United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/082
August 1991
&EPA Superfund
Record of Decision:
Tri-City Industrial Disposal,
KY
-------
50272-101
REPORT DOCUMENTATION 1'. REPORT NO.
PAGE EPA/ROD/R04-91/082
4.. TItle 8nd SWthIe
SUPERFUND RECORD OF DECISION
ri-City Industrial Disposal, KY
First Remedial Action - Final
7. Aulhor(81
1 ~
3. RecIpient'. Acceulon No.
5. Report Date
08/28/91
8.
8. Perfonnlng OrganlDtion Rept. No.
t. Pwrfonnlng Orgalnlzdon NIm8 8nd AddI888
10. ProJecVT.8klW0tk Unit No.
". Conttact(C) or Grant(G) No.
(C)
(G)
1~ ~ OrguU8tlon MIme 8nd Adch88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report . Period Covered
Agency
800/000
14.
15. Supplementary No..
..
16. Abetr.ct (LIdt: 200 worda)
The ~49-acre Tri-Cfty Industrial Disposal site is an inictive industrial waste
landfill located in Brooks, Bullitt County, Kentucky. Land use in the area is
predominantly agricultural and residential. The estimated 300 people who reside
within 1 mile of the site use ground water from a thin unconfined limestone aquifer
as their drinking water supply. Ground water discharges via several springs
~ncluding the Cox and Klapper Springs. From 1964 to 1967, Tri-City Industrial
,ervices, Inc., used the site to dispose of industrial waste including scrap lumber,
fiberglass insulation materials, drummed liquid wastes, and bulk liquids that were
poured onto the ground. In 1968, State officials reported that highly volatile
liquid wastes resembling paint thinners were disposed of on site. The site was a
source of citizen complaints about the condition of the landfill, explosions, fires,
and smoke during the disposal operations. A number of State and EPA investigations
were conducted between 1965 and 1989, which identified contaminants including PCBs,
phenols, metals, and various organic compounds in onsite soil, wastes, and
residential springs. In 1988, EPA provided local residents with an alternate water
supply, and conducted an emergency removal action to excavate and remove
(See Attached Page)
17. DocumenUnaJy818 L DMcripto..
Record of Decision - Tri-City
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (DCE,
Industrial Disposal, KY
PCE, TCE, toluene, vinyl chloride)
b. 1den1Ulenl0pen-Ended T-
c. COSA 11 Fl8lcl/Group
... Avlil8bility St8t.-nt
18. Secwity CI... (Thi8 Report)
None
20. Security CI... (Thl. Page)
None
21. No. 01 Page.
314
~ Price
~ AlS-Z38.18)
See /rutrucfiOM on Reve-
272 (4-77)
(Formerty NTlS-35)
Department of Conwnefee
-------
EPA/ROD/R04-91/082
Tri-City Industrial Disposal, KY
First Remedial Action - Final
stract (Continued)
approximately 165 drums in generally good condition, other crushed and empty drums,
metal containers, auto parts, 400 gallons of free liquids, and over 800 cubic yards of
suspected contaminated soil. This Record of Decision (ROD) addresses ground water
contamination as Operable Unit 1 (OU1). Should the confirmatory sampling of soil,
sediment, and air conducted in OU1 reveal unacceptable levels of hazardous
contaminants, additional measures may be necessary and will be implemented as OU2. The
primary contaminants of concern affecting the ground water are VOCs including DCE, PCE,
TCE, toluene, and vinyl chloride.
The selected remedial action for this site includes installing a carbon adsorption
system at the Cox Spring; treating contaminated ground water using carbon adsorption
and discharging the treated ground water to tributaries downstream of the springs;
conducting a leachability test to determine whether spent carbon is a hazardous waste;
regenerating, or treating and disposing of spent carbon offsite; continuing to provide
potable water to residents who previously used contaminated ground water as potable.
water until acceptable levels are reached; confirmatory sampling of soil, sediment, and
ambient air to assess the effectiveness of EPA's 1988 Emergency Removal Action;
long-term monitoring of ground water, surface water, sediment, and ecology;
implementing a worker health and safety program; and implementing institutional
controls including ground water use restrictions. The estimated present worth cost for
this remedial action is $2,098,000, which includes an annual O&M cost of $89,890 for
years 0-1, $70,686 for years 2-3, and $66,330 for years 4-30.
'~FORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals
~ed on SDWA MCLs or non-zero MCLGs, and include PCE 5 ug/l (MCL), TCE 5 ug/l
~oluene 1,000 ug/l (MCL), and xylenes 10,000 ug/l (MCL).
are
(MCL) ,
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
TRI-CITY INDUSTRIAL DISPOSAL SITE
OPERABLE UNIT .1
BROOKS, BULLITT COUNTY, KENTUCKY
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
-------
TRI-CITY INDUSTRIAL DISPOSAL SITE
BROOKS, BULLITT COUNTY, KENTUCKY
DECLARATION FOR THE RECORD OF DECISION
OPERABLE UNIT t 1
SITE NAME AND LOCATION
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial
action for Operable Unit 11 at the Tri-City Industrial Disposal
Site in Brooks, Kentucky, which was developed in accordance with
the Comprehensive Environmental Response,. Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments. and Reauthorization Act of 1986 (SARA) and, to the
extent practicable,the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based upon
the contents of the Administrative Record for the Tri-City
Industrial Disposal Site. .
At this time, the Commonwealth of Kentucky generally concurs
with the selected remedy for Operable Unit #1.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances. from
this' site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF SELECTED REMEDY
This operable unit is the first remedial action for the
Site. This remedy addresses clean-up of the groundwater (as it
discharges to the surface as springs) by eliminating or
reducing, through treatment, engineering, and institutional
controls, the risks posed by the Site. .
The major components of the selected remedy include:
Treatment of groundwater having contaminant
concentrations in excess of Maximum Contaminant Levels
(MCLs) and non-zero Maximum Contaminant Level Goals
(MCLGs);
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Declaration - Page 2
Continued provision of potable water 'to residents
affected by groundwater containing contaminant
concentrations in excess of MCLs and non-zero MCLGs~
Restrictions on the usage of groundwater
purposes until monitoring indicates that
of sufficient and consistent quality for
consumpt~on~
Confirmatory sampling of site soils, sediment, and
ambient air to ensure that all possible areas of
contamination are investigated~ and,
for domestic
the water is
human
Long-term monitoring of groundwater, surface water,
sediment, and ecology to identify additional
site-related impacts.
Should the confirmatory sampling included in Operable unit
.1 reveal unacceptable levels of hazardous contaminants, the
additional measures necessary to mitigate any threat to human
health and the environment will be implemented as Operable Unit
'2.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health, 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 trea~ment technologies to the maximum extent
practicable, and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
as a principal element.
Since 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.
G~rn/3tw
~Greer C. Tidwell, Regional
AUG 2 8 1991
Administrator
Date
-------
SECTION
1.0
2.0
3.0
4.0
5.0
6.0
7.0
TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION
1.1
1.2
Site Location
Site Description
. SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1
2.2
2.3
2.4
Site History
Initial Investigations
Removal Actions
Remedial Investigation/Feasibility
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE AND ROLE OF RESPONSE ACTIO~
SUMMARY OF SITE CHARACTERISTICS
5.1
5.2
5.3
Site Geology and Hydrogeology
Nature of Contamination
Extent of Contamination
5.3.1 Groundwater
5.3.2 Soils
5.3.3 Surface Water
5.3.4 Sediments
5.3.5 Air
6.1
SUMMARY OF SITE RISKS
6.2
6.3
Human Health Risks
6.1.1 Contaminants of Concern
6.1.2 Exposure Assessment
6.1.3 Toxicity Assessment
6.1.4 Risk Characterization
6.1.5 Risk Uncertainty
Environmental Risks
SWlllDary
DESCRIPTION OF ALTERNATIVES
7.1
7.2
7.3
Background
Remedial Alternatives
ARARs
-i-
Study
PAGE
1
1
1
6
6
7
8
12
16
17 .
17
17
20
23
23.
34
42
42
46
50
50
50
52
52
54
58
59
64
66
66
67
76
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SECTION
8.0
9.0
10.0
TABLE OF CONTENTS (cont'd)
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
Overall Protection of Human Health and
the Environment
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
. THE SELECTED REMEDY
THE STATUTORY DETERMINATIONS
10.1
10.2
10.3
10.4
10.5
Protection of Human Health and the
Environment
Compliance with ARARs
Cost Effectiveness
Utilization ot Permanent Solutions and
Alternative Treatment Technologies or
Resource Recovery Technologies to the
Maximum Extent Practicable
Preference for Treatment as a Principal
Element
APPENDIX A - KENTUCKY SURFACE WATER STANDARDS
APPENDIX B - COMMENTS FROM THE COMMONWEALTH OF KENTUCKY
REGARDING THE DRAFT RECORD OF DECISION
APPENDIX C - RESPONSIVENESS SUMMARY
-ii-
PAGE
77
77
78
79
80
81
81
82
83
84
84
89
89
91
92
92
93
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FIGURE
1
2
3.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
LIST OF FIGURES
TITLE
SITE LOCATION
SITE LAYOUT
GENERALIZED GEOLOGIC CROSS-SECTION
GEOPHYSICAL INVESTIGATION AREA
ELECTROMAGNETIC ANOMALIES
MAGNETIC ANOMALIES
SITE SKETCH SHOWING EMERGENCY REMOVAL TRENCH
SITE SKETCH SHOWING TEST PITS AND TRENCHES
APPROXIMATE WASTE DISPOSAL AREAS
KENTUCKY INVESTIGATION SAMPLE LOCATIONS
EPA SAMPLING LOCATIONS, MAY 1988
RI SPRING SAMPLING LOCATIONS
RI GROUNDWATER MONITORING WELL AND SOIL BORING
LOCATIONS
FASP SAMPLING LOCATIONS
RI SURFACE SOIL SAMPLING LOCATIONS
RI SURFACE WATER, SEDIMENT, AND AQUATIC BIOTA
SAMPLE LOCATIONS
RI AMBIENT AIR SAMPLING LOCATIONS
DIAGRAM OF SELECTED REMEDY
-iii-
PAGE
2
3
5
9
10
11
13
14
15
21
22
29
32
38
40
44
49
88
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TABLE.
1
2
3
4
5
6
7
8
9
10
11
12
13
. 14
. 15
LIST OF TABLES
TITLE
SUMMARY OF ANALYTICAL RESULTS
KENTUCKY SITE INVESTIGATION, APRIL 1987
CURRENT AND PROPOSED MCLs AND MCLGs
SUMMARY OF ORGANIC ANALYSES
EPA GROUNDWATER INVESTIGATION, MAY 1988
SUMMARY OF INORGANIC ANALYSES
EPA GROUNDWATER INVESTIGATION, MAY 1988
SUMMARY OF ORGANIC ANALYSES
RI SPRING SAMPLING, JULY 1989
SUMMARY OF INORGANIC ANALYSES
RI SPRING SAMPLING, JULY 1989
SUMMARY OF INORGANIC ANALYSES
RI GROUNDWATER SAMPLING, SEPT-NOV 1989
SUMMARY OF VOLATILE ORGANIC ANALYSES
EPA GROUNDWATER INVESTIGATION, DECEMBER 1990
SUMMARY OF INORGANIC ANALYSES
EPA GROUNDWATER INVESTIGATION, DECEMBER 1990
SUMMARY OF INORGANIC ANALYSES AS RANGES OF DATA
RI SURFACE & SUBSURFACE SOILS SAMPLING, 1989
SUMMARY OF INORGANIC ANALYSES AS RANGES OF DATA
RI SURFACE SOILS INVESTIGATION, DECEMBER 1990
SUMMARY OF INORGANIC ANALYSES
RI SURFACE WATER SAMPLING, JULY 1989
SUMMARY OF INORGANIC ANALYSES
RI STREAM SEDIMENT SAMPLING, JULY 1989
CONTAMINANTS OF CONCERN.
EXPOSURE .AND INTAKE ASSUMPTIONS FOR DERMAL
CON~ACT.AND INGESTION OF SURFACE (PRESENT)
ASD SUBSURFACE (FUTURE') SOIL PATHWAY MODELING
-iv-
~
24
25
27
28
30
31 .
33
35
36
41
43
45
47, 48
51
53
-------
TABLE
16
17
18
19
20
LIST OF TABLES (cont'd)
TITLE
TOXICOLOGICAL CRITERIA VALUES FOR CARCINOGENIC
HEALTH EFFECTS
TOXICOLOGICAL CRITERIA VALUES FOR NONCANCER
HEALTH BFFBCTS
SUMMARY OF BR-L CONCENTRATIONS FOR METALS
IN SEDIMENT
. "-
SUMMARY OF COSTS FOR REMEDIAL ALTBRNATIVES
SITE-SPECIFIC MCLa AND MCLGa (in PPB)
"¥
-
..
-v-
PAGE
55
56
61
70, 71
73
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TRI-CITY INDUSTRIAL DISPOSAL SITB
BROOKS, BULLITT COUNTY, KENTUCKY
TBE DECISION SUMMARY
1.0
SITE LOCATION AND DESCRIPTION
1.1
Site Location
The Tri-City Industrial Disposal. Superfund Site (the "Site")
is located in the community of Brooks in north-central Bullitt
County, Kentucky, approximately 15 miles south of Louisville
(see Figure 1). The Site consists of approximately 349 acres
and it is located on the south side of State Bighway 1526 (also
known as Brooks Bill Road), approximately four mile~ west of
u.S. Interstate 65 (see Figure 2). The geographical coordinates
for the Site are 38°2'50.9" north latitude and 85°46'06.1" west
longitude.
1.2
Site .Descriction
The Site is located in the Blue Grass Region of the Interior'
Low Plateaus Physiographic Province. The Blue Grass Region lies
within the Ohio River drainage basin and it is an area of
generally rolling uplands ranging in elevation from less than
800 feet above mean sea level (msl) in the northwest to .about
1000 feet in the southeast. The Site is within the Knobs
Regional Subdivision of the Blue Grass Region.
The climate in the Blue Grass Region is moderate with a mean
annual temperature of 67°F. The average annual summer
temperature is 75°F, and the average annual winter temperature
is 35°F. The average annual precipitation in Bullitt County is
55 inches and the mean annual lake evaporation is 35 inches,
resulting in a net precipitation of 20 inches.
Approximately 300 people live within one mile of the Site.
The Site and surrounding area are rural and the land use ~s
predominantly agricultural and residential. Several residences
exist on and adjacent to former disposal areas at the Site, and
a portion of the Site is used for agricultural purposes (i.e.,
pastures and small gardens). Other areas of the Site are
covered with grass and trees.
Notable surface features on-site include a shallow trench
partially filled with water at the southern end of the Site that
is approximately 240 feet long and 80 feet wide, and two shallow
ponds (each less than 1/8 of an acre), which are used to water
livestock.
-1-
-------
-2-
,/
FIGURE 1.
Site Location Map
",I>
. ~ ~
.<
...",c.",j
/
/~
",I>
~,
0,;'
"
,,-
"
< .
>
"
" .
"
,-
/
"
~
'1'
l
-------
Tri-City Industrial
Disposal Site
Study Area
EL 800 Ft.
EL. 600 Ft. X
-^
EL. 600 Fl. \/
BEGHTOL
RESIDENCE
BROOKS HILL ROAD (Hwy. 1526)
^^r 1
COX COXl,.
-SPRING RESID
KLAPPER •
BRAD.NG "ES.DEN/E
RESIDENCE *
LEGEND
RESIDENCE
A, SPRING
X ELEVATION ABOVE MSI.
"" FORMER TRI CITY
DISPOSAL AREA
0 830 Fl.
SCALE IN FEET
FIGURE 2. Site Layout
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-4-
Situated on a broad ridge known as the Beghtol Ridge, the
Site slope. moderately to the south. The elevations across the
Site range from 800 feet to 840 feet above msl. The southern
boundary and portions of the eastern and western boundaries drop
into steep, vegetated ravines having bottom elevations ranging
from 600 feet to 800 feet above msl within 400 horizontal feet
from the Site.
The original soils of the Site are classified as Crider silt
loams which are formed on long, steep hillsides and broad, .
gently sloping to moderately steep ridgetops and shoulder slopes,
above deep valleys. Crider soils are described as deep and well
drained with upper loamy zones and clayey subsoils.
The underlying geology of the area consists of limestones,
dolomites, siltstones, and silty shales in the upland Knob area,
and terrace deposits in the lowland valleys. The geologic
formations underlying the Site include, in stratigraphic order
(top to bottom), the Salem Limestone, the Barrodsburg Limestone,
and members of the Borden Formation. Figure 2 shows the
stratigraphy of the area. Formation thic.kness in the vicinity
of the Site ranges from 18 to 25 feet based on the geologic
map. Karst features are not developed at the Site due to the
significant amount of siltstone and shales interbedded within
the limestones underlying the Site. .
The groundwater at the Site primarily flows through
fractures and bedding planes that have been preferentially
enlarged by solutioning and where dolomitization has enhanced
the porosity and permeability of the aquifer. Groundwater
discharges via springs and seeps that sporadically occur where
the geologic units that comprise the aquifer are exposed.
Although the springs and seeps in the shallow limestone aquifer
tend to stop flowing during dry periods, they do produce
sufficient quantities of water for domestic use with the
assistance of a cistern. Springs are used. as water supply. .
sources more frequently than drilled wells due to the sporadic
and unpredictable occurrence of water in the members.
The Site is drained to the west, south, and east by Brushy
Fork Creek, which is a perennial stream. The springs and seeps
at the' Site represent sources of groundwater which contribute to
surface water runoff to Brushy Fork Creek. The source for the
creek is a small spring approximately 3,000 feet southeast of
the Site and located at an elevation of approximately 750 feet
above msl. Brushy Fork Creek flows westward for approximately
two miles, where it joins Knob Creek and becomes part of the
Ohio River drainage network. .
-------
850 ft.
800 ft.
750 ft.
700 ft.
wat
TRI-CITY SITE AREA
east
...
...
LEGEND
BORDEN FORMATION
QaI
MS
Mhb
IMbm
Mbh
QUATERNARY ALLUVIUM
SALEM LlMFSrONE
HARRODSBURGH LlMFSrONE
MULDRAUGH MEMBER
HOLTSCLAW MEMBER
GENERAUZED GEOLOGICAL CROSS SECTION
TRI-CITY INDUSTRIAL DISPOSAL SITE
BULUIT COUNTY. KENTUCKY
EBASCO &EIMC.ES tNCORI'ORA TED
. . D t
850 ft.
800ft.
750 ft.
700 ft.
I
\J1
,
FIGURE J
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-6-
Brushy Fork Creek is used seasonally for recreational
purposes and for the irrigation of nearby crops. The creek
appears to be a healthy stream supporting diverse communities of
macroinvertebrates and small fish. Adequate feeding habitat for
endangered species of bats and the bald eagle were determined to
not exist within the stream reach of Brushy Fork Creek and the
tributaries which are affected by the Site.
The Site is not located in a lOa-year floodplain. And, the
u.S. Fish and wildlife Service (FWS) has determined that Brushy
-Fork Creek is not a habitat for endangered species. The FWS has
also determined that the Site is not on a wetland, nor does it
affect a wetland.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1
Site Historv
i .
The Site was an industrial waste landfill known to have been
operated by Tri-City Industrial Services, Inc. from late 1964 to'
late 1967. The majority of the material reportedly disposed of
at the Site was industrial. in origin from several Louisville,
Kentucky industries. The bulk of the waste consisted of scrap
lumber and fiberglass insulation materials. The remaining waste
consisted of drummed liquid wastes and bulk liquids that were
poured onto the ground. In 1968, State officials reported that
highly volatile liquid wastes resembling paint thinners were
disposed of on-site.
Records indicate that a site attendant was present at the
Site at least during a portion of the time the landfill was
operated. The duties of the site attendant included pushing
each day's collection of refuse over the working face of the
landfill into the surrounding ravines. In at least one
instance, the attendant was instructed to pour liquid waste
material directly onto the ground to help alleviate fire and
explosion hazards.
The Site was a source of local citizen complaints and
concerns to state and county government officials on numerous
occasions during the disposal operations. In 1965, residents
near the Site first complained to local officials regarding the
unkempt condition of the landfill, explosions, fires, and smoke
which was said to irritate eyes~ make breathing difficult, and
have an offensive odo~. Additionally, deposition of ash and
charred debris on neighboring properties led to a civil lawsuit
for creating a public nuisance.
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-7-
The Bullitt County Health Department, County Attorney, and
the Commonwealth of Kentucky Department of Fish and Wildlife
Resources (then the Division of Fisheries) along with the
Department of Health (then the Division of Environmental Health)
investigated~hese complaints. An indictment, served to
Tri-City Industrial Services, Inc. and others in November 1967,
resulted in the arrest of the company's president, Mr. Barry
Kletter, on the nuisance charge. After Mr. Kletter's arrest, a
settlement was negotiated whereby the charges would be dropped
if the company agreed to stop disposing of and burning waste at
the Site. At about the same time as the arrest, a fire erupted
on the Site that burned for two years. Tri-City Industrial
Services, Inc. reportedly ceased all waste disposal activity
shortly after the fire began.
2.2
Initial Investiaations
BPA's involvement with the Site commenced in September 1985
following. notification by the Kentucky Natural Resources and
Environmental Protection Cabinet (the "Cabinet"). The Cabinet
conducted a Preliminary Assessment (PA) of the Site in September
1985 and recommended a high priority for inspection. The
Cabinet performed a Site Investigation (SI) in April 1987 to
determine the Site's eligibility for inclusion on EPA's National
Priority List (NPL). The investigation included identification
of several private, potable water supplies near.the Site and
multi-media sampling (waste, soil, and groundwater). Several
hazardous substances were detected in on-site soils and wastes,
including PCBs, phenols, heavy metals, and various organic
compounds. One residential spring, utilized by the Klapper
family as a source of potable water, located several hundred
yards west of the Site was sampled and it contained levels of
tetrachloroethene (also known as perchloroethylene, or PCB)
above Maximum Contaminant Levels (MCLs).
Following the Cabinet's release of the sampling results, EPA
conducted additional sampling and provided an alternate water
supply to the two Klapper residences in May 1988. EPA also
discovered that another spring closer to the Site was being used
as a source of potable water by Mr. and Mrs. William D. Cox,
Sr. Bottled water was supplied to the Cox, Sr. residence until
sampling results were obtained. Sampling of the Cox Spring.was
included in a May 1988 survey of potable water sources conducted
by EPA within an approximate on~-half mile radius of the Site.
The sampling confirmed again the presence of PCE in the Klapper
Spring, and,elevated levels of PCE and trichloroethene (TCE)
were found in the Cox Spring. . This survey identified the two
Klapper residences and the Cox, Sr. residence as the only
affected households within the investigated area. The provision
of bottled water to the Cox, Sr. residence and two Klapper
residences is an ongoing action funded by EPA.
-------
-8-
The findings of the potable water survey prompted EPA to
conduct an additional study in June 1988, the emphasis of which
was to assess the 'Site's potential impact on area residents via
ingestion of groundwater, inhalation of soil particulates, and
direct contact. Sample locations included sensitive areas such
as yards, gardens, and potable water supplies. Samples
collected included five composite surface soil samples, three
waste samples, and four groundwater samples.
The Site was proposed for inclusion on the NPL on June 24,
~988 (53 FR 23988) based primarily on the potential hazard from
contaminated groundwater. The Site became final on the NPL on
March 31, 1989 (54 FR 13302) with a Hazard Ranking Score (HRS)
of 33.82.
2.3
Removal Actions
The Site received further attention in June 1988 when EPA
responded to a telephone call from the Cox, Sr. family regarding
a "black ooze" emanating from their side yard. EPA's Technical
Assistance Team (TAT) contractor, Roy F.. Weston, collected two
samples from the reported stained area and also from a solid
material resembling paint waste. The samples indicated elevated
levels of xylene, toluene, ethylbenzene, and lead.
NUS Corporation, EPA's Field Investigation Team (FIT)
contractor, conducted a geophysical survey and field analytical
screening procedures (FASP) at the Site in August 1988 to
delineate waste disposal areas and provide additional subsurface
information. Magnetometry, resistivity, and electromagnetic
terrain conductivity surveys were performed during the
geophysical investigation. The study area is shown in Figure
4. The electromagnetic and magnetic anomalies are shown in .
Figures 5 and 6, respectively.
To complement and substantiate the information collected
during the geophysical survey, FASP were also conducted. The
FASP techniques employed were gas probes and subsurface soil
sample collection with analyses for volatile organic compounds
(VOCs). The locations for FASP were selected from those
geophysically anomalous areas yielding the highest
electromagnetic and magnetic readings.
The results of the FASP study tended to substantiate the
geophysical findings by detecting VOCs in significant
concentration close to the anomalies. Given the correlation
between the 'two surveys, the disposal of the waste was
apparently concentrated in the southern half of the landfill.
-------
-9-
l MOO.'..
"IIIDINCI
'IILD
CO
()
.:: 0
o
o
o
""~ 0
.(/..
GEOPHYSICAL INVESTIGATION AREA
TRI-CITY INDUSTRIAL DISPOSAL
BROOKS, BULLITT COUNTY, KENTUCKY
o
100 It.
ICALI
FIGURE 4
rnNt!@
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-10-
HOOSIIft
RESIOENCI
SPRING': 0
0
LEGEND
SJ ELECTROMAGNETIC ANOMALIES
, ANOMALIES
INDUSTRIAL DISPOSAL
BROOKS, BULLITT COUNTY, KENTUCKY
FIGURE 5
PRIMUS
-------
-11-
Hootiiit
RISIOINCI
LEGEND
MAONITIC ANOMALIES
0 100 ft.
•CALI
MAGNETIC ANOMALIES
TRI-CITY INDUSTRIAL DISPOSAL
BROOKS, BULLITT COUNTY, KENTUCKY
FIGURE 6
FfflIM! IS
1 MM^*^ I = tfTO\l
-------
-12-
Based on the results of the sampling conducted by EPA's TAT
contractor and the proximity of the contamination to the Cox,
Sr. residence, EPA conducted an Emergency Removal Action in
August and September 1988 to excavate and remove approximately
165 drums (f~ll or partially full) that were in generally good
condition, many crushed and empty drums, metal containers of
various sizes, auto parts, 400 gallons of free liquids, and over
800 cubic yards of suspected contaminated soil. The resulting
trench in the side yard was approximately ten feet deep, twelve
to fifteen feet wide, and thirty feet long. As shown in Figure
7, the trench extended northward through a portion of the
driveway. .
Following completion of the removal trench, numerous test
trenches were excavated to identify additional waste disposal
areas. The results of the geophysical surveys were used to aid
in determining the trenching locations. As shown in Figure 8,
the trenches were excavated in the Cox, Sr. side yard,
throughout a pasture east of the Cox, Sr. residence, and on the
Hoosier's.property, which is a five to seven acre tract east of.
the pasture that was sold by Mr. Cox, Sr. A limited number of
empty drums and drums containing solids were excavated and
staged, but no additional liquids were located. Primarily, the
operators encountered waste fiberglass insulation and ash,
indicating the historical fires. Many of the geophysical
anomalies were insulation and wire. The test excavation was
discontinued in September 1988 and the trenches were backfilled
and graded.
2.4
Remedial Investiaation/Feasibility Study
EPA began a Remedial Investigation (RI) in July 1989 to
characterize the Site and determine the nature and extent of
contamination. Since the geophysical survey and FASP indicated
that the disposal of waste was concentrated in the southern half
of the landfill, the field activities of the RI were
concentrated in that area. Figure 9 shows the RI sampling
locations with respect to the approximate waste disposal areas
based on two aerial photographs taken in May 1966 and January
1967.
Phase I of the RI was performed in July 1989 and the
activities included site topographic mapping, a surficial
geological assessment, surface water and sediment sampling,
spring sampling, surface soil sampling, and an aquatic biota
survey. Phase II of the RI was conducted from September to
November 1989 and the activities ~ncluded ground surveying,
temporary soil borings, subsurface soil sampling,' subsurface
geophysical investigations, groundwater investigations, aquifer.
tests, and air monitoring. All work was conducted by EPA's REM
III contractor, Ebasco Services, Inc.
-------
I
,
I
I :"""""""'" 're'nee" ""....."..,~
, Hoosier Property :
, , , , , .., .. . . . .. , .. , , , , , . .. , '!' , . , . . , , , , , , . . . , , . . , .. , , . , , .. . , , , .. , , , , . , , , , , .. . , . , , , . . . , . , . , . . , , . . , , , , .. '.. , .. , , . , . ..' , .. . . . , ......:
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WESTON MAJOR PROGRAMS
Region IV TAT
SITE'
Tri-City Industrial Disposal Site
ACTIVI1Y DESCRIPTION:~i!.e_,~ket~.h Indicati~~~-
too NO.:
04-8810-20 PCS' 2020
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I Cox Hom,
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Primary Drum
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Region IV TAT
Tri-City I~dustrial Disposal Site
WESTON MAJOR PROGRAMS
ACTIVITY DESCRIPTION:
SITE'
Size Edited Site Sketch With
04-8810-20 PCSN 2020
J~ 1989
TOO NO.:
~~~im~t.~
-------
-.1..)-
I
SOURCES:
MAY 1H6EP1C AERIAL PHOTO
JAN. 1H7 EPIC AEIUAL PHOTO
$5-01 (E)
LEGEND
WASTE DISPOSAL
AREAS -MAY, 1966
WASTE DISPOSAL
AREAS- JANUARY,I961
DRUM
STORAGE AND .
DISPOSAL AREAS (1)
EU5CO
APPROXIMATE WASTE DISPOSAL AREAS
COMPUED TO SAMPLING LOCADONS
TRI.cITY INDUSTRIAL DISPOSAL mE
BVLLn7 COUNTY KENTUCKY
FIGURE 9
EIMCO.IMCD ~TID
-------
-16-
During the RI, six groundwater monitoring wells were
installed and sampled. The installation of seven other wells
was attempted, but the wells were not completed because of
insufficient groundwater. Four springs were. sampled, and six
surface water samples were taken from Brushy Fork Creek and the
two tributaries that discharge to the creek. Twelve sediment
samples were collected in the areas of ~he springs and Brushy
Fork Creek. Twenty surface soil samples and twenty-five
subsurface soil samples were collected. In addition, sixteen
. air samples were collected at three locations that were selected
based on prevailing wind directions and the locations of
residents.
EPA conducted additional sampling of several springs,
including the Cox and Klapper Springs, and one monitoring well
in December 1990 to verify sampling conducted during the RI.
.Ebasco Services, Inc., under EPA's Alternative Remedial
Contracting Strategy (ARCS) IV contract, also conducted the
Feasibility Study to develop and evaluate remedial alternatives.
for addressing the Site's known contamination problems. The FS
was completed in April 1991, and EPA released the RI and FS
Reports to the public in May 1991. .
The Potentially Responsible Parties (PRPs) were notified in
writing in November 1988 and May 1989 via special notice letters
and given the opportunity to conduct the RIfFS with EPA .
oversight. However, none of the parties elected to undertake
these activities.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION.
A Community Relations Plan (CRP) for the Tri-City Site was
finalized in May 1989. This document included a list of
contacts and interested parties throughout government and the
local community. The CRP also established communication. .
pathways to ensure timely dissemination of pertinent.
information.
A fact sheet describing the Site and the nature of the RIfFS
proc~ss was distributed to the public in May 1989. EPA held an
availability session in Shepherdsville, Kentucky on June 1, 1989
. to discuss the RIfFS activities .and site-related concerns with
the community.
The RI and FS Reports were released to the public on May 2,
1991. The Proposed Plan Fact Sheet, which described EPA's
preferred alternative for remediation of the Site, was
distributed on April 19, 1991. The information used by EPA to
select a response action under CERCLA, including the previously
mentioned documents, has been included in the Administrative
Record at the information repositories located in the Ridgway
-------
-17-
Memorial Library in Shepherdsville, Kentucky and the Records
Center in EPA's Region IV office in Atlanta, Georgia.
A public ~omment period was held from May 2, 1991 to June 1,
1991. In addition, a public meeting was held on May 9, 1991 to
present the results of the RIfFS and to discuss the preferred
alternative as presented in the Proposed Plan Fact Sheet for the
Site. All comments received by EPA during the public comment
period, including those expressed verbally at the public
meeting, are addressed in the Responsiveness Summary contained
in Appendix C of this document. . The comments from the.
Commonwealth of Kentucky and EPA's response are included in
Appendix B. .
4.0
SCOPE AND ROLE OF RESPONSE ACTION
The Tri-City Site has been divided into two operable units.
Operable Unit 11 will include the remediation of contaminated
groundwater and confirmatory sampling to identify any
unacceptable levels of hazardous contaminants in areas of the
Site not otherwise addressed. Operable Unit .2 will involve the
additional measures necessary to mitigate any threat to human
health or the environment identified during the confirmatory
sampling in the first operable unit.
The remedy selected in this ROD is for Operable Unit 11 and
it addresses the contaminated groundwater as it discharges to
the springs. Contaminated groundwater poses the known major
threat to human health and the environment at the Site due to
the risk associated with ingestion of water containing volatile
organic compounds at levels above MCLs and non-zero Maximum
Contaminant Level Goals (MCLGs). Institutional controls will be
implemented to restrict potable usage and monitor springs in the
area of the Site until the water is of sufficient and consistent
quality for human consumption. Potable water will continue to
be provided to affected residents.
Operable Unit .1 also includes confirmatory sampling of site
soils, sediment, and ambient air to identify and define
additional areas of the Site that constitute a threat to human
. health and the environment. Long-term monitoring of the
groundwater, springs, surface water, sediment, and ecology will
be implemented to identify any site-related impacts.
5.0
SUMMARY OF SITE CHARACTERISTICS
5.1
Site Geoloqy and Bvdroaeoloqy
The local geology in the area of the Tri-City Site is
dominated by sedimentary rocks of Mississipian age. These
-------
-18-
include, in stratigraphic order (top to bottom), the Salem
Limestone, the Harrodsburg Limestone, and members of the Borden
Formation (the Muldraugh Member, the Holtsclaw Siltstone-Member,
and the Haney Member). The-stratigraphy of the area is shown in
Figure 2.
The Salem Limestone is described as interbedded limestone
and shale -which forms the caprock on most of the hills in the
Knob Region west of Sun Rise Ridge. Formation thickness in the
vicinity of the Site ranges from 18 to 25 feet based on the
geologic map. The contact of the Salem Limestone with the
. underlying Harrodsburg Limestone is generally distinct and
weathers to a silicified bed of granular fossil-fragmented
limestone.
The Harrodsburg Limestone forms the caprock on most of the
ridges and consists of light gray to yellowish gray fossil-
fragmented limestone weathering to a reddish, cherty clay soil.
The contact of the Harrodsburg Limestone with the underlying
Muldraugh Member of the Borden Formation is a clearly marked
lithologic change and is possibly unconformable.
The surficial, thin limestone aquifer is composed of the
Salem Limestone and the Harrodsburg Limestone. This aquifer is
unconfined and it varies from 10 to 50 feet in thickness. The
. groundwater moves along preferential flow p~thways within the
irregular contact between the partially decomposed and
completely decomposed rock (the overburden), thin fractures, and
solution channels along bedding planes. Springs and seeps
sporadically occur where the geologic units that comprise the
aquifer are exposed and mark the discharge points for the
preferential flow pathways.
The Muldraugh Member is the upper unit of the Borden
Formation and it consists of dolomitic siltstone, silty
dolomite, and limestone. Quartz geodes are common in the
dolomitic- siltstone and are a distinguishing feature of the
upper Muldraugh. A distinctive glauconite seam overlies the
limestone and is present in areas where the limestone is
absent. As a result, the glauconite seam is mapped as the base
of the Muldraugh Member.
The Holtsclaw Siltstone Member underlies the Muldraugh
Member and it is composed of siltstone and silty shale. The
siltstone in the Holtsclaw Member contains iron-stained, medium
gray, calcareous concretions. Locally, the Holtsclaw Member has
a silty shale near the top of the unit which is similar to the
underlying Haney Member. The contact between the Holtsclaw
Member and the Hancy Member is gradational with interbedding
over an interval as great as 40 feet. The Hancy Member is
composed of silty shale and it is stratigraphically equivalent
to the Holtsclaw Member in the area of the Site.
-------
-19-
Groundwater flows through interconnected fractures, bedding
planes, and dissolution pathways in the various members of the
Borden Formation. The extent of hydraulic connection, if any,
between the members is not known. The siltstone and limestone
units of these members produce sufficient water supplies for
domestic use. However, springs are used as water supply sources
more frequently than drilled wells due to the sporadic and
unpredictable occurrence of water in the members.
The data for the Tri-City Site indicates that most of the
recharge to the aquifers occurs on the north side of Beghtol
Ridge. Movement of groundwater is believed to be to the
south-southwest, moving down-dip along bedding planes and .
following availabl.e permeable pathways. Groundwater discharges
via springs and seeps which are predominantly located on the
south and west sides of Beghtol Ridge.
with the exception of bedrock outcrop occurrences along
dissecting streams, and at a limited number of other locations,
surface deposits at the Site consists of soils derived from the.
weathering of the Salem Limestone and Harrodsburg Limestone, or
an artificial fill comprised of disposal debris and locally
derived cover. Based on drilling and soil boring logs, the
unconsolidated zone ranges from 8.5 to 27 feet over the Site
with thinner overburden deposits in the northeast corner of the
Site and along the steep hillsides. The average depth to
bedrock is approximately 18 feet and maximum depths to bedrock
were in borings at the base of the hillsides.
Recharge to the aquifers occurs either by infiltration of
precipitation into the overburden or by infiltration of the
runoff directly into the aquifers. Infiltration through the
overburden to the partially decomposed rock of the Salem
Limestone/Harrodsburg Limestone aquifer is probably limited by
the low permeability and the thickness. Infiltration is
probably greater in the northern part of the Site (near the Cox,
Jr. and Hoosier residences) where the overburden is
approximately 5 feet thick due to past earthmoving operatioris,
than in the southern part of the Site. The low permeability and
greater thickness of the overburden also explains why the ponds
excavated in the southern part of the Site usually contain water
during periods when springs and seeps go dry.
Some hydraulic communication between the different aquifers
at the Site has been apparent. _Hydraulic communication between
the overburden and the Salem Limestone/Harrodsburg Limestone
aquifer is evident based on the springs and drilling. Springs
discharging from the Harrodsburg Limestone have been impacted by
contaminants buried in and/or poured onto the overburden" Water
or contaminants percolating through the overburden or wastes
-------
-20-
disposed on-site, or water infiltrating along the base of the
overburden, could enter the Salem Limestone/Barrodsburg
Limestone aquifer at the contact between the overburden and the
partially weathered rock to contaminate the aquifer.
Insufficient data exists to determine whether the Salem
Limestone/Barrodsburg Limestone aquifer and the Muldraugh Member
of the Borden Formation are hydraulically connected. The
contact between the two aquifers is marked by solutioning in the
Barrodsburg Limestone, which indicates that the Muldraugh Member
is more resistant. However, the extent of jointing or
fracturing in the Muldraugh Member or at the contact is not
known.
5.2
Nature of Contamination
The primary wastes of concern have been the drummed and bulk
liquids disposed of at the Site. The Cabinet's investigation in
April 1987 included the collection of two waste samples from
deteriorated drums protruding through the surface soil in the
ravine on the eastern side of the Site. These two samples,
although located near each other, .had significant differences in
composition. Sample TCD-08 contained much greater
concentrations of organic contaminants, with phenol,
4-methylphenol, and 2,4-dimethylphenol at 2860 ppm, 7813 ppm,
and 1553 ppm, respectively. Sample TCD-08A contained phenol and
4-methylphenol at concentrations less than 13 ppm. Sample
TCD-08A had significantly higher concentrations of inorganic
contaminants, exhibiting arsenic, chromium, lead, and mercury at
3.2 ppm, 49.3 ppm, 33.7 ppm, and 7.44 ppm, respectively. Each
of these contaminants was detected in sample TCD-08, but in
concentrations that ranged from 4.45 ppm to 0.024 ppm. Figure
10 shows the sampling locations during the Cabinet's
investigation.
During the additional study conducted by EPA in May 1988
three waste samples were collected from partially exposed drums
along the eastern and southern boundaries of the former disposal
area. The sample locations are shown in Figure 11. The
inorganic analyses of these samples revealed a number of
contaminants, including chromium, copper, lead, mercury, zinc,
and cyanide, which were common to all three samples. Of these
contaminants, lead was the most. predominant contaminant with
concentrations of 78 ppm to 390 ppm in the three samples.
Organic analyses were not conducted.
Waste samples were also co~lected by EPA during the
Emergency Removal Action conducted in August and September
1988. The hazardous materials indentified during the removal
included PCE, toluene, ethyl benzene, xylene, polychlorinated
biphenyls (PCBs), and lead.
-------
CATTLI
':~~ING
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LEGEND -', .,..-
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/1 IUR'ACI 08ITE
. IPRINO 'ACE 80lL COIIP L A I N
8ue8. MPLE OSAL
KDNREPy IN~USTRACLO~:~y,KENTUCKY
TRI-CIT BULLITT
BROOKS,. .
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RIIIDINCE
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LEGEND ,
wa8Te :
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TRI-CITY I:ULLITT COUN ,
BROOKS.
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FIGURE II
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-------
-23-
5.3
Extent of Contamination
Previous investigations at the Tri-City Site have included
sampling of groundwater, soils, surface water, sediments, and
ambient air. - The findings, by medium, are discussed below.
5.3.1
Groundwater
Groundwater, as it discharges to the surface as springs, has
been the predominant medium of concern at the Site because of
its use as a source of potable water. Groundwater has been
sampled in five separate events, one conducted by Kentucky and
four by EPA. The Kentucky investigation in April 1987 included
four groundwater samples, one each from Brading Spring '1,
Brading Spring '2, the Klapper Spring, and the unnamed spring on
the southeastern slope of the former disposal area. Al~ of the
springs, except for the unnamed spring, have been used as
sources of potable water. Brading Spring '1 is
topographically separated from the Site and is considered
representative of background conditions. Figure 10 shows the
sampling locations during the Cabinet's investigation.
The Kentucky investigation revealed organic contamination
. above background levels in the Klapper Spring and the unnamed
spring. However, only the levels of tetrachloroethene (PCE)
exceeded Maximum Contaminant Levels (MCLs). Metals levels did
not exceed MCLs. The analytical results are summarized in Table
1. Current and proposed MCLs and MCLGs that are pertinent to
the Site are listed in Table 2. .
EPA conducted further sampling of the Klapper Spring in May
1988. The results showed PCE at 133 ppb in the spring sample
and 50 ppb in the tap sample, levels which again exceeded MCLs.
Results of a screening of potable water sources conducted by EPA
in May 1988 again indicated the presence of PCE in the Klapper
Spring. In addition, PCE was detected in the Cox Spring.
Concurrent sampling done by the Cabinet and also analyzed in the
state's laboratory revealed levels of PCE above MCLs in the tap
and spring samples from the Cox, Sr. and Klapper residences.
This analysis also showed levels of TCE above MCLs in the spring
and tap samples collected from the Cox, Sr. residence. .
EPA collected four groundwater samples in late May 1988 as
part of an additional study to determine the impact of the
Site. These samples were collected from the Klapper Spring, the
Cox Spring, .the. Cattle Spring, and a private well near the
Beghtol residence. The sample locations are shown in Figure
11. The most significant findings were the analytical results
-------
TRI-CITY
TABLE 1
KENTUCKY SITE INVESTIGATION, APRIL 1987
INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF ANALYTICAL RESULTS (IN PPM)
GROUNDWATER SAMPLES
PARAHETER~ BRADING NO. 1 BRADING NO. 2 KLAPPER SPRING UNNAMED SPRING
Arsenic <0.001 0.001 <0.001 0.003
Barium 0.013 0.017 0.003 0.093
Cadmium <0.001 <0.001 <0.001 <0.001
Chromium 0.001 0.001 0.001 0.004
Lead <0.001 <0.001 <0.001 0.006
Mercury <0.0001 <0.0001 <0.0001 <0.0001
Selenium <0.001 0.006 0.006 0.005
Trane-1,2-Dich1oroethene <0.005 <0.005 <0.001 0.0028
1, 1, I-Trichloroethane ... <0.005 <0.005 0.0012 0.002
Trichloroethene (TCE) <0.005 <0.005 <0.001 0.0018
Tetrachloroet~ene (PCE) <0.005 <0.005 0.311 0.143 I
N
I,l-Dichloroethene <0.005. <0.005 0.0011 <0.001 ~
I
"
I
-------
-25-
TABLE 2
COJtRBNT AND PROPOSED MCLs AND MCLGs (in PPB)
PURGBABLE ORGANICS
MCL MCLG
100
7 7
70 70
100 100
S 0
1,000 1,000
200 200
S 0
2 0
10,000 10,000
Chloroform
1,1-Dichloroethene
Cis-l,2-Dichloroethene
Trans-1,2-Dichloroethene
Tetrachloroethene (PCB)
Toluene
i,l/l-Trichloroethane
Trichloroethene (TCB)
Vinyl Chloride
Xylenes
EXTRACTABLE ORGANICS
Bis (2-ethylhexyl) Phthalate
4*
0*
INORGANICS
Cadmium
Lead
Nickel
S
. 15**
100*
5
o
100*
. indicates a proposed MCL or MCLG
** indicates the action level established in S6 FR 26460,
June 7, 1991
- - indicates that a MCL or MCLG has not
been established
-------
-26-
from the Cox Spring sample. Four volatile organic compounds,
including PCB and TCB, were found at levels that exceeded MCLs.
PCB was again found in the Klapper Spring at an estimated value
that exceeded MCLs. One phthalate was found in the Cattle
Spring at a Tevel higher than the MCL. No contamination was
found in the well sample. The results of the organic analyses
are summarized in Table 3. Metals levels in the spring samples
did not exceed MCLs. The results of the inorganic analyses are
summarized in Table 4.
Samples from four springs were collected in July 198~ by
BPA's contractor, Bbasco Services, during the Remedial.
Investigation. A total of five samples, including one duplicate
from the Cox Spring, were collected from the Cox Spring, the.
Klapper Spring, the Cattle Spring, and Brading Spring No.2.
The sampling locations are shown in Figure 12. Only the samples
from the Cox Spring showed volatile organic contamination, with
the levels of four compounds exceeding MCLs. No semivolatile
organics or pesticides were found in the spring samples. A
summary of the organic analyses of the spring samples is shown .
in Table 5. Metals levels in the spring samples did not exceed
MCLs. The results of the inorganic analyses are summarized in
Table 6.
During Phase II of the RI, the installation of thirteen
monitoring wells was attempted. However, only six wells
provided sufficient water for completion. The attempted and
completed groundwater monitoring well locations are shown in
Figure 13. The well MW-02 is screened in the Harrodsburg
Limestone formation and the Muldraugh Member of the Borden
Formation. MW-04 and MW-08 are screened in the Muldraugh
Formation, and MW-05 is screened in the Salem Limestone
formation. MW-11 and MW-12 are screened in the Nancy Member of
the Borden Formation.
PCB was detected in monitoring well MW-04 at 10 ppb, a level
which is twice the MCL. Estimated quantities of total xylenes
were found in two samples collected from monitoring well MW-08,
but the levels were well below the MCL. No pesticides or
semivolatile organic compounds were found in the monitoring well
samples.
Cadmium was detected in the sample from MW-12 at a level
slightly above the MCL. Lead was detected in five well samples
from two different water formations at levels that ranged from 5
to 32 ppb. Lead was not detected in the formations immediately
underlying the Site. Nickel was found in five well samples from
three water formations at levels that ranged from 100 to 170
ppb. . Both metals occur naturally in the area of the Site, which
is a sedimentary environment dominated by limestones, shales,
and siltstones. The results of the inorganic analyses of the
samples from the groundwater monitoring wells are summarized in
Table 7. .
-------
-27-
TABLE 3
USEPA GROUNDWATER INVESTIGATION, MAY 1988
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF ORGANIC ANALYSES (IN PPB)
Beghtol
Parameters Cox Klapper Cattle Well
PURGEABLE ORGANICS
Chloroform 2.2J SOU s.OU s.OU
l,l-Dichloroethane 2.sJ SOU s.OU s.OU
l,l-Dichloroethene 1.2J. SOU s.OU s.OU
Cis-l,2-Dichloroethene 74J SOU s.OU s.OU
Trans-l,2-Dichloroethene O.92J SOU s.OU s.OU
Tetrachloroethene (PCE) 560 48J s.OU s.OU
Toluene s.OU SOU 9.4 s.OU
l,l,l-Trichloroe~ane 8.1 SOU s.OU s.OU
Trichloroethene [TCE) 69J SOU s.OU S.OU
Vinyl Chloride 2.9J SOU s.OU s.OU
O-Xylene s.OU SOU s.OU s.OU
(M- and/or P-) Xylene s.OU SOU s.OU s.OU
EXTRACTABLE ORGANICS
Benzo (A) Anthracene IOU IOU IOU IOU
Benzo (B and/or K) Fluoranthene IOU IOU IOU IOU
Bis (2-ethylhexyl) Phthalate IOU IOU 10 IOU
Chrysene IOU IOU IOU IOU
Fluoranthene IOU IOU IOU IOU
Phenanthrene IOU IOU IOU IOU
PYrene IOU IOU IOU IOU
U indicates that the material was analyzed for but not detected; the
number is the minimum quantitation limit.
-------
1
-28-
TABLE 4
USEPA GROUNDWATER INVESTIGATION, MAY 1988
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF I~ORGANIC ANALYSES (IN PPB)
PARAMETERS COX KLAPPER CATTLE BEGHTOL WELL
Aluminum 230 220 43,000 120
Barium .30 16 340 41
Calcium 100,000 63,000 100,000 100,000
Chromium 10U 10U 40 10U
Copper 10U 10U 39 12
Cyanide 4U 8U 4U 4U
Iron 200 170 52,000 50U
Lead 40U 40U 40U 40U .
Magnesium 6700 4300 11,000 28,000
Manganese 140 10U 3200 10U
Nickel 20U 20U 40 20U
Potassium 2000U 2000U 4700 2000U
Sodium 6400 4600 13,000 29,000
Zinc SO 76 180 22
U indicates that material was analyzed for but not detected;
the number is the minimum quantitation limit.
-------
EL. 600 FI. .
EL 800 Ft. .
5''''
. ...1I88G "'NG8, .
.a
.
..
LEGEND
RESIDENCE
x
SPRING
ELEVAnON AIIOVE MSL
SAMPLE LOCATION
NUMBER
5''''
.
EL. 600 Fl.
~
SPRING SA MrUNG I.oc.AnON MAr
TRI.crrV INDUSnlA L DISPOSAl. srr..
8Uu.rrrCOUNTY. KENnWKY
It'AKO.""" MXJI8III:N80
~
N
I
N
.c
I
8» IPL
SCAI.f:lN
n:t:T
.'U;UR.; 12
-------
TRI-CITY
TABLE 5
RI SPRING SAMPLING, JULY 1989
INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF ORGANIC ANALYSES (IN PPB) .
/
CHEMICAL COX COX DUP. KLAPPER CATTLE BRADING'2
Chloroform 5U 5U 5U 5U 5U
1,1-Dichloroethane 4J 4J 5U 5U 5U
l,l-Dichloroethene 5U 5U 5U 5U 5U
1,2-Dichloroethene (total) 260 280 5U 5U 5U
Tetrachloroethene 88 89 5U 5U 5U
Toluene 5U ~U 5U 5U 5U
1, 1, I-Trichloroethane 11 11 5U 5U 5U
Trichloroethene 20 20 5U 5U 5U I
Vinyl.Chlpr~de 31 32 IOU IOU IOU w
o
I
U indic~tes material analyzed for but not detected;
the number is the minimum quantitation limit.
