United States        Office of
Environmental Protection   Emergency and
Agency           Remedial Response
                                         EPA/ROD/R04-93/151
                                         September 1993
SEPA    Superfund
          Record of Decision :
          Smith's Farm Brooks, KY

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50272-101
  REPORT DOCUMENTATION
           PAGE
1. REPORT NO.
EPA/ROD/R04-93/151
3. Recipient's Accession No.
   Tttla and Subtitle
   SUPERFUND RECORD OF DECISION
   Smith's Farm Brooks, KY
   Second Remedial Action - Final
                                          5  Report Data
                                          	     09/17/93
7.   Authors)
                                          a  Perforating Organization Rapt. No.
a   Performing Organization Nam* and Address
                                          10  Project Task/Work Unit No.
                                                                     11.  Contraet(C) or Grant(G) No.
                                                                    (G)
    Sponsoring Organization Nama and Address
    U.S. Environmental  Protection Agency
    401 M Street,  S.w.
    Washington, D.C.   20460
                                          11  Type of Report & Period Covered

                                             800/800
                                                                     14.
IE  Supplementary Notes
                     PB94-964025
ia  Abstract (Umtt: 200 words)

  The 460-acre Smith's Farm Brooks site  is a former hazardous waste  disposal area  located
  in Brooks,  Bullitt County,  Kentucky.   Land use in the area is predominantly
  residential,  with areas  of deciduous forest around  the entire site.   The site borders
  forested hills to the north,  east, and west and a residential area to the south.   In
  addition,  intermittent streams flow along the north-central portion of the site  and
  drain  into the Unnamed Tributary of Bluelick Creek  and,  subsequently, into Floyd's
  Fork.  The site includes an 80-acre area that was used for unpermitted disposal  of
  drums  containing hazardous waste for a period of approximately 30  years.  It also
  includes a 37.5-acre landfill that was permitted by the State for  the disposal of  inert
  industrial waste from 1973 to 1989; however, the landfill had been used for disposal of
  industrial waste since the 1950s.  The disposal activities in both areas of the  site
  have resulted  in contamination of onsite environmental media.  In  1984, following
  investigations by EPA and the State, EPA performed  an immediate  removal of surface
  drums  from the unpermitted disposal area. Also, in  the 1980s, the  site operator
  reportedly burned piles  of wood debris to dispose of large volumes of scrap wood.   In
  an attempt to  smother the smoldering wood debris, the operator later buried the  debris

  (See Attached  Page)
17. Document Analysis    a. Descriptors
   Record of Decision - Smith's Farm Brooks, KY
   Second Remedial Action - Final
   Contaminated Media:  soil, sediment,  gw, sw
   Key  Contaminants:  VOCs (benzene,  TCE, toluene),  other organics (PAHs,  pesticides,
                       phenols), metals (arsenic,  chromium, lead)

   b.  Identifiera/Open-Ended Terms
      COSATI Field/Group
   Availability Statement
                          19.  Security Class (This Report)
                                    None
                                                    20.  Security Ctass (This Page)
                                                              None
          21.  No. of Pages
                 234
                                                                              22. Price

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EPA/ROD/RO4-93/151
Smith's Farm Brooks, KY
Second Remedial Action - Final

Abstract (Continued)

in the northern half of the landfill.  Several attempts to  smother the  fires were not
successful; subsurface thermal anomalies still exist in the northeast and northwest
corners of the landfill.  Beginning in 1988, EPA conducted  detailed onsite investigations,
which revealed organic and inorganic contamination in environmental media in the vicinity
of  both disposal areas.  For remediation purposes, the site was divided into two OUs.  A
1989 ROD and a 1991 ROD amendment addressed containment of  contaminated soil, sediment,
ground water in the surficial aquifer, and drums in the vicinity of the unpermitted drum
disposal area, as OU1.  This ROD addresses landfill wastes, leachate, leachate sediment,
surface soil, ground water, and surface water associated with the 37.5-acre landfill and
other small, outlying areas of contamination onsite, as OU2.  The primary contaminants of
concern affecting the soil, sediment, ground water, and surface water are VOCs, including
benzene, TCE, and toluene; other organics, including PAHs,  pesticides,  and phenols; and
metals, including arsenic, chromium, and lead.

The selected remedial action for this site includes excavating and consolidating wastes
from the small areas of contamination in the landfill; capping the landfill with a
RCRA—type cap with surface drainage controls and a gas control system;  excavating and
extinguishing the subsurface landfill fire; installing and  operating a  leachate collection
and treatment system for the shallow ground water; discharging the treated water to the
Unnamed Tributary; installing perimeter fencing, lockable gates, and warning signs/-
monitoring ground water; and implementing institutional controls, including deed, ground
water, surface water, and land use restrictions.  The estimated present worth cost for
this remedial action is $3,279,000, which includes an estimated total O&M cost of
$2,351,000 for a period of 30 years.

PERFORMANCE STANDARDS OR GOALS:

Chemical-specific soil cleanup goals for the excavation of  outlying areas of contamination
are based on achieving cancer risk levels of 10"^, and include PAHs 0.882 rag/kg and
pesticides 33.94 mg/kg.  Chemical-specific cleanup goals for collected  leachate and ground
water will be determined during the remedial design.  Discharge limits  for treated
effluents shall meet the requirements of State and Federal  surface water criteria.

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         RECORD OF DECISION
                   FOR

            OPERABLE TJNTT TWO

       SMITH'S FARM (BROOKS)

             CERCLA NPL SITE

 SHEPHERDSVILLE, BULLTIT COUNTY, KENTUCKY
                KY0972674139

SUMMARY OF REMEDIAL ALTERNATIVE
              SELECTION
                 AND THE

             DECLARATION
          UJS. Environmental Protection Agency
                 Region IV
                Atlanta, Georgja

               September 17,1993

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                  Remedial Alternative Selection

SITE NAME AMD LOCATION

Smith's Farm Site  (Second Operable Unit)
Brooks, Bullitt County, Kentucky
This decision document presents the selected final remedial action
for the Second Operable Unit of the Smith's.. Farm Site, Brooks,
Bullitt County, Kentucky, which was chosen in accordance with
CERCLA, as amended by SARA, and the National Oil and Hazardous
Substances Pollution Contingency Plan.  This decision is based on
the administrative record for the Site.  Among the Administrative
Record documents which form the basis for selection of the remedial
action are:

  • Remedial Investigation Report, Operable Unit Two
  • Feasibility Study Report, Operable Unit Two
  • Summary of Remedial Alternative Selection
  • Responsiveness Summary
  • Staff Recommendations and Reviews

The Commonwealth of Kentucky concurs with the selected remedy.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision  (ROD) , may present an imminent and
substantial endangerment to public health, welfare, or the
environment .
DEPTION OP
The function of this remedy is to reduce the risk associated with
exposure to the  (l) contaminated, on-site surface soils,  (2)
contaminated, on-site surface and ground waters,   (3) contaminated,
on-site stream sediments, and  (4) contaminated, on-site leachate
and leachate sediments.
•  Remediate subsurface thermal anomalies

•  Consolidate peripheral waste areas within landfill

•  Install extensive leachate collection system to  intercept and
   collect leachate and contaminated ground water

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•  Recontour surface  of landfill

•  install RCRA-type  cap with run-on  and run-off  control systems
   and a gas control  system

•  install multi-stage leachate treatment system  for  on- site
   discharge to the intermittent Unnamed Tributary east of the
   landfill

•  Install a perimeter fence and warning signs

•  Monitor the Operable Unit Two wells semi-annually  for five (5)
   years after construction is complete and thereafter annually for
   twenty- five  (25) years

•  Impose surface water and ground water use restrictions as
   well as deed restrictions to limit land use

DECLARATION

The selected remedy is protective of  human health and the
environment, attains  Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective.  This  remedy utilizes  permanent
solutions and alternative treatment  (or resource  recovery)
technologies to the mayi™,*™ extent practicable.   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 to the maximum extent
practicable.  However, because treatment of the principal threats
at the Site was not found to be practicable, this remedy does not
satisfy the statutory preference for  treatment of all Site wastes
as a principle element.  This remedy  utilizes containment due to
the technical impracticability of treating a large volume of mixed,
heterogeneous landfill wastes.

Because this remedy may result in hazardous substances remaining on
site above health-based levels, a review will be  conducted within
five (5) years after  the commencement of remedial action to ensure
that the remedy continues to provide  adequate protection of human
health and the environment.
     Date                                   Patrick X. Tobin
                                      Acting Regional Administrator

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        RECORD OF DECISION
                  FOR
           OPERABLE UNIT TWO

      SMITH'S FARM (BROOKS)

            CERCLA NFL SITE

SHEPHERDSVILLE, BULUTT COUNTY, KENTUCKY
                KY0972OT4I39


REMEDIAL ALTERNATIVE SELECTION
            EnTironmental Protectkm Agency
                 Region IV
               Atlanta, Georgia

              September 17,1993

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                           TABLE OF COMTEK*
1.0  iJTi'ltODUCTIOH	.	^

     1.1   SITE NAME, LOCATION AND DESCRIPTION	 i
     1.2   SITE HISTORY	x

2.0  KNPORCEMBKT HISTORY	5



4.0  SCOPE AHP ROIiE OP TF" OPERABLE tJNIT
     WI'JL'H^^T T*^"S SITE STRATEGY ---------------•-----------.-_.____ p

5.0  SUMMARY OP SITE CHARACTERISTICS 	9

     5.1   ENVIRONMENTAL SETTING	9

           5.1.1  fr-M««tf.	9
           5.1.2  Flora, I»T»Ji. - - - - — ---- —	*.	9
           5.1.3  Geology.	 10
           5.1.4  Soils.					10
           5.1.5  gw>**«weology. - - - - — ----	.	__ ]_Q
           5.1.6  Surface  Water ?"(! Topography. --- —	n

     5.2   GEOPHYSICAL INVESTIGATION RESULTS	 13

           5.2.1  Areal Extent of the TfgT*df±ll.	13
           5.2.2  vertical Extent of T-»^dfill.	13
           5.2.3  Lydflll Chiraeterization.	:	18
           5.2.4  Mapping  of Sv^smrfacs Condtictivc Pim*io  _...____ ig
           5.2.5  RccoT1T*aiss?T'CC of p*^P^  ------------- 29
           5.3.4  Surfa7e  f**1}  Sy^gurface Soil.	r	30
           5.3.5  Ggo^"<^ Water. - -	...	 33
           5.3.6  SviimfLTY  ff the Ce>TiteB*^T^yti.on i.n th.6  Study Area. 35

6.0  SUMMARY OP SITE RISKS	 35

     6.1   HUMAN HEALTH RISKS	43

           6*1.1  CoocfT'txati.oiis ot Coofi*Tn^T'f*T|t8 of  COOCCDQ in
                  Bach Medi.*""  fff ^li^pQSiire. ---- —.--__-.-----.--- 43
           6.1.2  .c™tmi»ii-r  of Results of Bacposure Assessment.	44

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           6.1.3  _ __
                  _  : - .
                                                                   49

                  6.1.3.1  Noncarcinogenic Effects -------------- 49
                  6.1.3.2  Carcinogenic Effects ----------------- 55
                  6.1.3.3  Dermal Exposures --------------------- 56

           6.1.4  PITHHM^V of Risk Charaeterigation of Each


                  6.1.4.1  Potential or Actual Carcinogenic Risks 57

                           6.1.4.1.1   Current Carcinogenic Risks
                                       for Residential Populationg 57
                           6.1.4.1.2   Future Ca.ycinoaen.ic Riglcp
                                       for Residential and
                                       Occupational Adult
                                       Populations --------------- 61

                  6.1.4.2  Noncarcinogenic Risks ---------------- 62

                           6.1.4.2.1   Current Nonearcinocrenic
                                       Risk ...................... 62
                           6.1.4.2.2   Future Noncarcinooenic Risk
                                       for Nearby Residents .
                                       On-site Residents, anj
                             '  "        Construction Workers ------ 63

                  6.1.4.3  Summary  ------------------------------ 65

     6.2   ENVIRONMENTAL EVALUATION ............................. 71

           6.2.1  SiTT"TTnT"oiif>Tit . ------------------------ 74
           7.1.3  G^m^yai Cr""i'"'>fritS .  ------------------------- — 75
           7.1.4  Ma -tor ARARs.  ------- . --------------------------- 75

     7.2   ALTERNATIVE II - LEACHATE COLLECTION AND TREATMENT --- 75

           7.2.1  T3fBa*">l>aT1t C^lt>lPon6'n t . -------------------------- 75
           7.2.2  ContaiT"t"BTI*' <"*T>oii'?TTt. ------------------------ 76
           7.2.3  G^^eral C<*"*T>oii'aT> ts .  --------------------------- 76
           7.2.4  Ma-tor ARARs.  ....... - ...... - ................... 76
                                    ii

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     7.3  ALTERNATIVE  III  -  CONSOLIDATION OF LANDFILL WASTE,
                             CAP AND COVER, LEACHATE COLLECTION
                             AND TREATMENT	 77

          7.3.1  Ta?O&tattoot Cm|>oitfpt.  -------------------------- 30
          7.5.2  Conta^^^"^TIt Coarpoa^Tit.	 — ------- — .	31

          7.5.4  Ma-lor ARARs. 	 82

     7.6  EXPLANATION  OF MAJOR APPLICABLE OR RELEVANT AND
          APPROPRIATE  REQUIREMENTS AND TO-BE-CONSIDERED
          STANDARDS	 82

          7.6.1  Ch*""^ca.1-specifd.c ARARs.	...— 35

                 7.6.1.1   Soil and Sediment --	—	 86
                 7.6.1.2   Water	 86
                 7.6.1.3   Air	 87

          7.6.2  Location-specific ARARs. 	 88
          7.6.3  Action-specific ARARs. 	 89
          7.6.4  Ma*1or State ARARs.	 90
          7.6.5  To-Be-Considereds (TBCs) . 	 92

8.0  SUMMARY OF COMPARATIVE  ANALYSIS OF ALTERNATIVES		93

     8.1  THRESHOLD CRITERIA	 93



          8.1.2  
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     8.2   PRIMARY BALANCING CRITERIA			97

           8.2.1  IiOno-y^>yp Effectiveness ff^tf  psf"iiTicnee.--------  97
           8.2.2  Reduction of Toacieitv. Mobility,  or •p^iirme
                  ThT"Ongh Trea.t*r"*»*-'fr' ---------—----_--------—-_-__  90
           8.2.3  Short-Term Effectiveness.		  100
           8,2.4  Tmpl amua>Ti»-»»>y< 1 -I fcy , -----------------	  1Q1
           8.2.5  Cost.		  102

     8.3   MODIFYING CRITERIA	  102

           8.3.1  State/SupDoirt Agency Aeeep^*T>gy	  102
           8.3.2  Cmmnm _. fcy ACCCPtfTlCC . —--—--—------—---•-—-—---_  104

9.0  Ttng  SEI_BCSl'i^|> WHnmTf --- — _-_-______ — _•_- — ___-_______________  104

           9.0.1  Trea+gggpj^ ^yppon^nts. -------------------------  105
           9.0.2  Conta.i.*y">_CTit gpa«->T|^;g  -..-__-.-.--.-. — ______  iQ5
           9.0.3  G^^eira.! CoigponpT't'p_ ---------------------------  105

     9.1   REMEDIATION LEVELS AND OBJECTIVES	  108

           9.1.1  Buried  Waste y"ill Material.	  109
           9.1.2  Leachate Water y»d Verv Shallow fi-rr>i-iT>i^ Water.--  ill
           9.1.3  Surface Water ypd Surface Water Se(^^TB*>r|ts.-~~ - -  112
           9.1.4  L*»"dflll T-jer""»l Anqwalies.	  114


     9.2   STATUTORY DETERMINATIONS	  114

           9.2.1  Protection of H"™*" Health* "^^1 the pnyj.yQTmi-mi' ^  114
           9.2.2  CoiBpH.ypoe With *t>ol-.c*^lc o_r RBlcvy^t y"^


                  9.2.2.1  Resource Conservation and Recovery Act
                            (RCRA) 	-	117
                  9.2.2.2  Clean Air Act  (CAA) 	  117
                  9.2.2.3  Ground Water/Surface Water ARARs	118

           9.2.3  Cost-Ef f eetlveness	  120

                  Al feyynative T_rea*^"nTIiTir>i <->cries oar Resource
                  Recoveirv Te^^^ologies to  the Mi*y^TB\''1'1 ^^rt?°Tlt
                  Praetic*^"1 f».	120


     9.3   DOCUMENTATION  OF SIGNIFICANT CHANGES	  121
                                     IV

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10.0 TT PKgP
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                              FIGURES
Figure
1.0  --  Site Location Map	  2
l.l  --  Site Map Depicting Two Operable Units	  3
5.1  --  Conceptual Hydrogeological Model --?	12
5.2  --  Portion of the U.S.G.S. Brooks 7.5-Minute
         Quadrangle 	 14
5.3  --  Interpreted Areal  Limit of Landfill Material
         Based on Geophysical Data	 15
5.4  --  Isopach Map of Landfill Material	16
5.5  --  Pre-Landfill Topographic Surface 	 17
5.6  --  Map of EM-31 Apparent Conductivity	19
5.7  --  Infrared Thermal Imagery Map	 21
5.8  --  Leachate and Leachate Sediment Analytical Data	26
5.9  --  Surface Hater and  Stream Sediment Analytical Data — 28
5.10 --  Surface and Subsurface Soil Analytical Data	31
5.11 --  Monitoring Well Analytical Data	 34
9.0  --  Areas of Suspected Contamination Outside
         the RCRA Cap	 106
9.1  --  Conceptual Leachate Collection Plan 	 107
                                  vi

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                                TABLES
                                                                 Paee


2.0  -- Smith's Farm Site - Remedial History. .....................  7
5.0  -- Smith's Farm - Operable Unit Two RI  - Waste Inventory ---- 23
5.1  -- Summary of Concentration Ranges of Chemicals of
        Concern by Media ----------------------------------------- 36
5.2  -- Estimated Exposure Point Concentrations ------------------ 37
6.0  -- Exposure Routes Considered ------------------------------- 45
6.1  -- Major Assumptions About Exposure Frequency and Duration --50
6.2  -- Chronic Health Criteria for Chemicals of Concern ..... ---- 53
6.3a -- Summary of Noncarcinogenic Risks - Current and Future ---- 58
6.3b -- Summary of Carcinogenic Risks - Current and Future ------- 59
6.4a -- Summary of Major Site Risks Based on Current Land Use ---- 66
6.4b -- Summary of Major Site Risks Based on Future land Use ----- 68
6.5  -- Comparison of Surface water Concentrations  (95% UCL) to
        Water Quality Criteria for the Protection of Aquatic Life  72
6.6  -- Comparison of Sediment Quality to Concentrations Found
        in the Unnamed Tributary's Sediments --------------------- 73
8.0  -- Description of Five Alternatives ......................... 103
9.0a -- Action Levels for Surface Soils and  Leachate Sediments
        for Landfill Consolidation --------------------- ...... ---- 110
9. Ob -- Action Subtotals for Landfill Consolidation .............. Ill
9.0c -- Remediation Levels for Ground, Surface, Leachate Water — 113
9.1  -- ARARs and TBCs for the Selected Remedy ................... 116
                                 vii

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 5.0  Summary Tables of Analytical Results from the Operable
      Unit Two Remedial Investigation  .

 5.1  Analytical Data from Sampling of the Unnamed Tributary

 7.0  Summary of Costs for Remedial Actions Alternatives

 7.1  Leachate Collection and Physical Treatment

 7.2  Collection and Chemical/Physical Treatment and
      Heavy Metals Removal
 7.3  Leachate Collection and Chemical/Physical Treatment
      for the Removal of Heavy Metals and Organ! cs

 7.4  Leachate Collection and Chemical/Physical/Biological
      Treatment for the Removal of Heavy Metals and Organics

 7.5  Leachate Interceptor Trench Typical Detail

 8.0  Letter of Concurrence from Commonwealth of Kentucky

 9.0  Determination of Action Levels in Tables 9.0a,9.0b,9.0c

10.0  Transcript of May 21, 1992 Public Meeting,
      Proposed Plan Presentation, and List of Attendees
                            viii

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1.0  IKTRODUCTIOK

1.1  SITE NAME, LOCATION AND DESCRIPTION

The Smith's Farm Site refers to an approximately 460-acre property
located in a rural part of Bullitt County, Kentucky, approximately
1.5 miles southwest of Brooks, Kentucky.  The Site is located at an
approximate latitude of 38 degrees 2 minutes 45 seconds and a
longitude of 85 degrees 44 minutes 0 seconds  (See Figure 1.0.).

The Site is bordered on the north, east, and west by forrested
hills and on the south by a residential area along Pryor Valley
Road.  The Site includes an area of approximately eighty (80) acres
where unpermitted disposal of drums occurred over a thirty  (30)
year period.  This area, which is being addressed in Phase One or
Operable Unit One, was the subject of a prior Remedial
Investigation /Feasibility Study  (RI/FS) funded by the USEPA, a
Record of Decision  (ROD) dated September 29, 1989, ay»3 a ROD
Amendment dated September 30, 1991.  The Site also contains a
landfill of approximately 37.5 acres (See Figure 1.1.) which was
permitted for inert industrial wastes by the Commonwealth of
Kentucky.  Phase Two or Operable Unit Two addresses the formerly
permitted landfill as well as several smaller outlying disposal
areas.  A major intermittent tributary, the Unnamed Tributary, of
Bluelick Creek and the Floyd's Fork stream system runs from the
northernmost portion of the Smith's Farm property to the
southernmost edge of that property and then off-site into Bluelick
Creek.  The Unnamed Tributary drains both major disposal areas.

At the southeast edge of the landfill along the access road there
are several small run-down wooden buildings, one of which houses an
inoperative electric pump and collection sump which are a part of
the old leachate collection and recirculation system.  The other
buildings in that same area served as equipment maintenance and
storage structures.  In the approximate center of the landfill,
there is a blue, metal building which served both as an office and
an equipment repair facility.

Along the east side of the landfill near the Unnamed Tributary, six
(6) leachate seeps have been identified.  These outbreaks flow out
of the earthen slope or from the bank of the Tributary.  Another
seep breaks out onto a low-lying area in the southwest quadrant of
the landfill.

1.2  SITE HISTORY

The Smith's Farm property is very hilly and not suitable for
farming or forestry; the hills have steep-sloped sides with little
flat area between.  The proximity of industries in and around
Louisville, and the need of those industries to dispose of  their

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SOURCE:
7.S nmuit OUADftANQE BROOKS. ttNTUCICY
SCALE IN MILES
0 1 MILE 2 MILES
*
SITE LOCATION MAP
SMITH'S FARM
OPERABLE UNIT 02 Rl
BULUTT COUNTY. KENTUCKY
FlGTOB 1.0

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       QUICK CEMETERY
         UNPERMITTED
         DISPOSAL AREA
         OPERABLE UNIT 01
INTERPRETED LIMITS
OF PERMITTED LANDFILL
OPERABLE UNIT 02

   MAINTENANCE BUILDING
                                                                             SITE MAP DEPICTING
                                                                             TWO OPERABLE UNITS
                                                                                  SMITH'S FARM
                                                                               OPERABLE UNIT 02
                                                                            BULUTT COUNTY. KENTUCKY

                                                                                  FIGURE l.l

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wastes cost-effectively, resulted in the unpermitted and permitted
disposal of  industrial and commercial wastes in two (2) major areas
and several  smaller areas at the Site.  Some of the Site's ravines
served as disposal "ditches' for construction debris, old household
appliances,  auto bodies, unsalvageable metallic industrial
equipment, used tires, used drums, drummed wastes, and
uncontainerized liquid and solid wastes.  The 37.5-acre landfill
area, which  was composed of a hilly ridge with a ravine on each
side, was permitted by the Commonwealth of Kentucky to accept inert
industrial wastes from November 1973 to May 1989, although the
landfill area had had industrial waste placed in it since the
1950's.  The permit was not in effect continuously and several
violations occurred.  The landfill was operated by the property
owner, Mr. Leonard 0. Smith, Sr., until his death in 1969, and by
his son, Harlan Smith, until his death in 1978.  The current
landfill and property owner is Mrs. Mary Ruth Smith, whose nephew,
Buddy Mobley, has operated the landfill.

In 1984, following several inspections by USEPA and Commonwealth
regulatory personnel, an immediate removal of surface drums, which
contained hazardous waste, from the unpermitted disposal area (the
area addressed by Operable Unit One) was conducted by USEPA.  The
Smith's Farm Site was added to the National Priorities List in June
1986.

During the 1980's, the landfill owner contracted for the
installation of a small leachate collection and recirculation
system at the landfill at the insistence of the Commonwealth.
Leachate lines of perforated plastic pipe were installed in ditches
at the overburden/bedrock interface on the southeastern and
southern sides of the landfill.  The collected leachate went to a
surge /col lection tank and then to a large pump from which it was
pumped up to the central part of the landfill where it was sprayed
onto the surface of the landfill from several vertical plastic
pipes.  The  system was used only intermittently and then,
reportedly,  was shutdown before the 1988-89 Operable Unit One
Remedial Investigation because of air emissions problems and
complaints from residents of the mobile home park to the south of
the landfill.

Reportedly,  also during the 1980's, the landfill operator, in an
attempt to dispose of large volumes of scrap wood, set piles of
wood debris  on fire in the northeast and northwest quadrants of the
landfill.  Later the operator buried the smoldering wood debris in
an attempt to smother the fires.  The attempt to smother the fires
was not completely successful and over the next few years the
operator made subsequent attempts to smother the subsurface
combustion by bulldozing the areas.  During the 1990 Operable Unit
Two Remedial Investigation, infrared aerial photography indicated
that thermal anomalies  (surface soil temperatures of 75-80 degrees
Fahrenheit on a cool morning) still existed; one in the northeast
and one in the northwest quadrant of the landfill.

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In 1988, field activities for the Operable Unit One RI/PS occurred.
The RI for Operable Unit One determined that leachate seeping from
the permitted landfill contains several volatile organic compounds
(i.e., chlorinated aliphatics, ketones, a«d monocyclic aromatics)
and heavy metals.  The Unnamed Tributary stream sediments are
contaminated by extractable organic compounds  (i.e., polycyclic
aromatic hydrocarbons) and heavy metals which are attributable to
releases from the permitted landfill, as well as the unpermitted
drum disposal area.  Soil samples collected from a location next to
the landfill were also contaminated with extractable organic
compounds.

The permit for the landfill expired on May 10, 1989.  The
Commonwealth of Kentucky determined that the permit should not be
renewed because  (1) a completed permit application had not been
received  (Kentucky Revised Statutes Section"224.855}; (2) hazardous
substances had been released from the permitted landfill anri
therefore remedial action to control the release(s) was required
(Kentucky Revised Statutes 224.877); and  (3) information required
in order for the Commonwealth to re-evaluate the permit's renewal
would be available only through a Site study comparable to a
Superfund Remedial Investigation  (401 Kentucky Administrative
Regulations 47:020 Section 5).

The nature and extent of the releases from within the general area
of the formerly permitted landfill and the threat to human health
and the environment posed by these releases has been determined.
The potential for contamination of the deeper ground water by
leachate from the Operable Unit Two formerly permitted landfill and
the Operable Unit One unpermitted drum disposal area has been
investigated and has been demonstrated to be insignificant due to
the extremely low permeability of the underlying shale geology.
Therefore, the deep limestone aquifer is not being addressed by the
selected remedy in this Record of Decision.

2.0  ENFORCEMENT HISTORY

Although Operable Unit Two is being treated as a separate phase of
the investigation and remediation of the Smith's Farm Site, the
enforcement activities for both Operable Units are intertwined.

During the summer of 1984 general notice letters and information
request letters were issued and the search for potentially
responsible parties (PRPs) was initiated.  During the spring of
1987, RI/PS special notice letters were issued to the PRPs.  A 1984
removal, which was conducted at the area addressed by Operable Unit
One by USEPA Region IV Emergency Response authorities, is the
subject of an ongoing HgRCTiA Section 107 cost recovery suit.  In
March 1990, the Department of Justice  (DOJ) on behalf of USEPA
filed civil action No. C-90-0232-L(M) against the owner and four
(4) other PRPs who sent waste to the Site.  On February 7, 1992
four  (4) of the Defendants filed a CKRCLA-based suit against

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fifty-three  (S3)  other PRPS  in U.S. District Court, Western
District of  Kentucky at Louisville, attesting to  recover past,
present, and future remediation  costs for both Operable Units of
the Site.  The remediation schedule for the Operable Unit One area
is in the Remedial  Action (RA) phase under a March 14, 1990
Unilateral Administrative Order  (UAO) addressed to thirty-six  (36)
of fifty-seven (57)  PRPS and according  to a September 30, 1991
Amendment to the  September 29, 1989 Operable Unit  One Record of
Decision  (ROD) .   The UAO was amended three  (3) times to incorporate
schedule changes  due to the  accomplishment of the  ROD Amendment.
An Administrative Order by Consent  (AOC) for a Remedial
Investigation/Feasibility Study  (RI/FS)  of the Operable Unit Two
formerly permitted  landfill, and proximal Site areas, was signed by
only one  (1)  of fifty- seven  (57) PRPs on November  9, 1989.  The
RI/FS was completed in January 1992.  Upon completion of the
Operable Unit Two ROD, DSEPA will give  the PRPs an opportunity to
perform the  remedy.   If the  PRPs refuse to perform the remedy as
set forth in the  ROD,  USBPA  has  the option to order compliance
through a Unilateral Administrative Order  (UAO) or to undertake to
conduct the  Remedial Design  and  Remedial Action utilizing Superfund
money and later pursuing the PRPs for cost recovery under CBRCIA
Section 107.

Table 2.0 outlines  the Smith's Farm Site's remedial history.

3*0  HIGHLIGHTS OP  COMMUNITY
As with the enforcement  activities, the  community relations
activities for the two Operable Units or phases are interrelated.

The September  29,  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, including
the sampling and analysis of  water from  private wells, 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  and the preferred
alternative for cleanup  was held on April 11, 1989.  The purpose of
the meeting was to discuss  the alternatives considered for Site
cleanup aTi
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TABLE 2.0: SMITH'S FARM SITE REMEDIAL HISTORY
REMEDIAL INVESTIGATION/
FEASIBILITY STUDY
RECORD - OF -DECISION
REMEDIAL DESIGN/
REMEDIAL ACTION
REMOVAL
LITIGATION
OPERABLE
  UNIT
  ONE
*EPA-FUNDED!
 COMPLETED
 01/30/89
'ORIGINALt 09/29/89
* AMENDMENTt 09/30/91
*UAO»  03/14/90
*FINAL RDt
 03/31/92
*1984-85
 REMOVAL
*COST RECOVERY
 SUIT BY EPA
 BEGUN 1989i
 ONGOING
OPERABLE
  UNIT
  TWO
•CONSENT ORDERt
 11/09/89
*RI/FS FINALS
 01/13/92
*STATB NOTICE
 OF VIOLATION
 TO LANDOWNER
 FOR LEACHATB
 PROBLEMi
 09/12/91
 *FINALt
  09/93
•EXPECTED STARTi     *N/A
     12/93
         *COST RECOVERY
          SUIT BY FOUR
          PRPS AGAINST
          53 PRPS FOR
          RECOVERY OF
          CBRCLA COSTSi
           02/07/92

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same location.   Tri-City Industrial Disposal Site Proposed Plan
public meeting was  followed by the Smith's Farm Site meeting at
which the current status of both Operable Units was presented a
questions from the  public were entertained.   On July 15, 199 1,
USBPA published  a notice in a local newspaper describing the
purpose of a public meeting to occur on July 18, 1991, and opening
the public comment  period for the proposed fundamental change to
the Operable Unit One  ROD.  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.
Comments were incorporated  into the Responsiveness Summary for the
Operable Unit One ROD  Amendment which was signed on September 30,
1991.

On May l, 1992,  a Proposed  Plan Pact Sheet for Operable Unit Two
was mailed to more  than 130 interested parties.  On Kay 15, 1992, a
meeting notice was  printed  in the local newspaper; the public
comment period was  started  and the public meeting was set for May
21, 1992.  The public  comment period was from May 6, 1992 to June
8, 1992.  The public meeting occurred on May 21, 1992.  Media
coverage was provided  by local newspapers and television stations.

4.0  SCOPE AND ROLE OP THE  OPERABLE UNIT
            THE  SITE STRATBgY
Under certain conditions 'the remediation of the problem (s) posed by
a Superfund site can be more effectively dealt with in stages, or
operable units.  The Smith's Farm Site is approximately 460 acres
which includes an approximate eighty  (80) acre area of unpermitted
drum disposal, a thirty -seven and one -half  (37.5) acre formerly
permitted solid waste  disposal landfill, and additional areas of
suspected drum disposal.   In the summer of 1987, USEPA Region IV
and the Commonwealth of Kentucky defined an area  (the eighty  [80]
acre unpermitted drum  disposal area) that needed immediate
attention in the form  of an RI/FS.  This area appeared to be the
most potent threat  on  the  Site based upon the large number of drums
in the area and the suspected waste types present.  USEPA
determined that other  areas on the Site would be evaluated at a
later date depending upon  the results of the initial RI/FS.


During the spring of 1988  while the Remedial Investigation  (RI)
field sampling program was being determined, USEPA decided to defer
the investigation of the deep aquifers beneath the Site.  Among the
reasons for this decision  were the complexities of and the time
associated with implementation of a full hydrogeological study and
the reasonable premise that contaminants were being transported
primarily by surface water runoff and through shallow
hydrogeological pathways.   Meanwhile, sampling of private drinking
water supplies in the  area of the Site was performed quarterly from
the spring of 1988  until April 1990 and no degradation of ground

                                 8

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water quality was detected.

In the spring of 1989, the Commonwealth of Kentucky informed USEPA
Region IV of its decision not to renew the Smith's Landfill solid
waste disposal permit and requested that USBPA proceed with an
RI/FS of the landfill area.

Operable Unit One, authorized by the September 29, 1989, Record of
Decision, which was amended by the September 29, 1991, Record of
Decision Amendment, addressed the contaminated soils,.sediments,
surficial aquifer, and drums of the eighty  (80) acre unpennitted
drum disposal area.  Operable Unit Two addresses the thirty-seven
and one-half (37.5) acre formerly permitted landfill, the aquifers
underlying the landfill, and outlying, small areas of
contamination.  The contaminated media to be addressed by the
Operable Unit Two ROD remedy are the landfill wastes, the leachate,
the leachate sediments, and surface soils.
5.1  ENVIRONMENTAL SETTING

5.1.1  Climate.

The area has four (4) distinct seasons with average daily maximum
temperatures for Bullitt and Spencer Counties ranging from 41.7
degrees Fahrenheit in January to 88.7 degrees in July.  Average
daily minimum temperatures for the same months range from 21.1
degrees to 63.1 degrees, respectively.

The annual average precipitation is 55.5 inches and is fairly
evenly distributed on a monthly basis.  Snowfall generally occurs
during the months of November to March and is greatest in January
(10.6 inches average).  Total average annual snowfall is 18.5
inches .
5.1.2  flora ?»nd

The dominant vegetation type in the area is mixed deciduous forest.
This plant community is dominated by a large diversity of broad-
leaved trees in both the higher and lower tree levels.

The terrestrial portion of the Site varies in relative elevation by
between two hundred  (200) and two hundred and fifty  (250) feet.
The sharp slopes and narrow ridges allow for a variety of habitats
and species.  This Site is heavily vegetated with mixed pine and
hardwood forest growth, which appear to be twenty- five  (25) to
forty (40) years old, except for the landfill which  is covered with
dense grasses.  The nearby residences are also well -grassed.
Aquatic systems in the Unnamed Tributary are m-in-imai .  The bedrock
streambed is covered with sand, gravel, and cobbles.  Typically,

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the upper reaches of  the  streams have no flowing water.  High water
flows occur during storm  events and are of short duration.

Terrestrial fauna consist of the usual small mammals, reptiles,
birds, and amphibians associated with second and third growth
forests in the area.  A listing of flora and fauna and Endangered
and Threatened Species  can be found in Section 4.6.7 of the
Operable Unit Two Remedial Investigation.

5.1.3  Geoloov.

Underlying the Site is  the Mississipian-age Borden formation, which
in descending order includes the Eoltzclaw Silts tone Member, the
Nancy Member  (silty shale) , the Kenwood Siltstone Member, and the
New Providence Shale  Member.  The depth to bedrock onsite is
commonly four  (4) to  six  (6) feet, and rock 'outcrops have been
observed.  Underlying the Borden Formation is the Devonian- age New
Albany shale, which overlies the Silurian- age Louisville Limestone.
The Silurian and Devonian -age rocks crop out approximately one (1)
mile east of the Site.

The rocks underlying  the  Site are nearly horizontal; the regional
dip of the top of the New Albany shale is to the west at about 110
feet per mile.  No major  faults have been mapped by the U.S.
Geological Survey in  this part of Kentucky.  Some joints and
possibly small-scale  faults are expected to be present in the rocks
underlying the Site.     - •

5.1.4  Soils.

Soils of the area are loamy on the slopes and ridges, and gravelly
loam in the small tributary floodplains of the Site.  Soils are
either the product of weathering of the underlying bedrock, or are
derived from material washed downs lope from nearby source areas.

5.1.5
The evaluation of the Site hydrogeology involved several
investigative methods,  including  (1) rock coring and packer
testing,  (2) downhole geophysical logging,  (3) monitoring well
installation, and  (4) water level measurements .  These
investigations produced enough data to create a conceptual
hydrogeologic model  for the Site.

Geophysical logging  responses and drilling  observations suggest
that the thick sequence of shale, comprised largely of the New
Providence Shale and the New Albany Shale,  inhibits the vertical
percolation of surface  infiltration and provides a natural barrier
to the more prolific limestone aquifer below.  Ground water may
occur within isolated fractures, formational contacts and bedding
planes in the shales resulting from vertical infiltration of
recharge water, but  these zones do not appear to be very

                                 10

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interconnected.  This water does not appear to be under any
artesian pressure.

No monitoring wells were installed into the limestone aquifer for
the Operable Unit Two Remedial Investigation.  Information on the
water-bearing capacity of this unit has been gained largely from
the coring and test hole drilling in which approximately ten (10)
feet of the limestone section was penetrated.  Cuttings from the
air rotary drilling of the test holes generally were dry and
powdery through the shale sequences, until the limestone was
penetrated and water was blown out of the hole.  Vugs (pits) and
cavities were observed in the recovered limestone core which
provide the ground water storage capacity in the limestone.  This
data suggests that the limestone serves as the principal uppermost
aquifer in the area.  However, within the Bluelick Creek drainage
basin more domestic water supply wells have 'been completed into the
shales or siltstones than into the underlying limestone.
Therefore, while the shale or silt stone may be a regional confining
unit containing very poor quality water, a part of the lower and
more permeable zone in the shale may be considered an aquifer based
upon the local ground water withdrawal pattern.

Another hydrogeologic system in the area is the alluvial valley and
surficial soil /weathered bedrock setting.  Several shallow
monitoring wells were installed within the surficial soil and
weathered bedrock  (shale) during the Operable Unit One activities,
to a depth of approximately ten  (10) feet.  These shallow wells
intercept the shallow water that infiltrates through the surficial
soils and flows along the soil/bedrock interface.  This flow
discharges into the alluvial valley deposits, as evidenced by
numerous flowing lea chat e outbreaks observed along the Unnamed
Tributary streambank.  Flow within the alluvial water table aquifer
follows the direction of surface water flow in the valley stream.
In other words, flow is controlled by topography.

It seems likely, based upon the observed hydrogeologic properties
of the shales, that the majority of recharge water filtering
through the surficial soils, »™* forming the shallow or perched
water zone at the weathered rock/soil interface, flows laterally
and discharges into the major valley alluvial aquifers.  Some
recharge water infiltrates through vertical/near vertical fractures
in the shale and accumulates in areas where the fracture zones
tighten.  The volume of water present in the shale and the rate of
recharge is considerably less than the confined limestone aquifer
below.  The potential for vertical migration of significant
quantities of leachate present within the landfill through the
thick shale sequences to the limestone aquifer is not significant.
See Figure 5.1, entitled "Conceptual Hydrogeologic Model".
5.1.6  Sturfaee Water ?nfl "Pppocnraohv.

The Site topography is characterized by conical -shaped knobs which

                                 11

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                                                                                                           SOIL HORIZON
                                            THE KNOBS
      NEW PROVIDENCE
           SHALE
        NEW ALBANY
           SHALE
SELLERSBURG LIMESTONE/
  LOUISVILLE LIMESTONE
              LEGEND
                    BEODINC_PLANE FRACTURES WITH GROUND WATER


                    FRACTURES, JOINTS WITH GROUND WATER


                    SOLUTION CAVITIES IN LIMESTONE WITH GROUND WATER


                    SURFICIAL AQUIFIER (ALLUVIAL VALLEY DEPOSITS AND SOIL)
NOT TO SCAlf
                                                                                              CONCEPTUAL HYDRO-GEOLOGIC
                                                                                                        MODEL
                                                                                                      SMITH'S FARM
                                                                                                   OPERABLE UNIT 02 Rl
                                                                                                 BULLIT7 COUNTY. KENTUCKY


                                                                                                      PlOITRR  «;. 1

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are connected by long, narrow ridges and steep hillsides and
ridgetops.  The ridges and knobs are dissected by intermittent
stream channels and small flowing streams.  Ground surface
elevations vary from about 800 feet AMSL  (above mean sea level) on
ridgetops and knobs to about 500 feet AMSL along the valleys.

Operable Unit One is located along a narrow ridge in the
north-central portion of the Site.  Intermittent valley streams
flank both sides of the ridge and drain into a larger'major valley
stream channel  ("Unnamed Tributary") along the eastern side of the
property. The Unnamed Tributary drains into Bluelick Creek which
empties into Floyds Fork immediately south of the Site, then into
the Salt River further to the southeast.  The landfill is located
in the south-central portion of the Site.  A mobile home park
exists off of Pryor Valley Road south of the Site.

Land surface elevations within the formerly permitted landfill vary
from approximately 645 feet AMSL in the northwest corner of the
landfill to 618 feet AMSL near the large maintenance building on-
Site.  The ground surface elevation drops abruptly to approximately
545 feet AMSL east of the large maintenance building to the Unnamed
Tributary.  A small amount of surface run-off follows valley slopes
to the southwest into the intermittent tributaries which flow into
Bluelick Creek.  Figure 5.2 shows the Site drainage patterns, and
indicates that the Site is confined to a narrow watershed which
drains to the Unnamed Tributary and then into Bluelick Creek.

5.2  GEOPHYSICAL INVESTIGATION RESULTS

5.2.1  Areal Extent of the T-i»«dfill.

To estimate the horizontal limits of the landfill material, data
from several geophysical surveys were interpreted together.  In
many locations, there was a distinct contrast between the highly
anomalous data collected over landfill material and the background
soils and rock surrounding the landfill.  Figure 5.3 shows the
limits of the main landfill based upon  (1) total magnetic field
intensity, (2) magnetic gradient, (3) apparent conductivity, and
(4) electromagnetic in-phase disturbance.  Each line of
electromagnetic data was plotted versus distance.  These plots were
primarily used in the interpretation of the landfill boundary.
Contour plots of these data were used primarily for identifying
anomalies within the landfill and not for determining the boundary
because of the smoothing that occurs when generating contour plots.

5.2.2  Vertical Ext^t ef the L»"dfill.

The depth to the bottom of the landfill material was investigated
using (1) seismic refraction and  (2) electrical resistivity
techniques.  The depth of penetration of electrical resistivity
soundings was somewhat limited by the highly conductive and


                                 13

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       QUADRANGLE LOCATION
                                                                      BOUNDARY
                                                                             •.*•«**  A  f-L:
                                            'N7ERPRETED
	SECONDARY DRAJNAGE DIVIDE
	.	MAJOR DRAINAGE DIVIDE
            (WATERSHED BOUNDARY)
                                                                     PORTION  OF THE U.S.G.S.
                                                                       BROOKS  7.5-MINUTE
                                                                          QUADRANGLE
                                                                           SMITH'S FARM
                                                                        OPERABLE UNIT 02 Ri
                                                                      BUUJTT COUNTY. KENTUCKY
0           2000         4000

SOURCE: U.S. GEOL SURVEY 7.S-MMUTC
«JBFC /tn«Mw~»-~—
                                                                           FXGOKB  5.2

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  INTERPRETED AREAL LIMIT
   OT LANDFILL MATERIAL
BASED ON GEOPHYSICAL DATA


        SMITH'S FARM
    OPERABLE UNIT 02 Rl
  BULUTT COUNTY. KENTUCKY

       FIGURE  5.3

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                     .V
                     1.
     ISOPACM  MAP OF
    LANDFILL MATERIAL
      SMITH'S FARM
  OPERABLE WIT 02 Kl
BULUTT C(X(NTY. KENTUCKY
     FlSOB*  §.4

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           I
I
  H 2C0600
   2CCCOO  -r*
                          NOTE: CONTOUR MTERVAL 10 FEET
A
 V
N 19S80C
                                        LEGEND

                                   «70—• ESTIMATED P^
                                        TOPOCR*PMIC CONTOUR

                                   £•   POND
                                     PRE-LANDFILL
                                 TOPOGRAPHIC  SURFACE
                                                                                       SMITH'S FARM
                                                                                    OPERABLE UNIT 02 Rl
                                                                                 BULLJTT COUNTY. KENTUCKY

                                                                                     I  FIGURE  5.5



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variable subsurface material.  The soundings were used mainly to
provide qualitative information about the vertical distribution of
landfill material.  See  Figure 5.4 arvj Figure 5.5 which demonstrate
the depth of the landfill material and the estimated pre-landfill
topographic surface,  respectively.  The average depth of the
western portion of the landfill is approximately forty (40) feet.
The eastern portion's average depth is about thirty (30) feet.



Areas of concentrated metallic debris a™* high apparent
conductivity were located within the landfill.  These
interpretations are based on geophysical surveys:  (l)
electromagnetic conductivity  (EM-31 and EM-34 measurements), (2)
electrical resistivity,  and (3) magnetometry.  Contour plots of
each survey technique were  made using commercially available
software.  These contour plots, along with X-Y plots of the data,
were used to interpret areas containing larger amounts of buried
metallic material.  In the  Remedial Investigation, one contour plot
(with a contour interval that provided a reasonably uncluttered
figure) of each of the above techniques was presented.  For
brevity's sake only one  figure, Figure 5.6, is presented here.
Figure 5.6 shows contoured  apparent conductivity data and shaded
areas representing some  of  the more intense anomalies.  These
anomalies are interpreted to be due to buried iron or nickel in
greater quantity than other parts of the Site.
5.2.4
face Conductive
Based upon a preliminary analysis of geophysical data, a
concentrated search  for  a  conductive plume, possibly related to
ground water contamination was  conducted southeast of the landfill
area.  The search was made using the EM-31 conductivity meter.  The
interpreted plume may emanate from the landfill toward the
tributary.  It is reasonable to conclude that this plume is
discharging to the Unnamed Tributary.  Leachate outbreaks are
present at the soil/shale  interface along points adjacent to the
interpreted plume on the west side of the stream bank of the
Unnamed Tributary.



The purpose of the reconnaissance of the Unnamed Tributary was to
investigate areas of buried metal identified during the Operable
Unit One Remedial investigation/Feasibility Study.  This
reconnaissance was accomplished using an EM-31 device.

Anomalous zones were differentiated based on the occurrence of
metallic objects observed  on the surface.  The metallic objects
observed on the surface  included drums, vehicles, and other
material.  The anomalies in these zones are likely caused by the
surface metallic objects,  but buried drums could exist in these

                                 18

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                                            LEGEND

                                      ZONE OF APPARENT CCMXC-V
                                          ES TH»N :cc fwrr-j/ —
                                      ZONE OF APPARENT
                                      GREATER THAN 200 mmno»/n

                                      EM-31 SURVEY UNC

                                      APPARENT CONDUCTIVITY CONTC
                              EM-31 VERTICAL DIPOLE MODE
                           CONTOUR INTERVAL = 50  mmhos/m
                                  MAP OF  EM-31 APPARENT
                                       CONDUCTIVITY
                                       SMITH'S FARM
                                    OPERABLE UNIT 02 Rl
                                 BUU1TT COUNTY. KENTUCKY

                                     '  FIGURE  5.6
19

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areas, but were masked by the surface debris

5,2.6  infrared Th.ert"»i  Tm
During the course  of  the geophysical surveys, it became apparent
that a small amount of vapor was venting from cracks in the
landfill cover in  an  area northeast of the large maintenance
building.  The former landfill operator indicated that a smoldering
subterranean fire  was causing the venting.  This condition had
existed for several years and was the result of a wood fire that
the landfill operator had repeatedly attempted to smother with soil
cover.  An aerial  infrared  thermal survey was conducted.  Two
thermal anomalies  were identified; one in the northeast of the
landfill where the vapor vent was detected and a smaller, less
intense one in the northwest part of the landfill (Figure 5.7).

5.2.7  Radiological Survey.

Utilizing a surveyed  grid,  a radiation scan was performed over the
landfill on June 26,  1990.   An Eberline BSP-2 Smart Portable
instrument was equipped with detectors to measure gamma, alpha, and
beta radiation.  No significant variances were observed.

