemical
4,4'-DDT
Dieldrin
Heptachlor
Heptachlor
Notes t
Toxicological")
Class
PC
PC
PC
Expoxide PC
Repreaent at 1 ve * '
Concentrat iona
in Groundwater
Quality
(ua/LI
0.54 2.4xlO~3,
0.4 7.1xlOT3,
0.88 2.9xlO~2,
0.76
Hater •^2-i-
Quality
Criteria
luq/L)
2.4xlO~4, 2.4xlO~5
7.6xlO~10, 7.6xlO~5
2.9xlO~3, 2.9xlO~4
N/A<4>
Aauatic
l/10th
tc <6>
1.1
0.8
19
4
Criteria
EPA
-------
-56-
At North Hollywood Dump, the current receptor population waa identified as
limited to the reaidential community surrounding the aite. Potential exposure
pathways evaluated included the ingestion by or direct contact with surface
soils, direct contact with surface waters (swimming), and the ingeetion of
fish. Ingestion of groundwater or inhalation of airborne contaminations or
fugitive dust were not identified aa significant exposure pathwaya.
Groundwater ingeation warn not conaidered an exposure pathway aince the
contaminated ehallow groundwater ia located directly beneath the aite and flows
directly into the Wolf River. There are currently no domestic supply wells
located in the Pluvial Sands Unit (shallow aquifer) between the Site and the
Wolf River. Therefore, there ia no current direct exposure by the public to
the contaminanta detected in the shallow aquifer. An ordinance in the City of
Memphia (Memphia Charter Section 424) preventa the installation of a water
supply well into the shallow aquifer within City limits if City water ia
available. A groundwater Quality Control Board for Shelby County haa been
established under Ordinance No. 3736 to secure, protect and preserve the
quality and quantity of the groundwater within Shelby County. This governing
body haa reaponaibility for enforcing the development of groundwater use in
Memphia.
Zn addition to the eatabliahment of the Groundwater Quality Control Board, the
Memphia and Shelby County Health Department ia eatabliahing regulationa for the
conatruction and modification of water .wella in Shelby County. These
regulationa are in accordance with the authority granted by Houae Bill No.
1008; Chapter 167; Section 17. Theae regulationa require that all wella be
constructed at leaat two feet above the 100-year flood plain. The area between
the Site and the Wolf River ia within the Wolf River 100-year flood plain.
Therefore, a domeatic supply well' could not be legally installed between the
Site and the Wolf River in the future.
Baaed on the inatitutional controla in place, the shallow aquifer between the
Site and the Wolf River cannot be used now or in the future aa a drinking water
aource. Therefore, the uae of shallow aquifer water aa a potable water source
ia not a complete route of expoaure. However, contaminated groundwater
discharging to the Wolf River may potentially impact the water quality of the
river. Therefore, the principal expoaure to the contaminated groundwater is
addreaaed under the diacuaaion of the Wolf River.
Inhalation of airborne contaminanta waa not conaidered a pathway since the
contaminanta axe contained by a aoil cover and the major contaminants do not
volatilize readily.
Assumptions uaed to characterize expoaure point concentrationa were all based
on a 70-Jcg adult.
Risk Characterization
The risk characterization quantifies present and/or potential future threats to
human health that reault from expoaure to the contaminanta of concern at North
Hollywood. The aite-apecific riak valuea are estimated by incorporating
information from the hazard identification, dose-response evaluation, and
exposure assessment.
-------
-57-
.en sufficient data are available, a quantitative evaluation ia made of either
>e incremental risk to the individual, resulting from exposure to a carcinogen
or, for noncarcinogena, a numerical index or ratio of the exposure dose level
to an acceptable does level is calculated.
«
Risks which were assessed in the North Hollywood Remedial Investigation include
noncarcinogenic and carcinogenic risks resulting from exposure to individual
COCs. '
For noncarcinogenic compounds, various regulatory agencies have developed
standards, guidelines and criteria which provide "acceptable* contaminant
levels considered to protect human populations from the possible adverse
effects resulting from chemical exposures. A ratio of the estimated body dose
level to the RfO or AIC provides a numerical index to show the transition
between acceptable and unacceptable exposure. This ratio is referred to as the
chronic hazard index. For noncarcinogenic risks, the term "significant" ia
used when the chronic hazard index is greater than one. When Federal standards
do not exist, a comparison was made to the most applicable criteria or
guideline.
Calculated contaminant dose levels, as described previously, were compared to .
the dose level associated with the most applicable standard or guideline. The
estimated chronic dose level in ug/kg/day is estimated using the exposure
assessment assumptions and actual site data. The dose level is then compared
fo the AIC to determine if chronic exposure to the contaminated soil presents a
gnificant risk.
«
For carcinogens or suspected carcinogens, a quantitative risk assessment
involves calculating risk levels considered to represent the probability or
range of probabilities of developing additional incidences of cancer under the
prescribed exposure conditions. Carcinogenic risk estimates, expressed as
additional incidences of cancer, are determined by multiplying the carcinogenic
potency factor, as described earlier, by the projected exposure dose level.
These risks are probabilities that are generally expressed in scientific
notation (e.g., 1 x 10 ). An excess lifetime cancer risk of 1 x 10
indicates that, as a plausible upper bound, an individual has a one in one
million chance of developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure conditions at a
site. To put the calculated risk estimates into perspective, they should be
evaluated against a baseline risk level. Risk levels of 10 to 10 can
be used to determine the "environmental significance* of the risk incurred and
are used as a target range for remedial purposes (0.3 EPA, 1986). Using thia
range as a base-line, a risk level greater then 10~4 is considered to present
a "significant* risk with regard to human health in an environmental context,
and levels less than 10 are considered "insignificant." A risk level
betwe«n 10~4 and 10~6 is classified as "potentially significant." The use
of the terms "significant*, "potentially significant* and "insignificant* are
not meant to imply acceptability; however, they help to put numerical risk
estimates developed in a risk assessment into perspective.
-------
-58-
Tha noncarcinogenic risk characterization for the North Hollywood Dump
concluded that under "realistic worst-caae" and "moat probable* exposure
scenarios the chronic noncarcinogenic risks associated with current and futur -•
exposures (ingestion or dermal contact) to surface soils appear to be
"insignificant." Likewise, acute or chronic dermal contact with surface water
under realistic worst-case and most probable exposure scenarios does not appear
to result in "significant" noncarcinogenic risk.
The carcinogenic risk characterization concluded that the carcinogenic risks
associated with future incidental ingestion of surface soils and dermal contact
with surface soils under realistic worst-case and most probable exposure
scenarios are considered "insignificant." Direct dermal contact with surface
waters under future realistic worst-case and most probable exposure scenarios
appears to be "insignificant* and fish consumption from the Wolf River also
appears to be "insignificant." However, scenarios which evaluate the
carcinogenic hazard associated with the ingestion of fish from the on-eite
ponds (Oxbow Lake and the dredge pond) predict the carcinogenic risk to be
"significant" (i.e., exceeds the SPA target range of 10~4 to 10"6) for the
realistic worst-case and "significant" for the most probable exposure
scenarios. A summary of carcinogenic risks for consuming fish from Oxbow lake
and/or the dredge pond is presented in Tables 16 and 17.
Environmental Risks
Environmental risks associated with the presence of soil contamination at North
Hollywood are expected to be minimal. Based on the investigation results,
surficial contamination is limited to relatively small areas of the present
cover that have eroded. Therefore, risks to flora and fauna at the surface are
limited. Environmental risks from the contaminated sediments in the on-site
ponds have already contaminated fish to above acceptable human health levels
and the contaminant have the potential to bioaccumulate in other biota. It
should be noted; however, that subsequent sedimentation of the on-site ponds
could have decreased the exposure to the contaminated sediments.
Affects of the shallow groundwater on the Wolf River were evaluated based on
stream water quality standards set by State and Federal criteria. In order to
evaluate whether the low level contaminated groundwater which discharges to the
Wolf River results in an exceedence of the Tennessee Water Quality Criteria or
the Federal Hater Quality Criteria, it is necessary to calculate the total
contaminant BASS flux into the Wolf River immediately adjacent to the Site.
upon determination of the mass flux to the river, a resultant instream
concentration can b« calculated for comparison of the instream water quality to
pre-established criteria.
The total mass flux was calculated across a boundary from upstream at a point
adjacent to the eastern edge of the landfill to a point downstream adjacent to
the western edge of the landfill. The contaminants used for this calculation
were the indicator chemicals previously identified.
-------
TABU 16
•VALOAtlOM OF MALTM •!•«
COHIIM»*IOM or nan r«OM oxaXM LAM
CA*»4eal
C««o««fcr
tm rtmh mg/kg
*»*«0« Omlly Imttk*
Chlocd*n«
Linden*
t.4S
2.23
0.2*
Heptochloc B|K»«ld« 0.33
DOT 0.44
TOTAL
4.It • 10~2
1.44 « 10~2
l.t* • iO"J
2.14 « I(TJ
2.92 K 10~J
».OJ B l
).«4 m IO'1
4.(2 » 10'1
«.30 • 10"J
rmetar XA1
1.1 B 10"*
JLA
1.73 H »0"J
4.0 • 10~>
1.1 • »0~J
7.It « I0"«
l.tl » I0~3
3.11 • 10~3
.1 • 10
-3
(1) Concent r«t ion* s«|M>ft»d by St«l« of T«no«aa«« OUK l'i»h Study I19III . Mhol* body cooc«ntc«lloa* •>•
cuitoitt >«t iun* Mould b« i|*n«ially lox»i .
(2| l^>w«l 1: ftaauJMi •«•(•()• conauofjl Ion of flah la k.i tjWday «nU 10% coawc fioa Oibow L«k«.
|j| l«w«l 2: Ajauaoa «v«i*
-------
-60-
17
•OMTACI MaTU UtOaBftX AMD KIM
coHCOMttioki or
Oft-llTB
•MM BOLLIMOOO DOI4V
<»•*•• Lak*
Dakar
Concantiation lag/kg)
•cr
Cone, la rich
ChMuc«l ttorn rich
!««•! I (•g/DAV)
!*«•! 2
rich Uo««
Uv.l 1
L*v«l 2
CUV |»j/k4/UAV|
Uval I
lavaI 2
Nota*;
1.
1.
2.
1.
• •
ft.
1.
1.
ft.
•0
ftl
•J
••
»
44
I*
44
!•
X
X
X
X
X
X
X
4
X
X
io-«
10**
10
10
10
10
10
.ft
10
10
»0
-2
-2
-4
-J
-J
-J
1
1
ft
1
1
4
1
4
1
.10
.44
.42
.4ft
.•4
.21
.12
.14
.02
X
X
X
X
X
X
X
»
X
X
10-*
,0*4
10*«
10-*
10-*
io-«
10-'
.1
io-»
io-»
4.00 X 10-*
4.14 X 10**
l.*04 a IO*1
1.21 X 10-'
2.41 X lO'*
1.11 X 10"*
1.41 X 10'*
14
2.41 X IO'1 ».2 X 10*'
4.01 X 10"* 1.2 X 10'*
1.1ft X 10~*
l.ftl X 10**
2.12 X 10**
1.14 X 10'*
2.11 X IO-*
l.ll X 10**
4.24 X I0~*
4. ft
l.ftl X 10'*
l.*l X 10-'
ft. 40 X 10'*
1.44 X 10**
1.10 X 10*°
4.04 X I0~*
1.0* X 10" »
1.22 X I0"«
1.44 X 10-'
• .1
4.40 X IO'1
1.41 X 10 *
0.00 X 10'*
4.14 X 10**
1.01 X IO'1
2.40 X 10"'
ft. 11 X 10-'
1.44 X 10'*
1.42 X 10"*
14
4.44 X 10"*
1.21 X 10'J
II 10
l.J
cli**ic*l concent ••! I un* •• i*(x>it*il in T«»k Clcawnl IV ttcpeil*. Av*(«g* of D«l*ct*.
bcr o«uia. Souicat Cfk IMIS databaca 01/10.
Cancai Hlak-t'lalii additional llfattaa cancar (tak aatlaatad to laault doa tb« apaclftad laval fa llch cun«u«^>lluii Cue a litatlM |ltt yaaf a| .
2. 14 giaaa
-------
-61-
•le IS presents the results of mass flux calculations for each indicator
mical and for each round of sampling including an average mass flux for all
rounds. Since the attenuation capacity of the constituents was not considered
in the mass flux calculations and since the full or partial limit of detection
was used for constituents not detected, the total mass flux presented in Table
18 is conservative. The actual mass flux to the Wolf River would be expected
to be much lower than these numbers. The sampling completed during the
Supplemental RI confirms this.
Using the mass flux calculation presented in Table 18 the resultant
concentration in the river was calculated to determine what impact contaminated
groundwater discharge could potentially have on the Wolf River water, sediment
quality, and aquatic life. The resultant concentrations in the Wolf River were
calculated using two flow rates provided by the USGS. The 3Q20 flow rate was
used to evaluate any immediate or short-term toxic effects to fish which could
potentially occur if contaminated groundwater was discharged to the wolf River
at low flow conditions. Zn addition, although not specifically identified in
the Tennessee Water Quality Criteria, the IS-year average flow in the Wolf
River was used to evaluate the long-tern chronic effects (of lifetime exposure)
to humans that could potentially catch and consume fish from the Wolf River on
a frequent basis.
Table 19 presents a summary of the resultant concentrations in the Wolf River
for each of the indicator chemicals for each of the assumed river flow rates.
Tennessee Water Quality Criteria established for the four river
ssifications are most stringent for Fish and Aquatic Life. Zn addition to
these State standards, Federal Water Quality Criteria are also established for
toxic effects to aquatic life and chronic effects to humans that consume
aquatic life only. All three of these criteria are presented on Table 19.
The resultant inriver concentration for all of the indicator chemicals, with
the exception of chlordane for the second round of data, are below the Federal
criteria for Freshwater Aquatic Life for both 24-hour exposure and the ceiling
exposure. Therefore, for the low flow ("worst case scenario") there will be no
significant impact to the fish found in the Wolf River except potentially for
chlordane.
Evaluation of the inriver concentration for long-tern chronic effects is more
appropriately carried out on the annual average flow of the river. The inriver
concentration for the Supplemental RZ sampling rounds for this flow were all
below the Federal Water Quality Criteria for the consumption of fish only
except for chlordane during the second round of sampling. Given the
conservative assumptions used in the mass flux calculations and the
calculations for the inriver concentration, it is concluded that the Site
should not significantly impact the Wolf River water quality based on
preestablished regulatory health-based criteria.
To monitor the shallow groundwater for changes in its effects on the river,
Alternate Concentration Limits (ACLs) were established using the mass flux
"culation and a 10 risk level for the consumption of fish from the
-------
TA3L2 18
SUMMARY OP GRCUNBWATSR MASS PLUX DATA
COMPOUND NAME
ROUND 1
(ug/d)
Total BHCs
Heptachlor —
Aldrin
Heptachlor Epoxide —
Oieldrin —
4, 4 '-DOT ' —
Chlordane —
Arsenic 2.04E+07
Barium 1 .47E+09
Nickel 2.19E+07
Lead 1 .062*08
Copper 8.83E+07
Zinc 1 .73B+08
Vanadium 5.55B-MJ7
Chromium 1.13E+08
HOUND 2
(uq/d)
S.74E-*-06
3.572*05
6.11E+04
4.71E*05
O.OOE-t-00
1 .97E-MJ5
2.38E*06
5.25B>06
1 .59E*09
2.39E+07
5.17E+07
1.5tE*08
9.44E*07
4.55E*07
1 .56E-MJ7
AVERAGE
ROUND 3
1 .49E-H35
1 .T4E*05
7.97E*03
1 .27E*05
0 .OOE-^00
7.97E+03
7.17B+04
9.51E*07
1 .95E*09
1.77E*07
2.04E+08
1.02E*08
1 .86E>08
5.87E-»-07
7. 798+07
S
ROUND 4
( u<7/d )
4.35S+Q5
8.41S*05
1 .372*05
4.68E+04
O.OOE+00
2.64E+04
5.59E+05
6.58 +07
1 .02E+09
3.26E+07
8.30B+07
5.93E+07
1 .66E>08
6.76E+07
1 .03E+08
AVERAGE
(uo/d)
2.?'S-06
4.J-E-05
6.9"=:*G4
2.152*05
O.OOS*00
7.725*04
1.00E+06
4.662*07
1 .S'2«09
2.40
1 .14E*08
T .002*08
1 .55S*08
5.68S*07
7.72E*OT
Notea;
1) Pi rat round pwticid* data not used due to lack o£ confirmation and elevated
concentrations in blanks.
2) 2.11E*06 - 2,110,000
-------
19
IMATRO 1MCHBAS80 COUCKNTtUTION IN MOLf RIVBR CAU8KO BV MOUTH HOU.VWOUO
MM run CALCULATIONS 109/1.)
Parameter
Tennaaaee
Mater
Quality
Criteria
for Aquatic
Life
(uq/L)
III
U)
Praah Matar
Aquatic Li fa
(nq/L)
Matar
Quality
Critarla
(nq/L)
Round |l
Round 11
C C
1 2
Total BMCa a.4
Heptachlor 19.0
Aldrln !-•
Heptachlor Kpoalde 4.0
Oieldrln 0.0
4.4'-OOT 1.1
Chloidane 4.1
Aiaenlc 110
Barium 40.000
Nlckal 400
Lead 140
Copper 100
Sine 190
Vanadium 4SO
Chromium 500
NUT Eiii
42.5(91(11) —
B7JI4 (III —
1.00
BTTI4
(10)00/2.000
1.0/5JO
1.9/2.500
MA/MA
1.9/2.500
I.0/1.100
4.1/2.400
MA/440.QUO
MA/MA I.0007000(71
94.000/1.000.000 07,710(7)
1,000/170,000
5.400/22,000
47.000/120.000
MA/MA
290/21.000 11,000
2.21
12.15
on
aril mi
"7.79 n.02
5«T7IT j.2ir7t~
~"ITY4r "47.12
47T7T 25TTTT
14TJT TiTTJf
imn
vror
ini
TIBC
42JTTI'
1.
BTVo*
6T17
fTTT
ITT40-
5I71I
irrsi
SI.C2
ITTTK
T77T4T
503:11
4T7I7. JliTlT
TTW
Avar«>|o All Huun.ln
C C i!
21 I
I) Valuea pritaantad ar« 1/10 of
for each conatltuant. LC*tQ value for orqanlc cttaatlcala in war* water apeclea Haled In Haiutliook
of Environmental Data on Orqanlc Chemlcala. Karel Verachueren. Van Moral rand Kharahold Co. New York). Inorqanlc LC5n informal ion from
Malar Quality Criteria, California State Hater Reaourcaa Control Board. L.K. Mctee, H.M. Half, Bdltore. 2nd Kdltlon 194).
Valuee preaented potential carclnoqena are for a 10 cancer rlak due to eMpoeura throuqh inqeatlon of contaminated aquatic orqanlama only
(Environmental Protection Aqency Mater Quality Criteria).
Plrat round peaticlde data not uaed due to lack of confirmation and elevated concentrattona In blanka.
C| representa 15 year avaraqa flow In Molf Mlver at Gormantown Hoed brldqe (1.050 cfa/2.549 ».IO L/dl. 5)
Mult Hiwer at Germantuwn Road bridge «a prcaented In UtiliS Open rile Hepuii 04-4147 (190 cfa/4.45_ a 10
llaidneoa C 100 uq/L CaCO^
l.t/t.'tOU - 24-hour e«pu!ture/i:el I Inq
'leuciiluil lur q*aWd-UIU'
2)
1)
4)
71
«l
41
IUI ricacill t:tl || I |>ll« ~ U4lt°.
Ill H..,iJ.--i l''^2£Jlij:'l l» l'i»»|-»Mi:il :ilale M.iloi U'>->>» y l'ilt«:tl.»
repieeenle I\)i0 fl
-------
-64-
river. The ACLs are calculated in Table 20. In order to determine if any of
the ACLa have been exceeded, the monitoring well* representing each of the
cells along the Wolf River would be sampled and analyzed for the indicator
chemicals. The data from each monitoring well would be averaged together using
a weighing factor baaed^on the groundwater flux from each cell.
Croundwater and surface water samples will initially be collected on a
quarterly basis.
1. If four consecutive quarterly samples show no exceedance of
established ACLs (which may be modified up to higher background
concentrations determined as an average of concurrent results from the
seven upgradient monitoring wells OW-2a, b, c; OW-3a, b, c; and TAG
10B), then the monitoring frequency may be reduced to a semiannual
basis.
2. If eight consecutive semiannual samples shew no exceedance of
established ACLs, then the monitoring frequency may be reduced further
to an annual basis.
3. If, after five years of monitoring, no ACL exceedance has been
shown, then further modifications of the monitoring program may be
considered.
4. If any sample during the monitoring period above shows an
exceedance of a parameter(s) specified in the,ACLs, monthly monitoring
will be instituted for that (those) parameters. This monitoring will
be conducted at the tren downgradient wells specified for the
calculation of contaminant flux in groundwater from the Site to Wolf
River. Quarterly monitoring will be continued for all other
parameters.
a. After twelve consecutive samples, a statistical analysis
using the t-distribution will be performed to determine if a
violation has occurred.
b. If a violation has occurred, appropriate remedial action will
be begun by the PRPs as specified on Page 92 and monthly
monitoring will continue until a statistical analysis shows a
violation is no longer occuring.
e. If a violation has not occurred, quarterly monitoring may be
resumed and monthly monitoring will not again be required for
that (those) parameter(s) that triggered the previous series of
monthly monitoring unless it (they) exceeds the high value(s)
measured during the twelve-month monitoring sequence.
Uncertainties
Regardless of the type of risk estimate developed, it should be emphasized that
all estimates of risk are based upon numerous assumptions and uncertainties.
In addition to limitations associated with site-specific chemical data, other
-------
TABU 20
OLLCUXATXOH Or CROtJHDWATIR CONOUITRATXOHS FOR AC1«
XOTXCATOR CHXKXCAX,
AVIRAGV
WAT»R QUALXTT<1) MASS FLUX GROUMOWATIR
CRXTIRXA TO WOLF RIVXR CONCZNTRAtZOV
(&9/X.) (ug/d)
Total BHCs
Heptachlor
Aldcin
Heptachlor Epoxide
Dieldrin
4, 4 '-DOT
Chlordane
Arsenic
Barium
l.SL
Q 214
Copper-^
Vanadium
Chromium^
1.00
O.L44
0.59
Q 48
ua
1,000, 000 <-i>
NA
3,49 x lfl.fi
1.S2 «
1.23 x
3 0
IgQ. 4?
I.Q73.
x IQlfl
1.77 x
19. S52
?iq i
Ifli
NA
1.3S x II
1.Q7 » Ii
NA
Q.45
NOTES:
(1)
(1)
(1)
(1)
Values presented aa potential carcinogens are for 1 x 10~6 cancer risk
due to exposure through ingestion of contaminated aquatic organisms only
aa presented in Environmental Protection Agency Hater Quality Criteria
Praaaorf
NA - Not available.
Criteria shown for hardness of 100 mg/L CaC02-
Criteria shown of alpha-BHC.
-------
-66-
as sumptions and uncertainties that affect the accuracy of the •ite-specific
risk characterizations result from the extrapolation of potential adverse human
health effects from animal studies, the extrapolation of effects observed at
high-dose to low-dose effects, the modeling of dose response effects, and
route-to-route extrapolation.
The us* of acceptable levels (established standards, criteria and guidelines)
and unit cancer riak values which are derived from animal studies introduces
uncertainty into the. risk estimates. In addition, the exposure coefficients
used in estimating body dose levels are often surrounded by uncertainties. As
such, these estimates should not stand alone from the various assumptions and
uncertainties upon which they are based. In developing numerical indices of
risk, an attempt is made to evaluate the effect of the assumptions and
limitations on the numerical estimates. When the assumptions and uncertainties
outweigh the meaningfulness of a risk assessment, a qualitative assessment of
the risk is performed.
The uncertainty factors which are incorporated into the risk estimates are
believed to be conservative. As such, when they are considered collectively,
exposure, and subsequently risk, may be overestimated. These estimated risk
calculations were based on present conditions at the site including the
temporary cover and no major increases of contaminants in the shallow aquifer
which discharges to the Wolf River. Additional risk could occur should the
concentration increase or the temporary cover erode.
In conclusion, based on the results of the risk assessment, actual or
threatened releases of hazardous substances from North Bollywood Dump, if not
addressed by implementing the response action selected in this ROD, may present
an endangerment to public health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVgS
The dump wastes, contaminated soil, surficial groundwater and pond sediments
are under consideration for cleanup. The landfill wastes and groundwater
require different technologies for remediation. The treatment alternatives are
divided into those for the landfill and groundwater and those for the surface
water impoundments. A remedy for the site and underlying surficial groundwater
is proposed to protect public health and the environment by controlling
exposure to contaminated materials and controlling migration of contaminants
into surrounding soils, sediments, and surface water. The on-site contaminated
wastes and soils preeent risk levels which are within BPA's acceptable range.
However, the landfill does not meet municipal landfill standards for the time
of its closure, and the temporary soil cover has the potential to erode.
Identified as a Class XI aquifer, the contaminated shallow groundwater beneath
the site is not used as a drinking water source due to well restrictions
imposed by Shelby County. Also, the shallow groundwater beneath the site
discharges directly into the Wolf River. Based on this information, the
shallow groundwater was evaluated on its effects on the Wolf River, and there
is presently no indication that the shallow ground is or will in the future
present a risk to the Wolf River. A remedy for the impoundment sediments is
proposed to protect public health and the environment by controlling the
-------
-67-
ingeation and accumulation of contaminants by flora and fauna, especially fish,
in Oxbow Lake and the dredge pond. The preferred alternatives will address the
dump wastes, contaminated soil, surficial groundwater and pond sediments as one
response action. The two preferred alternatives, once implemented, should
complete the response action at this site.
A total of four alternatives .were evaluated in detail for remediating the
landfill wastes and shallow ground water. Zn addition, six alternatives were
evaluated in detail for remediating the sediments in the surface water
impoundments.
Landfill Wastes and Shallow groundwater
The following lists the remedial alternatives under consideration for the
landfill wastes and shallow groundwater.
All these alternatives involve restrictions on land and well use at the site,
upkeep of the fence and property, and monitoring to assess the effectiveness of
the remedy.
ALTERNATIVE It NO ACTION
Present Worth (PW) Cost: $2,338,670
Years to Implement: 0
CZRCLA requires that the "No Action" alternative be considered at every site.
Under this alternative, no soil, sediment, or groundwater containment or
treatment would take place. They only reduction of contaminant levels would
occur via natural processes such as dispersion and attenuation. The only costs
would be for monitoring the site. Monitoring can be implemented using
previously installed wells.
ALTERNATIVE 2; LOW PERMEABILITY SOIL COVER
Present Worth Cost: $4,942,950
PW Capital Cost: $3,364,280
PW 0 & M Cost: $1,578,670
Years to Implement: 1
The existing low permeability cover on-site will be upgraded to meet the
sanitary landfill standards of a twenty-four inch cover and the existing fence
will be completed around the perimeter of the site. Excavation of the buried
wastes and contaminated soil identified during the supplemental RI/FS in the
more easily eroded areas near the Wolf River and the surface water impoundmenta
will be placed beneath the upgraded cover as part of this alternative.
The cover will contain an area of approximately seventy acres with an average
refuse layer of 26.5 feet thick. Erosion control matting will be placed along
the edges of the landfill in the ten-year flood plan and easily eroded areas.
Pegged sod will be placed along drainage swales and steep slopes of the
landfill. Erosion control will also be performed during the construction and
the period after while vegetation is established over the upgraded landfill
cover.
-------
-68-
\
AND HYDRAULIC CONTAINMENT BY
Present Worth Cost: $6,802,680
PW Capital Cost: $4,490,420 .
PW O & M Cost $4,312,260
Year to Implement: 5 -
The site will be covered and specific areas will be excavated as described in
Alternative 2. Alternative 3 also includes hydraulic containment of the site
by the use of extraction wells. Extraction wells will be place on site and
hydraulic performance monitoring wells will be installed for assessing the
performance of the extraction system. The extracted groundwater will be
discharged to the City of Memphis sewer system for treatment.
AND PHYSICJ
BY BARRIER
ALTERNATIVE 4i
WALL
Present Worth Cost: $13,251,555
PW Capital Cost: $11,025,685
O 6 M Cost: $2,225,870
Years to Implement: 2
Alternative 4 will consist of upgrading the existing cover and excavating
specified areas as described in Alternative 2. Alternative 4 will alao include
the construction of a barrier wall (containment wall) into the ground around
the perimeter to contain the -landfill wastes and underlying shallow
groundwater. The wall will be installed using slurry trench techniques and
will require the construction of a collection drain system to maintain an
inward hydraulic gradient and control flood waters higher than a ten year
flood. Extraction wells will be installed to remove water resulting from
infiltration and hydraulic performance monitoring wells will be installed to
monitor the performance of the containment system.
ARARS
Several specific Applicable or Relevant and Appropriate Requirements (ARAR3)
were identified for the remedial alternatives of the North Hollywood landfill
and shallow groundwater.
The sanitary landfill standards specified in the Tennessee Solid Waste
Regulations are an Applicable or Relevant and Appropriate Requirement (ARAR)
for the closure of North Bollywood due to it primarily being an old municipal
landfill for the City of Memphis. Under OIC regulations, to leave contaminants
in an aquifer above MCLs in Tennessee (even one not used as a drinking water
source) and in order to place additional restrictions on well installation and
use at the site, a groundwater classification for the site area must must be
obtained from the Tennessee Water Quality Control Board. State and Federal
Water Quality criteria are ARARs for groundwater discharges into the Wolf
River. The criteria and the associated Alternate Concentration Limits (ACLo)
for the groundwater contaminant levels are listed in Table 20 of the Risk
Characterization Section. The consolidation of waste in the area of
-------
-69-
contamination (AOC) does not constitute placement under the Resource
Conservation and Recovery Act (RCRA) Land Disposal Restriction (LDRs), and
therefore LDRs do not apply to the remedial alternatives. However, should
wastes be unexpectedly uncovered during the waste consolidation or movement
that require additional.containment, treatment, or removal, LDRs will be
complied with or treatability variances will be obtained. Should it become
necessary to pump and discharge groundwater, Clean Water Act pretreatment
standards for discharges to Publicly Owned Treatment Works (POTWs) would apply.
Surface Water Impoundments
As stated in the summary of site risks, sediment from early sampling indicates
an unacceptable human risk level from the long-term and frequent consumption of
fish from Oxbow Lake and the dredge pond. Due to the changes that can occur to
the sediment in a surface water body, additional sampling will take place
during the design phase of the remedy. This sampling will be done concurrently
with the design so as not to delay the remediation process. The sampling will
be done to verify the condition of the impoundments and to better define the
contaminated areas. This sampling will not affect the selected remedy unless
surface sediment contamination concentrations have decreased to within
acceptable risk levels.
The following lists the alternatives selected for remediation of the surface
water impoundments.
All alternatives involve restrictions on fishing until remediation is complete,
and monitoring is established to assess the effectiveness of the remedy.
ALTERNATIVE 1; NO ACTION
Present Worth (PW) Cost: $406,500
Years to Implement: 0
CZRCLA requires that the "No Action* alternative be considered at every site.
Under this alternative, no remediation of the impoundments' sediment or fish
would take place. The only reduction of contaminant levels would occur via
natural processes, and ARARs would not be met. The only costs would be for
monitoring.
ALTgRNATIVg 2: PERIODIC HARVESTING OP FISH
Present Worth Cost: $340,910
PW Capital Costs $113,635
PW O & M Cost: $227,275
Years to Implement: 20
Fish in the ponds will be harvested on a periodic basis to ensure
bioaccumulated contaminant levels in the fish are below acceptable
concentration levels set using the 10 risk of one potential additional case
of cancer in a population of one million persons. Fish will be harvested using
•Rotenone* or other appropriate agent. Poisoned fish will be disposed of in
containers paced with soil and sent to an appropriate landfill. Monitoring cf
fish contaminant levels will be required to determine harvesting times.
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-70-
ALTERNATIVg 3t DRZDCg WITH CONTAINMENT ON EAST SBCTOR OP
Present Worth Cost: $2,341,885
PW Capital Cost: $2,298,875
PW O & M: $43,010
Years to Implement: 2
Alternative 3 consists of the dredge/excavation of contaminated sediments from
the impoundments and containing sediments on the east sector of the landfill
beneath new cover. The sampling during the Remedial Design (RD) phase will be
used to determine contaminated sediment levels baaed on a 10~6 risk level for
consumption of the fish. The impoundments will be dewatered during the
excavation process and the fish will be harvested. The impoundments will be
restocked with fish after the action is complete to keep from affecting the
wildlife food chain in the area.
ALTERNATIVE 4; IN-PLACB CONTAINMENT WITH HYDRAOLIC PILL
Present Worth Cost: $3,098,940
PW Capital Cost: $3,067,300
PW O & M: $31,640
Years to Implement: 2
Three (3) feet of fill will be placed over the contaminated sediments to
contain the contamination. Depending on results from the fish and sediment
sampling establishing acceptable sediment levels, all "or part of the
approximate seventy acres of the dredge pond and the approximate ten acres of
Oxbow lake will be hydraulically contained. Ceofabric will be placed on the
slopes of the dredge pond and on the contaminated area of Oxbow Lake to suspend
the movement of contaminants and sediments from the small beaver pond will be
excavated and contained in Oxbow Lake. Partial dewatering of the impoundments
will be necessary. Pish from the impoundments will be harvested and the
impoundments restocked upon completion of the Remedial Action (RA).