J indicates an estimated value
-------
TABLE 6
RI SPRING SAMPLING, JULY 1989
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS,
SUMMARY OF INORGANIC ANALYSES (IN PPB)
KENTUCKY
CONTAMINANT COX COX DUP. KLAPPER CATTLE BRADING 12
Aluminum 110U 100U 60U 1000 40U
Arsenic 2U 2U 2U 2U 2U
Beryllium 2U 2U 2U 2U 2U
Cadmium 3U 4U 4U 4U 4U
Calcium 87000 88000 82000 52000 75000
Chromium 4U 4U 4U 4U 4U
Iron 150U 110U 40U 1300 30U
Lead 1U 1U 1U 5U 1U
Magnesium 6900 6900 6400 8800 15000
Manganese 1800 1600 9U 190 2U
Mercury 0.20UJ 0.20UJ 0.20UJ 0.20UJ 0.20UJ I
Nickel 20U 20U 9U 20U 9U w
~
Potassium 810U 790U 310U 3000 550U I
Sodium 6300 6200 5200 9200 11 000
Thallium 3U 3U 3U 3U 3U
Vanadium 5U 6U 5U 7U 6U
Zinc 40U 60U 5U 60U 9U
U indicates material analyzed for but not detected; the number is the minimum quantitation limit.
J indicates an estimated value
-------
BROOKS HILL ROAD
~
N
.
.A
X
LEGEND
RESIDENCE
SPRING
ELEVATION ABOVE MS L
t fENCED PASTURE
.. MONITOR WELL
--oA.. SOIL BORING NOT
...... COMPLETED AS A
MONITOR WELL
.IADING SPUNGS, I . 1
x
El. 600 Ft.
x
El. 600 Ft.
x
EL. 800 Ft.
I
l..J
t ~
I
MW-12
<+>
MW-11
..
FoaK
.
1.11 t'\.
I
REMEDIAL INVESTU;ATION GROUNDWATER
MONITOR WELL AND SOIL OORIN(; LOCATIONS
TRI-CITY INDUSTRIAL DISPOSAL SITE
OULLI'IT COUNTY. KENTUCK Y
SCAI.I!: IN J"I!:Io..T
;URE 1)
-------
TABLI 7
RI GROUNDWATER SAMPLING, SBPT-NOV 1989
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOkS, ~NTUCKY
SUMMARY or INORGANIC ANALYSBS (IN PPB)
CORTAMIHAIIT 1I1f-02 "'-04 1I1f-05 "'-08 1I1f-08-D 1I1f-11 II1f- 12
ALUMINUM 900 5800 1100 3300 2700 30000 44000
ARSBNIC 3U 3U 3U 3U 3u 3U 3U
BARIUM n 170 50 58 53 240 290
CADMIUM 3U 3U 3U 3U 3U 3U 6
CALCIUM 300000 740000 160000 450000 440000 49000 22000
CHROMIUM 18 32 38 64 47 46 74
COBALT 610 29 5U IOU 9U 28 40
COPPBR 20U 30U 20U 40U "30U 40U 64
IRON 2900 26000 1100 5500 4400 50000 82000 I
L8AD o3U 21 20U 13 5 18 32 w
w
HAGNBSIUM 80000 150000 23000 74000 69000 23000 13000 I
IlAHGARBSB 160 890 130 460 470 1200 1700
IIBRCURY 0.20U 0.20U 0.20U 0.20U 0.20U 0.20U 0.29
NICOL 110 170 49 120 100 67 110
POTASSIUM 31000 14000 300000 5000U 4800U 5300U 6100U
SODIUM 150000 38000 100000 64000 61000 170000 10000
THALLIUM 3U 3U 3U 3U 3U 3U 3U
VANADIUM 6U 310 6 'U 8U U 140
ZINC 280 O.OlU 120U 170 160U 340 410
U indicate. material analyzed for but not detected; the number i8 the minimum quantitation limit.
-------
-34-
BPA's Bnvironmental Services Division conducted additional
sampling of the Cox, Klapper, and Cattle Springs, and the
monitoring well MW-12 in December 1990. _Two volatile organic
compounds, PCB-and TCB, were detected at estimated levels in the
Cox Spring sample that were above the MCLs. An estimated level
of PCB was detected in the Klapper Spring sample and an
estimated level of toluene was found in the Cattle Spring
sample, but both levels were below MCLs. No volatile organic
contaminants were detected in the sample from MW-12. The
results of the volatile organic analyses are summarized in Table
8.
The metals detected in the spring samples were common to a
sed~entary environment. The levels of metals detected in the
spring samples and the sample from MW-12 did not exceed MCLs.
And though the min~um quantitation l~ts for lead and thallium
were higher than the proposed MCLs, these metals were not
detected during the RI when more sensitive analytical methods
were used (see the analytical data in Tables 6 and 7). The
results of the inorganic analyses of the samples collected in
December 1990 are summarized in Table 9.
5.3.2
Soils
--
Site soils were also investigated during five separate
events, one conducted by Kentucky and four by BPA. The Kentucky
investigation in April 1987 included three soil samples, one --
background (TCD-02) and two samples (TCD-06 and TCD-07) obtained
from the area around the waste sample locations. Figure 10
shows the soil sample locations. The background sample was
collected from a depth of 4 inches, while TCD-06 was taken
directly from the surface and TCD-07 was composited from the
surface to a depth of 4 feet.
Few organic contaminants were detected in the soil samples.
The greatest concentration observed was 2.8 ppm of methylphenol
found in TCD-06. This compound was not detected in the
background sample. In addition, TCD-06 contained two species of
PCBs, Aroclor 1254 and AXoclor 1260, at concentrations less than
0.30 ppm. These compounds were below detectable limits in the
other soil samples and also absent from the waste samples. For
the majority of inorganic contaminants detected, onsite
concentrations varied little from-background conditions. The
contaminants demonstrating significant concentrations above
background we~e cadmium and mercury.
During the additional study conducted by BPA in May 1988
five composite surface soil samples were collected from
sensitive areas, including two from gardens, two from yards, and
one from the southeastern slope of the landfill. The sample
locations were shown in Fiqure 11.
-------
-35-
TABLE 8
EPA GROUNDWATER INVESTIGATION, DECEMBER 1990
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF VOLATILE ORGANIC ANALYSES (IN PPB)
PARAMETER COX KLAPPER CATTLE MW-12
CIS-1,2-DICHLOROETHENE 48.1 5.0U 5.0U 5.0U
TETRACHLOROETHENE 250 0.77.1 5.0U 5.0U
TOLUENE 21.1 5.0U 0.58.1 5.0U
l,l,l-TRICHLOROETHANE 100U 5.0U 5.0U 5.0U
TRICHLOROETHENE. 12.1 5.0U 5.0U 5.0U
VINYL CHLORIDE 100U 5.0U 5.0U 5.0U
U indicates that material was analyzed for but not detected.
The number is the minimum quantitation limit.
.1 indicates an estimated value.
-------
-36-
TABLE 9
EPA GROUNDWATER INVESTIGATION, DECEMBER 1990
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF INORGANIC ANALYSES
COX KLAPPER CATTLE MW-12
RESULTS IN PPB
ALUMINUM 240 1100 580 43000
ARSENIC 30U 30U 30U 46
BARIUM 30 49 30 220
BERYLLIUM 5.0U 5.0U 5.0U 5.0U
CADMIUM 5.0U 5.0U 5.0U 5.0U
CHROMIUM 10U 10U 10U 67
COBALT 10U 10U 10U 22
COPPER 10U 10U 10U 36
LEAD 40U 40U 40U 40U
MANGANESE 150 51 25 650
MERCURY 0.2U 0.2U 0.2U 0.2U
NICKEL. 20U 20U 20U 76
STRONTIUM 89 67 93 88
THALLIUM 100U 100U 100U 100U
TITANIUM 11 24 20 320
VANADIUM 10U 10U 10U 110
YTTRIUM 10U 10U 10U 34
ZINC 14 13 14 180
RESULTS IN PPM
CALCIUM 82 29 91 20
IRON 0.22 1.1 0.58 92
MAGNESIUM 5.5 6.0U 5.2 13
POTASSIUM 2.0U 2.1 2.0U 7.2
SODIUM 3.6 1.5 9.1 8.0
U indicates material was analyzed for but not detected;
the number is the minimum quantitation limit.
-------
-37-
The results of the ~norganic analyses showed that the
surface soil sample TC-G-CS contained a number of metals. The
metals present in highest concentrations were copper, lead, and
zinc at 430 ppm, 210 ppm, and 870 ppm, respectively. These
metals were also present in the samples collected from the yards
(TC-F-CS and TC-D-CS) and the gardens (TC-B-CS and TC-E-CS), but
in substantially lower concentrations. Cyanide was detected in
all samples, but TC-G-CS and TC-D-CS contained the highest
levels: 4.8 ppm and 5.4 ppm, respectively. Other inorganic
contaminants of note that were present in TC-G-CS but absent
from the yard and garden samples were cadmium and mercury at 2.4
ppm and 2.8 ppm, respectively.
Organic analyses of the soil samples revealed few positively
identified compounds. Bis (2-ethylhexyl) phthalate and
Aroclor-1254 were detected in the sample TC-G-CS at
concentrations of 3700 ppb and 200 ppb, respectively. Both of
these compounds were absent from the yard and garden samples. A
number of polycyclic aromatic hydrocarbons (PABs) were also
detected in TC-G-CS in estimated concentrations that ranged fr~m
89 to 440 ppb. These compounds were absent from the other soil
samples collected. Toluene was detected at a level of 1000 ppb
in the sample TC-B-CS, which was collected from a garden
approximately 800 feet from the former disposal area. This
compound was also observed in TC-G-CS and both yard samples at
estimated concentrations ranging from 28 ppb to 2900 ppb.
Sample TC-B-CS also contained a number of pesticides, with
dieldrin and endosulfan appearing in the highest
concentrations: 27 ppb and 14 ppb, respectively. These
compounds were generally absent from the remaining soil samples,
except TC-E-CS which contained 4,4'-DDT at a level of 7.6 ppb.
Subsurface soil samples were collected during the field
analytical screening procedures (FASP) conducted by NUS
Corporation in August 1988 to complement the geophysical
survey. A total of 24 subsurface soil samples were collected,
including one background sample. Sample locations are shown in
Figure 14. The results of the field screening indicated the
presence of VOCs in the subsurface soils in three sections of
the landfill: the southwest corner, the southeast corner, and
along the central section of the eastern boundary. Of these
three areas, the highest concentrations of contaminants. were
found in the southwest corner of the landfill, which corresponds
with the area in which the Emergency Removal Action was
subsequently conducted. Elevated levels of l,l-dichloroethane,
trichloroethene, toluene, tetrachloroethene, ethyl benzene, and
p-xylene were f~und in two s~ples from this area. .
The southeast corner of the Site was represented by samples
TC-SS-l2, 13, and 14. Each of these samples contained elevated
levels of PCE. In addition, samples TC-SS-12 and 14 contained
l,l-dichloroethane. VOCs were also detected in samples
TC-SS-20, 21, and 23 along the eastern boundary of the landfill.
-------
-38-
.10-01
IALL
~ .....oue.l
\ It;J(:;
,.
i
Ift\
\
l HOO.,..
"."O.NC.
F.eLO
cox .....
..~.
FIeLD
.. -II
D
()
."-J &
t D
.)&8-lq 0
."-1. C:JC0
-'}. ~ 0 ~
. .'.-1' () 0,,#
) QC,
..~~O ~
°O~
M.~O 0 f'\.
...-0 0 I"J
...-0. t ~-1'
\ -1.
..0110 \
.0 0 ".-0' b ~
(J () \ \\ '. ..~10 I:U,'
.''.°rY Z.o () #'"
~::o~. r~o . ~.
o
100 ft.
''''''NO'~ 0
o
o
o
,,... 0 ()
I.,,,.
LEGEND
. IUI'U..'ACI 'O'L .
FASP SAMPLING LOCATIONS
TRI-CITY INDUSTRIAL DISPOSAL
BROOKS, BULLITT COUNTY, KENTUCKY
.CALI
FIGURE 14
rnNt!~
-------
-39-
Surface soil samples (0-6") were collected from twenty
locations during the Remedial Investigation, thirteen of the
drilling locations and seven selected site locations. The
sampling locations are shown in Figure 15.
Toluene was detected in the three samples TC-SS-07-1, ~8-1,
and 16-1 at levels between 30 ppb and 87 ppb. Toluene was also
detected in the samples TC-SS-19-1 and 21-1 on the eastern edge
of the former disposal area at estimated levels of 3 ppb and 5
ppb, respectively. Chloroform was detected in one sample,
TC-SS-11-1, near Brushy Fork Creek at an estimated level of 3
ppb.
Four species of PABs were detected at estimated levels
rangirig from 61 to 140 ppb in one surface soil sample,
TC-SS-21-1, on the eastern edge of the landfill. This sample
. also contained 490 ppb of Aroclor 1260, which is below EPA's
clean-up level of 0.5 to 1 ppm to achieve a E-6 cancer risk
level. One phthalate was detected at an estimated level of 120
ppb in the duplicate of TC-SS-03-1 on the southeastern edge of .
the disposal area.
The majority of the metals levels in the surface soil
samples were comparable to the levels in the background sample
TC-SS-Ol and were typical of a sedimentary environment
characterized by limestones, shales, and siltstones. The
analytical results are summarized in Table 10 as data ranges for
each contaminant.
A total of 27 subsurface soil samples were collected from 25
locations corresponding with the monitoring wells that were
attempted and completed during the Remedial Investigation.
Sample locations are shown in Figure 13. Sample depths varied
from two to seventeen feet. .
Volatile organic compounds (VOCs) were found in three
subsurface soil samples. An estimated level of 5 ppb PCE was
found in the soil boring closest to the southernmost disposal
trench, TC-SB-03, at a depth of 5 to 7 feet, and the duplicate
contained an estimated 3 ppm each of PCE and toluene. Fifteen
different PAB compounds and dibenzofuran were also found at this
sample location in the interval from 11 to 13 feet. Four
species of PABs were found in the sample collected from 5 to 7
feet, and i~s duplicate contained three PABs and two
phthalates. One phthalate was ~ound in TC-SB-01 at 10 to 12
feet and acetone was found in TC-SB-02 at 2 to 4 feet.
The metals levels in the subsurface soil s&mp.les were
comparable to the levels found in the surface soil samples. The
analytical results are summarized in Table 10 as ranges of data
for each contaminant. .
-------
LEGEND
~ SURFACE SOIL SAMPLE LOCATION
+SURFACE SOIL SAMPLE LOCATION
ASSOCIATED WITH A BORING
X ELnA110N ABOVE IISl
. flESl)ENCE
~.)(:1.'.): DISPOSAL AREA
+t::H~': .
.' ~
El. 600 Ft. J(
8EGlITOI. .lESmENCE
El. 800 A. J(
EL 600 Ft. I
PO..
~
SURFACE SOli. SAMft..ING I.O<:AllONS
TRI-CITY INDUSTRIAL DISPOSAl. SITE
8VLLI1T COII,,"Y. KJ:I'ITtJ(:1( Y
...
~
N
I
.p-
O
I
.. lit.
SCALE ..
FF.ET
.1GURE I 5
-------
-41-
TABLE 10
RI SURFACE' SUBSURFACE SOILS SAMPLING, 1989
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF INORGANIC ANALYSES AS RANGES OF DATA (IN PPM)
CONTAMINANT
SURFACE SOILS
4,400J - 190,000J
4.5 - 19
85 - 320
1.2 - 2.3
2 - 4 .
580 - 4,000
10 - 120
11 - 38
6.1 - 84J
11,000 - 55,000
16J - 66J
310 - 2,600
80J - 3,900J
SUBSURFACE SOILS
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
12 - 100'
420 - 1,500
260
18 - 86
37J - 130J
9,000 - 49,00-0
4.1 - 31J
37 - 370 .
1.1 - 3.7
4 - 13JN
440J - 14,000J
11 - 110
1. 8J - 36J
7.6 - 37J
13,000J - 62,000J
6J - 71
700 - 22,000
62J - 2,500J
10 - 86J
500 - 3,300
250 - 330
23 - 130
46J - 300J
J indicates an estLmated value
N indicates presumptive evidence of material
indicates material not detected above min~um
quantitation limit
-------
,-
-42-
Three surface soil samples (0-3") in the vicinity of the
monitoring well MW-12 were collected by EPA during the December
1990 investigation. These sample locations are sufficiently
removed from the disposal areas at the Tri-City Site to be
indicative of background conditions. Analytical results
indicated that the concentrations of metals in the soil samples
were common to a sedimentary environment dominated by
limestones, shales, and siltstones. Low concentrations of
mercury were detected in each soil sample, but mercury is found
in sedimentary environments and is often associated with
. carbonaceous materials such as limestones and shales. Mercury
was not detected in any of the soil samples collected during the
RI.' The results of the metals analyses from the December 1990
sampling event are summarized in Table 11 as ranges of data for
each contaminant. No purgeable organic compounds were found in
the samples. .
5.3.3
Surface Water
The surface water was investigated in July 1989 during the
RI. A total of seven surface water samples, including a
duplicate of SW-06, were collected at the locations shoWn in
Figure 16. Four samples were collected from Brushy Fork Creek
(one upstream, two directly south of the Site, and one
downstream), and one sample each was collected from the two
unnamed intermittent streams discharging to Brushy Fork Creek.
Chloroform was detected in the duplicate of SW-06 at an
estimated level of 2 ppb. TCE was detected in SW-02 at an
estimated level of 1 ppb. And, toluene was detected in SW-04 at
an estimated level of 4 ppb.
Barium and potassium were detected in all of the surface
water samples, except the upgradient sample. Nickel and
aluminum were found only in SW-05, which was collected from an
intermittent creek entering Brushy Fork Creek on the side
opposite from the Site. Manganese was detected in SW-05 and in
the upgradient sample. The other metals levels were comparable
across all samples. The analytical results from the metals
analyses are summarized in Table 12.
5.3.4
Sediments
Two sediment samples were collected by the Cabinet during
the April 1987 investigation, one background sample
correspondi~g to the water sample from Brading Spring No.1 and
one sample corresponding to the water sample from the unnamed
spring on the southeastern slope of the former disposal area. .
The unnamed spring sediment sample had greater concentrations of
the inorganic compounds detected (i.e., arsenic, barium,
-------
-43-
. TABLE 11 .
EPA SURFACE SOILS INVESTIGATION, DECEMBER 1990
SUMMARY OF INORGANIC ANALYSES AS RANGES OF DATA (IN PPM)
-
CONTAMINANT
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
. IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC.
CONCENTRATION
6,300 - 8,600
IOU - lSU
67 - 94
O.SOU - 1.0U
O.SOU - l.OU
2,300 - 2,500
8.4 - 13
6.7 - 11
6.5 - 9.6
11,000 - 21,000
16 - 17
980 - 2,400
660 - 910
0.06 - 0.10
12 - 23
600 - 920
100U - 200U
14 - 20
40 - 60
U indicates material was analyzed for but not detected;
the number is the minimum quantitation limit.
-------
El. 800 Fa. x
BRADING .
RESIDENC
E
so..
x
El. 600 Fa.
.
so
sw
.
X
MSL
AD
x
El. 600 Fa.
~
N
LEGEND
SAMPLE LOCATION
SEDIMENT SAMPLE
SURFACE WATER SAMPLE
RESIDENCE
ELEV A TION ABOVE
AQUATIC BIOTA SAMPLE
~..,....
.........p. 'IS.),:, ..'../
SUR.'ACE WAT":R, SlmIM..:NT ANn
AQUATIC mOTA SAMPU:
I.OCA TIONS
TRI-CITY INDUSTRIAL OISPOSAI.
DULLITT COUNTY, K":NTUCKY
[8ASCO S(RVICES 1NC00000000TEO
.
I
8. n
I
SCAl.F-IN
FIGURE 16
-------
TABU 12
RI SURFACE WATER SAMPLING, JULY 1989
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, KENTUCKY
SUMMARY OF INORGANIC ANALYSBS (IN PPB)
CONTAMINANT SW-Ol 8.-02 SW-O] SW-04 SW-05 SW-06
Aluminum 700U 60U 100U 400 1,600 140U
Barium 40U 33 ]7 ]5 55 35
Calcium 70,.000 48,000 51,000 50,000 62,000 48,000
Iron 960 10 170 10 ],000 180
llagne.ium 9,700 12 , 000 1],000 IJ,OOO IJ,OOO 12,000
lIangane.e 22 8U 8U 8U 230 8U
Nickel 200 6U 6U 6U 10 6U
Pota..ium 1,500U 2,000 2,000 1,900 2,200 1,900
Sodium 4,600 6,500 6,000 6,]00 7,700 6,200
I &W-07
400
J]
51,000
40U
12,000
8U
60
1,800
6,200
I
~
V1
I
o indicate. that material wa. analyzed for but not detected I the number i. the minimum quantitation 11m1t.
-------
-46-
cadmium, chromium, lead, mercury, and silver) than the
background sample. The concentration of the organic
contaminant, cis-1,3-dichloropropene, found in the unnamed
spring sediment sample was just slightly elevated above the
background level.
A total of eleven sediment samples were collected
concurrently with the surface water samples in July 1989 during
the Remedial Investigation. Four of the sediment samples were
collected from Brushy Fork Creek at the surface water sampling
locations, two were collected from the intermittent streams
flowing into Brushy Fork Creek at the surface water sampling
locations, and five were collected from the developed drainage
paths of the springs originating from the Site. The sediment
sampling locations are shown in Figure 16.
Several VOCs were found in the sediment sample SD-07
collected from the drainage pathway of the Cox Spring. Toluene,
acetone, and methyl ethyl ketone were detected at 15 ppb, 110
ppb, and 170 ppb, respectively, in SD-07. One phenol was
detected at estimated levels of 430 ppb and 250 ppb in the
sediment sample SD-11, and its duplicate SD-12, collected from
Brushy Fork Creek below the confluence with the Cox Spring
drainage pathway.
The levels of the metals found in the sediment samples were
comparable to the levels in the upgradient sample, except for,
the sample taken from the drainage pathway of the unnamed spring
SD-06. That sample contained the highest levels of most of the
metals, including lead and chromium. The results of the metals
analyses are summarized in Table 13.
5.3.5
Air
Air monitoring at the Tri-City Site was conducted during the
Remedial Investigation. Monitoring included the collection of
ambient air samples and real-time. air monitoring using direct
reading instruments during the Phase II drilling activities.
Three sampling locations were selected based on the locations of
the residences relative to the landfill areas, the prev~iling
wind directions at the time of the air sample collection, and
site operations. Ambient 8-hour air samples were taken at the
sampling stations prior to disturbance of the soil so that
pre-work site conditions could be documented. Subsequent
samples were obtained at the stations once a week during
drilling activities, resulting in a total of four samples at
each location. . Duplicate samples were taken at the location
next to the Cox, Jr. residence. The sampling locations are
shown in Figure 17.
-------
TABLB 13
RI SBDIMBNT SAMPLING, JULY 1989
TRI-CITY INDUSTRIAL DISpOSAL SITH, BROOKS, KENTUCKY
SUMMARY 0.. INORGANIC AMALYSBS (IN PPHI
COIfTAMIHAtfT 81>-01 So-02 So-03 So-04 60-05 60-06 I
Aluminum 13 , 000 8,500 7,700 8,700 10,000 15,000.1
Ar.enic 12 7.1 8.9.7 5UJ 7.6.1 19
BarlUII 110 68 67 73 96 220
Cadmium 1.3UJ 1.2u 0.97U 0.99U 1.4U 2UJ
Calcium 5,100 3,700 2,000 3,700 5,200 5,400
Chromium 33 19 83JN 11 35 160
Cobalt 26 12 16 13 17 32
Copper 20UJ 20U 9U 20U 20U 52.1
Iron 31,000 23,000 42,000 22,000 29,000 44 , 000 I
Lead 28.1 21 26 18 24.1 610.1 ~
'-I
Hagne.ium 2,600 2,200 2,500 2,800 2,900 I
1,700
Hangane.e 2,000.1 830 1,100 730 610 1,900.1
Mercury O.17UJ 0.2U O.IU O.IU 0.2U 0.24.1
Nickel 35 22 27 23 30 40
Pota..ium 1,500 1,100 1,100 .1,200 1,300 1,100
Sodium 100U 560U 460U 470U 680U 330U
Vanadium 40 26 44 20 ]2 58
Zinc 110.1 76 93 67 120 140.1
D indicate. that material was analyzed for but not detected; the number i. the minimum quantitation lLait.
.1 indicate. an e8timated value
N indicates presumptive evidence of presence of material
-------
TABLB 13 (cont'd)
RI S!DIMBNT SAMPLING, JULY 1989
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, DNTUCItY
SUMMARY or INORGANIC ANALYSBS (IN PPM)
CONTAMINANT 8D-01 SD-08 SD-09 SD-I0 SD-11 SD-12
Aluminum 10,000.1 11 , 000 9,600.1 8,]00 1,400 8,]00
Ar.enic 8 7,5 11 6.9.1 7.2.1 4.9.1
Barium 120 87 150 96 63 69
Cadmium 1.8UJ 1. 1 UJ 0.97UJ 0.99U 1.2U 1.3U
Calcium 14,000 8,800 3,800 3,400 4,800 4,600
Chromium 20U 20U 39 25 17 19
Cobalt 30U 20U 28 16 13 13
Copper 20UJ 20UJ 7UiJ 20U 12 20U
Iron 19 , 000 26,000 28,000 24,000 22,000 2],000 I
Lead 39.1 20.1 ]6.1 ]6 41 46 .j:-
ex>
Magne.ium 1,300 4,800 2,]00 19 2,000 2,200 I
Mangane.e 2,500.1 980.1 3,100.1 1,400 680 710
Mercury 0.25UJ 0.15UJ 0.13UJ O.lU 0.2u 0.2U
Nickel 24 ]0 28 20 20 20
Pota..ium 820 1,500 1,100 900 820 1,000
Sodium 140U 150U 2.1U 470 580U 620U
Vanadium 26 2] 37 27 24 26
Zinc 110.1 120.1 62.1 71 67 74
U indicate. that material was analyzed for but not detected; the number i. the minimum quantitation lLait.
.1 indicates an estimated value
N indicates presumptive evidence of presence of material
-------
-~-:-
BALL
RESIDENCE
Do
CJ
cox JR.
RESIDE."iCE
cox SR.
RESIDENCE
i
\
I
j
U TREE LINE
i
,
!
.'
/
/
/
I
t
/
i
I
.I
f
!
(
\
.)TCoAA.ol
_/
,'-
/'
/
~
IN]
"-.',
'.
,
\
~
;
;
i
!
\
\
""'-----"'~"-,
. I
I
I
"---
o.
. AMBIENT AIR SAMPL~G LOCATIONS
.
100
SCALE IN FEET
EBCO.
. . . .
'.... .. :. ,- '.~.
AMBIENI' AIJt SAMPLING LOCAnONS
TRJ.c1TY INDlJSTIUAL DISPOSAL srm
BlILLm COl1N1Y, Dm\JCICY
FIGURE 17
DAICO .1MCI811QW1OM'III)
-------
-.50-
Methylene chloride was found in three of the four samples
collected at location AA-Ol, once at the location next to the
Cox, Sr. residence, and once at the location next to the Cox,
Jr. residence. PCE was found in two of the samples from
location AA-O~ at a level of 3.7 ppb and an estimated level of
4.5 ppb. Freon 113 was tentatively identified as being an air
contaminant at all locations, but it was not identified during
all sampling events. The highest Freon 113 concentrations were
found at location AA-Ol. The only tentatively identified
organic compounds were aliphatic aldehydes, which were found at
all locations.
No consistent pattern of air contamination was found other
than PCB, which was detected when the wind blew up the faces of
the Cox Lobe. PCE was found during sampling events when the air
. speed was at its lowest, which potentially indicates that the
contamination source was close to the sampling location.
The samples from location AA-01 contained the largest number
of contaminants. Methylene chloride, Freon 113, and aliphatic.
aldehyes have not previously been identified with waste disposal
activities nor were they found in.any other media sampled during
the RI.
6.0
SUMMARY OF SITE RISKS
i
I
I
CERCLA directs that EPA must protect human health and the
environment from current and future exposure to hazardous
substances at Superfund sites. In order to assess the current
and future risks from the Tri-City Industrial Disposal site, a
baseline risk assessment was conducted as part of the Remedial
Investigation. This section of the Record of Decision
summarizes the Agency's findings concerning the Lmpact to human
health and the environment if contaminated media (i.e., soils,
ground water) at the Site were not remediated. The baseline
risk assessment is included in the RI Report as Appendix F.
6.1
Hnman Health Risks
6.1.1
Contaminants of Concern
. Table 14 provides a comprehensive list of the contaminants
identified as chemicals of potential concern at the Site in
their various media. The contaminants of concern are ten
organic chemicals and nine ino~ganic chemicals. Table 14 also
includes the reasonable maxLmum exposure limits which were used
in calculating the carcinogenic and noncarcinogenic risks
associated with each chemical.
-------
------.-
-51-
TAiLE 14
CONT4NlIAITS DETECTED
TRI-CITIES INDUSTRIAL DISPOSAL SITE
NO. Of
COMPOUND DETECT! 0815 !W!Y! !!W.!Y! RME LIMIT
SURFACE SOIL
Oraanics Cppb>
Toluene 4/15 U 1600 310
PANs 2115 U 1309 '9
BisC2-ethylhexyl)phthlllte 1/15 U 3700 330
PCB. 2/15 U '90 43
Inoralnics C~)
Blri UII "/15 u 320 .180
BerylliUli 4/15 U 2.1 1.4
ChromiUII 14/15 U 430 1.1'
Copper 8/15 U 430 47"
Nickel 6/15 U 100 100
Lucl 15/15 16 210 39
Vlnacliua 13/15 U 86 51
Zinc 15/15 40 870 220
SUBSURFACE SOIL
Oraanics Cppb)
Tetrlchloroethylene 2/9 U 5 6.5
Toluene 1/9 U 3 6.5
PAN. 2/9 U 480 '3
Inoraanics CPPM)
Beryll hn 5/9 U 3.7 2.2
CaaniUli 1/9 U 10 3.8
Chromiln 919 24 74 5.85
Nickel 919 10 66 45
Le8cl 919 11 71 53.5
Zinc 919 52 170 160
SEDIMENT
Oraanics Cppb)
Toluene 1/4 U 15 310
Inoraanics CppI)
SIr i UII 4/4 87 200 220
ChrCllliUII 2/4 U 160 160
Copper 1/4 U 52 52
Le8cl 4/4 20 610 379
SPR I NG WATER
Oralnic. Cppb)
Vinyl Chloride 3/9 U 32 20
1,1'Dichloroethane 4/9 U I, 65
""1-Trichloroethane 619 U 11 10.5
Trichloroethane 5/9 U '7 35
T.trachloroethylene 8/9 U 560 '20
1,2'Dichloroethylene 5/9 U 280 '2
AMBIENT AIR
. T.trachloroethyiene (111/10') 2112 U 28 2.8
-------
1
-52-
6.1.2
EXD08ure Assessment
The objective of the exposure assessment is to estimate the
type and magnitude of potential exposures to. the chemicals of
concern that are present at the site. The results of the
exposure assessment are combined with chemical-specific toxicity
information to characterize potential risks.
The primary human receptors at the Site are the inhabitants
of the four residences in the former disposal area. These
individuals may currently be exposed to site-related
contaminants in surface soil, surface water, sediment, and air.'
Potential future exposures would include those pathways, as well
as ground water/spring water and sub-surface soils. Although
the ground water/spring water is not currently being used as a
drinking water source, EPA and the Commonwealth of Kentucky have
classified the aquifer as a Class II-B aquifer, a resource which
should be maintained at drinking water quality.
The current exposure pathways considered were (1) dermal
contact and incidental ingestion of surface soils,
(2) ingestion of garden crops raised on-site, (3) ingestion of
beef cattle raised on-site, and (4) inhalation of volatile
organic compounds (VOCs) in ambient air. The future pathways
. considered include the current pathways and the following: (1)
dermal contact and incidental ingestion of exposed sub-surface
soils, (2) ingestion of spring water, and (3) inhalation of VOCs
released from spring water while showering.
Table 15 provides the exposure and intake assumptions which
were used in the baseline risk assessment.
6.1.3
Toxicitv Assessment
The toxicity assessment was conducted to further determine
the potential hazard posed by the chemicals of concern for which
exposure pathways have been identified. Available evidence was
weighed with regards to the potential of particular contaminants
to cause adverse effects in exposed individuals and to provide,
where po.aible, an estimate of the relationship between the
extent of exposure to a contaminant and the increased likelihood
. and/or severity of adverse effects.
Cancer potency factors (CPF~) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially
carcinogenic1chemicals. CPFs,' which are expressed in units of
(mg/kg/day)- , 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
-------
-53-
TABLE 15
EXPOSURE AND INTAKE ASSUMPTIONS FOR
DERMAL CONTACT AND INGESTION OF SURFACE (PRESENT)
AND SUBSURFACE (FUTURE) SOIL PATHWAY MODELING
LOCAL RESIDENTS - AGE GROUPS
(YEARS)
0-1
Dermal Exposure to Soil (day/year)
38
Dermal Exposure to Sediment/Water
(day/year)
Duration of Exposure (years)
Dermal Soil Deposition (mg/cm2)
1.4
Skin Surface Area Exposed (cm2)
1700
~ermal Absorption Factors: Soil
Semivolatile Organics
Volatile Organics
1. 2\
5%
Metals
1%
Dermal Absorption Factors: Sediment/
Water
Semivolatile Organics
Volatile Organics
12%
100%
Metals
1%
Gut Absorption Factors:
Metals, Semivolatiles
100%
Volatile Organics
100%
Soil Ingestion (mg/day)
100
2-6
155
o
22
7-11
12-17
18-70
78
22
6
30
2
1.4
2200
1.2%
5%
1%
12%
100%
1%
100%
100%
200
103
103
1.4
2000
1. 2%
5%
1%
12%
100%
1%
100%
100%
100
Sources:
Skin surface areas exposed are from Anderson, et al., (1984);
other parameter values were derived as described in the text.
44
44
5
5
1.4
1.4
3800
5900
1.2\
1.2%
5%
5%
1%
1%
12%
100%
12%
100\
1%
1%
100%
100%
100%
100\
100
100
-------
-54-
exposure at that intake level. The term "upper-bound" reflects
the conservative estimate of the risks calculated from the CPF.
Use of this approach makes underestimation of the actual cancer
risk highly unlikely. CPFs are derived from the results of
human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors have
been applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from
'exposure to chemicals exhibiting noncarcinogenic (systemic)
effects. RfDs, which are expressed in units of mg/kg/day, are
estimates of lifetime daily exposure levels for humans,
including sensitive individuals, which will.result in no adverse
health effects. Estimated intakes of chemicals from
environmental media (i.e., the amount of chemical ingested from
contaminated drinking water) can be compared to the RfD. RfDs
are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (i.e., to account
for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects
to occur. .
The Agency has derived CPFs and RfDs for the contaminants of
concern at the site for use in determining the upper-bound level
of cancer risk and non-cancer hazard from exposure to a given
level of contamination. These values are provided in Tables 16
and 17, respectively.
6.1.4
Risk Characterization
The risk characterization step of the baseline risk
assessment process integrates the toxicity and exposure
assessments into quantitative and qualitative expressions of
risk. The output of this process is a characterization of the
site-related potential noncarcinogenic and carcinogenic health
effects.
Exces8 lifetime cancer risks are determined by multiplying
the intake level with the cancer potency factor. These risks
are probabilities tha~ are generally expressed in scientific
notation (i.e., lxlO- or lE-6). An excess lifetime cancer
risk of lE-6 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.
-------
-55-
TAiLE 16
TOXICOLOGIC ClITERIA VALUES '01
CARCIIDGENIC HEALTM E"ECTS
Tal-CITIES INDUSTRIAL DISPOSAL SITE
CAIICU POTEIICT 'ACTOI (SLOPE FACTOR)
(1III/kl/dey)-1
WEIGMT 0' EVIDENCE
$UlSTAIiCE CUSS! FlCAT 1011 OIGAIICS) AFFECTED OIAL I NHALATI 011 SOJRCE
8eryl lillll " 12 L \l'1li . .1I 8.4 IRIS
CactDiUli 11 L\I'III. Resplr.tory . 6.1 IRIS
Treet
Carcinogenic PAM I 12 L\I'III. l.-ocLctlve 1 1. s!I 6.1it MEAST
Sy8t8l. Dlentiw
Treet
Chrcniun All L \l'1li . "1V IRIS
1.1-Dfchloroeth.ne C H~i08.rcC88 0.091 IIA IRIS
Nickel A'll lesplr.tory Treet . O.84'l1 HEAST
Polychlorinated liphenyll 12 Liver 7.7 IIA IRIS
Tltr.chloroethene 12 " Lu_t.. Liver 0.051 0.0033 MEAST
TriChloroethylene 12 L\I'III. Liver .011 .017 MEAST
Vinyl Chloride A L \l'1li 2.3 0.29 MEAST
lIotes: 1I
V
'li
. . lot c.rcinogen by thl, route
v.l,," Ifven .re for hu8Y8lent dlrCl8h.
it
v.lue liven I, for nfck.l ,..flnery ct.at
V.l,," liven ere for b8n10(.)~-: thf. value i8 currently \nier ,...,,'" by EPA
IIA . Not Ave I llbl.
-------
TAiLE 17
TOXiCOlOGICAL ClItElIA VALUES fOl -.cAllcn IlEAl1.. EffECtS
TI'-C'T'ES INDUSTI'Al DISPOSAL S'TE
0IAl EXPOSUIE '"lIAlATIOI EXPOSUIE
110 (-'1I8Id8v)'1 tllCEIfA'I" OIGAII(S) IfD (8Dllla/dly)-T "CEITA'I" OIGAII(S)
-SJAIICE fACTOI AffECtED fACTOI AffECTED SOUICE
I8r 1-.. 5.,0-2 100 Itood ,.,0-4 '000 fetoto.lelty 'I'S
lerytt 1-.. 5.,0'] tOO IIA IIA IIA IIA II'S
c.81-.. 5.,0" '0 Kidney IlAY IIA IIA 'I'S
a,,'.I-.. 5.,0-] 500 lIot Defined WI IIA IIA '1'5
CCIIIP8f' ].7.,0.2 lIone Geurle Irrlt. lIA'll IIA IIA Mel
l.-l IlAJI IIA}I
Ilcll.' 2"0'2 ]00 lecbted Or,. "t. IlAY IIA IIA '1'$ I
91110'] u'
V8'l8dI-.. IlEAST ()\
I
Zinc 2.,0" 10 ar-I. IIA IIA IIA IlEASt
1,1-Dlch'oroethane ,.,0.' 1000 IIA ta10-' 1000 Kidney IlEASt
1,Z-Dlch'oroethene 0.02 IlEASt
1,1,1-Trlchloroethane ].,0.' 1000 lIepato.lelty 9.,0.2 1000 lIepato.lelty IllS
T.tr8Chioroeth8n8 ,.,0.2 100 liver .WI IIA IIA IlEA"
Toh.. ].,0-1 100 Eye & loa. Irrlt. 2 100 Cent. lerv. Sys. IlEAST
1anc8rc1,....lc ,AlIa '.,0.] '00 Ocut.r Lnlone WI IIA IA IlEASt
lot... t
y
10 I. ..,.11... for thl. rout. of "Inlltr.tlon, vatue for tho othor route ... Uled In rllil ...nl8eftt.
10 I. ..,.11... for thl. rout. of "'nl.tr.tlon, "tanee not Inctuded In quentlt.tlve .....l8eftt.
10 IfD vel,," oro 8V811Ib1. for t.-l; rl.1I ch.racterh.tlon ..III Invotve the Ule of EPA'. bloltinetic 8Ddet,
V.tue ,Iven I. for niPlth.tene.
.. eapl.lned In the teat.
-------
-57-
EPA has set an acceptable carcinogenic risk range of 12-4
to 12-6, but prefers that remediation of Superfund sites
achieve a residual cancer risk no greater than 12-6. Bowever,
depending upon site factors, a risk of 1E-4 may be considered
protective. -The calculated upper-bound risks from the
ingestion of beef from cattle raised on-site would fall just
outside the lower limits of this risk range (22-4). This risk
level is based on the detection of PABs and one species of PCB
in one out of twenty surface soil samples collected during the
Remedial Investigation. The reasonable maximum exposure (RME)
was based on this detection and half the detection limit for
the other samples. Because of this low frequency of detection,
it is recommended that the presence of these carcinogenic
compounds be verified through additional sampling. The risk
assessment should then be revised to include the new data.
Two of the future exposure pathways, ingestion of spring
water and inhalation of VOCs while showering, exceed EPA's
acceptable carcinogenic risk range. The calculated risk levels
are 2E-3 and 1E-4, respectively. The contaminated spring water.
should be remediated. .
The carcinogenic upper-bound risk for each of the exposure
pathways (current and future) identified at the site are
summarized below:
Exposure Pathwavs
Lifetime Cancer Risk
Current Future
Total Risk
3.42-4
2.5E-5
1. 82-3
1.2E-4
8.9E-5
2.32-4
7.3E-7
2.62-7
2.3E-3
Inhalation of Air
Ingestion of Spring Water
Inhalation of VOCs while Showering
Ingestion of Garden Crops
Ingestion of Beef
Contact with Surface Soils
Contact with Sub-Surface Soils
2.52-5
NA
NA
8.92-5
2.32-4
7.32-7
NA
I,,'
I
NA - Not Applicable
Potential-concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived
from the contaminant concentrat~on in a given medium to the
. contaminant's reference dose). By adding the BQs for all
contaminants within a medium or across all media to which a
given population may be reasonably exposed, the Hazard Index
(HI) can be generated. The HI provides a useful reference
point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.
The HQs and HIs for the exposure pathways (current and future)
identified at the site are summarized below:
-------
-58-
EXDosure Pathwavs
Hazard Quotient
Current Future
Hazard Index
6.9
NA
NA
4.8E-2
1. 1E- 2
2.4E-l
NA
7.2
6.9
1.9
3.9E-l
4.8E-2
1.1E-2
2.4E-l
6.1E-l
Inhalation of Air
Ingestion of-Spring Water
Inhalation of VOCs while Showering
Ingestion of Garden Crops
Ingestion of Beef
Contact with Surface Soils
Contact with Sub-Surface Soils
1.OE+l
NA - Not Applicable
The BQ for the air pathway and the drinking water pathway
both exceed unity. The HQ for the drinking water pathway was
based on the presence of various chemicals at concentrations
exceeding EPA's Maximum Contaminant Levels (MCLs) for drinking
water.
The BQ for the air pathway was based on one chemical,
tetrachloroethene, which was detected in two out of twelve
samples taken on-site. The RME was based on these two
detections and half of the detection limit for ~he other ten
samples. A source for the presence of this contaminant in the
air has not been identified. Additional sampling is .
recommended to identify and define any sources. The risk
characterization should then be revised to include the new
data.
6.1.5
Risk Uncertaintv
There is a generally recognized uncertainty in human risk
values developed from experimental data. This is primarily due
to the uncertainty of extrapolation in the areas of (1) high to
low dose exposure and (2) animal data to values that are
protective of human health. The site specific uncertainty is
mainly in the degree of accuracy of the exposure assumptions.
Most of the exposure assumptions used in this, and any, risk
assessment have not been fully verified. For example, the.
degree of chemical absorption from the gut or through the skin
or the amount of soil contact tpat may occur is not known with
certainty. Generally accepted default values provided in
Agency guidance. were used whe~ available.
-------
-59-
In the presence of such uncertainty, the Agency and the
risk assessor have the obligation to make conservative
assumptions such that the likelihood is very small, approaching
zero, for the actual health risk to be greater than that
determined tnrough the risk assessment process. On the other
hand, the process is not intended to yield conservative risks
values that have no basis in reality. That balance was kept in
mind in the development of exposure assumptions and pathways
and in the interpretation of data and guidance for this
baseline risk assessment.
6.2
Environmental Risks
No ecological surveys or impact assessments were performed
on the Site prior to the RI. As part of the scope of RI
activities, an aquatic s.urvey of Brushy Fork Creek was
performed in July 1989 and reported in the RI Report. Surveys
of terrestrial species (i.e, plants, animals, and birds) were
not included in the scope of work.
Sampling stations for the aquatic survey were established
along the creek and corresponded with surface water sampling
locations when possible. The sampling stations are shown in
Figure 16. Physical and chemical stream parameters were
measured at all stations. Benthic macroinvertebrates were
quantitatively sampled at each station, identified, and the
diversity and tolerance levels of each population were
determined in the laboratory. Benthic macroinvertebrates
represent an ideal indicator community of water quality because
they are fairly immobile, abundant, easily collected, and
exhibit a varied degree of tolerance to pollutants. In.
addition to the benthic macroinvertebrate collections, the fish
population was analyzed to determine the ability of the stream
to support edible fish populations, and, if so, if this
population posed a threat to human health by being utilized as
a food source.
Diversity indices of the benthic macroinvertebrate
populations were calculated at each station. High diversities
indicate that the individuals comprising a population are
distributed among a large number of species. High diversities
. are typically characteristic of high water quality streams
where the benthic macroinvertebrate population consists of a
large number of less tolerant species with each species
represented by a few individuals. Low diversities are commonly
associated with. polluted or disturbed streams in which species
tolerant of pollution or disturbance replace the less tolerant
species in the population. The result is a small number of
tolerant species with each. species represented by a large
number of individuals.
-------
-60-
The atations had similar physiochemical parameters (i.e.,
temperature, pS, dissolved oxygen concentration, and specific
conductivity) and the benthic populations sampled at each
station could be compared directly. The diversity indices
varied only slightly and did not indicate any drastic changes
between the stations. The indices were moderately high
indicating good to fair water quality and the individuals were
evenly distributed among the species. Although there were
species or groups which dominated the population at a given
station, a large number of species with few representatives
maintained the diversity at each ~tation.
The biotic indices increased slightly at the downstream
stations, TC-AB-03 and TC-AB-04, suggesting the possibility of
some organic enrichment entering the creek from a non-human
source. However, the high diversity at the sampling stations
indicates that there are no serious point source pollutants
entering the stream. The possibility exists that this
enrichment is a result of residential and agricultural sources
rather than the Tri-City Site.
An assessment of the fish population of Brushy Fork Creek
was made at the downstream station (TC-AB-04) in order to
determine species composition, relative abundance, and the
presence of edible species. Five species of juvenile fish were
collected from the creek, indicating that natural reproduction
of these species was occurring within this particular stream
reach. The fish that were collected or observed were too small
to be a food supply and were not the typical species for sport
fishing or human consumption. .
Eleven sediment samples were collected in July 1989.during
the RI. The sampling locations are shown in Figure 16. The
data from the analyses of the sediment samples was discussed in
Section 5.3.4.
Although sediment quality criteria have not been
established for metals, effects levels have been estimated for
aquatic biota by the National Oceanic and Atmospheric
Administration (NOAA) based on the response of test organisms
to single toxins, including metals. The effects range-lower
(ER-L) value is an approximation of the concentration of a
single analyte at which adverse effects were first detected..
. ER-L values are not to be construed as NOAA standards or
criteria. And, since there is a low. degree of confidence in
.the accuracy of some of the values due to inconsistent or
insuffi7ent,data; these values may not be ecologically
protect1ve. Table 18 shows tne ER-L values for the metals
pertaining to the Site and the corresponding degrees of
confidence.
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I
I
CONTAMINANT
Arsenic
Chromium
Lead
Mercury
Nickel
-61-
TABLE 18
SUMMARY OF ER-L CONCENTRATIONS
FOR METALS IN SEDIMENT
ER-L
CONCENTRATION
DEGREE OF
CONFIDENCE
33 ppm
80
35
0.15
30
Low
Moderate
Moderate
Moderate
Moderate
NA = Not Available
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Sediment samples 01, 04, and 05 were located on tributaries
to Brushy Fork Creek which were not influenced by surface and
groundwater originating from the Tri-City Site. with the
exception of SD-05, the metals levels detected in these samples
were below the ER-L. The nickel level in SD-OS was equivalent
to the ER-L. .
Sediment sample SD-06 was located in the drainage pathway
from the unnamed spring to the southeast of the Cox Lobe. The
ER-L values for chromium and lead were substantially exceeded
in this sample. The level of c.hromium detected was twic~ the
ER-L. The estimated detected level of 610 ppm lead was more
than seventeen times the ER-L. The estimated detected level of
mercury was more than one-and-a half times the ER-L. Mercury
was not detected in the sediments at any other sampling
locations.
Even though none of the metals observed in the sediment
sample SD-06 were observed in the downstream surface water
sample SW-06, metals were detected in the corresponding
downstream sediment sample SD-11. The ER-L for lead was
exceeded in sample SD-11 by 6 ppm. The location of sample
SD-11 is downstream of both the unnamed spring and the Cox
Spring. .
Sediment sample SD-08 was located downstream of the Klapper
Spring. The detected metals were below the ER-L. Sample SD-02
was located on Brushy Fork Creek downstream of the unnamed
spring, the Cox Spring, and the Klapper Spring. Assuming that
this location is an area of deposition, this sample .represented
the combined discharge from these three pathways. The levels
of the detected metals were below the ER-L and no metals of
concern were observed in the corresponding water column sample
SW-02. .
Sediment sample SD-09 was located at the confluence of Seep
'1 and the Cattle Spring drainage. Arsenic, chromium, lead,
and nickel were detected in this sample. The lead level was 1
ppm above the BR-L.
Sediment sample SD-10 was located downstream of SD-09 and
before the confluence with Brushy Fork Creek. Arsenic,
chromium, lead, and nickel were detected in concentrations.
similar to the levels in SD-09.. The lead level in SD-10 was
also 1 ppm above the ER-L.
Sediment sample SD-03 was located in Brushy Fork Creek
downstream of all surface water drainage features originated
from the Site. Lead and nickel were detected in this sample at
levels below the ER-L. No metals of concern were detected in
the corresponding water column sample SW-03.
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Representatives from EPA and the Fish and Wildlife Service
(FWS) conducted a cursory ecological reconnaissance of the
Tri-City Site in August 1990. The objective of the
reconnaissance was to determine if suitable feeding habitat for
the endangered Indiana bat, gray bat, and bald eagle existed in
the first and second order streams downgradient of the Site.
Since the Indiana bat and gray bat are insectivores, a brief
aquatic macroinvertebrate study was conducted on Brushy Fork
Creek. In addition, a brief botanical survey and fish survey
were conducted on the creek.
Conductivity, pH, and temperature were measured at the Cox.
Spring, Klapper Spring, and in Brushy Fork Creek during the
reconnaissance. Conductivity was found to be slightly elevated
in the Cox and Klapper Springs as compared to Brushy Fork
Creek. The pH was circumneutral at all stations. All three
parameters were observed within adequate ranges which would
support the growth and maintenance of endemic aquatic biota.
Stream flow in Brushy Fork Creek during the reconnaissance
was extremely low. Fish and aquatic macroinvertebrates were.
concentrated in pools which were isolated from each other.
Similar species were collected during the reconnaissance as
were collected during the RI.
EPA determined that Brushy Fork Creek was apparently a
healthy stream supporting diverse communities of
macroinvertebrates and fish. The hatching aquatic insects in
the creek would have to be highly contaminated to constitute a
serious threat to the bats since it appeared doubtful that
foraging Indiana or gray bats would be able to find and consume
enough emerging insects along this stream to constitute a .
significant portion of their diet. Obvious signs of biological
contamination were not observed.
Since a toxicological examination of the Site has not been
conducted, FWS recommended that an ecological contaminant. .
monitoring program be included as part of the selected remedial
alternative for the Tri-City Site. This program should consist
of three monitoring episodes involving bioassays and tissue
analyses. The initial monitoring episode should be conducted
con~urrently with the confirmatory sampling during the Remedial
Design (RD) phase to establish the baseline conditions. The
second monitoring episode should be conducted one year later to
identify any short-term site-re~ated impacts. The third .
monitoring episode should be conducted five years after
implementation ~f the selected remedy to identify any long-term
site-related impacts. The monitoring episodes should also be
conducted during different seasons to be representative of site
conditions.
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If there has been no demonstrable indication of
site-related ecological degradation after the three monitoring
episodes, further ecological monitoring would not be
necessary. However, if the monitoring episodes indicate that
site-related~cological degration has occurred (or is
occurring), histopathological studies may be necessary to
further define the impact. The additional measures necessary
to mitigate the threat to the environment would be implemented
in Operable Unit '2.