5.2.8  girtittnpjy of  Results.

The areal extent of the landfill was determined from a combination
of geophysical methods.  The interpreted areal extent of the
landfill is approximately twenty- nine  (29) acres, although the area
effected by the landfill is about thirty-seven and one-half  (37.5)
acres .

The seismic refraction work provided an estimate of landfill depth
and was used to construct an isopach  (i.e., an isogram that
connects points of equal thickness of a geological stratum
formation or group of formations) map of the landfill material.
The landfill was interpreted to consist of two filled ravines on
either side of a north- south trending ridge.  The interpreted
maximum depth of the  landfill is approximately sixty  (60) to
seventy (70) feet  in  the western ravine, and fifty  (50) to sixty
(60) feet in the northeastern ravine.

Within the landfill,  several areas interpreted to have substantial
quantities of buried  metallic material were identified.  The
location of these  areas supports the concept of two ravines of fill
on either side of  the landfill access road interpreted from the
seismic refraction data.

A potential conductive plume was mapped on the southeast side of
the landfill.  This plume seemed to lead from the landfill toward
the Unnamed Tributary.  Surface metal interfered with the
collection of electromagnetic  (EM) data in much of  the plume search
area.  Zones of surface metal and buried metal objects were

                                 20

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  +   LEGEND

"AXJUUU TEMPERATURE ABOV*  BACKCROUND

TEMPERA1UKC SKMnCANTLT ABOVE BACKGROUND

TEMPCKATUftC SUOftLY ABOVE  8ACKCROUNO
          INFRARED THERMAL
             IMAGERY MAP
            SMITH'S FARM
        OPERABLE UNIT 02
     BULLTTT COUNTY. KENTUCKY

           PZ60KB  5.7


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outlined near the Unnamed Tributary.  The landfill received a
variety of wastes during its operation over the years.  However,
information obtained  from Site files and from intrusive
investigations indicate that the volumetric majority of the
landfill waste is construction debris, inert industrial waste, and
municipal solid waste.  Specific efremjcal wastes and generic wastes
reported in the USBPA and Commonwealth of Kentucky Site files as
having been disposed  of in the landfill are listed in Table 5.0.
Many of these wastes  are hazardous substances, pollutants, or
contaminants.  Industrial/commercial wastes disposed between the
mid-1950's and the mid-1980's included: acrylic and enamel paint
wastes and sludges, various resin and epoxy wastes, waste grease
and oil from machining processes, waste solvents, flyash, metallic
sludges, sewage treatment grit, wood and paper packaging waste,
soil contaminated with petroleum products,  .commercial solid waste
from business offices, and construction debris (wood,-iron,
ceramics, etc.) from  demolished buildings.  These wastes were
deposited as both drummed and bulked liquids and solids.  Poor
documentation of disposed materials prevents an accurate assessment
of the actual locations where waste disposal occurred •*«<* the
volumetric quantification of the different categories which were
disposed.  Additional information regarding the Site's disposal
history can be found  in the Administrative Record and in the
Commonwealth's files  on the formerly permitted landfill.

5.3  COKTAMINATION XH THE STUDY AREA

Tolerance limits derived from background concentrations were
developed for inorganic constituents in the surface water, soil,
and sediment in order to allow for statistically significant
variations in the background concentrations of the contaminants of
concern.  Thus, a numerical limit was set for the acceptance of
higher background concentrations of soil contaminants.  Any surface
water, soil, or sediment sample concentration above the tolerance
limit for that particular chemical was considered significant and
an indication of contamination for the purpose of calculation of
risks.  Tolerance limits for soil were determined by adding the
mean concentration of the background samples for a particular
constituent in a particular medium to two times the standard
deviation from the mean  (XL • Mean +  (2 x Standard Deviation)).
This approach attempts to increase the confidence that
concentrations exceeding the tolerance limit are truly significant.
Due to the limited sample size for surface water, the maximum
observed concentrations from some sample locations were used as the
tolerance limits.  Ground water data was evaluated by comparing
detected constituent  concentrations to USEPA Interim Primary
Drinking Water Standards.

Analytical data from  samples from each media were compared to  the
appropriate tolerance limits.  Soil, surface water sediment, and
leachate sediment data were compared with the soil tolerance
limits.  Surface water and leachate water data were compared to the

                                 22

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                            TABLE 5.0

                 SMITH'S PARK - OPERABLE UNIT TWO

                     PARTIAL WASTE INVENTORY
        Generic Wastes

Asbestos
Adhesives, Sealers
Alkyd Resins
Adipyl Chloride/Reacted bottoms
 (organic,acids,surfactants,
phosphates)
Boderite    Sludge(zinc
phosphate,Cr,Pb)
Boiler Ash
Binders (epoxy,acrylic,
polyester,vinyl,urea,butyrate,
nitrocellulose)
Bleaching Clay (spent)
Clay/Waste Sludge
Coal/Dust Sludge
Coal DustEmulsion
Coating Grease,Cutting Oil
Diesel Fuel/Soil
Epoxy/Hydrocarbon Solvents
Foundry Mill Dust
Flyash
Grease Wastes
Ion Exchange Resin
Km    Polymer,KAC   Pellets,Kx
Polymer
Latex Paint wastes
Mineral Spirits
Nickel Sludge
Oil Separator Sludge
Plexiglass, Acrylic Plastic
Porcelain Enamel Frit
Paint Sludge
Plastisol Primer Waste
Pigments
Polyester Resin
Rubber Waste Hycar 1312
Resin 3003
Silica Gel
Sewage Treatment Grit
Sulphoric Acid Sludge
Zinc Sludge
      Specific Chemicals

Abietic Acid
Aluminum Phosphate
Biphenyl (Diphenyl) ("Downtherm
A")
DDT  (1,1  bis (4-chlorophenyl)
2-2-2-trichloroethene)
Diphenyl Oxide ("Downtherm A")
Dichloroethane
Dimethylcyclbhexylamine
Ethyl Benzene
Ethanolamine
Iron Phosphate
Mineral Spirits
Nitrocellulose
Polystyrene
Phenylmercurie Acetate
Phosphoric Acid
Sodium Hydrosulfite
Toluene
TEA  (Triethanolamine)
Toluene Diisocyanate
Vinyl Toluene
Xylene
Zinc Phosphate
                                   Source: USEPA and Commonwealth
                                           of Kentucky  Permitted
                                           Landfill Files
                                23

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surface water tolerance limits.  Ground water data were compared to
drinking water standards.  Samples with constituents exceeding the
tolerance limits were identified as having significant constituent
concentrations.

No background concentrations were derived for volatile organic,
semi-volatile organic, and pesticide/PCB constituents as these are
not naturally occurring.  Any concentration detected above the
Contract Required Detection Limit  (CRDL) was considered significant
enough to identify an area as having significant constituent
concentrations.  These areas were separated on a quantitative
basis.

5.3.1  Exploratory Trenching Results.

In October 1990, samples were obtained from two soil test borings
and several drums were unearthed during exploratory trenching to
help characterize the landfill wastes.

Sample STB-2 was a dark sludge obtained in the vicinity of a buried
drum area in the northeast portion of the landfill.  Sample STB-2
contains relatively high concentrations of several inorganic
constituents  (Table 5.2, Attachment 5.0) when compared to STB-4,
drum or leachate samples.  Analytical results from STB-4 and drum
samples, designated "TP", generally exhibited lower inorganic
concentrations compared to the soil test boring sample STB-2.
Observations made at the 'time of sampling indicate that each drum
may have contained a specific type of waste.  Therefore, high
concentrations of a variety of constituents were not expected.

PCB-1254 was detected in an oily sample obtained from location
STB-4 at a concentration of 1700 ug/L  (ppb).

Three groups of volatiles were the predominate organic constituents
detected in waste samples.  These groups consisted of  (l) benzene,
toluene, ethylbenzene, and xylene  (BTEX),  (2) trichloroethene, and
(3) the ketones, 2-butanone and 4-methyl-2-pentanone.  Analytical
results for the waste samples are summarized in Table 5.3,
Attachment 5.0.  The waste sample at STB-2 contained total volatile
organics greater than 15,000 mg/kg  (ppm).  The waste sample at
STB-4 contained total volatile organics greater than 12,000 mg/L
(ppm).  Most of the aforementioned constituents were detected in
these samples.

Samples collected from drum locations  ("TP") all contained less
than 100 mg/kg  (ppm) of total volatile organics.  The constituents
detected were limited to those previously discussed and varied with
the drum waste sampled.  Very few semi-volatiles were detected in
the waste samples.  Sample TP-D-1 contained 120 mg/kg  (ppm) of bis
(2-ethylhexyl) phthalate, suggesting this area may be a source for
this constituent.  Another drum sample, TP-F-1, contained 13-15
       (ppm) of total semi-volatile constituents.

                                 24

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The data, in conjunction with the absence of substantial
concentrations of inorganic constituents, suggest that the drummed
waste samples contain organic wastes.  The soil test boring samples
from the landfill contained an expected variety of organic and
inorganic wastes.

5*3*2  Iieachgfc** *yd Lea.chute Sed^Tt|°p^

Leachate and leachate sediment samples were collected in September
1990 and March 1991 from seven (7) of the leachate seep locations
shown in Figure 5.8.

Several inorganic constituents were detected in leachate water and
sediment samples at concentrations above the surface water and soil
tolerance limits, respectively.  This comparison was made to better
characterize the leachate as a contributor to migration of
constituents at the Site.  Analytical results for the leachate
water (LW) and sediment  (LS) are shown on Tables 5.5 and 5.6,
Attachment 5.0, respectively.

•  A similar group of constituents was detected in excess of the
   soil tolerance limit from samples LS-01, LS-02, and LS-03.  At
   least two of these samples each contained arsenic, barium,
   cadmium, calcium, lead, manganese and zinc in concentrations
   greater than the tolerance limit.  This suggests a-similar
   source such as run-off from the northeast area of Operable Unit
   Two which is known to 'contain a significant amount of buried
   wastes.

•  Results from LW-01, LW-02 and LW-03, taken at locations along
   the western bank of the Unnamed Tributary where leachate from
   the landfill was breaking through the overburden, indicate
   constituents such as aluminum, barium, calcium, iron, magnesium,
   manganese, sodium and zinc present at concentrations greater
   than the surface water tolerance limit, but with arsenic,
   cadmium and lead below the tolerance limits.  This suggests that
   these metals are adsorbing to the soil at these outbreak
   locations.

•  Several constituents exceed the tolerance limits at locations
   LS-05 and LS-06 and LW-05 and LW-06.  These locations are near
   the leachate collection tank and pumphouse for the old landfill
   leachate collection system which was installed by Mrs. Smith.

•  Leachate water sample LW-08, collected from within the landfill
   in an area of partially buried drums, contained the highest
   concentrations of several metals found in the leachate water
   samples.

No pesticide or PCS constituents were detected ip the leachate
water and the leachate seep sediment samples collected in the
vicinity of the landfill.

                                 25

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                                                                                                 V
  •i 200600
 N 203030
M 199400
                                                                             «.17B> [0.017]
                                                                             Bt.Cd.Ce.Co.
                                                                             Cu.FtPb.Ma.Mn
                LEAOUTI

            •   UEAOM1E

           U>i01 LEAOMTE
N 198800   4-
N 198200
   LEACHATE AND
LEACHATE SEDIMENT
  ANALYTICAL DATA
           e   TCW

         t. LISTED CONSTITUENTS	
           TQLOUNCC IMT5 POR SUWACE
           •ATER AND 500. AND THE OW.
                                                                                      SMITH'S FARM
                                                                                   OPERABLE UNIT 02
                                                                                BUULJTT COUNTY. KENTUCKY

                                                                                    FIGURE 5.8
                                                   26

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Several volatile and semi-volatile organic constituents were
detected in leachate water and sediment samples.  Analytical
results for the leachate water and sediment are summarized in
Tables 5.5 and 5.6, Attachment 5.0.

•  Low concentrations  (<100 ug/L  [ppb]) of trichloroethylene and
   other related constituents were detected in LW-01 and LW-02,
   suggesting a similar source for these leachate outfalls.
   Similar constituents were detected in LS-02, indicating a
   possible impact of the leachate water on the outbreak sediments.

Volatiles were detected in samples from LW-06 and LS-06 in excess
of 10,000 ug/L  (ppb) and 5 mg/kg  (ppm), respectively.  These
constituents are believed to originate from the landfill leachate
collection system.

Samples from LS-08 and LW-08 contained high concentrations of
volatile organic constituents.  It is probable that liquid waste
containing volatile organic chemicals is leaking from partially
buried drums in this area and is  causing the high concentrations.
Several semi-volatile constituents were detected in leachate from
the landfill.  The majority of these are polynuclear aromatic
hydrocarbons (PAHs).

•  Very high concentrations of semi -volatile constituents were
   detected at locations LW-08 and LS-08.  This location is within
   an area of buried drums' in the southwest quadrant of the main
   landfill.

A variety of PAHs were detected at locations LS-05 and LS-06.
Several of the same constituents  were detected at location SD-23,
sampled during the Operable Unit  One Remedial Investigation in the
vicinity of LS-05 and LS-06.  In  conjunction with inorganic data,
and considering that these sampling locations were near the
leachate collection tank, these data appear to represent a
composite of the leachate that drains from the landfill.

•  Several PAHs were detected in  the LS-03 sample while only a few
   were detected at LS-Ol and LS-02.  This suggests that although
   these three  (3) locations may  be affected by a similar inorganic
   source, a separate, smaller source of semi-volatile organics in
   the northeast area of the landfill may be affecting the vicinity
   of LS-03.

•  Overall, semi-volatile contamination is more evident in the
   leachate sediment samples.  This is expected as most of these
   constituents are immiscible in water and will accumulate in the
   sediment because of their greater density.
                                 27

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OSV-03/5»-;03
                                                                                       SURFACE «ATER SAMPLMG LOCATION
                                                                                       SHCAM SOMENT SAMflMC LOCADQN

                                                                               SV-01/S&-C1
                                                                                  O    3UMFACE 1M1DI AND STKEAH
                                                                                       SAMPlMC LOCATION
                                                                                  [ ]    1BT4L VCUMU OKtMCS. «f A •>
                                                                                       TOTAL XM-MCLATU OKAWC1 ««A W
                                                    /LOCATION SD-0« S APPROXMATGLT
                                                    ' 1200* SOUTHWEST OF LOCATION SO-C
                                                             /   \OL3M> tO.IJ]
                                                             /     WaCaBC|i^filMnM.
                                                                                      SURFACE  WATER AND
                                                                                        STREAM SEDIMENT
                                                                                        ANALYTICAL DATA
      SMITH'S FARM
  OPERABLE UNIT 02 Rl
BUUJTT  COUNTY. KENTUCKY
                                                                                          FIGURE 5.9
                                                        28

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5.3.3
Surface water and stream sediment samples from the Unnamed
Tributary were obtained during the two sampling events.  Sampling
locations are shown on Figure 5.9.  Samples from SW-01 and SW-02
each contained aluminum, iron, and manganese above the tolerance
limit.  Sediment samples from these same locations (SD-Ol and
SD-02) each contained barium, copper, and manganese above the
tolerance limit .  The data suggest that these two locations are
similarly affected by the intermittent stream flowing from the
southwest edge of the landfill.

Antimony, beryllium, cadmium, cobalt, nickel, vanadium, and zinc
were detected above the tolerance limit at SD-03.  Except for zinc,
these constituents were not detected in surface water samples from
the same location.  This suggests that location SW/ SD-03 is
affected by a different source than SW/SD-01 and SW/SD-02, and
these metals may no longer be migrating from the landfill in the
SH/SD-03 area.

Surface water samples SW-04 and SW-05 each contained a similar
group of constituents above the tolerance limit.  This group
consisted of calcium, iron, magnesium, potassium, and sodium.  Both
samples were obtained along the Unnamed Tributary and were
anticipated to produce similar analytical results.  Sample SW-04
also contained lead, manganese, and selenium slightly above their
respective tolerance limits.

Sediment samples SD-04 and SD-05, located along the Unnamed
Tributary south of the landfill, each contained concentrations of
barium, calcium, copper, magnesium, manganese, and nickel above
their respective tolerance limits.  In addition, sample SD-05
contained arsenic, cadmium, cobalt, lead, and zinc above the
tolerance limits.  This suggests that the two locations are
affected by the same source or sources and that the heavier metals
are adsorbing to the soil prior to reaching location SD-04 which is
located approximately 1,200 feet downstream of SD-05.

Pesticides and polychlorinated biphenyls  (PCBs) were not detected
in any surface water or surface water sediment samples obtained
during the Operable Unit Two Remedial Investigation.

Analyses for organic constituents in surface water and sediment
samples indicated several low  (< 30 ppb in water, < 1 ppm in
sediment) concentrations of constituents often detected as
laboratory contaminants.

The volatiles, 2-butanbne, 4-methyl-2-pentanone, and acetone were
detected in sample SW-04.  These ketones were also detected in
nearby leachate water sample LW-06.
                                 29

-------
Semi-volatiles were detected at SW-04 and SW-05 in total
concentrations of lie ug/L  (ppb) and 32 ug/L  (ppb), respectively.
Location SW-05 is likely affected by leachate outbreaks along the
Unnamed Tributary.  Constituent concentrations at SW-04 are
probably the result of migration from leachate outbreaks LW-05 ?nd
LW-06.

Several semi-volatiles were detected in sample SD-05, approximately
one hundred  (100) feet downstream of SW-04.  The total
semi-volatile concentration of 26.9 mg/kg  (ppxn) is considered the
result of migration from the existing leachate collection system
tank area for the landfill.  These immiscible constituents may be
adsorbing to the Unnamed Tributary sediments.  This is supported by
the absence of several of these constituents in nearby surface
water sample SW-04 a"3 a reduced variety and concentration of
semi-volatiles detected downstream at SD-04."

During the Operable Unit One Remedial Investigation, surface water
samples and sediment samples were collected along Bluelick Creek
and the Unnamed Tributary.  Surface water and sediment immediately
south of the landfill contain similar inorganic constituents above
tolerance limits established for the Operable Units One and Two
Remedial Investigations.  Concentrations in both investigations for
the sediments are similar; however, concentrations for surface
waters are higher for Operable Unit Two than for Operable Unit One.
PAHs are higher for Operable Unit Two in both surface waters and
sediments compared to Operable Unit One.

5.3.4  Surface fT*d S'^^snrfcLce Soil Cont*™^nation.

Surface and subsurface soils were sampled as part of the Operable
Unit Two Remedial Investigation at the locations identified on
Figure 5.10.  Samples were taken along the approximate perimeter of
the landfill to better define the landfill's extent.  Samples were
also taken at some distance from the landfill to determine the
constituents of background surface and subsurface soils.

Samples obtained from locations SS-03A, SS-05A, SS-06A, and SS-07A
each contained cobalt and manganese concentrations above the
tolerance limit *"•"* SS-05A and SS-06A contained lead above the
tolerance limit.

Samples SS-10A and SS-20A, obtained from the southeast edge of the
landfill, contained a similar variety of metal concentrations above
the tolerance limit, as shown in Figure 5.10 and Table 5.7,
Attachment 5.0.  It is probable that these locations are affected
by run-off from the southeastern area of the landfill.  Another
potential source is an old leachate collection system header that
extends along the eastern side of the landfill.

Concentrations in samples from locations SS-13A and B, SS-14A and
B, SS-15A, SS-16A, SS-17A, SS-18A, and SS-19A exceeded the

                                 30

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                               UOENO
                         SS-01A
                            * SOIL SAHPlKC LOCATION

                            < > TOTAL SM-«OL»1U OROAMC3. mg/t,

                            ( ] TOTAL VCLATU ORCAMC&. K^/kf
                            
-------
tolerance limit for at least one of the following: cobalt, copper,
manganese, vanadium, and  zinc.  These locations all along the
western side of the landfill, appear to have been affected by a
similar source.  Geophysical data indicated areas of high
conductivity in the proximity of SS-17A, SS-18A, and SS-19A.  The
material deposited in these areas is a likely source of the
measurable contaminants.  The source material may have consisted of
foundry wastes, pigments, or sludges which were disposed of at the
Site, according to documentation.

The sample from location  SS-19A, located closest to an area of high
conductivity and above normal background temperature also contained
concentrations of mercury and cyanide at 0.59 and 2.8 mg/kg (ppm),
respectively.  These constituents were not found in any other soil
samples collected as part of the Operable Unit Two Remedial
Investigation.

Several pesticides were detected at sampling location SS-20A
(Figure 5.10).  These detections indicate a possible area of
pesticide concentrations  localized around SS-20A.  This conclusion
is supported by the absence of measurable pesticides in all other
sampling media and sampling locations in the Operable Unit Two
area.

Several semi -volatile constituents were detected at five  (5) of the
surface soil sampling locations in the vicinity of the area
addressed by Operable Unit'Two  (Table 5.7, Attachment 5.0).
Analytical results indicated very low concentrations of volatile
organic compounds  (VOCs)  identified as laboratory contaminants.
Thus, only semi-volatile  data was considered in assessing surface
soil organic contamination.

Several polynuclear aromatic hydrocarbons  (PAHs) were detected in
soil samples from SS-7A,  SS-8A, SS-lOA, and SS-18A.  With the
exception of SS-18A, the  total semi-volatile constituent
concentration was less than 3 mg/kg  (ppm) at each of these
locations.  The total for these four  (4) soil samples exceeded 20
mg/kg (ppm) .  The data suggests that SS-7A, SS-8A, and SS-lOA are
probably affected by leachate from the outbreaks along the eastern
side of the landfill.  Additionally, SS-18A is probably affected by
a localized source, e.g., buried material in the northwest portion
of the landfill.  This contention is supported by the absence of
significant semi•volatile concentrations in nearby samples.

Analytical results for subsurface soils  (Table 5.8, Attachment 5.0)
indicate very small concentrations  (<0.1 mg/kg  [ppm]) of VOCs
resulting from laboratory contamination.  Thus, no significant
contaminant concentrations are  considered to exist in the
subsurface at the four  (4) subsurface soil sampling locations.
                                 32

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5.3.5  Ground Water
There are currently thirty- seven  (37) ground water monitoring wells
in place on the Smith's Farm property: twenty  (20) installed by
USEPA for the Operable Unit One 81; eight  (8) wells installed by
Mrs. Smith around the permitted landfill; and nine (9) wells
installed by Law Environmental, Inc., for the Operable Unit Two RI.

As part of the Operable Unit Two Remedial Investigation sailing,
ground water samples were obtained from five  (5) monitoring wells
located within the landfill  (MW-17, MW-21A, MW-22A, MW-22B and
MW-24B) .  The remaining monitoring wells, installed as part of the
Operable Unit Two investigation  (MW-21B, MW-21C, MW-23A, MW-23B and
MW-24A) , were dry during both sampling events.  See Figure 5.11.

The ground water in the intervals monitored 'by the above-mentioned
wells is classified as Class III by USEPA' s Ground Water
Classification System.  Water-bearing zones containing Class III
ground water either contain water with a total dissolved solids
content of greater than 10,000 mg/1 or yield less than 150 gallons
per day  (24 -hour period) per well, and typically are not considered
potential drinking water sources.  Generally, MCLs are not AHA&s
for Class III ground water systems, but may be ARARs under certain
conditions (See Section 9.2.2.3.) and certainly may be used as a
practical standard when no other standard is deemed pertinent.

Both barium and chromium 'exceeded the new Maximum Contaminant Level
(KCL) for ground water at MW-17, which has a depth of 8.5 feet and
collects liquid at the overburden/ shale interface.  However, based
upon the available leachate and waste sampling data and the various
indications of the shale's low permeability, barium and chromium
are not considered to be indicators of ground water contamination
from the landfill, but are considered to be indicators of leachate
and leachate sediment contamination from the landfill.

Only one common monitoring well, MW-17, was sampled in the two
remedial investigations.  Concentrations of several inorganic
constituents were higher in the 1989 Operable Unit One Remedial
Investigation.  In particular, cadmium and chromium exceeded
drinking water MCLs.  Lead  (136 ppb) exceeded the Safe Drinking
Water Act action level of 15 ppb.  Results from the Operable Unit
Two Remedial Investigation indicated that only lead exceeded the
appropriate standard.

The on-site background well, MW-21A, which has a depth of 34.95
feet, was compared with private residential wells in the area.
Generally the background concentrations of metals fell within the
range of concentrations found in residential wells.  Manganese was
detected in the background monitoring well at 475 ppb compared to a
        of 320 ppb in the residential wells.  Magnesium was
detected in the background well, MW-21A, at  144,000 ppb.  The
residential well concentrations ranged from  200  to 5,400 ppb.  With

                                 33

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      QUICK CEMETERY
        VALLEY STREAMS
         UNPERMITTED
         DISPOSAL AREA
         OPERABLE  UNIT 01
                 OVERHEAD POWER
                 TRANSMISSION LINE
INTERPRETED LIMITS
OF PERMITTED LANDFILL
    MAINTENANCE BUILDING
                                                                                                       I
                                                                                         ICGBND
                                                                                    MW-23A  -
                                                                                         WOMKMNC «CLL LOCATON
                                                                                     < > TOTAL SEIH-VCLATl£ ORCAItCS.

                                                                                     [ ]  TOTAL VOIADLE ORGAMCS.

                                                                                         POND
                                                                                l.TME 60UKOARY SHOWN AS OPERABLE UNIT 01
                                                                                  CORRESPONDS TO THE STUDY AREA BOUNDARY
                                                                                  .REFERRED TO M THE OU-1  (S/TS REPORT.

                                                                                2. LISTED CONSTITUENTS MERC UtlttlU)
                                                                                   ABOVE TK COOL AND THE U.S.  EPA
                                                                                   INTERIM PRIMARY ORMKMC WATER STANDARD.
~ MW-ftA IS CONSOERED TO BE THE
eACKOROUND SAMPUNC LOCATION.

 ACCESS ROAD
                                                                                        MONITORING WELL
                                                                                        ANALYTICAL DATA
                                                                                             SMITH'S FARM
                                                                                         OPERABLE  UNIT 02 Rl
                                                                                       BULUTT COUNTY.  KENTUCKY
                                                                                            FIGDHE 5.11

-------
the exception of magnesium, the background well results are very
similar to the residential well data.  Analytic results indicated
no concentrations of PCBs and pesticides in ground water above
risk-based levels.

5.3.6  firnmuiT'Y of f*^ie Cont*""^"• tioo in the Study Area.

Table 5.1 summarizes the concentration ranges of contaminants of
potential concern found in certain media in the addressed by the
Operable Unit Two Remedial Investigation.

Table 5.2 summarizes the exposure point concentrations for each
contaminant of potential concern in each medium for both current
and future land uses.

Other t-.han construction debris and municipal solid waste (MSW),
which composes the volumetric majority of the material in the
landfill, a wide variety of wastes were disposed of in the
landfill.  Samples from drums and waste unearthed during the
landfill trenching into a geophysical anomaly in September 1990,
reaffirm the presence of a wide variety of BTEX, ketones, VOCs, and
inorganics.  The same groups of chemicals and metals were found in
the leachate in the pumphouse leachate sump in August 1990 and
thereafter, although the heavier organics and the metals appear to
drop out of the leachate stream between the appearance of the seep
and the point at which the' seep flows into the Unnamed Tributary
east of the landfill.  The data suggest that the Unnamed Tributary
is minimally affected by the landfill leachate seeps that flow into
it, although some sediments are contaminated with low levels of
semi-volatile organic compounds and heavy metals.  The leachate
seep that drains the southwest quadrant of the landfill appears to
have a weak intermittent flow which has caused some sediments to be
contaminated with heavy metals.  Surficial and shallow subsurface
soils at the edge of the landfill are contaminated with low to
moderate levels of heavy metals  (e.g., cadmium, cobalt, copper,
lead, vanadium, zinc) and very low levels of semi-volatile and
volatile organic compounds.  The delineation of several
electromagnetic anomalies at greater subsurface depths and
trenching to a depth of approximately twenty-five  (25) feet near
the northwest thermal anomaly indicate that the landfill waste is
heterogeneous, with construction debris, residential and commercial
trash, rusted drums, *•*$ bulk industrial liquid and solid waste,
both nonhazardous and hazardous, having been mixed together.  The
volume of leachate which flows into the Unnamed Tributary is
directly related to the amount of rainfall which has occurred.

6.0  SUMMARY OF SITE RISKS

Actual or threatened releases of hazardous substances  from this
site, if not addressed by  implementing the response action selected
in this Record of Decision (ROD), may present an  imminent and

                                 35

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TABLE 5.1
SUMMARY OF COHCBNTRATXON RANGES O? CHEMICALS OF POTBHTIAL CONCERN BY MBDIOM
Smith's Farm. Operable Unit IVro
Brooks, Kentucky

ieal


Acetone
Antimony
Arsenic
Barium
Benzene
Benzo(a)pyreae
Beozo(k)fluoroanUieae
BerylEum
bis(2-Etbyl-hexyl)phtba]aie
(BEHP)
Cadmium
ajpn— Chlordane
Kami&a — Chtordane
2 — Chlorophenol
Chromium
p,p'-DDD
p,p'-DDE
p,p'-DDT
1.4— DfcbJorabenzene
3?'- Dichlorobeozidine
lichloroetbane
14 - Diehloroethene
Diehlorom ethane
2.4 - Dimethylphenol
2,6-Dmitrotoluene
Flaoranihene (PAH)
Hepuchlor epoxide
Isopborone
Lead
Manganese
N-Nilrosodi-n-propylamine
Nickel
Nitrobenzene
Pheoaothreae
Phenol
Pyrene
Thallium
Toluene
1,1.2 -Triuchloroethane
Trichloroetheoe
Vanadium

.»"* Not Delected
Below Detected Limits
Ground
Water
W)
8-63 B
30-69
2-17
100-3800
ND
ND
ND
2-3 BDL
7

ND
ND
ND
5.0-300
ND
ND
ND
ND
ND
ND
ND
ND
2.0-4.0
ND
ND
ND
ND
ND
2.8-140
7-480
5.0-11
13-43
ND
ND
ND
ND
5.0-15
ND
ND
ND
BDL



Surface
Water
into
4-180
30-74
ND
BDL
ND
ND
ND
ND
3- 6 BDL

ND
ND
ND
BDL
ND
ND
ND
ND
BDL
ND- '
ND
ND
ND
BDL
ND
ND
ND
2.0-5.0
2-5.1
21-2170
5.0-5.0
ND
ND
ND
5-57
8
ND
ND
2J-24
ND
ND



Stream
Sediments
(tasks)
.005-. 120 B
6^>-217
0.6-263
50-174BKG
ND
.165- L3
1.65-1.1
3-3-26.4
5.0-510

0
0.051-0.61
ND
5.0-900
5-37
ND
ND
ND
.065-0260
ND
ND
ND
.003-.O49
ND
ND
.093-5
ND
.12-.165
2.6-87
303-1550
ND
25.6-218
ND
.13-4
ND
.08-5
BDL
ND
ND
ND
23-59 BKG
ND


Leachate
Water
(art)
4.0-1.400,000
30-281
5-17
45-622
2J-310
ND
ND
2J-32
85.0-510

9
ND
ND
5.0-900
5-37
ND
ND
ND
ND
10-160
2J-1700
2J-1LO
2J-85400
5.0-1.600.000
5.0-10
ND
ND
2.0-4900
3.4-176
500-9190
ND
19-259
5.0-LSOO.OOO
ND
5.0-5.000,000
ND
ND
2.5-9200
5
2.5-120
9-50
3.01-9.0


Leacbate
Sediments

.005-25
30-84
8X-2L6
43-217
ND
.165-310
200
4.1-18.9
.165-1200

1.0-5.10
ND
ND
ND
14.1-62.2
ND
ND
ND
.14-22
ND
.003- L6
ND
.002-3.4
.165-90
ND
.095-940
ND
ND
13.7-65.4
262-1410
ND
32.6-144
ND
.029-910
22
.099-920
ND
.003-6300
ND
.003-3.1
24-53.2
ND


Surface
Soils

.005-.043
6-45 BKG
.94 -18 BKG
27-77 BKG
ND
0.13- LS
0.11- L2
6.1 BKG
_ .044-2J

.5-1.8 BKG
.015-44
.008- JM
ND
13-28 BKG
.008-. 058
.008-.023
.008-. 047 -
BDL
ND
ND
ND
.003-.011
ND
ND
.15-3.3
.004-. 006
BDL
6.4-58
127-1040
ND
103- 179
ND
.098-2.7
ND
.13-3.1
BDL
.002-.012
ND
ND
23-44 BKG
ND


Subsurface
Soils

.005-.04
32 -43 BKG
3.2-9.1 BKG
32J-49S
ND
ND
ND
4.2-6 J BKG
0.17- 1.1

.94-6J
ND
ND
ND
8J-37J
ND
ND
ND
.08-. 17
ND
0.01
ND
.003-.01
ND
ND
ND
ND
ND
9- 16 BKG
153-219 BKG
ND
27.7-36 BKG
ND
ND
ND
ND
ND
ND
ND
ND
31.8-64.1
ND


• At Background Concentration
36

-------
                                       TABIiE 5.2
                       ESTIMATED EXPOSURE POINT CONCENTRATIONS
                                Smith's Farm, Operable Unit Two
                                      Brooks, Kentucky
J
idium
Ground
Water
















nind
jter



















Land Uses/ Populations
Current land Uses:
nearby residents using residential
wells for potable water source







Nearby residents using residential
wells for potable water source






Future Land Uses:
on-site residents







On-site residents







On-site residents



'athways

>rinking Water
ngestion







Dermal Contact








Drinking Water
ngestion






Dermal Contact







Inhalation
(Shower/house-
hold use)

•arameter

Diethyl phthalate
Aluminum
Antimony
Arsenic
iarium
Lead
Thallium
Zinc

)iethyl phthalate
Aluminum
Antimony
Arsenic
iarium
Lead
Thallium
Zinc

Antimony
terium
Chromium
Lead
Thallium
Dichloromethane
^-Nitrosodi-n-propyiamine

Antimony
Barium
Chromium
Lead
Thallium
Dichlorome thane
N-Nitrosodi-n-propylamine

Dichloromethane
N-Nitrosodi-n-propylamine

exposure
Concentration
UCL
3.0 ug/L
3860.0 ug/L
63.0 ug/L
14.0 ug/L
286.0 ug/L
136 ug/L
15.1 ug/L
103 ug/L
UCL
3.0 ug/L
3860.0 ug/L
63.0 ug/L
14.0 ug/L
286.0 ug/L
136 ug/L
15.1 ug/L
103 ug/L
UCL
69 ug/L
3000 ug/L
230 ug/L
100 ug/L
13.0 ug/L
2.7 ug/L
7.1 ug/L
UCL
69 ug/L
3000 ug/L
230 ug/L
100 ug/L
13.0 ug/L
2.7 ug/L
7.1 ug/L
UCL
2.7 ug/L
7.1 ug/L

UCL   Upper Concentration Limit
                                                 37

-------
ESTIMATED EXPOSURE POINT CONCENTRATIONS
         Smith's Farm, Operable Unit Two
               Brooks, Kentucky
xnfidltZOl
fttCC

«itaer












rface
Water









Surface
Soils







.

\jmnA Uses/ Populations*
Cmrent Land Uses:

Nearby residents and trespassers

wading in Bludick Creek & its
tributaries.



Nearby residents using surface
waters as a potable water
source.
Nearby residents using surface
waters as a potable water
source.


Future Land Uses:
On-site & offsite residents
and trespassers wading in
Bluelick Creek and its tributaries.
Residents using surface waters
as potable water source.

Residents using surface waters
as potable water source.


Current Land Use:
Nearby residents & trespassers









Pathways


Dermal Contact
(Recreational use)



Drinking Water
ngestion

Dermal Contact'
(shower/
household use)
inhalation of volatiles
shower/household use)

Dermal Contact


Drinking Water
Ingestion

Dermal Contact
(shower/ house-
hold use)


Incidental Ingestion,









Parameter


Antimony
Mttnpanese
Esophorone
N-Nitrosodi -n-propylamine
1 , 1 ,2-Trichloroethane

Manganese
[sophorone
''l-Nitrosodi-n-propylamine
isophorone
N-Nitrosodi-n-propylamine

NA


NA




NA



NA

bis(2-Ethylhexyl)phthalate
Heptachlor epoxide
4,4'-DDE
4,4'-DDD
4.4--DDT
al pha-Chlordane
gamma-Chlordane
Phenanthrene
Manganese
Nickel
Exposure
Concentration


63.0 ug/L
2100.0 ug/L
5.0 ug/L
5.0 ug/L
19.0 ug/L
UCL
170 ug/L
5.0 ug/L
5.0 ug/L
UCL
5.6 ug/L
5.0 ug/L

NA


NA




NA



NA
UCL
900 ug/kg
6.0 ug/kg
23 ug/kg
58 ug/kg
47 ug/kg
40 ug/kg
40 ug/kg
560 ug/kg
470.000 ug/kg
65,000 ug/kg

-------
                 5.2  (continued)

ESTIMATED EXPOSURE POINT CONCENTRATIONS
        Smith's Farm, Operable Unit Two
              Brooks, Kentucky

xiium
diurface
Soils








Sub-
Surface
Soils



Land Uses/ Populations Pathways
-unire Land Use:
:uiure on-site residents,
Construction workers








•uture Land Use:
Future on-site residents,
Construction workers














Stream
Sediments









;uture on-site residents,
Construction workers




Future on-site residents,
3onstniction workers





Current & Future Land Uses:
Current nearby residents and
trespassers and future on-site
residents exposed while wading
in surface waters







Inhalation of
:ugitive Dust









ocidental Ingestion,




Dermal Contact




Inhalation of
Fugitive Dust





Dermal Contact



•


1
(
(
--J
*arameter

bis(2-Ethylhexyl)phthalate
leptachlor epoxide
4,4'-DDE
4,4'-DDD
4,4*-DDT
alpha-Chlordane
gamma-Chlordane
'henanthrene
Manganese
Nickel

>ichloromethane
1 ,4-Dichlorobenzene
Jarium
Chromium
Cadmium
/anadium
)ichloromethane
, ,4-Dichlorobenzene
iarium
Chromium
"Cadmium
Vanadium
Dichloromethane
1 ,4-Dichlorobenzene
Sarium
"tirotnnttn.
r^gHiniuni
•'•

Vanadium

Oichloromethane
1 ,4-Dichlorobenzene
3enzo(a)pyrene
3enzo(k)fluoranthene
bis(2-Ethylhexyl)phthaUte
Isophorone
Antimony
Arsenic
Seryllhun
"^ dfniunr
Chromium
Exposure
Concentration
UCL
900 ug/kg
6.0 ug/kg
23 ug/kg
C* O
58 ug/kg
O^ ^X>
47 ug/kg
O ""C1
40 ue/ke
^- U
40 ue/ke
C^"O
560 ug/kg
470,000 ug/kg
65,000 ug/kg

UCL
1.0 ug/kg
170 ug/kg
495,000 ug/kg
37,500 ug/kg
6,300 ug/kg
64,100 ug/kg
UCL
1.0 ug/kg
170 ug/kg
495,000 ug/kg
37,500 ug/kg
6,300 ug/kg
64,100 ug/kg
UCL
1.0 ug/kg
170 ug/kg ;
495,000 ug/kg !
37,500 ug/kg j
6,300 ug/kg =
64,100 ug/kg :
I I/^T
UCL
30 ue/ke
•*" O^ **O :
210 ug/kg ;
640 ug/kg
510 ug/kg
510 ug/kg
170 ug/kg
130,000 ug/kg
17,000 ug/kg
16,000 ug/kg
13,000 ug/kg
41,000 ug/kg

-------
         TABLE 5.2  (continued)

ESTIMATED EXPOSURE POINT CONCENTRATIONS
        Smith's Farm, Operable Unit Two
              Brooks, Kentucky

«ftiffrn
Surface
Soils




















Surface
Soils





















Land Uses/ Populations
Current Land Use:
Nearby residents &. trespassers










Nearby residents & trespassers









Future Land Use:

Future on-siie residents.
Construction workers









Future cm-site residents,
Construction workers









Pathways

' Dermal Contact










inhalation of
Fugitive Dust




•




Incidental Ingestion










Dermal Contact










Parameter

bis(2-Etbylhexyl)phthalate
Heptachlor epoxide
4,4*-DDE
4.4--DDD
4,4'-DDT
alpha-Chlordane
gamma-Chlordane
Phenanthrene
Manganese
Nickel

bis(2-EthyIhexyJ)phthalate
Heptachlor epoxide
4,4'-DDE
4.4--DDD
4,4'-DDT
alpha-Chlordane
gamma-Chlordane
Phenanthrene
Manganese
Nickel

bis(2-Ethylhexyl)phthaiate
Heptachlor epoxide
4,4'-DDE
4,4'-DDD
4,4*-DDT
alpha-Chlordane
gamma-Chlordane
Phenanthrene
Manganese
Nickel

bis(2-EtbyIhexyl)phthalate
Heptachlor epoxide
4,4'-DDE
4,4'-DDD
4,4'-DDT
alpha-Chlordane
gamma-Chlordane
Phenanthrene
Manganese
Nickel
Exposure

fi/^i
-U-CL
900 ug/kg
6.0 ug/kg
23 ug/kg
58 ug/kg
47 ug/kg
40 ug/kg
40 ug/kg
560 ug/kg
470,000 ug/kg
65,000 ug/kg
•••••••••
UCL
900 ug/kg
6.0 ug/kg
23 ug/kg
58 ug/kg
47 ug/kg
40 ug/kg
40 ug/kg
560 ug/kg
470,000 ug/kg
65,000 ug/kg
UCL
900 ug/kg
6.0 ug/kg
23 ug/kg
58 ug/kg
47 ug/kg
40 ug/kg
40 ug/kg
560 ug/kg
470.000 ug/kg
65,000 ug/kg
UCL
900 ug/kg
6.0 ug/kg
23 ug/kg
58 ug/kg
47 ug/kg
40 ug/kg
40 ug/kg
560 ug/kg
470,000 ug/kg
65,000 ug/kg
                    40

-------
         TABLE  5.2  (continued)

ESTIMATED EXPOSURE POINT CONCENTRATIONS
        Smith's Farm, Operable Unit Two
              Brooks, Kentucky

jdium
Leachate
Water






























Lf**chatr-










.


Land Uses/ Populations
Current & F11*11*1^ Land Uses*
Current nearby residents and
trespassers and future pn-site
residents exposed while -visiting
site











Future Land Uses:
Construction workers














Current & Future Land Uses:
Current nearby residents an
-------
                                           TABLE 5.2  (continued)

                                ESTIMATED EXPOSURE POINT CONCENTRATIONS
                                         Smith's Farm, Operable Unit Two
                                                Brooks, Kentucky




                                                             Benzo(«)pyrene
                                                             bis<2-Etnylhex)rl)phthalate
                                                             Fluonnthene
                                                             Toluene
                                                             Trichloroethylene
                                                             Pyrene
                                                             Arsenic
  160,000  Dg/kg
  590,000  ng/kg
  470,000  ug/kg
3,100,000  ng/kg
     12.0  ug/kg
  460,000 ug/kg
  20,000 ug/kg
   4,300
UCL    Upper Concentration Limii

-------
substantial endangexment to public health, welfare, or the
environment.  This determination is based upon the information and
conclusions presented in this ROD, including the following summary
of Site risks  (The Remedial Investigation Report, Volume III,
December 1991, contains the risk assessment, the ecological
assessment, and appendices, and is a part of the Administrative
Record for the Site . ) .

6.1  HUMAN HEALTH RISKS

A baseline human health assessment was conducted in order to
determine the effects of existing conditions (i.e., the presence of
inorganic and organic constituents at the formerly permitted
landfill and in proximal areas) on the exposed and potentially
exposed populations in and around the Site if no action _is taken to
remediate conditions at the Site.  The baseline risk assessment
provides the basis for taking action and indicates the exposure
pathways that need to be addressed by the remedial action.  This
section of the ROD reports the results of the baseline risk
assessment conducted for this site.  The human health risk
presentation herein conforms with guidance contained in the Risk
Assessment Guidance for Superfund: Volume I; Human Health
Evaluation Manual  (Part A)  (RAGS)  (Interim Final, EPA/540/1-89/002,
December 1989) .
6.1.1  Concur trat ions of Co*? fry**^ *>!*** fcs o£ **rt^
-------
water lines to the few remaining unconnected residences in the
area, the use of surface water for household use poses the most
immediate risk for off -site receptors.  However, the concentrations
of Site- specific contaminants found in the Unnamed Tributary
surface waters during several sampling »"«•* analysis events have
been determined to be insignificant.  The most substantial on- site
risks are associated with leachate »"* leachate sediment.
The future use of the land surrounding the Smith's Farm property is
expected to be residential.  The very knobby, hilly topography
could not easily support commercial development.  Additionally,
structures built on slopes or on hilltops would have to be anchored
into the bedrock and structures built in the ravines would be
subject to washouts during very heavy rains.  The Smith's Farm
property contains two major hazardous waste . disposal areas.  Each
will, after remediation, be maintained for at least thirty (30)
years.  While the remaining Smith's Farm property may be available
for residential or commercial development, this Record- of -Decision
calls for deed restrictions, groundwater-use and land-use
restrictions which will, along with the proximity of two hazardous
waste disposal areas, tend to retard development.

6.1.2  S^T1***"? TV Qf ReSllltB Of
The exposure routes considered are summarized in Table 6.0.

Special subpopulations exist.  Children and adults ride through the
Smith's Farm property on motorcycles and other types of
recreational vehicles utilizing access provided by a power line
easement which runs east -west across the northern part of the
Smith's Farm property.  Adults also use the property as a hunting
anfl target -shoot ing area.  Children sometimes play in the surface
waters of the Unnamed Tributary, both on anfl off the Smith's Farm
property; however, the surface waters are only deep enough for
wading even at high water.  The subpopulations are accommodated by
the major exposure scenarios and pathways described in Table 6.0.

The exposure point concentrations for the current ground water use
scenarios (i.e., use of residential wells for potable water by
nearby residents) are based on the analytical results for the
monitoring well that is closest to the trailer park  (MW-17) which
was sampled for the Operable Unit Two RI  (Although MW-23 is closer
to the trailer park, it did not produce water during either
sampling event.).  MW-17 is screened at the overburden rock
interface and intercepts a leachate flow which is moving towards
the Unnamed Tributary.  MW-17 is more than 1,000 feet from the
trailer park.  The contaminant concentrations in water from MW-17
represent the RME for the trailer park, even though no
contamination has been detected in the residential wells within the
trailer park.

The recreational uses of Bluelick Creek and its tributaries are

                                 44

-------
       xasuc  £.0

EXPOSURE ROUTES CONSIDERED
 Sana's Turn, Operable Unit Two
       Brooks, Kentucky
TIMEraAME%
Current


Current and Future

Future

Future
Current **A Future


Foture



Cnrrrnt md Form*


iiiiroMW
Ground Water


Ground Water



Ground Water
Surface Water


Surface Water
Surface Soils


Subsurface Soil


**e*rt6W^
On-Site


Off-Site

Off-Site and
On-Site

On-Site
On-Site and
Off-Site

-
On-Site and
Off-Site
On-Site and
Off-Site
*

On-Site


I-EXPOSORE^OCTE-I
Inr-rioo (drinkmf
water). Dermal Contact
((bewer/bouiebobl nae)
inr^~, (drinkBir
•^WT), Pfrmal '"Vrtirt
(shower/bousehold use)

Ingestion (drinking water)
water),' Dermal Contact
Dermal Contact (wading)
•
organic vapors
Demal Contact

Inhalation of Fugitive
Dust
P-niH inh,!^.^ .^
InmHitf1 Inertam

mm^n^m
P^FVH^I Ajfc,ft
p-iLfrjifjuui n^n.1

Rrodffl*!*! Adult
Pniilmtif 1 Child
Residential Adult

Constntctioo
Rif SKtfp*i»t Adult
Residential Child
Resideatial Adult
Residential Child

Construction
Wotkexs
Resideatial Adult
Residential Chil^*
Woriceis (Future
Only)
RraMnPitl Adult
Dj>ci>^«> drinking,
gtwpirjyip after
visiting the site.
Absorption of

*yp^**^ body parts
while visiting the
site.
Exposure to dust
from surface soils
disturbed while
visiting site.
Assumption:
No removal of
place on-site.



















             45

-------
        TABLE 6.0
          (cartoned)
EXPOSURE ROUTES CONSIDERED
 Smith's Farm, Operable Unit Two
       Brooks, Kentucky
TIME FRAME
Future
Current and Future
Future
Current nd Future
Future
MHOTMlS;

Stream
SfriJTTIfllt
-------
limited due to their size  (typically 8 to 15 feet wide downstream
of the landfill and 0.5 to 1 foot deep), although it is assumed
that residents may occasionally wade in, and children-have been
seen playing in the Creek.  There are no permanent surface water
intakes located along Bluelick Creek or Floyd's Fork  (Kentucky
Department of Health, 1990).  The flow to the Creek and its
tributaries is too low to support large aquatic life.  The
ingestion of fish from the Creek and tributaries was therefore not
considered as a potential exposure pathway for trailer park
residents in this evaluation.  Although the Unnamed Tributary flows
over bedrock and sediments are washed out and replaced after
storms, there are pockets of sediments in the Creek bed that will
be considered as exposure points in the risk assessment.

