United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R04-91/088
September 1991
Superfund
Record of Decision:
Smith's Farm Brooks
(Amendment), KY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-91/088
3. Recipient1 • Accession No.
4. TWe and Subtitle
SUPERFUND RECORD OF DECISION
Smith's Farm Brooks, KY
First Remedial Action - (Amendment)
5. Report Date
09/30/91
7. Author(a)
8. Performing Organization Rept No.
8. Performing Organization Name and Addreaa
10. ProJect/Taak/Work UnM No.
11. Contr»ct(C) or Grant(G) No.
(C) .
(G)
12. Sponaoring Organization Name and Addreaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report A Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 worda)
The 500-acre Smith's Farm Brooks site is a former hazardous waste disposal area
located in Brooks, Bullitt County, Kentucky. The site is bordered on the north,
east, and west by forested hills and on the south by a residential area. The site
includes a 37.5-acre landfill that, until recently, was permitted by the State for
the disposal of solid waste. The site also includes an 80-acre area upgradient of
the permitted landfill on a mile-long ridge between two intermittent creeks where the
unpermitted disposal of drums containing hazardous waste occurred over a 20-year
period. This area has been divided into two areas known as Area A and Area B. As a
result of EPA investigations in 1984 that revealed chemicals leaking from drums, EPA
removed 6,000 drums of surface wastes, excavated contaminated soil, and implemented
site stabilization and erosion prevention measures. A 1989 Record of Decision (ROD)
addressed source control in the 80-acre area through thermal destruction.
Investigations during the RD revealed lower levels of PCBs and a lower volume of soil
requiring treatment than what was previously estimated in the RI, making incineration
less practical. This ROD amends the 1989 ROD and provides source control in the
80-acre area using chemical treatment, rather than thermal treatment. A second
(See Attached Page)
17. Document Analyaia a. Descriptor*
Record of Decision - Smith's Farm Brooks, KY
First Remedial Action - (Amendment)
Contaminated Media: soil, sediment, debris
Key Contaminants: organics (PAHs, PCBs), metals (lead)
e. COSATI Held/Group
J. AvailabiBty Statement
19. Security Class (This Report)
None
20. Security Ctats (Thla Page)
None
21. No. of Pages
208
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R04-91/088
Smith's Farm Brooks, KY
First Remedial Action - (Amendment)
istract (Continued)
operable unit will address remaining potential threats associated with the landfill, deep
ground water aquifers, and other suspected areas of drum disposal. The primary
contaminants of concern affecting the soil, sediment, and debris are organics including
PCBs and PAHs, and metals including lead.
The amended remedial action for this site includes excavating 16,000 cubic yards of
contaminated soil and excavating contaminated stream sediment in Area B, as defined in
the RI/FS; treating Area B soil and sediment onsite by a chemical process, possibly
dechlorination or hydrocarbon removal using APEG or BEST, respectively, and by a
solidification/fixation process; overpacking debris from Area B and disposing of the
overpacked debris and all treated soil and sediment from Area B onsite within Area A;
consolidating the contaminated soil, sediment, and debris from peripheral areas of Area A
into Area A; recontouring Area A; constructing and maintaining retaining walls, surface
runon/runoff control systems, and a leachate collection system in Area A, with onsite or
offsite treatment and disposal of leachate; capping Area A with a RCRA cap after all
material from Area A and B have been disposed of in Area A; ground water monitoring; and
implementing institutional controls including land use restrictions, and site access
restrictions. The estimated present worth cost for this remedial action ranges from
$22,000,000 to $25,000,000, based on the treatment selected. O&M costs were not
provided.
PERFORMANCE STANDARDS OR GOALS: Action levels for contaminated soil and/or sediment were
determined based on an excess lifetime cancer risk of 10~5, with the exception of lead,
"lich was based on an HK1. Chemical-specific goals for soil include PAHs 2 mg/kg and
.ead 500 mg/kg, and for sediment PAHs 5 mg/kg and PCBs 2 mg/kg.
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AMENDMENT
TO THE
RECORD OF DECISION
Fundamental Change to the Selected Remedial Alternative
SITE NAME AND LOCATION
Smith's Farm Site (First Operable Unit)
Brooks, Bullitt County, Kentucky
STATEMENT OF BASIS AND PURPOSE
This amendment to the decision document presents a fundamental
change to the selected remedial action for the Smith's Farm Site
(First Operable Unit), Brooks, Bullitt County, Kentucky,
developed in accordance with CERCLA, as amended by SARA, and
the National Contingency Plan. The following documents form the
basis for the fundamental change to the selected remedial
action:
- Remedial Investigation Report, Smith's Farm Site
- Feasibility Study Report, Smith's Farm Site
- Record of Decision, Smith's Farm Site, Operable
Unit One
- Preliminary and Intermediate Remedial Design
Reports, Smith's Farm Site, Operable Unit One
- Responsiveness Summary II, Smith's Farm Site,
Operable Unit One
DESCRIPTION OF THE MODIFIED REMEDY
The purpose of this Record of Decision Amendment is to modify
the remedy, based upon new information including recent sampling
data, so that the selected remedy is better suited to the
particular conditions posed by this Site.
The major components of the selected remedy include;
Site Area B and Stream Sediments
- Excavation to bedrock of contaminated soil and waste
materials from Site Area B and excavation of
contaminated stream sediments
- Chemical treatment (dechlorination or hydrocarbon
removal) and solidification/fixation of the
contaminated soils from Area B and the
contaminated stream sediments
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- 2 -
Site Area A
Recontouring Area A to achieve a maximum eighteen (18)
percent slope, combined with the consolidation of
wastes from peripheral areas and construction of
retaining walls for slope stabilization
"RCRA" Cap over Area A with engineered run-on and
run-off structures
Construction of a leachate collection system to
collect contaminated water discharging from Area A
General
- Access restriction and imposition of land-use
restrictions for contaminated areas
- Annual ground water monitoring for organic
contaminants and biennial ground water monitoring
for inorganic contaminants for up to thirty (30) years
- Maintenance of the "RCRA" cap and the leachate
collection system and associated run-on and run-off
control systems for up to thirty (30) years
- Leachate treatment, on-site or off-site, and proper
disposal and/or discharge for up to thirty (30)
years
DECLARATION
This modified remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate to the remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and
utilizes permanent solutions .and alternative treatment
technologies to the maximum extent practicable.
Because this remedy may 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.
S£r *c l"'
Date y^Greer C. Tidwell
Regional Administrator
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AMENDMENT TO THE RECORD OF DECISION
(A Fundamental Change to the Remedy]
SMITHS FARM CERCLA NPL SITE
OPERABLE UNIT ONE
Brooks, Bullitt County/ Kentucky
PREPARED BY:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
September 30, 1991
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CONTENTS
1.0 INTRODUCTION
1.1 SITE NAME AND LOCATION
1.2 LEAD AND SUPPORT AGENCIES
1.3 CERCLA Section 117 and NCP 300.435(c)(2)(ii)
1.4 ORIGINAL RECORD-OF-DECISION
1.5 SUMMARY OF CIRCUMSTANCES LEADING TO THE NEED
FOR A ROD AMENDMENT
1.6 ADMINISTRATIVE RECORD (NCP Section 300.825(a)(2))
1.7 ADMINISTRATIVE RECORD AVAILABILITY
2.0 REASONS FOR ISSUING ROD AMENDMENT
2.1 DESCRIPTION OF REMEDY SELECTED IN THE ORIGINAL
RECORD-OF-DECISION
2.2 SUMMARY OF RATIONALE FOR CHANGING THE REMEDY
SELECTED IN THE ORIGINAL RECORD-OF-DECISION
2.2.1 Comparison of RI and RD Soil Data
2.2.2 New Estimate of Soil Volume
2.2.3 Change in Remediation Technology
2.2.4 Conclusion
3.0 DESCRIPTION OF THE NEW ALTERNATIVE
3.1 COMPARISON OF THE ORIGINAL SELECTED REMEDY
WITH THE MODIFIED REMEDY
3.1.1 Treatment Component.
3.1.1.1 Original Remedy's Treatment Component.
3.1.1.2 Modified Remedy's Treatment Component.
3.1.2 Containment Component.
3.1.2.1 Original Remedy's Containment Component.
3.1.2.2 Modified Remedy's Containment Component.
3.1.3 Ground Water Component.
3.1.3.1 Original Remedy's Ground Water Component.
3.1.3.2 Modified Remedy's Ground Water Component.
3.1.4 General Components.
3.1.4.1 Original Remedy's General Components.
3.1.4.2 Modified Remedy's General Components.
3.1.5 Manor ARARs.
3.1.5.1 Original Remedy's Major ARARs.
3.1.5.2 Modified Remedy's Major ARARs.
4.0 EVALUATION OF THE ALTERNATIVE
4.1 PROFILES OF THE ORIGINAL SELECTED REMEDY AND THE
MODIFIED REMEDY USING THE NINE CRITERIA IN CERCLA AND
THE NCP
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4.1.1 Overall Protection of Human Health and
the Environment.
4.1.1.1 Original Remedy.
4.1.1.2 Modified Remedy.
4.1.2 Compliance with ARARs.
4.1.2.1 Original Remedy.
4.1.2.2 Modified Remedy.
4.1.3 Long-Term Effectiveness and Permanence.
4.1.3.1 Original Remedy.
4.1.3.2 Modified Remedy.
4.1.4 Reduction of Toxicity. Mobility or Volume
Through Treatment.
4.1.4.1 Original Remedy.
4.1.4.2 Modified Remedy.
4.1.5 Short-Term Effectiveness.
4.1.5.1 Original Remedy.
4.1.5.2 Modified Remedy.
4.1.6 Implementability.
4.1.6.1 Original Remedy.
4.1.6.2 Modified Remedy.
4.1.7 Cost.
4.1.7.1 Original Remedy.
4.1.7.2 Modified Remedy.
4.1.8 State Acceptance.
4.1.8.1 Original Remedy.
4.1.8.2 Modified Remedy.
4.1.9 Community Acceptance.
4.1.9.1 Original Remedy.
4.1.9.2 Modified Remedy.
5.0 STATUTORY DETERMINATIONS
5.1 SATISFACTION OF CERCLA Section 121
6.0 COMMUNITY RELATIONS
6.1 COMMUNITY RELATIONS ACTIVITIES
6.2 RESPONSIVENESS SUMMARY
6.2.1 Overview.
6.2.2 Background on Community Involvement.
6.2.3 Summary of Major Public Comments Received During
the Public Comment Period and EPA Responses to the
Comments.
7.0 ATTACHMENTS
7.1 RECORD OF DECISION (September 29, 1989)
7.2 TRANSCRIPT OF PUBLIC MEETING (July 18, 1991)
and LIST OF MEETING ATTENDEES
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7.2.1 Magistrate Mitchell's letter to EPA and
EPA's Response.
7.2.2 Kentucky's January 8. 1991 Comments on
the Draft Preliminary Remedial Design and
EPA7s Responses to those Comments.
7.2.3 Kentucky's Letter of September 26. 1991.
7.3 RI and RD SOIL DATA SUMMARIES
7.3.1 Remedial Investigation Data Summaries.
7.3.2 Remedial Design Investigation Data
Summaries.
7.4 INFORMATION ON TREATABILITY TESTS
7.4.1 Summary of Thermal Destruction and
Solidification/Fixation Treatability Studies.
7.4.2 Summary of Chemical Treatment Treatability
Study.
7.4.3 Summary of Bioremediation Treatability
Study.
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1.0 INTRODUCTION
1.1 SITE NAME AND LOCATION
The Smith's Farm Site is located in a rural area of Bullitt
County, Kentucky, approximately fifteen (15) miles south of
Louisville. The CERCLA Site is the 500-acre Smith's Farm
property approximately 1.5 miles southwest of Brooks, just north
of Pryor Valley Road (Figure 1). The Site includes two disposal
areas where disposal of hazardous waste occurred over a twenty
(20) year period. The area addressed by this Record of Decision
(ROD) Amendment, is an 80-acre area where numerous drums
containing hazardous waste were buried and scattered. The area
is on a mile-long ridge between two valley streams. The main
stream on the south side of the ridge is the Unnamed Tributary
which flows south to Blue Lick Creek (Figures 2 and 3). The
phase of the remedy which will address this disposal area has
been designated Operable Unit One. The second disposal area, a
formerly permitted landfill in the southern portion of the
Smith's Farm Site, will not be addressed by Operable Unit One,
but is the subject of an ongoing Remedial Investigation and
Feasibility Study (RI/FS) and is not the subject of this
Amendment.
1.2 LEAD AND SUPPORT AGENCIES
EPA has been the CERCLA lead agency since initiating an
immediate removal in 1984 in the area addressed by Operable Unit
One. The Site was ranked in 1985-86 and EPA placed the Site on
the National Priorities List (NPL) in June 1986. In 1987 EPA
attempted to negotiate with the potentially responsible parties
(PRPs) to undertake a Remedial Investigation and Feasibility
Study (RI/FS). Negotiations were unsuccessful and EPA undertook
the RI/FS utilizing its own contractor and Fund financing.
The RI/FS was completed in 1989. The Record-of-Decision (ROD)
was signed in September2" 4.98 9. Negotiations for implementation
of the Remedial Design/Remedial Action (RD/RA) began in December
1989, but were unsuccessful. A Unilateral Administrative Order
(UAO) for implementation of the RD/RA was issued to 36 PRPs in
March 1990. The Remedial Design and associated activities have
proceeded under an EPA enforcement lead.
EPA has consulted with the Commonwealth of Kentucky with respect
to response activities, and the Commonwealth has reviewed and
commented on both EPA decisions and PRP technical documents. At
the Operable Unit Two area the Commonwealth oversaw disposal
activities until it let the disposal permit expire in May 1989.
Kentucky did not concur with the original Record of Decision
(ROD) for the area addressed by Operable Unit One.
1.3 CERCLA Section 117 and NCP Section 300.435(c)(2)(ii)
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SOURCE: AVERiCAN DIGITAL CARTOGRAPHY
7.5 MINUTE QUADRANGLE BROOKS. KENTUCKY
SITE LOCATION MAP
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;oz
y.z
000^61 N
000861 N
000661 N
OOOOOZ H
000IOJ N
OOOJOJ N
OOOCOZ N
OOOtOZ N
OOOSOZ N
00090Z N
- 3 -
Figure 2
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OPERABLE
UNIT ONE
STUDY AREA
T
*•*
PERMITTED
LANDFILL
at* ic sou
o ao 900 teeo
1. THE BOUNDARY SHOW AS OPERABLE UNIT 01
CORRESPONDS TO THE STUDY AREA BOUNDARY
REFERRED TO IN THE Rl/FS REPORT.
2. BOUNDARY SURVEY PREFORMED BY
C.R.W. AERIAL SURVEYS. INC.
- SURVEY IS PRELIMINARY
SMITH'S FARM
OPERABLE UNIT ONE
STUDY AREA
SITE MAP
Figure ;
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The public participation requirements of both CERCLA Section
117 and Section 300.435(c)(2)(ii) of the NCP have been
satisfied. A press release was placed in a local newspaper,
fact sheets were sent to persons on EPA's Site mailing list,
and an availability session was conducted at a local meeting
place in May 1991. A second newspaper advertisement
describing the proposed fundamental change was placed in a
local newspaper, another fact sheet was sent out, and a public
meeting was held in July 1991. The public comment period was
thirty (30) days long. The draft ROD Amendment was sent to
the Commonwealth of Kentucky for review and comment.
1.4 ORIGINAL RECORD-OF-DECISION
The original Record-of-Decision (ROD) for Operable Unit One
was signed by the Regional Administrator of Region IV, Greer
C. Tidwell, on September 29, 1989. The Commonwealth of
Kentucky did not concur with the selected remedy.
1.5 SUMMARY OF THE CIRCUMSTANCES LEADING TO THE NEED FOR A
ROD AMENDMENT
In March 1984 EPA visited the area addressed by this ROD
Amendment and collected samples from the drums and spill areas
to determine if the area warranted consideration for cleanup.
This investigation revealed that the potential for the release
of chemicals from the drums represented an imminent and
substantial endangerment to public health and the environment,
and qualified for emergency removal funds.
From June through August, 1984, EPA removed surface wastes,
excavated contaminated soils, and undertook site stabilization
and erosion prevention measures. The removed surface wastes
included 6,000 drums, 2,000 of which contained hazardous
waste. Some of the wastes included polychlorinated biphenyls
(PCBs), acids, solvents, paints, bases, and various organic
compounds. During the emergency removal action, the Site was
evaluated to determine the need for additional remedial
measures. As a result of the evaluation, the Smith's Farm
Site was added to the National Priorities List (NPL) on June
10, 1986 with a score of 32.69 out of a possible 100 points on
the Hazard Ranking System (HRS). Listing on the NPL allows
Superfund monies to be made available for remedial activities.
In July 1987, the Remedial Investigation/Feasibility Study
(RI/FS) was initiated. Field work in support of the RI/FS
began in March 1988, and the RI Report was completed in
January 1989. The draft FS Report was submitted to the public
information repository in March 1989. In April 1989 a public
meeting was held to present EPA's Proposed Plan and to solicit
public comments. The ROD was signed on September 29, 1989.
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In December 1989, Special Notice Letters were sent to
fifty-nine (59) PRPs offering them the opportunity to conduct
the Remedial Design and Remedial Action (RD/RA).
Negotiations were unsuccessful and on March 14, 1990, EPA sent
a Unilateral Administrative Order (UAO) to thirty-six (36) of
the.PRPs ordering them to conduct the RD/RA. Thereafter, a
group of PRPs selected a design and construction supervising
contractor, and the RD was initiated.
During the RD phase additional studies were conducted to
address any problem areas and to verify data collected in
previous phases. Additional studies consisted of: (1) a
detailed land survey; (2) a grid sampling of soils (both
surface and subsurface) and stream sediments; (3) an attempt
at treatability testing for thermal treatment of soils; (4)
treatability testing for solidification/fixation of soils; (5)
treatability testing for biological and chemical treatment of
soils; (6) exploratory trenching and sampling of unearthed
drums; and (7) the drilling of core holes to depths in excess
of three hundred (300) feet to determine the Site
stratigraphy. RD investigations in the fall of 1990 produced
soil sampling data which indicated significant decreases in
concentrations of contaminants of concern compared to those
concentrations described in the RI in 1989. In December 1990
EPA contracted for an independent assessment of the
differences between the RI and the RD soil data. In February
1991 the assessment was completed. The report indicated that
the RD sampling and analysis effort was valid and acceptable.
Cross-checks of split sampling data by EPA indicated that the
PRPs' RD data was acceptable. The draft Preliminary (30%)
Remedial Design Report was approved by EPA in February 1991.
The draft Intermediate (60%) Design Report was submitted to
EPA on August 1, 1991.
1.6 ADMINISTRATIVE RECORD
The requirements set forth in Section 300.825(a)(2) of the NCP
have been satisfied. All major documents that form the basis
for the decision to modify the response action have been added
to the administrative record file.
1.7 ADMINISTRATIVE RECORD AVAILABILITY
The administrative record file is available for viewing by the
public during regular business hours at the following
locations:
Ridgeway Memorial Library
Walnut Street
P.O. Box 146
Shepherdsville, Kentucky 40165
(502) 543-7675
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U.S.E.P.A. Region IV Records Center
Ground Floor
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-0506
Copies of documents in the administrative record file may also
be obtained from EPA's Region IV Records Center in Atlanta by
writing to the Freedom-of-Information Act (FOIA) Coordinator
and requesting a copy of the Smith's Farm Administrative
Record Index. Choices of documents from the Index may be
expressed in additional FOIA requests.
2.0 REASONS FOR ISSUING THE ROD AMENDMENT
2.1 DESCRIPTION OF THE REMEDY SELECTED IN THE ORIGINAL
RECORD OF DECISION
Section 8.0, page 67, of the original ROD specified
Alternative 4: Capping of Area A, Incineration and
Solidification/Fixation of Area B as the most appropriate
remedy for Operable Unit One. The following two paragraphs
are quoted from the original ROD:
"Approximately 26,200 cubic yards of contaminated soil,
surface drums, buried drums, and fill material will be
excavated from Area B. Approximately 5,200 cubic yards of
contaminated on-site sediments will also be excavated from the
intermittent valley streams within the Study Area of the
Smith's Farm site. The contaminated sediments and material
from Area B will be treated using a thermal destruction unit.
Approximately 50% of the treated material will then be further
treated by solidification/fixation. Solidified material and
treated soils will then be returned for placement into Area B.
Wastes within Area A will be consolidated and capped with an
engineered cap in accordance witr Federal and State
requirements. In addition to capping Area A, the alternative
includes the incineration of an as yet undetermined but minor
volume of material in Area A. Prior to capping, exploratory
investigations will be performed in Area A to further define
the volume and nature of contaminants within that area. Upon
completion of the remedial design and/or the waste
consolidation, regrading, and exploratory investigation of
Area A, the exact volume and location of material in Area A
that will be incinerated will be determined. Criteria that
will be used to determine the material to be incinerated are
the numbers and locations of intact drums or waste "hot spots"
that are uncovered in Area A and cost considerations. The
treatment of selected Area A wastes would be the same as the
treatment of Area B wastes."
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The cleanup or action levels that follow are taken from TABLE
20, page 68, of the original ROD.
ACTION LEVELS FOR SOILS AND SEDIMENTS
Contaminant Media Unit Action Level Risk Level
Lead Soil mq/kq 500 10~6
PAHs Sediment mq/kq 5 10~5
PAHs Soil mq/kq 2 10"5
PCBs Sediment mg/kg 2 10~5.
2.2 SUMMARY OF RATIONALE FOR CHANGING REMEDY SELECTED IN THE
ORIGINAL RECORD-OF-DECISION
2.2.1 Comparison of RI and RD Soil Data.
Preliminary Remedial Design (PRO) grid sampling and analyses
indicated lower levels of contaminants of concern, especially
PCBs, than demonstrated during the RI (Refer to the original
ROD, Sections 5.2.1, 5.2.2, 5.2.5, 6.3.1, 6.3.2, 6.3.4,
6.5.1.1, 6.5.1.2, and 6.5.1.4.). PRO soil data was compared
with the RI soil data and each data set was deemed to be valid
(Refer to enclosed Appendix 7.3.). Utilizing both the surface
and the subsurface PRO soil data and the latest grid survey
points and the original action levels for the three
contaminants of concern (PCBs, PAHs, and Lead), new
contaminated soil volumes were calculated. The new volume of
soils for treatment was calculated to be approximately 16,000
cubic yards. The prior estimate was 31,400 cubic yards.
2.2.2 New Estimate of Soil Volume.
Soil samples were taken from Area B and analyzed for
contaminants of concern as a prelude to treatability testing.
The samples did not contain high enough levels of PCBs to be
incinerated to demonstrate the RCRA-required 99.9999%
Destruction Removal Efficiency (DRE).
Soil sampling and analyses in Area A indicate low levels of
PCBs. Sediment sampling and analyses along the intermittent
stream on the west side of the ridge demonstrated
nondetectable and low levels of PCBs.
2.2.3 Change in Remediation Technology.
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Lower concentrations of PCBs have been discovered and the
volume of contaminated soil to be treated has been estimated
to be much lower than originally thought, therefore,
incineration (thermal treatment) has become infeasible and
other technologies have been examined for their applicability
and reliability. Biological and chemical treatment
technologies were examined. Ensite's SAFE-SOIL'SM' process
was discarded after an unsuccessful treatability test was
completed. Galson Remediation's APEG-PLUS
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Originally, approximately 26,200 cubic yards of contaminated
soils and fill material from Area B were to be excavated;
approximately 5,200 cubic yards of contaminated on-site
sediments were to be excavated from the intermittent valley
streams within the Operable Unit One Study Area. Exploratory
investigations were to be performed in Area A to define the
volume and nature of contaminants within the Area. Selected
contaminated material in Area A was to be subjected to
treatment contingent upon the volume of material to be treated
and cost considerations. Area A waste, Area B waste, and
wastes from proximal areas were to be kept separate. Selected
soils and sediments from Areas A and B, and proxima'l areas,
were to be incinerated on-site. The incinerated material was
to be analyzed for lead. Those volumes of treated material
with concentrations of lead at or over the lead action level
were to be treated by solidification/fixation. Incinerated
materials having lead levels less than the lead action level
were to be placed back into their original areas. Solidified
materials originally from Area B and proximal areas were to be
returned to Area B. Solidified Area A materials were to be
returned to Area A. Refer to Section 8.0, page 67, and
Sections 7.3 and 7.4, pages 59-62, of the original ROD; and to
Sections 3.3 and 3.4, pages 3-14 through 3-26, of the
Feasibility'Study.
3.1.1.2 Modified Remedy's Treatment Component.
Approximately 16,000 cubic yards of contaminated soils in Area
B (Area of Contamination "B") will be excavated to the
underlying rock (or to a shallower depth at which
contamination is indicated to be below action levels).
Contaminated soils, sediments, and debris from the west side
of Area A, and contaminated soils, sediments, and debris from
an area immediately southeast of Area A (in and around sample
location AS-23) will not be treated, but consolidated in Area
A since they are in the Area A area of contamination.
Unearthed drums, metal objects, and similar debris excavated
from Area B will be decontaminated utilizing best management
practices, overpacked, and the overpacks placed in a shallow
grave in Area A prior to capping. Selected Area B soils will
be treated on-site by a chemical process designed to
dechlorinate PCBs in (such as the APEG process) or to remove
hydrocarbons from (such as the BEST process) contaminated
soils and by a solidification/ fixation process designed to
immobilize the remaining contaminants of concern which are at
or above the action levels (This treatment train must have
been demonstrated to achieve the cleanup levels established in
the original Record of Decision.). During full-scale
operation on-site, contaminant cleanup levels must be achieved
within a reasonable time pursuant to the schedule in the
EPA-approved Remedial Action Work Plan. All treated material
from Area B will be placed in Area A under the cap. For rr.cre
detailed information refer to Section 3.1, paces 14-28, of the
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draft Intermediate Design Report and to Sections 3.3 and 3.4,
pages 3-14 through 3-26, in the Feasibility Study.
Exploratory investigations were performed in Area A during the
Remedial Design investigation.
3.1.2 Containment Component.
3.1.2.1 Original Remedy's Containment Component.
Wastes placed within Area A were to be consolidated and capped
with an engineered cap in accordance with RCRA requirements.
According to Section 3.2 of the March 1989 Feasibility Study
by EBASCO, approximately 900 linear feet of retaining wall
were to be built along the west .side of Area A at the base of
the slope at least 25 feet from the intermittent stream. A
short double retaining wall was to be built along the
northeast portion of Area A. A leachate collection system was
to be integrated with the perimeter retaining structures.
Surface run-on and run-off structures were to be installed.
3.1.2.2 Modified Remedy's Containment Component.
Reinforced .concrete retaining walls will be built along most
of the west side of Area A and double, reinforced concrete
retaining walls are to be built along a section of the
northeast side of Area A. Other engineered retaining
structures will be built along the perimeter of Area A, where
appropriate. A leachate collection system will be integrated
with the perimeter retaining structures; leachate will be
collected in storage tank(s) of an appropriate size and
arrangements will be made for proper on-site or off-site
treatment and disposal of leachate. Surface run-on/ run-off
control systems will be designed for a 50-year 24-hour rain
event. Area A will be capped utilizing a RCRA cap which may
include a bentonite matting component. The RCRA cap will
include a synthetic geomembrane (HOPE or equivalent) of at
least 30 mil thickness. Refer to Sections 3.2 through 3.5,
pages 29 through 46, in the draft Intermediate Design Report.
3.1.3 Ground Water Component.
3.1.3.1 Original Remedy's Ground Water Component.
Ground water was to be monitored annually for up to
twenty-seven (27) years after construction was complete.
Ground water was to be sampled annually for all TCL compounds
and not for TAL constituents (unless the weight of evidence
indicated otherwise) in all Operable Unit One monitoring wells
(MW-1 through MW-15). Refer to Section 5.2.3, page 16, of the
original ROD and to Section 2.2.4.6, page 2-19, of the
Feasibility Study.
3.1.3.2 Modified Remedy's Ground Water Component.
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Ground water is to be monitored annually for TCL constituents
and biennially for TAL constituents for up to thirty (30)
years after construction is complete. Monitoring wells Mi-J-3
through MW-8 and MW-11 through MW-15 will be sampled.
Additional monitoring wells will be installed if determined by
EPA to be necessary.
During construction of the retaining walls and other
near-stream structures associated with Area A, precautions
will be taken in order to save the existing monitoring wells.
3.1.4 General Components.
3.1.4.1 Original Remedy's General Components.
Access to the area addressed by Operable Unit One was to be
restricted by fencing around the contaminated areas.
The RCRA cap was to be maintained for up to thirty (30) years
after construction was complete.
The leachate collection system was to be maintained for up to
thirty (30.) years after construction was complete.
Collected leachate was to be transported off-site for
treatment and disposal at an EPA-approved facility for up to
thirty (30) years after construction was complete. Reference
is made to Section 7.2, page 58, of the original ROD.
3.1.4.2 Modified Remedy's General Components.
Access to the area addressed by Operable Unit One will be
restricted by fencing Areas A and B at the least. The fencing
will be maintained for up to thirty (30) years after
construction is complete.
Necessary access roads will be maintained for up to thirty
(30) years after construction is complete.
The RCRA cap and surface run-on/run-off control structures as
well as those hydraulic energy dissipation and sedimentation
structures associated with the proximal stream beds will be
maintained for up to thirty (30) years after construction is
complete.
The leachate collection system will be maintained for up to
thirty (30) years after construction is complete.
Collected leachate will be transported off-site for treatment
at an EPA-approved facility, or treated on-site and discharged
(by permit, if necessary) to the Unnamed Tributary, for up to
thirty (30) years after construction is complete.
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Arrangements will be made for the institution of land-use
restrictions for the fenced areas and for any other proximal
or associated areas which may be determined by EPA to need
restricted access.
3.1.5 Maior ARARs.
3.1.5.1 Original Remedy's Major ARARs.
The ARARs which were associated with the original remedy are
set forth in Section 8.2, pages 70 through 73, of the original
ROD.
3.1.5.2 Modified Remedy's Major ARARs.
With the exception of the ARARs in Section 8.2 of the original
ROD which apply directly to incineration, the same ARARs apply
to the modified remedy. In addition, any discharges of
treated leachate will be in compliance with CERCLA Section
121(e) as well as all substantive Clean Water Act (CWA) and
federal and state National Pollutant Discharge Elimination
System (NPDES) requirements. If discharge occurs off-site, an
NPDES permit will be obtained. If underground storage tanks
are utilized in the leachate collection system, then the
applicable Underground Storage Tank (UST) requirements must be
met.
With regard to Section 8.2.1.A, Federal Resource Conservation
and Recovery Act (RCRA), of the original ROD, the application
of Land Disposal Restrictions (LDRs) as set forth in 40 CFR
Part 268 is explained in more detail in Section 4.1.2.2 below.
4.0 EVALUATION OF THE MODIFIED REMEDY
4.1 PROFILES OF THE ORIGINAL SELECTED REMEDY AND THE
MODIFIED REMEDY USING THE NINE CRITERIA IN
CERCLA AND THE NCP
4.1.1 Overall Protection of Human Health and the Environment.
4.1.1.1 Original Remedy.
The original remedy would have served to contain contaminants
within Area A, thereby eliminating or greatly reducing
infiltration of rainfall into the area. This would have
eliminated the pathways for exposure. Refer to the original
ROD, S'ection 8.1, pages 69-70, and to Section 7.6.1, page 65.
4.1.1.2 Modified Remedy.
The modified remedy would serve to protect human health and
the environment in the same fashion as the original remedy.
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4.1.2 Compliance with ARARs.
4.1.2.1 Original Remedy.
Refer to the original ROD, Section 8.1, pages 69-70, and to
Section 7.6.2, page 65.
4.1.2.2 Modified Remedy.
The modified remedy complies with ARARs in the same manner as
the original remedy, but without the necessity for complying
with the ARARs pertaining specifically to incineration. Refer
to Section 8.2, page 70, of the original ROD.
Section 8.2.1.A, Federal Resource Conservation and Recovery
Act (RCRA), of the original ROD, states that "40 CFR Part 268
Subpart D requires treatment by the best demonstrated
available technology (BOAT) before land disposal of
RCRA-similar wastes. The treatment of wastes excavated from ,
the Study Area will meet this requirement."
In the area addressed by Operable Unit One, Areas A and B are
considered separate Areas of Contamination (AOCs). Area B
soil and debris will be considered to be RCRA characteristic
waste until proven otherwise or unless the waste is regulated
by another statute, such as TOSCA. Placement occurs when
moving treated soil and debris from Area B to Area A.
Currently, contaminated soil and debris at CERCLA sites are
subject to the same treatment standards as the prohibited
hazardous 'wastes that they contain, unless a variance is
appropriate and approved according to 40 CFR Section 268.44.
4.1.3 Lonq-Term Effectiveness and Permanence.
4.1.3.1 Original Remedy.
The long-term effectiveness and permanence of the original
remedy is described in Section 8.1, pages 67 through 70, and
in Section 7.6.3, page 65.
4.1.3.2 Modified Remedy.
The modified remedy will satisfy this requirement in the same
way as the original remedy.
4.1.4 Reduction of Toxicity, Mobility or Volume Through
Treatment.
4.1.4.1 Original Remedy.
These reductions were described in the original ROD, pages 67
through 70, and in Section 7.6.4, page 65.
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4.1.4.2 Modified Remedy.
The modified remedy achieves these reductions in the same way
as the original remedy.