Continued monitoring of Brushy Fork Creek for increases in
water column and sediment contamination would also be included
in the ecological contaminant monitoring program. In addition,'
FWS recommended remediation of the contaminated springes) since
volatile organic compounds are entering Brushy Fork Creek via
this pathway. .
6.3
Summary
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this ROD, may present"an imminent and substantial
endangerment to public health, welfare, or the environment.
The health risk posed by thi~ Site is primarily from the
future use of the groundwater/spring water as a potable
source. This risk is due to the presence of VOCs at
concentrations above MCLs and non-zero MCLGs. These
contaminants should be remediated.
The baseline risk assessment also shows a potential health
risk associated with raising beef cattle and cultivating
gardens on-site. However, this potential risk is based the
detection of contaminants in one out of twenty on-site surface
soil samples. Because of the low frequency of detection, the
presence of surface soil contamination should be verified. The
presence of any air contaminants should also be confirmed. .
Tetrachloroethene was detected in two of twelve air samples
collected during the RI, but no source has been identified.
The ecological impacts to Brushy Fork Creek currently
originating from the Site have been determined to be minimal.
The creek is apparently a healthy stream supporting diverse
communities of macroinvertebrates and fish, and no data has
been collected to date to indicate that the creek has been
adversely affected. Also, there is not adequate feeding
habitat to support the endangeyed bats and the bald eagle
within the stream reach of the creek and its tributaries.
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i.
I
The ..diment sampling conducted during the RI revealed
levels of chromium and lead in one sample that substanti~lly
exceeded effects levels estimated by NOAA for aquatic biota.
In addition, mercury was detected in only that sample and at a
level above the ER-L~ Lead was also detected in a downstream
sample at a level slightly above the ER-L. Consequently, the
extent of inorganic contamination in the area of these sediment
samples should be verified. Since the ER-L for lead was
exceeded by only 1 ppm in two other samples, and the degree of
confidence in the lead ER-L as an indicator of adverse effects
. in aquatic biota is moderate, . additional action in the vicinity
of these samples is not currently justified.
Since a toxicological examination has not been conducted at
the Site, the Fish and Wildlife Service has recommended that
the contaminated spring flowing into the creek be remediated
and an ecological contaminant monitoring program be included in
the selected remedy. The program would also include monitoring
of Brushy Fork Creek for increases in water column and sediment
contamination.
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1.0
DESCRIPTION OF ALTERNATIVES
1.1
Backqround
A Feasibility Study (FS) was conducted to develop and
evaluate remedial alternatives for Operable Unit 11 at the
Tri-City Site. Remedial alternatives were assembled from
applicable remedial technology process options and were
initially evaluated for effectiveness, implementability, and
. cost. The alternatives meeting these criteria were then
evaluated and compared to the-nine criteria required by the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). In addition to the remedial alternatives, the NCP
requires that a no-action alternative be considered at every
Superfund site. The no-action alternative serves primarily as a
point of comparison for other alternatives.
The remedial alternatives proposed for the Tri-City Site
were developed to primarily address contaminated groundwater as-
it discharges to the springs. Treatment technologies that -
require the groundwater to be brought to the surface for
treatment using an extraction system were considered. However,
the effectiveness of a pumping well system would depend on the
ability of the individual wells to intersect fractures within
the bedrock. Only six of the thirteen groundwater monitoring
wells attempted at the Site produced sufficient water for
completion, and only one well (MW-08) had suffient yield to be
considered for extraction purposes. Consequently, a high degree
of uncertainty is associated with attempting to capture
contaminated groundwater within the variably fractured rock
mass. Moreover, the existence of a widespread, well-defined
volatile organic contaminant plume was not substantiated by the
analytical results from the RI.
At the Tri-City Site, groundwater discharges to the surface
as springs. The levels of volatile organic contaminants have
apparently decreased in the Klapper and Cattle Springs, and only
the Cox Spring currently contains-VOC levels in excess of MCLs
and non-zero. MCLGs. It is believed that the primary source of
the groundwater contamination was removed during the Emergency
Removal Action conducted by EPA in August and September 1988.
Confirmatory sampling in the area of the removal action is
necessary to determine if this source was completely removed.
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7.2
-67-
Remedial Alternatives
A total of four alternatives were evaluated in detail to
address Operable Unit 11 at the Tri-City Site. Except for the
no-action alternative, each alternative includes the following
common elements:
( 1 )
! .
(2 )
Institutional Controls. Interim actions that include
restrictions on the potable use of groundwater
containing, or potentially containing, levels of
contamination in excess of MCLs or non-zero HCLGs would
be implemented. These springs include the Cox Spring,
the Klapper Spring, the Cattle Spring, the Brading
Spring 11, and the unnamed spring. The restrictions
may include local ordinances, conservation or
restrictive easements, record notice or some other
appropriate measure. Potable water would continue
being provided to residents who previously used the
contaminated springs as sources of potable water. The
restrictions and the provision of potable water to
affected residents would continue until EPA, through
monitoring, determines that the water is of sufficient
and consistent quality for human consumption.
Long-term Monitoring. Since the on-site springs have
been historically used as sources of potable water,
long-term monitoring is proposed to ensure that
contaminant levels remain below MCLs and non-zero
MCLGs. Five of the on-site springs (Cox, Klapper,
Brading 12, Cattle, and the unnamed spring) would be
monitored quarterly for the first year to identify
seasonal variations in contaminant levels,
semi-annually for the next two years, and yearly
thereafter for up' to 27 years. In addition to
continuous reviews for any public health concerns, the
data from the spring sampling would be reviewed to
identify contaminant levels that warrant remedial
action. If treatment of any of the other on-site
springs, in addition to the Cox Spring, is determined
to be necessary, it will be included in Operable Unit
'1.
The groundwater would also be monitored for up to 30
years via annual sampling of the existing wells. The
surface water and sediment of Brushy Fork Creek would
be monitored via annual sampling for up to 30 years.
The 'sampling results would be reviewed every five years
for possible alterations in the monitoring program.
An ecological contaminant monitoring program involving
bioassays and tissue analyses would be conducted at the
Site. This program would consist of three monitoring
episodes , over the fiv~-year period following
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(3)
implementation of the remedy. The initial monitoring
episode would be conducted concurrently with the
confirmatory sampling during the RD phase to establish
baseline conditions. The second monitoring episode
would De conducted one year later to identify any
short-term site-related impacts. The third monitoring
episode would be conducted five years after
implementation of the remedy to ide~tify any long-term
site-related impacts. The monitoring episodes would
also be conducted during different seasons to be
representative of. site conditions. If the monitoring
episodes indicate that site-related ecological
degradation has occurred (or is occurring),
histopathological studies may be necessary to further
define the impact. The additional measures necessary
to mitigate the threat to the environment would be
implemented in Operable Unit '2.
Confirmatory Sampling. Confirmatory sampling would be
conducted to assess the effectiveness of the Emergency
Removal Action conducted near the Cox, Sr. residence.
The apparently disturbed areas in the northern portion
of the Site (as shown in the EPIC aerial photograph
taken in 1967) would be .also sampled to investigate
possible contamination fro~ drum disposal.
The surface soils along the eastern edge 6f the former
disposal area where the PABs and one species of PCB
were found during the RI would be sampled to establish
the extent of any PAS and PCB contamination.
The sediment. in the tributary to Brushy Fork Creek.
where the sample containing levels of chromium and lead
substantially above the ER-L values was collected
during the RI and extending to the location of the
downstream sample containing the lead level in excess
of the ER-L value would be sampled to determine the
extent of the contamination. Additional air sampling
along the slope of the Cox Lobe would be conducted to
identify the source of the PCE detected during the RI.
The remedial alternatives are described in the following
discussions.
Alternative 1 - No Action
Under this alternative, EPA would take no further action and
the Site would be left "as is". This alternative relies on
flushing of the groundwater via the springs to naturally remove
the volatile organic contamination and restore the groundwater
to a Class II-B aquifer suitable for drinking water purposes.
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It i. expected that the VOC levels in the Cox Spring will
decrease to near or below MCLs and non-zero MCLGs within ten
years. This conclusion is based on the following
considerations: (1) the soil contamination that constituted the
primary source of groundwater contamination has been removed;
(2) the VOCs of concern in the aquifer are highly mobile and
rapidly flushed from the aquifer; (3) the contaminants will
flush from the solutionally enlarged fractures of the limestone
aquifer more rapidly than if the aquifer were composed of a
porous medium such as sand or clay; and (4) infiltrating
precipitation will cause dilution of contaminants in the
aquifer. Moreover, the VOC levels in several springs appear to
be decreasing. This trend will be verified by long-term
monitoring.
This alternative would not reduce the risk associated with
the potential potable use of contaminated spring water and
groundwater. Moreover, any risks from potentially contaminated
site soils, sediment, and ambient air would not be investigated.
No funds would be spent for this alternative and it could be
implemented immediately. However,. since this alternative would
result in contamination remaining on-site, CERCLA requires that
the Site be reviewed every five years. If indicated by the
review, remedial actions would be implemented at that time to
mitigate any threat to hlunan health or the environment.-
Alternative 2 - Limited Action
This alternative includes the three major components
previously discussed: institutional controls, long-term
monitoring, and confirmatory sampling. Institutional controls
would be necessary until natural processes restore the
groundwater to a Class II-B aquifer suitable for drinking water
purposes. As described in the no-action alternative, it is
expected that the VOC levels in the Cox Spring will decrease to
near or below MCLs and non-zero MCLGs within ten years.
Since this alternative does not include treatment of the
contaminated spring water, it does not reduce the risk
associated with potential potable usage.
". The total present worth of this alternative for a 30-year
period is approximately $1,714,900 and the capital cost is
estimated to be $880,798. The annual operation and maintenance
costs are shown in Table 19. This alternative could be
implemented in approximately 12 months.
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-70-
TABLE 19
SUMMARY OF COSTS FOR REMEDIAL ALTERNATIVES
Alternative 1 - No Action
Total Present Worth
$0
°
°
°
°
Capital
Annual O&M
Ecological Cost
5-Year Cost
Alternative 2 - Limited Action
Capital
Annua;L O&M:
1st Year
2nd Year
3rd Year
4th-30th Year
Potable Water
Ecological Cost
5-Year Cost
$
880,798
56,396
46,026
46,026
40,842
2,420
22,704
10,000
Supply
Total Present Worth
$1,714,000
Alternative 3 - Carbon AdsorDtion
Capital
Annual O&M
Process Monitorinq
1st Year
2nd-30th Year.
Lonq-Term Monitorinq
1st Year
2nd Year
3rd Year
4th-30th Year
Potable Water SUDDlv
Ecological Cost
5-Year Cost
$
904,254
. 34,386
23,896
53,084
44,370
44,370
40,014
2,420
22,704
10,000
Total Present Worth
$2,098,000
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TABLE 19 (cont'd)
SUMMARY OF COSTS FOR REMEDIAL ALTERNATIVES
Alternative 4 - Aeration
Capital
Annual O&M
Process Monitorinq
1st-5th Year
6th-30th Year
LonQ-Term Monitoring
1st Year
2nd Year
3rd Year
4th-30th Year
Potable Water SUDDlv
Ecological Cost
5-Year Cost
$1,080,743
20,980
10,490
53,084 '
44,370
44,370
40,014
2,420
22,704
10,000
Total Present Worth
$1,990,000
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-72-
Since this alternative would result in contamination
remaining on-site, CERCLA requires that the Site be reviewed
every five years. If indicated by the review, remedial actions
would be implemented at that time to mitigate any threat to
human health-or the environment. .
Alternative 3 - Carbon Adsorction
This alternative includes the three major components
previously described and treatment of contaminated spring water
in a carbon adsorption system. A treatment system would be
installed only at the Cox Spring, unless monitoring indicated
that contamination in other springs exceeded MCLsor non-zero
MCLGs.The treatment system would consist of modifications to
the existing cistern and piping to a disposable activated carbon
canister. The cistern will equalize the contaminant
concentrations and a sand/geotextile filter will collect any
large particulates in the spring water. The spring water would
then flow to the carbon canister by gravity.
Remediation of contaminated groundwater for a Class II-B
aquifer is required to meet HCLs as established under the Safe
Drinking Water Act (40 CFR Part 141) and to attain non~zero
MCLGs. The HCLs and non-zero HCLGs for the contaminants of
concern in the Cox Spring are identified in Table 20. Reduction
of the contaminants to these levels would reduce the
carcinogenic risk associated with the ingestion of contaminated
water to 1.4E-4 and the Hazard Index to less than one (1) for a
70 kilogram (kg) adult over a 70-year lifetime. These levels
are within EPA's acceptable risk range of E-4 to E-6 and a
Hazard Index of less than one (1).
The treated water would be discharged to the tributaries
downstream of the springs. Any discharge to a nearby surface
water body is required to meet National Pollutant Discharge
Elimination System (NPDES) standards established by the Clean
Water Act and requlated by the Commonwealth of Kentucky. The
state surface water standards, 401 KAR 5:031, are included as
Appendix A of this document. Final discharge levels will be
determined by surface water flow information, contaminant
levels, and water quality testing that will be established by
the Commonwealth of Kentucky. The surface water discharge will
. be required to meet the NPDES limits that are established.
Treatment of contaminated spring water will continue until
contaminant. levels in the influent (i.e., the groundwater
discharging to the surface as a spring) decrease to below MCLs
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TABLE 20
SITE-SPECIFIC MCLs AND MCLGs (in PPB)
TRI-CITY INDUSTRIAL DISPOSAL SITE, BROOKS, XBN'l'UCKY
CONTAMINANTS RISK OR
OF CONCERN MCL (1) MCLG (2) BQ (3)
PURGEABLE ORGANICS
Chloroform 100 1.7E-5
l,l-Dichloroethene 7 7 0.02
Cis-l,2-Dichloroethene 70 70 0.2 .
Trans-1,2-Dichloroethene 100 100 0.14
Tetrachloroethene (PCB) 5 0 7.5E-6
Toluene 1000 1000 0.14
1, 1, 1-Trichloroethane 200 200 0.07
Trichloroethene (TCE) 5 0 1.6E-6
Vinyl Chloride 2 0 1.lE-4
Xylenes 10,000 10,000 0.14
EXTRACTABLE ORGANICS
Bis (2-ethylhexyl) Phthalate 4* 0* 1.6E-6
------
TOTAL CARCINOGENIC RISK 1.4E-4 (4)
TOTAL HAZARD INDEX 0.71
(1) Maximum Contaminant Levels (MCLs) are enforceable standards
promulgated under the Safe Drinking Water Act. These standards
apply to specific contaminants that SPA has determined to have
an adverse effect on human health above certain levels. MCLs
are used as remediation levels for contaminants having MCLs.
(2) Maximum Contaminant Level Goals (MCLGs) are non-enforceable
health-based goals that are protective of adverse human health
effects and that allow an adequate margin of safety.
(3) Risk levels and hazard quotients are based on the ingestion
of 2 liters of water every day by a 70 kg person for a lifetime
(70 years). Ri8k levels are for carcinogenic compounds. Bazard
quotients are for non-carcinogenic compounds.
(4) The majority of the risk i8 based on the ~CL for vinyl chloride.
This MCL i. set at the detection limit, therefore it is as low as
possibly attainab~e.
* indicates a proposed MCL or MCLG
- -. indicates that a MCL or MCLG has not been established
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and non-zero MCLGs by natural processes. As described in the
no-action alternative, the VOC levels in the Cox Spring are
expected to decrease to near or below MCLs and non-zero MCLGs
within ten y~ars.
Monthly monitoring of the influent and effluent would be
. required for the first year to. determine the frequency of carbon
replacement. For up to the following 29 years, the influent and
effluent would be sampled prior to carbon replacement.
The spent carbon would be regenerated or treated/disposed
off-site, so analysis of the spent carbon would be conducted
using the the Toxicity Characteristic Leaching Procedure (TCLP)
to determine if it is a hazardous waste. This analysis is
necessary to ensure that applicable Subtitle C or D requirements
of the Resource Conservation and Recovery Act (RCRA) are met.
The total present worth of Alternative 3 over a 30-year
period is. approximately $2,098,000 with a capital cost of
$904,254. The annual operation and maintenance costs are shown.
in Table 19.' The time required to implement this alternative is
expected to be 14 months, which includes 12 months for remedial
design and procurements and two months for construction.
Since this alternative would result in contamination
remaining on-site, CERCLA requires that the Site be reviewed
every five years. If indicated by the review, remedial actions
would be implemented at that time to mitigate any threat to
human health or the environment."
Alternative 4- Aeration
This alternative also includes the three major components
previously described and treatment of the contaminated spring
water by aeration. A treatment system would be installed only
at the Cox Spring, unless monitoring indicated that
contamination in other springs exceeded MCLs or non-zero MCLGs.
The aeration treatment process would involve the construction of
a series of approximately thirty concrete steps over which the
spring water would pass. Spring water would flow into and
through the aeration zone by gravity. The series of steps would
. increase the mixing of the spring water with air, thereby
promoting the evaporation of the VOCs from the water.
As in Alternative 3, remedi~tion of contaminated groundwater
for a Class 'II-~ aquifer is required to meet MCLs as established
under the Safe Drinking Water Act (40 CFR Part 141) and to
attain non-zero MCLGs. The MCLs and MCLGs for the contaminants
of concern in the Cox Spring were identified in Table 20.
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Treatment of contaminated spring water will continue until
contaminant levels in the influent (i.e., the groundwater
discharging to the surface as a spring) decreases to below MCLs
and non-zero MCLGs by natural processes. As described in the
no-action al~ernative, the VOC levels in the Cox Spring are
expected to decrease to near or below MCLs and non-zero MCLGs
within ten years.
The treated water would be discharged to the tributaries
downstream of the springs. As described in Alternative 3, any
discharge to a nearby surface water body is required to meet the
NPDBS standards established by the Clean Water Act and regulateq
by the Commonwealth of Kentucky. Final discharge levels will be
determined by surface water flow information, contaminant
levels, and water quality testing that will be established by
the Commonwealth of Kentucky. The surface. water discharge will
be required to meet the NPDES limits that are established.
A treatability study would be required to determine the
design parameters of the aeration system prior to conat~uction. .
The influent and effluent would be monitored monthly for the
first year and annually for up to the next 29 years if the
system is effective. This treatment process does not generate
any treatment residues other than air emissions. The
treatability study would include a~ evaluation of the air
emissions to determine if treatment would be necessary.
Releases from the aeration zone will comply with the Clean Ai~
Act as enforced through .federa1 and state standards.
The total present worth of this alternative for a 30-year
period is approximately $1,990,000 and the capital cost is
estimated at $1,080,743. The annual operation and maintenance
costs are shown in Table 19. The time required to implement
this alternative is expected to be 13 months, which includes 12
months for remedial design and procurements and one month for
construction.
Since this alternative would result in contamination
remaining on-site, CBRCLA requires that the Site be reviewed
every five years. If indicated by the review, remedial actions
would be implemented at that time to mitigate any threat to
human health or the environment.
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7.3
ARARs
The remedy implemented for Operable Unit '1 will meet the
performance standards described below, which. are the Applicable
or Relevant and Appropriate Requirements (ARARs) identified for
the proposed alternatives.
Remediation of contaminated groundwater for a. Class II-B
aquifer is required to meet MCLs as established under the Safe
Drinking Water Act (40 CFR Part 141) and to attain non-zero
MCLGs. The MCLs and HCLGs for the contaminants of concern at
the Site were identified in Table 20. Reduction of the
contaminants to these levels will reduce the risk associated
with the ingestion of contaminated groundwater to 1.4E-4 for a
70 kg adult over a 70-year lifetime. This risk falls within
EPA's acceptable risk range of E-4 to E-6.
Any discharge to a nearby surface water body is required to
meet National Pollutant Discharge Elimination System (NPDES)
standards established by the Clean Water Act and regulated by
the Commonwealth of Kentucky. The state surface water
standards, 401 KAR 5:031, are included as Appendix A of this
document. Final discharge levels will be determined by surface
water flow informtion, contaminant levels, and water quality
testing that will be established by the Commonwealth of
Kentucky. The surface water discharge will be required to meet
the NPDES limits that are established.
The Clean Air Act is an ARAR for the releases to air from
the treatment systems included in Alternatives 3 and 4.
Releases from these systems would comply with federal and state
standards promulgated under the Clean Air.Act.
The spent carbon from the carbon adsorptl~ft ~reatment system
in Alternative 3 would be regenerated or treated/disposed
off-site, so analysis of the spent carbon would be conducted
using the Toxicity Characteristic Leaching Procedure (TCLP)(40
CPR Part 262, Appendix II) to determine if it is a hazardous
waste. This analysis .is necessary to ensure that applicable
Subtitle C or D requirements of the Resource Conservation and
Recovery Act (RCRA) are met. If the spent carbon is determined
to be a hazardous waste based on the results of the TCLP and if
regeneration is not technically feasible, it would not be land
disposed unless the treatment standards for all applicable TCLP
constituents are met (40 CFR Pa~ 268).
Pursuant to. the Occupational Safety and Health Act of 1970
(OSHA), health and safety standards for employees engaged in
hazardous waste operations were effective on March 6, 1990 (54
FR 9294 )'. Consequently, a worker health and safety program that
complies with OSHA standards is required for the remedial
activities to be conducted on-site.
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8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During the Feasibility Study, a detailed analysis of each
alternative was performed using the nine evaluation criteria
identified in the NCP. .The advantages and disadvantages of each
alternative were then compared to identify the alternative
providing the best balance of the nine criteria. The following
discussions summarize the comparative analysis.
"8.1
Overall Protection of Human Health and the Environment
Overall protection of human health and the environment
addresses the degree to which the alternative eliminates,
reduces, or controls threats to public health and the
environment through treatment, engineering methods, or
institutional controls.
The present and future risks to human health and the
environment from exposure to contaminated groundwater (primarily
as it discharges to the surface as springs) would be unchanged
if Alternative 1 was implemented. Although it is anticipated
that contaminant concentrations will eventually decrease as a
result of" natural degradation and flushing, the VOCs iri the
spring water are currently volatilizing into the atmosphere
through natural mixing in t~e stream bed. The impact on
downgradient surface water bodies has been determined to be
minimal. In addition, any risks from potentially contaminated
site soils, sediment, and ambient air would not be investigated.
Alternative 2 includes institutional controls to restrict
residents from using groundwater and spring water for domestic
purposes, and it provides for potable water to affected
residents. Consequently, the potential risks to human health
from the use of contaminated groundwater and spring water would
be reduced. Any risks associated with potentially contaminated
site soils, sediment, and ambient air would also be investigated
in the alternative so it is more protective than Alternative 1.
However, neither alternative includes treatment of groundwater
to MCLs and non-zero HCLGs, and VOCs will continue to volatilize
into the atmosphere.
Alternative 3 would provide protection of human health and
the environment. Institutional.controls, provision of potable
water to affected residents, an~ groundwater treatment would
reduce the potential risk to human health from ingestion and
other household uses. . Groundwater treatment would also reduce
any en~ironmental impacts by preventing the spread of
cont~nants to Brushy Fork Creek and the atmosphere.
Contaminant levels in the groundwater would be reduced to
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levels in conformanca~ith ARARs. Moreover, any risks
associated with potentially contaminated site soils, sediment,
and ambient air would also be investigated in this alternative.
Alternative 4 would be protective of human health and the
environment. However, the proposed aeration system is
innovative and a treatability study would be necessary to
determine if air emission controls are required. The potential
risk to human health from ingestion of contaminated groundwater
and other household uses would be reduced by institutional
. controls, provision of potable water to affected residents, and
groundwater treatment to levels in conformance with ARARs.
Groundwater treatment would also reduce any environmental
impacts by preventing the spread of contaminants to Brushy Fork
Creek. As in Alternatives 2 and 3, any risks associated with
potentially contaminated site soils, sediment, and ambient air
would be investigated in Alternative 4.
8.2
ComDliance with ADDlicable or Relevant and ADDropriate
Reauirements CARARs)
Applicable requirements are those cleanup standards,
standards of control, and other substantive requirements,
criteria, or limitations promulgated under federal or state
environmental or facility siting law that specifically address a
hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a CBRCLA site. Relevant and
appropriate requirements are those cleanup standards, standards
of control, and other substantive requirements, criteria, or
limitations under federal or state environmental siting law
that, while not "applicable" to a hazardous substance,
pollutant, contaminant, remedial action location, or other
circumstance at a CBRCLA site, address problems or situations
sufficiently similar to those encountered at the CBRCLA site
that their use is well suited to the particular site.
Compliance with ARARs addresses whether a remedy will meet all
federal and state environmental laws and/or provide basis for a
waiver from any of these laws.
BPA has divided ARARs into the following three categories to
facilitate their identification: chemical-specific,
location-specific, and action-specific.
. Chemical-specific ARARs are. usually health- or risk-based
numerical values or methodologies used to determine acceptable
concentrations of ch~cals that may be found in or discharged
to the environment. .
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-79-
Location-specific ARARs restrict actions or contaminant
concentrations in certa~n environmentally sensitive areas.
Examples of areas regulated under various federal laws include
floodplains, wetlands, and locations where endangered species or
historically significant cultural resources are present. No
location-specific ARARs apply to the Tri-City Site.
Action-specific ARARs are usually technoloqy- or
activity-based requirements or limitations on actions or
~ondition~ involving specific substances.
Alternatives 1 and 2 would not comply with chemical-specific
ARARs since the Cox Spring would not be remediated. Groundwater
contaminant levels would continue to exceed MCLs and non-zero
MCLGs until natural degradation and flushing reduces the .
levels. There are no action-specific ARARs for Alternatives '1
and 2. .
Both Alternatives 3 and 4 would be in compliance with
chemical-specific ARARs. EPA has determined that the point of .
compliance for ARARs is where the groundwater discharges to the
surface as springs. Remediation of the Cox Spring (the only
spring currently containing contaminant levels in excess of MCLs
and non-zero MCLGs) will be in conformance with the Safe
Drinking Water Act and the treated discharge will meet NPDES
standards established by the Clean Water Act and regulated by
the Commonwealth of Kentucky.
Both Alternatives 3 and 4 would be in compliance with
action-specific ARARs. The spent carbon generated in
Alternative 3 would be evaluated for the toxicity charcteristic
to ensure that applicable Subtitle C or D requirements of RCRA
are met. A treatability study of the aeration system described
in Alternative 4 would be conducted to determine the
applicability of the Clean Air Act to emissions.
8.3
Lona-term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the ability
of an alternative to maintain reliable protection of human
health and the environment. This criterion includes the
consideration of residual risk and the adequacy and reliability
of controls.
Alternative 1 would not be effective in mitigating potential
risks associate~ with the domestic uses of groundwater and .
future land use scenarios, including excavation in areas of
potential subsurface soil contamination. Moreover, any risks
from potentially contaminated site soils, sediment, and ambient
air would not be investigated. Since potential risks are not
addressed, there is a likelihood that future remedial actions
would be necessary.
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Alternative 2 would mitigate the health risk through the
implementation of institutional controls to restrict the potable
use of contaminated groundwater. Groundwater use restrictions
would be easy_to implement and reliable in the long-term if
enforced by federal, state, or local agencies and complied with
by property owners. Moreover, the provision of potable water to
affected residents and long-term monitoring of the groundwater
are reliable methods to reduce the health risk associated with
contaminated water supplies. However, the contaminated
groundwater would not be treated.
. .
. .
Alternative 2 does not prevent the migration of
contamination to Brushy Fork Creek nor does it provide
protection to the biota. However, any adverse effects on
downgradient surface water bodies have, to date, been dete~ned
to be minimal, and long-term monitoring is a reliable method. for
detecting the migration of contaminants.
Alter~atives 3 and 4 provide the highest degrees of
long-term effectiveness and permanence because both al~ernatives
use irreversible treatment technologies to reduce the hazards
associated with VOCs in spring water. Alternative 3 utilizes a
proven and widely available technology. However, the spent
carbon filters would require regeneration or treatment and
disposal at an approved facility. The aeration system described
in Alternative 4 is innovative, and a treatability study would
be required to determine the design parameters. Moreover, the.
treatability study would be used to quantify the air emissions
from the zone of aeration and to determine if control measures
are necessary.
Both Alternatives 3 and 4 include long-term monitoring and
confirmatory sampling, which are effective methods of .
identifying any additional human health or environmental risks
associated with -the Site.
Reduction of Toxicitv. Mobilitv. or Volume through
Treatment
8.4
Reduction of toxicity, mobility, or volume refers to the
preference for a remedy that uses treatment to reduce health
- hazards, contaminant migration, or the quantity of contaminants
at the Site. - .
Alternatives 1 and 2 do not include treatment and would not
reduce the toxicity, mobility,. or volume of the contaminants in
the groundwater. Alternative 3 would reduce the mobility of
contaminants by transferring the VOCs to the activated carbon.
The toxicity and volume of the contaminants would be reduced
when the spent activated carbon is removed from the Site for
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regeneration or treatment prior to disposal at an approved
off-site facility. Alternative 4 would reduce the volume of
contaminants in the groundwater, but air emission controls would
be necessary to prevent transfer of the. contaminants to the
atmosphere. The nature and quantities of these contaminatnts
would be identified during the treatability study to determine
compliance with the appropriate air standards.
8.5
Short-term Effectiveness
Short-term effectiveness addresses the period of time needed
to achieve protection and assesses any risks to human health and
the environment during the construction and implementation
period until cleanup objectives are achieved.
There would be no short-term risk to the community and the
environment if Alternative 1 was implemented because no work
would be performed. And though the institutional controls
included in Alternative 2 would not result in short-term risks..
to the community, workers would need protective clothing during
field sampling activities to avoid contact with contaminants.
Alternatives 3 and 4 require installation of treatment
systems on-site, in addition to implementing the long-term
monitoring and confirmatory sampling programs. Both
alternatives required very limited construction that would
result in minimal impact on the on-site residents. Monitoring.
would be performed during construction to ensure protection of
the on-site residents and workers. Protective equipment would
also be used by workers who might come in contact with
contaminated groundwater. Impact to the c~eek would also be
minimal since the construction would be confined to a small
area.
Construction time periods are anticipated to be short for
the two treatment alternatives, with two months for Alternative
3 and one month for Alternative 4. The time required for
remedial design and procurement would be approximately 12 months
for both alternatives, but the treatability study necessary for
Alternative 4 would take an additional 6 months.
8.6
Imclementability
Implementability refers to the technical and administrative
feasibility .of an alternative, including the availability of
materials and services n~eded to implement the chosen solution.
It also includes coordination of federal, state, and local
governments to clean up the site.
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,.
Alternative 1 is the least difficult' alternative to
implement because no work is necessary. The institutional
controls included in Alternative 2 would be relatively easy to
implement by_federal, state, and local.officials, and/or the
property owners. Transportation of potable water would continue
using the established methods. Groundwater monitoring would be
performed using the previously installed monitoring wells and
the existing springs.
The carbon adsorption treatment system included in
Alternative 3 is relatively easy to implement because carbon
adsorbers are available as off-the-shelf items from many
vendors. Construction of the system should not pose major
problems unless the bedrock is shallow such that it impedes the
installation of underground piping. If this is the case,
insulation or soil covers could be used to protect the piping
from freezing during the winter.
Carbon adsorption is a proven and reliable technology for
treatment of VOCs. The operation of the system would require.
periodic sampling of the influent and effluent, replacing the
carbon canisters, cleaning the cistern and sand/geotextile
filter, and regeneration or treatment/disposal of the spent
carbon filters. Consequently, operation and maintenance of the
sytem would require a long-term commitment from state and local
agencies. Future remedial actions, if necessary, would be
relatively easy to implement since the carbon adsorbers are
removable. .
The aeration system included in Alternative 4 is also
relatively easy to implement. The aeration zone could be
constructed with small power equipment since heavy equipment
cannot access the spring, and materials are readily available
from multiple vendors. Operation and maintenance of this
treatment system would be limited to long-term monitoring.
However, this system is innovative and a treatability study is
necessary to determine the design parameters and to quantify the
air emissions. Delays in the implementation of this alternative
could arise as a result of unacceptable risk associated with the
VOC emissions. Moreover, future remedial actions may be
difficult to implement with the aeration zone in place.
8.7
Cost
This criterion involves evaiuation of the estimated capital
(i.e., the cost. of implementation) and operation and maintenance
costs for each alternative. The'costs for the four alternatives
developed for the Tri-City Site were itemized in Table 19.
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There are no capi~al or operation and maintenance costs
associated with Alternative 1 since no remedial action would be
implemented. . The capital cost for Alternative 2 is $880,798 and
the total present worth over a 30-year period is estimated to be
$1,714,000. -
The capital costs of Alternatives 3 and 4 are $904,254 and
$1,080,743, respectively. The total present worth over a
30-year period for these alternatives is $2,098,000 and
$1,990,000, respectively. While the "up front" cost is higher
for Alternative 4, the total present worth is slightly less
because operation and maintenance is minimal.
8.8
State AcceDtance
State acceptance indicates whether or not, based on its
review of the RI and FS Reports and the Proposed Plan, the
Commonwealth of Kentucky concurs with, opposes, or has no
comment on EPA's preferred alternative.
Based on review of the RI and FS Reports and the Proposed
Plan, the Commonwealth generally concurs with EPA's selected
remedy for Operable Unit '1. Although the Commonwealth believes
that a complete characterization of a site is necessary before a
successful strategy for remediation can be plot~ed, they will
consider the successful remediation of Operable unit '1 as a
first step in the complete remediation of the Tri-City Site.
The Commonwealth also continues to maintain that the statute
KRS 224.877 is a state ARAR that is more stringent than federal
requirements. However, if EPA meets the criteria outlined in
Section 10 of KRS 224.877, the Commonwealth believes that EPA
will have complied with the requirements of the statute.
Specifically, Section 10 of KRS 224.877 states that "the
remedial action shall protect human health, safety, and the
environment considering the following factors as appropriate:
(a) The characteristics of the substance, pollutant, or
contaminant, including its toxicity, persistence,
environmental fate and transport dynamics,
bioaccumulation, biomagnification, and potential for
sYnergistic interaction and with specific reference to
the environment in which the substance, pollutant, or
contaminant has been released;
(b) The .hydrogeologic characteristics of the facility and
the surrounding area;
(c) The proximity, quality, and current and future uses of
surface water and groundwater;
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(d) The potential effects of residual contamination of
potentially impacted surface water and groundwater;
(e) The chronic and acute health effects and environmental
consequences to terrestrial and aquatic life of exposure
to the hazardous substance, pollutant or contaminant
through direct and indirect pathways;
(f) An exposure assessment; and
. .
(g) All other available information."
EPA does not agree that KRS 224.877 is a state ARAR because
it does not contain any specific, enforceable requirements that
are more stringent than provided by federal law. Nonetheless,
EPA believes that the selected remedy complies with the
requirements of KRS 224.877 because it is protective of human
health; safety, and the environment taking the statutory factors
into consideration through the performance of a Remedial
Investigation, a Feasibility Study, and a Baseline Risk
Assessment. And, as stated in this Record of Decision, the risk
to human health and the environment associated with
contamination identified during the confirmatory sampling will
be re-evaluated based on the additional sampling data. Since
the Commonwealth did not submit timely comments on the Baseline
Risk Assessment, their concerns will be considered during the
re-evaluation.
The letter containing the Commonwealth's comments on the
Draft Record of Decision is included in Appendix B.
8.9
Communi tv AcceDtance
Community acceptance indicates the public support of a given
alternative. Community acceptance of the various alternatives
is evaluated in the Responsiveness Summary included in this
document in Appendix C. The Responsiveness Summary provides a
thorough review of the comments EPA received on the RI and FS
Reports and the Proposed Plan during the public meeting and the
public comment period. '.
9.0
THE SELECTED REMEDY
The investigations at the Tri-City Site have shown that the
Cox and Klapper Springs have contained levels of volatile
organic compounds in excess of MCLs. Both springs have been
used as sources of potable water by on-site residents. At this
time, however, only the Cox Spring contains contaminant levels
in excess of MCLs and non-zero MCLGs.
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Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, EPA
has selected Alternative 3, which includes treatment of the
contaminated spring water in a carbon adsorption system, as the
preferred method of addressing Operable Unit 11 at the Tri-City
Site. Carbon adsorption is a well-proven, reliable technology
that would be effective for removing the volatile organic
compounds from the spring water. Removal efficiencies as high
as 99 percent could potentially be achieved for these
contaminants.
Alternative 3 will involve the following specific
activities:
( 1 )
(2 )
( 3 )
Institutional controls to restrict the potable use of
groundwater containing, or potentially containing, .
levels of contamination in excess of MCLs and non-zero
MCLGs. Institutional controls may include local
ordinances, conservation or restrictive easements,
record notice, or some other appropriate measure. The
restrictions will remain in effect until EPA, through
monitoring, determines that the water is of sufficient
and consistent quality for human consumption.
Continued provision of potable water to residents who
previously used contaminated groundwater as a source of
potable water. Water will be supplied until EPA, .
through monitoring, determines that the water is of
sufficient and consistent quality for human
consumption.
Long-term monitoring of the groundwater, surface water,
sediment, and ecology. Since the on-site springs have
been historically used for potable water, long-term
monitoring is proposed to ensure that contaminant
levels remain below MCLs and non-zero MCLGs. Five of
the on-site springs (Cox, Klapper, Brading '2, Cattle,
and the unnamed spring) will be monitored quarterly for
the first year to identify seasonal variations in
contaminant levels, semi-annually for the next two
years, and yearly thereafter for up to 27 years. In
addition to continuous reviews for any public health
concerns, the data from the. spring sampling will be
reviewed to identify contaminant levels that warrant
remedial action. If treatment of any of the other
on~site springs, in addition to the Cox Spring, is
determined to be necessary, it will be included in
Operable Unit t1.
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(4)
-86-
The groundwater will be monitored for up to 30 years
via annual sampling of the existing we~ls. The surface
water and sediment of Brushy Fork Creek will also be
monitored via annual sampling for up to 30 years. The
sampling results will be reviewed every five years for
possible alterations in the monitoring program.
An ecological contaminant monitoring program involving
bioassays and tissue analyses will be conducted at the
Site. This program will consist of three monitQring
episodes .over the five-year .period following .
implementation of the remedy. The initial monitoring
episode will be conducted concurrently with the .
confirmatory sampling during the RD phase to establish
baseline conditions. The second monitoring episode
will be conducted one year later to identify any
short-term site-related impacts. The third monitoring
episode will be conducted five years after
implementation of the remedy to identify any long-term
site-related impacts. The monitoring episodes will
also be conducted during different seasons to be
representative of site conditions. If the monitoring
episodes indicate that site-related ecological
degradation has occurred (or is occurring),
histopathological studies may be necessary to further
define the impact. The additional measures necessary
to mitigate the threat to the environment will be
implemented in Operable Unit '2.
Confirmatory sampling to assess the effectiveness of
the Emergency Removal Action conducted near the Cox,
Sr. residence. The apparently disturbed areas in the
northern portion of the Site (as shown in the EPIC
aerial photograph taken in 1967) will be also sampled
to investigate possible contamination from drum
disposal.
The surface soils along the eastern edge of the former
disposal area where the PABs and one species of PCB
were found during the RI will also be sampled to
establish the extent of any PAS and PCB contamination.
The sediment in the tributary to Brushy Fork Creek
where the sample containing levels of chromium and lead
substantially above the ER~L values was collected
during theRI will be included in the confirmatory
sampling program to determine the extent of the
contamination. The sediment sampling will extend to
the location of the downstream sediment sample that
contained a level of lead in excess of the ER-L value.
Additional air sampling along the slopes of the Cox
Lobe will be conducted to identify the source of the
PCE detecte~ during the RI.
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C 5 )
Treatment of the contaminated water in the Cox Spring
in a carbon adsorption system. The treatment system
will consist of modifications to the existing cistern
and ~iping to a disposable activated carbon canister.
The cistern will equalize the contaminant
concentrations and a sand/geotextile filter will
collect any large particulates in the spring water.
The spring water will then flow to the carbon canister
by gravity. A preliminary diagram of the treatment
system is shown in Figure 18.
The system will be designed to handle an estimated
average year-round flow of 2.5 gallons per minute
Cgpm). The flow rate of the Cox Spring has been
estimated to be one (1) gpm during the dry season and 5
gpm maximum during wet weather. Specific flowrate
characteristics of the Cox Spring will be confirmed
during the Remedial Design phase.
The point of compliance for ARARs has been determined
to be where the groundwater discharges to the surface
as springs. Remediation of a Class II aquifer. is
required to meet MCLs and non-zero MCLGs as established
under the Safe Drinking Water Act. The treated water
will be dicharged to the downstream tributary. This
discharge will be required to meet the NPDES standards
established by the Clean Water Act and regulated by the
Commonwealth of Kentucky. The carbon canister will be
sized to treat the contaminant levels to these
. standards. The specific performance standards for
groundwater treatment have been discussed in Section
7.3 of this Record of Decision document. .
Monthly monitoring of the influent and effluent will be
required for the first year to determine the frequency
of carbon replacement. Based on an estimated average
year-round flow of 2.5 gpm, a replacement rate of one
canister containing 150 pounds of carbon every two
months is anticipated. This estimate will be verified
during the first year of monitoring. For up to the
following 29 years, the influent and effluent will be
8ampled prior to carbon replacement.
The spent carbon will be regenerated or treated/
disposed off-site. Evaluation for the toxicity
ch~racteristic will be necessary to ensure that the
applicable Subtitle C 0; D requirements of RCRA are
met. An estimated 900 pounds per year of contaminated
carbon is expected to be generated by the treatment.
sys~em~
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PtN.MaEftS ... L....... 2... .,.. .... J., .........
Of.SIGN flOW, GP" 25 25 2.5
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II"P AMBlrNT AMBIfNl -I[NI
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CO\I(R
LEGEND'
t>
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In addition to the above activities, various support.
activities including the implementation of a worker health and
safety program and environmental monitoring for indicator
chemical emissions will be conducted.
The estimated cost of Alternative 3 was shown in Table 19.
The total present worth is approximately $2,098,000 with an
estimated capital cost of $904,254. The time required to
implement this alternative is expected to be 14 months, which
"includes 12 months for remedial design and procurements and two
months for construction.
10.0
THE STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that provide
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. One of the requirements
specifies that when complete, the selected remedial action for
the site must comply with applicable or relevant and appropriate
environmental standards established under federal and state
environmental laws unless a waiver is justified. The selected
remedy must also 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 discussions address how the
selected remedy meets these statutory requirements.
10.1
Protection of Human Health and the Environment
Based on the baseline risk
risk is from the potential use
as a source of potable water.
of VOCs at levels in excess of
(MCLs) e.tablished by the Safe
assessment, the primary health
of the contaminated groundwater
This risk is due to the presence
the Maximum Contaminant Levels
Drinking Water Act.
The selected remedy protects human health and the
environment by treating the contaminated groundwater in a carbon
adsorption system. It is not practicable to extract groundwater
for treatment because of the hydrogeologic conditions at the
Site, so the contaminated groundwater will be treated as it
discharges to the surface as springs.
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The contaminants will be permanently removed from th~
groundwater by the activated carbon filtration system. The
spent carbon will then be transported off-site for regeneration
or treatment And disposal.
Treatment of the contaminated groundwater will continue
until contaminant levels in the influent decrease to below MCLs
and non-zero MCLGs by natural processes. It is anticipated that
the VOC levels will decrease to near or below MCLs and non-zero
-HCLGs within ten years.
Treatment of the contaminated groundwater to HCLs and
non-zero HCLGs will reduce the carcinogenic risk to 1.4E-4 and
the Hazard Index to less than one (1). These levels are within
EPA's acceptable risk range of E-4 to E-6 ~nd a Hazard Index of
less than one (1).
The baseline risk assessment also revealed a potential risk
associated with raising beef cattle and cultivating gardens
on-site. However, this potential risk is based on the detection
of polycyclic aromatic hydrocarbons (PABs) and one species of
PCB in one out of the twenty surface soil samp~es collected
during the RI. The extent of PCB and PAS contamination in
surface soils will be determined during the confirmatory
sampling. The associated risks will be re-evaluated based on
the new data.
Tetrachloroethene (also known as perchloroethylene, or PCE)
was detected in only two of the twelve ambient air samples
collected on-site during the RI. Although the risk associated
with this exposure pathway was within EPA's acceptable risk
range, the noncarcinogenic hazard quotient exceeded unity.
Since a source of the PCE contamination in the air has not been
identified, additional sampling will be conducted to determine
if a source of the PCE exists. The risks associated with the
air pathway will be re-evaluated based on the new data.
The sediment sampling conducted during the RI revealed
levels of chromium and lead in one sample that substantially
exceeded effects levels estimated by NOAA for aquatic biota.
Consequently, the extent of inorganic contamination will be
verified during the confirmatory sampling.
No unacceptable short-term risks or cross-media impacts are
anticipated to be caused by implementation of the selected
remedy.
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10.2
COmDliance with ARARs
The selected remedy involving treatment of contaminated
groundwater using carbon adsorption, institutional controls, the
provision of potable water, long-term monitoring, and
confirmatory sampling will comply with all Applicable or
Relevant and Appropriate Requirements (ARARs). The ARARs for
the selected remedy are listed below.
Chemical-scecific ARARs
Federal:
State:
Clean Water Act .
- National Pollutant Discharge Elimination
System (40 CFR Part 122)
- Water Quality Standards (40 CFR Part 131)
- Ambient Water Quality Criteria (Section
304(a)(1) of the Clean Water Act)
Safe Drinking Water Act
- Maximum Contaminant Levels (MCLs)
(40 CFR Part 141)
- Maximum Contaminant Level Goals (MCLGs)
(40 CFR Part 141, 50 FR 46936) .
401 KAR 5:031 - Surface Water Standards
Federal:
Action-scecific ARARs .
1- .-
State:
Resource Conservation and Recovery Act
- 40 CFR Part 262 (Generators & Temporary
Storage) .
40 CFR Part 263 (Manifests &
Transportation)
- 40 CFR Part 264 (Storage)
Clean Air Act (40 CFR Parts 50-62)
Occupational Safety and Health Act of 1970
- Health and safety standards for employees
engaged in hazardous waste operations
(54 FR 9294)
u.S. Department of Transportation's Hazardous
Materials Transportation Act of 1990
63:020 - Potentially Hazardous Matter or
Toxic Substances
- Treatment Requirements
- Transporting Hazardous Materials
Hazardous Material: Permits,
Emergency Procedures, Enforcement
401 KAR
401 KAR 5:035
601 KAR 1:025
KRS 174-415 -
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-92- .
10.3
Cost Effectiveness
The selected alternative, Alternative 3, is cost-effective
because it has been determined to provide overall effectiveness
proportional-to the. cost. Carbon adsorption is a proven,
reliable, and easily implementable technology for the treatment
ofVOCs in water. Minimal ri~k is associated with.
implementation and the operation and maintenance ~f the
treatment system. The total present worth of Alternative 3 is
$2,098,000.
10.4
Utilization of Permanent Solutions and Alternative
Treatment Technoloaies or Resource Recoverv Technoloaies
to the Maximum Extent practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for
Operable Unit One at the Tri-City Site. Of the alternatives
that are protective of human health and the environment and that
comply with ARARs, EPA has determined that the selected remedy
provides the best balance of tradeoffs with respect to long-term
effectiveness and permanence, . reduction of toxicity, mobility,
. or volume through treatment, short-term effectiveness,
implementability, and cost while considering state and community
acceptance.
The selected remedy utilizes a carbon adsorption treatment
system, which is a proven and reliable technology for the
removal of VOCs from water. Consequently, this alternative
would be effective in mitigating the risk associated with the
contaminated groundwater. .
Treatment in the carbon adsorption system would reduce the
mobility of contaminants by transferring the VOCs to the
activated carbon. The toxicity and volume of the contaminants
would be reduced when the spent carbon is removed from the Site
for regeneration or treatment prior to disposal at an approved
facility. '.
The carbon adsorption system is relatively easy to implement
and the limited construction would result in minimal risk to
workers and the community. The treatment system would also
require minimal operator attention, such as periodic sampling
and replacement .of the carbon containers.
The selected remedy, in comparison with the other treatment
. alternative considered, is more reliable and easier to
implement. It will significantly reduce the toxicity, mobility,
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---
I
I
-93-
and volume of hazardous substances on-site. And, it is
protective of human health and the environment. Therefore, it
has been determined to be the most appropriate remedy for the
contaminated~roundwater at the Tri-City Site.
10.5
Preference for Treatment as a Princical Element
BPA has determined that Alternative 3, which includes
treatment of contaminated groundwater in a carbon adsorption
system, satisfies the statutory preference for remedies that
employ treatment and meets the expectations in the NCP regarding
restoration of groundwater to its beneficial uses within a
reasonable timeframe.
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Record of Decision
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
APPENDICES
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Record of Decision/Operable Unit 11
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
APPENDICES
.
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Record of Decision/Operable Unit .1
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
APPENDIX A
Kentucky Surface Water Standards
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NATURAL RESOURCES AND ENVIRONMENTAL
PROTECTION CABINET
Department for Environmental Protection
Division of Water
401 KAR 5:031. Surface water standards.
RELATES TO: KRS Chapter 224
ST ATUTOR Y AUTHORITY: KRS 224.020, 224.033, 224.034, 224.037, 224.060
and 33 U.S.C. 1313
NECESSITY AND FUNCTION: This regulation sets forth water quality standar<1s
which consist of designated legitimate uses of the surface waters of the COl11mo.nwealth and
the associated water quality criteria necessary to protect those uses. Thes~ standards are
minimum criteria which apply to all surfac.e waters in order to maintain and protect them
'for designated uses. Criteria for nutrients are recognized and included. These water quality
.standards are established to protect public health and welfare, protect and enhance the
quality of water, and fulfill federal and state requirements for the establishment of water
quality standards. These water quality standards are subject to periodic review and revision
in accordance with federal and state laws. Definitions for terms used in this regulation are
found in 401 KAR 5:029.
Section 1.
Nutrient Limits.
(1)
In lakes, surface impoundments and their
tributaries, and other surface waters where eutrophication problems may exist, nitrogen,
phosphorus, carbon, aryd contributing trace element discharges will be limited as appropriate
by. the cabinet.
(2)
The affected surface waters will be designated as nutrient limited.
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Section 2. Minimum Criteria Applicable to all Surface Waters. (l)The following
minimum water quality criteria are applicable to all surface waters including mixing zones,
with the exception that toxicity to aquatic life in mixing zones shall be subject to the
provisions of 401 KAR 5:029, Section 5. Surface waters shall not be aesthetically or
otherwise degraded by substances that:
(a) Settle to form objectionable deposits;
(b) Float as debris, scum, oil, or other matter to form a nuisance;
(c) Produce objectionable color, odor, taste, or turbidity;
(d) Injure, are chronically or acutely toxic to or produce adverse physiological
or behavioral responses in humans, animals, or fish and other aquatic life;
(e) Produce undesirable aquatic life or result in the dominance of nuisance
species;
(f) Cause fish flesh tainting (the concentration of all phenolic compounds
which cause fish flesh tainting shall not exceed 5 ug/1 as an instream value);
(g) Cause the following changes in radionuclides:
1. The gross total alpha particle activity (including radium-226 but excluding
radon and uranium) to exceed fifteen (15) pCi/1;
2. Combined radium-226 and radium-228 to exceed five (5) pCi/1 (specific
determinations of radium-226 and radium-228 are not necessary if dissolved gross alpha
particle activity does not exceed five (5) pCi/1);
3. The concentration of total gross beta particle activity to exceed fifty (50)
pCi/1;
4. The concentration of tritium to exceed 20,000 pCi/1;
5. The concentration of total Strontium-90 to exceed eight (8) pCi/1.
(2) The following criteria are applicable to all surface waters outside designated
mixing zones except for those points where water is withdrawn for domestic water supply
use. They are established for the protection of human health from the consumption of fish
tissue, and shall not be exceeded.
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r--~
!
For those substances associated with a cancer risk, an acceptable risk level of no
more than one additional cancer case in a population of one million people 00-6) will be
utilized to establish the allowable concentration.
Table 1.