The Creek water may be used as a source of water for drinking,
bathing or washing.  A well is located adjacent to Bluelick Creek
due west of the permitted landfill and upstream of any areas
receiving drainage from the landfill.  A small electric pump was
observed in the Creek and upstream from the well.  The pump system
withdrew water from Bluelick Creek upgradient from the confluence
of Bluelick Creek and the Unnamed Tributary and delivered the water
to a residential lot via a pipeline  (LAW, 1991) .  The use of the
water is not known, although it is assumed to be used for household
uses.  While this small system is upstream of any potential Site-
related contamination, it illustrates the use of surface water as
potable water and the potential for similar uses downstream of
areas receiving run-off or* discharge from the Site.

Reportedly, hunting takes place on the Smith's Farm property.  Some
edible plants grow on the same property.  Therefore, there is a
potential for nearby residents and trespassers to ingest wildlife
that may have been exposed to Site contamination or to vegetation
that may have taken up Site contamination.  The ability of
contaminants to bioaccumulate in plant and animal tissue and the
extent to which they may bioaccumulate vary according to chemical
and organism exposed.  Site-specific data are not available to
adequately address the quantitative risk to such exposures.  A
survey to determine the type and volume of wildlife being hunted
was not performed, although it is assumed that doves and other
small animals are hunted occasionally for sport.  However, their
contribution to the diet of residents is expected to be minimal and
insignificant.  Therefore, these pathways were not quantified in
the Risk Assessment.

The next step in the exposure assessment is to quantify the
magnitude, frequency, ?r>d duration of exposure for the populations
and exposure pathways selected for quantitative evaluation.  This
step is most often conducted in two stages: first, exposure point
concentrations are estimated  (Table 5.2); then, pathway-specific
intakes are quantified.  Intake variables and exposure point
concentrations are selected so that the combination of all
variables results in an estimate of the reasonable maximum exposure

                                 47

-------
I
 (RME) for each pathway.  The RMB is the maiHunim exposure that is
reasonably expected to occur at a site.

Twenty  (20) potential exposure pathways were selected ?nfl
quantified in this assessment, including eight  (8) current exposure
pathways and twelve (12) future pathways.  The major pathways
quantified include the following:

Current Land Uses 	 Off-Site Residents

1.  Ingestion of drinking water
2.  Dermal contact while showering
3.  Inhalation of volatiles while showering
4.  Dermal contact with surface water and stream sediments while
    wadding
5.  Dermal contact with leachate water ««<* sediments while
    on-site
6.  Inhalation of contaminants in fugitive dust
7.  Incidental ingestion of surface soils
8.  Dermal contact with surface soils

Pu^y*"? i^nd Uses --- On-Site and Off-Site Residents

9.  Ingestion of drinking water
10. Dermal contact while showering
11. Inhalation of volatiles while showering
12. Dermal contact with leachate water and sediments
13. Dermal contact with surface soils
14. Inhalation of contaminants in fugitive dust
15. Incidental ingestion of surface soils
16. Dermal contact with surface water and stream sediments while
    wading

Future Land Uses 	 On-Site Workers

17. Dermal contact with surface and subsurface soils
18. Incidental ingestion of surface and subsurface soils
19. Inhalation of fugitive dust from surface and subsurface soils
20. Dermal contact with leachate water and sediment

Exposure point concentrations for each of the above-mentioned
pathways were determined based on the results of current monitoring
data from sampling locations on-site.  The exposure point
concentrations are multiplied by pathway-specific intake
assumptions to yield quantitative estimates of chemical intakes for
each pathway.  Exposure was quantified through the use of the
standard exposure factors and scenarios as defined in Human Health
Evaluation Manual. Supplemental Guidance: Standard Default Exposure
Factors (OSWER Directive 9285.6-03).  Table 5.2 summarizes the
exposure point concentrations for each contaminant of potential
concern in each medium for both current and future land uses.
Chemical-specific intake estimates are presented, by pathway, in

                                 48

-------
Section 3.0 and Appendix C of Volume III, the Risk Assessment, of
the Operable Unit Two Remedial Investigation Report.  Table 6.1
describes the major assumptions about exposure frequency ?nd
exposure duration.  More detailed information on the exposure
assessment may be found in Section 3.0 of the above-mentioned Risk
Assessment .
€.1.3  §*fiHm»-~f of the Toxieifcv Assessment of c?«t*Mlt'l"1"
-------
                                               TABLE 6.1

               MAJOR ASSUMPTIONS ABOUT EXPOSURE FREQUENCY AND DURATION
       EXPOSURE
     FREQUENCY
    ASSUMPTION
      DURATION
     ASSUMPTION
  RISK ASSESSMENT
      REFERENCE
Ingastion of Water
(OH and SW)
   2 Liters water/day
     350 days/year
Residential Adult & Child
30 years Residential Mult
 6 years Residential Child
   Table 3-3, p. 3-30 M
Inhalation of Volatiles
During Showers and
Household Use
(GM and SN)
     350 days/year
Residential Adult & Child
30 years Residential Adult
 6 years Residential Child
For inhalation dose factor
and other factors see Table
     3-4, p.  3-32 99
Dermal Contact During
Household Dse and
Recreation
(OH,  SN, and LN)
     350 days/year
Residential Adult & Child
30 years Residential Adult
 6 years Residential Child
   For skin surface area
 exposure assumptions and
other factors see Table 3-
      5, p.  3-33 99
Xngeation of Soils
(On-Site)
  200 mg soil/day Child
  100 mg soil/day Adult
     350 days/year
Residential Adult & Child
30 years Residential Adult
 6 years Residential Child
  Table 3-6, p. 3-36 99
                                 50 mg soil/day
                                 250 days/year
                               Occupational Adult
                                                   50

-------
                                                TABLE 6.1

               MAJOR ASSUMPTIONS ABOUT EXPOSURE FREQUENCY AND DURATION
       EXPOSURE
     FREQUENCY
    ASSUMPTION
      DURATION
     ASSUMPTION
  RISK ASSESSMENT
      REFERENCE
Inhalation of Fugitive
DuBtB  Prom Surficial Soils
(On-Site)
 20 mVday for 8 hour/day

     350 days/year
Residential Adult & Child
30 years Residential Adult
 6 years Residential Child
 1 year  Occupational Adult
  Table 3-7, p. 3-37 M
                                  250 days/year
                               Occupational Adult
Dermal Contact With Soils
(On-Site)
     350 days/year
Residential Adult & Child
                                  250 days/year
                               Occupational Adult
30 years Residential Adult
 6 years Residential Child
 1 year  Occupational Adult
  For skin surface area
 exposure assumptions and
other factors see Table 3-
      8, p.  3-39 
-------
media  (e.g.,  the amount of a contaminant(s)  of concern ingested
from contaminated drinking water)  can be compared to the RfD.  RfDs
are derived  from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g., to account for
the use of animal  data to predict effects on humans).  Chronic
RfDs/RfCs are specifically developed to be protective for long-term
exposures, i.e.,  seven years to a lifetime (seventy [70] years).
All exposures except childhood exposures in this preliminary risk
evaluation are assumed to be long-term.  The chronic RfDs/RfCs for
the chemicals of concern at this site are presented in Table 6.2
are derived  from USEPA's Integrated Risk Information System (IRIS),
1991.  The oral and inhalation RfDs shown in Table 6.2 are derived
from USEPA's Health Effects Assessment Summary Tables (EEAST,
1991).

Noncarcinogenic effects are characterized by comparing the
estimated chemical intakes to the appropriate RfD/RfC value.  The
RfD/RfC value is,  by definition, an estimate of a daily exposure
level for the human population that is likely to be without
appreciable  risk of deleterious effects during a lifetime.
Therefore, when the estimated chronic daily intake of a chemical
exceeds the  appropriate RfD/RfC, the ratio of exposure to toxicity,
there may be a concern for potential noncancer effects from
exposure to  that chemical.  The ratio of the chronic daily intake
to the chronic RfD/RfC is the "Hazard Quotient".  The sum of the


                 Non-cancer EQ - CDX/RfD

                 vhare:

                 CDI • Chronic Daily Intake
                 RfD - reference dose; and

                 CDI and RfD are expressed in the  same units
                 and represent the Mae exposure period
                 (i.e., chronic, subchronic, or short-tern).


Hazard Quotients for each chemical in a specific pathway is the
•Hazard Index (HZ) •.  By adding HQs for all contaminant (s) of
concern that affects the same target organ  (e.g., liver) within a
medium or across all media to which a given population may
reasonably be exposed, a Hazard Index can be generated.  It is
important to note that the Hazard Quotient does not represent a
statistical  probability; a ratio of 0.01 does not mean that there
is a one  (l)  in one hundred (100) chance of the effect occurring.
Rather, a Hazard Quotient greater than 1.0 indicates that the
•threshold"  for that chemical h?** been exceeded.  The chemical-
specific Hazard Quotient calculations are presented by pathway in
Appendix C of Volume III, the Risk Assessment, of the Operable Unit

                                  52

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. TABLI 6.2
CHRONIC HEALTH CRITERIA FOR
CHEMICALS OF CONCERN
Smith's Farm. Operable Unit Two
Brooks. Kentucky
Parameter
Acetone
Antimony
Arsenic
Barium
Benzene
Benzo(a)pyreoe
Benzo(k)
fluoroanthene
Beryllium
bls(2-Ethyl-
hexyl)phthalate (BEHP)
X
alpha-Chlordane
gamma-Chlordane
2-Chloropbenol
Chromium
j,p'-DDD
a,p'-DDE
j.p'-DDT
1 ,4-Dichlorobenzene
) ,3 •-Dichlorobenzidine
1. 1-Dichloroethane
1 . 1 -Dichloroethene
)ichloromethane
Methylene chloride)
NoncamnQffenie Criteria
Inhalation RfC Oral RfD
(mg/kg/d) (mg/kg/d)
ND
ND
ND
1E-4
-
-
• -
ND
ND
ND
ND
-
ND
2E-«
-
-
ND
7E-1
-
1E-1
ND
3E+0
1E-1
4E-4
IE-3
5E-2
-
-
-
5E-3
2E-2
' ' IE-3
(FOOD)
5E-4
(WATER)
6E-5
-
5E-3
5E-3
-
-
5E-4
ND
-
1E-1
9E-3
6E-2
Carcinogenic
Inhalation Slope
Factors
(mg/kg/d)-1
-
-
5.0E-2
—
2.9E-2
6.1
ND
8.4E+0
ND
6.1E-I-0
1.3E+0
I.3E+0
-
4.1E+1
NA
ND
3.4E-1
ND
ND
ND
1.2E+0
4.7E-7
C|QI> » Factnr^
Oral Slope
Factors
(mg/kg/d)-1
_
—
NA
—
2.9E-2
11.5
ND
4.3E+0
1.4E-2
ND
1.3E+0
1.3E+0
~
ND
2.4E-1
3.4E-1
3.4E-1
2.4E-2
4.5E-1
ND
6E-1
7.5E-3
i
Weight-of-Evidence
Classification
Inhalation/Oral


A/A

A/A
B2/B2
B2/B2
B2/B2
82/82
Bl/ND
B2/B2
B2/B2
B2/B2
A/ND
NA/B2
B2^2
B2^2
C/C
B2/B2
C/C
C/C
B2/B2
Note: neNaiieanmegaaeOHieTia.Iri>akaieril^iar^Or^
••«._ *• 	 : 	 r. «f 	 — - r_i.-f_^_ *» 	 f 	 1 ft 	 1 « 	 — - — >WM tlfmt~,t *•••• KFjlffT. 1991 fStf OO9e 4-14,
rktmlml mat aoaia*JJar *fa eratriam.
V>  Data art mat amiable.
•U   NotoppBeabic.
                                                            53

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., — ••» .
CHRONIC HEALTH CRITERIA FOR
CHEMICALS OF CONCERN ' ;
Smith's Farm. Operable Unit Two
Brooks, Kentucky
Noncarcinoeenic Criteria

Parameter

Diethylphthalate
2.4-Dimethylphenol
2.6-Dinjtrotoluene
Fluoranthene (PAH)
Hepuchlor epoxide
Isopborone
Lead
K£flnean*4Cfi
N-Nitrosodi-n-
opyUmine
Nickel
\
iniene
Pheaanthrene
Phenol
Pyrene
Thallium
Toluene
1 .1.2-Trichloroethane
Trichloroethene
/anadiiun
/inyl chloride

Inhalation RfC
(mg/kg/d)

ND
ND
*
ND
-
ND
ND
4E-4


ND

2E-3
*
ND
ND
ND
2E-I-0
ND
-
ND
—
Hale: T*t No*eani*ottmc Criteria, Uula&H KfC't and
v^.^ •• -* *T~_^. •* — - — • • .•—.-- •»___ 0

OralRfD
(mg/kg/d)

8E-1
2E-2
*
. 4E-2
-
2E-1
ND
1E-1


' " 2E-2

5E-4
*
6E-1
3E-2
7E-S
2E-1
4E-3
-
7E-3
-
Carcinogenic

Inhalation Slope
Factors
(mg/kg/d)"
-
-
ND .,
-
9.1E+0
ND
-
—
ND

8.4E-1

-
-
-
-
-
-
5.7E-2
1.7E-2
-
8.4E-5
Slope Factors

Oral Slope
Factors
(mg/kg/d)-'
-
-
6.8E-1
-
9.1E+0
4.1E-3
-
_
7.0E+0

ND

-
-
-
-
-
-
5.7E-2
1.1E-2
-
1.9E+0
Weight-of-Evidence
Classification
Inhalation/Oral



B2/B2

B2^2
OC
B2/B2

B2/B2

A/ND







ac
82^2

A/A
Oral tf>'*, ondemcdjmm HEAST. 1991 (Seepage 4-11, MUt Hiirmnt).
	 *^j f^i •• — •* 	 «.. jMmS**,i *«M to: A vr roor ^~* n<*m* *-i*
     KAAtteomou.).
     Oumieal not etoboud fur Air criterion.
•    Data an otaJeqiaiefor ytmrimriir rut
M7   Data an mot amiable.
•U   NotappBa&e.
                                                                54

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Two Remedial  Investigation.

USEPA assumes additivity of effects in evaluating noncarcinogenic
effects from a mixture of chemicals.  The  chemical-specific Hazard
Quotients are summed to yield an overall pathway Hazard Index;
pathway Hazard Indices are then summed to  yield a total risk for
each relevant population.  A sum totaling  greater than 1.0
indicates that the threshold or departure  point for that pathway or
pathway-population has been exceeded.

€.1.3.2  Carcinogenic Effects

Carcinogenesis,  unlike many noncarcinogenic health effects, is
generally thought to be a nonthreshold effect.   In other words,
USEPA assumes that a small number of molecular  events ra_« cause
changes in a single cell that can lead to  uncontrolled cellular
growth.  This hypothesized mechanism for carcinogenesis is referred
to as "nonthreshold", because there is believed to be essentially
no level of  exposure to such a chemical that  does not pose a finite
probability  of generating a carcinogenic response.

To evaluate  carcinogenic effects, USEPA uses  a  two-part evaluation
in which the chemical is first assigned a  weight-of-evidence
classification,  and then a Carcinogenic Slope Factor (CSF) is
calculated.   These Indices can be derived  for either oral or
inhalation exposures.  The weight-of-evidence classification is
based upon an evaluation -of the available  data  to determine the
likelihood that  the chemical is a human carcinogen.  Chemicals with
the strongest evidence of human carcinogenicity are denoted with
Class A, Bl,  or  B2, while chemicals with less supporting evidence
are classified as C or D.

                         USBPA Weight-of-Evidence
                        Classification System for
                             Carcinogenicity


                   Group                 Description


                    A
                    B                Probable human carcinogen
                     Bl              !,<-.«»«•* data are available
                     B2              Sufficient evidence in
                                     animals and inadequate or
                                     no evidence ^** ynimiipff
                    C                Possible human carcinogen
                    D                Hot classifiable as to
                                     human carcinogenicity
                    B                Evidence of noncarcinogenieity
                                     for humans
                                  55

-------
The Slope Factor quantitatively defines the relationship between
the dose and the response.   SFs have been developed by USBPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
contaminants of  concern.  SFs, which are expressed in units of
(mg/kg-day)*1, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day,  to provide an upper-bound estimate of the
excess lifetime  cancer risk associated with exposure at that intake
level.  The Slope Factor is generally expressed as a plausible
upper-bound estimate of the probability of response occurring per
unit of chemical.  The term •upperbound" reflects the conservative
estimate of the  risks calculated from the SF.  Use of this approach
makes underestimation of the actual cancer risk highly unlikely.
Slope Factors are derived from the results of human epidemiological
Studies Or Chronic  g^iTnal  bioaSSayS tO Which animal -t-o-an-iTnal
extrapolation »nd uncertainty factors have been applied (e.g., to
account for the  use of animal data to predict effects on humans).
The Carcinogenic Slope Factors for the chemicals of concern at this
site are presented  in Table 6.2.  These Slope Factors are derived
from USEPA's Health Effects Assessment Summary Tables (HEAST,
1991) .

For carcinogens,  risks are estimated as the incremental probability
of an individual developing cancer over a life-time as a result of
exposure to the  carcinogen.  Excess life-time cancer risk is
calculated from  the following equation:

                 Risk • GDI X SF

                 vhar*:

                 risk • a unities probability (e.g., 2 z 10*)
                 GDI » chronic daily intntea avaraged ovar 70
                      yaars (ag/kg-day)i and
                 SF -  alopa-factor, axprasftad as (mg/kg-day)'1

These risks are  probabilities that are generally expressed in
scientific notation (e.g.,  IxlCT* or 1E-06).  An excess lifetime
cancer risk of IxlO4 indicates that, as a reasonable maYinmm
estimate, an individual has a l in 1,000,000 chance of developing
cancer as a result  of site-related exposure to a carcinogen over a
70-year lifetime under the specific exposure conditions at a site.

6.1.3.3  Dermal  Exposures

No RfDs or CSFs  have been derived for dermal absorption.  Risks
associated with  dermal exposures may be evaluated with Oral
Absorbed Dose RfDs  or Oral Absorbed Slope Factors after dermal
exposures are converted to their respective absorbed dose.  Dermal
exposures were adjusted to absorbed dose estimates by assuming  that


                                  56

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the contaminants permeate skin at chemical-specific permeability
rates.  Permeability constants are listed on the Risk
Characterization Tables in Appendix C of the Risk Assessment,
Volume III, Remedial Investigation Report, December 1991.  Oral
RfDs and CSFs were also adjusted by the default oral absorption
rate of five  (5) percent, which was given in the Risk Assessment
Guidance (RAGS) and which gives an Absorbed Dose RfD or Absorbed
Dose CSF.  The Dermal Absorbed Dose intakes can then be compared to
Absorbed Dose toxicity values, as described in the Risk Assessment
Guidance for Superfund  (RAGS).


       Total Riak for ttlft Site.

The risk characterization integrates the results of the .exposure
and toxicity assessments into quantitative and qualitative
expressions of risk.  To characterize potential noncarcinogenic
effects, comparisons are made between the estimated chemical
intakes and the RfDs/RfCs for those chemicals; to characterize
potential carcinogenic effects, estimated chemical intakes are
multiplied by the chemical-specific Slope Factors to yield
chemical-specific dose-response information.  A summary of Site
major risks totals is set forth in Tables 6.3a and 6.3b.
Noncarcinogenic hazard indices totals greater than 1.0 also
indicate that remedial action may need to be implemented.
Carcinogenic risk totals for  each receptor greater than 1CT6 (or
greater than a l in 1,000,000 chance of getting a cancer solely
because of the described exposure) indicate that remedial action
may be called for.

6.1.4.1  Potential or Actual  Carcinogenic Risks

6.1.4.1.1  Current Carcinogenic Risks for Residential Populations

Surface Water - The carcinogenic risk from ingestion of surface
water by current residential  adults  (4 x 10^) exceeds the acceptable
upperbound risk range of 10"*  to 10"* chance of developing cancer as
a result of Site-related exposure to a carcinogen in surface water
over a seventy  (70) year lifetime under the specific exposure
conditions at the Site.  This n^gne an upperbound number, given the
concentrations of particular  contaminants and the exposure
described, out of ten thousand exposed humans, toxicologists would
expect that four  (4) additional or  "excess" exposed humans would be
inflicted with cancer.  This  risk is attributed to N-Nitrosodi-n-
propylamine, which was detected in  only one of three  (3)  samples
from locations potentially used for potable water sources.  The
reported concentration was estimated.  Additionally,  this
constituent was not detected  in any other medium at the Site.  The
exclusion of this data point  would  result  in a risk of  3  X  10' .
Additionally, the conservative assumptions used in the  calculation
of risk via this pathway  (i.e., one hundred  [100] percent of


                                 57

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TABU 6.3a:
Media; exposure
Types
Surface Water:
Residential
Ingestion
Dermal
Inhalation
Recreational
Dermal
Ground Water;
Residential

Ingestion
Dermal
Inhalation
Surface Soil :
Ingestion
Dermal
Inhalation
Subsurface Soil:
Ingestion
Dermal
Inhalation
Stream Sftfl««tTlfcff;
Dermal

Dermal
Leac*"'te Water:
Dermal
TOTALS (a)
SUMMARY OP BOHCARCZHOaXKZC RISKS - CORRECT AHD POTDU
Smith's Para • Operable Unit Two
Cy^x^^t Peculation
**"***f tlel Resident •!
Adult Child
Puture Papula t1**
Residential Residential Occupational
Adult Child Adult


0.01
0.002
NA*

0.5
0.003
NA*

0.05
0.001
NA*
0.02
0.002
NA*
NA
NA
NA

0.008
0.1
0.008
o.i .
NA


10
0.08
NA*
50
0.1
NA*
10
0.1
0.00004
60
0.2
0.00004
NA
NA
NA

0.1
2
0.02

NA -
NA
NA
0.1
5
0.07

NA
NA
NA
0.1
2
0.02
0.1
5
0.07

NA
NA
NA
NA
NA
NA
0.005
0.9
0.009

0.05
0.02
0.02

0.0003J 0.0*03
0.0003
0.003
0.004

0.04

300
300
0.4
0.04

600
700
•CK NUMn «• tiuud ladoB (HI*). HIM (iMUr tfci» 1* udial* • MMI&C
300
300
0.4

700
)00
0.5

3000
3000

58

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TABLE 6.3bs SDMKAKY OF CARCXNOG
Smith'* Faxm Sits •
Madia i
Exposure Types
aurfaea "Hater
Residential

Ingestion
Dermal
Inhalation
Recreational
Dermal
Qgoi|fid Water
Residential
Ingestion
Dermal
Inhalation
Surface Soil
Ingestion
Dermal
Inhalation
Subsurface Soil
Ingestion
Dermal
Inhalation
Stream Sediment
Dermal
Lsaehata Sediment
Dermal
Leachate Water
Dermal
TOTALS (a)
Residential Adult

BHXC RISKS - COSSSNT and FOTOSE
. Operable Halt Two
Tutwrt Pmiltti?r
Residential Adult Occupational Adult
-

4 X 10*
5 x itr5
NA*
4 X 10"*
5 X 10-5
NA*
NA
NA
NA

2 X lO*
2 X 10-6
NA
-

NA*
NA*
NA*

3 X 1Q-7
1 X 10-*
1 X 10-9
6 X ID"*
7 X 1(T5
2 X ID""
NA
NA
NA

3 X 10'7
1 X 10"
1 X 10'9
' 1 X 10"*
2 X 10*
2 X 10'"

NA
NA
NA
NA
NA
NA
3 X 10'"
4 X lO^8
2 X 10-7

2 X 10*
2 X 10"6
1 X 10"6

5 X 1(T*
5 X 10"*
2 X ID"4

2 X ID"5
1 X ID"3
2 X 10'J
1 X 10'3
7 X 10"6
2 X 10*
NA-N*i

                                   59

-------
I	
           drinking water comes from surface water sources) nay nave
           contributed to a high risk, as publicly supplied potable water is
           available to most residents.

           The carcinogenic risks to residential adults from recreational
           exposure to surface waters via dermal contact while wading and
           viadermal contact during showers ?TV* household use fall in the
           acceptable range.  Because of their insignificant concentrations in
           the surface waters, volatile organ!CB were excluded as chemicals of
           concern for this pathway, so there is no quantitative estimate of
           carcinogenic risk from current exposure to surface water via
           inhalation.

           Ground Water - There were no carcinogenic health criteria available
           for any of the constituents of concern evaluated for risk to
           current residents from the use of ground water as potable water.
           Therefore, there is no quantitative estimate of carcinogenic risk
           from current exposure to ground water via ingestion, inhalation, or
           dermal exposure.

           Stream Sediments - The risk of exposure to current residential
           adults and children via dermal contact with stream sediments falls
           within the acceptable cancer risk range.

           Surface Soils - The calculated carcinogenic risks for current
           residential exposure (adults and children) to surface soil via
           ingestion, dermal contact, and inhalation of fugitive dust are all
           within the acceptable range.

           Leachate Water - The current carcinogenic risk associated with
           dermal exposure to leachate water by residential adults falls
           within the 10"* to ICT* cancer risk range.

           Leachate Sediments - The current carcinogenic risk associated with
           dermal exposure to leachate sediments by residential adults exceeds
           the acceptable risk.  The calculated risk may be artificially high,
           as conservative assumptions were used in calculating dermal risk.
           Risk via dermal contact was calculated assuming one hundred (100)
           percent dermal absorption from the leachate sediments, and a five
           (5)  percent oral absorption efficiency in adjusting the oral RfD to
           a dermal RfD.  Additionally, the constituent concentrations
           detected in LH-08/LS-08 were extremely high and impacted heavily on
           the calculation of exposure point concentrations.  This sample
           location is located in an area of partially buried drums on the
           landfill.
                                            60

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6.1.4.1.2  Future Carcinooenie Risks for- Residential and
           Occupation?,] Adult Populations

Surface Water - The carcinogenic risk from ingestion of surface
water by future residential adults exceeds the acceptable 10"* to
10-6 risk range.  The greatest portion of the risk is attributed to
N-Nitrosodi-n-propylamine, which was detected in only one of five
(5) samples.  The reported concentration was estimated.  The
exclusion of this data point would result in an upperbound
carcinogenic risk of 3 X 10"7.

The carcinogenic risks to residential adults from exposure via
dermal contact with surface water used as potable water and from
recreational exposure to surface waters while wading fall in the
acceptable risk range.  Because of their insignificant
concentrations in the surface waters, volatile organics were
excluded as chemicals of concern for this pathway, so there is no
quantitative estimate of carcinogenic risk from future exposure to
surface water via inhalation.

Ground Water - The carcinogenic risk to residential adults from
potential use of on-Site ground water as drinking water exceeds the
acceptable cancer risk.  The greatest portion of the risk is
attributed to N-Nitrosodi-n-propylamine, which was detected in only
one (1} of four (4) samples  (MW-24B).  It was assumed that one
hundred (100) percent of an individual's drinking water comes from
ground water.  However, the ground water is of poor quality, the
aquifers under and near the Site having been classified "Class C"
or Class III, unsuitable for use as drinking water.  Publicly
supplied water is currently available to virtually all the
residences in the area.

Based upon current Site-specific data, the inhalation of volatiles
and dermal exposure during showering and household use by future
residents do not pose a carcinogenic risk.  Future risks associated
with ground water exposure do not involve the assumption that the
constituent concentrations will remain the same and do not account
for decay, degradation, and attenuation of contaminants over time.

Stream Sediments - The risk of exposure to future residential and
occupational adults via dermal contact with stream sediments
immediately proximal to the formerly permitted landfill falls
within the acceptable cancer risk range.

Surface Soils - The calculated carcinogenic risks for future
exposure of residential adults and children and occupational adults
to surface soil via ingestion, dermal contact, and inhalation of
fugitive dust are all within the acceptable range.  Based upon
current Site-specific data, there is no unacceptable carcinogenic
risk from exposure to surface soil via these pathways.

-------
Subsurface Soils  - The  carcinogenic risks to future occupational
workers from exposure to  constituents in subsurface soils via
incidental ingestion, dermal contact, and inhalation of fugitive
dust fall within  the acceptable range.

Leachate Water •  The future carcinogenic risks associated with
dermal exposure to leachate water by residential adults a
occupational works fall within the acceptable risk range.

Leachate Sediments - The  current carcinogenic risks associated with
dermal exposure to leachate sediments by residential *r\$
occupational adults exceed the acceptable risk.  Conservative
assumptions were  used in  calculating dermal risk and the
constituent concentrations detected in LS-08 impacted heavily on
the calculation of exposure point concentrations, as previously
discussed.  The calculation of future risks'assumes no attenuation
of constituent concentrations.

6.1.4.2  Noncarcinogenic  Risks.

6.1.4.2.1  Current Noncarcinogenic Risk

Currently exposed populations include nearby residents (adults and
children) and trespassers only.  The media-specific risks, by
pathway, are presented  as follows.

Surface Water - The chronic Hazard Indices total for ingestion of
surface water used as potable water and for dermal exposure via
wading gnd during showers and household use falls below the Hazard
Index departure point of  1.0 for both residential adults and
children.  Therefore, based upon current Site data, there is no
evidence of unacceptable  risks to persons using surface water for
bathing and household use, and for wading.

Because of their  insignificant concentrations, volatile organ!cs
were not selected as chemicals of concern for exposure via
inhalation during showers and household use.  Therefore, no Hazard
Index was calculated for  exposure via this pathway.

Ground Water - The Hazard Indices total for current exposure to
ground water via  ingestion by residential adults and children
exceed the departure point of 1.0.  Antimony and thallium pose the
greatest risk of  exposure to both receptors via this pathway, which
would otherwise be acceptable.  The use of MW-17 for the exposure
calculation is required,  but a conservative procedure, as it
contained the highest concentrations of all on-Site monitoring
wells sampled for the Operable Unit Two Remedial Investigation.
This well is screened at  the rock/overburden interface and
intercepts a leachate flow.  The use of this shallow water for
drinking water is neither advisable nor feasible.,
                                 62

-------
The risk of dermal exposure and  inhalation of chemicals  in ground
water used for potable water by  current residential adults and
children falls below  the  departure point of i.o.  Therefore, based
on current Site data, there is no evidence of unacceptable risks to
persons using surface water for  bathing, for household use, and for
wading.

Stream Sediments - The Hazard Indices total for exposure of current
residential adults and children  to stream sediments via  dermal
contact falls below the departure point of 1.0.  Therefore, an
unacceptable risk from current exposure to stream sediments does
not exist.

Surface Soils - The calculated Hazard Indices total for
noncarcinogenic effects of exposure of current residential adults
and children to surface soil via ingestion and via inhalation of
fugitive dust is below the departure point of 1.0.  Based upon
current Site-specific data, there is no unacceptable
noncarcinogenic risk  from exposure to surface soil via these
pathways.

The Hazard Indices total  for exposure of these receptors via dermal
absorption exceeds the departure point of 1.0.  The risk is
attributed to the presence of alpha- and gamma-chlordane detected
in one (1) surface soil sample.  The reported concentrations of
these constituents were analytically estimated.  Further, these
constituents were not found in any other media at the Site.  The
Hazard Indices total  for  dermal  exposure was calculated using the
idealized assumption that a one  hundred (100} percent dermal
absorption efficiency occurred.

Leachate Water - The Hazard Indices total for current
noncarcinogenic risk associated  with dermal exposure to  leachate
water by residential adults and  children exceeds the departure
point of 1.0 for acceptable risk.  Additionally, the constituent
concentrations detected in LW-08 were extremely high and impacted
heavily on the calculation of exposure point concentrations.  The
calculation of future risk also  assumes no attenuation of
constituent concentrations.

Leachate Sediments - The  Hazard  Indices total for current
noncarcinogenic risk associated  with dermal exposure to  leachate
sediments by residential  adults  and children falls below the
departure point of 1.0.

6.1.4.2.2  Future Noncarcinogenic Risk for Nearby Residents.
           On-site Residents, and Construction Workers

Surface Water - The chronic Hazard Indices total is less than 1.0
for ingestion gncl dermal  exposure during showers anri household use
and for recreational dermal exposure while wading for both
residential adults and children.  Therefore, based upon  current

                                 63

-------
Site data, there is no evidence of unacceptable systemic risks to
persons who may use surface water for bathing and household use,
and for wading.  Volatile organics  (VOCs) were determined not to be
chemicals of concern for this pathway.  Therefore, no Hazard Index
was calculated for exposure via inhalation of VOCs during showers
and household use.

Ground Water - The Hazard Indices total for future exposure to
ground water via ingestion of drinking water by residential adults
and children exceeds the departure point of 1.0.  The risk is
attributed to the presence of heavy metals in the ground water.
Reduction of constituent concentrations through decay, degradation,
and attentuation are not accounted for.  As previously discussed,
both the shallow and the deep ground water in this area is of poor
quality and undesirable as a potable water source.

The Hazard Indices total for inhalation of volatiles and dermal
contact with ground water during household use by residential
adults and children falls below the departure point.  Therefore,
based on the Site-specific data, there is no evident risk of
exposure via these pathways.

Stream Sediments - The Hazard Indices total for exposure of future
residential adults and children and future occupational workers to
stream sediments via dermal contact falls below the departure point
of 1.0.  Therefore, there is no unacceptable systemic risk from
dermal exposure to stream sediments.

Surface Soils - The calculated Hazard Indices total for
noncarcinogenic effects of exposure of future residential adults
and children and future occupational workers to surface soil via
ingestion, and via inhalation of fugitive dust is within the
acceptable range.  Based upon current Site-specific data, and
assuming no increase in constituent concentrations, there are no
unacceptable systemic risks from exposure to surface soil via these
pathways.

The Hazard Indices total for exposure of future residential adults
?nd children via dermal absorption exceeds the departure point of
1.0.  The risk is attributed to chlordanes detected in surface
soil.  The Hazard Indices for dermal exposure were calculated using
the required conservative assumptions.  The Hazard Index for
exposure of occupational workers to surface soil via dermal contact
falls below the departure point of 1.0.

Subsurface Soils - The calculated Hazard Indices total for
noncarcinogenic effects of exposure to future occupational workers
to constituents in subsurface soil via incidental ingestion, dermal
contact, or inhalation of fugitive dust falls within the acceptable
range.  Therefore, based upon current Site-specific data, and
assuming that concentrations will not increase in the future, there
are no unacceptable systemic risks from exposure to subsurface soil

                                 64

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via these pathways.

Leachate Water - The Hazard Indices total for future risk
associated with dermal exposure to leachate water by residential
adults and children and occupational adults exceeds the departure
point for acceptable risk.  The constituent concentrations detected
in sample LW-08 were extremely high and heavily impacted the
calculation of exposure point concentrations.

Leachate Sediments - The Hazard Indices total for future
noncarcinogenic risk associated with dermal exposure to leachate
sediments by residential adults and children and occupational
adults falls below the departure point of l.o.

6.1.4.3  Summary

The major carcinogenic risks for current residential adults are
from ingestion of surface water, dermal exposure with surface
soils, and dermal exposure with leachate sediment.  Secondary
potential or actual carcinogenic risks for current residential
adults are from dermal exposure to surface water and to leachate
water.  The major carcinogenic risks for future residential adults
are from ingestion of surface water, ingestion of ground water and
dermal exposure to surface soil and to leachate sediment.
Secondary carcinogenic risks are from dermal exposure to surface
water, ground water, and leachate water.  The major potential or
actual carcinogenic risk -for future occupational adults  (on-site
workers) is from dermal exposure to leachate sediment.

The major noncarcinogenic risk for all categories of human
receptors is from dermal exposure to leachate water; however, the
future occupational adult has a high risk associated with this type
of exposure.

Tables 6.4 a and b summarize the major Site risks based on current
and future land use, respectively.  Those are the immediate risks
to be mitigated by the selected remedy.  The tables include risks
for each chemical that contributes to a pathway that exceeds a 1 X
10"* carcinogenic risk or a Hazard Index of 1.0 or greater.
Chemicals contributing risk to these pathways are not included if
their individual carcinogenic risk contribution is less than 1 X
10"* or their noncarcinogenic Hazard Quotient is less than 0.1.

Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangennent
to public health, welfare, or the environment.
                                 65

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TABLE 6.4ai SUMMARY OF SITE RlbKS BASED ON CURRENT LAND USB
TOTAL
SXPOSURB
POINT
NeubjCurmt
RMldrattd FopuhtioB
(Aduttf and ChDdren)












EXPOSURE
PATBtOOf
iBgeatloB of Ground
Water/Driattnt Water*



Fktawaj ToUl
iBfMtfoB of Sarfm
Water/Drinklnc Water
(Adult and CUM)**
Pathway ToUl
Dermal Contact WhQa
Walking TbroD|h
iMchito Water
(RM!AmtUlAdnK«Dd
Child)



r»thw«y Total
Dermal ConUd White
Walkln( Tfcrou|h
Luchato Sedlmmta
(Rdtdentlal AdoH and
Child)
crarrwoNaNT
OP CONCERN
Aadmony
Arnnle
Barium
Thallium

N-NHraMdl-B-
propyuniiiw

2-CUorophnol
J,«-
Dborthjlplunol
Nhrobcuen*
nnol

Bnuo(a)p7rtiw
GDI
(mg/kg-day)
I.TXl^NoBcuc
9.1 X 1C* C
3.« X 104 NoBctm
I.RXIO'C
7.7Xl»*NoiMaic
3.7 X l»« C
4.1 X I04 Noncare
2.0XI»'C
•
«.0 X 19* Cue

IJXlO'NoBtaic
S.»XI04C
lJX10*NoBeaic
2.»X1»'C
(JXlfNoneare
LSXIO'C
IJXlO'Nonurc
4.1X10'C

2.03 X104 Care
SP
	
	
	
	

7.0

2.5 X104
IXlfr*
	
	

2JX101
CANCER RISK
(GDI x SF)
	
	
	
	
	
4.1 X 10*
4.2 XIO4

I'
	
	
	 i
4.7 XIO4
RfD
(ng/kg-
day)
4 XIO4
1X10*
5X10*
7.0 X I04
	
	
	
JJXIO4
1X10*
2.5 X 104
3X10'
	

NONCANCKR
BQ
(CDI/BJED)
4JA
20 C
0.4 A
1.1 C
OJA
0.7 C
5.1 A
M.OC
10.7 A
50.5 C
	
	
2.4 C
12 A
250 A
410 C
1.4 C
MJ.OA
(13 JC

66

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TABLE 6.4as SUMMARY OF SITE RISKS BASED ON CURRENT LAND USB
TOTAL
EXPOSURE
POINT







flora of ToUl Biporan
MutlUiki
EXPOSURE
PATHWAY

Nthwiy ToUl
DenMlCoeUetwWi
SnrflebJSolb
(RwldentUl Adah and
CbOd)



f.th««j Tout

CONTAMINANT
OF CONCERN
BUU-EthjIhexjl)
pBthtbto

BUU-EthjUiexjI)
pfcthiUU
4,4'-DDT
Alphi cklordiiM
Gunmi ehlordan*


CDI
(ag/kg-day)
7.4»xio4cuc
t.nxio*c

«.I7X10*NoBe»re
l.«7X10« Smllh't Farm pnpntj.
Net«li Hi* «(»v» ubb b • . If tie tbk for •« bdHdud «rdno»«nk coudhirat la • ptthw*; b (rattar Una or eqoil to 1X 10",
      Ibra It b Bitod. IfUiaiUBUBrfeiKlBeewileibkfortgJvwpithw^UiiwtorUiiuier^qiultoJXlO4, thenhUk«p«. If th« kuard qadtnt for u lodMdtul Boounbogtak
      ceiudbiml U • (wthwaj b »ra*Ur than or *qu«l to 0.1, lien U b Uitod. If the kuard Index for • glvra pathwij b (rotter Ibu or •qnal to 1.0, then h b kept. Cuthofnk
      rkk BDmbat Udlut* Ik* IneramnUl ontM Bhtlroe unoer rbk. Hitird ladOM (HIi) |mtor Ihtn 1.0 Indlute • il|BlAunt cbuH* (kit noiK«Rli>ocenlc BUBUB hcdtK rffat* wffl
      occur §l«n the dowribed tnporarM.
Note 2i The louree of the Slope Fieton b BEAST.
                                                                          67

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TABLE 6.4b« SUMMARY OF SITE RISKS BASED ON FUTURE LAND USB
TOTAL
EXPOSURE
POINT
Neufcj Pbtnr»
Rntdratlil rbpulrfoa
(AdnhiudCUMnn)












EXPOSURE
pATomr
lactation of Ground
W«tcr/DrlnHn|WttM*





Maw.y Total
Itenul Contact White
Walking Through
LMduto Water
(ItoldcntUI Adult ud
Child)



nthwiy Total
Dtrmil Contact WhO*
Walking Through
Luehato Sedlmnti
(ItoldcntUI AduK and
ChDd)
CONTAMINANT
OP CONCERN
Antimony
Amok
Btrfam
OiromhiBi
••Nhratodl-n-
propjUmlM
Thifflura

l-Chlorophenol
»,«•
DimHhjIphenol
Nltrobtueoc
nnol

Benio(i)p;r«ix>
CDI
(mg/kg-day)
MXlifNonttic
».OXI»»C
4.3 X IV Manure
2.1 X If C
«.1XIO*NOBUK
S.OXIO'C
«J X 10* NODUR
3.0XI»'C
•.SXlO^NoDure >
MXlVC
4.1 X IV Nonauc
2.0X10*C

I.«XI««NOMUC
MXIVC
IJXtO'Nonurc
J.»X10>C
< 3 X 10* NOBUK
I.$XIO*C
IJXIO'Nonurt
4.2 X 10* C

2.03 X I04 Circ
SP
	
	
	
	
7.0
	

2.5 X 10*
IX 10*
	
	

13\l
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TABLE 6.4bi SUMMARY OF SITE RISKS BASED ON FUTURE LAND USE
TOTAL
EXPOSURE
POINT










Vttun Omp«ri(»il
(Adah)





EXPOSURE
PATBHAY

rwhw«?Taut
DtnulCMUdwttfc
SariUJSolb
(RmUntbl Arfuft uc)
Cktld)






rtlkwuj Total
DmulCMUctWUI*
W«lH»t Through
LMthiteMlBnt*
(Ompitlmu) Aduh)
Itlkwty TaUl
DtnulCMtartWth
UKfciUWkO*
WorkU« On-Sft*
(Onaip^loul AduH)



GONZAMZKUIT
OF CONCERN
BtiU-ElkjftMTl)
phtlifjito

BbU-ElkrlknjI)
pfcthikl*
BtpUcUor •podefe
M'-DDE
4,4'-DDD
4.4--DDT
Alpha cfclordjoe
G«mm> chlonluc

B«Bio(i)nraa*

DtchlorooxtfcuM
l-CUorojAwd
NHrabmutm
Kmol
CDJ
(Off/kg -day)
1.49 X ID4 C.rc
1.58 X 10^ C

«.I7 X 10* NOBUK
I.C7X 10* C
I.7«X l«'CiK
«.T« X 10' C.re
1.71 X It4 C.re
3.21 X I04 NOBUR
1.70 X 104 C
1.74 X 10* Nonc.ix
7.40 X I04 C
2.74 X I04 Noauic
7.40 X 10* C

0.7 X 10' C.re

2.1 X If Noatut
2 J X IV NOBUIC
•.1 X 10* NOBUR
2J X 10' NOBUK
SP
2.0 X 10'

2.0 X 10'
1.02 > 10*
(.00
4.00
4.00
2«
2*

1JXIOP

l.S X 10*
	
	
	
CANCER RISK
(GDI x SP)
2.1 X 10-
4.7 X 19*
	
3.2 X 10*
4.6 X 10'
0.2X10*
	
	
	
0.« X 10*
2.0 X 10*
2.0 X I04
•
	
	
	
RfD
(mg/kg-
day)
1.0 X 10*
—
1.0 X 10*
—
—
—
1.50 X 10*
3.00 X 10*
3.00 X 10*
	
—
	
3.0 X 10*
2.SXI04
2.S X 10*
3.0 X 10'
MONCAJVCKR
HO
(CDI/RfD)
	
	
0.2 C
	
	
	
O.I A
0.4 C
0.*A
2.SC
0.»A
2.5 C
2.0 A
s.cc
	
—
0.7 A
0.*A
3,200 A
7.5 A
69

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TABLE 6.4bi SUMMARY OF SITE RISKS BASED ON FUTURE LAND USE
TOTAL
Riposms
POINT

AIM*/ Total
lUrfdMtUlJUd
Oerap«tl*u] Bipolar*
MatUtki
ttxposms
PATBHAY
htkwai Told

CONTAMINANT
OP CONCERN


GDI
(mg/kg-day)


SP


CANCBR RISK
(COX x SF)

1.4 X !»'
RfO
(mg/kg-
day)

"1——
MDNCANCRB
HO
(CDI/RfD)
3.2M.I A
J.4M.IA
«7»JC
A       AdaH
C       CUM
Cue    Cardau*»»J>
Noacan NoacardBOfeak


•     Makl are anoclltxl wMh lamina  oveHjurden/rotk lalcrfM* to utok
      ludflD toMktto flOTrb« la*«rd* Ik* UUMOM! IXbutarj.


•*    Mhlu an mntUtert whk l«j«»lln« of turfM witor from ik* Ununwl TribuUrj »d Blurikk Crack dowutmm from Ik* Smllk'i Firm property.
Niteli It* abev* Ubta k • MBUUT el Slle cardiocMk **d loBurdaognk rilkf.  If Ik* rilk for «B Individual cardnoajtnk wnitftuenl In a patkway U (raalcr Ikan or equal to I X IB1, lk»
       k It Iftod.  U Ik* nauiMd (ajdiof^ik rilk for a ()«•• palkway U (raator Ifcin or equal to I X 10*, Ikan It U kept. If Hie kuard quodent for IB Individual BOB*airlnoa>enk
       majllliiaal b a patk»ir b |n*t*r tkia or equal to ».l, Ifcea h b UiM.  If Ik* baiard ladoi for a aj«e oatkwa* b (reator tkaa or equal to 1.0, tkea It b kept. CarHnapnle
       rbk •BBDan tedkate Ik* bwiMantal *xe*M HTedn* taaear rbk. Uaiard Indexea OD») greater Ikaa 1.0 Indicate a iltnlfieaat ckaece Ikal aoDurdaoceok kumaa kealtb ttTerU
       •O oetar ajven Ik* 6>*crU>ed *«po>ur*i.
Not* It 1W aourw oflk* Slap* Farton b BEAST.
                                                                              70

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6.2  EBTVTRONUEZZTAL EVALUATION

Potential ecological receptors present  in the vicinity of the Site
and potential pathways by which these receptors might be exposed to
chemicals of concern present in surface soils, leachate, surface
water, and stream sediments were identified.  Risks to
environmental receptors arising from exposure to Site constituents
were characterized.  Potential receptors are: terrestrial
vegetation, terrestrial wildlife, endangered and threatened
species, aquatic wildlife, and aquatic  vegetation.  For additional
information on endangered »"<* threatened species, see Section 7.6.2
herein.

Sources of uncertainty in the determination of the ecological
qualitative risk assessment include:(a)  confidence that all key
contaminants were identified and
    quantified accurately;

(b) dependence on toxicity data which are the foundation for
    all health-based ARARs and which are based on animal
    experiments and epidemiological  study groups;

(c) confidence in the identification of all exposure parameters
    and exposure pathways appropriate to the site;

(d) uncertainty in the comparison of site concentrations to
    ARARs by which additive effects  may be overlooked;

(e) confidence in the identification and characterization of
    the exposed populations, both current and future, and the
    land use, both current and future;

(f) qualitative risk assessments which  rely on background
    concentrations and chemical-specific ARARs are somewhat
    limited in that they cannot account for cumulative toxic
    effects from several chemicals or several exposure routes; and

(g) the imprecision of present scientific data on exactly what
    constituent concentrations pose  a hazard to environmental
    receptors.

6.2.1

Any negative impacts on terrestrial  flora and fauna by the
contaminants of concern are not readily apparent.  Aquatic life in
Bluelick Creek and the Unnamed Tributary may potentially suffer
negative impacts from constituents currently detected in leachate
water and leachate sediment which discharge to surface waters.
However, the natural character of the streams and pools, i.e., the
intermittent flow and the poor water quality, does not readily
support aquatic life.  Tables 6.5 and 6.6 compare surface water and

                                 71

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surface water sediment quality criteria to existing concentrations
in these  two media.  Terrestrial and riparian  communities
periodically utilizing intermittent streams  for a water source or
habitat may be negatively impacted by constituent concentrations in
stream waters, sediments and leachate reaching surface waters.  As
the rate  of flow is generally low in intermittent streams adjacent
to the Site,  the level of exposure is expected to be low to
moderate.   Based upon seasonal flow rates, surface water impacts
are expected to be minimal.