4.1.5 Short-Term Effectiveness.
4.1.5.1 Original Remedy.
This requirement is discussed in the original ROD in Section
8.1, pages 67 through 70, and in Section 7.6.5, page 66.
4.1.5.2 Modified Remedy.
The modified remedy would meet this requirement in much the
same manner as the original remedy. Area B contaminated soils
would be treated and placed in Area A prior to the capping of
Area A. Thus Area B remediation would occur rapidly. Area A
interim containment and control measures would mitigate the
short-term endangerment; as soon as the retaining structures
are in place around Area A and the synthetic geomembrane
applied to the graded surface of Area A containment will be
complete, with the exception of the installation of the
remaining components of the RCRA cap.
4.1.6 Implementability.
4.1.6.1 Original Remedy.
The implementability of the original remedy is described in
the original ROD in Section 8.1, pages 67 through 70, and in
Section 7.6.6, page 66.
4.1.6.2 Modified Remedy.
The modified remedy is as implementable as the original
remedy, and perhaps more so since the large incinerator and
associated machinery will be replaced with chemical processing
or stabilization equipment which is expected to produce fewer
mobilization and set-up problems.
4.1.7 Cost.
4.1.7.1 Original Remedy.
The cost estimate for the original remedy was approximately
$27,000,000.
4'. 1.7.2 Modified Remedy.
The cost of the modified remedy has been estimated to be $22 -
$25 million.
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4.1.8 State Acceptance.
4.1.8.1 Original Remedy.
The Commonwealth of Kentucky did not concur with the original
ROD which was signed in September 1989. Refer to the original
ROD, Section 7.6.8, page 66.
4.1.8.2 Modified Remedy.
The Commonwealth has been given a reasonable time of not less
than ten (10) working days to review and comment on the ROD
amendment. The Commonwealth has indicated that it cannot give
specific comments on the ROD amendment within a reasonable
time and referred to their January 8, 1991 draft Preliminary
Remedial Design comments. The Commonwealth has been given an
opportunity to discuss specific ARARs with respect to the ROD
amendment, but has indicated that it cannot do so in a
reasonable time. The Commonwealth's concerns and EPA's
responses to those concerns are contained in Attachment
7.2.2. The Commonwealth concurs with the substitution of
chemical treatment for incineration, but continues to object
to the overall solution for remediation of the Site. The
Commonwealth's letter of September 26, 1991 is Attachment
7.2.3.
4.1.9 Community Acceptance.
4.1.9.1 Original Remedy.
The community expressed serious concerns about the use of an
incinerator at the Site, but accepted the original remedy.
Refer to the original ROD, Section 7.6.9, page 66, as well as
to the Responsiveness Summary attached to the original ROD.
4.1.9.2 Modified Remedy.
The modified remedy was generally acceptable to the
community. Refer to the Responsiveness Summary, Section 6.2,
in this Amendment.
5.0 STATUTORY DETERMINATIONS
5.1 SATISFACTION OF CERCLA Section 121
The remediation goals as expressed in the original ROD in
Section 8.1, pp. 67-70, remain the same. The discussion
concerning remediation goals, attainment of ARARs,
cost-effectiveness, utilization of permanent solutions and
alternative treatment technologies to the maximum extent
practicable, and preference for treatment as a principal
element remain essentially the same. Therefore, the
applicable portions of CERCLA Section 121 have been satisfied.
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6.0 COMMUNITY RELATIONS
6.1 COMMUNITY RELATIONS ACTIVITIES
The September 1989 Operable Unit One ROD was based upon the RI
completed in January 1989. A public information meeting was
held on March 12, 1988 to address existing community concerns
and to provide the community with information about the
studies that were conducted or that were planned for the
Site. After the release of the Feasibility Study to the
public, another public meeting to describe current conditions
at the Site, the alternatives considered for Site cleanup, and
the preferred alternative for cleanup was held on April 11,
1989. The ROD was signed on September 29, 1989.
On May 9, 1991 a meeting was conducted in conjunction with the
Tri-City Industrial Disposal Site Proposed Plan public
meeting. A fact sheet for the Smith's Farm Site was sent out
with the Proposed Plan fact sheets for the Tri-City Site given
that many of the interested parties are the same. The Smith's
Farm fact sheet contained a description of the Proposed
Fundamental Change to the original remedy. On July 15, 1991,
a notice appeared in a local newspaper describing the purpose
of a public meeting to occur on July 18, 1991, and opening the
public comment period. The public meeting occurred on July
18, 1991 with television and newspaper coverage. The public
comment period extended from July 15, 1991 through August 15,
1991.
6.2 RESPONSIVENESS SUMMARY FOR ROD AMENDMENT FOR
OPERABLE UNIT ONE
6.2.1 Overview.
During the July 18, 1991 Public Meeting, EPA presented the
proposed plan for the modified remedy and solicited questions
from the public. A list of attendees is included in
Attachment 7.2. Representatives from Kentucky's Department of
Law and Environmental Protection Cabinet as well as from the
Bullitt County Health Department and local governments
attended the meeting.
The crux of EPA's Fundamental Change to the original remedy is
the substitution of a chemical treatment process (or
stabilization process or a combination of chemical and
stabilization processes) for soils contaminated with PCBs,
PAHs, and lead at levels above those Action Levels described
in Section 2.1 above.
6.2.2 Background on Community Involvement and Concerns.
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Media interest in the Site and in EPA's activities at the Site
has been significant, beginnning with the immediate removal
action completed in 1984. The local news media covered
activities at the Site throughout the Remedial Investigation
in 1988.
Since the fieldwork at the area addressed by Operable Unit One
in the fall of 1990, some citizens have expressed interest in
whether the Site's proximity to their residences tends to
depress their property values. Other citizens are concerned
about the quality of the ground water being obtained from
private wells for drinking and washing. The Bullitt County
Health Department as well as some residents of the mobile home
park near the Site have been concerned about surface water
contamination due to leachate emanating from both the Operable
Unit One area and the Operable Unit Two area. Reportedly, the
Commonwealth and the Bullitt County Health Department had
representatives at the videotaping. For a time during late
1990 and early 1991 the intermittent stream known as the
Unnamed Tributary, which runs from the area addressed by
Operable Unit One to the Operable Unit Two area and to Blue
Lick Creek, was posted as a precaution against possible
surface water contamination. However, three separate sampling
and analysis events demonstrated that there were no detectable
levels of contaminants immediately downstream of the leachate
seeps.
During the July 18, 1991 public meeting several citizens
expressed their displeasure with the quality of the well water
at certain of the mobile home park residences. One resident
was drawing water from a dammed area of a tributary of
Bluelick Creek because his well water was of poor quality.
The local Magistrate, Dennis Mitchell, expressed the County's
need for funds to extend public drinking water lines to all of
the residences in the mobile home park and to nearby areas in
letters to the EPA Regional Administrator and to Commonwealth
and federal congressional representatives. As of the date of
the signature of the ROD Amendment all inquiries by Mr.
Mitchell and Commonwealth and federal congressional
representatives have been responded to by the EPA Regional
office (More details about this matter are set forth in the
next section of this Responsiveness Summary and in Attachment
7.2.1.). Although a number of comments and concerns were
raised in the availability session and at the public meeting
concerning the Proposed Fundamental Change to the original
Record of Decision, only one follow-up letter was received
from anyone during the Public Comment Period. The Community
Relations Coordinator (CRC) received one phone call from the
Commonwealth on the last day of the Public Comment Period.
6.2.3 Summary of Major Public Comments Received During the
Public Comment Period and EPA Responses to the Comments.
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During the public meeting on Thursday, July 18, 1991, several
comments were made by the public.
1. A commenter questioned the original plan to incinerate
contaminated soils on-site and suggested that the incineration
could still occur, but off-site at a facility in Bullitt
County. The commenter felt that this would provide much
needed work for the residents of the County.
EPA's Response; A search for RCRA-permitted incineration
facilities in the area indicated that there were no facilities
nearby that were permitted to incinerate hazardous waste.
.2. Several commenters were distressed about the poor quality
of ground water near the Site and the lack of availability of
public drinking water hookups in some parts of the mobile home
park and in the general area south of the Site.
EPA's Response; There are two reasons why the ground water is
of poor quality in the area of the mobile home park and in the
general Site area: (1) the natural shallow shale aquifer as
well as the deeper limestone aquifer produce low quality
water, i.e., the aquifers in the vicinity of the Site are
categorized as Class III aquifers which means that the
production rate is low and the suspended solids are high; and
(2) most of the homes in the area of the Site are connected to
either single septic tank systems or to sewage lagoon systems
or to small packaged sewage treatment systems. The effluent,
discharge, and leachate from these systems either moves
through the overburden and into the streams in the area or
follows the water well casings down to their intake points,
thereby contaminating both surface water and ground water.
Heavy rainfalls flush out the streams because the streams
generally have relatively smooth rock bottoms and partially
flush out contamination from septic systems which are into the
overburden. However, homes in low-lying areas may have their
yards flooded and it may take some time before the water
levels subside. During these periods septic systems do not
work properly and there may be contamination of water wells at
those locations.
The available evidence indicates that the Smith's Farm Site
has not contaminated the off-site ground water. The
stratigraphic investigation done with respect to both Operable
Units indicates that there are roughly two hundred feet of
compact shale underlying the general Site area. These layers
of shale have a very low permeability and generally shield the
deeper aquifer from infiltration by rain and the possible
leachate produced in the overburden which is on top of the
uppermost shale layer.
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EPA has recently responded to inquiries by Bullitt County
officials, specifically Mr. Dennis Mitchell, Magistrate, as to
the availability of federal funding for the extension of
public drinking water and sewage collection lines into those
areas which do not presently have access to those services
(See Attachment 7.2.1.).
3. A commenter wanted to know why the stream flowing through
the Site had been posted near the mobile home park.
EPA's Response; The stream was posted by the Bullitt County
Health Department shortly after some fieldwork was done at the
Smith's Farm Site and after a television station aired a piece
showing the leachate collection sump at the Operable Unit Two
area overflowing with leachate in the vicinity of the stream
designated as the Unnamed Tributary on Site maps. The
leachate seeps were sampled at several points and the stream
was sampled at several points. While the leachate was
contaminated, the stream samples analyses indicated no
detectable levels of contamination a short distance downstream
from the leachate seeps. One stream sample immediately
adjacent to the southernmost leachate seep had very low levels
of organic contaminants, but these levels were below
applicable Commonwealth and EPA surface water standards.
Both Operable Units One and, most likely, Operable Unit Two
will entail the construction of a leachate collection system
and on-site or off-site leachate treatment provisions.
Additional remediation measures should reduce the amount of
leachate flowing into the streams to an insignificant amount.
Construction with respect to Operable Unit One is expected to
begin late in the summer of 1992. Construction at the
Operable Unit Two area could begin late in 1993 or early in
1994.
4. The Kentucky Resources Council, Inc. had four comments:
a. KRS 224.877 is a state ARAR which must be followed by EPA
in determining Action Levels for remediation.
EPA Response; KRS 224.877 does not require cleanup to
background levels as has been argued by the Commonwealth in
the past. The Action Levels described in the original Record
of Decision have been determined to be protective of human
health and the environment.
b. The extent of contamination for Area A has not been
thoroughly characterized.
EPA's Response; Magnetometer studies, electromagnetic
surveys, soil sampling, and exploratory trenching integrated
with subsurface sampling have defined not only the extent of
contamination, but the general nature of contamination. The
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results of these studies and investigations are contained in
the Preliminary and Intermediate Design packages.
c. The original Record of Decision called for treatment of
some 26,000 cubic yards of contaminated soil, which has
apparently been reduced to 16,000 cubic yards. Additional
confirmatory testing is necessary to assure that the extent of
soil in need of removal and remediation has been determined
conclusively, and that areas are not deleted prematurely or on
the basis of only one sampling event.
EPA's Response; A thorough surface and subsurface grid
sampling of Areas A, B, and the stream sediments on the east
and west of the ridge has been completed during the
Preliminary Remedial Design phase. Split and confirmatory
sampling has been accomplished by EPA. Additionally, an
independent comparison of prior Remedial Investigation data
and the Preliminary Remedial Design data has been completed.
In some cases three or four sampling and analysis events have
been accomplished at one sampling location. Also, during the
actual excavation for treatment, soil sampling will occur to
ascertain that soils contaminated above Action Levels are
removed for treatment.
d. To the extent that Portland cement is utilized for
stabilization of contaminated soil, USEPA should assure that
the cement is "virgin" cement that has not been produced by a
facility that co-fires hazardous wastes as a fuel source.
Significant uncertainties remain concerning the long-term
stability of waste residues and metals in such cements, and it
is prudent to avoid possibly compounding site contamination
utilizing such cement. The Council is also concerned with the
leaching potential of the solidified material, and requests
that sufficient testing be done to assure the long-term
integrity of the solidified material.
EPA's Response! Treatability study procedures dictate that
cement and additives or pozzolanic stabilizing material be
analyzed prior to use. However, at full-scale production only
a limited number of samples may be analyzed. Leaching
potential tests, i.e., the TCLP and several similar tests, are
mandatory both up-front during bench-scale testing and during
the actual implementation of full-scale processing. EPA will
split samples throughout the entire process to ensure that the
appropriate level of quality is maintained.
The transcript of the July 18, 1991 public meeting is enclosed
herein as Attachment 7.2.
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ATTACHMENT 7.2.1
MAGISTRATE DENNIS MITCHELL'S LETTER
TO EPA AND EPA'S RESPONSE
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Dennis Mitchell
1st District Magistrate
Box 1180, Cow Branch Road
West Point, KY 40177
(502)-935-4048
""-*- July 10. 1991
Greer Kidwell, Regional^Administrator
EPA Region 4
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Kidwell,
One oflthe-main-concerns x>f-the people in our area,, is .WATER.;. .Many.p.eople .,take,
this:resource -for granted.- -(Those of us without water consider it-a-very,valuable
commodity.
It has been-brought-to our attention recently that, our.groundwater may be.con-
taminated from hazardous-wastes -dumped at several, sites .in our community. . The. clean.
up of these areas will '-be'. a monumental undertaking. Can. this. be. cleaned up suff-
iciently-to ensure-safe-drinking water? What effect will this., water have. on., .the.
livestock in the area?
- With-the underground-geological formation of our area,, pollutants, can seep down-
ward -into the groundwater^and-may be carried horizontally. for miles .(and may. even
resurface) contaminating vater supplies over a vast area. Many* area, residents that
had good wells ten years ago have been advised not to drink their water after having
it tested recently.
Three families-in the area- of one of the dump sites are being supplied with
water paid for the EPA. Does the water become safe to drink on the other side of
their property line?
While reading newspaper articles from the Courier Journal, I. came upon some
very disturbing information as shown by the following quotes;
January 19,; 1979: "In the Louisville area, state and federal environ-
mental officials have discovered at least four dumping grounds for barrels
full of possibly hazardous industrial wastes..Some of the chemicals pose
possible threats to drinking water supplies."
January 17, 1979: "Edgar Hartowicz, a biologist and an assistant director
in the water quality division, analyzed water samples taken from the strea.
He testified that pollution from Taylor's operation (Valley of the Drums)
interfere both directly with the life cycle and with.the food chain of aquatic
life in the stream." Joe Vanhoozer stated he had to stop raising pigs because
of contaminated water in the stream, ."a large volume of contaminated runoff
is entering Wilson Creek."
February 3, 1979: "..some drums had spilled and that most of the
materials had solidified upon the ground around the drums. Wilson Creek,
which runs through the property, contained what appeared to be paint on its
bed."
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February 22, 1979: "Enviornmental officials say chat
between 10,000 and 100,000 barrels of industrial waste are
scattered (in the Valley of the Drums)."
March 4, 19ZSU,.,.."... the steady rains of the past few days
have saturated the,ground, causing water to floy from the valley.
It has taken" with*it the oils and harmful chemicals from the
barrels, many of which are leaking."
March. 5, 1979; "Preliminary analysis of water samples...
revealed that the stream has small quantities of benzenei'a :
known cancer causing chemical and other toxic chemicals, including
toluene.-and -.ketones, EPA officials said last night. '-A• mult-i—
colored, sheen was visible in the sediments of the ••stream; rT. "•• •'-'--
;.J3ie..exavct ichreat ,to individuals who take their-water-supplies-from •'•
.;•. the. creek cor- nearby wells is not known, EPA spofcesmen'-said."-
March. 14, 1979: "...EPA officials pointed out'a--one-half -:
.acre area..where virtually all vegetation has died. Chemicals -
.. from.£he..site have seeped downhill and collected-into murky
stagnant pools." : '--. •
March 20, 1979: "...EPA...laboratory tests have found PCB,
..an .extremely, toxic substance, in the creek's sediment. --Like DDT
.they-are soluable in fat or oils, but only slightly;soluable in
.water. .For this reason, when PCB's enter a waber'-body the chera- -
;ical. sinks .to the bottom remaining largely insoluble-for many
years."
March 22, 1979: "...on the dump sight itself, the EPA samples
showed...PCfis measuring up to 14 parts per million."
April 13, .1979: "PCBs have been found in stream sediments at
.the Valley of the Drums in samples as high as 14 parts per million."
June 17, 1979: "It takes the equivalent of 2 to 10 people
working for an entire year just to do the technical work on these '
cases....we just don't have the time and staff to go around suing L
everybody."
June 19, 1979: "Priority is given to areas of high population
where people's drinking or food supplies may be threatened by runoff
from wastes. Because the area around Smiths Dump is sparsely pop-
ulated, officials moved slowly in determining how dangerous the
wastes were."
June 21, 1984: "I personally don't know of any (dump site)
thats any bigger", said Charles Jeter, head of EPA's regional
office in Atlanta.
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June 24, 1984: "Drums containing acid have been found along a road where
children play. Youths also rode dirt bikes in contaminated areas, EPA officials
say."
June 28, 1984: HEADLJNE..."Residents near dump are leery about water."
April 7, 1989:~~Kluesner said., "area wells have been tested and found to
be safe. However, the EPA is concerned about the potential for future con-
tamination." .-—
April 12, 1989: "I would guess that what went irit-o the landfill is what
went into the farm also, Millanti said. Officials have identified PCBs,
.acids, solvents, paints and metals at the illegal- dumps. •--Kluesner said water
.has been .seen seeping from the landfill and Millanti-said-he would assume
-•that gr-oundwater beneath the landfill is contaminated as well." -
-.June, 1989: "The Tri-City Disposal Superfund Site is located in a rural
community in-northern Bullitt County. It consists of approximately 57 acres
..and is contaminated by a variety of hazardous substances/ including phenols,
PCBs and lead."
April 19.91: .EPA Proposed Plan Fact Sheet.. ."It is believed that the con-
tami.na.ced groundwater is gradually being flushed through the springs."
In the area surrounding Smith's Farm and Tri-City Disposal there^are approx-
ately 1100 households and may small springs and streams which have runoff from
ese dumps. Nichols Elementary School is located at the end of Knob Creek where
1 of these springs and streams empty.
I am magistrate for this area in Bullitt County, Kentucky and the property
hundreds of my neighbors and constitutents lies in the middle of a triangle
rmed by dump sites. I would appreciate consideration for funding of water line
stallation in. this area to eliminate the risk of consuming contaminated water.
With funding we could install water lines that'would bring water from the
uisville Water Company. Louisville has an excellent filtering and distribution
stem. Large municipal water systems remove and filter both pollutants and
rmful natural substances from the water. We would no longer have to worry about
nsuming contaminated water and would be spared the costly expense of having
ter hauled to our homes. Even those of us who have cisterns need to be cautious
cause a crack could allow polluted water to permeate our supposedly "safe water".
Thanking you in advance and looking forward to hearing from you regarding this
tter, I remain.
Respectfully yours,
Dennis Mitchell, Magistrate
Bullitt County, Kentucky
fdlm
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cc:
Senator Wendell Ford~~'"
Senator Fred Bradley- -*'
State Representative Mark Brown
Congressman Williain_.Natcher
-------
s.''*
2 , " I \
" S UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 3O365
JUL 2 6 1991
4WD
Mr. Dennis Mitchell
1st District Magistrate
Box 1180, Cow Branch Road
West Point, Kentucky 40177 :"
Re: Smith's Farm CERCLA NPL Site . c. : ;-i\..<
A.L. Taylor CERCLA NPL Site ;. = ;..
.-. M'J Tri^City Industrial Disposal CERCLA NPL -Site-
Dear Mr. Mitchell:
. ^ ^Pursuant .to'^your-^letter of July 10, 1991 -to- Mr»:.Greer'3!idwell./
i- Jtegicuxal- .'Administrator, the Agency has considered Jf-undiTKp the
, £.:€xtenaion _of cpublicr.^water lines into the 'areas you 'described;- -
^Bawewer/ tthe.rAgency has found no legal and scientific .'basis- to
, _ rfiupport the expenditure of Superfund money- tfor: this-' purpose.'
iWhile:cthe three. CERCLA NPL Sites in Bullifct- County 'have .:
undoubtably .-effected: the environment in the very- immediate area
ofJeach;of the sites, there is no scientific evidence to
.indicate /that there is widespread contamination from these three
sites that is affecting the large number of -people described in
your letter.
.There may be other, reasons why the quality -:of the ground water
in the area has -deteriorated. Our research "indicates that most
private wells in the general area to which you desire to bring
public water are into the shallow aquifer. According to our
research, the natural geochemistry of the shallow (and deep)
aquifer does not foster immediately drinkable, high quality
ground water. Additionally, a significant amount of ground
water and surface water contamination may be 'occurring because
of leaching and discharging from septic tanks, package sewage
treatment plants, and other man-made sources.
Since EPA can discern no widespread, short-term, immediate
public health threat from all three Superfund sites together,
funds from the Hazardous Substance Response Trust Fund may not
be used to extend public water lines into the areas you
describe. However, there is a State Revolving Fund (SRF)
managed by the Commonwealth which may be able to provide your
county with funds. The Commonwealth contact for the SRF is
Mr. William Gatewood. He can be reached at (502) 564-3410. A
member of my staff has contacted Mr. Gatewood and has described
your situation to him.
Printed on Recycled Ptptr
-------
- 2 -
.If you have further questions with regard to these Superfund
.sites, please contact Tony DeAngelo at (404) 347-7791.
Sincerely
Acting Director
Haste Management Division
-------
ATTACHMENT 7.2.2
KENTUCKY'S JANUARY 8, 1991 COMMENTS
ON THE DRAFT PRELIMINARY REMEDIAL DESIGN
AND EPA'S RESPONSES TO THOSE COMMENTS
-------
7^ /^7 ; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
V • g V
*'«, -a,*- REGION IV
345 COURTLAND STREET N.E.
SEP 3 0 £91 ATLANTA. GEORGIA 3O365
4WD-NSRB
Mr. Carl Millanti
Manager
Uncontrolled Sites Branch
Division of Waste Management
Department of Environmental Protection
Natural Resources and Environmental
Protection Cabinet
Commonwealth of Kentucky
Frankfort Office Park
18 Reilly Road
Frankfort, Kentucky 40601
Re: Smith's Farm CERCLA NPL Site
Brooks, Bullitt County, Kentucky
Operable Unit One - Preliminary RD
EPA's Response to Kentucky's Comments
on the Preliminary RD
Dear Mr. Millanti:
Pursuant to your January 8, 1991 letter and to questions posed
by Mr. Salanski during the public meeting on July 18, 1991, the
Region has considered the Commonwealth's comments on the draft
Preliminary Remedial Design and is responding as follows.
Additionally, the Agency wonders why no written comments on the
proposed plan were received during the time period after the May
9 and July 18, 1991 meetings or after receipt of the first draft
of the ROD amendment sent to you on August 23, 1991.
1. Page 1-2 through para 1, page 2.
Additional site characterization has been done in both Areas A
and B (and in Operable Unit Two), Area C having been dismissed
after the 1984-85 removal as well as during the Fund-lead
RI/FS. Both the shallow and the deep aquifers at both Operable
Units have been examined. With regard to the last sentence of
the first paragraph on page 2, the Commonwealth is well aware of
EPA's position on the ARARs issue in this case. For example,
EPA's stance with regard to cleanup to background levels at RCRA
sites is described in James Scarborough's letter of February 26,
1990 (See Attachment 1.). Furthermore, cleanup to background
levels would require the excavation of all of the overburden in
both Areas A and B, as well as stream sediments, the grinding
and pulverizing of all excavated material, and the processing
through a three or more stage treatment train prior to
Printed on Recydec
-------
p.2
redeposition. This remedial action would undoubtably take more
than three years and $150 million to complete, whether or not an
EPA contractor or a PRP contractor was involved. Additionally,
in terms of the assessed risk, cleanup to background levels
would achieve approximately the same levels of protection as the
proposed modified remedy.
2. Page 2, para through end of page.
After the November 29, 1990 meeting in Atlanta, the Region
contracted for a detailed comparison of the RI and PRD data.
The completed report indicated that both sets of data were valid
and that differences existed because of different sample types,
sampling intervals, and because of a developing PCB vertical
concentration gradient. Analysis of split samples as well as of
separate samples taken by EPA reaffirm the PRD's analytical
findings.
The volume estimates made during the RI were made with the
reasonable assumption that contaminants were moving downsiope;
thus, volumes were estimated by outlining downslope areas which,
while not confirmed by sampling and analysis, by best
professional judgement were probably contaminated. Thorough
grid sampling during the PRD proved the earlier estimates to be
incorrect. Additionally, a review of the current proposal
would have indicated that the 16,000 cubic yard estimate may be
expanded because further sampling/analysis will be done during
the actual RA excavations. More information on this subject is
slated to appear in the Pre-Final Design Report. Area B.
contamination has not been discounted. A review of the proposal
would have indicated that a significant portion of Area B is
expected to be excavated to the rock, and the excavated material
treated. It must be noted that most of the Area B overburden or
material between the surface and the top of the rock layer is
less than five (5) feet deep.
3. Page 3 and page 4 through first para.
RCRA cap specifications are not etched in stone. In recent
years new information and products have come to the
marketplace. One of these products is bentonite matting. This
matting has been and is being utilized at many RCRA and CERCLA
sites not only in the U.S., but at similar sites in foreign
countries. The results of lab tests and practical applications
in recent years verify the substitutability of bentonite matting
for a clay layer in some situations.
-------
p.3
Information on bentonite matting is enclosed (See Attachment
2.). Bentonite matting is particularly feasible at Operable
Unit One's Area A for several reasons:
a) The 5.5 foot thick cap and cover you described would require
at least 90,000 cubic yards of material to be moved onto the
Site, i.e., 5.5 ft X 43,560 fWacre X 10 acres X 1 yd3/27
ftj - 90,000 yd1*. The limited accessibility of the Site
would require that smaller dump trucks be used and, therefore,
only about 8 ydj of material could be brought on-site in one
truck. Thus, more than 11,000 truckloads would be required. The
air pollution and other environmental damage from the operation
of those trucks would undoubtably outweigh the questionable,
debatable benefits of the thicker, heavier cap and cover.
b) The use of the thicker cap would require larger reinforced
concrete retaining walls and tend to reduce the capacity of the
fill. The use of bentonite matting would allow an optimal
balance of fill capacity and retaining wall size.
c) The components of the bentonite matting based cap are more
readily transported and more easily applied while providing a
level of protection equivalent to a two (2) foot thick clay
layer having a hydraulic conductivity of 10~7 cm/sec (See
Attachment 3.).
d) Given the maximum eighteen (18) percent slopes to be capped
and the limited access in this situation, the bentonite matting
is more feasible than a two (2) foot layer of compacted clay. A
review of the current proposal would have indicated that a
terraced cap surface is mandatory; the design packages have
contained this requirement.
4. Page 4, second para.
Full-scan, TCL/TAL analyses were completed; however, only the
results for the three contaminants of concern (PCBs, PAHs, and
lead) were reported in the PRD since these were the indicators
by which areas of contamination and soil volumes were and are
defined.
5. Page 4, third para through third full para, page 5.
Trenching performed during the PRD phase indicated that the vast
majority of drums are rusted and that most are in several
pieces. Most drums were deemed to be "RCRA-empty" when disposed
or filled with trash. Very few drums had liquid wastes in
them. A more thorough investigative excavation of Areas A, B,
and C and proximal areas, given the decision to cap Area A, is
not necessary. A review of the current proposal would have
indicated that all three areas plus additional proximal property
-------
p.4
will be fenced and appropriate deed restrictions emplaced.
Soils and sediments contaminated above the ROD action levels and
proximal to Areas A and B will be excavated and treated and
deposited in the area to be capped.
6. Page 5, last para.
The RPM shut down the quarterly monitoring at that time for
several reasons:
a) There was no analytical evidence to support further
quarterly monitoring of private wells.
b) Page 8-3 of the RI/FS as well as further investigation by the
RPM revealed that less than six (6) households might be
potentially effected.
c) The hydrogeological connection between the geology under the
areas effected by the two Operable Units and the geology under
the residences was remote at best. Discussions with EPA and
USGS hydrogeologists indicated that there was no significant
hydrologic circulation either in the shale layers or the
limestone layer under the Site. In fact, the water in the
limestone layer under the Site appears to be millenia-old sea
water which has dissolved as much of the limestone as chemically
possible given the conditions at depth.
d) There was no evidence that the surface water and sediments
downstream from the Site were significantly effected.
e) If the twenty-one (21) residences continued to be sampled for
the TCL/TAL at approximately $2,000 per sample, the annual cost
would be in excess of $168,000. This money might be better
spent for other activities at the Site considering the dubious
hydraulic connection involved.
f) The ground water quality data for metals clearly indicate
that there is very poor water quality within the shale zones.
What little ground water there is in the intervals monitored has
been determined to be Class III ground water by our Regional
hydrogeology experts. Water bearing zones containing Class III
ground water either contain water with a total dissolved solids
content greater than 10,000 mg/L or with a yield less than 150
gallons per day per well.
7.' Page 6.
The leachate problem at the Operable Unit One area is not
currently presenting a significant problem. Implementation of
the design for the capped area will eliminate the leachate
-------
p.5
problem at the area addressed by Operable Unit One. At the area
addressed by Operable Unit Two insignificant levels of
contaminants have been detected in the Unnamed Tributary
immediately adjacent to the seeps. However, even Ms. Sue Green,
a Commonwealth inspector, has indicated that the levels of
contaminants in the stream immediately adjacent to the seeps are
not currently of concern. Furthermore, remediation options in
the draft Feasibility Study for the Operable Unit Two area
include a rather sophisticated landfill leachate collection,
treatment, and disposal system.
A perusal of the draft Intermediate Design Report, Section
3.5.3, and attendant drawings, will indicate the measures for
surface run-on and run-off management and erosion control during
the RA.
The Agency feels that there has been a satisfactory
characterization of the nature and extent of contamination at
the area addressed by Operable Unit One. Federal and State
ARARs are definitely being taken into consideration.
EPA has offered the Commonwealth many opportunities to split
samples. The Commonwealth has not demonstrated a willingness to
split samples with EPA at each and every opportunity.
In conclusion, the Agency has determined that the technical
direction of the Operable Unit One activities is valid. A more
extensive and intensive investigation is not necessary prior to
initiation of the remedial action. The proposed modified remedy
will achieve the necessary risk reduction targets and will serve
to further protect the public health and the environment.
Sincerely,
Tarold W. TayJor,SJr., Chief
Kentucky/Tennessee Section
North Superfund Remedial Branch
Waste Management Division
Attachments (3)
-------
ATTACHMENT II
February 26, 1990 Scarborough-to-Bush letter
on clean-up to Background Levels
-------
* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
FEfi ! i IflSfl 3AS COUKTUANO STwecr.
ATLANTA. GEORGIA 3O36S
7
/
4WD-RCRA
Ms. Susan Bush, Director
Division of Waste Management
Kentucky Department for Environmental Protection
Frankfort Office Park
18 Reilly Road
Frankfort, Kentucky 40601
RE: Removal or Decontamination Standard Required to Achieve
Clean Closure
Dear Ms. Bush:
This is in response to a letter to me, dated June 28, 1989, from Don
Barker, former Director of the Division of Waste Management, which
indicated disagreement with the EPA's policy of determining clean closure
based on removal or decontamination to Agency-approved limits or factors
rather than to background levels. The controversy arose from a statement
to that effect, regarding the clean closure standard, in the May 12, 1989,
Guidance on Demonstrating Equivalency of Part 265 Clean Closures with Part
264 Requirements, promulgated by the EPA. Mr. Barker stated that
regulations required the removal or decontamination of all waste residues,
contaminated containment system components, contaminated soils, and
structures and equipment contaminated with waste. Be further stated that,
by interpreting the "remove or decontaminate" standard in accordance with
the plain or commonly understood meaning of the language, equivalency
demonstrations in Kentucky should be based on background levels as opposed
to Agency-approved limits, and requested that the EPA obtain State
concurrence prior to issuing any decisions on equivalency demonstrations
for Kentucky facilities.
The XPA does not require removal or decontamination to naturally occurring
background levels as an automatic and mandatory requirement to achieve
clean closure. The interim status surface impoundment clean closure
procedure*) irTtr^Bt"^* in the March 19, 1987, Federal Register, cited by
Mr. "•rftrr to support hi* position of requiring background levels to
certify n1*)*n closure, in fact reflect Agency policy to use health-based
perforaaao*) standards for clean closures. In order to properly and
correctly apply regulation*, it is insufficient to merely read a
regulation and apply to it an interpretation "in accordance with the plain
or commonly understood meaning of the language". It is essential to also
read the preamble preceding promulgation or amendment of the regulation in
question. The language in the preamble is vital in understanding both the
scope and meaning of the regulation and the specific regulatory intent of
those who wrote it.
