Uratrt St«»»
Environmental Protection
Agency
OtKotOl
EPA/fiOOR03-86«22
Supekfund
Record of
Leetown Pesticide, WV
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TECHNICAL REPORT DA T A
f"rGtI r8tJ '''fI'I4CIIOIfI Off lit. ,.,V,,,. ~/tJrf cOIfI"f'lI"rJ
,. III.'OIilT "'0. 12. 2. III.CI'I~"'T'S "CCISSIO'" "'0.
EPA/ROD/R03-86/022 PM F, 2 2 .4 8 5 4 III
.. TlTL. ."'0 SU8TITLI S. III.'OIilT OATI
SUPERFUND RECORD OF DECISION March 31. 1986
Leetown Pesticide, WV e. '1 IIII',:) 111M ''''0 OlllO"",,'ATIO... COOl
7. AuTHOIII'51 .. '11III'OIllM,...O OIllOA"",ATIO'" ""OlilT "'0
'I. ""I'O"M''''O O"'..AIoI.,ATIO... "'AMI AHO AOOIilISS la. ''''OOIilAM 'L&M."'T "'g.
11. ...""H , ...... ,I....AH "'g.
Same as box 12.
12. 51'OH50111''''0 AOI...CY HAMI A"'O AOOIilISS ,:1. T,,'. 01' IIII"OIilT AHO "'''''00 COVI"'IO
U.S. Environme"tal Protection Agency Final ROD Reoort
401 M Street, S.W. . 1.. S"O"SOIll''''O AOI...CY COOl
Washington, D.C. 20460 300/00
15. SUI''''''IMINTA'''Y NOTI.
-
1.. A8STlilACT
The Lee~own Pesticide site is located in norlheast West Virginia, approximately 8
miles soutn of Martinsburg, West Virginia. The .site. is actually composed of a numbe
of areas affected by surface disposal of pesticides, agricultural use of pesticides, a
landfilling. A total of eight specific areas of waste disposal or accumulation were
identified during the initial RI study. Of these eight areas, two were the result of
alleged disposal of pesticide-contaminated debris from a fire that occurred in 1975 ac
the Miller Chemical Company~ These two areas include the former pesticide pile and th
suspected pesticide hndfarm areas. Four of the contaminated areas are associated wit
former use of the land for orchard production. The two remaining sites are active
landfills.
The results ot the contaminant release and exposure study indicate that the suspect
la~dfarm and apple orchards do not appear to comprise significant sources of
environmental contamina~ion. The only th~ee areas out of the eight investigated that
present concentrations ofpestic~des above ambient soil background (non-pesticide use
areas) and orc~ard background levels (pesticide application areas) are the following:
. Former Pesticide Pile Area (presently: Robinson Property)
. ' Former Jeffersc.n Orchard Mixing Area (presently: Rob inson Property)
. Former Crimm Orchard Packing Shed (presently: Tabb Barn)
(~ee Attachea Sheet)
17. 1(1'( WQIIIO' ANO OOCtJMI...T A...A","SII
~. O.£CllllltTO"'. b. 1 01... TII". IIIS/O".'" 1"'010 TI!"'MS C. COSATI Fietd/~fOVP
Record of .Decisian
Leetown Pesticide, WV
Contaminated Media: so 11; sediments
Key contaminants: pesticides, ocganicsi
inorganics
". 0ISTIII'8UTI0... STATE MINT 1.. S£CI./I'I,TY CLAS., nil' R,po", 21, ...0."1' 'AOIS
None - .. 92
2a. SICYI'II T" CLASS I TIII1/1.'" 22. '''''CI
None
!,. ,- 2220-1 (It.... '-771
d
d
. ".."'0'" &0''''0'' " O.'O"'C".
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EPA/ROD/~03-86/022
Leetown ~esticide, WV
16.
ABSTkACT (continued)
. The selectea remedial action for this site includes: excavation ~nd
consolidation of approximately 3600 cubic yards of contaminated 80i1 from
the three areas mentioned above: placement of these soils in an ons.t-.
8tr~atment bed8 to enhance anaerobic biodegradation of the pesticide
contamination, removal and offsite disposal of the contaminated flooring, a
wooden spray wagon, and drums of pesticide pro~uct in a permitted hazardous
waste facility, construction of a monitoring well network: and construction
of surface water dive~sion systems, sedimentation channels, and diversion
dikes. Total capital cost. for the selected remedial alternative i.s .
estimated to be $1,014,000 with CiM costa approximately $10,000 Lor th~
first year and $',SOa for the second. .
.'
. '
I,
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~Er.dRJ (IF )t::CIS[I)~;"
~~~~diJl A~cion Alt~rnatlve S~t~~ti~n
'" i : ~ :
.L~t!t,)wn ?~Hid,j~ Sit.!, Jefferson Count:',
;,'t!St ::ir~inia
D0C\lm~nts Revie'Jed
The u1',d.!rtyin~ c.!chni~31 infcr:nati,)n, IInle.... other'Jise specifl.!d,
used f~r a~3lysis 0f c05t-~tfectivendss and f~asibiiity 0i remedial
alternatives is lnctude~ l~ the fvlLowin~ documents and proie~t
correspondence. I have been brief~d by my staff of ~heir content.., and
they form the principal ~asis for my d~cision of the appropriate ~xtent
vi remedial action~ .
- "Remedial lrivestigaticn Report" (Draft), Leetown Pesticide Site,
Jefferson County, West Vir~inia (NUS Corporation, February L986)
- "Fe~sibility Study of AlternatIves" (Draft), Leetown Pesticide Site,
Jefferson County, W~st Virginia (NUS Corporation, February L986)
- Recommendations by the West Virginia Department of :-latural Resources.
- St2ff summarl~s and recommer.~ations.including the attached
"Summary of Remed .1 Alternative Selection, lee town .Pesl1cide Site".
D~scrlption of the Selecaeo Remedy
- Excavation and consolidation of approximately 3.600 cubic yards of
contaminated soil from three separate contaminated areas (Former
Pesticide Pile Area; For-mer- Pesticide ~lxlng Ar~a and the Former
Crlom Packin, Shed Area) ..
- Place~ent of these soils in a "treatment bed", constructed on the
sHe near the FOnDer Pestidde Pile Area. Treatment of chese so11s
to enhance anaerobic blodegradation of the pesticide contamination.
- Removal and disposal in ~ permitted hazardous waste facility of the
contaminated flooring, a 'Jooden spray wagon. and drums of pesticide
product. The pr-eferred off-site disposal method for the drums of
pesticide product is incinerat~on.
. Construction ~f a monltoring well network upgradient and downgradient
of the treatment bed ar-ea. It is estimated that 6 downgradienc
a~d 2 upgradient wells will be sufficient for ground water- monitoring
-during and subsequenc to tr-eat:llent operations. .
- All anclllary construction necessary tosupporc site activities.
. These include: construction of tempor3ry access roads, decontamination
pads, surfdce wacer diversion systems, sedimentation channels 3nd
diverslon dikes.
- Any field testing and/or- laboratory be~ch scale testing needed to
verify soil conditioning material and quantity for maximizing
biodegradability within the treatment bed. These tench tests will
be performed in a pre-design phase. .
j' I
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..;per.2~i~:, .3nd ~!ai~tcnan..:t!
Opt'r.ltion .lnll .,ai='te'1ance (,) .!. ~t) will "e i!1iti~teti hy t'le State of
~est ~lr~I=,la one ~t!ai subsequ~nt ~o the cOM~te:ion of tht! remedial
actions. Remerlial actions will he cU~jidered completed, ~hen tar~et DOT
t.~....~13 dr-I! r~~ch~d ii. the treated soils. Since this a "~lean closure'"
t~pt! of~peratlon. the only state conducted 0 & ~ antl~lpateQ will be
two Ye.JCS .:Jf ~roun
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I
I '
CO~TESTS
Section
Page
A.
Site Location a~d
L1e s c: rip t ion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.
Sit e Iii s tor y. .
. ,. . . ..8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2
c.
Re!!led1al
................ 6
[nvescigati~n Scope.................
,D.
~ydrologic Investigat'ion (Surface Waters).................... 6
Q-\ ?hystcal Data.....................~..................... ~
0-2 Chemical Data...........,..".,."."."",.."",..".", 7,
E.
Hydrologic Investigation (Sedi~ents)......................... 7
F.
Iiydrogealogic Investigation (Ceo logy)........................ 8'
F-1. Physical Data........................................... 9
G.
Iiydrogeologic
G-1 Phya1 cal
G-2 Chemi cal
Investigation (Cround wate~)...........~.......
Oa t a. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . . .
10
10
11
Data................................~..~.-......
H.
,
The Biota Investigation......................................
H-l Aqua t1 c: Survey.."........................................
K-Z Fish Survey.............................................
H-3 PhY9~c:al Data................. '..'.' 8.........'..... .'.8..
H-4 Chemical Data"...... 8._...'" 8".........................
12
12
12
13
13
I.
S01ls .Invesc1gat1on.....................~........._..........
1-1 Background Samples.........~............................
I-2
I-3
I-4
1-;
I-6
14
14
14
15
16
17
17
r-7
I-8
Suspected Pesti~ide La~dfarm (Lloyd proper~y)...........
Crimm O~chard (rabb Pro~=ty}...........................
Jefferson Orc~ard ~;::r&w Property)......................
Jefferson Orchard (Robinson Properey)...................
For~er Jefferson Orchard Pest~c1de Mixing Area..........
(Robinson P~operty)
Former Pesticide Pile Area (Robinson Property)..........
West Virginia DOH Garage Landfill.......................
17
18
J.
SUllllDary of
18
Condl t 10ns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
K.
Health and Environmental tmpacts...............~.............
19
K-l Qualitative Risks......................................
K-La Former Jefferson Orchard...............................
19
19
(USF&W and Ro;inson Property)
K-lb Crimm Orchard (Tabb Property).......................... 20
K-1c Suspected PC3ticide Landfarm (Lloyd Property).......... 20
K-ld Jeffecson County Landfill.............................. 20
K-IA~WV DOH Garage Landfill................................. 21
K--lf ForoJler Pesticide Pile Are..............."............... 21
. .
i<-lg Pe3ti~lde M1.xi~'g Area.........,........"""""".""" 21
v
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Section
Pa~e
!(-lh
K- 2
1<-3
Former Crimm Orchard Packing Shed..................... 22
Environmental R1sks..............~....................' 22
Quantitative Risks................................~... 23
,
..,
Remedial Action Te~hnology Screening....................... :4
~.
Development of R~medlal Action Alternatfve~......, ......... :5
~.
Description of Remedial Action Alt~rnatives...............;. 26
~-l Remedial Action Aiternative No. l- ~o Actio~..~...... ~7
~-2 Remedial ~ction Alt~rnative No. ~ - ~o Action......... 27
~-3 Remedial Action Alternative ~o. 3.......~............. 27
Soil cap with monitoring
:-.1-4 Remedial Action. Alternative No.4..................... 28
~ulC1-~edia Cap
~-S Remedial Action Alternative No.5..................... 29
Onst te -Landfill
N-6 Remedial Action Alternati'te No.6.... ................. 30
Offsite Disposal .
N-7 Remedial Action Alternative No. 7........~...........~ 31
On91 te Treatment .
O.
Recommended
A~ternatlve.................................... 32
P.
Contaminant Reduction target tevels............ ............ 34
Q.
Operation and Maintainance (O&M)........................... 35
R.
Compliance with Other Environmental taws................... 36
R-l General............................................... 36
R-2 Resource Conservation and Recovery Act (RCRA)......... 37
R-l Wetlands/Floodplains -Assessment..... ~.... ~............ 37
S.
Evaluation of Altetnatives Not Selected.................... 39
T.
Proposed Acttnn......~...............'....................... 4l
Attachme1'ts:
- Raspensivenes. Summary
EnforC~Dc Status .
(Enforcement Confidential-tllaY be removed from public copies)
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- ~.~.. ...
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- - -... - --- _. -
~ - ,
~ c--
-:...