ALTERNATIVES 5; IN-PLACT CONTAINMENT BY NATURAL DEPOSITION AND REROUTING OP
WOLF RIVER
Present Worth Cost: $2,263,130
PW Capital Cost* $2,224,700
PW O & M Cost: $38,430
Years to Implement: 10
Alternative 5 consists of diverting the Wolf River through the dredge pond and
utilizing natural sedimentation to cover the contaminated sediments. Inlet and
outlet channels from the Wolf River will be excavated, and a dam will built to
channel water from the Wolf River to flow through the dredge pond. Soil
excavated from the channels would be used to backfill Oxbow Lake. Pish would
be harvested from the dredge pond to prevent them from entering the Wolf River
and fish barriers would be used to prevent fish from the Wolf River from
entering the dredge pond and coming in contact with the sediments.
-------
-71-
ALTERNATIVB 61 EXCAVATE WITH CONTAINMENT ON EAST SECTOR OF LANPPILL AND
IN-PLACE CONTAZNMgNT WITH HYPRAOLIC PZLZj
Present Worth Coat: $2,988,860
PW Capital Cost: $2,94$,850
PW O & M Cost: $43,010
Years to Implement: 2
» •
Alternative 6 consist* of excavation of contaminated sediments at shallow water
depths with on-site disposal like Alternative 3 and the in-place containment of
contaminated bottom sediments with hydraulic fill like Alternative 4. As in
Alternatives 3 and 4, the fish will be harvested and the impoundments restocked
at the end of the Remedial Action.
ARABS
ARARs for the surface water impoundments include the Pood and Drug
Administration's (PDA) action levels for contaminants in fish tissue.
However, it is anticipated that levels set on a 10~6 risk level using the
data taken from the fish sampling that will be performed during the RD will be
lower than the PDA action levels. Zn the interest of public health, EPA will .
use the fish concentration levels that are more protective in establishing
acceptable sediment concentration levels and remediation requirements for the
surface impoundments.
Zn dewatering the impoundments for remediation, Clean-Hater Act standards for
discharges to POTWs and the filling of inland surface water bodies under
Section 404 will apply.
Any consolidation of the contaminated sediments on site would not, however, be
applicable under RCRA LDRs since the consolidation in the area of containment
does not constitute placement.
SUMMARY OP COMPARATIVE ANALYSIS OP ALTgRNATZVBS
The remedial alternatives developed during the North Hollywood Dump Site PS
were evaluated by U.S. EPA using the following nine criteria. The advantages
and disadvantages of each alternative were then compared to identify the
alternative providing the best balance among these nine criteria.
1. Overall Protection of Human Health and the Environment addresses
whether or not an alternative provides adequate protection and
describes how risks are eliminated, reduced or controlled through
treatment and engineering or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) addresses whether or not an alternative will meet all of the
applicable or relevant and appropriate requirements or provide grounds
for invoking a waiver.
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-72-
3. Long-term Effectiveness and Permanence refers to the ability of an
alternative to maintain reliable protection of human health and the
environment, over time, once cleanup objectives have been met.
4. Reduction of Toicicity, Mobility or Volume is the anticipated
performance of the treatment technologies an alternative may employ.
5. Short-term Effectiveness involves the period of time needed to achieve
protection and any adverse impacts on human health and the environment
that may be posed during the construction and implementation period
until cleanup objectives are achieved.
6. Zmplementability is the technical and administrative feasibility of an
alternative, including the availability of goods and services needed to
implement the solution.
7. Cost includes capital costs, as well as operation and maintenance
costs.
a. Agency Acceptance indicates whether, based on its review of the HS/FS
and Proposed Plan, U.S. SPA TNDKZ agree on the preferred alternative.
9. Community Acceptance indicates the public support of a given
alternative. This criteria is discussed in the Responsiveness Summary.
Landfill Wastes and Shallow Croundwater
The following is the evaluation of the four (4) alternatives for the landfill
wastes and groundwater using the nine criteria. A comparison of the
alternatives omitting State and Community Acceptance is presented in Table 21.
Overall Protection of H\*fan Health and the Environment
All alternatives presented in this document except for No Action would be
protective of human health and the environment based on present conditions.
The No Action alternative is not protective because in the future, failure of
the temporary cover on the site could allow human or animal exposure to
contaminants through soil contact and migration of unacceptable levels of
contaminants into the Wolf River. The other alternatives would prevent human
or animal exposure to on-site contaminants and control contaminant
concentration* from entering the Wolf River. However, should contaminant
concentration* in the groundwater increase to above acceptable 10 risk
levels, Alternatives 3 and 4 would be protective of human health and the
environment.
Compliance with Applic*^le or the Relevant and Appropriate Requirements
All alternativee except for No Action would comply with applicable or relevant
and appropriate requirements (ARARs). The No Action alternative is not in full
compliance with ARARs for the closure of landfills and would allow for possible
direct contact or exposure to hazardous substances. Alternatives 2 through 4
are in compliance with sanitary landfill closure requirements and Alternatives
-------
-n-
TA»LH 21
SUMMABY Of DETAILED ANALYSIS O* HfcMfcDIAL ALTKMNATIVIS KMl
LANDMU WASTHS AND CBOUNDWATU
NOHTH HOLLYWOOD DUMT. MKMTIUS, TCNNliSSEf
EVALUATION CJUTCHM
ALTWNATtVf I
H» VmiUut Acttom
ALJfKNATIVt a
ALTIKNAVWI J
famuibl* Cover *m4
Comltimmtmt ky Cilnu;li 1-411 be
cuiurulleil
• Shod let m linp*ct> lium
•It borne cmiuliNii «K| MxliiiH.tu
killing to •decent «re*»
Irnm c»f«v«|i
into
• SliuiMerni iin|wu-|> CM IK.*
if nitty ruiiUolleJ fur
cumyunant
willi tviulriullun ttl the
tunUliuiienl wM nuy be
ilillinill lo cunlnil
«Mutuletl
UiuJliU
Kc»IJu4l n»k
Uiulltll
with
ruk
with
bnJfiU
ri»k
-------
-74-
TAKUt 21
r 11.| '•
EVALUATION CJUTEAM
SUMMAftY Of UtfTAILtU ANALYSIS Of MKMKDIAL ALTKHNATIVKS VOK
LANDMLL WASTES AMU GBOUNUWATKR
NORTH HOLLYWOOD DUMT, MHMTH1S, TKNNKSSUI
ALTiMMATIVC I
H» ftutka Actbm
!*«/•*«*!• C«/
miiM* Cot** »*4
ALTCNMATIVf 4
!»«»muMt Cover «*4
IVall
Long-Term KlkclivcntM
UnJIUI cuver only
cilccllvc •otl
|KraMncia In the long Ictm
L«mUlU cover pcnMncnl MM!
cllecilv* IM the lung-lcna
• Lamllill cuvcr pecnancia MM!
dlccUvc to Ike lung Iciia
• eiiccttvc OMiUlnmcnl ul
(rounJwAlcr lMni|iuf I to the
bngtenn
dlvcUve to lite luitg-icnn
• tllvtllvc conl«lnmvnl ul
giuuiulwtlet lun»|Mil in Uic
lungtenn
Mtxluil
Mubilily o» Volume
• No reduction Achieved
Noiluect reduction through
lor Uiullill
• No direct icduclMHi Ihiough
lor UndllU
• No direct rcduclkin through
lor UndllU w«»lr>
-------
TAILU 21
Page
SUMMAHV Of UfcTAIUiD ANALYSIS Of BEMUUAL ALTUftNATIVKS fOft
LANDFILL WAST.eS AND CBOUNDWATUI
NOATH HOLLYWOOD DUMT. MCMTH1S. TONNCSSKM
EVALUATION CJUTIAM
ALTCNM4TJVC t
N» further Actiou
ALTCHNATtVK 3
CMlMMMBffcyfeta
ftwmtMt Citvtr •>i>l
W»H
Kt\lui iiim ol Tukicily.
Mobility ur Volume
• Inductl ic«luctton iii MUM ul
CUIlUIIUIUUlU llll« Ut IMllM^l
• Indued reduction In OWM of
• Indirect redudlon In matt ol
atnUiitlikMtU due lu iMiui«l
1 liulu eel icJucllun ot inutttlily of
Umlllll M«Ue cunUiiuiunU
due lo Inctcued aiver UucfcneM
MM! «uucUlnl i cductfan la
lallllHlloii
Indued icdutllun ul nuiUlily ul
Undlul w«*le cunuiiuiunls due
lo IncrcMed cover ihittiKk* *nd
MMicMicd nsdudioii Iii
Inllllrallon
IMnxl reduclMin In giuuiulw*!**
cvnUnuiuiU HMM «nd umUUly
Indued ledudkut ol inobiliiy «>l
Uiullill w«»l« cunUiiun^nu due
hi iiR-i eased cuver lhkin«.-M Mid
akMiculcd (vducitun In
Diitvi inJuiliun in ^iuun«l
iitiiUiiiiiuiil nMM and nml»tny
due ki ctNiUlnaienl and
Dimrl reduciion ul i»»kiiy til
Cklrattcd gruuikJ%v«lfi lliioii£
liulntenl in Mcni|«hik ItlllV
Ihini nrdurlliin ul
r»lf atltd gi uundwalci lliiti.i^l
lii-jlinenl In Mcni|iluk I'lll W
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-76-
TAMLU 21
SUMMARV OV UfcTAIUO ANALYSIS Of REMEDIAL ALTERNATIVES FOR
LANUMU. WASTES AND CRGUNUWATKR
NOHTIIIIUUVWOOU DUMT. MKMNUS. TENNESSEB
I'..,.. •,.
EVALUATION CHITCNM
AITCRAMT1VC I
No t'milka A(tto»
ALTtHNATWK t
Cuvtt
AITKHNATlVt: J
C»»lmutmtmt ky tlilfMriio*
Wttlt
AI-TtKNAllVt 4
timtttU Covtr »a>t
IVnll
lni|>lein«;nUbilily
Co»l
• N/A
S N/A
• Indirect t"o»l* *ntl
O)uliii£i.fiL*ic£ TTV^SSO
• Tout P.CX.IU Worth: 2.JJB.67U
Nu ioreM3C*Uc u*tf* cunoeni*
1 Intlu 4x1 Cults aiul
l.77y.7UQ
Tul*l Tf
Worth:
• Nu lufCMMlile iiu|iir ttuuvnis
lor bmliill cover cuai|MMiciil
uei iuniuntx nuy be Uillitruli
2.4tt»>4l»
1ol*l I'leiem Woilh: fc.B02.6BU
lot UlMlllU CUVM l(IIM|NMM-|ll
ieUle«l concern*
• hilt'giily ol consliuiivtl ctinUui
nieiii w«U i|ueslloiublc due MI
lni|ileiiM!nubllily tlifikulilo
• t'4|>iull'o»l»: $ 6.IUI.IV.
•OliMCtMU 2.22VM/II
• liulli tx'l Coil* aiul
4.VA.SMI
1'ieaeiil Wuiili: IJ.MI.Vi •
(°4|>IUl t'Oil MMIMllVL* III
4itllfl|»«letl
Jilluullle*
-------
-II-
TAMLH 21
SUMMAKY OF UfcTAILVD ANALYSIS Of KKMfcUl AL AtTKRNATIVfcS H>H
LANUHU. WASTES ANU CMUUNUWATW
NOftTU HOLLYWOOD UUMT. MHMMUS. TfcNNESSKU
IVALUATIOH CJUTLNM
ALTCHNATtVC I
No tttitkt* Acttom
ALTCKNATWC 2
ftrmtmklt C»»ir
ALTKHNATIVK J
trm*»U* CAIMV **J
4
»
WM
Cont|>luncc wilh AMAIU
PtilUI cuni|* Wbct«
JlUllllCtl
I'fulccliun ul
I IUIIMII I le*Uh «nJ the
fonli
I'f ukxiiun likcrv«Mxl lor
Untllill
Full cont|>4Uncv with
iluttMC AHAIUc«(K|it whcie
Full cum|)lunoe twilh
AKAIU lo» c>lf«cu.il
t'tottfUon reluct on
C4mlrub lof ui)(e>lM>
ol OMiLvrii In Umrt ha in
Undlill
• I'rulci'UtMi nl liuuun lu-jSlli auj
lite cnvliuiuiiciil viuuitxl in llie
Full complUiu-c with Uiullill
ctuMUc AHAK*c»LV|i| wlw ic
' Full tiMiipU«m;e
AKAKa lor enU*tli*l
> IVdltl 1(011 ffltCi I'liiUvlum ul IIUIIMII lit-allli jii.
Ilic cnvifuiuiMail tuiun-U in il»
ILMI^ Ivmi
N/A Nul <|'|-|K
-------
-78-
3 and 4 are in compliance with the ARARs for discharge of waste water.
Alternatives 2 through 4 will also comply with all applicable RCRA LDRs.
Variances in the State of Tennessee groundwater standards under the Underground
Injection Control (UZC) Regulations will be sought so that restrictions could
be placed on groundwater use at the site. Should the variances be denied and a
waiver not be justified, groundwater treatment as specified in Alternative 3
could be used to meet applicable groundwater standards.
Reduction of Toxieitv. Mobility o
Since none of the remedial alternatives will involve the treatment of the
landfilled wastes, there will be no direct reduction in the toxicity, mobility,
or volume of landfill contaminants. Indirectly, a reduction in the mobility of
landfill contaminants will occur for Alternatives 2 through 4 due to the cover
reducing the amount of rain water filtering through the wastes and eliminating
contaminated soils moving off-site from erosion.
Alternatives 3 and 4 will result in a significant reduction of the aquifer
contaminant mobility, toxicity, and mass due to the removal of contaminated
shallow groundwater.
Long-term effectiveness
All alternatives except for No Action will provide long-term effectiveness and
permanence. The temporary cover in place could in the future expose the public
and the environment to the contaminants on-site
Short -Term Effectiveness
The degree of short-term effectiveness achieved by the alternatives which
involve remedial action is greatest for Alternative 2. The lowest degree of
short-term effectiveness is achieved by Alternative 4.
The construction of the low permeability soil landfill cover in Alternative 2
will result in the least amount of risk to the community, workers and the
environment. The primary risks to the community and workers will be due to
airborne dust emissions whereas the main impact of the environment will be due
to potential increased sediment loadings to the adjacent surface waterbodies in
the short-term. These risks, however, are readily controlled and mitigated.
These potential impacts are common to all three of the alternatives which
involve upgrading the existing cover.
Alternative 3 will increase the potential risk to workers due to the increased
contact with contaminated media. However, this risk to the worker is readily
addressed by enforcing an appropriate health and safety program during
construction. Alternative 4 will present potential risks to the workers and
community which will be more difficult to address. The construction of the
containment wall in Alternative 4 will likely encounter landfilled wastes along
the landfill perimeter. Consequently, the implementation of this alternative
would present a greater risk to workers and the community than for the other
remedial alternatives due to the potential for serious site incidents to occur.
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-79-
The implementability of an alternative is baaed on technical feasibility,
administrative feasibility and availability of services and materials. The
construction and materials of the upgraded low permeability soil landfill cover
for Alternatives 2 through 4 utilizes standard construction techniques and can
be completed within a single construction season. Consequently, the
implementation of this component of these remedial alternatives will not be of
concern.
The primary difficulty which is anticipated for Alternative 3 is the inherent
problem in evaluating the hydraulic performance of the system due to the
hydraulic characteristic of the shallow aquifer and the proximity of the Wolf
River. By comparison, the implementation of Alternative 4 is anticipated to
encounter numerous difficulties. The constructability of the containment wall
is the major implementability concern. Due to geologic conditions at the site,
the integrity of a constructed containment wall will be questionable. In
addition, the existing topography is not well-suited to the construction of a
containment wall. Other implementability concerns include the anticipated
interference of adjacent structures, the stability of landfill slopes, and the
availability of suitable clay backfill.
Cost
"he present worth cost associated with Alternative 1 is $2,338,670. The
stimated present worth cost of Alternative 2 is $4,942,950. Alternative 3 La
$6,778,620, and Alternative 4 is $13,251,555. The present worth value
represents the total cost of the'remediation expressed in today's dollars.
Alternatives 3 and 4 are not cost effective for present site conditions since
contaminant concentrations in the groundwater are not above acceptable risk
levels, and therefore, do not provide an added degree of protection.
State Acceptance
The State of Tennessee has assisted SPA in the review of reports and site
evaluations. The State has reviewed and conditionally concur with the selected
remedy for the landfill wastes and groundwater as long as the groundwater
variance is received from the Tennessee Water Quality Board (See Appendix B).
Community Acceptance
Community response to the alternatives is presented in the responsiveness
summary which addresses comments received during the public meeting and public
comment period. Although the public had general questions concerning the
remedy, no comments were received that indicated the need for a major change in
the remedy selected.
Surface Water Impoun^ments
he following is the evaluation of the six (6) alternatives for the surface
water impoundments using the nine criteria. A comparison of the alternatives
omittine state and Community Acceptance is Presented in Table 22.
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-80-
Overall Protection of Human Health and the Environment
All the alternatives presented in this document except for No Action would be
protective of human health; however, Alternative 2 does not provide a degree of
protection to the environment. The No Action alternative is not protective
because it allows bioaccumulation of contaminants by wildlife in the
impoundment and the passible human ingestion of contaminated fish. Alternative
2 does not prevent bioaccumulation. in the wildlife population. Alternative 3
through 6 prevent the biota in the impoundment from coming in contact with or
ingesting contaminated sediments.
Compliance with Apclica^le or Relevant and Appropriate requirements
All alternatives except for No Action and Alternative 5 would comply with
ARARs. The No Action alternative would allow the levels of contaminants in the
edible portions of fish to remain above health risk levels. Alternative S
would not comply with the U.S. Army Corps of Engineers regulatory program
requirements. The other alternatives would return fish contamination levels to
below acceptable standard and would meet applicable RCRA LORs, surface water
quality standards, closure regulations, and effluent discharge requirements.
Reduction or Toxieitv. Mobility or Volume
Since none of the remedial alternatives will involve the treatment of the
contaminated sediments, there will be no reduction in the toxicity, or volume
of contaminants associated with bottom sediments.
Due to the removal and securement. of the bottom sediments, Alternative 3, 5,
and 6 will result in a significant reduction in environmental mobility and mass
of contaminants in the aquatic environment, but not for the whole site since
the sediments will be placed in the landfill. Alternatives 4, 5, and 6 will
result in a significant reduction in environmental mobility due to the
isolation of contaminated sediments below a layer of clean fill.
Lona-Term Effectiveness
All of the alternatives except no Action would provide long-term effectiveness;
however, there is no permanence associated with Alternative 2. Once the
contaminated sediments are no longer accessible to the impoundments' biota for
accumulation, fish tissue concentrations will start decreasing and return to
acceptable levels.
Short-Tern effectiveness
All of the remedies except No Action will remove contaminated fish from the
impoundments during the remedial action effectively reducing short-term
exposure to contaminated fish. Prior to the action, the community will be
protected from short-term risk from fish consumption through institutional
controls warning persons of fishing hazards. Short-term human exposure through
contact with contaminated sediments during the remediation will be controlled
through health and safety procedures.
-------
22
MJMMAftY Of UtTAIlfcO AN AUMS O* BU4UM AL ALUftMAll VU HM
MMPACE WATtt IMTOUNUMtMIS
CttUIMTION CUnUA
C «•!«>••••» •• tttt
S«IM •/UH/i"
Ml
•IMT
jtrrNMum •
MM
c«
N/A
nrmnii«Hy fcinn ilrtrnnM
fl4 CflUl^lA k4lil
' SlMMl MtB ••*IHMtOM«Ul
bnfMtl tnx»
dUUIUUt
> Skutt-Utm
1*1
|>Mtwl.
lu Wull HlM(,
ul iunUiulMMil lUfc. IUM
ul H4«I(
-------
-82-
TABU 22
MJMMABV or DCTAIUD ANALVMS o» UMUM At ALTUMAHVU KM
MJWAlX MATU IMfOUMOkUMT*
CMIIMTJON CJUTEftM
4lIEBM4im I
Im fU«» C
factor •/ U**/UJ
• lUildutl rt*k t**ot-Ul*l
P^l finnirtna'Tl Itek
• Not WkwHv* of
lUk Jui lu
Mttkkll«4MI
• IU*UuUilak
• HaUiMl rt*k M«KUI*| • UlMUv* U Ik* kwg uim
Itok MMKUI«|
lu • «lgi>Uli«Hl
ra* In Ik* k>*g Mini
wkh
WoU W«M
• EJkKtiv* to Ik* k»f Km • kUy ka •IkKllvn to ik«
fcjAM ftMHk •Uttdl
kulaui
•thl«v«l U Ik
IcfMt
-------
-8J-
ALJUHATtVt I
TAIU 22
ftUMMABY Of UfcTAJltU ANALYSIS Of BUtUN At AUUMAUVfcS KM
tUBSACS WA1U IMTOUNUMKMn
4in«N4Tm I
!*«<«« *U*
LU»»»HJI»
MuttlU-y IK Vuluin*
• Natltalmluillu* • NudlnU wductlua
I lluuugk
Iktuu^k
ua al
MuJ«|CB4i«lkMI Mill
itu* to Hnhiglnl upuk*
by luk
mutrtlhy *«J vahum ul
amuailaMU to W|IMI|C
• Sl(*lltU>» l*t«) Mklcvv
due tu nuiuvcl ul
nn-iui
t <4
JIM to UuUllun ul
l M
Ml
diM tu |MI!A| ItMi ttl
tuatomliiMml *cJbi
fctluw
-------
-H4-
TAMU 22
MJMMAAV Uff UtT All UJ AN At VMS UT UMUMAl AlTUNATlVfcS MM
MJU> Atk WATU IMTOUNIJMUm
•••IP «»!»
(VALUATION COfllJUA
FtrietUe Utntttiug
•in**
ftfl
N/A
• No
• 6*v«*l
•owtUMM»t&fc
iM la ra^uliwl
AUM* la >4««yH» MW*T
talMiu|4kM ky Wall
to twluow ol
limn*! by »U» ol
-------
TABU 22
MJMMAAV Of IMTAIUD ANAtWUt Off UMUNAl ALTiAMATIVU HM
MJBfACS WATU IMTOUNOMSMn
M*4«JtM
•I H+
I
*t
DtUt»*U*
AllTUMTIVC 4
l»HfttCf*til*mmt
i u^titMf nu
Ainutunvt •
•VMMvVMHf
C«M«*MWM
> C«f>ltol
CUM » N/A
, U4MCu*U 2II/UU
• Tuult
«0*>JU
I N/A
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-------
-86-
TAMU 22
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MJIUACk WA1U IMrUUNUk
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AHAIU
• ClNKflllM Milk dlMk*lg«
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III N/A -
-------
-87-
Th* primary difference* between the alternatives are the extent of the
potential environmental impact related to implementation. Alternative 4 does
not require the handling of contaminated sediments whereas the other
alternatives involve dredge/excavation activities which may potentially impact
workers and the community. Consequently, this alternative is considered to
have a greater degree of short-term effectiveness. The potential, for
short-term impact associated with-Alternative 3 is deemed to be marginally
greater than the potential for impacts associated with the implementation of
Alternative 6. This difference is primarily due to the nature of the work and
recognizes that dredging is less readily controlled than mechanical excavation
and that there are hazards to the community and the environment which are
inherent to the operation of liquid impoundments. Alternative 5 is deemed to
be the least effective of the alternatives in the short-term due to the
potential impacts to the Wolf River and adjoining floodplain. The potential
impacts from the implementation of this alternative are not limited to the
immediate area of the impoundments.
Imolementabilitv
The implementability of an alternative is based on technical feasibility,
administrative feasibility and the availability of services and materials.
There are no major concerns regarding the implementability of Alternatives 2
and 4. Alternatives 3 and 6, however, are considered difficult to implement
due to the degree of dewatering of the abandoned dredge pond which is
required. In addition, the implementation of Alternative 3 will be limited by
the size of the dredge pond, the ability to accommodate significant changes in
the volume of material to be handled, and the required length of the
construction period. Alternative 3 also requires the wet handling of
contaminated sediments which may be difficult. The technical feasibility of
settling out dredged sediments without the use of flocculants is uncertain.
This factor will potentially have a significant impact on the implementability
of this alternative.
Consequently, Alternative 3 is considered to be the most difficult to implement
and the most sensitive to potential implementation problems.
The implementability of Alternative 5 is anticipated to be limited by
administrative and environmental concerns. Due to the potential environmental
impact of this alternative, it is anticipated that the implementation of this
alternative will be delayed significantly.
Cost
The present worth cost of Alternative 1 is $406,500. Alternative 2 has an
estimated present worth cost of $340,910 including Operations and Maintenance
(O6M) costs. The estimated present worth of Alternative 3 is $2,341,885,
Alternative 4 is $3,098,940, Alternative 5 is $2,263,130 and Alternative 6 ia
$2,988,860.
The indirect capital coats for several of these alternatives, however, are
highly sensitive to changes in the volume of contaminated sediments to be
-------
-88-
handled. Alt amative 3 is the moat sensitive to volume changes whereas
Alternative 4 is the least sensitive. Due to the required partial excavation
of contaminated sediments to be handled, the indirect capital costs for
Alternatives 5 and 6 are^ moderately sensitive. Consequently, the indirect
capital costs associated* with Alternatives 3, 5, and 6 could vary significantly
once the lateral and vertical extent of sediments to be removed is refined by
the results from the precbnatruction sediment sampling program.
State Acceptance
The State of Tennessee has assisted EPA in the review of reports and site
evaluations. The State has reviewed and concurs with the selected remedy for
the impoundments (See Appendix B).
Community Acceptance
Community response to the alternatives is presented in the responsiveness
summary which addresses comments received during the public meeting and public
comment period. Although the public had general questions concerning the
remedy, no comments were received that indicated the need for a major change in.
the remedy selected.
SELECTED PRMBDIBS
Landfill WastesandShallow Groundwater
<*
The selected remedy for the landfill wastes and shallow groundwater is
Alternative 2 involving the containment of the wastes using a low permeability
sanitary landfill cover and securing the site by completing the perimeter
fence.
The selected remedy will include the following activities:
i) discing the existing 70-acre landfill surface;
ii) proof rolling the entire 70-acre landfill surface;
iii) excavating the buried drums north of the West Sector, characterizing
drum contents and consolidating all solid contents on the surface of
the Meet Sector beneath the final cover. All liquid wastes found will
be disposed of off-Site in accordance with Federal and State standards.
Should contaminant levels in the solid contents of the drums warrant
off-site disposal, the solid contents would also be disposed of
off-site in accordance with applicable regulations.
iv) excavating contaminated surface soil detected in the more easily eroded
areas near the Wolf River and the abandoned dredge a pond and
consolidating all excavated material on the Site beneath the final
cover.
v) supply, place and compact approximately 67,000 cubic yards of common
fill over the West Sector to increase the final cover thickness by an
additional twelve inches to a total thickness of 24 inches;
-------
-89-
vi) supply/ place and compact approximately 82/000 cubic yards of common
fill over the East Sector to increase the final cover thickness by an
additional sixteen inches to a total thickness of 24 inches;
vii) broadcast fertilizing and seeding of the landfill surface;
ix) placing pegged sod along drainage swales and on steep slopes of the
landfill; and
x) installing approximately 3,900 feet and 3,300 feet of standard
chain-link fencing to complete the perimeter fencing of the West and
Bast Sectors, respectively.
The extent of remedial activities are shown on Figure 7. Estimated costs are
shown in Table 23.
Maintenance activities will include:
i) periodic inspection of the landfill surface including slopes;
ii) periodic inspection of the monitoring well network and Site fence;
tii) periodic mowing of the vegetation over the 70-acre landfill;
,v) the application of fertilizer at a specified frequency;
i
v) re-establishment of vegetation over distressed areas;
vi) periodic repair of areas eroded by surface water runoff or by flooding
of the Wolf River;
vii) maintenance of the Site fence and signs; and
viii) control of burrowing animals.
Monitoring activities will include:
i) periodic collection of water level measurements from the existing
monitoring well network and the continuous water level monitoring of
the Wolf River;
ii) periodic sampling and analysis of groundwater from the monitoring well
network;
iii) periodic sampling and analysis of surface water from the Wolf River;
and
iv) periodic sampling and analysis of fish from the Wolf River.
vhe ACLs (see Table 20, Summary of Site Risks) set for the shallow groundwater
mass flux into the river will be monitored at the edge of the waste management
area. Jhould the mass flux of shallow groundwater from the site increase and
-------
* f moo*to 0*1 etc
fOHO
NCI It: IAC VVTJ1 LdC*no»lS Af'HROXIMAlt
figure 7
REMEDIAL ALTERNATIVE 2 - PERMEABLE COVER
,, LANDFILL WASTES AND GROUNDWATER
North Hollywood Dump
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-91-
TABLE 23
LANDFILL WASTES AND GROUNDWATER
COST ESTIMATE SUMMARY - PERMEABLE COVER
NORTH HOLLYWOOD DUMP, MEMPHIS TENNESSEE
Description
A. CAPITAL COSTS
Project Startup & Closeout
Excavation of Drums and Contaminated Soil
Permeable Landfill Cover
Erosion Control (10 Year Flood)
Fencing
Health and Safety
Miscellaneous
SUBTOTAL - CAPITAL COSTS
B. OPERATION it MAINTENANCE COSTS
Croundwater Monitoring
Wolf River Monitoring
Biota Monitoring
Landfill Inspection & Maintenance
Monitoring Well Inspection & Maintenance
SUBTOTAL - O&M COSTS
SUBTOTAL - CAPITAL AND O&M COSTS
C. INDIRECT COSTS
Administration & Legal
Engineering
Construction Supervision
SUBTOTAL - INDIRECT COSTS
D. CONTINGENCY
TOTAL ESTIMATED COST
Present
Worth
S 66.300
$ 75.000
819330
478.300
86.400
52.500
6,000
$444.870
114.450
141,350
846,760
30.740
5394.960
153.460
237,690
Prestnt
Worth
Totals
51.534,530
SU78.670
53,163,250
5791,110
5988,590
54,942,950
Note:
1) Refer to Appenuix C for detaii^jd cost
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-92-
start exceeding the ACLs on a continual basis (see page 64 for the shallow
groundwater monitoring criteria), the contingency alternative. 3, (groundwater
pump and discharge to the city sewer) will be implemented to control
contaminated groundwater flow into the river to below the 10"6 risk level.
The point of compliance for the groundwater will be the edge of the waste
management area. It necessary, pretreatment will be conducted prior to
discharging the contaminated groundwater into the city sewer.
In addition to the above activities, various support activities will be
conducted including:
i) the implementation of a worker health and safety program;
ii) environmental monitoring for dust and particulate indicator pesticide
emissions; and
iii) the implementation of a soil erosion control program during
construction and in the interim period following construction during
establishment of vegetation over the upgraded landfill cover.
Surface Water Impoundments
The selected remedy for the surface water impoundments is Alternative 4
involving the containment of contaminated sediments in the impoundments using
hydraulic fill. Prior to the remedial action during the design phase,
additional sampling of the sediments and fish in the impoundments will be
performed due to the changes that can occur to the sediment in a surface water
body over time.
This sampling will be done concurrently with the design so as not to delay the
remediation process. The sampling will be done to verify the condition of the
impoundments, to better define the contaminated areas and to determine
acceptable sediment concentrations based on a 10~6 risk for fish
consumption. Acceptable sediment contaminant levels will be calculated using
levels presently found in the impoundment sediments and fish, and the
acceptable fish tissue concentration levels in Table 24. This sampling will
not affect the selected remedy unless fish and surface sediment contamination
concentrations have decreased to within acceptable risk levels.
The selected remedy will include the following activities:
i) the implementation of a detained bottom profile survey using
sonar techniques to determine pre-fill conditions;
ii) the construction of rough graded access roads to the
impoundments;
iii) the installation of a pipeline and discharge headers from the
inactive dredge pond located north of the Wolf River to the
abandoned dredge pond and Oxbow Lake;
iv) the installation of geofabric onto slopes and bottom surfaces of
the impoundment which may be susceptible to scour during the
hydraulic fill operation;
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-93-
v) the placement of dredged fill by hydraulic methods in the dredge
pond and the Oxbow Lake;
vi the placement of dredged and stockpiled backfill onto the upper
slopes which cannot be covered effectively by hydraulic methods;
vii) the excavation of sediments from the Beaver Pond and placement of
these sediments in the Oxbow Lake prior to hydraulic fill;
viii) the implementation of a post-construction bottom profile survey
in the abandoned dredge pond to confirm the fill thickness; and
ix) the harvesting and restocking of fish from the impoundments.
Geofabric will be placed over the contaminated surface of the Oxbow Lake and
along contaminated shallow slopes of the abandoned dredge pond due to the
potential scour and suspension of contaminated sediments while placing fill
hydraulically. The geofabric sheets will be prestitched together prior to
placement and will be sunk into position using sandbags. Prior to filling, the
geofabric will be securely anchored by staking.
The placement of hydraulic fill will be performed in a controlled manner.