-------
In the March 19, 1987, Tedaral Keoi«i;«T. $265.228 (•)(!) placed a
requirement on the owner or operator at closure tot
or decontaminate all waste residues,
*ted containment system components
(liners, etc'.), contaminated subsoils, and
structures and equipment contaminated with
waata and laachate, and manage than aa
hasardoua waata unless $261.3(d) of thia
chaptar appliaa;
Tba alternative waa to eloaa in plaea aa a landfill rathar than pursue tha
claan eloaura option. Tha praambla to tha regulation makes it elaar that
tha 8FA did not intand to pradicata claan cloaura upon removal or
dacoBtaaination to background levels, consider tha following axcarpta
from 52 Q 8706, March 19, 1987s
...the Agency interprets the terms "renove" and
•decontaminate' to aaan removal of all wastes
and liners, and the removal of laachate and
materials contaminated with the waate or leachate
(including ground water) that poae a substantial
preaent or potential threat to human health or
the environment.
Because regulations for atorage facilitiea
require no further post-closure care...the
Agency will require owners or operators to
remove all waatea and contaminated liners
and to demonstrate that any"haxardoua
constituents left in the subsoils will not
cauae unacceptable riaka to human health or
the environment.
The cloaure demonstrations submitted by
facility owners and operators must document
that the contaminants left in the subsoils
will net iJBpact any environmental media
including ground water, surface water, or
the atmosphere in excess of Agency-
tr* •'•••"**"*aM4 limits or factors...If no
Agency-recommended exposure limits exist
for a haaacdoua constituent then the owner
or operator sjuat either remove the
ooBftitoent down to background levels,
Lt data of sufficient quality for the
to determine the environmental and
health effects of the conatituent, or follow
landfill closure and poet-cloaura requir
-------
The Language in the preamble is clear. Xt is not necessary to remove or
decontaminate all vast* residues and contaminated subsoils to background
levels, but rather only to levels that will not cause unacceptable risks
to human health or the environment. To further reduce possible confusion
on this matter, a Hotice of clarification was published la the March 28,
1988, Federal Raoiata'p. Consider th« following excerpt from S3 Q 9944,
March 28, 19801
The term "wast* residues' refers to any
hazardous constituents derived from
hazardous wastes that are present in the
environment at or above levels of human
health or environmental concern.. .To
remove) or decontaminate these residues, the
unit owner or operator must remove or
decontaminate all contaminated materials,
. including liners and leachate collection devices,
unsaturated soils, saturated soils, ground
water, surface water, surface water sediments,
and any other material containing hazardous
constituents released from a hazardous waste
management unit prior to completion of
closure. . •
Zt is obvious that, under the) regulation in question, waste residues may
be removed or decontaminated while leaving in place in the subsoils,
ground water, or surface water hazardous constituents below levels of
human health or environmental concern, but above background levels.
The SPA regulations do not provide Justification for .Kentucky's current
policy of requiring removal or decontamination to background levels before
certifying clean closure. Zt is the Agency's policy to set removal or
decontamination standards based on Agency-approved limits or factors
appropriate to the hazardous constituents present and the media in which
they are located. When evaluating equivalency demonstrations at
facilities at which Kentucky has previously approved clean closure, we
will base our evaluation upon Agency-approved limits, and may issue
decisions on such demonstrations without requiring removal or
decontamination to background levels. These Agency-approved limits
include water quality standards and criteria, iiSTlnmm contaminant levels
(MCLs), health-based limits based upon verified reference doeee (RfDs) and
Carcinogenic Potency Factors (C?rs), or site-specific Agency-approved
health advisor lee. All of these limits have been derived using very
and exposure interpretations and assumptions.
RCKA closure and corrective action program is to
media to levels consistent with potential future as
-------
Clean up to levela beyond what ia protective of human health and the
environment (i.e., to background) haa been found to be infeaaibla and
unattainable at moat sitea due to costs, limited waata dlapoaal capacity
and technological limitations. Compliance with a cleanup standard
cons latent with levela protective of human health and the environment
would be eonaiatent with Kentucky'a uae of MCLa established under the Safe
Drinking Water Act for potable ground water. Zt would alao result in eore
facilities pursuing the clean cloaure option rather than placing a cap on
the unit and leaving the waate in place.
Zn the event that Kentucky'a regulations are more stringent than thoae of
the SPA, Kentucky haa the right to impose ita own State permitting
requirementa. Upon receipt of documentation of more atringent clean
cloaure requirements, the SPA will notify facilities where an equivalency
determination has been made that Kentucky's requirements are more
atringent than the SPA'S and that they may be subject to additional state
permitting requirements or to future RdtA permitting requirementa upon
authorisation to Kentucky of this portion of the program. If the State
does not have more stringent regulations or requirements for clean
closure, we request that Kentucky reevaluate its position and adopt a
policy that is in line with that of the SPA as clearly expressed in the
regulatory language referenced above.
Zf you have any questions or commenta regarding thia letter, please
contact Wayne Garfinkel, P.S., or Larry Fitchhorn, P.S., at (404)
347-3433.
Sincerely yours,
Scarbrough,
RCRA Branch
feate Management Diviaion
-------
ATTACHMENT 12
Information on Bentonite Matting in RCRA
Type Cap Systems
-------
ac i
*• 7
> JT
•s s
5: —
II
y. =
"5
5 "
'
CLAYMAX* LC Liner System for
Liquid Containment
2. MANUFACTURER
Clem Environmental Corporation
P.O. Box 88. Cordon Road
Fairmount. Georgia 30139
Phone: .404) 337-5316
(312) 321-6255 (in ID
FAX: ;4Q4> 337-2215
(312) 321-6258 un ID
Telex: 543408
3. PRODUCT DESCRIPTION
8as/c Use: CLAYMAX* LC liner
is a specially constructed, flex-
ible, impermeable liner system
which utilizes the mineral, so-
dium bentonite clay, and the geo-
textile polypropylene. Sodium
bentonite is a high-swelling smec-
tite which gives CLAYMAX* LC
liner the ability to heal itself if
ripped or punctured. In a hy-
drated state, the clay has tremen-
dous impermeability and a great
resistance to chemicals—acids,
bases and hydrocarbons. The
bentonite swells to form an im-
permeable barrier upon contact
with water or leachates.
CLAYMAX* LC liner system can
be used in construction appli-
cations for the containment or
exclusion of liquid. These appli-
cations include fresh water
ponds, waste lagoons, municipal
landfills (including caps), tank
farm containments, earthen irri-
gation canals, industrial con-
tainments and earthen dams.
Seaming is accomplished by a
simple overlap with adjoining ma-
terial since the hvdrated ben-
tonite swells to form an imper-
meable bond. Minor damage is
self-healing and major cuts or
tears are easily and effectively re-
paired* using patches of CLAY-
MAX* LC liner material,
CLAYMAX* LC liner is manufac-
tured 13.5 feet wide and 82 feet
long rolled on cardboard cores.
This allows for easy handling at
the job site. Longer material can
be furnished upon request. No
special seaming tools or fasteners
are required and CLAYMAX* LC
liner's flexibility speeds installa-
tion. The material can be cut with
T»» wvpom S0K-OM* torn* MM Mm e
i by C$1. i«M. 1«U. 1«*.
pipes, (anus, etc.-
CLAYMAX* LC liner is designed
for fast installation with a min-
imum amount of manpower.
equipment and site preparation
on both large and small |ob sites. •
It affords a maximum of con-
tainment protection with none of
the problems usually associated
Tni» Spec-Data sneet conforms
to •ditonai sty** oretcnoeo oy
The Construction Specifications
Institute The manufacturer .5
'esoonsioie 'or tecnnicai ac-
curacy.
Aunam (ram**. AMuntfn*. VA ZDM.
Product Specification .Topical'—CUVMA.X- LC
Bentomte Content
Thickness
Liner Dimensions
Effective Area Covered
Roll Weight-Unit
Permeability Coefficient
•Longer rolls available on tpecial order.
1 0 lb per square toot
'. inch
13.5 feet » 82 teet
1059.3 square teet -assume •> overiao
alone one side and one enai
1130lb$. 'mimmumi
2 x 10''° cm per second < » J5 head
pressure
: < io
Laboratory Test Data
Procedure—Six inches of sand covering CLAYMAX1 LC liner m a triaxal cell under
thirtv-uve teet ot water head pressure.
Croup
Water
Salt
Acid
Calcium
Alcohol
Organic*
Leachate
Pressure
Ptrmttnt
De-Aired Water
Seawater
Acetic Acid
Phosphoric Acid '
Calcium Chloride
Ethyl Alcohol
viethvlene Chloride 3
•I & *f> Fuel Oil 3
Sewage BOO > 38.000 8
Paper Pulp Sludge 2
ISO foot Water Head i
Many more tests are available; contact CEC for more details. The above test per-
formance data were produced under laboratory conditions The actual performance
characteristics may varv. No performance warranty is expressed or implied.
10 cm sec
• 10 cm sec
•10 cm let
•9 cm sec
•9 cm »ec
•9 cm sec
10 cm sec
10 -9 cm sec
10 -10 cm sec
10 -10 cm sec
10 -9 cm sec
£•
~s
Roll Content
Roll Weight
Roll Size
Packaging and Shipping
11070 square teet
1135 Ibs. (approx.) wrapped
14.5 feet long iPVC wrapped) x 18" diameter
(approx.)
s
Material Specifications
Primary tacking i Typical Properties;)—Polypropylene >s nonbiodegradabie and inert
to most chemicals, acids and alkalis.
Color
Filler Fiber
Substrate
Weight
Tensile Strength
Crab Strength lASTM D-16B2)
Mullen Burst Strength
(ASTM D774)
Puncture Strength (V-»-
mandnl ASTM 03787 MOO.)
Melting Point
Elongation lASTM D-1682>
Shrinkage
Hot Water
Dry (20 mm (a. 270°F)
Cover Fabric
Weight
Crab Strength
Bunt Strength
Bentonite (Sodium Montmorillonite)
Sizing
Mineralogical Composition
Adhesive
Storage
Natural white
Nylon
24 x 10 Delustered woven polypropylene.
non-toxic, water permeable
4 oz. per square yard
78 Ibs. per inch (minimum)
Warp 95 Ibs., Fill 70 Ibs.
250.25 Ibs. per square, inch
249 Ibs.
32TF
Warp 15%. Fill 18%
Nil
2%
100% spunlace polyester; open weave
allow* (or expansion of bentomte
1 oz. per square yard
Warp 30 Ibs., Fill 13.6 Ibs.
35 Ibt. per square inch
Specially graded. 6 mesh and 30 mesh
granule*
90% Montmorillonite (min.)
Water soluabte. non-toxic
On dry ground under roof or other
protective covering
The manufacturer reserves the right to change product specifications and
instructions/limitations without notice. Information contained herein supersedes
previously printed material (5>S8>.
02770
-------
CLAYMAX* LC Imer is
self-sealing and is extremely resil-
ient and damage resistant.
Composition of Materials:
CLAYMAX' LC liner is a multi-
lavered lirver svstem consisting ot
a la^er or tough, durable and flex-
ible hea^v. polypropylene, coated
with •.odium bentonite clav. The
bentonite 15 covered with a laver
ot thm poKe'ster open-weave
scrim-which protects the ben-
tonite during transportation and
installation.
Sizes: CLAY MAX' LC liner is
supplied m rolled sheets. The ma-
terial is 13.5 feet wide and 82 feet
long. The material is rolled on
3'';-inch cardboard cores. Special
lengths mav be ordered.
Site Preparation: Excavation should be well contoured; all rocks
vegetation and protrusions larger than 2 inches m diameter should
be removed.
4. TECHNICAL DATA
Refer to Specification Table on
Page 1.
CLAYMAX* LC liner's active in-
gredient, natural sodium ben-
tonite. has the ability to swell in
the presence of water to a vol-
umetric expansion of 15 times re-
sulting m a 6-fold increase in
weight. Actual installation swell-
ing is controlled by the weight of
aggregate or cover material to
onlv 2 to 3 times the original vol-
ume. Further expansion is pos-
sible into anv voids.
Limitations: CLAYMAX* LC
Irner material MUST be protected
from ultraviolet light with 6-12
inches of backfill or aggregate.
For ponds and lagoons, the ag-
gregate on slopes should not ex-
ceed 12 inches. If backfill is used,
it should be compacted with
wheeled, rolling equipment.
Pond installations, with slopes
greater than 2-to-l and in excess
of 20 feet, should b* discussed
with CtC.
CLAYMAX1 LC liner must be
stored off the ground in a dry
place.
In soils of high alkalinity, acidity
or-brine conditions (or other
groundwater contamination),
samples should be submitted to
CEC for analysis. CEC will issue
any necessary special installation
instructions.
Where installation of CLAY-
MAX* LC liner must resist ex-
treme hydrostatic pressure, a
double layer may be required.
Please consult CEC or your local
Installing adjoining rolls of CLAYMAX* LC requires a 6-mch over-
lap All seaming on slopes must be vertical and perpendicular to
the base.
•;•,.;., •;.!•:. . ;•;.
Detail of the 6-mch overlap; all soil must be removed from the
overlap area of the liner to ensure a monolithic seal.
-------
The 6-1 nch seams may be
opening during the
or pinned to base soil to potvent seam
'
E
mm^£$$$&
Anchoring: Each CLAYMAX' LC roll must be locked into trenches at the
top of the slope, covered with fill and compacted to prevent slippage.
Special installation application
procedures for CLA>MAX* LC
liner must be approved, m vxnt-
mg. bv the manufacturer prior to
installation.
CLAYV1AX* LC liner that hdb
been damaged bv precipitation
prior to backfill protection ML>T
BE REPLACED if seal integrity i> to
be maintained.
5. INSTALLATION
Site Preptntion: The pond, la-
goon, tank farm enclosure or
canal excavation dimensions
should be determined to allow for
final addition of the required 6-12
inches or soil or aggttgate cover
(Mterial. ^
~ jred with
ximum of
dial
Covering: Backfill should always be pushed forward with equipment
operating on the backfill. Cover material (other than aggregate) should
be compacted after placement.
protrusions
2 inches in
loved, and
the entir* acafifotifli) should be
compacted tt> |0% optimum den-
sity Minor surface irregularities.
however, can be accommodated.
Compaction can be accomplished
using either conventional rolling
equipment or wheeled vehicles.
Use of sheepsfoot rolling equip-
ment is not recommended. A
liner locking trench must be pro-
vided at the top of all slopes.
Orientation: It is essential to in-
stall CLAYMAX* LC liner so that
all seams of the material laid on
slopes are perpendicular to the
pond bottom. This will prevent
seam displacement during cover
material placement.
Anchoring: All CLAYMAX* LC
liner "runs" must be locked into
trenches at the top of the slopes.
covered with fill and compacted
to prevent slippage. The locking
trench should be 24 inches back
horizontally from the top of the
slope. The trench should have
minimum depth of 18 inches and
a width of at least 12 inches. Long,
steep slopes may require a re-
vised locking trench design.
Seaming: It is essential that the
first and succeeding rolls of
CLAYMAX* LC liner be pulled
tight to smooth out creases or ir-
regularities in the "runs". CLAY-
MAX* LC liner should always be
installed with the polypropylene
side up, showing the stenciled
trademark CLAYMAX*. Once the
-------
mg ' runs ' need only be laid witn
a 6-mch overlap on each side. Be
certain that all dirt is removed
from the overlap area of the mat.
The 6-inch seams may be stapled
iwith uncrimped staples; or
pmned to the base soil to prevent
seam opening during the installa-
tion process. In composite lining
svstems. the seams may be glued
it required.
Repairing: Irregular shapes.
cuts or tears in installed CLAY-
MAX* LC liner are easily accom-
modated by covering such areas
with sufficient CLAYMAX* LC
liner to provide a 6-inch overlap
on all adjoining CLAYMAX* LC
liner pieces. These repair pieces
should be pinned or glued in
place to hold the material until
cover material has been placed.
Covering: Cover material
should be applied as roll "runs"
are completed to afford maximum
protection against damage from
personnel or equipment. Cor-
rectly installed, CLAYMAX* LC
liner is sufficiently resilient to
support installation personnel.
Care should be exercised to pre-
vent seam damage, and backfill
should always be pushed forward
with equipment operating on the
backfill. Cover material should be
compacted after placement.
Handling Suggestions: CLAY-
MAX* LC liner MUST be pulled
from the top of the roll and in-
stalled polypropylene side UP.
(This side is stenciled CLAYMAX*).
The liner can be either pulled
ot a siope. or tne tree er.
first be secured in the locking
trench and the suspended roll can
be backed down the slope and
across the excavation by the sup-
porting vehicle. Suspending and
unrolling CLAYMAX* LC liner is
facilitated bv inserting a heavv-
dutv. 3-mch diameter steel pipe
(schedule 80 or heavier), through
the 3'-:-inch cardboard core that
CLAYMAX- LC Imer is shipped
on. This pipe should be 16 or 17
feet long to accommodate the
hoisting chains from the lifting
vehicle. The lifting vehicle mav be
wheeled power equipment with a
front-end bucket. A spreader bar
may be required to ensure roll
clearance and to prevent damage
to roll edges.
Installation Precautions:
CAUTION—CLAYMAX* LC liner
should not be installed in stand-
ing water or while heavy rain is
falling.
6. AVAILABILITY AND COST
Availability: CLAYMAX* LC
Liquid Containment System is
available through a worldwide
network of distributors and ap-
proved installers.-Contact the
manufacturer or your local CLAY-
MAX* LC liner representative to
order.
Cosf: Material cost will vary de-
pending on such factors as
"point-of-use location." For cur-
rent cost information, contact
your local CLAYMAX* LC liner
representative. For the name, ad-
contact the manutacturer.
7. WARRANTY
CLAYMAX* LC Liquid Con-
tainment System is normally wai-
ranted by the installing contractor
who will make specific details
available upon request.
8. MAINTENANCE
No maintenance is required
when CLAYMAX* LC liner is in-
stalled m accordance with the
manufacturer's instructions:
however, the protective cover
layer (backfill) must be main-
tained and repaired as necessarv.
9. TECHNICAL SERVICES
Clem Environmental Corpora-
tion (CEO will provide, on re-
quest, necessary technical assis-
tance in the .evaluation of
installation applicability. On-site
installation assistance is also
available from the manufacturer.
10. FILING SYSTEMS
SPEC-DATA* II
Sweets 02770/CLE. BuyLine 3526
Additional information is avail-
able from the manufacturer
upon request.
The information and recom-
mendations contained here
are based on data which is b
lieved to be reliable, but
such information and recom-
mendations are given without
guarantee or warranty.
CLAYMAX* LC LINER ADVANTAGES
Economical and easy to install
Minimal labor required
All seams are simple 6-inch
overlap
Liner can be cut and trimmed
with a utility knife
Totally flexible
No bentonite loss when cut or
trimmed
Self-healing/Self-sealing
Minimum 1 Ib. bentonite per
square foot
Natural sealant actuated by
water or leachates
5-89-1901
-------
Bentonlte Netting 1n Composite Lining System
H1ll1am R. Schubert, Assec. Member. ASCE*
Abstract
The 1984 Hazardous and Solid Haste Amndments to RCRA mandated
that double lining systens utllzlng synthetic membrane liners be
required for hazardous waste landfills. Recognizing the susceptibility
of synthetic membranes to small defects, such as punctures and faulty
seams, many designers opted to combine synthetic membrane liners
with a clay component. Lining systems utllzlng • synthetic membrane
and clay materials are known as composite liners. The clay component
of many composite liners range from l.S feet to S feet In thickness.
Due to landfill volume constraints, a composite liner utilizing
bentonlte matting as the clay component was designed. The thickness
of this composite liner 1s less than O.S Inches. The liner consists
of prefabricated bentonlte matting material placed between two
polyethylene membranes.
Laboratory testing consisted of subjecting the composite Uner
to actual landfill leachate under design maximum hydraulic heads,
as simulated 1n a trlaxlal cell. A series of tests were run to
simulate combinations of simultaneous defects 1n both the top and
bottom membrane. Simulations consisted of a combination of defect
types, Including rips, punctures, and large holes. In all cases,
Initial leakage was limited to a very small amount (I.e. 20 m11l1l1ters
or less), prior to the sealing of the defect by the bentonlte.
Chemical compatibility of the bentonlte was also evaluated using
standard methodology developed for slurry wall technology.
Details of the actual construction of this Uner, as( well as
operating performance data to date, are also presented with this
paper.
Introduction
The 1984 Hazardous and Solid Haste Amendments to RCRA mandated
that double lining systems utillzlna synthetic membrane liners be
require* for hazardous waste landfills. Specifically, the new law
required that a synthetic membrane Uner be used as the first
containment device for hazardous waste containment, Below that
synthetic liner, the new law required a secondary leachate collection
'Regional Engineer, Haste Management of North America, Inc. 7300
College Drive, Palos Heights, Illinois 60463
Schubert
-------
systeai underlain by • stcond lining systt*. Such a system would
allow for rapid dtttctlen and removal of any Itachatt that had passed
through tht primary synthetic Hntr. Thtst rtqu1rtm»nts art known
as "MiniBUB Ttchnology Requirements" for llntrs 1n hazardous waste
landfills. Whllt sptclfylng that a synthetic membrane Hntr bt ustd
for a primary Hntr. the law did allow sow latltudt In choosing
whethtr synthttlc Mttrlals, clay mettrlals, or a composUt lining
systt* (both clay and synthttlc nattrlals) art ustd for tht lowtr
Hntr.
Tht clay and synthttlc ntmbrant nattHals, whllt capablt of
hydraulic contalnmtnt, txhlblt distinct properties which art ptrtlnent
1n tht design of tht lining systta.
U.S. EPA has conttndtd that penetration Into tht Hntr during
tht active 11ft should bt severely restricted. Tht txtremely low
permeability characteristics of synthttlc mnbrant llntrs appear
to meet that criteria. On tht othtr hand. Mny designers art
uncomfortable with tht susctptlblHty of synthttlc membranes to failure
dut to manufacturing defects, punctures, ttars, faulty seams, ttc.
Clays exhibit characteristics, such as swelling and self-sealing,
that art not prtsent In synthttlc membranes. Tht composite liner
concept combines the qualities of minimum ptnetratlon and forgiveness
to minor defects.
For these reasons, many designers feel that tht ust of composite
liners 1s advantageous for both upper and lowtr Hntrs 1n tht Minimum
Technology design. Dut to landfill capacity considerations, composite
Hntr designs for top liners havt generally llmlttd tht thickness
of the clay component to approximately 1.5 to S fttt. Figure 1 shows
a generalized cross section of the double composite Hntr system.
MOTIITlU M»1tCTl«C
«•*(•*« tttf •
•• •.••:•.••' Y •-••.:'•:.• '•••• **•
*..* .*•*.* * .',.
Figure 1. Double Composite L1ntr Systta
Schubert
-------
In in tffort to «ax1i1zt tht stlf-sta11ng characttrUtlcs of
the upptr cotjposltt llntr and to •InlUzt tht voluat of landfill
lost to tht llntr system, • dtslgn 1* being ustd at CIO Landfill,
<• Caluott City. Illinois, using prtfabHcattd btntonltt Mttlng
In pi act of tht clay covenant. The thickness of tht «at 1* about
3/8 of an Inch. The btntonltt Batting 1s sandwlchtd bttwttn two
layers of polytthyltnt uembrane. Tht polyethyltnt «a«6rant on the
botton side prevents swelling of the Mttlng Into tht dralnagt t»d1a
of tht secondary leachate collection systt*. A generalized
cross-section 1s shown In Figure 2.
.
7 - ,* »• -AIM***!
• \ ^f
•uorciixt MO
'Tt \.
-------
Figure 3. BentonUe Matting Material
Laboratory Testing: Phase 1
Prior to the use of this design, the primary composite liner
was subjected to several laboratory testing programs. The first
phase of the laboratory testing was semi•quantitative leak testing.
The objective of this testing was to evaluate the performance of
the btfltonlU aatttng when subjected to leachate passing through
a small defect In • synthetic liner. Particular attention was paid
to the swelling performance of the bentonlte around the defects and
the ability of the bentonlte to plug these holes.
To test the effectiveness of the matting In this application.
2.8 Inch diameter coupons of high density polyethylene (HOPE) and
the bentonlte matting were cut. These coupons were Inserted Into
• standard trlaxlal loll testing apparatus. ?The mailing waspiace 8
Schubert
-------
between tht two HOPE coupons nth a sptclflc defect (I.e. 0.5 inch
diameter holt, slit, or puncturt) in each of tht HOPE coupons.
Porous stonts and filter paptr were ustd on the outside of the
polyethylene coupons to distribute the leachate evenly across the
surface of the test coupons. A latex membrane was placed around
the sides of this apparatus. The trlaxlal cell MS then filled with
water and pressurized to a call pressure of 30 psl. This confining
pressure was used to prevent the flow of leachate down the outside
of the sample during the test. Leachate was obtained fro* the
hazardous waste landfill for use 1n the laboratory testing program.
The leachate was Introduced Into the top of the sample through a
tube and measuring burette systen and pressurized to 10 ps1
(approximately 20 fttt of hydraulic head). This resulted la a gradient
across the 3/8 Inch thick netting of approximately 73f.
The tubing totf measuring burette systen was purged of all air
and filled wit* 4tacHate prior to the beglnnlja of the test. On
Initial pressurlzatlon, • small _|aount of leacnfte flowed Into the
matting coupons. After th1t,4n1tiat flow, the samples were monitored
for periods of three t^-Tiffr days "to determine 1f additional flow
was occurring. After tit end of tecfc- test,"'- Qitw-o^pUs were
disassembled and visually observed. •*"•* ••:.
Two separate series of tests were used In tfrts seal-quantitative
leak testing phase of the laboratory program. Tht first series
Included four HOPE and matting coupon setups. The sample sets differed
only 1n the type of defect present 1n the two HOPE coupons. Defects
were made only 1n the HOPE components of the composite liner. The
defects In the first test series were: top coupon punched, bottom
coupon punched; top coupon silt, bottom coupon slit; top coupon
punched, bottom coupon silt; top coupon slit, bottom coupon punched.
In each case, the silt was a one Inch long cut from a razor blade
penetrating the full depth of the synthetic membrane liner. The
defect Identified as a "punch" was a hole through the synthetic
membrane Uner Induced by driving a sixteen penny nail through the
membrane. The slits and punches were centered on the coupon such
that they were directly opposite from each other with only the matting
coupon in between. The results of the test program over a three
day period are shown In Table 1. In this series, the 10 ps1 pressure
was applied Instantaneously and three of four samples showed some.
Inflow upon Initial pressurlzatlon. All of the Initial Inflow occurred
within the first 60 seconds of the test. The quantity of this Initial
Inflow ranged from zero to 40 mllHllters of leachate. In addition,
the sample with a top coupon punched and a bottom coupon silt showed
approximately 20 still 1 liters of discharge during this same Initial
period. Since the Intent of the experiment was to simulate a
hypothetical field condition, saturation of the sample was not an
objective. Therefore, discharge volumes are Independent of Inflow
volumes. No Inflow or outflow was recorded after the Initial
pressurlzatlon. It Is Interesting to note that the reading from
Day 4 on the punch/slot sample shows an Increase of volum In the
Inflow burette. This was apparently due to • slight upward
displacement and Increased pore pressure of the wetted apparatus,
Schubert
-------
caused by the expansion of the bentonlte.
Sample
TABLE I
Snail Defect Lei k Testing
Inflow Burette Read In? (art)
Punch/Punch
Slot/Slot
Punch/Slot
Slot/Punch
Start of
Test
. Total
>1schare« (ml)
The
testing f
defects--**
of thrtr
testing
bottoa
hole, bottt*
diameter
was aga
series of tests, usttf 'fcfeu.|t«t-quant1tatfc|sv leak
d 1n order to monitor tTit'+ftHfryfrSlUrger
s. This second series of tests-fetalslsted
MS run., for a period of five days". This
|op coupon with a 0.84 Inch diameter hole.
turt; top coupon with a 0.84 Inch diameter
• slltj and the top coupon with a 0.84 Inch
with a 0.14 Inch diameter hole. Leachate
totb th« staple at a differential pressure of
10 psl (flradUitr^-73«). The Inflow results Monitored during this
test series ait swim triable 2. In these tests, a aaxlMi of 1.6
mllU liters had leaked fro* the primary containment. The results
from this test grovp IndlcaU that the type of defect has little
effect on the actual flow rite through the composite liner.
Additionally, the test results Indicate that the composite liner
Is capable of self-sealing relatively large holes located directly
opposite from each other 1n the top and bottom synthetic membranes.
Schubert
-------
imple 1
32.8
32.8
33.0
33.0
33.0
33.2
33.2
33.2
34.0
34.0
34.4
1.6
Sample 2
35.2
35.2
34.8
34.6
34.4
34.4
34.4
34.4
34.4
34.4
34.4
0.8
Sample 3
53.0
53.0
52.6
•52.0
52.0
52.0
52.0
52.0
52.0
52.0
52.2
0.8
TABLE 2
Large Otftet Ltak Testing
Inflow Buitttt toad1no (ml)
Date Tint
Day 1 14:30
17:00
Day 2 8:00
13:00
17:00
Day 3 8:00
12:00
17:00
Day 4 8:00
17:00
Day 6 10:30
TOTAL INFLOW
Sample 1 Top coupon dafact • 0.84-Inch dlamtttr holt
Bottoa coupon dtftct • Puncturt holt from 16-ptnny nail
Sample 2 Top coupon defect • 0.84-Inch diameter holt
Bottom coupon dtftct • l-1nch-long $1H from razor blade
Sample 3 Top coupon dtftct • 0.84-Inch dlamtttr holt
Bottom coupon dtftct • 0.84-inch diameter holt
Note 1: No rtcordtd outflow fro* the samples. '
Nott 2: Somt burtttt rtadlngs progrtss from hlghtr valut to lower
valut dut to Invtrttd graduations on tht burtttt.
Visual obstrvatlon of samples, from both strlts of ttsts. rtvtaltd
that tht btntonltt Mttlng was significantly wttttd ntar tht proximity
of tach of tht ntabrant dtftcts. Tht wetting of tht btntonltt. 1n
turn, caus«4 significant swtlllng of tht matting which caustd plugging
of tht dtftct.
Laboratory Ttstlng: Phtst 2
Having demonstrated tht effectiveness of tht 11ntr as a plugging
devlct, It was Important to evaluate tht long ttm rtslstanct to
flow provided by tht btntonltt near a hypothetical dtftct In tht
mtfflbrant. Tht stcond phast of tht laboratory testing program consisted
of eviluattng tht btntonltt matting Itself as an effective barrier
Schubtrt
-------
and che«1cal coe$at1b1l1ty characteristics of th« leachate/btntonlte
systen.
Two trlaxlal permeability ttsts Mr* performed on btntonUe Mttlng
coupons. Tht experimental setup for each sample consisted of • sample
of bentofilte netting placed between two HOPE coupons. A 0.84 inch
dfameter hole was drilled 1n each HOPE layer to allow the peraem
to Infiltrate through the bentonHe matting. This setup simulates
the flow condition which would occur near a hypothetical defect In
the composite liner. It also provides for quantification of the
permeability characteristics of the bentonlte netting.
Sample 1 was permeated with 54 •11l1l1ters of distilled water
at a differential pressure of 10 psl. Sample 2 was permeated with
a total volume of 260 mllllllters of leachate at a differential
pressure of 20 ps1. The co-efficient of permeability for Samples
1 and 2 are 1.2 times 10'' centimeters per second and 8.1 tines 10'10
centimeters per second, respectively. The details of these tests
are shown 1n Table 3. The two co-efficient of permeability values
are extremely close and represent virtually no difference, given
the sample variability and precision of the test procedure. Both
permeability values are more than one order magnitude less than the
1 times 10"' centimeters per second value, commonly considered to
represent suitable Uner material. The 260 mllllllters of pemeant
used 1n Sample 2 represents well over 100 pore volumes of perneant
through the sample. This extended permeation 1s greatly 1n excess
of the 2 to 5 pore volumes normally considered to be sufficient to
cause any possible chemical effects In a permeant/Hner system. In
addition, the bentonlte matting shows excellent performance when
exposed to high gradients. It Is speculated that the fabric and
paper surfaces of the mat serve 'to retain soil particles, thereby
mitigating erosion and piping damage.
TABLE 3
Permeability Test Results
Sample Area Length Pressure Gradient Permeability
(an2) (cm) Head (cm) (H/L) (cm/sec)
Sample 1 39.73 0.755 703.6 738 1.2 x 10'9
Sample 2 39.73 0.755 1758.9 1845 8.1 x 10'10
8 Schubert
-------
An API Fllttr Lou Test MS lUo p«rforMd on tht btntonlte scraptd
fro« tht Mttlng nattrlal. This ttst 1s coewonly ustd to evaluate
tht rtlatlvt chemical compatibility of • city •1ntn1 to a permtant.
Properties of charged clay particles are tvaluated by tht filtration
characteristics of a clay/permeent slurry. A pet-meant that floculatts
a previously dlspcrstd soil structurt will txhlblt higher filtrate
volumes (e.g. higher permeability) during this ttst. The btntonlte
was allowed to hydrate 1n a sample of the leachate for a 24 hour
period prior to conducting a test. The hydrated btntonlte was placed
1n a filter cell and subjected to a constant pressure of 100 ps1
for thirty «1 notes. The filtrate loss was 15.6 •1111l1ters and the
thickness of tht filter cake on the filter was 0.205 centimeters.
These values art typical of the filtrate loss experienced with tap
water/bentonltt slurries.
Construction
Tht double composite lining system was constructed, utilizing
strict quality control per U.S. EPA Suldanct. Tht top 3 feet of
a 30 foot Insltu clay liner was ovtr-txcavattd and rtcompacted.