6.2.2


Effects upon endangered and threatened species in the Site area
have not  been detected.  If a threatened or.endangered species is
identified as a receptor, or potential receptor,  then the
Ecological Risk Assessment will be revised to  consider the Site-
related impacts on an individual of the status species.   The U.S.
Department of the Interior, Fish and Wildlife  Service,  has not
granted a release from potential environmental damages under the
Endangered Species Act or under any other law  or  regulation.
TABLE 6.5
COMPARISON OF SURFACE WATER CONCENTRATIONS (95% UCL) TO WATER
QUALITY CRITERIA -FOR THE PROTECTION OF AQUATIC LIFE
Parameter
1, 1,2-Trichloroe thane
Ijophorone
H-Hitrosodi -n-propylamina
Antimony
Manganese
95% KM*
UCL" ABC««
(ug/L) (ug/L)
19.0
5.0
5.0
63.0
2,100.0
--
--
--
'
--
FAWQC *••
for Protection of
Aquatic Life
Acute (ug/L) Chronic

117,000
5,650
9,000
--
9,400
--
--
1,600
--
•  TJCL

•• KNNAHC

••• FAWQC
                Confidence Limit

         • Kentucky Warm (Surface) Water Aquatic Habitat Criteria

         • Federal Ambient Water (Surface Water) Quality Criteria
          for Protection of Aquatic Life
   ug/L   - micrograms per liter or part* per billion (ppb)
                                  72

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COMPARISON OF SBD]
Of COHTJuUMANTS re
TABLE 6.6
OSEETT QDALXT7 C&ZTERZA
JtJHD ZH THE UKNAMED TR.

TO CuiNCJiblTitATXOHS
IBUTASY'S SEDIMENTS
95 % IJCL* HOAA LKTRC's ••
Contaminants Concentrations (mg/kg) (ag/kg)
1,4-Dichlorobenzene
Benso (a) pyrene
Benxo(k) fluoranthene
Bis(2-Btbylhexyl)
phthalate
Fluoranthene
Xcophozonc
Phanantbrene
Pyrena
Oiebloromethana
Antiaony
Araaole
Beryllium
Cadmium
Gu?flni.mi
Laad
Manganese
Hickel
Thallium
0.21
0.64
0.51
0.40
1.70
0.17
1.60
2.20
0.03
130.0
17.0
" " 8.9
13.0
41.0
61.0
1077.0
839.0
0.13
HX
0.4
HA
HA
0.6
HA
0.22
0.35
HA
2.0
33.0
HA
5.0
80.0
35.0
HA
30.0
HA
                Confidence Limit

••  Rational Oceanic and Atmospheric Administration  (HQAA)
    Low Effects Threshold Range Concentrations  (LBTRC's)  for
    sediments  are To-Be-Considered  (TBC)  criteria

•g/kg - milligrams per kilogram (parts per million)
                                    73

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7.0
In the Operable Unit Two Feasibility Study numerous alternatives
for remediation were developed and then screened based upon five
(5) pif*-for categories of action: l) no-action; 2) institutional
action; 3) containment; 4) treatment; and 5) disposal.  An
individual analysis of alternatives was then made against two  (2)
tt7rf*ffT*Tld evaluation criteria; 1) overall protection of human
health and the environment and 2) compliance with ABARs.  Surviving
alternatives were subjected to a comparative analysis of the
alternatives based upon five  (5) modifying evaluation erifcariat 1)
long-term effectiveness and permanence; 2) reduction of toxicity,
mobility, and volume through treatment ; 3) short-term
effectiveness; 4) implementability; »"<* 5) cost.  This process
resulted in five  (5) manor types of remedial aetipnp being retained
for further consideration:  1) no-action; 2) limited institutional
actions; 3) RCRA-type cap, actions in peripheral areas, actions in
electromagnetic anomalies; 4} collection and treatment of leachate;
and 5) actions to extinguish thermal anomalies.
These five  (5) manor types of remedial actions wef^ gy'bdivided into
a total of fourteen  (14) subtypes based upon site -specific
applicability, known availability, and proven performance; remedial
action types 3}, 4), and 5) above were comprised of five  (5), four
(4), and three  (3) subtypes, respectively.  A summary 'of  these
fourteen (14) subtypes, including their respective capital costs
and thirty  (30) year O&M costs, is presented in Attachment 7.0.
Prom these subtypes f ive (51 al t ernat ives were constructed.
Alternative I was no-action, a baseline alternative which is
required to be evaluated.  The other four  (4) alternatives
addressed the different threats at the landfill to varying degrees
and in different manners.  In May 1992, Alternative III was
presented to the public »"d Kentucky as USEPA's proposed  plan for
cleanup.  After the public comment period and Kentucky's
concurrence with the proposed plan, two  (2) additional criteria
were assessed: 1) state acceptance and 2) community acceptance.
Alternative III was selected as the remedy taking into
consideration the threshold evaluation criteria, the modifying
evaluation criteria, and comments from the community and  the
Commonwealth of Kentucky.  A description of each of the five  (5)
alternatives which were considered follows.  A more detailed
description of the alternatives can be found in the final
Feasibility Study Report for Operable Unit Two, located in the
Administrative Record.

7.1  ALTERNATIVE I - NO ACTION
There would be no treatment under  this  alternative.

7.1.2
There would be no containment  efforts under this alternative.
                                 74

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7.1.3
The no-action alternative provides for a range of activities from
no-action whatsoever  (i.e., the  "do nothing" approach) to the same
package of institutional actions which are components of
Alternatives II, III, IV, and V.  Prom a practical standpoint the
landfill would, at the very least, have to be monitored.  It would
be realistic and appropriate to order that the leachate seeps,
surface waters, and monitoring wells be monitored. For the purposes
of this discussion, however, no action means that no additional
actions would be taken.

7.1.4  Ma -lor ARARs.

This alternative does not comply with RCRA Subtitle C landfill
closure requirements, because there would be no  cap/ cover and no
leachate collection and treatment system.  The State requirements
which reflect those in RCRA Subtitle C would not be satisfied
either.  RCRA LDRs would not be a factor because landfill
electromagnetic anomalies would not be excavated and, therefore,
placement would not occur.  The leachate seeps would not be
remediated; therefore, the federal and state Ambient Water Quality
Criteria (AWQC) for surface waters would probably not be satisfied
where the seeps entered the Unnamed Tributary.   The substantive
requirements for a Kentucky Pollution Discharge  Elimination System
(KPDES) or National Pollution Discharge Elimination System (NPDES)
permit would not be able -to be met with only physical treatment of
leachate.  The landfill thermal anomalies would  not be remediated
and landfill consolidation would not occur, so the National Ambient
Air Quality Standards  (NAAQS) of the Clean Air Act  (CAA) would not
be pertinent.  Monitoring ground water quality for comparison to
the Safe Drinking Mater Act  (SDWA) Kfl'"-im"" Contaminant Levels
(KCLs) and surface waters for comparison to federal and state AWQC
would probably be required.

7.2  ALTERNATIVE IX - LEACHATE COLLECTION AND TREATMENT

7.2.1  Treat"*** OTit CoHtpon*Pti

A leachate collection system as described in Figure 9.1 and in
Attachments 7.1 ainfl 7.5 would be constructed.  Perforated piping in
gravel -lined ditches along the east and south sides of the landfill
will collect gr^ direct leachate to a leachate treatment plant at
the southeastern corner of the landfill. near the Unnamed Tributary.
Collected leachate would be treated only by physical processes,
such as sedimentation anrf filtration, and the effluent discharged
on- site to the Unnamed Tributary.  The substantive requirements of
a KPDES  (NPDES) permit would, nevertheless, have to be met.
The subsurface thermal anomalies would be remediated by excavation
and open air combustion until extinguished.  A water spray could
also be used to hasten the quenching of the thermal anomaly.


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7.2.2
A leachate collection and treatment system as mentioned in Section
7.2.1 above would be constructed to intercept, collect, and contain
leachate moving through waste towards the Unnamed Tributary, and
other areas downgradient from the landfill (See Figure 9.1.).

No consolidation of landfill material would be undertaken.  No new
cap/ cover would be installed.  The surface of the landfill would be
left as is.  Leachate would be contained within the leachate
collection and treatment system.  Sludge from the leachate
collection and treatment system would be containerized ?*"* properly
disposed of.
7.2.3  G^^cral C"T>OP*>T>ts.

Monitoring of the leachate treatment system effluent would be
performed monthly for the first year after construction is
complete, quarterly for the second year, and semi -annually
thereafter for the next twenty-eight (28) years; however, this
monitoring schedule may be modified by USEPA during the Remedial
Design phase.  Sampling and full -scan  (TCL/TAL) analysis of
Operable Unit Two ground water monitoring wells would be performed
semi -annually for the first five  (5) years and then annually for
the next twenty -five  (25) years.  The frequency and character of
sampling and analysis may be modified by the USEPA at any time.

A perimeter fence, lockable gates, warning signs and other security
measures would be installed around the landfill and the leachate
treatment plant.

Hater-use restrictions for ground water and surface water would be
imposed in the immediate area of the landfill.

Deed restrictions would be imposed to restrict future land-use.
The landfill and the immediate area should not be utilized for
residential or commercial building.

7.2.4

This alternative would comply with some, but not all of the BCRA
Subtitle C requirements for landfill closure.  The requirement for
a cap would not be satisfied, because there would be no cap.  The
surface of the landfill would be left as is.  However, leachate
would be collected and subjected to physical treatment processes
only.  Therefore, the federal and state AWQC  (CWA) for organics in
surface waters would not be satisfied at the point in -the Unnamed
Tributary where the discharge would occur.  The use of only
physical leachate treatment processes would allow many organics to
move through the treatment machinery and be discharged into the
Unnamed Tributary; thus, the substantive requirements of a KPDES
permit, which is based upon AWQC and other criteria, would not be

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satisfied.  The landfill thermal anomalies would not be remediated
and there would be no consolidation of the landfill's peripheral
areas, so the CAA NAAQS would not be invoked.  Long-term monitoring
of Site ground water, surface water, and the XPDBS discharge would
be accomplished.

7.3  ALTERNATIVE III - CONSOLIDATION OF LANDFILL WASTE, CAP AND
                       COVER, LEACBATE COLLECTION AND TREATMENT

7.3.1
A leachate treatment plant incorporating physical treatment  (such
as filtration and aeration) and chemical treatment systems  (such as
the addition of polymers and aluminum sulfate to promote
coagulation) would be built to the southeast of the landfill.
Leachate treatment effluent would be discharged on- site to the
Unnamed Tributary.  The substantive requirements of a KPDES  (NPDES)
permit would, nevertheless, be required to be met.

The subsurface thermal anomalies would be excavated and allowed to
open air burn until extinguished.  A water spray may be used to
hasten the elimination of the combustion.

7.3.2
A leachate collection and treatment system as described in Section
7.3.1 above and in Attachments 7.2 and 7.5 would be constructed to
intercept, collect, and contain leachate moving through waste
towards the Unnamed Tributary, and other areas downgradient from
the landfill  (Figure 9.1).  Sludge from the leachate collection and
treatment system would be containerized and properly disposed.

Contiguous Areas A and B  (Figure 9.0) would be consolidated within
the landfill and the surface of the landfill would be contoured.
The areal extent of contamination in Areas A and B would be
determined by a thorough surface and subsurface grid sampling
effort during the Remedial Design phase.

A RCRA-type cap and cover with engineered run-on and run- off
systems would be installed over the approximately thirty  (30) acre
area which constitutes the main landfill.
7.3.3  G*"T<*>Tal Cc""i 'Qiiyp ts »

Monitoring of the leachate treatment system effluent would be
performed monthly for the first year after construction  is
complete, quarterly for the second year, and semi-annually
thereafter for the next twenty -eight  (28) years; however, this
monitoring schedule may be modified during the Remedial  Design
phase.  Sampling and full -scan  (TCL/TAL) analysis  of Operable Unit
Two ground water monitoring wells would be performed semi-annually
for the first five  (5) years and then annually for the next  twenty -

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five  (25} years.  The  frequency and  character of sampling
analysis may be modified by the USEPA at any time.

A perimeter fence,  lockable gates, warning signs &*** other security
measures would be installed around the landfill and the leachate
treatment plant.

Water-use restrictions for ground water and surface water would be
imposed in the immediate area  of the landfill.

Deed restrictions would be imposed to restrict future land-use.
The landfill and the immediate area  should not be utilized for
residential or commercial building.



This alternative would comply  with the requirements of RCRA
Subtitle C for landfill closure.  Certain peripheral areas of the
landfill would be consolidated into  the main part of the landfill.
The landfill thermal anomalies will  be extinguished by excavation,
open burning, and quenching with water spray.  During the
consolidation and thermal anomaly extinguishing, measures will be
taken to satisfy the requirements in the CAA NAAQS (Section 112)
pertaining to fugitive emissions.  The RCRA cap/cover would have a
composite hydraulic permeability of  at least 10*7 cm/sec and would
have both an HDPE liner as well as either two feet of compacted
clay or a layer of  bentonite matting.  The cover would be contoured
so as to reduce erosion and potential washout damage to the
surrounding area.   A leachate  collection and treatment system will
be installed.  The  treatment system  will have both physical and
chemical treatment  stages,  and a biological treatment stage, if it
is necessary to reduce concentrations of certain VOCs to very low
levels before discharge.   The  substantive requirements of a KPDES
permit would be satisfied.   The discharge to the Unnamed Tributary
would have to meet  the AWQC for surface water.

7.4  ALTERNATIVE IV -  STABILIZATION  OF LANDFILL ANOMALIES,
                       CONSOLIDATION  OF LANDFILL WASTE, LEACHATE
                       COLLECTION AND TREATMENT, CAP AND COVER

7.4.1  Treat t"it><°Tit
A leachate treatment plant  incorporating physical treatment  (such
as filtration and aeration)  and chemical treatment systems  (such as
the addition of polymers  and aluminum sulfate  to promote
coagulation) would be built to the  southeast of the landfill.  A
biological treatment stage  would be included,  if necessary.
Leachate treatment effluent would be discharged on-site to the
Unnamed Tributary.  The substantive requirements of a KPDBS  (NPDBS)
permit would, nevertheless,  be required to be  met.
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The subsurface thermal anomalies would be extinguished by injecting
water into them thereby displacing subsurface oxygen and quenching
the combustion.  The thermal anomalies would not be excavated
during this process.
The major electromagnetic anomalies would be excavated and the
waste from them subjected to on- site stabilization/solidification
in order to immobilize both organic and metallic contaminants.  The
stabilized waste would be redeposited in the landfill.

7.4*2
A leachate collection and treatment system as described in Section
7.4.1 above and in Attachments 7.3 and 7.5 and would be constructed
to intercept, collect, and contain leachate. which had- moved through
waste towards the Unnamed Tributary, and other areas downgradient
from the landfill (See Figure 9.1).  Sludge from the leachate
collection . and treatment system would be containerized and properly
disposed.

Contiguous Areas A and B (Figure 9.0) would be consolidated within
the landfill and the surface of the landfill contoured.  The areal
extent of contamination in Areas A and B would be determined by a
thorough surface and subsurface grid sampling effort during the
Remedial Design phase.
A KCKA-type cap anri cover with engineered run-on and run- off
systems would be installed over the approximately thirty (30) acre
area which constitutes the main landfill.



Monitoring of the leachate treatment system effluent would be
performed monthly for the first year after construction is
complete, quarterly for the second year, and semi -annually
thereafter for the next twenty- eight (28) years; however, this
monitoring schedule may be modified during the Remedial Design
phase.  Sampling and full -scan  (TCL/TAL) analysis of Operable Unit
Two ground water monitoring wells would be performed semi- annually
for the first five  (5) years and then annually for the next twenty-
five  (25) years.  The frequency and character of sampling and
analysis may be modified by the USEPA at any time.

A perimeter fence, lockable gates, warning signs and other security
measures would be installed around the landfill and the leachate
treatment plant.

Water-use restrictions for ground water and surface water would be
imposed in the immediate area of the landfill.

Deed restrictions would be imposed to restrict future land-use.
The landfill and the immediate area should not be utilized for

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residential or commercial building.



This alternative would  comply with the requirements of BCRA
Subtitle C for landfill closure.  Certain peripheral areas of the
landfill would be consolidated into the "?in part of the landfill.
The landfill thermal anomalies would be extinguished by injection
of water into subsurface areas.  During the landfill consolidation
and thermal anomaly extinguishing, measures will be taken to
satisfy the requirements in  the CAA NAAQS  (Section 112) pertaining
to fugitive emissions.  The  landfill electromagnetic anomalies
would be excavated and  the excavated material sorted, screened, and
solidified with Portland cement and redisposed.  The treated
material would have to  satisfy the KCRA LDR requirements for
leachability of what are currently unknown contaminants .~  A
variance would be needed if  the leachability requirement could not
be satisfied; however,  the preference for permanent treatment of
wastes under CERCLA would be only partially satisfied.  The BCBA
cap/cover would have a  composite hydraulic permeability of at least
ICr cm/sec and would have both an HOPE liner as well as either two
feet of compacted clay  or a  layer of bentonite matting.  The cover
would be contoured so as to  reduce erosion and potential washout
damage to the surrounding area.  A leachate collection and
treatment system would  be installed.  The treatment system would
have both physical and  chemical treatment stages, and a biological
treatment stage, if it  is necessary to reduce concentrations of
certain VOCs to very low levels before discharge.  The substantive
requirements of a XPDES permit would be satisfied.  The discharge
to the Unnamed Tributary would have to meet the federal or state
ANQC, whichever is more stringent, and other standards for surface
water .

7.5  ALTERNATIVE V - INCINERATION AND STABILIZATION OF LANDFILL
                     ANOMALIES, CONSOLIDATION OF LANDFILL WASTE,
                     LEACHATE COLLECTION AND TREATMENT, CAP AND
                     COVER

7*5*1  Tr
The major landfill electromagnetic  anomalies would be excavated,
sorted, »"<* screened before being incinerated  in an on-Site rotary
kiln incinerator to destroy the organics.  The treated materials
would be solidified with Portland cement to stabilize the
inorganics, and then redisposed.

A leachate treatment plant incorporating physical treatment  (such
as filtration and aeration),  chemical  treatment (such -as the
addition of polymers qnd gi \nn|mm sulf ate  to promote coagulation) ,
anA biological treatment systems would be  built to the southeast of
the landfill.  Leachate treatment effluent would be discharged  op-


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Bite Co the Unnamed Tributary.  The substantive requirements of a
KPDBS  (NPDBS) permit would, nevertheless, be required to be met.

The subsurface thermal anomalies would be extinguished by gas
injection.  Pressurized nitrogen  (N2)  or carbon dioxide (CO,) would
be released into the anomalies to displace the subsurface oxygen
feeding the thermal anomalies and, thus, stop the combustion.

7*5*2  Con ta ^ *«•»»« t C^T'oa^'p t «

A leachate collection and treatment system as described above in
Section 7.5.1 gn^ in Attachments 7.4 ^nfl 7.5 would be constructed
to intercept, collect, and contain leachate moving through waste
towards the Unnamed Tributary, and other areas downgradient from
the landfill  (See Figure 9.1.}.  Sludge from the leachate
collection and treatment system would be containerized and properly
disposed.

Contiguous Areas A and B  (Figure 9.0) would be consolidated within
the landfill and the surface of the landfill contoured.  The areal
extent of contamination in Areas A and B would be determined by a
thorough surface and subsurface grid sampling effort during the
Remedial Design phase.

A RCBA-type cap and cover with engineered run-on and run- off
systems would be constructed over the approximately thirty  (30)
acre area which constitutes the main landfill.

7*5*3
Monitoring of the leachate treatment system effluent quality would
be performed monthly for the first year after  construction is
complete, quarterly for the second year, and semi -annually
thereafter for the next twenty- eight  (28) years; however, this
monitoring schedule may be modified with USEPA approval during the
Remedial Design phase.  Sampling and full -scan (TCL/TAL) analysis
of Operable Unit Two ground water monitoring wells would be
performed semi -annually for the first five  (5) years and then
annually for the next twenty- five  (25) years.  The frequency and
character of sampling and analysis may be modified by  the USEPA at
any time.

A perimeter fence, loclcable gates, warning signs and other security
measures would be installed around the landfill and the leachate
treatment plant.

Water-use restrictions for ground water and surface water would be
imposed in the immediate area of the landfill.

Deed restrictions would be imposed to restrict future  land-use.
The landfill and the immediate area should not be utilized for


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residential or commercial building.



This alternative would comply with the requirements of RCRA
Subtitle C for landfill closure.  Certain peripheral areas of the
landfill would be consolidated into the main part of the landfill.
The landfill thermal anomalies would be extinguished by injection"
of nitrogen  (Nj)  or carbon dioxide (002) gas into subsurface areas.
During the landfill consolidation and thermal anomaly
extinguishing, measures will be taken to satisfy the requirements
in the CAA NAAQS  (Section 112) pertaining to fugitive emissions.
The landfill electromagnetic anomalies would be excavated and the
excavated material sorted, screened, and incinerated on-Site to
destroy the organics.  The treated material would be solidified
with Portland cement and redisposed.  The treated material would
have to satisfy the RCRA LDR requirements for leachability of what
are currently unknown contaminants.  A variance would be needed if
the leachability requirement could not be satisfied.  The
preference for permanent treatment of wastes under eggcTV* would be
satisfied.  The RCRA cap/cover would have a composite hydraulic
permeability of at least 10'7 cm/sec and would have both an HDPE
liner as well as either two feet of compacted clay or a layer of
bentonite matting.  The cover would be contoured so as to reduce
erosion »«d potential washout damage to the surrounding area.  A
leachate collection gnd treatment system would be installed.  The
treatment system would have both physical and chemical treatment
stages, and a biological treatment stage, if it is necessary to
reduce concentrations of certain VOCs to very low levels before
discharge.  The substantive requirements of a XPDES permit would be
satisfied.  The discharge to the Unnamed Tributary would have to
meet the federal or state AWQC, whichever is more stringent, for
surface water.

7.6  EXPLANATION OF MAJOR APPLICABLE OR RELEVANT AND APPROPRIATE
     REQUIREMENTS  (ARARs) AND TO-BE-CONSIDERED  (TBCs) STANDARDS

In this section a general discussion of major applicable or
relevant and appropriate requirements  {ARARs) and " to-be-
considered*•  (TBCs) is presented.

Section 121(d) of CBRCLA requires that at the completion of
remedial action, the Site should achieve a level of control which
complies with federal and state environmental laws that are
applicable or relevant and appropriate  (ARAR) to the hazardous
substances, pollutants, or contaminants at the  Site.  An
•applicable" requirement is any cleanup standard, standard of
control, or other substantive environmental protection standard
promulgated under federal or state law that specifically addresses
a hazardous substance, pollutant, contaminant,  remedial action,
location, or other circumstances at a CERCLA site.  To be


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•applicable', all of the jurisdiction^ prerequisites of a
requirement must be satisfied with respect to the remedial action
or site circumstances.  A "relevant and appropriate" requirement is
any promulgated federal or state environmental law that, while not
"applicable" to the hazardous substance, remedial action, or
location at a CRBCLft, site still addresses problems or situations
sufficiently similar to those encountered at the Site that its use
is well -suited to the particular site.

A requirement may be either "applicable" or "relevant and
appropriate", but not both.  A requirement that is relevant and
appropriate must be complied with to the same degree as if it were
applicable.  However, there is more discretion in this
determination.  For example, only a part of a requirement may be
relevant and appropriate at a site.  Only substantive -requirements
can be ARARs.  Administrative requirements cannot be ARARs.

If no A&AR exists for a chemical or the circumstances surrounding
the release of a chemical, or if existing ARARs do not ensure
protection of human health and the environment, federal and state
criteria, advisories, guidance, or proposed rules may be
considered.  Even if used, however, these "to be considered* (TBC)
materials cannot actually be ARARs.
USEPA has ^stpfrlished three  (3) categories of ARARa:

(1) A chemical -specific ARAR sets health or risk-based
concentration limits or ranges in various environmental media for
specific hazardous substances, pollutants, or contaminants.
Examples of such media are air and water.  These ARARs set
protective cleanup levels for the contaminants of concern in the
designated media or indicate an acceptable level of discharge into
a particular medium that occurs during a remedial activity.

(2) An action-specific ARAR is a performance , design, or other
similar act ion- specific requirement that controls particular
remedial activities.  These requirements are not triggered by the
specific chemicals present at a site, but by the particular
remedial activities that are selected to accomplish a remedy.
These requirements do not in themselves determine the remedial
alternative; rather, they indicate how a selected alternative must
be achieved.

(3) A location-specific ARAR sets restrictions on activities,
depending on the characteristics of a site or its environs.
Location- specific requirements apply to remedial actions evaluated
for the site and may be used to restrict or preclude particular
remedial alternatives due to the location or characteristics of the
Site.

The first step in identifying the ARARs for the site involves
identifying the potential chemical-, action-, and location- specific

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requirements.  The  "^eond. P^eP involves analyzing those
requirements to determine whether they are applicable.  For a
requirement to be applicable, the site circumstances must meet all
of the jurisdictions! prerequisites of the requirements.  Such
jurisdictional prerequisites may include:

                 Substance type
                 Site or location type
                 Affected entities
                 Time period
                 Actions involved
                 Other  regulatory authorities

If the requirement  fails to meet any jurisdictional prerequisite,
the requirement is  not  applicable.  The analysis then addresses
whether the requirement is relevant and appropriate.  The
evaluation factors  for  determining whether a requirement is
relevant or appropriate include:

1.  Whether the specific objectives of the statute and regulations
under which the requirement was created are similar to the specific
objectives of the CERCLA action.

2.  Whether the media regulated or affected by the requirement are
similar to the media contaminated or affected at the CERCLA site.

3.  Whether the substances' regulated by the requirement are similar
to the substances found at the CERCLA site.

4.  Whether the entities or interests affected or protected are
similar to the entities or interests affected by the CERCLA site.

5.  Whether the actions or activities regulated by the requirement
are similar to the  remedial action contemplated at the CERCLA site.

6.  Whether the type of place regulated is similar to the type of
place affected by the CERCLA site or CERCIA action.

7.  Whether the type of structure or facility regulated is similar
to the type of structure or facility affected by the release or
contemplated by the CERCLA action.

8.  Whether any consideration of use or potential use of affected
resources in the requirement is similar to the use or potential use
of the affected resource.

9.  Whether the purpose of the requirement in the program of its
origin is served by its application at the CERCLA site.

10. Whether any variances, waivers, or exemptions from the
requirement are available for the circumstances of the CKRCTA site
or CSRCLA action.

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If a regulatory scheme appears  to be  "relevant ***"* appropriate",
each provision in that scheme must be reviewed to determine its
relevance and appropriateness for the Site.  If  an evaluation of a
provision against these  factors indicates  that the Site
circumstances are "sufficiently similar" to the  problems addressed
by the provision, then the provision  is relevant and appropriate
for evaluating remedial  alternatives.  Otherwise, it is dropped
from consideration.

If an ARAR does not exist or is insufficient to  protect human
health and the environment, then criteria, guidance, proposed
rules, or advisories that are developed or approved by federal or
state agencies should be analyzed for their pertinence in
establishing a protective remedy.  These materials, which are not
legally binding, are classified as "to be  considered"  (TBC)
materials.

If a requirement is determined  to be  an ARAR, it must be complied
with unless it meets the CERCLA criteria for a waiver.  Under
Section 121(d)(4) of CERCIA, USEPA may waive compliance with an
ARAR if one of the following six (6)  conditions  can be
demonstrated:

(1)  Selection of Interim Remedy - The remedial  action selected is
only part of a total remedial action  that  will attain the ARAR
level or standard of control when completed.

(2)  Greater Risk to Human Health and the  Environment Posed -
Compliance with the ARAR at the site  will  result in greater risk to
human health and the environment than the  alternative option
chosen.

(3)  Technical Impracticability - Compliance with the requirement
is technically impracticable from an  engineering perspective.

(4)  Equivalent Standard of Performance Attained - The remedial
action selected will attain a standard of  performance that is
equivalent to that required by  the ARAR through  use of another
method or approach.

(5)  Inconsistent Application of State Requirements - The State has
not consistently applied (or demonstrated  an intention to apply
consistently) the ARAR in similar circumstances  at other remedial
actions.

(6)  Fund Balancing - Attainment of the ARAR would not provide a
balance between the need for protection of public health or welfare
and the environment at this site and  the availability of Fund
amounts to respond to other sites that present or may present a
threat to the public health or  the environment,  taking into
consideration the relative immediacy  of such threats  (for Fund-
financed cleanups only).

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7.6.1.1  Soil and Sediment

No Federal or State chemical-specific ARAR hag been identified for
anil and sediments with the possible exception of the levels set
under the RCRA Land Disposal Restrictions (LDRs).  The T-T>Pg are
discussed under action-specific ARARs since they axe to be applied
only if placement occurs and hazardous waste material is land-
disposed as a part of the remedy.

7.6.1.2  Water

Federal chemical-specific ARARs have been identified for water.
Ground water and surface water, as differentiated from leachate,
will not be treated under the selected remedy/ unless at a future
date USEPA determines that treatment is necessary.  However,
landfill leachate will be treated and discharged to the on-Site
intermittent stream, the Unnamed Tributary, which the Commonwealth
of Kentucky considers surface water.  The Unnamed Tributary is fed
by waters affected by both Operable Units One and Two.  The
Operable Unit One Remedial Action will ensure that leachate from
that area will be collected on-Site before it mixes with stream
waters.  CERCIA Section 121(e) indicates that a  permit ia not
required for an on-site discharge.  However, the substantive
requirements of a Kentucky Pollutant Discharge Elimination System
(KPDES, NPDES)  (401 KAR 5x005) permit are to be  satisfied.
Background surface water quality sample analyses, federal and state
surface water quality criteria  (AWQC), and human health risk-based
levels will be utilized in the determination of  the discharge
standards.  These standards were developed under the Safe Drinking
Water Act  (SDWA), and the Clean Water Act (CWA) .

Maximum Contaminant Levels  (MCLs) are enforceable drinking water
standards for public water supplies developed under the SDWA.  KCLs
apply to specified contaminants which USEPA has  determined have an
adverse effect on human health above certain levels.  These
standards must be met by all public drinking water systems.
Because these standards are to be met by public  water supply
systems, they are not directly pertinent to on-Site ground water.
However, for ground water that is a potential source of drinking
water  XCZis are generally relevg^t ar>d appropriate standards unless
the water is too saline or too contaminated to be used as a
drinking water source  (53 PR 51441).  Because KCLs were promulgated
for the protection of drinking water supplies, because the ground
water under the Site has been categorized Class  1X1  (Subclass B) by
the USEPA, because very few local residences utilize water drawn
from isolated shallow and deep off-Site systems  for household use
(with and without treatment), and because ground water from
monitoring wells must be compared to a suitable  standard, KCLs are
not ARARs, but TBCs.  In that ground water under and near the
landfill does not present a significant exposure problem, no ground

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water treatment is contemplated.

Water Quality Criteria  (WQC) are guidelines developed under the
CIO..  These Federal criteria are used by states to develop their
water quality standards.  Different WQC are derived for protection
of human health and for protection of aquatic life.  The USSPA
Water Quality Criteria found in Section 304(a)(1) of the Clean
Water Act are relevant and appropriate criteria for the Site.  The
USEPA criteria for protection of aquatic life from acute or chronic
toxic effects or the human health criteria for consumption of fish,
whichever is more stringent, is a chemical-specific re^gvgnt ^TH*
appropriate requirement for the surface waters on the Site except
where Kentucky Water Quality Standard* (WQS) or human health risk-
based levels are more stringent.

7.6.1.3  Air

Federal chemical-specific ABARs have been identified for air
emissions from the Site.  During the extinguishing of the
subsurface thermal anomalies and during the consolidation of Areas
A and B within the main landfill, air emissions may become a
problem.  The specific chemical vapors or particulate matter which
may present an air emissions problem are not known at this time.
Gaseous emissions from uncontrolled hazardous waste sites may be
due to the vaporization of liquids, thermal destruction of
organ!cs, venting of entrained gases, or cnemical and biological
reactions with solid and -liquid waste material.  Methods for
controlling the release of gaseous emissions into the atmosphere
include the installation of covers, and the use of active gas
collection systems, to collect and control gases generated in
landfills.  Emissions of particulate matter are likely to be caused
by incineration or by sources of fugitive dust emissions (Emissions
that do not pass through a stack, chimney, vent, or other
functionally equivalent opening are "fugitive" emissions.), such as
wind erosion of exposed waste materials or cover soil.  Commonly
used measures for controlling fugitive dust emissions from inactive
waste piles and from active cleanup sites, and measures which would
be an integral part of the remedy at Operable Unit Two of the
Smith's Farm Site, include use of chemical dust suppressants, wind
screens, water spraying, and other dust control measures commonly
used during construction.  The Clean Air Act  (CAA) National Atnbient
Air Quality Standards (KAAQS) (40 CFR Part 50) requirements are
pertinent to alternatives which require incineration of landfill
wastes, which require the excavation of landfill waste which may
emit organic vapors, or on-site sources which may combust upon
exposure to air and produce harmful smoke and particulates.  KAAQS
applies to six (6) criteria pollutants: 1) particulate natter equal
to or less than ten  (10) microns particle size/ 2) sulfur dioxide,
3) carbon monoxide, 4) ozone, 5) nitrogen dioxide, and 6) lead.
Under Section 107 of the CAA, the Commonwealth of Kentucky has the
primary responsibility for assuring that the HAAQS are attained and
maintained.  Pursuant to Section 112 of the CAA, the USEPA

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identifies pollutants for which no ambient air quality standard
exists, but that cause or contribute to air pollution that may
reasonably be anticipated to result in an increase in mortality or
in serious irreversible, or incapacitating reversible) illness.
The rftm HAAQs are a  chemical-specific relevajif. a^fl appropriate
requirement for the  Site.

RCRA air emissions regulations for hazardous waste piles, land
treatment, and landfills are limited to the requirement that
particulate matter from such facilities be controlled by covers or
other means.  40 CFR Sections 264.251, 264.273, and 264.301 are
relevgri^ ^nd appropriate requirements.

7.6.2  Legation-specific ARARs.

Commonwealth location-specific ARARs have been identified for the
Smith's Farm Site and are addressed in Section 7.6.4.  Federal
location-specific ARARs have been identified as follows:

RCRA location requirements mandate that  (1) hazardous waste
treatment, storage,  or disposal facilities located within a one
hundred  (100) year floodplain must be designed, constructed,
operated and maintained to avoid washout  (40 CFR 264.18 (b)) and (2)
hazardous waste treatment, storage, or disposal facilities may not
be located within two hundred  (200) feet of a significant
geological fault  (40 CFR 264.18(b)).  In general, RCKA authority
has been delegated to the Commonwealth of Kentucky.  The Site is
not located in a floodplain, nor is it located within two hundred
(200) feet of a known significant geological fault; therefore, the
RCRA location requirements are not ARARs.

Fish and Wildlife Coordination Act  (FWCA), 16 USC Section 661 et
seq., requires adequate protection of fish and wildlife if any
stream or other body of water is modified.  The FWCA would be
pertinent to alternatives which would consolidate the wastes from
Areas A and B within the main landfill because such consolidation
would modify or effect at least the west bank of the Unnamed
Tributary.  Any alternative requiring remedial action construction
could impact the Unnamed Tributary adversely unless precautions are
taken to minimize erosion and silting.  The Unnamed Tributary  (1)
is an intermittent stream with rock bottoms and minimal aquatic
life,  (2) harbors little or no vegetable or humic matter and other
sediments, and  (3) does not accumulate water in large pools.
However, because the lower reaches of the Tributary contain some
water most of the year, the FWCA is a relevant and appropriate
requirement for the  Site.

Endangered Species Act  (ESA), Section 7(a), requires that  Federal
agencies, in consultation with  the U.S. Department of the  Interior
(USDOI) and the National Marine Fisheries Service  (NMFS),  as
appropriate, ensure  that the actions they authorize, fund,  or  carry
out are not likely to jeopardize the continued existence of

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endangered or threatened species, or adversely modify or destroy
their critical habitats.  Actions that might jeopardize listed
species include direct and indirect effects, as well as the
cumulative effects of other actions that are interrelated or
interdependent with the proposed action.  Substantive compliance
with the ESA means that the lead agency must identify whether a
threatened or endangered species, or its critical habitat, will be
affected by a proposed response action.  If so, the agency must
avoid the action or take appropriate mitigation measures so that
the action does not affect the species or its critical habitat.
If, at any point, the conclusion is reached that endangered species
are not present or will not be affected, no further action is
required.

Two  (2) endangered species which may occur near the Site area were
identified by the Fish *r*6 Wildlife Service'of the U.S. Department
of the Interior.  These species are the Indian bat (Mvotis sodalis)
and the Bald Eagle (Haliaeetus leucocephalus).  Two (2) species of
plants under current status review are the Shepherdsville glade
cress  (Leavenworthia exious) and Synandra (Svnandra hispidula).
The Site is not a critical habitat for these species and the remedy
will not significantly affect these species.  Therefore, the ESA is
not a location-specific ARAB, requirement at the Site.

7.6.3  Action-specific ARARs.

Federal regulations that 'are action-specific ARARs for the Site are
discussed below:

The Occupational Safety and Health (OSEA) Standards (29 CFR
Sections 1910.120, .1000 - .1500, Parts 1926.53, .650 - .653) are
not ARARs, because they are incorporated in CBRCXiA, as amended by
SARA.  Nevertheless, they will be required to be met because they
apply directly by virtue of their own regulatory authority working
through CSRCLA Section 126.  Under the authority of Section 126 of
the Superfund Amendments and Reauthorization Act of 1986  (SARA),
USEPA and OSHA promulgated identical health and safety standards to
protect workers engaged in hazardous waste operations and emergency
response.  The OSHA regulations, codified at 29 CFR Section
1910.120, became effective on March 6, 1990  (54 FR 9294).  The
USEPA regulations incorporate the OSHA standards by reference and
are codified at 40 CFR Part 311  (54 £R 26654).  The OSHA standards
(1910.120) for hazardous substance response actions under CERCLA
establish the safety and health program requirements that must be
implemented in the cleanup phase of a CERCLA response.  Under the
regulations, a health and safety program will be required for
employees and contractors working at the Site.  The standards found
in 1910.1000 - .1500 govern CERCLA response actions involving any
type of hazardous substance that may result in adverse effects on
employees' health and safety.  These standards also incorporate all
of the requirements of 29 CFR Part 1926, the OSHA health and safety
standards for construction.  The provisions of 29 CFR 1926.650 -

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.653 are pertinent to any excavation, trenching, and shoring that
is undertaken as part of the construction of trenches, cut-off
walls, etc.

The Resource Conservation and Recovery Act  (&CRA) **ae action-
specific provisions which are pertinent to the Site and have been
promulgated under 40 CFR Parts 264, 265, and 280.  USEPA has
determined that the above regulations are relevant to RCRA-
characterized or listed hazardous wastes (40 CFR Part 260) if the
wastes were disposed at the Site after November 19, 1980, or if the
CBBCLA remedial action consists of treatment, storage or disposal
(TSD) of hazardous wastes as defined by RCRA (40 CFR Part 264).  In
addition, these regulations may be relevant and appropriate to
remedies involving RCRA hazardous wastes disposed at the Site prior
to November 19, 1980, even if those remedies do not involve
treatment, storage, or disposal of those wastes  (Hazardous wastes
were disposed at the Site before November 19, 1980.).  Examples of
RCRA requirements include minimum technology (MINTECH) standards,
treatment standards, monitoring requirements, and storage and
disposal prohibitions.  For Operable Unit Two,  the pertinent
portions of RCRA are relevant and appropriate action-specific
ARARs, because all of the jurisdictional prerequisites of RCRA
cannot be satisfied.  Although USEPA has delegated the RCRA program
to Kentucky, some federal hazardous waste management regulations
promulgated under ESMA have not been delegated to Kentucky.  For
the authorized portions of RCRA, the State requirements are
applicable and the corresponding federal RCRA requirements are
         and aroriate; both are ARARs.
7.6.4  Ma-tor State ARARs.

A variety of Kentucky Administrative Regulations  (KARs) pertaining
to hazardous waste and hazardous substances, air quality, water
quality, and transportation are ARARs or TBCs to actions to be
taken at the Site.

The following regulations pertaining to hazardous waste and
hazardous substances  are relevant requirements for the Site,
because RCRA hazardous wastes were disposed of in the landfill
after November 19, 1980:

• 401 KAR 34x060, Sections 1,8,9,12 - Groundwater protection

  Sections 8 and 9 set forth general ground water monitoring
  requirements and detection monitoring program requirements which
  are relevant and appropriate.

• 401 KAR 34:070 and  KAR 47:040  - Closure  and post-closure

  These sections reflect the RCRA closure  requirements. They set
  out closure performance standards which, among other
  requirements, are intended to minimize the need for further

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  maintenance and control, minimize or eliminate to the extent
  necessary post -closure escape of hazardous constituents to ground
  water or surface water or through the atmosphere, to protect
  human health and the environment.  They provide for the
  disposal or decontamination of equipment, structures, and soils.
  They require a survey plat to be submitted to the local
  zoning authority and the Commonwealth.  They provide for
  post -closure care and use of property.  They require a
  notation on the deed to the property noting the previous
  management of hazardous wastes thereon and the land use
  restrictions resulting from that use.  These requirements are
          "
• 401 XAR 34:190 - Tanks

  This part of EAR 34 regulates tank systems that are used for
  treatment and storage of hazardous waste.  This applies to tanks
  used in the leachate collection and treatment system as well as
  such tanks as are needed to store water used for decontamination
  activities.  Permits are not required for CRRCLA cleanup
  activities.  This KAR is applicable.

• 401 KAR 34:230, Sections 6,7,8,9 - Landfills

  Section 6 provides standards for covers  (caps) for sites where
  waste is left in place.  These standards will apply to the design
  of the final cap at the Site.  These requirements contain RCRA
  standards.  They are applicable.

Regulations pertaining to air emissions which will impact
remediation;

• 401 KAR 34:240, 50:025, 51:010, 51:052, 53:010, 63:005, 63:010,
  63:020, 63:021 - Air pollution and fugitive emissions control
  requirements

  The fugitive air emissions standards and control measures found
  in these KARs are applicable to the Site remedial activities
  because they apply to potential operations such as cap
  installation, excavation of trenches, and consolidation of
  landfill wastes, and other activities that may emit dust and
  other air contaminants.  The standards require individuals to
  take reasonable precautions to prevent particulate matter from
  becoming airborne when material is handled, or processed, a
  building is constructed, altered, or demolished, or a road is
  used.  Visible fugitive dust emissions must be contained within
  the lot line of the property on which the emissions originate.
  This requirement reflects provisions of the CAA and is an
  appl i cgbl e requirement .

Regulations pertaining to water which will impact remediation
include :

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• 401 IAR 5*005  - Permits to discharge sewage; industrial and
  other wastes;  definitions

  The substantive requirements of this provision are relevant!
  appropriate requirements which must be met for any discharge.
  However, no permit is required for on- Site CKBCI^ activities!
Kentucky's Surface Water Quality Standards, set out in 401 EAR
5s 02 6 -  s035, set "mini mum criteria applicable to all surface
waters".  These criteria include specific limits on certain
contaminants.  In addition, to the extent that the Site contains
surface waters as defined by 401 EAR 5s 029 Section l(bb), including
intermittent streams with well-defined banks and beds, the surface
water standards are gpp] j 7?M? chemical •specific standards.
Sections 10 and 11 of 401 EAR 34s 060 set forth standards* for the
compliance monitoring program and corrective action programs which
establish how the data gathered will be evaluated a^c* what actions
must be taken to eliminate contamination of ground water.  Should
the ground water monitoring at the Site indicate that the
KCLs/MCLGs are consistently exceeded, then an appropriate
corrective action will be applied to comply with the MCLs/UCLGs.
Sections 10 and 11 would then become gppj ? 7?1?1 /?

Regulations which pertain to soil and surface water conservation
and will impact remediation include:

• ERS 262 - Soil and Water Conservation requirements

  Chapter 262 of the Kentucky Revised Statutes, which provides for
  the establishment of soil and water conservation requirements to
  prevent and control soil erosion, are applicable requirements for
  this Site.  Remedial activities could create changes in soil
  conditions and surface water flow.  The requirements for the
  technologies /actions that could lead to large-scale soil
  disturbance are applicable.

7.6.5
ifm'ri-Hnn* contaminant Level Goals  (MCLGs) are non-enforceable health-
based goals for drinking water developed under the SDWA.  MCLGs are
entirely health-based  and their  attainment assures that even
sensitive populations  would experience no known or anticipated
adverse health effects.  Since MCLGs  are non-enforceable, chemical-
specific goals for drinking water,  they are chemical-specific TBCs.
Under the NCP the USEPA requires that KCLGs set at levels above
zero  (non-zero MCLGs)  be attained during a CBRCLA cleanup where
they are relevant and  appropriate.  Where the MCLG is  equal to
zero, the USEPA sets the cleanup level to be the  corresponding MCL.

Location-specific and  action-specific To-Be-Considereds  (TBCs)
identified for Operable Unit Two of the Smith's Farm Site include

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well drilling, sealing, and pump  installation requirements.  Well
drilling, sealing, and pump installations will be addressed in the
design documents and will be conducted in accordance with the
requirements for all actions.  The  landfill cap and cover system
will be designed in accordance with current USEPA guidance on
RCRA/CERCLA Final Covers.

The RCRA Land Disposal Restrictions (LDRs)  (40 CFR Part 268) were
identified as potential ARARs for the Site, because some of the
wastes to be managed during the remediation are hazardous wastes;
and placement of hazardous wastes is planned for in Alternatives IV
and V, and not called for in Alternatives II and III or in the
selected remedy.  Nevertheless, USEPA has determined that LDR soil
cleanup levels set forth in the RCRA LDR regulations (40 CFR 268)
are TBCe with respect to the determination of the extent, of waste
and soils in landfill areas which are to be consolidated within the
main landfill area, although risk-based action levels were utilized
for consolidation.

The RCRA Proposed Subpart S  (55 PR  30798-30884) Corrective Action
Levels  (RCALs) describe health-based criteria for soil
contamination.  The exceedance of the criteria indicates that
remediation may be required.  Because CALs are not promulgated,
they are not ARARs. but are TBCs  with respect to the delineation of
the extent of waste and soils in  the contiguous landfill areas
which are to be consolidated into the main landfill area.

8.0  SUMMARY OP COMPARATIVE ANALYSIS OP ALTERNATIVES

8.1  THRESHOLD CRITERIA

8.1.1  Overall Protection o^ TTinmiii  Health y*»ti the EnviroT*"|OT|t.
Alternative I is the no-action alternative which would provide
inadequate protection of human health and the environment.  The
formerly permitted landfill would  continue to present unacceptable,
excessive risks and hazards to the nearby residents.

Alternative XI would not provide as much overall protection of
human health and the environment as Alternatives III, IV, and V,
but more *>»»« Alternative I.  Unacceptable, excessive risks would
remain.  The landfill waste would  not be consolidated and a cap
would not be installed, but a leachate  collection and treatment
system would be constructed and maintained.  The volume  of leachate
generated would be as large as in  the past; a large amount of
leachate would be generated after  heavy rainfalls because of the
lack of a cap and cover system.  Therefore, a large capacity
leachate treatment plant would be  required.  The leachate would be
treated only by physical treatment processes which would result in
the unacceptable discharge of some organic contaminants  to the
Unnamed Tributary.  The landfill's subsurface thermal anomalies
would be extinguished by Tneann of  excavation, open air burn-out,

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and a final water spray.  A perimeter fence would be built
long-term well monitoring g«d institutional measures would be
undertaken.  Without a  cap/cover and more  complete treatment of
collected leachate, the overall protection of human health *^<3 the
environment would be inadequate since the  potential for exposures
to the contaminated surface soils, leachate, and leachate sediments
would still be significant and unacceptable.

Alternative ZZZ would provide an adequate  degree of protection for
humans and the environment by reducing exposure risks to acceptable
levels.  Alternative III would  (1) subdue  the two landfill
subsurface thermal anomalies by means of excavation, open air burn-
out, and a final extinguishing spray with  water or another
nonhazardous extinguishing agent,  (2) consolidate landfilled
materials, and contain  the landfill material with a RCKA-type
cap/cover system  (thereby reducing leachate'generation
dramatically),  (3) collect and treat any landfill leachate before
on-Site discharge to the Unnamed Tributary, and (4) provide
institutional controls.  After the leachate collection/treatment
system and the cap/cover are in place, leachate volume even after
heavy rainfalls is expected to be much less than in the past (an
estimated reduction of  greater than ninety percent  [90%]). The
exposures to contaminated surface soils, exposed waste, leachate,
leachate sediments, and stream sediments would be eliminated
through containment measures.  Leachate treatment by physical,
chemical, and, if necessary, biological or other means, would
eliminate the contamination entering the Unnamed Tributary.

Alternative IV provides about the same adequate degree of overall
protection for humans ?«3 the environment  as Alternative III.
Alternative IV would subdue the two landfill subsurface thermal
anomalies by water injection, consolidate  peripheral landfilled
materials and contain the landfill material with a RCEA-type
cap/cover system  (and thereby reduce leachate generation
dramatically), collect  and treat the landfill leachate before
discharging the treated fluids on-Site to  the Unnamed Tributary,
and provide institutional controls.  However, on-Site
solidification/stabilization would be used on the waste in the
landfill's electromagnetic anomalies in an attempt to stabilize
drummed and undrummed hazardous wastes in  place and thereby prevent
further leaching of both organic and inorganic constituents from
those wastes.  The landfill's subsurface thermal anomalies would be
extinguished by water injection after a leachate collection and
treatment system was installed.