~ i"
i-
S~mmarv of Remedial Alternative Selection
.
Leetown Pe~ticide Sit~
A.
Site Location and Description
The L~etown Site is located in extreme northeastern West Virginia
approximately 8 ~ile~ south of Martinsb~rg, WQst Virginia.
The "si te" is actually composed of a number of areas of concern
relative to surface disposal of pesticides, a~ric~ltural use of pesticidp.s,
and landfilling. The study area has ~een ~erfned as the Bell Spring Run
and Blue and Gray Spri~~ Run watersheds from the areas of contamination
to the points of interest (i.e. ?oten:ia~ receptors), as shown in Figure t.
Land use in the study area is predominantly agricultural, dedicated
to pasture or forage/rowcrop production for dairy cattle operations.
This is in contrast to orr:hards, which were the prevalent land use in the
area in the past. Habitat suitability for terrestrial wildlife and
avi:auna is restricted by the agricultural development. The upper reaches
- of the Bell Spring Run watershed are predominantly dedicated to pasture
and rowcrop production. This portion of the study area also encompasses
the potential sources ot environmental contamination. Fencerows within
the developed agricultural 'areas, as well as areas not presently being
~anaged for pa~ture or crop produ~tion, frequently support dense growths
of brambles that provide food, nesting, and escape cover for small mammals.
, Small woodlcts (less than 50 acres) may be found in the lower reaches
of the watershed. In this vicini ty they are accompanied by the most
significant wetlands found ir. the study area. The latter are found on
the lower reaches of Bell Spring Run, near National Fisheries Center
(~FC) Reservoir A, and in the vicinity of Gray Spring Run. These wetlands
have oeen mapped by the West Virginia Department of Satural Resources,
Wlldl1 fe Resources Division (WDHR WaD), as Marsh No. 75, or the Ho.'ewell
~rsh, although they do not cOnl1Dunicate. The northern component o~ the
~arsh occupies an area of 17 to 20 acres on Bell Spring Run, while the
southern component is a- =ore nondescript area within the immediate recharge
zone of Gray Spring.
The occurence of potential sources of contamination in the Leetown
area :IIay be associated with une or more of three distinct activities:
1) agricultural use of pesticides; 2) pe~ticide di~posal; and 3) land-
filling activtties. A total of ei~ht specific areas of waste disposal
or accumulation were ar.tually identified during initial RI :ltudy, as
shown in Figure 2.
Of these eight areas, two were the result of alleged disposal of
pesticide-contaminated debris from a fire that occurred in 1975 at the
~iller Chemical Company in nearby Ranson, West Virginia. These included
the- former pesticide.pile area and the suspected pesticide landfarm area,
Areas 2, and 4, raspectively, on Ftgure 2.
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Reproduced from
Sev available copy.
X
X
X
• e
X"
X
f
APPROXIMATE BOUNDARY
OF smgy AREA
9ASC fcA* IS A PORTION OF TMC U.3.S.S. MtOOLCWAY, WV QUAOft*1*GUC (7.S MIMUTC SCIUCS, IWW. CCD
INTERVAL ZQ'.
LOCATION MAP
LEETOWN PESTICIDE SITE, LEETOWN. WV
SCALE' l" a!
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LEGEND
0 FOHMtB
SOUHCt
_ CUuNIt
(i) SuSnXUO rtjiiLkjt i
(5) fONMlH JtfftHSU. OHCnAHU HtSllClOt »««*. SlilL
(b) fOMMlH CMMM OHCHAHU
0 fOHMLH CMMM UNCllAMU HACRINO :
(«) WVOUI MAmllNAMCt CAHAU.
INC IMU
. wit i»
P6FJN1TIQN Of POTENTIAL CONTAMINANT SOURCES
LEETOWN PESTICIDE SlTE^ LEETOWN. WV
K«t
Figur* 2
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.~ -- --..
. -. ..
- . - -.
"<: -
,.-:
.
-2-
Four of che concaminanc sources are associated ~ith fo~~er use of
the land for orchard production. The JeHerson Orchard for:':lerly occupi
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f
-«.^--/;-/v I
* '{' ,' '* ced from
copy.
Fiflur* 3
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.-"'('-" ._-"-
-)-
~ith the e~ception of ~esidential pa~cels along roadways, ~ost of ch~
land tn the interio~ of the wd~ershed is presently held by the U.S. Fish
.s. WI~dl1ie Se~v~.:e (USF&WS), rep~eser.ted locally by the Leetown ~ational
Fisheries C..!nte~ (~FC), Julian and Luola Robinson, Jefferson County, '
Willa~d lloyd, ;.11111a:1l Edwards, and Lyle C. Tabb III. ~Iost of the land
is devot~d tQ pasture or to the production of ~rain and/or silage corn
and sm~ll grains in ~otation for dairy cattle ,feed.
Historically, ag~icultu~al use of pesticides refers primarily to the
use of DDT as a spray ap~lication to control ir.sect damage to fruit. !WO
orchards e~isted in the watershed at one ti~e. The largest of these was
the Jefferson Orcha~d, operated by ~r. John F. Ambrose or lands now
belonging to the USF&WS and the Robins)ns. ~r. Ambrose purchased plot 2&
(reference Figure 3) on December 1(), 1937. Accordin~ to local ae;counts,
the orthard was li~ited to this tract of ,land, on both sides of Jefferson
Road (Route 15/1). A pesticide mixing shed was located at the intersection
of Jeffers~n Road and Bell Spring Run on the eastern side of the roadway.
Present ~ema1r.s of this shed include the stone foundation (approximate
dimensions: 50 feet square) for the first floo~ and a 12-Eoot square
concrete pad on the souther~ end of the foundation. The northern exposure
of ~he foundation is keyed into the topography, while a wall consisting
of 10 courses of concrete blocks separates the foundation from the concrete
pad. So s~perstructure for the building persists. although steel pipes,
approximately 8 feet on-center, protrude slightly from the conc=ete wall
adj3cent t" the pad. This llIixing shed was apparently used to formulate
all or ~he pesticides used the the Jefferson Orchard.
In the late' '50's or early '60's the Jefferson Orchard was abondoned.'
A~ that time Mr. Amrose apparently pastured beef cattle on .the property
befor'! selling the portion of plot 26 to the west of Jefferson Road to
~r. A~thur D~dson, Sr., and plot 26.2 to John F. and Luola G. Robinson.
Both of these transactions took place on October 27, 1966. ~r. Dodson
operated the property as a dairy farm until is death, at which time the
operation of the farm was taken over by his nephew. Mr. Roy F.Dodson.
"Ir.Arthur Dodson's son. Arthur, Jr., presently resides on plot 26.7,
acquired in 1974.' ,
Plot 26 was purchased by Albert ~. and Felicidad C. Boholst on
December 20, 1977, from the Dodsons, who subsequently conveyed the'parcel
to t he Nature Conservancy on April 30,. 1980 and to the USF&WS on ~arch
6, 1984. ~. Roy Dodson continues to operate the dairy farm, leasing
the land from the USF&WS through the NFC.' ,
The second orchard in the watershed was the former Crimm Orchard,
purchased as plot 23 by George R. Crimm on January 29, 1951. A packing
shed was located on a hilltop 'in the central portion of this tract. The
timber structure still remains. and is used by ~r. Lyle C. Tabb III as a
storage building for hay and straw. "Ir. Tabb purchaud plot 23 rrum ~r.
Crimm on August 24, 1966.
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-4-
.
The Crimm Orchard Packing Shed was apparencly used for pesticide
formulation, as well as for preparation of che crop "or shi pment. Drums
containing liquid pesticide formul.Jtions, and bags of powdered materi-ils
such as guthion and d1nitro-ort~0-cresol were discovered by ~r. Tabb in
th~ eastern porticn of t~e structure in the summer of 1984. Mr. Tabb
notiiied EPA or his findin~.
In response to this notification, the U.S. !PA conducted an assessment
for removal action at this packing shed. After careful dnalysis and
considering reco~mendatiQns from the Centers EOl' Disease Control, the EPA
Jetermined that no immediate threat was presented by che contamination
and no removal action was warrant~~. Subsequently, chis area was added
co ttle "LeetownSite" for remedial consideration, since it was withi;1 the
boundaries of the study area.
Pesticide disposa13~eas are distinguished from areas of agricultural
application of pesticides ~ithin the watershed. Residue containing
pesticides was allegedl,; ~~=:,,"sed at the Former Pesticide Pile Area on
che Robinson property and at the Suspected Pesticide Landfarm, presently
located on property owned by Willard Lloyd. Both dls~osal activities
. allegedly took place someci~e prior to the spring of 19R1 and allegedly
may have involved pesticid~s and other debris from a 1975 fire at the
Miller Chemical Company in Ranson, West Virginia, approximately five
ciles southeast of thp. Bel, Spring Run watershEd.
. Local accounts of the disposal activities agree only in that Mr.
Arthur Dodson, Sr., was the prfn~ipal. At the time of the alleged
incident, Mr. Dodson was operated a dairy farTD in tt-e area, as noted
above. One account indicates that spreadable debris from the Miller
Chemical fire were landfarmed in. 1975 on a tract of approximately 100
acres (Hughart 1981). This tract was being leased at the time of the
disposal by Mr. Dodson froll Mr. Jeffrey Sagel, and is now owned by Mr.
Willard Lloyd. ~is account further indicates that debris which could
not be spread ~ere dumped on the Rob~ nson property., also bei ng leased
at the time by Mr. Dodson.
A second account suggests that th~ pesticide pile on the Robinson
property, while ~rigi~ating from the ~iller Chemical facility, consisted
only of lime slag and fine material cleaned from the facility during
nor~al housekeeping operations, and had little to do with the fire
(~ort~eimer, 1982). Th~ second account does not refer to any landfarming
of pesticides on the Lloyd property.
Irrespective of the means by which the pesticide pile was placed on
. the Robinson property, initial concern was .raised by representatives of
the Lee town ~FC, based on anal yses of the pUe done in 1981. These
analyses showed elevated levels of pesticides. During a subsequent site
t~spect1on by the West Virginia Department of Satur.al Resources (WVDNR)
on August 2~, 1981, it was deteraune~ that an area ~C about 1,000 3quare
feet had been,covered to a dspth of about 4 feet with & crystalline
material. Samples of the material and its i!llmediate surroundings taken
' .
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I .
by thl! WVDNR on October 27. 1981. showed elevatedlevels of
pesticides (186.000 pares per billion (ppb» as well as DOT
and DOE (63.300 ppb). .
11pha-BHC
( 37 .000 ppb)
In 1982 the ~iller Chemical Company agreed to cooperaee in removt~g
ehe pile. bue coneinued to maintain that r:he pile did r.or: coneain peseL:ides
from the fice ae ies faciliey. Ber:ween April and June 1983 ehe ~iller
Chemical Company removed aboue 160 cubic yards of wasee and soil maeerial
froIDehe pile area.
Two ongoing landfills represenr: the only significant. known activiey
of this eype wir:h the watershed. Historically. ehe first of ehese landfills
occupies land presenely owned by r:he West Virginia Deparemene of. Highways
(:~'DOH). and is located i~mediately north of their maintenance faciliey
ae the inr:ersection of. Routes 6 (Darke Lane). 15. and 1SIl. The solid
wane landfill. as well as an associated Nad kill disposal area and
limeseone quarry...re operaeeJ solely for the use of the WVDOK, and are.
presenely secu(Od from unaothorized vehicle a~cess by a chain link fence.
Accordin~ Co a local resident. however, t~is landfill operated prior co
development of the Jefferson Cou~ty Landfill. discussed below, as a .
refuse disposal area for local residents. In particular,. aerosol cannister~
of DOT produced by the Dix1e-NarcoCompanyi n Charles Town were disposed
of in the lal\dfill. These cannistus are known locally as DDT bom~s, ~nd
were used for topical appli~ation of DDT tocaccle to control flies.
Typical waste handling practices at the landfill a:: the time of ~D! bomb
disposal included burnin~ the refuse. A number of the cannisters allegedly
exploded during this process.