Compaction of this 3 foot layer achieved densities abovt 951 of the
Standard Proctor Density and Insltu coefficient of permeability values
of less than 1 times 10"' centimeters per second. The 1ns1tu
coefficient of permeability was determined by falling head permeability
tests performed 1n a test fill at the site. On top of tht rtcompacted
clay layer, a 60 nil HOPE liner was Installed. These two components
formed the bottom composite liner for the double liner system. .As
the HOPE panels were placed, all panel seams were verified and tested
for continuity, tensile strength, and peel adhesion. Other properties
of the HOPE sheet were also routinely verified.
A synthetic secondary leachate collection layer was then Installed
between the two composite Uner systems. Panels of this material
were Installed utilizing small plastic straps at regular Intervals
along the seam length.
The lower. 60 nil HOPE component, of the upper composite Uner
was then Installed. Installation of this laytr utilized tht Identical
quality control proctdurts as outlined for tht synthetic component
of tht lowtr compos1tt llntr, ts stattd abovt. Abovt this stcond
HOPE laytr, tht btntonltt matting was placed. Out to tht rtlatlvt
weight of this mattrial, as compartd to synthetic membranes and
geotextllts. btntonltt netting rolls were relatively small 1n length
and width. Extreme cart was taktn to ensure that tht btntonltt matting
was net wtt or a»1st prior to placement. Molsttnlng of this material
would nakt 1t extremely heavy, and thtrtfort. extremely difficult
to piact. When tht btntonltt matting material was shipped to the
site, til rolls were Individually wrapped In t moUture tight plastic
wrapping. Etch Individually wrapped roll was -stored 1n t closed
topped vtn until Immediately prior to placement. Installation of
the matting mattrlal 1s shown In Figure 4.
Schubert
-------
Figure 4. Instillation of Bentonlte Matting
Seaming of tht Individual benton He panels was accomplished by
simply overlapping each adjoining panel by • width of six Inches.
This procedure was recommended by the manufacturer. Preparation
of • bentonlte panel prior to the Installation of • successive panel
1s shown In Figure 5. Placement of panels on the excavation slopes
sometlMS resulted 1n «1nor sliding of the bentonlte panels from
their original position. To prevent this, small strips of polyester
geotextllt were heat welded to the geotextlle component of adjoining
bentonlte Matting panels. Although this seaming technique has minor
structural value, 1t did prevent the bentonlte netting panels from
sliding during placement. An example of this 'tack-weld* 1s shown
In Figure 6.
10
Schubert
i
-------
Figure 5. Preptntlon of Pint! for PUctmtnt of Adjtctnt Pintl
Flflurt 6. Tack Wilding of Adjictnt P»ntli
Schutert
-------
vor i',.1*
component of the top composite Hner. Seaalng and quality control
proctdurts for this layer is Identical to those outlined above.
Performance
A 2 acre cell of a hazardous waste landfill was llntd with a
double composite liner system, as described above. This cell has
been In operation since March, 1986. To date, there has been no
accumulation of leachate 1n the secondary leachate collection system.
Conclusion
This paper describes the design philosophy, testing, and
construction of • composite double lining system used at a commercial
hazardous waste landfill. Top composite liners In a double Hner
system utilizing bentonlte matting Material can be effective and
economically justifiable. The use of prefabricated bentonlte materials
1n composite lining system can allow construction of a composite
Hner while affording a minimum cross section thickness of the lining
system.
Acknowledgements
CID Metropolitan Environmental Complex 1s an Integrated waste
disposal facility, servicing CMcagoland and surrounding areas 1n
the Midwest. The facility 1s owned and operated by Waste Management
of Illinois, Inc., a division of Haste Management of North America.
Their cooperation 1n this project 1s greatly appreciated. The
cooperation of Canonle Engineers,. Chesterton, Indiana, who were
responsible for performing all of the laboratory tests described
herein 1s also greatly appreciated. The cooperation of Almcor,
Hundeleln, Illinois, 1s also greatly appreciated for use of photographs
and technical review of this paper.
Conversion of Units
Unit Used SI Unit Equivalent
Foot 0.3048 Meters
Inch 25.4 Millimeters
Pounds per square Inch (ps1) 6.89S KN/mter*
M11 0.0254 Millimeters
Acre 0.4047 Hectares
12 Schubert
-------
References
1. American Petroleum Institute, 'Recommended Practice for Standard
Procedure for Testing Drilling Fluids'. Specification RT 138,
8th Edition. Dallas. April 1980.
2. U.S. EPA, 1982. "RCRA Guidance Document, Surface Impoundments,
Liner Systems, Final Cover, and Freeboard Control." Draft
Document.
3. U.S. EPA. 1985, "Minimum Technology Guidance on Double Liner
Systems for Landfills and Surface Impoundments-Design, Construction
and Operation'. Draft Document.
4. Weeks O.L., Schubert W.R.. 1985, "Development of Minimum Technology
for Hazardous Waste Landfills', Proceedings of Workshop entitled
'Utilization, Treatment, and Disposal of Waste on Land". December
6-7, 1985, Chicago, Soil Science Society of America, Inc.
13 Schubert
-------
ZEVELOPKENT CF MlNIMVM 7ECHNC1CCV FC? HA2ARCCCS WAS7S LANCFlLis
Clif Weeks
wiilian Schubert
:-. r-car.r y?ars much attention has been focused on the Isolation of hazardous was-.e
i- lar.dfills for the protection of human health and cha environment. The most preva-
ent mechanism for isnlation has been various landfill lintr systems. Prior to r.ra
rt^rse Conservation and Recovery Act (RCRA) in 1976, owntri and operators of waste
csal facilitir« had no federal regulations to specify «h»t type of lir.nr, if any,
used, "any of the cvrr.er/operators relied largely en In-situ or reccmpactec1. soil
liners. T.w.e reliance or. snil liners has been largely due to th« economy of the
:.-.stailaticr. ar.d the idea that soil, being the weathered end product of geologic.
rit-rials, was chemically inert and resistant no chemical attack by the waste to be
isolated. Cnly in instances where suitable soils were not available would other
lirer .r.aterials be used. Since the inception of RCRA, the requirements far !i.-ers
r.avr evclvcd ir.ro composite systems consisting of synthetic membrar.as arc soil
-atirif-3 s.
Ir. tha fsllcwir.g sections the various lir.cr types which have been «rec:;i*cl ar?
rr^'cr.sed. Also discussed is ch* recent U.S.EPA minimum Technology requirements a.-.:.
vir•.;•-$ approaches ~e meeting these requiremerts in practice. Amcr.g thes« is the
iystem presrr^ly beirn utilized at the Waste ^*r.agem«nt of Illinois, Inc., CIS
rardfill ir. Calumet City, Illinois.
Lir.sr £i/cr
-------
ms3®ftg£®$r;-
tesptife
Wilt/ |4l*nc»
1*11)
Precipitation falling on * landfill can Dither flow over lard surface as surface
r-r.cff or infiltrate the landfill cover. Part of the infiltration is returned to the
atsesphere through evapotranspiraticn while the remainder is either stored in the
CCV.T or enters the landfill. The water which eventually reaches and percolates
through the waste material is transformed irto leachate by collecting soluble cher.ical
species and particulate matter from the waste. The leachate moves veirrically through
the Itr.dfill, controlled by the waste permeability and internal landfill gradients-,
until encountering a physical or hydraulic barrier. Unless such a barrier is preser.t.
a potential exists for leachate migration into underlying soils and grcundwater.
In order to prevent or reduce the amount of leachatt produced and the amount
which can accumulate at th« base of a landfill, th» features shown in Figure 3 should
be incorporated into the landfill.
-------
ltd)
These features are:
A final cover/top liner which reduces infiltration and promotes rur.
evapotranspiration.
n low perr.eability bottom liner which will contain any leachata
water infiltrating through the final cover/top liner.
A leachate detection/collection system which will allow monitoring
rer.cval of leachate if and when it appears.
Ec:.ta. the final cover/top liner and bottom liner systems can range from a
fcil liner to a system with multilayers of soils, polyir.cric membranes, gcotex
a-.d drainage r.edia.
= ff a
«rated
f=r and
simple
r.iies
-------
.~£--'.^:;rj .Requirements-
Tatle 1 crrsr.clocicjlly outlines t.w.e t:.S.E?A regulatory requirements fcr h
waste la.-.dfili lir.ers.
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7>.e P.ftscurctt Conservation and Recovery Act of 1976 is the primary federal law which
;«5ulJtes hazardous wast* disposal facilities. The law charges USEPA with the adair.-
istraticn of th« proqraa. The first regulations pertaining to hazardous waste land-
fill liners w«r« promulgated on May 19, 1960. The liner requirements are found in the
-------
^"— •414«ftOs,| c
«i Tr»M«lt 0«UII
_ . VtGlTATlOK . .
v t » i .
V ^.
I THICK (HIM I MIL COVCN IWtl MO«T IMH»VtOu»
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•arc
-------
July 26, 1982 (Permitted and Inttrin Status Facilities) — These regular isr.s
required both types «f facilities to have lintr and leachate colltction systc.r. as
well as a final eovtr. In the preaofile to these regulation*. It was stated that c.-.ly
"dc sii.-.imus" penetration of the p«nne*nt into the liner would be acceptable duri.-.g t.w.«
active life of the facility. "Da minimus" penetration was described as that degree
wh;ch ccc-rs in synthetic rnemJsrare liners. Penetration that normally occurs in clay
li.-ers was r.ct cs.-.sirtered "de minimus." In this manner, USEPA effectively set fc«st
available technology standards for liners, specifically the use of synthetic rr.emhrj.-e
liners. Much s! the impetus for using synthetic liners was based on research per-
formed *• a r.unber of institutions on the compatibility of soils with liquid hazardous
was-re. Much of this research involved the use of pure organic solvents which resulted
:.-. draratic ir.creases in permeability of soil materials. Th» validity of this
researc!-. in application to disposal sites is suspect and has been the subject of aiuch
teiite.
C.S.£?A issued a guidance for liner (U.S.EPA 1982) used in surface impoun&nen:*
a.-d landfills. The liner system would include the following:
liner
a sircle soil (clay) or synthetic material as a minimum. If waste would
rer.ain at closure, a synthetic lir.er would be used.
if an impoundment was designed to be in use longer than 30 y^nrs, a primary
synthetic lir.er and a secondary clay liner would be used.
the synthetic liner would be a minimum of 30 mils thick in addition to
being physically and chemically resistant to the waste.
soil liners would be a_minimum of 2 feet thick with a saturated hydraulic
conductivity of 1 x 10*' or/sec. The soil liner would be thick enough to
contain wasr.e within the lir.er during the operating life of the syster..
'final cover) liner svstem
The cap would be no more pemeaMe than the bottom liner and consists cf a
twc fact thick vegetated top cover, a 30 centimeter thick granular layer
wi-h a minimum hydraulic corductiviry of 1 x 10 * cm/sec., and a lover
permeability layer consisting of a synthetic membrane liner, 20 mil minimum
thickness, and a soil layer, minimum 2 feet thick, with saturated hydraulic
conductivity of IxlO*7 cm/sec.
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Fi-^res 5 and 6 show details cf lir.er a.-..i cap (fi.-.al cover) systems
the ascve requir«ff.«nt*.
r
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-------
scv. 8, 19S4 (Permitted and Interim Status Facilities) — Tht Hazardous a.-.i S=:..".
waste Ar.er.dr.tnt requires, 4t the base of landfills, the us* of two or more liners a-d
a leachate collection system. USEPA Issued 4 draft guidance document outlining the
rr.i.-.ir.-T. technology requirements of the double liner system. The document required
that a double liner system be used with a secondary leachate collection systen between
the two lir.ers. It also required that a synthetic membrane be used for the uppermost'
li.-.er ar.d that clay or a composite clay/synthetic membrane be used for the bottom
li.-.er. In subsequent guidance USEPA largely discounted the suitability of clay alert
as a bcttcm liner and provided breakthrough time requirements be used as bottom liner
perfcrr.ar.ee criteria. In evaluating breakthrough in c)ay liners, very conservative
assurp:i=r.s were required to be made regarding hydraulic properties of geologic
r.a-terials. .
The elements of the double liner system consist of a primary leachate collccticrt
a.-d rer-.aval system, a primary synthetic liner, A secondary leachate collection system.
a.-.d a secs.-.iary composite synthetic/clay liner. The main requirements of the liner
ara given telcw.
and secondary synthetic liners
must be a minimus of 30 mil thick.
r.ust be chemically resistant as determined by EPA test method 2020.
design must protect liner from operating and service loading.
.ft synthetic/clay liner
The synthetic component of this liner must prevent liquid penetration
cf the liner during the period of post closure monitoring.
Clay liner must be ajninimxun of three feet thick with a saturated
conductivity cf ixio"7 cm/sec, or less.
-------
.er syssesi designed to meet air.isun technology requirements are illustrated
-~«s 7 through 10.
«OK*I»«S
CtOTClTict ULTtH CATCH
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•CCOTflTIlt
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on rr
MOTtCTivf
?£CCNOA«f CSM'OtiTt LINC* CJNJHT.MC
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SuWACC l«0«.)
SCCONOAM COM*Ofirt LMCM
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-------
LATCH
w io*a««
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CCOTCXTItC
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-------
ii'.srz Zesi^.ad to tfinvru/n Techno'.,?*
After a review of the evolution of the liner requirements it should bt o-v~u, ....
the Xey eler.e.-.t in ar.y liner system is the synthetic and clay liners. Tht'ot-tr'kev
•*•*••" i« the leachate collection/detection system, but this will not be discussed
The clay and synthetic membrane materials, while both capable of hyd-au'-- —
tair.r.er.t, exhibit distinct properties which are pertinent in the designYf a'll.-ir.g"
i'S£?A has contended that penetration into the liner during the active life sCould
te severely restricted. The extremely .low permeability characteristics of synchet-c
re.-^rar.e liners appear -.o meet that criteria. On the other hand, rany designers are
ur.c=:r.fcrtabie with the susceptibility of synthetic membrane* to failure, due to
r.ar.u.'acturir.g defects, punctures, tears, faulty sears, etc. Clays exhibit character-
is-.ics such as swelling and self-sealing that are not present in synthetic mentranes
The ccrscsite liner concept mmbines the qualities of minimum penetration and for-
giveness to minor defects.
Fcr thes* reaacr.s, many designers feel that the use of composite liners is
advantageous fsr both upper and lower liners in the minimun technology design. Due
satenal har.dling landfill space considerations, composite liner designs for top
li.-ars have generally limited the thickness of the clay component to approximately 2
to 5 feet. Figure 11 shows a generalized cross-section of the double composite liner
•IITI
MO'I trill MOIICTiv*
'•crtcritc t»'««
a*i w i to» >oor
ntn»
cc»!
PIOUKI 11 OOUiH COMPOIITI UINCK STITIM
-------
:.-. ar. effort to maximize the self-sealing characteristics of the upper csr.pcs-'
li.-.er and to minimize the volume of landfill lest to the liner system, e design is ~
bei.-.g used at CID Landfill, in Calumet City, Illinois, using prefabricated bentonite
matting in place of the clay component of the upper composite liner. The ber.toni-e
clay minerals optimize the swelling, and therefore the self-staling characteristics
of the clay compcnent. The th'ickr.ess of the mat is about 3/8 of an inch. The ben-
tsr.ite mattxr.g is sandwiched between two layers of polyethylene membrane in crier'to
prevent swelling of the matting into the drainage media of the secondary leacna-e
collection system. A generalized cross-section is shown in Figure 12.
- -"./%.'
>, "~t " .* i »44 4 MOW i «4iri
\
9f «»
rt «4t
f s s s f s x- s x- x x- x- \ ._
X / •(a«O*«4«ClMa-l4Mil9* l« aMXCTIt {'.IT
PIOUMI IS OOWiti COM^OIlTt LINIM tY«TIM UTILIZING •INTOHITI MAT
The bentonit* Batting is comprised of granular b«ntonite adhered to a polyester
gec:extil« with • water soluble glue. A protective paper sheet is also glued to the
back in crder to provide containment of the granular bentonite during shipping and
placement. Car* tnist be taken during shipping and installation in order to kaep the
matting dry. If the ratting becomes wet, placement problement problem will occur due
to the extreme weight of the wetted matting and dclamination of the bentonite,
geotextile, and paper layers. More uniform in-place thicknesses of bentonite also car
be achieved if the granular bentonite can remain rigid, until activated in actual
service. Seaming of the matting is accomplished by simple lapping of the material to
avoid gapping. Xn order to minimize wetting of the material after placement,
construction specifications retired covering of the mat with synthetic membrane and
the end of each working day.
-------
The installation was subject to rigid third party quality control procedures »..i
has tee.-, installed in accordance with the design specifications and permits.
Laboratory tests performed on the composite liner indicate that the bentonite win te
properly activated and perform the self-sealing function when permeated with the
leachates that are being generated at the site. This installation has recently bee-,
crr.pleted. There is no Icng-tera performance documentation available.
Conclusions
This paper reviews the evolution of liner design for hazardous waste landfills since
the first RCRA regulations in 1980. We have also presented a discussion of different
apprraches used in meeting recent minimum technology requirements. The use. of
composite clay/synthetic membrane liners seems prudent in implementation of these
standards. In scr.e cases, prefabricated bentonite matting may be used as a soil
ccr.pcr.e.-.t in a ccirposite liner system.
Reference -
1) U'.S.iPA, 1983, "Lining of Waste Impoundment and Disposal Facilities," SW-370,
Cffire of Sclid Waste and Emergency Response, Washington, D.C.
I) 'v.S.EPA, 1522, "RCRA Guidance Document, Surface Impoundments, Liner Systems,
Final Cover, and Freeboard Control." Draft Document.
3) C.S.EPA, 1985, "Minimum Technology Guidance on Double Liner Systems for
Landfills and Surface Impoundments—Design, Construction and Operation" Draft
Cccusient.
-------
TECHNICAL NOTE NO. 1
REVISION NO. 0
COMPARISON OF STEADY-STATE LEAKAGE RATES
FOR AOVECTIVE FLOW THROUGH CLAYMAX
AND COMPACTED CLAY LINERS
for
James Clen Corporation
444 North Michigan, Suite 1610
Chicago, Illinois 60611
GeoServlces Inc. Consulting Engineers
5950 Live Oak Parkway, Suite 330
Norcross, Georgia 30093
GeoServlces Project Number: P1061
December 1988
-------
Decmber 1988 Ttchnie.i Not* 1
Cl«t Environment*!. I«c
NO.
TECHNICAL NOTE NO. 1
REVISION NO. 0
COMPARISON OF STEADY-STATE LEAKAGE RATES FOR AOVECTIVE
FLOW THROUGH CLAYMAX AND COMPACTED CLAY LINERS
1. INTRODUCTION
Lining systems are used 1n solid and hazardous waste landfills, surface
Impoundments, water storage ponds, wastewater treatment ponds, evaporation
basins, and other structures whose function 1s to store or contain fluids. These
lining systems typically consist of compacted clay layers used either alone or
in conjunction with geomembranes and other materials. Whether the clay liners
are used alone or in combination with geomembrane liners, the leakage rates
through the lining systems are minimized by using a compacted clay layer with
a hydraulic conductivity that is as low as possible. In some geographical areas,
however, the occurrence of clay materials suitable for use 1n constructing low-
permeability liners 1s limited. In these areas, it may be cost effective to use
a CLAYMAX liner 1n place of the compacted clay.
This Technical Note No. I compares the relative performance of CLAYMAJ
with compacted clay liners for several different lining system configurations!
For this technical note, the comparison 1s limited to the ability of CLAYMAX and
compacted clay liners to minimize advective leachate migration through the liner.
Subsequent technical notes compare other important properties of soil liners,
such as hydrodynamlc dispersion through liner systems, slope stability,
durability, resistance to chemical attack, and constructability.
2. LINING SYSTEMS
2.1 Description of Lining Systems
Four basic types of lining systems are considered 1n this report. The four
Incorporate Tow-permeability compacted clay layers, geomembranes, and high-
permeability drainage layers, as shown in Figure 1. These four lining systems
are described below:
• Single Liner. A single Uner may consist of a compacted clay layer
or geomembrane. In a landfill, this liner Is overlain by a drainage
media such as sand, gravel or a synthetic drainage material. This
drainage media above the liner 1n a landfill Is called a leachate
collection and removal system (LCRS). In a lagoon, pond, or surface
Impoundment, there Is no LCRS.
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1988 Technical Nott I
Cl«« Environmental, Hc.
Revision Ho. 0
• Single-Composite Liner. A single-composite liner typically consists
of a geomembrane underlain by a layer of compacted clay. In a
municipal solid waste landfill, the composite Uner 1s overlain by
an LCRS. In a lagoon, pond, or surface Impoundment, there 1s no
LCRS.
• Double-Liner. A double-liner system 1n a landfill typically consists
of, from top to bottom, an LCRS, a geomembrane top liner, a leakage
detection, collection and removal system (LDCRS), and a bottom liner.
The bottom Uner may be a compacted clay layer or a composite
consisting of a geomembrane underlain by a compacted clay layer.
In a lagoon, pond, or surface Impoundment, there is no LCRS above
the top geomembrane liner.
• Double-Composite Liner. A double-composite Uner system is a
variation of the double-liner system. In a double-composite liner
system, both the upper and lower liners are composites.
Both double-!1ner systems and double-composite liner systems may be used
in hazardous waste landfills. Existing U.S. Environmental Protection Agency
(EPA) regulations require a double-liner system with either a compacted clay or
composite bottom liner, as described in USEPA [1985]. Many states (New York,
New Jersey, and Pennsylvania, for example) now require the use of double-liner
systems in municipal solid waste landfills. Increasingly, landfill owners are
selecting double-liner systems to minimize their liabilities and the
environmental Impacts of their landfills.
2.2 Applications of CLAYHAX In Lining Systems
CLAYMAX is a very low permeability, flexible soil liner composed of sodium
montmorillonite (a highly plastic smectite clay) sandwiched between two
polypropylene geotextiles. In a hydrated (swollen) state, the clay exhibits a
very low hydraulic conductivity and a high resistance to attack by adds, bases,
and hydrocarbons. Given these characteristics, CLAYMAX can be considered for
use in any of the four lining system applications described 1n the previous
section. Specifically, the possible uses for CLAYMAX Include (Figure 1):
• Single Uner. CLAYMAX may be used 1n Heu of a geomembrane or
compacted clay layer;
• Single-Composite Liner. CLAYMAX may be substituted for the compacted
clay layer 1n a single composite Uner system;
• Double-Uner. CLAYMAX may be substituted for the compacted clay
bottom Uner or the compacted clay components of the composite bottom
liner; and
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19U TtcNiic.l Hot! 1
ClOT £nv1ror«»nul. Inc.
Rtvlflon No
• Double-Composite Liner. CLAYMAX may be substituted for the compacted
clay components of either the top or bottom composite liners.
2.3 Evaluation qf the Suitability of CLAYMAX
In hazardous waste landfills and 1n municipal solid waste landfills In many
states, an "innovative" lining system component may be substituted for a
"standard" component If equivalency can be demonstrated. A demonstration of
equivalency addresses the required performance criteria for the lining system.
The demonstration of equivalency for the substitution of CLAYMAX for the
compacted clay layers 1n the four lining systems described previously would
consist of:
• a comparison of the capabilities of liners constructed with CLAYMAX
and compacted clay layers to contain leachate. This comparison
should address leachate migration due to both advective an'd diffusive
transport mechanisms;
• a comparison of slope stability for lining systems constructed from
CLAYMAX and compacted clay;
• a comparison of the mechanical properties affecting the long-term
durability of CLAYMAX and compacted clay;
• a comparison of the resistance to chemical attack of CLAYMAX and
compacted clay by the leachates contained within the lining system
and
• a comparison of the constructablllty of lining systems Incorporating
CLAYMAX and compacted clays.
This technical note addresses only the comparison of leachate migration
due to advection through liners constructed with CLAYMAX and compacted clays.
The remaining comparisons listed above, which comprise a full demonstration of
equivalency, will be addressed in subsequent CLAYMAX technical notes.
3. MECHANISMS FOR LEACHATE MIGRATION
The two primary mechanisms for leachate migration through compacted clay
or CLAYMAX I1ntr$ are tdvectlon and hydrodynamk dispersion [freeze and Cherry,
1979].
Advection 1$ the process by which solutes are transported through a porous
media In response to a hydraulic gradient or head difference. Advective flow
through clay and CLAYMAX liners 1s discussed in Section 4.
Hydrodynamlc dispersion 1s a transport process consisting of two primary
components [Freeze and Cherry, 1979J: (1) mechanical mixing during fluid
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tecvtar 19U Ttchnic*! Mot. I
Clot Eiwlroflntnul. Inc.
Rtvllton No. 0
advectlon; and (11) molecular diffusion. Mechanical mixing 1s defined as a
mixing process resulting from velocity gradients that develop as a permeant flows
through the soil, while molecular diffusion 1s defined as the process by which
solutes are transported through a porous media 1n response to a chemical
concentration gradient. In a compacted clay or CLAYMAX liner, the flow velocities
are small. Therefore, the velocity gradients contributing to mechanical mixing
are negligible 1n low permeability compacted clays or CLAYMAX, and molecular
diffusion 1s the dominant process 1n hydrodynamlc dispersion. Leachate migration
due to molecular diffusion 1s addressed in a separate technical note.
Leachate migration rates through composite liners (which can consist of
a geomembrane underlain by either a compacted clay layer or a layer of CLAYMAX)
are lower than leachate migration rates through clay layers or CLAYMAX alone
[USEPA, 1987]. Leachate migration rates through composite liners are primarily
a function of the hydraulic head above the Uner, the size and frequency of
defects 1n the geomembrane, the hydraulic conductivity of the clay, and the
Intimacy of the contact between the geomembrane and the clay [Glroud and
Bonaparte, 1988]. Leachate migration rates through composite Uner systems
constructed with compacted clays and CLAYMAX are discussed 1n Section 5.
4. ADVECTION
4.1 Introduction
Advectlon 1s the process by which solutes are transported 1n response to
a hydraulic gradient. The solutes are transported at an average rate equal to
the seepage velocity, vs, given by a modified form of Carey's equation:
v, - J
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19M Ttchnlc«l Not* I
C1«B EnvlrorMinttl. Inc.
No. 0
• 1e - hydraulic gradient of CLAYMAX (dimenslonless), given by:
1e ' (h. * Dc)/°c (Equation 2)
• v, • seepage velocity through compacted clay layer (ft/s or m/s);
• K, • hydraulic conductivity of compacted clay layer (cm/s or m/s);
• D, • thickness of compacted clay layer (ft or m);
• n( • porosity of compacted clay layer (dimenslonless); and
• . 1 • hydraulic gradient of compacted clay layer (dimenslonless),
given by:
*» • (h- * °i)/Ds (Equation 3)
If it 1s assumed that Carey's equation 1s valid, the steady-state flow
rate through a compacted clay Uner, q,, may be computed as follows:
q, - K$1f A (Equation 4)
where: A • the cross-sectional area of'flow (ft2 or m2). Similarly, the steady-
state flow rate through a CLAYMAX liner is given by:
qc • KC1C A (Equation 5)
4.2 Seepage Velocity
The seepage velocity, given by Equation 1, 1s a function of the hydraulic
conductivity of the compacted clay or CLAYMAX, the porosity of the compacted clay
or CLAYMAX, and the hydraulic gradient acting on the compacted clay or CLAYMAX.
GeoServlces has recently measured the hydraulic conductivity of CLAYMAX.
The tests were carried out 1n a flexible wall permeameter with an aqueous sodium
solution as the perneant. A hydraulic conductivity of 2 x 10*10 cm/s was
obtained. This value of hydraulic conductivity 1s lower than the hydraulic
conductivity of alnost all compacted clay liners. It 1s also lower than the
maximum hydraulic conductivity of 10*7 cm/s allowed by USEPA regulations for
hazardous waste regulations (40 CFR 264). Based on Equation 1, for an equal
hydraulic gradient and cross-sectional area of flow, the lower hydraulic
conductivity of CLAYMAX results 1n a lower seepage velocity than that for
compacted clay. For a given hydraulic head, however, the hydraulic gradient
acting on CLAYMAX will be higher than the hydraulic gradient acting on the
compacted clay. This Is because CLAYMAX 1s relatively thin (e.g., 0.4 1n., or
10 mm), whereas compacted clay liners are typically relatively thick (e.g., 3
5
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0*c«*»r 19M T«ehnlc«l Not, l
1« Ciw1rwMnt«1. Inc.
No. 0
ft, or 0.9 m). Inspection of Equations 2 and 3 show that for a given value of
hw, the thicker the liner, the lower the hydraulic gradient.
The higher hydraulic gradient of CLAYHAX acts to counteract the beneficial
effect of Us lower hydraulic conductivity, especially at higher values of h
At low hydraulic heads, the difference 1n hydraulic gradient between a compacted
clay and ClAYMAX becomes small, and the seepage velocity 1s primarily a function
of the hydraulic conductivities of the two materials.
4.3 Comparison of Steady State Leachate Migration
If 1t Is assumed that advectlve flow 1s the only mechanism contributing
to leachate migration through a liner, CLAYMAX would provide equivalent
performance to a compacted clay layer 1f the advectlve steady state leachate
migration rates through the two materials were equal. This can be expressed by
the equation:
q, • qc (Equation 6)
Substituting the appropriate terms Into Equations 1 and 6, and assuming n, • ne:
K,1, • KC1C (Equation 7)
Substituting Equations 2 and 3 Into Equation 7 yields:
K, (0, + hJ/D, - Kc (Oe + hJ/De - (Equation 8)
Solving this equation for D, results 1n: > + _A_
w
0, • - (Equation 9)
This equation 1s Interesting 1n that 1t shows that under steady-state
conditions, the required compacted clay layer thickness, D,, can become very
large to obtain equivalency with CLAYMAX. In fact, the equation shows that for
a given ratio of KVK,, there 1s a hydraulic head below which the steady-state
seepage velocity of compacted clay will be larger than the seepage velocity of
CLAYMAX, ne Batter what the thickness of the compacted clay. Inspection of
Equation 9 shows that as the denominator approaches zero, D, approaches Infinity,
so that an Infinite thickness of compacted clay Is required to give a seepage
velocity equal to that of CLAYMAX. Solving for the point at which the
denominator of Equation 9 equals zero gives the following result:
h,- Oe (K/Kc - 1) (Equation 10)
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19M Noti 1
Rtvljton NO.
Any value of hydraulic head on the liner less than or equal to the value of
h obtained from Equation 10 results 1n a lower steady-state seepage velocity
through CLAYMAX than through any thickness of compacted clay Uner. Flaure 2
Illustrates this result. y
For values of hw greater than that given by Equation 10, Equation 9 can be
solved for the required thickness of compacted clay, Dt, to obtain a compacted
clay steady-state seepage velocity equal to the steady-state seepage velocity
1n CLAYMAX. The results of these calculations are presented 1n Figure 3.
Typical numerical results from Figure 3 are given 1n the table below:
EQUIVALENT DEPTH OF SOIL
Kc (cm/s) K, (cm/s) h. (m) Dc (mm) D, (mm)
10'' . 10"' .10 10 100
ID'10 10-' 1.00 10 10,000
10'10 10*7 10.00 10 1,000,000
From the foregoing, 1t can be concluded that for typical field condition'
(I.e., Dc - 0.4 1n., K - 2 x 10"l° cm/s, D, - 3 ft, and K, - 10"7
cm/s) advectlve flow through a CLAYMAX liner will be much lower than advect1v_
flow through a compacted clay liner.
The steady state seepage rates due to hydrodynamlc dispersion are discussed
1n a separate technical note.
4.3 Breakthrough Time
Breakthrough time 1s defined as the time required for a drop of leachate
entering a layer of compacted clay or CLAYMAX to pass through the layer and Into
the surrounding environment. The analysis presented 1n this section 1s conducted
using the assumption of one-dimensional steady-state flow conditions. For this
case, the breakthrough time 1s equal to the thickness of the Uner divided by
the steady-state seepage velocity.
To find the depth of soil needed to provide a breakthrough time equal to that
of CLAYMAX, the following equation applies:
D/v, - Dc/vc (Equation 11)
Substituting Equations 1, 2, and 3 Into Equation 11, and assuming n, » ne
gives:
7
-------
Dtcwtwr 19M f»chn(e«l Noti l
ClOT Envlronwnul. He.
Rtvtiion NO. 0
D2 D2
« - Uc (Equation 12)
K, (h. + D,) Kc (h. + De)
Solving this equation 1n a dlmenslonless form results 1n:
0, K,
— • —
DC 2Ke
Calculations have been carried out using Equatlo and a range of ratios
of hydraulic conductivities. The family of curves resulting from the
calculations are shown 1n Figure 4. The figure shows that Equatlo 1s
bounded asymptotically at low hydraulic heads by the ratio of KVK,.; for
example, for IC/K. • 100, at low hydraulic heads the compacted clay must
be 100 times thicker than CLAYMAX to provide an equal breakthrough time.
For larger hydraulic heads, the required depth of compacted clay
decreases.
Numerical results provided by Figure 4 are given In the table below:
EQUIVALENT DEPTH OF SOIL FOR BREAKTHROUGH TIME
Kc (cm/s) K, (cm/3) hw (m) De (m) D, (m)
10-9 10*; .01 0.1 J 0.35
10*9 10'; .01 1 x 10'4 0.99
10'10 10'7 .01 0.01 5.01
From the foregoing, 1t can be concluded that for the typical field
conditions described previously, solute breakthrough times for the CLAYHAX
layer are on the same order of, or larger than, breakthrough times for the
compacted clay liners.