Water Quality Criteria for Protection of Human Health
from the Consumption of Fish Tissue
Substances Not Linked to Cancer
Metalsl
Antimony
Chromium (III)
Mercury
Nickel
Thallium
Organics
Acrolein
1,2,4,S-tetrachlorobenzene
Pentachlorobenzene
1 , 1 , I-trichloroethane
bis(2-chloroisopropyl) ether
Dichlorobenzenes
Dichloropropenes
Endosulfan
Ethylbenzene
Fluoranthene
Isophorone
2.4-dinitro-o-cresol
Dinitrophenol
Concentrat ion -
( ug/l)
45,000
3,433,000
0.146
100
48
780
48
85
1.030.000
4,360
2.600
14,100
159
3,280
54
520,000
765
14.300
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Dibutyl phthalate
Diethyl -phthalate
154,000
1,800,000
Di-2-ethylhexyl phthal'a te
50,000
Dimethyl phthalate.
2,900,000
Toluene
424,000
Substances Linked to Cancer
Metalsl
Beryllium
0.117
Organics
Acrylonitrile
0.65
Aldrin
.000079
Benzene
40.0
Benzidine
.00053
Carbon tetrachloride
6.94.
Chlordane
.00048
Hexachlorobenzene
.00074
1,2~ichloroethane
243
1,1,2-trichloroethane
41.8
1, l,2,2,-tetrachJoroethane
10.7
Hexachloroethane
8.74
2,4,6-trichlorophenol
3.6
bis(2-chloroethyl) ether
1. 36
Chloroform
15.7
DDT
0.00002~
Dichlorobenzidine
0.02
1,1-dichloroethylene
1. 85
Dieldrin
0.000076
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2,4-dinitrotoluene 9.1
Dioxin (2,3,7,8-TCDD) 0.000000014
Diphenylhydrazine 0.56
Halomethanes 15.7
Heptachlor 0.00029
Hexachlorobutadiene 50.0
alpha Hexachlorocyclohexane (HCH) 0.031
betaHCH 0.0547
gamma HCH (lindane) 0.0625
Technical HCH 0.0414
N-nitrosodiethylamine 1.24
N-nitfosodimethylamine 16.0
N-nitrosodibutylamine 0.587
N-nitroscxliphenylamine 16.1
N-nitrosopyrrolidine 91.9
Polychlorinated Biphenyls (PCBs) 0.000079
Polynuclear Aromatic Hydrocarbons (PAHs) 0.0311
Tetrachloroethylene 8.85
Toxaphene 0.00073
Trichlorethylene 80.7
Vinyl Chloride 525
^Total recoverable form measured in an unfiltered sample
Section 3. Use Classifications and Associated Criteria. (1) Surface waters may
be designated as having one (1) or more of the following legitimate uses and associated use
criteria. The classifications in Sections 4, 5, 6, and 7 include the most common usage of
surface waters within the Commonwealth. Nothing in this regulation shall be construed to
prohibit or impair the legitimate beneficial uses of these waters. The criteria in Section 2
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and the following use criteria represent minimum conditions necessary to protect surface
waters for the indicated use and to provide for the protection of human health from fish
consumption or a combination of fish and water consumption.
(2) On occasion surface water quality may be outside of the limits established
to protect designated uses because of natural conditions. When this condition occurs during
periods when stream flows are below the flow which is used by the cabinet to establish
effluent limits for wastewater treatment facilities, a discharger shall not be considered a
contributor to instream violations of water quality standards, provided that treatment in
compliance with permit requirements is maintained.
(3) Governing flows for water quality-based permits. The following stream
flows are to be utilized when deriving KPDES permit limitations for the protection of
surface waters for the listed uses and purposes.
(a) Aquatic life protection - 7QjQ
(b) Water-based recreation protection - 7QiQ
(c) Domestic water supply protection - Harmonic mean for cancer-linked
substances, 7Qio for noncancer-linked substances, determined at points of
withdrawal
(d) Human health protection from fish consumption only - Harmonic mean for
cancer-linked substances, 7Q10 for noncancer-linked substances
(e) Protection of aesthetics and for changes in radionuclides -
Section 4. Aquatic Life. (1) Warmwater aquatic habitat. The following
parameters and associated criteria shall apply for the protection of productive warmwater
aquatic communities, fowl, animal wildlife, arborous growth, agricultural, and industrial
uses:
(a) Natural alkalinity as CaCO3 shall not be reduced by more than twenty-five
(25) percent. Where natural alkalinity is below twenty (20) mg/1 CaCO^t no reduction below
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the natural level. is allowed. Alkalinity shall not be reduced or increased to a degree which
may adversely affect the aquatic community.
(b)
pH shall not be less than 6.0 nor more than 9.0 and shall not fluctuate more
than one (1) unit over a period of twenty-four (24) hours.
(c)
Flow shall not be altered to a degree which will adversely affect the
aquatic com munity.
(d)
Temperature shall not exceed 31.7 degrees Celsius (eighty-nine (89)
degrees Fahrenheit):
1.
The normal daily and seasonal temperature fluctuations that existed before
the addition of heat due to other than natural causes shall be maintained.
2.
The cabinet will determine allowable surface water temperatures on a site-
specific basis utilizing available data which shall be based on the effects of temperature on
the aquatic biota which utilize specific surface waters of the Commonwealth and which may
be affected by person-induced temperature changes. Effects on downstream uses will a1so
- .
be considered in determining site-specific temperatures.
As a guideline, the water
temperature for all surface waters shall comply with the limits shown in the following table:
~.
Period
Instantaneous
Average
Maximum
Month/Date
(OF)
(OF)
January 1-31 45 50
February 1-29 45 50
March 1-15 51 56
March 16-31 54- 59
April 1-15 58 64
April 16-30 64 69
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May 1-15 68 73
May 16-31 75 80
June 1-15 80 85
June 16-30 83 87
July 1-31 84 89
August 1-31 84 89
September 1-15 84 87
September 16-30 82 86
October 1-15 77 82
October 16-31 72 77
November 1-30 67 72
December 1-31 52 57
3.
A successful demonstration concerning thermal discharge limits carried out
under Section 316(a) of the Clean Water Act shall constitute compliance with the
temperature requirements of this subsection.
A successful demonstration assures the
protection and propagation of a balanced indigenous population of shellfish, fish and wildlife
in or on the water into which the discharge is made.
(e)
Dissolved oxygen:
1.
Dissolved oxygen shall be maintained at a minimum concentration of five
(5) mgll daily average; at no time shall the instantaneous minimum be less than four (4)
m g/l.
2.
The dissolved oxygen concentration shall be measured at mid-depth in
waters having a total depth of ten (10) feet or less and at representative depths in other
waters.
(0
Sol ids:
.
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1. Total dissolved solids: Total dissolved solids shall not be changed to the
extent that the Indigenous aquatic community is adversely affected.
2. Total suspended solids: Total suspended solids shall not be changed to the
extent that the indigenous aquatic community is adversely affected.
3. Settleable solids: The addition of settleable solids that may adversely
alter the stream bottom is prohibited.
(g) Ammonia: The concentration of the un-ionized form shall not be greater
than 0.05 mg/l at any time instream after mixing. Un-ionized ammonia shall be determined
from values for total ammonia-N, in mg/l, pH and temperature, by means of the following
equation:
Y = 1.2 (Total ammona-N)/U + 10?ka-PH]
pKa = 0.0902 + (2730/273.2+ Tc)
Where:
Tc = Temperature, degrees Celsius
Y = Un-ionized ammonia (mg/l)
(h) Toxics:
1. The allowable instream concentration of toxic substances or whole
effluents containing toxic substances which are noncumulative or nonpersistent (half-life of
less than ninety-six (96) hours) when not specified elsewhere in this section, shall not exceed
the No Observed Effect Level (NOEL) or 0.1 of the ninety-six (96) hour median lethal
concentration (LCSO) of a representative indigenous or indicator aquatic organism(s) or
exceed a chronic toxicity unit of one, whichever is more appropriate.
2. The allowable instream concentration of toxic substances or whole
effluents containing toxic substances which- are bioaccumulative or persistent, including
pesticides, when not specified elsewhere in this section, shall not exceed the NOEL or 0.01
of the ninety-six (96) hour median lethal concentration (LCSO) of a representative indigenous
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or indicator aquatic organism(s) or exceed a chronic toxicity unit of one, whichever is more
appropriate.
3.
In the absence of acute criteria for substances listed in Table 2 or for other
substances known to be toxic but not listed in this regulation, or for whole effluents which
are acutely toxic, the allowable concentration shall not exceed the LC 1 or 1/3 LC 50
concentration derived from bioassay tests on a representative indigenous or indicator
aquatic organism(s) or exceed 0.3 acute toxicity units, whichever is more appropriate.
4.
Where specific application factors have been determined for a toxic
substance or whole effluent such as an acute/chronic ratio or water effect ratio, they may
be used instead of the 0.1 and 0.01 factors listed in this subsection upon approval by the
cabinet.
5.
Allowable instream concentrations for specific substances (acute and
chronic criteria) are listed in Table 2. These concentrations are based on protecting aquatic
life from acute and chronic toxicity, and shall not be exceeded.
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Substance
Arsenic
Arsenic (III)
Beryllium
Cadmium (ug/l)
Chromium (III) (ug/l)
Chromium (VI)
Copper (ug/l)
Iron
Table 2
Warm water Aquatic Habitat Criterial
Acute Criteria
Metals
360 ug/l
e(l.128 [In Hard.) - 3.828)
e(O.8190 [In Hard] + 3.688)
16 ug/l
e(.9422[In Hard] - 1.464)
4.0 mgll
Chronic Criteria
50 ug/l
190 ug/l
11 ug/l soft water2
1100 ug/l hard water2
e(0.7852[1n Hard] - 3.490)
e(0.8190[ln Hard] + 1.561)
11 ug/l
e(.8545Un Hard] - 1.465)
1.0 mg/13
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Lead (ug/I)
e(1.213 [In Hard) - 1.460)
e( 1.213 [In Hard) - 4.705)
Mercury
2.4 ug/l
0.012 ug/l
Nickel (ug/I)
e(0.8460 [In Hard] + 3.3612)
e(0.8460 [In Hard) + 1.1645)
Selenium
20 ug/l
5 ug/l
Silver (ug/l)
e(1.12 [In Hard] - 6.52)
Zinc (ug/I)
e(0.8473 [In Hard] + 0.8604)
e(0.8413 [In Hard] + 0.7.1; H)
Organics
Aldrin
3.0 ug/l
Chlordane
2.4 ug/l
0.0043 ug/l
Chloropyrif os
0.083 ug/l
0.041 ug/l
DDT
1.1 ug/l
0.001 ug/l
Dieldrin
.2.5 ug/l
0.0019 ug/l
Endosulfan
0.22 ug/l
0.056 ug/l
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Endrin
0.18 ug/l
0.0023 ug/l
Heptachlor
0.52 ug/l
0.0038 ug/l
Lindane
2.0 ug/l
0.080 ug/l
Parathion
0.065 ug/l
0.013 ug/l
Pentachlorophenol (ug/l)
eO.005 [pH] - 4.830)
e(1.005 [pH] - 5.290)
Phthalate estel'S
3 ug/l
Polychlorinated Biphenyls (PCBs)
0.0014 ug/l
Toxaphene
0.73 ug/l
0.0002 ug/l
Othel'S
Chloride
1200 mg/l
600 mg/l
Chlorine, total residual
19 ug/l
10 ug/l
Cyan.ide, free
22 ug/l
5 ug/l
Hydrogen sulfide (undissociated)
2 ug/l
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1 Metal criteria, for purposes of this regulation, are total recoverable metals to be
measured in an unfiltered sample.
2 Soft water has an equivalent concentration of calcium carbonate (CaC03) of 0 to 75 mg/I.
and hard water has an equivalent concentration of calcium carbonate (CaC03) of over 75
mg/l.
3 The chronic criterion for total recoverable iron shall not excl!ed 3.5 mgll when it is
established that there will be no damage to aquatic life.
.Hard = Hardness as mgll CaCO 3
(2)
Coldwater aquatic habitat.
The following parameters and their associated
criteria are for the protection of productive coldwater aquatic communities and strea~"
which support trout populations (whether self-sustaining or reproducing) on a year-round
. .
basis. All of the criteria adopted for the protection of warm water aquatic life also apply to
the protection of coldwater habitats with the following additions:
(a)
Dissolved oxygen:
1.
A minimum concentration of six (6) mg/l as a daily average and five (5) mgll as
an instantaneous minimum shall be maintained at all times.
2.
In impoundments which support trout, the concentration of dissolved oxygen in
waters below the epilimnion shall be kept consistent with natural water quality.
(b)
Temperature. Water temperature shall not be increased through man's activities
above the natural seasonal temperatures.
Section 5. Domestic Water Supply Use. Maximum allowable instream concentrations
(Qr specific substances, to be applicable at the 'point of withdrawal, for use for domest ic
water supply from surface water sources are specified in Table 3 and shall not be exceeded.
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Table 3
Domestic Water Supply Source Criterial
Substances Not Linked to Cancer
Concentration
Metals
i
1-
Antimony
0.146
mg/l
mg/l
Barium
1
Cadmium
0.010
mg/l
Chromium
Chromium (III)
170
mg/l.
mg/l
0.050
Copper
1
mg/l
Lead. 0.05 mg/l
Manganese 0.05 mg/l
- Mercury 0.144 ug/l
Nickel 13.4 ug/l
Selenium 0.01 mg/l
Silver 0.05 mg/l
Thallium 0.013 mg/l
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1-
Organics
Acrolein 0.320 mg/l
Monochlorobenzene 0.488 mg/l
I-2-4-5-tetrachlorobenzene 0.038 mg/l
Pentachlorobenzene 0.074 mg/l
1,1, I-trichloroethane 18.4 mg/l
2,4,5 -trichlorophenol 2.6 mg/l
Bis (2-chloroisopropyl) ether 0.0347 mg/l
Dichlorobenzenes 0.400 mg/l
2,4-dichlorophenol 3.090 mgll
Dichioropropenes 0.087 mg/l
Endosulfan 0.074 mg/l
Endrin 0.001 mg/l
Ethylbenzene 1.4 mg/l,
Fluoranthene 0.042 mg/l
. Hexachlorocyclopentadiene 0.206 mg/l
Isophorone 5.2 mg/l
,Nitrobenzene 19.8 mg/l
2-4-dinitro-o-cresol 0.0134 mg/l
Dinitrophenol 0.070 mg/l
Pentachlorophenol 1.0 mg/l
Phenol 3.5 mg/l
Dibutyl phthalate 34 mg/l
Diethyl phthalate 350 mg/l
Di-2-ethylhexyl phthalate 15 mg/l
Dimethyl phthalate 313 mg/l
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1-
Asbestos (fibers/liter)
30,000
Benzene
0.66
Benzidine
0.00012
Carbon tetrachloride
0.40
Chlordane
0.00046
,
Hexachlorobenzene
0.00072
1,2-dichloroethane
0.94
1,I,2-trichloroethane
0.60
1,1,2,2,-tetrachloroethane
0.17
Hexachloroethane
1.9
2,4, 6-trichlorophe no I
1.2
bis(2-chloroethyl} ether
0.03
Chloroform
0.19
DDT
0.000024
.Dichlorobenzidine
0.01
1,1-dichloroethylene
0.033
,pieldrin .
0.000071
2,4-dinitrotoluene
0.11
Dioxin (2,,3,1,8-TCDD)
0.000000013
Diphenylhydrazine
0.042
Halomethanes
0.19
Heptachlor
0.00028
Hexachlorobutadiene
0.45
alpha. Hexachlorocyclohexane (HCH)
0.009
beta HCH
0.016
gamma HCH (Lindane)
0.019
Technical HCH
0.012
-------
N -nitrosodiethylam ine
N -nitrosodi methylamine
0.0008
0.0014
N -nitrosodibutylam ine
0.0064
N -nitrosodiphenylam ine
4.9
N-nitrosopyrrolidine
0.016
0.000019
Polychlorinated Biphenyls (PCBs)
Polynuclear Aromatic Hydrocarbons (PAHs)
0.0028
Tetrachloroethylene
0.8
Toxaphene
0.00011
Trichloroethylene
2.1
Vinyl Chloride
2.0
ISee note 1 in Table 2.
Section 6. Recreational Waters. (1) Primary contact recreation water. Primary
contact recreation waters are waters suitable for full body contact recreation during the
recreation season of May 1 through October 31. Criteria for primary contact recreat ion
waters are listed below:
(a)
Fecal coliform content shall not exceed 200 colonies per 100 ml as a
monthly geometric mean based on not less than five (5) samples per month; nor exceed 400
colonies per 100 ml In twenty (20) percent or more of aU samples taken during the month;
these limits are applicable during the recreation season. Fecal coliform criteria listed in
subsection 2(a) of this section apply during the remainder of the year.
(b)
-
pH shall be between 6.0 to 9.0 and shall not change more than one (1) pH
unit within this range over a period of twenty-four (24) hours.
(2)
Secondary contact recreation water. Secondary contact recreation waters
are waters suitable for partial body contact.recreation, with minimal threat to public health
-------
due to water quality. The following criteria apply to waters classified for secondary contact
recreation use during the entire year:
(a)
Fecal coliform content shall not exceed 1000 colonies per 100 ml as a
monthly geometric mean based on not less than five (5) samples per month; nor exceed 2000
colonies per 100 ml in twenty (20) percent or m'ore of all samples taken during the month.
(b)
pH shall be between 6.0 to 9.0 and shall not change more than one (1) pH
unit within this range over a period of twenty-four (24) hours.
I
I
I -
Section 7. Outstanding Resource Waters. This classification category incl~des
certain unique waters of the Commonwealth.
(1)
(a)
Water for inclusion:
Automatic inclusion. The following surface waters shall au~omatically be .
included in this category:
Waters designated under the Kentucky Wild Rivers Act, KRS 146.200 -
1.
146.360.
2.
Waters designated under the Federal Wild and Scenic River Act, 16 U.S.C.
1271 et seq. and high quality waters constituting an outstanding national
resource water.
3.
Waters identified under the Kentucky Nature Preserves Act, KRS 146.410-
146.530, which are contained within a formally dedicated nature preserve or are published in
the registry of natural areas and concurred upon by the cabinet.
Waters that support federally recognized endangered or threatened species
under the Endangered Species Act of 1973, as amended, 16 U.S.C. 1531 et seq.
4.
(b)
Other surface waters may be included in this
Permissible consideration.
category as determined by' the cabinet if:
1.
The surface waters flow through or are bounded by state or federal fores.t
land, or are of exceptional aesthetic or ecological value or are within the boundaries of
-------
national, state, or local government parks, or are a part of a unique geological or historical
area recognized by state or federal designation; or
2.
They are a component part of an undisturbed or relatively undisturbed
watershed that can provide basic scientific data and possess outstanding water quality
characteristics; or two (2) of the following criteria:
a.
Support a diverse or unique native aquatic flora or fauna.
b.
Possess physical or chemical characteristics that provide. an unusual and
uncommon aquatic habitat.
c.
Provide a unique aquatic environment within a physiographic region.
(2)
Outstanding resource waters protection:
The classification of certain
waters as outstanding resource waters shall fairly and fully reflect those aspects of the
waters for which the classification is proposed. The cabinet will determine water quality
criteria for these waters as follows:
(a)
At a minimum, the criteria of Section 2 and the appropriate criteria
associated with the stream use classification assignments in 401 KAR 5:026, are applicable
to these waters.
(b)
Where the values identified for an outstanding resource. water are
dependent upon or related to instream water quality, the cabinet will review existing water
quality criteria and determine whether additional criteria or more stringent criteria are
necessary for protection, and evaluate the need for the development of additional data upon
which to base the determination. Existing water quality and habitat shall be maintained and
protected in thOM waters designated as outstanding resource waters which support federally
threatened and endangered species of aquatic organisms, unless it can be demonstrated to
the satisfaction of the cabinet, that lowering of water quality or a habitat modification will
not have a harmful effect on the threatened or. endangered species which the water
supports.
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(c)
"Water quality shall be maintained and protected in waters which
constitute an outstanding national resource. The cabinet may approve temporary or short-
term changes in water guality if the changes to the waters in question have no demonstrable
impact on the ability of the waters to support this use."
(d)
Adoption of more protective criteria in accordance with this section will
be listed with the respective stream segment in 401 KAR 5:026, and will be promulgated as
an administrative regulation pursuant to KRS Chapter 13A.
Determination of classification:
(3)
(a)
Any person may present a proposal to class:fy certain waters under this
section. Documentation requirements in support of an outstanding resource water propo~al
shall contain those elements outlined in 401 KAR 5:026, Section 5 (1) through (8).
(b)
The cabinet will review the proposal and supporting docum'entation to .
determine whether the proposed waters qu.alify as outstanding resource water:; within the
criteria established by this regulation. The cabinet will document the determination to deny
or to propose reclassification, and a copy of the decision will be served upon the petitioner
and other interested parties.
(c)
After considering all of the pertinent data, a reclassification, if
'appropriate, will be made pursuant to 401 KAR 5:026.
Section 8. Water Quality Criteria for the Main Stem of the Ohio River. The
following criteria apply'to the main stem of the
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(2)
Temperature. (a) Allowable stream temperatures are:
Period
Instantaneous
Month/Date
Average (oP)
Maximum (oP)
January 1-31 45 50
February 1-29 45 50
March 1-15 51 56
_.
...;' 59
March 16-31 54
April 1-15 58 64
April 16-30 64 69
May 1-15 68 73
May 16-31 75 80
June 1-15 80 85
June 16-30 83 87
July 1-31 84 89
August 1:-31 84 89
September 1-15 84 87
September 16-30 82 86
October 1-15 77 82
October 16-31 72 77
November 1-30 67 72
December 1-31 52 57
(b)
. .
A successful demonstration .conducted for thermal discharge limits under
Section 316(a) of the Clean Water Act will constitute compliance with these temperature
criteria.
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(3)
Total dissolved solids: Not to exceed 500 mgll as a monthly average, nor
exceed 750 mgll at any time.
Equivalent 250C specific conductance values are 800 and
1,200 micromhoslcm respectively.
(4)
Maximum allowable instream concentrations for specific parameters are
given below. Metal concentrations are total recoverable values except hexavalent chrom iu m
which is dissolved.'
Parameter
Concentration (mg/l)
Arsenic .05
Barium 1.0
Chloride 250
Fluoride 1.0
Nitrite + Nitrate Nitrogen 10.0
Nitrite-Nitrogen 1.0
~henolics .005
Sulfate 250
Chronie Criteria
Aeute Criteria
Concentration
Concentrat ion
Parameter
ug/l
ug/l
Cadmium
e(.7852 (In Hard] - 3:490)
e(1.128 [In Hard] - 3.828
Chromium (hexavalent)
11
16
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Copper
e(.8545 [In Hard) - 1.465)
e(.9422 [In Hard) - 1.464)
Cyanide «(ree)
5
22
Lead
e(1.273 [In Hard] - 4.705)
e(1.273 [In Hard) - 1.460)
Mercury
.012
2.4
Zinc
e(.84 7 3 [In Hard] + .7614)
e(8473 [In Hard] + .8604)
(5)
The net discharge of aldrin, dieldrin, DDT, including DDD and DDE, endrin,
toxaphene, benzidine and PCBs is prohibited. .
Section 9. Exceptions to Criteria.
!-
;.
~. 5, 6, 7, and 8 upon demonstration by an applicant that maintenance of applicable water
(1)
The cabinet may grant exceptions to the criteria contained in Sections 2, 4.
quality criteria are not attainable Or scientifically valid but the use classification. is still
appropriate. This determination wi'U be made on a case-by-case basis with respect to a
specific surface water following an analysis (or each area.
(2)
The analysis shall show that the water quality criteria cannot be reasonably
. achieved either on a seasonal or year-round basis due to natural conditions, or site-specific
factors differing from the conditions used to d~rive Section 2, 4, 5, 6, 7, and 8 criteria, or a
demonstration that meeting the criteria would cause substantial and widespread econom ic
and social impact. Site-specific criteria shall'be developed by the applicant utilizing toxicity
tests, indicator organisms, and application factors that are consistent with those outlined in
"Water Quality Standards Handbook" (EPA, 1983). In addition, an applicant shall supply the
documentation listed in Section 5 of 401 KA R 5:026.
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(3) An exception to criteria listed in Section 2(2) for the protection of human
health from the consumption of fish tissue may be granted if it can be demonstrated that
natural, ephemeral, intermittent or low flow conditions or water levels preclude the year-
round support of a fishery, unless these conditions may be compensated for by the discharge
of sufficient volume of effluent discharges.
(4)
Before granting an exception to water quality criteria, the cabinet shall
ensure that the water quality standards of downstream waters are attained and maintained.
(5)
All exceptions to water quality criteria will be sUbject to review at least
every three years.
(6)
Upon completing a
review
and the procedures for promulgation of
administrative regulations pursuant to KRS Chapter 13A, exceptions to water quality
criteria will be listed with the respective surface water in 401 KAR 5:026.
Adopted May 31, 1990
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Record of Decision/Operable Unit .1
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
APPENDIX B
Comments from the Commonwealth of Kentucky
Regarding the Draft Record of Decision
-------
-",.. . III .. III WI.
, :. "" , r'm ,
I-I'\"",~I\'",I'\II 1\1-
4...4 ~47 :5~:;1 ,
CAllI&. H. IMDuv
IICM1MY
w.... I ...~ G. WLKIN80N
QO\t l1li NOlI
COMMONWiALTH OF KENTuCKY
NATURAL. RlaOURcu AND I!NVIRONMENTAL PROTICTION CABlNI!T
OEPARTMENT FOA ENVIRONMENTAL PROTECTION
F..ANK'O,", OPPICIi PARK
18 R!lLLY ROAO
FRANKFORT. KENTUCKY 40801 .
AUqu.t 28, 1991 .
Harold W. Taylor" Jr., Chief
Kantucky/Tanna..aa Ramedial Seotion
Nor~ Superfun~ Remedial Branch
Unite~ state. Environmental Protection
345 Courtland street, N.B.
Atlanta, Qaorqia 30355
Agancy
1U!: :
Dratt ~.cord ot Decision and Comment. on tha Propo.ed Plan
Tri-City rndu.trial Di.po.al Supertund Site, Operable unit #1
Brook., 8ullitt County, Kentucky
Daar Mr. Taylor:
-
Thank you tor ~. a~~1tional time to allow the Commonwealt.h of
Kantucky to adequately review the Draft Racord of Daci.ion (ROO)
for tha Tri-c!ty Sita, Operable Unit. #1. A. .tated previou.ly, wa
baliava that complete Characterization ot a .ita i. nece..ary
. betora a .ucca..tul .trateqy tor remediation can be plotted. Such
a characterization ha. not been done at. Tri-City. However, we
recognize the inherent 4ifficultia. ot the prooe.. an~ the
programmatic constraint. within which BPA mu.t operate. Ke~tucky
will con.ider the .ucce..tUl remediation of operable Unit 11 a. a
fir.t .tep in completa remediation ot tha ant ire .ite.
We qanerally concur with the remedial alternativa .elacted in
tha Faa.ibility StUdy 1. i.e., treatment of watar di.charqad trom the
Cox Sprinq by activatad carbon ad80rption. It i8 under.tood that
other .pring. .. well.a. qroundwater, .urtace water, ..diment and'
ecoloqy will oontinue to be monitor.~ and contirmatory .amplinq
will ba conducted to ...e.. the ettectivene.. of the e..rqency
re.oval aotion near tha Cox, Sr. ra.i~ence. EPA will proviCSa
pota~le water to ra.ident. who previoU.ly u.e4 the contaminated
spr1nq. and will eftect in.titutional controls over the u.e ot
contaminateCS w.tar .ourca..
To the extent that the 8a.elin. Ri.k A..e..mant may nee4 to be
moditied a. a r..ult o~ con~irmatory ...pling, ple..e con.id.r
relevant comment. diracted to you in our April 4, 1991 letter. A.
O Print8d on ~ ....
An Iquet ~ ~ M"JH
.-. --.... _._.~
-..-.-
--.-. . N_- .----- ... .
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~~" I Q I . i.J~1'" I rul'I CI'tV.
~I'IUIC:I.I.; tj-'d-:ll ; l::/IPM ;
FRAN~FORT, KY...
4~4 341 1695:; 3
Mr. Taylor
Page two
Au;U.t 28, 1991
you know, th. Ri.k A..e...ent Section of the Kentucky Divi.ion of
Environmental 'S.rvice. concluded ~at, due to deticiencie. in the
report which they r.vi.w.d, the cumulativ. lit.tim. ri.k could not
. be ..t.ablishecS. Th.y al.o concluded that the ecolo;ical a..a..ment
wa. not complat.. .nouqh to draw any conolu.ion.. Since the
8a.alin. Ri.k As....ment i8 a key compon.nt in ..ttinq rem.diation
: ;oal., 1t 1. imperative t.hat Xentucky and BPI., agr.e on the
. A.....ment '. validity. .'
Kentucky continue. to maintain that ERS 224.877 18 an
Applicable or aelevant an4 Appropriate Requirement (ARAR) which 1.
more 8tringent that fecieral requir..ent., a po.it.1on with which BPA
doe. not aqree. W. do aCJre., however, that it BPI. meet. the
criteria outlined in Section 10 of DS 224.877, it will have
complied wi1:h the requirement. of the statute. 1.9ain, the 8as.11n.
Ri.k As.e..ment. 1s important in ciet.rmin1nq compliance with Section
10 and th.retore mu.t be reliable.
W. have a.ked the Xentucky Division of Water Quality to
identity the .pecit1c criteria in 401 KAR 5:031 which are
applicable to the eite. This information will be forwarded to you
a. quickly a. we receive it.
Plea.. contact Rick Hogan or me at (502) 564-6716 if you have
any que.tion..
Sincerely,
~~.Jf-~tJ-"1
Carl Mill~~~~r
Uncontrolled Site. Branch
Divi.ion o~ wa.~e Manaq..ent
CM/RH/kb
CCI
Kim Oat.., O.S. SPA-Region IV
,,11e
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Record of Decision/Operable Unit '1
Tri-City Industrial Disposal Site
Brook., Bullitt County, Kentucky
APPENDIX C
Responsiveness Summary
i C
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I.
OVERVIEW
The Responsiveness Summary, as described' in the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP), is a
summary of ~ignificant comments, criticisms, and new relevant
information submitted during the public comment period for the
Proposeq Plan and the responses by the u.S. Environmental
Protection Agency (EPA) to each issue. This Responsiveness
Summary for the Tri-City Industrial Disposal Site in Brooks,
Kentucky includes the information described in the NCP and a
summary of the community invo:J.vement with the Site. . "
The Proposed Plan Fact Sheet for Operable unit #1, which
described EPA's preferred alternative for addressing the
contaminants found at the Tri-City Site, was distributed to
interested parties on April 19, 1991. The Proposed Plan Fact
Sheet summarized the Site's background information, the results
of the Remedial Investigation/Feasibility Study (RI/FS), and
EPA's preferred remedial alternative. The Proposed Plan Fact
Sheet is included as Attachment 1 to this document.
. EPA held a public comment period from May 2 through June 1,
1991 for interested parties to comment on the RI and FS Reports
and the Proposed Plan for Operable Unit #1 of the Site. All
comments received by EPA during the public comment period were
considered in the final selection of the remedial alternative
for Operable Unit #1. '
EPA held a public meeting on May 9, 1991 at 7 PM in the
library of the Bullitt Lick Middle School in Shepherdsville,
Kentucky to describe the Superfund process, to discuss the
results of the RI and the FS, and to present the proposed
remedial alternatives for addressing Operable Unit #1. The
proceedings of this meeting are documented in the official
transcript that is included as Attachment 2 of this
Responsiveness Summary.
This Responsiveness Summary is organized into the following
sections and attachments:
I.
OVERVIEW. This section describes the purpose of the
a..ponsiveness Summary and the events that preceded its
development.
II.
SUMMARY OF COMMUNITY INVOLVEMENT. This section
summarizes community interest in the Site, EPA's
co~unity relations activities, and key public concerns.
-1-
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i
I
III.
-2-
SUMMARY OF MAJOR VERBAL QUESTIONS AND COMMENTS RECEIVED
AND AGENCY RESPONSES. This section summarizes the
verbal comments received by EPA during the meeting with
local government officials on May 2, 1991 and the public
me~ting on May 2, 1991, and EPA's responses to those
comments.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES. This section references
the written comments received during the publ~c comment.
period and EPA's written responses to these comments.
: The letters containing these comments are included in
this document as Attachment 6.
IV.
ATTACHMENT 1:
ATTACHMENT 2:
ATTACHMENT 3:
ATTACHMENT 4:
ATTACHMENT 5:
ATTACHMENT 6:
ATTACHMENT 7:
The Proposed Plan Fact Sheet for Operable
Unit #1.
Transcript from the Public Meeting held
on May 9, 1991
Sign-In Sheets from meeting with local
officials and the Public Meeting, both
held on May 9, 1991
EPA Memorandum dated May 16, 1991
regarding the provision of public water
to site residents
Band-Out from the Public Meeting held on
May 9, 1991
Letter from EPA to Ms. Sue Bayes dated
August 26, 1991 in response to request
for sampling information
Written comments received during the
public comment period and EPA's responses
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-3-
II.
SUMMARY OF COMMUNITY INVOLVEMENT
A.
Background
The Tri-City Industrial Disposal Site was an industrial
waste land~ill knoWn to have been operated by Tri-City
Industrial Services, Inc. from late 1964 to late 1967. The Site
is located in northern Bullitt County, Kentucky approximately 15
miles south of Louisville, Kentucky in the community of Brooks.
Several families currently live on or adjacent to disposal areas
that were active during the landfill operations.
The Site was a source of local citizen complaints and
concerns to state and county government officials on numerous
occasions during the disposal operations. In 1965, residents
near the Site first complained to local officials about the
unkempt condition of the landfill, explosions, fires, and smoke
which was said to irritate eyes, make breathing difficult, and
have an offensive odor. Additionally, deposition of ash and
charred debris on neighboring properties led to a civil lawsuit
for creating a public nuisance. In September 1966, the Bullitt.
County Circuit Court judge issued a permanent injunction
prohibiting the burning of refuse at the Site. However, the
judge ruled that use of the property for refuse disposal did not
constitute a nuisance and was not unlawful.
In December 1966, the citizens of Brooks submitted a
petition to the Kentucky Division of Environmental Health (DEH)
to close the landfill. The Bullitt County Health Department,
County Attorney, and the Commonwealth of Kentucky Department of
Fish and wildlife Resources along with DEH (now the Department
of Health) investigated these complaints. The Kentucky DEH
respon4ed that no health laws were being violated. However,
since the court prohibited burning of refuse at the landfill, a
contempt of court charge was filed against Tri-City Service's
president, Mr. Harry Kletter, in May 1967.. In addition, two
Grand Jury indictments were also served to Tri-City Services and
to Mr. Kletter in March and November 1967. The first indictment
charged the owners and operators of the landfill with creating a
public nuisance. This indictment was later dismissed because of
insufficient evidence. The citizens of Brooks obtained the
second indictment against Tri-City Services, which resulted in
. th~ issuance of a warrant for the arrest of Mr. Kletter.
Following Mr. Kletter's arrest 'on the nuisance charge, a
settlement was arranged whereby the charges would be dropped if
Tri-City Services agreed to stop disposing of and burning waste
at the Site. The arrest coincided with the eruption of a fire
at the Site that burned for two years. Tri-City Services
reportedly ceased all waste disposal activity shortly after the
fire began.
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-4-
Several individuals living in the vicinity of the Site have
filed a private civil suit against Waste Management of Kentucky,
Inc., Ford Motor Company, and General Electric Company, Inc.
alleging damages resulting from contamination originating
on-site. . ~his action is apparently on-going.
B.
EPA's Community Relations Activities
EPA involvement with the Site commenced in September 1985
following notification by the Kentucky Natural Resources and
Environmental Protection Cabinet. To date, theEPA has
conducted the following community relations activities at the
Site:
- Issued a press release on May 24, 1988, in conjunction
with the state agency, to announce a residential water
sampling program;
- Established an information repository at the Ridgway
Memorial Library in Shepherdsville, Kentucky in May 1988
to make site-related information available to the public;
- Established communications
affected area to keep them
activities taking place at
September 1988;
- Conducted telephone interviews with citizens in the.
community during the period from April 7 to April 19, 1989
to gain an understanding of the community's perceptions of
the Site;
with the residents of the
informed of emergency removal
the Site in August and
- Conducted community interviews during a Site visit held
April 11 through April 13, 1989;
Published a Community Relations Plan in May 1989 to
present an overview of community concerns and provide the
basis for determining the ~ppropriate community relations
activities to support the RI/FS activities to be conducted
at the Site; .
- Issued' a press release on May 25, 1989 to announce an
availability session and an informal presentation to
discuss activities at the Site and describe the sampling
to be conducted during the Remedial Investigation;
- Issued a fact sheet in May 1989 to briefly describe the
Site, the nature of the RI/FS, the community relations
activities during the RI/FS, and future activities to be
conducted by EPA at the Site;
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-5-
- Conducted an availability session and informational
meeting on June 1, 1989 at the Bullitt Lick Middle School
in Shepherdsville, Kentucky to discuss the RIfFS'
activities with concerned citizens and local officials;
- Updated the mailing list in March 1991;
- Conducted telephone interviews of several on-site
residents to identify any new community concerns;
- Issued a fact sheet in April 1991 to describe the results
of the RIfFS and present EPA's preferred alternative for
addressing Operable Unit '1;
- Issued a public notice on April 29, 1991 to announce the
Proposed Plan public meeting;
- Conducted a 30-day public comment period from May 2
through June 1, 1991 for the community to express concerns
regarding the EPA's Proposed Plan for Operable unit #1;
- Released the Administrative Record on May 2, 1991 for
public review at the Ridgway Memorial Library and the
EPA-Region IV Library;
.
- Met.with locally elected government officials on May 9,
1991: at 10 AM to discuss site-related concerns; and
- Conducted a public meeting
Bullitt Lick Middle School
present the results of the
alternative for addressing
on May 9, 1991 at 7 PM at the
in Shepherdsville, Kentucky to
RIfFS and EPA's preferred
Operable Unit #1 at the Site.
C.
Community Concerns
The following concerns pertaining to the Tri-City Site were
identified by local citizens during the telephone interviews and
the interviews during the site visit in April 1989.
- Water Contamination
The majority of residents in the area appeared to be using
cistern systems, although several residents used wells and
springs for potable water. Residents living along Brushy
Fork Creek were concerned that the water might contain
contaminants from the Site. Some residents were concerned
about children' playing in tbe creek or how their livestock
may be affected by potentially contaminated water.
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-6-
Health Concerns
In general, the residents living near the Site were
concerned about their health and the safety of their
livestock and the environment in which they live.
Resiaents were interested in receiving information, as it
became available, on the actual hazards associated with
the Site and how these hazards will affect their health
and well-being. The health problems at the time were
perceived as being caused by previous exposures to
contaminants from the Site.
Enforcement' Efforts
Awareness of the costs estimated to cleanup the Smith's
Farm Site prompted the desire to identify the parties
responsible for the contamination at the Tri-City Site.
Concerned citizens with information about other dump sites
or active dumping activities which may not be under
appropriate controls were not sure to whom their concerns
should be addressed.
.;
The north central Bullitt County community has participated
in three federal Superfund sites: The A.L. Taylor Site (which
is better known as the Valley of the Drums), the Smith's Farm
Site, and the Tri-City Site. Residents have indicated an
overall concern regarding dumping practices in their county.
Many residents complained about random and varied dumping
locations along steep ravines in the area and expressed concerns
about well water contamination. The rough geography and sparse
population has apparently made the area attractive to "midnight
dumping."
The Tri-City Site, from the perspective of local, county,
and state officials, did not seem to be as significant a source
of concerns as the Smith's Farm Site. In interviews conducted
for the development of the Community Relations Plan, the
overwhelming majority of the state and local officials stated
that they had not received complaints related to the Tri-City
Site.
EPA conducted telephone interviews with several on-site
. residents in April 1991 to identify any new community concerns
and to inform them of the upcoming public meeting. The primary
concerns voiced by the residents involved the contaminated
springs that had been used as sources of potable water, the lack
of a public water supply, and the disruption caused by the
Emergency Removal Action conducted by EPA in August and
September 1988.
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-7-
III.
SUMMARY OF MAJOR VERBAL OUESTIONS AND COMMENTS RECEIVED
AND AGENCY RESPONSES
Representatives from EPA met with locally elected government
officials at the Bullitt County Health Department in
Shepherdsville, Kentucky on May 9, 1991 before the public
meeting. The sign-in sheet for this meeting is included in
Attachment 3. The purpose of the meeting was to discuss
site-related concerns. The following comments and concerns were
raised during the meeting.
1. c When were samples last collected at the Site? When will
the confirmatory sampling included in the proposed
remedial 'alternative be conducted?
EPA Response: EPA's contractor, Ebasco Services, Inc.,
collected surface water, sediment, and surface soil
samples during Phase I of the Remedial Investigation in
July 1989. Phase II of the Remedial Investigation was
conducted from September to November 1989 and the
'sampling activities included the collection of
subsurface soil, groundwater, and air samples. EPA's
Environmental Services Division conducted additional
sampling of the Cox, Klapper, and Cattle Springs, and
monitoring well MW-12, in December 1990 to verify the
sampling conducted during the Remedial Investigation.
The confirmatory sampling of site soils, sediment, and
air that is included in the proposed remedy is
anticipated to be conducted during the Remedial Design
phase. EPA expects to implement the Remedial Design in
six months to one year after the Record of Decision is
signed by the Regional Administrator.
If additional contamination is found during the,
confirmatory sampling, will the remedy be changed?
2.
EPA Response: The purpose of the confirmatory sampling
is to identify any additional contamination. The
confirmatory sampling and the evaluation of the risk to
human health or the environment from any identified
contamination have been included in Operable Unit 11 for
the Tri-City Site. The measures necessary to mitigate
any threat to human health or the environment will be
implemented in Operable Unit 12. Consequently, the
remedy for Operable Unit '1 will remain the same, but
the results of the confirmatory sampling will determine
th~ actions included in Operable Unit 12.
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-8-
3.
Bow many homes are being provided with potable water?
Will the provision of potable water continue for 30
years?
4.
EPA Response: Three residences, the two Klapper homes
ana the Cox, Sr. residence, have been provided with
potable water by EPA since May 1988 due to the volatile
organic contamination in the Cox and Klapper Springs.
The remedy for Operable Unit #1 includes the continued
provision of potable water to these residences until EPA
determines, through long-term monitoring, that the
groundwater is of sufficient and consistent quality for
human consumption. .
Are the families affected by the contaminated springs
currently in any danger?
s.
EPA Response: No." EPA is providing the affected
residents with potable water so that domestic usage of
the contaminated springs is not necessary. In addition,
"the proposed remedy will include institutional controls
to restrict the potable usage of any groundwater
(including the locations where the groundwater.
discharges to the surface as springs) containing, or
potentially containing, levels of contamination in
excess of the Maximum Contaminant Levels established by
the Safe Drinking Water Act. The restrictions may
include local ordinances, conservation or restrictive
easements, record notice, or some other appropriate
measure. Restrictions will be placed on the Cox Spring,
the Klapper Spring, the Cattle Spring, the Brading
Spring 11, and the unnamed spring, and on the
installation and use of groundwater wells.
Are Superfund monies, or other federal funds, available
for the installation of public water lines to the
residents on and in the area of the Tri-City Site?
EPA Response: This concern was also raised by one of
the site residents during the telephone interviews
conducted in April 1991. Based on EPA's research
following the telephone interview, it was determined
that the installation of water lines to the site
residents would cost approximately $1.5 million. The
provision of potable water to the three residents
affected by the contaminated springs costs approximately
$2,420 annually. It is anticipated that the continued
provision of potable water to these residents will be
necessary for at least ten more years, resulting in an
estimated total expenditure for the provision of
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-9-
potable water of $31,460. Consequently, it is not
cost-effective for EPA to fund the installation of the
public water line. Moreover, it is apparently
appropriate to only use Superfund monies for the
res~dents affected by the contaminated sources of
drinking water. No other federal funds were identified
as being available for the installation of public water
lines. The results of EPA's research are documented in
the memorandum dated May 15, 1991 from Ms. Kimberly
Gates, Remedial Project Manager, to Mr. Harold Taylor,
Kentucky/Tennessee Remedial Section Chief, included as
Attachment 4.
6.
How close is the Tri-City Site to the Smith's Farm Site,
which is also located in Bullitt County? Is it possible
for contamination from the Smith's Farm Site to affect
the Tri-City Site or vice versa?
EPA Response: The two sites are approximately two miles
apart and they are topographically separated by hills
"and valleys. . Based on available information about the
two sites, it is not believed to be possible for either
site to affect the other.
7.
Have all the drums on the Tri-City Site been excavated?
EPA Response: Geophysical surveys of the Site were
conducted prior to the initiation of the Emergency
Removal Action in August 1988. In addition to -
identifying the area of drum disposal in the side yard
of the Cox, Sr. residence, the results of the"
geophysical surveys were used to aid in determining
additional trenching locations in the former landfill
area. The trenching revealed that many of the
geophysical anomalies were isulation and wire. A
limited number of empty drums and drums containing
solids were excavated and staged, but no additional
liquids were located. The primary drum disposal
location is believed to have been the side yard of the
Cox, Sr. residence where 165 drums containing liquid
va.tes were excavated. It is believed that all drums
containing hazardous materials have been removed from
the Tri-City Site. "
8.
Have any wildlife studies been conducted at the Tri-City
Site?
EPA Response: EPA's Remedial Investigation included an
aquatic survey of Brushy Fork Creek. In addition, an
ecological reconnaissance of the Site was conducted by
EPA and the u.S. Fish' Wildlife Service in August
1990. As a result of these studies, it has been
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-10-
9.
determined that Brushy Fork Creek is apparently a
healthy stream supporting ,diverse communities of fish
and insects. An ecological contaminant monitoring
program has been included in the proposed remedy to
determine if the Site is causing any short-term or
lonq-term impacts to the environment. If any
site-related ecological degradation is occurring, the
measures necessary to mitigate the threat to the
environment will be implemented in Oper~le unit 12.
Explain the ,"State Acceptance" criterion for the
assessment of the preferred remedial alternative. If
the Commonwealth of Kentucky does not agree with EPA's
proposed remedy and provide the 10% cost share, will
anything get accomplished at the Site?
EPA Response: State acceptance indicates whether or
not, based on its review of the Remedial Investigation
and Feasibility Study Reports, and the Proposed Plan,
the Commonwealth of Kentucky concurs with, opposes, or
has no comment on EPA's preferred alternative. .
Following signature of the Record of Decision, EPA will
send Special Notice Letters to the Potentially
Responsible Parties (PRPs) giving them the opportunity
to perform the work involved in the selected remedy. If
the PRPs decline to perform the work, EPA has the option
of issuing a Unilateral Adminstrative Order to order the
PRPs to perform the work described in the Record of
Decision or EPA can perform the work using the monies
provided by the Superfund trust fund. The 10% cost
share from the Commonwealth of Kentucky would be
necessary for EPA to perform the work. If the
Commonwealth does not concur with the selected remedy,
~we can only assume that they would not agree to the 10%
cost share. If that were to happen and we were not
successful negotiating with the PRPs to perform the
work, it is possible that no remedy would be implemented
at the Site. However, EPA is optimistic that use of the
Agency's various enforcement tools will encourage the'
PRPs to perform the needed Remedial Design and Remedial
Action.
The comments voiced during the Proposed Plan pUblic meeting
he~d on May 9, 1991 for the Tri-City Site and EPA's responses
are summarized below by subject. The proceedings of this
meeting are documented in the official transcript that is
included as Attachment 2 of this Responsiveness Summary. The
sign-in sheets for the meeting are included in Attachment 3. A
copy of the hand-out that was prepared for the meeting is
included in Attachment S.
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A.
-11-
The rmpact and Hazards from the Site
1.
What are the health hazards from the Site to future
generations?
2.
-
EPA Response: Based on the Baseline ~isk Assessment
that was conducted as part of the Remedial
Investigation, EPA has identified potential health
hazards associated with the ingestion of contaminated
groundwater. Since potable water is being provided to
affected residents, contaminated groundwater does not
present a.current health. hazard. EPA also identified
the site soils as a potential human health hazard if
cattle are grazed and gardens are grown in soils
containing a widespread level of contamination as was
found in the one surface soil sample collected from the
edge of the former landfill area. Confirmatory sampling
is included in the proposed remedy to determine if the
contamination is widespread.
.What are the hazards associated with waste materials
remaining on-site?
EPA Response: As part of the Emergency Removal Action
that was conducted by EPA in 1988, areas of the Site
that showed anomalies during the geophysical
investigations were trenched. The operators of the
backhoes primarily found fiberglass insulation, ash,
wood, empty drums, and nonhazardous garbage.
Consequently, based on the trenching and the sampling
that has been conducted, additional excavations do not
appear to be necessary because the hazardous materials
have been removed. . .
3.
What is the downstream impact of the contamination in
the springs?
EPA Response: Based on the sampling conducted during
the Remedial Investigation, Brushy Fork Creek has
apparently not been adversely impacted by the Site.
4.
18 it possible for site-related contamination to migrate
to a drinking water well located at the foot of Brooks
Hill (i.e., four miles away)?
BPA Response: Based on the available information about
the hydrogeology and topography of the Site and the
surrounding area, there is apparently no regional
movement of groundwater away from the Site. The
geologic formations immediately underneath the Site
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-12-
appear to be the only ones affected, and the
contaminated groundwater has been discharging to the
surface as springs instead of migrating into deeper
formations. The deeper wells installed during the
Rem~dial Investigation were not impacted by the Site.
Moreover, based on the topography of the area, the only
wells that could be impacted would be wells screened in
the formations immediately under the Site.
Could PCB contamination from the Site have migrated to
Brushy Fork Creek and then downstream to Knob Creek?
5.
BPA Response: One species of PCB, Aroclor 1260, was
detected at a level of 490 parts per billion in one
surface soil sample collected from the eastern edge of
the landfill during the Remedial Investigation. This
detected level is less than half of one part per
million. BPA's clean-up level for PCBs in a residential
area is one-half to one part per million. PCBs were not
,detected in any other samples collected during the RI,
including the surface water and sediment samples
collected from Brushy Fork Creek. If the PCB
contamination had been widespread, we would have found
PCBs in the other samples and there probably would have
been a noticeable impact to the environment. Moreover,
PCBs do not tend to migrate so we would not expect to
see downstream PCB contamination. .
6.
If sampling at the Site had been conducted fifteen years
ago, would the detected levels of contaminants have been
higher?
BPA Response: It is not possible to answer this
question without data from sampling. However, if
volatile organic compounds (e.g., from solvents) had
contaminated surface soils fifteen years ago, these
compounds would probably have volatilized into the air
or have migrated to the subsurface. In the case of the
groundwater, there are too many variables (i.e., the
rat. of water movement, the rate of contaminant
8igration into and within the water, the rates of
natural contaminant degradation and flushing, etc.) to
.peculate on whether contaminant levels have been higher
in the past.
The Waste at the Site
1.
What was in the drums that'were excavated during the
emergency removal in 1988 and how deep was the
excavation? Did BPA dig down to uncontaminated soil?
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C.
-13-
BPA Response: The drummed materials included silicon
and paint wastes, and the analyses revealed heavy metals
and semi-volatile organic compounds. Additional
information is included in the Emergency Response Action
Fi~al Report which is available for review in the
Administrative Record at the Ridgway Memorial Library in
Shepherdsville, Kentucky. According to this report, a
variety of hazardous substances were detected in the
analyses and the following waste streams were
classified: organic liquids, aqueous liquids, PCB
liquids, PCB solids, organic solids, and nonhazardous
soil and debris. Th& hazardous compounds that. were .
identified included tetrachloroethene, toluene, ethyl
benzene, xylene, PCBs, and lead. The trench that was
excavated to remove the drums from the side yard at the
Cox, Sr. residence was 'approximately thirty feet long by
twelve to fifteen feet wide by ten feet deep. Samples
were collected from the soil following removal to
determine if the soil was hazardous. Confirmatory
. sampling in the area of the removal trench has been
included in the proposed remedy to determine if all of
the contaminated soil was removed.
The Contaminated Springs and the provision of Potable Water
1.