The Jefferson County landf1l119 located
WVDO~ maintenance garage, across Route.lS/I.
waste disposal facility has been active since
. County Commission assuming' responsibility for
immediately east of the
This municipal and industrial
1967, with the Jefferson.
its operation in 1972.
In 1981 the State Depart~ent of Health gave permission for the 3-M
plant in ~iddleway, West Virginia, to plac30ne truckload (approximately
5 cubi c yar.ds) of sludge in the landfill daily. However, this approval
was rescinded when appro..c1mately 600 cubic yards of the sludge was
depositad i" thp. landfill during the first two days of the project.
The Jefferson County Landfill has been l...ted in West Virginia's
Open Dump Inventory as a potential candidate for further investigation
relative.to Hsting .In the National Priorities list. The first step in
chis process, development of a Preliminary Assessment (PA), was undertaken
b~ the WVDNR, DiVision of Water Resources, on April 4, 1984. It is
anticipated that this process will continue, with ultimate ranking of the
JefEerson County Landfill using the Hazard Ranking Syste~ (HRS), and
evaluation of the possibility of inclusion of the site on the NPL.
Since chis was ~t!O''ft to be :he case. the actual investig~ti()n of the
landfill focused on the potential offsite migration of contaminants
throught the groundwater and surface water systems, ~ather than on
characterhaticnof the Landfill leseLf.. 'The pr1.mary purpose of this was
to d~ter~ine the overall quality of the drinking water source (aquifer).
1n the l.ae"town Area, and. 1f any contamin3t1on was found, to pinpoint
~ources.of that c~ntaminatio~ to mitigate the problem.
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Similarly. the WVDOH laridfill is part of an active facility and the
responsibility for maintenance !ndsafe 0~er3ti~n of "t~e landfill rests
wich the WVDNR. The RI attempted to define the potencial for contaminant
~igration from this landfill via direct contac~ with landfill soils. but
did not attempt to fully characterize the contents of the landfill.
C.
Rem~dial Investigation Scope
A total of ~43 environmental samples ~ere coll~cted in vartous ~atrix
at different locations during the Leetown Pesticide Superfund Project.
Table l provides a breakdown of the numh~r of samples and matrix for each
sampling area.
"D.
Hydrolo~ic Investigation (SurfacE Waters)
D-l.
Physic,l Data:
Local streams and their topographic drainage divid~~ relevant to the
Leetown Pesticide Si~e are shown in Figure 4. The surface water draina~e
system Is pred~mJnantly of the trellis type in which streams of si~ilar
order run pari\llel ':0 each other and lie perpendicular to their tributaries
and receiving streams. In the Leetown area however, much drainage"
apparently occurs through solution channels In the underlying li~estone
"bedrock. this is evidenced by the fact that most "flr~t order streams
'ori~inate at free-flowing Jp:ings situated in highly-folded and faul~ed
ca~~cnate rocks. Large portions of individual copographic drainage basins
above these springs are without defined stream channels. indicating the
"presence of solution cavities which collect and transmit infiltrated
-rainfall. "
" Local streams most likely to receive contaminants directly fr~~
sources In the study area include Link Spring Run, 8ell Spring Run, and
Gray Spring Run. Both L1nk and Bell Spring Runs originate at springs
located ap~~oximately 3/4 of a "~ile east of the Leetown N~tional Fisheries
Center (~FC). aoth strums flow we1tward past, and in some cases directly
adjacent to, contaminated area~. Link Spring Run fQrms a confluenc~ with
8ell Spring about 1/2 mile east of theNFC, just south of the former
Criallll Orchard. " Be11 Spring Run continues westward through a manmade
ialpoundment of the NFC (Reservoir A) past Leetown Road.and i"'to Hopewell"
Run ~ear the H3ndicapped Fishing"Area.
Gray S~ri~g Run actually originates at two springs (Blue and Gray)
located on NiC propertty approximately 2000 feet southeast of the
a~~inistration building. Gray Spring aun flows through a less developed
area of the NFC, past homes on 1.eetown Road and Into Hopewell Run 1000
fee t south of Bell Sprt ng Run. 8ell Spri ng Run receives surface water
rU:1off frolll tb~ contaminated areas, as well as runoff frols the Jeffp.rson
and Cl'iazm Orchards. SIJrf1~!! water -3nd sediment. were obtained from Sell
,
Spring to assess the impacts of the contaminateC1" aro!a!l ~1nchdi..g t.n...
orchards} on this 9urface w~ter body and its aquatic life.
-------
Table I
SC'Jpe of. Sampling During the Laetown .?estici.de Remedial Investi~ation
Samp1in~ Location
3ackgrc.und
fSon-Pest1c(d~ Areas)
Crimm Orchard
(Tabb Property)
Crimm Orchard Pac~ing She~
(Tc.bb Barn)
Jeffers~n Orchard
'.( U. S. F'N Property)
Jefferson Orchard
(RobInson Property)
Jefferson Orchard Pest1c~ Ie
~ixing Area (Robinson P~operty)
?estic1de Pile Area
(Robinson Property)
WV-DOH Garage Landfill
Suspected Pes:icide landfarm
(Lloyd Property)
Jefferson Co. Landfill
~ational Fisheries Centerl
Hopewell Run Watershed
Residential Wells
Sprir.gs
L1 nk Spr1 ng and.
hell Spring Runs
Matrix.
'3urfs4:t SoUs
Ground Water
Surface Water
Sediment
Fish
. Tctal
~atrix
Surf.aceSoi 1
Surface Soil
Surface Soil
Surface S011
Ground Water
Surface 501 i
Surface Sol1
Ground Water
Surface Soil
Ground Water
Surface S011
Grouni Water
Ground Water
Surface Water
Sedi~ent
Fish
Ground Water
Ground Water
Surface Water
Sediment
Fish.
Totals
, .
II of Samples
271
52
n
6S
23
443
~umber ~f Samples
35
4
to
10
3 "-
6
16
40
4
7
2
146
6
13
13
49
IS
13
8
19
16
8
-------
BASE WUP 13 A
CT TH£ US.fl.3. MIOOL£WAY, WV
-------
-7.-
D-'
-.
Chemical Data:
Samplictg locations for the Bell Spring Run watershed
are indicated in Figure S.
The analyt~cal results indicate that surfJce water samples from Bell
Spri~~ Run do not contain organic chemicals found in soil samples from
the .contaminated areas. !he only Hazardous Substance List (HSL) ,'r~anic
.chemical detected in surface water samples were di-n-butyl phthalate,.
pyrene. and!cenaphthene. Th.ese analytes were identi fi.ed sporadically
(less than 2 of 14 samples) and at low concentrations. pyrene (4 ug/l)
and acenaphthene (6 ug/l) were detected in samples obtained at downstream
loctions, either near the wetland area or immediately upelevation of It.
Thp.se substances :!lay be prp.sent because of isolated, small spHls in the
area. These analytes were identified in only one Qf two duplicate samples
frail! the wetland area~ Polynuclear aromatics (PAHs) were not identified
Ii the three prim~ry source areas and were not detected at appreciable
~oncentrations in any of the other areas investigated. The presence of
these substances is not considered indicativ~ of a PAH problem at the
Leetown Pesticide Site. Di-n-butyl phthalate was detected in one sample
.at a concentration of 4 ug/t. This, and other phthalate esters are.
common la~oratory contaminants. The sporadic occurrence of this substance
and the low concentrati~n detected do not indicate that this substance.
ot other phthalate esters are present in Bell Spring Run at .levels of
concern.
I .
The resules for inorganic ~nalytes fur surface water samples indicate
that arsenic, copper, chromlum,lead. cercury, and zinc are present 1n
Bell Spring Run. All but the arsenic concentration exceed the Ambienc
Water Quality Criteria for the protection of aquMtic life. Since inorgani~
conc~ntrations 1n surface water samples do not vary significantly from
the upstream to the downstream locations, these concentrations may be
. representative of natural oac~gr~und levels. A summary assessment of the
impa~'s of these substances on aquatic organisms is provided in t~is
<:1ocuments Health an~ Environmental Impacts Section, (Sect~on ie).
E.
Hydrolo~ic Investigation (Sediments)
Table 2 ~resents HSLpesci~ide and inorganic an~lytical results for
sediment samples collected from Bell Spring Run and Link Spring Run during
the RI. Various HSL organic chemicals were d~tected 1n sediment samples
oh.:ained from Bell Spring Run.. Phenol and 4-methylphenol wen detecte~
ir\ three of twelve sediment samples collected from the stream and the'
downstream wetland area. Benzoic acid was detected in two sediment
3amples obtained frc~.Bell Spring Run.
Of the eight areas sr.udles during the Remedlal,Investigation. on11
the Jefferson County Landf111 constitutes a potential so~rr.e of these
chemc:.1a l.s. Phenol and benzo~ c acid were detected 1n landfill monltori ng
well. samples at maximum ~oncentrati~ns of 9 ug/l and II ug/t respectively,
The low concentrations of these analytesdetected in monit~ring well
samp),es "nd various aspects of the sedimenc results rilemseive. tend to
rule out the landfill as the sour~e of these chemicals.
.. '
-------
u
I INK iPMI«C. HUN
!. f t ' i .
<\ 7
ilKOOl^'1 LINK '.IK,!,..
•;; ,•' A -
'/i/L1---
.:---:/.•;..
v/1
'b
toc»iio«
• fISH SAMPlC UKAHOW
SURFACE WATER. SEDIMENT a FISH SAMPLING LOCATIONS
BELL/LINK SPRING WATERSHEDS
LEETOWN PESTICIDE SITE. LEETOWN. WV
Reproduced from
be it avB*t*t>l* copy
Flgur* S
mull
-------
1-"
Table 2
Sediment Analytical Results
Liuk and Bell Sprin~ Runs
and ~arsh Area at Leetown
Location Cl'1emi ~. -1 Concentr3cion Ranp'e DeCectlon Frequenc:"
Be 11 Spr1n't Run 4,I.'-DOT 10-12 u~/kg va
4,4'-DOO 8.8-37 ug/""~ 2/8
4,4-00E 4.0-140 Ltg/kg .7/8
.\rsenic ND 0/8
r....ad 1;, 1- 3 5 m~ /kg 8/8
L1 nk S prt ng Pun 4' 4'-00T . ~O 0/4
,
4'4'-DDD 4.0 ug/kg 1/4
4,4 -ODE 4.1-8.3 ug/kg 2/4
Arsenic 12 mg/kg 1/4
tt!ad 7-28 mg/kg 4/4
~arsh Area 4'4 -DDT ND 0/4
4'4 -OOD 24 ug/~g 1/4
4'4 -ODE 100 ug/kg 1/4
Arsenic S1) 0/4
Lead .11-27 mg/kg 4/4
-------
-8-
Alchough phe~oland be~%oic acid were dete~ted in one sedi~ent sam,le
at relatively high concentrati~n~ (830 and 1,600 ug/kg, respectively),
they were not detected In a duplicate sampl~ ob.ained ac the same location.
This discrepan,cy indicates that eic:her the contaminativn with these
ch~micals is n~t ~xc~nslve (I.e., it is very localized), or chat these
substances may have been inadvertently introduced to the samples during
~xtraction and pr~paratlon. The fact that these chemicals were identified
only in the one sample and at a substancial distance downs cream in thp.
wecland are~, is considered further evidence of only isolated contamination
with these substances.
The appearance of these chemicals in sediment sa~pl~s is considered
highly unusual, especially in tight of their absence in surface water
samrl~s obtained at the same locations. .
Pesticide compounds, Including 4,4'-00T and metabolites, were 1dentified
1n ~umerous sediment samples obtained from Bell Spring Run. The
presence of pesticides. io sedl~ents ls probably directly attributable to
surface water convection of contaminated soil from both the primary
contamination zones a~d the. former apple orchards. Sediments obtained.
adjacent to the Robinson property pesticide mixing area contain~c the
highest levels of ~,4'-OCT and metabolites. This is considerad evidence
of the impact of the r~sid~al contamination remaining in this area.