5. FUN THROUGH COMPOSITE LINERS
5.1 Introduction
This section presents an analysis of the two-dimensional advectlve
flow of leachate through a composite liner. The analysis uses a model
developed by Glroud and Bonaparte [1988]. The model 1s used to compare
the performance of composite liners having a geooembrane upper component
with a hole 1n 1t and a compacted clay or CLAYHAX lower component. Only
advectlve flow 1s considered.
8
-------
D*c«*»r 19M Ttctaieil Nott 1
ClOT CnvtronMtfUil. Inc.
R«vlnon No. '
5.2 Analytical Model for Evaluating Flow Through a Composite Hn»r
A composite liner 1s a liner comprised of two or more low-permeability
components made of different materials 1n contact with each other. The
purpose of a composite liner is to combine the advantages of two
materials, such as geomembranes and soils, which have different hydraulic,
physical, and endurance properties. The presence of an Intact geomembrane
is beneficial because Its very low permeability decreases the rate of
leachate migrating through the liner by several orders of magnitude
compared to the rate of leachate migration through a layer of compacted
soil. The presence of a compacted clay layer or CLAYMAX beneath the
geomembrane Is beneficial because It Increases the breakthrough time and
it decreases the rate of leachate migration through any holes in the
geomembrane.
As stated previously, leachate migration through a composite liner is
a function of the hydraulic head on top of the liner, the hydraulic
conductivities of the individual components of the liner, the quality of
the contact between the two components, and the frequency and sizes of any
defects in the geomembrane component of the liner.
Leachate migration through the geomembrane component of the composite
liner can be due to either permeation through the geomembrane (i.e.,
leachate migration through a geomembrane that has no defects); or flow
through geomembrane defects such as holes or plnholes. Giroud and
Bonaparte [1988] have shown that leakage due to permeation is several
orders of magnitude less than leakage through typical defects in
geomembranes. (Their analysis made use of Information obtained from a
field study to determine average sizes and frequencies of geomembrane
defects in projects constructed under the guidance of a good construction
quality assurance program). Thus, the analysis presented in this section
assumes that leachate migration through a composite liner is through a
hole in the geooaabrane.
The contact between the geomembrane and underlying layer affect the
amount of leachate migration through a geomembrane defect. In general,
the mechanisa of leachate migration through a composite liner when there
is a hole 1n the geomembrane is as follows: the fluid (I.e., liquid or
vapor) first migrates through the geomembrane hole; the fluid may then
travel laterally some distance in the space, 1f any, between the
geooeabrane and the underlying layer; finally, the fluid migrates Into and
eventually through the underlying layer. The less Intimate the contact
between the geomembrane and compacted clay components of the composite
Uner, the greater the rate of leachate migration.
The four equations given by Giroud and Bonaparte [1988] for leakage
through holes In geomembranes of composite liners are given below as a
function of the contact quality:
-------
19M TK>*!C«I K0t* i
Clm Envlrotwtnul. He.
Rtvtjton No. 0
Contact or Flow Condition plow __
absolute minimum flow - vertical flow Q - K,a (hw + H)/H
perfect contact - approximate value
of Q given by radial flow Q • tKhwd
excellent contact - empirical equations
from model tests Q - O^a0-1*0-"^
absolute maximum • flow resulting from
large space between geomembrane and soil Q • 0.6 a 2ghw
where: Q • leakage rate; K • hydraulic conductivity of layer underlying
geomembrane; a • area of hole 1n geomembrane; hw • liquid depth on
geomembrane; H • thickness of soil layer; d - diameter of hole 1n
geomembrane; and g • acceleration due to gravity. The third equation
given above 1s empirically derived and must use the following units: a(m ),
K (m/s), and hw (m).
5.3 Results of Analytical Mode.1 for Compacted Clay and CLAYMAX
The analytical model presented in the previous section 1s applied to
two composite liners 1n this section: (1) a geomembrane underlain by a
layer of compacted clay; and (11) a geomembrane underlain by a layer of
CLAYMAX.
Figure 6 shows leakage rates for a particular value of head due to a
geomembrane hole 1n a composite liner as a function of field conditions
and the hydraulic conductivity of the layer underlying the geomembrane.
As explained 1n Glroud and Bonaparte [1983], the field conditions can be
defined as follows for the two extremes: (1) best •> the layer underlying
the geomembrane Is well-compacted, flat and smooth, has not been deformed
by rutting during construction, has no clods and cracks, and the
geomembrane Is flexible and has no wrinkles; and (11) worst - the soil 1s
poorly compacted, has an Irregular surface and Is cracked, and the
geomembraiM 1s stiff and exhibits a pattern of large, connected wrinkles.
As shown In Figure 5, for the range of hydraulic conductivities which
can be expected for compacted clay and CLAYMAX, the steady-state rate of
leachate migration due to advectlon through composite liners underlain
with CLAYMAX are 1n general several orders of magnitude lower than those
associated with composite liners underlain with a layer of compacted clay.
10
-------
Dtcwtar 1988 Ttchnietl Kott 1
ClOT EnvlronMtntil. Inc.
B«v1llon No. 0
6. CONCLUSIONS
• Based on a one-dimensional advectlve transport model, a layer of
CLAYMAX with a hydraulic conductivity of 2 x 10'10 cm/s and a
thickness of 0.4 In., and a compacted clay layer with a hydraulic
conductivity of 1 x 10"7 cm/s and a thickness of 3 ft, the
following comments apply:
steady-state leachate migration rates through CLAYMAX
are much lower than for the compacted clay layer, and
solute breakthrough (or transit) tines for the CLAYMAX
layer are of the same order of, or larger than,
breakthrough times for the compacted clay layer.
• Based on a two-dimensional, steady-state advectlve model, the
rate of leachate migration through a hole 1n the geomembrane
component of a composite liner will be much lower if the
geomembrane is underlain by a layer of CLAYMAX than if it 1s
underlain by a layer of compacted clay with a hydraulic
conductivity of 10"7 cm/s.
• Subsequent CLAYMAX technical notes will address other important
design properties and characteristics of CLAYMAX and compacted
clay liners including hydrodynamlc dispersion, slope stability,
durability, resistance to chemical attack, and constructabillty.
11
-------
Not* 1
lOT Env1rof*int«l, lie.
Ktvlslon Ne. 0
BIBLIOGRAPHY
Freeze, R.A., and Cherry, J.A., "Groundwater". Prentice-Hall, Inc.,
Englewood Cliffs, New Jersey, 1979.
Glroud, J.P., and Bonaparte, R., "Leakage Through Liners Constructed with
Geomembranes", accepted for publication 1n GeotextHes and Geomembranes.
1988.
Mitchell, J.K., "Soil Behavior". John Wiley and Sons, New York, NY, 1976.
USEPA, "Minimum Technology Guidance on Double Liner Systems for Landfills
and Surface Impoundments -- Design. Construction, and Operation*. Draft
Second Version, EPA/530-SW-85-102, U.S. Environmental Protection Agency,
Cincinnati, OH, May 1985, 71 p.
USEPA, "Background Document; Bottom Liner Performance 1n Double-Lined
Landfills and Surface Impoundments*. EPA/530-SW-87-013, U.S. Environmental
Protection Agency, Washington, DC, Prepared by GeoServlces Inc., Apr
1987b, 301 p.
12
-------
USES FOR CLAYMAX
;•„ LCRS GRANULAR •'.'•'.'.'.;
/.; .DRAINAGE LAYER • :.'. ;;•
»•/;'; /;/////
COMPACTED CLAY LINER /
/
0
•LCRS GRANULAR •.'•.'•
Dfl A I N A G E. L A Y E R .'.; {'.''..•
•CLAYMAX LINER
SINGLE LINER SYSTEM
'.-..:;-Y LCRS GRANULAR •'.'/;.'•'•'
;-..:v.- .DRAINAGE LAYER- V-f.
•••••••'•••••-••••••••••••••••yj-'--
GEOMEMBRANE
•LCRS GRANULAR :'•''••'•'•
DRAINAGE. LAYEflI V;V;.
' • •'•'• • •••••••••••."
///////// / ' /NGEOMEMBRANE
COMPACTED CLAY LINER /
CLAYMAX LINER
SINGLE COMPOSITE LINER SYSTEM
•/.•'.'• LCRS GRANULAR'N>'v>:
•.;•;: ORAINAGE LAYER ':'.•'.'•;
LCRS GRANULAR '-.•.;.;•;
COMPACTED CLAY LINER /
CLAYMAX LINER
DOUBLE LINER SYSTEM
•';•. •••' LCRS GRANULAR•.•;•:•
'' ' ''' ''''
//////// ' VEOMEMBRANE
/ COATACTEp CLAY LINER
ORANULARTit-*^
LAYER.
COMPACTED CLAY LINER /
/X / // // / //•///
.-.-• -.. fcwna GRANULAR'•'.'.-'-:
GEOMEMBRANE^^r.D.RAINAGE LAYER - V'•'
CLAYMAX LINER--?35Bpi .
_A |^^^LOCRS OflANULAfl^:Mg
S/ ^«*W,W,M,WW.^,V
GEOMEMBRANE /^6^ACTED CL/Y UNER V
DOUBLE COMPOSITE LINER SYSTEM
GEOSERVICES INC.
CONSULTING ENGINEERS
FIGURE NO.
1
PROJECT NO.
P1061
DOCUMENT NO.
TN 1
PAGE NO.
-------
LIMITING HYDRAULIC HEAD AT WHICH STEADY-STATE
SEEPAGE VELOCITIES THROUGH CLAY WILL ALWAYS
EXCEED THOSE THROUGH CLAYMAX (ADVECTION ONLY)
GEOSERVICES INC.
CONSULTING ENGINEERS
FIGURE NO.
PROJECT NO.
DOCUMENT NO.
2
P1061
TN 1
-------
DEPTH OF COMPACTED CLAY REQUIRED FOR EQUAL
STEADY-STATE SEEPAGE VELOCITY (ADVECTION ONLY)
10
GEOSERVICES INC.
CONSULTING ENGINEERS
FIGURE NO.
PROJECT NO.
DOCUMENT NO.
3
P1061
TN 1 ~*~
-------
GEOSERV/CES INC.
CONSULTING ENGINEERS
-------
UJ
O
X
UJ
LEAKAGE RATE DUE TO A GEOMEMBRANE HOLE IN A
FIELD CONDITIONS
10
-4
best good poor worst
to •
to0-
00-
10
•12
id1"
Liquid Depth on Untf
Holt ATM
Holt Dianwttr ———
• 0.030 m
•1xl64 m2
-0.011 m
Comptcttd Clay Thickntss 0.9 m
CLAYMAX Thicknxt Q.Q1 m
COMPACTED CLAY
K, cm/s
CLAYMAX
K, cm/s
COMPACTED CLAY
— —— CLAYMAX
MINIMUM
FLOW
PERFECT
CONTACT
EXCELLENT
CONTACT
MAXIMl
FLOW
y^=gsN QEOSERVICES INC.
* -^ CONSULTING ENGINEERS
name NO.
PROJECT NO.
5
P1061
OOCUUCNT MO TN |^—
PAOC NO.
-------
ATTACHMENT #3
Calculations on Hydraulic Conductivity
and Associated Information
-------
:fo -^reftr*' ~fc- (*P,
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i in M'imni/-iii.'ii
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CEORIO »
CEOTEXTILE
GEONET
EOGRID
HOPE GEOMEMBRANE
..*... _ ....... ±_ ______ _
BENTONITE MATTING
HOPE OCOMtMBRANE
CEONET
GEOTEXTILE
CAP "A"
CAP "B"
• THE REQUIREMENT FOR A GEOCRlO WIIL
BE EVALUATED AS THE DESIGN PROCEEDS
fCMEDIAL AC1ION
SMITH'S FARM OPERABLE UNIT ONE
LAW ENVIRONMENTAL. MC.
CONCEPTUAL DETAILS - AREA A CAP
JOH NO 41 Ot>
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CALCULATION COVER SHEET
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-------
I******
PERCOLATION THROUGH COVER
REMEDIAL ACTION - SMITH'S FARM
APRIL 10, 1991 - CLAY SOIL
GOOD GRASS
LAYER 1
VERTICAL PERCOLATION LAYER
THICKNESS
POROSITY
FIELD CAPACITY
WILTING POINT
INITIAL SOIL WATER CONTENT
SATURATED HYDRAULIC CONDUCTIVITY
24.00 INCHES
0.4730 VOL/VOL
0.2217 VOL/VOL
0.1043 VOL/VOL
0.2217 VOL/VOL
0.002183999866 CM/SEC
LAYER 2
LATERAL DRAINAGE LAYER
THICKNESS
POROSITY
FIELD CAPACITY
WILTING POINT
INITIAL SOIL WATER CONTENT
SATURATED HYDRAULIC CONDUCTIVITY
SLOPE
DRAINAGE LENGTH
0.22 INCHES
0.8200 VOL/VOL
0.0500 VOL/VOL
0.0200 VOL/VOL
0.0500 VOL/VOL
18.000000000000 CM/SEC
18.00 PERCENT
250.0 FEET
LAYER 3
BARRIER SOIL LINER WITH FLEXIBLE MEMBRANE LINER
THICKNESS - 24.00 INCHES
-------
POROSITY
FIELD CAPACITY
WILTING POINT
INITIAL SOIL WATER CONTENT
SATURATED HYDRAULIC CONDUCTIVITY
LINER LEAKAGE FRACTION
0.4300 VOL/VOL
0.3663 VOL/VOL
0.2802 VOL/VOL
0.4300 VOL/VOL
0.000000100000 CM/SEC
0.00500000
GENERAL SIMULATION DATA
SCS RUNOFF CURVE NUMBER
TOTAL AREA OF COVER
EVAPORATIVE ZONE DEPTH
UPPER LIMIT VEG. STORAGE
INITIAL VEG. STORAGE
INITIAL SNOW WATER CONTENT
INITIAL TOTAL WATER STORAGE IN
SOIL AND WASTE LAYERS
80.00
421000. SQ FT
24.00 INCHES
11.3520 INCHES
5.8735 INCHES
0.0000 INCHES
15.6518 INCHES
SOIL WATER CONTENT INITIALIZED BY PROGRAM.
CLIMATOLOGICAL DATA
SYNTHETIC RAINFALL WITH SYNTHETIC DAILY TEMPERATURES AND
SOLAR RADIATION FOR LOUISVILLE KENTUCKY
MAXIMUM LEAF AREA INDEX » 3.30
START OF GROWING SEASON (JULIAN DATE) » 108
END OF GROWING SEASON (JULIAN DATE) » 297
NORMAL MEAN MONTHLY TEMPERATURES, DEGREES FAHRENHEIT
JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DEC
32.50
77.60
3S.90
76.40
45.10
69.90
56.60
57.70
65.40
46.10
73.70
37.20
AVERAGE MONTHLY VALUES IN INCHES FOR YEARS
1 THROUGH
JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DE
PRECIPITATION
TOTALS
2.58
3.63
2.75
2.25
3.78
3.85
5.57
2.41
2.62
3.14
3.66
3.09
-------
STD. DEVIATIONS
RUNOFF
TOTALS
ST'D. DEVIATIONS
EVAPOTRANS P I RAT I ON
TOTALS
STD. DEVIATIONS
LATERAL DRAINAGE FROM
TOTALS
STD. DEVIATIONS
PERCOLATION FROM LAYE
TOTALS
STD. DEVIATIONS
1
2
0
0
0
0
1
3
0
0
1
0
1
0
R
0
0
0
0
.34
.22
.000
.021
.000
.031
.081
.328
.140
.867
LAYER
.5775
.0000
.6169
.0000
3
.0000
.0000
.0000
.0000
0
1
0
c
0
0
1
2
0
1
2
1
0
0
0
0
0
0
0
.80
.55
.000
. COO
.001
.000
.712
.363
.313
.796
.0607
.0000
.5677
.0000
.0000
.0000
.0000
.0000
0
1
0
0
0
0
2
3
0
1
1
0
0
0
0
0
0
0
.67
.09
.032
.068
.071
.069
.844
.203
.140
.315
.3651
.0014
.9457
.0032
.0000
.0000
.0000
.0000
2.
1.
0.
0.
0.
0.
4.
2.
0.
0.
1.
0.
1.
0.
0.
0.
0.
0.
72
41
036
001
051
002
293
310
242
649
1131
0217
0806
0431
0000
0000
0000
0000
0.
1.
0.
0.
0.
0.
4.
1.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
35
77
001
005
003
010
314
494
932
256
5231
2564
7121
4243
0000
0000
0000
0000
2.02
1.43
0.010
0.026
0.022
0.042
3.866
1.180
0.713
0.192
0.0022
1.3213
0.0035
1.5266
0.0000
0.0000
0.0000
0.0000
AVERAGE ANNUAL TOTALS & (STD. DEVIATIONS) FOR YEARS 1 THROUGH 5
(INCHES)
PRECIPITATION
RUNOFF
EVAPOTRANSPIRATION
LATERAL DRAINAGE FROM
LAYER 2
PERCOLATION FROM LAYER 3
CHANGE IN WATER STORAGE
39.33 I
0.199 i
31.988
7.2424
0.0003
-0.102
( 2.889)
( 0.133)
( 2.707)
( 1.5436)
( 0.0000)
( 0.642)
(CU. FT.)
1379757.
6990.
1122256.
254089.
11.
.-3589.
PERCENT
100.00
0.51
81.34
18.42
0.00
-0.26
-------
>**** *
PEAK DAILY VALUES FOR YEARS
PRECIPITATION
RUNOFF
LATERAL DRAINAGE FROM LAYER 2
PERCOLATION FROM LAYER' 3
HEAD ON LAYER 3
SNOW WATER
MAXIMUM. VEG. SOIL WATER (VOL/VOL)
MINIMUM VEG. SOIL WATER (VOL/VOL)
1 THROUGH
(INCHES)
2.39
0.159
0.5342
0.0000
0.1
1.03
0.3203
0.1043
5
(CU. FT.)
83849.2
5580.7
18742.0
0.1
36068.9
FINAL WATER STORAGE AT END OF YEAR 5
» ^ ^ «» ^^M MW^^ ^ W» W ^ •* <•> ** • ^ ^ •* ^ ^ ^ ••• ** ^ ^ ^ ••* ^ ^ ^ ^ ** **• *• ** •* ••• ••
LAYER (INCHES) (VOL/VOL)
1 5.45 0.2272
2 0.01 0.0505
3 10.32 0.4300
SHOW WATER 0.00
-------
PERCOLATION THROUGH COVER
REMEDIAL ACTION - SMITH'S FARM
APRIL 10, 1991 - BENTONITE MATTING
GOOD GRASS
LAYER 1
VERTICAL PERCOLATION LAYER
THICKNESS
POROSITY
FIELD CAPACITY
WILTING POINT
INITIAL SOIL WATER CONTENT
SATURATED HYDRAULIC CONDUCTIVITY
24.00 INCHES
0.4730 VOL/VOL
0.2217 VOL/VOL
0.1043 VOL/VOL
0.2217 VOL/VOL
0.002183999866 CM/SEC
LAYER 2
LATERAL DRAINAGE LAYER
THICKNESS
POROSITY
FIELD CAPACITY
WILTING POINT
INITIAL SOIL WATER CONTENT
SATURATED HYDRAULIC CONDUCTIVITY
SLOPE
DRAINAGE LENGTH
0.22 INCHES
0.8200 VOL/VOL
0.0500 VOL/VOL
0.0200 VOL/VOL
0.0500 VOL/VOL
18.000000000000 CM/SEC
18.00 PERCENT
250.0 FEET
LAYER 3
BARRIER SOIL LINER WITH FLEXIBLE MEMBRANE LINER
THICKNESS - 0.25 INCHES
-------
POROSITY
FIELD CAPACITY
WILTING POINT
INITIAL SOIL WATER CONTENT
SATURATED HYDRAULIC CONDUCTIVITY
LINER LEAKAGE FRACTION
0.4300 VOL/VOL
0.3700 VOL/VOL
0.2800 VOL/VOL
0.4300 VOL/VOL
0.000000001000 CM/SEC
0.00500000
GENERAL SIMULATION DATA
SCS RUNOFF CURVE NUMBER
TOTAL AREA OF COVER
EVAPORATIVE ZONE DEPTH
UPPER LIMIT VEG. STORAGE
INITIAL VEG. STORAGE
INITIAL SNOW WATER CONTENT
INITIAL TOTAL WATER STORAGE
SOIL AND WASTE LAYERS
80.
421000,
24,
11,
5,
0,
00
SQ FT
00 INCHES
3520 INCHES
8735 INCHES
0000 INCHES
IN
5.4393 INCHES
SOIL WATER CONTENT INITIALIZED BY PROGRAM.
CLIMATOLOGICAL DATA
SYNTHETIC RAINFALL WITH SYNTHETIC DAILY TEMPERATURES AND
SOLAR RADIATION FOR LOUISVILLE KENTUCKY
MAXIMUM LEAF AREA INDEX =3.30
START OF GROWING SEASON (JULIAN DATE) = 108
END OF GROWING SEASON (JULIAN DATE) = 297
NORMAL MEAN MONTHLY TEMPERATURES, DEGREES FAHRENHEIT
JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DEC
32.50
77.60
35.90
76.40
45.10
69.90
56.60
57.70
65.40
46.10
73.70
37.20
AVERAGE MONTHLY VALUES IN INCHES FOR YEARS
1 THROUGH
JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DEC
PRECIPITATION
TOTALS
2.58
3.63
2.75
2.25
3.78
3.85
5.57 2.62 3.66
2.41 3.14 3.09
-------
STD. DEVIATIONS
RUNOFF
TOTALS
STD. DEVIATIONS
EVAPOTRANSPIRATION
TOTALS
STD. DEVIATIONS
LATERAL DRAINAGE FROM
TOTALS
STD. DEVIATIONS
PERCOLATION FROM LAYE
TOTALS
STD. DEVIATIONS
1
2
0
0
0
0
1
3
0
0
1
0
1
0
R
0
0
0
0
.34
.22
.000
.021
.000
.031
.081
.328
.140
.867
LAYER
.5775
.0000
.6169
.0000
3
.0000
.0000
.0000
.0000
0.
1.
0.
0.
0.
0.
1.
2.
0.
1.
2
1.
0.
0.
0.
0.
0.
0.
0.
80
55
000
000
001
000
712
363
313
796
0606
0000
5677
0000
0000
0000
0000
0000
0.
1.
0.
0.
0.
0.
2.
3.
0.
1.
1.
0.
0.
0.
0.
0.
0.
0.
67
09
032
068
071
069
844
202
140
315
3649
0015
9457
0032
0000
0000
0000
0000
2.
1.
0.
0.
0.
0.
4.
2.
0.
0.
1.
0.
1.
0.
0.
0.
0.
0.
72
41
036
001
051
002
281
310
240
649
1129
0217
0804
0431
0000
0000
0000
0000
0.
1.
0.
0.
0.
0.
4.
1.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
35
77
001
005
003
010
324
494
915
256
5235
2564
7118
4243
0000
0000
0000
0000
2.02
1.43
0.010
0.026
0.022
0.042
3.866
-1.180
0.713
0.192
0.0022
1.3214
0.0035
1.5267
0.0000
0.0000
0.0000
0.0000
WERAGE ANNUAL TOTALS 6 (STD. DEVIATIONS) FOR YEARS 1 THROUGH 5
(INCHES)
PRECIPITATION
RUNOFF
EVAPOTRANSPIRATION
LATERAL DRAINAGE FROM
LAYER 2
PERCOLATION FROM LAYER 3
CHANGE IN WATER STORAGE
39.33 I
0.199 i
31.988 l
7.2426 i
0.0000 i
-0.102
; 2.889)
( 0.133)
( 2.707)
( 1.5431)
( 0.0000)
( 0.641)
(CU. FT.)
1379757.
6990.
1122251.
254095.
0.
-3579.
PERCENT
100.00
0.51
81.34
18.42
0.00
-0.26
-------
>*•• «
PEAK DAILY VALUES FOR YEARS
PRECIPITATION
RUNOFF
LATERAL DRAINAGE FROM LAYER 2
PERCOLATION FROM LAYER 3
HEAD ON LAYER 3
SNOW WATER
MAXIMUM VEG. SOIL WATER (VOL/VOL)
MINIMUM VEG. SOIL WATER (VOL/VOL)
1 THROUGH
(INCHES)
2.39
0.159
0.5342
0.0000
0.1
1.03
0.3203
0.1043
5
(CU. FT.)
83849.2
5580.3
18742.5
0.0
36068.9
FINAL WATER STORAGE AT END OF YEAR 5
»M«W««W«»W«W««««W«»
-------
u
Project Title:
Project Name:
Project No.:
___. UATION WOnKSHefci
C€O€/ -
4r\-
J Sheet 1 of 2
*bc'll By: (Q .
Date:
Checked:
4r\ 1C
CLIMATOLOQICAL DATA
Location: L£ U '*=>U i \ I C .
Maximum Leaf Area Index: O
/—/• N
Choose type: Default/Manual/SuntnetuP
( *=> years)
or Bare ground/poor/fairffiood^xcellent grass
Evaporative Zone Depth: "7*4- inches or Bare ground/fair grass/excellent grass
(not gr««t«f than d«pth to lin«f) _
SOIL DATA
/»— \
Program to initialize soil water content? (Yes/Mo
Layer
Number
(from top)
1
2
3
Liner Leakage Soil Compacted? Initial
Thickness Layer Type Fraction Texture (Soil textures Soil Water
(Layer type 4) Number 1 to 15) Content*
inches (i to 4) (Otoi) 0 to 20) (Yes or No) vol/voi
2A I (1 or 2)! (o.oooi-Bood'OA/oo •. ~[ i KJ
O.'L'L ^ : \9a : kj
2^4- 4- C. OCS • \(+
4 '
5 : ;
6 I :
7 ;
8
9
10
11
12
i ! ' ;
j ! 1 •
! ! i i
i i
i I' r
i i
• initial soil wattr content not asked for if program is to initialize the soil water or if layer type is 3 or 4.
Value mutt be between wilting point and porosity.
USER-SPECIFIED SOIL TEXTURES
Soil Texture Wilting Field S«t. Hydraulic
Number Point Capacity Porosity Conductivity
: VOi/VOi VOl/VOi : VOt/VOl
19s
i9b
20a
20b
i D.O*L ! D.DS I O.&2,
i I !
! I !
I I i
cm/sec
Ifi
-------
neLP MODEL CALCULATION WORKSHEET
J Sheet 2 of 2
DESIGN DATA
Layer 1: If soil texture no. is between 1 4 15,
type of vegetation: Bare ground/poor/fair/^ogpyexceiient grass
SCS Runoff Curve No. (OptionaJ): (1 to 100)
If soil texture no. is between 16 & 20,
SCS Runoff Curve No.:
s"
Run-off: Landfill • Open (not covered) o
-------
MtfL
project -rule:
Project Name:
Proiect No.:
Qe\/s^ "
3 Sheet 1 of 2
Bv:
(TKs
O
Checked:
Location: LcQSvA I \-e.
CLIMATQLOGICAL DATA
Choose type:
Maximum Leaf Area index: "5,3
or Bare ground/poor/fairflftabdjexcellent grass
( ^ years)
Evaporative Zone Depth: ZAr inches or Bare ground/fair grass/excellent grass
(net flfttUf than d«pth to lin«r) ^
SOIL DATA
Program to initialize soil water content?
Liner Leakage Soil Compacted? Initial
Layer Thickness Layer Type Fraction Texture (Soil textures Soil Water
Number (Layer type 4) Number itolS) Content*
(from top) inches (1 to 4) (Otoi) (1 to 20) (Yes or No) vol/vol
1 • 1A- I (1 or2)' (ooooi-goodOA/oa i "7 : fvj
2 C.ZZ. *L l^a M
3 Q. IS 4- C CcrS ZDa
4
5
6
7 ;
a i
9
10 i
11 I
12
I '
!
i ;
. i i
! ! !
1 ! !
i i 1
• Initial soil wattr content not asked for if program is to initialize the soil water or if layer type is 3 or 4.
Value must be between wilting point and porosity.
USER-SPECIFIED SOIL TEXTURES
Soil Texture
Number
I9a
I9b
20a
20b
Wilting
Point
vol/vol
o.ct
O.Tfr
Field
Capacity
vol/vol
Sat. Hydraulic
Porosity Conductivity
vol/vol^
C. C<=, \ 0. 8Z
C ?3~1
i
i 0.4-3
cm/sec
\&
I v 1 0"'
-------
POOR QUALITY
ORIGINAL
-------
ATTACHMENT 7.2.3
KENTUCKY'S LETTER DATED SEPTEMBER 26, 1991
-------
S=N7 3v:C= = " FOR ENV. PROTECT, i 9-26-91 ; 2=17=M '. FRANKFORT, KY- AOi 5*7
it-It•" brand fax transmittal memo 7871 |«o
-------
Mr. DoAngelo
Page two
September 26, 1991
of these comments, we continue to object to the overall solution
for remediation of the Smith's Farm site.
Sincerely,
Rick Hogan, supervisor
Remedial Action section
Uncontrolled Sites Branch
Division of Waste Management
RH/kb
cct File
Bob Padgett
Carl Millanti
-------
ATTACHMENT 7.3
RI AND RD SOIL SAMPLING DATA SUMMARIES
-------
ATTACHMENT 7.3.1
REMEDIAL INVESTIGATION DATA SUMMARIES
-------
5.0 SURFACE AND SHALLOW SOIL INVESTIGATION
5.1 PURPOSE AND
Soil samples were collected from the ground surface and
from depths of less than four feet. The soil sampling was
designed to address several data needs. First, three
samples (SL-21, SL-22, and SL-23) were collected (Figures
5-1 and 5-2) to determine the background quality of
surficial soils in the site area. These samples were
collected from areas where disposal activities apparently
did not take place. This assessment was made on the basis
of aerial photographs and visual observations made in the
area. Second, two samples (SL-24 and SL-25) were collected
from beneath the cross country electrical power
transmission lines which bisect the site just south of the
Study Area. It is believed that chemical herbicides are
used to inhibit vegetative growth within the power line
right-of-way. These samples were intended to identify the
herbicide and aid in assessment of such herbicide
applications as a possible source of contamination detected
in samples from within the Study Area. Third, eleven
samples (SL-26 to SL-36) were collected from locations
within the Study Area to help assess risks associated with
contact with contaminated surficial soils. These locations
were selected in the field using two critera: the
potential for high levels of contamination based on
appearance and general knowledge of the Study Area
developed durir.z the investigation and the potential for
human contact i_.e. proximity to a road, path or dirt bike
trail). Finally, eight samples (SL-37 to SL-44) were
collected from four hand augered borings. Two of these
borings were completed on the opposite bank of each of the
two creeks that define the boundaries of the Study Area.
Two samples were collected from each boring: one from near
the ground surface and one from a depth of about four
feet. The purpose of these samples was to confirm that
contamination is confined to the Study Area. Care was
taken to collect these samples on the hillside above the
stream at locations which would not be affected by
contaminated stream water during periods of high flow.
5.2 METHODOLOGY
All surficial samples (SL-21 to SL-36) were collected using
stainless steel scoops or spoons. At the four hand augered
sample locations, the surficial soil sample was collected
using a stainless steel scoop or spoon. The sample
collected at depth was taken from the auger barrel. All
5-1
-------
• SOIL SAMPLE
LOCATION
REM HI
SMITH'S FARM
SURFICIAL SOIL SAMPLE LOCATIONS IN
VICINITY OF THE STUDY AREA
CC. JOHNSON 8 MALHOTRA . P C.
5-2
-------
CUICX
CiMETARY
/ PERMITTED
SOURCE^ PROPERTY TAX MAP
SCALE
0' 660-
REM III
SMITH'S FARM
DATE
OCT. 1988
SURFIC1AL SOIL SAMPLE LOCATION
OF THE STUDY AREA
OUTSIDE
C.C.JOHNSON & MALHOTRA.P.C.
-------
samples were deposited into decontaminated stainless stee;
bouls and mixed gently before removal of the volatile
organics portion of the sample. Volatile organic sample
containers were sealed with electrical tape immediately
after collection. The remaining sample was mixed again
before being transferred to sample containers. All
equipment used to collect the soil samples was
decontaminated in accordance with Region IV ESD Standard
Operating Procedures.
5.3 RESULTS
Results of the CLP analysis of soil samples are presented
in Tables 5-1 and 5-2.
5 . 4 DATA ANALYSIS
Samples were considered contaminated when any organic
compound was detected which does not occur naturally and
which could not be attributed to sampling or analytical
technique. Evaluation of inorganic contamination was based
on comparison with concentrations detected in background
samples (SL-21, SL-22 and SL-23). Toluene was detected in
all of the background samples and in over 80 percent of all
samples collected. The source of toluene in these samples
cannot be determined, however, toluene concentrations in
these samples will be regarded as questionable.
Three surficial soil samples (SL-21, SL-22, SL-23) were
collected during the investigation to determine background
conditions. All of the samples contained toluene, as
discussed above, but were otherwise uncontaminated.
Samples SL-24 and SL-25 were collected from the power line
right-of-way to determine the effect of aerial herbicide
applications on analytical results from this investiga-
tion. Organic analysis results were consistent with
results of the background samples except for detection of
970 ug/kg of bis(2-ethyl hexyl) phthalate in SL-25.
Concentration of inorganic compounds was not significantly
greater than background in either of these two samples.
Samples SL-26 through SL-36 were collected from within the
Study Area at locations with a high potential for
contamination or high potential for human contact.