Dredged fill will be discharged initially over the deepest areas of the
impoundments to be covered and proceed towards the more shallow areas. Prior
»o covering the Oxbow Lake contamination the contaminated sediments from the
Beaver pond will be excavated and placed on the slopes' of the Oxbow. The
abandoned dredge pond'will receive a cover thickness of three feet. Due to the
difficulty of placing fill by hydraulic method* directly against shallow slopes
in the dredge pond, these slopes will be covered by mechanical means. Dredged
material will be discharged onto a spoil area adjacent to the Wolf River and
drained for use as backfill material. This backfill material will be
mechanically placed over the upper slopes of the dredge pond where hydraulic
filling is ineffective. It is anticipated that mechanical dewatering will be
required to lower the water level in the dredge pond during mechanical
placement of the dredged fill.
Open completion of the fill operations, the fish remaining in the abandoned
dredge pond will be harvested. A post-construction bottom profile survey will
be conducted in the completed dredge pond to verify the uniformity of the fill
operation. Disturbed areas around the impoundments will be restored by
reseeding as necessary and the impoundments will be restocked with fish.
Figures a through 10 illustrates the extent of the remedial construction
activities required for this alternative. Estimated costs are shown in
Table 25.
A long-term monitoring program for the surface water impoundments would be
implemented after the remediation is complete to verify that sediment levels do
not increase above the 10 health based levels set during the Remedial
eeign.
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-95-
FROM INACTIVE
DREDGE POND
f ' J CXCAVA1C BOHOM StOutNf
figure 8
REMEDIAL ALTERNATIVE 4 - IN-PLACE
CONTAINMENT WITH HYDRAULIC FILL
SURFACE WATER IMPOUNDMENTS
North Hollywood Dump
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-94-
TABLB 24
ALLOWABLE CONTAMINANT LEVELS IN FISH TISSUE
(USING A 10~6 RISK LEVEL FOR A 70 KG ADULT CONSUMING
6.5 GRAMS OP FISH PER DAY)
CONTAMINANT
Chlorodane
Chlorodene
Heptachlor
Heptachlor Epoxide
Aldrin
Dieldrin
Total BHC
.,4' DDT
Endrin
Arsenic
Barium
Nickel
Lead
Copper
Zinc
Vanadium
CONTAMINANT LEVEL (MC/KG)
8.3 X 10"3
8.3 X 10"3
2.4 X 10~3
2.4 x 10"3
6.54 x 10"4
6.7 x 10'4
2.0 x 10"2
3.2 x 10~2
*
3.2
6.2 x 10
538
215
1.5
398
2154
75
-3
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-96-
SEED DISTURBED AHEAS
NORMAL WATER LLVtL
BEAVER PONO SEDIMENTS
DISPOSED OF WITHIN
OXBOW LAKE
ANCHOR
STAKES
HYDRAUUCAU.Y fill
ENTIRE OXBOW LAKE
VNltl DREDGED MAItWAL
GEOFABRIC PLACED ON BASE
AND SLOPES OK OXBOW LAKE
PRIOR TO HYDRAULIC FILL
OPERATIONS
figure 9
HYDRAULICALLY FILLED OXBOJfc LAKL
North Hollvwooff Dumt>
-------
TABLE 25
SURFACE WATER IMPOUNDMENTS
COST ESTIMATE SUMMARY - IN PLACE CONTAINMENT OF
SEDIMENTS WITH HYDRAULIC FILL
NORTH HOLLYWOOD DUMP, MEMPHIS TENNESSEE
Page I of 2
A. CAPITAL COSTS
Precoristructfon Sampling and Surveys
Project Startup & doseout
Slurry Pipe and Discharge Headers
Installation of Geofabric
Hydraulically Cover Dredge Pond
Hydraulically Fill Oxbow
Excavate Beaver Pond
Mechanical Placement of Backfill
Dewatertng of Dredge Pond
Confirmatory Survey
Harvesting of Fish
Health and Safety
Environmental Monitoring
SUBTOTAL - CAPITAL COSTS
Present
Worth
$90000
105,300
45X00
151,400
904,800
234,000
6,500
223,000
58,100
15X00
27,000
.16,520
2.070
Present
Worth
Totals
$1,383,690
B. OPERATION* MAINTENANCE COSTS
Monitoring of Impoundment Waters
Biota Monitoring
SUBTOTAL - O&M COSTS
$17,650
13,990
SUBTOTAL - CAPITAL AND O&M COSTS
51.9l5.33ti
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-100-
STATUTORY DBTSRHINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund sites is
to undertake remedial actions that achieve adequate protection of human health
and the environment. In addition, section 121 of CERCLA establishes several
other statutory requirements and preferences. These specify that when
complete, the selected remedial action or this site must comply with applicable
or relevant and appropriate environmental standards established under Federal
and State environmental laws unless a statutory waiver is justified. The
selected remedy also must be cost effective and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly reduce the
volume, toxicity, or mobility of hazardous wastes as their principal element.
The following sections discuss how the selected remedy meets these statutory
requ irement s.
Protection of Human Health and the environment
Based on the site risk assessment, long term exposure to contaminants through
the consumption of contaminated fish is the identified risk associated with the
site. And although no excessive risk was identified for exposure to the
landfill, this risk level was based on present conditions which include a
temporary cover over the site.
The placement of the- low permeability sanitary landfill cover over the site and
hydraulic fill over the contaminated sediments protects human health and the
environment by removing and containing the contaminants away from the exposure
pathway. The landfill contaminants and contaminated sediments will be
contained so that plant and animal life will no longer come in contact with and
bioaccumulate the contamination. The contaminated fish will then be removed
and the surface water impoundments restocked. The cancer risk associated with
the site will be reduced to around 1 x 10"6 and the Hazard Indices (HI) ratio
will be less than 1.
There will be no unacceptable short-term threats or cross media impacts
associated with the selected remedies that cannot be readily controlled since
only minimal contact with or movement of the wastes will occur.
Compliance with ARARs
The selected remedies of a low permeability soil cover for the landfill
contaminants, groundwater monitoring, hydraulic fill containment of
contaminated sediments in the impoundments, and removal of the contaminated
fish will comply with all applicable or relevant and appropriate requirements
(ARARs). The ARARs are presented below.
Action Specific ARARs:
• Tennessee Solid Waste Regulations, Rule 1200-1-7 - 001-007
• Tennessee Water Quality Control Act, TN Code 69-3-104
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-JO-
TABLE 25
Page 2 of 2
SUWACE WATER IMPOUNDMENTS ^^^
COST ESTIMATE SUMMARY • IN PLACE CONTAINMENT OF
SEDIMENTS WITH HYDRAULIC FILL
NORTH HOLLYWOOD DUMP, MEMPHIS TENNESSEE
C. INDIRECT COSTS
Administration & Legal
Engineering
Construction Supervision
SUBTOTAL • INDIRECT COSTS
D. CONTINGENCY
TOTAL ESTIMATED COST
Present
Worth
$ 100310
188,360
282,550
Present
Worth
Totals
$ 571,420
S 612,190
S3.098.940
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-101-
• Clean Water Act (40 CFR 122), including Section 404
• National Pretreatment Standards (40 CFR 403)
• Chapter 33 of th« Memphis Coda ralatad to "Sawar and Sewage Disposal"
(Memphis Sawar Ordinance)
• USPDA Zdible portion of ?iah levels
* and National Primary and Secondary Ambient Air Quality (40 CFR 50)
Chemical Specific ARARs:
• Tennessee Water Quality Criteria (1200-4)
Location Specific ARARs:
* none
RCRA Land Disposal Restrictions (LDRs) are not applicable to this remedial
action since the consolidation of waste within the area of containment (which
is being performed for the flood plain areas of the landfill and part of the
contaminated sediments) does not constitute "placement.* Therefore LDRs do not
apply. The Federal Safe Drinking Water Act (SDWA) does not apply to the
shallow groundwater beneath the site since the contaminated groundwater ia only
beneath the site and flows directly into the Wolf River. Institutional
controls by Shelby County controlling the placement of wells into the shallow
aquifer inside of the Memphis City limits and land restrictions also preclude
the contaminated groundwater from being used a drinking water source.
Cost effectiveness
The selected remedies are cost-effective because they have been determined to
provide overall effectiveness proportional to their costs. Alternative 2 for
the landfill wastes and groundwater is the least costly of Alternatives 2, 3
and 4 which meet all ARARs and are equally protective of human health and the
environment. Alternative 4 for the surface water impoundments is comparable in
cost to Alternatives 3 and 6 which also meet all evaluation criteria, but
Alternative 4 hae a lesser degree of short-term impacts and cost variability.
Utilization of Permanent Solutions and Alternative Treatment Technologies or
e Recovery Technologies to the Mftyvm"nn Bxtent
U.S. EPA and the State of Tennessee believe the selected remedy represents the
maximum extent to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner for the final remedy at the North Hollywood
site. Of the alternatives that are protective of human health and the
environment and comply with ARARs, O.S. BPA and the State have determined that
the selected remedy provides the best balance of trade-offs in terms of
long-term effectiveness and permanence, reduction in toxicity, mobility or
volume achieved through treatment, short-term effectiveness, implement ability,
-------
• 102-
at, also considering the statutory preference for treatment aa a principal
element and considering State and community acceptance.
The selected remedies for the containment of the landfill waatea and the
surface water impoundments can be implemented and completed more quickly, with
less difficulty, and at less cost than treatment technologies due to the vast
amount of material and the low-levels of contamination present at the site.
Preference for Treatment as a Principal Element
In selecting the remedies for the North Hollywood Dump, EPA considered the use
of treatment technologies to the maximum extent possible. As stated
previously, however, due to high costs and implementation problems for
treatment use at a large municipal landfill and since no significant changes in
risk levels would occur with the containment of the waste, treatment waa not
consider an effective option for North Hollywood Dump.
DOCUMENTATION OP SIGNIFICANT CHANCES
The preferred alternative (Alternative 4) for the surface water impoundments
originally did not intend to remove and restock the contaminated fiah from the
surface water impoundments in addition to placing hydraulic fill over the
contaminated sediments. The selected remedy for the surface water impoundments
•ill include the removal of contaminated fish from the surface water
Impoundments as well as the hydraulic containment of the contaminated
sediments.
Originally, institutional fishing restrictions were going to be kept in place
to warn residents from eating contaminated fish from the impoundments.
However, public comments (see responsiveness summary) indicated the resident
will likely continue to fish in the impoundments regardless of posted
restricts. Zn the interest of public health and to quicken the clean-up's
effect on the environment, fish from the impoundments will be removed during
the remedial action and the impoundments will be restocked after remediation.
The impoundments will be restocked due to the potential for environmental
effects on the area's wildlife and their food supply should the fish not be
replaced. It is not the intent of EPA to approve of fishing in the
impoundments until it is determined that it is safe again to fiah.
-------
APPENDIX A
NORTH HOLLYWOOD DUMP SITE
RESPONSIVENESS SUMMARY
-------
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public comment period from
June 28 through July 27, 1990 for interested pa les to comment on the Remedial
Investigation/Feasibility Study (RI/FS) results and the Proposed Plan for the
North Hollyvood 'Dump Site in Memphis, Tennessee.
The Proposed Plan, included in Attachment A of this document, provides a summary
of the site's background information leading up to the public comment period.
Specifically, the Proposed Plan includes the following sections: Introduction.
Site Background, Scope and Role of the Response Action, Summary of Site Risks.
Summary of Alternatives, Evaluation and Analysis of Alternatives, The Community's
Role in the Selection Process, List of Contacts, Glossary of Evaluation Criteria.
and Glossary of Terms. \
EPA held a public meeting at 7:30 pm on June 28, 1990 at the Board of Education
facility in Memphis, Tennessee to outline the RI/FS and describe EPA's proposed
remedial alternatives for contaminants found in the landfill, groundwater, lakes.
a . *
and sediments at the North Hollyvood Dump Site. All-, comments received by EPA
during the public comment period will be considered in the final selection of a
remedial alternative for the areas of contamination at the North Hollyvood Dump
Site.
The Responsiveness Summary, required by the Superfund Law, provides a summary of
citizens' comments and concerns identified and received during the public comment
period, and EPA's responses to those comments and concerns.
This Responsiveness Summary is organized into the following sections and
attachments:
I. RESPONSIVENESS SUMMARY OVERVIEW. This section outlines the purposes
of the public comment period and the Responsiveness Summary. It
also references the appended background information leading up to
the public comment period.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS. This section
provides a brief history of community concerns and interest
-------
identified as pare of Che Community Relations Plan and during che
o "/FS-
0.III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
-^ COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS. This section
V- summarizes che oral comments received by EPA* ac che June 28, 1990
public meeting, and provides EPA's responses to these comments.
IV. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSES TO THESE COMMENTS. This seccion concains che one leccer
received by EPA containing written comments, as well as EPA's
wriccen response to chac leccer.
ATTACHMENT A: Actachoenc A concains che Proposed Plan which was
distributed co che public during che public meeting held on June 28.
1990 and mailed Co che information repository and chose included on
che mailing lisc.
ATTACHMENT B: AtcachmenC B includes Che sign in sheets from che
public meeting held on June 28, 1990 ac che Board of Education
facilicy, 2597 Avery Avenue, Memphis, Tennessee.
\
ATTACHMENT C: ACCachaenc C includes names, addresses and phone
numbers of che information repositories designated for the North
Hollywood Dump Sice.
ATTACHMENT D: Accachmenc D includes the official transcript of the
Public Hearing on che Proposed Plan for. che Cleanup of che North
Hollywood Dump National Priorities Lisc Sice locaced in Memphis,
Tennessee.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
A. Background on Community Involvemene
Frequenc princ, radio and celevision media coverage on che sice began in 1980 and
continued Chrough 1984. Media coverage from 1984 co 1990 was infrequenc and
sporadic. The nose accive period of community involvement was from 1980 to 1981.
During this time, cicizens of Norch Hollywood became concerned about the toxic
chemicals buried ac Che sice.
Environmental groups formed prior Co and during che early 1980's, such as che
Norch Hollywood Healch and Safecy Committee and che Cypress Health and Safety
Committee (CHSC), expressed concerns about che sice. Community groups and
-------
organizations became involved wich the sice. These groups included che League
of Women's Voters (LOW), che Tennessee Association of Community Organization
Reform Now (ACORN), the Urban League (UL), Tennesseeans Against Chemical Hazards,
and che Tennessee Self Help Missions. EPA formed the Metro Area Environmental
Task Force (MATF), consisting of representatives from local citizens groups and
Federal, county and city government personnel to address local concerns regarding
the site and obtain public comments regarding plans for site work.
In December 1980, state and local officials announced the formation of the
Technical Action Croup (TAG), consisting of representatives from the EPA. che
state and others including the Velsicol Chemical Corporation, « potentially
responsible party (PRP). The TAG was organized to maximize cleanup efforts
conducted by Velsicol. In February 1981, the TAG conducted a cleanup of hot
spots at the sice.
After che discovery of contaminated fish in the Wolf River, county commissioners
requested chat che Memphis and Shelby County Health Department (MSCHD) conduct
•aedical examination of persons who regularly ate chemically-contaminated fish.
"The MSCHD ran tests on fish from cvo wholesale dealers and found chat pesticide
levels in the fish were well below Food and Drug Administration (FDA) levels.
Warnings against using fish as a food source were posted along the Wolf River in
March 1981.
According to information obtained from community interviews conducted in March
1990, community members were unaware of the sice status and activities conducted
during the past two to three years. Residents who were familiar with current
conditions at the site stated that fishing near the site was still a problem.
Most residents interviewed stated that the governmental agencies handling the
site remedial activities had done an acceptable Job.
B. Background on Community Concerns
From information obtained during the community interviews conducted in March
1990, the site, which was considered by the community to be a high priority
aring the early 1980's, no longer appeared to be as high of a concern to che
3
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majority of Hollywood residents. The people interviewed in the Hollywood
community were generally unaware of the site conditions and activities conducted
to date, and therefore stated no concerns. Only a few residents living near the
site and a number of citizens living outside the Hollywood community were
familiar with the site and expressed concerns. Their concerns are summarized as
follows:
I. Hollywood residents stated concern regarding their general health
and the environment. Residents had heard rumors regarding illnesses
developed from the toxic chemicals buried at the site. The
community would like to see the site cleaned up and monitored on a
regular basis to protect their health and safety.
2. Some residents stated a mistrust for EPA and local government
officials.
3. Hollywood residents expressed concern that those persons fishing at
the site may be selling potentially site-contaminated fish to the
public.
4. Hollywood residents requested more information about the site. They
claimed chat no information had been received since the health
surveys were conducted approximately two to three years ago.
• *
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC MEETING
CONDUCTED ON JUNE 28. 1990 AND EPA'S RESPONSES TO THESE COMMENTS
COMMENT: A local resident questioned why a landfill cover of only 24 inches was
considered and what the cover was to consist of.
RESPONSE: EPA classified the North Hollywood Dump as a municipal waste landfill
rather than a hazardous waste landfill. The borings obtained at the site found
tree stumps, burned debris and ash. Under EPA's classification, the most
appropriate regulation for this site was to close the landfill as a sanitary
landfill; requiring a 24 inch cover of low permeability soil.
COMMENT: A local resident questioned if groundwater from the dump was going only
to the Wolf River; not beyond.
-------
RESPONSE: EPA carefully Investigated the flow of groundwater through the site
to the Volf River. EPA was concerned about the possibility of:
1. Contaminated groundwater in the surficial aquifer under the site
migrating into the lower, confined, drinking water aquifer; and
2. Groundwater in the surficial aquifer flowing under the Volf River
and contaminating areas to the north of the Volf River.
Detailed studies indicated that a continuous clay layer, 100 to 200 feet in
thickness, separated the underlying drinking water aquifer (the Memphis Sands)
from contaminants in the surficial aquifer (the Fluvial Sands). Hydraulic
gradients clearly showed that the water was flowing toward and converging at the
Volf River from both the north and south sides of the Volf River. Pressure
gradients also indicated that groundwater within the surficial aquifer was rising*
into the Volf River, rather than flowing under it.
COMMENT: A local resident questioned why contamination warning signs were posted
at the ponds located north of Interstate 2
-------
compounds exist only in concentrations below levels which would significantly
affect the fish in the Wolf River.
COMMENT: A citizen questioned why EPA was going to conduct any site remedial
work if there was a relatively low risk associated with the contaminants
originating from the sice.
RESPONSE: Despite the low risk associated with the site, the site does not meet
Federal and state regulatory standards. EPA will continue to monitor the
groundwater leaving the North Hollywood Dump and flowing toward the Wolf River.
COMMENT: A local resident asked EPA to explain the preferred alternative for the
remediation of Oxbow Lake and the dredge lake.
RESPONSE: The preferred alternative for remediation of Oxbow Lake and the dredge
lake consisted of a three foot clay cover placed on the bottoms of the lakes to
keep biota (i.e.. fish) from coming in contact with plant life growing in
contaminated areas.
•»
COMMENT: A local resident questioned if the sediment covers would allow people
to consume fish obtained from Oxbow Lake and the dredge lake and not become
contaminated.
RESPONSE: Fishing restrictions would be placed on the aforementioned lakes until
future periodic fish studies indicated that the fish were acceptable for human
consumption. Based on public concerns about fishing and the effect of
contaminated fish on the animal food chain, the fish in the lakes will be
removed, and Che lakes restocked.
COMMENT: A local resident questioned when it would be safe to fish in Oxbow Lake
and the dredge lake.
RESPONSE: Once EPA sampling indicated that the fish were no longer contaminated,
fishing could resume immediately. The anticipated time frame was approximately
five years, the life span of the contaminated fish, once the covers were in-
-------
place. However, Oxbow Lake and the dredge pond are located on private property
and EPA will not deternine if fishing is allowed on the property, only if the
fish are safe for consumption.
COMMENT: A local resident questioned the mobilization of chlordane in the
groundwater.
RESPONSE: Sampling results indicated that concentrations of chlordane found in
Che groundwater were below EPA established standards and would not significantly
affect Che Volf River. To ensure thac chlordane remained relatively immobile.
EPA would install groundwater monitoring wells along the Volf River to routinely
measure the chlordane concentrations in the groundwater. Should levels exceed
the established levels in the future, measures would be taken to remediate the
problem.
COMMENT: A local resident questioned why the fence did not totally encompass the
site.
RESPONSE: The fence would be upgraded to totally encompass the site and
maintained as part of the remedy.
COMMENT: A concerned resident heard that the Volf River was not contaminated by
the North Hollywood Dump and wanted to know how fish became contaminated with
chlordane.
RESPONSE: The North Hollywood Dump Site is not the only source of contamination
found along the Volf River. EPA has not been able to pinpoint any significant
point sources to date, but chlordane is used in most homes for termite control.
The impact of the site on the Volf River has decreased significantly over the
years that EPA has studied this site. Studies indicate that the site's current
impact on the Volf River is below the EPA established water quality criteria.
COMMENT: A local resident questioned what level of protection would be required
for workers excavating the material on the north side of the site, adjacent to
the Volf River, for burial in the middle of the site.
-------
RESPONSE: EPA estimated that the material to be excavated would require level
B or C personal protective equipment. The level would be determined prior to
releasing the contract for bids. The level would determine the health and safety
requirements specified in the design for remedial action.
COMMENT: A local resident questioned if EPA was aware that the State of
Tennessee had issued a National Pollution Discharge Elimination System (NPOES)
permit to a local factory allowing them to discharge water to the abandoned
dredge pond.
RESPONSE: During Che public meeting, EPA and the State of Tennessee Superfund
Program agreed to check Into this permit. Upon review, the State of Tennessee
identified an industry located on Chelsea Street that has a NPDES permit for
discharge of cooling water. The discharge enters a city drainage ditch which
leads to the Workhouse Bayou Pumping Station and then to the Wolf River. Stora^
drainage from the north side of the plant enters the abandoned dredge pond
through a culvert. Recently, state personnel observed an oily material in the
ditch. The industry has installed an oil-water separator to control the oily
material in the stormwater run-off. Since the stormwater is receiving treatment.
the existing NPDES permit was*modified to add another discharge point.
There has been no change in the amount of water entering the dredge pond (storm
water only). The storm water is now receiving treatment (and being monitored)
to prevent contaminants from entering the pond.
COMMENT: A local resident questioned if there were any provisions available to
residents to help them understand the technical issues presented in the Proposed
Plan Fact Sheet.
RESPONSE: EPA explained the Technical Assistance Grant Program and how residents
and groups could apply for the grant. Information was provided in the package
of handouts EPA prepared and distributed to those attending the meeting.
COMMENT: A local citizen wanted to know how many sampling points existed north
of the site on the Wolf River.
8
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RESPONSE: There was one well located north of Che sice on che other side of the
'olf River to demonstraee a groundwater upflow and discharge to the Wolf River
consistent with the findings on che south side of the sice. EPA was primarily
concentrating on monitoring the site itself with minimal sampling on the north
sice of che Wolf River.
COMMENT: A local resident questioned the hydraulics of the site area;
specifically the upward hydraulics on both sides of the Wolf River and the
continuity of che underlying clay layer.
RESPONSE: Monitoring conducted by EPA and the United States Geological Survey
(USCS) demonstrated that the clay layer was continuous from each side of the Volf
River. The aforementioned monitoring indicated chat groundwater discharge was
to the Volf River.
\
COMMENT: A local resident questioned, if chosen as an alternative, how a barrier
would be constructed since the landfill was permeable.
RESPONSE: The problem with the barrier would be digging through the waste icself
in order to construct ic. Hydraulic pumping was preferred over che barrier wall
and would prevenc discharge to the U'olf River.
COMMENT: A local resident questioned if a monitoring well was installed to the
Memphis aquifer located 500*1000 feet below land surface and, if so, stated
concern about contaminating the Memphis aquifer.
RESPONSE: Wells were not installed into the Memphis aquifer under the
Supplemental RI but were installed under the Technical Action Group study.
COMMENT: A local resident questioned if severe pumping from some of che
groundwacer wells would cause groundwater in che surface aquifer to penetrate
into the confined aquifer.
-------
RESPONSE: There could be some areas In che overall larger Memphis vicinicy where
this would be possible, but noc in the area of the sice because of che existing
clay layer.
COMMENT: A resident was concerned about che flooding of Uolf River. -He raised
che question of che Wolf River recharging che contaminated shallow aquifer during
flood stages.
RESPONSE: EPA was concerned that during flood stages an extensive reversal flow
could occur. EPA was also concerned that contamination concentrations measured
in the background well were influenced by backflow caused by flood stages. There
could be some backflow. but it would be a localized effect so when conditions
returned to normal, che flood waters would return to the Wolf River and noc
affecc propercy very far back on each bank.
\
COMMENT: A local citizen questioned if the elevated levels of chlordane found
in background wells located on Birch Screec originaced from che sice or ocher
sources.
*
RESPONSE: Ic apparently originaced from other sources; flood backflow from che
Uolf River would not reach those wells.
COMMENT: A local citizen asked if EPA had conducted any studies to determine if
contamination existed in che neighborhoods adjacenc Co che sice and roadways
leading co che sice.
RESPONSE: In the early 1980's, Johns Hopkins University conducted a preliminary
healch study in the community. Around 1982, the Centers for Disease Concrol
started working officially with EPA to deal with healch issues relating to
Superfund. Offsite contamination was found in the neighborhood. One hundred and
ninety four people in the Hollywood area were scudied. Results from these
studies did not indicace elevated levels of contaminants that could be attribuced
Co Che sice. Elevated levels of pesticides, not associated with the site, were
found in people who consumed fish from Oxbow lake, the dredge lake and the Uolf
River. No adverse health effects were found in the people studied.
10
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COMMENT: A local resident questioned when the remedial alternative program would
-care.
RESPONSE: A typical Superfund site requires approximately one year to complete
construction. Actual physical construction would not begin until the design work
was completed, approved, signed off, and a contract was released for bids either
by EPA or the PRPs. Actual construction would probably not start until
approximately I 1/2 years.
COMMENT: A local resident questioned if the contractor's work had to meet all
applicable EPA cleanup standards.
RESPONSE: The contractor had to comply with EPA's cleanup standards no matter
if EPA or the City of Memphis lets the contract. The Corps of Engineers would
most likely oversee the contractor's work to ensure compliance.
\
COMMENT: A local resident questioned how much the site remediation would cost
and who would pay for the remediation.
•»
RESPONSE: The total, cost, not including a contingency, was estimated ac 8
million dollars. If the PRPs did not make a good faith offer to pay for Che
remediation, then EPA will spend public monies to implement the remedy.
COMMENT: A local resident questioned if the PRPs would be willing co pay for che
sice remediation.
RESPONSE: EPA anticipated that the PRPs would come forth with a good faith offer
but would not know until negotiations were conducted.
COMMENT: A local resident questioned what the cost would be to revitalize che
dump to che extent chat it would be commercially useful property.
RESPONSE: This was discussed and concluded that to revitalize che dump into
commercially useful property was not technically feasible for a site of chis
size. A commercial incineracor would have co be brought onsite to incinerate all
11
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Che waste mnd Chen scabillze or solidify the ash for burial In a RCRA-permitted
landfill.
COMMENT: A local resident questioned who owned the site property.
RESPONSE: The sice was private property. EPA had conducted a file search on the
property and the property owners.
COMMENT: A local resident questioned if EPA had a list of PRPs. who the PRPs
were and if he could obtain a copy of the list.
RESPONSE: EPA has a list of PRPs which is a continuously evolving list. To
obtain a copy of the list, an individual would have to submit a Freedom of
Information Act (FOIA) request to obtain the list. EPA explained that parties.
included on the list were potentially responsible and not necessarily the actual
responsible parties. Therefore, the list is subject to additions or deletions
at any point in time.
COMMENT: A local resident questioned how much input"the PRPs had in selecting
the cleanup remedy and expressed concern that the PRPs would select the least
expensive alternative.
RESPONSE: EPA, not Che PRPs, selected all alternatives for any site. The
cleanup plan was non-negotiable; it was an independent EPA (Federal) and state
decision.
COMMENT: A local resident questioned if a local organization could obtain a
Technical Assistance Crane (TAG).
RESPONSE: Yes; if Che group was Che only local group applying for che TAG and
met EPA's requirements.
12
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IV. WRITTEN COMMENTS RECEIVED DfRINC THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSE TO THESE COMMENTS
This section contains copies of che five letters received by EPA
containing written comments. Each letter is followed by a copy of EPA's
written response to the letter.
13
-------
Felicia Barnec:
3-5 Courtland 5"-^
-
Atlanta, GA
-------
WE, AREA. RESIDENTS OF THE HOLLYWOOD LANDFILL, HAVg NOT
BEEN ADEQUATELY REASSURED ABOUT THE SAFETY OF THE SOIL
AND WATER IN OUR AREA. WE ARE NOTIFYING ALL THE
"POTENTIALLY RESPONSIBLE PARTIES" FOR THE HAZARDOUS
SUBSTANCES IN THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES TO THE EXISTING SITE AS IS, MUST INCLUDE
CONSIDERATION OF THE HEALTH, WELFARE, FEARS, AND
DESIRES OF OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION AND SAFETY PROBLEMS
ASSOCIATED WITH THE HOLLYWOOD LANDFILL. IN RESPONSE TO
OUR PREDICAMENT WE ARE NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OUR PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WE DESIRE FURTHER CONTACT WITH THB
POTENTIALLY RESPONSIBLE PARTIES AND THE LOCAL
LEGISLATIVE BODIES CONCERNING OU1 REQUEST.
AJLJL/ (T^ui^ tyZi frJJC
'XJ/c 141 Jj
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WE, AREA. RESIDENTS OF THE HOLLYWOOD LANDFILL, HAVE NOT
BEEN ADEQUATELY REASSURED ABOUT THE SAFETY OF THE SOIL
AND WATER IN OUR AREA. WE ARE NOTIFYING ALL THE
"POTENTIALLY RESPONSIBLE PARTIES" FOR THE HAZARDOUS
SUBSTANCES IN THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES TO THE EXISTING SITE AS IS, MUST INCLUDE
CONSIDERATION OF THE HEALTH, WELFARE, FEARS, AND
DESIRES OF OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION AND SAFETY PROBLEMS
ASSOCIATED WITH THE HOLLYWOOD LANDFILL. IN RESPONSE TO
OUR PREDICAMENT W3 ARE NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OUR PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WE DESIRE FU1THE1 CONTACT WITH THE
POTENTIALLY RESPONSIBLE PARTIES AND THE LOCAL
LEGISLATIVE BODIES CONCERNING OUR REQUEST.
-------
WE, AREA. RESIDENTS OF THE HOLLYWOOD LANDFILL, HAVE NOT
BEEN ADEQUATELY REASSURED ABOUT THE SAFETY OF THE SOIL
AND WATER IN OUR AREA. WE ARE NOTIFYING ALL THE
-POTENTIALLY RESPONSIBLE PARTIES" FOR THE HAZARDOUS
SUBSTANCES IN THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES TO THE EXISTING SITE AS IS, MUST INCLUDE
CONSIDERATION OF THE HEALTH, WELFARE, FEARS, AND
DESIRES OF OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION AND SAFETY PROBLEMS
ASSOCIATED WITH THE HOLLYVOOD LANDFILL. IN RESPONSE TO
OU1 PREDICAMENT WE ARE NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OU1 PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WE DESIRE FURTHER CONTACT WITH THE
POTENTIALLY RESPONSIBLE PARTIES AND THE LOCAL
LEGISLATIVE BODIES CONCERNING OUR REQUEST.
^U*
?$.;#
-------
WI, AREA: RESIDENTS OP THE HOLLYWOOD LANDFILL, HAVE NOT
BEEN ADEQUATELY REASSURED ABOUT THE SAFETY OP THE SOIL
AND WATER IN OUR AREA. WE ARE NOTIFYING ALL THE
"POTENTIALLY RESPONSIBLE PARTIES* FOR THE HAZARDOUS
SUBSTANCES IN THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES TO THE EXISTING SITE AS IS, MUST INCLUDE
CONSIDERATION OP THE HEALTH, WELFARE, FEARS, AND
DESIRES OP OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION AND SAFETY PROBLEMS
ASSOCIATED WITH THS HOLLYWOOD LANDFILL. IN RESPONSE TO
OUR PREDICAMENT VI ARI NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OUR PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WE DESIRI FURTHER CONTACT WITH THE
POTENTIALLY RESPONSIBLE PARTIES AND THE LOCAL
LEGISLATIVE BODIES CONCERNING OUR REQUEST.
-------
WE, AREA: RESIDENTS OF THB HOLLYWOOD LANDFILL, HI78 NOT
BEEN ADEQUATELY REASSURED ABOUT THB SAFETY OF THB SOIL
AND WATER IN OUR AREA. WE ARE NOTIFYING ALL THB
"POTENTIALLY RESPONSIBLE PASTIES" FOR THE HAZARDOUS
SUBSTANCES IN THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES TO THE EXISTING SITS AS IS, MUST INCLUDE
CONSIDERATION OF THE HEALTH, WELFARE, FEARS, AND
DESIRES OF OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION AND SAFETY PROBLEMS
ASSOCIATED WITH THE HOLLYWOOD LANDFILL. IN RESPONSE TO
OUR PREDICAMENT WS ARE NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OUR PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WE DBSIRB FURTHER CONTACT WITH THB
POTENTIALLY RESPONSIBLE PARTIES AND THB LOCAL
LEGISLATIVE BODIES CONCERNING OUR 1BQUBST.