Another area with relativel~ high concentrat1ons of pesticides (124 ug/kg
'total OCT and metabolites) 1s the. wetland area at the western end of Bell
Spring Run. This Is an area where suspended sediments ace expected to
settle; thus the presence of pesticides in this area Is not unusual.
The results for lnorganic analytes presented In Table 2 {nciicate that
inor~anic ~onc~ritration8 are similar in sediment samples coliected along
che length of Bell Spring Run.
Hydrogeo:o~ic Investigation (Geology)
The inieial phase of the subsurface investigation concentrated on
the suspcct~d source ~reas of c~ntamination as opposed to a compr~h~nsive
hydro~eologic investigac10n and monitoring network. A survey of the.
ncarby domestic water wells through discussions with local residents.
. revealed thac the majori ty of wells are deeper than 150 feet. In some
cases wells were drl1le(. .1:0 this depth to ..,crease :-rield for troiler
~ourts and farms, and 1n other cases permeability was low 1n the upper.
part of ~~e aquifer and dril'lng was advanced to 1nrercept deeper, wate~-
bearin~ fractures. Additionally, some of these de~oer ~'ells ne cased
off throu~h the upper part of the water table ~ue to turbidity caused by
clay-filled cavities.
F.
Since many of the domestic wells 9ampled are &t least 150 feet deep
and sho~cd no evidence of con:aminatio~ 1n previous samplln~done b? the
Jeffe~son County Health Oeparement (JC~J) and 1n the Rt, the first phase
df the dril1i.n~ prO!f~am was designed to monitor S?;roundwacer qual1.:y ..n
the ~hallow part 0f the aquifer close to the suspected source areas where
dilution and d1!.persion w0111~ be \:n1nimizec. .
......
-------
SUBSURFACE INVESTIGATION BASE MAP
LEE TOWN PESTICIDE SITE. LEE TOWN. WV
Flgur* 6
-------
-9-
During the first ?hase, 6 exploration borings were drill~d and l~ ,
:1!onitoring wells were installed. Four wells wereinst311ed at the former
pesticide pile area, 6 wells and ~ ~xploration borings around the periphery
of the Jefferson County Landfill aud 4 wells and 2 exploration borings on
or within close prioximity, to the suspected pesticide landfarm area. In
dddi tion 13 residential wells in the Leeto..,n 'Area were sampled and analyzed
for HSl Orga~ics and Inor~anics. Figure ~ r~ a well and ~xploratory
bori~g location map for the work undertaKen in the r~medial ihvestigation.
To define flo~directions and aquifer parameters, per~eability testing
and dye tracer testing were coriducte~ aft~r :1!onit~rin~ well installation.
Borehole logglng was conducted on 5 of the 6 exploration boreholes
(E-l. E-2, E-J, E-S and E-6) and on monitorin~ wells :-!W-1B, :-!W-J, ~-S8,
~"-7, ~{W:-~ and :'~W-ll. Extremely us~ful info~ation was obtained on water-
~earing fracture systems, solutions channeling, and degree and extent of
fraceu~ing in bedrock.
logs utilized in the investigation were spontaneous potential,
temperature, fluid tonductivity, resistivity, sonic, gamma, densiey,
caliper and neutron.
Three different methods of permeability testing were used to determine
aquifer parameters: par.ker testing, constant head infiltration, and ~lug
t~sting.
, F-l.
Physical Data:
The leetown Site is underlain by a sequence of steeply-dipping,
faulced carbonate rock~, and varying thicknesses of ' residual soils. The
site area is ch~racterized by a very high degree of lateral variability
in occurrence of geologic formations due to the extensive folding. In
additton to this, the presence of a karst terrain with solutioning
activity in the carbonate bedrock contributes to complicate the hydrogeo-
logic setting.
A generalized strategic column is illustrated in Figure 7. A geologic
map of the leetown area 1~ found in Figure 8 and a, geologic cross section
within the ea~ternmost conococheague fot"mation is presented in F1~ure 9.
In addition, a generalized geologic cross-section of the former pesticide
pile area is found In Figure 10. '
G.
nydro~eolog1c Invest11l;ation (t;round Water)
G~L .
J
Physical Data:
. ,
The water cable aquifer within the'area of investigation 15'01 very
complex hydrogeologic s,stem with many factors controlling ground water
f~ow. The folded and faulted Ordovician to Cambt"ian ~arbonate deposits
~hich ~ake up the aquifer hav~ virtually no primary porosity. Secondary
poro~ity, consisting of fractures, bedding planes, joints and cleavage
?lanp.~ are the pathways for 6round water flowing through bedrock. Many
~f these secondary openings have been widened by solution activity wichin
the carbonate deposits. Conversely, calcite veins and fillings have
-------
XC.1.N4.-NO '-I
: SLACK, ctrAs.CNA,.
£5-CN£ 3£:S AT 5CMC
BEACHES. accc-iccc
'-,Me3""ON£. OAP.K-GP.AY TO 8LU£ - BLACK, APMANlTlC AND
CCNGwCMgRtTiC,SOMETIMES ASGIULACEOuS, "MIN-3EOOEO.
?£W .METABENTONlTE LAYE3S. - SCO FT "ntCX
_.MESTQN£, OOVE-GHAY, APMANlTtC.veHY PURE.-iSOFT "HiCX.
wCUOMlTE, LlSHT-GPAY. FINELY CHYSTAUJNE CiLClTC
«£:NS COMMON. ~43S FT. THICK.
., MESTCNE 1NQ DOUOMlTg, LIGHT-OSAT, iPMANlTIC AND
CCNGLCMWlTJC.CCCASSiONAur CHERfY -2750 FT TH.CK.
uMESTONE AND OOLCMITE.30U3MITE
UPWARD.
MlOOLE LlMESTONe, APHANITIC.
LI MESTCNE,
SOME OOLOMlTt.
AMD CONOLOMCMITIC,
LIMESTONE, EDGEWISE CONGLOMERATE WITH SOME
APMANIT1C ZONES.CUTANO-^LL STRUCTURES THROUGHOUT,
CHERT STRINGERS RARE- /4.OAU STRUCTU^.S IN UPPER
ZONE. ~8OO FT. THICK.
LIMESTONE.LIGHT- CQ DARK-GRAY, EDGEWISE CONGLO -
MCRITIC,ARGILLACEOUS, WITH UNOULAR SILTY LAMINAE.
iQO-ZOOFT. THlCX
LIMESTONE, DARK -SLUE-GRAY, APHANITIC. SILICEOUS
AND ARGILLACEOUS LAMINAE COMMON. SOME EDGEWISE
CONGLOMERATES, ESPECIALLY NEAR BASE. OCCASIONAL
COARSE SANO 8EDS.ANO SANOY ZONE •'EAR TOP.
OOLITIC, OOLOMITIC,AND ALGAL SEOS COMMON.
^I89O FT. THICK.
t*OU*CCl>
OOLOMITE. DARK-SLUE-GRAY, FREQUENTLY SANOY, SOME
OIARTZ SANDSTONE. CHERT NOOULES AND ALGAL
STRUCTURES A8UNOANT. -v22fl FT. THICK.
,IT. AC.,>
GENERALIZED STRATIGRAPHiC COLUMN
LEETOWN PESTICIDE SITE. LEETQWN. WV
F1««r« 7
-------
NATIONAL
• •SHESIES
C" 3C-CWAYS -iV£ 3££';
C9S
LEGEND
........ BCAOWAY
-,| — AXIS Of SY*CUN€
— { — AXIS or AMno.iN6
........ --• CONTACT
- — FAULT
>•«» STWKX ANO DIP
STRIKE ANO DIP
OVERTURNED
FORMATION
Oe! | CMAMOCRSaURQ LIMESTONE
NEW MAflKET UMESTONE
PMESium STATION OOLOMfT
Orr I ROCXOALC RUN FORMATION
%c7 CONOCOCXAOUe FORMATION
aoiEKC.1911
STONeHCNQK UMCSTONC
GgQLQGIC MAP OF THE LEETOWN AREA
LEETOWN PESTICIDE SITE. LEETOWN. WV
SCALED r
F1«nr« ft
-------
BELL SfHING]
-25O
LEGEND
X
N
CONTACT
ATTITUDE OF BEDDING
INFERRED GEOLOGIC STRUCTURE
TO EROSION
INFERRED EXTENSION OF FAULT
PRIOR TO EROSION
FAULT (ARROWS SHOW DISPLACEMENT)
ROCHDALE RUN FORMATION
CONOCOCHEAGUE FORMATION
STONEHtNGE LIMESTONE
STOUFFEHSTOWN MEMflEft OF
STONEHENGE LIMESTONE
FOR LOCATION Of CROSS SECTION SEE FIGURE
Flflur* 0
GEOLOGIC CROSS SECTION
LEETOWN PESTICIDE SITE. LEETOWN. \NV
.SCALE-l"= 1000"HORIZ., l"= CO' VERT:(VERT. EXAGGERATIONO«)
-------
WtST
t A ,1
tuRMUl
SIlClUl I'll t
>4U fMt." H t I
HESlDUAL CLAY
SILTY CLAY
STOUFFERSTOW
pill HI • I "• HIO jun
STONE HENCE
bari*i lo«liant iv infcrre* IIOB M«r6y Wtrjck eulcioyv luna
lo •tt«>al«< IIM prtitiKe »' < citlo* Airier *l IM pvitKIM pll« It inlliltt bf prOJtCIIHf btd'Kk ««pl« <1 MM j I* < «?
(
IH)«I/ UUI M (111
GENERALIZED GEOLOGIC CROSS SECTION-PESTICIDE PILE AREA
IEETOWN PESTICIDE SITE. LEcTOWN.WV
tlOO
•Itlll
fi>
Fiflur* 1O
-------
-10-
sealdd some of these openin~s. Tneaquifer, for the most part, occurs
under wat~r ~able conditions; however, local departures from. the water
tahle conditions are prevalent at sOC'le of the well locations.
Figure 11 is a water table contour map of the area of 1nve~t1gation
, under typical water table conditions stowing an overall west, northwest
ground water flow direction. This map compares favorably with a water
table contour map of the overall Leetown area prepared by Environmental
Data .in 1981 (Jones and Dieke, 1981). Figure 12 is a cross-section
parallel to the water table contours. .
Although the contour ~ap is indicative of the overall ground water
flow direction, it masks the localized control that beddin( ?lanes,
Jolnts, fractures, and thick residual clay deposits exert on ground water
flo~ 1n this ~arst environment. '.
The strike of the beds near the potential contaminant source areas
19 approximately N20oE. In this area, bedrock is steeply dipping, creating
a potential groundwater flow component along both beddin~ planes and the
stri~e of bedrock ~utcrops. This would cause groundwater flow in an
approxi~ate north-northeast and/or south-south~est direction which is
approximately parallel to the wacer caole con~ours.
Borehole geophysical logging of the explor&tion borings and alonitoring
wells illustrates ,the secon~ary porosity characteristic of this carbonate
aquifer.' Water-bearing fractures and sotution weathered zones are readily
identifiable on the'logs of borings with moderate to good permeability.
Bori~gswith low permeability were difficult to cnrrelate hydrologically,
and ~enerally did not show conclusive results from the geophysical logs.
Recharge to the aquifer is the result of pre~ipitation and infiltration.
Ruponse of the aquifer to precipitation events is variable in rate and
~'C!gnitude and is dependent on the interconnection of the ground surface
to the aquiter and the localized storage capacity of the aquifer.
Dye~tracer testine of the aquifer confirms the localized. mul~:-
directional flow ~thin the system. Significant precipitation events
were found to increue the flow velocity drastically ~thin the groundwater
sy~teal and flush groundwater 'from temporary storage. .
Ground water flow directi~n and velocity a~e highly controlled by
seasonal influences, only a portion of which were actually reflected in
the dye-tracer study performed as a part of the Rt. Based on the
observation of dyes in Gray Spring, velocity of groundwatorflow appears
. . ~
to be in excess of 100 feet per day (ft/day). This flow velocity apparently
resulted from a sudden inflow of water to the system as a resulc of
dramatic incroases in infiltration. Under low water table conditions,
however t groundwater flow rates are not dri ven by in flow. and appear to
be extre~ely low.