Alternative V provides  more than adequate  overall protection for
human health and the environment, but at an excessive cost.  All of
the landfill's electromagnetic anomalies would be remediated
through on-Site incineration gn
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into the main landfill area.  A leachate collection and treatment
system would eliminate organics and inorganics from the leachate by
physical, chemical, and biological, or other treatment, before on-
Site discharge to the Unnamed Tributary.  The landfill would be
capped, covered, and fenced.  Thus, the sources of contamination
would be contained and the potential exposures for both humans and
the environment would be virtually eliminated.  Incineration of
wastes from the landfill's electromagnetic anomalies would destroy
organic waste constituents, but would leave inorganics to migrate,
unless a separate solidification/stabilization treatment phase was
implemented.

8.1.2  CTlii»*iee With ARARs.

Alternative I, no action, does not comply with ARARs.

In Alternative II leachate treated only by means of physical
processes will be discharged to the Unnamed Tributary.  ASARa for
surface water  (Federal and State AWQC) will not be met due to the
limited degree of leachate treatment provided.  XCLs for ground
water would be utilized for TBCs.  On-Site monitoring wells would
be sampled periodically as in the other four  (4) alternatives.
Alternative II will not comply with RCRA regulations pertaining to
the proper closure of a landfill since there is no engineered cap
and cover system to reduce infiltration, percolation, and the
generation of leachate.  The requirements for HAAQS, State, and
local burning ordinances -would be observed during the excavation
and open air burn-out of the landfill's thermal anomalies; measures
designed to reduce fugitive emissions and particulates would be
implemented.  Peripheral landfill material would not be
consolidated as it would be in Alternatives III, IV, and V.

Alternative III will comply with surface water ARARs  (Federal and
State AWQC) if biological treatment is utilized in conjunction with
the physical and chemical treatment of leachate  (See Section
9.0.1.).  MCLs for ground water would be utilized as TBCs.  On-Site
monitoring wells would be sampled periodically.  Treatment of
ground water is neither expected nor predicted due to the low
permeability and isolating character of the shale geology
underlying the landfill.  Alternative III will comply with RCRA
(and XAR) regulations pertaining to the proper closure of a
landfill since there is an engineered cap and cover system to
reduce infiltration, percolation, and the generation of leachate.
It appears that ARARs do not exist for the remediation of the
landfill's thermal anomalies.  The requirements for NAAQS, State,
and local burning ordinances would need to be observed during
excavation; measures designed to reduce fugitive emissions and
particulates would be implemented not only during the extinguishing
of the subsurface thermal anomalies, but also during the
consolidation of peripheral landfill material into the main
landfill area as in Alternatives IV and V.  All other ARARs would
be complied with.

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Alternative XV will  comply with ARAB* for surface water  (Federal
and State ANQC).  XCLa  for ground water would be utilized as TBCs.
On-Site monitoring wells would be sampled periodically.  Treatment
of ground water is neither expected nor predicted due to the low
permeability and  isolating character of the shale geology.
Solidification of the landfill's electromagnetic anomalies would
comply with RCRA  LDR requirements with regard to the leachability
of the stabilized/solidified wastes; administrative variances may
be necessary due  to  the technical impracticability of treating
heterogeneous  wastes to the low specific-constituent cleanup levels
required under LDRs.  It does not appear that there are ARARs
specific to remediation of the landfill's subsurface thermal
anomalies.  However, the HAAQS, State, and local burning ordinances
would be substantively  adhered to; measures designed to reduce
fugitive emissions and  particulates would be implemented.
Peripheral landfill  material would be consolidated as in
Alternatives III  and V; therefore, the fugitive emissions and
particulates associated with the consolidation of landfill wastes
would have to  be  dealt  with during construction.  Alternative IV
will comply with  RCRA regulations pertaining to the proper closure
of a landfill  since  there is an engineered cap and cover system to
reduce infiltration, percolation, and the generation of leachate.

Alternative V  will comply with all ARARs.  It will meet surface
water ARARs  (Federal and State AWQC) via the leachate collection
and treatment  system.   Leachate migration to the Unnamed Tributary
would stop due to the installation and operation of a leachate
collection and treatment system.  MCLs for ground water would be
utilized as TBCs. On-Site monitoring wells would be sampled
periodically.  Incinerated contaminated material from the
landfill's electromagnetic anomalies would be treated in compliance
with CAA and RCRA ARARs pertaining to air quality and the operation
of hazardous waste incinerators.  The material resulting from
incineration would probably not satisfy LDR leachability standards
for inorganic  constituents; thus, variances may be needed to allow
redisposal, or the material may need to be stabilized/solidified.
It appears that ARARs specifically for the remediation of the
landfill's subsurface thermal anomalies do not exist; however, the
substantive requirements of the HAAQS, State, and local burning
ordinances would  be  met; measures designed to reduce fugitive
emissions and  particulates would be implemented.  Peripheral
landfill material would be consolidated as in Alternatives III and
IV; therefore, the fugitive emissions and particulates associated
with the consolidation  of peripheral landfill wastes would have  to
be managed during construction.  Alternative V will comply with
RCRA regulations  pertaining to the proper closure of a landfill
since there is an engineered cap and cover system to reduce
infiltration,  percolation, and the generation of leachate, and a
leachate containment and treatment system.
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8.2  PRIMARY BALANCING CRITERIA

8.2.1
Alternative Z is the no-action alternative.  This alternative
reflects the current situation with regard to the protection of
human health and the environment.  The alternative is not an
effective remedy and, therefore, does not provide the necessary
long- term effectiveness, protectiveness , and permanence.

Alternative XX does not require treatment of the landfill
electromagnetic anomalies and does not incorporate the
consolidation and capping of the landfill waste.  The landfill
thermal anomalies would be extinguished by excavation and open air
burn-out.  Leachate is collected and treated using only physical
treatment, but no chemical or biological treatment stages.
Institutional and security measures would be undertaken.  This
alternative does not provide as effective, permanent, and reliable
protection of human health and the environment as do Alternatives
III, IV, and V.  Without a cap and cover  (as in Alternatives III,
IV, and V) , rainfall will infiltrate through the landfill waste and
flush out waste constituents which will appear in the leachate.
The quantity of leachate generated will be proportional to the
amount of rainfall; a large treatment system will be required to
handle the large quantity of leachate generated during high
rainfall events, and there will still be an unacceptable discharge
of organic contaminants to* the Unnamed Tributary.  Thus, the
long-term effectiveness of the Alternative II remedy is not
acceptable; there is no comprehensive, permanently effective
remediation as there is in Alternatives III, IV, and V.

Alternative XXX does not treat the landfill's electromagnetic
anomalies, but does extinguish the subsurface thermal anomalies by
means of excavation, airing, and spraying with water.  After
peripheral landfill areas are consolidated, the landfill will be
capped and covered.  The leachate would be collected and treated
physically, chemically, and, if necessary, biologically or by other
processes, to remove both organ! cs and inorganics from the leachate
before discharging the treated fluids.  Institutional and security
measures would be as in Alternatives II, IV, and V.  The long-term
effectiveness, permanence, and expected reduction in residual risk
are acceptable and reflect a more reliable and permanent level of
protection of human health and the environment than Alternatives I
and II, gn<3 a level of long-term effectiveness on par with
Alternatives IV and V.

Alternative XV provides long-term effectiveness and permanence in
much the same fashion as Alternative III above.  However, the
landfill's excavated electromagnetic anomalies would be treated
on- site by stabilization with cement or pozzolanic additives; and
the landfill's subsurface thermal anomalies would be extinguished
by water injection.  The long-term prognosis for contaminant

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migration and transmission would be approximately the same as for
Alternative III in that leachate generation would be dramatically
reduced, and leachate treatment would eliminate the migration of
untreated leachate to the Unnamed Tributary.  The stabilization of
the landfill's electromagnetic anomalies would greatly retard the
leaching of a portion of the landf illed drummed »nd undrummed
wastes, but, in the long-term, both the treated and untreated
landfill wastes would still generate a quantity of leachate
relative to the actual effectiveness of the cap »n^ cover system.
Alternative V would do the most towards the reduction of expected
residual risk, but at excessive cost.  Outlying or peripheral areas
of contamination would be consolidated for capping.  The permanent
cap and cover would virtually eliminate the risk of soil ingest ion
and dermal contact and would effect a drastic reduction in the
volume of leachate generated.  Prior to capping, the landfill's
thermal anomalies would be excavated and incinerated on- site, thus
removing the organics from the waste.  The subsurface thermal
anomalies would be extinguished by gas (CO, or Nj) injection.  The
virtual elimination of leachate seepage into the Unnamed Tributary,
and elsewhere, would reduce the amounts of contaminated fluids
affecting the on- Site intermittent streams and their sediments.
The cap and cover would reduce the amount of rainfall infiltration.
The small amount of leachate generated by the landfill would be
captured by the leachate collection system and treated by a
multi-stage leachate treatment system which would treat the
leachate physically, chemically, and biologically, or by other
processes, to approved standards before on- Site discharge of the
clean effluent to the Unnamed Tributary.  The landfill and the
leachate treatment system would be fenced, signed, and inspected
regularly.  With proper operation and maintenance, the cap,
leachate collection and treatment system, and security measures
would constitute a permanent remediation and would continue to be
effective well into the future, but at excessive cost relative to
Alternatives III and IV.

8.2.2  Reduction of Toxieitv. Mobility, er Volume
Alternative Z is  the no -action alternative.  No cap or cover would
be installed.  And, except for the installation of a fence and
continued monitoring, the landfill would be as it was. as of the
completion of this Record of Decision.  There would be no reduction
of toxicity, mobility, or volume through treatment .

Alternative II requires  the extinguishing of the landfill's
subsurface thermal anomalies by means of excavation, airing, and
spraying with water.  This process may generate smoke, fugitive
emissions, and various particulates which would be managed
according to HAAQS, State, and local requirements.  No cap or cover
would be installed; therefore, the fluctuations in the volume of


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leachate generated would be the same as in Alternative I.  This
alternative requires the installation of a leachate collection and
treatment system similar to that in Alternatives III, TV, and V,
but only physical treatment processes would be used for leachate
treatment.  Thus, some organic contaminants would not be removed
from the leachate before discharge, which may be construed as a
partial reduction of total original toxicity, mobility, and volume.
The landfill's electromagnetic anomalies would not be.addressed and
would, therefore, not be subjected to a reduction of toxicity,
mobility, or volume.

Alternative III reduces the generation of leachate by installation
of a cap and cover.  Any leachate generated after the installation
of the cap and cover will be collected and treated by physical,
chemical, and, if necessary, biological or other processes, and the
treated effluent discharged to the Unnamed Tributary.  The
landfill's subsurface thermal anomalies would be extinguished by
excavation, airing, and spraying with water.  Alternative III does
not attempt to treat the landfill's electromagnetic anomalies, but
relies on the cap and cover to reduce rainfall infiltration and
thus lessen leachate volume such that the smaller amount of
leachate generated can be readily collected and treated by standard
physical, chemical, and, if necessary, biological or other
treatment processes.  The cap and cover would reduce the amount of
leachate generated by more than ninety percent (90%).  The
toxicity, mobility, and volume of leachate would be reduced.  The
mobility of the landfilled • waste contaminants would be reduced, but
the toxicity and volume of the source waste materials would not be
decreased.

Alternative IV extinguishes the subsurface thermal anomalies by
means of water injection which will, in the short-term, generate
leachate which will have to be collected and treated before
discharge.  Thus, a leachate collection and treatment system will
have to be in place prior to the work on the landfill's subsurface
thermal anomalies.  The landfill's electromagnetic anomalies would
be stabilized with cement or pozzolanic additives which would
reduce the toxicity, mobility, and, to an unknown degree, the
volume of hazardous substances available for leachate generation.
With the cap gnd cover installed and the leachate collection and
treatment systems operating, the Alternative TV remedy should
reduce the overall toxicity and mobility of the hazardous
components of the waste.  The volume of hazardous substances
available for exposure to humans and the environment would be
lessened by solidification/stabilization of the landfill's
electromagnetic anomalies and by the multi-stage treatment of
leachate.  The cap ??*<* cover would reduce the amount of leachate
generated by more than ninety percent  (90%).

Alternative V reduces the toxicity of the landfill waste in the
electromagnetic anomalies by subjecting the excavated waste from
the anomalies to on-site incineration  (which is a very expensive

                                 99

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treatment process), thus removing the organics from the waste.
However, inorganics would remain a problem unless they were
immobilized by solidification/stabilization before redisposal into
the landfill.  The landfill's subsurface thermal anomalies would be
extinguished by means of gas  (COj or Nj) injection, which would not
generate any leachate, unlike the procedures used in Alternatives
III and IV.  The cap and cover would reduce the amount of leachate
generated by more than ninety percent  (90%) .  Waste toxicity,
mobility, and volume would be reduced as aforementioned.

8.2.3  Short-Term Ef f ectivf ness.

Alternative I, the no-action alternative, has already achieved its
optimal short-term effectiveness.

Alternative XX would begin to be effective when the leachate
collection and treatment systems were operating.  Without a cap,
however, the amount of leachate generated would continue to
fluctuate widely; and with a treatment system relying only on
physical processes for leachate treatment, the fluid entering the
Unnamed Tributary will probably exhibit approximately the same
characteristics as it has in the past.

Alternative XXX would begin to have a significant amount of
effectiveness after the bentonite matting layer had been installed
on the landfill subsequent to the subsurface thermal anomalies
having been remediated.  -Rainfall infiltration and, consequently,
leachate production would be reduced.  Optimal short-term
effectiveness would begin to occur when the cap and the leachate
collection and treatment systems were completely in place as in
ALternatives IV and V.  Temporary check dams and erosion control
measures along the Unnamed Tributary would minimize contaminant
transmission.

Alternative XV would begin to have significant short-term
effectiveness once the solidification of the landfill waste in the
electromagnetic anomalies was completed, the thermal anomalies were
remediated, and the bentonite matting layer of the cap was
installed.  Optimal effectiveness would not occur until the the
completed cap and leachate collection and treatment systems were in
place and the leachate treatment plant was fully functional as in
Alternatives III and V.

Alternative V would begin to have significant short-term
effectiveness once the incineration of the landfill electromagnetic
anomalies was completed, the thermal anomalies were remediated, and
the bentonite matting layer of the cap was installed.  Further
gains in effectiveness would occur with the completion of the cap
ar>d cover system and the full functioning of the leachate treatment
plant as in Alternatives III and IV.
                                 100

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8.2.4

Alternative I is inplementable in that no major work must be done
to satisfy its requirements.

Alternative II is very implementable.  The landfill's
electromagnetic anomalies would not be remediated.  The subsurface
thermal anomalies would be extinguished by excavation and airing,
although as in Alternative III below, water may be sprayed on the
smoldering material to smother the combustion.  Once the subsurface
thermal problem is remediated, the landfill surface can be
recontoured; the construction of the leachate collection
treatment system can proceed concurrently.

Alternative III is somewhat more complicated to implement than
Alternative II.  The landfill surface cannot be recontoured until
the subsurface thermal anomalies are extinguished.  The smoldering
material would be excavated and allowed to burn out.  Water may be
sprayed on the burning material in order to cool it, to dissipate
the built-up heat, and to smother the combustion.  However, a
leachate collection and treatment system may not have to be in
place and operating early in the construction.  Temporary earthen
berms, silt fences, and check dams would mitigate the surface run-
off.  Once the landfill surface is recontoured, the leachate
collection and treatment systems as well as the cap and cover would
be installed in the same way as in Alternatives TV and V.

Alternative IV is the second most complicated alternative to
implement.  The landfill surface cannot be recontoured until the
landfill's electromagnetic and thermal anomalies are dealt with.
However, the anomalous wastes would be subjected to solidification/
stabilization which would have fewer administrative problems than
incineration.  The extinguishing of the subsurface thermal
anomalies by means of water injection would require that at least a
rudimentary leachate collection and treatment system be in place
and operating or that other capture devices be installed into the
landfill downgradient from the subsurface thermal anomalies to
collect and treat  (and possibly reuse) the injected water.

Alternative V is the most complicated alternative to implement.
The landfill surface cannot be recontoured until the subsurface
thermal anomalies are extinguished and the landfill electromagnetic
anomalies are excavated and incinerated on-site.  Companies
offering incineration technologies do not supply their services on
demand, but require substantial lead times.  Additionally,
treatability studies, mobilization, test burns, material sorting,
mechanical breakdowns, weather delays, and demobilization expend
large amounts of time 3»?«3 money.  While the remedy is technically
feasible, it is administratively complex.  The services of many
different subcontractors would be utilized.  The,timing and
movement of the subcontractors would have to be choreographed and
adjustments made as problems are encountered.  The extinguishing of

                                101

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the subsurface thermal anomalies by means of gas  (CO, or N,)
injection nay not work as advertised; therefore,  it may take longer
to extinguish the thermal anomaly than was originally anticipated.

8.2.5  Cost.

Alternative Z has an estimated Present Worth Cost between zero *nrf
$2,191,000, depending upon how many institutional actions are
undertaken.

Alternative II has an estimated Present Worth Cost of $3,279,000.

Alternative ZZZ has an estimated Present Worth Cost of $38,975,000.

Alternative ZV is the next most costly remedy.  It has an estimated
Present Worth Cost of $66,883,000.

Alternative V is the most costly alternative of the five (5)
alternatives presented.  Its estimated Present Worth Cost is
$115,027,000.

Estimated Present Worth Costs reflected above are broken down into
Capital Costs and Thirty  (30) Year 0 & M Costs in Table 8.0.

8.3  MODIFYING CRITERIA

8.3.1  State/Support AgOT>cv Acceptance.

The Commonwealth of Kentucky did not concur with  the Operable Unit
One Record of Decision which was completed in September 1989.
Kentucky offered only a partial concurrence on the Amendment to the
Operable Unit One Record of Decision, which was finalized in
September 1991.  The Commonwealth gave partial concurrence to the
Operable Unit Two proposed plan remedy in that it concurred with
                                 102

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                       TABLE  8.0 i DESCRir   >N OF  FIVE ALTERNATIVES
         DESCRIPTION

No Action or Limited Action

Limited Institutional Action,
Collection and Treatment of
Leachate Using Physical
Treatment,  Extinguish Landfill
Fire By Excavation

Limited Institutional Action,
Excavate Areas of Outlying Soil
Contamination and Cap Formerly
Permitted Landfill, Collection
of Leachate and Chemical/Physical
Treatment for Heavy Metal and
Organic Removal, Extinguish
Landfill Fire by Excavation

Limited Institutional Action,
Excavate Areas of Outlying Soil
Contamination and Cap Formerly
Permitted Landfill, Excavate Hot
Spots and Treat Using On-site
Stabilization, Collection of
Leachate and Chemical/physical
Treatment for Heavy Metal and
Organic Removal, Extinguish
Landfill Fire By Water Injection

Limited Institutional Action,
Excavate Areas of Outlying Soil
Contamination and Cap Formerly
Permitted Landfill, Excavate Hot
Spots and Treat Using On-site
Incineration,  Collection of
Leachate and Chemical/Physical/
Biological Treatment for Heavy
Metal and Organic Removal,
Extinguish Landfill Fire By Gas
Injection
       TOTAL PWC

$0 to $2,191,000
CAP  COST

 $133,000
30-YR.  Q&M COST

  $2,058,000
      $3,279,000
$928,000
  $2,351,000
      $38,975,000     $34,579,000
                  $4,378,000
      $66,883,000     $62,505,000
                  $4,378,000
    $115,027,000     $109,175,000
                 $5,852,000
                                               103

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the installation of the RCRA-type cap and cover system and with the
implementation of the leachate collection and treatment system
design, but wanted the landfill anomalies to be treated by
solidification.  The Commonwealth has since concurred with the
Operable Unit Two selected remedy.

6.3.2

In the past the community has not been overly aggressive about
being involved with activities at Smith's Farm, although public
meetings have always been well -at tended.  Bullitt County government
officials  (i.e., the Health Department, the County Magistrate, and
a. County Judge) have maintained contact with USEPA Region IV and
have attended all of the public meetings.  The Responsiveness
Summaries for the ROD and the ROD Amendment for Operable Unit One
indicate that the community was not in favor of on- site
incineration as well as the hauling of hazardous materials over
County roads.  Additionally, residents of the mobile home park
immediately south of the landfill have been quite vocal about the
need to extend public water lines to all residences in and
around the mobile home park.  Because of the thin overburden in the
area of the mobile home park, the continued use of cisterns and
septic tanks by several households in the area, and the existence
of a common above-ground sewage lagoon in the mobile home park, the
use of stream water for drinking/bathing and the use of shallow
wells is not recommended from a public health standpoint.  The
community appears to understand that, at the present time, the
runoff from the landfill does not have a significant
environmental impact on the Unnamed Tributary and the mobile home
park, and that problems with unpotable ground water and surface
water generally derive from population density, the lack of
competent water and sewage treatment facilities for some
households, and the naturally poor quality of ground water and
surface water in the area.

9 » 0
The selected remedy is a modified Alternative III which includes
 (1) the extinguishing of the subsurface landfill thermal anomalies,
 (2) the consolidation within the landfill of peripheral, contiguous
areas of landfill material,  (3) the installation of a. leachate
collection system at the bedrock surface along the entire east and
southern sides of the landfill, which diverts leachate to a
collection tank and to a multi-stage treatment system which then
discharges treated, cleaned liquid to the Unnamed Tributary,  (4)
the installation of a mult i- layer RCRA-type cap and cover system
with attendant run-on a^a run- off systems, and  (5) the installation
of perimeter fencing, lockable gates, warning signs,  and the
imposition of deed restrictions and water use restrictions.


                                104

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9.0.1
Subject collected leachate to both physical ?nd chemical treatment
and, if necessary, biological or other treatment process (es) , and
discharge on-Site to the Unnamed Tributary.  The discharge shall
meet the substantive requirements of a XPDBS  (NPDES) discharge.

Excavate thermal anomalies and spray with water or fire retardant
chemical foam or apply other appropriate nonhazardous substances
until the combustion has been extinguished.

9.0.2  Cootai™*****1 1 Cos8nt .

Excavate contaminated soil and waste from Areas A and Bland other
contiguous contaminated areas  (e.g., sediments from the Unnamed
Tributary) immediately proximal to the formerly permitted landfill
and consolidate them within the main landfill area  (See Figure
9.0.) .  The extent of contamination in contiguous Areas A and B
(and other contiguous areas) shall be determined by surface and
subsurface grid sampling, and by best engineering judgement, during
the Remedial Design phase  (See Section 9.1.5.).

Drums and other waste uncovered during excavation shall be handled
with best management practices and consolidated within the main
landfill.  Since consolidation will take place within the same area
of contamination  (AOC) , such consolidation will not constitute
placement of wastes under RCRA and will not, therefore, trigger
RCRA Landban Restrictions  (40 CFR Part 268) .

Construct a leachate collection system to intercept and collect
leachate moving through waste and fill material towards the Unnamed
Tributary and other areas downgradient from the landfill  (See
Figure 9.1.).

Contour/ terrace the surface of the landfill and ins tall the  cap and
cover.  The RCRA- type cap shall include a synthetic membrane of at
least forty  (40) mil thickness gnd may substitute bentonite matting
for the two  (2) foot thick clay layer, and may substitute
geotextile materials for the drainage layer (s ).  Permanent
engineered run-on and run- off systems shall be constructed as a
part of the cap/cover system.  The run-on and run- off controls
shall be designed for at least a fifty  (50) year rainfall event
with a factor of safety of at least one -and -one -half  (1.5) .  During
the Remedial Action construction, temporary run -on/ run -off and
erosion/silt control systems shall be in place.
9.0.3  GOT^6r&l Cffr*f>T>oPor' t s .

Investigate and better delineate the metallic anomalies,  i.e.,


                                105

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                   SOL SM0UNC
                   LOCATION
                   UOUIWl) MCA OT
                   MO MUMS
AREAS OF SUSPECTED CONTAMINATION
      OUTSIDE THE RCRA CAP
           SMITH'S FARM
       OPERABLE UNIT 02
     BULUTT COUNTY. KENTUCKY
          FIGDRB  9.0

-------
                                      390— cesmc oxro*
                         CONCEPTUAL L£ACHATE COLLECTION
                                      PLAN
                                  SMITH'S FARM
                               OPERABLE UNIT 02
                             BUUJTT COUNTY. KENTUCKY
                                  FIGURE  9.1
107

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smaller dump sites, along the Unnamed Tributary from the Operable
Unit Two area, the formerly permitted landfill, to beyond the area
addressed by the Operable Unit One activities.  Excavate and
dispose of surficial metallic and nonmetallic anomalous materials
in either the Operable Unit One or the Operable Unit Two landfill
(See Section 9.1.5.}.

Expand the existing ecological survey to include bioassays of biota
living in the Unnamed Tributary.  More thoroughly investigate the
landfill's affects on flora and fauna and, especially, threatened
and endangered species.

Install a perimeter fence, lockable gates, warning signs, and other
security measures.

Perform sampling and full-scan  (TCL/TAL) analysis of Operable Unit
Two ground water monitoring wells and certain surface waters
semi-annually for the first five  (5) years after landfill closure
and then annually for the next twenty-five (25) years.  The
frequency and character of sampling and analysis of the leachate
effluent will be determined during the Remedial Design phase and
may be modified by USEPA and the Commonwealth of Kentucky at any
time.

Impose water use restrictions for ground water and surface water in
the immediate area of the landfill.  These waters shall not be used
for potable water sources as a precaution against possible future
releases of contaminants.

Impose deed restrictions to restrict future land-use.  The landfill
and the immediate area around the landfill shall not be utilized
for residential or commercial building due to the continued
presence of hazardous contaminants on-Site and the probable
settling and subsidence of the landfill.

9.1  REMEDIATION LEVELS AMD OBJECTIVES

The purpose of this remediation activity is to reduce present risks
posed by direct contact with landfill contaminated soils/sediments/
leachate, to reduce the need for long-term management,
significantly reduce the toxicity, mobility and volume of waste
both long-term and short-term, and during remediation.  There are
two media with their two associated remediation activities which
need remediation levels to define either the extent of the
contamination or the quality of the treatment process (es).  The two
media are  (1) waste and fill/soils/leachate sediments, and
(2) leachate water/very shallow ground water.  Haste and
fill/soils/leachate sediments will be excavated/moved to other
parts of the landfill in order to consolidate material and contour
the surface of the landfill.
                                 108

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Very shallow ground water derived directly from rainfall flows
vertically and horizontally through the landfill and overburden,
generating and carrying leachate, and then along the
overburden/rock interface, and emerges as seeping/flowing leachate.
Leachate flows into the Unnamed Tributary where it may be ingested
as drinking water by residents.  Leachate liquid is to be
collected, treated, and the cleaned liquid discharged on-Site to
the Unnamed Tributary.

9.1.1  Buried Waste y"fl gill Material.

The formerly permitted landfill contains a variety of industrial
wastes, including an unknown number of buried drums which may
contain hazardous substances.  The wastes and drums in the formerly
permitted landfill are mixed with trash, construction debris, and
other fill material.  The remediation objective for the landfill
waste a«H fill material is to control the migration of contaminants
from the waste and fill material to the surrounding media by
consolidation and containment of the landfill material.

When consolidating the waste, fill material, soils, and leachate
sediments from the east side of the landfill near the Unnamed
Tributary and from Area B on the southwest side, excavation to the
bedrock may be required.  During the Remedial Design process, the
areal limits of the excavation shall be determined by the results
of additional grid sampling all along the east, southeast, an<*
southwest sides of the landfill, as well as by best engineering
judgement, except as described in Section 9.1.5.  Since the areas
to be excavated and consolidated within the main body of the
landfill are contiguous areas of the landfill, LDR requirements
relating to placement do not apply.  Sediments in the bed of the
Unnamed Tributary and soils east of the Unnamed Tributary shall not
be consolidated into the main landfill without prior approval by
the USEPA.

The remediation levels for organic contaminants of concern for
surface soils and leachate sediments, which will be utilized for
the consolidation of peripheral landfill areas, are set forth in
Tables 9.0a and 9.Ob.  The remediation levels in Tables 9.0a and
9.Ob are to be utilized only to delineate the areal extent of the
material to be consolidated.  If- additional contaminants are
discovered during the remedial design, or the remedial action,
which warrant the calculation of additional soil remediation
levels, USBPA will establish these new levels using a similar
approach to that utilized in the calculations for the remediation
levels set forth in Tables 9.0a and 9.Ob.

The Table 9.0a Remediation Levels for consolidation of surface
soils g"fl leachate sediments were determined by back-calculating
from an individual constituent carcinogenic risk of l X lO^6 and an
individual constituent noncarcinogenic risk of HQ «= 0.1  (for an


                                109

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TABLE 9.0 a
REMEDIATION LEVELS FOR SURFACE SOILS AMD LBACHATB SEDIMENTS
MEDIUM
SdrfanSeOi






tMthtto
MUMrti (So
N«teMa»)

BASELINE
EXPOSURE
SCENARIO
fenuICMiMt
WKkBnrfkUlfeOi






l>m«l C'MUri
WhbWilklBf
nmaik LMch«*
fcolmemli**

CONTAMINANT
OP CONCERN
Bk(2-Edulh«jl) I**""*
Btptwbr •paid*
M'-ODB
4,4'4)DD
M'-DDT
uphfrCUordue
guoBU-CUorouM
!>••••(•) pynM
Bbd-ElkjrlWol) phlb.lito
BA8BLINB
BUOSORB
POINT
CONCENTRATION
M B«*|
•.OMm«/k«
•.<£)m(/k( t
•.M8m|/k|
1.047 Bf/kf
».M mt/kt
«.M mi/k(
l« nt/k|
SM Bif/kf
CURRENT RISK
BASED ON
BASELINE
EXPOSURE
POINT
CONCENTRATION
HQ - 2.5 C
3.2 X 10* Cue
4.«XIO*Cuc
• J X If Cut
MX 10* Cut
HQ - X.S C
no-2.se
4.7 X tO* Cue
2.1 X 104 Cut
FOR LANDFILL CONSOLIDATION
REMEDIATION
LBVEIi
FOR
CONSOLIDATION
OP SOILS AND
SEDIMENTS
OJ4 n(/k|
I.IT oj/k«
S.W a«/kt
re* «i/kt
I3.S o»*|
3JM a«/k|
3J4 o|/k|
** «J42 •«/!«
*• 28IJ ncAg
1 (OJ4 Bif/ki)
REMEDIATION
LEVEL POR
CONSOLIDATION
CALCULATED
USINO THIS
RISK
HQ - «.l C
IX 10* Cut
IX 10* Cue
IXIfCuc
HQ - (.1 C
HQ - • J C
HQ - • J C
IX!** Cue
IX I*4 Cue
    li  tMcftu* MdkMiU u* to b* tTMted M wrfanxfl* for Uw puipow of o».
       Cklld.
       Htard Quota! (nnd wtth Mncudaok^k ibk).
       nOSfruu per UOUUB or puta p»r mUBoB (ppm).
                                                                     110

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TABLE 9.0 b
REXEDIATIOH SUBTOTALS FOR COHSOZiXDAXION OF SOILS AHD LEACHATE SXDZMSHTS
SKKXVOLATILKS


PESTICIDES






Benzo (a) pyrena
Bis (2-ethylhaxyl)
phtbalate
SUBTOTAL
Heptachlor epoxide
4,4' -DDK
4, 4' -ODD
4, 4' -DDT
alpha - Chlordaae
gamma * Chi OT**^* ^^
SUBTOTAL
0.342 mg/kg
0.54 mg/kg
0.682 Bg/kg
1.87 us/kg
5.00 ug/kg
7.09 ug/kg
13.5 ug/kg
3.24 ug/kg
3.24 ug/kg
33.94 ug/kg
 Note:  If either the semi-volatiles subtotal or the pesticides subtotal or
       the sua of the two subtotals is met or exceeded. then the affected
       soils and sediments shall be consolidated into the main portion of
       «-v>+ landfill.  Exceeding an individual reaediation level will
       trigger the removal of the soil if that individual constituent
       level causes one chemical group to meet or exceed its subtotal.

adult or  a child,  whichever was appropriate)  utilizing standard
risk assessment equations which may be found in Section 3 of the
Operable  Unit Two Risk Assessment.  If the  calculated Remediation
Level  (or Exposure Point Concentration)  could not be accommodated
by USEPA  Region IV Environmental  Compliance Branch Standard
Operating Procedures and Quality  Assurance  Manual  (ECBSOPQAM)
Contract  Required Quantitation Limits  (CRQL) , then a slightly
higher risk was utilized and another Remediation Level calculated.
This process  was repeated until the Remediation Level could be
accommodated  by the CRQL.  For further explanation of the manner of
determination of the Remediation  Levels, see Attachment 9.0.

Table 9. Ob sets forth a decision  mechanism for determining
peripheral areas to be consolidated.   Alternatively, all  of the
soils and leachate sediments in the peripheral areas roughly
delineated in Figure 9.0 may be excavated to the bedrock  and
consolidated  in the main landfill area.

9.1.2  Leachate y«^ v?rv Shallow Ground Water.
The remediation objective for the leachate is to prevent  or
minimize leachate generation  and subsequent leachate migration into
the surrounding media.
                                  ill

-------
Hazardous constituents have been detected in the leachate which
collects and flows in the formerly permitted landfill gnd in the
soils between the landfill and the Unnamed Tributary.  Rain water
infiltrates through landfilled waste generating leachate which
migrates along the soil/bedrock interface and discharges through
seeps or visible leachate outbreaks along the soil /bedrock
interface exposed along and near the western bank of the Unnamed
Tributary.

If the landfill wastes and fill material are successfully contained
for the long-term, rainfall infiltration into the landfill will be
minimized, and the production of leachate will likewise be reduced
or eliminated.  Even after containment measures are implemented,
some leachate may continue to emanate from the landfill as a result
of (l) liquids which remain contained within the waste material
after capping,  (2) a small amount of rainfall infiltration, and (3)
natural changes in subsurface temperature and pressure.  The
remediation objective for this continued leaching is to prevent the
infiltration of rain water and migration of any resulting leachate
beyond the boundary of the containment area by capping the landfill
and by intercepting, collecting, and treating the leachate.

The area or very shallow plume of leachate perched or flowing on
the bedrock under and around the pump house, and under the
unimproved road next to the pump house, in the southeast quadrant
of the landfill, will be intercepted by the leachate collection
system.                  • '

It is necessary to treat the collected leachate to at least the
surface water quality criteria  (Kentucky Warm Water Aquatic Habitat
Criteria and the Federal Ambient Water Quality Criteria for the
Protection of Aquatic Life, and other standards) which protect the
public health, the public welfare, and the environment and which
allow an on-Site discharge to the Unnamed Tributary.  In accordance
with Section 121 (e) of CERCLA, a permit is not needed for the on-
Site discharge of treated leachate to the Unnamed Tributary.
However, the discharge shall comply with all substantive
requirements of the KPDBS (NPDES).  Exact discharge criteria will
be established during the Remedial Design phase.  However, Table
9.0c describes the human health risk remediation levels for treated
leachate water which shall be considered when determining the exact
discharge criteria.



Hazardous constituents detected in the intermittent Unnamed
Tributary result primarily from leachate seepage into the Tributary
as described in Section 9.1.2 above; however, the Tributary may
also be impacted by surface run-off from the landfill.  Some
leachate will continue to be generated, but will be contained by
the collection system; the primary source of contamination of the
Tributary will be eliminated.  When the landfill surface is covered

                                112

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TABLE 9.0 0
REMEDIATION LEVELS FOR GROUND WATER, SURFACE WATER, LEACHATE WATER
MEDIUM
Ground Water





Surf an Water
(Unnamed
Tributary)
Leacfcate Water
(So* not* Mow)




BASELINE
RXPOSORB
SCENARIO
iBftfllOD Of
Grand Water A*
Drinking Water





InfMtion of
Surface Water u
Drinking Water
Dermal Contact
WhBe Walking
Through Leaehato
Water




CONTAMINANT
OP CONCERN
Anttmonj
Anode
Barlam
Cnronilont
N-nhroeotfl-n-propylamlne
Itanium
N-nltroaodl-n-propytaniliw
2-Chlorophenol
DkUorometaane
2,4-IHmethjt-ptienol
Nllrobenaene
Phenol
BASELINE-
EXPOSURE
POINT
CONCENTRATION
<3ut/L
Uui/L
2Mut/L
230UC/L
7.lug/L
isug/i.
5.0 ug/I,
540ug/L
42,000 U(/L
790,000 u|/L
890,000 U|/L
3,000,000 u(/L
RISK BASED ON
BASELINE
EXPOSURE
POINT
CONCENTRATION
HQ - 10 C
no - 1.8 c
no- 0.7 c
HQ-C.OC
6.0 X 104 Care
no - 21.0 c
4.2 X 104 Cart
no - 2.4 c
I1Q - 0.7 A
DQ - 12 A
no - 
-------
by an impermeable barrier,  then contact between surface run-on/run-
off and the  landfill waste,  the secondary  source of  contaminated
water, will  be  eliminated.   Remediation of Unnamed Tributary
surface waters  and sediments is not  currently considered necessary
since  (1) average contaminant levels in the Unnamed  Tributary and
in its sediments  (near the  formerly  permitted landfill) are at
acceptable levels and (2) planned  remediation activities are
directed at  eliminating the possibility of further contamination of
surface waters  and surface  water sediments.

9.1.4  T-«"dfill Therm* 1 An«*""^lies.

Two underground thermal anomalies  have been detected in the
northeast and northwest portions of  the landfill.  The source of
these anomalies appears to  be two  subterranean fires of buried,
smoldering wood.   Although  the thermal anomalies appear not to
represent any danger,  they  will be further investigated and
extinguished as a part of the remedial action at the landfill.

There are no apparent air quality  standards associated with open
air burning  or  smoldering of wood, and other materials, which may
or may not be contaminated  with hazardous  substances.  However,
the local fire  department shall be consulted and air quality
monitoring for  this specific remediation activity shall be
maintained until  the fire(s)  are extinguished.  A written record of
the air monitoring effort shall be made part of the  Remedial Action
Report .

9.1.5  Metal ^"""""lies Near the
Surf icial metal  anomalies  lying along the Unnamed Tributary between
the Operable Unit  Two and  Operable Unit One areas, and identified
during the Operable Unit Two Remedial Investigation, shall be
excavated and  disposed, using best management techniques, into
either the Operable Unit One or the Operable Unit Two landfill
based upon several factors,  including  (l) the schedule for the
construction of  the Operable Unit One and Two landfills,  (2) the
volume of material to be disposed, and  (3) the distance of the
particular anomaly from an Operable Unit landfill.

Nonmetallic trash,  such as old vehicle tires and vehicle  seat
covers, shall  be disposed  utilizing best management practices.

9.2  STATUTORY DETERIORATIONS

9.2.1  Protection  of Human HypTth g"d the Envj1"t

The selected remedy will eliminate, reduce, or control risks posed
through each pathway by means of treatment and implementation of
engineering and  institutional controls and thus ensure adequate
protection of  human health *n^ the environment.  Potential risks
posed by Operable  Unit Two through each of the following  pathways
will be either eliminated, reduced, or controlled by the  response
action.

Although the surface waters  of the Unnamed Tributary have not been
demonstrated to  have been  significantly contaminated, several

                                114

-------
leachate  seeps  along the east side of  the  landfill  flow into  the
Unnamed Tributary.   Additionally,  surface  run- off from the existing
landfill  cover  flows into the Unnamed  Tributary.  The  installation
of a RCRA-type  landfill cap will minimize  the amount of leachate
generated and will  place a barrier between the  contaminated
landfill  soils  and  the top of the  landfill such that surface  run-
off will  not  be contaminated by "dirty"  surface soils.   The
installation  of the leachate collection  and treatment  system  will
further isolate the reduced amount of  landfill  leachate and will
treat the leachate,  and discharge  the  treated,  cleaned liquid to
the Unnamed Tributary.

The small ponds to  the southwest of the  landfill that  catch some
landfill  surface run- off will benefit  from the  installation of a
proper  cap and  cover and the accompanying  run-on/run-off diversion
structures which are expected to divert  surface run- off to armored
outfalls  on the banks of the Unnamed Tributary.

Thus, the surface water,  leachate  seeps, and surface soil pathways
will be eliminated  or controlled by the  remedy.

Buried  waste  and subsurface soils  will be  contained by  the RCRA-
type cap  and  the compact shale rock under  the landfill.  A leachate
plume has been  determined to be a  problem  only  in the southeast
quadrant  of the landfill.   The leachate  collection  and  treatment
system  should control  the described leachate problem.

USEPA has determined that there is not a current air contamination
problem.   However,  during the remedial design further air
monitoring will be  accomplished; and during the remedial action on-
Site air  monitoring will be an integral  part of the Health and
Safety  Plan and of  field operations.

The remedy is protective of the environment because the cap and the
leachate  collection and treatment  system significantly  decrease
flora and fauna contamination;  and the leachate treatment system
reduces the potential  for significant  contamination of  the Unnamed
Tributary and the piscatory and bent hie  species therein.

Site future risks will  be reduced  to within the 104 to  10~* range
for carcinogens and the Hazard Indices total for non- carcinogens
will be less  than 1.0.

No unacceptable short-term risks or cross -media impacts will  be
created by implementation of the remedy.
9.2.2  Cypl 1* 1*"?^ Kith Aoplie>*^>l8 or
                     {ARARs)
The selected alternative consists of closure of the formerly
permitted Smith's landfill in accordance with KDNREPC and RCRA
regulations governing hazardous waste landfill closures, along with
a sampling program to monitor changes in ground water, surface
water, and the effectiveness of leachate treatment .  Alternative
III is designed to meet the applicable or relevant and appropriate
requirements  (ARARs) .  The Federal ARARs include the Resource
Conservation and Recovery Act  (RCRA) (42 USCA Section 6901 et seq


                                115

-------
                               TABLE 9.It MAJOR ARAR8  AMD  TBCs  FOR THE SELECTED  REMEDY
      TYPE OP  ARAR
APPLICABLE
RELEVANT  & APPROPRIATE
                                                                        TO-BE-CONSIDERED'8
    Chemical-ipecifio
1\t» ARARi ud IBCi trt hcdth «r ibk-
bM*d eomtntka Bate or nnfM la
vutau MilmiiiMBtil ntdli for ipcdfle
huutau MM*JK«,
                            I. OMB Air Art, Ntdonil AmMnl Air QD«%
                             SUadmnU (CAA, NAAQS)
                                   1. Rnoam C«BMmik> ud IMXMJ Ad,
                                    rrapawdSnbputS, Ctmdh* Adka Urcb
                                    (RCAU)
                                                                   . OMUI W«tar Act, Muhn C«rt«Bkuut
                                                                    Unl OiMb (CWA MCMWi 40 CFI141M-
                                                                                                             3. Cbu WAr Act, Muda
                                                                                                              Unh (MCU)t CWA ferttiM J04(i)(« ud 4*
                                                                                                              CF« I41.I1-I41.K

                                                                                                             4. K—totkj Mhtut DM*!* ElMBjtlw
                                                                                                              Sl^Ml (KTOES)i 401 KAR Si02«-i49S
    Location-ipeci fio
Tkw* ARARi u4 TBCi ru» pvfmuuM*,
nqrinmMrti tkM Mfrtral putfrolu
nmdUl MdrhtM ud bdkat* hew •
iihrtiil ritirm^h* ••< U *tM«Tx».
                                                                      I. Hifc uid WDdBTc Caonfljutfcw Ad ttHM
    Action-•pacific
1W* ARARi ud IBCf H( raliimeM ••
•dMtfM, di|MMbt area Ik* Ainct^itkt
•f • At «r te Mvtrtai ud wv b* utd lo
rMtrtct «r pwrfmW putlnUr nnedUI
uwulhH do* U Ik* locttka w
                           I. RCRA SMtfon 164 do put)
                                                                                                              Lud DbptMl RMtitcdew (ICRA LDRi)i
                                                                                                              40CFR2CI.I-MI.SO
                                                                    116

-------
and 40 CFR Part 264) and the Clean Air Act (42 USCA 7401 at aeg and
40 CFE. Part 50 and 61) .  State ARARs include: 601 KAR 1x025 --
Transportation of Hazardous Materials and KRS 174.415 -- Hazardous
Materials, Permits, Emergency Procedures, Enforcement; 401 KAR
34t240, 50:025, 51:010, 51.052, 53i010, 63i010, 63:020, 63:021, and
63s005 pertaining to air pollution and fugitive emissions control
requirements; and 401 XAR 341070, and 471040 pertaining to deed
notices on solid or hazardous waste sites.  For further discussion
of Site ARARs, see Sections 7.6, 8.1.2, Table 9.1, and Sections
9.2.2.1 through 9.2.2.3.

9.2.2.1  Resource Conservation and Recovery Act (RCRA)

Because some disposal of hazardous waste at the Smith's landfill
occurred after the effective date of the RCRA regulation (November
19, 1980) the requirements of RCRA Subtitle*C regulations which are
triggered by the selected remedy are applicable and must be met.
Section 264.310 of RCRA Subpart N specifies the performance-based
requirements for a cover at completion of landfill construction.
The cover system for the landfill will be a cap and cover system as
described in RCRA guidance and will comply with the relevant and
appropriate RCRA regulations.  The cap will minimize migration of
liquid through the landfill, function with minimum maintenance,
promote surface drainage, minimize erosion, minimize leachate
generation, accommodate settling, and be less than the permeability
of natural subsoils present.

After construction is completed, the substantive monitoring and
maintenance requirements contained in Section 264.117 through
264.120 of Subpart 6 will be conducted.  The landfill will be
capped according to the standards in Subpart 6 Section 264.111 -
Closure Performance Standards.  After the closure activities have
concluded, a survey plat, as prescribed in Subpart 6 Section
264.116, indicating the location and dimensions of the disposal
area will be submitted to the local zoning authority, or to the
authority with jurisdiction over local land use, and the USEPA
Region IV Regional Administrator as well as the Director, Division
of Waste Management, Kentucky Natural Resources and Environmental
Protection Cabinet.

Monitoring (full-scan TCL/TAL analyses) of existing ground water
monitoring wells and surface waters will occur semi-annually for
the first five (5) years after construction is complete and
thereafter annually for twenty-five  (25) years.  Monitoring of
leachate treatment effluent will occur according to the plan
established and approved by USEPA during the Remedial Design.
USEPA may modify the monitoring plan during or after the RD/RA.

9.2.2.2  Clean Air Act  (CAA)

The Clean Air Act  (CAA) identifies and regulates pollutants that
could be released during earth-moving activities associated with

                                117

-------
the excavation of soils,  sediments, and drum wastes of  the
landfill.  The CAA,  Section 109/  outlines  the criteria  pollutants
for which National Air Quality Standards  (KAAQS) have been
established.   CAA, Section 112, identifies pollutants for which
there are no pertinent Ambient Air Quality Standards, those
substances regulated under the Federal national Emission Standards
for Hazardous  Pollutants.   The CAA, Sections 109 and 112, is an
ARAR and the regulations'  standards will be complied with during
implementation of the selected remedy.  State regulations
concerning the release of  toxic air emissions, and reflecting
pertinent CAA  provisions,  will also be satisfied.

9.2.2.3  Ground/Surface Water ARARs

Two groups of  federal environmental standards and criteria are
considered ARARs  or  TBCs  for the  surface water at the Smith's
landfill:  Safe Drinking Water Act (SDWA)  «»•»•
-------
mobile home park and the surrounding area are on public water,
which has as its source the Salt River.  A very few residences in
the surrounding area obtain their water from either the shallow
ground water regime  (i.e., from isolated fractures), from cisterns
filled with rainwater or trucked water, or from the intermittent
streams which run through the stream valley upon which the mobile
home park is built.  The County is planning to extend public
drinking water lines to the few remaining unconnected residences in
the area.

The ground water units in the shale strata as well as the ground
water units in the deeper limestone aquifer are classified by USEPA
as Class ZZZ ground water systems.  Class IZZ ground water systems
either produce water having a suspended solids concentration of at
least 10,000 ppm and/or produce only 150 gallons or less per well
per day.  Class ZZZ is subcategorized primarily on the basis of the
degree of interconnection with surface waters or adjacent ground
water units containing ground water of a higher class.  Subclass
ZZZ B is restricted to ground waters characterized by a low degree
of interconnection to adjacent surface waters or ground waters of a
higher class within the Classification Review Area.  These ground
waters are naturally isolated from sources of drinking water in
such a way that there is little potential for producing additional
adverse effects on human health and the environment.  Where
hydrogeologic data are available, the Classification Review Area
can be subdivided to reflect the presence of naturally occurring,
ground water bodies of variable size that may have significantly
different use and value.  These ground water bodies, referred to as
•ground water units*, must be characterized by a degree of non-
interconnection  (between adjacent ground water units) such that an
adverse change in water quality to one ground water unit will have
little likelihood of causing an adverse change in water quality in
the adjacent unit.  Each ground water unit can be treated as a
separate subdivision of the Classification Review Area.  A
Classification System decision is made for the ground water unit or
units potentially impacted by a specific activity.  At the Smith's
Farm Site, the ground water units under the area addressed by
Operable Unit Two  (the landfill and immediately proximal areas) are
hydrogeologically isolated from those ground water units under the
mobile home park and under nearby residential areas.