Contamination was detected in all of the samples and
included volatile organics, phenolic compounds, PAHs, PCBs
and metals. Organic analysis results were not available
for SL-34 as the CLP organics laboratory claimed the sample
5-4
-------
TABLE 5-1
SMITH'S FMtM
SOU. SAMPLES — ORGANIC
UESULTS IN UG/KG
OROMIIC
PARAHr.lf.RS
I.I DICMI.OROE1IIAHE
1 . 2 IHCIII.OIIOEIIICME
IRICIII.OHOKIIICNE
l»l.ui:iiE
EIIIVI. BCMZCNC
TOTAL KVLCIII:S
3 AND/OR 4 METHYL PHEHOL
ISOPIIOROtlE
NAPHTHALENE
2 -HeillVUIAPimiALEIIE
DIHETKVI. Plllllnl.AlE
DI-N BUrVLPIHIIALATE
PVREIIB
BEIIZYI. BlfTYI. PimiM>TE
B|9l2-nilYI.IIEXVI.|riMIIKLK1E
UI-H-OCrVLPIIIHALME
PCB-1248
PCB-1234
PCB-1260
SI.
21 1
190
•
5)1.
2IA -1
110
!il.
22 1
190
ill.
21 1
160
Ml.
24 1
110
HI.
2«> 1
37
9/0
HI.
26 1
31
. 'M
4.1
5»
71
32(11)0
4-JUJ
9BO
sun
1000
200000C
.11.
2/1
3J
1300
380
i 01.
1 211 1
130
64.1
4B.I
501
420(1.1
75J
1100
1000
31.
29-1
1.1
330
B2.J
I50J
1600
4/0
410
91.
10 1
190
64J
72,1
3/0
2200C
SI.
31 1
2J
7200C
91.
32 1
1200
36.1
1 30.1
40.1
310
.1 - estimated vain*
C - r«9ull> con*limed by OCHS
Natal Blank calla la table Indicate no detection.
-------
TABLE 5-1 (TOUT.)
SMITH'S t'AHM
.SOIL .SAMPLES — OltttANIC
RESULTS IN UK/Kti
cr.
ORGANIC
PARAHCICR9
i.l-oicuiuHni:iiiMic
i.2-ninii.oiioi:iiii:nc
iRinii.oHoeinuic
IOI.UI:NE
tlim. BENZDIE
lOfkt XYI.Ctir.9
3 AMD/OR 4 HE III VL PHENOL
ISUI'ltORONC
NAPII IIIAI i:ne
2 ME IHYUHUnmiM.niE
DIHCIIUL PHIHM.ME
Dl N BUrVLPIIIllALAlE
PVREIIE
BCIIZVL BtrTVI. PinilAI.AlE
BI91 2-E1II1TI.IIEXYI IHHIHALATE
Dl -H-OCIYU'IIIIIAI-AIE
PCB-1240
PCB-1294
PCB 1 260
91.
33 1
3VO
200
91.
34 1
a
A
N
P
L
e
N
O
T
R
E
C
E
1
V
E
D
91.
1
1
1
1
1
1
1
I fll.
| 36 1
260
I90O
2BO
6MI
81.
36A 1
20O
1 7O.I
68J
2SOOJ
720
1 "((IOC
91.
yi -i
4.1
'
HI.
311 1
4.1
SI.
34 1
•
3J
SI.
4O 1
i|.
Ill
26
91.
42 1
4J
SI.
41 1
09
SI.
44 1
J - •otlmaled value
C • ivaulta con(li»«d by OCH3
-------
TAW.R 5-2
BMITirtt FAUM
SOIL SAMI'l.t:!! — INOROANICH
HK.SIJLTS IN M
-------
TARI.E 5-2 (CONT. )
SMITH'S FAKM
ROIL SAMPLES — INORGANICS
RESULTS IN MG/KG
en
i
CX>
IHOROAHIC
PARAMLTKR.I
ALUMINUM
AHIIHOHY
AHSLHIC
HARIIIN
BI:HVII.IUM
CAHMIIM
CALCIUM
ClinoMIUH
cunAi.r
COPPER
IRON
I.CAU
MAdllCSmiN
HAIIOAIIESE
HCRCURV
IIICKCI.
POTASSIUM
SMT.MIUH
SII.VIIR
BOD HIM
VAIIADIUN
ZINC
CYANIDE
SI.
33-1
14000
62
22
31000
ltt.1
460
.22.IN
28
1.4.1
20
Ml.
34 1
6200
340
100000
29
30000
320.1
40000
3BO
.32.111
13
220.1
1 .5
(II.
35-1
1 70011
I7O
24
44000
44.1
25O
27
. 76J
28
Ml.
36-1
IBOOO
4100
4'
140
20000
II 00.1
iao
23
1.6.1
31
920.1
2.3
fll.
36A- 1
21000
2900
1.9
80
3600O
I5OOJ
210
. 2IJM
27
2400
I.VI
37
560.1
2
ill.
37 1
I2OOO
97
21
21000
1 7.1
59O
•
I7J
.75J
22
Ml.
3H 1
' I4OOO
34
24
32000
310
.45.111
31
2500
3.6J
21
SI.
39 1
II 000
67
1.4
21
leooo
I9J
820
. 3IJII
20
1300
I.I.I
3.8.1
22
SI.
40 1
14000
39
33000
I3J
290
.22.111
16
I.8J
29
01.
41 1
9900
41
21000
IBJ
3BO
.27.111
9.2
IJ
17
SI.
42-1
14000
48
32000
260
.2JH
31
2400
69.1
19
91.
4J-I
II 000
89
30000
440
.36.111
13
.64J
25
6)1
91. 1
44 1 1
I looo :
i
i
43 1
1
1
;
1
i
1
35OOO I
9 b.l 1
:
34» :
. 26.ui :
24 1
1
1411
2 U :
70 :
2) :
i
.1 - ent (mated value
H ~ pi •aiiraft Iv* •vldenca of pi eaeitra ol cnntoilal
-------
was not received. All traffic reports, chain-of-custody
reports and other paper work indicate that the sample was
collected, packaged and shipped to the laboratory. The
reason for this discrepancy is unknown, it should be noted
that all but one of the samples analyzed for organic
compounds contained PCBs. The data in Table 5-1
illustrates the variability of waste constituents found at
various locations within the Study Area.
Samples SL-37 through SL-44 were collected from four
locations just beyond the boundaries of the Study Area to
confirm that no disposal too* place in these areas.
Samples SL-37, SL-39, SL-41 and SL-43 were collected from
near the ground surface while SL-38, SL-40, SL-42 and SL-44
were collected from between two and one-half and three and
one-half feet below ground surface. All but one of these
samples (SL-40) contained toluene and no other organic
contamination was detected in any of these samples. No
significant deviations from background concentrations were
noted for inorganic contaminants in any of these eight
samples. It can be concluded from a review of this data
that the streams east and west of the Study Area define the
limits of disposal and contamination in those areas.
A review of all surficial soil data reveals several facts.
First, the herbicide applications reported on the power
line right-of-way seem to have had little or no effect as
indicated by the results of the June, 1988 sampling.
Second, the selected locations sampled on-site were
contamiriated with a variety of organic and inorganic
chemicals with PCBs being detected in all but one of the
on-site samples analyzed. Finally, it appears that
contamination originating from disposal in the Study Area
has not migrated across the creeks defining the east and
west boundaries.
5-9
-------
6.0 SURFACE WATER AND SEDIMENT INVESTIGATION
6.1 PURPOSE AND SCOPE
The purpose of the surface water and sediment investigation
was to characterize the quality of surface water and
sediment with respect to chemical contamination. Data from
this investigation allowed an evaluation of the extent of
migration of contamination from the Study Area to potential
downstream receptors. It was also possible to evaluate the
effect of other potential contamination sources within the
drainage basin.
Surface water and sediment samples were first collected
during a preliminary site visit in December, 1987. Surface
water samples were collected from seven locations (SW-3
through SW-9) and sediment samples from nine locations
(SD-3 through SD-11.1) during this effort. Several of
these surface water and sediment samples were taken from
groundwater/leachate seeps and most were located
immediately in and around the Study Area. Analytical
results from these samples provided the REM III team with a
limited characterization of the site prior to initiation of
the site investigation effort. An additional round of
surface water and sediment samples was collected during the
site investigation in April, 1988. This sampling consisted
of the collection of surface water (SW-ii through SW-33)
and sediment (SD-11.2 through SD-33) samples at 23
locations throughout the drainage basin of the Unnamed
Tributary. Due to an oversight, the last sample collected
in December, 1987 and the first sample collected during
April, 1988 were both labelled SD-il. These samples have
been renumbered. The December, 1987 sample is numbered
SD-11.1 and the April, 1988 sample is numbered SD-11.2.
Two additional surface water samples (SW-34 and SW-35) were
collected from near the permitted landfill during other
investigations.
A second round of surface water samples will be collected
at eight of the locations sampled during April, 1988. The
purpose of this second sampling round is to confirm results
of the first round and evaluate differences in contaminant
loadings to surface waters during varying flow conditions.
These samples will be collected during a period of wet
weather.
6-1
-------
6.2 METHODOLOGY
Surface water samples were collected by allowing the sample
to flow directly into the sample containers. Volatile
organics samples were collected first and the tops of the
vials were sealed immediately with electrical tape. Care
was taken during water sampling to avoid disturbing the
sediment. The single exception to this procedure was
collection of SW-3, a sample of groundwater seeping through
the banJcs of the Unnamed Tributary. This sample is a
composite of the discharge of two seeps about eight feet
apart. In each case, a core of the stream bank was removed
by driving a decontaminated stainless steel pipe about
fifteen inches into the bank and removing it. Perforated,
decontaminated stainless steel pipes were then inserted
into the void spaces left by the cores to serve as a
conduit for the seepage, which was collected in
decontaminated glass trays and transferred into sample
containers.
Sediment samples were collected using decontaminated
stainless steel scoops or spoons. The sample was
transferred quickly into decontaminated glass or stainless
steel bowls and gently mixed before removing the volatile
organics fraction of the samples. The remaining sample
containers were filled following a more thorough mixing of
the remaining sample.
Surface water sample locations are shown in Figures 6-1 and
6-2 and sediment sample locations are presented in Figures
6-3 and 6-4.
6.3 RESULTS
Results of CLP analysis of surface water samples are
presented in Tables 6-1 and 6-2; sediment sample results
are presented in Tables 6-3 and 6-4.
6.4 DATA ANALYSIS
In the following data analysis, samples were considered
contaminated when any organic compound was detected which
does not occur naturally and which could not be attributed
to sampling or analytical technique. Evaluation of
inorganic compound concentrations was based on comparison
to concentrations detected in background samples. Samples
SW-ll, SD-11.2, SW/SD-12, SW/SD-19, SW/SD-20 and SW/SD-27
were considered background because of their location within
the drainage basin.
6-2
-------
RCACS
STREAMS
STUDY
APEA
80UNCAPY
SW WATER
SAMPLE
LOCATION
REM III
SMITH'S FARM
SURFACE WATER SAMPLE LOCATIONS IN THE
VICINITY OF THE STUDY AREA
C.C.JCHNSON & MALHOTHA.P.C.
-------
/ PERMITTED
LANDRLL
SOURCE ^PROPERTY TAX MAP
DATE
OCT. 1988
REM III
SMITH'S FARM
SURFACE WATER SAMPLE LOCATIONS
OUTSIDE OF THE STUDY AREA
C.C.JOHNSON & M ALHOTR A.P.C.
6-4
-------
ROAOS
STREAMS
STUDY
APEA
BOUNDARY
• SEDIMENT SAMPLE
LOCATIONS
SCALE
0' 200
REM III
SMITH'S FARM
SEDIMENT SAMPLE LOCATIONS IN THE
OATS
OCT. 1988
VICINITY OF THE STUDY AREA
C.C.JOHNSON & MALHOTRA.P.C.
-------
/ PERMITTED
LANDFILL
SOURCE^ PROPERTY TAX MAP
REM III
SMITH'S FARM
SEDIMENT SAMPLE LOCATIONS OUTSIDE
OF THE STUDY AREA
C.C.JCHNSON & M ALHOTS A.P.C.
6-6
-------
TABLE 6-1
.SMITH'S FARM
SURFACE WATKR UAMPLKH — OROAHIC
U IN UG/L
cr>
i
^-4
ONUMHC PARMU.-ICR9
VIIIVL CHLORIDE
CIIIOHE1IIMIE
m.iimfiit: CHLORIDE
»( IfOIIK
1 . 1 DICIILOflOEIIIEHe
I.I DICIILOROEIIIMie
1.2 immOROEIIILIIC
MLIIIVI. C1IIVL HEVTOIIE
I.I. 1 -1BKIIIOWOUHAHE
miciiioHoniiuie
BEllZUIC
HC1IUL l30BUlYt KETONC
TCIH«rilLO«OCfllCNi:
lomtiii:
CHI ONUBCNZCHC
cinvi. enizEiic
IUIAL XVItWLS
1 IILIKJI.
bl:ilZVL ALCOHOL
2 HCIIIVL PIICHOL
1 MID/OH {-METHYL PIIDIOU
i^oi'itoRoiie
1.4 IHNC1MVI.PMCNOL
• IHZOIC tCII)
lUnilllKI.UIC
2 Ml.lim NAPHTIUI.UIE
uuiki'iiiiiriie
IIU)HklllllUIE
ICB 1242
ITB 12)4
ITB 1260
I3U-O)
ISM 04
law -o&
a i ooii
B30J
300UO.I
3200
71
440
«l
40
9.31
101
131
IBW Ob
30.1
:nw 06*
ItlW HI
11
3.1
I!IM UB
I1J
1 .7
I!IW U9
21
i:iw ii
IUM 12
IBW- 11
IUW 14
46
30
16
•
IJ
a
42
1 SM 1 i
ISW 16
II
10
1 UU 17
IJ
i:,w iu
1
1
:sw i«
If.U 20
J - ••IIIMlCll V«|U«
M - »i««iunrl lv« cvldtnc* of rr«««nc« of
li>(*:
l*, Iti
cclli la t«bl« Indlccl* no
-------
TADI.E 6-1 (CONT. )
SMITH'S FAUM
SURFACE WATKR SAMPLES — ORGANIC
UEUIILTS IN UG/L
UHUAHIC PAHAHI.1ER9
IOW 21 ISW-22 ISW 21 I9W 24 ISW 25 I.'IW 26 I»W 27 I!«W 20 1IIW 2V l:,W 21AI!iW JO t'iw
i;;w 12 ::;w I/A::.W
:nw
CT>
1
to
VIIIVL CHI OH IDE
OIIORCIimiE
MI.IIIVI LUC CHLORIDE
ACIIOIIE
I.I HirillOROETllEHE
l.l-DICIII.OHOEIIIAlie
1.2 DICHIOROEIIIUIE
HCTIIVL EIIIVL KEVIOHE
l.l.l-lMICHIOAOEIHAlie
IHICIILOHOtlHCHC
bEUZEIIE
HEIIIVL I90BWTYL KETOME
1 1IRAOII 0«0t IHEJIE
10IIILIIE
CHI ONUBUIZCIIE
EIHVt BniZEIIE
IOIAL xyieiiLs
HIIIK)L
ULHZVI. M.COHOL
2 HEIIIVt PIIEIIOL
J AMD/OH 4 MtriHYL PIIDWL
I sornofluiie
2.4 IIIMEIIULPHDIOI.
BIM2OIC AC 10
IIM'HIIIMEHE
2 HEIIIYIHAPimiALDIE
ACEHAPIiniUIE
rilK)MAMIIIi:ilE
KB 1242
I«B 1234
Kb 1260
1 - «a( l«i«l «d v«ltl*
malai la
1
31
27
2)
3J
3J
9
4J
26J
31
II
11
381
1.1
420.1
281
1/01
9J
no
4)
94
12.1
871
15.1
2J
29
1.1
•III
3.1
II
790
5601
22
440
II
I50U
14
96(1
310
17(10
III
III
III
121
61
»l I
81
2 7
26IIU.II
J 1(10 IH
72.1
2IUO
2700
160
49U
-------
TABLE 6-2
SMITH'S FARM
SURFACE WATER 3AMIM.IXJ — INORGANIC
HESUl.Tii IN Ufi/L
en
i
UD
IHUHUMUC f>»R«HCTCN3
MltUINM
Ml CIMI HIV
AHaflllC
BANIUN
UIHdl.MM
CADMIUM
TALCUM
CIINOHIUM
COUAI.I
COPI'tN
INUII
IKAD
HftlillESIIM
HAIIUAIICSC
HimtlHV
IIICKU.
POIKSSItM
seiEiiiuN
SILVER
SOUMM
IIIAII.IIM
VMIAblllt
21 IIC
CVAIIIDC
3W-03
49
7211
II
190
6JN
4300O
34
33000
laooo
1300
12000
II 0000
SW-04
440
3
36
13000
3200
0200
170
II 000
33000
2OJ
aw -09
2401)
HOB
IOJII
210
IO.IN
28000
I7J
41
24
90000
2OOOO
7500
940O
100000
law 06
2100
9.111
110
3400
I3OOO
1900
250
1000
27000
ISW 06A
230O
10 III
IJO
3300
I40OO
I30O
240
IBOO
27000
ISW O/
9/0
t
06
II 0000
13.1
3600
4300O
1100
4OOOO
I70OOO
IbW 00
J/000
7VUN
ia 111
I90O
2
92.IH
920UO ,
93.1
IOO
140
37OOOO
020H
3/OUO
3000
0.92.IH
36000
13
9OOUO
140
«JU
IBM U9
1 39
II 60.111
30
I2OOO
1400
OOOO
29
2600
OIOO
ISW ||
06001
9IOO
leoo
1 !IW 1 2
IIOOOJ
IBOO
IliW 1 1
aaooj
36OO
2IOO
.
IliW 14
8300J
3300
43
1900
ISW 13
09OOJ
6200
260O
7600
:SW 16
7001
3000
14
2JUO
940O
ISW 17
20
IIOOOJ
6800
2100
l!iW la
IIOOOJ
6700
2100
6100
1 BW 19
1 6OOO 1
6MIO
IHOO
IGW 30
330
1
1
1 00001
7001
7 4I>O
41
2400
R - r«a«nc* at i»*t«rl*l
J - ••llaat*d valu*
Nutai klcok call* In tabU Indicate no datactlon.
-------
TABLE 6-2 (CONT.)
SMITH'H FARM
SURFACE WATER 9AMPI.EU — INORGANIC
HESULTU IN UG/L
IINIROMIIC PARMICItRS 1 SM 21 !9M 22 1 SM 23 t!IU 24 IflW 25 1 RW 26 1 (JM 27 I!IM 26 ItiM 29 IfiM 29A!SW-10 I!1M 31 ISM 32 1 KM )2Ai.SM-tt ISM-M 1 ;;M 15
M.UHIINM
MIBIIIIC
BAR H>H
Bt:R*ll.HM
CMWimi
CMC HIM
CIIROIIIUM
CUBM.I
COITER
IROII
LEAD
HMillESIUM
HRN(IK|IE3C
HEHCURV
NICKEL
POIKS9HM
9CI.CII IUM
3IIWIH
900 HIM
VkllKDIUK
21 IIC
CVMIIDE
IIOOOJ
6500
1900
120003
740O
2500
•500
1 30003
620O
29OO
7600
290
150003
7IOJ
9100
360O
93OO
I500O.I
6303
9300
33OO
9100
I9000J
7IOO
2300
62OO.I
4700
IBOO
41
I700UI
750O
2500
5700
36O
84(103
730.1
54
-------
TABLE 63
SMITH'S FARM
SFDIMFNT HAMIM.ES -- ORGANIC
RFSUI.TH IN UG/K<]
UMUMIIC
IBD-OI iao-04 ISO os iiiii u6 luii O6»i:n> u/ I no us i mi o* tun io i-jit ii i MID ii.jiuu ti inn ii inn 14 :r.u is :su i» IBD I' isn le
vimi nil on IDC
tlllOlmLIIIAHt
ACtKMIC
1.1 nt on ononiiriic
1.1 iiiriiioHuciiiAiic
1.2 DIUIIOHOCIIItllC
riiiiinoroiiii
mnirt cum. ircioiie
1.1.1 iHinii.onocniAiic
mi < in OHOI. i iimc
1.1. a iHKiiiouocniftiic
• IIIZCML
IICIIKI. inoBuni. KCIOIIC
IICIIItL MMVL fcCIOIIC
itiiiMiuoaocniiiic
lUIUIIIC
t in (uiuoni/anc
UIUI. •tlUIIIC
IOIAL ivitnca
2 HtinirL purikri.
> AIIO/CM 4 NCiiiyL ninioL
isui'iionoiiE
2.4 UUICIIUiniUKN.
•IIUOI1- ACID
2 NtllUIIIAFHnUiait
AltllAfllllllMC
01 II BOIVIHIIIIAlArC
IIIHUIZUKIHAII
IIINIflCNC
iiiiuniiooopiiuiot
MMIIAHIIUICIIC
AiiiiinAcnic
II.UUNAIIIIIUIC
rmitiic
niiizvt wirrL niniitkiE
BMIZOUIkllllUlkfUIC
rmivsuic
• 1912 tlll«lllCI«l.irinilAL»lC
DI u ocivmiuiAi.tic
BIMZUIB AIIU/OH KIILINNIAHIimiC
•III^O A PVHIIIC
IHM no < 1.2.) riupvnriic
III til II/OI A. Ill AIIIHIIACI.IIC
UIM/oltilllll'LUiril.llC
r< B inn
U U 1114
u ii i Jta
4400J
IOOOJ
1000
5»OOJ
21001
3400J
JOOOI
14001
.
.
eoooj
2IOJ
I400J
40O
1*1
9*
II 0001
u
14OOOII
2IUUUII
1
2VOOUII
16UUUII
1
mm uiooj
1
L - i ••»!(• cuiilll»t«i lUnh cell* in t«bl« Indicate no detection.
-------
TARI.F. 63 irorrr.)
SMITH'!i I'AUM
SRIH MI-INT .'iAMI'I.KS -- ONGANIC
UK.'HII.IM IN IWi/KG
cr>
i
»• *
INJ
uHiuiiic FAiUMiiina IBO i» ian 20 I9i> ;i INK 22 ::n> it tun 24 1:111 2* I:MI M uui 2; inn 20 IHI> ;• i; n 1:111 ti isu mit>o 11 i
v IIIKI. tMi.uninc
1 III Mllll MIMIC
M IIIMIC
1.1 DKiiiMMCiiifMC
I.I III till Mine MIMIC
1. 2 1)1 rill IMIUCIIIUIC
an mini ui til
Htnm mm. Knoiic
i.i.i IR mil unot MIMIC
im(iiioN/«* HIimuHMIIIIfMC
•III2O K r«HLI>C
iiiiuiiuii.2.) roirvnriic
(IIBIII;OU.IIUIIIIIII>< rue
biii/uioiiiiriiwi mi:
i riB ma
i «•<• i2)4
i no ilia
I30J
2J
21
2J
1101
1*01
•loo 1
4/a.l
4IOJ
171001
lltuol
I/IOOI
15/UUJ
1
IHUOI
lliou.l
1
1
1 i«no 1
1 1 (Oil 1
1 1 IIMI i
I »v>t
Ilklllll
1
1
1
21
•9J
*4J
SU
;u
2OOI
I20UI
• lu.l
4IUI
42UI
.
«eui
1 Illl
1*111
JIUI
ti
»J
1701
tl.l
1IOJ
2MI
2*OJ
3700
7»OI
4IOUI
2IIUO.I
1 700 1
IlkUUI
2)001
a loi
4101
2)01
•>»ui
IJ
11*1
/Bl
41J
Ml
tool
• /J
JIOI
nei
1 toi
1*01
• II
31
2/OJ
••J
13OI
_
lion
4J
240.1
500.1
1500
3.1
1.1
•J
4IIO
1 I.I
«l
21
•J
220
II
1 HI
5/U
*40
1401
2400
22IIO
1100
JVOOO
>On
2J
uo
4J
1
110 1
1
12001 1
'I 1
111 1
1)00 1
1
14(101 1
20 1
S/OI »
M 1
M 1
18001 1
• 1 1
l« 1
24UO 1
1
IIUO 1
jMnia i
II 01 1
4 III 1 1
1
4&I 1
1
eio i
1 101 1
i
i
i
i
i
i
i
i
i
i
I
i
i
I
i
i
i
i
i
i
i
1100 1
-------
TABLE 6-4
SMITH'S FARM
SEDIMENT SAMPLES — INORGANIC
RESULTS IN MO/KG
CT>
1
t— «
CO
IHOROANIC PARAHLTER9 180-03 180-04 ISO OS 180 06 I8I> O6AI8D O7 IHII-IIB IHO 09 I9U-IO ISII-1 1 . 1 191) 1 1 . 2ISI) -12 190-13 IBD-M ISO 13 IBD 16 ISO 17 !90 IB
kl.lMIIIIM I7700J II 1000.11 10000.11 13000.11 140OO.II 1 300O.II95OO.I I90OOJ I74OO.I IIOOOOJ II 1000 J I9300J
Ml II HUH Y 1 03H 1 SIR
AH5FIIIC I3.7JM I5.IJII
BARIIIH
BI:R>I.I.I«H
CADHHM
CMC 11*4
CIIHOMHM
COBM.r
COPPER
IRON
IEAO
MAUIIE9HM
HAIIUAIILSe
MtHCUfly
IIICKEL
POIAS9MM
9EIEHIUH
911 VER
soo HIM
IHAIMUM
VAIIAUIIM
ZIMC
CHAIIIDC
9]
3.3JN
iaoo
26J
I»J
14
41000
3000
2SOJ
I300J
1*0
24
90
7J
4.4JH
1200
28J
ISJ
14
2BOOO
3900
310.1
I400J
26
110
B9H 1 II2R 1 94H 1 I20R 1 1 IOR
4111 19 0)11 15.5111 16.7111 14. 6 Jll
47
4.2JH
34J
I7J
13
34000
3BOO
230J
I40OJ
730
23
110
270
6 . 2 Jll
750
3BJ
I3J
16
37000
4IOJ
3500
230J
IBOOJ
31
160
200
4.3JH
660
35J
I3J
14
27OOO
240.1
3600
I9OJ
2200J
32
130
210
6.3JN
IBOO
30J
22J
21
47000
3100
370J
1500.1
3)0
39
140
61
3.IN
2IOO
12.1
I2J
13
3400O
2900
340J
I600J
230
23
as
B5R 1 B2H
II Jll IB. 2 Jll
61
4. UN
670
I2J
26J
• .7
20000
3600
I60OJ
IIOOJ
22
90
210
4.3.IM
040
14.1
141
B. 3
29000
20OO
140.1
730J
220
21
no
B5R
3. 2 III
55
4.IN
70O
I7J
I6J
7.7
3OOOO
2300
330J
1300.1
32
93
77J
1 600.1
I6J
270OOJ
I4J
2600.1
620.1
21
IBOOJ
26
72.1
BJH
781
IIOOJ
ISJ
17
2BOOOJ
I4J
2400J
• 90J
26
I500J
22
6IJ
1 1 ooo j 1 1 2000 j : 1 1 000.1 1 1 1 ooo ,1 1 1 1000.1 1 1 3000.1
i
7.2JN IB.7.IN
64
1 200.1
I4J
16
3IOOOJ
I6J
3200.1
390.1
23
I6OO.I
23
100.1
6IJ
IBJ
30000J
19.1
33001
460J
1*
2200J
23
BOJ
;
21.111
120.1
12001
20J
17
45000J
321
29001
790J
76
2000J
2B
1001
13.111
95.1
1400.1
I7J
20
29000J
16.1
33001
I500.J
32
20001
20
1301
32.111
120.1
3IJ
25
7BOOOJ
170.1
3600.1
9t>UI
43
22011 1
32
2201
36JN 1
1301 :
i
1
23000.1 1
331 ;
28
110000.1
IBOI
130001
12001
37
22001
;
I.4J :
:
i
16 i
3801 :
! ;
J - ••(l«*l«d value .
II - pi dumpily* evidence of precede* of Beterlel
R - data not leileble
NJtet lleok cell* In table Indicate1 no detection.
-------
TABLE 6-4 (CONT.)
SMITH'S FAKM
SEDIMENT SAMPLES — INORGANIC
RESULTS IN MG/KG
IHOROAHIC PARAMETERS ISO 19 ISO 20 ISU-21 IBIt 21 IHI) 23 I8U 24 ISO 25 ISO 26 Kill 27 ISO 28 IHU 29 IMO 29AIBO 3O 100 31 I!IU 32 Itill 32A!!:ii 33
AUMIMIM 1 1 1 OOOJ 1 1 2OOOJ 1 1 SOOOJ 1 1 3OOO.1 1 1 3OIIOJ 1 1 2OOOJ 1 1 4OOO./I 1 SdOO.I 1 1 IIHIO.1 1 1 2OOO.I 1 1 4OOOJ 1 1 IOOU.1 1 1 UOOOJ 1 1 3OOOJ 1 1 7OOU.1 1 1 6OOO.I i 1 1 4IUO.I
AHUNGIIV
AHSEIIIC
BARIUM
BIN til MM
CAUNIUN
CM CUM
CIIROHHM
COBM r
COPPER
IRON
LEAD
MAGNESIUM
MANUAIieSE
HCHCUHV
MICK EL
POIAS3IIM
SEIEIIIUH
SILVER
BODIUH
1IIAI.I.IUM
VANADIUM
ZIIIC
C«ANIDE
3.3J
HIM
34J
I7J
18
37000J
I4J
3400J
970J
23
2000J
21
97J
I8JH
33J
6IOOJ
I9J
21
3 2000 J
I6J
6200
IOOOJ
29
I900J
I.9J
26
IIOJ
33 IH
76J
•
39J
26
74000J
29J
4300.1
IIOOJ
47
2600J
1.6J
36
170.1
1
I6.IH 1 43 JN
99J 1 100.1
1
1
13000)1 130OOI
27.1 1 23J
20 1 22
1
69000.1 16 2000 J
44.1 1 IIOJ
9900.1 II 11)00 1
710.1 1 8/OJ
1
48 1 37
3KIO 12300.1
1
1
1
1
23 1 27
240.1 1 260.1
1
I9.IN
BOJ
34OOJ
221
24
86000.1
72J
3400J
aio.i
99
2300J
31
iao.1
i
I6IM IB.2JII
I20J
4IOOJ
33J
311
97000
26.1
49OO.I
I300J
110
2800.1
1.6.1
43
170.1
2300J
2 J.I
21
31000.1
9.3.1
630O.I
4IOJ
66
4300J
26
90.1
I2.IH
69.1
12001
IBI
240001
Ml
3OOIII
4101
24
2100.1
23
83.1
17.111
60.1
44OO.I
IBI
13
340001
131
4UOOI
5701
37
23001
27
92J
1
6.3.IH 1 I2JN
4JO.I 1 IIOOJ
|
1
IBOOJ II600J
3IJ 1 3/J
2) 1 23
|
3 2000 J 131 001
I30J 1 IBOI
36001 133001
1300.1 II 600.1
1
28 1 27
2600.1 II 8001
1
1
1
1
26 1 21
II O.I 1 100.1
1
I4JN
79J
I200J
13.1
19
23000J
241
3100.1
740J
27
1700.1
19
81)
17. IN
23UOJ
2IOOJ
120.1
28
36 OOOJ
99OJ
41001
3IOJ
42
2700.1
23
140.1
83J
23J
27000.1
3IJ
4BOO.I
260.1
29
3400J
29
HOI
73J
22J
23000.1
2UI
43001
2 •!!)!
26
2900.1
23
94.1
93.1
I7J
laonoi
47.1
IBOO
200J
18
1300.1
72.1
J - •stlnatcil v«lu«
H - ?i**umptlv« *v|d*nc« of Fl«a»nc« at natcrlal
N - dtta not i*IUbl*
-------
ATTACHMENT 7.3.2
REMEDIAL DESIGN INVESTIGATION
DATA SUMMARIES
-------
c —
D -
0 —
AREA B
90UNDAPY
(45 SHOWN
IN FS)
OPERABLE UNIT
ONE STUDT
BOUNDARY
L'N'G LOCATION
SCD-y£NT SAMSLI'.'G LOCATION
GCOTEC"Ni:A!. SOWING LOCATION
H (DCS'CNATES SURFACt SOIL BORING)
B (OJSIGNATCS BOWNC INTO BEDROCK)
P (OtSSMATES 'EST PIT)
AST A 50UNDARY "
' ' TRANSMISSON LINE
r=!Cw C.C JOHNSON & UALHO'SA. P.c.