The scoragecapacity of the aquifer appears rather large, based on
the conc.entraCions of tracers remaining in the injection wells after 5.
~onths~ ..
-------
i V > / ' ' • ^^
.. -, >^r-. •-- ' •';
11 41
Mil* Kttl CO«IOu*IM Kill
I I- .*(i 1 if t ) » ItM CIMU
J*Bil CONTOUR MAP 3/ 6/65
LEETOWN PESTICIDE SITE.LEETOWN.W
nrproc*uc«ct from
best avwiabl* copy
Flgur* 11
if «U •."III
-------
MM 9
• •Mkt 1.
»»*»»
L
MW 7
IT;:,:;.
400
IMW f |
CONOCOCHEACUC
FORMATION
GEOLOGIC CROSS SECTION A-A'
LEETOWN PESTICIDE SITE. LLETOWN. WV
=X»' HONUONIM., f'Vt V€HIM.»i
Flgur* 12
-------
- - - -- -_.
-11-
G-2.
Chemical Data:
Sampling of the monitoring wells installed durin~ the Phase 1 ~el1s
revealed no evidence of pesticide conta~ination. w~ile it is likely that
the net~ork of t4 ~onitoring wells over an area as large as the sitc may
~ot ~e adequate to monitor the karst aqui~er, the very low water solubi~lty
of pesticides and th~ir high tendency to adsoro to sediment make groundwater
~ontaminatio~ unlikely. "
An example of the immobility of the pesticides occurs at the former
pesticide pile area where high concentrations of contamination In this
area appear confined to the up~er ~ inches of clay soil in the pile area
anJ adjacellt surface drai.lage. The aquifer in this area occurs under /
unconfined laminar flow conditions with a depth to the water table of
on11 15 feet. Infiltration to the aquifer after storm events was found"
to be rapid in this area. Yet monitoring wells located 200 feet downgradient
from the center of "the pile area show no evidence of contamination.
Organic and inorganic results for gr.ound wat~r samples obtained from
monitoring wells in the vicinity of the for~er pesticide pile area indicate
that ground water in chis vicinity is not contaminated by ne1ther pestic~des
nor the inorganic COt ,:aminants of conce-rn (arsenic, lead, and mercury).
The assessment cf grounG water contamination potential for pesticides
revealed that contamination in this area does not pose a threat to ground-
war:r. Modeling indicates -=hat approximately 200 years will transpire
be~~re the 4,4'-DDT will infiltrate throught the vadose zone to the
water table. The predicted worst case, long-term =oncentration. is
approximately 4 x 10-2 ug/l. Additional groundwater investigation in this
area because of concern over pesticide contamination appears unwarranted.
~o organic oc p~sticide contamination was detected in monitoring
wells lIear the WVDOH garage. In addition, lead and other inorganic
analytes were not detected (above drinking water standards) in the
groun~water ~amples obtained from the monitoring we:l~ near the garage.
Table) summarizes the organic and inorganic chemicals detected in
groundwater samples from monitoring wells near the Jefferson County
Landfill. Thf table reveals that or.ty low levels of readily leachable
volatile and acid extractable organic contaminants were detected in these
groundwater samples. l,l-dichloroethane, te:rachloroethene, trtchloroethene,
1,2-dichloroethene, phenol, and Z-butanone (methyl ethyl k~tone) were
dete~ted infrequently and at low concentrations (t.e., less than three
samples contained ea~h of the organic chemicals, and with the exception
of methyl ethyl \cetone (38 ug/l), no organic subst3nCft was detected in
excess of 5 ug/l). These results, as w~ll as those for residential and
domestic wells sampled 1n the leetown area. indicate v~ry limited tmpact
on groundwater quality attributable to disposal of organic wastes tn the
county landfill. "
-------
I ! - -'-
T ,"~I. 3
HSL CHEMICALS DETECTeD IN GROUNDWATER SAMPLES
JEFFERSON. COUNTY LANDFilL MONITORING WELLS.
LEETOWN PEST1CIDE SITE
LEETOWN. WEST VIRGINIA
(Based on analytic results for samples collected bV
NUS Corporation. 1985)
Concentration Detection
CAS II Chemical 2!I'IQe (UQ/I) FreQuencv
Organics -
78-93-3 2-butanone 38 1/13
75-34-3 1.1-dichloroethane 3 - 5 2/13
127-~S-4 tetrachloroethene 2 (all) 3/13
79-01-6 trlchloroethene 1 - 3 2/~3
156-60-5 1.2 -diChlor09thene 2 1/13
108-95-2 pnenoi 6 - 9 3/13
65-85-0 benzoic acid 11 1/13
84-74-2 di-n-butVlphthalate 115 1/13
Inorganics
7429-90-5 aluminum 59 - 190 8/13
513-71-9 barium 57 - 245 13/13
100-44-7 beryllium 0.6 - 0.7 .2/13'
7440-4~-9 cadmium 6.4 1/13
7440-70-2 calcium 59.490 - 184.600 13/13
7440-41-3 chromium 4.3 - 15 4/13
7440-48-4 cobalt .r 11-14 2/13
7440-50-8 :opper 5.7 - '0 5/13
1309-37-' iron 13 .. 10.900 4/13
7439-92-1 lead 6.2 - 12 3/13
7439-95-4 magnesium 7.229 - 24.950 13/13
7439-S6"5 manganese 16 - U~50 12/'3
7440-02-0 nickel 24 - 29 2/13
7440-09-7 potassium 3. HO - 14.000 13 13
7440-22-4 :;:lver 8.2 - 8.3 2/13
7440-23-4 sodium 6.190 - 37,710 i3/13
7440-62-2 vanadium 11 - 11.1 21'3.
. 7440-66-6 zinc 6.8 - 39 7/13
Source: NUS CorpClration. Pittsburgh. Pennsvlvania, February 1988.
-------
-12-
lead was present in landfill groundwater samples at a maximum,
concentration of 12 uS/l. Additional low-level contamination-with such
trace elements as cadmium (6 ug/l) and chromiu~ (15 ug/l) was detected,
but only spor~dically. a~d results were not ~uplicated during Successive
sampling rounds. The sporadic occurrence of lead a!1d other inorg~nic
analytes in the groundwater samples, a~ well as their relatively low'
conce~::'''ti ons. indicate that suhstantial amounts of metals are ,not being'
.eleased fo~m the landfill at this time.. Substantial amounts of clay are
present in t~e overburden in the leetown area. The clay and the expected
high conce~t~atio~s of calciu~ carbonate in this karst area may substanti~lly
retard release and transport of metah via preCipitation of insoluble
~alts (carbonates) or through cation exchange.
H.
The Biotia Investigatio~
Potential receptors of contamination from the Leetown Site include
the local biota, principally aquatic life and waterfowl. No specific
s~rvey of naturally-occurring terrestrial vegetation was conducted, since
~his medium appears to be neither a potential receptor of contandnation,
nor a means of contaminant transport. . Over half of the water~hed consists
of pasture or is under cultivation. Clearing of land for agrtcultural
use, and ac~ive management of cleared areas for crop production represent
the mosr significant impacts to lerrestrial vegetative habitats within
the watershed.' ~ost of the land near the potential sources of contaminati~n
i~ in pasture or row crop production, providing little diverSity of
habitat for colonization by wildlife. Host of the diversity of cover
types in these areas in provided by fencerows occupied by woody shrubs
and ,brambles.
H-l.
t ..~tic Survey:
A primary objective of the aquatic survey at the Leetown Sit~ w~s to
~~aluat~ the potencial for ~dverse effects to fish and higher trophic
rev'~ls, ir.cluding man, as a result of accumulation of cont1minants via
th~ aquatic food chain. In addition, the general condition 0f the aquatic
community was investigated as an indication of the ovprall extent of
contaminant impact to the watershed.
The aquatic survey consisted of fish collection for tissue! analysis
to determine rotentfal uptake 0: pesticides through the aquatic food
chain, collection of benthic macroinvertebrate samples to serve as an
indicator ofche extent of contaminant impact, and subject.ive assessment
of the aquatic community. Subjective asseS3ment of the benthic sample
collections in the fl~ldindicated that further identlffcationand
cla3sificatlon of the samples would probably not yield diversity indices
sutf~ciently different from one another. The henthic samples were therefore
consigned to secure storage and were available i£ ne~d'!d to supplemenc .
the ongoing evaluation.
H-2.
Fish Survey:
A total of ei~ht sampling stations were selected, representative of
the B~l'l Spring Run, Hopewell Run, and Blue and Gray Spring Run water!lheds,
".
-------
-13-
and the National. Fisheries Center (~FC). An overall ecological assessment
of the aquatic community was conducted, and fisl:1 tissue samples were
obtained to be analyzed for both or~~nic and 1nor~anic constituent~ of
the HSL. Sampling pro~ed~res ~dopted for the survey included electrofishing,
seining, gil1netting, and use of minnow traps. .
H-).
Physical Data:
A total of 25 benthic macroinvertebrate samples were collected,
preser~ed in 10 percent formalin, ~nd placed io secure storage. As .
noted above,.a decision was made based. on field examin~tion of the henthos
to defer further evaluation of the benthic samples.
. A tot~l of 4,9t1 (:sh were collected during the aquatic investigation.
These fl'sh re("resented 7 families and 16 species. Totals of 23 and 20
~ample~ of adequate weight for laboratory analysis were prepared for
re3pective ana)ysis for organic and inorganic constituents on the HSt.
Based on a subjective evaluatio~ of the numbers of individuals a~d
species found in the collections from Bell Spring Run and from th~ drainage
from Blue ~nd Gray Springs, it appears that all trophic levels are
represented, and.chat the overall community structure is stable. No
significant evidence was found, for example, in the Bell Spting Run
collections made in the vicinity of the former 'pesticide mixing area
indicating adverse eff~cts on the fi£h populatio~.
. With r~spec~ to subjective examination of the benthic community,
there appears to be evidence of nutrient input into tink and Bell Spring
Run from pastures and crop areas. In particular, thi9 was noted in the
vicinity of Bell Spring Run and Route 15/1, in an area that was at one
r.ime a pig sty. It did not appear, based on the available data, that
significant additional information would be pbtained by a more thorough
evaluation of the 25 benthic samples current~y pres~rv~d and in secure
storagL. .
H-4.
Chl'mical Data:
liSt organic and i~or~anic analytical results for fish samples obtained
from Be!l Sp~ing Run are presented in Table 4. Since fish are frep. to
~ove along the entire course of Bell Spring Run, specific samples pr~vide
no \ndication of contaminaticn in specific locations. Because of their
hloconcentration factors, pesrlcides display a marked tendency ~o a~cumulate
in tissues of aquatic or~anism9. This phenomenon i9 verified by the
analytical results for fish tissues. ,Total concentrations of pesticide
compounds ranged as high as 1,800 ug/kg.. Pesticides were the only organic
analytes detected in fish tissu~s, reflective of their bioaccumulative
tendencies and their p~rvasiveness in the_surrounding watershed.
he pr~dominant inor~anic substances detected i~ the various source
areas (i.e., ~rsenic, m~rcury, and l~dd) were virtually undete~ted in
fish tlssue'H Other analytes detected 1n surface water s,1mplc!s a!>ove the.
Am~lant~Watar Quality Criteria for protection of aquatic life (i.e..
chrom~um, copper, and ~inc) were found in fish tissues at ~elatively low
leveis.These trace elements occur naturally 1n the enviror.ment and are
-------
I
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TablQ 4
1151. ~t AHAaYIICA& N5UU:;
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44
-------
-1~-
generally necessary constitue~~s for normal body funccions. The maxi~um
concentrations of these chemicals were detect~d in the drgans of a bottom
feeding fish (carp). The conr.entrations det~cted in the edible portion
of this fish (I.e., the fillet) were much lower than these levels.
Ie, 'Soils Investigation
1-1.