The AWQC established under the Section 304 of the CM* are relevant
and appropriate requirements at the Site.  The AWQC are established
for protection of freshwater aquatic organisms.  The AWQC will be
met at the point the treated leachate discharges to the closest
surface water body, i.e., the Unnamed Tributary.  Monitoring
shallow ground water, upgradient of the surface water body and
northeast of the area addressed by Operable Unit One  (the MW-21
well cluster), will check compliance with AWQC.

State criteria listed for waters used as a Warm Water Aquatic
Habitat  (401 XAR 5s031) were more stringent than potential federal

                                119

-------
ARAR0 for three  (3) contaminants and will be the ARARa for those
three (3) contaminants in lieu of the federal AWQC for the same
contaminants .

401 KAR 34:020, a State ARAR, involves the construction of a waste
facility in a flood-prone area or the potential increase in
flooding hazards due to construction in a certain area.  The
remedial design for the selected remedy will consider on- site
flood-prone areas.

Location- specific ARARs will be addressed in the design documents
for the selected alternative.

9.2.3  Cost-Effectiveness .

The selected remedy is cost -effective because it has been
determined to provide overall effectiveness proportioned to its
costs (present worth = $38,975,000).  Table 8.0 compares estimated
costs associated with all five  (5) alternatives.  The selected
remedy has a moderate capital cost and O&M costs which are
approximately the same as the higher cost Alternatives IV ?nd V.
In Alternatives IV and V the application of treatment processes to
the landfill's electromagnetic anomalies do not eliminate the
generation of landfill leachate, but merely change the quantities
of constituents in the leachate.
9.2.4  Utilization of Peffon^^t Solutions »*y t
                             ce Recovery Te
USEPA has determined  that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner.

Based upon the information presented, the selected remedy will
protect surface water and ground water quality by reducing
infiltration and leachate production.  It provides the best balance
among all nine (9) evaluation criteria, with the following being
the most important considerations for the Site:

1.  Compliance with State and Federal requirements
    for solid waste landfill closure;

2.  Availability of equipment and materials;

3.  Cost of construction, O&M;

4.  Elimination of rain water infiltration and, thus,
    reduction in the  volume of leachate released, after
    treatment, to the surface water; and,
                                 120

-------
5.  Continued monitoring to ensure the remedy continues
    to be protective of human health and the environment.

9.2.5  Preference for Ti-aatnent aa a Principal Elmant.

The selected remedy does not satisfy the statutory preference for
treatment because treatment of landfill waste, other than leachate,
is impractical.  The remedy does not include treatment of any
contaminated landfill waste matrix.  Treatment of the source of
contamination  (the entire landfill) is technically impracticable,
because of the large volume of material, the known heterogeneity of
the material, and the low average contaminant concentrations
believed to be present.  The feasibility of treating isolated,
heavily contaminated areas is in question, because the nature and
extent of anomalous contamination within the fill area has not been
quantified and would be very difficult  (and'costly) to quantify.

Alternatives IV and V would not provide any additional public
health benefit over Alternative III, landfill closure with
monitoring (the selected remedy), because existing conditions
currently do not pose an immediate, acute risk to human health and
the environment and the planned low permeability RCRA-type cap will
significantly reduce the generation of leachate.  The operation of
a leachate collection and treatment system should dramatically
reduce the quantity of contaminants migrating to the Unnamed
Tributary, and other downgradient areas.  The monitoring program
that will be implemented•as part of this action will detect changes
in ground water, surface water, and other media.  These data will
be reviewed as they are collected, so that if significant
degradation in the quality of these media is noted, then further
action can be initiated.  The effectiveness of the remedy will be
reevaluated at least five (5) years after completion of the
remedial action.

9.3  DOCUMENTATION OF SIGNIFICAKT CHANGES

There were two changes made to the selected remedy from the time
the Proposed Plan and the RI/FS Reports were released for public
comment to the time of the final selection of the remedy  (CBRCLA
Section 117(b)).  The first change was to require the further
investigation, better delineation, and disposal of the surficial
metallic anomalies along the Unnamed Tributary from the Operable
Unit Two area north to beyond the Operable Unit One area.  The
second change was made between the time the Proposed Plan was
published and the signing of the Record-of-Decision.  The
requirement for a XPDBS  (NPBBS) permit for the discharge of treated
leachate from the leachate treatment system into the Unnamed
Tributary was eliminated.  According to Section 121(e) of CERCLA,
and the HCP, an on-Site discharge does not require a permit;
however, the substantive requirements of the CMA, Section 402,
HPDBS ?nfl the corresponding KPDBS regulations will be adhered to.


                                121

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                        ATTACHHEIJT 5.0
        Summary Tables of Analytical Results from the
           Operable Unit Two Remedial  Investigation
5.3  — Inorganic Results - Smith's Farm - Operable Unit Two
        RI - Waste Samples
5.4  — Summary of Detected Organic Constituents - Smith's
        Farm - Operable Unit Two RI - Waste Samples
5.5a — Inorganic Results - Smith's Farm - Operable Unit
        Two RI - Leachate Water Samples
5.5b — Summary of Detected Organic Constituents - Smith's
        Farm - Operable Unit Two RI - Leachate Water Samples
5.5c — Summary of Detected Organic Constituents - Smith's
        Farm - Operable Unit Two RI - Leachate Water Samples
        (Continued)
5.6a — Inorganic Results - Smith's Farm - Operable Unit
        Two RI - Leachate Sediment Samples
5.6b — Summary of Dete.cted Organic Constituents - Smith's
        Farm - Operable Unit Two RI - Leachate Sediment
        Samples
5.6c — Summary of Detected Organic Constituents - Smith's
        Farm - Operable Unit Two RI - Leachate Sediment
        Samples
5.7a -•>• Inorganic Results - Smith's Farm - Operable Unit
        Two RI - Surface Soil  Samples
5. Tb — Inorganic Results - Smith's Farm - Operable Unit Two
        RI - Surface Soil Samples
5.7c — Pesticide/PCB  Results  - Surface Soil  Samples -
        Smith's Farm - Operable Unit Two RI - Summary of
        Detected Constituents
5.8a — Summary of Detected Organic Constituents  - Smith's
        Farm - Operable Unit Two RI - Surface Soil Samples
5.8b — Summary of Detected Organic Constituents  - Smith's
        Farm - Operable Unit Two RI - Surface Soil Samples
5.8c — Inorganic Results - Smith's Farm  - Operable  Unit  Two
        RI - Subsurface Soil Samples
5.8d — Summary of Detected Organic Constituents  - Smith's
        Farm - Operable Unit Two RI - Subsurface  Soil  Samples

-------
Inwgenlc Heeull*
Smith'* Film • Opeiefal* Unit
W**t* SamplM
no HI
Conililu*nl (mg/kg)
Aluminum
Antimony
Aiecntc
Bulum
Bciyllium
Cedmlum
Cetclum
Ctiiomkim
Cobalt
lion
l**d 	
M*gn**lum
Mengin***
Meiculy
Nickel
PotaMlum
8*l*nkjm
BllvM
Sodium
ThiHIum
Vanadium
Zlno
Cyanide
~ STB 2
H*iull
•1*0
• 5(
	 256
15*
1C*
46
• 140
17 7
26*
	 21»
125000
• 7 7
7090
1010
• 1 4
•07
016
1.1
4((
022
111
2((
20
N
—
— •

. _ .
N
y_
B
NU
U
B
BW


U


S





10
10
	






~~ST
R**ull
• 1(0
472
0.50
1400
SO
•40
1(20
21(0
207
MS
41(00
100
1010
720
44
(10
1210
12
1210
0(0
I5(
1410
5410
B-4-
N»
t
U
*
,
»
at
«
u
;-
N*
U
,
,
U
BUM
U
U
U
«
- —
- —









	
2

10




	

IH A 1
Hetull
24(
• 1
0 15
• 7
010
0(4
116
1 4
4 4
• 1
540
1 7
214
5 1
0*1
20
256
025
20
•60
Oil
14
1(5
1 1
NU
UW
U
U
U
B
U
U
N
U
II
U
NUW
U
II
UW
U
NU




IPB 1
Heiull
(100
25 (
1 1
157
40
15
6(200
212
II 0
191
11500
7OO
6950
261
0 12
111
•52
010
15
1070
015
122
1250
1 6

N
BW
....

B
N
U
B
NUW

1
U


NU
...
10

— •

Sampling I ucnttuii
'"ip~c-i~"
FUlull
12100
11 4
20!
Ill
15
1 5
1*70
Sit
'412
22000
160
1(50
516
012
7 7
2270
010
24
477
0 15
225
114
1 5
N
S
N
U
B
INW
U
UW
NU
*
t


Ih
6140
1 7
5(4
15
1 (
1590
22 7
11 1
25600
5000
2190
164
0 10
44 1
• II
1 2
20
13»
0 12
154
1 1
I) 1
NU
S
N
U
1
NU
U
i
U

NU



7000
5

	
IP t 1
Heeull
1060
016
10
02(
0(0
((200
12
4 1
152
1010
1 7
5(400
• 1 0
0 10
202
024
,._ 20
0.12
• (46
090
1.2
NU
BW
B
U
u

u
NS
U
NU
W
U



...
IHF 1
Meat ill
11601
IK
09!
I)]
01
0(
105
1
1
1
Itt
041
7/5
14 4
0 14
76
Oil
26
745
0 16
2 1
120
2 1
>
) BN
k UW
Wl
U
u
B
U
U
U
UW
>
W
YU
1
*u
i
•4




IPO 1
Reeull
57 6
• II 1
0*2
10
01
0 7«
114
1 7
12
45
1 4
766
1 1
0 11
17
017 U
25 U
2170
016 NU
20 U
6 4
16 NU
1
t S

 U IndlccU* »l«m«nl •»•» tnilyitd loi but no) d*l*cl*d «l th* HiUd d*l«cl'  •< limil
 B Indlcal** umpl* value !• bilwcin lh» Iniiiumcnl detection llmll end lit  . jnlncl r«qun«d d««clion lunil
 N Indlcilt* iplko ••mpl* not within i«cov*iy limit*
 8 Indlcil** * v*lu* d*t*imin*d by method a* *t*nd*id eddillon
 W Indlc*!***nelytlc*l *plk* f*coveiy >40Kend <(5W,or > 115%. end Ih* »mple ebtoibcnce or concinlielion
   I* < 50% ol th* (plk*. n*port lh* tempi* i**utt* lo Ih* ln*lium*nl Detection limit (50% fule being epplied )
 • Indie*!** duplicet* anelyil* not wiltiln contiol limn*
 Th* mild column lot **ch eemple locellon Indicelee the dilution tetio ol Ih* «n«lyi«d •impl* (il any)
 « Indlcel** leiulU ete in ug/l
                                                                                                                                                                     TABLE  5.3

-------
Sumnary ol llHtuclutl Oio^inti: t^in
Smith'* Fnim • Op*nth Unil I wo
Wait* ttemub*
ConititiMnt
IfohMM (ne/*g)
f~l,1-TitehicMO*»iin* 	
2-6uanon*
2-H*unofl*
4-M*t*l2-p*nMnon*
Ac* Ion*
Strain*
ttiytMruin*
iUttytan* Cntorid*
SlYiin*
T*ktcMoto*fti*n*
Tolucn*
tricMoKMttwn*
Xytan** (total)
S*m»M>liM*i frnoAfl/
3.3'-OicMoiobwtiidin*
3-Nrtranilin*
{•CMora-S-nwftytotonol
4 NNro*n*n*
fiintolcTScid
^s-ss'113^'1^-
P.itcM.ifCB.mAa)
Pcai2S4
" ~ Mil .".'
R*inH
too
""1400
730
160


11000
• 0
4100
§1
J
A
J+
E
J»"


jf
E
	
2500

2500
100000
"5366
2500
2500


100000
2500
2500
fllluM


• • 	

-



- •

- Tib 4
MOO

•5000
180000
~MOOO
3160000
•300


120000

•300000
R**uN



1700
if"

•
&J*
»
F"
F


•
.—
	

.
2500

2500
15000
2500
2500
"2500


2500

2500

._...
••-•
II' A 1
lies, ,11
"460
-I!? ?

HtluN

.1*
12500
12500
....

" IPO 1
Rajull
"""20
" " 70

to


H«».,n




?.
J»

*
San

L»
125
125
•-

pling l.nculKini
IPC t"
!«•!-!
16
094
51

14
120
Ratiilt
038
•

«
•'
It
I2S
125
J25
125
125
125

I
llos.iM
1 1
10
i 7
0«9
056
17
24
,»
M) 1
.1
J
Ji
125
125
125
125
125
125

125



1000
II
Rulull
04



t 5
- • •
01

58
J.L
1
Jl "
»
125
125
125
125
R..UH


. 0 16



•
•-

IPF 1
Haiuti
..">•
'654
'.*?

1*0
R*MJ||
2 1
0082
0*1
" 029
063
11
04

t
t
—
J»
j* '
J»
J«
Ji
It
250


250
250
250

250
•-

IP
Ruliill
04

13
i i
190
210
"i i
'"40
6(7
; Ti


a t
— fT«.»-
JL

j«
it
r«j


250
250
250
250
250
250
250
2fe
250

 8hnk c«li Indoil* oon*Utu*nt§ *n*V'*d lot but not d*t*ct*d
 J Indicate* *n «.lit*dbl*nk
 E  Indiata* con*Mu*nt conc*ntmtion *»o**d* tt» atbmton mng* ol Hi* iniuuiiwul
 « IndnlM* medium l*v*l*n*ly*l*w** p*i4omt*d
 th* **d oolumn lo» Meh Mmpto loc*«on IndValM •» Mmfil* dilution lactoi (il any)
• IndnM* oono*n
-------
 Inorganic RetulU
 Smith'* Farm - Operable Unll Two Rl
 Leachata Wetei Sample*
Constituent (ug/L)
Aluminum
Antimony
Artenlc
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
lion
lead
M*gnetlum
Manganaia
Mercury
Nickel
Potatikim
Selenium
Sltvar
Sodium
TTiaJllum
Vanadium
Zlno
Cyanide


LW-Ot
Ratull
324
42.9
0.70
622
1.4
3.0
250000
66
20.7
70
3060
3.4
127000
917
	 0.20
350
73800
6.0
96
355000
0.70
7.6
10.3
N
U
U

U
U

y
U
B
NW

y
B
NUto
U
UW
U












S


—




LW-01 dup
Ratull
1160
42.9
0.70
692
1.4
3.0
226000
9.0
20.7
80
10600
1.4
124000
707
	 0.20
.29.0
75100
6.0
35.0
397000
0.70
10
37.0
	 HI
N
y
u

u
u

B
u
B
t
BNVt

L.
NW


UW
B



5
LW
Result
967
429
070
45 0
14
30
~44600C
66
600
90
2020
10
390000
9190
020
aTfdo
6.0
14.0
291000
070
90
690
to
4)2
M
U
UW
B
U
U
J
B
BN
UW
B
U

5
S




Sempling Location!
LW-03
Result
279
77.0
7.0
its
1.4
709W
66
207
tso
3540
	 9.5
27600
500
020
190
23600
12
9.6
64500
0.70
7.6
24.0
10
N
UW
B
U
U
U
U
B
vIS

U
B
NUM
U
U
U
U
10



ivy
Result
22400
281
166
202
32.0
"83900
37.0
46.0
36.0
297000
176
66400
3330
020
200
13500
60
96
126000
070
5O.O
342
to
«5
U
BS
B
>
\J
J
UW
J
to

5



Lw
Reaull
2620
42.9
126
534
1.4
3.0
107000
10
20.7
63
20200
9.7
75300
1750
0.20
_ ... J2.0
43700
2.4
9.6
196000
0.70
110
32.0
to
•O6

N
U
S

U
u


u
1
us

u
NUV\
u
yw
i
t

-

2

Lwoa
Retull
3S4oL'
	 547|
121 JUS
690 JB
1301
"~222J
467J
63JU
MspogJN
ZZIIsFl8
I7400J
7~J730
27600
2.4
96
662000
60
7.6
12100
__.. 227
UW
NU
EUN
U
N
2
20
10
50
 U Indicate* *l«m*n1 wa* analyzad lot but not detected at the listed delected limit.
 B Indicate* ••mpU value U between the Inilmment detection limit and the contract required detection limit
 N Indicate* *pJk* i*mpl* no) within recovery llmfli
 8 Indicate* a value determined by method of (landard addition.
 W Indicate* analytical epike recovery >4OH end <65%. or > 115%. and the temple absorbance or concenliation
    I* <50% ol the tptke.  Report the (ample reiulla to the Instrument Detection limit  (50% rule being ipplied)
 * Indicate* duplicate analysis not within control limit*.
 E Indicate* a value estimated or not reported due to Uio presence ol interference.
| '        ^       t Detected concentration* exceeding Hie CMUI. end Dm loleionco I mill
 The third column lor each sample location indicates Die dilution ratio ol Uio enalytud iumplu (il any)
TABLE  5.5A

-------
Summary ol Datactad Organic Conalituant*
Smith'* Farm - Oparabla Unit Two HI
Laachata Watar Sampla*
Conttituant
VolttHtt (uo/L)
,1,1-Tflchtoioalhana
,1,2-TrlcMoroalhana
,1-CHchloroalhana
,1-CHchloroathan* ;
,2-Dlchloroathana
1 ,2-Dlchloroathana ((old)
2-Butanona
2-Haxanona
4-Mathyl-2-pantanona
Aoalona
Baniana
Chlorobaniana
Chloroform
Ethylbantana
Mathylana Chlorlda
Toluana
Trlchtoro«th«n*
Vinyl CNoild*
XyUn*. Total

LW^>^
R«tuN


20

4
17



18
13
3

34
5
13
4
9
0




-L-


~B~

J




J
J





	


.-*. •


-- —





LW 01 dup
R*tuh


14


11


....... '2
7
	
&
4
5


S




._.. .

B

J
J













LW-02
RaiuH
75
S
25
11

24


6

5
4
"46










BJ



J










-
•-



—
-
Sampling Location
	 LW-03
R»iull
	 -






4


4








BJ
J












-
•
LW

IS

R««ull











-- 	 —


• -- • 	











i 	









	

—


—
LW06
Ratull



	 26
3100
120
1000
15400

190
100


30


J
"E
j
B
J

"j








LW08
n«*uN
330
J100

1800000
31000
21000
1400000
310
85
85000
9200
340
.....


E
E
E
E
'j
E
•-
25
loop


1000
25
25
1000
25
J_...?5
1000
25
"25
 Bland call* Indlcata conttltuanla analyiad lor but not dataclad.
 J Indlcataa an aitlmatad valua.
 B Indlcataa contllluant dalaclad In acioclatad blank.
 E Indlcata* eonttltuanl eoncantiatlon axeaad* th* ealibtatlon tange ol th* in*tium*nt.
 + Indlcata* a madlum lava) analytla waa partoimad.
 Tha Ihlid column loi aach *ampla location Indlcata* tha **mpla dilution lactoi (II any).
 •• Analytleal raaull* fiom lha 0/20/90 and 3/21/91 (ampllng d*la* aia compiled lot Ihl* location.
                                                                                                                                             TABLE  5. SB

-------
Summary of Detected Organic Constituent*
Smith'* F«im - Operable Unit Two Rl
LeeeheU Weter Sempte*
Constituent
S»ml-vol»HI»» (UQ/I)
\ ,2-Dlehlorobeniene
2,4-DlmethyJphenol
2,6-Dlnltrototuene
2-Melhytphenol
2-Nltroenlllne
2-Nrtrophenol
3.3-Dlehlorobenildlne
3-NHroenHlne
4-Chloro-3 methyl phenol
4-Melhytphenol
4-NHfocnlllne
4-Nlttophenol
Acenephthene
Beniolc Acid
Benio(b)luorenthene
bl*(2-chtoro*lhoxy)m*lh*n*
bl*(2-chtorol*opropyl)*th*r
b|i(2-Ethy)hexyl)phthetet«
Butyl beniyl phlhelete
DUthylphlhelet*
Dtmethylphthelete
Dl n butyfphthcUU
liophoron*
NHiobonion*
P*nUohtoroph«nol
Phenol

LW-01
Rotult

11

21













7


• - 	 -
2


















"j




J














---
---



	



	 LW-OI dup
Result

9















e




2



J



-
...
J

J





--
"•




.„

Si
IW02
Retult














	

















-

—



— -

• —









•-







-•
mpllng Locetiont *nc
LW-03
Retull











... .
. 	 '_. -








....


...


















1 Data*
LW-05
Raiull
. 	






-



	



... .._














c






-
.__.




...




-





LW 06
Reeull
t
300

5900
4







	 ..





	 16

500

iiboo


j

—








E

-
•-








-


	 Tl
iwoa
ReiuN
"leoooot
1C
3500000
44
160
160
	 92
980
3000000
240
300
510
"62
5)0
"si
t;
SIO
62
44
74
210
4900
1500000
16
5000000

J
J
J
J
J
J
J
j
j
J
j"

J
J
j
J
J
20000
20
20000

20
20
"" 20
200
20000
20
	 20
200
20
" 20
	 20
20
20
"1".'.?9
20
20
20000
20000
20
20000
 Blenk celle Indlcete conitllucnte enelyted (01 but not detected.
 J Indlcete* en ettlmeted velu*.
 B Indicate* eonttlluent detected In ***ocl*t*d bl*nh.
 E Indloete* conilllu*nt concentretlon exceed* the cellbrellon r*nga o< the intliument.
 •f Indleete* • medium level enely*!* we* perfotmed.
 The third column for eech temple locetlon Indlcete* the *empla dilution (actor |il eny).
 •• Analytical laaull* horn the 0/20/90 and 3/21/91 tamplinQ data* ate compiled tor Ihlt location.
                                                                                                                                                TABLE  5 . 5C

-------
Inorganic Results
Smith'* Farm • Operable Unit Two Rl
Lcachate Sediment Samples
Constituent (pig/kg)
Aluminum
Antimony
AiMnlc
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Laad
Magnesium
Manganaie
Marcury
Nickel
Potassium
Selenium
Slrver
Sodium
Thallium
Vanadkim
Zlno
Cyanide

LS^I
Result
12000
389
2t.fi
217
4.1
3.4
96000
t4.t
12.9
2.0
29500
23.3
4140
•12
0.16
32.6
1930
038
4.1
	 395
_ 0.22
23.5
63.7
2.0


N





N
BN
NU

S
U
N
U
B
U
N
U



S








2
...
...
-
LS4>2
Result
17500
30.0
te.«
43.2
6.3
2.7
2300
21.3
«t .9
3.3
44100
18.7
5290
958
0.15
78.4
2820
0.36
_ 	 jj
444
021
30.3
	 162
1.9

N
S
B



N
M
BN

S
U
*J
U
U
B
U
N
U


4








2







IS
Result
16100
420
19.7
130
5.2
_ 3.2
25200
26.0
17.8
2.5
35800
65.4
11700
796
0.20
40.0
3640
0.40
38
494
028
35.2
143
2.5
O3
N
S


1
BN
NU
S
U
N
U
U
}
U
 40% end < 85%, or > 115%, and Hie sample absorbanco or concentration
   I* <50% ol the spike.  Report the sample results to the Instrument Detection Limit  (50% rule being applied.)
 • Indicates duplicete analysis not willim control limits.
 E Indicates a value estimated 01 not reported due to the presence ol mlorivionce
I       =m.... i     j Q8|Bcjetj eO|,ccl,|Iai|ons exceeding the CRDl  ond Ilio lolciance I mill
 The 'third'column lor each sample location indicates the dilution mho ot thu mialyjud snmplu  (il any)
TABLE  5.6A

-------
Summary ol Dal*ct*d Organic Constituent*
Smith'* F*im - Op*r*bl* Unit Two Rl
L*ach*1* S*£m*nl SampUa
Conttlluant
Volttlltt (motto)
1 .1 ,1 -Trtchloroathan*
t.1-Dlchlofo*th*n*
2-Bu1«non*
2-H*x*non*
4-M*thyl-2-p*nt*non*
Aoaton*
B*ni*n*
Chtorob*ni*n*
Ethyjb*nt*n*
M*thyt*n*Chlortd*
Styren*
Talraehloroathane
Totu*n*
Trichtoro*th*n*
Xytma. Told
Sampling Locations
IS 01
Raiull









0.013



" 0022












--













LS02
Rciull
0.03
0008



0.072






"6.021










...._





-


1803
Ratull

— •-•


7.5



... ..

+
....



--
125




	
LS-04
Raiull
- ••--•
	
0.044



0.002

• • --


-
•-
•

BJ


._.


.-
...



LS
n»suii

0.14
0033

OS




LS-06
naiull
575
	

-•
..__





....
	

....


._.

-
LS 06 dup
Retull
" 	 1.4

0.21
3



0.032


0.018
~~6.bl7
E


:



. ..





Lsoa
Ratutl
88
1.6

60

25
2.2
12
890
3.4
" ~26
"21
6356
"a"?
31*00
JV
Jt
j»
jf
]»'
t
f
»
»
2500
2500

125000

2500
2500
2500
125000
2 SCO
125000
"2500
125000
~25OO
125000
Blank calla Indlcala eonitlluanla analyzad lor but not dalaclad.
J Indkataa •naitlmatadvalua.
6 Indtcata* eontllluanl dataeladln •••ocUUd blank.
E Indlcalaa eonalltuant eone«nlratlon •xeaada Iha calibration rang* ol Ih* Intlnjmanl.
4  ln«Jlc*t*a • (Mdlum l*v*l *n*ly*la w*» p*rfortn*d.
1h* third column tor *«oh aampl* location Indicate* Ih* tampl* dilution (actor (il any).
                                                                                                                                          TABLE  5. 6s

-------
Summary ot Detected Organic Constituent*
Smllh'e Faim - Operable) Unit Two Rl
Leiachaie) Sediment Sample*
Constituent
S»ml-vol»UI»» (mg/kiif
1 ,2-Dlehlorobeniene
1 ,4-Olehlorobenxene
>.4-Dlmethwlphenol
t-Methyln*phth«Jen»
•-Methvlphenot
l-ChJoro-3-mathyt phenol
••Metnylphenol
koenaphthene
tathrecene
leniole Acid
)enio(a) anthracene
9ento(a)pyrene
ienio[b)fluorenth*n*
)enio(o,h,l)pery1
Rtiult

014











~0.24

0055


0.035
028
0495






0.099

J




—


._..

J

J


J
J
J



—
J










—

—








—

...


LS02
RttuH

0.2




	

0.021




"b.37





0.18





6 02fl



BJ







J




J "





BJ





J ""


-
-

LS-03
Rotull
".. ..2?
110
-. ?§p
400
310
350
170
200
400
••— yj
'. ??
940
120
200
."." **
910
920
J
J
J
J


75
	
"75
z?
75
75
75
75
75


75
75
75


75
75
75

75
75

75

LS
Sir
•04
npling Loc»li<

H««ult
. 	
	

	
0.088

1.6


- — -






6.17

012
—
J

J












J

J

-•


...


-...
—




LS
Reeull
013
0.32
029
052
015
04
0.34
079
o!b56
0.13
066
0.68
ins
05
J
J
J
J
J
J
J

J
1


.._
-•


-



LS-06
Reeull
0.47
1
0.58
~~0.3
0~92
1.2
067
0.82
0.46
0.39

1.2



0.41
~5"e
0.24
0.55


3.1
12
2.4
j"_
J

J
J
J
J
J
J
j
j

J

1'

BJ

j
J


--
j

--

—
—
--

....


...

—

...

LS-06 dup
Roiull
0.04
" 0.73

1.4

0.81
0.23
067
"a
6
.6

.6
.2

1.6
0.18

0051

4.4
"b^B
09
0.13
0.12
3
1.4
"4.5
J
)



...





-





Houll
_M
190
1

" 1200
140
18
"306
9.6
45
14
L808
f
+
il
\l
t
»




	
--
. _..

. —

_. .
Blank ccllt Indlcal* conttllucnt* analyzed (Of but not delected.
J Indicate* en ettlmaled value.
B Indlcelet constituent delected In aitociated blank.
E Indlcatee conetlluent concentiallon exceed* the cellbietlon range ol the intliumenl.
4  Indicate* a medium level enalytli we* performed.
The third column lor each (ample location Indicate* the *emple dilution (actor (il any).
TABLE  5.6c

-------
Ino n)ank Raiutti
ototttTaFanii • Opa>abl«> Unit loo Rl
SuitJC* BaH aamplaa
ConMftuanl (moAgJ
Mumlnum
Mmonv
Af*anle
laitum
Ban/Mum
Cadmium
Calcium
Wuomkim
Cofaa*
Coppa.
ion
Laad
Maa«a«lum
Uanganata
Maituiy
«cM
•ofeaakw
BiliBlum
SIW
BodkM
IhaMurn
i/inadkim
line
CyanUa

89 01 A
aVlt/90
fla«u«
10600
15 »
33
an
29
0*4
aia
144
• 4
11
1*200
7*
7210
IK
OH
1*0
1410
089
80
897
0.19
811
04.7
11

N

B

U
e

a
u

NS


U
...
NU
U .
BU
U


U
-•

-



-

4




-•


SSO2A
*/t
Rain*
14400
aai
• 5
440
44
14
7*0
217
104
59
8*700
• 4
4110
217
oia
11*
2090
08*
aa
87*
01*
114
II*
14
I/M
N

B


B

B
B
N
LI
NU
U
11
U
U

...
-



-
B3-01A
•en
.as*
14000
114
• 1
6*0
1*
0*1
•63
171
11*
*•
20700
19*
4120
341
on
i*t
1710
030
aa
87*
014
303
M«
1 4

MO

BN
9


B
B
B
..._
N

U
...
B
U
LJ
u

u





...
9

-

S3 OIA
9/70/W
RMU*
moo
1*9
sa
51*
a*
0*4
114
1*3
• 0
a*
ItBOO
'134
1770
187
018
209
•7*
040
ai
014
111
49*
19
N
B
B
B
NS
U
B
B
U
U
1
u
!
2
SS
e/?
H.vutl
154 UO
139
171
66*
99
16
2*5
726
84*
• 8
41100
21 1
1740
1040
on
470
2UUO
062
aa
218
014
140
115
1 4
Sampling location* and Ratei
05A
u/uo
N
N
—

B

N

N
U
BW
II
I
IW
u-
1





5




SS
9/7
Hitult
14100
094
78*
89
1 1
278
139
iaa
44
17900
901
1010
M4
Oil
101
798
017
aa
878
014
289
91 7
14
06A
0/90
NU
BW


B

B
N
U
B
B
U
U
uw
u




10




S3
9/2
R.iutl
15100
491
10*
971
97
14
74}
72*
21*
71
448(10
197
1510
as*
012
764
tin
052
81
268
014
394
550
1 5
07A
0/90
H
N9

B


N
N
LI
U
l





i


SS
9/2
Rnull
I8HOO
24
485
44
16
1*1
194
129
96
3370O
15 1
4450
729
012
358
1470
094
22
284
0 14
379
103
1 9
DBA
0/80
N
NS
--

B
N
[
N
U
JW
-




i


SS
9/a
18800
31
9
96
1*
12
474
171
121
10
27100
115
1510
244
017
401
2080
OK
21
287
014
Ml
15
09A
0/90
N
NS


B
N
1
i*
-


.






2




-



99
9/2
RaiuH
I470C
24
1*
OS
4
1
•491
708
17.1
150
17200
778
7780
430
012
in
7400
060
23
784
049
791
111
19
IOA
11/90
N
NS

N
N
S

SS MA
8/ 18/90
H.iull
.»f
452JB
"1
J"
39
20 (
IJJ
49
13«00
112
4010
251
012
401
3230
078
11
281
0 18
38 1
128
	 ^J
H
'
NS
U
aw
u
ii
u
U
Background
Hanga
IOHOO 71800
116742
4 10 1
1*9071
33*7
in
181 4 13
145784
79 121
5126
712OO 39IOO
Sill 1
2510 4IUO |
175735
Ml
74241 7
I2M2990
HO
NO
NO
Ml
786394
872 107
NO
cno
IOOO
10
20
0*
IOOO
004
9
IOOO
1
a
IOOO
a
10
4
a
lolannca
Uml
117
794

'
430
7*7
11*
17*
47906
1*1
98*3
2541
01
_ 911
lew
01
87
144
07
4)9
114
1*
 U Indkatoa atamanl •» analpad tor bu« not dalaclad al dn limn
 N Indtotaa cpka aampla no) nWtln tacoxiy Imte
 B Mk»t*a a Mlua datormliwd by mathcxl o) dandatd addmon
 W ManlnaMykal apMa Mcevaiy >40» and < *5%. 01 > 119%. and ttta aampla abtoitianca 01 concaniiillim
   Mia«Ci»a RapaitlNaumplamuittuaialnitfUfflanlOalacllanllfflli |5U» nut lulng appiKd |
i                I  OMaclad c«neanMlloni aitaadlng lha CROl and ma lolannta I Imlt
 •  Indkalaadur-lcawanaV*** "ol*RMnconbollimit*
 NO IndlcalMnodMacttbUbacliaioundianaa
 Ttia Mid column lor aach aampla hxallon Indkjl.i lha dilution rallo ol lha analyiad tampl* |H *"yl
                                                                                                                                                                                    TABLE  5.7A

-------
 ln<»g«nlc Hsiulli
 BnMTtFtfl* • 0|>«mtato UnN tvo Rl
 Suite* Soil SimplM
ConiMucnt ImoAQ)
(UumtnuM
*****
Aiwnfc
SwVim
BwyMum
UdniluM
Cakkm
OnifiluM
Cob**
Cot*.
ton
LMtf
UtgnMlum
MtngtiuM
MMtunr
McM
•otaMlum
Ottvtum
a**
Bodkin
n»*)UA4Oft«nd «8i%. at > II9», *nd tti* wmpK (bwituiK*
   H <90%o» RtporttWMmpl«CMulliloa<*lntliuRiinlO«Knanllnill  (9O%
|  n   i nrn I-T| Q^^,^ unc4«rii«lani (icMdlng OK CHOI «nd tt» Iol4mnc« I Imll
^ kidhalMdiviHuUiiMV1'* Ml "I*!" conuol llmlt»
 NO lndk»W« no d«l»c»t>U NKkoioundr.no>
 Th« BiUd column toi <*ch MmpM location Indium d.« dilution mUa ol lh> •n*h/i«d umpU |il
oi ioni*nir»itun
    • ppllMt)
                                                                                                     TABLE   5.7D

-------
Table
Pesticide/PCB Results
Surface Soil Samples
Smith's Farm - Operable Unit Two Rl
Summary of Detected Constituents
1
Detected i
Constituents ;
Heptachlor Epoxide
4,4'- DDE
4,4'- DDD
4.4'- DDT
alpha-Chlordane
gamma-Chlordane
Location, Sampling Date and
Concentration Units
SS-20A-1 s SS-20A-1 dup
9/20/90 ; - 9/20/90
ug/kg ug/kg
5.7 J 5.7 J .
23 27
58 55
47 60
15J 15J '•
7.8 J 8.1 J
J Estimated Concentration.
* Analytical results represent an oil sample obtained at this location.
                                                   TABLE  5.7c

-------
Summtfy t lO«l*iloJ »ni«o«
              '
 }b*ntohiitn
                             SS IA
                                              58 8A
                                             029
                                            oou
                                                                             uuov  B
                                                                                          uuiliuni
                                                                                               SSM
    S-iB*.

lUlull
                                                                                                                                              0002
                                                                                                                                           "Mull
                                                                                                                                               0 12  J
                                                                                                                                              OOTi
                                                                                                                                              031
                                                                                                                                              010
-. 5'i
•••tin
001
I4xi.ll
"oo;
01
001
0(M3
Oil
Oil
n i?
IIIH4
u i;
pnvi
»A
e
i
s
)
t
i
t
i
.1
t
i








SS MA
HMUII
HMU!
""01


oo;


i


i


                                                                                                                                                                                   J
                                                                                                                                                                                   J
                                                                                                                                                                              01?  J
                c«nililu*nl* «n«lyt*< DM ultmtnn nng* ol Ih* Intliumtnl
 lh« *iM column to) ««ch MHI|>|» lacxdan IndlcalM Ih* umpu dlluuon kcloi |« >ny)
                                                                                                                                                                                   TABLE   5. BA

-------
                        L Conmiiu«nit
8mlth'«»•«* • CJp«™t>l» Unit l«n Ml
Suite* Oo» t)*ntpl*i
                                                            SSIM
                                                                               Sanijjliny louiliunt
                                                                                            SS ISA
                                                                                         lu.un
                                                                                           OOJll
                                                                                                        	SSj&J

                                                                                                        Mnun
                                                                                                           0 II BJ
   SSI/J

lloiull
llexill
   OOA  J
   S3 I
—	•

Hnull


  OOI2|

fluuB
                                                                                                                                          ooeJ
                                                                                                                                           0)1
                                                                                                                                            ii
                                                                                                                                            ii
                                                                                                                                           to>i
                                                                                                                                           6}
                                                                                                                                                BJ
                                                                                                                                               BJ
                                                                                                                                                           SS IK A
                                                                                                                                                        flnull
.... Si»i.
                                HMull
                                    0    J
Bunk c««> kidluu con«Hu*nl> (lolyixl loi l>ul not
C kvtuM uniMtMnl eont.fXn.Uun « Initpum.rM
« Mk«IM« mwJkjo towUMVi* MipwtoimMl
111* tibd column hi wch »mpl* touuon IndkatM Ux Mmpto dilution hcioi (il «ny|
                                                                                                                                                                             TABI.B  5.8s

-------
 Inorganic Reiullt
 Smith'i F«rm • Operable Unit Two Rl
 Subturface Soil Sample*
Constituent (mg/kgj
Aluminum
Antimony
Areenk
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
5?ER?1...
ron
Lead
Magnedum
Menganeae
Mercury
Nickel
Potassium
Seknlum
Sirver
Sodium
Th (Ilium
Vanadium
Zinc
Cyanide _
SS-«B
9/20190
ReiuN
18000
43.4
7.6
495
4.7
0.94
322
23.5
12.0
	 237
34000
9.0
5700
. . r - .=--- s?--.
153
0.12
27.7
1750
0.26
2.3
264
0.14
329
105
1.5

N
B


B
a




N

U


U
U
U
U

y
•
—












SS4f
9/2C
Result
21600
252
12.9
691
66
	 2jj
257
15
TTl 'Til Kft
__1SJB
22.2
48800
_^20.5
6300
X10
012
358
1990
028
2.3
286
	 0.14
_ 46.5
119
15
Sa
Idup
1/90
N
B
....

NS

U


BW
U
U
U
U
mpl


5







ng Locatio
sis
9/2(
ResuH
16700
325
32
32.3
42
1.6
378
183
10.9
13.2
32300
11.8
5200
208
0.12
34.1
3480
0.42
2.2
401
0.14
31.8
995
1.5
ns an
88
)/90
N
N
B
B
B
B
N

S
N
U


BW
U
1
U
)•
dD


2







ales
SS
9/1!
Result
-™. — „„...
31000
364
9
71.
6.5
6.3
914
. 37.5
^_1SJ
21.2
42200
159
4730
219
012
35.9
2420
0.28
22
501
0.16
64.1
809
1.4
13B
1/90
N
B

NS

U


NU
U



4





-

 U lndk«l*« •lament *•• Miclyied for but not detected at the listed delected limit.
 B Indicate* **mple value li between the Instrument detection limit and lha contract requited detection limit.
 N Indicate* iplke sample not wfttiln recovery limits.
 S Indicate* • value determined by method ol standard addition.
 W Indicate* analytical *plk* recovery >40% and <85%, oc > 115%. end tha sample abtorbance 01 concentration
   U <5O%,ot the (pike. Report the tample results to the Instrument Detection Limit. (50% rule being applied)
||  	'.'."''. ~$ Detected concentrations exceeding ttio CROL and the Tolerance Umll.
 ^ Innate* dupiicata analysis not within control limits
 NO Indicates no detectable background range
 The third column tor each sample location indicates the dilution rutio ol the analyiod sample (if any)
SS HB
9/19/90
Result
21200
32.
79
47
6.3
1 9
209
246
„.. jj?j|
J99
44700
9.2
2620
192
0.12
29.0
1350
028
22
264
0.16
45.2
66.3
IS

N




B



NS
U


NU
U
1
u


1










3










Background
Ruiiye
1060021600
11. B 74 2
4-101
19.962.1
3362
118
162-413
14.5-26.4
7.9-12.1
5-12.8
23200-39700
5.9-17.1
2510-4690
125-235
NO
24.241.7
1250-2990
NO
NO
NO
NO
26.8-39.4
57 2 107
NO
cno
4
1

40


1000
J
10
•
20
0.6
1000
3
0.04
8
000
1
2
000
2
10
4
2
Tolerance
Llmil
24356
801
11.7
754
6.6
2.1
430
287
136
128
42906
191
5595
256
0.1
513
3669
03
27
344
02
435
tie
1 8
TABLE   5. 8c

-------
Summary ol Detected Organic Constituents
Smith's Farm - Operable Unit Two Rl
Subsurface Soil Samples
Constituent
Volaliles (mg/kg)
t.t Dichloroethane
Acetone
Melhylene Chloride
Semi volaliles (mg/kg)
\ .4 Dlchlorobenzene
^!?(2 Ethylhexyl) phthalate
Din butyl phlhalate
SS
Result

0.036
0.01
Result
4B
B
B

SS4B
Result
0.017
001
Result
0.074
dup
B '
B

Sampling Locations
SSBB
Result
0006
0023
Result
1.1
005
J
J

SS 13B
Result
Result
0.076
068
0027
J
J

SSI
Result
Result
Oil
022
40
J
j

Blank cells indicate constituents analyzed lor but nol delected.
J Indicates an estimated value.
B Indicates constituent detected in associated blank
E Indicates constituent concentration exceeds the calibration range of the instrument.
+ Indicates a medium level analysis was performed
The third column for each sample location indicates the sample dilution (actor (il any)
                                                                                                           TABLE 5.80

-------
                      ATTACHMENT 5.1
Analytical data from the sampling of the Unnamed Tributary

-------
                                                 SAMPLE AND A WAI. VS IS MANAGfMFNT  SYSIEM
lP«-Ktlj|l)N IV E!
PURfiEABLE ORGANICS DATA REPORT
• •
• •
• •
























PROJECT NO. 90-899 SAMPLE NO BOOM SAMMI f IYPI GROUNDWA
SOURCE. SMITHS FARM
STATION 10: MW22A WELL
UG/L ANALYTICAL RESULTS
S.OU CHLOROMETHANC
S.OU VINYL CHLORIDE
5 OU BROMOME THANE
S OU CHLOROEIHANC
S OU TRICHLOROHUOROUe THANE
S.OU 1,1-OICHLOROETHENEO.t-DICHlOROETHYLENf )
SOU ACE TONE
12U CARBON OISULFIDE
S.OU UETHVLENE CHLORIDE
SOU IRANS-I.2-OICHLOROETHENE
S.OU 1.1-D1CHLOROCTHANE
lyu VJNYL ACETATE
S.OU, CIS-T.2-DICHLOROCTHENE
S.OU 2.2-DlCHLOROPROPANE
SOU METHYL ETHYL KETONE
S.OU BROMOCHLOROUE THANE
S OU CHLOROFORM
S.OU I.I.I-TRICHIOROE THANE
SOU 1.1-DICHLOROPROPENE
5 OU CARBON TFTHACHLORIDE
5 . OU 1 . 2 -0 1 CHL OROE THANE
S.OU BtN/tNE
S.OU TRICHLOROFTHENEI IRICHLOROETHYLENE )
SOU 1.2 OICHLOROrROPANE
S.OU OlRROMOMFIHANE
S.OU BROMODICHLOROME THANE
bD. AIMLNS. GA 10/02/90
PROG ELFM f.SF COLLECTED 0V. B CAPRMA .,
r.iT*: IHEPERDSVI si: KY ..
COLUGJION START: 09/I9/9O I3IO MOP; On/OO/00 ••
"G/L ANALYTICAL Rrr.llllS
5.011 CIS 1.3-DICHLOROPROPfNE
1211 MEIHYl ISOBUIYL KETONF
S OU TOLUENE
S.OU TRANS-I.3-DICHLOROPROPFNE
5 OU I.I.2-IRKHLOKOE THANE
S OU TETRACHLOROETHENEI TETRACHLOROE TMYLENE )
SOU 1 ,3-DICHLOKOPROPANE
12U METHYL BUTYL KETONF
S.OU OIBROMOCHLOROME THANE

5 OU 1.1.1.2 TETRACHLOROE THANE
5 OU FIMVL BEN/L-NE
5 OU (M- AND/OR P-JKVIFNE
S.OU 0-XVLENE
S OU SIVftENE
5 OU BROMOFORM
5 OU BROMOHEN/ENE
SOU 1 . 1.2. 2- IF TRACK! OROE IHANF
6011 1 .2.3-TRICHLOROPROPANE
r» TiU O- 1 Hi uliiMUL U£Nfc
5 Oil T CIILOROIOLUCMC
SOU I.3-DICHLOROBEN2ENE
5 OU I.4-DICHLOROBFN7ENF
b OU I.2-DICHLOROBEN7ENE


• t(REMARKS* ••
                                                                    • ••REMARr.S"1
•••FOOTNOTES***
   • /(-AVERAGE VALUE     *NA-NOT  ANALV2FD    •NAI-INTfRrERENf.ES  «.l-f SI (MAlEP VAIHE  *N-PRESUMPT IVf fVIOENCE Or PRCSfNCt OF  MAICftlAL
   • K-AC10AL WAtUI  IS -.NOWN III  Bt  KSS 1MAN, VALUE GIVEN  .L-ACIUAL VALUE IS KNOWN TO BE GREAKR  I MAN VALUE
   •U-MATERIAL HAS  ANALV2EO FOR BUT NOT DETECTED  IHE NUMBtH Is IHE MINIMUM QUANTIIAIION LIMIT

-------
                      ..  .
EXTRACTABLE  ORGANIC* Ife/A REPORT
                                                  SAMPLE AND ANALYSIS MANAf.FMFNT  SVSIFM
                                                      EPA-RtGION  IV ESD.  AIHLNS  GA
                                                                                                                              10/04/UO
PROJECT NO.  90-899    SAMPLE NO  50OI3  SAMPI.F  IVPf   CROUNDWA
S«IORI F  SMI IMS FARM
STATION 10:  MW22A WELL
                                                                                                                        ..
                                                                        PROG  El EM  SSF    COLLCCIEO BV  (ICAPRIIA
                                                                        CITV   SlimNOSVI             SJ: K.V
                                                                        COLLECTION START   09/19/90  1.110    SKIP  nn/oo/oo
    UC/L                 ANALYTICAL  RESULTS

    10U   BISC2 CIILOROCTHVU ETHER
    MIU   BIStV-CHLOROISOPROPYL) ETHER
    IOU   N-NITnObODI N-PROPVLAMINt
    IOU   MtX All ILOROE THANE
    IOU   NITROBENZENE
    IOU    ISOPHORONE
    mil   BIS<2-CHLOROETHOXY) METHANE
    IOU    1.2  4-TRICHLOROBEN7ENE
    IOU   NAPHTHALENE
    1OU   4-> Hi OfOANIL IMC
    100   HCXACIILOROBUIADIENE
    1UU   jf-MblHVLNAPHTHALENE
    IOU   HEXACHLOROCVCLOPENTAOIENF (HCCP)
    IOU   2  CIILORONAPMTHALENE
    IOU   2-NITROANII INE
    IOU   DIMETHVL PHTHALATE
    tllti   ACENAPHTHVLENE
    IOU   2  6-OINITROTnLUENE
    IOU   3-NIIROANILINE
    IOU   AC.FNAMHlHtNt
    IOU   OIBCN70FURAN
    Kin   2,4-UINIIROTOLUENE
    tOU   OlflHVl  PMlM»| Alt
    iou   FLUOREIJE
    IOU   4-f.HLOROpmNVL PHENVL ETHER
    IOU   4  NITROANILINE
    tOU   N-NIIROSOniPHFNVLAMtNE/OIPHENVLAM|NC
    IOU   4-BRGMOf-Ht NVI  PHI.NVI  llMtN
    tOU   HtXACHLOKOUENZENE (IICOI
    IOU   PHtNAN1MR INF
    IOU   ANTHRACENE
    Km   01 -N-BUIVI PHTHALATE
UG/L

 1011
 Mill
 tOU
 IOU
 IOU
 IOU
 1011
 IOU
 tOU
 lOli
 HVI
 (Oil
 IOU
 iou
 IOU
 20U
 IOU
 IOU
 IOU
 IOU
 :-Oi:
 IOU
 IOU
 1(11'
 IOU
 20U
 ?OII
 IOU
 ^)U
 ?OU
                                                                                       ANALYTICAI  RF'.UI