NAME
ADDRBSS
jlS A •
-------
WE, AREA: RESIDENTS OF THE HOLLYWOOD LANDFILL, HAV1 NOT
BEEN ADEQUATELY REASSURED ABOUT TH* SAFETY OF THE SOIL
AND WATER IN OUR AREA. WE ARE NOTIFYING ALL THE
"POTENTIALLY RESPONSIBLE PARTIES* FOR THE HAZARDOUS
SUBSTANCES IN) THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES ,10 THE EXISTING SITE AS IS, MUST INCLUDE
CONSIDERATION OF THE HEALTH, WELFARE, FEARS, AND
DESIRES OF OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION^AND SAFETY PROBLEMS
ASSOCIATED WITH THE HOLLYWOOD LANDFILL. IN RESPONSE TO
OUR PREDICAMENT WE ARE NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OUR PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WE DESIRE FURTHER CONTACT WITH THE
POTENTIALLY RESPONSIBLE PARTIES AND THE LOCAL
LEGISLATIVE BODIES CONCERNING OUR REQUEST.
NAME
K
ADDRESS
-------
VI. AREA: RESIDENTS OF THE HOLLYVOOO LANDFILL, HAVE NOT
BBEK ADEQUATELY REASSURED ABOUT THE SAFETY OF THE SOIL
AND VATE1 IN OUR AREA. WE ARE NOTIFYING ALL THB
"POTENTIALLY RESPONSIBLB PARTIES" FOR THB HAZARDOUS
SUBSTANCES IN THE HOLLYWOOD LANDFILL THAT ACCEPTABLE
ALTERNATIVES TO THE EXISTING SITE AS IS, MUST INCLUDE
CONSIDERATION OF THE HEALTH, WELFARE, FEARS, AND
DESIRES OF OUR NEIGHBORHOOD WHICH FOR YEARS HAS
DIRECTLY SUFFERED THE POLLUTION AND SAFETY PROBLEMS
ASSOCIATED WITH THB HOLLYVOOO LANDFILL. IN RESPONSE TO
OUR PREDICAMENT VB ABB NOW ASKING YOU TO CONSIDER A
BUY-OUT OF OU1 PROPERTIES AND A RELOCATION OF OUR
FAMILIES. WB DBSIBB FURTHER CONTACT WITH THB
POTENTIALLY RESPONSIBLE PARTIES AND THB LOCAL
LEGISLATIVE BODIES CONCERNING OUR REQUEST.
N
-------
_ ut/^ i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
y ^^^^^^^^^ £
343 COUPTUANO STREET N E.
ATLANTA GEORGIA 3O363
AUG 2 7 ISSO
Ms. Rosie B. Smith
2472 Heard Avenue
Memphis, TN 381'28
Dear Ms. Smith:
Thank you for notifying EPA of your concerns about the North
Hollywood Dump NPL site in Memphis, Tennessee. I have forwarded your
petition to the State of Tennesse and Memphis City Councilman
Shepperson A. Wilbun.
•
Based on studies of North Hollywood performed by different agencies,,
EPA has proposed a final remediation for the site that will remove
the few health risks that have been identified. Since this
remediation should remove the final health risks associated with the
site, EPA is not presently considering the permanent relocation of
area residents; however, as stated before, local representatives have
notified of your concern.
Please find enclosed a letter sent to Councilman Wilbun addressing
specific health concerns at North Hollywood which I hope will address
some of your concerns as well.
Please contact me at (404) 347-7791, should you have any additional
questions.
Sincerely,
Felicia Barnett
Remedial Project Manager
KY/TN Section, NSRB
Enclosure
cc: Richard Holland, State of Tennessee
-------
SHEPPCRSON A. W1L3UN. JR.
Councilman-
CITY COUNCIL
August 3, 1990
Felicia Barnett
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Barnett: ,
I share with my constituents from North Memphis a growing
concern over EPA 'a plans for the North Hollywood Dump Site.
It is the perception of many area residents that no one is
genuinely concerned for their health, well being, and
property values. I am deeply disturbed by the possibility
that EPA's plans may not fully weigh the plight of those
who live, and have lived for years, with the daily
realities of this landfill.
Specifically, I have questions about the surface soil and
the Health Department '-s study: 1) A mixed message is sent
to area residents when they are told that there are "high"
concentrations of harmful chemicals in tKeir yards, yet
there is no health threat to them. I cannot get
reassurances about the sub-surface soil. If the ground-
water under the site is contaminated with chlordane,
heptachlor, arsenic, lead, etc., what is the status of the
soil between the groundwater and the surface soil? Is
working in a garden or eating from a garden as dangerous as
eating fish from the Wolf River where the groundwater
discharges? 2) Were the results of the Health
Department's study explained to area residents? What is
the health status of children, the elderly, and the sick if
the "no health threat" report is based on the effects of
these chemicals on adults? I have other similar questions.
I have pledged my support to the residents who live near
the landfill. Given that the present plan basically calls
only for extra dirt to be used as cover, we seek the
certainty that there are no future, present, or residual
health hazards to the community from the site. We also
seek equitable and just treatment for area residents,
including the consideration of a buy-out of their
properties and relocation of their families.
ep Vilbun
-------
C-i:- CN
"'
AUG23S90
Councilman Shepperson A. Hilbun, Jr.
City Council
City of Memphis
Suits 514
125 N. Mid-America Mall
Memphis, T.V 38103-2086
Dear Mr. Wilbun:
This letter is in response to /our letter of August 3, 1990,
concerning the .Vorth Hollywood Dump Proposed Plan for site
remediation. These responses to your request for information vi^l
also be included in SPA's final Record of Decision document for this
site.
EPA regrets that you and possibly some of the residents in the area
of Worth Hcllywccc perceive a lack of concern over their health ar.c
veil being. 'EPA is" deeply concerned about the public health ar.c
environment around the north Hollywood UPL site. EPA has seen
involved *ith extensive studies of the area* including the Memphis a-c
Shelby County Health Department (MSCHD) study (please find en'clcsec.
that you mer.~ior.ee in your letter and a Reaiecial
Investigacion/.reasiiility Study (RI/FS) performed under a
Commissioner's Order from the State of Tennessee. All of these
reports and additional data on North Hollywood are available in the
Memphis-Shelby County Public Library located at 1850 Peabody Avenue
in 'Memphis, Tennessee. Cn March 26 and 27, EPA representatives
conducted a door to door survey in tne nearby community requesting
names for our mailing list and interviewing around twenty residents
aiout tneir concerns. EPA has also requested public comments on iti
Proposed Plan for the North Hollywood site through cvo notices in the
Memphis Commercial Appeal, facts sheets that were mailed to local
residents and a public meeting that was held on June 28, 1990. As cf
this date, EPA has not received specific comments on the plan except
from persons at the public meeting.
your letter asJcs questions concerning the May 12, 1988 Health
Department Study performed by Memphis-Shelby County and the Centers
for Disease Control (CDC) . This study addresses effects of the dump
on persons near the site up to the date of the study. Very specific
questions about the study should be addressed to the Health
Department or the CDC. The public health advisor who worJts with us
here at EPA Region 4 has already requested some of the
medical /toxicological staff who were involved in the study to respond
to you regarding your health related questions. However, I hope the
following will respond to the general questions in your letter.
Please note that EPA did not base its selection of a remedy for .Vorth
Hollywood on the Health Department Study, but used all of the
information and studies performed on the site.
-------
-2-
1; A mixed message is sent to area residents when they are told chat
there are "high" concentrations of harmful chemicals in their
yards/ yet there is no health threat to them.
The Health Department Study does not state that the levels of dorrs
contaminants in the surrounding neighbor are "high". The report
states that the levels are "higher' or elevated above levels that
vere found in a comparison area. Although elevated higher than
levels in another similar community in the area/ these contaminant
levels are not high enough to cause health concerns as indicated by
the blood tests run by the Health Department and additional long-term
risk calculations made for the site during the RI/PS study. The long
term risks for the site are calculated in the Health Assessment
Section of the RI report. These calculations vere based on the both
children and adult exposures over a lifetime of exposure using v
conservative assumptions such as continual exposure to the highest
level of off site soil contamination found instead of an average of
the contamination found in the nearby residential area. These
calculations indicated that long term risks from contact with
off-site soils are within acceptable risk ranges.
2) 1 cannot get reassurances about sub-surface soil. If the
grouncwater under the site is contaminated vith chlorodane,
heptachlor, arsenic/ lead/ etc./ what is the status of the
soil betveen the groundwater and the surface soil? Is vorkir.g
in a garden or eating from a garden as dangerous as eating
fish out of the Wolf River, vhere the groundvater discharges?
As stated previously the risks associated vith long term exposure :c
off'Site soils vere found to be vithin acceptable risJt ranges. The
Health Department study also shoved no adverse effects from the
consumption of vegetables taken from gardens in the area. It should
be noted that the contaminated groundwater that you refer to is
beneath the site and flows into the Wolf River/ not into the
residential area.
Groundwater contaminant levels in the residential area are general!/
much lower than those detected beneath the dump.
3) Vere the results of the Health Department's study explained to
the area residents? what is the health status of children/ the
elderly and the sick if the "no health threat" report is based or.
the effects of these chemicals on adults?
The MSCHD and the CDC held a meeting to discuss the study vith local
residents at the Shannon School on June 30, 1988. Also as previously
stated/ EPA's evaluation of the site risks vas based on additional
risk studies besides the Health Department's. These risks vere
calculated using possible exposures to children.
-------
MEMPHIS AND SHELBY COUNTY
HEALTH DEPARTMENT
•MCMMAN KAMM. M o.
Director
• ICMAftO C MACKCTT
WIUUIAM N MO»»IS
August 22, 1990
CERTIFIED MAIL I P-104 160 706
Ma. Felicia Barnett
Remedial Project Manager
U.S. EPA Region ZV
345 Courtland Street, N.E.
Atlanta, CA 30365
Oear Ms. Barnett:
Let ae take this opportunity to thank you for cooing to Memphis and
addressing our Groundwater Quality Control Board for Shelby County
regarding the North Hollywood Ouap Site and the ^proposed plan for the
cleanup of said site.
The Groundvater Quality Control Board Is In agreeaent with EPA'3
current proposal, but did have sotae long-range concerns regarding the
contamination levels that would remain in the shallow groundwater.
The Board's concern was over the proposed long-range use of the site
which sight disturb the artificial and/or the natural barriers that
currently prevent the shallow groundvater from entering the Memphis
sands from which this area draws its drinking water. You did mention
that restriction* would be recorded in the titles of current property
owners. However, the Board is concerned about the extent of the
restriction and the length of time in which they would remain in
effect. H«, therefore, would appreciate knowing sore about the nature
of the restrictions and how they would be handled.
Once again thank you for the very informative update, ar.d we look
forward to working with you in the future.
Sincerely,
w.S. Crawford, Chairman
Groundwater Quality Control Board
wsc:HX:br
CC: Groundwater Quality Control Board Members
Richard Holland
-------
M: •'..
• '
JT!>
UNITE3STA75S ENVI9CNMSNTAL^S3-S:?iCN AGENCY
\^fc»^y
*»,...„.• REGION IV
3C36S
Mr. w. S. Crawford
Chairrran, Grour.dwater Quality Control Board
Memphis and Shelby County Health Department
814 Jefferson Avenue
Memphis, Tennessee 38105
Dear MT. Crawford:
I wish to thank you for the opportunity to address the MSCHD
Groundwater Quality Board concerning EPA's proposed remedy for the
North Hollywood Dump.
In reference to the concern expressed in your letter of August 22,
1990, EPA wculc welcome the MSCHD Grcundwater Quality Board's \
comments on the final deed restrictions placed on the North Hollywood
Dump to prevent contamination from entering the Memphis Sands
Aquifer. Specific deed restrictions for the North Hollywood site
/ill be established by EPA's legal staff during the Remedial
«sign/Remedial Action (RD/RA) phase of the remedy. At that ti.r.e,
-PA can r.ctify you of the restrictions and review your comments en
them prior to" incorporating the restrictions^on the land deeds.
Please contact me at (404) 347-7791 to let me know if you would like
to be notified directly or through the State of Tennessee Superfund
program.
Sincerely,
Felicia Barnett
Remedial Project Manager
KY/TN Section, NSRB
cc: Deborah Espy, ORC
Richard Holland, State of Tennessee
-------
MEMPHIS ENVIRONMENTAL CENTER. ;NC
\P*>.
.on« *i|i '4* •«* r^f ei :riu: :r.r;. _:e :.-.:.--:.
.-.:o the Aiirninisirative Record.
^
Velsicoi aererally supporis :.u.e agency's proposed remedial plan ai ;-.:::r.e. '.r. :r.t
June i9°0 Plar. Fact Sheet. Tnis plan in essence -Acuic close tne Nc."..-. H(.;/.*>.:<.\.
Dump tn a manner consistent with that of any ether sanitary r.ur.:c:pai !-.-._::!:.
The available information, including investigation to date estabiisn :n: :hi< -7= ;:'
remedy will fully and adequately protect human health and en'.iron,T.er.t. ''.'e.i'.w'c'.
believes this is an appropriate and reasonable remedial measure that •*:'.'. ia::;r. ?o:r.
the environmental as well as the regulatory requirements of this site.
There are other contaminants found at the site other than just :he resticxes .i.-.c
metais mentioned in the Public Hearing. These contaminants are Ice."titled .~. :r.e
Supplemental RI/FS. Apr::. 1990. Any sound remediation plan .T.US: tike .r.:c
account the world of contaminants found at the site and structure any remeui-1
program to address the requirements of the site as a whole. Velsicoi believes :.-.u;
the agency's currently proposed remedy meets this requirement of an o^riill
remedial program for the site.
Velsiccl supports the findings and conclusions expressed in the Public Hsarir.t; the:
the site poses little current and future risk to the environment (i.e. Wolf River i and
that the planned additional remediation actions (i.e. additional cover and erci:cn
control) will increase the overall security of the site and help maintain that security
into the future.
s
-------
Ms. Felicia Barnett
August 23, 1990
page two
Velsicol Chemical Corporation. City of Memphis and Buckman Laboratories have
worked cooperatively with both the State of Tennessee and the USEPA to investigate
and resolve any environmental problems the North Hollywood Dump Site may pose.
Up to this point in time these PRPs are all that have come forward to take
responsibility for this site. On March 5, 1990, the USEPA notified some 20 other
PRPs of their potential liability. Velsicol supports and will assist in any way possible
the agency's renewed efforts to enlist the help of these additional PRPs.
larvell, III
Manager, Environmental Services
GRH/dkd
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' REGION IV
343 COURTUANC S'
g jcg0 QUANTA GEOPG-A 3O363 .
Mr. Gecrge Har'/ell
Manager, Er.vironr.entai Services
Memphis Envirorjner.tal Center
2603 Corporate Avenue
Suite 100
Memphis, Tennessee 38132
Dear Mr. Harveli:
ThanJc you for your statements concerning the Remedial
Investigation/Feasibility Study (RI/FS) and selected remedy for the
North Hollywood Dump NPL site in Memphis, Tennessee. Your comments
will be incorporated into the Responsiveness Summary of the Recori of
Decision 'ROD; ar.d the Administrative Record for the site.
\
Please contact me at (404) 347-7791 if you have any questions.
Sincerely,
Felicia Barnett
Remedial Project Manager
KY/TN Section, NSR3
cc: Richard Holland, State of Tennessee
-------
o
DO.VELSO.V. BEARMAN. ADAMS. WILLIAMS & KIRSCH
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' t S «CC- 3 «. »0 • .«•€••••• M*. »»0 •.a.->"90..' . -IU. . t»t..|- '•
August 24, 1990
Ms. Felicia Barnett
Remedial Project Manager
U.S. EPA, Region IV
345 Courtland St., N.E.
Atlanta, Georgia 30365
RE: North Hollywood Dump Supplemental Remedial
Investigation Final Report, July 1989
Dear Ms. Barnett:
This letter is written for the purpose of commenting on
the above-referenced report on behalf of The Procter & Gamble
Cellulose Company. After a thorough review of the
Supplemental Remedial Investigation Final Report and other
documents which show the levels of copper which have been
detected at the North Hollywood Dump, we have been advised by
our environmental consultants that there are no health or
environmental risks associated with the presence of this
substance. The data in the Administrative Record appears to
wholly support this conclusion. Furthermore, it is our
understanding from conversations with EPA technical personnel
that the agency's opinion is in accord.
Additionally, although copper is noted as a "major
contaminant" in the Superfund Proposed Plan Fact Sheet and
as a metal of concern and indicator chemical in the Executive
Summary for the Supplemental Remedial Investigation Final
Report, the analysis of the data has revealed that no action
is necessary in response to copper because copper presents no
environmental or health risk at the Hollywood Dump site.
-------
Ms. Felicia Barnett
^August 24, 1990
Page 2
We would ask that the results of the technical review as
outlined in the report of Dames & Moore, and the analysis
used therein regarding the lack of any problems related to
copper be included in the Administrative Record in this
matter.
Very truly yours,
MSW/sg/5487
cc: David E. Ross, Esq.
Sharon E. Abrams, Esq.
Bearman, Jr.
P. McCalla
M. Scott Willhite
Attorneys for The Procter
ft Gamble Cellulose Company
-------
DAMES & MOORE
August 2?. 1990
Ms. Felicia Barnett
Remedial Projccc Manager
U.S. EPA Region IV
345 Courtland Serc«c. N.E.
Atlanta, Georgia 30365
Dear Ms. Barrett:
Re: North Hollyvood 3ucp
Supplemental Remedial Investigation
Final Report:. July 1989
Ac Che request of The Procter & Caable Cellulose Company. Daaes & Moore
reviewed the Supplemental Remedial Investigation Final Report, dated July 1989
(Supplemental RI), that was prepared by Conestoga-Rovtrs & Associates. The focus
of Dames & Moore's review of that report was on the effect of copper disposal
at the site. Our review Indicates that copper contaaination is not a concern
in any of the exposure routes for the site, as outlined below:
Ground water • Copper concentrations in dowr.gradient well samples are
similar to upgradient wells (see page 147 of Supplemental RI ar.d
Appendices L and M). v
Surface water • Comparison of copper concentrations in surface water
samples downstream and upstream indicate that the stream water is
not impacted by copper concentrations in leachate or runoff from the
site (see Tables 4.9 and 4.12 and page 1S2 of the Supplemental RI).
Stream sediment • There was no variation in copper concentrations in the
sediment samples taken downstream and upstream of the site (see page
134 of the Supplemental RI ar.d Appendix S) .
Surface soil and cap • The concentrations of copper in the site soils ar.d
the cap placed over the site are within the range expected for
alluvial soils (see page 160 and Tables 4.16 and 4.17).
Therefore, disposal of copper at the North Hollywood Dump does not appear
to present a health or environmental risk to the surrounding area. Based on the
information provided in the Supplemental RI, no response appears necessary due
to the presence of copper.
Respectfully yours,
DAMES & MOOR!
ne P. HacGregor
egulatory Analyst
VUliam G. Smith, PC
Senior Geologist/Associate
-------
-_- _
l»n.tt« SltlfI
O* '«•
OC
r/EPA
«*y I. 1986
S>X 440/5-96-001
QUALITY CRITERIA
for
WATER
1986
ACPAQOUCCDBV
U.S. OEPAHTVCMTOF COMMERCE
NATDMLTECMKM.
-------
•COPPER
ACU...IC LIFE SUMMARY;
Acute toxicity data are available for species in 41 genera of
freshwater animals. At a hardness of 50 mg/L the genera range in
sensitivity from 16.74 ug/L for Ptychocheilus to 10,240 ug/L for
«
Acroneuria. Data for eight species indicate that acute tcxicity
decreases as hardness increases. Additional data for several
species indicate that toxicity also decreases with increases in
alkalinity and total organic carbon.
Chronic values are available for 15 freshwater species and
range frcn 3.873 ug, L for brook trout to 60.36 ug/L for northern
piXe. Fish and invertebrate species seem to be about equally
sensitive to the chronic toxicity of copper.
fo.xicity tests have been conducted on copper with a wide
range of freshwater plants and the sensitivities are similar to
those of anir.als. Conplexir.g effects of the test r.edia and a
lack cf cccd analytical data r.ake interpretation and application
of these results difficult. Protection of animal species,
however, appears to offer adequate protection of plants. Capper
does not appear to bioconcentrate very much in the edible portion
of freshwater aquatic species.
The acute sensitivities of saltwater animals to copper range
from 5.3 ug/L for the blue mussel to 600 ug/L for the green crab.
A chronic life-cycle test has been conducted with a mysid, and
adverse effects were observed at 77 ug/L but not at 38 ug/L,
w" ' ch resulted in an acute-chronic ratio of 3.346. Several
*__.dicates suspended, canceled or restricted by U.S.EPA Office
of Pesticides and Toxic Substances
-------
saltwater algal species have been tested, ar.d effects vere
?
observed between 5 and 100 ug/L. Oysters can bioaccumuiate
•
copper up to 28,200 tines, and become bluish-green, apparently
w
without significant mortality. In long-term exposures, the bay
scallop was killed at 5 ug/L. . .
i
NATIONAL CRITERIA; ' '
Th« procedures described in the Guidelines for Deriving *"
Numerical National Water C'-ality Criteria far the Protection of "
Aquatic Organisms and Uses indicate that, except possibly where a r'
locally important species is very sensitive, freshwater aquatic s
organisms and their uses should not be affected u.-.acceptably i'*f r
the 4-day average concentration (in ug/L) of copper does not e
exceed the numerical value given by 0(0.8545 ^ In(hardr.ess) ;-1.46 = :
\
more than once every 3 years on the average and if the i-hcur '
A-
average concentration (in ug/L) does net exceed the numerical
value given by e;c.9422; In(hardness) ; -1.454) r.ore than or.ce every
3 years on the average. For example, at hardnesses of 50, :::.
and 200 mg/L as CaC03 the 4-day average concentrations of copper
are 6.5, 12, and 21 ug/L, respectively, and the 1-hour average 1>
concentrations are 9.2, 13, and 34 ug/L.
The procedures described in the Guidelines indicate that,
except possibly where a locally important species is very
sensitive, saltwater aquatic organisms and their uses should r.c-
be affected unacceptably if the 1-hour average concentration cf
BC
copper does not exceed 2.9 ug/L more than once every 3 years cr.
c "
the average. ""
i~
EPA believes that a measurement such -as "acid-soluble" would
1C
-------
ovide a more scientifically correct basis upon which to
establish criteria for metals. The criteria were developed on
this basis. However, at this time, no EPA approved methods for
such a measurement are available to implement the criteria
through the regulatory programs of the Agency and the States.
Th« Agency is considering development and approval of methods
for a measurement such as acid-soluble. Until available,
however, EPA recommends applying the criteria using the total
recoverable method. This has two impacts: (1) certain species of
some metals cannot be analyzed directly because the total
recoverable r.ethod does not distinguish between individual •
oxidation states, and (2) these criteria may be overly protective
"hen based en the total recoverable method.
The recommended exceedence frequency of 3 years is the
Agency's best scientific judgment of the average amount of time
it will take an unstressed system to recover from a pollution
event in which exposure to copper exceeds the criterion. A
stressed system, for example, one in which several outfalls occur
in a limited area, would be expected to require more time for
recovery. The resilience of ecosystems and their ability to
recover differ greatly, however, and site-specific criteria may
be established if adequate justification is provided.
The use of criteria in developing waste treatment facilities
requires the selection of an appropriate wasteload allocation
model. Dynamic models are preferred for the application of these
iteria. Limited data or other factors' may make their use
impractical, in which case one should rely on a steady-state
model. The Agency recommends the interim use of 1Q5 or 1Q1O for
-------
Criterion Maximum Concentration design flow and 7Q5 or 7Qio for
the Criterion Continuous Concentration (CCC) design flow in
steady-state models for unstressed and stressed systems
respectively. These natters are discussed in sore detail in the
Technical Support Cocuner.t for Water Quality-Sased Toxics Centre 1
(U.S. SPA, 1985).
HUMAN HEALTH CRITERIA:
Sufficient data is not available for copper to derive a level
which would protect against the potential toxicity of this
compound. Using available organoleptic data, for controlling
undesirable taste and odor quality of ambient water, the
\
estimated level is 1 mg/L. It should be recognized that
orgar.cleptic data as a basis for establishing a water quality
criteria have ii.-itaticns ar.d have no der.cnstratei reiaticr.si-.ip
to cctential adverse huran health effects.
(45 F.R. 79318 Nov. 23,1980) (50 F.R. 30784, July 29, 1985)
SEE APPENDIX A FOR METHODOLOGY
-------
l.tVKI.S OF COI'I'I K OKTKCTKO AT HOLLYWOOD DUMP
I'osl e He ler 11 mi
(Water Measured in Hi Digrams/
Liters or parts per Million) Komi.I Hound . Hound Hound
I 2.3 4
Croundwater -O/H1 .HO**1 .090* .05?*
Surface W.iler (Wolf River)6 .O.". NO NO .001.
Safe Drinking Water Standard7 l.oo 1.00 I.(Ml 1.00
I. Table. QA/QC Hetsls Analysis (mfjl.) Hound I ./Croundwater Samples, Supplemental RI/FS, North Hollywood
Dump. Page I of 1 (Exhibit I).
2. Table. <)A/()C Hetal Analysis (•(;/!•) KUIUM! I. CruiiiMlw.itvr S.i»pleti, Snppleaental HI/KS. North Hollywood
Dusp. Page 2 of 5 (Exhibit 2).
3. Table. QA/QC Metal Analysis («g/l.) H.iuuJ 2. Crounilwater SanpleK. Supplemental MI/KS. North Hnllywood
Dump. Page of 5. (Exhibit 3).
4. Table. Metal Analysis (*g/L) Round i. Crnumluater Samples. Supplemental Rl/FS North Hollywood Dump.
Page I of 2. (Exhibit 4).
«
5. Table. Hetal Analysis (rng/L) Round 4. Croundwater Samples, Supplemental Rl/FS. North Hollywood Dump.
(Exhibit 5).
6. Table. Metals Analysis (mg/L) Wolf Hlver Water. Supplemental HI/KS. North Hollywood Dump
(Exhibit 6).
7. Hazardous Substance Guidelines. Tennessee Division of Solid Waste Management Super fund (Kxhlhlt /).
C.F.R. f 141. et seq.
-------
(Soil Measured In Milligrams
Per Kilogram Unless Designated
Otherwise)
Surface Soil
Wolf River Sediment (tig/kg)
Safety Standard
12
Round
1
NA8*
NA
100.00
Round
2
71. 91"
l«».h
100.00
Round
1
NA*
NA
100.00
Kound
4
., ,11
47.6
NA
100.00
8. Table. Limits of Detection, Hetals Aii.ilysls (mg/kg) Surface Soil Samples, Supplemental RI/FS. North
Hollywood Dump. (Exhibit 8).
9. Table. Metal Analysis (mg/kg) Round 2. Suit ate Soil Samples, Supplemental RI/FS. North Hollywood Dump.
(Exhibit 9).
10. Table. Metal Analysis (mg/kg) Round 2. Surface Soil Samples, Supplemental RI/FS, North Hollywood Dump.
Page 2 of 2. (Exhibit 10).
II. Table. Mulal Analysis (mg/kg) Round 4, Surf.ire Soil Snmplcu. Supplemental RI/FS. Ntirlh Hollywood Dump.
Page I of 2. (Exhibit II).
12. Table. Metal Analysis (ug/kg) Round 2. Wolf River Sediment Samples. Supplemental RI/FS North Hollywood
Dump. Page I of 1. (Exhibit 12).
13. See Footnote 7. (Exhibit 7).
-------
»r
UA/UT HKTAI.S AMALVSI* |i»|/|.|
•OIIMII I. GMOllNIMATSN SAMM.L't
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NO
.•!•
NO
.411
1. !!•
NA
NA
NA
NO
MA
MA
MA
.•11
I.IM
NO
.**•
MO
.1*1
2.22C
.•!•
.•••
.•Ift
NO
.*2*
.•2*
Mil
.••ft
.•19
.••1
.•••
.•ft*
.•SI
.•Ift
.•9*
NA
.•IS
.**•
.lift
.11*
.•14
.•*9
1.91ft
NO
.••4
.•!•
.4(1
l.ftlft
.•IB
.•II
.•*9
Nil
.IIS
.•24
Mil
.•ft*
1.914
NO
.••S
.*!*
.lift
11.14*
.•Ift
.•4*
.•II
NO
.2m
.•SB
Mil
I 1.11.1
-------
TAIIl.t.
UA/UV Hl.TAI. ANALYSIS |a»|/l.|
HOIIHO 2. CRnilNOWATCII SANPLCS
siM-n.tmMTAi. M/rs. HOMII HOI.I.»WOOO »*IMP
H»:TAI.
SAHPLK NtlH
cor rnii
MAM UN
•IMI.LlUn
CHROMIUM
CAOMIUH
CVMOMTIIIN
ALUHIMUH
AftSBNlC
NICKEL
LCAO
HIRCIIRV
SIMC
VAHAOIIIM
CtAMIOK
HDTAL
HAHK
SAHPI.C HUH
COPPBR '
•AMIUH
•(MILLION
CIIIIOHIUH
CADMIUM
STBOMTIIIM
ALUHIMUH
AMBMIC
NICKEL
LKAO
HCMCIIHV
SIHC
VANADIUM
CVANine
IIMI
I*
.11*
.S*4
NO
NO
NO
.14*
.Ml
.•44
.Ill
NO
.as*
.••i
.••12
OMI I
14
NO
NO
NO
NO
.Sit
2.4*1
NO
.••1
.••I
NO
.•14
NO
Nil
IIMI
L«b
Hup.
I*
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NO
NA
NA
NA
own
L«b
Hop.
• I
14
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NO
ow*
1
II
MA
HA
HA
HA
HA
HA
HA
HA
HA
MA
HA
HA
HA
NO
OMII
Lab
Oup.
• 2
24
HA
HA
HA
HA
HA
HA
HA
HA
HA
HA
HA
HA
NA
.••1?
OW*
rlltaiol
94
NO
.12*
NO
NO
HO
.IS*
.»*•
.••4
.•12
NO
.•••4
.•II
NO
NA
OMII
MatlU
44
.•11
.911
NO
NO
HO
.491
1.21*
NO
.••4
.•19
NO
.•!•
NO
.•021
• IHU
Illl-
1 llliM «•!
911
NO
NO
NO
NO
NO
NO
NO
.••1
NO
.••4
NO
^ .«24
HO
NA
OWI 1
Mat! I"
l.ab Oap.
• 1
44
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
.0112%
UM9lt
19
.•2*
.192
.•••I
NO
NO
.141
*.J4*
.MS
.•41
.•14
.•••4
.241
.••44
NO
OMII
Mat • !•
l.ai* Oup.
42
44
NA •
HA
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
.••!•
OW9O
Lab
Pup.
19
NA
NA
NA
NA
HA
HA
HA
.*••
.*4t
.•11
.•••4
NA
.•II
NA
OWI4A
2S
.•14
I.SM
NO
NO
Nil
.S4«
1.191
NO
.•It
.•2S
NO
.•42
NO
NA
OWI*
2*
.•••
.941
NO
HO
HO
.SM
I. 211
.••1
.•II
.•••
NO
.•41
NO
NO
OMI4A
rial*
Pup.
SI
.•It
l.42t
NO
HO
NO
.441
1.911
.••1
.•21
.•II
NO
.•24
NO
.!%•
OWI*
Lab
Oup.
2*
.•14
.911
MO
MO
MO
.S4t
a. 1*1
MA
MA
HA
HA
.tit
HA
HA
OMI4N
24
HA
HA
HA
HA
NA
HA
HA
HA
HA
HA
HA
HA
HA
.•24
,
OWI*
Mal4
Oup.
SI
MO
l.lll
.•••4
HO
HO
.4IS
I.*4t
HO
.til
.••4
HO
.M9
HO
.•14
OMI4N
rlllaiaa
9S
HO
l.49t
HO
HO
HO
.44*
1.111
.Ml
.•14
HO
HO
.••9
NO
NA
OMII
11
.til
.•9t
HO
MO
MO
.I4S
4.SS4
HO
.•!»
.tis
HO
.til
HO
NA
OMI4*
Ua-
llll*fa«l
99
.*4t
l.44t
.•••»
MO
MO
.422
9.*49
NO
.*!•
.*2S
NO
.•49
NO
NA
MMII
Lab
Pup.
41
21
MA
MA
MA
MA
NA
NA
NA
NA
NA
NA
HA
HA
HA
.•19
OWI4A
21
.•SI
.!•!
NO
Nil
HD
.24)
.992
.•49
.M2
.191
.•••1
.•9S
NO
NO
owll
Lab
Pup.
• 2
21
MA
MA
HA
HA
HA
HA
NA
NA
HA
HA
HA
HA
NA
.•!•
OMI4A
Lab
Pup.
It
.•SI
.IS*
NO
HO
NO
.211
.4S*
NA
NA
NA
.•Ml
.Ml
NO
NA
I Hlnl.il
-------
or 4
HI.C
U»/0«- HKTAI.S AMALVSI* (••I/I.)
NOIIMl 2. CaOIIMUMATKN SAHM.C4
UMITMHI:MT*I. m/ra. Nuwtti itou.vwoott
HKTAI. OMIC OMIC
NANK OMIC Spill* Splfc*
(••awn) |N*«**4|
IIMJA
OM2A
(IMJU
4IM2U
4plA«
tIMJA
•plk«
(IW2C
OMIC
pup.
OM|A
OMIA
tlt««
Pup,
OMIA
!!«««
Oup.