Background Samples:
Historical evidence and chemical analytical results for surface soil
sample9 collected in the vicinity of the site indicate that agricultural
pestir.ides have been used in the past and are presently found in the soil
at ~ackgrounc lev~ls in areas other than where di~ect agricultural
application occurred (orchards and crop fields). Background concentrations
have'been established for comparative purposes to aid in id~ntifying
contaminated areas. Si~ce in~rganic HSL chem!cals occur naturally in the
ambient environment, resules for samples obtained In ~ackground areas
,provide a means of gauging the extent of contamination wieh trace elements.
Table 5 presents background'levels for HSL'organlc and Inorganic
substances detected in samples collected in areas where no evidence of
pesticide use exists. Concentration ranges for detected chemicals and
average values for each analyte' are also presented in Table 5. '
t "
4.,4'-DDT and 4,4'-DDE were sporadically detected In background
samples at relatively low levels. Toxaphene was detected in a background
compost te sampl!! at" a concentration l, 179 ug/kg. This Is considered an
anomalous occurence; actual background toxaphene c~ncenttation~ are
considered nearer or belo~ the lower end of the reportedconcentrat}on
range. The pt;'esenc~ of these pesticides 1!\ background samples are Indicative
of the use of these sub~tances for agricultucal purposes. their presence
In areas ,)ther tnan chose specified as agricultural areas such as orchards
or othe,:, crop fields Ls probably actributable :0 surfac.e wal:~r or atmospheric
transport. Alchough these substances were detected 10 some",
background samples, chelr occurence was. somswhat sporadic, as shown by
the frequency of occurence.' .
Five of t~ tventy-s1x background 9011s samples were subjected to
inorganic anAlysis. Table 5 indicaces that all but tWO analytes wete
d~t~cced In atl five of the samptes submitc!d for inorganic analysis. '
Arsenic and sodium were detected In only three of che samples. '
1-2.
Suspected Pesticide Landfarm (Lloyd Propercy):
Sumerous organic compounds were detected In samples from the suspected
pe~::ic1de landfam, i ncludl ng: tolu~ne, rhthalaces and polynuclear
aromatic hydrocarbon, (P~As).
P~st1c1:ies detected in samples from the suspected p~stlclde landfann
include alpha-BHC, beca-~HC, delta-BHC, gamma-BHC (lindane), aldrin,
n-i:ptachlor ep"x1de, dieldrin, 4,4'-DDT, 4,,':"-DDD, 4,4'-DDE, ,endosulfan
II. and toxaphene. O€ these analytes, only toxaphene WI'IS de'tected
frequently (i.e., lr 33 of 78 90il samples colle~ted In chfS area). '
Concentrations of toxaphene ranged .19 high as 1,100 ug/kg (ppb). Other
-------
.if -_L
Tab.. 5
HSL CHEMICALS DETECTED tN BACXGROUND SOIL SAMPLES
. LEETOWN PESTICIDE SITE
LEETOWN. WEST VIRGINIA
(Based on analytical results for.
samples collected by NUS Corporation. 1984/1985)
Surface SOil Samoles
Concentration ["Ietec~jon
C":'S" C~emlcaf RanOI! :reQuencv Averaoe ....:..!l.-
Or~anics (.- q/lcq)
50-29-3 4 .1'-(,)DT 5.0. 1.'26 0.2 '0
7.1-54-8 .1. .1'-ODE 4..1-36 6/26 4..1 9.1
roxapnene 62-1.179 5/26 110 290
InorqanlCS (mQ/\(Q)
7429-90-5 aluminum 18.480-15.000 5/5 11.000 3.000
7440-38-2 . arsenic 6,5-7.8 3/5 4.2 3.5
5'3-77-9 barium 52-74 5/5 65 8.2
100-44-7 beryllium 1,3-1,7 5/5 1.4 0.15
}440-70-2 calcium 1.310-2.730 5/5 2.100 560
7440-41-3. chromium 23-38 5/5 29 5.2
7440-48-4 cObalt 9.S- 1 9 5/5 14 3.5
7.440-50-8 copper. 9.5-16 5/5 12 2.4
1309-37-1 iron . 11,900-27.800 5/5 21,000 3.700
7439-92-1 lead 17-30 5/5 22 4.5
7439-95-4 magnesium 914-3.860 5/5 2.100 1,100
7433-ge-5 manganese 5 1 0- 1.1 10 5/5 840 250
7440-,J2-Q :'1ickel 11-19 5/5 14 2.9
7.140-09-7 potassium 341 -1.160 5/5 / 680 290
7440-23-4 sodium '9-36 3/5 16 14
7440-62-2 vanadium 32-50 5/5 36 6.9
7.140-66-6 zInc 22-41 5/5 33 6,7
= n - standard deviation based on n (26 or 5) occurrences
Sourca: NUS CorporatIon. Pittsburgh. Pennsylvania. February 1 SSE;'
,-"
-------
-15-
pesticides were detected infrequen~ly, and at relatively :ow levels, in
contr~st to the toxaphene concentrations. . Toxaphene is one of the most
wacer soluble, and hence, :1Iost hydrologically mobile pesticides detected
in soil samples from the lloydproperty. ~odelin~ efforts indicaced that
even this most pervasive, concentr~ted, and m~bile chemical may contamiace
groundwater beneath the suspected landfat~ at theorecical worst case
concentracions of approximacely 4 '.' 10 -) ug/l (below the rninimurninstrumenc
decection limits). Potential human ~xposure ~ay occur through direct
dermal contact or through inhalcltion of fugitive dust: or vehicularcillage
e~issions.
, Contami~ation with other organic analyces (including various volatiles,
phthalate esters, an-J polyt\uclear aromatic hydrocarbons) is also evident.
These substances were infrequently detected and concentrations were.
generally on the order of instrument detecti 00 11mi ts. Groundwater
contamination with these chemicals is considered unlikely in light of the
results of the toxaphene modeling ~ffort, the low concentrations detected,
and the generally immobile nature of these chemicals.
Comparison of the inorganic results at the suspected landfarm 'Jith
the background levels ~resent~d in Table 5 reveals that most Inorganic
analytes were detected at background levels in the Lloyd property soil
samples. Exceptions include antimony, arsenic, cadmium, lead, mercury,
selenium, silver, and tin. Of these, all but lead were detected infrequently
(i.e., in less than 10 of 68 samples collected)., The sporadic occurrence
of these'substances and the relatively low concentrations indicate little
inorganic contamination in'the suspected landfarm. Although lead was
detected somewhat more frequently (l.e., in 46 of 68 samples), only seven
samples contained l~ad above the maxlmum detected background concentration
of 30 mg/kg. Of these seven, six samples contained lead at a concentration
below 40 mg/kg. The only apparent anomalous occurrence was the presence
of lead in one sample at a concentration of 133 aig/k~. Lead and other
trace element concentrations do not seem to di fEel' signi ficantly enough
from background to indicate an inorganic contaminant source on the Lloyd
property. . .
'[-3.
Crimm Orchard (1abb Property):
~,4'-DDT and 4,4'-DDE were present 1n soils in the former CritDID
Orchard iri excess of "natural" soil background levels of areas not
associated wit~ pesticide application. Concentrations ranged as high as
2,447 ug/kg (ppb) for 4,4'-ODT and 1,774 ug/kg (ppb) for 4,~'-DOE. The
presence of the pesticides 1n so11 ~amples from this area is considered
indicative of the use of DOT for agricultural purposes. This orchard
contained the lowest concentrations of 4,4'-DDT and metabolites of any of
the orctard areas sampled. Thus, it is considered likely that the use or
pesticides in this area was not as prevalent as in other orchards in the
study area. These saMples can be used as background samples when compared
to disposal areas (i.e., Pesticide pile mixing areas) which are located
-..Lthin the boundaries of the former orchards. The formulacion (i.e.,
mixing of 3011d matrix pesticides with water for spraying or bomb
appl1c,Oltion) and'storage of pesticides was practiced in an apple-packing
shed in this area. Drums containing pesticide substances were found in
chis shed during the NUS investigation and pesticides were detected in
5011 samples ErotO: beneath the shed and in its immediate vicinity.
-------
-16-
.
Pes~icide concentrations in this area are in excess of ~oth "natural"
50i1 ~ackground levels and t~e pesciciae concent~ations detected in soil
samples from the Crimm Orchard ?roper.
Summari~s of analytical r~sults for soil samples co11ect~d in and
around t~is pac~ing shed (also ref~~red to as the Tabb ~arn)are ?resented
in :ab1~~. This table reveals chac ~,~'-DDT, ~,~'-DDD and ~,~I-DDE are
"resenc in ':~is area at :1Iaxi:num concencncions of 9,000; 4,OO/), and 9,CJOrJ
ug/~g (ppb). respectively. .
Total :oncentrations of ~,4'-DDTand mecabclites reached 22,000
u~/kg In t~e vicinity of che packing shed (a sa~ple from below che floor).
:his ::Iaxi::lu::I value is in excess of boch the "natural" soil concentration
of approxiillacely 4 ug/kg and the "background" Crimm t')rchard concentration
or approxi:nately 4,000 ug/kg.
.Results for inorganic analytes detected in sampl~s obcained from
this area are also presented in Table ;;. . !he following analytes wer~
detected in these samples in excess of background concentra~ions: arsenic,
cadmium, copper. lead, mercury, silver, tin, and zinc. Of these, arsenic,
~erc1~1:y, l~ad ,. and zinc were detected frequently and at concentrations
considered significantly in excess of background. Arsenic, lead and
::Iercury are of some concern from a toxicological viewpoint.
t .
1-4." Jeffuson Orchard (USF&~ Property):
'Table 7 su:mnarized the HSL organic results for sol1 samples obtained
from'the Jef ferson Orchard located to the nortn of Bell Spring Run and
~est' of Route 15/1. Various phthalate esters, polynuclear aromatic
hydrocarbons, and benzo{c acid were detected. in these samples. L.lese
resu:ts were all quantified below the method detection limits ,or these
samples. !hese results are considered of relatively little significance,
in view of their sporadic occurence, particularly when contrasted wit~
che results for pesticides detected in these samples.
~.4'-DDT, 4,4'-ODD, and 4,4'-DDE were detected In all five samples
obtained from this orchard at maximum concentrations of 7,600, 300, and
8,000 ug/kg (ppb), respectively. Such results are evidence.of extensive
use of pesticides in this orcharJ, These concentrations are higher than
t~ose detected in the Crimm Orchard. 10tal 4,4'-OD1 and metabo11~e
concentrations range to approximately 16,000 ~/kg.
The results 'of these samples can also be used as background levles
.Jhen compared with disposal areas, such as the pesticide pile and the
::Iixing areas, chat are located within the former boundaries of the old
:Jrchards.
1~orgQnic sam?les from cheorchard area i~d1cate levels of Arsenic at
38 ::Ig/kg on average with a maxi~\A detection of 53 mg/kg. Lead levels in
t~ese areas are detect~d at an ay~rage or 209 mg/kg, and a ::Iaxi~um of
3':' 1 :!}g / kg.
-------
. -. - .J-
Tab I. 6
. HSL CHEMICALS DETECTED IN SAMPLES
FROM THE CRIMM G~HARO PACKING ~HED {TASS SARN}
LEETOWN P~STICIDE SITE .
LEETOWN, WEST VIRGINIA
. (Based on analytical results for
samplescolleC'ted by NUS Corporation, 1985)
Surlace Soil Sa",oles
ConcentratIon Frequency
CAS. C~e"..ical RanQ8 of Occurrence
Oroanics t'J~/l(c)
:0-29-3 4.4'-00T 20-9.000 5/5
74-54-8 .1.4'-000 tOO-4.000 3/5
72-55-9 ~.J:-ooe 30-9.000 5/5
InorQanlCS ImQ/I(Q)
7429-90-5 aluminum . 5.383-10.498 5/5
7440-38-2 arsenic 3-26 5/5
513-77-9 barium 50-91 4/5
7440-43-9 cadmium 0.7 1/5
7UO-70.-2 calcium .6.608-38.1 15 5/5
7440-41-3 chromium 10-31. 1/5
7"0-43-4 cobalt 5 5/5
74.1.0-50-8 copper .12-80 5/5
t309-37-1 iron 6.625-17,022 5/5
7439-92-1 lead 63-725 5/5
7439-95-4 magnesium 591-2.562 5/5
7439-96-; manganese 39-655 5/5
7439-97-6 mercury 0.18-0.52 5/5
7440-02-0 nickel 5-6 2/5
744(1-09-:7 potassium 527-916 3/5.