                                                                         FLUOlUNTlirNt
                                                                         PVRtNF
                                                                         BEN7VI nilTVI  niTIIAIAtt
                                                                         3.3'-OI(:ilLOROBENZIDINE
                                                                         BFN/OIAIANTHHALENE
                                                                         CHRVSENE
                                                                         FIIS(7-t IHVLHEXVI. ) PMTHALAfE
                                                                         DI-N-OCIVI PHTHALATf
                                                                         RFN?0(B AND/OR K)FLUORANTH[NC
                                                                         11,'DCNC (1.2.3 CD! PVRCMF
                                                                         OinFN/OIA.HIANTHRACENE
                                                                         BtN70(CHI (PFRVI FNF.
                                                                         PHENOL
                                                                         t i.HI OHOpHtNOI
                                                                         BENZYL ALCOHOL
                                                                         V-MMIWI'MtNOL
                                                                         13 AND/OR 4- IMFIMVI CH» Ndl
                                                                         2 NIIROPHENOL
                                                                         P 4-OIMI  lMVLPHfm.H.
                                                                         (UllZOIC  ACID
                                                                         2.4-OICHLOROPHENOL
                                                                         4-tttLORO-3-MKTHYI PHf Nl»
                                                                         3.1.R IRICHLOROPHENOL
                                                                         ? 4 «;-IH|rHlOROPHFN'JL
                                                                         2.4-DINIIROPHENOL
                                                                         /I-NI IHl'I'MlNOL
                                                                         2. 3.4.6-TFTfiAC.HI (INllMlli NHI
                                                                         ?-MtlHYI  1.6-DIMIIROriirNOl
                                                                         PtNlAdll  UHOPHlNIII
 t oRIMARKS***
    '2-AVERAUt VALUE    .NA-MOT  ANALYZED    «NAI-INTFRFIftf Nl FS  ••>-( SI IM«lf 0 VA| lit  -N PRFSUMPTIVf f.VIOtNCt OF PRESCMCC Of UAItRlAi
    • K-ACTUAL VAlUf IS KNIIWN  I"  Ht  IFSS IHAN VAl UF  CIUFN  «l  AC1UAL VALUE  IS KNOWM TO Rf r.REAIIR  (MAN VAI uf lilVf.N
    • O-MMERIAL WAS ANALYZED  FOR BUI  HC>', i.fUl lfl>  IM|  N|>UM( u |S IMF MINIMUM QUANItlOtlON LIMIT

-------
                                                 SAMPLE  AND ANALYSIS MANACrfMFNf SVSIfM
                                                      EPA-REGION IV ESO.  AllltNS. GA
MISCELLANEOUS  EXIRACIABlF COMPOUNDS -  DATA RFPORT

                            SAMPLE NO. SOOt3   SAMPLE  TYPE  GROUNDWA
                                                                                                                             tO/04/
-------
PfSIICIOrS/PCB'S DATA REPORT
                                                  SAMPIt  AND ANAI.VSIS MANAGFMFNI  SYS1IM
                                                       El'A HIGIOM IV tSO. ATHENS.  GA
                                                                                                                                10/11/90
PROJCC1 NO. 9O-B99 ' SAMPLE NO 50013 SAMPIt
SOURCE: SMITHS FARM
STATION 10: MW22A WELL '
UG/L
O IOU
0 IOU
0. IOU
0 IOU
O. IOU
0. IOU
0 IOU
0 IOU
0 IOU
0 IOU
0. IOU
0. IOU
0. IOU
o tou
0 IOU
0 670
2.4U
2 4U
2.4U
ANALVIICAL RtSUI IS
AlORIN
HfPIACHLOR
HEPIACHLOR E POX IDE
ALPHA -BMC
BE 1 A -BMC
GAMMA- BHC (LINDANE)
DELTA-BHC
ENDOSULFAN 1 (ALPHA)
OIELDRIN
4.4--ODT (P.P'-OOTI
4.4--ODE (P.P'-ODE)
4. 4' -000 (P.P'-OOO)
ENDRIN
ENDOSULFAN II (BETA)
ENDOSULFAN SUI.FATE
CHLORDANE (TECH. MIXTURE) /I
PCB-1242 (AROfLOR 1242)
PrB-1254 (AHOCIOR 1254)
PCB-I22I (AKOCLOR 1221)
IVPI : GROUNDWA PRdii U I'M. SSF COLLECT! 1) IW: OCAI'MIIA
•:ilV: MUPCRDSVI SI: KV
COI.Lrr.llON STAM: 09/19/90 1.110 MOP 00/00/00 •
•
U(i/L
i> <1II
2 111
2 411
2.411
3 1U
	
_. _
	
	
	
	
	
	
—
0 7011
0 IOU



ANAI.YI II Al Kt MM IS
PCD 1232 (AROCIOR 123?)
I-CH-124B (AROtl.OR I?4H)
ITB -1260 (AKOCI.OH 1200)
PLH-IOI6 (AROCLOK 1010)
IOXAPMFNE
CHLORUCNE /2
ALPHA (.Ml OROrNF. /2
HI IA CKIORDtNr. /V
(.AMMA-CIIIOHOtNF /2
(iAMMA-rillOHDANE /2
IRANS-NONAI.MLOR /2
ALPHA-CIILOROANC /2
CIVNONAf.IU.OR /2
OXVrillOHOANF (OCTACMLORtPOXini ) n
MF IIIOKVI HI OR
E NOR IN Kl K1NE


•
••'REMARKS*•
                                                                     • ••HI MARKS* ••
   • A^AWERAGE  VALUE     »NA-NOT ANAIV2ED     »NAI - iNURFERENff S  •J-tSIIMAUD VALUf   •N-PRESUMPM VE I VMM NCI  OF  PHtSINU  (II  MAIfHIAl
   • K-ACTUAL VALUE  IS KNOWN TO BE LESS MIAN VAl Ut  (,IVIN  «|. A( IIIAI  VALUE IS KNOWN  10 HI CRFAItR  (MAN VAltll  (,IV(N
   • U-MATfWIAL  WAS ANA) V/FD FOR BUI NOT DCIirilO   Mil  NUMIIt H IS HIE MINIMUM OUANIIIAIION  I IMII                 C-f.OMF IKMI 0  HV (1C/MS
    1  WHfN NO VALUE  IS RIPORtlO  SEE CHLORDANI CONST I lur.NIS     ^  CONSII lUfNIS OR MflAflOLKtS  Of irCKNUAl rill OHUANI

-------
                                                 SAMPLE AND ANALYSIS MANAGEMENT SYSTEM
METALS DATA REPORT                                  EPA-REG.ON .V ESD.  ATHENS. GA.                                         ,0/18/go
                                                                                                                 .

              iSi,2?~??2u '  SAMPLI  "°  80013  SAMPU Tm:  CR°UND»A ,   PROG ELEM:  SSF    COLLECTED BV:  e CAPRITA
      SOURCE:  SMITHS FARM                                              CITY-  SHEPEROSVI             SI-  KY
••    STATION  ID:  MW22A WLL »                                          COLLECTION  START: 09/19/90 ; 1310   STOP: 00/00/00

•••  •  •••••••••••••••••••••••••••••••...,.,..,,.,,,,,..,,..,
                         ANALYTICAL RESULTS                           MG/L               ANALYTICAL RESOL1S
      ...  fi5SJHIC                                                      ^28  MAGNESIUM
      NA  BORON                                                        >.0  IRON
     HO  BARIUM                                                       410  SODIUM
    5.0U  BERYLLIUM                 .^/                                  H  POTASSIUM
    5.0U  CADMIUM
     IOU  COBALT
     IOU  CHROMIUM
     IOU  COPPER        ^
     IOU  MOLYBDENUM ^
      24  NICKEL^
     40U  LEAD t-^
     30U  ANTIMONY       .l-nV'"
     40U  SELENIUM     "A •/ f /
     25U  TIN        / ?>   '
    3700  STRONTIUM^
     SOU  TELLURIUM
      SO  TITANIUM
    1OOU  THALLIUM
      16  VANADIUM
     IOU  YTTRIUM
      29  2INC
      NA  /IHMIMIIIM
    o.au  MtnaiUY
    S9OO  ALUMINUM
      72  MANGANESE
.••REMARKS*••                                                      •••RfMARKS'**




•••FOOTNOTES***
   • A-AVCRAGE VALUE    *NA-NOT ANALYZED    «NA|  iNTtRFCRCNCFS   'J-fSTIMATIO VALUE  *N-PRESUMPTIVE  IVWlNCt OF PftCSfNrF  OF  MATERIAL
   • K-ACTUAl VALUE 15. KNOWN TO BE LESS THAN VAl lit  GIVEN  *L-ACIUAL  VALUF  IS KNOWN TO BE GREATER IIIAN VALUE OWN
   • U-MAIERIAL WAS ANAIY7EO FOR BUI NO! OUtCIFO  HIE  NUMBFR  IS  lilt MINIMUM QUANIMATION LIMII

-------
                                                   SAMPLE ANi,  *NALYSIS MANAGEMFNI  SVSIFM
                                                       EPA  RLGIUN IV ISO. AllltNS.  GA                                            10/23/90

SPECIFIED ANALYSIS DATA REPORT
     PROJfCI  NO. 9O-899 •   SAMPLE NO. S0013  SAMI'I t lYPt :  GROUNDWA    PROfi F.LFM.  SSf    COLIF.C1EO  BV:  It CAPRIIA
     SOURCE:  SMITHS FARM                                                CUV  SHFPEROSVI              SI:  KV
     STATION  If): MH22A  WELL                                             mi.ir CTIOM  SFARI :  09/19/90   13tO   STOP: 00/00/00
                                                  Uf'.UI.IS  UN! IS   PARAMriLH
                                                         1U OG/L   CVANIDF./
               VALUE     -NA-NOr  ANAI V/EO     •"«!  INIHUHUNItS  •.) ».«, I IMAI tO VAMIf  «N t'Rt SIIMI-1 I Vf  fVIIKNIf  l)»  I'lir.l NI t  1^  MAIMHAI
   .K Artllikt  UAIDE IS KWOWM  10  BE LESS MIAN VAI lit  I.IV/114  >l  A( IIIAI VAIUL  IS rNf)WN 1O 1)1  tiRIAIIR  IMAM VAI Ul  I.IVIH
   IU-MAIEMIAL HAS ANALV?"O  FOR BUT  NOI mm  no   mt  NIIMIUR r, MIL MINIMUM QUANIIIAIION LIMII

-------
PURGCABLE  ORGAN|C'>*fTA REPORT
    ?•••••••••••••••••••
     PROJECT  NO.  00 H99     SAMPLE NO  !.OOf..i
     SOURCE :  SMITHS FARM
     STATION  ID  SW03-I UNNAMED CREEK
                                                   SAMPLE AND ANALYSIS MANAf.FMfMI SVSIfM
                                                       EPA-NttilON IV rSI).  AllltNS. GA
SAMI'I I  IVI'I   bUHFACEWA
    UG/L                 ANALYTICAL RESm IS

   5.0U   CMLOROUriHANC
   b OU   VINVL  CHI OR IDE
   S OU   BROMOMEIilANE
   5 OU   CHLOROEIMANE
   5 OU   TRICHLOROKLUOHOMCTHANE
   5.0U   1 . 1-DICHI OROETHENE< I. 1-OICHLOKOr IHYI
    SOU   ACE TONE
    I2U   CARBON OISUIFIOE
   5 OU   MEIMVLEN1  CHLORIDE
   5 OU   1 PANS-1 .;>-!>!CHLOROE THEME
   5.0U   t.t-DICHLOROCTHANE
    »VU   VJNVL  ACETATE
   S.OU   CIS-I.2-DICHLOROETHENE
   S.OU   2.2  DICIILOROPROPANf
    SOU   METHVL I IMVI  KEIONt
   S.OU   8ROMOCIILOROMC THANE
   5 nil   CHLOROFORM
   SOU   1.1,1-TRiriUOROETHANE
   SOU   l.t-DICHLOROPROPENE
   S OU   CAR ROW H IH»<
   b on   i. 2  nir.ui i
   S (!'•   OtN.'lNt
   G OU   Tfilf.MI ORdllHtNM IRKHLOHOUMYI I MM
   S.OU   1 .Z-DICIILOI'.IIPROPANf.
   S.OU   OlflROMOMMHANt
   5. OU   BROMODI CHI OROME THANF
                          PHOG tl.FM  r.SF   COLLCCTED BV  W RtVELS
                          f.MV  SMfPfftDbVI             SI : KV
                          COLLlCtlON S1ART; 09/20/9O  M.'iS    SIMM  OO/oo/OO
                                                                                10/02/«JO

                                                                               i t • •
"G/L

b f)U
 I VII
r>.ou
b OU
5 OU
b OU
5 nil
 t?u
b OH
5 OJ
SCII
«. nu
5 OU
'j 01'
B OU
S OU
r, nu
r> on
S OH
'. till
•l (I'.l
', III!
'., OU
•l 1)11
                                             ANALYTICAL RfSUUS

                                CIS 1.3 DICIILOROPROPFNE
                                MEIHYL IbOUUIYL KFTONF
                                TOLUENE
                                TRANS-1.3-DICMLOROPROPENE
                                I  l.?-lft|IHLUHOEIHANE
                                It IRAtllLOROf THEME ( TETRACHl ORHf IHVI.ENE I
                                1 . 3-UIUILOKOPROPANE
                                METHVL DUTVI KFTONE
                                DIRROMnrilLOROME IHANE
                                (.Ml iikubf N/tNt
                                1.1.1.2 TCTRACIILOROt THANE
                                FIHVL UEN/tNE
                                (M- AND/OR P-tXVI FMf
                                0-XYI FNF
                                SIVhlNt
                                BROMOrORM
                                HHllMOHtN.'tNE
                                  I .2.7-TriRArifl OROf 111 AM
                                 .?..1-IH|(HLOUUPROPANE
                                  i III nHiilni. llfKt
                                  r.llLOIIOIGLUCIJC
                                  J-DK MI aftoBiN?fNf
                                 .
                                 .2-niCHI.OROBEN7ENE
••'REMARKS*••
  ••FOOTNOTES"*
    • A-AVERAGt VALUE     -NA N01  ANALYZED    -NAT-INII MFC RENl f S  . l-f SI IMAlED VAI HE  «N-PRESI»MP11VE HMOfWrf OF PRfSCWfE Of MAIfH|A|
    • k-ACTUAL VAl.UE  IS KNOWN  III  HI  I ESS 1H/>N VALIIF I.IVIN   •L-AIIUAL  VALUt IS KNOWN TO flf r.REAHH IMAM VAU'f
    • U-MAltRIAL WAS  AIIAl  y?f 0  FOR BUI  NOT DITEl IH>  lul Nl/MOl H  Is ),,[  MINIMUM QUANII l« I C'N LIMIT

-------
Ml MAC I ABLE  OHGANICSXlA REPORT
                                                  SAMPLE  AMD «,f HI 1'iVl *•% I i
(OLLECJION START 09/20/00 ll.is
»li/L ANALYTICAL Rt

**••••••«••«»«
REVELS
' V
V V
M'i(» - OO/OO/llf)

tou
KM)
tOU
IOU
lOU
IOU
toil
IOU
IOU
IOU
IOU
1110
IOU
IOU
IOU
IOU
KIU
IOU
IOU
IOU
IOU
10»
IOU
tou
lou
tOU
IOU
IOU
IOU
IOU
IOU
inn
          im<2 ciununr THVD FIHFM
          Hl'j( 2-CHI HKOir.OPROPVL)  CTHtR
          N  NITKIISUI'I N-MHOPVLAMINt
          III XALIILOKOIIIIANE
          NlimiBEN/ENt
          ISOPMORONE
          BISI2-CHLOROF.THOXY) METHANE
          l.2.«l-TRKHlOROeEN2EM£
          NAPllTHALCrJC
          4-r.HI IIH08MIL INt
          HEXACIILOROOUTAOIENF
          if-Mt IHVLNAPMTMALENE
          HEXACHLOROCVCLOPENTAOIfNF (HCCP)
          2  CIILOnONAPMTMALENE
          2-NIIROANII INE
          DIMETHYL PlllHALATC
          AttWAPHTMVI ENE
          2  6-OINITROTOLUENE
          3-NITROANII. INC
          DIOENZOFURAN
          2.4-OINITROTOLUENE
          OtETHVL  PHtMAi A If
          4-CNi.OROpHiNvi  PHENVL  ETHER
          4-IJITROAMH INE
          N-NIIROSOOIPlUNVlAMINE/DIPHfNVl AMINI
          •1-BROMuPHENVL HllNVL MHtM
          MtXACHLOROOENZENE
          PHENANIHHfNf
          ANTHRACENE
          DI-N-bUlVlPillllAI AM
ton
ll>il
tou
Hill
10(1
1011
IOU
IOU
IOU
IOU
\M
(Oil
IOU
t()U
IOU
20U
ion
tOU
IOU
i.lll
:•»:•.!
ton
tnu
IOU
IOU
?OU
?Oll
IOU
2011
?OII
CVHINt
REN?VL no i vi
.1.:V-|)ll I
(IfN/lX AlANlHHAUNe
f.HRVSENE
BIS(if-tlHVLMEXYL) PHTMALATE
OI-N-OCIVI PlIIMAI Atf
BEN?0(B AND/OR K If LUORANTIICME
            .
ir.'DEIJC (t.2.3 CO! PVKCWf
niHFN/OIA.HIANTHRACfNF
BEN20(GHIIPFRVI F.NF
PHENOL
? I.HI OROPHINOI
BtN^VL ALCOHOL
V-MF i HVL PHENOL
( J AND/OR 4- IMF IHVI PHI NOI
? NITROPHENOL
^ -1-fMMf |H»I
y.l-DUHLOHOPHENOL
•i-r.HLORO-3-MKTiivi
?.<1.6-IRirilLOROPMENOL
? 4 ^-IRKHLnpnpHfMOL
2.4-OINIIROPIICNOL
>|-MI IR'iPHtNOL
2.3 4 fi-TETRACHIOROpHENfil
? MFTHVI.-4.fi niNIIROPIirUOl
I'l Ml Ai III UHUI'Hf Will
• ••REMARKS'"
                                                                      •» tKlMARC.0' • '
11(FOOTNOTES*• •
    • A-AVERACt VALUE     -WA-NOT  ANALYZED    -NAI-INK Rll RENlf S   «.I-E <.! (MATED VAI llf  'N-PRESUMPTIVE EVIDENCE Of PRCSEMCE Of
    • K-ACIOAL VALUE IS I^NUWN  lf»  HE  I E^S THAN VAMlE GIVEN  »L ACTUAL  VALUE IS KNOWN TO BE GREATER IMAM VAI I* MvEN
    •U-MATERIAL WAS ANALVTCC  TOR BUT NOT DEiEi'.TII)  IH» MUMRE N  Is  IME  MINIMUM QUANT 11 AI ION LIMIT

-------
PrSIICIOES/PCB'S DAI A REPORI
                                                   SAMPI f AND ANALYSIS MANAOFMFNT  SVSKM
                                                       EPA IIFtilON IV rSI). AIIIINS.  GA
                                                                                                                                m/1 i/on
PROJECT NO. '10 899 SAMPLE NO !.00f..l SAMI'I 1 IVP
bOIIRfE SMI HIS fAHM
SIAIIOM II): SWO:)-! UNNAMED TRICK

SIIRFAUWA I'RUi; FLIM SSf COLI 1 I IED 0V W REVELS
1 (IV SllfPFRdSVI SI KV
f ni i M:nr.N SIARI 09/20/00 ii;Mi STOP nn/on/no

    UG/L

  0. 1011
  o tou
    IOU
    tou
    IOU
  o tou
  o. tou
  O IOU
    IOU
    tou
    IOU
    IOU
    tou
    , IOU
    tou
  0.67U
   2.4U
   2.4U
   2.4U
0.
0.
0.
0.
0
0.
0
0
0.
0.
                        ANAlVIICAt RFSIIl IS
AIDRIM
IIFITAtHKlH
IIH-rACHLUH E POX I Of
ALPMA-BMC
6ETA-BMC
GAMMA-Blir (I.INOANE)
OfLtA-Bur.
ENOOSUlfAN I (ALPHA)
OIELORIN
4.1'-OOT  (P.P'-OOT)
4.4'-DO£  (P.P'-DD£)
4.4?-DOD  (P.P'-DDD)
fNOR IN
ENOOSULFAN II (BETA)
CNDOSULFAM SUIFATE
CHLOROANE IIECH.  MIXTURE)
PCB-1242  (AROCLOR 1242)
PCB-I2S4  (AHOCLOR 1254)
PCB-t22l  (AROCLOR 1221)
 Uli/l.

1 'IK
? -in
2-111
2.411
3 IU
                                                                     0 ?OII
                                                                     0 IOU
               ANAI.VTICAl ME Sill IS

Pi:f»  I2J2  IAROCIOR 12.1?)
l'i:il-l/"IB  (AROCKIK I24H)
Pril  1260  (AROCLOR I2M))
I'lfl-IOir,  (AROCLOR 1016)
TOXAPHENE
r.HLORDENE  /2
Al PHA-CHI OHOFNE    /2
flfJA CIIIOROENE    /2
GAMMA-CHI OROENE    /2
GAMMA-CHI ORDANE    /2
IRANS-NDNACHLOR    /2
ALPIIA-CIILORDANE    /2
f.lS-NONACHIOR      /2
OXVI HLOHDANE (OCIACHLORf POXIIH )
MEIHOXVCIIUIR
(NDRIN MTONE
...REMARKS*••
                                                                     ...R| MARKS'"
 • A-AVERAOE  VALUE    *NA-NOT ANALY7EO    «NA| INK HFERENI (S  «J ESIIMAIFD  VAl III   »N PRESIIMPIIVE FVIDINIE  OF  PRESENCE OF MAMHIAl
 • K-ACTUAL  VALUE IS rNOWM 10 BE LESS  IMAN VALID  i.lVEM  t|  A( DIAL VALUE  IS  KNOWN  10 HE  (iREAICR MIAN VALUE  I1IVIW „„-,„,.,_ .
 • U-MA1FRIAI. WAS ANAIV7II) FOR BUI NOI  01 II < 'f>  '"f NIIMHIR  IS HIE MINIMI/M  OIIANIIIAIION I.IMII                 '-fONFIRMIF) (IV r.C/MS
  I  WHENNOVAIUE  IS REPORIID  SEE CHI MROANE < d>JSI I TUENIS     2  f OMSII MJF.NIS OR  Mf IAOOL I If S OF  IECIINKAI
                                                                                                               CHlflROANl

-------
METALS DATA REPORT
                                                 SAMPLE AMD ANALYSIS MANAGEMENT SYSTEM
                                                     E»>A-REGIOM |V tSD. ATHENS. CA.
•'•'
•••
     SOURCE-  SMiTHWARM
     DUUnLC .  jMI In j f AKM
     SfAllOM 10: S*03-t UNNAMED CRCfK
                                                       .

                         "°  5°°63  SAMPU f VW :  SO«^«t»A
                                                                       ,... .....  ............

                                                                       PROG ELEM  SSF  COLLECTED BY  W REVELS
                                                                       r I I V •  QlJFDFOftcui             c t .  u \t

                                                                       COLLicilOM START:  09/20/9O  lUB^ STOP:  00/00/00
    ••
    UO/L
      65
    S.OU
    5.0U
     IOU
     IOU
     IOU
     I OU
     20U
     30U
     40U
     2SU
     600
     SOU
      30
    100U
     IOU
     IOU
      45
      NA
    0.2'J
    2100
      63
                       ••«
              ANALYTICAL  RESULTS
nnnn
BORON
BARIUM
BERVLLIUM
CADMIUM
COBALT
CHROMIUM
COPPER
MOL VBDENUM
                                     ,   i ,1
                                   ,>l  //»
                                       '
          ANTIMONY
          SELENIUM
          TIN
          STRONTIUM
          TELLURIUM
          TITANIUM
          THALLIUM
          VANADIUM
          YTTRIUM
          7IMC
          MERCURY
          ALUMINUM
          MANGANESE
                                                                     .«.
                                                                     MG/L


                                                                        5?
                                                                        71
                                                                       o o
                                                                        39
                                                                       49
                                                                                       ...... ••*
                                                                                         ^ALYHCAL RESUl IS
                                                                                                                            10/)e/90


                                                                                                                                  '
                                                                                                                                  *'
                                                                             CALCIUM
                                                                             MAGNESIUM
                                                                             I ROM
                                                                             SODIUM
                                                                             POTASSIUM
                                                                             POfASSIUM
•••REMARKS***
                                                                   •••Rf MARKS* ••
•••FOOTNOTES***
   •A-AVERAGE VALUE    -NA-NOT ANALYZED    *NAI - INtf RFERENfES  »J-EST (MATED VALUE   *N-PRf SUMPT I VE EVIDENCE OF PRESENfE OF MATERIAL
   • K-ACTUAL VALUE IS KNOWN TO BE LESS THAN VALUf  r.lVI'N  M-ACTUAI  VALUE  IS KNOWN  TO BE CRfAIfR IHAN VALOF OIVIN
   • U-MAIERIAL WAS ANA) V7EO FOR BUT NOT WlfClfO  Mil  NIIMBFR IS IKE  MINIMUM QUANTirAIION LIMIT

-------
                                                 SAMPLE AND ANALYSIS  MANAf.FMFNT  SYSTFM
                                                     FPA-REGION  IV  FSD.  AIHENS.  GA.                                          10/23/90

SPECIFIED ANALYSIS DATA REPORT'
     PROJECT NO.  9O-899 •   SAMPLE NO. 5OO63  SAMPH TYPE: SURFACEWA   PROG FLFM:  SSF    COLLECTED BV  W REVfLS
     SOURCE: SMITHS FARM                                              CITY  SMEPEROSVI             SI:  KV
     STATION ID.  SWO.1-1  UNNAMED CREEK  "                              COLIFCI ION  SIARI  09/20/90  1135   STOP: 00/00/00
                                                IIF.SIILIS  UNITS  PARAMFIfK
                                                     A OU UG/L  CYANIDE
   .A-AVERAGE VALUF     «NA-NOT  ANALYSED    -NAI - INItHFERENI f S  .J-FSI IMAteO VALUE   .N-PNESUMPIIVt EVIPfNrt 0> WSfWF Of MAIfHJAl
   • K-ACTUAt. VALUf  IS KNOWN  TO  BE  LESS  THAN VAl lit  GIVIN  «L  ACIIIAl  VAlUt  IS KNOWN  TO Of  GREAIfR THAN VAI Ut I.IVlN
   • U-MAICRIAL WAS  AWAlV/fl)  FOR BUT  NOT DIIECKO   IMF  NUMOLH IS lilt MINIMUM QUANT I TAT ION LIMI I

-------
PURCI AIILE OR11ANIC.S  OAfA RFPOKf
                                                   '.AMPIF  AND ANAIYSIS  MANAGEMINI SVST(M
                                                        tl>A-Hir,ION  IV  ISO.  AIIIINS. (.A"
                                                                                                                                      1/00
  PROJECT HO  00-B99 •   SAMPLE NO  !>00iy -SAMIUE  IVPf   LtACHAIt
  SOURCE  SMITHS  FARM
  MAI ION ID  S03-I  LEACHATE STREAM
 Uti/KC

 7f»ll
 /Ml
 7cu
 7«.U
 76U
 76U
760U
760U
 76U
 76U
 76U
760U
 76U
 76U
760U
 76U
 76U
 76U
 76U
 76U
 76U
 760
 76U
 76U
 76U
 7611
                          ANALVMCAl  RFSIM IS
                                                                           (•nnitEIFM  SSF   (OLLECIll) IIV. BCAPHIIA
                                                                           I I IV  Sill PIHDSVI             $1  KV
                                                                           iflliff.MON ',TA«I  09/18/90  1715   SIOl'.  nn/oo/no
                                                                                              ANALYTICAL KEMHIS
           CIIIORllMI IIIANE
           VINVl UIHlH IDE
           CIILIlKUE IHANE
           TRIOIIOROHHOROMETHANE
           I . l-l)l<;HlOROEIHENEn , 1-DICHLOIinf IHYI fNI )
           Af.fl ONE
           CARBOM DISUI MDE
           METHVUNE CHLORIDE
           IRAMS-I.2-DICHLOROETHENE
           1.1-DICMLOnnETHANE
           VINVL ACEIAIE
           CIS-I .2-DICIILOROETHENE
           2.2-DICHLOnOPROPANE
           METHYL EIHVI. KFTONE
           BROMOCHLOKOUE THANE
           CHLOROFORM
           I. I . 1-TRICHLOROETHANE
           1. 1-OICHLOUOPHOPENE
           CARBOM Tl 1UACHI.ORIDE
           1.2-DICHLOKOETHANE
           BENZENE
           IRICHLOROf ItlfNtl IRICIILOROf IHVI I Nl )
           1.2-DICMLOROPROPANE
           DinROMOMFIHANF
           nROMODir.HMIHIlMI IHANI
  71.1)11
   /l>ll
   7bll
   7611
   /(ill
   7GU
  760U
   /Oil
   7611
   7611
   7611
   76U
   /fill
   7CU
   7611
   7611
   7611
   /(iU
   7hll
   71.11
   /l.ll
   /Oil
   7lill
.1.1 <)
MflllYI  I Sf Kill I VI  MIUNI
 KUUINl
 IRANS-l.a-OICIILOROPROI'tNK
 I. I.? IRII.IILOROEMIANF
 IF IRAfllinRnnilFNF ( IEIRA( HI OHOI IIIYMNM
 1.3  DICIII.UROPHOPANE
MFTHVL HUT VI KETflNE
D I nilOMOl III OROME IIIANE
CHLUROBEN7FNE
I.1.1.2-TE1RACHIOROETHANF
(IHVI. RIN7FNE
(M-  ANn/OR  P-)XVLENE
0-XVItNE
SIYRfNE
OROMOIORM
OROMnllFN/ENE
I . 1.2.2-UIRACHLOROFTHANE
1.2.3-IRIC.HLOROPROPANE
O-riltOROlOIUENE
P-CHLOROIOLUENF.
I . .T-|)ICMLOnODf NZENt
I .<4-DICHLOROnEN?ENE
1 .2 Oiail.OHOBEN7ENE
PfRC.fNt MOISTURE
•••REMARKS*••
                                                                        • «ltf
   • A^AVERAOE  VALUE    •NA-NOT  ANALV2EO    -NAI  INI I lift RINI t S  -.1-1 «.r IMAIEO VALUE   «N I'RFSUMPI I V[ EVIOINlt  Ol  PHESENCt
   • K-ACTUAl  VAI Uf  IS tNOWN  10  HE  I ESS IHAN VA| III  I.IVIN  .|  Al THAI VAI III  IS KNOWN 10 III (.RFAIIft  I MAN  VALIIf  lilVIM
   • U-MAIERIAL WAS  ANAI Y/ll)  fOR BUI  NO! 01 IK  1(0   Mil  NUMHIH IS Hit MINIMUM OUrtNIIIAIION LIMII
                                                                                                                         Of  MA If NI At

-------
EKIKACIABLE  ORGftMt.S DATA REPORT
                                                   SAMPLE AND  ANALYSIS MANACFMFNI  SVMFM
                                                       EPA-KEGION IV ESO  AIHLNS   GA
                                                                                  '
                                                                                                                                 O'J/2'J/OO
    PROJECT  NO. 00 099
    Mjuki.f   ->MIIMS FARM
    STATION  10: S03-1 LEACHATC STREAM
                             SAMPLE NO. fiOOt?  SAMMI IvH  Ll*CHAIE
                                                                          PROG Jl FM  c.'l    COLLEC1ED DV   n CAPRIlA
                                                                          r.iTv- siifPFRDsvi             si   KV
                                                                          COLLECTION START.  09/18/90  I 74S   STOP- OO/OO/OO
 MOOOU
 IIOOOU
 nonnu
 IIOOOU
 IIOOOU
 IIOOOU
 nonnu
 I ll-OOl)
 IIOOOU
 IIOOOU
   UC/KG                ANALYTICAL RESULTS

ItOODU    BIS! 2 CIILOROCTHVU  fTHFR
          BIS»2-CIII OnOISOPROPYl) ETHER
          N-NITROSuDI N-PHOmAUINE
          HtXAUILOROE THANE
          NITROBENZENE
          ISOPHORONE
          6IS<2-CHLOftOETI»XV)  METHANE
          1 . 2.4-1HIUILOR08EN7ENE
          NAPHTHALENE
          4-1 HIIIN04NII |NE
          IICXACHLGRGBUTAOIENF.
          2-MtlHVLNAPHTIIALCNE
          HFXACHLOHOI.VCLOPENIADIENF ( M< ' |> )
          2  CMLORONAPHTHALCNE
          ?-Nl 1POANII INt
          OlUrillVL PIHHALATE
          AltNAPHTMVLENF
          2.6-DINHROTOmENE
          3-NIIIIOAIJII. INE
          Ai CMfl'MdO Mt
          OIBEMZOFIIIIAM                             '  • J
          2,4 OINI tUOtOLUtNE                       .'  •'•
          OlEIMYL HI I MAI Alt:                           ,
          FLUORINE                                 .'•• /
          4-CIII liHIil-MINVI. PMtNYL  ETllFII            ,,   ..
          -s  a 1 1 ROAM 1 1 i wr                          / .*• - (-
          N-NIIIIOSnllll'MFNVI AMINE/ntPIIINVI  AMINI   . .   r
          4  linOMdl-Ml NVI   I'HlNVI. tlHtN             /'•
          lirXACIILOItimiNZENE  IIICD)            '
          PHfNANliml Nl                           / /•',  '(
          AMTIIR ACINI                             '  '
          UI-N-IIUIYI I'll! I IA| All
 110000
 linnnil
 IIOOOU
 IIOOOU
  2300J
 IHHH'll
 IIOOOU
  SIOOJ
 IIOTiOU
 1 1 ncnu
 111)0011
 IIOOOU
 IIOOOU
 4BOOO
 1 1 000
 I IO(N)M
  UO/fG

K'JOOO
46OOO
IIOOOU
IKIDIIU
23000
21000
IIOOOU
tifxiou
I /OfiO
 esooj
I IOOO'J
 9700J
I 10001*
IIOOOU
21001111
1 1 OOOU
I 11 Illl III
i mm ui
i UK n in
I Hull III
•/iiiooii
/I I Illl III
IIOOOU
,'1111)011
.'iiinir.i
 .LI j
              ANALYTICAI RCSIU JS

FLUORANTIIENE
PYRhMt
BEN7VI FIUTVI  PIITIIAI AIT
3.3'-DICHLOROBENZIDINE
BFN/OIAIANlHKAttNE
CHRVSENE
HIS(2-tlHYLHEXYl ) PHTMALAIE
DI-N-or.lYi PHIHAI AIF
BEN201B AND/OK  MFLUORANTIIEMF.

                                                                                                                        •*
IHCUJO U.S.3  CD)  PVRfNF
01HFN/OI A. HI ANTHRACENE
BEN?0(GHI IPERVItNt
PHFNOI
/ l III IIMilMHt NM|
BtN/YL ALCOHOL
V-M^ IMYlPlltN'JL
I.I-ANO/OM  IKiaiLUROPIItUOL

2.4 I) IN I IROPHF.NOL

2.3 4.r»-IFTRArH| I
? MFMIVI  4.6 OINITIIOPIIINOI
!•( Ml Ai HI IIHIU'MINIII
I'LltHNI MDISTUni
    r//

i-    O'Y

""{<:.!>
                                                                 • 1
                                                                                              .-A
                                                                                                   . /»
                                                                                                     »<•«,
 • ••REMARKS'"
  t«F001NOTCS»«
    'A-AVERAGt  VALUE     'NA-NOI ANALYZED     «NAI - IN1I HF| RfNl.fS   «.|-F«.! IMA Itl) VA| \>t  -N-PRESUMPIIVE EVIDENCE Of PRESENCE 0)
    • K-ACTUAL VALUE  IS H.WW4 U» Ht LESS  IHAN VAI UF  GIVEN  «V ACIUAL  VALUE IS KNOWKI TO BF OflUlfH |M
-------
                                                 SAMPLE  AND  ANALYSIS MANAGfMFNI SVSIIM
                                                     EPA-REGION IV ESD.  AllllNS. CA
MISCELLANEOUS  EXlRAt.lABIf  COMPOUNDS -  OAU RIPOHT
              S!,,*rH??2..   SAMPU "°  S°01V
            .  SMITHS EARM
     STATION  10:  S03- 1  LEACIIAIE STREAM   .•
                                                                    PRO', ti.tM  SSf   lU.|.M:ltD HV: B CAPRITA
                                                                    tllY  SMEPERDSVI            U  kV
                                                                    mi i M I inw SlARI ;  C9/lfi/9n  I/H>    '_tpP.  nn/n,vnn
      jf-f"
      JC'.C
        t;.o
     '*> o. t1
     "  &.<--
        V->r
        •/.«••
                                AMAI VI (I A( M| Ml| IS

                       2000JN   FLUOKENONE
                       3OOOJM   OIBEN201MIOPHINF
                       SOOOJN   CARBAZOLE
                      tOOOOJN   METMYlPHrNANIIIHENEH  1SOMERS)
                      tOOOOJN   CVCLOPENTAPMENANTHRENE
                       SOOOJN   PHENYLNAPHTHAIENE
                      300OOJN   METHYLFLUORANldENEIb  ISiWRS*
                       6000JN   BEN?ANTIinACEMONE(2  JSCMCRS)
                       SOOOJN   nEM;nwAPM|nrMHinPHENb
                       SOOOJN   BENZOniENANTHRENt
                       SOOOJN   FLUORANMIENAMINE(2  ISOMERS)
                       7OOOJN   METHYlBfMZftNIIlHACtNH V  ISCMf'.HS)
                      30OOOJN   BCN/OFLUORANfllErJCINOT B OR K)(2  ISOMFRSt
              r»>
               . (
             •r«..v
• A- AVERAGE VALUE
                    -NA-NOI  ANAI V/tU     «NAI  INTI Rf ERENCES  •J-ESIIMA?CO VALUE  «N-PRE SIIMPri Vf
  -
•R-ftCTUAt VALUE  IS KNOWN  TO BC  LCSS  UIAM WAI «lf  (.IVfM  «t -A( IHAJ. vALUt  IS KNOWN 1O BE CREA1ER 1IIAN VALUI
*U-MA MMIAl WAS  *NA| ""tO  /OR  BUT  NOI  IX IIC.IIO.  HIE  NUMBER I', IMF MINIMUM OUANI
                                                                                                             (If  PHfStNl.t  OF  MAirRIAL
   QC IUOICATCS  1IIA1 OAIA  UNUSAfll f
                                              .
                                              MAY  MM  MAY NOI  RE  PRESlNl
                                                                                   I IAI \«H I (Mil
                                                                             RESAMPLING  AND REANAIVSIS «S MFlfSSAMV »HH VtHIMlAtlON

-------
PESMCIUES/PCn'S OAIA REPORT
     •  ••••••••••••••••••t
     PROJECT NO  90 HW   SAMPLE  NO.  «>ooi?
     SOURCE  SMITHS i ARM
     STATION ID  S0:i I tfACHATE STREAM
                                                    •.AMI-IT  AND ANAIVMS MANAI.IMINI SY'.IIM
                                                        IPA-lfll.H'N  IV  I SI).  AIIIENV liA
                                                                                                                                   10/10/00
SAMI'I I  IVI'E   LtACMAIt
                          CHOI; r i FM  SM   couicito HV
                          •  I IV:  SHE PHUV.VI             SI
                          i.Oi LECTION MART  09/18/90  I /4<
                                                                                                                SI Oll  OO/no/no
    UG/KG                ANALVIICAL  HE Sill IS

    -IbU    ALPRIN
    4SU    HUM At Ml (U(
    tSU    HUM ACHI fill  £ POX IDE
    4SU    ALPHA-III 1C
    4!iU    BC1A-HIIC
    tf.U    GAMMA-IIHC (LINDANE)
    45U    OCLIA-BHC
    45U    ENDOSULTAN  I  (ALPHA)
    5IU    DIF.IORIN
   IIOU    4.4'-DDT I P.P'-DOT)
   IIOU    4.4--ODE (P.P'-ODE)
   IIOU    4.4--OOD (P.P'-DDO)
   IIOU    fNOR IN
   IIOU    ENDOSUITAN  II  (BETA)
   i inn    ENDOSUI.FAN  SI/I.FATE
   39011    CMLORDANt I  ItCII  MIXTURE)  /I
  noon    pen-i242 
Pfll-ti'/IH (AROCKIU  I1MHI
l'i:H-l?60 (ARUr.LOR  I?60I
Pl.n  lOlb (AKOCLOR  IOH.)
UlXAPIITNf
IIIIORIUNI   /?
A| rilA-r.HI ORDfWE   /2
IK (A r.llinRDT.NI    /2
liAMMA CHI OIIDCNE   /?
I.AMMA-nil OHOANE   /2
TRANS-NdNACIII.OR   /2
Al CHA CHLORDANE   /2
i:lc.--NONAI III.OR     /2
MXVIIIIDKDANI.  (OCfAIJILOKI POXIIII )   /?
Ml IIIOXVdlldR
INDIUM M (ONE
PIRIIfNT MOIblURE
  •REMARKS*
                                                                       • • 'III MAItKV • •
   • A-AVERAGE  VALUE    -NA-NOI  ANALV2ED     «NA|- INIf Rff RIMCES   • J-ESIIMAIED VAI Uf  «N Pftf SUMP I IWf  IWIIIINH  III  I'RIStNCf  01  MAIINIAL
   • K-ACIUAL  VALUE I!, KNOWN  TO  BE  lESS HIAN VALIIl  I.IVIN  •(.-ACTUAL  VALUE  IS KNOWN TO M URIAH H  IIIAN VAI lit  I.IVIN
   • II-MAIERIAI  WAS AMAI V?fI)  FOR Bill NOT 1)1 Hf Iff)   IHI  NUMHFR IS IHf MINIMUM QUANIIIAIKIN I  IM| I                 I  (nNIIRMID  (IV I.I/MS
    I  WHEN NO VAI.Uf  I', RCPORItD.  SEE CHI IIROANl I.ONM I IIIEMIS     /  (ONSI I lUlNl S OH Ml. 1AIIOL I US  Of  IMIINKAI  ClllOHDANI

-------
METALS DATA REPORT
*»»••••••*•*•
•»   PROJECI NO. 90-899
•»   SOURCE: SMITHS FARM
••   STATION ID: S03-I LEACHATE STREAM
                                                SAMPLE AND ANALYSIS MAMAGFMFNT SVSIEM
                                                    EPA-REGION IV fSO.  AlMENS. CA
                            •*•»*•••
                           SAMPLE  NO.  5001?
                                                                                                                          10/18/90
                                             SAMPLE  TYPE:  LEACHAIE
    MG/KG
    4.0U  SILVER  /
      10  ARSENIC*'
      NA  BORON
     120  BARIUM
    2 OU  BERYLLIUM
    2.0U  CADMIUM/
      20  COBALT4/
      18  CHROMIUM"
      17  COPPER
    4.0U  MOLYBDENUM^
      34
      47
     I2U  ANTIMONY
     I6U  SELENIUM
     10U  TIN        /
      22  STRONTIUM^
     20U  TELLURIUM
      40  TITANIUM
     40U  THALLIUM
      28  VANADIUM
     7.1  YTTRIUM
     170  7INC
      NA  ZIRCONIUM
  I) OSII  MMJIJIHV
  12000  ALUMINUM
     5OO  MANGANESE
                        ANALYTICAL  RESULTS
«,,.,,,,,,,

  PROG ELEM  5SF   COLLECTED BV: B CAPRI TA .....
  CHV: SHEPERDbVI            SI: KY
  COLLECTION START:  09/18/90  1715   STOP: 00/00/00

.«.,., ..... • «•«••••••.,,
MG/KG               AMALVriCAL RE SUMS
  9300  CALCIUM
  7200  MAGNESIUM
 37000  IRON
  400U  SODIUM
  20OO  POIASSIUM
    29  PERCENT MOISTURE
                                                                                                                       •  •  •  •  • ••
..REMARKS'"
                                                                  ...RfMARKS'.*
  •A-AVERAGE VALUE    'NA-NOT ANALYZED    »NAI-INIf RFERENCeS   'J-ESTIMATED VAl HE  .N-PRFSUMPIIVE fVinfNrf  Of  PRFStNCf Of UAfrHlAi
  •K-ACTUAL VALUE IS KNOWN TO BE LESS THAN VAIUE  MVEN  'l-ACIOAL VALUE  IS KNOWN TO BE GREATER  THAN VA| Uf  f;IV»N
  •U-MATERIAL WAS ANALYZED FOR BUT NOT DlTECIED   IMF  NUMBER  IS THE MINIMUM QUANIIIAHON LIMII

-------
                                                   SAMPLE  AND ANALYSIS MANAGEMENT SYSIfM
                                                       EPA-RLGION  IV ESD.  AllllNS. GA                                           10/23/90

SPECIFIED ANALYSIS DATA REPORT
     PROJECI  NO.  90-899    SAMPLE  NO  SOOI7  '.AMI'I.I  TYPE   LEACHAIE    PROli  ILEM  SSf   COLLECIED  DV  H CAPRI (A
     SOURCE:  SMITH'. FARM                                                UIY;  SHEPEROSVI             SI   KY
     STAMON  10  S03-I LEACHATE  STREAM                                 COLLECTION SIARF:  09/18/90  / 1 /1«j   MOP. 00/00/00
                                                 llf'.IM. IS   ONUS  fARAMfllR
                                                     0  281) MO/KG CYANIDE
              VAIUE     «NA NOI ANAI Y^EI)     »NA|  INIHIftHf MCES  • J -fST IMAI tO VAI (If   «N PHEbllMI'l (WE tVllUNK '* IWSENU  Of MAIIMIAI
   • K-ACTUAL VALUE  I1.  KNOWN IO BE IESS IIIAN VAI ME  r.lvEN  M-ACIUAL VALUl  IS KNOWN  10 llf  URCAlfR MIAN VAI 01 UVIN
   • U-MAIEKIAL WAS  ANAIY2EI) fOR BUT NOI DMI.MII)  (III  NtlMULK IS lilt MINIMUM QUAMTIIAIION IIMI I

-------
                  ATTACHMENT 7.0
Summary of Costs for Remedial Actions Alternatives

-------
SUMMARY OF COSTS
FOR REMEDIAL ACTION ALTERNATIVES
SMITH'S FARM OPERABLE UNIT 2-FEASIBILITY STUDY
ALTERNATIVE
1
2
3A-1
3A-2
3B
3C-1
3C-2
4A
4B
4C
4D
5A
5B
5C
*
DESCRIPTION
No action
Limited institutional action
CAP permitted landfill and outlying
areas of soil contamination
Excavate areas of outlying soil
contamination and CAP permitted
landfill
RCRA CAP and contain hot spots
RCRA CAP and excavate hot spots
and treat using on-site incineration
RCRA CAP and excavate hot spots
and treat using on-site stabilization
Collection and treatment of leachate
usinc^physical treatment
Collection and treatment of leachate
using chemical/physical treatment
Collection of leachate and chemical/
physical treatment for heavy metal
and organic removal
Collection of leachate and chemical/
physical biological treatment for
heavy metal and organic removal
Extinguish landfill fire by excavation
Extinguish landfill fire by water injection
Extinguish landfill fire by gas injection
Cost does not Include landfill CAP.
Add cost for alternative 3A-1 or 3A-2
lo obtain total cost foi this iilternative.
PRESENT
WORTH COST
0
2.191
36.806
33.386
9.216*
72.969*
28.064*
0.744
1.869
3.054
4.797
0.344
0.188
1.684

CAPITAL
COST
0
0.133
36.724
33.304
9.216*
72.969*
28.064*
0.451
•;. 0.558
0.816
1.085
i
0.344
0.188
1.684

30 YEAR
O&M COST
0
2.058
0.082
0.082
0 j
0
0
0.293
1.311
2.238
3.712
0
0
0


-------
              ATTACHMENT 7.1  ...





Leachate Collection and Physical Treatment

-------
LIQUID  WASTE	
FROM COLLECTION
SYSTEM
II ACMATE
COILLCT10N
TANK
4000 GAL.


FILIHAIION
DISCHARGE
TO UNNAMED
TRIBUTARY
                                                                           LEACHA7E COLLECTION
                                                                        AND PHYSICAL 1REA1MEN1
                                                                                 SMITH'S FARM
                                                                             OPERABLE UNIT 02 FS
                                                                           BULLITT COUNTY. KENTUCKY

-------
              ATTACHMENT 7.2
Collection and Chemical/Physical Treatment
         and Heavy Metals Removal

-------
                                      PH
                                 ADJUSTMLN1
            PH
       ADJUSTMENT
LIQUID WASTE	
FROM COLLECIION
SYSTEM
IFACHAIE
COLLECTION
TANK
4000 CAI .