OMIA
UM-
lttt«i«
•AHfLC HUH
coma
•AMUM
••MM. I UN
CMMMIIUN
CADMIUM
•TIIOMTIUH
ALUMINUM
AR4BNIC
MICKIL
LIAO
HIACIIAV
• IMC
V*MAOIUN
CVANIOI
.•14 MA MA
.11* MA MA
MO MA MA
MO MA MA
MO MA MA
.!!• MA MA
I.ICS MA NA
NO MA NA
.1*4 NA NA
.••1 NA NA
NO NA NA
.•!• NA NA
NO NA NA
NO .140 .141
NO
.•14
NO
MO
NO
.111
.411
NO
.•1}
.••s
NO
NO
NO
.••IS
NA
MA
NA
MA
MA
MA
MA
MA
MA
MA
MO
MA
MA
MA
.•44
.444
.114
.•II
.•41
4*.414
.444
.•»4
.441
.44*4
.111
.141
NO
44
.14*
.411
.•II
.141
.114
1.44*
.•II
.•11
.••14
.•41
.114
44 4 4 I
.144 .MS NA NO
.41t .144 NA .141
.•II .Ml MA NO
.114 .M4 NA NO
.•41 .•!• NA NO
.144 .«44 NA .144
!.!!• !?.•»• NA !.!••
.•11 .Ml NA .444
.44* .114 NA NO
.•24 .444 NA Nil
.4414 MO NO NO
.114 .44* NA .«I4
.144 .141 NA NO
4M.444 .4414 NA NA
ffl ffl 1
NO NA MA
.III NA NA
NO NA NA
NO NA NA
NO NA NA
. II* MA MA
.•4* MA NA
MO NO NA
NO Nil NA
Nil Mil NA
NO NA NA
.••1 MA MA
NO NO NA
NA NA NA
HBTAL
HANI
OMIC
OMIC
•plk«
(RNOMM)
OMIC
OM4A
OM4A
Lab
Pap.
II
OM4A
Pup.
12
OM4A
OM4A
•pit*
OM4A
•plk*
OM44) OM4«
OMSB Lab rUI4
Pup. Oup.
•AHfLI MUM
corn*
•A*IUN
•••ILLIUH
CMBONIUN
CAOHIUH
•MONTI UN
ALUHIMUM
AHIKMIC
NICKEL
LIAO
NCKCURtf
»IMC
VANADIUH
CVAMIOI
4*
.11*
.•41
NO .411
MO .144
MO .441
.114
I.))*
MO
.•II
NO
NO .441
.•44 .Ml
MO .1)1
.•II
.IS4
.•44
4.2*1
.•14
.•if
-•*!
.114
NO
4M.4M 42«.«M
MO
MO
MO
MO
.114
.4*1
NO
.••1
.•14
NO
.•14
NO
NO
MA
MA
MA
MA
MA
MA
MA
MA
MA
NA
MA
MA
MA
NO
I*
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MA
MO
II
NO
.144
NO
MO
MO
2.42*
MO
.••4
NO
.•I)
NO
.••14
12
MA
NA
NA
NA
NA
NA
MA
MA
NA
NA
NA
NA
NA
.14*
II
NA
NA
NA
NA
NA
NA
MA
MA
NA
MA
MA
MA
MA
.141
II
.•14
II
.•14
4«
NO
NO NO NO
.•44 .*I4 NO
NO NO NO
.114 .211 .211
1.44* l.2ff« 2.44*
MO NA NO
.•14 NA .•)!
.••4 NA .411
NO NA NO
.411 .414 .••!
.•)• NA .«44
NO NA NO
-------
••I
I Ml I
TAHl.t
Hi:tAI. ANALYSIS l
HHIINII I. I;MUIINI>MATI:W
m/rs. NOMTII HOI.I.VMOOII
mini*
METAL
NAME
SAMPLE HIM
COMMENTS
ARSCMIC
•RRVLLIOM
LKAO
NICKEL
SINC
STHOMTIUM
COPPKR
•ARIUH
CHROMIUM
CADMIUM
ALUMINUM
HEHCUNV
VAMAOIUM
CVANIOB
MKTAL
MANE
SAMPLE NUN
COMMKMTS
AMMIC
•KRVLLIUH
LIAO
MICHEL
SINC
STRONTIUM
COPPRR
•ARIUM
CUR OM HIM
CAOHIUH
ALUMINUM
MERCURY
VANADIUM
cvAMine
OMIA
II
H
• .•42
NO
.•44
.•44
NO
.444
.•12
.411
NO
Mil
1.44*
NO
• .•22
NO
OM4A
1
• .••9
NO
.••1
.••4
.•42
.441
.•II
.144
.•41
NO
4.24
NO
• .•47
NO
OH in
4
L
• .•14
NO
.•IS
.•IS
.042
.144
.011
.142
NO
NO
1.44
NO
0.022
NO
OM40
4
L
• .00S
NO
.••9
.022
.114
.141
.•14
.424
.041
NO
.4«
NO
.027
.••21
OWIC
4
9
• .022
MO
.0SS
.010
.101
.141
.041
.IS0
MO
NO
1.22
NO
NO
NO
OH?
„
0.014
NO
• .MS
MO
0.I1S
0.144
0.014
0.S21
0.09S
NO
1.1?
NO
0.01S
0.0022
OM2A
24
0.009
NO
MO
0.004
• ••!•
• .144
MO
0.241
NO
NO
0.910
NO
NO
0.0041
CMS
„
L
.049
.••II
.•12
.MS
.!•*
.219
.•2S
.414
.••4
MO
12.4
• .•4
NO
Nil
IIMJII
t
.Ml
.•••4
.•12
.•21
.414
. 149
NO
.III
.•II
NO
?.• J
NO
*.*'«
NO
OH9A
14
• .Ml
NO
• .M4
• .•44
• ••44
• .141
NO
• .Ml
NO
NO
1. Itf
Nil
NO
Nil
UWJi:
10
L
• .•12
NO
.•II
.•IS
.•41
. 444
.•12
.•42
.•14
NO .
.01 '
NO
.044
.•44
OH90
II
• .•11
NO
.•22
.•21
.•II
.122
.•19
.•?•
.919
NO
2.44
NO
• .•II
NO
IIMIA
21
L
• .••?
NO
• •••4
• .••4
• .•41
• .214
NO
0.141
NO
NO
1.14
NO
0.024
NO
UMIII
I I
0.019
NO
OMM:
14
Mil
MO
.012
.•14
.414
.211
MO
.112
.•41
NO
• .•4
NO
• ••II
NO
OM4A
14
fH
MU
Mil
.***
.•21
OW4II
M
.9999
OM4A
I
L
• .•••
NO
.414
.1*1
MO
.••4
.•If
NO
l.*9
NO
I.C4S
NO
.441
MO
.141
.•14
NO
• .114
NO
NO
Mil
NO
.•M
.121
.•!•
.•••
.•12
NO
11.44
NO
• .•IS
NO
.291
.•12
.249
.•41
NO
7.12
NO
NO
• ••Ml
OM4II
.•21
.•••I
.•If
.•II
.414
,214
.•21
!«42
.•44
I 1.2
NO
*.*» I
NO
OMIC
NO
.•21
.M9
.•Si
.4*1
.•IS
NO
!.••
NO
• .•24
NO
OMII
19
n
• .•14
NO
• .•II
0.001
0.041
• .144
NO
NO
• .•14
NO
NO
• .•44
Nil
OMI2*
N
• .014
NO
0.00S
• .•21
0.211
0.022
0.244
NO
NO
I.Ill
NO
0.029
0.0*24
OMI20
21
ir
.001
.0004
.049
.011
.044
.094
.049
.104
.041
NO
11.11
NO
0.014
0.0*42
OMII
II
0.019
NO
0.010
0.001
0.074
0.440
OWI4A
4H
NO
.109
.009
.044
OMI48
41
.024
.0021
.044
.049
.141
.494
0.0IS
NO
NU
l.*tf
NO
0.021
•.••24
.••I
1.44
NO
NO
l.ttf
NO
NO
.•4
NO
».*
NO
NO
iMlltlltl
-------
I III /
IH.K
MIT*!. .SIS <*|/M
HIIIINII 4. CRIIIINIIWATEM SAMI'I.KS
MIITI.IHKNfAl IM/rS. IIIIHTII IIUM.fMIMIIl IMIMf
METAL
MAHE
OWI*
OWIB
MIC
MM}*
OWJll
OWir
OWlA
OWill
(MIC
OM4A
NO
.•!•
.BIS
.8*4
.494
• 617
^1.421
.841
NO
4.41
Nil
.621
.882
.llil.l I
-------
HUM I
Mk I III VIM MAIfN
•jtm • • i !• Mini III 'I ;§. Nintlii !•• I (Miaul !•••
Ml* Mil I lumtMi / l*a«Mi » *••*«•
• .....
MM I MN1 MHl M«« Mil MM/ MM I MH« Mil MU MN| MN« MM I Ml/
37 a» a« a^ ^>« ^:< ** *' *'• «» ««• «v »» /»
CIMMIMIb » f I- • If I
Cl*»fN •••>« MWM*M*M*NOMIM0 NO N* M> *«• •.»•« «.«•«
MMIIIM •••»« •••» •.•!> •.»« •••» •.•!! •.•!• • »^« Ml MB MO MO •.•>« •••4V •.•?/ •••//
M Mil HIM NOMlMONeNOMOMANO MUMDMOMOMON0NONO
LIMUNIlM MOM0MWMOM0MOMOM) MttNOMOMAM0NUNttNI»
CMlMlun MONOMOMOMOMUMUMO MUMUMOMUMOMOMOMU
6IMUNIIIM •.•» •.•>• •.•>» •.•?! •••!! ».»»i •••>» K.»l| MU MO MO MO m.»JJ • •/« O.W/I
MiniMM •.>*• •.»»» •.}*• •.)•• |.*i« J.«3» !.•/* >.•»! i. vi i. ill i. it i.-/* •.»•> ».«a> o.avj
M«t4Nll. MO MO MO M) NO O.O«3 O.O03 0.0*1 O.OOU MO O.OOS O.OlM NO MO Nil O.Wtl
Mll^ki MOMONOMOMONONONO NO HB NO 9.OOO O. WJI • IMJI O.MM« MU
ItAlt NO NO MO MO MM*} O.MO4 O.MM O. *«> O.OO* ». MM O.OO4 O.OOO O.OO* «.O*I O Mil H.MII
MM:IM« NO NO MO NO NO O.*»«4 O.OOOI O.OO04 . MO «.OO> O.OO* O.OOI MO NO NO NO
/IML o.o«« o.oor o.ooa MO o.o^» o.oif o.ois o.oii o.oo* MO o.oo* NO o.on o o'/i o oyo *.*••<
vANAUlun MOMOMOMONONOMONO O.O7I O.*2> 0.071 •.O/f NO NO NO
LVANIOt MOMOMONONONONOMO NO MO NO NO NO NO O ••}
I Mini.It I.
-------
15; 24
Tennessee
Cam souno
Toluene
Carson tetrac^iartee
Chiorornrm
:»let!tyler.« cnioridc
7 1 trsc::ioro<*thy icnc
Tric.*.ioroetnylene
1 ,1 , :«7richlor3tnsne
£thylasetats
Xyiencc
Metny: sttyl i***
3,3
3,5
31,:
5!s
3,3
3,J
1
Water limits, ciariiiod by V.EO S-2
Nitrates (N). 10 ppm " ""
SuUatos-230 ppm
phospnftte - should be set below 50 ppm In watsr (gives renal damage in rats, is 10 times
dietary, adequate nutritional level lor rots)
1. Federal Register, 43:231, Nov. 1980.
2. Long term 5NARL
3. Interim drinking Water Standard
Dangerous Properties of Industrial Materials. N. Irvine Ssx
10-day SNARL
.. Federal Register,
-------
Water Act u amended (42 U.8.C, 300f Fhe secondary mannnm
nant levels for public water systems
are as follows:
(b) "r*nnTiTr'"*nt" means mn7 physi-
cal. chemical biological. or radlologl-
or matter in water.
"Public water system" means a
system for the provision to the public
of piped water for human consump-
tion. if such a system has at least fif-
teen service connections or regularly
serves an average of at least twenty-
five individuals daily at least 60 days
out of the year. Such term includes (1)
any collection, treatment, storage, and
distribution facilities under control of
the operator of such system and used
primarily in connection with such
system, and (2) any collection or pre*
treatment storage facilities not under
such control which are used primarily
in connection with such system. A
public water system is either a "com-
munity water system" or a "non-com-
munity water system."
(d) "State" means the agency of the
State or Tribal government which has
jurisdiction over public water systems.
During any period when a State does
not have responsibility pursuant to
ion 1443 of the Act. the term
l'9tate" means the Regional Adminis-
trator. U.S. Environmental Protection
Agency.
(e) "Supplier of water" means any
person wno owns or operates a public
water system.
(f) "Secondary n****™*"*™ contami-
nant levels" means SMCLs which
apply to public water systems and
which, in the judgement of the Ad-
ministrator. are requisite to protect
the public welfare. The SMCL means
the •»•«"»"•» permissible level of a
contaminant in water which is deliv-
ered to the free flowing outlet of the
ultimate user of public water system.
Contaminants added to the water
under circumstances controlled by the
user, except those resulting from cor-
rosion of piping and plumbing caused
by water quality, are excluded from
this definition.
(44 FR 42198. July 19. 1979. u amended at
37412. Sept. 26.1988]
Ota
T^^^tt
Znc.
i (TOS),
n«/k
9*0/1
levels represent reasonable
goals for drinking water quality. The
States may establish higher or lower
levels which may be appropriate de-
pendent upon local conditions such as
unavailability of alternate source
waters or other compelling factors.
provided that public health and wel-
fare are not adversely affected.
(44 FR 42198. July 19. 1979. aa amended at
31 FR 11412. Apr. 2. 1984]
§ 143.4 Monitoring.
•
(a) It is recommended that the pa-
rameters in these regulations should
be monitored at intervals no less fre-
quent than the monitoring performed
for inorganic chemical contaminants
listed in the National Interim Primary
Drinking Water Regulations as appli-
cable to community water systems.
More frequent monitoring would be
appropriate for specific parameters
such as pH. color, odor or others under
certain circumstances as directed by
the State.
(b) Analyses conducted to determine
compliance with i 143.3 should be
made in accordance with the following
methods:
(1) Cnlorlde—Potenttometric
Method. "Standard Methods for the
of Water and
Wastewater." 14th Edition, p. 306.
(2) Color—Platinum-Cobalt Method.
"Methods for Chemical Analysis of
Water and Wastes." p. 38-38. EPA.
Office of Technology Transfer. Wash-
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-------
TABLE
LIMITS CF DETECTION. METALS ANALYSIS
SURFACE SOIL SAMPLES
SUPPLEMENTAL RI/FS. NORTH HQLLYWOC2 DUMP
POUND 2 POUND 4
•
COPPER 2.4 0.8
BARIUM i.3 0.7
BERYLLIUM 0.102 0.8
CHROMIUM 2.34 1.4
CADMIUM 0.02 1.0
STRONTIUM 4.0 0.4
ALUMINUM 4.7 20.o
ARSENIC 0.4 1. I
NICKEL l.l 9.0
LEAD 3.12 1.0
^ERCURY 0.023 0.10
ZINC 3.4 i.O
VANAOILM 5.0 1.0
-------
Hi: 1*1. ANALYSIS (*.|/k.||
HOIIMI 2. SUMMCS SOU. SANfl.KS
MI/FS; NORTH MOI.I.VMOUH
IMIHI*
HKTAI.
NAME
COHHKMTS
ARSENIC
•BS ILL HIM
LBAO
NICKKi.
SING
Sf MONTI UH
corrss
•ASIUM
CNSOMIUM
CADMIUM
ALUMINUM
MESCUSV
VANADIUM
METAL
NAME
COMMENTS
ARSENIC
•BSVLLIU
tSAO
NICBEL
SINC
STSONTIU
corrss
BAA 1 UN
CNSOMIUM
CADMIUM
ALUMINUM
MESCURV
VANADIUM
ASI
• -A"
l.S
• .141
4.
2.
II.
4.
4.
IS.
NO
• .•S
21.2
NO
NO
ASI
• -4"
9.2
• .4SS
!•.
2.
IS.
II.
12.
ISI
NO
• .24
492*
NO
NO
ASI
4-12"
• .•
1 «.121
• .
S.
24.
1.
I*.
9*.
NO
• .•1
S44S
NO
IS.S
ASI
4-12*
.4
.24S
*
,
1 .
.
.
44.
NO
S.SS
124*
NO
NO
AS2
•-4"
1.1
S.4SI
IS.
1.
IS.
12.
IS.
Ill
NO
• .14
S.41
NO
40.4
ASS
•-f
LM
• .4
• .•IS
1 .4
NO
NO
NO
2.9
4.4
NO
NO
1SS
NO
ND
AS2
4-12"
S.»
*.4tfS
12.
1.
IS.
I*.
14.
9S.
NO
S.SS
4.S4S
NO
ND
ASS
4-12"
M
*.9
NO
1.4
NO
4.S
NO
NO
24.9
NO
S.SS
119 2
NO
Nil
A:; i
S-4"
1.
4.S
• .SI A
S. 1
2*.*
12.4
IS.S
IS.l
ISS
NO
• .••1
4.49*
NO
ND
AS9
• -4*
M
2.1
• .111
l.S
1.9
12.2
NO
NO
IS. 4
NO
S.SS
ISS 2
NO
J.tf
AS 1
4-12"
1.
1.
S.
IS.
1.
22.
4.
1.
41.
NO
• ' •••
'42SS
NO
ND
AS9
4-12*
1.
2.4
• illS
NO
2.1
II. 1
NO
ND
11. S
NO
• .•4
ISS
NO
1 . 9
A:. 4
S-4"
S. 1
19 S.4I
11.2
s.s
11.4
IS.l
14.2
IIS
NO
1 •-•!
4SSS
NO
NO
ASI*
• -A-
1.9
• .411
9.
S.
4S.
9.
S.
99.
NO
• .14
• 4S»
NO
12.4
AS4
4-12"
4.1
4 •.!!!
9.1
S.2
IS.l
4.2
• .1
44.1
ND
*.!•
1490
NO
ND
ASI*
4-12"
1.9
C.14*
4.1
NO
2S.4
9.*
S.9
94.*
NO
• .1 1
•S2S S
NO
11. S
ASS
• -4"
M
Nil
NO
NO
ND
ND
NO
NO
9.1
NO
*.*4
IS4
NO
11.4
ASH
• -4"
.1
.2*1
,
*
2 .
.
.
141
NO
S.IS
91*
NO
1 1.2
ASS
4-12'
S.9
NO
MO
ND
ND
2.S
11.2
NO
212
NO
ND
ASA
• -4*
4.S
NO
4.
it.
1.
V
42.'
NO
0.SS9
42IS
NO
Nil
Aik
4-12*
IS
2
I
142
NO
S.I4
S22*
NO
ND
ASM
4-12*
I.
12.4
.124
2 .
ISI
NO
S.I4
444*
NO
S.2
ASI2
• -4"
LM
1. I
S.244
»
4.
24.
4.
4.
122
NO
S.SS
449*
NO
12.4
ASI 2
4-12*
I.M
S.9
• .Id I
4.1
1.1
21.9
1.S4
NO
ss
4.11
S.S9
41/S
NO
II.tf
lxhil.lt M
-------
TAIII.I:
MI:CAI. ANALYSIS (••i/fc'il
MOIIHU ). SURFACE SOU. SAHI'I.KS
UIII'fl.KMKNTAI. MI/FS. NORTH lini.l.VMOOll
MINI'
MKTA.I.
NANK
ASI )
• -4*
ASM
4-12-
ASM
•-*•
ASM
4-12-
ASIS
ASI4
4-12'
ASI4
• -A-
ASM
4-12'
ASH
§-*•
ASH
4-12'
ASIC
• •A"
ASIC
4-12'
II. I
IS.)
COMMENTS
ARSENIC
•ERTLLIII
LEAD
NICKEL
I INC
STRONTIII
corritR
•ARIUN
CNROMIIIM
CADMIUM
ALUMIHIM I4lfl*
HCRCURV NO
VANADIUM 21.4
isa
NO
*.•
• .SI]
22.9
12.1
21. •
4.4
• .«
1*4
NO
N
MO
2.4
!».•
NO
NO
NO
2.4
NO
.II
NO
II. I
NO
NO
NO
NO
1.2
NO
NO
Nil
Nil
Nil
Nil
NO
2*4
NO
Nil
NO
2.2
I.I
l.«
NO
Nil
22. I
NO
• .•
II*
NO
Nil
NO
NO
1.2
NO
NO
Nil
NO
NO
-•*
1.4
• .1
14.2
9.1
NO
114
NO
NO
I.
• .
1.
M.
NO
NO
4*.
NO
I
Ml
4
1
NO
Nil'
NO
NO
4.(
I.I
•.*••
1*.S
14.1
II. •
2*. 4
4.1
III*
NO
• .91
911*
NO
14. •
9.1
• .429
!•.«
11.4
11.4
14. •
• .4
244
NO
• .II
111*
NO
14.2
l.<
• .1
24.
19.
12.
4.
II.
141
NO
*.l
911*
NO
11.4
I 4.4
H4 *.9*4
12.9
II. 1
14.1
4.1
9.1
112
NO
2 * . 1 2
11**
NO
1 1.4
HBTAL
NAHB
ACI*
•-4"
All*
4-12'
ASI«
•-4"
AS2*
4-12-
COHHENTS
ARSENIC
•MILLIU
LKAO
NICKCL
• INC
•THONTIU
corn*
•A*IUN
CHROMIUM
CAOMIUN
ALUMINUM
NERCURV
VANADIUM
II.1
• .242
19.
44.
41.
II.
21.
114
NO
• .44
9I*«
NO
41.2
• .9
• .494
91.•
• 4.1
114.4
II.•
44.2
141
NO
• .21
*•*•
• ••41
21.4
II.•
• .911
22.
24.
121.
II.
29.
114
NO
• .14
!•*••
• ••24
21.•
M
1.9
• .114
19.
14.
II.
II.
**.
II.»
NO
14. I
I »li il.i
-------
»: I
Ain.t
Ml fAl. ANAI.VSIS |»|/h<||
IIOIIHII 4. SlIMfAClJ SOIL SAHI'I.|:.S
MIITI »m:iif4i ni/IT.. MOUTH n«i I.VHIHIII mini*
COMPOUND
NAMK
Iflist • ASl-44 AS2-44 ASl-44 AS4-04 ASSHfc AS! 04 AS044 AS? 84 ASI*-44 ASII-*4 ASI2-44 ASI l-*4
cltac.l
SAMPLE N
ARSENIC 9.«2
•ERVLLIU HO
LEAO 4.44
NICKEL HO
•INC 24.S
•fRONTIII S.49
corn* s.4«
•ARIUM 49.9
CHROMIUM I*.2
CADMIUM HO
ALUMINUM 4988.*
HERCUMr NO
VANAOIUM 11.*
COMPOUND
HAM*
(flfflt • ASI4-44 ASIS-C4 ASI4-V4 ASI7-I4 ASI9-44 AS2*-I4 AS2I-M AS12-44 AS21-44 AS24-44 AS2V 44 AS14 44 ASH 04
chat.|
SAMPLE N
AR0KNIC 1.42
•••VU.IH HO
LIAO I.2S
HICKEL HO
•INC 4.41
•fRONTIU 1.47
corn* 0.02
•ARIUM II.S
CHROMIUM NO
CADMIUM NO
ALUMINUM 1290.*
MERCURY NO
VANAOIUM I.S*
11. 7
NO
9.14
• .11
1S.I
14.1
• .•4
44.4
24.4
NO
71S0.4)
NO
12.4
!•.?
NO
• .!•
• .11
2«.«
5.1*
4.42
Sl.t
II. 1
NO
14IR.4)
NO
21.9
• .74
NO
IS.*
!•.«
4«.»
!•.•
1.21
141. •
21.7
NO
794C.4)
NO
11.7
11.9
NO
!•••
• .IS
11.9
9.S4
1.94
14.1
14. »
NO
74*4.4)
Nil
14.2
S.%4
Nit •
9. 14
4.1*
21. •
4.94
4.41
*%.*
11. S •
Nil
4/H4.4
Nil
11.4
41. 4
NO
IS*.*
41.1
114.*
14.4*
41.4*
191.*
24.4
Nl>
444*. *
I.S4
II. I
4.41
NO
1.11
S.4*
21. S
1.44
2.2*
41. •
1.44
NO
141*. •
NO
I*. 9
11.2
NO
7.S*
4. IS
24.4
7.44
• .•«
M.4
14.4
NO
441*. *
Nil
12.1
4.1*
NO
4.2S
NO
17.9
4.29
S.4I
49. «
9.21
NO
14I4.4)
NO
II. 1
9.99
NO
*.7S
4.44
24.7
S.44
S.S4
S4.I
11.9*
Nil
SS2*.*
Nil
4.41
10.4
NO
IR.0
• ./S
21.1
4.«4
1.79
74.4
11.9
NO
42MI.*
NO
14.4
1.44
NO
I.2S
MO
4.S9
1.44
NO
24.4
2.4*
NO
14)0.8
NO
2.24
».44
NO
5.41
• .11
14. •
?.*2
2.2*
41.1
4.42
NO
441*. •
NO
7.41
4.91
NO
S.88
».I4
12.9
• .49
1.22
44.1
IS.I
NO
S4I0.*
NO
18. S
I*.S
NO
l.ll
*.IS
2S.4
S.0I
2.19
10. S
9. 14
NO
1440.0
Nil
IH.4
II.*
NO
II.
44.
41.
11.
l«.
9*.
12.
Nil
J/10.0
• .14
1'. 1
9.4*
NO
9.1*
S.41
21. S
4.47
4. IS
44.1
12.4
Nil
*000.*
NO
4. 11
7.17
NO
4.44
*.7S
24.2
4.44
4.72
41.)
17. 1
NO
7400.0
NO
II. 1
7.21
NO
7.1*
S.41
11.1
4.79
S.S4
SI.*
10. S
NO
1140.*
Nil
4.91
0.10
NO
l*.4
4.11
41.1
4.90
7.40
00.0
14.7
Nil
4990.*
NO
I*. 4
II. S
NO
0.11
4. IS
24.4
4. IS
9.14
SI. 9
11.4
NO
SI/8.*
• .IS
Mil
4.99
NO
4. 14
NO
IS. 4
I.S9
4.24
24.4
4.4*
NO
12/0.0
Nil
S.«t
9.1*
NO
7.40
NO
21.4
4.40
14.1
44.4
11.0
NO
41/8.8
Nil
14. 1
-------
r*M
it* i
Nl.TM. *MM.*klS |V|/k'||
•IIIIMI I. MUtV MIVCB StlllMCMr SAMMIS
m/rs. NIIMM MOLLIMOIUI uunr
COMHMMIO
MAIM
MSI
MS 4
• -•*
MM
»-•*•
Mkl
• f
MSI
MS«
»-!!•
COHMKMTS
ftBSIHIC
•••fix HIM
11*0
MICH I.
• IMC
ttBOMTIUM
corn*
•AMI UN
CftOHIUM
*t UN I HIM
VkMAOIUH
a.tti
11.
it.
n.
It!
MO
a.ia
atia
MO
ia.t
a.tll
ia.
i.
it.
ia.
is.
ta.
MO
a.ti
a.t
a.tu
ia.
a.
n.
ii.
it.
^i«t
MO
a it
a.4ia
• .t
• .I
it.t
11.1
II.t .
in ;
MO
a. ja
MO
n.a
MO
i«.a
a.ata
it.a
a.i
a.tti
MO
at.
MO
a.ii
n«a
a.att
n.i
a.(
ia.
i.
it.
a.
it.
ti.
MO
a.i
!%•
MO
It.
ua 9.\
t.
t.
at.
9.
1*.
ai.
•0
t a.i
tua
Ma
i n. i
tai
t
i
I -1,11. i I I
-------
ATTACHMENT A
NORTH HOLLYWOOD DUMP SITE
PROPOSED PLAN
-------
Superfund
Proposed Plan Fact Sheet
wEPA
North Hollywood
Dump Site
Memphis, Tennessee
June 1990
•-
INTRODUCTION
This Proposed P'an is issued to describe me alternatives that
th« U.S. Environmental Protection Agency (EPA) has con-
stdered for the eea^uo of the North Hollywood Ourrp Na-
tional Priorities Lst (NPL) Site (the site) located m Memphis.
Tennessee (see Figure 1). This plan presents an evaluation
of c'eanup afte^atives. including the aAernatrves preferred
by EPA. The alternatives summarized are described in
greater detail ~ :he Pemeeiai Investigation (Rl) and Feasibil-
ity Study (FS) Reports which are available, with the site's Ad-
ministrative Record, at the information rtoosnory 'ocated at
the Memphis-Shelby County Public Library. 185C Peaoody
'venue. Memphis. Tenntsste
A supplemental Rl was conducted and an FS was pr*oar«d
by some of the potentially responsible parties (PRPs, under
a Commissioner's Order from the State of Tennessee The
State of Tennessee was the lead agency for the s.te from
1985 until late 1988. when site lead was transferred to EPA.
The Si ate of Tennessee now acts as a support agency for this
site.
deci-
The alternatives EPA prefers represent a
sion. subject to pubK comment. Section Ii7(ai of the
Comprehensive Environmental Response, Comsensat'C-n
and Lability Act (CERCLA) of 1980. as amended by tr>e
Suoerfund Amendments and Reauthonzaton Ac SARA . o'
1936. requires publication of a notice and or>ef ara ,s s :' a
FIGURE 1. Location Map, North Hollywood Dump Site
-------
Proposed Pi*" 'or sit* remediation. This plan provides
baog'ound information on th* sit*, describes In* remedial
alternatives, provides the rational* lor identification of th*
preferred alternatives, and outlines ;r« roi* of th* pubic m
-e o^g EPA makftafinaJ decisionon »'emedy.
EPA encourages th* pubic to submit written comments on all
alter-atives pr*s*nt*d m this plan Public comments *nay
resul m selection of alternatives other than the on*s pre-
ferred by EPA for the sita
SlTg BACKGROUND
Th* North Hollywood Dump was a municipal landfill that
operated from the mid-1930's until th* mid-1960's. Th*
landfill was used primarily lor th* disposal of muncipal
refuse; nowever, industrial refuse was aiso disposed m the
landfill.
Th* sit* i* divided by Hollywood Street into two separate
areas of refuse disposal: th* East and West Sectors. Conv
b.ned. the East and West Sectors encompass an area of ap-
proximately seventy acres and have an average refuse layer
of 26.5 feet (see Figure 2).
Although disposal records for the site are not available, aenal
pnotographs of the Memphis area between 1937 and 1979
snow horizontal eipansion of the site between the mid-
1930's to the m.d-1950'8. During th* mid to 'ate '95Cs
active burning was evident and by th* ate 1950s expats sr
of th* dump was primarily vencal instead of horizontal 1>e
landfill expanded quickly m the 1960's from under so ac-
•oovw 70 acres. By 1967. legal disposal had ceased at'
site although unauthorized dumping occurred m th* 1970 „
In 1979. EPA and th* State of Tennesse* began mves: gat-
ing this site due to concerns regarding the ooss>bie disoosai
of hazardous substances in th* landfill initial studi*s con-
duced by EPA. U S Geological Survey (USCS) and local
authorities identif.ed chemicals in the dump that had tre
potential to cause adverse rt*aitn and environmental ejects
Based on th* results of mesa studies, a Technical Action
Group was formed in 1980. The group consisted of person-
nel from the following agencies: EPA Regan IV. the Tennes-
see Department of Hearth and Environment (TNOHEj. the
C
-------
»re discussed, however, it WM determined by EPA that
Irt-ooai data was needed before selectcn of a final rem-
Upon nof cat.cn by EPA. agroupof PRPs agreed to perform
a suooiementai Rl/FS m 1985. At that time, the State of
Tennessee became the lead agency and issued a
Commissioner s Order under whicfl tfe supplemental RlFS
would o« performed T>e Slat* c* Tennessee was th* lead
agency from 1985 to 'ate 1988 wr«n EPA Region IV became
m* lead agency. The supplemental Rl and FS Reports were
finalized in Apnl and May 1990. respectively.
Th« finding of the supplemental Rl confirmed the presence of
contaminants at the site, in shallowgroundwater beneath the
site and in sediments of adjacent surface water impound-
ments (Oxbow Lade, and dredge pond). The following lists
the major contaminants detected at the site:
Chtordane
Aldrm
Heptachior
Total BHC
Heptachtor Epoxide
4. 4 DOT
Oieldrin
Chromium
Arsenic
Barium
Nickel
Lead
Copper
Z:nc
Vanadium
Endnn
The Proposed Plan accesses two identified areas of con-
»rn associated with tre site. The first area accressad
;iudes the site wastes ard tre Fluvial Sand Unit (shallow
,roundwater) that discharge to the Wolf River. The second
area addressed includes the secernent and fish-in adjacent
surface water impoundments.