7440-:!2-4 silver 1 (both) 2/5
1440 ~ 31 -s tin 7 1/5
7UO-62-2 vanadium 7-211 5/5
.1440 "66-6 zinc 52-234 5/5
Source:
NUS Corporation.Pittsburgn. Pennsvlv ania.February 1988.
-------
" j
CAS'
--'-
114 66-1
84-/4-2
117.81.7
91-10-3
12900-0
hh U!t II
~O-20-3
14-54-8
U -!»!i 9
T abl. 1
IISL CIIlMICA'S OUlCILU IN SAMI'US InOM UIE fonM... JU unSUN OnCtlAIIU (USI WS l'IUWIUI VI
UUOWN PESHClUl SilL .
IUIOWN. WESl VInGINIA
(Uasod on analytical rosulls '0' samples 'olleclo&l bV NUS Co.poraho.:. 190~1
Chomical
SUI'aco Suil SaIll11Itl~"h_'--- - -.. . -' . .
Conunlraliun nan!l!!.j1!Jl{ruL -~~!!!~!!~I!! !! ~!I~!!.!!!~; Y .
dielhvll)hlhalale
&.Ii -n-bulv' phlhalale
bis(2 - ulhvlheMylh)hlhalale
1,240K I/~,
560K - 1,240K 41!.
!)09K - 1,2:101( :I/~,
!)tl9K 1 I!,
88]K . 1 /!.
8,U:JtUC. II:,
4,500 - 7.600 !./~ I'
!)O - 300 !,/~ \'
2,900 - 8,000 !J/!.
naphlha;ene
pv.ene
benzoic acid
.
!
4,4'.OOT
4,4'-OnO
4,4"OUE
I( - laboralorv qualiller Indicatino compound presenl below Iho doloction 'limil I)rovichul.
Suurce: NUS Corporation, t'ilisburOh. Pennsylvania. February 1986. ,
-------
-17-
[-5.
Jefferson Orchard (Robinson Property):
Sumerous .5011 sa1]1ples were obtai:1ed from t~is i'rop~r:y, '",ith the
majority taKen from areas influenced. by the for~er pesticide pile area.
50il samples indicative of agricultural use (orchard) i~clude Qne composite
soil sa~ple from the orchard area proper, and several samples fro~ the
vicinicy of c~e pesticide mixing area.
Organic results for che composite soil sample obtained in the
eastermnost ;>rotion of the Jefferson Orchard ar~ presented i:t Table g.
These results indic.ate that 4,4'-DDT 'and 4,4'-DOE are present in surface
soil concentrations of 7,L30 and 6,925 ugikg (ppb), respeccively. Thus,
it appears that agricultural background concentrations or ~,~I-DDT and.
its ~etabol1tes are 'approx1~ately L':',OOO ug/kg (ppb) in chis area. This
is s1~llar to concentrations detected on the~SF&~S property. Trace
elemen~ concentrations are expected to be similar to -natural" soil
background levels (Table 5).
1norg4nic levels fruM the Jefferson Orchard at the Robinson Pr~perty
show ar!l~nic in the sol1s at 117 :ng/kg (avg.) and le.?d in ~''''o samples at
':'7~ ~g/kg and 991 mg/kg.
1-6.
Former Jefferson Orchard Pesticide Mixing Area (Robinson,Property):
Results ~or samples obtained from the pesticide mixing area located
00 the Robinson Property (Table 9), reveals the presence of m:!thylene
chloride, dl-n~butyl phthalate, 4,4'-ODT, 4,4'-000, 4,4'-00E, and endosulfan
'sulfate. Met~ylene chloride and di-n-butyl phthalate were detected in
one of six and two of se~en samples, respectively. Methylene chloride
was detected at a concentration of ~6 ug/k~. 80th di-n-butyl phthalate
results were present in,the laboratory reagent blank associated with the,
samples. 80th methylene chloride and phthalate esters are common laboratory
contam!n3nts. The sporadic occurrence and relatively low concentrations
of chese substances do not indicate any substantial contamination with.
HSL organic analyces other than pesticides in chis area.
4,4'-001 and its ~etabolites, as well as endosulfan sulfate, were
d~tected at much higher concentrations and generally more frequently in
soil samples from this area. 4,4'-001, 4,4'-00D, 4,4'-ODE, 'and endosulfan
sulfate were detected at maximum concentrations of 59,000, 50,000, 48,000
and 59,000 ug/kg (ppb), respectively. The concentrations are in excess
of the concentrations detected in both "natur~l- soil and "background"
Jefferson Orchard soil and may be cQnsider~d residual contamination
associated with formulation of pesticides in this area. .
in the Mixing Area arsenic was detected in composite samples on the
average of 62 ~g/kg and lead at L99 mg/kg.
I-i.
Former Pesticide Pile Area (Robinson Party):
Table 10 presents a summary of the pesticide and inorganic chemicals
detected in soil samples from the =or~er pesticide pile area.
Hex~chlorobenzene, chrysene; phenanthrene, fluoranthene, alpha-BHC, beta-
SHC, gamma-BHC, 4,4'-ODT, ':',4'-DOD, 4;4'-DDE, and ~ndrin were detected.
Except for the pesticides, all organic analytes were quantified below
-------
" I
T.b.. .
IIS8 CllfMICA8S 1~.:1[C1(n I,. SAMI-US IIIOM TlIEfORMERJEFrERSON OnCllARO (ROUINSON PIIO.-fltly)
" unOWN PESTICIDE SITE
. tEn OWN. WEST VIRGINIA .
(Uas~d on analVaical resulls' for $amples collecled bV NUS Corpora lion. 1985)
CAS II
--.....- --
Chornical
. Surface Soil Samples
Con~onlr8Iion. Ranne ('iD/kg)
OOIO(liOIl frecluency
!.u I!J :a
1/ ~.~ !.I
4,4'-I)Ur
4,4'-OUt:
7,130
6.925
1/1
111
-...---
"-
-.'
CAS II - Cli&lIIiul AtJslt at:1 Service No.
SUUII.U NUS COlllmatiun, t-illstJUIUh, I"unnsylvania, fobruary 1986.
"
.f
-------
Tabla 8
___(;AS !.-
USl ClltMICAlS Ot-nCIEO IN SAMPUS fROM nil: PESJICIOf MIXING AR£A
UffOWN PESTICIDE snE
unowH. WEST VIRGINIA
CO..8d on 8nalW1lul ..aulll '01 aampa.. COIl8C8'~ bV .NUS Corporallon. 1884-IU8S)
Sufface Soli S8mple,
Conunl..llon R.no.
Chemical
O'Olnlcs lilil/lIg)
1'3 O!.t 2
m.'hyl.n. chlorld.
46
84 /ot 2
- 1,0808 - 1.1908
dl-n-bulyl ph4h.lal.
~029 3
/4 ~4'8
1l-~~-9
ItUI 0/ 8
4.4'-001
".4'-000
4,"'-00E
Endosul..n lull.l.
800 - 5U.000
100 - 50,000.
3,800C - 48.000
58,000 - fal.OOO
InO'08nl" (maiko)
14J!1 !)U S
/440 :UI 2
51]-;1-9
100-44-1
/440 10-20.
144\1-4/-)
1440-48'4
/440508
n09-31- I.
/439-92-1
/439-95-4
709-9i-fa
7439'01-6
/440 02-0
1440 09..7
1440 22 4
1440 2J 5
144062.2
14411 66 6
3.690 - '1.200
2J - 110
131 - 160
0.81 - 2.1
28,800 - 181..000
'4 - 31
4.8 - 12
2] - 48
1,850 - 10,600.
104 - 328
'.110 - 3.010
115-450
0.1 - 03
12 - 11
286 - 1..00
3.5- 3.6
21~ 145
86-21
36 - 116
.'umlnum
,u8nle;
barium
b.:-ylllum
calcium
e;hlom'um
coba"
copp..
Iron
lead
magne.lum
manganese
m..cury
nldel
pOlasslum
~lIve.
sodium
vanadium.
line;
---
~;IIIIII I!
:t (; - laboralory qu.lille. IndlcaUng pesllcld. p"llmc. conll.mad by aC/MS.
4 0 - labof.lory qUIll".. lodlcallng compound d.'.lcladln lab ...oeol bla"lt. .
!» . - CAS' (Chemlc.1 Abslr.CI 5..vlce No.) p....nl.d '0. I.on (111) ollidi.
NtiS COfIICIf alio". P'UsbufUh. Pennsylvania, hbrual-Y 1986.
Oel.cllo" rrequencv
.1/6
2n
1/1
511
1/7
2/1
]/]
J/J
3/3
3/3
311
]/3
2/3
3/3
1/3
)/3
J/J
Ji3
21)
1/J
3/3
2/3
J/3
3/1
J/J
'-
,
r
-------
.::..~
Table. 10
~estic1des Detected 1n Samples From S011s in the For:er Pesticide Pile Area
Pesticide Concentration Rar.ge (ug/kg) Frequ~ncy of Occurence
BRC (alpha) 17-8,700 12/2S
3RC (beta) 87-95 2/25
BRC (gaoma) 80-220 3/25
!.,!.'-DDT 430-250,000 25/25
;',4'-00D 220-16,000 18/25
4,4'-ODE 220-110,000 25/25
Endrin 8,000 1/25
r
All COT, ODD, DOE and BHC (alpha) results were conf1~ed by GC/MS
analysis.
-------
-18-
~~e method detection li~its associated with the samples. In addition to
the low concentrations exhibited by the base/neutral/acid extractables,
these substances ''''era infrequently detected (t .e., in two 'or less of thE::
t~enty-five samples analyzed). ' Th~ pesticides (~articularly ~.4'-DDT and
its ~etabolites. and alpha-BHC) were detected much more frequently and at
significantl1 higher concentrations. ~axim~m concentration~ detected
for 4.4'-ODT. 4,~'-DDD. 4.4'-DDE. and alpha-BHC were 250.000. 16,000.
1LO.000. and 8,700 ug/~g (ppb). respectively. Th~se results are in
excess of, both "natural" soil backgrcund and Jefferson Orchard "backgrouna"
'soil concentrations. and are believed to b~residual contamination from
disposal of pesticide debri~ In this area.
, Contrast of the Inorganic results for samples obtained in this area
with the "natural" sol1 background levels In Table 5 reveals that several
inorganic substances are present above the naturally occurring backgro~nd
concentrations. The results for arsenic, lead. and mercury are of particular
interest and are illustrated on Table 11.
The average concentration of
mg/kg and 284 mg/kg respectively.
In the ~ixing Area (As. 62 mg/kg;
(As. 56 mg/kg and Pb. 325 mg/kg).
difference In the concentration.
arsenic a'nd lead in 'the pile area 1 s 137
When compareri to the average concentration
Pb. L99 mg/kg) and in the Orchard Area.
there Is little significanr 3tatistical
I-8.
West Virginia Oepart~nt of Highways (t~DOH) Garage Landfill:
Sam?les were collected In this are~ ~o assess potential impacts on
groundwater In the Leetown area, since i!ndfilling was also reportedly
prar.ticed In this area.
Dl-n-butyl'phthalate (698 ug/kg), 4.4'-ODT (lZ0 ug/kg), 4,4'-DDD
(7.1 ug/kg). and 4,4'-ODE (100 ug/kg) were detec:r.ed'in 1,4,2, and 3 of 6
soil sampl~s obtained from the garage area. respectively. The presence
of the pesticides in S~f: may be attributable to airborne transport of
contaminated particullces fram agricultural areas tn the vicinity of the
garage.