LIW^S OF AȣA
1C SE CAPPED
SMITH'S
-------
TABLE 2-1
RESULTS OF CHEMICAL ANALYSES ON SOIL SAMPLES
REMEDIAL ACTION - SMITH'S FARM
OPERABLE UNIT ONE
BULLITT COUNTY, KENTUCKY
Sample
Location
A-S
A-6
B-4
B-4D
B-5
B-6
B-7
C-2
C-3
C-4
C-5
C-6
C-8
D-2
D-3
D-4
D-5
D-6
D-7
D-8
E-l
E-2
E-3
E-3D
E-4
E-5
E~6
E-7
Sample Total Lead
Depth PCBs
(ft) fmc/kc) fmc/kc)
0-1
3-5
0-1
3-5
0-1
0-1
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
0-1
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
0-1
0-1
3-5
0-1
3-5
0-1
0-1
3-5
0-1
3-5
0-1
0-1
0-1
3-5
0-1
0-1
0-1
3-5
ND
ND
ND
ND
ND
ND
37.0
56.8
3.2
ND
ND
ND
ND
ND
ND
6.6
6.7
7.6
45.0
ND
ND '
ND
ND
0.1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.1
0.3
10.6
7.1
17.0
13.2
10.2
40.3
25.8
8.4
35.5
10.7
10.0
12.1
5.9
9.8
.' 14.3
47.5
: 9.5
. 26.1
65.0
: 16.1
9.8
14.9
10.2
12.9
10.8
11.9
25.4
9.7
12.9
10.0
11.5
6.9
8.1
7.9
7.9
14.6
15.3
93
9.8
10.0
6.8
13.4
11.0
Sample
Location
E-8
E-9
F-l
F-2
F-3
F-4
F-5
F-6
F-6D
F-7
F-7D
F-8
F-9
F-10
G-l
G-2
G-3
G-4
G-5
G-7
G-7 (Pens)
G-8
G-9
G-10
H-3
H-4
H-5
Sample Total Lead
Depth PCBs
(ft) (me/kg) (mt/krt
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
3-5
0-1
3-5
0-1
0-1
0-1
0-1
0-1
3-5
0-1
3-5
0-1
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
0-1
0-1
3-5
0-1
0-1
3-5
0-1
3-5
0-1
0-1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.0
0.4
1.4
0.2
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.6
16
ND
ND
ND
ND
ND
ND
ND
ND
ND
14.2
7.4
12.4
9.5
9.8
7.7
10.0
18.6
9.2
10.5
9.8
11.0
9.2
15.9
18.8
11.9
13.0
20.3
162.0
41.1
147.0
25.5
8.0
11.3
9.9
9.4
9.2
7.1
9.1
9.5
5.9
157.0
245.0
11.1
59.0
257.0
10.4
7.7
8.9
13.4
14.8
46.6
-------
TABLE 2-1
RESULTS OF CHEMICAL ANALYSES ON SOIL SAMPLES
REMEDIAL ACTION - SMITH'S FARM
OPERABLE UNIT ONE
BULLITT COUNTY, KENTUCKY
Sample
Location
H-9
H-10
H-ll
1-3
1-4
MO
Ml
J-10
Ml
K-10
K-ll
K-12
L-10
L-ll
L-12
M-10
M-ll
M-12
M-13
N-8
N-9
N-10
N-ll
0-8
O-9
O-10
0-11
Sample Total Lead
Depth PCBs
ffrt rme/ke) fme/ke)
0-1
0-1
0-1
3-5
0-1
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
0-1
3-5
0-1
0-1
0-1
0-1
0-1
3-5
0-1
0-1
0-1
3-5
0-1
3-5
ND
0.2
ND
ND
ND
ND
ND
0.3
ND
ND
ND
0.5
ND
ND
ND
ND
1.1
ND
1.1
0.5
30.0
ND
2.7
ND
ND
ND
20.0
ND
03
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.7
ND
200.0
8.9
10.3
7.4
15.3
11.4
8.8
23.4
8.0
14.8
13.7
35.5
16.8
12.5
93.1
10.1
71.2
13.8
62.4
10.6
53.9
7.1
23.3
12.7
27.5
10.4
54.6
16.7
15.2
14.5
75.9
37.4
11.9
9630.0
16.3
14.5
23.4
7.9
8.5
8.6
230.0
18.4
Sample
Location
AS-2
AS-3
AS-3D
AS-4
AS-5
AS-6
AS-6D
AS-7
AS-8
AS-9
AS-9D
AS- 10
AS- 11
AS-12
AS- 13
AS-14
AS-14D
AS-21
AS-22
AS-23
AS-23D
Sample Total Lead
Depth PCBs
ffO fme/ke) (me/kt^
0-1
3-5
0-1
0-1
0-1
0-1
0-1
3-5
0-1
0-1
3-5
0-1
0-1
3-5
3-5
0-1
0-1
0-1
0-1
0-1
0-1
0-1
3-5
0-1
0-1
0-1
6.1
0.2
222.0
195.0
150.0
0.4
3.6
ND
2.9
ND
ND
11.0
0.4
1.5
1.9
0.3
0.1
ND
ND
ND
ND
ND
ND
ND
ND
14.6
7.0
185.0
163.0
87.8
25.3
- 11.5
8.6
14.3
11.9
9.4
56.6
13.6
13.4
20.1
12.6
8.8
11.1
7.6
8.8
10.3
17.9
15.5
14.6
1580.0
NDI 474.0
-------
TABLE 2-2
RESULTS OF CHEMICAL ANALYSIS ON SEDIMENT SAMPLE
REMEDIAL DESIGN - SMITH'S FARM
OPERABLE UNIT ONE
BULLITT COUNTY, KENTUCKY
Sample
Location
Sample Total Total
Depth PCBs PAHs
fme/ke^ Cme/ke^
SS-1A
SS-1AD
SS-2
SS-3
SS-4
SS-5
SS-6
AS-1
AS-15
AS-16
AS-17
AS-18
AS-18D
AS-19
AS-20
0-1
0-1
3-5
0-1
3-5
0-1
3-5
0-1
3-5
0-1
0-1
0-1
8.9
5.5
ND
1.21
1.02
1.02
0.57
ND
0.88
ND
15.3
4.4
0.92
ND
0.68
18.7
0.085
ND
0.080
0.25
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.247
ND
0.038
ND
3.1
ND
ND
ND
-------
ATTACHMENT 7.4
TREATABILITY TEST INFORMATION
-------
ATTACHMENT 7.4 . 1
SUMMARY OF THERMAL DESTRUCTION AND
SOLIDIFICATION/FIXATION
TREATABILITY STUDIES
-------
3.0 REMEDIAL DESIGN
3.1 THERMAL DESTRUCTION AND SOLIDIFICATION/FIXATION
The design criteria for this component of the RA is based on the remediation goals
presented in the ROD. The extent of the area to be treated has been determined as
described in Section 2.2.1. Those limits and the treatment areas for thermal destruction and
solidification/fixation (S/F) are shown on Sheet 6 of the Preliminary Design Drawings.
Within Area B, soils and sediments with constituents above action levels will be excavated
in phases and stockpiled (three-day supply) for treatment on-site. The stockpile will feed
a mobile thermal destruction unit (incinerator). Residuals from the incinerator (ash) will
be placed daily in individual stockpiles or bins that will be sampled and tested for
compliance with the action levels for PCB, PAH and lead. Five daily ash stockpiles will be
maintained in order to allow response time for representative sampling and analysis for the
above constituents. Lead found in the ash above the action levels will be immobilized by
solidification/fixation.
Due to the steepness of the slopes in Area B, considerable construction difficulties are
anticipated if material were to be replaced on those slopes. Therefore, the ash with lead
concentrations below action levels and solidified/fixated material will be consolidated within
the capped area.
The required efficiency standards for hazardous waste incinerators are set forth in 40 CFR
Pans 264, 270, and 761. These regulations specify three major requirements regarding
incinerator performance:
Smith's Farm - Preliminary Design 40 November 7, 1990
-------
99.99 % destruction removal efficiency (DRE) of designated Principal Organic
Hazardous Constituents (POHCs) and 99.9999% DRE for PCBs
0.08 grams per dry standard cubic foot (gm/DSCF) of paniculate emission
corrected to seven percent oxygen
Four pounds per hour of hydrogen chloride emission or a 99% removal
efficiency
As part of the RD Work Plan, a thermal treatability study was performed. The objective
of the thermal treatability study was to determine the most feasible thermal treatment
alternative for soil and sediment with PCB and PAH concentrations above the action levels
set by the ROD of two ppm and five ppm, respectively. The tasks associated with this
objective were as follows:
Determine the DRE standards
Determine a list of POHCs
Develop incinerator performance standards
Section 3.1.1 discusses the results of the thermal treatability study. A detailed report of the
study, as well as the recommended incineration systems, is included as Attachment 1. Sheet
8 of the Preliminary Design Drawings outlines the four recommended treatment systems.
Once the soils and sediments with constituents above action levels are combusted, the ash
will be tested to determine if further treatment of the ash is required. For design purposes,
it was estimated that approximately 50% of the ash from the incineration will require
further treatment by S/F.
Smith's Farm - Preliminary Design 41 November 7, 1990
-------
As part of the design of the S/F treatment system, a treatability study was conducted. S/F
treatability studies generally are conducted to evaluate the most feasible S/F treatment for
the waste of interest. The purpose of the S/F treatability study at the Smith's Farm Site was
to demonstrate the feasibility of S/F treatment for the residual ash from the incineration
of soils and sediments containing greater than 500 ppm total lead. The study was conducted
to determine the following:
Initial selection of solidification reagent or reagent mixture
Initial setting time and estimated rate of gain of strength
Leachabiliry of lead after S/F
Unconfined compressive strength (UCS) of solidified ash
Workability of proposed mixture
Section 3.1.2 discusses the results of the S/F treatability study. A detailed description of the
treatability study is included as Attachment 1.
3.1.1 Summary of Thermal Treatability Study
Three waste samples were collected for thermal treatability and S/F testing. Of these
samples, two were used for the thermal treatability study conducted in a muffle furnace at
the Chemical Waste Management, Inc. (Chem-Waste) facility in Riverdale, Illinois for
thermal treatability. The ash from one of these samples was then used for S/F testing. The
third sample was incinerated with the same methodology used in the thermal treatability
testing, and then S/F testing was performed.
Smith's Farm - Preliminary Design 42 November 7, 1990
-------
Thermal treatability testing was not able to demonstrate that the waste at the Smith's Farm
Site could be thermally treated to a DRE for PCBs of 99.9999%. This was due to the low
action level constituents in the soils and sediments (a maximum of 53 ppm) as discussed in
Section 2.2.1 and the analytical detection limitation (<0.05ppm).
PAHs and POHCs were not found in the soil and sediment samples taken for testing above
the analytical detection limit, 0.33 ppm. This detection level is well below the required
action level of five ppm for PAHs. A list of PAHs analyzed for in the samples is given in
Table 3-1. Since PAHs and POHCs were not detected above detection limits, a POHC of
significant concentration could not be selected nor could a list of potential POHCs be
determined or a DRE be determined for the POHCs. The guideline for concentration of
a POHC to be significant is 100 ppm.
Due to the limited concentrations of PCBs, PAHs, and lead in the soil-and sediment
samples from the Smith's Farm Site, limited information on incineration guidelines was
obtained from the thermal treatability testing. However, information on the required
primary combustion chamber temperature was obtained. An operating temperature in the
primary combustion chamber of approximately 1300-1800°F should be sufficient to destruct
the organic material. The addition of a secondary combustion chamber will decrease the
emission of organics from the incinerator. This information, along with the waste
characteristics in Section 2.2.1 a refined estimate of the amount of waste to be incinerated,
the emission limitations per 40 CFR Subparts 264 and 270, the desired time of incineration
Smith's Farm - Preliminary Design 43 November 7, 1990
-------
TABLE 3-1
POLYNUCLEAR AROMATIC HYDROCARBONS
FOR WHICH ANALYSES WERE CONDUCTED
SMITH'S FARM SITE - OPERABLE UNIT ONE STUDY AREA
BULLITT COUNTY, KENTUCKY
Acenaphtbene
Acenaphthylene
Anthracene
Benzo(a)amhracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
2-Chloronaphthalene
Chrysene
Dibenzofuran
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(l,2,3-cd)pyrene
2-MethylnaphthaJene
Naphthalene
Phenanthrene
Pyrene
Smith's Farm - Preliminary Design 44 November 7, 1990
-------
(less than nine months), the ability to utilize either a rotary kiln, a fluidized bed or an
infrared mobile incineration system and the incineration performance specification should
provide sufficient guidance for the selection of an incinerator.
The selected incineration contractor will be required to develop a plan (commonly referred
to as the trial burn plan) to test the incineration equipment using the Smith's Farm Site
material. The trial burn would demonstrate whether the incinerator is capable of meeting
regulatory requirements.
3.12 Summary of Solidification/Fixation Treatability Study
Total analyses for PCBs, PAHs and lead were conducted on the three samples of ash from
the thermal destruction treatabiliry study. In addition, Toxicity Characteristic Leaching
Procedure (TCLP) analyses were conducted to indicate the amount of lead potentially
leaching. The results of these analyses, listed on Table 3-2, indicate that lead is not leaching
using TCLP at a concentration above the TCLP characteristic concentration of five
milligrams per liter (mg/1). As such, S/F treatability studies were conducted to address the
strength of the solidified ash only.
To address the strength of the solidified ash and to estimate qualitatively the initial setting
strength, an ash sample from soil sample CB6X was mixed with portland cement at an ash-
to-cement-to-water ratio of 1:0.65:0.25. The mixture set quickly; initial strength estimates
(after 24 hours) using a pocket penetrometer indicated strengths of greater than 55 pounds
per square inch (psi). The UCS of the solidified ash sample CB6X using ASTM Method
D 2166 was 152 psi.
Smith's Farm - Preliminary Design 45 November 7, 1990
-------
TABLE 3-2
RESULTS OF TOTALS AND TCLP ANALYSES ON ASH
SMITH'S FARM SITE - OPERABLE UNIT ONE
BULLITT COUNTY, KENTUCKY
CONSTITUENT UNITS
Aroclor 1248 mg/kg
Aroclor 1260 mg/kg
PAHs (3) mg/kg
Lead mg/kg
TCLP Lead mgl
CB6X (1) i C635X(1) i SL-32
Ash 1 Ash 2 1 Ash 1 Ash 2 i Ash
<5(2) <5
<5(2) <5
<0.33 <0.33
78 68
<0.15 <0.15
<5 <5
<5 <5
<0.33 <0.33
46 48
<0.15 <0.15
...
<0.20
56
0.11
NOTES: (1) Two samples of ash were analyzed
(2) Reanalysis by more sensitive method indicates concentrations below
analytical detection limits (O.OS mg/kg)
(3) Concentrations of PAHs were below analytical detection limit
(0.33 mg/kg for samples CB6X and CB635X, 0.20 mg/kg for sample SL-32)
-------
A S/F treatability study was conducted on a second ash sample from soil sample SL-32.
Though lead was detected in the TCLP extract (Table 3-2) the concentration was below the
TCLP characteristic concentration of five mg/1. Thus the treatability study was conducted
to address the strength of the solidified ash. Ash from sample SL-32 was mixed with a more
economical reagent, cement kiln dust, in an ash-to-reagent-to-water ratio of 1.0:0.65:0.25.
The mixture hardened within 24 hours. The UCS of the solidified ash after three days of
curing was 108 psi.
Although using portland cement or cement kiln dust at the 1:0.65:0.25 mix ratio does not
necessarily represent the optimum or most economical mix, these rough cuts did indicate
that attaining the required strength was possible within the specified three-day cure time.
However, as mentioned previously, because the concentrations of lead in the TCLP extract
of the untreated ash were near or below detection limits, there was not a basis of
comparison for evaluating the mobility of lead. As such, the effectiveness of this particular
mix ratio in reducing the mobility of lead was not evaluated.
It should be noted that the concentrations of lead in the soil samples from Area B were
below action levels. In addition, though lead was detected in the ash, lead was not detected
in the TCLP extract in two ash samples. Due to the low concentration of leachable lead in
the soil and corresponding ash, the methodology of treatment of the soils and sediments will
be re-evaluated during the Intermediate Design. This re-evaluation will be conducted in
. conjunction with the evaluation of treatment methodologies for PCBs and PAHs as
discussed in Section 3.1.1. As the concentrations of lead are below action levels and due
Smith's Farm - Preliminary Design 47 November 7, 1990
-------
to the low teachability of lead at the site, the need for fixation of the lead will also be
evaluated. Thus, a detailed design of a S/F treatment system for the incinerator ash at the
Smith's Farm Site was not completed. A more detailed design for S/F treatment may be
addressed upon evaluation of the ash from the trial bum if lead is present in the ash at
concentrations high enough to warrant S/F.
3.1-3 Thermal Destruction and Solidification/Fixation Design Parameters
The following items, as a minimum, will be addressed during the Intermediate and Final
Design phases of the incineration and the S/F treatment systems:
Incinerator
1. Incineration of soils and sediments exceeding action levels (preliminary design
estimate: 16,000 cy)
2. Operational parameters for the incineration including scenarios or conditions
for cessation of incineration
3. Incinerator trial burn to define the operating conditions of the incinerator and
the air pollution control equipment (including primary and secondary
combustion temperatures and residence times)
4. Waste limitations (i.e., chlorine content in the soil and sediments, waste feed
rates, heavy metal feed rates)
5. Emission rates of stack gases such as hydrochloric acid, carbon monoxide,
total hydrocarbons, carbon dioxide, sulfur dioxide and oxygen
6. Air pollution control system design, limitations and operating criteria
7. Required monitoring system and testing criteria
Smith's Farm - Preliminary Design 48 November 7, 1990
-------
8. Destruction of 99.99% of the POHCs and 99.9999% of the PCBs
9. Material handling and excavation of soil to load stockpile soil and remove
incinerated ash
10. Record-keeping and reporting of emissions
11. Operating schedule
Solidification/Fixation
1. Solidification of ash exceeding action levels (preliminary design estimate:
8,000 cy)
2. Verification of feasibility of 1:0.65:0.25 ash-to-reagent-to-water ratio
3. . Attain a UCS strength of 18 psi
4. Concentration of lead in TCLP extract of solidified ash to be less than 5
milligrams per liter
5. Schedule of mixing that allows for three days of curing and subsequent
analysis
6. Material handling system to load stockpiled ash and dispose of solidified ash
3.1.4 Alternative Treatment Technologies
The methodology for the treatment of soils and sediments from Area B will be re-evaluated
during the Intermediate Design phase. The reasons for this are:
Preliminary results of LAW's sampling and analysis indicate relatively low
levels of PCBs, PAHs and lead in the soils and sediments.
Smith's Farm - Preliminary Design 49 November 7, 1990
-------
The requirement for thermal treatment of soils containing PCBs to a DRE of
99.9999% cannot be demonstrated at this time.
The volume of soils and sediments to be treated is likely to be significantly
less than the volume estimated in the FS.
Other forms of treatment will therefore be evaluated. Potentially applicable treatment
alternatives have been identified as:
Chemical Treatment - a chemical process would involve chemically reacting
action level constituents, and ultimate removal of action level constituents to
below action levels.
Biological Treatment - a biological process would involve the biodegradation
of action level constituents to below action levels.
Solidification/Fixation - action level constituents would be immobilized using
a conventional solidification/fixation process.
32 RCRA CAP
The purpose of the RCRA cap is to (1) control infiltration of rainwater, (2) divert surface
water and (3) provide suitable soil in which to develop vegetation. The separation of
rainwater and surface water from the area acts to reduce the production of leachate, while
the vegetative cover serves to control erosion.
Smith's Farm - Preliminary Design 50 November 7, 1990
-------
ATTACHMENT 7.4.2
SUMMARY OF APEG DECHLORINATION
TREATABILITY STUDIES
-------
GRC
j*~cmifncm. inc.
July 25, 1991
GRC Environmental, Inc.
Final Report
Treatability Study for the
Smith's Farm Super-fund Site
Presented to:
Law Environment*!. Inc.
Kennesaw. Georgia
-------
TAPI -fi Of f^WTF^TS
Executive Summary 1
Introduction 2
Preparation of the Sample 2
Preliminary Analysis 2
Treatment Reactions 4
Evaluation 6
In-House PCB Analysis of Exit Fractions 6
Mass Balance and Reagent Recovery 8
Analysis from Outside Laboratories 10
Waste Disposal 10
Summary 10
Appendix 1. Methods Used
Appendix 2. Mass Balance Sheets
Appendix 3. Outside Laboratory Results
Appendix 4. Cost Estimate for Pilot- and Full-Scale Remediation
Appendix 5. GRC QA Report
-------
FINAL REPORT
APEG-PLUS™ TREAT ABILITY STIJDY
FOR THE SMITH'S FARM SUPERFUND SITE
July 25. 1991
Executive Summary
GRC Environmental, Inc. (GRC), was successful in treating a contaminated soil sample
from the Smith's Farm Superfund site in Kentucky using APEG-PLUS™
dechlorination treatment. The 2 ppm PCB action level for the soil matrix was reached
within four hours of treatment with less than GRC's standard reagent loading. PCBs
found in the exit fractions were below the action level with the exception of the
condensate. Discussion of the condensate includes relatively simple solutions.
Reaction 1 reduced the PCB concentration to below the action level in only two hours.
suggesting that an optimized reaction with only 60% loading would be beneficial.
Reaction 2 at the reduced reagent loading reached the action level in four hours.
Thus, Reaction 2 conditions indicate that larger scale treatment costs could be
reduced substantially by using less of the reagent mixture required per cubic yard of
soil to be treated. Also, more soil per batch could be treated (less reagent volume).
thereby reducing the treatment time for the overall remediation costs.
CRC Environmental, Inc. I ROM 17
-------
Introduction
GRC has completed a treatability study on a soil sample from the Smith's Farm
Superfund site in Kentucky to determine the effectiveness of GRCs APEG-PLUS"™*
chemical dechlorination process in treating the contaminated soil. This repon
constitutes final results for the treatability study performed on Smith's Farm soil
matrix. The study demonstrated that dechlorination was successful in reducing PCB
concentrations to below the 2 part per million (ppm) action level in less than four
hours. The results of quality assurance analyses conducted by Versar Laboratories,
an independent lab. are included as Appendix 3.
Preparation of the Sample
Law. the prime contractor for the Smith's Farm site, delivered eight jars of PCB-
contaminated soil from the site on April 19. 1991. to the GRC laboratory located at Joy
Road in East Syracuse. New York. The sample was considered representative of the
site; GRC was instructed to use four of the jars (from sample area AS-3) for the actual
treatability study testing. GRC personnel passed the soil through a screen with
quarter-inch openings to remove pebbles and sticks and collected the soil in a metal
pan. All work with this material was conducted under a fume hood by personnel
wearing appropriate gloves.
Preliminary Analysis
To make certain that a homogeneous sample for preliminary analysts was used, one
aliquot (cored sample of approximately 60 grams) was taken from each of the four
jars to be treated. After passing the soil through a quarter-inch screen (reported as
the per cent oversized material), the soil sample was analyzed for PCBs using GRC's
usual method (see Appendix 1). The "as received" soil was measured for the
percentage (by weight) of moisture and also screened to provide panicle size
distribution (PSD) information. Another necessary preliminary analysis was to test
the Smith's Farm soil's capacity to absorb potassium hydroxide (KOH). referred to as
the KOH absorption capacity. An amount of KOH in excess of that consumed by the
soil must be present during a reaction to assure successful dechlorination of the
contaminant. The data generated in this portion of the treatability study are
summarized in Tables 1 and 2.
CRC Environmental. Inc. 2 R00017
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Tiblfi 1
Preliminary Analysis nf Smith's Farm
PCB concentration, ppm*
Per cent oversize (over 0.25 inch)
KOH absorption capacity, mg/g*
Per cent moisture*
= Average value of multiple determinations.
37
4.7
100
16
Screen Panicle Size Distribution
Sieve Size
Drv Screened
Wet Screened
Sieve Number
1/4-
#18
#35
#60
#140
#300
(irt i Hi meters)
6.35
1.00
0.50
0.25
0.11
0.05
Per Cent Passing
95.3
58.9
41.3
28.3
17.2
12.4
Per Cent Passing
100.0
83.9
80.3
74.6
73.2
63.8
The purpose of both a dry screen and wet screen panicle size distribution was to
provide information for materials handling equipment in larger scale operations.
As-received material fed into the process would behave most similarly to the panicles
described in the dry screen analysis. However, under reaction conditions and
subsequent processing steps, the matrix would behave more like those panicles
described in the wet screen analysis. Note that the fraction over a quaner inch in
size is not applicable for reaction conditions because it was removed from the feed as
oversized material.
The substantial difference between the dry and wet screened material finer than
#300 (or 0.05 millimeters) can have a significant impact on larger scale processing.
From the panicle size distribution (PSD) information in Table 2. approximately 50 per
cent more material will behave as finer than 0.05 millimeters after being loaded into
CRC Environmeraal. Inc.
R00017
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the system and wetted with retgents. This type of behavior would be expected of a
clay-like matrix.
A representative ponton of the feed (finer than a quarter inch in size) to the APEG-
PLUS™ process was sent out for confirmation USEPA Contract Laboratory Protocol
(CLP) analysis to Versar Laboratories, Inc., Springfield, Virginia. CLP analysis is
discussed in the section titled Analysis from Outside Laboratories later in this report.
Treatment Reactions
Two reactions following GRC's standard protocol, which is described briefly below (a
full description of the protocol is detailed in Appendix 1) were performed on
representative portions of the Smith's Farm sample from site AS-3. These portions
also had the oversized (greater than quarter inch) material removed. The APEG-
PLUS™ process uses polyethylene glycol (PEG), triethylene glycol methyl ether and
higher homologs (TMH), dimethyl sulfoxide (DMSO), and potassium hydroxide in a
45% solution by weight (45% KOH) as reagents. Each reaction was run at 150°C for 7
hours starting when heat was first applied.
Reaction 1 of the soil used the standard 100% reagent loading for a 500-gram charge
of input soil. A 100% reagent loading for 500 grams of soil would include a total of 500
grams of reagent in the ratio of 1:1:2:2 for PEG:TMH:DMSO:45% KOH. respectively. The
second reaction incorporated 60% loading of reagents for a standard 500 grams of
soil. The materials loaded into the reactor for both reactions are listed in Table 3.
Table 3. Reaction Innut Quantities
Reaction
Grams of as-received soil
Grams of PEG
Grams of TMH
Grams of DMSO
Grams of 45% KOH
Total grams of reagents
* 1
500.2
84.3
89.8
166.9
167.2
508.2
#2
508.7
59.4
59.7
100.6
101.2
320.9
GRC Environmental. Inc. 4 R00017
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Prior to aniJysis. i recovery surrogate is idded to each sample for quality assurance
(QA) purposes. Decacblorobiphenyl (DCB) recovery surrogate is used for PCB
analysis and the amount recovered is expressed as a percentage (%R). GRCs standard
reaction protocol includes monitoring the progress of dechlorination by taking
samples every hour and analyzing the samples for the targe: contaminant as we
proceed (in real time).
For both reactions, the total ppm concentration of PCBs found in each monitoring
sample along with the per cent surrogate recovery is included in Table 4. These data
indicate that both reactions were successful in reaching the 2 ppm action level in a
relatively short period of time.
Table 4 Reaction Monitoring Data
Reaction 1 Reaction 2
Hour
0
1
2
3
4
5
6
7
Treated Soil
Soil Dup.
ppm PCB
35
3.0
1.1
<1J
<1.1
<1.7
•tf.8
<\2
<17
<2.Q
DCB%R
101
67
92
97
98
85
88
94
101
99
ppm PCB
35
18
8.0
2.5
1.7
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Figure 1. PCB Concentration vi Time for Reactions 1_ ind 2
100
Reaction 1
Reaction 2
3 4
Time (Hours)
Evaluation
Reaction 1 reduced the PCB concentration to below the action level in only two hours,
suggesting that an optimized reaction with only 60% loading would be beneficial.
Reaction 2 at the reduced reagent loading reached the action level in four hours.
Thus. Reaction 2 conditions indicate that larger scale treatment costs could be
reduced substantially by using less of the reagent mixture required per cubic yard of
soil to be treated. Also, more soil per batch could be treated (less reagent volume).
thereby reducing the treatment time for the overall remediation costs.
ln-House PCB Antlyaia of Exit Fractions
GRC analyzed the exit fractions from Reaction 2 in order to verify that PCBs were
reacted and not simply removed by APEG-PLUSm treatment. Analysis by GRC's
analytical methods was considered necessary because standard standard PCB analysis
methods do not compensate for alterations in the PCB peak pattern or for
interference from glycols and DMSO unique to APEG-PLUSTV treatment. Results of
these analyses are presented in Table 5.
GRC Environmental, Inc.
Rooon
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Table 5 PCB Atialvsi* of Exit Fraction* fnr P»*rrirm ~)
Fraction
Condensate
Reagent
Wash 1
Wash 2
Wash 3
Wash 4
Wash 5
Vent traps
Treated soil
Treated soil duplicate
Treated soil average
% Relative stand, deviation
Treated soil spike
Spike added (ppm)
% Spike recovery
(ppm PCB)
12
<1.7
<0.6
<0.8
<0.7
<0.1
<1.1
NA
0.1
0.1
0.1
0.0
13
14
92
(DCS* R)
77
96
79
78
97
101
105
NA
77
87
80
(Notes for Table 5)
[DCB%R = per cent recovery of decachlorobiphenyl (the recovery surrogate).
included for QA purposes. NA = Not Analyzed by GRC (see Analysis frorn Outside
Laboratories section). < means below detection limit given. Treated Soil is the final
washed soil. All PCB concentrations are reported on a dry weight basis.]
The precision of PCB analysis is indicated by the per cent relative standard deviation
(which equals the standard deviation expressed as a percentage of the mean)
calculated from duplicate or replicate samples. The precision shown in Table 5 for
duplicate analysis on the treated soil was excellent (0%). Please note that these
values shown in Table 5 are significantly below the detection limit for the treated soil
PCB analysis calculated detection limit of <0.5 ppm (see Table 4). However, the actual
values obtained are included here to demonstrate the precision of GRC's PCB
analytical method.
Accuracy is evaluated by examining the per cent recovery of spiked samples and the
per cent recovery of the DCB recovery surrogate. The spike recovery of 92%
indicates that the accuracy of GRC's rapid analytical method for PCBs is very good and
well within our QA goals. The DCB recoveries for the exit fractions were also within
the QA criteria.
GRC Environmental, Inc. 7 R00017
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The data presented in Table 5 indicate that the APEC-PLUS™ treatment did not simply
remove the PCBs from the soil into the exit fractions, but actually reacted them, with
the possible exception of the condensate. The presence of PCBs in the condensate is
fairly unusual. A mass balance for PCBs indicates that approximately 90% of the PCBs
were destroyed by the dechlorination process, see Appendix 2. The PCBs found in the
condensate account for about 7% of the total, with the remaining 3% distributed
among the other exit fractions, all of which have PCB concentrations below the 2
ppm action level. Several methods exist for removing PCBs found in water fractions.
including carbon absorption. The necessity for this type of treatment would be
verified in pilot plant testing.
Mass Balance and Reagent Recovery
Full-scale remediation cost estimates are calculated from mass balance and reagent
consumption data generated from the optimized reaction. Results of the mass balance
calculations and reagent analysis can be found in Appendix 2. Tables 6 and 7
summarize mass balance data and reagent recovery information, respectively.
Table 6. Soil Mass Balance Calculations for Reaction 2
INPUT OUTPUT
Total wet soil mass (grams) 508.7 587.8
% Moisture 16.0 37.0
Total dry soil mass (grams) 427.3 370.3
% Recovery, dry mass 86.7
% Overall mass recovery • 89.3
•includes soil, condensate. reagent and washwater
Although both the dry mass and overall mass recoveries are similar, both are lower
than usual. Mass losses can occur from any one or several of the following:
• material may be left on the inner walls of sampling pipettes in the
laboratory,
liquids may leak from the lab reactor seal.
• water vapor may leak from the ground glass joints in the lab reactor top
or condenser system.
CRC Environmental, Inc. 8 R00017
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• . guses may leave the lab reactor, or
• minor spills may occur during handling in the laboratory.
No significant leaks, spills, or gas discharges were observed and recorded during the
reaction. A closer look at the mass balance sheets in Appendix 2 shows that washes 3.
4 and 5 experienced problems, averaging approximately 10% difference between
input and output mass. Washes 1 and 2 experienced only a 5% difference. These
differences do not translate directly to mass loss, but rather may be indicative of
handling techniques at a very small scale in the laboratory. Mass balances would
improve with scale up through pilot- and full-scale testing.
Table 7. Reagent Recovery Analysis Results
Reagent Component
Dry mass used
Grams found/ condensate
Grams found/reagent
Grams found/wash 1
Grams found /wash 2
Grams found/wash 3 *
Grams found /wash 4
Grams found/wash 5
Grams found/treated soil
Total grams recovered-dry
% Recovery
PEG
59.4
0.0
9.2
17
5.8
1.5
0.5
0.1
0.0
34
57
TMH
59.7
0.6
16
32
8
2.5
1.1
0.2
0.0
61
100
DMSO
101
3.6
31
62
14
4.3
2.2
0.6
1.6
120
120
KOH
45.5
0.0
0.3
12
5.5
0.0
0.0
0.0
0.0
18
40
* Residual KOH neutralized during wash 3.
The recovery of TMH and DMSO was very good. A significant amount of PEG was
apparently consumed in side reactions or unavailable for recovery in subsequent
soil washing steps. The low KOH recovery suggests a consumption in side reactions
which is verified by the KOH absorption capacity measured at 100 mg/g as shown in
Table 1; for every 100 grams of soil. 10 grams of KOH are consumed. Thus, for the 427
grams of dry input soil into reaction 2. approximately 43 grams of KOH would be
consumed in side reactions related to KOH absorption capacity. However, not all of
the KOH was consumed in this manner during the reaction. The KOH absorption
capacity test is performed overnight, whereas the reactions were carried out for only
seven hours. Pilot plant test runs on the Smith's Farm soil matrix would evaluate the
consumption of PEG and KOH noted in the laboratory.
CRC Environmental, Inc. 9 R00017
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Analsis from Qutaidc
Simples from Reaction 2's feed, treated soil, condeasate. reagent, composite wish
water, and vent trap were submitted to Versar Laboratories. Inc. (Springfield.
Virginia) for CLP analysis of polychlorinated biphenyls (PCBs by method CLP-PEST)
and poly aromatic hydrocarbons (PAHs by method CLP-SV). In addition, analysis of
lead by method 239.2 CLP-M was performed on all the above mentioned samples
except the vent trap. The initial results, provided in Appendix 3, indicate that all
components passed QA.
Waste Disposal
After the final report has been accepted by Law. GRC will pack and return the
analytical samples and related materials to Law at the Smith's Farm site. .'Ultimate
disposal of these materials will be the responsibility of Law.