SCOPE AND ROLE OF RESPQNSg ACTION
The dump wastes, cor.tamirated soil, surf'eial groundwater
and pond seciments are under consideration for cleanup. A
remedy for th* sne and unoertying surfcial groundwater is
proposed to protect public health and the environment by
controlling exposure to contaminated materials and control-
ling migration of contaminants into surrounding soils, sedi-
ments, and surface water. The contaminated shallow
groundwater b*n*ath the sit* is not used as a drinking water
source due to well restrictions imposed by Shelby County. In
addition, the groundwater underlying the sit* discharges
directly into the Wolf River and do** not l*«v* th* sit* in any
other direction. For th*s* reasons, th* shallow groundwater
is evaluated based on its effects on the Wolf River, not as a
drinking water source. A remedy for th* impoundment
sediments is proposed to protect pubfic health and th*
environment by controlling the ingestion and accumulation of
contaminants by flora and fauna, especially fish, in Oxbow
Lake and the dredge pond. The preferred alternatives will
address the dump wastes, contaminated soil, surfcial
groundwater and pond sediments as one response action.
Th* two preferred alternatives, one* implemented, should
complete the response action at this sit*.
«• remedial alternates under consideration are presented
slow. The FS Report pr***nts amor* thorough description
and evaluation of these alternatives. The Administrative
Record, when contains the FS Report along with other docu-
ments and correspondence that are used to decide the site
remedies, is available for pubic review at the site mformatcn
repository, located at the Memphis- Shelby County Public
Library. 1850 Peabody Avenue. Memphis. Tennessee.
Based on n*w inform at en or public comments, EPA in
consultation with the State of Tennessee, may modify the
preferred alternatives or select another response actxsn
presented >n the Proposed Plan and the FS Report. The
pubic >s encouraged to review and comment on all alterna-
tives 'dentrt.ed.
SUMMARY OF SITE RISKS
Ounng the supplemental Rl/f S. an analysis was conducted
to estimate th* health or environment at problems that could
result if th* contamination at th* sit* was not remediated.
This analysis, commonly referred to as a baseline nsk
assessment, focused on the health effects that could ••suit
from long-term direct exposure to high concentratcns of the
contaminants as a result of ingesting the fish or having the
skin com* in contact with th* soil or surface water.
Groundwater contaminated by the sita flows directly mto the
Wolf River and is not accessible as a drinking wa'er source
du* to th* prohibition imposed by Shelby Courty for tr^e
installation of shallow wells and borings throughout the
county. Therefore, there should be no pathway of direct
exposure to contaminated groundwater. However, to pro-
vide greater assurance that institutional control will prevent
the use of th* shallow groundwater beneath the North
Hollywood Dump, vanancas m state and local groune«atar
standards for the srfe area will be sought so that grc^Cwater
us* restrictions could be placed on property deads.
Risk of long-term exposure to contaminants from the site
were calculated based on major contaminants detected at
th* sit* when included potential human carcinogens. Car-
cinogenic nsks are expressed as the probability of additional
cancer nsks resulting from a lifetime of exposure. For non-
carcinogens, the Agency evaluates the risk by determining a
Hazard Index (HI). The HI is a number that reflects a
comparison of the calculated exposure level for a contami-
nant at the site to an exposure level that would not cause
harm from daily exposure for a lifetime i.e.. the reference
dose (RIO). A HI greater than 1.0 indicates that exposure
exceeds the protective level. These estimated risk calcula-
tions were based on present conditions at the site including
the temporary cap and no major increases of contaminants
in the shallow aquifer which discharge* into the Wolf River.
Allowable groundwater concentrations for discharge to the
Wolf River were set based on Federal, state and local water
quality standards for carcinogens using a 10* risk from
exposure through ingestion of contaminated fish.
The HI calculated for exposure to non-carcinogens in the soil
and surface waters at the site were well below 1.0. Therefore.
these substances are not present at levels that would be
expected to cause concern. Lkewae. exposure to carcino-
genic compounds through soil or surface water contact was
also determined not to be a health concern. Risk calculations
based on assumed possible exposure pathways yielded an
uppertound lifetime risk of less than 10*. Risk from the
ingestion of aquatic organisms and fish in the stretch of the
Wolf River impacted by the site was also determined to be
Page 3
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be"ow the levels o' concern However. health ';$ks from long.
term (70 years) exposure to carcinogenic compounds from
the si* >n f'Sh obtained from the Oxbow La«« and dredge
pond were found to present concern for those who consume
contaminated fish caught from these. areas as a. sease Control in
1985 at me request of the US. EPA found no evidence of
increased hearth effects among persons living m the Holly-
wood area that could be attributed to the North Hollywood
Dump. Also, this risk calculation is based on contaminant
levels measured during the original Rl. Changes in condi-
tions that could affect the risk are likery to have occurred since
that time. Additional contaminant measurement to evaluate
this situation win be conducted during the remedial design
phase of the project Actual or threatened future releases of
hazardous substances from this site, if not addressed by the
preferred alternatives or one of the active measures consid-
ered. may present an endangermentto public health, welfare
or the environment, including possible exposure to hazard*
ous substances should the temporary cover erode.
o
UMMARY OP ALTERNATIVES
Landfill
and Shallow Groundwataf
The following i;sts the remedial alternatives under considera-
tion (or the lancMi wastes and shallow groundwater. The FS
Report contains a more detailed evaluation of each alterna-
tive.
1. No Action;
2. Low Permeaoi.'ty Soil Cover:
3. Low Permeabii-ty Soil Cover and groundwater extraction
with discharge to sewer system for treatment; and
4. Low PermeaOiiity Sol Cover and physical containment by
barrier wall.
All these alternatives involve restrictions on land and well use
at the sue, upkeep of the fence and property, and monitoring
to assess the effectiveness of the remedy.
ALTERNATIVE 1; NQ ACTION
Present Worth (PW) Cost: $2.338.670
Years to Implement: 0
CERCLA requires that the *No Action* alternative be consid-
ered at every site. Under this alternative, no soil, sediment.
or groundwater containment or treatment would take place.
The only reduction of contaminant levels would occur via
natural processes such as dispersion and attenuation. The
only costs would be for monitoring the site.
ALTERNATIVE 2: LOW PERMEABILITY SOIL COVER
Present Worth Cost: S4.942.950
PW Capital Cost: $3.364.260
PW O & M Cost: $1 .578.670
Years to Implement: 1
The existing low permeability cover onsite will be upgraded
to meet the sanitary landfill standards and the existing fence
will be completed around the perimeter of the site. Exc*--
tion of the buned wastes and contaminated sod
-------
sad o<* c-rrent informavcr. these a.te'ratves orcvde the
_est ba'anc* among the nine cnter.a that EPA uses to
evaluate alteratives. The following analyses section pro-
vides a g:ossacr
Alternative 2 and less for Alternative 3 and Alternative 4 The
lowest degree of short-term effectiveness >s achieved by
Alternative 4.
The construction of the low permeability soil landfill cover ;n
Alternative 2 will result m the least amount of nsx to the
community, wofterj and tr*e environment. The primary ri$*s
to the community and workers will be due to airborne dust
emissions wnereas the main impact of the environment will
bs due to potential increased sediment loadings to the
adjacent surface water bodies m the short-term. These »:sks.
however, are readily controlled and mitigated. These poten-
tial impacts are common to all three of the alternatives which
involve upgrading the existing cover.
Alternative 3 will increase the potential nsk to workers due to
the increased contact with contaminated media. However.
this nsk to the worker is readily addressed by enforcing an
appropriate health and safety program dunng construction.
Alternative 4 will present potential risks to the workers and
community which will be more difficult to address. The
construction of the containment wall in Alternative 4 will likely
encounter landfilled wastes along the landfill perimeter.
Consequently, the implementation of this alternative would
prestnt a greater nsk to workers and the community than for
the other remedial alternatives due to the potential for sancus
site incidents to occur.
Imalementablllhr
The implerrentability of an alternative is based on tacm.cai
feasibility, administrative feasibility and availably of serv-
ices and materials. The construction and materials of tre
upgraded iow permeability soil landfill cover for Alternatives
2 through 4 util.zes standard construction techniques and
can be completed within a single construction season
Consequently, the implementation of this component of
these remedial alternatives will not bs of concern.
The primary difficulty which is anticipated for Alternative 3 is
tne inherent problem in evaluating the hydraulic performance
of the system due to the hydraulic charactenstcs of the
shallow aquifer and the proximity of the Wolf River. By
comparison, the implementation of Alternative 4 is antici-
pated to encounter numerous difficulties. The constructabil-
ity of the containment wad is the major impiementability
concern. Due to geologic conditions at the site, the integrity
of a constructed containment wall will be questionable, in
addition, the existing topography is not well-suited to the
construction of a containment wall. Other implementabihry
concerns include the anticipated interference of adjacent
structures, the stability of landfill slopes, and the availability
of suitable clay backfill
Cost
The present worth cost associated with Alternative 1 is $
2.338.670. The estimated present worth cost of Alternative
2 is $4.942.950. Alternative 3 is $ 6,778.620. and Alternative
4 is $13,251.555. The present worth value repiesant* the
total cost of the remediatcn expressed in today's dollars
-------
Alternatives 3 and 4 arc not cost effective for present site
conditions S
-------
i.nated sediments in the impoundments to conta " them
place and remove them from the pathway of eipcsure to
the fish.
ALTERNATIVE S IN-PLACE CONTAINMENT BY
*1A,TI IPAL OPPOSITION AND PEHQUTINn OP
WQLFRlVgH
Present Worth Cost: S2.263.130
PW Caortal Cost $2.224.700
PW O4M Cost: $38.430
Years to Implement: 10
Alternative S consists of diverting the Wolf River thrown the
impoundments and utilizing natural sedimentation :o cover
the contaminated sediments.
ALTERNATIVE S: EXCAVATE WITH CONTAINMENT QN
EAST SECTOR OP LANGFILL AND IN-PLACE
CONTAINMENT WITH HYDRAULIC FILL
Present Worth Cost: S2.988.860
PW Capital Cost: $2.945.850
PWOAMCost: $43.010
Years to Implement: 10
Alternative 6 consists of excavation of contaminated sedi-
ments at shallow water depths with onsite disposal like
Alternative 3 and the in-place containment of contaminated
--nom sediments with hydraulic fill like Alternative 4. Appli-
ibie RCRA LORs will be met for the sediment placed m the
andMI.
EVALUATION QP ALTERNATIVES
The preferred alternative for remediation of the surface water
impoundments at the North Hollywood Dump Site >s Alterna-
tive 4. Alternative 4 involves the m-place containment of
contaminated sediments using hydraulic fill. This includes
placement of an even layer of fill over contaminated sedi-
ments to prevent contact with the impoundments aquatic
biota and monitoring to ensure the effectiveness and perma-
nence of the remedy. Based on current information, this
alternative provides the best balance among the mnecritena.
ANALYSIS
Overall Protection of Humin Hearth end the
Environment
All the alternative* presented in this document except for No
Action would be protective of human health; however. Alter-
native 2 does not provide a degree of protection to the envi-
ronment. The No Action alternative is not protective because
it allows bcaccumulation of contaminants by wildlife in the
impoundment and the possible human ingest on of contami-
nated fish. Alternative 2 does not prevent bioaccumulation in
the wildlife population. Alternative 3 through 6 prevent the
biota in the impoundment from coming in contact with or
'ngesting contaminated sediments.
-omollence with Applicable or Relevant end
Appropriate Requirements
All alternatives except for No Action and Alternative 5 would
comply with ARAfis. The No Actcn alternative would allow
the levels of contaminants m the edible portons of *>sh to
remain above health risk levels. Alternative 5 would not
comply with the U S Army Corps of Engineers regulatory
program requirements. The other alternatives would return
fish contamination levels to beiow acceptable standards and
would meet applicable RCRA LORs. surface water quality
standards, closure reguiatans. and effluent discharge re-
quirements.
Reduction of Toxleltv. Mobility or Volume
Since none of the remedial alternatives wtH invoke the
treatment of the contaminated sediments, there w.ii 5e no
reduction m the toxcity, or volume of contaminants associ-
ated with bottom sediments.
Due to the removal and securement of the bottom sedirr ent s.
Alternatives 3. S. and 6 will result in a significant reduction in
environmental mobility and mass of contaminants m the
aquatic environment, but not for the whole site since the
sediments will be placed m the landfill. Alternatives 4.5. and
6 will result in a significant reduction in environmental mobility
due to the isolation of contaminated sediments below a lay er
of dean fill. v
Lone-Term Effectiveness)
All of the alternatives except No Action would provide long-
term effectiveness; however, there is no permanence asso-
ciated with Alternative 2. Once the contaminated sec..-^ers
are no longer accessible to the impoundments' Dicta 'or
accumulation, f isfl tissue concentrations will start tfee-aas.rg
and return to acceptable levels.
Short-Term Effectiveness
An estimated ten years will be necessary to ac^eve tr*e
remedial action goals for the decreased contaminant con-
centration levels m the impoundment fish for all of :ne
alternatives except No Action and fish harvesting. During
that time the community will be protected from short-term risk
from fish consumption through institutional controls warning
persons of fishing hazards. Short-term human exposure
through contact with contaminated sediments during the
remediation will be controlled through health and safety
procedures.
The primary differences between the alternatives are the
extent of the potential environmental impact related to im-
plementation. Alternative 4 does not require the handling of
contaminated sediments whereas the other aftematrves
involve dredging/excavation activities which may potentially
impact workers and the community. Consequently, this
alternative is considered to have a greater degree of short-
term effectiveness. The potential for short-term impacts
associated with Alternative 3 is deemed to be marginally
greater than the potential tor impacts associated with the
implementation of Alternative 6. This difference is primarily
due to the nature of the work and recognizes that dredging is
less readily controlled than mechanical excavation and that
there are hazards to the community and the environment
which are inherent to the operation of liquid impoundments.
Alternative 5 is deemed to be the least effective of the
alternatives in the short-term due to the potential impacts to
Page 7
-------
the WoN Rivtr and ad|0-nmg floodp.'am. The potential im-
pacts from the implementation oi this alternative art not
to the immediate area of the impoundments.
The .mpiementabilrty of art alternative is based on technical
feasb'"ty. aominsfavve ?eas.b«iity and me avaiUOiiity of
sen/eas and materials.
There art no major concerns regarding the impiementability
of A.terratrves 2 and 4. Alternatives 3 and 6. However. arc
cons.dered difficult to implement due to the degree of dewa-
ttrmg of the abandoned dredge pond which is required. In
addition, the implementation of Alternative 3 will be limited by
the size of the dredge pond, the ability to accommodate
significant changes m the volume of material to be handled.
and the required length of the construction penod. ARerna-
tive 3 also requires the wet handling of contaminated sedi-
ments which may be difficult. The technical feasibility of
settling out dredged sediments without the us* of flocculants
a uncertain. This factor will potentially r-ave a s^nificant
impact on the implementability of this alternative. Conse-
quently. Alternative 3 is considered to be the most difficult to
implement and the most sensitive to potential implementa-
tion problems.
The impienentability of Alternative 5 is anticpated to be
limited by administrative and environmental corcerns. Due
to the potential environmental impact of this alterative, t is
anticipate :rat the imp.anentation of this alter at.ve will be
delayed significantly.
Coat
The present worth cost of Alternative t is $408.500. Alterna-
tive 2 *as an estimated present worth cost of $340.910
including Ooaranons and Maintenance (O4M) costs. The
estimated present worth of Alternative 3 is $2.341.885.
Alternative 4 is $3.098.940. Alternative S « $2.263.130 and
Alternative 6 is $2.988.860.
The indirect capital costs for several of these alternatives,
however, are highly sensitive to changes in the volume of
contaminated sediments to be handled. Alternative 3 is the
most sensitive to volume changes whereas Alternative 4 is
the least sensitive. Due to the required partial eicavation of
contaminated sediments, the indirect capital costs for Alter-
natives 5 and 6 are moderately sensitive. Consequently, the
indirect capital costs associated with Alternative* 3. 5. and 6
could vary significantly once the lateral and vertical extent of
sediments to be removed is refined by the results from the
preconstruction sediment sampling program.
State Acceptance
The State of Tennessee has assisted EPA in the review of
reports and site evaluations. The State has reviewed and
tentatively agrees with the proposed remedy for the im-
poundments and is awaiting public comment before final
concurrence.
Community Acceptance.
Community acceptance of the various alternatives will be
evaluated during the public comment percd and w.'l oe
described in the ROD for the site.
The Preferred Alternative.
The preferred alternative • Alternative 4 • involves the con-
tainment of contaminated sediment to prevent beta contact
with and accumuiaton of the site contaminants found at
elevated risk levels. Alternative 4 mvorves containment o»
contaminants through fill or cover over the contaminated
areas and institutional controls on fishing until acceotaoie
fish tissue levels are reached. Alternative 4 has the '
-------
Memphis-Shelby County Pubic Library and
Information Center
850 Ptaoody Avenue
Memphis. Tennessee 33104
(90') 725-8821
Contact: Ms Jan Condren
LIST QP CONTACTS
Implementablllty: is the technical and administrative
-------
openings >n rocks to the point of saturation. Unlike surface
water, groundwater cannot dean itself by eiposure to sun or
raps usually
located in a public building that « convenient for local
residents, such as a pubic school, city hall, or a library. As
the site proceeds through the Superfund Remedial Process,
the file at the information repository « continually updated.
Monitoring: The continued collection of information about
the environment that helps gauge the effectiveness ol •
cleanup action.
Potential Responsible Parties (PRPs): This may be an
individual, a company or a group of companies who may
have contributed to the hazardous conditions at a site. These
parties may be held liable for costs of the remedial activities
by the EPA through CERCLA laws.
Preferred Alternative After evaluating and examining the
various remedial alternatives. EPA selects the best alterna-
tive based on relevant cost and non-cost factors.
Proposed Plan: A fact shaet summarizing EPA's preferred
c.'eanwO strategy tor an NPL s.te. the rationale lor tne prefer-
ence and reviews of the alternatives presented m the detailed
of the remedial .nves; gaticnfeasibility study.
Resource Conservation and Recovery Act (RCRA): A
Federal law that established a regulatory system to track
hazardous substances from the time of generation to dis-
posal. The law requires safe and secure procedures to *
used in treating, transporting, stonng. and disposing
hazardous substances. RCRA is designed to prevent new.
uncontrolled hazardous waste sites.
Record of Decision (ROD): A pubic document that explains
which cleanup alternative will be used at a National Priorities
Ust site and the reasons 'or choosing that cleanup alternative
over other possibilities.
Remedial Alternatives: A list of the most technologically
feasible alternatives for a remedial strategy.
Remedial Investigation and Feasibility Study (Ri/FS).
Two distinct but related studies, normally conducted to-
gether, intended to define the nature and extent of contami-
nation at a site (Rl) and to evaluate appropriate, site-specf e
remedies necessary to achieve final cleanup at the site (FS).
Responsiveness Summary: A summary of oral and/or
written public comments received by EPA during a comment
period.
Superfund Amendments and Reauthorlzstlon Act
(SARA): Modifications to CERCLA enacted on October 17.
1986.
Total BHC: A man-made chemical that exists in 9.5":
different chemical forms that are used as .nsecrotfas Wn «
no longer available, the most commonly usad was li
Page 10
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MAILING LIST ADDITIONS
To be placed on the mailing list for the North Hollywood Dump Site.
please complete this form and mail to:
Ms. Suzanne Durham
Community Relations Coordinator. U.S. EPA. Region IV
345 Counland Street. N£.. Atlanta. GA 3036S
Name
Address —
Affiliation
Telephone
,J
United States
Environmental Protection Agency
Region 4
345 Courtland Street. NE
Atlanta, GA 30365
Official Business
Penalty for Private Use
$300
-------
ATTACHMENT 3
NORTH HOLLYWOOD DUMP SITE
PUBLIC MEETING SIGN IN SHEETS
-------
Public Meeting Sign In Sheet
June 28, 90
Name
Address
Telephone
Nuaber
Afflllal ion
Uu you want: t.o
be Included on
Che nailing list?
How did you learn about tltln
•eel Ing 7
1 1
M
/i
-------
Public Meeiin
-------
Public Meeting Sign In Sheet
June 28, 90
/lane
Address
Telephone
Nunber
ATf llialinu
Uu you want to
be Included on
the nailing list
How did you Lcani uhuul llils
•eel lnj»?
JAbu*
T u
-y^
o
\ft*>^.
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^
-------
ATTACHMENT C
NAMES. ADDRESSES AND TELEPHONE NUMBERS
OF THE INFORMATION REPOSITORIES DESIGNATED FOR
THE NORTH HOLLWOOD DUMP SITE
-------
1. Memphis-Shelby County Public Library and Information Center
1850 Peabody Avenue
Memphis. Tennessee 38104
(901) 725-8821
Contact: Ms. Jan Condren
2. EPA Record Center
345 Courtland Street, ME
Atlanta, Georgia 30365
(404) 347-0506
-------
ATTACHMENT 0
THE OFFICIAL TRANSCRIPT OF THE PUBLIC HEARING
ON THE PROPOSED PLAN FOR CLEANUP
OF THE NORTH HOLLYVOOD DUMP NATIONAL PRIORITIES LIST SITE
LOCATED IN MEMPHIS. TENNESSEE
-------
North Hollyvoc"**nu*p 8it«
Public Heating to In 8h««t
June 28, T990
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North Hollywood Dump Site
Public Meeting sign In aheet
June 28, 1990
Name
Address
Telephone
Nuwber
Afllllal Ion
Do you want to •
be Included on :
die Mil ing HitV
., ,.
liowdl4yfiM learn about this
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-------
North Hollywood "M»p Bite
Public Meeting 8 in Sheet
June 26,
Address
T«l«phone
Affiliation
Do you 'want to
b« Included on
che •ailing 1UC
•am about tillN'
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-------
ATTACH.Mt.V7 C
NAMES. ADDRESSES AND TELEPHONE NUMBERS
OF THE INFORMATION REPOSITORIES DESIGNATED FOR
THE NORTH HOLLYWOOD DUMP SITE
-------
i. Memphis-Shelby Councy Public Library and Information Center
1850 Peabody Avenue
Memphis, Tennessee 38104
(901) 725-8821
Contact: Ms. Jan Condren
2. EPA Record Center
345 Courcland Street. NE
Atlanta, Georgia 30365
(404) 347-0506
-------
ATTACHMENT 0
THE OFFICIAL TRANSCRIPT OF THE PUBLIC HEARING
ON THE PROPOSED PLAN FOR CLEANUP
OF THE NORTH HOLLYWOOD DUMP NATIONAL PRIORITIES LIST SITE
LOCATED IN MEMPHIS. TENNESSEE
-------
\
' \.
1 \
2
3 __ __
4
-5 PUBLIC HEARING ON THE PROPOSED
PLAN FOR THE CLEANUP OF THE NORTH HOLLYWOOD
6 DUMP NATIONAL PRIORITIES LIST SITE
LOCATED IN MEMPHIS, TENNESSEE
7
8
9
10
11
12
131
«
14 '
15 JUNE 28, 1990
16 7:30 p.m.
17 Board of Education
18 2597 Avery Avenue
19 Memphis, Tennessee
20
21
22
23
ORIGINAL
-------
1 PROCEEDINGS
MR. TAYLOR! First of all, I would
3 like to welcome everyone to the meeting. My name
4 is Harold Taylor, and I'll be the moderator, if
5 needed, tonight. I'm an employee with the United
6 States Environmental Protection Agency, Region
7 IV. And our office is located in Atlanta,
8 Georgia. From that office we do the federal
9 regulatory affairs for the eight southeastern
10 states. Currently, I am the acting chief of the
11 Tennessee/Kentucky remedial section in the EPA
12 Superfund program.
?" The purpose of the meeting tonight, as
It I'm sure you are aware, is to go over and present
15 to you the proposed plan for the remediation of
16 the North Hollywood Superfund Site. EPA has
17 basically planned to present to you and to solicit
18 comments from you. We'll go over a little bit
19 tonight about how we would like to do that.
20 X think the main objective of the meeting
21 tonight is to present to you what that plan is and
22 to tell you how you can get involved in community
23 relations and get involved in the final selection
-------
1 of the plan.
2 If I could just a minute, does everyone
3 have the handouts that were available at the
4 front? There are actually three handouts. One is
5 about a ten page beige document, which is actually
6 a fact sheet on the proposed plan that we'll be
7 discussing tonight. If you don't have a copy,
8 we'll be glad to present you one at the end of the
9 meeting, or if you raise your hand I'm sure
10 someone will get you one. The second is a white
11 document. It basically describes what the
12 Superfund process is. It's a good reference
13 document. The third is basically a two page beige
14 handout which has the agenda for tonight. If I
15 could, I'll ask you to turn to page two of that
16 handout.
17 As you see, we've got about an hour of
18 presentation that we would like to make to you.
19 We would like to go over a little bit of the
20 history of the site, where we currently are with
21 the site as far as the Superfund process, where
22 we're headed with the site, and a little bit about
23 how you can get involved in that process.
-------
We would like to go over the past
sampling that's been done at the site. And we
3 would like to go over briefly the risk assessment
4 that was done at the site. We would like to go
5 into a little more detail on the proposed plans,
6 the alternatives that have been considered and the
7 one that we're proposing to you here tonight.
9 And then we would like to reserve, the end
9 of the meeting for questions and answers. We have
10 a number of people here, that I'll go over in just
11 a minute, that surely can answer the majority of
12 your questions for you.
As you notice, there's a microphone in
*
14 the middle of the room. And, if I could, I would
IS ask you to refrain from asking questions during
16 the presentation, but make note of them. And then
17 after the formal presentation is finished what I
18 would like for you to do is use the microphone so
19 that everyone can hear what your question is and
20 so that we can basically have a record of what
21 your concerns are here tonight.
22 When you approach the microphone, I would
23 like for you to basically state your name and then
-------
1 the question. if you have a number of questions
2 tonight/ because of the number of people that are
3 here, I would like to ask that you at least
4 initially keep your questions to about five
5 minutes per person. If we have more time at the
6 end of the meeting, then we'll go back. if you
7 have more questions, we'll rotate and let you ask
8 your additional questions.
9 At the very end after we're through with
10 your questions if anyone would like to just have a
11 comment, we're here to receive your oral comments
12 today. We do have a stenographer who will be
13 recording your comments for EPA.
14 If I could, I would like to take just a
IS minute to introduce a few of the state and federal
16 people who are here tonight. On my left is
17 Felicia Barnett. Felicia works with me in EPA
18 Region IV ia Atlanta. She's the remedial project
19 manager for the North Hollywood site. She
20 basically coordinates all the functions as far as
21 EPA is concerned, and she's the one that basically
22 formats and writes the decision to the agency.
23 Over on Felicia's left -- Elmer, if you
-------
' could, raise your hand -- is Elmer Akin. Elmer is
2 our risk assessment coordinator. He works in both
3 the Superfund program and the ongoing RCRA
4 hazardous waste program.
S On Elmer's left is Suzanne Durham. And
6 Suzanne Durham, again, works for EPA Region IV.
7 She's the community relations coordinator for the
8 site. In addition to this site she works all the
9 sites in Tennessee, Kentucky, North Carolina, and
10 South Carolina community relations.
11 Over on my right is Richard Holland.
12 Richard Holland is with the Tennessee Department
1 of Public Health, Division Superfund, and he's out
14 of the Jackson office.
IS Over on Richard's right is Bruce
16 Monteith. And Bruce Monteith is a consultant of
17 Conestoga-Rovera fit Associates, and they are the
18 consultants who perform a lot of the remedial
19 investigations] at the site.
20 Rudy Collins -- Rudy, raise your hand --
21 is with the Tennessee Department of Public Health,
22 Division Superfund, out of the Jackson office.
23 Betty Manis (phonetically spelled), who
-------
1 is out of the Jackson office, Tennessee Division
2 of Superfund.
3 Linda Anderson-Carnahan. I'll get out
4 that hard name. Linda is with the office of
S policy and management with EPA.
6 Dave Hill is also EPA Region IV, and Dave
7 is with the groundwater technology unit.
8 Over here on my left, Chuck
9 Pietrosewicz. Chuck is with another federal
10 agency, the Agency for Toxic Substance and Disease
11 Registry. They are basically another agency from
12 EPA that was created to oversee and conduct health
13 assessments at Superfund sites.
14 I think that's basically'the people we
IS have here tonight. So I hope that any questions
16 that you have we can answer. Again, let me just
17 briefly go over, before we go into the history,
18 the Superfund process and where we are tonight.
19 As you are well aware, North Hollywood
20 has been a Superfund site for a number of years.
21 Basically the first part of the Superfund process
22 is listing a site on the National Priority List.
23 And North Hollywood was listed in the early
-------
8
1980'i.
2 The second step basically in the
3 Superfund process, if you want to sort of look, on
4 this white handout that I gave you, about the
5 third page, it has a flow chart of the Superfund
6 process. You'll see step three and four of the
7 remedial investigation feasibility studies, and we
8 would like to present to you tonight some of the
9 findings from the studies that have been conducted
10 at North Hollywood.
11 We're basically right in the middle at
12 number five which is public comments. We're here
1 tonight to basically present to you the plan that
14 we're proposing to go over, to answer any
15 questions that you may have, and tell you how you
16 can become involved in that decision making
17 process.
18 The next step after we've solicited your
19 comments will be to formalize the closure plan or
20 remediation plan for North Hollywood, and that
21 will be done so in what's recorded there as number
22 six as record of decision. And that will be
23 signed by the regional administrator of EPA Region
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1 IV. It will basically formalize the plan that EPA
2 has used at the site.
3 After the record of decision EPA will
4 basically negotiate with any potential responsible
5 parties that we've identified at the site to do
6 the remedial design. We hope to start the
7 remedial design on the project sometime at the end
t
8 of this year. Designs can take anywhere from six
9 months to a year to complete. Then the actual
10 remediation will occur at the EPA oversite.
11 There's basically two ways that can
12 happen. One, the potential responsible parties
13 can enter into and consent to a decree with EPA
«
14 which will be overseen by Federal District Court,
IS or the fund can go ahead and clean up and EPA will
16 hire the contractors and do the work.
17 With that brief introduction, I would
18 like to turn it over to Felicia Barnett who will
19 go over a little bit of the site history and where
20 we are presently with the North Hollywood site.
21 MS. BARNBTT: Hello, I'm Felicia
22 Barnett, and I'm the remedial project manager for
23 this site. I'm going to put a photo -- for most
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10
people, I'm sure that you know where the dump is
2 located/ bat I want to put this on the screen just
3 to look at.
4 The North Hollywood, dump was a municipal
S landfill that was run by the City of Memphis from
6 about the mid 1930's to the mid 1960's. It did
7 accept some industrial waste during that time.
8 And about the late 1970's it was determined that
9 there may be some health concerns. The community
10 was concerned and the state and EPA got together
11 and started working on some investigations of the
1? site. Also at that time a few of the PRP's,
1. potential responsibility parties, -that had placed
14 some of the industrial waste in the dump did come
IS in and help us do some study work on the site and
16 paid for some of it.
17 EPA in the early 1980's determined that
18 there was some emergency work that needed to be
19 done to protect the public health, and there was
20 emergency removal of some soil off the site. A
21 technical assistance group was formulated in the
22 early 1980's as the site was put on the National
23 Priorities List. This was mainly a federal EPA
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11
1 program, and the state officials. There were also
2 a few of the potential responsible parties in this
3 group.
4 When this group went out to study the
S dump and determine what potential hazards were
6 related to it, the studies were done and they were
7 evaluated by EPA. And in 1984 we tried to come up
8 with a remedy for the site. However, upon the
9 review of the data it was noted that we needed •
10 additional data to make a final remediation, and
11 we did do the emergency work that was needed.
12 There was a cover that was put on the site by some
13 potential responsible parties of about twelve
14 inches.
IS At that time in 1984 because there was
16 additional data that needed to be done, a
17 supplemental remedial investigation was put
18 together, and there were notice letters sent out
19 to potential responsible parties to come in and do
20 that work. Some of those responsible parties did
21 come forward and were put under a commissioner's
22 order from the State of Tennessee. The State of
23 Tennessee overviewed some more investigative work,
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12
and remedial investigation reports have been put
2 together.
3 In late 1988, because of overview
4 problems EPA took back, over the review of the
5 supplemental remedial investigation and the RI,
6 the feasibility study that was performed.
7 From this data we've come up with a
8 proposed plan that we're presenting to you this
9 evening, and we've reached the point of trying to
10 get to the record of decision for this site.
11 And from here I want to turn it over to
12 Suzanne Durham who will tell you a few things
1 about community relations.
14 ' MS. DURHAM: I'm Suzanne Durham,
IS Community Relations Coordinator for this site.
16 Community involvement is very important for the
17 Superfund sites and can have a tremendous impact
18 on decisions that are made at these sites. There
19 are nine criteria used in evaluating cleanup
20 alternatives. One of those is community
21 acceptance.
22 The purpose of our meeting tonight is to
23 present the findings of our investigation, to
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"II"
13
1 present the alternatives under consideration,
2 EPA's preferred alternative, and then to hear from
3 you, the affected community.
4 We very recently issued a Proposed Plan
5 Fact Sheet, one of these handouts you picked up at
6 the registration table, which summarizes the
7 findings of our investigations. We also sent an
8 administrative record to the Memphis-Shelby County
9 Public Library. This administrative record
10 contains all the documents EPA used in making its
11 preferred alternative decision.
12 I urge you to review those documents, to
13 ask us questions tonight, and to submit written
• » *•
14 comments to our agency. The comment period begins
IS today, June 28th, and runs through July 27th. If,
16 however, additional time is needed to prepare your
17 comments, we can grant an extension. Your request
18 for that extension must be in the regional office
19 within two weeks of today's meeting.
20 After the comment period closes, we
21 prepare a responsiveness summary which is a
22 document that will summarize your questions and
23 concerns and our responses to those questions and
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14
concerns. After careful consideration of your
2 comments* state comments, our regional
3 administrator will sign a record of decision which
4 will document in detail how we will go about site
S cleanup.