How long will it take until the water in the Cox Spring
is safe to drink?
2.
EPA Response: If the primary source of contamination.
was removed by the Emergency Removal Action, it is
anticipated that any residual contamination in the
limestone and rock underlying the Site would be flushed
out through the springs within ten years. Groundwater
treatment will continue until the contaminant levels in
the groundwater (as it discharges to the surface)
decrease to within drinking water standards (i.e.,
Maximum Contaminant Levels and non-zero Maximum
Contaminant Level Goals).
Since BPA's primary concern at the Site is the
contaminated groundwater, why hasn't the installation of
public water lines been considered as a possible
alternative? For the cost of the proposed remedy (i.e.,
$2 million), thirty-five to forty miles of water line
could be run throughout the area.
BPA Response: A significant portion of the cost of the
remedy is for the additional sampling, the long-term
monitoring, and the treatment of the Cox Spring. The
total cost of providing potable water to the residences
affected by the groundwater contamination is .
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-14-
approximately $2,420 annually, or an estimated $24,200
over the anticipated ten-year p~riod. And, as
previously discussed in this Responsiveness Summary, no
other federal funds were identified as being available
for the installation of public water lines. EPA would
have considered using Superfund monies for public water
to the affected residents if this alternative had been
cost-effective.
D.
Additional Sampling to be Conducted
1.
:How long will the additional sampling take?
EPA Response: EPA expects that the confirmatory
sampling could take up to one year to complete after
initiation. The long-term monitoring could be performed
for up to thirty years. The time period for monitoring
the springs will depend on how quickly the contaminant
levels decrease. The monitoring will continue until EPA
determines that the water is of sufficient and
consistent quality for human consumption.
2.
will another public hearing be conducted after the
additional sampling is completed to inform the community
about the results?
E.
EPA Response: If the confirmatory sampling reveals
unacceptable levels of hazardous contaminants, the
additional measures necessary to mitigate any threat to
human health or the environment will be implemented as
Operable unit #2. Consequently, we would conduct
another public comment period and public meeting to
inform the community and solicit comments on the
proposed remedial alternatives.
EPA's Involvement with the Site
1.
How long has EPA known about the contaminated springs at
the Site?
SPA Response: EPA was notified about one of the
contaminated springs, the Klapper Spring, by the
Commonwealth of Kentucky in 1988. EPA conducted
additional sampling in May 1988 to confirm the
contamination. EPA also identified another contaminated
spring that was being used for drinking water. EPA then
began providing potable water to the people that had
been using the two springs as sources of drinking
water. EPA also conducted an Emergency Removal Action
in 1988 to remove drums of liquid waste from the Cox,
Sr. property.
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I -
i
I
-
F.
-15-
2.
What brought the Site to EPA's or the state's attention?
BPA Response: EPA was initially notified about the Site
in 1985 by the Commonwealth of Kentucky. The actual
si~e discovery probably resulted from several different
lists of disposal sites~ One list, the "Eckhart List",
was created in 1979 as a result of a requirement that
the fifty major chemical companies in the united States
report all of their disposal sites in the country to
EPA. At the same time, EPA was maintaining a list of
potential hazardous waste sites based on information
from the states. The Tri-City Site could have been on
one of these lists, or the attention could have resulted
from a past complaint.
3.
will EPA, as a government agency, remain in existence
for the time period it will take to implement the
remedy?
..EPA Response: Whether or not EPA will be in existence
to enforce the long-term monitoring for up to thirty.
years will depend on Congress. Since we generally rely
on the states after the first year of the remedy, the
question is really whether or not the Commonwealth of
Kentucky will be there. .
State 'Involvement with the Site
1.
How long were on-site residents still drinking
contaminated water after the sampling was conducted by
the Commonwealth of Kentucky in 1987?
Response from the Commonwealth of Kentucky: We have no
excuses to justify not acting on the sampling results
that indicated that the Klapper Spring was contaminated
and being used for potable water. The lapse from 1987
to 1988 was an oversight and there were serious
repercussions as a result. .
2.
What would be necessary for the Commonwealth to concur
with BPA's proposed remedy?
Response from the Commonwealth of Kentucky: The
Commonwealth generally requires cleanup to a more
stringent level than EPA and there is a difference of
opinion regarding how that is handled. This
disagreement is state-wide, and not specific to the
Tri-City Site. Moreover, the Commonwealth believes that
the Site has not been adequately characterized and that
it is inappropriate to select a remedy at this time. .
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,
I
-16-
3.
Is state funding available for the installation of
public water lines in the area of the Site?
Response from the Commonwealth of Kentucky: Our primary
concern is removal of the people from the effects of
contamination. We feel that they have been removed
since they are no longer drinking contaminated water.
It would not benefit the Commonwealth in general to run
the water line.
During the public meeting, a resident who lives adjacent to
-the former disposal area asked about the analytical results from
the sampling conducted on her property during the Remedial
Investigation. EPA responded in writing to this request for
information, and a copy of the letter is included in Attachment
6. -
IV.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
The comments received by EPA during the public comment
period held from May 2, 1991 through June 1, 1991 and the
Agency's responses are contained in Attachment 7. Comments were
received from two of the Potentially Responsible Parties, Waste
Management of Kentucky, Inc. and Ford Motor Company, and from
the Kentucky Resources Council.
-------
Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 1
Proposed Plan Fact Sheet for Operable unit #1
..
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Proposed Plan
Fact Sheet
Tri-City Industrial Disposal Site
Operable Unit One
Brooks, Kentucky
ft EPA
. -
Region IV
April 1991
INTRODUCTION
The U.S. Environmental Protection Agency (EPA), in
Cooperation with the Commonwealth of Kentucky,
recendy completed a Remedial Investigation (RI) to
identify and characterize the nature and extent of
contamination at the Tri-City Industrial Disposal Site
(the .Site.) in Brooks, Bulliu County, Kentucky. At
the coaclusion of the RI, a Feasibility Study (FS) was
condu.cteci to evaluate cleanup alternatives that address
contamination problems identified at the Site during the
. RI and other investigations. The results of the
investigation at the Site are discussed in the RI Report.
Details of the alternatives evaluation are presented in
the FS Report. Both reports are available for public
review locally at the information repository located at
the Ridgway Memorial Library on Walnut Street in
Shepherdsville, Kentucky (see . Additional Public
Information. on the back page).
-
This fact sheet presents EPA's preferred cleanup
alternative, known as a Proposed Plan, for addressing
;JtOundwater contamination problems at the Tri-City
Site. It also includes information on how interested
members of the community can participate in EPA's
selection process by submitting comments on the
alternatives presented in the Proposed Plan. Section
117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980,
as arnfl!Uded by the Superfund Amendments and
Reauthorization Act (SARA) of 1986, requires that
EP A publish Proposed Plans for addressing
contaminAtion problems at Superfund sites and provide
the public with an opportunity to comment on the
proposed course of action. EPA's Regional
Administrator and the Commonwealth of Kentucky will
consider public comments as part o( the final
decision-making process for selecting the cleanup
remedy for the Site.
This Proposed Plan:
1. Includes a brief bistory of the Site and the
principal findiniS of site investigations;
2.
Presents the alternatives for the Site considered
by EP A;
Oudines the criteria used by EP A to .
recommend an alternative for use at the Site;
Provides a summary of the analysis of
alternatives;
Presents EPA's rationale for its preliminary
selection of the preferred alternative; and
Explains the opportunities for the public to
comment on the remedial alternatives.
3.
4.
s.
6.
BACKGROUND INFORMATION
The Tri-City Industrial Disposal Site wu an industrial
waste landfill known to have been operated by Tri-City
Industrial Services, Inc. (the .Company.) from late
1964 to late 1967. The Site, as shown in Figure I, is
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located in northern Bullitt County, Kentudcy,
approximately 15 miles lOuth of Louisville, KentUCky,
in die colDlllUDity of Brooks. The Site CODSists of an
~pt"" 57 acres to,ether with aDY real property to
which bazatdous coDStitueDts have mipated including,
but DOl limited to, the Cox aDd Klapper Sprinls. The
Site is 10caJed on the IOUth side of State Highway 1526
(Brooks Hill R.oad) on Klapper Road, approximately
four miles west of U.S. IDtastate 65 aDd five miles
northwest of Shepberdsville, KentUCky.
Situated on . broad ridle kDowD as the Begbtol Ridge,
ihe Site slopes moderately to the south. The southern
'boUDdary aDd portions of the western aDd eastern
boundaries drop into steep, vegetated ravines. All
surface draiDage ultimately flows south. where it enters
Brushy Fort Creek, an intermittent stream that forms a
confluence with Knob Creek approximately one and a
half miles west of the Site. The majority of the Site is
covered with J1"8SS and a few trees. A site map is
provided in Fipre 2.
I
I
Site ownership is c:urreDtly divided between Mr. and
Mrs. William Dawson .Cox, Sr., Mr. William Dawson
Cox, Ir., aDd Mr. aDd Mrs. Wenfrey C. Hoosier.
These families, Mr. O. E. Ball, Mr. aDd Mrs. Roger
Klapper, aDd Mrs. Loretta Klapper currently live on or
adjlCeDt to former disposal areas on the Site.
FIGURE 2
Tri-City Industrial
Disposal Site
Study Area
EL eoo Ft.
The Site was a source of local citizen complaints and
concerns to State aDd County officials on numerous
occasions durinl the disposal operations. ID 1965,
residents near the Site first complained to local
officials reprdinl the unkempt conditiOD of the
IandfiJ,l, explosions and fires, and smoke which was
said to irritate eyes, make breathiDl difficult, aDd have
aD offensive odor. AddibGmaUy, deposition of ash aDd
charred debris on neighboring properties led to a civil
lawsuit for creating a public nuisauce. The Bullitt
County Health Departmeat, County Attorney, aDd the
Commonwealth of Kentucky Departmeat of Fish aDd
Wildlife Resources (Division of Fisheries) aIoDI with
the Department of Health (then the Division of
~vironmenta1 Health) investigated these complaints.
An indictmeDt, served to Tri-City Industrial Services,
IDc. and others in November 1967, resulted in the
arrest of the Company's president, Mr. Harry KIetter,
on the nuisance charse. After Mr. lOetter's arrest, a
settlement was ne,otiated whereby the charges would
be dropped if the Company aped to stop disposing of
aDd bumiD, waste at the Site. At about the same time
as the arrest, a fire erupted on the Site that burned for
two years. The Company reportedly ceased all waste .
disposal activity shortly after the fire bepn.
EP A involvement with the Site commenced in
September 1985 foUowiDl notification by the KentUCky
~
LEGEND
. RESIDENCE
... SPRI:oiG
X ELEVATION dOVE MSL
9 FO.~E. T1U-CrT'Y
DISPOSA1. AR£A
o 830 FI.
. ,
SCALf IN FEET
2
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,Natural Resources and Environmental Protection
Cabinet (&he .Cabinet.). The Cabinet conducted a Site
Investigation (S1) at the Site in April 1987 to determine
its eliaibility for inclusion on EPA's National Priorities
List (NPL), which is a federal roster of &he Dation's
- hazardous waste sites eliaible for investigation and
cleanup under &he Superfund program.
t- The Cabinet's SI report revealed a number of heavy
, metals and organic contAminAnts in on-site soil samples
and the presence of tetrachloroethene (also known as
perchloroe&hylene, or PCE) in nearby springs,
including two used for potable water by nearby
- residents. This finding prompted EP A to provide an
,alteruate water supply to several residences in &he area,
- an aCtion which is ongoing. - In addition. the springs
used for potable water, along wi&h a number of
additioaal springs in &he area, were &hen sampled by
EP A. This resampling of springs confirmed the
presence of PCE in &he previously sampled potable
water sources.
The Site received further attention when waste material
was observed to be seeping out onto Mr. Cox's lawn,
which prompted EP A to conduct an Emergency
Removal Action in this area during the Summer of
1988. This activity resulted in &he excavation and
removal of approximately 165 drums (full or partially
full), 400 gallons of free liquids, and 1000 cubic yards
of soil and debris. Hazardous materials identified
during the removal included PCE, toluene, ethyl
benzene, xylene, polychlorinated biphenyls (PCBs),
and lead. The cost of this action was approximately
$736,000 and it was totally funded by &he federal trust
. fund known as . Superfund. .
The majority of &he materials reportedly disposed of at
&he Site were industrial in origin from several
Louisville, Kentucky-based industries. The bulk of the
waste consisted of wood and fiberglass insulation
material. The remaining wastes consisted of drummed
residues and the liquid contents of drums that were
poured onto the ground at the Site.
Based on the data from the Cabinet's SI report, EPA
evaluated the hazards at the Site using the Mitre
Hazard Ranking System (HRS). This system uses
scores from 0 to 100 to indicate the probability and
magnitude of harm to public health and the
environment. Any site with a score of 28.50 or higher
is eligible for inclusion on. the NPL, which pwkes
federal Superfund monies available for investigating
and cleaning up the site, IS necessary. As I result of
- this evaluation, &he Tri-City Site received a HRS score
of 33.82, based primarily on the potential hazard from
contaminated groundwater (namely the springs), and it
was included on the NPL on March 31, 1989.
EP A began the first phase of a long-term two-part
comprehemive study of contaminAtion at the Site,
called a Remedial Investigation, in 1uly 1989. The
investigation wu completed in August 1990. EPA
conducted additional samplina of several springs,
including the Cox and Klapper Sprinas, and one
monitoring well in December 1990 to verify sampling
conducted during the RI. The second phase of the
study at the Site, the Feasibility Study, has been
conducted to develop remedial alternatives for
addressing the Site's known contamination problems.
As with the earlier removal action, the RI and the FS
were entirely funded by the federal Superfund trust
fund.
RESULTS OF THE REMEDIAL INVESTIGATION
EPA's Remedial Investigation of the Tri-City Industrial
Disposal Site focused on identifying the nature and
extent of contamination in disposal areas outside the
area where the Emergency Removal Action was
conducted. The RI included the sampling of
groundwater, surface water, sediments, soils, and
ambient air. During the RI, six groundwater
monitoring weUs were installed and sampled. The
installation of seven other wells Was attempted, but not
completed because of insufficient groundwater. Four
springs were sampled, and six surface water samples
were taken from Brushy Fork Creek and the two
tributaries that discharge to the creek. Twelve
sediment samples were coUected in the areas of the
springs and Brushy Fork Creek. Twenty surface soils
samples and 2S subsurface soil samples were collected.
And, 16 air samples were collected at three locations
that were selected based on prevailing wind directions
and &he locations of residents. A detailed discussion of
the RI results can be found in the RI Report available
at the site information repository.
Of particular concem to EP A was contamination found
in the Cox Spring. One sample and its duplicate
collected from the Cox Spring were found to contain
volatile organic compounds (VOCs), including PCE, at
levels which exceeded federally established Maximum
Contamin:ant Levels (MCLs). Several of &he same
contaminants were found at similar levels in a sample
from the Cox Spri1ia collected by EP A in December
1990. PCE was also found in the monitoring well next
to the Cox, Sr. residence during the RI.
Volatile orpnic compounds were not found in the
- o&her springs sampled during the RI. However, small
quantities of VOCs were found in samples collected -by
EPA from the Klapper Spring and the Cattle Spring in
'December 1990. Although the contaminAnt levels did
not exceed MCu, additional monitoring is warranted
to determine if future levels will require action.
3
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. Low levels of polycyclic aromatic hydrocarbons
(PAHs) and PCBs were found in surface soil samples
on-site durin, the RI. However, additional sampling is
~ry to determine the extent, if any, of
coataminAtion. Moreover, PCE was detected in low
CODC:a1trations in tWo air samples when the wind was
blowin, up the slopes of the Cox Lobe.
Lead was detected in one sediment sample in a
tributary of Brushy Fork Creek. However, additional
samplin, is necessary to determine the extent of any
. lead contamination in the sediment.
EP A conducted a joint ecological assessment of the
Site with the U.S. Fish &. Wildlife Service in August
. 1990. The current ecological impacts were determined
to be ~inirnal, but continued monitoring was
recommended to identify any future impacts.
SUMMARY OF SITE RISKS
Durin, the Remedial Investigation, an analysis was
conducted to estimate the human health or
environmental problems that could result if the
CODt8minat~on identified at the site was not cleaned up.
This analysis, mown as a Baseline Risk Assessment,
focused on the potential health effects from long-term
direct exposure to the contaminants found at the Site.
EPA has concluded that the major risk to human health
and the environment at the Site would result from the
- ingestion of ,roundwater contaminated with volatile
: organic compounds, including PCE. This is not a
,. current risk because potentially affected residences are
~ being supplied with an alternate drinking water source.
~. However, if residents were to use contaminated
. groundwater or spring water as a source of drinking
water in the future, there would be long-term risks to
human health.
A current exposure pathway that remains of concern is
the air pathway. Although the calculated risk, based
on the levels of PCE detected in the tWo air samples,
does not represent a health concern, EP A recommends
. additional samplina to determine if there is still a
. source of PCE on-site.
Actual or threatened releases of hazardous substances
from this Site, if not addressed by the preferred
alternative or one of the other active measures
considered, may present a current or potential threat to
public health, welfare, or the environment.
For more information about the risks posed by the
coDta"1itllItion at the Tri-City Industrial Disposal Site,
please refer to the Baseline Risk Assessment contained
in the RI Report. This document is available for
review at the information repository at the Ridgway
Memorial Library in Shepherdsville, Kentucky.
SCOPE AND OBJECTIVES OF THIS REMEDIAL
ACTION
Using the information ,athered durin, the Remedial
Investigation and the Baseline Risk Assessment, EP A
identified the foUowin, remedial action objectives for
the cleanup at the Tri-City Industrial Disposal Site:
. Groundwater - (1) To clean up sprina water having
contaminant concentrations in excess.of MCLs, and
(2) to restrict potable usaae and monitOr springs in
the area of the Site until the water is of sufficient
and consistent quality for human consumption. .
. Soil - To perform Confirmatory Sampling of site
soil to confirm that (1) aU contaminAnts of concern
were removed by the Emeraency Removal Action,
(2) PCB and PAH contaminat~on is lOCAlized, (3)
apparently disturbed areas in the northeast quadrant
. of the Site (as shown in the aerial photorraPh taken
in 1967) are clean, and (4) the soil on the sloped
areas of the fill is clean.
. Sediment - To perform Confirmatory Sampling to
determine the extent of any lead contamination in the
tributary of Brushy Fork Creek.
. Air - To perform Confirmatory Sampling of ambient
air to determine if there is a pattern of
contamination and identify a source.
. Surface Water - To monitor surface water to provide
assurance that surface water quality is not affected
by site contaminants.
. Ecological - To monitor Brushy Fork Creek to
identify future impacts from the Site.
Tbe remedial action objectives proposed in this piau
address the cleanup of contamiftGtec;l aroundwater
(which is the principal threat mown to exist at the
Site), institutional tOntrols, monitorinl and
Confirmatory Sampling. These actions wiU be
implemented as Operable Unit'1.
If the Confirmatory Sampling reveals unacceptable
levels of hazardous contaminAnts in areas of the Site
that are not addressed by these remedial action
objectives, the additional measures necessary to
mitigate any threat to human health or the environment
will be implemented as Operable Unit 112.
4
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SUMMARY OF REMEDIAL ALTERNATIVES
EP A developed four remedial action alternatives to
address the remedial actioD objectives established for
the Site. Since the sampling conducted during the RI
and in December 1990 indicated that only the Cox
Spring is contAminlltoeri. the contaminAted groundwater
will be addressed by cleaning up the spring. Only one
aroundwater monitoring welJ out of the fifteen borings
drilled during the Remedial Investigation bad sufficient
yield to be considered for extraction purposes.
Therefore, a high degree of uncertainty exists in
attempting to capture the contaminated groundwater
within the variably fractured bedrock beneath the Site.
It is believed that the9Qntaminated groundwater is
gradually being flushed through the springs.
The following descriptions of clean-up alternatives are
summarizations. The FS Report contains a more
detailed evaluation of eacb alternative.
ALTERNATIVE 1 - No ACTION
By law, EPA is required to evaluate a .No Action.
alternative to serve as a basis against which other
alternatives can be compared. Under the no action
alternative, the site would be left .as is. and no funds
would be spent for this remedial alternative.
ALTERNATIVE 2 - L~urED ACTION
Major components include:
. Institutional controls
,.; Monitoring
. Confirmatory sampling
.Under this alternative, institutional controls such as
local ordinances, conservation or restrictive easements,
deed restrictions, record notice or some other
appropriate measure would be imposed to prevent
residents from using aroundwater or spring water for
domestic purposes. Potable water would be supplied
to the on-site residents until EPA determines, through
monitoring, that the springs are suitable for potable
water usage. .
The springs would be monitored by quarterly sampling
for the first year to identifY. seasonal variations in
contAminllnt levels, semi-annually for the next two
. years, and yearly thereafter for up to 27 years. In
addition to continuous reviews for any public health
concerns, the sampling results from the springs would
be reviewed to identify contaminant levels that wanant
remedial action. The groundwater and surface water
would be monitored via annual sampling for up to 30
years and the sampling results would be reviewed
every five years for possible alterations in the
monitoring proaram. Ecological monitoring would be
conducted every other year for the first ten years and
every five years thereafter for up to 20 years.
Confirmatory sampling would be conducted to assess
the effectiveness of the Emergency Removal Action
near the Cox, Sr. residence. The apparently disturbed
areas in the northeast quadrant of the Site (as shown in
the aerial photograph taken in 1967) would be sampled
to investigate possible contamination from drum
disposal. The surface soils of the landfill would be
sampled to establish the extent of PCB and PAH
contamination. The sMimf!nt in the tributary of
Brushy Fort Creek would be sampled to determine the
extent of any lead contamination. Additional air
sampling would be conducted. The slopes of the fill
area and the on-site ponds would also be samPied.
The total present worth of this alternative for a 30-year
period is approximately $1,714,000.
ALTERNATIVE 3 - CARBON ADsORPTION
Major components include:
. Carbon adsorption
. Institutional controls
. Monitoring
. Confirmatory sampling
This alternative involves treating the contamin"t~
spring water in . carbon adsorption system containing
an activated carbon adsorber. Monthly monitoring of
the influent and effluent would be required for the first
year to determine the frequency of carbon filter
replacement. During the following 29 years, the
influent and effluent would be sampled prior to carbon
filter replacement. The spent carbon would be
disposed of in . RCRA TSD facility in accordance
with the appropriate RCRA regulations. If the cai-bon
can be regeoerated-bd reused, that option will be
considered if it is cost-effective.
Combined with this alternative are the following
actions previously described in Alternative 2:
prevention of potable use of the groundwater and .
spring water and provision of an alternate water
supply, until otherwise determined by EPA; long-term
monitoring of groundwater, spring water, and surface
water; ecological monitQring; and confirmatory
sampling.
5
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The total present worth of this alternative over a
3O-year period is approximately $2,098,000.
ALTERNATIVE 4 - AERATION
Major components include:
. Aeration
. Institutional controls
. MonitorinS
. Confirmatory sampling
This alternative consists of aerating the contaminated
spring water prior to its release. This process would
involve the construction of a series of concrete steps
over which the spring water would pass. The water
would aerate and thereby volatilize the major
contAminants of concern (VOCS). A treatability study
would be required to determine the design parameters
for the aeration system prior to the construction of the
steps. The influent ind effluent would be monitored
monthly for the first five years and annually for up to
the next 2S years if the system is effective.
Combined with this alternative are the following
actions previously described in Alternative 2:
prevention of the potable use of aroundwater and
spring water and provision of an alternate water
supply, until otherwise determined by EP A; long-term
monitoring of aroundwater, spring water, and surface
water: ecological monitoring: and confirmatory
sampling.
The total present worth of this alternative for a 30-year
period is approximately $1,990,000.
CRITERIA FOR EVALUATING REMEDIAL
ALTERNATIVES
EPA's selection of the preferred cleanup alternative for
the Tri-City Industrial Disposal Site, as described in
this Proposed Plan, is the result of a comprehensive
evaluation aod screenina process. The feasibility
Study (fS) for the Site was conducted to identify and
analyze the alternatives considered for addressing
contamination at the Site. The fS Report for the
Tri-City Site describes, in detail, the alternatives
considered, as well as the process and criteria EP A
used to narrow the list to four potential remedial
alternatives to address spring water contamination.
EP A used the following nine criteria to evaluate
alternatives identified in the fS. While overall
protection of human health and the environment is the
primary objective of the remedial action, the remedial
alternative(s) selected for the Site must achieve the best
balance among the evaluation criteria considering the
scope and relative degree of the contAmination at the
Site.
6
1.
Overall protection of human health and the
euvironmeut: EP A .ss~~ the degree to
wbicbeaCb alternative eliminates, reduces, or
controls threats to public health and the
environment throuSh treatment, enaineering
methods or institutional controls.
2.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs): The
alternatives are evaluated for compliance with
aU state and federal environmental and public
health laws and requirements that apply or are
relevant and appropriate to the site conditions.
3.
Cost: The benefits of implementing a
particular remedial alternative are weighed
against the cost of implementation. Costs
include the capital (up-front) cost of .
implementina an alternative as well as the cost
of operating and maintaining the alternative
over the lon8 term, and the net present worth
of both capital and operation and maintenance
costs.
4.
Implementability: EP A considers the technical
feasibility (e.,., how difficult the alternative is
to construct and operate) and administrative
ease (e.g., the amount of coordination with
other government agencies that is needed) of a
remedy, including the availability of necessary
materials and services.
s.
Short-term effectiveness: The length of time
needed to implement each alternative is
coDsidered, and EP A 8Sses~ the risks that
may be posed to workers and nearby residents
durina construction and implementation,
6.
Long-term effectiveness: The alternatives are
evaluated based on theit ability to maintain
reliable pn>tection of public health and the
environment over time once the cleanup goals
have been met.
7.
Reduction of contAmiftUlt toxicity, mobility,
and volume: EP A evaluates each alternative
based on how it reduces (1) the harmful natUre
of the contAminants, (2) their ability to move
through the environment, and (3) the volume or
amount of contamination at the site.
-------
8.
State acceptaDce: EP A requests state comments
CD the Remedial Investigation and Feasibility
Study reports, IS well as the Proposed Plan,
and must take into consideration whether the
state concurs with, opposes, or has no comment
on EPA's preferred alternative.
9.
Community acceptance: To ensure ~t the
public has an adequate opportunity to provide
input, EP A holds a public comment period and
considers and responds to aU comments
received from the community prior to the final
selection of a remedial action.
EVALUATION OJ: ALTERNATIVES
Table 1 summarizes how the alternatives were
evaluated using seven of the nine criteria.
State Acceptance
The Kentucky Natural Resources and Environmental
Protection Cabinet (the .Cabinet.) bas reviewed and
provided EP A with comments regarding the reports
and data from the RI and the FS. Based upon their
review of the selected alternatives, the Cabinet does
not believe that State ARARs, as outlined in KRS
224.877, are being addressed. Nor do they feel that
enough technical information about the Site is available
to justify remedial action at this time.
However, EPA has carefully coDSidered the
requirements of KRS 224.87 and believes that
Alternatives 3 and 4 are in compliance. Additionally,
EP A feels that sampling data warrants the cleanup of
. the Cox Spring, provision of potable water, and
monitoring of groundwater, springs, and surface water.
EP A agrees that further samplina of sediments, site
soils, and ambient air is necessary before making any
decisions regarding cleanup.
Communi tv AcceDtance
Community acceptance of the various alternatives will
be evaluated during the public comment period and it
will be described in the Record of Decision (ROD) for
the Site.
EPA'S PREFERRED ALTERNATIVE
Based CD the analysis of alternatives in the Feasibility
Study Report, EPA has identified Alternative 3 as the
preferred method of addressing the established
remedial action objectives for the Tri-City Industrial
Disposal Site.
EP A preferred Alternative 3 to address the
contJIm;nsated sprina water in Cox SpriDa. This
alternative involves treating the sprina \Wt.er in a
carbon adsorption system to remove the volatile
organic compounds (V0Cs).
All of the alternatives, except Alternative 1 (No
Action) provide adequate protection of human health
and the environment. The risk associated with the
cootJIm;nsated sprina water and the potential risks from
the contJIm;n-ted soils and air are investigated further
to determine future remedial action.
Alternative 3 provides the most protection for human
health and environment beCause the VOCs will be
destroyed when the exhausted caibon filter is treated.
Alternative 4 is less protective because the VOCs are
merely transferred from the spring water to the
atmosphere. However, both alternatives are effective
in preventing contamination of surface water
down gradient of the spring. Although Alternative 2
restricts potable use of the spring water, it will not
prevent downgradient contamination.
Both Alternative 3 and 4 provide long-term
effectiveness and permanence because treatment
technologies are used to reduce the hazards associated
with the VOCS. However, the aeration described in
Alternative 4' is innovative and it requires a treatability
study to determine the design parameters.
Alternative 3 is a proven and widely available
technology and it is easier to implement than
Alternative 4. Alternative 2 costs the least, except for
the No Action alternative, but it will not provide
long-term effectiveness and permanence. The costs to
implement Alternatives 3 and 4 are not substantially
different.
Alternative 3 would reduce the toxicity, mobility, and
volume of contaminated spring water through
treatment. Alternative 4 would reduce the toxicity and
volume of contaminated spring water, but the mobility
is not reduced because the contllm;nants are transferred
to the atmosphere. Alternative 2 will not reduce the
toxicity, mobility, or volume of the CQntaminated
spring water.
..
Alternatives 3 and 4 require installation of treatment
units on-site. Therefore, the associated short-term
risks to workers on-site and residents are similar. The
time for implementation, approximately fourteen
months, is also similar for both alternatives.
Alternative 2 could be implemented expediently. And.
Alternatives 3 and 4 comply with all ARARs.
7
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ALTERNATIVE ,
NO ACTION
DescriDt ion:
No remediat action witt be perfor8ed
and the site woutd be teft as is.
OVerait Protection: .
Risks to hu.an heatth and envlronRent
not changed.
00
C~tlance With ARARs:
Woutd not comply with chemlcal-
specific ARARs for groundwater. Would
c08ply with location-specific ARARs.
There are no action-specific ARARs.
,
Long-Term Effectiveness:
Not effective In reducing risk frGIII
groundwater contaminants. Aquifer
restoration depends on natural
ftushing and degradation of
contaminants.
TABLE'
SUMMARY OF ALTERNATIVES EVALUATION
TRI-CITY INDUSTRIAL DISPOSAL SITE
OPERABLE UNIT" FEASIBILITY STUDY
ALTERNATIVE 2
LIMITED ACTION
Restrict groundwater and spring
water use through institutional
controts. Provide potabte water
supply to site residents. Perform.
long-term monitoring and conf.lr-
lIIatory samptlng.
Risks to human health reduced by
restricting groundwater use. Risk
to envl ronRent not changed. Surface
water not degraded. VOCs discharge
to atmosphere. Risks from
cont.inated salt, sediment, and air
woutd be addressed by conflr88tory
sanlpling.
Would not comply with chemlcel-
specific ARARs for groundwater.
Would cOMply with location-specific
and action-specific ARARs. There
are no chemical-specific ARARs for
cteanup of salt, sediment, end air.
Instltutlonat controts would ensure
that groundwater Is not used as a
potabte water suppty. Not effective
In reducing groundwater contaminant
concentrations. Aquifer restoration
depends on naturat ftushing and
degradation of contaminants.
Long-term monitoring required.
ALTERNATIVE 3
CARBON ADSORPTION
Cottect and treat spring water with
carbon adsorption. Sanlpte influent
and efftuent ~nthty for one year to
determine carbon reptacement sched-
ute. S~te prior to carbon replace-
8ent for the next 29 years. DispOse
of spent carbon In RCRA landfllt.
Restrict groundwater and spring water
use through Instltutlonat controts.
Provide potable water supply to site
residents. Perform long-term
8Onitoring and confir88tory s8lpling.
Risks reduced by rellloving spring
water cont..inants and by restricting
groundwater use. Treatment of spring
water will prevent the spread of
contaminants to protect the
envlron8ent from further degrada-
tion. Risks frGIII contaminated 80it,
lediant, and air woutd be addressed
by conflr88tory S8lllpting.
Treated spring water would comply
with chemical-specific ARARs for
surface water and groundwater. Woutd
alia c08ply with tocatlon-speclflc
and action- specific ARARs. There
are no chemicat-speclfic ARARs for
cteanup of soil, sediment, and air.
Spring ~ater treat.-nt woutd reduce
the future potentiat risk fro.
ingestion and other househotd uses
and surface water contamination.
Aquifer restoration depends on
naturat ftushlng and degradation of
contallinants. Process monitoring
required. Requires regeneration or
disposat of spent carbon. vacs are
destroyed. Institutionat controls
would ensure that groundwater is not
used as a potable water source.
ALTERNATIVE 4
AERATION
Cottect and treat spring water with
aeration. Sampte inftuent and
efftuent lIIonthty for first 5 years
and annuatly for the next 25 years.
Restrict grqundwater and spring water
use through institutional controts.
Provide potabte water suppty to site
residents. Perform long-term
8Onitoring and confir88tory S8lllpting.
Risks reduced by re.ovlng spring
water cont_lnants and by restricting
groundwater use. Treatant of spring
water wilt prevent the spread of
contaminants to downgradlent surface
water. Witt discharge VOCs to
atllOsphere. Risks frGIII cont..lnated
soil, sediment, and air woutd be
addressed by confir..tory s-.pllng.
Treated spring water would comply
with chemical-specific ARARs for
surface water. Woutd also co.ply
with tocatlon-speclflc and actlon-
specific ARARs. There ar. no
che.lcal-speciflc ARARs for cleanup
of soil, sedilllent, and air.
Spring water treatlllent woutd reduce
the future potential risk fro.
ingestion and other household uses
and surface water. contalllination.
Aquifer restoration depends on
naturat ftushing and degradation of
contaminants. Process monitoring
required. VOCs are discharged to the
atmosphere. Institutional controls
would ensure that groundwater is not
used as a potable water source.
-------
ALTERNATIVE 1
NO ACTION
Reduction of Toxicity. Mobility
and Volune:
No reduction of toxicity, mobility or
vol~.
Short-Tenl Effectiveness:
No risks to public.
Implementability:
No work to be 1~Ie8f1ted.
\0
f.2!! :
\
Capl tal:
Annual o&M:
Ecological Cost:
5-Year Cost:
Present Worth:
so
SO
'SO
so
SO
TABLE 1 (Cont'd)
ALTERNATIVE 2
LlMITEO ACTION
No reduction of toxicity, aobility
or vol~e of contaminated spring
water. Mobility of contaminants
would increase when discharged to
the atllosphere.
No risk to public froll sallpllng
activities. Protective equlp8ent
required for personnel conducting
long-tera aonltoring and confir-
lIatory sampling.
Institutional controls can be
illPleMented by federal, state, local
officials, and/or owners. Ground-
water 8Onltorlng could be perforlled
using previously installed wells.
Alternate water supply would
continue using current aethod.
Capital:
Annuli I o&M:
1st Year S 56,396
2nd Year S 46,026
3rd Year S 46,026
4th-30th Year S 40,842
Pot. Water Supply S 2,420
Ecological Cost: S, 22,704
5-Year Cost: S' 10,000
Present Worth: S1,714,OOO
S 880,798
ALTERNATIVE 3
CARBON ADSORPTION
Spring water treatment would reduce
the toxicity, volume and mobility of
. spring water contaminants.
little risk to public or workers
c1.Iring IlIpleMentatlon. Workers would
be required to wear protective equip-
llent. Spring water treat.ent would
be operational within one to two
IIonths after site work Is initiated-
Conflrllatory sa.pllng would take
twelve to eighteen lIonths.
Technology dellonstrated and c~r-
clallyavallable. SPDES compliance
lIonltorlng required. Institutional
controls can be I.pleaented by'
federal, state, local officials
and/or ownera. Groundwater
aonltorlng could be perfor8ed using
previously Installed wells.
Alternate water supply would continue
using current llethod.
Capl tal:
Annual o&M:
Process Monltorlna:
1st Year S 34,386
2nd-30th Year: S 23,896
long-Term Monitorlna:
1st Year S 53,084
2nd Year S 44,310
3rd Year S 44,310
4th-30th Yelr S 40,014
Pot. Water Supply S 2,420
Ecologicil Cost S 22,704
5-Year Cost: S 10,000
Present Worth: S2,098,OOO
S 904,254
ALTERNATIVE 4
AERA TI ON
Spring water treatment would reduce
the toxicity an~ volUlle of conta.-
Inants. Mobility of contaliinants
would Increase when dl'scharged to the
, Itmosphere.
little rlak to public or workers
c1.Irlng I lip I 88entat Ion. Workers would
be required to wear protective equip-
..nt. Spring water treatllent would
be ~peratlonal within one to two
months after site work 18 Initiated.
Conflrllatory sallpllng would take
twelve to eighteen Months.
Technology dellonstrated and cOmller-
clallyavallable. SPDES cOllpllance
monitoring required. Institutional
controls can be lapleMented by
federal, state, local officials
and/or owners. Groundwater aonltor-
Ing could be perforaed using
previoully Installed weill.
Alternate water lupply would continue
using current llethod.
Capital:
Annuli I o&M:
Process Monitoring:
1st-5th Year S 20,980
6th-30th Year: S 10,490
Long-Tefl! Monitoring:
1st Year S 53,084
2nd Yelr S 44,370
3rd Year S 44,370
4th-30th Year S 40,014
Pot. Water Supply S 2,420
Ecological Cost S 22,704
5-Year Cost: S 10,000
Present Worth: S1,990,OOO
S1,080,743
-------
Consequently, Altemative 3 represents the best balance
amon, the criteria used in the evaluation. It is
protective of human health and the environment,
utilizes . permanent solution, poses little risk to the
public or workers on-site, is readily implementable,
and is cost-effective. It also satisfies EPA's preference
for treatment as . principal element.
EPA's selection of A1terna~ve 3 as the preferred
remedial action at the Tri-City Industrial Disposal Site
is preliminary. Based on new information or public
comments, EPA, in consultation with the
Commonwealth of Kentucky, may later modify the
preferred alternative or select another remedial action
p~ted in this Pro~sed Plan and the FS Report.
THE NEXT STEP
After the public comment period ends on June I, 1991
(see below), EP A will review and consider all
comments received from the community as part of the
process of reaching a final decision on the most
appropriate remedial alternative, or combination of
alternatives, to address the contamination at the
Tri-City Industrial Disposal Site. EPA's final choice
of . remedy will be issued in a Record of Decision
(ROD) for the Site this summer. A document, called
the Responsiveness Summary, that summarizes EP A's
responses to comments received during the public
comment period will be issued with the ROD.
Once the ROD is signed by the EP A Regional
Administrator, it will become part of the
Administrative Record. EP A will then offer the
Potentially Responsible Parties (PRPs) the opportunity
to conduct the Remedial Design and Remedial Action
under the terms of a Consent Decree. When the
"" negotiation period ends, either the PRPs or EP A will
begin developing the engineering design plans for
implementing the remedial altemative(s).
If the Confirmatory Sampling conducted during the
Remedial Design phase reveals unacceptable levels of
hazardous contJlminllnts in areas of the Site that are not
addressed by the remedial actiODS identified in this
Proposed Plan, the additional measures necessary to
mitigate any threat to human health or the environment
will be implemented as Operable Unit #2.
GLOSSARY
Activated Carbon: A powdered or granular form of .
carbon that has been treated to increase its surface area
and adsorptive properties. It is widely used in .
pollution control systems because contaminAnts are
adsorbed. or adhered, to the surface of the carbon.
Administrative Record: A file which contains all
information used by the lead agency to make its
decision on the selection of a response action under
CERCLA. This file is required to be available for
public review and a copy is to be established at or near
. the site, usually in an information repository. A
duplicate file is maintained at a central location, such
as a regional EPA andlor state office.
Aeration: A purification process that increases
exposure of contaminated water to air circulation to
remove volatile contJlminJlnts.
Applicable or Relevant and Appropriate Requirements
(ARARs): Federal and State requirements that a
remedy selected by EP A must attain. These
requirements are site-specific and are generally
categorized as chemica1-specific, location-specific, and
ac:tion--specific.
Bedrock: The layer. of rock located below the glacially
deposited soil and rock under the earth's surface.
Bedrock can be either solid or fractured (cracked);
fractured bedrock can support aquifers.
Bench-sca1e Study: A type of treatability study that is
performed in the laboratory using small amounts of
waste. These tests are generally used to determine if
the 8cbemistry8 of the cleanup process works.
Carbon Adsorption: A process for removing a variety
of organic compounds. It involves passing the water
througb a chamber that is packed with activated carbon
particles, where contJlminAnts attach to the carbon
particles, effectively removing contJlminants from the
water.
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA).: A
Federal law passed in 1980 and modified in 1986 by
the Superfund Amendments and Reauthorization Act
(SARA). These acts created . special tax that goes
into a trust fund, commonly known as Superfund, to
investigate and clean up abandoned or uncontrolled
hazardous waste sites. Under the program, EP A can
either: (1) pay for site cleanup when parties
responsible for the contamination cannot be located or
are unwilling or unable to perform the work, or (2)
take legal action taTorc:e parties responsible for site
contamination to clean up the site or pay back the
Fedetal government for the cost of the cleanup.
Consent Decree: A legal document, approved by a
judge, that formalizes an agreement reached between
EP A and PRPs throuah which PRPs will conduct all or
part of . cleanup action at a Superfund site. The
consent decree describes the actions the PRPs will
take.
10
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Ecoloaica1 Monitoring: Monitoring of an ecosystem to
determine if it is being adversely impacted by
contAminAnts oriJinatin. from . hazardous waste site.
The monitorinl includes the analyses of tissues from
organisms in the ecosystem and using living organisms
to measure the effects of a contaminAnt.
Effluent: The stream of water that flows out of a
,treatment process.
Emergency Removal Action: An immediate action
taken over the short-term to address a release or
threatened release of hazardous substances.
Feasibility Study (FS): The second part of a two-part
, scudy called . Remedial InvestigationIFeasibility Study
(RlIFS).The FS identifies and evaluates remedial
alternatives that are designed to address c:ontamination
problems found during the RI at a Superfund site. '
(See the definition for RI.)
Groundwater: Water found beneath the earth's surface
that fills spaces between materials such as sand, soil,
gravel, and cracks in bedrock to the point of
saturation. Groundwater is often used as a source of
drinking water via municipal or domestic wells.
Groundwater typically flows very slowly c:ompared to
surface water, along routes that often lead to rivers or
la1ces.
Hazardo~ Substance: Any material that poses a threat
to human health and/or the environment. Typical .
hazardous substances are materials that are toxic,
. c:orrosive, ignitable, explosive, or chemically reactive.
.' Influent: The stream of c:ontaminated water entering a
treatment process. .
Information Repository: The location of a file
c:ontaining current information, technical reports, and
reference documents regarding a Superfund site. The
information repository is usually located in a public
building that is convenient for local residents, such as
a public school, city hall, or library.
Institutional Controls: Legal, non~ngineering
measures to prevent human exposure to c:ontAminAPts
at hazardous waste sites.
Maxiinum ContJminAftt Levels (MCLs): Enforceable
drinking water standards developed under the Safe
Drinking Water Act for public water supplies. MCLs
are the maximum permissible levels of coataminants.
Monitoring: The c:ontinued collection of information
about the environment that helps determine the
effectiveness of a cleanup action.
National Priorities List (NPL): EPA's list of the top
priority hazardous waste sites that are eligible for
federal money under Superfund.
Net Present Worth: The amount of money necessary
to secure the promise of future payment, or series of
payments, at an 'C$I'1W'4 interest rate.
Operable Unit: A discrete action that comprises an
incremental step toward c:omprehemively addressing
problems at a Superfund site. Operable units may
address geographical portions of. site, specific site
problems (such as CODt.Dmin"ted JI'Oundwater), or
interim actions that will be followed by subsequent
actions whicb fully address the scope of the problem.
Organic Compounds: One of two large cWses of
chemical compounds: organic and inorganic. The.
term .organic. is used to describe substances that are
primarily composed of carbon, hydrolen, and oxygen.
Examples of organic compounds include petroleum
products sucb as solvents, oils, and pesticides.
Parts per Million (ppm): A way of expressing tiny.
c:oncentrations of pollutants in air, water, soil, human
tissue, food, or other products. One ppm of a
c:ompound in water corresponds to one gallon of the
chemical in one million gallons of water.
Polychlorinated Biphenyls (PCBs): A ,roup of toxic,
persistent organic cbemicals used in transformers and
capacitors for insulating purposes and in gas pipeline
systems as a lubricant. Further sale for new use waS
banned by law in 1979.
Polycyclic Aromatic Hydrocarbons (PAHs): A group
of organic compounds characterized by a fused
ring-like molecular structure. P AHs are common
environmental pollutants that are produced by the
incomplete combustion of organic materials. These
c:ompounds occur in the exhaust from motor vehicles
and other gasoline and diesel engines, the emissions
from c:oal-, oil-, and wood-burning stoves and
furnaces, cigarette smoke, and cbarcoa1-broiled foods.
Persistence: Refers to the length of time a c:ompound,
once introduced in~ the environment, stays there.
Potable water. Water that is safe for drinking and
cooking.
Potentially Responsible Parties (pRPs): An individual,
busiDess, or govemmeat organizatioa ideatified by
EP A as potentially liable for the actual or threatened
release of hazardous substances from an uncontrolled
hazardous waste site.
11
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Record of Decision (ROD): A public document that
explaiDs which cleanup alternative will be used at a
National Priorities List site and the reasons for
choosiDi that cleanup alternative over other
possibilities.
Remedial Action (RA): The actu&J construction or
implementation phase of a Superfund site cleanup that
fonows the remedial design.
Remedial Alternatives: A combination of technical and
administrative methods developed and evaluated in a
Feasibility Study that can be used to address
contamination at a Superfund site.
Remedial Desip (RD): The phase of a Superfund site
cleanup that fonows the RemediallnvestigatioDl
Feasibility Study and includes development of
engineering drawings and specifications.
Remedial Investigation (RI): The first part of a
two-part study called a RemediallnvestigatioDl
Feasibility Study (RIIFS). The RI. is a study during
which information is eollected and analyzed to
determine the nature and extent of contamination at a
Superfund site.
Resource Conservation and Recovery Act (RCRA):
This act regulates the transportation, storage,
treatment, and disposal of hazardous wastes.
Sediment: Materials such as sand, soil, mud, and
decomposing animals and plants that settle to the
bottom of a pond, stream, river, or lake.
Source: Area(s} at a hazardous waste site from which
groundwater and surface water contamination
originate.
Superfund: The name commonly used in reference to
the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980,
as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986. Superfund also
refers to the trust fund that is used for to pay for the
investigations and cleanini up of abandoned or
uncontrolled hazardous waste sites.
Surface Water: Streams, lakes, ponds, rivers, or any
other body of water naturally open to the atmosphere.
Toxicity: The degree of danger posed by a substance
to animal or plant life.
Treatability Study: A study that is conducted to collect
data on cleanup technologies to determine if they will
be effective.
Treatment, Storage, and Disposal (TSD) Facility: Any
building, structure, or instaUatioo where a hazardous
substance bas been treaSed, stored, or d,isposed. TSD
facilities are reauJated by EP A and state iovemments
under the Resource Conservation and Recovery Act
(RCRA).
Volatile Organic Compound {VOC}: A group of
organic compounds that are cbaracteri.zed by the
tendency to evaporate (or volatiliz.e) into the air from
water or soil. Common VOCs include commercial and
industrial solvents such as toluene, xylene,
tetracbloroetbene (percbloroethyleoe, or PCE), and
ethyl benzene.
TECHNICAL ASSISTANCE GRANT (TAG)
PROGRAM
Community groups interested in interpreting the
technical information presented in the RI and FS
reports and other studies may be eligible for one grant
of up to $50,000 in Federal funds. The purpose of the
grant is to provide technical assistance for community
residents seekina to understand site documents. .For
further information or an application, contact the TAG
Coordinator identified at the end of this fact sheet.
OPPORTUNITIES FOR PUBUC INVOLVEMENT
Public Comment Period
EP A is conducting a 30-day public comment period
from May 2 to June I, 1991 to provide an opportunity
for public involvement in the final cleanup decision.
During the comment period, the public is invited to
review this Proposed Plan and the Remedial
. Investigation and Feasibility Study reports. These
documents are available at the information repositories
indicated below. During the comment period,
interested members of the community may submit
written comments to Ms. Suzanne Durham, the EP A
Community Relations Coordinator for the Tri-City
Industrial Disposal Superfund Site, at the address listed
below. Comments must be postmarked no later than
June I, 1991. Oral comments may be presented
during the Public Meeting.
~
Public Meetinll
EPA will hold a public meeting on May 9, 1991 at
7:00 PM in the library of the Bullitt Lick Middle
School, located at 1080 West Blue Lick Road in
Sbepherdsville, Kentucky. This meeting will include a
presentation that describes the activities and findings of
the RemediallnvestigaUon conducted at the Site and
the evaluation of cleanup alteniatives conducted during
the Feasibility Study. The public is encouraged to
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atteDd the meeting "to hear the presentation, to ask
ques&ions, and to comment on altematives identified in
the Proposed PlaD. Comments made during the
meeting will be tnDSCribed, and a copy of the
transcript will be added to the Site's Administrative
Record available at the information repository.
The following EP A and State personnel may be
contacted if you have further questions:
Additional Public Information
Suzanne Dwbam (404) 347-7791
Community Relations Coordinator
Waste Management Division (4WD-NSRB)
U.S. EPA - Region IV"
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Because the Proposed Plan provides only a summary
description of the Tri-City Industrial Disposal Site and
the cleanup alternatives considered, the public is
encouraged to consult the Administrative Record,
which contains the Remedial Investigation Report, the
Feasibility Study Report, and other site documents, for
a detailed explanation of the Site and all of the
remedial alternatives under consideration.
Kimberly Gates
Remedial Project Manager
Waste Management Division (4WD-NSRB)
U.S. EPA - Region IV
345 Courtland Street, N .E.
Atlanta, Georgia 30365
(404) 347-7791
Records Center
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Contact: Mr. Tom Love
Hours: Monday - Friday, 8 AM - 5 PM
(404) 347-0506
Denise Bland (404) 347-2234
Tec:hnic:al Assistance Grant Coordinator
Waste Management Division (4WD-WPB)
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
The Administrative Record will be available for review
at the following locations no later than May 2, 1991:
Ridgway Memorial Library
Walnut Street
. P. o. Box 146
Shepherdsville, Kentucky 40165
Contact: Mr. Randy Matlow, Director
Hours: Monday - Saturday, 9 AM - 5 PM
Tuesday 9 AM - 7 PM
(502) 543-7675
Bob Padgett
Uncontrolled Sites Branch" .
Division of Waste Management
Kentucky Department for Environmental
Protection
18 Reilly Road
Frankfort, Kentucky 40601
(502) 564-(j716
Mai1in~ List Additions
If you would like your name and address placed on EPA's mailing list to receive information on the Tri-City Industrial
Disposal Superfund Site, please fill out this form and mail it to:
Suzanne Durham
Community Relations Coordinator
Waste Management Division (4WD-NSRB)
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
,.
Name:
Address:
Telephone:
Affiliation:
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Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 2
Transcript from the Public Meeting
May 9, 1991
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u.s. ENVIRONMENTAL PROTECTION AGENCY
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REGION IV
9
PUBLIC INFORMATION MEETING
TRI-CITY INDUSTRIAL DISPOSAL
SUPERFUND SITE
MAY 9, 1991
7:00 P.M.
BULLITT LICK MIDDLE SCHOOL
1080 WEST BLUE LICK ROAD
SHEPHERDSVILLE, KENTUCKY 40165
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REPORTED BY:
SHARON L. KLOSTERMAN
Cou~t Reporter
1806 South Third Street
Louisville, Kentucky 40208
(502) 637-1602
OR\G\NAl
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APPEARANCES:
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HAROLD TAYLOR
Chief
Tennessee-Kentucky Remedial Sect.
Superfund Program
Environmental Protection Agency
Region IV
345 N. Courtland Street, N.E.
Atlanta, Georgia 30365
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KIM GATES
Remedial Project Manager
Tennessee-Kentucky Remedial Sect.