Summary
The APEG-PLUS™ treatability study on the soil from the Smith's Farm site was very
successful in reducing the PCB concentrate in the soil to less than 2 ppm PCB. The
excellent results are reflected in the shon duration required for the reaction to take
place •- under four hours •- and the low reagent loading required (60 per cent). Both
factors indicate that the Smith's Farm soil is an easy matrix in which to apply
chemical dechlorination. which should result in cost savings to the client..
PCBs found in the exit fractions were below 'the action level with the exception of the
condensate. Discussion of the condensate included relatively simple solutions to this
concern. Mass balance data indicated lower than normal mass recoveries, although
these recoveries are probably the result of materials handling conditions at lab scale;
scale-up to pilot and full scale would improve the situation. Reagent recoveries were
within expected ranges with the exception of PEG; some PEG appeared to be consumed
in side reactions and was subsequently unavailable for recovery.
GRC Environmenul. Inc. 10 R00017
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July 25, 1991
GRC ENVIRONMENTAL, INC.
Appendix 2: Mass Balance Sheets
-------
Smitrvt Farm M«*»
MASS BALANCE: Laboratory Dechlortnation Reaction for Smith'* Farm Sell
Reaction 2
Inputs
Untreated Sol
PH3
TTyH
PCS
DMSO
45%KOH
Wash 1
Wash 2
Wash 3
Wash 4
Wash 5
Acid added
replace cond.
Total Inputs
SOIL
total matt
% moisture
dry mass
(grams)
50$. 70
59.43
59.72
0.02
100.64
101.17
505.60
501.90
475.08
507.10
520.30
25.35
106.04
3471.05
INPUT
508.70
16.00
427.31
% Recovery, dry basis
Results are accurate to 2
REAGENT INPUT
component
Dry mass used
PEG
59.43
CONDENSATE OUTPUT
total mass
mg/g
mass lound
% recovery
105.94
0.00
0.00
REAGENT OUTPUT
total mass
mg/g
mass found
% recovery
91.93
100.00
9.19
15.47
WASH 1 OUTPUT
total mass
mg/g
mass found
% recovery
482.74
35.20
16.99
28.59
WASH 2 OUTPUT
total mass
mg/g
mass found
% recovery
478.69
12.20
5.84
9.82
WASH 3 OUTPUT
total mass
ITIQ/Q
mass lound
% recovery
420.80
3.50
1.47
2.48
Outputs
Treated Soil
Reagent
Slurry samps
Wash 1
Wash 2
Wash 3
Wash 4
Wash 5
condensate
Total Outputs
FINAL
587.84
37.00
370.34
86.67
(orams)
587.84
91.93
18.80
482.74
478.59
420.80
442.23
472.26
105.94
3101.13
significant digits.
TMH
59.72
SAMPLE •
5.90
0.63
1.05
SAMPLE f
179.40
16.49
27.62
SAMPLE 0
65.90
31.81
53.27
SAMPLE 0
16.70
7.99
13.38
SAMPLE •
5.90
2.48
4.16
DMSO
100.64
910507173525
33.70
3.57
3.55
910509092025
335.30
30.82
30.63
910509094025
128.30
61.94
61.54
910509094525
28.80
13.78
13.70
910509095025
10.20
4.29
4.26
% recovery •
KOH
45.53
pom •
0.00
0.00
3.35
0.31
0.68
25.20
12.17
26.72
11.40
5.46
11.98
0.00
0.00
89.34
PCB (pom)
0.02
11.60
0.01
0.00
6.64
0.39
0.00
0.00
0.19
0.05
0.00
0.00
0.13
0.04
0.00
0.00
0.10
0.01
0.00
0.00
0.02
Pags 1
-------
Smitrrt Firm U«M Baianc*
WASH 4 OUTPUT
total rruu»
mg/g
m**« found
% recovery
442.23
1.20
O.S3
0.19
WASH S OUTPUT
total man
mg/g
mais found
% recovery
472.26
0.30
0.14
0.24
FINAL SOIL OUTPUT
total matt
mg/g
mast found
% recovery
Tout %R
587.84
0.00
0.00
57.50
SAMPLE t
2.50
1.11
1.85
SAMPLE •
0.50
0.24
0.40
SAMPLE •
0.00
0.00
101.72
910509114025
4.90
2.17
2.15
910509115025
1.25
0.50
0.59
910509135025
2.65
1.56
1.55.
117.97
0.00
0.00
0.00
0.00
0.00
0.00
39.38
0.03
0.00
0.00
0.07
0.04
0.00
0.00
0.10
0.70
0.00
0.00
2.22
9.49
Page 2
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July 25, 1991
GRC ENVIRONMENTAL, INC.
Appendix 5: GRC QA Report
-------
Analysis
The precision of PCB analysis is indicated by the relative standard deviation, or RSD.
(the standard deviation expressed as a percentage of the mean) calculated from
duplicate or replicate samples. Accuracy is evaluated by examining the per cent
recovery of spiked samples and the per cent recovery of the recovery surrogate,
decachlorobiphenyl. The results of a duplicate and spike on the treated soil from the
Smith's Farm site are listed in Table 5-1.
Table 5-1. PCB Analysis Duplicate and Soike Analysis for
Reaction 2.
Sample Description
Treated Soil
Treated Soil. Duplicate
Treated Soil. Spike
ppm
PCB
0.1
0.1
13
Treated Soil
Average
ppm
0.1
ppm
% RSD Added
0
14
% Spike
Recovery
92
The above results are well within the goals for precision and accuracy set in the
QAPP. The RSD is considerably more precise than ±50% and the spike recovery is
very accurate at 92% (QAPP spike recovery guideline requires recoveries within 50 -
150%).
Figure 5.1 is a control chart showing the per cent recoveries of the recovery
surrogate (decachlorobiphenyl) for all of the samples analyzed for PCBs during the
Smith's Farm treatability study. The mean is shown along with ± the first standard
deviation (1 SD) and ± the second standard deviation (2 SD)
The mean DCS recovery for Smith's Farm work was 90% with a standard deviation of
±29. This represents a Relative Standard Deviation (RSD) of ±32%. Both the mean
value and the RSD are well within the ±40% and ±50% respective guidelines set in
the QAPP. Figure 5-1 clearly shows that some of the first and last samples analyzed
for PCBs had an effect on the standard deviation. The first two data points falling
outside the ±2 SD limit were from analysis of the as received soil matrix. Notes in the
project laboratory notebook indicate that a new device in GRC's lab for preparing
samples was tested during this period and the data may reflect a training session.
Another pair of DCS recoveries falling outside the ±2 SD limit was associated with
-------
Figure 5.1: DCB Percent Recovery Control Chan
••* Data Points
•• + 2SD
- +1 SD
— Mean
- -1 SD
•• -2SD
5 10 15 20 25 30 35 40
Number of Samples Tested
analysis of Reaction 2 treated soil. The most likely explanation for these results is
technician error where a double dose of DCB surrogate was added to one sample and
none to the next. All samples with rejected data were rerun successfully.
GRC verifies the accuracy of the chromatographic procedure by analyzing a standard
solution as though it were a sample. Three samples of 1 ppm PCB check standards
were run with batches of samples from the Smith's Farm soil project. The average
result obtained was 1.0 ppm with a standard deviation of 0.1 ppm with a RSD of 10%.
This is better than the ±20% RSD goal set in the QAPP.
Completeness of data is evaluated by dividing the number of samples for which valid
results are obtained by the total number of samples analyzed. The Smith's Farm
project included PCB analysis on 27 samples. Valid data were obtained for 24 of them.
making the data 89% complete. This is just under the 90% guideline for per cent
completeness set in the QAPP. Incomplete data were associated with analysis of
reaction monitoring samples where insufficient quantity prohibits re-analysis.
-------
Reagent Component Analysis
Table 5-2 indicates the precision and accuracy of GRCs DMSO. TMH and PEG reagent
component analysis performed on the treated soil from Reaction 2. The precision is
measured by the RSD on duplicate analysis and the accuracy is measured by the
matrix spike per cent recovery. Please note that the values reponed are near or
below the detection limits which are 1 mg/g, 1 mg/g and 10 mg/g for DMSO. TMH and
PEG. respectively.
Table 5-2. Reagent Component Quality Control Analysis for
Reaction 2. Treated
Sample Description
Treated Soil
Treated Soil. Duplicate
Treated Soil, Average
Treated Soil. %RSD
Treated Soil, Spike (added
amount)
Treated Soil. Analysts Results
Treated Soil, % Spike Recovery
Soil
DMSO
mg/g
2.7
0.3
1.5
113
25
24
96
TMH
mg/g
0.0
0.1
0.1
71
12
11
92
PEG
mg/g
0.0
0.0
0.0
0.0
13
17
131
The precision was not within GRCs quality control guidelines (±30% for DMSO and
±50% TMH). Duplicate analysis near or below the detection limit will inherently
show less precision. The discrepancy in this analysis was due to an interference
from an unidentified peak in the chromatogram. Steps towards identification and
elimination of this peak were not pursued for this study. The RSD for PEG was well
within the ±50% goal.
The matrix spike results shown in Table 5-2 are excellent for DMSO and TMH and
within the ±50% goal for PEG.
Quality control measures for KOH reagent analysis consisted of performing every
titration in duplicate. Table 5-3 shows the degree of precision obtained from this
-------
analysis on the exit fractions from Reaction 2. Note that washes three through five
and the treated soil are not included because the soil was neutralized after the second
wash. The RSDs shown are acceptable and well under the 30% guideline.
Table S-3. KQH Quality Control Analysis for Reaction 2
Sample Result
Description mg/g Average %RSD
Reagent 3.33 3.35 0.6
3.36
Wash 1 25.9 25.2 3.4
24.5
Wash 2 11.7 11.4 3.7
11.1
-------
ATTACHMENT 7.4.3
SUMMARY OF BIOREMEDIATION
TREATABILITY STUDY
-------
ENSUE PROJECT NO. 31-1614
REPORT ON A BENCH-SCALE TREATABUJTT
STUDY OF THE SAFESOIL"1 BIOTREATMENT
PROCESS ON SOIL FROM THE
SMITH'S FARM SITE
VOLUME I - REPORT
Presented to:
Law Environmental, Inc.
112 TownPark Drive
Kennesaw, Georgia 30144
Submitted by:
ENSITE, Inc.
5203 South Royal Atlanta Drive
Tucker, Georgia 30084
June 20,1991
PROJECTS-6/19/91:31 • 16U
-------
TABLE OF CONTENTS
SECTION
1.0
2.0
3.0
4.0
5.0
INTRODUCTION/SCOPE OF WORK
MECHANISM OF THE SAFESOIL5* BIOTREATMENT
PROCESS
EXPERIMENTAL DESIGN
RESULTS AND DISCUSSION
CONCLUSIONS AND RECOMMENDATIONS
PAGE
1-1
2-1
3-1
4-1
5-1
TABLES
Table 1 - Soil PCB Concentration Before and
After Treatment by the SafeSoil
Biotreatment Process for Smith's
Farm AS-3
Table 2 - ANOVA Table for PCB Concentration-
Smith's Farm AS-3
Table 3 - Soil Bacterial Content Before and
After Treatment by the SafeSoil
Biotreatment Process
Table 4 - Soil PCB Concentration Before and
After Treatment by the SafeSoil
Biotreatment Process for Smith's
Farm CB-6
Table 5 - ANOVA Table for PCB Concentration-
Smiih's Farm CB-6
4-2
4-3
4-6
4-9
4-10
FIGURES
Figure 1 - SafeSoil Effect on Soil PCB and
Bacterial Concentration for Smith's
Farm AS-3
4-4
PIOJECT$-6/19/91:31-16H
-------
SECTION
FIGURES (continued)
Figure 2 - SafeSoil Effect on Soil PCS and 4-5
Bacterial Concentrations for Smith's
Farm CB-6
Appendices
A - Laboratory Reports - Volumes n, m, IV, V, VI, vn
B - Chain-of-Custody Forms - Volume Vn
u
>JECTJ-6/19/91:!M6K
-------
ETECTJTTVE SUM\f flR y
ENSITE was contracted by Law Environmental, Inc. on behalf of the Smith's Farm PRPs
to conduct bench-scale trtatability studies to determine if the SafeSoil Biotreatment Process
would be effective as a remedial option for soil of this site. Two areas of this site, AS-3 and
CB-6, were identified by Law Environmental to be tested by ENSITE.
SafeSoil was applied to the soil samples in a manner and concentration consistent with that
of normal field operations, and soil PCB, PAH, and bacterial content were monitored
independently for each sample as a function of posttreatmem curing time. Monitoring soil
PAH concentrations was later discontinued due to the apparent lack of PAHs in any soil
sample tested (AS-3 or CB-6). The data indicate that, as normally applied, SafeSoil did not
mediate any significant reduction in PCB concentration for either sample (AS-3 or CB-6)
examined, although soil bacterial population densities increased dramatically in response to
SafeSoil treatment. This implies that PCB-degrading bacteria have yet to become
acclimated so that they will degrade PCBs. Lack of PCB biodegradation can be attributed
to a variety of rate limiting factors. In the current study, the non-effectiveness of SafeSoil
is attributed to a combination of biochemical rate-limiting factors. For the AS-3 soil, the
most influential factor is probably cometabolite limitation. For the CB-6 soil, cometabolite
as well as concentration limitation are probably the most influential factors in suppressing
PCB biodegradation.
Final recommendations are to repeat this experiment at the bench-scale, on soil
representative of the Smith's Farm site, adding nonchlohnated biphenyl to the soil (as a
cometabolite) to induce enzyme synthesis and "turn on" PCB biodegradation.
P«OJECTS-6/19/91:J1-16U
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1.0 INTRODUCTION/SCOPE f)f WORK
ENSITE was contracted by Law Environmental, Inc. on behalf of the Smith's Farm PRPs
to conduct bench-scale treatability studies to test the effectiveness of the SafeSoil™
Biotreatment Process on soil from two regions, AS-3 and CB-6, within the Smith's Farm site.
Both sites were identified to ENSITE as having significant contamination with both PCBs
and PAHs. ENSITE proposed to treat samples from both regions separately and monitor
contaminant reduction following treatment with SafeSoil as a function of time for each site
independently. As originally specified, sediment samples were also to be analyzed; this was,
however, changed at the direction of Law Environmental.
The bench-scale treatability study consists of treatment of the contaminated soil
(approximately 6 kg) with the SafeSoil additive in the laboratory at ENSITE. Once treated,
the soil is placed on trays and allowed to "cure", during which time biodegradation of
organic contaminants actually occurs. This was conducted under laboratory conditions that
were designed to mimic field conditions as closely as possible. This is done in order to
minimize "flask-to-field11 variability, often cited as a reason for the failure of field
applications ofbioremediation procedures. At various phases of the treatment process (i.e.-
various times posttreatment during curing), soil samples were taken and analyzed for PCB
and PAH content and for bacterial population sizes. Total PCB and PAH content was
monitored to assess SafeSoil effectiveness for contaminant degradation. Bacterial
population size was monitored as a check to verify that effective biological degradation was
occurring. Also, in accordance with specifications of the RFP, a particle size and moisture
content analysis was conducted on soil from each region, AS-3 and CB-6. These tests were
required in order to demonstrate that the treatability sample matrix was representative of
field conditions.
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2.0MECHANISM OF THE SAFESQH™ ^TREATMENTPROCESS
Polychlorinated biphenyls (PCBs) are a class of compounds that contain a chlorinate
biphenyl ring. Polyaromatic hydrocarbons (PAHs) are a class of compounds that consist of
conjugated, nonchlorinated aromatic rings.
It is well established that PCBs are degraded by aerobic bacteria. PCBs are obligatory
cometabolized by aerobic bacteria. Cometabolism means that cells will not degrade a PCB
congener unless a structurally similar, yet more readily utilizable compound (the
cometabolite) is present. Cometabolites serve as inducers to "turn on" synthesis of enzymes
responsible for metabolism of the cometabolite. These enzymes are nonspecific in nature
and can gratuitously attack any structurally similar compound. A cometabolite for PCBs is
nonchlorinated biphenyl. Specifically, enzymes synthesized by bacteria specifically to
metabolize nonchlorinated biphenyl fail to distinguish between nonchlorinated and
chlorinated biphenyl molecules and non-specifically attack PCB congeners. It should be
noted that in nature, frequently, naturally occurring compounds, such as phenolics derived
from lignin biodegradation, are sufficiently structurally similar to PCBs structurally to serve
as cometabolites without the addition of any exogenous cometabolites.
The classical pathway for aerobic PCB biodegradation by cometabolism involves oxidation
of the lesser chlorinated phenyl ring by an oxygenase enzyme. The oxidized chlorophenyl
ring is then enzymatically cleaved, and the products of ring cleavage are sequentially
dehalogenated and oxidized to yield C02, microbial biomass and inorganic chloride anions.
PAHs are metabolized similarly, yet no dehalogenation occurs. Endproducts of PAH
metabolism include biomass and CO2. Many higher order PAHs are cometabolized,
including indeno(l,2,3-c,d)pyrene and benzo(a)pyrene. Most lower molecular weight PAHs
are metabolized normally.
Microbial genera that can degrade these compounds include, but are not limited to those
listed below:
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PROJECTS-4/19/91:31-16U
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ECBS. PAHs
Alcdtigenes Alcali genes
Corynebacterium Cunninghamella
Pseudomonas Pseudomonas
Nocardia
In general, the more complex a compound is, the more difficult it is to biodegrade, and the
longer the period of time required for biodegradation. With regard to PCBs, more heavily
chlorinated congeners (i.e.-hexa-and heptachlorobiphenyls) are more difficult to biodegrade
than are less heavily chlorinated congeners (i.e.-di-and trichlorobiphenyls). For example,
Aroclor 1260, a complex mixture of PCB congeners containing a relatively high proportion
of the more heavily chlorinated congeners, would degrade slower than Aroclor 1242, which
contains proportionately lower concentrations of the more heavily chlorinated congeners.
Similarly, polyaromatic hydrocarbons (PAHs), are increasingly more difficult to degrade as
their molecular weight increases. For example, 5-ring PAHs (i.e.-benzo(a)pyrene) are
biodegraded much slower biologically than do 2-ring PAHs (i.e.—naphthalene).
The SafeSoil"" Biotreatment Process is described as follows. SafeSoil is an ex-siru process
involving excavation of the contaminated soil, mixing with the SafeSoil additive in a mixer
on-site, and placement of the soil in curing piles on site. The process and additive address
all of the ecological and process-related limitations for bioremediation as described below.
The soil is thoroughly mixed and air is introduced to the treated soil during mixing, and the
treatment process ensures that air is encapsulated in the curing piles so that oxygen does
not become limiting to biodegradation rates'during the curing phase of processing. The
additive itself contains some inorganic nitrogen (N) and phosphorous (P) salts which are
always added in excess to overcome N and P limitations observed at most sites. Most of the
nitrogen that SafeSoil supplies is organic N in the form of protein. The inclusion of natural
surfactants in the additive allows for mobilization of absorbed bacterial and fungal cells,
while at the same time mobilizing contaminants (by emulsification), thus facilitating effective
microbial attack of the contaminant molecules in the interstitial pore space. Contaminant
structure with regard to toxicity cannot be ameliorated by' any addition; however,
contaminant toxicity can be partially compensated by the addition of readily utilizable
2-2
ueCTS>*/19/91:31-16U
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carbon sources. Moreover, inclusion of some amount of oxygenase enzyme allows for
initialoxidation of the parent compound to occur without de novo enzyme synthesis. The
initial oxidation products can then induce the synthesis of many other pathway enzymes, thus
facilitating further degradation.
2-3
PROJECTS-6/19/91:31-16U
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3.0 EXPtlRTMENT AT .
Upon receipt of the samples at ENSITE, the following treatment protocol was employed.
From each of the areas under consideration, the AS-3 and the CB-6 areas, a 6 kg aliquot
was removed, treated separately with the SafeSoil additive in a manner and concentration
consistent with that usually employed for field applications, and placed on trays in the
laboratory to cure. For the purposes of sample nomenclature on the laboratory reports and
chains-of-custody, AS-3 was rrdciignatcd "Smith's Farm No. l"and CB-6 was
"Smith's Farm No. 2". The report refers to each sample as the designation originally
supplied. The soil was mixed in a Hobart Industrial Mixer and curing was conducted under
laboratory-simulated field conditions.
Prior to treatment, the soil was sampled (n»3; composite) for each area and these samples
were sent to the subcontractor analytical chemistry laboratory for determination of PCS
concentration by EPA Method 8080 and PAH content by EPA Method 8270. Samples were
also taken for each area (n«3; composite) and sent to the subcontractor microbiological
laboratory for determination of total heterotrophic bacteria by the standard plate count
technique. Also, one subsample from each area was also analyzed for panicle size analysis
by the Law Environmental Physical Laboratories.
Posttreatment, duplicate subsamples (n«2) were taken and shipped to the subcontractor
analytical chemistry laboratory for analysis of PCB content by EPA Method 8080 and PAH
content by EPA Method 8270. This sampling was conducted on days 6, 17, 48 and 52.
Because of apparent lack of response to treatment initially, soil from both areas was
retreated on day 41. Analysis was conducted according to CLP procedures for all sampling
days except day 48. This was conducted by a non-CLP laboratory so that immediate
turnaround could be received. Because of the apparent lack of PAHs in both the
pretreatmem samples, and in samples collected on day 6, days 17, 48 and 52 were not
analyzed for PAH concentration. Additionally, duplicate subsamples were taken on each
sampling day and shipped to the analytical microbiology laboratory for determination of soil
bacterial population density by the standard plate count technique. Due to the long length
3-1
PROJECTS-6/19/91:31-16U
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of time required for this study, soil moisture content was found to be growth limiting and
water was added as needed.
The subcontractor laboratories employed in this study were EcoTek in Atlanta, Georgia,
Advanced Chemistry Labs in Atlanta, and Gold Kist Research Center in Lithonia, Georgia.
EcoTek was the laboratory responsible for chemical analysis by CLP procedures, while Gold
Kist Research Center will be responsible for microbiological analyses. Advanced Chemistry
Labs was used as a non-CLP laboratory to obtain rush turnaround for samples collected on
day 48. Law Environmental Physical Laboratory was responsible for soil particle size
analysis. EcoTek is a participating laboratory in the EPA Contract Laboratory Program
(CLP).
3-2
--E::S-6/19/91:31-16U
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4.0 PSTTT T A*
The data indicates that the SafeSoil Biotreatment Process was not effective at mediating
PCS removal under normal operating conditions. This is borne out by Tables 1 and 2, and
by Figures 1 and 2, which summarize changes in soil PCB concentration as a function of
curing time for both the AS-3 and CB-6 areas, respectfully. Soil PAH content was measured
by EPA Method 8270 and found to be below detection limits for samples collected both
pretreatment and on day 6 posttreatment. The data for these analyses are not presented
in the text of this report; however, the raw data including all required CLP reporting forms
are included in Appendix A of this report, as are all other analytical data, including results
for EPA 8080 analyses (and associated required CLP forms), results for the panicle size
analysis of the soil, and results of bacteriological analysis performed. Like PAH
measurements, the particle size analyses results are not presented in the text of this report.
Data presented in the text of this report is limited to PCB measurements made using EPA
Method 8080 and associated soil bacteriological measurements. It should be noted that the
EPA Method 8270 procedure (for PAHs) tentatively identified nonspecific PCB congeners
by estimation and comparison using a library search. These data are not quantitive and
have not been included for the purpose of this report.
For area AS-3, soil PCB concentrations were approximately 22,000ppb Gig/kg) prior to
SafeSoil treatment (Table 1). By day 17, no significant reduction had been observed, and
the sample was retreated on day 41. The lag time between the day 17 and the retreatment
day is reflective of the long turnaround tune- obtained using CLP procedures. Similarly,
retreatment failed to cause any significant biological degradation of PCBs. Day 48 and 52
PCB concentrations were not significantly different from any sample collected previously
(Tables 1 and 2). One-way analysis of variance was conducted on PCB concentration data
derived from soil samples collected from area AS-3 and results of this analysis confirm the
fact that no significant reduction in PCB concentration had occurred during the course of
this study (P<0.15). The ANOVA table for soil PCB concentration as a function of time
for area AS-3 is provided in Table 2. Soil bacterial population densities increased
dramatically in response to SafeSoil treatment and retreatment (Table 3 and Figure 1) for
4-1
P«OJECT$-6/19/91:31-16U
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Table 1. Soil PCB Concentration Before and After Treatment by the SafeSoil Biotreatment Process for
Smith's Farm AS-3
Day Number
Pretreal
Day 6
Day 17
Day 48
Day 52
Replicate No.
1
2
3
1
2
1
2
1
2
1
2
PCB Concentration (ppb)
Aroclor 1248
4700
•
Aroclor I2S4
21000
31000
21000
31000
37000
54000
24700
33500
53000
34000
Aroclor 1260
9500
Toul
21000
31000
14200
21000
31000
37000
54000
24700
33500
53000
34000
Mean
22067
26000
45500
29100
43500
S.E.
5976
7071
12021
6223
13435
I
ro
Note: Staple* were retreated on dtf 41
Nate: Dty 48 «r«* utiyzed by m mm-CLP laboratory
-------
TABLE2
ANOVA Table forPCB Concentration
Smith's Farm AS-3
Source Sum of SflMfCfi Pep fees of Freedom MCflH SflliarC
Model 1013309697 4 253327424 0.1094
Error 13892246667 6 2315374444
Total 14905556364 10
4-3
MOJECTS-6/19/V1:31 • 1614
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Figure 1. SafeSoil Effect on
Soil PCB and Bacterial Concentrations
for Smith's Farm AS-3
PCB Concentration (ppm)
Soil Bacteria (CFlMOe6/g)
20 30 40
Curing Time (days)
60
60
PCB Concentration
Soil Bacteria
-------
01
Figure 2. SafeSoil Effect on
Soil PCB and Bacterial Concentrations
for Smith's Farm CB-6
6000
PCB Concentration (ppb)
Soil Bacteria (CFU*10e6/g)
20 30 40
Curing Time (days)
300
60
PCB Concentration
Soil Bacteria
-------
Table 3. Soil Bacterial Content Before and After Treatment by the SafeSoil Biotreatment Process
•
a\
Simple No.
SPfl
(AS-3)
svn
(CB-6)
Sample Day
Prelrealment
Day 6
Day 20
Day 41
DayS2
Prelreatraent
Day 6
Day 20
Day 41
Day 52
Soil Bacteria (Millions of CFU/g)
XI X2 X3
0.95 0.17 1.00
23.00 19.00
0.90 O.SO
21.00 11.00
60.00 45.00
3.20 2.10 2.00
92.00 120.00
1.10 1.50
220.00 280.00
20000 210.00
Mean
0.94
21.00
0.15
19.50
52.50
2.43
106.00
1.65
250.00
205.00
S.E.
0.07
2.83
0.07
2.12
10.61
0.67
19.80
0.21
42.43
7.07
Note: Samples were retreated on d*y 41.
-------
this sample. The fact that bacterial growth occurred, and dramatic (20-50 fold) increases
in soil bacterial population density were noted for AS-3 soil (Table 3) implies that there is
not an inhibitory substance in the soil that will preclude growth. Because PCE-degrading
bacteria are common soil isolates, they too have been increased in number, but these
bacteria are not growing at the expense of PCB congeners, which did not exhibit decreases
in concentration coincident with bacterial population increases (Figure 1). These organisms
are using other carbon sources and are not utilizing the PCB congeners themselves as
carbon and energy sources. Moreover, because bacterial populations exhibited such large
increases in size coupled with no. significant PCB removal following either initial treatment
by SafeSoil or subsequent retreatment by SafeSoil on day 41 (Figure 1), it is clear that
oxygen, inorganic/organic nutrients, and PCB bioavailability are not rate-limiting factors for
soil of this area (AS-3).
The data does suggest that the PCB-degrading organisms have not yet become
and as such have not yet "turned on" cell machinery for PCB biodegradation. This can be
due to two factors:
• Cometabolite limitation
• Presence of PCB in concentrations insufficient to trigger the biodegradation
reaction
Cometabolite limitation means that the cometabolites required for biological degradation
of PCBs are not present. Cometabolite limitation may be the reason why no biological
degradation of PCBs has occurred. One method that can be employed to overcome this
limiting factor is to add a Cometabolite (unchlorinated biphenyl) to the soil prior to
treatment. Unchlorinated biphenyl can serve as a Cometabolite of PCB congeners and
induce the synthesis of enzymes necessary for bacterial metabolism of PCBs to occur.
Also, the initial levels of PCB in this soil may be too low to trigger the enzymatic reactions
responsible for their destruction. The specific threshold concentration will be largely
dependent on the specific species mediating PCB biodegradation, the PCB congeners
4-7
PROJECTS -6/19/91 :SV16U
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themselves, and soil type involved and can be determined experimentally. Regarding
solution options, very little can be done if PCS concentration is the rate-limiting factor.
Degradation of low concentrations of PCBs will occur, but over long periods of time, during
which time, populations of microorganisms, with kinetic parameters applicable for low
concentration, high rate (low K,, high V^ PCB metabolism, will establish themselves.
There is very little that can be done to speed this process.
Another possible reason for biodegradation rate limitation is that because the PCB
constituents present in this soil are of a highly weathered nature, the more readily
biodegradable congeners of Aroclor 1254 (i.e.-di-,tri-,and tetrachlorobiphenyl congeners)
have already been degraded by natural soil microflora, leaving the more heavily chlorinated
congeners (i.e.— penta-.hexa-, and heptachlorobiphenyl) behind. These more heavily
chlorinated congeners are notoriously recalcitrant, and will simply take longer periods of
time for degradation to occur.
With regard to sample AS-3, cometabolite limitation is probably the most influential rate
limiting factor. This would be consistent with many published laboratory studies and would
be the easiest possibility to investigate on a bench-scale basis. However, other possibilities
cannot be eliminated in lieu of this specific explanation. In fact, failure of SafeSoil to
mediate an effect with AS-3 soil results from a combination of the above described limiting
factors, with cometabolite limitation being the most influential.
Similar results were obtained with area CB-6 as were obtained with area AS-3. SafeSoil
treatment apparently caused no significant decline in total PCB concentration (Table 4).
PCB congeners were present in this soil were in extremely low concentrations initially
(<5000fig/kg), and these levels did not significantly change as a result of SafeSoil treatment
(Tables 4 and 5). One way analysis of variance (ANOVA) was performed on the PCB
concentration data for area CB-6 and confirms this premise (P<0.15). The ANOVA table
is presented in Table 5. Also, soil bacterial population densities in CB-6 soil increased
dramatically for this site, up to 200 fold (Table 3). Increases in the size of soil bacterial
populations, without concomitant reduction in PCB concentration (Figure 2) were also
4-8
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Table 4. Soil PCB Concentration Before and After Treatment by the SafeSoil Biotreatment Process for
Smith's Farm CB-6
DiyNMtor
tYrtfMt
D«y6
Day 17
Day 41
Day 52
lUpllMtoNo.
1
2
3
1
2
1
2
1
2
1
2
PCB CoacartntlM (|
Arodor 1241
3100
4«0
1700
1900
ISOO
1600
ND (
-------
TABLES
ANOVA Table for PCB Concentration
Smith's Farm CB-6
Source Sum of Squares Degrees of Freedom Mean Square E
Model 1459756 3 .486585 0.0109
Error 178256600 4 44564150
Total 179716356
4-10
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observed with the AS-3 soil. Again, this observation implies that nothing present in this soil
is inhibitory to bacterial growth and that indigenous microflora have not yet become
arrlimafrd to PCB metabolism. This could be for the same reasons that were specified for
AS-3:
• Cometabolite Limitation;
• Concentration Limitation (PCB concentration too low);
• Weathered nature of the compounds.
The most influential rate limiting factor for the CB-6 soil is probably concentration
limitation coupled with cometabolite limitation. The levels of PCB are likely too «maii to
generate a response from indigenous microflora. As was stated before, biodegradation of
low concentrations of PCB will occur, but the time frame required for low concentration,
high rate PCB degrading populations to hfcornf established fln^ a****i'fnttfd ran be quite
long and there is very little that can be done to accelerate the process. Rate limitation for
PCB biodegradation for CB-6 soil results from a combination of all described rate limiting
factors, with low PCB concentration and cometabolite limitation exerting the most effect.
One other possible rate-limiting factor for soil from both of these areas (AS-3 and CB-6)
is that, in both cases, PCB-degrading bacteria were not present in the soil. Owing to the
ubiquitous presence of Alcaligenes, Pseudamonas and Nocardia species in soil, this is likely
not a significant factor. It is more likely that these organisms are present in the soil, but are
not degrading PCBs, due to limitations described earlier.
Because the rate-limiting factors predominant at this site appear to be
biochemical/microbiological in nature, other bioremediation technologies would likely not
be successful on this soil either. The lack of effect of SafeSoil for soil of this site is a
reflection of biochemical limitations that all bioremediation technologies share and is not
a technology-specific limitation.
4-11
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5.0 CONCLUSIONS
In summary, the data do indicate that as normally applied, the SafeSoil Biotreannent
Process was not effective at reducing PCS concentration in soil from dther the AS-3 or CB-
6 area of the Smith's Farm site. Because cometabolite limitation was identified as a
probable rate-limiting factor for PCS metabolism, final recornmendations are repeat this
experiment, at the bench-scale, adding unchlorinated biphenyl as a cometabolite to «^'jc?
the synthesis of the PCS biodegradation pathway enzymes. The soil to be used in this test
should be representative of the area to be treated in the manner and more heavily
contaminated with PCBs, if this is representative of the site.
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