AEHAIION/
CHEMICAI
OXIDATION
COAGULA TION
   AND
CLARIFICATION
FILTRATION
                       DISCHARGE
                       TO  UNNAMED
                       TRIHUFARY
                                                     COAGULANT
                                                         AID
                                                                                                     COLLECTION AND CHEMlCAL/PHYblCAl
                                                                                                          TREATMENT  or LEACHATE
                                                                                                        FOR HEAVY METAL  REMOVAL
                                                                                                              SMITH'S FARM
                                                                                                          OPERABLE UNIT 02 FS
                                                                                                        EUJLUTT COUNTY, KENlUCKY

-------
                   ATTACHMENT 7.3
Leachate Collection and Chemical/Physical Treatment:
    for the Removal of Heavy Metals and Organics

-------
                                     pH
                                 AOJUSIMLNT
    pH
ADJUSTMENT
LIQUID WASTE -
FROM COLLECTION
SYSTEM
                        UISCMAI«;L
                        TO UNNAMED
                        TRIBUTARY
          COAGULATION
             AND
          ClARiriCAllON
                                                                                 FILTRATION
                                                     COAGULANT
                                                         AID
                                                                                 EFFLUENT
                                                                                 COLLECTION
                                                                                               LEACHATE COLLECTION AND
                                                                                            CMEMICAL/PHrSICAL TREATMCHl
                                                                                             FOR THE REMOVAL OF HEAVY
                                                                                                 METAL AND ORCANICS
                                                                                                    SMITH'S FARM
                                                                                                OPERABLE UNIT 02 FS
                                                                                              BULLITT COUNTY. KENTUCKY

-------
                    ATTACHMENT 7.4
 Leachate Collection and Chemical/Physical/Biological
Treatment for the Removal of Heavy Metals and Organics

-------
                                      pM
                                 4DJUSIMENT
                               PH
                           ADJUSTMENT
LIQUID WASTE	'-
FROM COLLECTION
SYSTEM
 LEACHAlf
:OLLECTION
   TANK
 4000 CAl
AERATION/
CHEMICAL
OXIDATION
COACUIATION
   AND
CURiriCAIION
FILTRATION
                                                     COAGULANT
                                                         AID
                                            DISCHARGE -»	
                                            TO UNNAMED
                                            TRIBUTARY
                                      CARBON
                                    FILTRATION
                                     BIOLOGICAL
                                     TREATMENT
                                                                                             LEACHATE COLLECTION  AND
                                                                                           CHEMICAL/PHYSICAL BIOLOGICAI
                                                                                          TREATMENT TOR  THE REMOVAL OF
                                                                                           HEAVY MEM'S AND ORGANICS
                                                                                                   SMITH'S FARM
                                                                                               OPERABLE UNIT 02 FS
                                                                                             UUILITT COUNTY. KENTUCKY

-------
              ATTACHMENT 7.5





Leachate Interceptor Trench Typical Detail

-------
                                              (TYP)
    SOIL
DEPTH VARIES
                NO. 57 HOUND
                SIONE (TYP)
                                                                         SYNTHETIC LINER
— BACKFILL WITH CLAY SOIL
                                                                            AGGREGATE  (MIN )
                                                                         AROUND PIPE
                                                                                          I.EACHATE  INTERCEPTOR
                                                                                                  TRENCH
                                                                                              TYPICAL  DETAIL
                                                                                                SMITH'S FARM
                                                                                             OPERABLE UNIT 02  fS
                                                                                           BULUTT  COUNTY. KENTUCKY

-------
      ATTACHMENT 8.0
Letter of Concurrence From
 Commonwealth, of Kentucky

-------
                                        f-oe   r- = -^ ,*.-**•    ,<-:*:   \  •
            1  .
 PHILUP J- SHEPHERD
                                                                BRERETON c. JONES
                 KlA-mo.i t»     COMMONWEALTH QP KENTUCKY
                 NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
                       DEPARTMENT FOR ENVIRONMENTAL PROTECTION
                                             P*«K
                                      REIU.Y ROAO
                                       
-------
                       COMMONWEALTH OF KENTUCKY
          NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
                DEPARTMENT FOR ENVIRONMENTAL PROTECTION
                         FRANKFORT OFFICE PARK
                             18 REIU.Y ROAD
                        FRANKFORT. KENTUCKY
                           June  5,  1992
Mr. Tony DeAngelo,  Senior Project Manager
U.S. Environmental  Protection Agency-Region IV
345 courtland street,  N.E.
Atlanta, GA  30265


RE:  Smith's Farm,  Operable Unit 2 Proposed Flan


Dear Mr. DeAngelo:


     We have reviewed the proposed plan for remediation of operable
Unit 2 at the Smith's  Farm site and believe that, if  implemented,
it will  be  a major step forward in the reduction  of health  and
environmental risks.  We also recognize EPA's obligation to provide
cost-effective  solutions for sites  on the  National Priority List
and  it is  obvious that you  have made  a  painstaking effort  to
provide such a  solution in this case.

     It is  the position of the  Commonwealth  of  Kentucky (and is
clearly  stated  in the National Contingency  Plan)  that,  where
appropriate,  engineering  controls  such as  containment  must  be
combined with the treatment of principal threats posed by a site.
Therefore, while the Commonwealth endorsee capping the landfill and
treating leachate, we also believe there must be a concerted effort
to identify  and treat  "hot spots" within the fill.

     Our other  concern with the proposed plan is that there  is no
remedial objective for contaminated  shallow  groundwater.  While
collection  of  leachate may resolve this problem,  we  recommend a
contingency  plan in the remedial design for pumping and treating of
groundwater.
                    O
   Printed on Rscyclvd Paper
An Equal Opportunity Emptoytr M/f/H

-------
Mr. DeAngelo
Page Two
June 5, 1992
     Thank you for the opportunity to provide these comments.  We
are looking  forward  to  being involved in the remedial design and
remedial  action at  Smith's Farm.   Please  keep  us  informed  on
continuing developments.
                                   Rick Hogan, Supervisor
                                   Federal Superfund Section
                                   Superfund Branch
                                   Division of Waste Management
RH:kb

-------
PHILLIP J. SHEPHERD                     /jffiu?*®*                     BRERETON C. JONES
    SECRETARY                         [§[ g« \-\                         GOVERNOR
                              COMMONWEALTH OF KENTUCKY
                NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
                      DEPARTMENT FOR ENVIRONMENTAL PROTECTION
                                 FRANKFORT OFFICE PARK
                                   14 REILLY ROAD
                               FRANKFORT. KENTUCKY 406O1
                              September 16, 1992
     Mr. Tony DeAngelo, Jr.
     SRPM,  KY/TN Section NSRB
     Waste  Management Division
     U.S. Environmental Protection Agency
     Region IV
     345 Courtland Street, N.E.
     Atlanta,  GA 30365

     RE:  Smith's Farm CERCLA NPL  Site
          Brooks, Bullitt County,  Kentucky
          Operable Unit Two
          ROD Remedy

     Dear Mr.  DeAngelo:

          The Commonwealth  of Kentucky,  Department  for Environmental
     Protection has reviewed the  proposed remedy contained in the Record
     of  Decision  for  Smith's Farm,  Unit Two.   This  remedy, which  is
     identified  as Alternative  3  in the Feasibility  Study,  would
     essentially consist of  consolidation  and  capping of the  landfill
     along  with  construction of a  leachate collection and treatment
     system.   Long term monitoring of the site would continue after the
     remedy  is implemented .

          The Commonwealth concurs with the proposed remedy.   We look
     forward to working with you on this  site in the future.
                                          Sincerely,
                                                  \ i ' **nfi*  \
                                          Caroline P. Tiaight,  Director
                                          Division of Waste Management
     CPH/RH/kb

     c:   Carl Millanti
          Farough Fakharpour
                                 Printed on Recycled Paper
                             An Equal Opportunity Employer M/F/H

-------
                       ATTACHMENT 9.0





Determination of Remediation Levels in Tables 9.0 a ft b & C

-------
  DETERMINATION OF REMEDIATION LEVELS IN TABLES  9.0a,  9.Ob, 9.0c


Remediation levels for individual  constituents were determined  by
balancing acceptable, desireable risk levels (noncarcinogenic and
carcinogenic)  with Contract  Required Detection  Limits  (CRDLs)  or
Contract Required Quantitation Levels (CRQLs)  so that remediation
levels were significantly below the  Exposure Point Concentrations
(EPCs).  The formulae on pages 3-30,  3-33, 3-34,  3-39 and 3-40, and
Appendix C, of  the Risk  Assessment, Volume III of  the Remedial
Investigation Report,  were used to  calculate Remediation Levels
from  Desired  Risk  Levels  and vice  versa.   Medium Soil/Sediment
CRDLs  for  Pesticide/PCB  TCL compounds  were defined by  the PRP
laboratory as  being 15 times the individual Low Soil/Sediment CRDL.
Medium Soil/Sediment CRDLs for Semi-Volatile TCL  compounds were
defined  as being 60  times the individual Low  Soil/Sediment CRDL.
The  difficulty of  analyzing  samples at both  the  Low and Medium
CRDLs was recognized.  Originally, back calculations utilized those
PRP  lab  CRDLs.   However,  Contract  Required Quantitation Limits
(CRQLs)  from the Exhibit C addendum to the USEPA  Region IV ECBSOPQA
Manual were eventually utilized.   The adjustments of risk level
relative to  those  CRQLs  was accomplished  by  relating the risk
contribution of an individual constituent to a  specific pathway.
Standard CRQLs from Exhibit  C were used for Target Compound List
(TCL)  compounds and  standard CRDLs  from Exhibit C were used for
Target Analyte List  (TAL)  compounds.  As a  practical matter, one
has  to   be able  to  assure  detection  and  quantitation of   a
constituent before one can  assign a  risk to that concentration
relative to a specific pathway.   Numbers have been rounded where
appropriate.

Surface  Soils -  Dermal Contact
Constituent
i-. Bis(2-ethylhexyl)
phtnalate
EPC
0.9 mg/kg
Remediation
Level
0.54 mg/kg
CROL(Low)
0.33 mg/kg
[CRDL(Med)
0.33 mg/kg)
Desired
Risk
0.1 C
Note:  The Remediation level is less than the BPC.  CRQL(Med) is less than the
      Remediation Level.  Current and future noncarcinogenic risks are
      significant contributors to total pathway risk.

                             Remediation                       Desired
   Constituent	EPC	Level	CROL (Low)	Risk

2^. Heptachlor epoxide 0.006 mg/kg  1.87 ug/kg       1.7 ug/kg       1 X lO"5
                                               [CRDL (Low)
                                               0.533 ug/kg]

Note:  The Remediation Level is less than the BPC.  The CRQL(Hed) is more than
      the Remediation Level.  So the Low CRQL was utilized. Current and future
      carcinogenic risks are significant contributors to total pathway risk.

-------
                                  Remediation                          Desired
   Constituent	BPC.	Level	CROL (Low)	Risk

1^. 4,4'-DDE            0.023  ing/kg   5  ug/kg           3.3 ug/kg        1 X lO"*
                                                       [CRDL (Low)
                                                        1.07 ug/kg]

Note:  The Remediation Level is  less than  the  EPC.   CRQL(Med)  is higher t>^n
       the Remediation Level BO the CRQL(Low) was utilized.  Future  carcinogenic
       risks are significant contributors  to total pathway risk.



                                  Remediation                          Desired
   Constituent         BPC           Level              CRpL(Low)         Risk

4,,. 4,4'-ODD            0.058  mg/kg   7  ug/kg       -    3.3 ug/kg        1 X 10*
                                                       [CRDL (Low)
                                                        1.07 ug/kg]

Note:  The Remediation Level  is less than the BPC.  The CRQL(Med) is greater than
       Remediation  Level,  so we  utilized CRQL(Low),  which is less  than the
       Remediation  Level.
Remediation
Constituent EPC Level CROL (Low)
5_^ 4, 4 '-DDT 0.047 mg/kg 13.5 ug/kg 3.3 ug/kg
- • [CRDL(Med)
16 ug/kg]
Desired
Risk
0.1 C
Note:  The Remediation Level is less than the EPC.  The CRDL(Med) is higher than
       Remediation Level associated with 0.1 C HQ; the CRQL(Low)  Remediation
       Level.
Remediation
Constituent EPC Level
j^ alpha Chlordane 0.04 mg/kg 3.24 ug/kg
CROL (Low)
1.7 ug/kg
[CRDL (Low)
5.33 ug/kg]
Desired
Risk
0.2 C
Note:  The Remediation Level is less than the BPC.  The CRQL(Low) is greater than
       the Remediation Level for 0.1  C HQ.
Remediation
Constituent EPC Level
?_.. gamma Chlordane 0.04 mg/kg 3.24 ug/kg
CROL (Low)
1.7 ug/kg
[CRDL (Low)
5.33 ug/kg]
Desired
Risk
0.2 C
Note:  The Remediation Level is less than the EPC.  The CRQL(Low)  is greater than
       the Remediation Level for 0.1 C HQ.

-------
Constituent
8. Benzo(a)pyrene
(Residential)
(Future
Occupational)
Remediation
BPC Level
160 mg/kg
160 mg/kg
0.342 mg/kg
0.796 mg/kg
CROL(Low)
0.33 mg/kg
0.33 mg/kg
Desired
Risk
1 X 10-"
1 X 10-6
                                                      [CRDL(Med)
                                                 0.33 mg/kg for both]

Note:  The Remediation Level is less than the BPC.  The CRQL(Med)  is less
       the Remediation Level for 1 X 10"4 carcinogenic risk.  A 1 X 10"*
       carcinogenic risk was utilized for the Desired Risk.  The  lower  of the
       two Remediation Levels was chosen.
Remediation
Constituent BPC Level
9_,. Bis{2-ethylhexyl) 590 mg/kg
phthalate
281.2 mg/kg
[0.54 mg/kg]
CROL(Low)
0.33 mg/kg
[CRDL (Low)
0.33 mg/kg]
Desired
Risk
1 X 10-*
Note:  The Remediation Level is less than the BPC.  The CRQL(Low)  is less than
       the Remediation Level for 1 X 10~* risk.  In 1. above.  Bis (2-ethylhexyl)
       phthalate in Surface Soils has an Remediation Level of 0.54 mg/kg at a
       noncarcinogenic risk of HQ = 0.1 for children.  Since Surface Soils and
       Leachate Sediments will, as a practical matter, be mixed during
       consolidation and the volume of Leachate Sediments is expected to be small
       relative to the volume of Surface Soils,  the lower Remediation Level of
       0.54 mg/kg was chosen.



Ground Water - Inaestion as  Prinking Water

                                 Remediation                           Desired
   Constituent	EPC	Level	CROL	Risk

10. Antimony          63 ug/L       62 ug/L           60 ug/L           2 C
                                                       (CRDL)

Note:  Desired Risk was raised from 0.1 C to accommodate the CRDL.


                                 Remediation                           Desired
   Constituent	EPC.	Level	£BQ£	Eis3£_

11. Arsenic           14 ug/L       11 ug/L           10 ug/L           1.4 C
                                                       (CRDL)

Note:  The Desired Risk was raised from 0.1 C to  accommodate the CRDL.

-------
                                 Remediation                          Desired
   Constituent	EPC	Level	CROL	Risk
12- Barium            266 ug/L      231 ug/L          200 ug/L          0.6 C

Note:  The Desired Risk was raised to 0.6 C from 0.1 C to accommodate the CRDL.


                                 Remediation                          Desired
	Constituent	EPC	Level	CROL	Risk

13L. Chromium          230 ug/L       11 ug/L           10 ug/L          0.3 C

Note:  The Desired Risk was raised from 0.1 C to 0.3 C to accommodate the CRQL.


                                 Remediation                          Desired
	Constituent	EPC	Level	•   CROL	Risk

14. N-nitrosodi-
    n-propylamine     7.1 ug/L       11 ug/L           10 ug/L       8.4 X 10~*

Note:  The Desired Risk was raised from l X 10* to 8.4  X 10"4 to accommodate
       the CRQL.


                                 Remediation                          Desired
   Constituent	EgC	Level	CROL	Risk

15_. Thallium          15 ug/1. -      11 ug/L           10 ug/L           20 C

Note:  The Desired Risk was raised to 20 C from 0.1 C to accommodate the CRDL.


Surface Water - Inaestion as Drinking Water

                                Remediation                           Desired
   Constituent	E£C	Level	CROL	Risk

16. N-nitrosodi-
    n-propylamine     5-0 ug/L      11 ug/L           10 ug/L           20 C

Note:  The Desired Risk was raised to 20 C from 0.1 C to accommodate the CRDL.


                                         tile Walking/Wac

                                Remediation                           Desired
   Constituent	EgC	Level	CROL	Risk

17. 2-Chlorophenol    540 ug/L      23 ug/L          10 ug/L          0.1 C

Note:  The Remediation Level was above the EPC even at the Desired Risk of 0.1
      C.  A check of the Risk Assessment Numbers  indicated incorrect calculations
      which means a number or numbers is incorrect in the Assessment tables. We
      will utilize the above-described Remediation Level..

-------
                                Remediation                            Desired
   Constituent        BPC          Level	CROL	Risk

18. Diehloromethane  42,000 ug/L   5,870 ug/L        10 ug/L            0.1 A

Note:  No adjustments to the Desired Risk were made.

                                Remediation                            Desired
   Constituent	SPC          Level             CROL	;	Risk

19. 2,4-Dimethyl-
    phenol            790,000 ug/L 4,570 ug/L        10 ug/L            0.1 C.

Note:  No adjustments to the Desired Risk were made.



                                Remediation        •                    Desired
   Constituent        EPC          Level             CROL               Ripk

20. Nitrobenzene      890,000 ug/L 250 ug/L          10 ug/L            0.1 C

Note:  No adjustments to the Desired Risk were made.



                                Remediation                            Desired
   Constituent	EPC	Level	CROL	Risk

21. Phenol            3,000,000 ug/L 365,000 ug/L    10 ug/L            0.1 C

Note:  No adjustments to the Desired Risk were made.

-------
                                   EXHIBIT C
                        TARGET COMPOUND LIST (TCL)  AND
                 CONTRACT REQUIRED QUANTITATION LIMITS (CRQL)
NOTE:  The values in chese cables are quantitation limits, no.c absolute
detection limits .  The amount of material necessary to produce a detector
response that can be identified and reliably quantified is greater than that
needed to siaply be detected above the background noise.  The quantization
limits ir. these  tables are set at the concentrations in the sar.ple equivalent
to the concentration of the lowest calibration standard analyzed for each
Specific quantitation liaits are highly matrix dependent.  The quantitation
limits listed herein are provided  for guidance and may not always be
achievable .

The CRQL values listed on  the  following pages are based  on the analysis  of
samples according  the specifications given  in Exhibit D.  For each  fraction
and matrix, a brief synopsis of  the sampling handling and analysis  steps is
given, along with  an example calculation  for the CRQL value.  .-.11 CRQL values
are rounded to tvo significant figures.   "or soil samples, the aoisturs
content of the samples is  not  considered  in these example calculations.
                              C-l                                  OLMOi.O

-------
 TARGET COMPOUND LIST (TCL) AND CONTRACT REQUIRED QUANTITATION  LIMITS  (CRQL)
Volatiles
i .
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.


21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
Chlorome chane
Bromome chane
Vinyl Chloride
Chloroe chane
Mechylene Chloride
Ace cone
Carbon Disulfide
1 , 1 -Dichloroechene
1, 1-Dichloroe chane
1,2 -Dichloroechene (cocal)
Chloroform
1 , 2-Dichloroechane
2 - Bucanone
1,1, 1 -Trichloroechane
Carbon Tecrachloride
Bromodichlorome chane
1 , 2 -Dichloropropane
cis - 1 , 3 -Dichloropropene
Trichloroe chene
Dibromochloromethane
1.1,2 -Trichloroe ehane
Benzene
crans- 1, 3 -Dichloropropene
Bromoform
4 -Methyl- 2 -pencanone
2-Hexanone
Te crachloroe chene
Toluene
1,1,2,2 -Tecrachloroechane
Chlorobenzene
Echyl Benzene
S cyrene
Xvlenes (Tocal)
CAS Number
74-87-3
74-83-9
75-01-4
75-00-3
75-09-2
67-64-1
75-15-0
75-35-4
75-34-3
540-59-0
67-66-3
107-06-2
78-93-3'
71-55-6
56-23-5
75-27-4
78-87-5
10061-01-5
79-01-6
124-48-1
79-00-5
71-43-2
10061-02-6
75-25-2
108-10-1
591-78-6
127-18-4
108-88-3
79-34-5
108-90-7
100-41-4
100-42-5
1330-20-7
Ouanci
Water
u^/L
10
10
10
10
10
10
10
10
10
.10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
cation L
Low
Soil
ue/Ke
10
10
10
10
10
10
10
10 -
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
imits*
Med.
Soil
ug/Kp
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
' 1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
1200
On
Column
(ne)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50'-
(so:
(50^
(50)
(50)
(50)
(50)
(50)
(50)
(50)
(50;
(5C;
•-• Quancicacion limits  listed  for soil/sediment  are  based  on wet weight.  The
quancitacion limits calculated by the  laboratory for  soil/sediment.
calculated on dry weight basis as required by the contract, will  be higher.
                                    C-2
                                                                      OLMOL.O

-------
 Note that the  CRQL values listed on the preceding page may not be those
 specified in previous CLP Statements of Work.   These values are set at
 concentrations in the sample equivalent to the concentration of the lowesc
 calibration standard specified in Exhibit D VOA.   Lower quantitation limits
 may be achievable for water samples by employing the Statement of Work for
 Low Concentration Water for Organic Analyses.

 VOLATILES

 Water Samples

 A 5 mL volume  of water is purged with an inert gas at ambient temperature.
 The volatiles  are trapped on solid sorbents,  and desorbed directly onto the
 GC/KS.  For a  sample with compound X at the CRQL of 10 ug/L:

 (10 ug/L) (5 mL) (10*3  L/mL) - 50 x  10'3 ug - 50 ng on the GC column

 Lou Level Soil/Sediment Sample_s

 A 5 g aliquot  of the soil/sediment sample is added to a volume of water in a
 purge tube, heated, and purged with an inert gas.  The volatiles are trapped,
 and later desorbed directly onto the GC/MS.  For a sample with compound X ac
 the CRQL of 10 ug/Kg:

 (10 ug/Kg) (5  g) (10'3  Kg/g) - 50 x  10'3 ug - 50 ng on the GC column

 Medium Level Soil/Sediment Samples

NA 4 g aliquot  of soil/sediment is extracted with 10 mL of methanol. and
 filtered through glass wool.  Only 1 mL of the methanol extract is taken for
 screening and analysis.  Based on the results of a GC/FID screen, an aliquot
 of the methanol extract is added to 5 mL of reagent water and purged at
 ambient temperature.  The largest aliquot of extract considered in Exhibit D
 is ICO uL.  For a sample with compound X ac the CRQL of 1200 ug/Kg:

 (1200 ug/Kg) (4 g) (10':  Kg/g) -  4800  x 10*3 ug - 4800 ng

 This raaterial  is contained in the 10 mL methanol extract:

 (4800 ng)/ 10  mL - 480 ng/mL

 Of which. 100  uL are purged from the reagent water.

 (480 ng/mL) (100 uL) (10'3  mL/uL) - 480 x 10'l ng ) 50 ng on the GC column

 Note that for both low and medium soil/sediment  samples, while  it  may  affecc
 ;he purging efficiency, the volume  of  reagent water used in the  purging
 process does not affect the calculations.
                                     C- 3                               OLMO1.0

-------
 TARGET COMPOUND LIST  (TCL> AND CONTRACT REQUIRED QUANTITATION LIMITS  (CRQD
Seraivolaciles
34.
35.
36.
37.
38.
39.
40.
41.

42.
43.

44.
45.
46.
47.
48.
49.

50
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
Phenol
bis(2-Chloroechyl) echer
2-Chlorophenol
1 , 3-Dichlorobenzene
1 ,4-Dichlorobenzene
1,2- Dichlorobenzene
2-Mechylphenol
2.2'-oxybis
( 1 - Chloropropane ) *
4-Mechylphenol
N-Nitroso-di-n-
propylamine
Hexachloroechane
Nitrobenzene
Isophocone
2-Nicrophenol
2 ,4-Dimechylphenol
bis (2-Chloroechoxy)
methane
2 , 4-Dichlorophenol
1 , 2 . 4-Trichlorobenzene
Naphthalene
4-Chloroaniline
Hexachlcrobutadiene
4-Chloro-3-mechylphenol
2-Methylnaphthalene
Hexachlorocyclopentadiene
2,4. 6 -Triehlorophenol
2,4, 5 -Triehlorophenol
2 • Chloronaphchalene
2-Nitroaniline
Dimethylphchalate
Acenaphchylene
2 , 6-Dinicrocoluene
3-Nitroaniline
Acenaphthene
2.4-Dinicrophenol
4-Nicrophenol
CAS Number
108-95-2
111-44-4
95-57-8
541-73-1-
106-46-7
95-50-1
95-48-7

108-60-1
106-44-5

621-64-7
67-72-1
98-95-3
78-59-1
88-75-5
105-67-9

111-91-1
120-83-2
120-82-1
91-20-3
106-i7-3
87-58-3
59-50-7
91-57-6
77-47-4
88-06-2
95-95-4
91-58-7
88-74.4
131-11-3
208-96-8
606-20-2
99-09-2
83-32-9
51-28-5
100-02-7
Quancitacion Limits*
Low Med.
Vacer Soil Soil
u£/L ue/Ke ue/Ke
10
10
10
10
10
10
10

10
10

10
10
10
10
10
10

10
10
10
10
10
10
10
10
10
10
25
10
25
10
10
10
25
10
25
25
330
330
330
330
330
330
. 330

330
330

330
330
330
330
330
330

330
330
330
330
33C
330
330
330
330
330
800
330
800
330
330
330
800
330
800
800
10000
10000
10000
10000
10000
10000
10000

10000
10000

10000
10000
10000
10000
10000
10000

10000
loeoo
10000
10000
10000
10000
10000
10000
10000
10000
25000
10000
25000
10000
10000
10000
25000
10000
, 25000
25000
On
Column
(ne)
(20)
(20)
(20)
(20)
(20)
(20)
(20)

(20)
(20)

(20)
(20)
(20)
(20)
(20)
(20)

(20)
(20)
(20)
(20)
(2C)
(20)
(20)
(20)
(20)
(20)
(50)
(20)
(50)
(20)
(20)
(20)
(50)
(20)
(50)
(50)
= Previously known  by the name  bis(2-Chloroisopropyl)  ether
                                    C-4
OLIO 1.2  1/9L

-------
   Semivolatiles
                               CAS Number
Ouantitation Limits,*
       Low     Med.       On
Wacer  Soil    Soil    'Column
ue/L   ue/Ke   ug/Kg	(ngj
                                                     33C
                                                     330
                                                     330
                                                     330
                                                     330

                                                     330
                                                     330
                                                     ?•>.!•;
                                                           10000
                                                           10000
800
800
330
330
330
25000
25000
10000
10000
10000
(50)
(50)
(20)
(20)
(20)
69.  Dibenzofuran                132-64-9     10      330   10000
70.  2.4-Dinitrotoluene          121-14-2     10      330   10000
71.  Diechylphchalate             84-66-2     10      330   10000
72.  4-Chlorophenyl-phenyl
     ether                     7005-72-3     10      330
73.  Fluorene                     86-73-7     10      330
74. 4-Nitroaniline              100-01-6     25
75. 4,6-Dinitro-2-methylphenol  534-52-1     25
76. N-nitrosodiphenylamine       86-30-6     10
77. 4-Bromophenyl-phenylether   101-55-3     10
78. Hexachlorobenzene           118-74-1     10

79. Pentachlorophenol            87-86-5     25
80. Phenanchrene                 85-01-8     10
81. Anthracene                  120-12-7     10
82. Carbazole                    86-74-8     10
83. Di-n-butylphthaiate          84-74-2     10

84. Fluoranthene                206-44-0     10
85. Pyrene                      129-00-0     10
86. Butylbenzylphthalate         85-68-7     10
87. 3,3'-Dichlorobenzidine       91-94-1     10
38. Benzo(a)anthracene           56-55-3     10

.,9. Chrysene                    218-01-9     10
90. bis(2-Ethylhexyl)phchalate  117-81-7     10
91. Di-n-octylphthalate         117-84-0     1C
92. Benzo (b) "fluoranthene        205-99-2     1C
93. Benzo(k)fluoranthene        207-08-9     10
               10000
               10000
               10000
               10000
               10000

               10000
               10000
               10000
               1000C
               10000
=c.  Benzo(a)pyrene               50-32-8      10      330   10000
95.  Indenod. 2.3-cd)?yrene       193-39-5      1C      22C   10000
96.  Dibenz(a.h)anchracene        53-70-3      10      330   10000
97.  Benzo(g.h.i)perylene         191-24-2      10      330   10000
                        (20)
                        (20)
                        (20)

                        (20)
                        (20)
800
330
330
330
330
25000
10000
10000
10000
10000
(50)
(20)
(20)
(20)
(20)
(20)
(20)
(20)
(20)
(20)

(20)
(20)
(20)
(20).
(2C>

(20)
(20)
(20)
(20)
                                                                         The
* Quantitation  limits  listed for soil/sediment are based on wet weight.
quantisation  limits calculated by the laboratory for soii/sediment.
calculated  on dry weight basis as required by the contract, will be higher.
                                    C-5
                                                                OLM01.1  12/90

-------
SEMIVOLATILES

Uacer Samples

AIL volume of water  is excracced in a continuous liquid-liquid extractor
with nethylene chloride at a pH of approximately 2.  This extract is reduced
in volume Co 1.0 mL, and a 2 uL volume is injected onto the GC/MS for
analysis.  For a sample with compound X at the CRQL of 10 ug/L:

(10 ug/L) (1 L) -  10 ug in the original extract

When the extract is concentrated, this material is contained in the 1 mL
concentrated extract,  of which 2 uL are injected into the instrument:

(10 ug/mL) (2 uL)  (10'3 mL/uL)  - 20  x 10'3 ug - 20 ng on the GC column

Low Soil Samples

A 30 g soil sample is  extracted three times with methylene chloride/acetone
at ambient pH, by  sonication.  The extract is reduced in volume to 1.0 mL,
and a 2 uL volume  is injected onto the GC/KS for analysis.  For a sample wich
compound X at the  CRQL of 330 ug/Kg:

(330 ug/Kg) (30 g) (10-3 Kg/g)  - 9900 x  10'3 ug - 9.9 ug

When the sample extract is to be subjected to Gel  Permeation Chromatography
(required) to remove high molecular weight interferences, the volume of the
extract is initially reduced to 10 =L.  This 10 xL is pur through the G?C
column, and only 5 mL  are collected  off the G?C.   That 5 nL volume is reduced
to 0.5 mL prior to analysis.  Therefore:

(9.9 ug/10 mL) (5  mL)  - 4.95 ug

This material is contained  ir.  the 0.: nl  extract,  ;f which 2 uL are  injected
into the instrument:

(4.95 ug/0.5 mL) (2 uL) (10'3 mL/uL)  - 1.93 x 10"2  ug ) 20 ng on the  GC cclursr.

Medium Soil Samples

A 1 g soil sample  is extracted once  with  10 mL of  oethylene chloride/acetone,
which is filtered  through glass wool  to remove particles  of soil.  The
filtered extract is  then subjected  co G?C clean  up,  and  only  5 mL of extract
are collected after GPC.  This  extract  is reduced  in volume to 0.5 mL,  of
which 2 uL are injected onto  the GC/MS.   For  a sample with compound  X ar the
CRQL of 10.000 ug/Kg:
(10,000 ug/Kg)  (Ig)  dO'3 Kg/g) -  10 -_|
(continued)
                                     C-6                          OLM01.2  L/91

-------
Semivolaciles. Medium Soil, continued -

This material is contained in che 10 mL extract, of which only 5 mL are
collected after GPC:

(10 ug) (5 mL/10mL) - 5 ug

The volume of this extract is reduced co 0.5 mL. of which 2 uL are injected
into the instrument:

(5 ug/0.5 mL) (2 uL) (10'3 mL/uL)  -  20  x IQ'3 ug - 20 ng on the GC column

Eight semivolatile compounds are  calibrated using only a four point initial
calibration, with the lowest standard at 50 ng.  Therefore, the CRQL values
for these eight compounds are 2.5 times higher  for all matrices and levels.
                                     C-7                        OLM01.1  12/90

-------
 TARGET  COMPOUND  LIST  (TCL) AND CONTRACT REQUIRED QUANTITATION LIMITS (CRQL)
                                            Quancitacion Limits*
                                            Uacer   Soil    On Column
98.
99.
100.
101.
102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.
121.
122.
123.
124.
125.
alpha -BHC
beca-BHC
delta-BHC
gamma -BHC (Lindane)
Hepcachlor
Aldrin
Hepcachlor epoxide
Endosulfan I
Dieldrin
4, 4' -DDE
Endrin
Endosulfan II
4, 4 '-ODD
Endosulfan sulface
4, 4'. DDT
Mechoxychlor
Endrin kecone
Endrin aldehyde
alpha-Chlordane
gamma - Chi o r dane
Toxaphene
Aroelor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
319-84-6
319-85-7
319-86-8
58-89-9
76-44-8
309-00-2
1024-57-3
959-98-8
60-57-1
72-55-9
72-20-8
33213-65-9
72-54-8
1031-07-8
50-29-3
72-43-5
53494-70-5
7421-36-3
5103-71-9
5103-74-2
8001-35-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
0.05
0.05
0.05
0.05
0.05
0.05
0.05
0.05
o.io -
0.10
0.10
0.10
0.10
0.10
0.10
0.50
0.10
0.10
0.05
0.05
5.0
1.0
2.0
1.0
1.0
1.0
1.0
1.0
1.7
1.7
1.7
1.7
1.7
1.7
1.7
1.7
3.3
3.3
3.3
3.3
3.3
3.3
3.3
17.0
3.3
3.3
1.7
' 1.7
170.0
33.0
67.0
33.0
33.0
33.0
33.0
33.0
5
5
5
5
5
5
5
5
10
10
10
10
10
10
10
50
10
10
5
5
500
100
200
100
100
100
100
100
* Quancitacion limits  lisced  for soil/sediment are based on wee weight.  The
quancicacion limits calculated by  the  laboratory  for soil/sediment,
calculated on dry weight  basis as  required by the contract, will be higher.

There is no differentiation between  the  preparation of  low and medium  soil
samples in this method for the analysis  of Pescicides/Arociors.
                                    C-8
OLM01.1  12/90

-------
PESTICIDES/AROCLORS

Uacer Samples

A 1 L volunc of water is extracted three times with methylene chloride or by
a continuous liquid-liquid extractor.  This extract is reduced in volume to
approximately 3-5 ml., and diluted up to 10.0 mL with clean solvent.  Uhen Gel
Permeation Chromatography is performed, only 5 of the 10 mL of extract are
collected after GPC.

Regardless of whether GPC is performed, either 1.0 or 2.0 mL of the 10.0 mL
of the original extracts are taken through the remaining clean'up steps
(Florisil and sulfur removal).  The volume taken through Florisil cleanup and
the final volume of the extract after the clean up steps depends on the        ;
requirements of the autosampler.  If the autosampler can handle 1.0 mL final
extract volumes, this is the volume taken through ..Florisil and the final       j
volume.  If the autosampler cannot reliably handle 1.0 mL volumes, the volume
is 2.0 mL.  When using an autosarapler. the injection volume may be 1.0 or 2.0
uL.  Manual injections must use a 2.0 uL injection volume.

For a sample with compound X at the CRQL of 0.05 ug/L and an autosampler       '
requiring a 1.0 mL volume:

(0.05 ug/L) (1 L) - 0.05 ug in  the original extract

This material is contained in the 10.0 mL of extract:

(0.05 ug)/ (10.0 mL) - 0.005-ug/mL

Of which, only 1.0 mL is carried through the remaining clean up steps.  For a
final extract volume of 1.0 mL  and a 1 uL injection volume:

(0.005 ug/mL)(l uL)(10-J raL/uL)  - 5  x 10"e ug - 5 pg on the GC colur.r.

So.il Samples

There is no differentiation between  the preparation of low and mediu.'n  soil
ssmp1?- in this method for the  analysis of pesticices/Aroclors.   A  ;0  §  so..
sarspie is extracted three times with methylene chloride/acetone by             ;
sonication.  The extract is reduced  in volume to 10.0 mL  and subjected to Gel
Permeation Chromatography.  After GPC, only 5.0 mL of extract are collected.
However, as with the water sample described above, either 1.0  or 2.0  mL of   j
that extract are subjected to the other clean up steps, so no  loss  of
sensitivity results from the use of  GPC.  From this point on,  the soil sample
extract is handled  in the same  fashion as the extract of  a water  sample.   For
a sample with compound X at the CRQL of 1." ug/Kg:

.1.7 --g/Kg) (20 g)  (10°  Kg/g)  - 51 x 10'- ug - 51 ng  in  the  original  excrscr

This material is contained in the  10.0 mL  of  extract:

(51 ng)/ 10 nL - 5.1 ng/mL

(continued)


                                    C-9                         OLM01.2   1/91

-------
Pesticides/Aroclors.  continued -

Of which, only  1.0  or 2.0 mL are  carried  through the remaining cleanup steps.
For a final extract volume  of 1.0 mL and  a 1 uL injection volume:

(5.1 ng/mL)(l uLHlO'3 mL/uL) - 5.1 x 10"' ng ) 5 pg on the CC coluam.

For either water or soil samples, if the  autosaopler used requires a 2.0 mL
final volume, the concentration in  the  10.0 mL of extract above remains the
same.

Using a 2 uL injection volume,  cvice the  total number of picograms are
injected onto the GC  column.   However,  because the injection volume muse be
the same for samples  and standards, cvice as much material is injected onto
the column during calibration,  and  thus the amount of compound X injected
from the sample extract is  equivalent to  the amount of compound X injected
from the calibration  standard,  regardless of injection volume.

If a single injection is used for two GC  columns attached to a single
injection port, it  may be necessary to  use an injection volume greater than 2
uL.
                                    C-10                         OLM01.5   V91

-------
                                         TABLE 3-3
                        CURRENT & FUTURE RESIDENTIAL EXPOSURE:
                       INGESnON OF CHEMICALS IN DRINKING WATER
                                    DIGESTION INTAKES
                                Smith's Farm, Operable Unit Two
                                       Brooks, Kentucky
INGESTION INTAKE (•)

Where: C
IR
EF =
ED =
BW =
AT =
Exposure
Variable
IR
EF
ED (Adult)
ED (Child)
BW (Adult)
BW (Child)
AT (Noncarc. - Adult)
AT (Noncarc. - Child)
AT (Carcinogen)
C • IR • EF • ED
BW* AT
Concentration in Media of Concern, mg/L
Ingestion Rate, L/day
Exposure Frequency, days/year
Exposure Duration, years
Body Weight, kg
Averaging Time, days
Ingesuon of Drinking Water
(Surface Water or Ground Water)
2
350
30
6
70
15 \
10,950
2,190
25,550
  PATHWAY-SPECIFIC INTAKES:
                    Water (Current it. Future):
Residential Adult (Noncarcinogens)

Residential Adult (Carcinogens)

Residential Child (Noncarcinogens)
                                                   C»

                                                   C«

                                                   C •
0.027  = Intake (mg/kg/day)

0.012  = Intake (mg/kg/day)

 0.13  = Intake (mg/kg/day)
(a) Chemical-specific intakes are calculated individually in the risk calculation tables (Appendix C).
                                          3-30

-------
                                             TABLE 3-5
                           CURRENT & FUTURE RESIDENTIAL EXPOSURE-
                          DERMAL CONTACT WITH CHEMICALS IN WATER
                                          DERMAL DOSES
                                    Smith's Farm, Operable Unit Two
                                           Brooks, Kentucky
DERMAL INTAKE (SHOWER)










Exposure
Variable
SA
SA
PC
ET
EF
EF
ED
ED
BW
BW
AT
AT
AT












(Adult)
(Child)


(Adult)
(Child)
(Adult)
(Child)
(Adult)
(Child)
(Noncarc.-
(Noncarc.-

C
SA
PC
ET
EF
ED
BW
.AT
CF












Adult)
Child)
(Carcinogen)
(a)



—

=
=
C • SA • PC * ET • EF • ED • CP
BW'AT
Concentration in Media of Concern,
Surface Area of Exposed Skin, cm1


mg/L

= Dermal Permeability Constant, cm/hr






Shower
Scenario
18,150
"7,200

0.25
350
350
30
6
70
15
10,950
2,190
25,550
=
=
=
=
=
=
Residential
Wading
2,550
7,200
CHEMICAL
2.6
7
7
30
6
70
15
10,950
2,190
25,550
Exposure Time, hr/day
Exposure Frequency, days/yr
Exposure Duration, years
Body Weight, kg
Averaging Time, days
Conversion Factor, .001 L/cm"3
Leachate Water







Residential Occupational
1,000
525
SPECIFIC(b)
2.6
7
7
30
6
70
15
10,950
2,190
25,550 .
935
~

1
250
NA
1
—
70
'
365
—
25,550
PATHWAY-SPECIFIC INTAKES:
Dermal Intake During Showering:
  Residential Adult (Noncarcinogens)
  Residential Adult (Carcinogens)
  Residential Child (Noncarcinogens)
C » PC • CF •     6.20E-K)!  = Intake (mg/kg/day)
C • PC • CF •     2.70E-K)!  = Intake (mg/kg/day)
C * PC • CF •     1.20E-»C2  = Intake (mg/kg/day)
(a) Chemical-specific intakes are calculated individually in the risk calculation tables (Appendix C).
(b) Chemical-specific permeability constants, multiplied by the conversion factor of 0.001 L/cm'3, are included in
    the intake calculations in the risk calculation sheets (Appendix C).
                                            3-33

-------
                                          TABLE 3-5 (continued)
                             CURRENT &. FUTURE RESIDENTIAL EXPOSURE:
                            DERMAL CONTACT WITH CHEMICALS IN WATER
                                            DERMAL DOSES
                                     Smith's Farm, Operable Unit Two
                                            Brooks, Kentucky
Dermal Tnt«V* During
  Residential Adult (Noncarcinogeos)
  Residential Adult (Carcinogens)
  Residential Child (Noncarcinogens)
C « PC • CF •
C • PC • CF •
C • PC • CF *
          1.80E+00 = Intake (mg/kg/day)
          7.80E-01 = Intake (mg/kg/day)
          2.40E+01 = Intake (mg/kg/day)
Dermal Intake from Exposure to Leachate Water:
  Residential Adult (Noncarcinogens)
  Residential Adult (Carcinogens)
  Residential Child (Noncarcinogens)
  Occupational Adult(Noncarcinogens)
  Occupational Adult(Carcinogens)
C • PC • CF •
C * PC • CF •
C • PC • CF •
C*PC
C*PC
CF«
CF •
7.10E-01  = Intake (mg/kg/day)
3.10E-01  = Intake (mg/kg/day)
1.70E-KX)  = Intake (mg/kg/day)
9.10E+00  = Intake (mg/kg/day)
1.30E-01  = Intake (mg/kg/day)
(a) Chemical-specific intakes are calculated individually in the risk calculation tables (Appendix C).
(b) Chemical-specific permeability constants, multiplied by the conversion factor of 0.001 L/cm"3, are included in
    the intake calculations in the risk calculation sheets (Appendix C).
                                             3-34

-------
                                                 TABLE 3-8
                                     FUTURE OCCUPATIONAL EXPOSURE,
                               CURRENT AND FUTURE RESIDENTIAL EXPOSURE
                                       DERMAL CONTACT WITH SOILS
                                               DERMAL DOSES
                                         Smith's Farm,Operable Unit Two
                                               Brooks, Kentucky
DERMAL INTAKE (a)










Exposure
SA
SA
AF
ABS
EF
ED
ED
BW
BW
AT
AT
AT

C
SA
AF
ABS
EF
ED
BW
AT
CF
Variable
(Adult) . •
(Child)



(Adult)
(Child)
(Adult)
(Child)
(Noncarc.- Adult)
(Noncarc.- Child)
(Carcinogen)
Conversion Factor
C • SA • AF • ABS * EF • ED • CF
BW'AT

Concentration in Media of Concern, mg/lcg
Surface Area of Exposed Skin,
Soil to Skin Adherance'Factor,
Absorption Factor (unitless)
Exposure Frequency, days/yr
Exposure Duration, years
Body Weight, kg
Avenging Time, days
cmVday
mg/cm2





Conversion Factor (10"-6 kg/mg)
Residential Occupational
5,000
2,900
1
100% (metals: 0.1%)
350
30
6
70
15
10,950
2,190
25,550
1E-06
3,160
—
1
100% (metals: 0.1%)
250
1
—
70
—
365
—
25,550
1E-06
               PATHWAY-SPECIFIC INTAKES (mg/kg/day):
                     Intake:
                  Residential Adult (Noncarcinogens)
                  Residential Adult (Carcinogens)
                  Residential Child (Noncarcinogens)
                  Occupational Adult (Noncarcinogens)
                  Occupational Adult (Carcinogens)
    ORGANICS:
C • 6.85E-05
C* 2.94E-05
    METALS:
C • 6.85E-08 =Intake (mg/kg/day)
C • 2.94E-08 =Intake (mg/kg/day)
C • 1.85E-04   C • 1.85E-07 =Intake (mg/kg/day)
C • 3.09E-05   C • 3.09E-08 =Intake (mg/kg/day)
C* 4.42E-07   C» 4.42E-10 =Intake (mg/kg/day)
               (a) Chemical-specific intakes are calculated individually in the risk calculation sheets (Appendix Q.
                                                         3-39
f •>

-------
                                    TABLE 3-9
                        FUTURE OCCUPATIONAL EXPOSURE:
                  CURRENT AND FUTURE RESIDENTIAL EXPOSURE
                        DERMAL CONTACT WITH SEDIMENTS
                                  DERMAL DOSES
                           Smith's Finn, Operable Unit Two
                                  Brooks, Kentucky
DERMAL INTAKE (a)











Exposure
SA
SA
AF
ABS
ET
EF
ED
ED
BW
BW
AT
AT
AT
CF

C
SA
AF
ABS
ET
EF
ED
BW =
AT
CF
Variable . .
(Adult)
(Child)




(Adult)
(Child)
(Adult)
(Child)
(Noncarc.- Adult)
(Noncarc.- Child)
(Carcinogen)

C • SA • AF • ABS • ET • EF • ED • CF
BW'AT
Concentration in Media of Concern, mg/kg
Surface Area of Exposed Skin, cmVday
Soil to Skin Adhennce Factor, mg/cm*
Absorption Factor (unitleas)
Exposure Time, hr/day * day/24 hr (i.e., fraction of day)
Exposure Frequency, days/yr
Exposure Duration, years
Body Weight, kg
Averaging Time, days
Conversion Factor (10*-6 kg/mg)
Residential Occupational
1,000 935
1,935
1 1
100% (metals: 0.1%) 100% (metals: 0.1%)
2.6 1
7 250
30 1
6
70 70
15 —
10,950 365
2,190
25,550 25,550
1E-06 1E-06
PATHWAY-SPECIFIC INTAKES (mg/kg/day):
   Residential Adult (Noncarcinogens)
   Residential Adult (Carcinogens)
   Residential Child (Noncarcinogens)
ORGANICS:
 C« 2.96E-08
 C* 1.27E-08
 METALS:
C» 2.96E-11
C» 1.27E-11
 Intake (mg/kg/day)
: Intake (mg/kg/day)
 C • 2.68E-07   C • 2.68E-10  - Intake (mg/kg/day)
   Occupational Adult (Noncarcinogens)       C •  3.81E-C7
   Occupational Adult (Carcinogens)          C •  5.46E-09
(a) Chemical-specific intakes are calculated individually in the risk calculation tables (Appendix C)
                C* 3.81E-10  = Intake (mg/kg/day)
                C* 5.46E-12  = Intake (mg/kg/day)
                                         3-40

-------
                        INORGANIC TARGET ANALYTE LIST (TAL)
          Analyce
Contract Required
  Detection Limit
      (ug/L)
          Aluminum
          Antimony
          Arsenic
          Barium
          Beryllium
          Cadmium
          Calcium
          Chromium
          Cobalt
          Copper
          Iron
          Lead
          Magnesium
          Manganese
          Mercury
          Nickel
          Potassium
          Selenium
          Silver
          Sodium
          Thallium
          Vanadium
          Zinc
          Cyanide
        200
         60
         10
        200
          5
          5
       5000
         10
         50
         25
        100
          3
       5000
         15
          0.2
         40
       5000
          5
         10
       5000
         10
         50
         20
         10
(1)   Subject to the restrictions specified in the first page of Part G,
     Section IV of Exhibit D (Alternate Methods • Catastrophic Failure)  any
     analytical method specified in SOW Exhibit D -ay be utilized as long as
     the documented instrument or method detection limits meet the Contract
     Required Detection Limit (CRDL) requirements.  Higher detection limits
     may only be used in the following circumstance:

               If the  sample  concentration exceeds five•times  the detection
               limit of the  instrument or method in use,  the value may be
               reported even  though the instrument or method detection limit
               may not equal  the Contract Required Detection Limit.   This is
               illustrated in the exacoie beiou-:
               For lead:

               Method in use = ICP
               Instrument Detection Limit (IDL) - 40
               Sample concentration - 220
               Contract Required Detection Limit (CRDL)
            - 3
                                    C-l
                           ILM02.0

-------
(2)
          The value of 220 may be reported even chough che instrument
          detection limit is greater than CRDL. The instrument or
          method detection limit muse be documented as described in
          Exhibits B and E.

The CRDLs are the  instrument detection limits obtained in pure water
that must be met using the procedure in Exhibit £.  The detection
limits for samples may be considerably higher depending on che sample
matrix.
                                 C"2                                ILM02.0

-------
U.S. DEPARTMENT OF COMMERCE
National Technical Information Service
Springfield. Va. 2? 1(11
AN EQUAL OPPORTUNITY EMPLOYER
orriciAL HUSINESS
Penalty for Private Use. $300
                                        POSTAGE AND FEES PAID
                                    US. DEPARTMENT OF COMMERCE
                                              COM-211

                                             FIRST CLASS

-------