Superfund Program
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
8
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TONY .DEANGELO
Remedial Project Manager
Smith's Farm Site
Tennessee-Kentucky Remedial Sect.
Superfund Program
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
BROOK DICKERSON
Regional Counsel
Office of Regional Counsel
Superfund Program
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
~
SUZANNE DURHAM
Community Relations Coordinator
Tennessee-Kentucky Remedial Sect.
Superfund Program
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
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APPEARANCES (continued)
GLENN ADAMS
Water Division
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
TONY ABLE
Groundwater Technology Support
Unit
Environmental Protectional Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
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The following was heard on
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Thursday, May 9th, 1991, at 7:00 O'clock p.m., at Blue
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Lick-Middle School in Shepherdsville, Bullitt County
.5
Kentucky.
6
MR. TAYLOR:
Welcome,
7
everybody.
My name is Harold Taylor.
I am the Chief
8
of the Tennessee-Kentucky Remedial Section in the
9
Superfund Program at Region IV, EPA, in Atlanta
Georgia.
We are here tonight for the
Tri-Cities public meeting.
We'll get into the agenda
and everything in a minute.
We are going to have a
presentation, a short presentation, after we get
through with the Tri-Cities presentation on the Smith's
Farm Site.
So, dual purpose tonight but the primary
purpose is to go over the. Tri-City Site and Proposed
Plan for the remediation of that site.
So, for those
of you that are here primarily for Smith's Farm, we'll
try and get through the Tri-Cities as fast as we can
~
and not keep you here all night.
First of all, I'd like to, number
one,
thank the school for letting use their facilities
here.
This is about the third time I know that I. have
been here and they are more than accomodating.
In fact
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it's one of the better facilities that we get to use in
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Tennessee or Kentucky.
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First of all, what I'd like to do
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is introduce a few of the peo~le that are here tonight.
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We have some - - can you all hear me alright?
Good.
6
I'll try to speak up.
Let me just introduce a few of
7
the local people that we have here.
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Glenn Armstrong.
There we go.
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Glenn is the Bullitt County Judge-Executive.
Appreciate it, Glenn.
Dennis Mitchell, Bullitt County
Magistrate.
Is that right?
Thanks, Dennis.
Ned Fitzgibbons with the Bullitt
County Health Department.
Appreciate it, Ned, your
coming tonight.
Carl Millan~i is here with the
Kentucky Superfund Program.
And next to Carl is Rick
Cogan.
And right behind Rick is Bob Padgett, all with
the Superfund Program.
Let me see.
Okay.
Let me
introduce the - - Glenn Armstrong.
0-
I got Glenn.
There
we go.
Okay.
Let me introduce a few of the EPA
people that are here tonight.
On my immediate" left,
your right, is Kim Gates.
Kim is the Remedial Project
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Manager in the Tennessee-Kentucky Remedial Section at
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EP.~, Region IV,
in Atlanta, ~ho is in charge of the
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Tri-City Site.
It is her responsibility to o~ersee the
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project and basically move EPA through the Superfund
~
process on the Site.
So, she'll be making
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presentations tonight on what we have done to date with
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the the Tri-City Sit~.
Over on her left is Tony
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De~ngelo.
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Tony DeAngelo is the Remedial
Project ~anagpr for the Smith'~ Farm Site.
He is also
in the Tennessee-Kentucky Remedial Section at the u.s.
EPA, Region IV, in Atlanta,
Georgia.
No'" ,
o\"er on my
right is Brook Dickerson.
Brook Dickerson is the Assistant
Regional Counsel
in our Office of Regional Counsel and
she is the attorney ~ho is representing the u.S. EPA,
Region IV,
for the Tri-City Site.
O~er on her right is
Suzanne Durham.
Suzanne Durham is the Community
Relations Coordinator for the Tri-City Site and for the
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Smith's Farm Site and for all the other sites in
Tennessee and KentuckY.
And over, again, on her right
. .
is Glenn .~dams.
Glenn is a toxicologist in the
~ater Division and he is here tonight mainly to ans~er
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any qUE'!stions t.h~t people may have about. the he~lth
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effects, or ~hatE'!ver, regarding the chemicals that we
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found at the Site.
And over on his right is Tony Able.
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Tony is a groundwater hydrologist
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that's in our Groundwater Technology Support Unit
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at EPA, Region IV.
So, I think I've introduced pretty
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much everyone here.
R
Khat \oie're going to try to do
tonight, if you look over thE'! agend~, and if you don't
nav8, there are copies of most of t.he slides there in
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t.he back, along ~ith the f~ct sheet on the Tri-City
Site an~ the fact shE'!et on thE'! Smith's Farm Site."
What
~E'! ~re going t.o do tonight.
is run
through this ~genda
in atl0ut an hour i1nd then open it up for questions and
ans~ers on the Trj-City
Sitf>.
h'e do na\Oe a court reporter here
~ho is completing a record for thE'! agency.
So wha t \o."e
w11] ask you to do is let us get through our hour of
presentation and hold your questions until the end ano
then we'll answer your questions.
The other thing thi1t
,.
r would ask you to do is when you, if you do have a
question at the end, I'd like to ask you to please
stand up ano stat.e your"name so that we have ~ record
of who is asking the question.
A.nd if you have a
re~]]y diffir.ult. name to spell it might not hurt to
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spell your name for the reporter and I'm sure she will
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appreciate that.
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We will take about a ten minute
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break after we get through with the questions and
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answers on Tri-Cities.
The Court Reporter will stop
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and then we'll answer any questions you have on the
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Smith's Farm Site at that time.
I think that's pretty
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much it for the agenda.
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Just go over and we'll go over
this a couple of times tonight.
But the Administrative
Record for the Tri-City Site, and that is a record for
all documents that EPA has used to come to the proposed
plan that we are here to discuss tonight.
They are
located at the Ridgeway Memorial Library in
Shepherdsville.
It's - - the documents are probably
about - - fit on a bookshelf about yea long.
But we'll
try and summarize it, as best we can tonight, what's in .
those documents for you.
But we do welcome you to go
to the library and review the documents at any time
that you please.
,.
I want to go over just real
briefly ~he Superfund process, in general, to bring you
. .
up with how we got to where we are and where we are
currently because it is a somewhat confusing procedure.
As you see, it starts off with a
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Site Discovery Process and the Smith's Farm Site, as
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you well know, has a history dating back to '87/'88, as
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far as the agency is concerned.
After a site is
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discovered, and basically anyone can do that; a
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citizen, an industry, a state agency, a federal agency.
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And when I say "discover', that means that it goes into
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our inventory of Potential Hazardous Waste Sites.
We
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have an inventory of approximately thirty-some odd
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thousand of potential hazardous waste sites in the
nation.
After the site is discovered it is
put on our surplus list of potential sites and we
basically go out and do Preliminary Assessment, Site
Inspection, if necessary.
And eventually we go through
a hazardous ranking process for those sites that
warrant that type of attention.
After a site is. ranked and put on
the NPL, we go through a remedial investigation and
feasibility study.
We have done all of these things at
the Tri-City Site and we're about somewhere right in
~
here.
Because we are here tonight to solicit community
input. on the propo~ed plan that is in the fact sheet at
the back of the room.
After we have done that we will
go through what we call what we call a 'Record of
Decision' ,
and then the site will go through a Remedial
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De~ign and Remedial Action.
I'll explain a little bit
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about each of those.
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Again, sit~s can be discovered and
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That means if you know of other
reported by ~nyone.
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sites, we'd be glad to hear about them.
Either the
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state or the federal government will look at that and
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make a preliminary as~essment and Site Investigation
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that. is n~q1Jired and determine if t.he site warrants
9
furt.her ~t.\Idy.
For those sites that warrant
furthpr ~tudy we go t.hrough what. is ~alled a "Hazardou~
RAnking
System".
And it is basically a numerical way
t.o rate sit.es so that. you can get. a way to c~mpare
site!" Across the nation t.o make sure that. the federnl
go\-ernmpnt is working on those sites t.hat. are - - that
pose the most potential risk or dangers because there
are so many sites.
Any sit.e that scotes over 28.5
currently goes on the on the National Priorities List.
There are several other ways to
get on. the NPL.
The state can request one site per
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state to go on the NPL wit.hput going through a
hazardous ranking.
And there are certain others cases
t.hat if there is immediat.e threat and t.he s~ore doesn't
rank appropriate then it. can be put on t.he in ~PL.
Again, the NPL is just. t.he
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nation's highe~t priority sites.
At a mininum the ~PL
is updated annutilly.
We are going through a revamp of
the Hazardous Ranking System currently but I think
natienwide there are over twelve hundred sites on the
National Priority List.
Approximately 160 in Region
IV, which is the eight southeast and southern states.
And there are seventeen sites that are ranked in
Kentucky.
There are actually three in Bu}]itt County.
Agtiin,
just to emphasize that the
~hole purposp for the ~ational Priority List and the
Hnzaroous Ranking System is so that the federal
government ~orks on ~hat are potentinlly the ~orst
sites in the nation.
Okay.
After a site is ranked and
put nn thp NPL,
thp goyernment can do ~hat is callpd a
:Remedinl Investigation'.
And it is basically just to
go (HI t
and Jook at thp site nnd dete~mine ~hat the
extent of contamination is.
After we have determined
the extent we .~ill evaul~te those contaminants and see
what risk they pose, if any,
to the public or the
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environment.
~fter the Remedial Investigation
is done and we kno~ basically the extent of the
contamination,
the types of contaminants and what risks
they pose to the public or enyironments,
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~e do a
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Feasibility Study.
And that. is just a st.,udy that
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focuses on what type of remedial alternatives there are
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and which
ones
appear to be more useab1e at that site.
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Again, what
- after we have done
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a Feasibility Study we will go in, after we have
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solicited public comments which we are doing part of
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that tonight, ,we'll review the public comments and
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finalize the decision in a Record of Decision.
And
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that will he a formal document that the Regional
Administrator at EPA,
Region IV, will sign that says
that this is the selected alternative for this site.
Again, you can see it is somewhat
of a long systp.nl.
But after t.he Record of Decision is
is signp.d thp.re is a Remedial Design.
In other words,
therp. is no detailed design when the Record of Decision
is signed.
There will be a detailed design done which
wi 1J
to implement that a1ternati\"e ~"OU
say, YOIJ know,
need to first go in and study the structure of the
soils, do more monitoring, et ceterra.
And then once the design is done
..
generally that design will be bid out.
..Just like you
wouldn't build a house unless you had a set of plans,
the design is just simply that.
It's t~ come up with a
set of plans that you can b1d out.
And then the
Remedial Action, whatever that 1s, is actually carried
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out.
That's pretty much the process.
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With that, I'm going to turn the
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meeting over right no~ to Kim Gates who will go over
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the site background and what we found in the Remedial
5
Investigation.
And that's pretty much it for no~.
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Thank you, very much.
7
MS. GATES:
Hi, everybody.
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I'm Remedial Project Manager on the
I'm Kim Gatps.
q
'Tri-r.ity Site.
And T apologize if I do a little too
milch reading but I am very nervous.
I have never done
one of these meetings before.
I am not a great public
sppaker, I am a better engineer.
The Tri -Ci ty Indu,Stri al Si te, the
SlIpprfund Sit.e,
located in northern Bullitt County,
is
approximately J5 mUes south of Louisville, in the
community of Brooks.
The Site is located south of
State High~ay 1526, on Klapper Road.
The Site was used as an industrial
landfill from late 1964 to late 1967.
The landfill
accepted ~aste from several industries in the
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Louisville area and the bulk of materials disposed of
at the Site reportedly consisted of were scrap lumber
and fiher glass insulation.
drum ~aste and
Ho~e\!er,
hulk liqui.ds \o."ere also disposed of at the Site.
The Si te ~as a source of.
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complaints to local government officials from nearby
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residents during the disposal operations.
The
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complaints were regarding the bad condition of the
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landfill,
explosions, fires, smoke, and offensive
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odors.
A civil lawsuit was filed in November, 1967,
6
against Tri-City Industrial Services and the company
7
agreed to stop disposing and burning of waste 'if the.
8
charges were dropped.
At about the same time, however,
9
a fire erupted at the Site that reportedly burned for
two years.
The Kentucky Natural Resources and
Eln"j ronmental Prot.ect.ion Cabinet,
and I'll refer to
them aR
'the Cahinet' as I go through my talk, the
r.ahinet condur.ted a Site in\"estigation in April 1987,
to determine if the potential environmental hazards of
the Site were great enough for it to be included nn
EP\'s ~ationa] Priorities List.
The Site Investigation revealed
that heavy metals and organic contaminants were present
in on-site soil samples and the presence of
.,.
tetrachloroethene in two springs that were being used
for drinking water,by nearby residents.
EPA started
pro\"iding watf!r to the affected residents and resampled
thp springs to confirm the contamination.
The Site received further
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attention ~hen wa~te materials observed to be seeping
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out of the side yard of the Cox, Sr., residence which
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is located adjacent to the disposal area.
EPA
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condtlcted an emergency removal in 1988 that resulted in
5
the excavation of approximately 165 full or partially
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full drums, 400 gallons of free liquids, and a 1000
7
cubic yards of soil and debris.
8
The Site was included on the
9
National Priorities List in March, 1989, ba~ed
primnrily on the potential hazard from contaminated
grounch,a t.er,
namely the springs.
In July 1989, EPA began the first
phase of a long-term two-part det.ailed study of the
Sit e.
This first phase is raIled 'Remedial
Invest igat ion '.
And the plJrpose of t.he Remedial
Investigation is to characterize the Site conditions,
det.erm:ine the nat.ure of the wast.e, and evaluate the
risk to human health and the environment.
Both phaseR of this detailed study, as well as the
earlier removal, have been funded by the federal
...
Superfund trust fund.
The Remedial Investigation
included the sampling of ground~ater,
surface ~at.er,
sediment, soils, and air.
During the investigation six
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groundwater monit.oring wells ~ere inst.alled and
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sampled.
The installation of seven other wells was
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attempted, but these wells were not completed because
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there was not enough water.
Six surface water samples
4
were-taken f~om Brushy Fork Creek and four springs were
5
sampled with 'a duplicate sample taken from the Cox
6
Spring.
Twelve sediment samples were ,collected in the
7
areas of the springs and Brushy Fork Creek.
Twenty
8
surface soil samples and 25 subsurface soil samples
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And, 16 air samples were collected at
were collected.
three locations.
The three air sample locations were
selected based on the prevailing wind directions and
the locations of the residents.
A detailed discussion
of results of the Remedial Investigation can be found
in the report that has been included in the
Administrative Record at the Ridgeway Memorial Library.
And I'll refer to that when I talk about some of the
documents and the information, I will refer back to the
Administrative Record in the Ridgeway Memorial Library
, wher~ you can look them up.
We are particularly concerned
,.
about the contamination found in the Cox Spring.
Several volatile organic compounds, including
tetrachloroethene, were found at levels above maximum
contaminant levels which are enforceable drinking water
standards developed under the Federal Safe Drinking
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Water Act.
Several of the same contaminants were found
2
at similar levels in the sample collected by EPA in
/1
3
December 1990.
During the Remedial Investigation
4
tetrachloroethene was also found in the monitoring well
5
next "to the Cox, Sr., residence.
6
Volatile organic compounds were
7
not found in the other springs sampled during the 1989
8
investigation.
However, small quantities of
9
contaminants were found in samples collected by EPA
from the Klapper and Cattle Spring in December 1990.
Although the quantities did not exceed the Maximum
Contaminant Levels, we believe that additional
monitoring is necessary in the event that future levels
are higher.
Tetrachloroethene was also
detected at low levels in two air samples.
An
additional sampling is recommended to determine if
there is a source.
One species of PCB and low levels
of polycyclic aromatic hydrocarbons, also now known as
PAHs, were found in One surface soil sample at the edge
~
of the landfill.
Low levels of PAHs wer~ also. found in
one subsurface soil sample in the same area.
And that
subsurface soil sample was from about five to 13 feet
deep.
The EPA believes that further sampling in this
area of the landfill is necessary to determine the
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extent of any contamination.
2
Lead was detected in one sediment
3
sample in a tributar~ of Brushy Fork Creek.
However,
4
additional sediment sampling is necessary in that area
5
also to determine if there is an extent of lead
6
contamination.
7
'EPA conducted an ecological
8
asseSRment in AugURt 1990, along \dth the u.s. Fish &
9
"ildlife Servir.e.
This ~as to determine if Site
reJated contamiilation was causing ecological damage.
The r.urrent impacts ~ere determined to be minimal, but
conUnued monitor.ing was recommended to ident.ify any
furture impacts.
Rased on the results of the
Remedial Investigation and the Baseline Risk
.2\sRessment,
~e have identified actions to be taken at
the Site as the first Operable Unit.
And as an aside,
an Operable Unit is defined as one action or a set of
actions that are taken to address ~ite problems.
An
Operable Unit can include specific site problems such
~
as the contamination in Cox Spring and interim actions
such as further sampling that ~jll be followed by later
actions to address any identified problems.
And we
~ould include these later actions as another Operable
Unit.
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The actions that we have
2
identified to be taken as the first Operable Unit at
3
this Site involve not - - no use of the groundwater and
4
spring water for drinking water purposes and a
5
continued provision of water to affected residents,
6
cleaning up the Cox Spring, further sampling of Site
7
soils, the sediment in ihe tributary of Brushy Fork
8
r.reek and air.
And long-term monitoring of groundwater
9
in the ot.her springs and t.he surface water sediment and
pc-ology of Rrllshy Fork Creek.
If the additional sampling reveals
contnminntion at le\"els that present a human health or
erJ\"i rc)nmen t a I
threat, the actions t.hat
are necessary to
remO\'8
thnt threat will implemented as Operable Unit
# 2.
Glenn Adams is here to answer any
questions you all may have regarding the Risk
Assessment that was conducted as part'of the Remedial
Investigation.
EPA has recently completed second
..
phase of the long-term two-part detailed st.udy of the
Site.
This second phase is called Feasibility Study.
The purpose of the Fea!=;ibility Stuay is the development.
ana evaluation of, cleanup alternatives for the Site
baRed on available information.
Four possible Remedial
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Alternatives ~ere identified to address the findings in
2
the Remedial Investigation.
3
Each alternative was evaluated
4
using eight of the nine evaluation criteria.
The
5
criteria invo]ving community issues and concerns is
6
being evaluated during this meeting and the Public
7
. .
Comment Period which ends June 1.
8
The criteria we look at when we
9
evaluat.e alternatives inc]ude the overall protect:ion of
h 11 man he a 1 t h and t 11 e en vir 0 n men t, com p 1 i an c e ~ i t h s tat e.
and federal and environmental public health la~s, and
reqlJirements that apply or are relevant and appropriate
to the site conditions.
And thp acronym AR\R that you
see there, stands for Applicable or Relevant and
Appropr-j ate Requi rements.
We also evaluate the long and
short-term effectiveness and how wel]
the alternative
reduces the harmful nature of the contaminants, which
we refer to as 'toxicity',
the ability of the
contaminants to move through the environment, and the
..
volume or amount of contamination at the site.
We also
evaluate.how easy the alternative is to construct and
implement, the state acceptance of the alternative, t.he
community acceptance and last, but certainly not least,
the CORt effectiveness of the alternative.
\\"hich
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involves weighing the benefits of implementation
2
against the total cost.
3
The evaluation of the alternatives
4
proposed for the Tri-City Site are described in detail
5
in the Feasibility Study Report that is available for
6
review in the Administrative Record at the Ridgeway
7
Memorial Library.
8
The four alternatives that were
q
developed for the Site are:
Alternative J,. is no
action.
By law, EP\ is required to evaluate a No
Action AJternative to serve as a basis against which
other alternatives can be compared.
Under the ~o
Action .])'lternative the Site would be left as is and no
funns \""ould he spent.
The second alternative in\-o1\oes
limited action which includes institutional control
such as local ordinances, record notice, or some other
appropriate measure to restrict people from using
groundwater or spring water for domestic purposes.
The
provision of drinking water would continue until EPA
~
determines that the spring water is safe for drinking.
This alternative also involves the long-term monitoring
of the groundwat.er and the springs and the surface
water,
sediment, and ecology of Brushy Fork Creek.
l. 0 n f j r mat 0 r y sam p 1 j n g 0 f s j t.' e so i 1 s,t h e sed i men tin
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the tributary of Brushy Fork Creek, and the air would
2
also be condu~ted.
3
The third alternative involves the
4
actions described in the second alternative and
5
cleaning up the Cox Spring by treating the contaminated
6
spring water in a carbon absorption system.
This
system is essentially a filtration system that contains
8
an activated carbon filter.
The contaminated spring
9
".ater wnuld pass through the system and the volatile or
orgr:lIljc compounds would stick t.o t.he carbon.
The -.;ater
that leavRs the system would be sampled regularly to
det.ermine when the filter needs to he replaced.
The
USRQ fil ter wnuld either be treated for reuse. or
properly diRposed of.
The fourth alternative also
j 11\"0] yes t.he act j onR des~ribed j n the second
alternative in treatment of the ~ontaminated spring
water.
However,
this alternative consists of aerating
the contaminated spring water to remove the
contamination.
,.
The aeration system would consist
of what we are looking at this point, is approximately
30 concrete steps that -.;ould bR constructed for the
spring -.;ater to pass over as it runs do~n the hil].
The purpose of the steps is to increase the mixing of
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the air and water so that the volatile organic
compounds leave the water and enter the air.
Since
this treatment method is not- well-established, a study
would have to be done to determine .if it would be
effective and if the contamination entering the air
would also require treatment.
These alternatives were described
in the Proposed Plan Fact Sheet and discussed in detail
in the Feasibility Study Report.
Based on the analysis of
alternatives conducted during the Feasibility Study we
recommend Alternative 3 to address the actions we have
determined to be needed at the Site.
As I mentioned previously,
Alternative 3 involves institutional controls to
r~strict domestic use of the groundwater and ~pring
water, provision of alternate water to affected
residents, long-term monitoring and Confirmatory
Sampling.
EPA prefers the third alternative
,.
for the following reasons:
Number one, it is the
alternative that is most protective of human health and
the environment.
It provides reliable protection over
time with minimal risks during construction and
implementation.
It prevents contamination of Brushy
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Fork Creek and the air. It utilizes a permanent
solution. It uses a proven and widely available
technology that is easy to implement. It reduces the
toxieity, mobility and volume of contaminated spring
water through treatment and it is cost effective.
And
it satifies EPA's preference for treatment as the
principal element.
And though we prefer Alternative 3 -
at this time, the selection of this alternative is
preliminary.
Based on new information or public
comments, EPA in consultation with the Cabinet, may
later modify this alternative or select one of the
others I have presented or that was discussed in the
Feasibility Study before.
After the Public Comment Period
ends on June 1, 1991, EPA will review and consider all
the comments received frpm the community.
A document
called the 'Responsiveness Summary',' that summarizes
EPA's responses to the comments received, will be
issued with the Record of Decision this summer.
The Record of Decision documents
,.
EPA's final choice of a remedy and we anticipate
issuing it in July of this year.
After it is signed by
the Regional Administrator, the Record.of Decision will
be included in the Administrative Record at the
Ridgeway Memorial Library.
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And if you would like further
2
information about the Site, these people can be
3
contacted:
Suzanne, as you know, is here and I am here
4
also!..
These addresses and phone numbers are also
5
listed in the fact sheet.
And with that, I'm going to
6
turn things over to Suzanne Durham to talk to you about
7
Community Relations Activities.
8
Thank you.
9
SUZANNE DURHAM:
Good evening.
I'm Suzanne Durham and I am the Community Relations
Coordinator for this Site.
Choosing the final response
action is perhaps the most important decision made at
any Superfund site.
EPA's job is to analyze the
hazards and to deploy the experts.
But the agency
needs citizen input as it makes choices for affected
communi ties. .
Because the people in the community with
the Superfund site are those most directly affected by
hazardous waste problems and cleanup processes, we
en~ourage citizens to get involved in that decision
making process.
Public involvement and comment does
.. .
influence EPA cleanup plans by your providing valuable
information about site condition, community concerns,
and your preferences.
We recently issued a Proposed Plan
Fact Sheet which summarizes the Remedial Investigation
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and Feasibility Study.
We also sent the Administrative
2
Record to the Ridgeway Memorial Library.
And that
3
Administrative Record contains all the documents that
4
we uaed in developing our Proposed Plan and Preferred
5
Alternatives.
6
I hope you have had the
7
opportunity to go by that library and look at the.
8
Administrative Record, if not, please do so and then
9
ask your questjons tonight and submit your written
comments to the Agency.
We are soliciting comments on
all alternatives under consideration.
The comment
period began May 2, and extends through June 1, 1991.
If you need additional time we can grant an extension.
We need you to submit a request for that extension
within two weeks of tonight's meeting however.
After the Public Comment Period
ends the EPA prepares a document called a
Responsiveness Summary.
And that's where we summarize
your comments and questions and then our responses to
you.
The Record of Decision, which is the document
..
describing in detail the cleanup action to be used,
will be signed after careful consideration of state and
public comments.
When the Record of Decision is signed
by our Regional Administrator in Atlanta, a notice will
be published in your local newspaper.
And at that
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point the Record of Decision and Responsiveness Summary
2
would become available to the public as part of the
3
Administrative Record.
4
An excellent opportunity for
5
community involvement is through our Technical
6
Assistance Grant or TAG Program.
Congress recognized
7
that our documents were quite lengthy and technical in
8
nature and we can now provide the opportunity for a
9
community group in to receive a grant in the amount Of
Fifty Thousand Dollars to hire an expert to interpret
our data for you.
In summary, the goal of community
relations is to keep you informed and involved in
complex decisions which will affect your community.
Kim, and I, are your two contacts at EPA and we want
you to feel free to contact us anytime you have a
question or a concern.
Right now, I'll ask Brook
Dickerson, our attorney, to speak with you about the
Enforcement Process.
...
BROOK DICKERSON:
Thank you,
Suzanne.
Can everyone hear me? Okay. My
name is Brook Dickerson. I'm the Assistant Regional
Counsel for Region IV. As Harold mentioned, those are
...-..d
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the eight southeastern states which of course includes
2
Kent.ucky.
3
As you have just heard, the EPA
4
has ~roposed a plan for cleaning up the Tri-City
Industrial Site.
The public will have an opportunity
6
to comment on that proposed plan.
And after those
7
comments are received and looked at by EPA the Regional
8
Administrator, for Region IV, will make the ultimate
9
decision on exactly what remedy will be required to
clean up t.he Sit.e.
J am here to talk about how we get
the ball rolling in implementing that remedy.
A major goal of EPA is to have
sltes cleaned up by those persons whom the law has
determined are responsihle for cleaning up the sit.e.
The law set.s forth four groups of persons who are
~ete~mined to be potent.ially responsible.
Thc)se groups.
include either, number one,
the current owners and
operators of the property.
Number two,
either the owners or
operators of the property at the time that the
..
hazardous substances were initially released or during
the release.
The third group of potentially
responsihile parties are transporters.
Those persons
who were involved in transporting hazardous substances
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to the site.
2
And the fourth group are those
3
persons who we call
"Generators".
Basically, they are
4
the persons who arranged for the disposal of hazardous
5
substances through the transporters and they - - and
6
those substances eventually .ended up at the site.
We
7
call these different groups of persons Potentially
8
Rp.sponsible Parties, or PRPs for short.
This means
9
that they are potentially liable for performing the
cleanup or for paying the cost of the cleanup generally
is more appropriate.
EPA attempts to identify as many
PRPs as possible and as early as possible in. the, you
kno,,', scheme.
Some parties may no longer be around.
Some parties may not have the financial resources
available to participate in a cleanup of the site.
And
some parties which would - - who would otherwise be
potentially responsible may have valid defenses which
are available under the law.
If the PRPs are
id~ntified early enough EPA notifies them of the
.-
potential liability and offers them the opportunity to
participate in the. cleanup.
As you have seen,
it is a very
long process and ~e .try to get private parties involved
J
as early as possible.
If they have not been identified
....~j
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beforehand, or if they were identified but declined to
2
participate, EPA notifies them again after the Record
3
of Decision which is document outlining the fi~al
4
decision on what remedy will be appropriate.
5
.This notification is called a
6
'Special Notice Letter'.
The Special Notice Letter
7
does three things.
First it gives the potentially
8
responsible parties more information about the site.
9
Secondly, it gives them the opportunity to perform the
work or to offer to pay for th~ work.
Third, it places
a moratorium on EPA act.ivities for 60 days.
No~ the moratorium period means
t.hat. EPA ~i]l restrain from activities which ~ould
incur additional costs for cleaning up the site unless
Cln emergency comes up and act.ion is required.
The
reason ~e do. that is so that the EPA and the PRPs can
try to negotiate a set.tlement.
The PRPs have 60 days to show the
EPA two things:
First, they have to demonstrate to the
EPA that they have a good faith intent to either
,.
perform the Remedial Action. or to pay for that action.
They must also demonstrate. to EPA's satisfaction that
they are capable of doing the work correctly and
competently or that they are capable of financing the
cost associat.ed ~ith the ~ork.
If they can demonstrat.e
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these two things to EPA that's cal]ed a good faith
2
.offer.
If the good faith offer is received ~ithin that
3
first 60 day period then EPA will extend the moratorium
4
for a second 60 days.
So, we end up with a 120 days of
5
a negotiation period or approximately four months.
6
This is so that EPA and the PRPs, either all of them or
7
~hichever ones want to g6 forward in the negotiations, -
8
can ~ork out the details of the agreement.
EPA ""ill
9
invite the state and the natural resource trustees to
participate in the negotiations if they choose.
If an
agreement iA reached it is spelled out in a document
called a 'Consent Decree'.
One thing r'd like to make clear
is that when we negotiate with Potentially Responsible
Parties we are not negotiating ~hat work wil] be done
at the site.
That work is required by whatever has
been inc]uded .in the Record of Decision.
v,'e are
negotiating other types of iss~es, usually legal
issueR.
For example if there are past costs that might
have been incurred before we got into the Remedial
..
Investigation or the Feasibility Study that Kim
described" and those are still outstanding, we might
~ant to negotiate those kinds of costs.,
The Consent Decree must be
approved by .the Department of Justice.
That's required
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After the Department of Justice approves
by the law.
2
the Consent Decree it is filed with the court.
This
3
usually takes approximately forty-five days.
After it
4
is filed with the court it is a pUblic document and the
5
pUblic is invited to look through the terms of the
6
specific agreement and to comment on those terms.
If
7
EPA receives comments which cause it to want to change
8
terms of the agreement, it will amend the Consent
9
Decree and then move that it be issued as final bY the
court.
If no amendments are required then the Consent
Decree becomes final as it stands.
Now,
once this is
entered into as final by the court, it's an enforceable
document.
So that if there were ever any problems EPA
',.;nuld just go straight to the court to have it enforced
as if it were a law.
This process usually takes an
additional thirty to 45 days.
It can take longer if
Public Comment raises substantial concerns or points to -
new issues which need to be considered.
Now, if the EPA and the Potential
Responsible Parties have not been able to come to any
~
type of an agreement, EPA has two options on how to
proceed.
First, it can issue an order to the
Potentially Responsible -Parties ordering them to
perform the work as set forth in that Record of
Decision.
This order is called a 'Unilateral
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Administrative Order.' and it is also enforceable in
2
court but not immediately because it hasn't been
3
entered as final by the court.
So, it doesn't take
4
long-to issue the order but if we needed to go in to
5
enforce it because the Potentially Responsible Parties
6
continue not to be cooperative then the trial may take
7
some time.
8
EPA's second option is go in and
9
perform the ~ork itself using monies provid~d by the
Superfund ~hich was the trust fund that Kim mentioned
earlier.
After that, EPA would most likelY sue those
PRPs for reimbursement of its costs.
This process can
t.ake sorne time but. it important to t.ry to get. t.hose ~ho
are responsible for cleaning up the' si te to clean up
the site.
It'g in our interest t.o look
to them expend
resources before using up the very limited dollars
~hich are available in the trust fund.
For .every site
where we can use Potentially Responsible Party dollars
or private funds the more money is left in Superfund to
clean up new sites where there may not be any PRPs left
~
or there may not be any PRP money.
One thing I would also like to
mention is that even if Potent.ially Responsible Parties
do agree to do the work, EPA will always oversee all of
the work t.hat is done to ensure that it is done
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correctly and competently.
If EPA ever determines that
2
that work is not being done correctly, or if new
3
information is discovered which leads EPA to determine
4
that-a change is required, EPA can always take back
5
authority over the site and run the cleanup itself.
6
If you have any questions during
7
the question and answer period, I will be glad to
8
answer them.
9
Thank you.
HAROLD TAYLOR:
What I would
like you to do, if possible, is stand up and state your
full namoe.
And if it's a difficult name, spell it.
I'd appreciate you spelling it.
Direct your questions
to me and then either I'll try to answer them or direct
them to the appropriate party for them to answer.
So, if there are any questions.
Yes, ma'am.
RUTH KLAPPER.
I am Ruth
Yes.
Klapper.
HAROLD TAYLOR:
Yes,o ma' am.
..
RUTH KLAPPER:
I'd like to
find out what about the health hazards in the future
for the future generations of our children.
HAROLD TAYLOR:
If I could,
what I will do is turn that over to Glenn Adams.
But
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I'd like to say that we have done a Risk Assessment of
potential hazards to the community over the short and
the long-term.
And I'll let Glenn sort of go over our
process and what we think the health hazards are.
. GLEN ADAMS:
Yes, ma'am.
What we do when it comes to Risk Assessment.
The
Remedial Investigation goes out and takes the samples
of the soils, the surface water, the sediment, the
groundwater; we do different things.
We go through and
we do a full-blown Risk Assessment which takes into
account all the different exposure scenarios for a
pathway, or exposure pathway is another term.
For that
to be complete it takes exposure to contamination, say
with groundwater or springs, which isn't the case here
at Tri-City.
Someone has to be drinking that water
~hich was occurring at the time of the discovery.
That's why that was stopped by alternate bottled water.
So we went through and did the
Risk Assessment looking at the soils; the surface soils
which would be exposed.
Say if children were out there
..
playing,or adults getting incidental ingestional where
they have dirt on their hands and go to the mouth or
something; dermal exposure just where it is on the
hands absorbed in through the skin: the ground~ater was
looked at for ingestion.
And this is all based on a
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lifetime exposure which is 70 years.
We looked at 365
2
days a year that this is occurring.
3
Also at the Tri-City Site we
4
looked at the cattle to see if the cattle were raised
5
on the Site and that being ingested for 365 days a
6
year.
If a vegetable garden was grown on the site and
7
that 365 days a year.
Out of all the exposure
8
That .is
scenarios water was the greatest risk there.
9
why we implemented this procedure in trying to clean up
the groundwater or the spring water there.
The only other one that indicated
a problem was the cattle or vegetable gardens.
That
was based on one surface soil sample that was on one
edge of the Site that the soil sample was taken.
We
think if, you know, there is a possibility there could
be a problem there so we're going to go out and
resample that in the next part of the plan and try to
find out if that was an anomoly or just one occurrence.
Because there was twenty. samples taken out there and
that was the only one detected.
,.
We have this quantification limits
which are like
- - I'm trying to think - - our
instruments can detect - - they can detect below that
but if we are not exactly sure what concentration.
They just know it's there and it's an estimated
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concentration.
2
The three - - the two different
3
types of chemical that were detected, one of those was
4
belo~ detection and the other one was just above.
They
5
were below our action levels which, when you clean up
6
sites, we usually go to at this time.
So what we want
7
to do is go back out there, take some samples around
8
that area and try to determine if there is some
9
contamination out there, high or lo~.
And at that time
we would go back and do another Risk Assessment on it
t.o d~termine,"'hat levels ~e need to clean that up.
RUTH KL.~PPER:
Well, in other
~ordR, we are not
supposed t.o be using our garden?
I
mean, soil was taken and ~e were never given a result
of the soil testing.
GLEN .~D.~!'-1S:
Like I said,
t.here was only one place out there that any
contamination was found at very low levels.
It does
not indicate an unacceptable risk' at this time.
That's
why we want to go out and take some more samples to
..
determine that.
Like I said, these are based on
seventy years; not on three years or seven years even.
So ~e stretch it nut over a seventy year period to
1
determine whether it is acceptable or not. at the levels
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it's at.
2
RUTH KLAPPER:
A seventy yea\-
period?
4
GLEN ADAMS:
Yes,
ma'am.
5
That's the average lifetime.
6
Meaning
BROOK DICKERSON:
7
everyday for seventy years?
8
GLEN ADAMS:
Yes.
9
Also, \o:hat
RUTH KL.~PPER:
about the remaining material - - waste material still
on the Cox property?
HAROLD TAYLOR:
Are you
referring to the debris?
RUTH KLAPPER:
The stuff on
the ground.
HAROLD TAYLOR:
I'm sure you
\o:ere there when the removal took place in 1q88.
RUTH KLAPPER:
Right.
HAROLD TAYLOR:
As part of
that removal they went around with the backhoe and
;-
trenched areas that had the highest anoma1ies according
to the magnetometer studies that were done.
And they
basicaJly found insulation,
wood, ash, 'empty drums,
basically nonhazardouR garbage materials.
So, based upon the trenching and
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based upon the sampling that we have done we don't see
2
the need to remove any more materials.
3
if you'll read the
We also,
4
Proposed Plan and Feasibility Study, and analyzing some
-5
of the areas of topography.
And in reviewing the
6
sample results that we have there is some other areas
7
out there that they think need further
8
And the large part of the monetary
characterization.
9
expenditure where the first area of the community was
essentially done is to go back and look at those areas
in more detail to make sure that there is no more what
we call source material; no more buried hazardous
materials.
But based upon the study that we
hin-e done toda~- and the analysis that we ha,.e done
~nday, the materials that are there in the areas that
we have looked at don't justify removal.
RUTH KLAPPER:
Well, some of
the places though that weren't dug up were places that
were burning back when it was burning.
t'"
So that's \oIhy I
wondered what would still be under there now.
HAROLD TAYLOR:
ma'am.
Yes,
And,
I know what - - I think what you're saying
again,
is to be a hundred perr.ent sure that there were no
materials there you would need to dig the \oIhole area
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up.
But what we have done is based upon, again, the
2
sediment samples in the areas outside of the Site,
3
based upon the monitoring wells that were put in, based
4
upon-the samples of the springs, based upon the
5
subsurface soil samples and surface soil samples, we
6
haven't found anything that warrants removal or
7
treatment of this source material.
8
We do still have contamination in
9
the springs.
That contamination has varied somewhat
since it was originally taken.
Some of the
contaminants have actually decreased since the removal.
We're not sure enough to say that that's because we
have got~en all of the material out or whether there is
still source material left there at the Site.
So, what we are proposing is to
going in and remediate that spring, continue to sample
the springs, go in and do more investigation of the
Site and make sure there is not more source.
Even to
the taking of samples in the area where the removal was
done.
~
So, we are not confident.
If we
were confident we would know, quote/unquote, "No source
material left", we would just say we're going to
remediate the spring and we'll require that no. one
drink the water and that we are going to supply bottled
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~ater for those people that are impacted and ~e are not
2
going to do any more work.
We're not going to do any
3
more sampling.
But we are not certain and that's why
4
we are proposing quite a bit of additional sampling at
5
the Site.
6
Based upon what we know today we
7
don't think that - - and the results, there is any need
8
for the removal of the material that we have sampled so
9
far.
RUTH KLAPPER:
So, based what
YOIJ kno,", today then the value of our property hasn't
gone down any?
HAROLD TAYLOR:
.~gain, I'm a
scientist and I am rea]ly not a real estate person.
So
as far as property values, I really can't speak to
that.
Obviously, the Site was a disposal site.
The
Site is on the National Prioiities List.
It is a
Superfund Site.
How that impacts the value, I am
certainly not qualified to say.
..
RUTH KLAPPER:
Thank you.
HAROLD TAYLOR:
Yes, sir.
Would you state your
name,
please?
EDGAR RASH:
Edgar Rash.
HAROLD TAYLOR:
Edgar Rash?
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How do you spell your last name?
2
EDGAR RASH:
R-A-S-H.
3
HAROLD TAYLOR:
Yes, sir.
4
EDGAR RASH:
You say
.5
insulation was found.
Was it asbestos?
6
HAROLD TAYLOR:
It was fiber
7
glass insu)ation that was found.
We did not find
8
asbestos.
9
EDGAR RASH:
I was just
wondering.
Because when - - I guess back in the 1960's
or '70's,
when they made fiber glass it was asbestos.
And r was just curious.
HAROLD TAYLOR:
Well, you
kno\\,
back in that time there \\as asbestos insu]ation
made.
But at the same time there was also fiber glass
iflsulation and rock wool insulation, you kno\\, was also
made.
Based on the sampling results that
we have to date, there is fiber out there.
Based upon
our review of what's out there, the guys that dug up
,.
the trenches, it is not an asbestos fiber.
EDGAR RASH:
Well, how long
will this sampling take ~lace?
How many years are you
talking about?
HAROLD TAYLOR:
Maybe if I
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'could get Kim to go over the sampling that we have.
We
2
have really several different programs.
One is the
3
Confirmation Sampling Program to go out and make sure
4
there aren't other source materials out there.
That
5
sampling could be done, you know, basically in a year's
6
time like - - about like the Remedial Investigation
7
over the same time frame.
8
we are proposing to monitor
Now,
9
the springs that are contaminated now for up to thirty
years.
Now,
if the spring levels still continue to
decrease and the levels drop off to acceptable drinking
water standards we would monitor that in sufficient
long enough time to make sure that it is safe.
But
then once we sample it long enough, in our minds we can
say stop the monitoring and remove the carbon
filtration.
We also have an ecological study
monitoring.
We have some sediment.
Might go into
that.
KIM GATES:
I can go
~
through it real quick if you are interested.
This is a diagram of the site.
What we plan to do is we got a lead contaminated sedi-
ment sample on the tributary here of Brushy Fork Creek.
So we are going to do some more sampling around that
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hit of lead to determine if we have an area there that
2
warrants excavation and removal.
3
We found a couple of ,air samples
4
that-had the tetrachloroethene in them along the edges
5
of the landfill.
So, we're going to do some sampling
6
along the edges of the landfill here to determine if
7
there is a potential source there that we need to
8
remove.
9
~e want to do some more sampling
along these edges also to determine,
again, if there is
a source there of contamination that we need to remove.
And ~e are going to do some soil sampling on-site.
This is a compiled figure.
It was
basically a compilation of two area photographs that
~ere taken in 1966 and '67, when the disposal
operati6ns were occurring.
And these were areas that
\<,'e saw on
the photographs as active areas.
We don't
really have that much sampling in these two areas.
And
we don't know that they are drum storage and disposal
areas.
That's,
again, there is a Question mark after
..
that.
They are distrubed areas and we couldn't tell
~hether. or not they were just areas that were dug up
for fill material or ~hether or not there were drums
there.
So "E' want to do some more sampling up in these
areas.
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'1
And we wanted to do some sampling
2
along the edge of the landfill where we found the PCB
3
contamination;
the one sample of PCBs.
4
And also, too, this is a figure, a
5
very - - how do I want to put it?
6
HAROLD TAYLOR:
It's a sketch.
7
KIM GATES:
A sketch.
8
That's good.
A sketch of the Site that was done during
9
the - - for the removal report.
And the trench at the
side of the Cox home, that's where the hundred and
sixty-five drums were removed.
But we would like to do
some more sampling in this area to determine .whether or
not that we got all of the contamination out of this
area.
Because we believe that this is the source of
the contamination in the Cox Spring.
If indeed there
is another - - more material there that could be
contributing to contamination, we would like to do some
more sampling in this area also.
So, that's really about it as far
as the additional sampling we would like to do.
~
EDGAR .RASH:
What type of
sampling?
You said you had PCBs?
KIM GATES:
We had one
species of PCB found.
Yes.
EDGAR RASH:
What quality?
J
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HAROLD TAYLOR:
It was - -
2
well, Aroclor 1260, I believe.
And that's half a part
3
per million.
So EPA's kind of the most conservative
4
standard for cleanup of a residential area would be one
5
part per million.
6
EDGAR RASH:
That's about
7
half.
8
HAROLD TAYLOR:
But I think it
9
still warrants us going out there.
EDGAR RASH:
What would be
your all's - - how would you all handle the PCBs
through the filtration that you all were discussing
earlier?
HAROLD TAYLOR:
Well, if it is
PCBs in the soils we only would have to go to the
Second Operative Unit of the Feasibility Study.
PCBs
can, you know at low levels, can be solidified and
massed so 'that they're maintained and don't move or
migrate.
They can be buried somewhere.
If they're over certain levels,
..
over like five hundred parts per million, they have to
be incinerated.
That's the law.
You can isolate PCBs
if they're on the surface and low levels it might just
be necessary to just cap them in place if that's the
only vector, so to speak.
There are several different
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It depends on what levels are found.
ways.
2
EDGAR RASH:
I know PCBs
3
don't break down.
4
HAROLD TAYLOR:
That's right.
5
Well...
6
EDGAR RASH:
(INTERRUPTING)
7
The .only true way is to do it through
8
incineration.
q
HAROLD TAYLOR:
Again, it
rea] 1 y depends on ho~' - - you kno"" ri ght now we found
point-four or five, or something like that.
And that
is not - - again, that's not two untypical of a lot of
areas already since we used Pr.Bs so widespread in our
country for years and years and years.
It's not too
untypical of just virgin type areas, some",hat.
Yes, ma'am.-
Your name, please.
SHARON BURBA:
Sharon Burba.
HAROLD TAYLOR:
Yes, ma'am.
SHARON BURBA:
You're talking
about the Site. and how the testing was corning out and
..
it's just above or just below what you all consider to
be okay.
If it had of been done fifteen years ago
would it have been the Same or would the testings have
proved to have been higher?
Would it have been
worse?
I
HAROLD TAYLOR:
Again, I
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really can't say.
That's hard to spec~late on.
When
2
you are talking of volatile organic compounds that are
3
up on the surface perhaps fifteen years ago, obviously
4
if it is volatile just by the definition of that word
5
that it would volatilize to the air and not stay in the
6
soil for a period of time.
So, if there were solvents,
7
say, on th~ ground they would be high at that time and
8
over
time they would either volatilize to the air or
9
they wouJd seep down to the groundwater.
10
But really, I can't speculate on
11
what the levels would have been at this specific site.
SHARON BURBA:
Can you tell
me exactly ho~ long EPA has known about this; about the
problem?
HAROLD T.:a. YLOR :
To the best of
my knowledge ~e were notified in 1988.
SHARON BURBA:
EPA did not
know before 1988?
HAROLD TAYLOR:
Again, we were
as, I understand jt and as I recall, the information
..
carne to us from the state about the Site in 1988 and
that is - - that was the contamination of that spring
water.
Which we went out to look at, w~ sampled and
found that there was indeed contamination of the
spring.
We provided bottled water to those that
were
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drinking the water and then found the drums on the Cox
2
property and removed those drums.
3
Yes, sir.
4
NED FITZGIBBONS:
Ned
5
Fitzgibbons, with the Health Department.
Two questions
6
really.
First, in terms of the cleaning up of the
7
Cox's Springs through the carbon absorption, I know
8
looking at the original - - the treatment itself
\.'p"re
9
Do you have any kind of a
and then monitoring there.
time frame in terms of approximately how long it would
take to make that spring,
say safe to drink from 'the
time you start; less than thirty years in other words?
HAROLD T.?>. YLOR :
Again, you
know,
I can speculate but I really - - groundwater
clean up - - and I'd ask Tony Able to comment.
Groundwater treatment is a fairly
complex technology at best.
The levels that we have
seen over the time frame that we have been looking at
it, at least we tend to say they have decreased over
that time frame.
If we remove, you know, the majority
..
of the source, and that should continue, ~he treatment
would not go on for the whole thirty year period.
If
thp.re is still a source out there, you kno..., 10\..' Jevel,
it may go thirty ~ear period or it may take longer.
Tony, do you have anything to add?
\
d
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TONY ABLE:
I can give you an
educated guess just from being involved with these type
of sites and fthat I think might be happening.
If we have the contaminants
removed from the soils, if the new soil samples don't
show any more sources of contaminants, then that means
that the contaminants ~re probably still in the "rock
and the limestones on top of the hill there.
.A.nd these
contaminants,
they will be flowing through smaller
cracks in the rock.
And the rock can clean itself up
faster or contaminants don't have the tendency to ~ti~k
to the rock as well as they would be the soil.
Say if we had a drum of soil
setting here and we poured some r.ontaminants in it, and
a drnm full of rocks sitting here and \oOe pour seime
r.ontaminants in it, and allow the rain to wash over
them for severa] months, the rocks would he washed nff
and cleaned up faster than the soil would.
So, in this case if we don't find
anything in the soil, it is probably still in the rocks
and it will flush itself out.
Okay.
NED .FITZGIBBONS:
You say
quickoer in UJat last word.
Quicker is what?
TONY ABLE:
I was talking
to Harold today and this is still an educated guess.
I
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would say within ten years, provided there are no soil
sources.
The levels aren't substantially higher than
the drinking water standards that are established right
now. - So, we don't have that far to go.
Okay.
HAROLD TAYLOR:
Yes, sir.
Your name, please, sir?
KEVIN HEATH:
Kevin Heath;
H-E-A-T-H.
Can you tell us what was in the drums and how
far down underneath the drums did you excavate to find
out?
Did you dig down to uncontaminated earth and stop
and what was in the drums?
That's my two questions.
HAROLD TAYLOR:
I might get
Kim to speak a little bit about what was in them.
We
know PCE was the contaminant we found in the
groundwater and we also found sludges and paints and
those kinds of things.
The removal that was done, again
there was obviously the drums, some liquids that were
.
found, and there was contaminated soil that was
removed.
I don't know how familiar you are with the
Site but it doesn't take too far, particularly in that
area, to get down to bedrock.
The removal was done to get
obviously all the build-up of sludge in the soil, the
~
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drums that ~ere found.
And there ~ere confirmation
2
samples taken to see ~hat the levels ~ere in the soils
3
at the time they.qujt digging.
4
In retrospect~ on looking back at
.5
the site sampling that ~as done at the time, we in the
6.
Remedial Program, which is more concerned with the
7
long-term impact of, say, the groundwater, we're not
8
satisfied that the sampling that was done ~as
9
sufficient.
It ~as our o'-'n sampling.
\o,'e 're not
satisfjed that that sampling '-'as sufficient to give us
the kind of ans'-'er '-'e need to say ~hether that area is
tota11y clean or ,-,hether additional soils need to be.
removed from that area.
So in fact, Kim, you may kno'-' a
ljttle hjt more ahout the materials that
found.
were
KI~I Gl\TES:
The drum
materjal jncluded silicone and paint wastes and the
analysis revealed metal contaminants and some
semi-volatile organic contaminants.
And if you want
some more detail on that the Emergency Removal Report
is in the Administrative record at the Ridgeway
Memorial Library.
Just for your information too, it
'-'as - -
the trenc~ that ~as dug that removed the - -
for the removal of the drums is thirty feet long by
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t~e]ve to fifteen wide, and ten feet deep.
And they
2
had - - in order for them to properly dispose of the
3
soil that was taken out of the trench, .analyses were
4
done_on the soil to determine whether or not it was
5
hazardous and where it would need to be disposed of.
6
Again, there is more information
7
on that in the Administrative Record.
8
KEVIN HE.?o.TH:
Thank you.
q
HAROLD TAYLOR:
Are there any
10
more questions?
Yes, sir.
NED FITZGIBBONS:
Just one other
then.
Something that I raised about it earlier
regarding the state acceptance or lack thereof,
regarding the technical information about the Site.
Since Mr. Millanti and Mr. Padgett
are here,
I know this is your meeting but I'd like to
hear from them ~hat more information they would need in
order to agree with essentially ~hat you're shooting at
in terms of removal and whether or not there is going
to be some head knocking on it.
I don't mean to put
you on the spot, guys.
BOB PADGETT:
I'm Bob
Padgett and I'm with the State of Kentucky.
I guess
Ned is referring to in the fact sheet the State
Acceptance portion that indicates that the State is not
..,..
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in agreement with EPA on the remedy at this time.
2
There is two basic differences
3
with the State and the EPA on this particular project.
4
It first deals with just the way the two agencies view
5
the Superfund and its mandate to clean up a certain
6
level or to which laws apply to state or the federal
7
governments.