6 After signature of that record of
7 decision we will place a notice in your local
8 newspaper announcing our decision. And at that
9 point, the record of decision, a responsiveness
10 summary will become a part of the public record
11 and will be included in the administrative record
12 at the library.
/..
An excellent opportunity .for communities
14 to become involved 'in these decisions at sites in
IS their communities is through our Technical
16 Assistance Grant, or TAG program. Congress
17 recognizes that our documents are quite lengthy
18 and highly technical in nature, and we do now
19 offer a community group the opportunity to apply
20 for a grant in the amount of fifty thousand
21 dollars to hire technical advisors to interpret
22 our data. There is more information about the TAG
23 program in the handout that you picked up off the
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IS
\
1 registration table.
2 In summary, the goal of the community
3 relations program ia to keep you informed and
4 involved in complex decisions that are made within
5 your community. Felicia and I will be your two
6 contacts at EPA. Our names, addresses, and
7 telephone numbers are in that fact sheet. Feel
8 free to call either one of us at any time.
9 And now Bruce Monteith will talk with you
10 about sampling investigation at the site.
11 MR. MONTEITH: What I would like to
12 do tonight is just briefly summarize the sampling
13 that was completed at the North Hollywood dump as
»
14 part of the supplemental RI program. The sampling
IS completed was for purposes of generating data to
16 help develop the proposed plan, final
17 remediation. •
18 Just to highlight some of the pertinent
19 areas of the site, the landfill itself shown in
20 the green here is approximately seventy acres and
21 is divided by North Hollywood Street. The west
22 sector, which is this side, and the east sector
23 cover approximately the same area.
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16
There is also the abandoned dredge pond
« off to the east here. Oxbow Lake, which is the
3 original channel of Wolf River which is now an
4 isolated surface water body as a result of some
5 rechannelization of the Wolf River. There's also
6 what's referred to as a beaver pond. It's not
7 shown on here, but it's a small little wet area in
8 between the Oxbow Lake and the abandoned dredge
9 pond. And then the Wolf River, which drains from
10 east to west towards the Mississippi.
11 As Felicia identified, the initial work
12 that was completed was completed by the TAG group,
the Technical Action Group. And there was really
»
14 two objectives of .that group, some short-term
IS objectives, which included some remedial work on
16 the site to secure some areas, and then the larger
17 task was the initial RI/FS, or investigation of
18 the site itself. And that was divided into six
19 task elements which again included some data
20 collections, specifically collecting samples from
21 the Wolf River, the surface water bodies in the
22 area of the site, monitoring well installations,
23 and groundwater sampling, and some surface oil
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17
sampling around the property.
Subsequent to the initial RF that was
completed by the TAG there was a determination
made that there was some additional data that was
required for the site to, again, help develop the
final remedy. And this work was completed by the
PRP group that Felicia had mentioned, and the
specific objectives of that supplemental RI
program is listed here. And, again, the PRP group
developed a work plan which was designed to
collect the additional samples at the site to
augment the program completed initially by the
TAG.
In order to meet these objectives, the
supplemental RI work plan was divided into five
specific work tasks: Including sampling of the
landfill waste, a hydrogeological investigation
which included installation of some additional
groundwater monitoring wells, some water level
measurements of the Wolf River, and some of the
wells on the site, some four rounds of groundwater
sampling. There was also surface water and
sediment sampling of the Wolf River, some surface
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19
there was a number of wells installed around the
2 area of the site, including three background wells
3 which were to measure the groundwater quality
4 prior to it flowing underneath the landfill, as
5 well as a number of wells located along Wolf
6 River, both on the south side and the north side,
7 to try and find the hydraulics of the groundwater
8 system. The biggest question was whether the
9 groundwater did, in fact, discharge to the Wolf
10 River.
11 The results of the analysis of the
12 groundwater sampling demonstrated that it had
actually confirmed the work that had been done by
14 the TAG group which showed that there were some
IS areas that were impacted by the site directly
16 beneath the landfill and between the landfill and
17 the river and that, in fact, the groundwater did
18 discharge to the Wolf River. There was no flow
19 past the Wolf River.
20 Just to briefly summarize the hydraulics
21 of the system or the groundwater flow condition,
22 this just demonstrates the water is flowing from a
23 north to south direction to the Wolf River.
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20
1 Again, to help put the conditions of the
2 site in perspective, the green is showing the
3 landfill, the waste area. The groundwater that
4 was being investigated was within what's called
5 the fluvial sand unit, and that was the upper
6 aquifer. And it was found to be in direct contact
7 with the waste. And the arrows here show the
8 direction of groundwater flow. And through the
9 series .of nested wells around the site, as we've
10 demonstrated, the groundwater flows to the north
11 and then there's an upward flow to the Wolf
12 River.
13 In addition to the groundwater monitoring
14 that was completed at the site there was some
15 sampling of the Wolf River completed at four
16 locationst One being upgrading of the site, two
17 immediately adjacent to the site, and one
18 downstreaa of site. The river flow is from the
19 east to west direction to the Mississippi River.
20 At each of these locations there was a round of
21 sediment samples collected as well as a round of
22 surface water samples collected jointly for each
23 groundwater sampling round. The results of this
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21
1 sampling did not demonstrate that there was any
2 impact to the surface water and sediment quality
3 in the Wolf River caused by the site.
4 Zn addition to the sediment samples there
5 was some surface samples collected in the
S immediate area of the landfill and over around the
•
7 abandoned dredge pond area. The yellow dots were
8 the surface soil samples initially proposed under
9 the work plan. After that first round of sampling
10 there was a second round proposed, and some
11 additional surface soil samples were collected
}2 between these two areas trying to correlate the
•»
13 two areas.. The surface soil sampling included six
14 inch intervals down to a depth of eighteen
IS inches.
16 For the surface soil sampling there were
17 isolated locations where some of the site specific
18 constituents were detected at elevated levels, and
19 they were concentrated around the immediate area
20 landfill and at a fev locations along the east
21 side of the abandoned dredge pond.
22 And, finally, the last set of samples
23 collected. Again, this was not originally
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22
1 included under the work plan, but they were added
2 to the sampling program while it was being carried
3 out. There were samples collected from the final
4 cover which was placed over the landfill in 1984,
S and it was decided to collect the surface soil
6 samples at these locations just to try and
7 demonstrate whether the cover placed in 1984 had
8 been effective in securing the site.
9 And the results of the sampling here
10 again showed very isolated spots where there were
11 some site constituents detected, but they were in
12 areas where there had been identified erosional
13 problems when the cap was first p-ut on and over
14 the first year to two years where those erosional
15 problems had gradually been recovered and secured
16 again. So overall the sampling of the cap itself
17 demonstrated it had been effective in securing the
18 site.
19 Elmer Akin will now talk on the risk
20 assessments.
21 MR. AKINt We're real pleased that
22 there are more of you than there are of us
23 tonight. We have been in situations where we
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23
outnumber the audience. We really appreciate your
2 interest because we've done a lot of work here,
3 and we're very pleased with the site at this point
4 and maybe the end in sight.
5 I want to talk about quickly -- I really
6 want to be here to answer your questions later in
7 the meeting, but I want to just say a few things
8 about risk assessment.
9 There are really two types of risk
10 assessments or health evaluations that are done on
11 any Superfund site and were done on this site.
12 One is called a health assessment, and that's
j conducted by Chuck's group, ATSDR', the sister
14 federal agency that does a lot of the health work
IS at Superfund sites. The health assessment is an
16 evaluation to determine if there's any ill effect
17 or health hazards to any of the citizens of the
18 community from the site as it now exists. So
19 that's a look at the current situation, to sea if
20 anyone is harmed.
21 The part that I do, the risk assessment
22 part, is -- that I'm going to talk about here --
23 is that look at the long range, what effect this
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24
\
1 site might have to anyone who would come in
2 contact with it into the future. We look at a lot
3 of possibilities of waste that people could be
4 harmed from that site.
S One of the biggest jobs of risk
6 assessment is to determine what are the possible
7 ways that people could be harmed after long-term
8 exposure to that site. What about kids that might
9 get on that site, climb the fence, or ride their
10 bikes over there, fishing in the pond, dust coming v
11 off the site, water getting to the river, all
12 those possible ways, all that we can possibly come
13 up with where people might be harmed. Not that
14 they are, but they might be if this situation
15 happened.
16 That's part of the risk assessment
17 process, and the agency mandates that we do that
18 for each Superfund site. It requires a number of
19 skills to conduct that, tozicologists who know
20 about the toxic effects of chemicals, people like
21 Dave and Linda who are Involved in the ecology or
22 the movement of waters, hydrogeology, and that
23 type of thing to evaluate the possibility of
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25
contamination as it goes there.
2 w« think we've done a thorough evaluation
3 of this site relative to the possible future
4 exposure-ways, pathways. And we think, from the
5 work that Bruce has talked about, the site has
S been characterized from the standpoint of what
7 types of hazardous substances are there.
8 And you have kind of a brief summary of
9 the risk assessment -- everyone does have this,
10 right? The risk assessment is a technical report, .
11 but we try to make it so it's understandable. And
"» I'll certainly be here this evening to answer any
13 questions you might have about the risk
14 assessment. Thank you.
IS MS. BARNETT: I want to get back up
16 here and discuss the alternatives that we have
17 looked at for this site and the preferred
18 alternative that we've done. One of the things
19 that I think should be said is the majority of the
20 contaminants that we found to be of a concern when
21 we were evaluating the site were pesticides and
22 metals. These are relatively nonmobile. However,
23 they do have some high toxicities associated with
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26
1 them.
2 During the RZ and the PS, the RI samples
3 the site, identifies contaminants that we have
4 problems with, and the risk assessment is done to
5 determine areas that can have a long term risk.
6 And then, as part of the feasibility study, the
7 feasibility study also evaluates different
8 alternatives for the site using nine criteria that
9 EPA uses. One of which, if you can see, is
10 community acceptance.
11 The nine criteria are the overall
12 protection of human health in the environment,
13 compliance with what we call applicable or
14 relevant and appropriate requirements -- which are
IS really basically local standards, federal
16 standards, laws, regulations -- production of
17 toxicity, mobility of volume, the short-term
18 effectiveness of the remedy, the implementability
19 of the remedy or how easily it can be done or how
20 hard it is going to be or what kind of problems we
21 might run into, the cost, state acceptance and
22 community acceptance, and long-term effectiveness
23 and permanence.
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27
1 I'm using these criteria. The
2 feasibility study evaluates alternatives, looks at
3 different alternatives for the site and comes up
4 with the most feasible. On the North Hollywood
5 dump site it was determined that there are
6 actually two areas of concern that needed to be
7 addressed. One of which is the landfill itself
8 and the groundwater underneath it coming in
9 contact with it. The other is the abandoned
10 dredge pond and Oxbow Lake.
11 There are alternatives for both. I'm
? going to discuss the landfill first, and then I'm
*
13 going to discuss the pond and the sediments. The
14 landfill did not during the risk assessment show
IS any immediate risk to the community now that the
16 twelve inch cover has been placed on it. However,
17 when going through the criteria, one of the things
18 that that covers is it doesn't even meet standards
19 for municipal landfills. Another thing is that we
20 couldn't guarantee the permanence of it because it
21 is a cover that's not as large as we think it
22 should be.
23 So we reviewed alternatives to deal with
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28
1 those problems. And of those we cane up with four
2 separate alternatives. We also have the
3 groundwater underneath it that has to be
4 reviewed. One of them is no action. That's done
S on all Superfund sites, and it's a basis for
6 comparison. The second alternative is a low
7 permeability cover. The third is a low
8 permeability cover with containment of the
9 groundwater by extraction wells. And the fourth
10 is a low permeability cover with containment by a
11 barrier wall.
12 These alternatives are mentioned on page
13 four of your handout. And the criteria are
14 mentioned on page nine so that you can go back and
IS evaluate. A discussion of those criteria and how
16 they fit with these alternatives goes from page
17 four to page six.
18 Upon review of the criteria and basing it
19 on the risk assessment, the shallow groundwater
20 going into the river is presently not having a
21 major effect on the river. So it was determined
22 that all the groundwater needed was monitoring and
23 that extraction by the wells was not necessary.
-------
However, upon reviewing the criteria we did
2 determine that there still wasn't permanence with
3 the cap, nor did it meet regulatory standards. So
4 the low permeability cover was the preferred
S alternative by EPA for the landfill.
6 . For the dredge ponds and the Oxbow Lake
7 there was a risk associated with eating fish over
8 the long-term from that site, continuous
9 consumption of fish taken from those ponds.
10 Because of that problem and the risk associated
11 with it, six alternatives were evaluated using the
* criteria to address the fish in the pond and the
i3 sediments where the contamination" was coming
14 from.
IS Alternative number one is no action.
16 Number two is a periodic harvesting of the fish so
17 the people wouldn't be eating contaminated fish.
18 Dredge with containment on east sector of the
19 landfill, which is basically dredging of
20 contaminated sediments from the bottom of the pond
21 and placing them on the landfill underneath the
22 cover. The fourth alternative is in-place
23 containment with a hydraulic fill, a wet sediment
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30
1 fill. And the fifth is in-place containment by
2 rerouting of the Wolf River. Six was excavation
3 and containment on the east sector of the landfill
4 for the shallow areas and a hydraulic containment
S of the lower areas of the ponds.
6 These were evaluated as well using the
7 nine criteria, and froa that alternative four was
8 chosen as EPA's preferred alternative. This was
9 based on the fact that the short-term effects of
10 doing this would be a great deal less than it
11 would be for excavation or any type of rerouting
12 of Wolf River.
13 Excavation would, of couTse, bring
14 contaminated sediments to the surface and possibly
IS cause problems with short-term exposure to people
16 where there are sediments.
17 The periodic harvesting of the fish was
18 not really a peraanent solution to the problem.
19 And no action obviously is not doing
20 anything permanent for the risk associated with
21 the site.
22 But the in-place containment by rerouting
23 of the Wolf River had a lot of problems, including
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31
meeting the Corps of Engineers standards. The
2 implementability of that would be very hard to
3 do.
4 I'm going to put up a photograph of the
5 site showing you the areas that would be covered
6 by the landfill cover. This is the dump here.
7 This area would all be covered by a two foot
8 cover. The edges here that are dark would have
9 peg sod and matting placed around it in certain
10 areas. They are to control erosion problems
11 because those areas are next to the river and have
"2 flood problems. There are areas along here and
*3 the edges next to the river that we will be moving
14 into the center of the dump. There is no great
IS difference between contamination in the dump and
16 along the edges. However, because of erosion
17 problems we want to put them in a more containable
18 place.
19 For the dredge ponds and the lake, the
20 large area is the dredge pond. The lighter area
21 that you see would be mechanically placed fill.
22 Whereas, just an area of hydraulic sediments here
23 would be placed along the edges. All of this
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32
1 would be mechanically placed in Oxbow Lake. There
2 would also be a Geofabric placed along the edges
3 that were more likely to slide or move to hold the
4 sediments in place and contain the landfill and
S the dredge ponds.
6 And we'll start the question and answer
7 session, and Harold will be our moderator.
8 MR. TAYLOR: Surely you've got a
9 question, someone.
10 MR- KELLY: My name is Kenny Kelly.
11 I'm with the people of Woodstock, Incorporated.
12 I've been watching this site pretty extensively
13 for at least years now. And, first off, I would
14 like to make a comment. I think the whole
15 situation has been a farce. The U.S. EPA who
16 couldn't find the so-called hot spots on the North
17 Hollywood dump until Dr. David Wilson came down
18 from Vanderbilt University and, with his own
19 sampling and analysis, identified them. And then
20 it got on the list. T.ail were tripping all over
21 the hexachlorobenzene and didn't even see it
22 there.
23 Second off, I have a question, and then
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33
I'll sit down and give somebody else a chance. If
2 nobody else wants one, I've got more. Why are we
3 only considering a twenty-four inch cover? What
4 is this cover consisting of? And is it my
5 understanding it's an acceptable cover for a
6 sanitary or so-called municipal landfill? We're
7 dealing with a hazardous site here.
8 MR. TAYLOR: I'll try a stab at
9 that. We've basically classified the North
10 Hollywood dump, although there are some industrial
\
11 wastes there -- and I think everyone is well aware
12 of that -- we've classified it more as a municipal
waste landfill than a hazardous uaste landfill.
14 The borings that were done at the site
15 largely found washing machines, tree stumps,
16 burned debris, ash. As you well know, it was an
17 open burning dump for a number of years. So under
18 our classification we basically feel that closing
19 the landfill as a sanitary landfill is the most
20 appropriate regulation to close the landfill
21 under.
22 Clay is put on there because that's
23 basically the method which you use to close a
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34
1 sanitary landfill. I think you should also take
2 into account that the North Hollywood dump, that
3 the bottom is basically placed on sand and gravel,
4 but closed pretty readily to the Wolf River. So
5 you are basically not looking at a cap doing a
6 whole heck of a lot of good except for keeping
7 some percolation out of the waste and keeping
8 people from coming in contact with the waste.
9 So X think that's primarily why the clay
10 cap was chosen over what you might call a RCRA
11 engineered cap with multiple layers or those kinds
12 of things. It really wasn't thought to be that
13 much of an advantage.
14 MR. STRAUGHN: I'm Art Straughn. I
IS have a couple of questions to clarify. One, the
16 hydrodynamics of the situation, the flow of the
17 groundwater, it appears that the groundwater that
18 came off of the dump just went to the Wolf River
19 and no further, is that correct, from the
20 viewpoint you just showed on -- your engineer
21 showed?
22 MR. TAYLOR* Perhaps I can get Oave
23 Hill to address that, if you would, Oave.
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35
MR. HILL: We looked in detail at
2 what happens to the groundwater after it goes by.
3 And we're very concerned that we don't want this
4 to get into anyone's drinking water aquifer.. We
5 looked carefully at the deeper aquifer that the
6 City of Memphis gets its water supply from. And
7 as you may know, the U.S. Geological Survey has
8 made a detailed study of some windows between the
9 superficial sands and the lower aquifer.
10 In the broad -- more than the Memphis
11 area. It's kind of the West Tennessee area. And
there are some interconnections, but in the area
i3 of -- a large area -- well, around the North
* * * •
14 Hollywood dump there is at least -- I forget the
IS figure, but there's one or two hundred feet of
16 clay that's protecting the underlying aquifer from
17 anything that would come down from the dump.
18 Now, within the superficial sands itself,
19 if you remember from the diagram that was set up
20 here, the flow lines came up. What we see
21 actually is an increased head where the lower --
22 and we actually detect the pressure gradient is
23 from the deeper... Toward the surface. So the
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36
\
1 water is actually flowing up toward the river from
2 both sides of it.
3 And because of these two considerations
4 there is a good clay layer aquifer, we call it,
5 that separates the good drink water aquifer below
6 from the impact of -- the flow lines clearly show
7 that it was bringing it to the Wolf River.
8 MR. STRAUGHNi Why is it then that
9 they have the contaminated signs on the ponds that
10 are north of the interstate from there, apparently
\
11 they have found contaminated fish in those ponds
12 in the past?
13 MR. HILL: There is. significant
14 contamination here*, and we wish it was only
IS attributable to this site, and we can get a handle
16 on it just from dealing with this site. But we've
17 done upstream and downstream studies and we've
18 found contamination both upstream and downstream
19 in the fish.
20 MR. STRAUGHHi But north of the
21 interstate there is some ponds that are a good
22 half a mile to a mile north, and they have in the
23 past been found to contain contaminated f.'sh.
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37
Where would that contamination be coining from?
2 MR. HILL: Felicia is just running
3 over with answers. Here she is.
4 . MS. BARNETT: When the studies were
5 done -- those ponds do sit next to the dump.
6 That's coming from sedimentation back when the
7 site was eroding. The Wolf River would flood back
8 over the site back before the covers were put on
9 it, and the superficial contamination was being
10 pushed back into those ponds.
11 MR. STRAUGHN: North of the
interstate?
*3 MS. BARNETT: North' of the
14 interstate?
IS MR. STRAUGHN: Yes.
16 MS. BARNETT: I'm not familiar with
17 which ponds you are talking about then.
18 MR. STRAUGHNt There are some small
19 ponds north of the interstate that have had signs
20 posted fro» the Health Department indicating
21 contamination.
22 MS. BARNETT: Those, as far as we
23 can tell, are not related to the site. I think
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38
1 what he said is true. There are other sources of
2 contamination in this area.. And the river when it
3 floods back is carrying contamination into any
4 ponds it may flood into because the river itself
5 is posted no fishing as well.
6 MR. STRAUGHN: But earlier you
7 seemed to indicate that the Wolf River is no
8 longer being contaminated from the dump.
9 MS. BARNETTs The contamination from
10 the dump is not affecting the Wolf River, but the .
11 Wolf River does have contamination in it. As a
12 matter of fact, you Xnow some history of the Wolf
13 River. It has been closed for fishing many miles
14 upstream of the North Hollywood dump. They just
IS opened a section of it recently again for fishing,
16 and in an area that's north of the dump.
17 MR. STRAUGHN: But you are saying
18 that the Hollywood dump does not present a
19 potential haxard for fishing in the Wolf River
20 now?
21 MS. BARNETTs The North Hollywood
22 dump is not adding a potential hazard to the Wolf
23 River, no, from the dump itself. But there are
-------
39
problems with the Wolf River as far as things that
2 have gotten into it. The flow coming from the
3 dump -- like I said, the contamination is mostly
4 pesticides and metals. Those do not move readily
5 in water, and that is not one of the major
6 contaminants that are affecting the fish in the
7 enclosure of the Wolf River now.
8 MR. STRAUGHN: So you've presented
9 to us this evening a picture of a relatively low
10 risk associated with the Hollywood dump. Why are
11 you going to do anything at all?
1^1. MS. BARNBTT: Well, like I said,
u there is a low risk, but it does hot meet
14 regulatory standards. And there is the risk that
IS the cover that's been placed on it from a direct
16 contact standpoint is not permanent. Although it
17 is not affecting the river/ we do have a backup.
18 We are going to be monitoring the groundwater
19 that's going from the dump into the river. And
20 right now we don't see a problem, but we will be
21 monitoring it and there is a backup should that
22 groundwater increase. We don't expect it to. But
23 should it happen, we can go in and treat the
-------
4G
1 groundwater «o it doesn't go into the river.
2 MR. STRAUGHN: The alternative you
3 had for taking care of the Oxbow Lake and the
4 dredge lake, I wasn't sure -- are you going to
S actually fill them in completely or put a --
5 MS. BARNETT: No. It's a cover.
7 It's about three feet of cover.
S MR. STRAUGHNi On the bottom of the
9 lake?
10 MS. BARNETT: On the bottom of the
11 lake, yes.
12 MR. STRAUGHN: Keep anything from
13 seeping up into .--
14 MS. BARNETT: Yeah. Right. It will
15 keep biota, the fish, from coning in contact with
16 plant life growing in a contaminated area. And
17 fish bio-accumulate certain types of compounds,
18 and one of them happens to be pesticides and — or
19 some of these pesticides. The one that we found
20 was chlordaoe, and it is bio-accumulable. Small
21 concentrations can get bio-accumulated. ?ish eat
22 from the same area over and over and over again.
23 And we will be covering the bottom of those ponds
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41
to deal with that problem.
2 MR. STRAUGHN: And so those people
3 who did fish in those ponds could be assured that
4 they would not be contaminated if they ate the
5 fish?
6 MS. BARNETT: There will be
7 restrictions on the ponds until -- we will be
8 studying the fish on a periodic basis. The level
9 should go down and the fish -- when we cover the
10 bottom over, then they will be acceptable for
11 fishing.
'12 However, there is also the alternative
j that -- and we want comments on fhis -- if there's
14 people who are not going to obey those signs and
15 stuff, we could go in after we cover the ponds and
16 remove the fish and restock it. Although, they
17 are private ponds right now and supposedly only
18 the people that own them are supposed to be
19 fishing out of them. But should the community
20 indicate to us that there is a vast majority of
21 the people fishing out of those ponds right now,
22 we can go in. And when we do this bottom
23 sediment, we'll go ahead and remove the fish
-------
42
1 immediately.
2 MR. STRAUGKN: What would be the
3 time frame then you would expect to clear up the
4 problem so that fishing would be safe?
5 MS. BARNETT: The time frame for if
6 we put in the sediments and cover them as is now
7 and don't remove -- some of the fish will have to
8 be removed anyway, especially the larger ones,
9 because we will have to lower the level of the
10 lake and the dredge ponds. If sampling shows that
11 there is no problem with those that are left
12 behind/ then fishing would be immediate. However,
13 the life span of the fish that ar« contaminated
14 would be the time, which would be about five
15 years, before fishing could be resumed.
16 MR. STRAUGHN: Thank you.
17 MS. LOGANs I'm Linda Logan (court
18 reporter requested name repeated for
19 clarification). I've been working on the
20 mobilisation of chlordane at the North Hollywood
21 dump project (court reporter requested Ms. Logan
22 to speak up and repeat what was said). And while
23 I agree that chlordane is essentially a
-------
43
A (inaudible) compound, I'm certainly concerned
2 about its mobilization in the downgrading
3 groundwater, which we know has elevated,
4 dissolving any (inaudible) kind of
5 concentrations. And certainly any kind of a
6 compound, it's apparent absorbability is going to
7 be increased because it's all absorbed in the
8 (inaudible). I wanted to get a few comments on
9 that, please.
10 MR. HILL: We have been particularly
11 concerned with chlordane. As Bruce knows, we've
'2 commented back and forth between ourselves a lot
j.3 about that. In the sampling that's been done in
14 the past, that's what we're basing our results
IS on. It showed that the levels of the groundwater
16 were below any that would significantly affect the
17 Wolf River to make it follow the criteria that EPA
18 has set up -- with a few exceptions and just a few
19 samples -- where chlordane was above the standards
20 we were setting.
21 And we realize, as you said, that
22 although something in its purest state can be
23 fairly immobile and absorbed into the soil, there
-------
44
\
1 are many factors that can make it more mobile. So
2 we are very concerned about that. And because of
3 that/ we're setting up a network of wells, that
4 Bruce touched on, along the river to measure --
•
S and these will be monitored regularly -- for the
6 concentrations of these contaminants in the
7 groundwater.
8 And this will be kind of a double-edged
9 sword. If we find there is no problem, then we
10 can gradually reduce the monitoring frequency. If
11 we find there is a problem, we're going to
12 increase the frequency. I mean, if there's a
13 suggestion of a problem, we're going to increase
14 the monitoring of the frequency so we can
IS determine for sure -- if we're actually causing a
16 violation of the standards that would affect the
17 Wolf River above our water quality criteria, then
18 we're going to require that action be taken,
19 whether it's -- it'll probably involve some
20 extraction of groundwater so we can get back below
21 these levels.
22 We'll be watching chlordane very closely
23 because that's the number one problem we find.
-------
45
1 MR. TAYLOR: I would like to Just
2 stress, too -- and I don't think we've made this
3 really apparent tonight -- that we do have a
4 contingency which will be in the record of
S decision that the proposed panel will discuss.
6 And should the levels exceed some of the health
7 based or aquatic based levels we'll be looking at,
8 that pump and treat can be implemented without
9 having to go back and do another rod, do another
10 feasibility study, those kinds of things.
11 So we will have a backup plan should
12 those levels be of concern. That plan will be to
.3 basically contain the water on site, to pump and
14 treat and discharge to the municipal treatments.
IS MR. KELLY: I've just got a head
16 full of questions about this site. You'll have to
17 excuse me. One of them I've heard, looking at the
18 different studies of health consequences, somebody
19 may climb over the fence. Why should we have to
20 climb over the fence when the fence does not go
21 around North Hollywood dump? I would like to
22 bring it to the attention of the U.S. EPA that the
23 fence ends behind the residences and is basically
-------
46
1 just a cosmetic approach to dealing with the
2 landfill.
3 I don't remember the specific year at
4 this point in time, but you've mentioned the
5 different shallow veils that were placed on that
6 site. I was on site as a member of the Memphis
7 Area Environmental Task Force, Investigative
8 Subcommittee, when the United States Geological
9 Survey was putting wells in on the west side of
10 the North Hollywood dump, at which point while I
11 was on the site they did not hit clay in one of
.12 their auger holes. That point has never been
13 mentioned in any study that I've seen. I haven't
*
14 gotten to the library yet, so I don't know if it
15 is in the one that you've got now.
16 Terry Cochran (phonetically spelled)
17 explained that they brought another auger on the
18 next day, moved fifty or seventy foot away, dug a
19 hole and they hit clay. But that auger that did
20 hit that clay layer that day had already dug two
21 or three wells previously that morning before it
22 hit clay.
23 So basically my comment is that I do not
-------
47
1 see any investigations to date that prove that
there is not a direct hydraulic connection via
3 stained windows between the contaminated shallow
4 aquifer and Memphis drinking water supply.
5 I heard a statement made that the Wolf
6 River is not being contaminated by the North
7 Hollywood. Then how did the chlordane get in the
8 fish? Does anybody have a response to that?
9 MR. TAYLOR: There are several
10 questions there.
11 MR. KELLY: Several comments. One
12 question.
I1 MR. HILL: We're not saying that the
«
1.' North Hollywood dump has not impacted the Wolf
IS River. I think it clearly has. That's why we're
16 here. It appears that the impact has decreased
17 significantly over the, as you point out, years
18 we've been looking at this site.
19 It's our hope that when we take the
20 actions that Felicia has talked about, put the
21 cover on and stabilize the size, that the impact
22 will further decrease. As we calculate the impact
23 now, we impact -- although it is an impact, the
-------
48
1 impact is below the levels that EPA has set to
2 regulate in the water quality criteria. These are
3 extremely low levels based on some very sensitive
4 organisms that EPA geologists have looked at in
5 detail.
6 There are apparently other sources.
•
7 We've not been able to pinpoint any significant
8 point source. But as you well know, chlordane is
9 used in almost every home site in the past for
10 termite control. So we're not saying the Wolf
11 River is crystalline. We're not quite that dumb.
12 We realize there are lots of sources of
13 contamination.
V
14 The North .Hollywood dump is a single site
15 that we can put or draw on a map and approach with
16 our procedures here. But the way the whole
17 process works is we go after the -- you'll notice
18 our term -- potential responsible parties, but we
19 can't hold them responsible for something that's
20 outside their jurisdiction. We realize there are
21 other sources. We're trying to address the one
22 that's here.
23 If you know of any other significant
-------
1 sources -- thia ,• „
i« one we've been beatin, OB
2 people for a lona ,
, k 9/ l0"9 time " 'ell u, 4bout
3 them. We can *«ii
follow what we can find. It._
4 *iv" b"«< «udy. we can't ,o and
5 __...__.
49
13
16
i « l.ol.t. what co.e, fron t,u/L=e 80 we can
this under control.
glos,ed
"e, a tew thing.
and- ot
11 remedy.
12 MR. KELLY: One decade later. It
only took a decade to get that fence completed.
We're really making progress.
15 MR. TAYLOR: We share your concern
the length of time it has taken to get this
17 site addressed properly.
18
th.0
th. oP«ating enginaer..
.at.rial ont
he iandfui
Biddl. and
-------
50
1 MR. TAYLOR: Yes, sir.
2 MR. MALONE: What level of material
3 cleanup will that be?
4 MS. BARNETT: It's a low level
5 contaminated material we will use.
6 MR. MALONE; Will it be B, C?
7 MS. BARNETT: We will do a safety
8 plan to evaluate exactly what it will be. It
9 won't be level A.
10 MR. MALONE: Oh, I didn't figure it
11 would be.
12 MS. BARNETT: It will probably be, I
13 would say, at least C to B level, depending on
14 which area we're doing. But it will be moved and
IS placed into a better empty cover.
16 MR. MALONE: Before the contract is
17 ever led, you will have the level of material?
18 MS. BARNETT: Tea. We'll know what
19 level we'll need before we do that.
20 MR. TAYLOR: That will be part of
21 the design, basically to determine what health and
22 safety needs are needed during the remedial
23 action.
-------
SI
1 MR. KELLY: la the U.S. EPA aware
that the State of Tennessee has issued a national
3 pollution discharge elimination permit, NPS, to a
4 local factory to allow them to discharge water
5 into the abandoned dredge pond?
6 MR. TAYLOR: I'm not aware of that.
7 MR. KELLY: I wasn't either until
8 just a few days ago.
9 MR. TAYLOR: Could you give us a
10 little more detail?
11 MR. KELLY: We've got some people
12 from the state, the Department of Health
1? Environment, perhaps they can give you some more
*
1. detail. That's what they get paid for. It's a
IS cotton seed oil company down the road on Chelsea
16 Avenue who has been discharging contaminated
17 material. They just recently got an NPS permit
18 modification which called for -- and I believe
19 there's a commissioner's order on it, so X don't
20 know why it's such a mystery to everybody.
21 MR. TAYLOR: I think what they're
22 saying is it's a different division, but we'll
23 certainly look into that for you. We certainly
-------
52
1 appreciate you bringing it up. Are there any
2 other questions?
3 MR. KELLY: Why didn't we hold this
4 meeting at Shannon School next to the North
5 Hollywood dump? Maybe we would have gotten some
6 participants from the neighborhood that are
7 possibly being affected by the landfill.