8
EPA views this in one context to
9
take it down to certain action levels based on risk to
human health and environment.
The State generally
vie\o."s cleanup at the background level or to a risk
based number but the way we arrive at the numbers
diffE'Ys.
And so :it is the way the agencies handle that
sort of information where we differ.
The bottom line is in that respect
is that we generally require cleanup to a more
stringent level than the EPA does and there is a
difference of opinion how that is handled.
To ~nswer the question more
directly, what more information would be required.
We
would - - the usual phrase we look at in cleaning up a
site when we characterize it as a site, is figure out
exactly what is there.
The phrase we usually use is
determine the vertical and horizontal extent of
contamination.
And it was the State's opinion that the
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sampling done to date was not adequate in all areas.
2
They apparently indicated this and a need for
3
additional sampling.
That falls back then to the
4
difference between the way the agencies handle that.
5
The State does not deem, and we have said in the
6
comments that we have sent to EPA, that it is proper at
7
this time to issue a Record of Decision which says that
8
this is the remedy if there is not enough information
9
to say what needs to be remedied.
NED FITZGIBBONS:
So, you just
need to think that the study needs to go on longer
before the final Record of Decision is made.
BOB PADGETT:
There are two
basic things to handle this information.
The first one
is when a decision is made to what level is the site
being cleaned up by that decision.
In other words,
how much information do you have to make the decision
that you are making.
BOB PADGETT:
The other
phrase we've used here is how clean is clean?
The
agencies have a disagreement over how clean is clean.
HAROLD TAYLOR:
And then I'd
like to point out that the disagreement that we have is
not just over Tri-Cities.
This disagreement is
statewide.
Basically the sites have been ongoing since
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1
1988, beginning with the B.F. Goodrich/Airco Site,
2
which we are in current disagreement on and have yet to
3
settle on that.
I think if we could ever come to terms
4
perhaps with those sites that we will be in a better
5
situation to handle the sites in the future.
But until
6
we do, we are continuing to try and work with the state
7
and resolve our problems as best we can between the two
8
agencies.
9
Yes, sir.
Your name,
please?
PEWEE MCGRUDGER:
My name is
McGruder.
Local resident.
How far downstream from
these springs is pollution going?
HAROLD TAYLOR:
Well, again, I
may refer to Kim again to back me up here.
You're
familiar with where the springs are on the Site?
PEWEE MCGRUDER:
Yes, sir.
I
drilled wells for thirty years.
HAROLD TAYLOR:
You know, the
sites are fairly high up on the topography of the
areas.
You might show us - - the springs
are high up on the topography of the area.
The creeks
are down at the bottom of the topography.
As part of
the Remedial Investigation we did sample upstream and
downstream and right in the area where those streams
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1
were discharged.
Obviously the springs themselves are
2
contaminated but by the time the water transverses down
3
the banks, enters the creek and is djluted with the
4
waters in the creek, you basically can't find a problem
5
in the creeks down below the Site.
6
PEWEE MCGRUDER:
Your all's
7
basic concern is the underground water?
8
sir.
HAROLD TAYLOR:
Yes,
9
Do you realize
PEWEE MCGRUDER:
that for Two Million Dollars that between thirty-five
and forty miles of water line could be run througho~t
that area and would solve that problem?
HAROLD TAYLOR:
Well, let me
say that the Two Million Dollars you see there is not
/'
for just providing water to those residents and for
actually even treating the water that is there.
A great majority of that money
that you see is for additional testing and sampling
that we are doing today.
But we did look into - - one
of our problems is how to provide water to the impacted
people in the most cost effective way.
I think you're
correct for prob~bly Two million dollars, if that was
the only thing the agency had to be concerned about, we
could run a water line to provide those residents that
are on that Site with water.
But we would still have
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the additional sampling that we need to do and the
2
monitoring that we need to do.
3
So, I agree with you that if all
4
we had to do was provide water to the impacted
5
residents we could do that for the money.
6
PEWEE MCGRUDER:
You could run
thirty-five miles.
You could run the whole area out
8
there for Two Million Dollars.
9
Well,
again,
HAROLD TAYLOR:
we have looked into what it would cost.
But you. are
probably right about running water lines but obviously
you have to get the water up on top of that hill
somehow and have a reservoir for that water.
PEWEE MCGRUDER:
Do you have an
estimate of what that would run?
HAROLD TAYLOR:
You know, Kim
might - - I know you have talked to people about
running water lines to that area.
You might look it up
real quick.
KIM GATES:
Yeah.
I did a
little bit of research in this - - into this so I could
speak intelligently about it.
I talked to a Mr. Tad
{sic} Burke, of the Kentucky Turnpike Water District.
And he told me it would cost about 1.5 Million Dollars
to get water lines up to the top of the hill to where
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the residents are located that are affected.
And we
?
are looking at right now at an annual cost of $2200 to
3
provide water to three families.
4
PEWEE MCGRUDER:
How many feet
5
from the top of the hill is it to this Cox property?
6
I don't
HAROLD TAYLOR:
7
understand the question.
8
PEWEE MCGRUDER:
Well, how far
9
from the top of Rrooks Hill, back, are we talking about
to these properties that are contaminated?
KIM GATES:
Well, from
~hat ~e have been able to tell, these properties are
located at the top of the hil]; up a knob.
PE\,.EE MCGRUDER:
Two and a half
miles from the top of the hill.
H.\ROLD TAYLOR:
You're on the
top of the area that you're at.
Rut there is an area
that is higher.
RUTH KLAPPER:
He is talking
about as you come up Brooks Hill Road.
Frc>m the top of
this hill, to there, to our property.
PEWEE MCGRUDGER:
How far is
that?
RUTH KLAPPER:
It is about
two and a half miles.
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PEWEE MCGRUDER:
It can be
2
served cheaper than that I think.
3
EDGAR RASH:
Back in the
4
early- '70's, we as a community looking at the cost and
5
it was right around a hundred-forty-four-thousand at
6
one time and that was just for the tank and the
7
installation.
Louisville Water Company, Mr. McGruder
8
was over Turnpike Water Corporation at that time.
And
9
if Kentucky Turnpike Water Company would have turned
the system over to Louisville they said they would
definitely get water up there.
HAROLD TAYLOR:
Again, to
supply municipal water is really a state and local
decision about whether to extend resources to put in
water lines and water systems.
EPA, the Superfund
Program, we're not really in the business of installing
municipal water systems unl.ss that's the most cost
effective way to handle a problem at a Superfund site.
Here we have basically a handful
of residents that are impacted immediately by the Site.
And to run water lines to tanks, to pumps, et ceterra,
the lines out to those families is just not cost
effective to us and that. is .why we have not chosen that
alternative.
If we were talking about thousands
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of people and it were more cost effective to provide a
2
long-term water supply that is what we would propose
3
tonight.
4
PEWEE MCGRUDER:
Would five
5
hundred thousand be cost effective?
6
HAROLD TAYLOR:
No, sir.
7
Not - - again, as I think
we
have stated, it is in the
8
T~o Thousand Dollar range to carry water, and that is
9
probably a hjgh estimate,
to carry water to the
impacted people on the Site on a yearly basis.
We cost
the \..'hole thing OlJt for thirty years as if it may take
that long.
It may only take t~n years to do it.
But
if you're asking me is Ten Thousand Dollars cost
effective as opposed to half a million dollars, then
it's not.
PEKEE ~ICGRt}DGER:
(INTERRUPTI~G)
Rut if this contamination spreads to other
peoples' wells.
HAROLD TAYLOR:
If the
contamination were even in an area where it could then
that would be a consideration.
But we know these
springs discharge on those hill slopes and that is the
dischnrge of surface or ground\..'ater as we know it.
So,
there is really no \..'ay for it to spread to wider
communities.
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Yes, ma'am.
2
CHARLOTTE FLOWERS:
Charlotte
3
Flowers, from Brooks.
~e
Does it spread to the wells?
4
have ~ell water.
Does it spread to the wells?
We
5
live at the foot:of Brooks Hill.
6
HAROLD TAYLOR:
Perhaps,
7
Tony, it might be good to sho~ the...
R
TONY ABLE:
More than
9
likely ",'hat js happening here is that this - -
I think
the Site - - the springs are in this location along the
edges of this limestone formation here.
Maybe I ought
to go back and tell you what these formations are.
This is a cross section of the
geology of the Site and these two formations here are
Jimestones.
And I was talking earlier how the water is
probably moving through the cracks in the limestones.
And these are sandstones here.
And the djfference in
the water, the way the water moves through these things
is that these limestones are kind of like - - they're
calcium carbonate, almost like baking soda.
And they
can be dissolved more easily than these sandstones
which are just the ,same chemical compound as glass.
And so more flow channels can open up in these
limestones and allow the water to move through them
more easily than they do the sandstones.
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So that is why we're getting the
springs that are coming out of the sides of the hills
near the location where these two formations come
toget-her.
The rain water falls down into the
limestones, goes down vertically until it hits these
sandstones,
and then comes out and discharges as
springs on the sides of the hills.
So that tells us
that more than likely this stuff is not moving down to
th~ lower aquafers.
CHARLOTTE FLOWERS:
So, you don't
think it ~ould be in the wells?
TONY .~BLE:
No.
TO~Y ABLE:
Was that
sufficient?
CHARLOTTE FLOWERS:
~o.
KIM GATES:
\\'here is your
well in reference to the Site?
CHARLOTTE FLOWERS:
It is at .the
foot of Brooks .Hill.
TONY ABLE:
Is it near - -
is it on this map?
CHARLOTTE FLOWERS:
I can't find
it.
KIM GATES:
Is it .near the
interstate?
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CHARLOTTE FLOWERS:
\oie're
Vh-huh.
2
between the railroad tracks and 65.
TONY ABLE:
So that's a
4
mile or two miles or three miles aw~y7
5
CHARLOTTE FLOWERS:
It is four
6
miles.
7
Yeah.
I would
TONY ABLE:
8
say absolutely no chance of this Site impacting you.
9
KIM GATES:
Here's the
Site and you're over near the interstate?
CHARLOTTE FLOWERS:
Yeah.
You
don't think it would affect us?
TONY ABLE:
I don't
No.
think there is any chance of it whatsoever.
H.?.ROLD TAYLOR:
As \.;e
Clnrently understand that, gettin~ back kind of I guess
to this Site, ma'am,
understand it the hydrology
as we
and geology of the area now, the rainfall percolates
- - hits the Site, percolates down basically through
these disposal areas here, goes immediately down and
out those channels to the springs.
And the only real
groundwater that we are talking about being impacted is
right basically under those areas of discharges of the
springs.
There is no regional movement of the
groundwater away from the Site.
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CHARLOTTE FLOWERS: I know.
But it
2
looks like if it is hitting the top of the ground, if
3
there is a well there it would seep into the w~ll.
4
TONY ABLE:
If the well
5
were right in the area of the surface aquifer
6
If you drilled a well through it you
contamination.
7
might. have a chance of carrying it through.
8
And we're not
KIM GATES:
9
seeing the Site impacting the wells at the bottom of
the hill; just down the slope from the Site.
Because,
a~ Tony described, the contamination is coming out the
springs.
It is not going down into the deep~r aquifers
where we drilled these wells.
HAROLD TAYLOR:
Yes, sir.
EDGAR RASH:
Did you say
you were close to 657
CHARLOTTE FLOWERS:
Uh-huh.
EDGAR RASH:
We.II, aren I t
those streams down through - - aren't they contaminated
now; there by the truck stop?
CHARLOTTE FLOWERS:
I don't
Yeah.
know what they're contaminated with.
EDGAR RASH:
Of course
you're closer to Smith's dump?
CHARLOTTE FLOWERS:
We
No.
No.
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live there - - we adjoin Sanders Lane.
But those
2
creeks are contaminated.
They have tested them and
3
everything but ~e don't kno~ what it is.
4
Again,
HAROLD TAYLOR:
that's
5
not related to the Tri-Cities or the Smith's Farm Site.
6
But it is related to some other activity in the area I
7
assume- .
8
It ma~. be an
UNKNOWN:
9
underground tank.
H.~R()LD TAYLOR:
So, I - - and
again,
a~are of any specific problem.
I'm
we're not
- - I'll be glad to talk to you after the meeting to
see if there is anything the EPA, as an agency, needs
to be concerned with.
But I don't believe those are
related to the Trj-City Disposal Site.
DENNIS MITCHELL:
Did you say
that thjs Brushy Fork Creek, does it empty into Knob
Creek?
Did you also say that the PCBs never break
down?
HAROLD TAYLOR:
Kim?
Well,
PCBs are a long lived chemical compound.
Never is a
long word to use.
DENNIS MITCHELL:
When I say
'never', are \.Ie
talking about thirty, forty, fifty
years ~ould these still be around?
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HAROLD TAYLOR:
Yes,
sir.
2
DENNIS MITCHELL:
Okay.
In
3
other words, it means those PCBs can be in Knob Creek
4
then ?-
5
HAROLD TAYLOR:
Well, if
6
you're saying that PCBs can be in Knob Creek, I can't
7
say that they are or they are not.
I am saying that as
R
far as the Sjte, we only found one sample that had
9
detectable levels' of prBs.
That was around a half a
part per million range.
Which is not uncommon to find
under transformers or any other places where there's
heen electrical
transformer fluids used.
This Site is - - it is
a source
of - - it's not like this is a source of PCR
contamination that could have spread miles and miles.
And the sediment samples that we did in Brushy Fork
Creek, right under the Site, didn't have PCB levels
that we could discern.
So if we had PCBs leaving the
Site, I would, number one,
expect to find them on the
Site still since they don't degrade and they don't
migrate very far.
~umber two, if they had of been on
the Site and they had of migrated, I would expect to
find them close to the Site.
And I found neither one
of those.
--
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So, I don't think that this Site
would be a problem with PCBs in Brushy Fork Creek or to
the creek that you have mentioned.
KIM GATES:
And yes, in
answer to your question.
Brushy Fork Creek does,
approximately two miles down, join Knob Creek.
But, as
I"had already told you, EPA did an ecological
reconnaissance of Brushy Fork Creek, along with Fish &
Wildlife Service,
in August of last year.
And from
what the Fish & Wildlife Service people were able to
determine, and our own biologist~ that went out, this
is a pretty healthy creek.
So, we are not seeing any site
related impacts to the creek.
And if you all are
concerned ahout Knob Creek further downstream, there
may he something impacting it beyond the Tri-City Site.
Rut we're not even seeing the impact in the Rrush1- Fork
Creek.
HAROLD TAYLOR:
Yes,
sir.
EDGAR RASH:
Cox's house,
isn't it built right over t9P of that dump?
KIM GATES:
It is built to
the side of the disposal
area.
HAROLD TAYLOR:
It might be
good if we could go back to the areas that we have
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marked. . .
2
KIM GATES:
(INTERRUPTING)
3
Oh, the aeri al.
Yeah.
This is an area of
4
activity so, yeah.
5
HAROLD TAYLOR:
It looks like
6
in an area of activity from all of the aerial
photographs.
R
EDG_~R R.~SH:
So, more than
q
likely there is hazardous materials underneath the
house.
V;ould you sa~'?
HAROLD TAYLOR:
We haven't.
sampled under his house.
We have sampled a portion of
the areas that ~e have excavated and the trenches that
...e made through there.
If it is material that similar
to the other materials that ...e found then there is not
\"ery much hazardous substance ini t.
If further
studies see that ~e have a bigger source area then - -
I mean - - so far we are not - - I wouldn't say, based
upon the information that I reviewed that hazardous
substances,
as we know them, are of concern in his
house if it is consistent with the others.
Yes,
sir.
GLE~N ARMSTRONG:
When ...iU
these other samples be made?
will we have another
puhlic hearing after you get these samples so we'll
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know more of what we're looking at?
2
H.~ROLD TAYLOR:
Glenn, what
3
the other samples, as J tried to explain earlier today
4
and as I think Brook Dickerson explained this
5
afternoon, after tonight, after the Public Comment
6
Period ends, EPA will review comments and review our
decision to see if we need to change or modify our
8
decision based upon the comments that we receive.
Then
9
we'll sign our Record of Decision with a response and a
summary of the comments.
We'll ent~r then that - - what.
we're
referring to as a 'Moratorium Period', ~here
under our statutes we are restricted from spending
federal money until we give the Potential Responsible
Parties an opportunity to come forth in a good faith
offer and to volunteer to do the work.
That process
takes, af~er the ROD is signed, takes a hundred twenty
days or more.
So, at best, we can't do any work during
that Moratorium Period if that plays out the way it
normally does.
After that Moratorium Period and
we are successful in making the Responsible Parties say
they will do the work and then that decree is entered
in federal court and there is another Public Comment
Period on that decree.
And then the court action files
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the decree and basically that's usually when the
2
And then that is when the PRPs,
decrees are effected.
3
the Potential Responsible Parties, would go out and
4
hire a contractor, submit a work plan to the agency for
5
our review.
We would review it, comment, and have them
6
change or modify the report.
Once we approve the
7
report to the work plan then the sampling would begin. -
8
So, that sampling may take
9
any~here from a half of a year, to a year from no~,
before it commences and it may take up to a year to
complete.
If we find contamination in those samples
that warrant us doing what we call a 'Second Operative
Unit', then doing \o,'hat we're doing tonight. we'll have
another Public Comment Period, we'll have another
pUblic meeting, to go over the Alternatives and to seek
public comment.
If we go out and find that there
are no more contaminants, there is no more concern,
then we wouldn't be required to have a pUblic meeting.
But more than likely, as we try to do throughout all
. sites we control, what we find will go in the
Administrative Record at the Ridgeway Memorial Library.
v; e ' 11 . con tin 11 e t he fa c t she e t pro c e s s; w.e' 11 m ail 0 u t
t.o all interested parties updates on what is going on.
BROOK DICKERSON:
Harold, can I
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ad~ something to that?
2
If you ever have questions about results or
3
certain documents that you wanted to see that were not
4
neceasarily available in the Administrative Record, you
5
do have the opportunity to request certain information
6
from the EPA according to the Freedom of Information
7
And if you ever have questions about that I
Act.
8
imagine you can contact Suzanne or you can just write
9
dir~ctly to the EPA and direct it to the Freedom of
Information ~ct Officer - - that makes sense - - just
at our regional office at Atlanta which the address is
in your fact sheet.
So, if that ever comes up, and you
are interested in seeing something that is not
otherwise available,
that option is opened up to
you.
H.~ROLD T.~YLOR:
Let me get to
this lady that hasn't asked a question.
SUE HAYES:
Sue Hayes.
I
think on the previous slide here, I think I live at the
MW07 location, it is across from Hoosiers.
It's right.
off of Brooks Hill Road.
They drilled on the property and
they said I would get a report within six months and I
still haven't hear.d anything and it's been almost two
years.
And I don't know the results of anything, and I
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don't know if anything was found in that area or not.
2
There is a spring on my property that I don't know if
3
that was one of the contaminated springs or what.
4
HAROLD TAYLOR:
What we'll do,
5
and obviously we can't do it in the meeting, if you
6
would, come up to us after the meeting.
We'll make
7
sUre we have your compl~te name" and address and get you
8
t.he i.nformation.
9
Yes, ma'am,
in the hack~
SH.\RON BtTRBA:
What
p r () per t j e s c1 (> the E P "\. . " (I N.\ U D I B L E )
rOURT REPORTER:
I can't hear.
H .\ R 0 L D T A}" LOR:
"~g a in, the - -
looking back at Kim,
again,
as I recall,
we \.'ere
revje~jng the data t.hat the state has a Preliminary
Assessment and Site Investigation Grant from the
Environmental Protection Agency to go out and - - if
you remember at the start of the meeting when we were
talking about site discovery and thirty thousand-plus
sites around the nation.
Obviously the Tri-City Site
was indicated prohably because that they had an old
permit as a trash site, probably because of the old
past hjstory.
And I may ask Carl or Bob jf they kno\.'
~hat originally brought it to the state or EPA's
attention.
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The actual EPA got involved when
2
we received the data, I believe in 1987, investigations
3
that the state had done.
And as we reviewed that data
4
we saw this problem, went out and sampled the wells and
5
did the removal out there.
6
How about Bob or Carl know the
7
original reason for the Tri-City Site being looked at
8
by the state and federal agencies.
9
Pr\J\NOv.'~ :
The original
reason why the EPA...
HAROLD TAYLOR:
(INTERRUPTING)
The very original reason.
U!'JK~OWN:
TJlat I don I t
kno\~.
I would make the assumption that it was just the
review of records and it was put on the EPA list funded
by the EPA for the initial site..
HAROLD TAYLOR:
The actual
Site Discovery List that I referred to earlier came
about as a result of several different lists.
Senator
Eckhart, from Texas, back in 1979 required the fifty
major chemical companies in the United States to report
to the EPA all of their disposal sites across the
country.
That created what we termed in '79 as the
'Eckhart List'.
A few years later they a statute which
says anybody who has any knowledge of disposal of
more
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than fifty-five gallons of what we term
'Hazardous
2
Substances', was to notify the U.S. EPA of the location
3
it was disposed of.
As you can imagine that created
4
quit~ a list of sites.
.5
At the same time the EPA was, from
6
the states, was maintaining their own list of Potential
7
Hazardous Waste Sites.
Those sites were indeed also
8
'Inventory of Hazardous
added to what we now call the
9
I can't really answer your question
\o:aste Si tes' .
whether tonight whether it was on the Eckhart Study,
whether it was part of Section l03-C, whether it was
just a site where the state or the federal government
had a past complaint and just entered it directly
themselves or whether it was a citizen's complaint.
SHARON BURBA:
Does the state
k~ow when... (INAUDIBLE).
UNJ\Nm-:K:
Ma~' of 19RR, I
believe it was.
HAROLD TAYLOR:
Yes,
ma'am.
RUTH KLAPPER:
Will there be
a difference in the level of what you find in a wet
season compared to a dry season.
HAROLD TAYLOR:
In
groundwater?
RUTH KLAPPER:
Yes.
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HAROLD TAYLOR:
Tony, you
2
might.
3
TONY ABLE:
That is a
4
possibility and we try to design that long-term
.5
monitoring of these things.
I would recommend
6
something like quarterly for one year and try to
7
coordinate that.
One of those sampling events with a
8
rainy season, one with a dry season, and it could go
9
It could be higher in the summer or the
either way.
dry season,
because of less pollution.
Or it could be
higher in the wet season because of more flushing.
We
just have to wait and see.
HAROLD T.~YLOR:
I think the
ans\..er is yes.
But whether it is higher in droughts,
or lower in droughts, that is something to determine.
Yes, sir, in the back there.
D.~VTD BURB.~:
~~. name is
David Burba.
If the levels were above standards in
'88, do you have any educated guess how long it had
been that way?
HAROLD TAYLOR:
I couldn't
speculate as to how long it had been that way.
No,
sir.
It is, like I say, it would be speculation on my
part without the data to show.
D_~VID Bt!RB_~:
Would you
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guess that maybe they were higher at one time than they
2
were in '88?
3
HAROLD TAYLOR:
Again,
4
without, you know, more data it is hard to say.
If the
5
contaminants had been there and had been in contact
6
with the water for a long period of time, the
7
groundwater, and had moved as fast as the water moved,
R
perhaps they had been there for a long time.
9
To be quite honest, ~hat goes on
underground is really hard for anybody to speculate on
because of the rates of the transport of the water
theory, rates of the transport of contaminants with
that ~ater, varies.
It may have been there a long
time.
It may have been just - - we may have been lucky
and found it on the first sample.
Really can't
say.
Yes,
sir.
EDG.~R RASH:
Ho~ long - -
now this is an 'jf question'.
EPA, is it going to be
around for those seventy years or is there a
possibility that it could dissolve and, if so, what
would happen to the projects that are in working order
now?
HAROLD TAYLOR:
Again, let me
restate the seventy years that we mentioned before was
~hat we used for our Risk Assessments which ~e think is
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1
the average life span that we try to calculate risk
2
over a seventy year period of time.
3
What we are going for in this
4
Record of Decision is to monitor and maintain these
5
controls for thirty years, up to thirty years,
6
depending on whether it is required and we have to
7
re-evaluate the remedy at this Site every five years.
8
That's what our statute requires us to do.
9
Whether you're asking me whether
EPA will be here to enforce it, ! can't re~lly tell you
th~t.
We work at the whim of Congress and Congress can
dissolve or create agencies at its will.
Congress
obviously had the intent to - - for us to do these
kinds of things or they wouldn't have passed the kinds
of statutes for our monitoring and controls for thirty
years at a time.
If we enter into an agreement with
the Potential Responsible Parties, that agreement would
be lodged in federal district court and subject to that
court's ruling, per see
So that any time there is a
violation the court would have authority to take
corrective actions.
If indeed this goes into what we
call" 'Funding "Response' , the actual implementation of
the remedy would be done generally by the federal
government with ten percent state cost share.
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COURT REPORTER:
Excuse me?
2
HAROLD TAYLOR:
And we would
3
actually go out and monitor the sites for the first
4
year to make sure everything was going properly and
5
then the actual responsibilities for the next
6
twenty-nine years would go to the Commonwealth of
Ke-ntucky and that is the way the statute is written.
8
So, I guess the next question is
9
whether the Commonwealth of Kentucky would be here:
EDGAR RASH:
Yeah.
But how
well will they do the job?
HAROLD TAYLOR:
Again, the
responsibility would be with the Cabinet.
Yes, ma'am.
REBA MILLS:
I am Reba
Mills.
And talking about the time and nobody knowing
when this happened.
We were fighting this and Mr.
Farris was helping us.
And we thought everyone in
Bullitt County knew about' it at the time it was
burning.
It burned two years.
HAROLD TAYLOR:
You're talking
about 1969?
REBA MILES:
Right.
HAROLD TAYLOR:
Again, you
know, EPA was created about that same time.
So we
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1
obviously weren't even around then.
The actual program
2
that controls ongoing generations of hazardous
3
substances and hazardous waste wasn't created until
4
1 9 8 0 .-
5
So, I understand what you're
6
saying about the Site and the Bullitt County Health
7
Department was involved.
8
REBA MILES:
We didn't have
9
zoning laws at that time either.
HAROLD TAYLOR:
All I can say
is that the federal government and state became
involved and we had statutes when we became involved in
the Site. And that was unfortunately well after the
Site was a problem.
EDGAR RASH:
No telling how
much damage had been done.
Right?
HAROLD TAYLOR:
Well, I mean
we know what...
EDGAR RASH:
(INTERRUPTING)
That has not been detected.
HAROLD TAYLOR:
All we can say
is what the current risks are and the future risks are.
We can't evaluate what we went on before we became
involved.
Yes, ma'am.
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RUTH KLAPPER:
Who actually
2
discovered that the springs were contaminated; EPA or
3
the state?
4
HAROLD TAYLOR:
Well,
again,
5
the data was provided from the state, to EPA, and we
6
reviewed that data and said, you know, it looks like we
have a problem here and went out and sent people to
8
resample those springs to make sure that those samples
9
weren't polluted or were indeed correct.
So that
occurred in about 1988.
I think the data that you're
referring to was collected in '87.
Carl.
CARL MILLANTI:
Harold, would you
clarify something for us?
Are the state's comments on
this Proposal Plan included as part of public record
maintained at the library?
KIM GATES:
Yes.
HAROLD TAYLOR:
The answer is
yes.
CARL MILLANTI:
For those
here,
the state does represent your interests in this
matter and you ought to look at our comments too, in
evaluating the whole process.
HAROLD TAYLOR:
Yes, ma'am.
UNKNOWN:
How does
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82
1
Bullitt County feel about the Site itself?
2
HAROLD TAYLOR:
Bullitt County
3
Health Department?
4
UNKNOWN: .
And all the
5
people.
6
HAROLD TAYLOR:
Do they?
7
UNKNOWN:
What they're
8
coming in here to do; trying to clean it up.
9
HAROLD TAYLOR:
Again, why
we're here tonight is to try to explain what the
alternatives are and get comments from the public. .
That process has not been done yet.
. Yes, ma'am, in the back.
SHARON BURBA:
At the time
they discovered there was a problem and they got the
test results in 1987, from that time, until when, did
they get the people affected in that area on bottled
water?
How long were those people still drinking that
water out of those springs and why was that allowed?
HAROLD TAYLOR:
I think you're
referring to the lapse between 1987 and 1988?
SHARON BURBA:
I don't even
care if it is a month.
To me, I would want to know
immediately.
It seems like somebody had a
responsibility here and didn't follow through with it.
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1
HAROLD TAYLOR:
I'll let Carl
2
Millanti, with the Commonwealth, address that question.
3
CARL MILLANTI:
I'll put it
4
as tactfully as I can.
There is no excuse for what
5
happened and it was somebody's responsibility.
They
6
did not see to that responsibility and there were Borne
7
serious rep~rcussions over it.
That is why I am in
8
There is no need to mince words.
this position.
It
9
was an oversight.
HAROLD TAYLOR:
Are there any
ad~itional questions?
DENNIS MITCHELL:
I might ask
one thing:
Has the state looked at this thing and is
there any possibility that maybe the state is looking
at maybe funding anything in this area, maybe water, to
stop any potential problems that may happen ten years,
fifty years down the road?
CARL MILLANTI:
No, not
really.
Harold kind of hit on it early on.
It
wouldn't be cost effective for one thing.
My main
concern is to remove the people from the effects of the
contamination and the remediated site.
We feel they
have'been removed along with drinking contaminated
water.
It wouldn't benefit the Commonwealth in general
to run that water line.
J
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84
1
DENNIS MITCHELL:
I mean, even
2
help with it or anything?
3
CARL MILLANTI:
I don't know
4
what grounds we would have to have to get help.
5
UNKNOWN:
As I
6
understand it those wells are all disconnected.
7
MR. TAYLOR:
If there
8
aren't any additional questions I'd like to take a ten
9
minute break and those of you that are interested in
Smith's Farm we will come back at
._......1- ..:_--~ --"
- - ~~~ ~ JU~~ ~a~~
it 9:00 o'clock.
We'll have Tony DeAngelo present a
small presentation on Smith's Farm and then we will
answer any questions on the the Smith's Farm Site.
Thank you very much for coming
tonight.
(CONCLUSION OF PUBLIC MEETING FOR THE TRI-CITY
INDUSTRIAL DISPOSAL SITE)
***
. * * *
***
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1
2
STATE OF KENTUCKY
3
COUNTY OF BULLITT:
ss
4
I, SHARON L. KLOSTERMAN, Notary Public in and
5
for the State of Kentucky, at Large, do hereby certify
6
that the foregoing transcript of the PROPOSED PLAN .
7
PUBLIC MEETING FOR THE TRI-CITY INDUSTRIAL DISPOSAL
8
SITE, was taken at the time and place stated in the
9
foregoing caption; that said meeting was taken by me in
Stenograhic notes and afterwards transcribed by me;
that this is a true, full, and accurate transcript to .
the best of my ability.
Furth~r, that I am not of kin
nor related to this matter in any way.
Witness my hand this~
day of June, 1991
~J
HARON L. KLOSTERMAN
Notary Public, State of Kentucky, at Large
My Commission expires:
7/1/92
-------
Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 3
Sign-In Sheets
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-------
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-------
. SIGN-IN SHEET
SITE: TRI-Cm INDUSTRIAL DISPOOAL SITE
DhTE:MAY 9, 1991 (Proposed Plan Public Meeting)
----
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Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 4
EPA Memorandum dated May 16, 1991
Regarding the Provision of Public Water
to Site Residents
-------
..,..,..t,":' S1....,:-
, .
:- j., ~ %
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~"'''' .,~
04( caQO't.'"'
UNITED STATES ENVIRONMENTAL PROTECTION AGE~CY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
MEMORANDUM
DATE:
MAY 1 6 1391
TO:
Provision of Public Water to Tri-City Site Residents
Kimberly Gates,Remedial,project Hanaqer ~~~
Harold Taylor, Chief II l..RdJ.~ "
Kentucky/Tennessee Re~al ie~io -
North Superfund Remedial Bran
- SUBJECT :-
FROM:
Before the Proposed Plan Fact Sheet was mailed on April 19,
1991, I called the residents on the Tri-City Site to determine
if they had any concerns that warranted a trip before the public
meeting on May 9th. I talked with Mrs. William Cox, Sr. and
Mrs. Ruth Klappar on April 9th, Mrs. Wenfrey Hoosier on April
10th, and Mr. William Cox, Jr. on April 11th.
One of the predominant concerns at the site was voiced by Mrs.
Hoosier, and it was regarding the provision of public water to
all of the people living in the area of the site. EPA started
providing drinking water to the Cox, Sr. residence and the two
Klapper residences in 1988 when it was revealed that the Cox and
Klapper Springs were contaminated with volatile organic
compounds above Maximum Contaminant Levels. Other residents in
the area, including Mrs. Hoosier, use cisterns or buy water for
potable use.
Following my conversation with Mrs. Hoosier, I looked into
providing the Tri-City Site residents with public water. I
contacted Mr. John Smither at the Kentucky Department for
Environmental Protection (502/564-3410) and he suggested that I
contact the water districts in the area. of the site, the Salt
River Water District and the Kentucky Turnpike Water District~
Mr. Smither vaguely recalled looking into this issue a couple of
years ago. He remembered that several miles of water line would
be necessary and that the terrain was a problem so booster pumps
would be needed. He thought that the water districts would
probably provide the water, but that someone would have to pay
for the water line. According to Mr. Smither, the area is
sparsely populated and people typically buy water because there
are no public water lines.
-------
Memo to Tri-City Site File
May 15, 1991
Page 2
According to the receptionist at the Salt River Water District
(502/955-9281), the Brooks area would be served by the Kentucky
Turnpike Water District. I talked with Mr. Tad Burke, the
commissioner~f the Kentucky Turnpike Water District
(502/955-9217), on April 24, 1991 and he was familiar with the
situation.' He said that it is in the "master plan" to provide
water to the people living in the area of the Tri-City Site, but
that it would cost approximately $1.5 million to run the line
and instal: the two water tanks that are necessary. He asked me
if .any federal monies were available to finance the water line.
I talked with Mr. Bob Humphries in State Programs in EPA Region
IV's Water Management Division on April 25th and he told me that
EPA does not have provisions for providing funds in this
situation. He suggested that state or local government agencies
. be contacted.
I talked with Mr. Greg powell, the On-Scene Coordinator involved
with the Emergency Removal Action cO::lducted by EPA in 1988, on
April 22nd and he looked into the C03t of installing a water
line to site residents in 1988. He remembered a cost of over $1
million, but he suggested that I contact Mr. Bob Padgett at the
Kentucky Department for Environmental Protection for (KDEP)
documentation.
I talked with Mr. Padgett at KDEP on April 25, 1991 and he did
not recall being involved with investigating the feasibility of
installing a water line. However, a letter dated May 26, 1989
from Mr. Carl Millantiof KDEP to Ms. Felicia Barnett, a
previous Remedial Project Manager assigned to the site,
indicates. that Kentucky agreed with EPA providing water to the
affected residents rather than extending the public water line
based on the associated costs. Since I expected this issue to
be raised during the public meeting on May 9th, I suggestec that
Mr. Padgett look into the availability of state funds for the
water line for informational purposes.
I also reviewed the Guidance Document for providina Alternate
Water Supplies, EPA/540/G-87/006, February 1988 to determine if
EPA had other provisions for providing water. However, it
appears to be .appropriate for EPA to only supply water to the
residents affected by the contaminated sources (i.e., the Cox
and Klapper Springs). And, using tank trucks to provide water
is currently the most cost-effective method.
-------
Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 5
Hand-Out from the Public Meeting
May 9, 1991
-------
, --
u.s. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ft
~
PUBLIC INFORMATION MEETING
Tri-City Industrial Disposal
Superfund Site
May 9,1991
Bullitt Lick Middle School
1080 West Blue Lick Road
. .
Shcpherdsvil1e, Kentucky
, '
,
-------
AGENDA
.. Introduction &. Welcome
. Superfund Process Overview
. Tri-City Site Background &
Remedial Investigation Summary
. Feasibility Study Results
. EPA's Recommended Alternative
. The Next Step.
. Community Relations
. Enforcement Activities
. Tri-City Question & Answer Session
. Smith's Fann Site Presentation
. Smith's Fann Question & Answer Session
-------
Administrative Record Location
Ridgway Memorial Library
Walnut Street.
Post Office Box 146
Shepherdsville, Kentucky 40. 165
(50.2) 543-7675
-------
SITE BACKGROUN[)
. Industrial waste landfill operated by 'fri-City
Industrial Services, Inc. from late 1964
to late 1967
. Bulk of the waste consisted of scrap lumber and
fiberglass insulation materials
. Other waste consisted of drummed liquids and
liquid wastes that were poured onto the ground
at the site
.
Site reportedly burned for 2 years from 1967 to 1969
-------
SITE BACKGROUND (cont'd)
Kentucky conducted a Site Investigation (SI) in
April 1987 to determine the site's eligibility for
inclusion on EPA's National Priorities List (NPL);
site included on the NPL in March 1989
SI revealed tetrachloroethene in 2 springs used by
residents for domestic water; EPA has been providing
water to affected residents
EPA conducted an Emergency Removal Action at the site
during the Summer of 1988 to excavate and remove
165 drums that contained liquid waste material
-------
. ----------"<----- -- -
REMEDIAL INVESTIGA'fION
EPA conducted the Remedial Investigation (RI)
at the site during 1989 and 1990 to:
. characterize site conditions,
. detennine the type of waste present
at the site, and
. assess risk to human health and the
environment.
-------
. -
i
RI FINDINGS
. Cox Spring contained several volatile
organic compounds, including
tetrachloroethene (also known as PCE),
at levels above the federally established
Maximum Contaminant Levels (MCLs);
PCE was also found in the monitoring
well next to the Cox, Sr. residence'
. PCE'was detected at low concentrations'
in 2 air samples
. One species of polychlorinated biphenyl (PCB)
and lo\v levels of polycyclic aromatic
hydrocarbons (PARs) were found in one
surface soil sample, and low levels of
P AHs were also found in a subsurface soil
sample in the same area
. Lead was detected in one sediment sample
in a tributary of Brushy Fork Creek
. Minimal ecological impacts from the site
on B,rushy Fo.rk Creek
-------
RISAMPLING
. Monitoring Wells = 6 ..
(a total of 13 wells were attempted)
. Surface Water Samples = 7
. Spring Water Samples = 5
. Sediment Samples = 12
. Surface Soil Samples = 20
. Subsurface Soil Samples = 27
. Air Samples = 16
(at 3 locations)
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RI CONCLUSIONS
Operable Unit One
. ;Restrict use o.f groundwater and spring.
water for domestic purposes, and
provide water
. Clean up spring water contaminated
. above MCLs
. Confinnatory sampling of site soils,
sediment, and air
. Long-tenn monitoring of groundwater
and spring water, and the surface
water, sediment, and ecology in
Brushy Fork Creek
Operable Unit Two
. Actions detennined to be necessary based
on the results of the Conflffilatory
Sampling in Operable Unit One
-------
FEASIBILITY STUD~{
. EPA initiated the Feasibilty Study (FS) during the Summer
of 1990 to develop and evaluate cleanup alternatives for
the site.
. Four possible remedial alternatives were identified and
each alternative was evaluated using eight of the nine
evaluation criteria; the ninth criterion, community acceptance,
is being evaluated during the public comment period.
-------
POSSIBLE RE:MEDIAL ALTERNATIVES
Alternative 1 - No Action -
Alternative 2 - Limited Action
. Institutional Controls
. Monitoring
. Confinnatory Sampling
Alternative 3 - Carbon Adsorption
. Carbon Adsorption
. Institutional Controls
. Monitoring
. Confinnatory Sampling
Alternative 4 - Aeration
. Aeration
. Institutional Controls
. Monitoring
. Confinnatory Sampling
~
-------
i
I
, .
I
EPA's RECOMMENDED ALTEI~NATIVE
Alternative 3 - Carbon Adsorption
. Institutional controls to prevent domestic use of the' groundwater.
and spring water; provision of an alternate water supply.
. Treatment of contaminated spring water in a carbon adsorption
system containing an activated carbon filter; spent carbon
would be regenerated or appropriately treated/disposed.
. Long-term monitoring of groundwater, spring water, surface water,
and sediments.
. Ecological monitoring of Brushy Fork Crfeek.
. Confirmatory sampling of site soils, sedirnent in the tributary of
Brushy Fork Creek, and the air.
-------
EP A's RECOMMENDED AL TERNA TIVE
. .Alternative 3 - Carbon Adsorption is preferred for the fol1~wing
reasons:
1. Most protective of human health and the environment.
2. Provides reliable protection over time with minimal risk
during construction and implementation.
3. Prevents contamination of Brushy Fork Creek and the air.
4. Utilizes a pennanent solution.
5. Uses a proven and widely available technology that is
easy to implement.
6. Reduces the toxicity, mobility, and volume of contaminated
spring water throu gh treatmen t.
7. Cost effective.
8. Satisfies EP A's preference for treatment as a principal
element.
-------
THE NEXT STEP
. Public comment period ends on June Jl, 1991
. EPA will respond to the comments received and the
responses will be summarized in a document called
the Responsiveness Summary
. EPA's final choice of a remedy will be documented
in the Record of Decision (ROD) to be issued in
July 1991 .
. Signed ROD, which includes the Responsiveness
. Summary, will become part of the j\dministrative
Record in the Information Repository
-------
FOR FURTHER INFORMATION ABOUT THIS SITE~ CONTACT:
Ms. Suzanne Durham
Community Relations Coordinator
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347- 7791
QUESTIONS CAN ALSO BE DIRECTED TO:
Mr. Bob Padgett
Environmental Coordinator
. Division of Waste Management
Kentucky Dept. for Environmental Protection
18 Rci1ly Road
Frankfort, Ky 4060]
(502) 564'-67] 6
Ms. Kimberly Gates
Remedial Project Manager
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-7791
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Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 6
EPA Letter dated August 26, 1991 to Concerned Citizen
regarding Sampling Conducted at the Site
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..to s~"..
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, I .
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i"1r,. ~,~
4l ..,1"""
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGiA 30365
4WD-NSRB
AUG 2 6 iS91-
Sue Hayes
4821 Brooks Hill Road
Brooks, Kentucky 40109
RE:
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
Dear Ms. Hayes:
The purpose of this letter is to document the conversation we
had following the Proposed Plan Public Meeting on May 9, 1991
for the Tri-City Site. The meeting was held in the library of
the Bullitt Lick Middle School in Shepherdsville, Kentucky.
During the meeting you asked about the analytical results from
the sampling of the groundwater monitoring well MW-07 and the
spring on your property during the Remedial Investigation
conducted by EPA in 1989. As I informed you after the meeting,
the installation of monitoring w~ll MW-07 was not completed due
to insufficient groundwater. However, analyses were conducted
on a surface soil sample collected from that location and on one
subsurface soil sample collected at a depth of five to seven
feet from a soil boring.
Toluene was found in the surface soil sample at a level of 72
parts per billion. Although this compound was detected in
several other surface soil samples during the Remedial
Investigation in similar or smaller concentrations, these levels
are not indicative of a contamination problem that represents a
threat to human health or the environment.
The Cattle Spring was sampled during the Remedial Investigation
and again in December 1990 by EPA's Environmental Services
Division. The results from the analyses of the two different
sample. are .hewn in the enclosed data sheets. The analytical
data indicated that the Maximum Contaminant Levels (MCLs)
~stabli8hed by the Safe Drinking Water Act were not exceeded
during either sampling event. However, EPA has proposed
restrictions on the domestic usage of the spring water until
long-term monitoring shows that the water is of sufficient and
consistent quality for human consumption.
Printed on Rec,
-------
M8. Bayes
Auqust 26, 1991
Page 2
Detailed information about EPA's investigations at the Tri-City
Site is available in the Administrative Record in the Ridgway
Memorial Library in Shepherdsville for your review. And, if you
have further questions about the analytical information I have
enclosed, -please contact me at (404) 347-7791.
Sincerely yours,
ICtYv.,~~ \~~
Kimberly J. ~~U.T.
Remedial Project Manager.
Kentucky/Tennessee Remedial Section
North Superfund Remedial Branch
Waste Management Division
Enclosures
cc:
Suzanne Durham, Community Relations Coordinator
-------
SAMPLE AND ANALVSIS MAN~GEMENT SYSTEM
EPA-REGION IV ESD. ATHENS. GA.
08/25/89
IIfTAlS DATA REPORT
... . . . . . . . . . . . . . . . . .
.. PROJECT NO. 89-621 SAMPLE NO.
.. SOURCE: TRI-CITV INDUSTRIAl
.. STATION ID: TC-SP-Q4-1
.. CASE NUMBER: 12345
..
...
. . . . . . . . . . . . . . . .
37924 SAMPLE TVPE: SURfACEWA
. . . . . . . . . . . . . . . . . . . . . . . . . .
PROG ELEM: SSf COlLECTED BV: P STONE
CITV: BROOKS ST: KV
COlLECTION START: 07/19/89 1430 STOP: 00/00/00
MD NUMBER: N648
. . . ...
..
..
..
..
..
. . . . . . . . . . ...
SAS NUMBER:
. . . . . . . . . . . . . . . . . . . . . . . . . . . .
ANALVTICAL RESULTS
. . .
UG/L
1000
30U
2U
SOU .
2U
4U
52000
4U
7U
20U
1300
5U
8800
. . . . .
UG/L
190
0.20UJ
20U
3000
2UJ
9UJ
9200
3U
NA
7U
60U
. . . . . . . . . . . . . . . .
ANAlVTICAl RESULTS
AlUMINUM
ANT IImNV .
ARSENIC
BARIUM
BERVLLIUM
CADMIUM
CAlCIUM
CHROMIUM
COBAl T
COPPER
!RON
LEAD
MAGNESIUM
MANGANESE
MERCURV
NICKEL
POTASSIUM
SELENIUM
SILVER
SOD I UM
THALLI UM
TIN
VANADIUM
ZINC
.. . REMARKS" .
...REMARKS."
...FooTNOTES...
.A-AVERAGE.VAlUE .NA-NOT ANAlVZED .NAI-INTERFERENCES .J-ESTIMATED VALUE 8N-PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAl
.K-ACTUAL VAlUE IS KNOWN TO BE LESS THAN VALUE GIVEN .L-ACTUAL VALUE IS KNOWN TO BE GREATER THAN VAlUE GIVEN
.U-MATERIAl WAS ANAlVZED FOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM QUANTI TAT ION LIMIT.
.R-QC INDICATES THAT DATA UNUSABLE. COMPOUND MAV OR .MAY NOT BE PRESENT. RESAMPLING AND REANALYSIS IS NECESSARV fOR VERifICATION.
-------
.....,
-,'
SAMPLE AND ANAlVSIS MANAGEMENT SYSTEM
EPA-REGION IV ESO. ATHENS. GA.
08/25/89
SPECIfIED ANAlVSIS DATA REPORr
... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.. PROJECT NO. 89-621 SAMPLE NO. 37924 SAMPLE TVPE: SURFACEWA
.. SOURCE: TRI-CITV INDUSTRIAl
.. STATION ID: TC-SP-Q4-1
.. CASE. NO. : 12345 SAS NO.:
..
... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .-. . . . .. . . . . . . . .
. . . . . . . e . . e . e . . e . . e - . . . . . - .
PROG ElEM: SSF COlLECTED BV: P STONE
CITY: BROOKS ST: KV
COlLECTION STARr: 07/19/89 1430 STOP: 00/00/00
D. NO.: N733 YO NO: N648
. . . ...
.e
..
..
..
..
...
RESULTS UNITS PARAMETER
0.01UJ MG/L CVANIDE
. .. REMARKS" .
HOLDING TIME EXCEEDED-CN
...REMARKS".
...FooTNOTES---
.A-AVERAGE VAlUE eNA-NOT ANAlVZED .NAI-INTERfERENCES .J-ESTIMATED VALUE eN-PRESUMPTIVE EVIDENCE Of PRESENCE Of MATERIAl
.K-ACTUAl VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN eL-ACTUAL VAlUE IS KNOWN 1'0 BE GREATER THAN VAlUE GIVEN
.U-MATERIAl WAS ANALVZED FOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM QUANTIlfATION LIMIT.
-------
SAMPLE AND ANALVSIS MANAGEMENT SYSTEM
EPA-REGION IV ESD, ATHENS, GA.
09/04/89
EXTRACTABLE ORGANICS DATA REPORT
... . . . . . . . . . . . . . . . . . , , , , , . , . . , , , , , ,
.. PROJECT NO. 89--621 . SAMPLE NO. 37924 SAMPLE TYPE: SURfACEWA
,. SOURCf: TRI-CTTY INDUSTRIAL
u STATION ID: T(,-SP-()4-1
"
.. CASE NO.: 12345 SAS NO. :
'" . , , , , , , , , . , , . , , . . . . . . , , , .', . , , . . , ,
U6/1 ANALYTICAL RESULTS
10U
10U
10U
10U
10U
10UJ
10U
10U
10U
10U
10U
10U
10U
10U
10U
1QU
50UJ
10U
10U
10U
10U
10U
10U
10U
10U
10U
10U
50U
10U
50U
10U
10UR
10U
, . . . . . , , , . , , , . . . , . . , . . , , , , . , . . ..,
PR0G ELEM: SSf COLLECTED BV: P STONE ,.
cny. BROOKS ST: KY u
COLLECTION START. 07/1&;89 1430 STOP' 00/00/00 "
,.
D. NO.: N733 ..
. . . . . . . , , , , . . , - - - - . . - , , , , , . . . '"
UG/L ANAL VTlCAL RESULTS
50U ,3-NITROANILINE
10U 'ACENAPHTHENE
50UJ 2,4-DINITROPHENOL
50U 4-NITROPHENOL
10U DIBENZOfURAN
10U 2,4-DINITROTOLUENE
10U DIETHVL PHTHALATE
10U 4-CHLOROPHENYL PUENVL ETHER
10U FLUORENE
SOU 4-NITROANILINE
SOUJ 2-METHYL-4 6-DINITROPHENOL
10U N-NITRosooipHENYLAMINE/DIPHENYLAMINE
10U 4-BROMOPHENYL PHENYL EtHER
10U HEXACHLOR08ENZfNE (HC8)
SOU PENT ACHLOROPHENOL '
10U PHENANTHRENE
10U ANTHRACENE
10U DI-N-BUTYLPHTHALATE
10U FLUORANTHENE
10U PYRENE
10U BENZYL BUTYL PHTHALATE
20U 3,3'-DICHLOROBENZIDINE
10U BENZO(A)ANTHRACENE
10U CHRYSENE
10U BIS(2-ETHYLHEXYL) PHTHALATE
10U DI-N-OCTVLPHTHALATE
10U BENZO(B AND/OR K)FLUORANTHENE
10U BENZo-A-PYRENE
10U INDENQ (1.2 3-CD) PYRENE
10U DIBENZO(A,H)ANTHRACENE
10U BENZO(GHI,PERYLENE
PHENOl
BIS(2-CHlOROETHVL) ETHER
2-CHLOROPHENOL
1,3-0ICHlOROBEN2ENE
1,4-DICHlOROBENZENE
BENZYL ALCOHOL
1.2-DICHLOROBfN2ENE
2-METHYLPHENOL
BIS(2-CHLOROISOPROPYL) ETHER
(3-AND/OR 4-)METHVLPHENOl
N-NITROSODI-N-PROPYlAMINE
HEXACHLOROETHANE
NITROBENZENE
I SOPHORONE
2-NITROPHENOl
2t4-DIMETHYlPHENOl
B N20IC ACID
,BISC 2-CHlOROETHOXY) METHANE
2. 4-D I CHLOROPHENOL
1.2.4-TRICHLOROBENZENE
NAPHTHALENE
4-CHLOROANllINE
HEXACHlOROBUTADIENE
4-CHlORo-3-METHYLPHENOl
2-METHYLNAPHTHALENE
HEXACHLOROCVCLOPENTADIENE (HCep)
2,4,6-TRICHLOROPHENOl
2,4.5-TRICHlOROPHENOl
2-CHLORONAPHTHAlENE
2-NITROAN I LI NE
DIMETHVL PHTHALATE
ACENAPHTHYLENE
2.6-DINITROTOLUENE
,,'FooTNOTES'"
'A-AVERAGE VALUE 'NA-NOT ANALYZED 'NAI-INTERFERENCES 'J-ESTIMATED VALUE -N-PRESUMPTIVE EVIDENCE Of PRESENCE Of MATERIAL
'K-ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN -l-ACTUAl VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN'
-U-MATERIAL WAS ANALYZED fOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM QUANTITATION LIMIT.
'R-QC INDICATES THAT DATA UNUSABLE. COMPOUND MAY OR MAY NOT BE PRESENT. RESAMPllNG AND REANALVSIS IS NECESSARY fOR VERIFICATION.
-------
. . .
UG/l.
O.05OU
O.05OU
O.050U
O.050U
0.05OUR
O.05OU
0.05OU
O.050U
0.10U
0.10U
0.10U
0.10U
0.10U
0.10U
0.10U
.. - REMARKS- ..
. . . . . ". . . . . . . . . . .
37924 SAMPLE TYPE: SURfACEWA
SAMPLE AND ANALVSIS MANAGEMENT SYSlEM
EPA-REGION IV ESD, ATHENS, GA.
09/04/89
. . .. . . . II; .
PROG ElEM: SSF
CITV: BROOKS
~OLLECTION SURT.
D. NUMBER: U733
SAS NUMBER;
. . . . . . .
. . . . . . . . . . . . .
. . .
UG/L
. . . . . . . . . . . . . . . . . .
:OLLECTED BY; P STONE "
ST: KY
Oi/19/89 1430 STOP: 00/00/00
. . . ...
..
..
..
..
..
. . . . ...
...',...
. . ~ . ~ . . . . .
ANALYTICAL RESULTS
. . . . .
PESTICIDES/PCB'S DATA REPORT
... . . . . . . . .". . . . . . . . .
.. PROJECT NO. 89-621 'SAMPlE NO.
.. SOURf.f: TRI-CITY INDUSTRI~L
.. STATION 10: TC-SP-Q4-1
.. CASE NUMBER: 12345
..
...
. . . . . . . . . ..
ANALYTIC~ RESULTS
ALPH~-BHC
BETA-BHC
DELTA-:BHC
GAMMA-BHC (LI NOANE )
HEPTACHLOR
ALDRIN
HEPTACHLOR EPOXIDE
ENDOSULFAN I (ALPHA)
OIELlIMIN
4,4'-DDE (P,P'-oDE)
EN DR IN
ENDOSULFAN II (BETA)
4,4'-DOD (P,P'-DDD)
ENDOSULfAN SULFATE
4,4'-DDT (P,P'-DDT)
O.50lI
0.10U
O.50U
O.50U
LOU
O.50U
O.50U
O.50U
0.50U
O.50U
LOU
LOU
METHOX'iCHLOR
ENDR I N KETONE
CHLORD~NE (TECH. MIXTURE)
GAMMA-CHLORDANE /2
ALF'IIA-CHLORDANE /2
TOXAPHENE
PCB-1016 (A ROC LOR 1016)
PCB-1221 (A ROC LOR 1221)
PCB-1232 (A ROC LOR 1232)
PCB-1242 (A ROC LOR 1242)
PCB-12'48 (A ROC LOR 1248)
PCB-1 ~:54 (A ROC LOR 1254)
PCB-' ~~60 (A ROC LOR 1260)
/1
. ..REMARKS'"
...FooTNOTES'" "
'A-AVERAGE VALUE 'NA-NOT ANALYZED .NAI-INTERFERENCES 'J-ESTIMATED VALUE 'N-PRESUMPTIVE EVIDENCE OF PRESENCE Of MATERIAL
'K-ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN 'L-ACTUAL VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN
'U-MATERIAL WAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM OUANTITATION LIMIT.
'R-QC INDICATES THAT DATA UNUSABLE. COMPOUND MAY OR MAV NOT BE PRESENT. RESAMPLING AND REANALVSIS IS NECESSARY FOR VERIFICATION.
-C-CONFIRMED BY GCMS ,. WHEN NO VALUE IS REPORTED, SEE CHlORDANE CONSTITUENTS.
-------
SAMPLE AND ANALVSIS MANAGEMENT SYSTEM
EPA-REGION IV ESD. ATHENS. GA.
PURGEABLE ORGANICS DATA REPORT
... . . . . . . . . . . . . .'. . . . . 8 8 . . . . . . . . . . . 8 .
.. PROJECT NO. 89-621 SAMPLE NO. 37924 SAMPLE TY~E: SURfACfWA
.. SOURCE: TRI-CITY INDUSTRiAl
.. STATION 10; TC-SP-Q4-1
..
.. CASE NO.: 12345 SAS NO. :
... . . . . . . . . . . . . . . . . 8 . e e e e . e . e e . . e . . .
UG/I ANALYTICAl RESULTS
10UJ
10U
10U
10U
5U
10U
5U
5U
5U
5U
5U
5U
10U
5U
5U
10UJ
5U
.e.REMARKS'"
. . . . . . . . . . . . . . . . . . . . . . . . . .
PROG ELEM: SSF COLLECTED BY; P STONE
CITV; BROOI<.S ST: KY
COLLECTION START. 07;19/89 1430 STOP: 00/00/00
D. NO.: N733
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
UG/L ANAlYTICAL'RESULTS
bU 1.2-DICHLOROPROPANE
5U CIS-1.3-DICHLOROPROPENE
5U TRICHLOROETHENE(TRICHLOROETHVLENE)
5U DIBROMOCHlOROMETHANE
5U 1.1.2-TRICHLOROETHANE
5U BENZENE
5U TRANS-1.3-DICHlOROPROPENE
5UJ BROMOFORM
10UJ METHYL ISOButYL KETONE
10UJ METHYL BUTYL KETONE
5U TfTRACHlOROfTHENE(TETRACHlOROETHVLENE)
5UJ 1.1.2.2-TETRACHlOROfTHANE
5U TOLUENE
5U CHlOROBENZENE
5U ETHYL BENZENE
5U STYRENE
5U TOTAL XYLENES
. . . ...
..
--
..
ee
e.
...
CHLOROMETHANE
BROMOMETHANE
VINYL CHLORIDE
CHLOROfTHANE
METHYLENE CHLORIDE
ACETONE
CARBON DISULFIDE
1.1-DICHLOROETHENE(1.1-DICHLOROfTHVlENE)
1. 1-oJ~HLOROETHANE
1.2-DICHlOROfTHENE (TOTAl)
CHLOROfORM
1 2-D I CHLOROE THANE
METHYL ETHYL KETONE
1.1.1-TRICHlOROETHANE
CARBON TETRACHLORIDE
VINYL ACETATE
BROIIODICHLOROIIETHANf
'.
...REMARKS'"
09/04/89
...fooTNOTES'" .
'A-AVERAGE VALUE eNA-NOT ANALYZED eNAI-INTERFERENCES -J-ESTIMATED VALUE 8N-PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
eK-ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN el-ACTUAl VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN
eU-MATERIAl WAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM QUANTITATION liMIT.
eR-QC INDICATES THAT DATA UNUSABLE. COMPOUND MAY OR MAY NOT BE PRESENT. RESAMPLING AND REANAlYSIS IS NECESSARY fOR VERIFICATION.
-------
PURGEABLE ORGANICS DATA REPORT
... . . . . . . . . . . . . . . . . . . . .
.. PROJECT NO. 91-203 SAMPLE NO. 52958
.. SOURCE: TRI CITV INDOSTRIAL
.. STATION 10: TRIC-08 SPRING CATTLEMAN
..
...
f
. . .
UG/L
5.0U
5.0U
5.0U
S.OU
S.OU
5.0U
SOU
12U
5.0U
S.OU
5.0U
12U
S.OU
5.0U
SOU
S.OU
S.OU
S.OU
5.0U
S.OU
S.OU
S.OU
S.OU
5.0U
S.OU
S.OU
,
l'
t,
,
,
"\
"
o
. . . . . . . . . . . . . . . . .
ANALYTICAL RESULTS
SAMPLE AND ANALYSIS MANAGEMENT SYSTEM
EPA-REGION IV ESD. ATHENS. G,!I,.
. . . . . . . . . . . ... . . . . . ~ . . . . . . . . . . . . . . . . . . .
SAMPLE TYPE: GROUNDWA PROG ELEM: SSF COLLECTED BY: C TILL
CITV: 8ROO~:S ST: KV
COLLECTION, START: 12/04/90 1219 STOP: 00/00/00
CHLOROMETHANE
VINVL CHLORIDE
8ROMOMfTHANE
CHlOROETHANE
TRICHlOROFlUOROMETHANf
1.I-DICHlOROETHENE(1.1-DICHLOROETHVLENE}
ACETONE
CAR80N DISUlfIDE
METHYLENE CHLORIDE
TRANS-1.2-DICHlOROETHENE
1.1-DICHlOROETHANE
VINYL ACETATE
CIS-I.2-DICHlOROETHENE
2.2-DIClllOROPROPANE
METHYL ETHYL KETONE
BROMOCHlOROMETHANE
CHLOROfORM
1.1. I-TRICHLOROETHANE
1.I-DICHlOROPROPENE
CARBON TETRACHLORIDE
1.2-DICHlOROETHANE
8ENZENE '
TRICHlOROETHENE(TRICHlOROETHYLENE}
1.2-DICHlOROPROPANE
DIBROMOMETHANE
BROMOD I CHLOROMETHANE
. . . . . . . . . . . . . . .
UG/l
5.0U
12U
/0. 58J
5.0U
5.0U
5.0U
5.0U
12U
5.0U
S.OU
5,OU
5.0U
5.0U
5.0U
S,OU
S.OU
S.OU
5,OU
S,OU
S.OU
5.0U
S.OU
5,OU
5.0U
. . . ~ . . . . . . . . . . . . . . . . . . .
ANALYTICAL RESULTS
C I S- 'I . 3-D I CHLOROPROPENE
MET HilL ISOBUTYL KETONE
'TOLUENE
TRANS-I.3-DICHlOROPROPENE
, 1.1. :Z-TRICHLOROETHANE
TETRj~CHlOROETHENE (TETRACHlOROETHV(ENE)
1.3-DICHLOROPROPANE
ME TH'(L BUTVl KETONE
DIBROMOCHLOROMETUANE
CHLOROBENZENE
,. ,. 1.2-TETRACHlOROETHANE
ETHYL BENZENE
(M- AND/OR P-}XYlENE
o XYLENE
STYRENE
8ROMOFORM
BROMOBENZENE
1.1.2.2-TETRACHlOROETHANE
1.2.3-TRICHlOROPROPANE
O-CHLOROTOlUENE
P-CHlOROTOlUENE
1.3-DICHlOROBENZENE
1.4-DICHlOROBENZENE
1.2-DICHlOROBENZENE
12/12/90
. . . . ...
..
..
..
..
. . . . ...
..-FooTNOTES-..
-A-AVERAGE VALUE -NA-NOT ANALYZED .NAI-INTERFERENCES .J-ESTIMATED VALUE .N-PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-K-ACTUAl VALUE IS KNOWN TO BE lESS THAN VALUE GIVEN -L-ACTUAL VALUE 15 KNOWN TO BE GREATER THAN VALUE GIVEN
.U-MATERIAl WAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER IS TUE MINIMUM QUANTITATION lIMIT.,
'-
-------
METALS DATA REPORT
SAMPLE AND ANALYSIS MANAGEMENT SYSTEM
EPA-REGI°N IV ES°' ATHEIB' "'
°'"7'91
•••
*• PROJECT NO. 91-203 SAMPLE NO. 52958 SAMPLE TYPE: CROUNOWA
•• SOURCE: TRI CITY INDUSTRIAL
•• STATION ID: TRIC-08 SPRING CATTLEMAN
PROG ELEM: SSF COLLECTED BY: C TILL
CITY: BROOKS ST: KY
COLLECTION START: 12/04/90 1219 STOP: 00/00/00
,,,
•••
UG/L
10U SILVER
30U ARSENIC
N/A BORON
30 BARIUM '
5.0U BERYLLIUM
5.0U CADMIUM
10U COBALT
10U CHROMIUM
10U COPPER
10U MOLYBDENUM
20U NICKEL
40U LEAD
30U ANTIMONY
40U SELENIUM
25U TIN
93 STRONTIUM
SOU TELLURIUM
20 TITANIUM
1OOU THALLIUM
10U VANADIUM
10U YTTRIUM
14 2INC
N/A ZIRCONIUM
0.2U MERCURY
580 ALUMINUM
25 MANGANESE
ANALYTICAL RESULTS
MG/L
91
5.2
0 58
9.1
2.0U
ANALYTICAL RESULTS
CALCIUM
MAGNESIUM
IRON
SODIUM
POTASSIUM
«»»REMARKS»»«
•••REMARKS***
•A^AVERAGE'VALUE »NA-NOT ANALYZED .NAI-INTERFERENCES »J-ESTIMATED VALUE »N-PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
•K-ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUE GIVEN «L-ACTUAL VALUE IS KNOWN TO BE GREATER THAN VALUE GIVEN
• U-MATERIAL WAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM QUANT IT AT ION LIMIT.
-------
Tri-City Industrial Disposal Site
Responsiveness Summary
ATTACHMENT 7
Written Comments Received During Public Comment Period
and EPA'S Responses
-------
---.
,
- ---- ----
~
~
(!j
Waste Management of North Amer;ca. Inc.
3003 Bunerfield Aoao -:>aK ar:;cl(. :lIi -c.s ,::2'
May 31, 1991
Ms. Suzanne Durh~ -
Community Relations Coordinator
Waste Management Division (4WD-NSRB)
United States Environmental Protection Agency
Region IV
345 Counland Street, N.E.
Atlanta, Georgia 30365
Re:
Comments to the RIfFS and Proposed Plan
Tri-City Industrial Disposal Site
Bullett County, Kentucky
Dear Ms. Durham:
Waste Management of Kentucky, Inc., (WMK) and Ford Motor Company (Ford), which-
were identified by USEP A as potentially responsible parties at the site, have reviewed the
above-referenced documents and submit the attached comments for the Agency's review.
WMK and Ford believe the site has been adequately characterized and the selected remedy
is protective of human health and the environment. However, WMK and Ford believe the
sampling and analytical requirements contained in the proposed plan should be modified,
as indicated in the attached comments.
We would be pleased to meet with you at your convenience to discuss the comments.
Sincerely,
FORD MOTOR COMPANY
~~f) ;).~
Brett D. Heinrich
Environmental Counsel
WASTE MANAGEMENT OF
KENTUCKY, INC.
WASTE MANAGEMENT OF
KENTUCKY, INC.
BDH:lc
Attachments
708/572.8800 . ieiex: 253094. TWX. 910.651.0029
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COMMENTS ON PROPOSED PLAN
FOR REMEDIAL ACTION AT THE
TRI-CITY INDUSTRIAL DISPOSAL SITE
OPERABLE UNIT ONE
MAY 31, 1991
PREPARED FOR:
WASTE MANAGEMENT OF KENTUCKY, INC.
FORD MOTOR COMPANY, INC.
PREPARED BY:
SIRRINE ENVIRONMENTAL CONSULTANTS, INC.
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.
[
BACKGROUND
The U.S. Environmental Protection Agency (EPA) released a proposed plan for remediation of
Operable Unit One at the Tri-City Industrial Disposal Site ("Site") in Brooks, Kentucky in April
1991. The preferred remedy involves:
.
Treatment of the Cox, Sr., spring water with a carbon. adsorption system to
remove volatile organic compounds (VOCs)
Confirmatory sampling of the area where waste materials were removed during
EPA's Emergency Removal Action in 1988
Additional sampling of site media to further delineate the extent of contamination
Ecological monitoring of site surface waters (Brushy Fork Creek), biological
tissue analysis, and potentially histopathological studies.
.
.
.
Waste Management of Kentucky, Inc. (WMK) and Ford Motor Company (Ford) have been
identified by USEPA as potentially responsible parties (PRPs) at the Site. Tri-City Industrial
Services, Inc., a predecessor company to WMK, leased the site from October 1966 to December
1967 and hauled waste for Ford Motor Company.
WMK and Ford have reviewed the proposed plan and herewith submit the rationale for our
comments and requests consideration of changes in the plan based on these comments. WMK
and Ford are prepared to review these comments with EP A at their request.
ADDmONAL SAMPLING
Characterization of the Site was conducted during the following investigations:
.
Kentucky DNREPC (April 1987)
EPA Technical Assistance Team (August 1988)
EPA Field Investigation Team (NUS, August 1988)
.
.
1
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.
Remedial Investigation
Phase I (July 1989)
Phase n (November 1989)
EP A Environmental Services Division (December 1990)
.
In addition, EPA conducted an Emergency Removal Action in September 1988 involving the
removal of drums, free liquids and contaminated soils from the Site. Magnetometer,
electromagnetic and soil gas surveys were conducted midway through the investigations (August
. .
1988) to identify potential source areas. Based on these surveys, subsequent investigations were
focused on the southern portion of the Site. Site investigations involved analysis of the
following:
.
S waste samples
S 1 surface soil samples
26 subsurface soil samples
6 surface water samples
13 sediment samples
18 spring/groundwater samples
12 air samples
.
.
.
.
.
.
Six monitoring wells were installed while seven additional proposed wells could not be installed
due to the absence of groundwater at the Site. The low permeability bedrock underlying the Site
limits the vertical movement of groundwater and has led to preferential groundwater movement
marked by the fonnation of springs, which have been thoroughly monitored.
. The existing characterization of the Site is sufficient for the preparation of a baseline risk
assessment and evaluation of potential remedial alternatives. Further characterization of the Site
should be limited to presently identified areas of potential concern. Additional site sampling and
analysis should be ~mited to the .tasks outlined below per the headings given in the proposed
plan.
2
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Groundwater
Due to the underlying impenneable bedrock and the preferential flow to springs, only 6 out of
13 borings at the Site encountered free groundwater. Only one of the monitoring wells has
sufficient yield to sustain flow. As a result, well-point extraction would not be possible. The
13 borings delineate the potential distribution of groundwater at the Site. Funher
characterization can-best be accomplished through annual sampling of the springs for VOCs.
The Remedial Investigation indicated potential metals contamination at certain wells. However,
~e revised MCL for chromium is 100 ug/l(56 FR 3526; January 30, 1991). The maximum
chromium level of 74 ug/l at the site (MW-12) is therefore within the MCL. The proposed
corrective action level for nickel in groundwater is 700 ug/l (55 FR 30798; July 27, 1990). All
Site groundwater and springs are within this level for nickel.
S2il
1)
2)
3)
Confinnatory sampling of the waste disposal area affected by the Emergency Removal
Action is appropriate to define the residual contaminant concentrations and assess their
potential to impact spring water above MCLs.
PCBs were only found in lout of 20 surface soil samples collected during the RI. The
detected concentration (0.490 mg/kg) is less than EPA's recommended CERCLA cleanup
level of 1 mg/kg (OSWER Dir. No. 9355-4-01). PAHs were only found in 2 out of 20
. .
locations and were detected at concentrations below the minimum quantitation limit.
PCBs and P AHs were found at concentrations below regulatory concern in limited areas
of the Site. These compounds are not mobile (Section 5.2.3 of the RI) and funher
characterization is not warranted.
Magnetometer, electromagnetic and soil gas surveys conducted by EP A FIT in 1988
found no evidence of a potential source area in the northeast comer of the Site. Results
of these surveys were used to focus attention on the southern portion of the Site, which
was extensively trenched during the removal effort without finding significant areas of
3
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contamination outside of the removal action. No funher characterization of the nonheast
area is warranted.
4)
Surficial soil contamination along the periphery of the Site is generally absent except for
trace levels of a PCB and P AHs. These compounds are not mobile through surface
runoff and significant impact on the sloped areas is not anticipated. Any contamination
in the sloped areas would be expected to be observed in the surface water and sediments
of Brushy Fork Creek. With the possible exception of lead in sediments at one location
(SD-06), no site-related compounds were detected in surface waters or sediments. In the
absence of a significant sourCe or impact, characterization of the sloped areas is not
warranted.
~ediment
Sediment samples should be collected upstream, downstream and at sampling location SD-06 for
. - lead. Duplicate samples should be collected to establish any variability in analyses.
Air
Trace levels of PCE were detected during 2 out of 4 sampling events at the background sampling
location at the Site, approximately 450 feet away from the nearest residence. PCE was not
detected in the ambient air at the Cox, Sr. or Cox, Jr. residences. The risk levels generated for
inhalation of PCE are based on inappropriate exposure levels and toxicity factors (see
attachment). The actual risk level from inhalation of maximum PCE levels at the Site is 1.1 x
10-', which is below the risk range identified in the NCP (40 CFR 300.430). The presence of
PCE only at a background location, the absence of PCE at the residences, and the absence of
significant risks indicates that ambient air concentrations are not a concern at the Site.
Therefore, air monitoring is not warranted.
Surface Water
No site-related compounds were detected in any of the 11 surface water sampling stations. An
assessment by EPA's Ecological Support Branch and the Kentucky Division of Water in August
4
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r-
I
of 1990 detennined that any ecological impacts from the Site on Brushy Fork Creek are
8minimal8 and that additional biological testing of the water column and sediment was not
necessary if:
1)
2)
3)
the spring(s) of potential concern were treated
the source was remediated
water volume in the creek was monitored and impacted sediments were
. delineated.
These three requirements would be satisfied as follows:
1)
2)
treatment of the Cox, Sr. spring and monitoring of the remaining spring~'
confirmation sampling in the area of the Emergency Removal Action to define
any residual source concentrations and their potential to impact groundwater
stream gauging and delineation of the lead concentrations in the vicinity of SD-
06. .
3)
Biological monitoring is indicated only where there is chemical and/or observational evidence
of environmental impact, neither of which exists at the Site. The ecological assessment
concluded that any impacts on Brushy Fork Creek are the result of agricultural (nutrient) runoff.
In the absence of any significant impact from the Site and considering proposed remedial and
investigatory activities, biological monitoring of Site surface waters is not warranted.
Ecoloeical
. The only potentially site-related compound identified as posing a potential risk to the
environment is lead in the vicinity of sediment sampling station SD-06. The lead concentration
in sediments at SD-06 (610 mg/kg) is nearly ten times the highest concentration detected in Site
soils (71 mg/kg) , thereby calling into question the value at SD-06. Downstream sediment
samples were not contaminated, indicating a localized condition. Lead concentrations in the
vicinity of SD-06 and their potential risk to the environment will be addressed through sampling
5
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during Remedial Design. Lead is not considered to be a bioaccumulative material, which
precludes the need for any tissue analyses. Any ecological testing should be deferred pending
the results of the resampling in the vicinity of SD-06.
SPRING WATER TREATMENT REOUIREMENTS
The characterization of treatment requirements for the Cox, Sr. spring in the Feasibility Study
was sufficient for the evaluation of remedial alternatives. More detailed characterization of the
treatment p~ss will be required to assure the effectiveness of the remedy.
1)
Sedimentation would be ineffective for the removal of particle sizes that could
potentially plug activated carbon beds. Filtration, typically using a bag or
cartridge filter, is the preierred method of preiteatmefii.
implemented at the Site.
~.:t~.':_- "",,- "a "A'!II";1u
rl.1UGUVU \,oGJ1 u""" ~tw44W£'&J
2)
Naturally occurring iron levels at the Site can also cause plugging of carbon beds
through scale formation. Iron levels need to be quantified to assess the potential
for Scale formation.
3)
A single carbon column will not allow the most efficient use of carbon or provide
a safety factor for discharge. Carbon adsorption design typically involves two or
more columns in series.
4)
Gravity flow at the Site will involve placement of the carbon system down a
ravine, complicating operations and. maintenance. Therefore, the design may
have to be changed.
5)
The point of discharge for treated water, effluent requirements, and monitoring
requirements must be established prior to design. Contrary to the FS, discharge
to a surface water would be based on Federal and Commonwealth Ambient Water
Quality Criteria, not MCLs.
6
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6)
The period of carbon replacement will be defIned once the influent loadings and
effluent requirements are established. Design will anticipate a decrease in
influent concentrations over time (life-cycle design).
Based on these considerations, projected costs given in the FS are likely underestimated but still
within the required accuracy range of +50/-30 percent.
SITE ASSESSMENT SUMMARY
I
i-
Following several investigations of Site springs, the installation of 6 monitoring wells, and the
identification of the absence of groundwater at 7 locations, the only confirmed groundwater
impact at the Site is at the Cox, Sr. spring. The most likely source is the adjacent area where
the former d~ms and free liquids were removed by EPA in 1988. Total VOC concentrations
at the spring have decreased more than 20 percent between the RI sampling (November 1989)
and the EPA-ESD sampling (December 1990), indicating the effectiveness of EPA's removal
action toward lowering VOC concentrations at the spring.
I -
Attempts to locate another source at the Site included screening techniques (EM, magnetometer,
and soil gas surveys) to identify potential source areas for subsequent detailed characterization.
The screening techniques employed were extensive and allowed more effective assessment of a
defined portion of the Site. The screening survey was followed by extensive test pitting and soil
sampling. These procedures comply with EPA guidance for characterizing large areas
containing heterogeneous fill materials such as landfills (Conductine Remedial
InvestiiationsIFeasibility Studies for CERCLA Municipal Landfill Sites, EPA, February 1991).
The results of this testing found no potentially signifIcant source areas other than the area
addressed by EPA's Emergency Removal Action. The absence of other source areas is
cOrroborated by impacts identified only at the Cox, Sr. spring.
1-
The only area of potentially significant environmental impact is associated with lead levels in
sediments at the sainpling station SD-<>6.
7
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PROPOSED REMEDIAL RESPONSE
Areas of potential concern at the Site are limited to the following areas:
.3)
1)
2)
VOCs at the Cox, Sr. spring
potential residual VOCs in soils in the area of EP A's Emergency Removal Action
of 1988
lead in sediments at sampling station SD-06 in Brushy Fork Creek.
To address these areas, the following activities should be undertaken during Remedial Design:
1)
Conduct a more detailed evaluation of treatment system design for the Cox, Sr.
spring, including:
. proposed method for disposal of treated water discharge in
accordance with applicable effluent requirements
specific design elements, including flow range and influent total
organic carbon, iron, and total suspended solids concentrations
pretreatment for solids and scale-forming materials (e.g., iron)
whether the use of polishing carbon adsorber(s) would be
necessary
establish regular (annual) monitoring of other Site springs.
.
.
.
.
2)
Conduct confirmation sampling, via subsurface borings, of soils in the vicinity of
the Emergency Removal Action for VOCs. Evaluate the potential impact of any
residual VOCs on groundwater through unsaturated transport modeling (e.g.,
Vadose Interactive Process model). Evaluate the results with respect to potential
human health risks and ARARs and establish the need for further remedial
activities as Operable Unit Two.
8
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3)
Confirm the presence and extent of lead in sediments at SD-Q6. Based on these
results, evaluate the need for bioassay testing and/or remedial measures.
Remaining media at the Site have been adequately characterized and further assessment is not
warranted. Additional activities should further characterize only the areas of potential concern
which have been presently identified. .
9
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A IT ACHMENT: RISK ASSESSMENT OF PCE AIR CONCENTRATIONS
Risk levels identified in the Baseline Risk Assessment of airborne PCE are based on
inappropriate exposure levels and toxicity factors. The rationale for more realistic risk levels
follows.
PCE has been removed from the IRIS data base and presently is under review due to questions
on the strength of evidence for carcinogenicity. Assuming PCE is a carcinogen, calculation of
an alternative concentration level for air based on a 1 x 10-6 Cancer risk yields a value of 38 ppb
PCE (see attached equations). Likewise inhalation risk for residential exposure would be I.IE-?
for adult exposure based upon use of the following EP A toxicity and exposure factors (references
attached) :
"inhalation slope factor = 1.8E-3 (mg/kg-day)"l
inhalation rate = 20 m3/day (adult)
exposure time = 3 hrs/wk (adult)
exposure frequency = 350 dayslyr
exposure duration = 30 years (adult)
With regard to potential systemic toxicity, the use of an oral reference dose to calculate an
inhalation pathway, as was done in the Risk Assessment, is inappropriate. EPA's Human Health
Evaluation Manual (HHEM; 1989) guidance recommends contacting EPA's Environmental
Criteria and Assessment Office (ECAO) for guidance when route-specific reference doses are
not available. ECAO toxicologists will calculate a route-specific reference dose or recommend
a reference dose based on extrapolation from available reference doses. In the absence of this
information, HHEM guidance recommends a qualitative, not quantitative, treatment of risk.
ECAO toxicologists were contacted and confirmed that an oral reference dose was inappropriate
for exposure due to inhalation.
10
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On a semi-quantitative level, the ACGIH TW A (time weighted average) for PCE is 50 ppm (339
mg/mJ), while the STEL (short term exposure limit) is 200 ppm (1370 mg/mJ) based on an 8-
hour interval. These limits are set to prevent anesthetic effects and to provide a wide margin
of safety of liver injury. The OSHA PEL (permissible exposure level) is 25 ppm (170 mglm~.
The PEL establishes a safe level for worker exposure based on an 8-hour work day, which
exceeds the 3-hour weekly exposure value established by EPA for residential exposure. The
PEL level is approximately 6,000 times the maximum PCE air concentration measured at the
Site. These factors would indicate that the risk estimates for the air inhalation pathway were
inappropriately conservative. Considering the. measured concentration, frequency.and location
of detects, any risks from PCE inhalation should be insignificant for present and future
exposures.
The risk level of 1.IE-7 for inhalation of PCE is based on approved EP A factors and is more
realistic than that presented in the Site risk assessment. Even this level is likely overly
. . .
conservative considering that PCE was only found half of the time at a distance of 450 feet from
the nearest residence and in light of the questions regarding PCE carcinogenicity. The risk level
of 1.1E-7 is not considered significant per the NCP (40 CFR 300.430), and PCE air
concentrations at the Site are not a concern.
11
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Inhalation Slope Factor
DT (acceptable daily dose)
Inhalation PPL V
Inhalation Intake
Risk
. For Inh3lation of Volatiles:
Slope Factor =
PPLV
Risk
TRI-CITY INDUSTRIAL DISPOSAL SITE
RISK LEVEL BASIS AND CALCULATIONS
-
Unit Risk x 70 kg x 103
20 m3/day
=
S.2E-7 x 3500 = 1.8E-3 (mg/kg-day)"1
=
1 x l~ = 5.6 x 10~ mg/kg-day
1.8 x 1003
-
....I!T X BW x AT
mxET~EF"ED
=
5.6E-4 x 70 ke x 25550 days
0.83 m3/hr x 0.44 hr/day x 350 days/hr x 30 yr
2.6E-l mg/m3 = 3.8E-2 ppm = 38 ppb
-
-
CA x IR x ET x EF x ED .
BW x AT
-
2.8D-2 me/m3 x 0.83 m3/hr x 0.44 hr/day x 350 d x 30 yr
70 kg x 25550 d
-
6.0E-5
-
. Intake x Slope Factor
-
6.05E-5 x 1.8E-3 = 1.1E-7
-
1.8E-3 (mg/kg-day)"1
2.6E-l mg/m3 = 38 ppb
-
1.1E-7
12
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In calculation of PPL V and Intake/Risk, factors used that are different than those used by the
risk assessment (RA):
Slope Factor:
calculated from Unit Risk Factor found in EPA Health Effects
Assessment Summary Tables (January 1991)
Inhalation Rate:
20 m3/day, as per EPA Supplemental Guidance (March 25, 1991).
The RA used 30 m3/day.
Exposure Time:
3 hours per week time spent outdoor at residence by adult, as per
EPA Exposure Factors Handbook (1990)~ The RA u~ lIS
hours/week inside residence.
Exposure Frequency:
350 days/year, as per EPA Supplemental GuidanCe. The RA used
365 days/year. '
Exposure Duration:
30 years upper bound time at one residence, as per EP A HHEM
guidance. The RA used 48 years, broken down into six age
groups. The risk level of 1.IE-7 is baSed on a 3O-year adult
exposure.
i-
13
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..
Office 01 the General Counlel
Ford Motor Complny
Park line Towera Welt, SUite 401
One Parklana Boulevard
Oearborn, Michigan 48128
June 25, 1991
Ms. Suzanne Durham
Community Relations Coordinator
Waste Management Division (4WD-NSRB)
u.S. Environmental Protection Agency
. Reg ion IV
345 Courtland'Street, N.E.
Atlanta,.. Georgia 30365
Re:
Comments to the RIfFS and Proposed Plan
Tri-City Industrial Disposal Site
Bullitt County, Kentucky
Dear Ms. Durham:
Under a cover letter dated May 31, 1991, and signed by Brett
D. Heinrich, Environmental Counsel, Waste Management of Kentucky,
Inc. ("WMK"), a document entitled "Comments on Proposed Plan for
Remedial Action at the Tri-city Industrial Disposal Site Operable
Unit One" ("Comments") was forwarded to you. This document was
sent without an opportunity on the part of Ford Motor Company
("Ford") to review the final draft. The purpose of this letter
is to clarify the position of Ford with respect to a statement
which appears in the Comments.
The last sentence of the first paragraph on page 1 of the
Comments states that "Tri-City Industrial Services, Inc., a
predecessor company to WMK, leased the site from October 1966 to
, December 1967 and hauled waste for Ford Motor Company." This
sentence is literally correct in that Tri-City did haul waste for
Ford during the stated time period. However, to the extent the
sentence may be read to imply that Ford waste was hauled to the
Tri-City Ipdustrial DisDosal Site,. Ford denies any such implica-
tion. Ford's position on this matter has been set forth in the
pleadings filed in u.s. v. Waste Management of Kentuckv. Inc.. et
al., Action No. C-90-0632-L(S), and the statement in the Comments
does not represent a change in that position. .
-------
-2-
Please include this letter in the administrative record for
the Tri-city Industrial Disposal Site. Thank you for your
attention.
S7J(Jr~.
Mark D. Edie ~
Staff Attorney
MDE:se
I'
I
cc:
Brooke F. Dickerson
Brett D. Heinrich
Robert E. Leininger
Paul G. Wolfteich
I
"
-------
V ; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
V"» ' V
»y «c-.i- REGION IV
345 COURTLANO STREET NE
ATLANTA. GECRGlA 3O365
4WD-NSRB
AUG 0 2 1331
Brett D. Heinrich
Environmental Counsel
Waste Management of North America, Inc.
3003 Butterfield Road
Oak Brook, Illinois 60521
RE: Comments on the Proposed Flan
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
Dear Mr. Heinrich:
This letter is in response to the'comments submitted by Waste
Management of Kentucky, Inc. and Ford Motor Company on the*
Remedial Investigation (RI) and Feasibility Study (FS) Reports
and the Proposed Plan for the Tri-City Industrial Disposal Site
in Brooks, Kentucky. Since your comments were not itemized,
this response will address the conclusions and recommendations
as they appear in the submitted report dated May 31, 1991.
Although we concur that the selected remedy for Operable Unit #1
is protective of human health and the environment, we believe
that confirmatory sampling is necessary to completely
characterize the areas of concern on-site. Details regarding
the numbers of samples and sample locations will be finalized
during the Remedial Design (RD) phase.
EPA has the following responses to the comments in your report:
1) Page 2, Paragraph 3: The existing characterization of
the Site is sufficient to address the groundwater
contamination. As described in the RI (specifically,
the Baseline Risk Assessment) and the FS Reports,
definitive conclusions about surface soil contamination
along the eastern edge of the former disposal area,
sediment contamination in the tributary to Brushy Fork
Creek, and ambient air contamination along the slopes
of the Cox Lobe cannot be made based on existing data.
Confirmatory sampling is necessary in these areas, the
area where the Emergency Removal Action was conducted,
and the northern portion of the Site (as shown in the
EPIC aerial photograph taken in 1967) where drum
storage and/or disposal potentially occurred to
adequately characterize any contamination and assess
the associated risk.
Printed on Recycled Paper
-------
.
Mr. Heinrich
Auqust 2, 1991
Page 2
2)
Page 3, "Groundwater" section: Although the levels of
lead and nickel found in several of the groundwater
monitoring well samples were above the action level for
lead and the proposed Maximum Contaminant Level (MCL)
for nickel, the detected levels did not appear to be
raflective of anyone water-bearing zone. Lead was
detected in the wells screened in the Muldraugh Member
and the Nancy Member. It was not detected in the zones
immediately underlying the Site. Nickel was found in
the Harrodsburg Limestone, the Muldraugh Member, and
the Nancy Member.
Both metals occur naturally in the area of the Site,
which is a sedimentary environment dominated by
limestones, shales, and siltstones. Moreover, these
metals were not detected°i.ri the spring samples, which
were the primary sources of potable water for on~site
residents. Consequently, remedial action is not
justified based on the detections of .lead and nickel.
3)
Note: The proposed MCL for nickel is 100 ug/l (55 FR,
July 25, 1990), not the 700 ug/1 level stated in the.
comments report. .
Page 3, Item 2: The Baseline Risk Assessment revealed
a potential risk to human health from the ingestion of
garden crops and beef from cattle raised on-site based
on the levels of PASs and PCBs found in surface soils
during the RI and the previous soil sampling conducted
by BPA in June 1988. However, the risk estimates
calculated for the vegetable and beef pathways were
based on only two positive detection values.
Confirmatory sampling is necessary to generate data
that better characterizes the area of concern. The
number of samples and the sample locations will be
finalized during the RD phase.
4 )
Page 3, Item 3: Although the geophysical survey
conducted by BPA's Field Investigation Team in August
1988 included the northern portion of the Site, none of
. the 8ampling locations for the field analytical
screening procedures (FASP) were in this area (see
Piqure 2-13 from the RIIFS Work Plan developed by NUS
Corporation). An electromagnetically anomalous area
was detected in the northern area of the Site
immediately south of the Cox, Jr. residence (see Figure
2-8 in the RIIFS Work Plan). Moreover, based on the
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Mr. Heinrich
August 2, 1991
Page 3 .
6)
7 )
5)
analysis of two aerial photographs of the Site taken in
1966 and 1967, drum storage andlor disposal is a
probability in this area. Consequently, confirmatory
sampling is proposed in Operable Unit 11 to identify
apd determine the extent of any contamination that may
be present.
Page 4, Item 4: The slopes of the Cox Lobe will be
investigated further if the results of the additional
air sampling indicate that a potential source exists.
Page 4, "Sediment" section: Although sediment quality
criteria have not been establised for metals, effects
levels have been estimated by the National Oceanic and
Atmospheric Administration based on the response of
test organisms to single.~dxins, including metals. The
effects range-lower (ER-L) is a concentration of a
single analyts At tha lo~ end of the r~n9~ in. which
effects have been observed. The ER-L values for
chromium, lead, and mercury were exceeded in the
sediment sample SD-06 collected from the drainage.
pathway of the unnamed spring into Brushy Fork Creek.
during the RI. The ER-L value for lead was also
exceeded in the downstream sediment sample SD-11.
Consequently, the sediment in the area of the sample
SD-06 and extending to the area of the sample SD-11
will be sampled further during the RD/RA phase to
determine the extent of the metals contamination.
Page 4, "Air" section: The exposure levels and
toxicity factors used to generate the risk levels for
inhalation of air contaminated with tetrachloroethene
(also known as perchloroethylene, or PCE) were
appropriate at the time the Baseline Risk Assessment
was performed. Some of the quidance values discussed
in the attachment to the comments were issued after the
Ba.eline Ri.k Assessment was performed. For example,
the Human Health Bvaluation Manual Supplemental
Guidance was issued on March 25, 1991 and the Baseline
Ri.k A8se.sment for the Tri-City Site was finalized in
Augu.t 1990.
. .
The source of the toxicity value. for PCB that were
used in the Baseline Risk A..e.sment i. the Health
Effect. Summary Table. (BEAST) generated in the Fourth.
Quarter of FY89. The carcinogenic cla..ification of.
PCB has been verified and the slope factor has changed
'since that time. However, the values used in the
Baseline Ri.k A8sessment were correct at the time of
their u.e.
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Mr. Heinrich
August 2, 1991
Page 4
8)
Two out of-three air samples that were collected at a
location along a slope of the Cox Lobe contained PCE.
These samples were collected over a period of one month
during the RI. The Baseline Risk Assessment revealed
th~t the air pathway is a cu~rent exposure pathway that
is sti_l of concern not only because of the risk
_associated with the detected contamination, but also
because additional information regarding the source and
seasonal variation in contaminant levels is necessary.
The risk estimate based on the two positive detection
values may be an underestimate and future sampling is
necessary to determine if this is a one-time effect, if
the PCB is originating on-site, and if there is a
source of the PCB on-site. The risk estimate will be
re-calculated based on the new data and current
toxici ty values. ". .
Pages 4 & 5, "Surface Water" section: The U.S.
Department of the Interior, as a federal natural
resource trustee, recommended the performance of a
biological contaminant monitoring program at the
Tri-City Site. This recommendation was documented in "a
letter dated Auqust 24, 1990 from Mr. Mark Wilson,
Contaminant Specialist from the Fish & Wildlife
Service, following a cursory site reconnaissance
conducted jointly with EPA in Auqust 1990. Since an
evaluation of the potential threat to non-human (i.e.,
environmental) receptors has not been performed, a
biological contaminant monitoring program will be
included in Operable Unit tl~ BPA has been in
communication with Mr. Wilson to coordinate the
development of a site-specific program. The details of
the sample frequencies, locations, and media will be
finalized during the RD phase.
9)
Page 6, "Spring Water Treatment Requirements" section:
The detailed design of the carbon adsorption treatment
.y.tem for the Cox Spring will be developed during the
Remedial Design phase of the Superfund process. Should
you elect to conduct the Remedial Design/Remedial
Action for Operable Unit '1, BPA will evaluate your
de.ign recommendations during that phase of the
process.
The performance standards- for the treatment system will
include the standards establi.hed by the Safe Drinking
Water-Act and the Clean Water Act. Remediation of
contaminated groundwater for a Cla.. 11-8 aquifer is
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Mr. Heinrich
August 2, 1991
Page 5
10)
required to meet MCLs as established by the Safe
Drinking Water Act (40 CFR Part 141) and, if possible,
to attain Maximum Contaminant Level Goals (MCLGs).
Since the treated water will be discharged to the
downstream tributary, the discharge is required to meet
. the National Pollutant Discharge El~nation System
(NPDES) standards established by the Clean Water Act
and regulated by the Commonwealth of Kentucky.
Page 7, Paragraph 1 of the "Site Assessment Summary"
section: It is not po~sible, based on existing data,
to quantitatively define a trend of decreasing VOC -
levels in all of the springs. The two tables included
in this letter as Enclosures .1 and .2 summarize the
data from the organic analyses of the samples collected
from the Cox and Klapper Springs.
In the Cox Spriuq, ~~antitiaQ of l,l-diohloroeth~nei
1,2-dichloroethene, 1,1,1-trichloroethane, and vinyl
chloride increased between the sampling event conducted
by EPA in May 1988 and the RI sampling conducted in
July 1989. The minimum quantitation limits for the
analyses of 1,1-dichloroethane, 1,1,1-trichloroethane,
and vinyl chloride in the samples collected in December
1990 were set too high to produce comparable data.
While the level of tetrachloroethene in the Cox Spring
decreased from May 1988 to July 1989, it increased from
July 1989 to December 1990. The level of toluene was
also elevated in the December 1990 sample. Only the
level of trichloroethene appeared to consistently
decrea.e over time.
In the Klapper Spring, the level. of VOCs have
decreased over time and only tetrachloroethene was
detected in the December 1990 sample. The primary
contaminant of concern in the Cattle Spring, toluene,
has decreased from 9.4 ppb in May 1988 to an undetected
level above the minimum quanti tat ion limit of 5 ppb
during the RI. Toluene was detected at an estimated
level of 0.58 ppb in the December 1990 sample.
voc. have not been detected in the .ample. collected
from Brading Spring .2 by Kentucky in April 1987 and
during the RI in July 1989. The unnamed spring has
apparently only been .ampled once and that was by
Kentucky in April 1987. Trans-1,2-dichloroethene,
1,1,1-trichloroethane, trichloroethene, and
tetrachloroethene were detected in the sample from the
unnamed spring- .
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Mr. Heinrich
Auqust 2, 1991
Page 6
11)
12)
13)
BPA believes that the drums removed during the 1988
action were the primary source of the groundwater
contamination. Bowever, confirmatory sampling in the
area of the removal will determine if that source was
completely removed. Moreover, long-term monitoring of
the-groundwater is necessary to identify a trend of
decreasing VOC levels in the Cox Spring and the unnamed
spring, and to ensure that contaminant levels remain
below MCLs in the Klapper and Cattle Springs.
Page 7, Paragraph 2 of the "Site Assessment Summary"
section: .See EPA's response in Item 4 of this letter.
Page 7, last sentence: The areas of concern at the
Tri-City Site that require further investigation have
been previously discussed -In this letter. With regards
to potential contaminants in the sediment in the area
of RI sample SD-06, see Item 6 of this letter.
Pages 8 , 9, "Proposed Remedial Response" section: The
conclusions and recommedations on these pages have been
previously addressed in this letter.
Pages 10-13, Attachment: The statement that PCB has
been removed from the IRIS database is incorrect. The
carcinogenic information for PCB has not been included
in IRIS yet. The information has been verified and it
is pending input into IRIS at the present time.
If you have any questions regarding this response, please
contact me at (404) 347-7791.
14)
Sincerely yours,
~
Kimberly J. 8 .I.T.
Remedial Project Manager
Kentucky/Tenn..see Remedial Section
North Superfund Remedial Branch
Waste MaDagement Divi.ion
'Enclosure.
cc:
Mark Edie/Pord Motor Company
Harold Taylor/EPA
Brooke. Dickerson/SPA
-------
Letter to Mr. Seinrich
August 2, 1991
ENCLOSURE *1
CONTAMINANT LEVELS IN COX SPRING (IN PPB)
CONTAMINANT MAY 1988 RI RI-DUP DEC 1990
Chloroform 2.2J 5U 5U 100U
1,1-Dichloroethane 2.5J 4J 4J 100U
1,1-Dichloroethene 1.2J. 5U 5U 100U
Cis-1,2-Dichloroethene 74J 260 * 280 * 48J
Trans-1,2-Dichloroethene 0.92J 100U
Tetrachloroethene 560 88 89 250
l,l,l-Trichloroethane 8.1 . 11 .11 100U
Trichloroethene 69J 20 20 l2J
Toluene 5.0U 5U 5U 21J
Vinyl chloricie ... "'.. ." "2") 1nnn
~.~t.J ~... .... -...--
U indicates that material was analyzed for but not detected;
the number is the minimum quantitation limit.
* indicates total level of 1,2-dichloroethene detected.
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Letter to Mr. Heinrich
August 2, 1991
ENCLOSURE 12
CONTAMINANT LEVELS IN KLAPPER SPRING (IN PPB)
CONTAMINANT KY SI MAY 1988 RI DEC 1990
1,1-Dichloroethene 1.1 SOU SU S.OU
Cis-1,2-Dichloroethene DNA SOU SU * S.OU
Trans-l,2-Dichloroethene <1 SOU S.OU
Tetrachloroethene 311 48J SU 0~77J
Toluene DNA SOU SU S.OU
1,1,1-Trichloroethane 1.2 SOU SU S.OU
Trichloroethene <1 .. -SOU SU S.OU
Vinyl Chloride DNA SOU 10U S.OU
DNA indicates data not available
U indicates that material was analyzed for but not detected~
the number is the minimum quanti tat ion limit.
* indicates the total level of 1,2-dichloroethene detected
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UNITED STATES ENVIRONMENTAL PROTECTIONAGEt!CY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
4WD-NSRB
JUL 3 0 1991'
Tom FitzGera~d, Director
Kentucky Resources Council
Post Office Box 1070
Frankfort, Kentucky 40602
RE:
Comments on Proposed Plan
Tri-City Industrial Disposal Site
Brooks, Bullitt County, Kentucky
Dear Mr. FitzGerald:
This letter is in response to your comments dated June 6, 1991
regarding the Proposed Plan for the Tri-City Industrial Disposal
. ~iT~ in RrnnKs. Kentuckv. Althouah vou concurred with the
~~;;e;ts-;~b~tt~d-by the Commonwealth of Kentucky to EPA in a
letter dated April 4, 1991, your letter specifically addressed
two of the Commonwealth's concerns. '
EPA disagrees with the Commonwealth's position regarding not
taking remedial action at the Tri-City Site until the site has
been "completely" characterized. Based on the existing data
from the sampling activities that have been conducted at the
site, treatment of the Cox Spring is justified by the fact that
this spring was a potable water source that still contains
volatile organic contaminant levels in excess of Maximum
Contaminant Levels (MCLs).
EPA identified other areas of concern during the Remedial
InvestigAtion, but these areas require additional sampling to
determine the extent of any contamination and the associated
risk. Consequently, EPA is addressing this site as operable
units, as defined in the National Contingency Plan. Operable
Unit #1 will include the remediation of contaminated groundwater
as it vents to the surface and confirmatory sampling to identify
any unacceptable levels of hazardous contaminants in areas of
the site not otherwise addressed. Operable unit #2 will involve
the additional measures necessary to mitigate any threat to
human health and the environment identified during the
confirmatory sampling conducted in Operable Unit #1.
EPA is successfully using operable units to expedite needed
'remedial actions ,at Superfund sites where sufficient data exists
to warrant ~ remedial action, but where additional data is
needed to complete all potential remedial actions at the site.
The alternative to not using operable units would be to delay
needed remedial actions in order to collect additional data.
Printed on Recycled Paper
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.. .-_. -.
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Mr. FitzGerald
July 30, 1991
Page 2
EPA does not recognize KRS 224.877 as a state Applicable or
Relevant and Appropriate Requirement (ARAR) since it does not
contain any specific, enforceable requirements that are more
stringent th~n provided by federal la~. EPA's position with
regards to KRS 224.877 is explained in the letter dated July 24,
1991 in response to the Commonwealth's comments dated April 4,
1991. A copy of EPA's response is enclosed for your reference.
If you have additional concerns, please do not hesitate to
contact me.
Sincerely yoursy
};j W
1!1~. ~ Jr., Chief
Kentucky/Tennessee Remedial Section
North Superfund Remedial Branch
Waste Management Division
Enclosure
cc:
Carl Millanti, Commonwealth of Kentucky
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Post Office Box 1070
Frankfort. Kentucky 40602
(502) 875-2428
June 6, 1991
Ms. Suzanne Durham
Community Relations Coordinator
Waste Management,Division (4WD-NSRB)
u.S. Environmental Protection Agency
Region IV
345 Courtland Street NE
Atlanta GA 30365
Re: Tri-City Industrial Disposal Site
Proposed Remedial Plan
Dear Ms. Durham:
The Kentucky Resources Council, Inc. (Council), a non-profit
membership organization comprised of Kentuckians concerned with
the prudent use ana conservation of the natural resources of the
Commonwealth, submits these comments on the proposed remedial plan
for the Brooks, Kentucky Tri-City Industrial Disposal Site.
The Council appreciates EPA allowing these comments to be
submitted outside the formal comment period. After a review of
the proposal, the Council concurs with the comments submitted by
letter of April 4, 1991 by the Commonwealth of Kentucky, Division
of Waste Management, Uncontrolled Sites Branch, and incorporates
those comments herein as if fully set forth below.
The Council understands that EPA is under some pressure to
produce "results" under the Superfund program, but external
pressures cannot justify adoption of a remedial plan when the
underlying site investigation and characterization has not been
completed in a satisfactory manner that identifies fully the fate
and transport of contaminants into the local environment.
The Council is also concerned that the provisions of KRS
224.877 have not been respected as the ARAR in this case. The
state statute, which governs hazardous substance and environmental
emergency remediation, plainly demands that the remediation be
taken to natura~ly occurring backround levels, or that extensive
documentation of the absence of environmental risk from residual
contamination be provided where clean-up to less-than-background
is proposed.
printed on :00"'. recycled paper
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The inter-agency friction that has developed due to the
failure to accord KRS 224.877 the proper respect as an ARAR in
this and other cases is counterproductive and provides inadequate
protection to the public and the natural environment. The Council
urges your of ice to reconsider the proposed remedial plan, to
reopen the remedial investigation in order to more fully
characterize the site; and to propose a remedy consistent with KRS
224.877.
Thank you for your consideration of these comments.
Sincerely,
Tom FitzGer ld
Director
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