8 . MS. BARNETT: We knocked on doors in
9 the neighborhood. We sent fliers to all of those
10 people. We didn't hold it at Shannon School
11 because this setup was a better setup for a
12 community meeting. The school really wasn't a
13 good place to have a meeting and be able to get
*
14 microphones and be able to set up and hear all the
IS comnrents easily. Those people were notified.
16 MS. BELL: Is this the flier, when
17 you say you sent fliers out in the community?
18 MS. BARNETT: Yeah, we mailed them
19 out to people. We knocked on doors. I sent
20 people out --
21 MS. BELL: I received a copy in the
22 mail, and I was a little bit concerned. It's a
23 good document, but it's a technical document, and
-------
53
1 we acknowledge that. So those residents in the
area would not understand not one iota of this
3 type information. And I'm not being critical. I
4 guess at this point the question I'm raising is
5 whether or not there would be some provisions for
6 the people from the community -- it seems to me I
7 remember some years ago some provision in
8 Superfund that would allow for some community
9 ground or something to be made available so --
10 MS. BARNETT: Yeah -- if you could,
11 come up to the microphone and tell her your
12 name -- there is, and I'll let Suzanne address
13 t ?i a t.
' >
MS. BELL: My name is Carolyn Bell,
IS and I'm a concerned citizen. And since the
16 gentleman brought the question up, I was just
17 following up on the fact the information here is
18 very technical and it does not limit itself to the
19 residents that live around the Hollywood dump. So
20 I was wondering if there would be some provision
21 available for those residents to perhaps hire
22 their own consultant to sift through this
23 information and present it to them in a manner in
-------
54
1 which they would be able to understand.
2 MS. DURHAM: Thank you, Carolyn.
3 Yes/ we do have a Technical Assistance Grant
4 program available. It is a little complicated,
5 and it takes a lot of time. We do have people at
6 EPA who can come into this community and sit down
7 with those people and help them fill out their
8 application and walk them through the process.
9 They need to be incorporated. They need to send a
10 letter to EPA stating that there is a group
11 interested in a TAG grant, and then we will send a
12 package and get back with them.
13 If anyone is interested in applying for a
14 Technical Assistance Grant, they need to submit a
15 letter of intent. And they can submit it to my
16 attention and I'll get back with them.
17 MS. BELL: And then if someone does
18 submit, and as you do go through this process,
19 will this delay your response period? I see the
20 period is one month.
21 MS. DURHAM: No, it won't delay that
22 at all. And, unfortunately, this is a little
23 misleading, offering the Technical Assistance
-------
i Grant now. It really won't help much at this
point, but this process will go on for two, maybe
3 three years. So they will still have an
4 opportunity to participate. It will take
5 approximately four months to get the grant on
6 board, and hopefully our record of decision will
7 be signed by then.
8 MS. ADAMS: Clara Adams, and I'm
9 with the people of Woodstock. We would like to
10 have one of those fifty thousand dollar grants to
11 study our neighborhood, if we can get it.
12 MS. DURHAM: Would you submit a
letter of intent to the agency? And we'll send a
*
14 grant application..
IS MS. ACAMS: Yeah.
16 MS. DURHAM: This document is in
17 your package of handouts. Ma'am, there are some
18 restrictions on the fifty thousand dollars.
19 Okay. Call the agency and we'll get you started
20 on it.
21 MR. POWELL: Ed Powell. I'm a
22 little concerned about the chlordane runoff. I
23 was wondering why every stream in Tennessee
-------
56
1 doesn't have fishing restrictions if we're worried
2 about runoff. On your chart with the red and
3 yellow dots and so forth -- I guess it was Bruce's
4 question -- Z only saw one sampling point north of
5 the Wolf River. How many actual sampling points
6 were north?
7 MR. MONTEITH: There was the one
8 sampling point north of the Wolf River. What we
9 were trying to demonstrate with these was the
10 hydraulics of the system. The groundwater did
11 discharge to the Wolf River. So we were able to
12 do that with nested wells primarily on this area
13 of the site. We're concentrating jon monitoring
14 the site itself.
IS But by locating the one well on the north
16 site of the landfill -- that's the well that also
17 demonstrated that there was the upward grading and
18 the groundwater discharging up into the Wolf
19 River -- we are finding it consistent with what we
20 found on the south side. Zt was felt only the one
21 site was required on the north side of the
22 landfill. Once we define the hydraulics of the
23 system, the one site was adequate.
-------
57
r MR. POWELL: For the level you were
checking the hydraulics out there, there were a
3 number of hydraulics?
4 MR. MONTEITH: Right.
S MR. POWELL: Of course, we don't
6 really know -- knowing the hydrogeology and the
7 holes we discovered out at Carrier air
8 conditioning or somewhere, we don't really know
9 that a lot of this isn't going straight down?
10 MR. MONTEITH: Well, at this site
11 and partially in response to Mr. Kelly's comment
12 about them not finding any clay -- I'm not sure
where he's getting that information. Once I think
*
14 he has an opportunity to read the supplement RR
15 report and review the boring logs for the site
16 he'll see that we did, in fact, hit clay at every
17 location that we drilled at the site.
18 MR. KELLYi No, sir, you didn't. I
19 was an eyewitness.
20 MR. MONTEITH: And that will also go
21 into details in describing the hydraulics.
22 MR. POWELL: I'm a little surprised
23 that you got the upperward hydraulics on both
-------
58
1 sides of the Wolf River, which is normally formed
2 by a softer area. it seems a little strange, but
3 yet I assume the clay bed keeps it from crossing
4 the Wolf River?
5 MR. MONTEITH: Well, again, without
6 getting into a lot of detail -- I don't know if
7 you've had an opportunity to read the document,
8 but it goes into a lot of detail in describing the
9 geology of the site and the hydraulics at the
10 site. And I think once you see the way it is
11 presented there, that it will become clear to you
12 that we're dealing with the fluvial sands of the
13 site here. And all the monitoring that we have
*
14 done here demonstrates that the clay is continuous
15 from each site and that there is discharge to the
16 Wolf River.
17 MR. POWELL: You have one other
18 chart up there that showed elevation of the site.
19 I was just wondering how exaggerated that was. It
20 looked like a little mound.
21 MR. MONTBITHs It is an exaggerated
22 scale. Again, to fit it on to the drawing there
23 is an exaggeration to that scale. Again, if you
-------
i are familiar to the site, the site is relatively
2 flat.
3 MR. POWELL: But basically it is,
4 however, higher in elevation than the surrounding
5 areas?
6 MR. MONTEITH: The surrounding areas
7 surrounding the Wolf River.
8 MR. POWELL: The Oxbow Lake and
9 dredge ponds and so forth around it, they appear
10 to be higher.
11 MR. MONTEITH: Yes.
12 MR. POWELL: The landfill is
obviously very permeable. But a barrier wall that
14 they've mentioned in alternative four, I've seen
IS it a variety of different ways, how would they go
16 about constructing a barrier wall if they decided
17 to?
18 MR. MONTEITH: Well, that was one of
19 the things that was evaluated under the
20 feasibility study. Felicia ran through a number
21 of criteria that evaluate the technologies. And
22 one of the difficulties with the barrier wall,
23 this site, was the constructability of that. To
-------
60
1 avoid having to -- there would be difficulty
2 potentially trying to dig through the waste itself
3 which creates problems itself with the
4 construction of it, significant elevation and
5 changes around the perimeter of 'the site also
6 creates difficulty.
7 There are a lot of problems associated
8 with that barrier wall. That's why there was
9 the -- if there is a need to do any further work
10 down the road, the hydraulic pumping is the
11 preferred alternative to the barrier wall. It
12 will serve the same purpose, preventing discharge
13 to the wolf River.
»
14 ' MR. P'OWELL: Did I understand that
15 y'all did run a well down to the Memphis aquifer
16 which is about a five hundred to a thousand feet?
17 MR. MONTEITH: Under this study that
18 wasn't done.
19 MR. POWELL: It was not?
20 MR. MONTEITH: It was not done under
21 this study.
22 MR. POWELL: Good. Because I'm
23 worried about putting a well through this land.
-------
61
1 it would contaminate this.
MR. MONTEITH: when I say under this
3 study, I mean under the supplemental RI program
4 which we were directly involved in that was not
5 carried out. But there was sampling done under
6 the TAG study of wells within the area that were
7 done in the Memphis sand.
8 . MR. POWELL: The Memphis wells?
9 MLGiW wells?
10 MR. MONTEITHs Wells within the area
11 of the site, Memphis area, that were in that
12 aquifer. And they were set up.
1 •> MS. LOGAN: Linda Logan from Memphis
*
1. State again. Is there not some evidence that
15 severe pumping from some of the groundwater wells
16 has actually now caused some of the groundwater to
17 actually be able to go from the surface aquifer to
18 the confined aquifer? Somewhere I seemed to have
19 read this, or X think it was an article that was
20 in the Commercial Appeal about a month ago based
21 on some work that was done by the civil
22 engineering department at Memphis State.
23 MR. HILL: I'm not familiar with the
-------
62
1 study you are talking about in particular, but I
2 do remember looking at the geological survey
3 report where they indicated that there are some
4 areas in the overall larger Memphis area where
S that would be possible, and I would imagine it
6 would be those areas. It's not in this particular
7 dump site area because of the clay layer there.
8 Even the tremendous amount of overpumping of the
9 aquifer wouldn't change the local hydrogeology
10 right through the river side.
11 As far as the rainwater feeding the Wolf
12 River, it doesn't take a clay finger down there to
13 convert it up. It's simply the concept that the
14 river is draining groundwater as opposed to being
IS a discharging river which would feed the
16 groundwater. If it was feeding the groundwater,
17 that groundwater we've shown flowing from south to
18 north would clearly flow under. But since it's
19 draining the groundwater, it is just the hydraulic
20 flow is all that is needed to ride it out through
21 the river.
22 MR. KELLY: I'm not a hydrologist.
23 I'm not an environmentalist. I'm not a
-------
63
1 scientist. But I know the Wolf River rises. And
\
when the wolf River gets high at flood stages is
3 it not possible it is recharging this contaminated
4 shallow aquifer? It's a situation that works both
5 ways at different times of the year/ is that not
6 correct?
7 MR. HILL: We've had a lot of
8 discussions about that, too, and we were concerned
9 that during flood stage it might get a tremendous
10 reversal flow. We were concerned about some of
11 the consecrations that we've measured in the
12 background wells being influenced by back flow
13 caused by flood stages.
«
So I personally got the geologic -- the
f • *
15 U.S. GS flood records all the way back into the
16 1940's following that river. And as best we could
17 determine after extensive discussion back and
18 forth, the back flow would probably go about a
19 little over two hundred feet back up toward the
20 dump site. It would not be in the order of a
21 thousand or more feet.
22 Yes, there would be some back flow, but
23 it would be a mobilized effect so when you get
-------
64
1 back to normal conditions it would go back to the
2 river and it would not affect it that far out on
3 each bank.
4 MR. KELLY: In the early 1980'§ a
5 background well was placed at the -- let's see, I
6 believe it's called the library now, the North
7 Hollywood Street, which showed elevated levels of
8 chlordane in that background sample well.
9 MR. HILL: You are speaking along
10 Birch Street?
11 MR. KELLY: Yes. Those that came
12 from the North Hollywood dump or other sources?
13 MR. HILL: We've had a lot of
<•
14 discussion about that, too. That's why I raised
15 the issue of the effect of floods on the dump
16 site. And apparently the flood back flow is not
17 enough to reach those wells.
18 MR. KELLY: So the answer would be
19 from other sources?
20 MR. HILL: It's apparently not from
21 the dump.
22 MR. KELLY: Back in the early
23 1980's, once again, Dr. David Wilson did studies
-------
65
1 not only on the dump site but the neighborhood
surrounding the North Hollywood dump. They found
3 elevated levels of chlordane and other chemicals
4 along the streets and in the neighborhood. Has
5 U.S. CPA done any studies to back this up or to
6 disprove it, or is this just going to be
7 overlooked?
8 MR. HILL: In years past we've done
9 exhaustive studies of claims just such as that for
10 individual neighborhoods where they felt there
11 were high levels, and we have a lot more claims
12 that we have not been able to find the source
1 for.
14 • MR. KELLY: At the North Hollywood
IS site have y'all done any studies to see if any
IS contaminants were along the roadways leading to
17 the North Hollywood dump?
18 MR. TAYLOR: If I could, I'll now
19 introduce Chuck Pietrosewicz with the Agency for
20 Disease Registry, basically their sister agency to
21 CDC who did a health study.
22 MR. KELLY: That's also a farce.
23 MR. PIETROSEWICZ: That's a matter
-------
66
1 for discussion.
2 MR. KELLY: Yes, it is.
3 MR. PIETROSEWICZz Back in the early
4 1980's John Hopkins University did a preliminary
5 health study in the community. And back in 1982
6 or thereabouts is when the Center for Disease
7 Control/ which I used to work for, started working
8 officially with EPA to deal with health issues
9 relating to Superfund. This is one of the handful
10 of sites around the country that EPA has to do a
11 formal major health study at. And we did.
12 And you are right, we found based on the
13 environmental samples, a lot of off-site
*
14 contamination .in the neighborhood and such, but we
IS also studied the people. We studied a hundred and
16 ninety-four folks in the Hollywood area --
17 MR. KELLY: Compare damage to
18 another --
19 MR. PIETROSEWICZ: And a hundred and
20 seventy-four people in what we call a comparative
21 study area and studied bloods, fat, urine,
22 questionnaires, and physical examinations and
23 really did not find any elevated levels that could
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be attributed to folks in the area being exposed
i to various pesticides- that we found at the dump,
3 We did find elevated levels of folks who
4 fished and ate from Oxbow Lake and the other lake
5 and the river.
6 MR. KELLY: I just thought I heard
7 an opinion stated a minute ago that these are
8 private bodies of waters and they didn't think
9 people were fishing in there besides the land
10 owners.
11 MS. BARNETT: No. We didn't say we
12 didn't think people -- we wanted to know from the
community how many --
14 ' MR. K-ELLY: They are.
IS MS. BARNETT: Yeah, how many --
16 MR. KELLY: They are. They are
17 fishing.
18 MS. BARNETTi (Continuing...) how
19 many and such because we are going to be dealing
20 with those lakes and ponds.
21 MR. KELLY: Just drive down the road
22 that goes along where the fence is and you'll see
23 them.
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1 MR. PIETROSEWIC2: Oh, yeah. I've
2 been there. I know what you are talking about.
3 But we did find elevated fat and blood levels in
4 folka who admitted to fishing and eating fish fro..i
5 the ponds. We never found adverse health effects
6 in the folks that we studied. We did find
7 elevated levels of blood and fat.
8 I don't know how much you know about what
9 the Center for Disease Control is all about, but
10 the issue is try to cut down on exposure. So the
11 concern is to cut down potential for exposure of
12 pesticides from eating fish in the lakes and
13 rivers.
*
14 • MR. POWELL: Wasn't that study
15 really just to try to be able to propose a much
16 larger study that was never finished or done?
17 MR. PIETROSEWICZ: No.
18 MR. POWELLs Well, I thought that it
19 was.
20 MR. PIETROSEWICZ: John Hopkins
21 essentially composed that. We followed up on it
22 after the work that we did. Collaboratively
23 Tennessee Department of Health Environment --
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actually the Memphis-Shelby County Health
2 Department., they had th.e Lead really, and we
3 worked with them. It really is a collaborative
4 effort. The bottom line is no.
5 MR. KELLY: That's the same health
6 department that said darn we didn't know that
7 neighborhood was contaminated until we used them
8 for background samples.
9 I would like to answer two questions. He
10 said he didn't know where I got my information
11 concerning the drilling of a well that did not hit
12 the clay layer. That is from an eyewitness
account, another man w.io was present, David
14 Graham. The United States Geological Survey and I
15 will send U.S. EPA a notarized statement from an
16 independent eyewitness who was also present on the
17 site when I was there and made that observation.
18 MR. TAYLOR: Are there any other
19 questions?
20 MR. MALONEs My name is Ellis
21 Malone. If you do this work, when will you have
22 the program to start?
23 MR. TAYLORt Mr. Malone, what we
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I need to do, of course, first is to summarize the
2 plan. Of course we're here tonight soliciting
3 public comments. Assuming that the public likes
4 the plan or accepts the plan and we move on to a
5 record of decision, we would like to start the
6 design work basically before the wet season
7 starts, which is November, December, January.
8 That design work -- without going into great
9 detail about the scheduling, a typical Superfund
10 site takes around a year to complete from the day
11 you start until the day you finish.
12 So actual physical construction wouldn't
13 begin until that design work is done, complete,
14 approved, signed off on, and a contract is led out
IS to bid either by EPA or PRP's to do the work. So
16 we're probably looking at, optimistically, actual
17 construction to start in a year and a half or a
18 year and a quarter or something like that.
19 MR. KALONE: When you get ready to
20 do the work, that contractor will have to meet all
21 EPA standards as far as cleaning up the whatever
22 level that you decide it is, is that right?
23 MR. TAYLORs Yes, sir. What will
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1 happen, if EPA obviously bids out the project,
we'll have our own stats and the contractor will
3 bid on it, and he'll have to comply with our
4 stats. It will most likely be overseen by the
5 Corps of Engineers.
6 MR. MALONE: If it's EPA's money
7 used for the cleanup, regardless of who lets --
8 whether you let the contract, whether the city
9 lets the contract, or whoever lets the contract,
10 the standards set up by EPA for cleanup, the
11 contractor will have to meet those?
12 MR. TAYLOR: That's correct. The
M standard set in the remedial design plan approved
*
by EPA, whoever lets the contract, will have to be
15 met by the contractor, that's correct.
16 MR. MALONE: Is the cost for this
17 going to be about eight million dollars?
18 MR. PIETROSEWICZ: I think that's
19 the total cost, if we don't have to go to a
20 contingency.
21 MR. MALONEt And you mentioned these
22 potential responsible parties for the
23 contamination are going to share in the cost?
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1 MR. TAYLOR? That is one option that
2 EPA will have. And once the record of decision is
3 signed, those potential responsible parties will
4 get basically a notice letter front EPA that says
5 we're intending to spend public money unless
6 someone comes forth with a good faith offer to
7 spend their own money. They generally have sixty
8 days to make that offer. And after that sixty
9 days if an offer has not been made, or the offer
10 is not made in good faith, EPA is free to go ahead
11 and spend public monies to implement the remedy.
12 If a good faith offer is made,
13 negotiations will begin with those«potential
14 responsible parties for a period of sixty days,
IS which basically a consent order or consent decree
16 in this case would be negotiated. After that's
17 done it would be entered in a local federal
18 district court and, there again, be public comment
19 on the consent decree.
20 MR. MALONEs What is your feeling
21 about these potential contaminators as far as
22 their contributions, do you have a feel for that,
23 whether they are willing at this time?
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MR. TAYLORs My general feel for
* chis *ite is chat the ?RP*«- will come forth with a
3 good faith offer and enter into negotiations with
4 the agency.
5 MR. MALONE: The status in which
6 they would make their faith good is not known
7 though, right?
8 MR. TAYLOR: That's always an
9 unanswered question until you actually enter into
10 negotiations. EPA has a policy, by the way, of --
11 it's certainly not the only case -- if after the
12 sixty days a good faith offer is not made,
typically EPA will issue those potential
14 responsible parties* a unilateral administrative
15 order ordering them to implement the remedy. Then
16 they will be given a certain grace period to
17 comply with the remedy. And if they don't, then
18 the EPA will go forward.
19 If under the terms of the order they
20 don't coaply with that order and later in a court
21 of law they are found to be a potential
22 responsible party, or a responsible party, they
23 could suffer fines for not complying with the
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1 order on a daily basis/ and they could suffer
2 treble damages. Meaning that EPA could bring a
3 lawsuit. And if we spend a dollar, we could sue
4 them and potentially win three dollars back.
S MR. MALONE: You've looked at a
6 number of options, and one of the options was
7 essentially doing nothing. But we really haven't
8 looked at the other end of the pendulum. And that
9 is, revitalizing to the extent that it will be
10 commercially useful property. What will be the
11 cost on doing that kind of revitalization in the
12 area?
13 MR. TAYLOR: Maybe Felicia knows
14 more about the cost, but we did look at those
IS options early on. For large municipal landfills,
16 which EPA meets quite a few of them on the
17 National Priorities List, it's pretty easy to go
18 through the calculations when you have
19 twenty-three or twenty-seven feet to fill over a
20 seventy acre site and determine what it would cost
21 to bring in a commercial incinerator and
22 incinerate all that waste and then stabilize or
23 solidify the ash and bury it in a RCRA landfill.
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Those options were looked at early on.
2 It's just that those aren't really technically
3 feasible to carry out on a site that's this
4 large.
5 MR. STRAUGHN: Is it technical or
6 economical?
7 MR. TAYLOR: It's really both. And
8 it's a matter of impleraentability, too. Long term
9 -- you were talking about an incinerator that
10 burns so many cubic feet of waste a minute, and
11 you basically would be out there for quite some
12 time doing something like that. So if you are
' talking about returning it back to* its original
14 use, if you brought an incinerator in and started
15 incinerating it, it wouldn't be in your or my
16 lifetime that it was brought back to its original
17 use.
18 MS. RAINES: Margery Raines. This
19 is a legal question. Who owns this land?
20 MR. TAYLOR: We don't have our
21 attorney here tonight.
22 MS. BARNETT: It is private
23 property.
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1 MR. TAYLOR: We know who the
2 property owner* are. I don't happen to know them
3 off the top of my head. We have done a final
4 search on the property, on the property owners.
5 MR. KELLY: Have y'all completed
6 your list of principal responsible parties?
7 MR. TAYLOR: As you probably are
8 well aware, that list is an evolving, continuous
9 thing. Do we have a list of PRP's today? Yes, we
10 do.
11 MR. KELLY: Who are they?
12 MR. TAYLOR: Of course the City of
13 Memphis is one for operating the site.
14 MR. KELLY: Shelby County.
15 MR. TAYLOR: A number of PRP's.
16 Basically, a lot of the companies that are
17 surrounding the site.
18 MR. KELLY: Buckman? Kimberly
19 Clark?
20 MR. TAYLOR: Those names sound
21 familiar. To be honest --
22 MR. KELLY: Yeah, they do sound
23 familiar. I want to know who is principally
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responsible for the situation to begin with, or
4 who is on your list. If we don't know who is on
3 your list, then how can we submit comments?
4 MR. TAYLOR: We're really not asking
5 for comments on who is a potentially responsible
S party.
7 MR. KELLY: You've got to get input
8 from somebody on this. You've been fiddling
9 around ten years and you ain't figured out who
10 they are yet. Somebody's going to have to tell
11 you.
12 MR. TAYLOR: Well, if you have
1 information, we appreciate your supplying it. But
14 1 promise you we have a list of potentially
15 responsible parties for the site.
16 MR. KELLY: How can we obtain a copy
17 of that list? Do we have to go POIA?
18 MR. TAYLORs If you'll just submit a
19 report asking for it, we'll be glad to provide
20 it.
21 MR. KELLY: Free of information or
22 just an across the board request?
23 MR. TAYLOR: Just send us the
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\
1 request. Every request is free of information.
2 MR. POWELL: But will we get an
3 answer for it?
4 MR. TAYLOR: There's no problem
5 sending you a list of potentially responsible A
6 parties. Remember, the first word is potentially
7 responsible, and it does not mean that they are
8 responsible parties. It does not mean a court of
9 law is bound to be responsible. It also doesn't
10 mean that two weeks from now we won't have more.
11 It doesn't mean two weeks from now we won't have
12 less. It's a continuous type situation.
13 As you are well aware, tire landfill was
14 operated in the 1950's and 1960's.
15 MR. KELLY: And they were dumping in
16 the 1980's out there also.
17 MR. TAYLOR: Well, my point is
18 there's not a lot of records. We've gone back and
19 done extensive studies. We've asked people --
20 we've done enough work to get PRP's. And I'm
21 fairly competent someone will come forth and do
22 the work.
23 Again, if we have questions, if you could
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79
approach the microphone, I know our stenographer
2 would be happier.
3 MR. KELLY: I've got one more and
4 I'm going to shut up.
5 MR. TAYLORs If we could, just one
6 more question.
7 MR. KELLY: Okay. That's what I
8 said, just one more. It's actually a comment.
9 Every United States Geological Survey performed in
10 the Memphis area since 1964 has stated if
11 contaminants enter into and concentrate in the
12 shallow aquifer, contamination of the Memphis
f-a sands will occur. I don't see any reason to allow
14 these contaminants to enter into, to concentrate
15 in, and to just let them sit there. Thank you.
16 MR. TAYLOR: Thank you. Are there
17 any additional comments or questions? Thank you.
18 MS. STAFF: I'm Sharon Fidler with
19 the League of Women Voters, and I serve on the
20 Metropolitan Area Environmental Task Force. I
21 have a few concerns with that. During the
22 lifetime of the task force there were certain
23 studies that were done in which samples were
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1 lost. When the reports were given to the task
2 force, the response was I'm sorry we lost the
3 samples. Well, that doesn't inspire a great deal
4 of confidence. Now, I want to know if y'all know
5 whether or not additional work was done to correct
6 this?
7 . Secondly, there was a grant given to an
8 organization in the north to provide a technical
9 assistance booklet for people in the area. I
10 think it was a ten thousand dollar grant. At that
11 time Or. George Wood offered to do the same
12 thing -- he was eminently qualified -- for only
13 the cost of the paper. He was turned down. And
14 that ten thousand dollars grant resulted in
15 nothing.
16 This company spent seven thousand dollars
17 on phone calls, a rough draft, and a couple of
18 plane trips. We never saw anything once we sent
19 the rough drafts back. Finally we convinced the
20 people of EPA to cancel the rest of the three
21 thousand dollars. We had nothing to show for it.
22 We finally ended the task force because
23 nothing was happening. We weren't getting
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information, and this is far worse. It is to
2 their credit that a group of people from the city
3 and some chemical companies got together and
4 formed a TAG group and covered the dump at that
5 time because nothing was being done. However,
6 there is also some concern that this is, of
7 course, a party that is deeply concerned because
8 they are potentially responsible parties.
9 Now, what I want to know also is how much
10 input do those parties have on what your
11 determination is of how you will go about
12 correcting this problem? I mean, it seems logical
- that if the parties are responsible, they are
14 going to want to have the least expensive
IS alternative available. And I want to know, how
16 much credence do you give to their input to this
17 alternative?
18 MR. TAYLORs All the alternatives
19 that EPA selects for any site are selected by EPA
20 and not the potential responsible parties. The
21 cleanup plan is non-negotiable. It is not subject
22 to negotiations. It is not done with that intent
23 in mind. It's an independent EPA and federal
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82
1 decision, and state, as to what needs to be done
2 -o the site.
3 MS. FIOLER: Also, how about the
4 Technical Assistance Grant, would you consider
5 giving it to a local organization that has the
6 credentials rather than some group up in Wisconsin
7 who does this as a matter of course and obviously
8 didn't do well by us the first time?
9 MR. TAYLOR: I believe I'll let
10 Suzanne address this, but the Technical Assistance
11 Grants have only been in life for maybe two years
12 now. In fact, I was involved in the first one
13 against this issue in Region IV. -
14 MS. FIOLER: Well, that may have
IS been, but it was a ten thousand dollar grant to
16 this company.
17 MR. TAYLOR: Again, that was
18 something prior to my time certainly with the
19 agency also. Now we really have to go through a
20 pretty rigorous procedure to make sure the group
21 is affected by the site, that they are indeed a
22 local group, and they're the only local group that
23 actually wants the TAG grant. As part of the
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procedure that Suzanne is describing, it takes
< about four months before a grant can be issued.
3 Are there any other questions tonight?
4 If there aren't, that will conclude the meeting.
5 We'll be up front here if anybody would like to
6 come up and ask us individual questions.
7 (Whereupon, said public hearing was
8 concluded at approximately 9:15 p.m.)
9
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IS
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COURT REPORTER'S
STATE" OF TENNESSEE:
COUNTY OF SHELBY:
I, LAURA L. RHODES, Reporter and Notary
Public, Shelby County, Tennessee, CERTIFY:
1. The foregoing public hearing was
taken before me at the time and place stated in
the foregoing styled cause with the appearances as
noted;
2. Being a Court Reporter, I then
reported the public hearing in Stenotype to the
best of my skill and ability, and the foregoing
pages contain a full, true and correct transcript
of my said Stenotype notes then and there taken;
3. I am not in the employ of and am not
related to any of the parties, and I have no
interest in the matter involved.
WITNESS MY SIGNATURE, this, the / /TXda'
LyiURA L. RHODES
egistered Professional Reporter
Notary Public for the
State of Tennessee
My commission expires: 8/17/91
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APPENDIX B
NORTH HOLLYWOOD DUMP SITE
LETTERS PROM SUPPORT AGENCIES
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\
STATl OP TENNIMII
DEPARTMENT Of HEALTH AND ENVIRONMENT
SOUTHWEST TENNUSSI MOIONAL OFFICI
tM StJMMAII AVI NUI
JACKSON, TBNNISSU 3MQ14M4
September 9, 1990
Ma. Felicia Barnett
U.S. EPA
KT/TN Section» NSRB
345 Courtland St., NE
Atlanta, GA 30365
Re i North Hollywood Dump Site
Draft Record of Decision
Dear Ms. Bam«tt:
""•e Tennessee Division of Superfund has received and reviewed the Draft
ial Record of Decision (and supporting docucentation) for the North
..jllywood Dump Site as enclosed with your letter dated September 5, 1990.
Coonenta art provided below:
1. This Division has rerbablly indicated its agreement with the remedy
for the surface water impoundments. As indicated in previous comments,
we do not feel it necessary to reatock the dredge pond with fish but
will have no objection If EPA feels such action is needed.
2. The present interpretation of the Tennessee UIC regulations suggests
that all groundwater be suitable for drinking purposes unless
otherwise classified. EPA has indicated its willingness to request
a change (or variance) in the classification so that drinking water
would not be an acceptable use of groundwater at the North Hollywood
Dump site and drinking water wells could be restricted. This
Division is aware that CERCLA allows the use of ACLs at this site
so the proposed limitations are appropriate. This Division agrees
with the proposed remedy for the Landfill Wastes and Shallow Groundwater
Providing that EPA obtains a variance from the Tennessee Water Quality
Control Board. If the Board does not approve such a chaage, this
Division will request that the matter be reviewed and consideration
be given to requiring groundwater treatment (as described in
Alternative 3).
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KB. Felicia Barnett
Page 2
September 9, 1990
la •ummary, the State of Tennessee concurs with EPA in its selection of
remedial alternatives for the North Hollywood site. This concurr»nc« is
contingent on the action of the Water Quality Control Board regarding the
groundwater classification. The Record of Decision appears to provide a
sound ba*i* tfor finally remediating thia site.
*.~^-' tzfyrtyr *'*'* -••»——- *—- --'•-^-- —-
This Division appreciates EPA's efforts in this matter and in providing for
Stats* involvement. This Division fully Intends to continue its support
agency rolt during future actions at thia aite.
SinCfccerly,
Richard Holland
Manager, Jackson Field Office
Division of Superfund
XNH/lk
cc» DSF, Nashville
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
71990
S OP
SCLIO WASTg ANO 6MSWG6.NCV BSSP3NS8
MEMORANDUM
SUBJECT: Consultation on the Containment - Only Remedy for
th* Njjrtt^Hollywogd Dump, Memphis, Tennessee
J\4L
FROM:
'CERCIJC Enforcement Division, OWPE
TO: Patrick M. Tobin, Director
Waste Management Division
Region IV
My staff has consulted with your staff on the preferred raaedy
for the North Hollywood Dump Site. OWPE concurs with the ranedy
selected by the Region. -..
Should you have any questions, please contact Neilima Senjalia
of my staff at FTS 475-7027.
cc: Bruce Diamond
Bill Hanson, OERR
Harold Taylor, Region IV
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-2-
If you have any additional questions or concerns, please
contact me at (404) 347-7791*.
Sincerely,
Felicia Barnett
Remedial Project Manager
KY/TN Section, NSSB
cc: Richard Holland, State of Tennessee
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.'••••-,
• '
t . , I
UNITED STATiS £V* • 3CS'.'£N7AL PROTECTION AGE
REGION IV
**.»N-A G£^»G * 3O363
AUG 8 0 1330
Mr. Jon P. McCalla
Keiskeil, Dor.elson, Bearman, Adams, Williams & Kirsch
Twentieth Floor
First Tennessee Building
165 Madison Avenue
Memphis, Tennessee 38103
Dear Mr. McCalla:
This letter is in response to your letter of August 27, 1990,
commenting on the North Hollywood Dump NPL site Remedial
Investigation/Feasibility Study (RI/FS) and Proposed Plan for
site remediation. Your letter specifically commented on the
identification and use of copper as a "major contaminant" at
the site.
'^eneraily, EPA concurs with the Dames & Moore review and with
^he summary prepared by Keiskeli, Donelson, Bearman, Adams,
Williams & Kirch., dated August 24, 1990, which concluded that
there is presently no health risks attributable to copper at
the site.
The ACL for copper is based or. a very protective
environmental value for freshwater organisms of 5.6 ug/1 in
the Wolf River. This is equivalent to a ground water
concentration of 1088 ug/1, which has not been approached in
the monitoring wells at the site. However, should the site
not be closed with an appropriate cover, future conditions
could create a possible exposure to copper at levels that
could be a health concern.
Copper was included as a "major contaminant" because it is
normally included in the "heavy metals" classification of
hazardous tubstances and it was frequently measured at above
the minimum detection level during the investigation of the
site.
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