The inorganic results for soil sam?lQ~ obtained in this area indicate
that lead 1s preser:t 1n so11 at 133 mg/kg 1.n one sample. The occurence
oJf lead at: this 10cat10n may be a9Soci~'ted with vehicular eI1l199ions.
J.
Summary of Conditions
The results of the contam1 nant relea~eand exposure stud}' Indicate
that the suspected landfarl1l and the a?ple ~rchards do not appear to
comprise signi f1cant, sources of envt ronment.d contamination, espec1ally
In comparison to contaminated areas such as the former pes~ic1de pile and
'the two pesticide mixing/storage areas. Thi9 Is discussed in detail In
~he Healr.h and Env1ron1D~ntal II1I?3Cts section (Section K) of this document.
E~idence ,of suostantial contaminatlJn was not ~dentified In either land-
filling area. ' '
-------
- .
.I l- - -(...
~.
Table. 11
. Lead, Arsenic and ~ercurv Det~c:ad in 50il Samcl~s
From the Former P~st1cide Pile Area
Chemi cal C"ncentration Range Frequency of Occurence
Lead (Pb) 44-1,040 15/15
Arsenic CAS) 21-759 15/15
~ercury (Hg) .1-1 12115
-------
-l9-
The three areas that present concentraUons of pestici.:it>3 above that
of ambient soil background (non-pesticide use areas) and orchard background
levels (pesticide appli cation areas) .are the followi ng:
.. Fonner Pesticide Pile Area (Presently:Robins~n Property)
Q. For:ner Jeff~rson Orchard ~ixing Area (Presently: RobiCtson Property)
.. Former Crimm Orchard Packing Shed (Presently: Tabb Barn)
. It. is these areas that will be the focus of the Health and Environmental
Impact S~ction ~f this document.
Lead and Cirsenic levels found i" the' 50115 of the disposal areas are
comparable to levels found in the Leetown orchards and are in turn compa~able
to the Ctational average for other orchard areas.
SampHng of monitoring wells and residential wells (27 in total)
reveal no evidence of pesticide co~tamin~tion in the ground water. Low
levels of readily inorganic, volatile and acid extractable organic.
compounds were det'"cted in the monitoring. wells installed at. the base of
the Jefferson Co. Landfill. These compounds were detected infrequently
and at low concentrations.
The tesults of the en~re hydroge~logic tnvestigation indicaeevery
11ml ted lmpacLon ground w,ater quaU ty in the te'!town area. The assessment
of ground water contamination potential for pesti~ides from the pesticide
pile are~ revealed that a?proximately Z50 years will t'ass before DOT will
infiltrate the vadose zone to the water table. The predicted worst case,
long .term concentration is approxll11E.t.ely .04 ug/l., .
Surface water samples in B~ll Spring and Link Spring Runs had anamolous
levels of some inorganic elements. Howeve~, the concentrations of these
elements were similar In both upstream ~nd downstream samples and may be
amJient bdckground levels for this area;
DDE and lead appear to be high
poi nts correspor.~lng .to the surface
contaminants will take place In the
Section of this doc~ment.
1n sedi~ent samples taken ~t sampling
water samples. Focus on th..,se .
Health and. Environmental Impact
The Biotic Ir'estigatlon reveals a.heAlthy macro1nvet-dbrate and
fish population as far dS species diversity Is concerned. Samples
indicated eievated levels (due to bioc6ncentration) of pesticides In some
fish analyted. These results will be discussed in the Healtn and
Environmental Impact Section of this document.
K.
Health and !n~lronmental Im~acts
K-l.
Qualitative Risks:
K-la.
Former Jefferson Orchard (USF&WS and Robinson Property):
Table 1Z shows l.evels of UDT in. the Jefferson Orchard are comparable.
to those found 1~ orchard areas ch.oughout the United States. Because
-------
1--<-
Table ~2
--
Mean Pesticide Residue Concentrations
at Leetown and u.s. Orchards
Pesticide U.S. Orchards (ug/kg) Le~town Orchards (I\g/~g).
DDT/~o!taboli tes 3,310-122,600 9,186 iUax
To xa p~e ne 7,720 ~D
Aldrin :0 ~
Dit!ljrin 190-1,410 ND
End ri n 1 ,240-6,300 ~
Endosulfan 2,300 ~D
Gamma-BHC (Linderne) SO ND
-------
-10-
ehe Jefferson orchard 15 abandoned, eXPQsures will be ~ihlmal. However,
a poreicn of ehe par~el owned 'by ehe USF&WS is used fer ehe produceion of
silage corn for dairy caeele ae ehe Dodson farm. Consumpeion of silage
and/or grassesehae: may have e:aken up p(!selcldes couldresule in eh£'
eveneual accuMulaeion of DOT In ehe milk fae:of ehese cows. However,
milk from all dairies In ehe Vlr6inia/~aryland ~ilk Producers Associaelon
15 regularly monie;Jred for unaccepeable levels of peseicides" so exposure
of ehe general ;>ublic will be circumveneed.
Fugleive duse is noe a signlflcane: problem In ehe orchards, primarily
~ecause of ehavegetaeive cover .and ehe diseance Co recepeors.
K-lb.
Crimm Or~harj (Tabb Property):
E~oslon of ehe DDT found In the former Crimm Orchard will move
contaminanes .:>fEslte Co Bell Spring Run. ,Unless ehe orchard area is put
Ineo row crops ae some fue'.!::e elme, s.eormwaeer erosion will remain ehe
dom nant coneami nan:: eransport mechanism and. exposure route.
Fugueive.duse: will not be a significant problem In chis area,
primarily because ehe area 15 vegee:ated and there are no nearby receptors.
If, however, Chat ve~etaeion is disturbed by future agricultural
activities, fugitive dust could become slightly more significant.
Agricultural activity will result In both dermal and lnhalaticnal/lngestional
exposures of e:he farmers wotking C~e land. .
K-lc.
Suspected Pesticide Landfa~ Area
(Lloyd Property):
Th! levels of pesticides found i~ the s~spected pesticide landfarm
area are well below the average values reported for other cornfields
ehroughout the United States. toxaphene is the major conta'Dinant found
on the property. Toxaphene and DDT are unlikely to move Into the
groundwater because of their high soil/sediment ~dsorption ~oefficients.
Because of ehe immobile nature of toxaphene and e:he other ~esticides
found, exposures will probably occur only e:hrough dermal contact during
e i11i n~ .
Erodedmae:erial from e:he suspected land farm area
carried e:o the Gray Spring w.atershed, which was found
contamination. Therefore, it appears that se:ormwater
major e:ranspo:t route for e:his area.,
would probably be
to be free of.
runoff 1 s not a
K-ld.
Jefferson County Landfill:"
This landfill Is an active facility currently administered by e:he
Jefferson County Commission. The landfill presents no ldentifiabl~
current risk to residents or workers. ~o signiHcant hazardous constituents
were found in any of the moni e:ori ng wells e:hat encircle the landfi 11, and
nearby residential Hells were also clean. ~onieoring wells were Insealled
around ehe landfill ~nly In an ~tr.empt co determine wheeher Ie presented
a currene risk Co any potential receptors. The 'composition of ehe buried
~astes was not studied, eherefore ehe potential for future exposures or
risks 15 not known.
, .
-------
1-
-21-
K-le.
~~DOH Garage Landfill:
As with the county landfill, this is an active facility that is
currently adminiscer,ed b::-- the State or West Virg!,oia. The WVDOH garage
and its landfill were investigated as part of this study in order to
d~ter~ine whether it presents 3 ris~ to any receptors. Wells installed
near the fadlity as well 'as' its water supply '",ere found to be free of
concamination. ~o exposure pathway ~ould be identified for this area,
therer~re the sit~ appears to present no risk.
K-l f.
Former Pesticide Pile Area:
The highest concentrations of pesticides and several inorganics
(arsenic, had and mercury) were found in the samplas collected from the
former pesticide pile area~ The nature of th~se conta~inants causes them
to adsorb to soil particles. Contaminants will be ~eleased only when che
30il is di~turbeJ.
One potential release ~echanism that was evaiuated Eor the pes~icid~
pile area is the generation of fugitive dust fro~ the unvegetated area~
Winds m3Y entrain dry soil particles and move them offsite to human
receptors.
Another release mechanism, which could also ~es41t i~ human exposure,
is agricultural activity S4ch as plowing or harvesting. The pesticide
pile area 1s currently in pasture, but there i9 a p099ib1lity chat the
so11 could be tilled at some future time. If plowing should occur, it
would most likely take place over the entire Robinson property, and
therefore, the farmer would be exposed to av~rage, areawide contaminant
concentrations. Both dermal and inhatat10nal/ins~stional exposures would
occur from agric~ltural activities~
K-lg.
Pesticide Mixing Area:
Soils surrounding the fo~mer Jefferson Orchard pesticide mixing area
exhibit h1~h levels of pestictdes, second only in concentration to'the
former ?esticide pile area. Soil disturbance will be the major contaminant
relp-ase mechanism.
Because the fQrm~r ~IAio~ area is well-vegetated, overland flow
(runoff) will not be a major route of transport. However, minor erosion
could occur, and if it did, contaminants would be transported directly to
Bell Spring Run because of !~s proximity, thereby entering the aquatic
food chaj~. tn this area there would be less chance for these contaminated
soils to mix with other contaminated so11s because of the area's pt"oximity
to the stream. ' .'
Fugitive dust will not present a problem In this
established vegetative cover. However, grazing could
ar.ea 1 s wi thin che fence on the Robinson property.
area because of the
occur be~ause the
Tilling the soil around the e~isting foundation could ~esult in both
dermal and inhalation/ingestional exposure as described for the former
pesticide pile area. As with that area, che mixing area Is not currently
under culcivat1on. If the land should be rotated into row crops and if
. i: were plowed close to the foundation, exposure could occur. -....
-------
-22-
K-lh.
Fenler Crimm Orchard Packi!1g Shed:
The soils beneath and i~mediately surroundin~ t~e packi!1g shed are
contaminated with levels of pesticides that exceed the levels found in
t~esurrounding orchard area. These pesticides will only be released to
the environment when the soils are disturbed in some way.
Presently, wind-blown dust a.nd soil erosion are not problems because
there is vegetation around the shed. While it is possi~le for some
erosion to occur, vegetation between Bell Spring Run ard the contaminated
'soils would preclude contaminants from entering the aquatic food chain.
If the area immediately adjacent to the ~hed, and part\cularly the
soil~ beneath the shed (if it were razed), should be plowed at some future
time, farners ~ould experience both derlDal and inhalational/ingestional
exposure.
1(-2.
Environmental Risks:
Preli~inary estimates were made of the amount of contaminated s011
that may enter the streams from the identified source areas. Average
pesticide concentrations in the orchards wli!re used for the calculations
. in order to more accurate~y assess actual contami~ant loading. Although'
~oncentrat~~ns from the actual pesticide pile were not used~ average DDT
concentrations for the form,r Je.:fers"nOrchard (Robinson property) were
used as an estimate of sediment "dilution" during a 25-year rainfall
event. After the expected rapid settle~ent of these sediments, partitioning
between the water ~nd sediment was estimated using published values for
~oil/sediment adsorption coefficients. A bioconcentration factor was
applied to the expected water concentration. It .,as found that the
~aximc~ predicted concentration of DDT in fish tissue would be 3.5 ppm.
The Food and Drug Administration (FDA) has set 5.0 pplll as the action
leve~ for commercial fisheries, but this value does not apply to recreational
fisheries. The National Academy of Sciences (~AS) ~as recommended a
level of 1.0 ppm for total DOT in fish for the protection of wiLdli fe
Both the observed and the ~AS-recommended valup.s are less than the worst-case
predicted levels. The :uax1::1'JIII observed ODT concentration in' fish tissue'
was ~.8 ppm, which is approxi~ately equal to the ~hS guideline. Because
of this fact, it is" unlikely that wildlife will he afr.,;ted by the observed
levels of DDT in fish. In addition, the terrestrial habitats in the.
area are not unique, nor are they home to any known endangered or threatened
species. Human exposure through ingestion of fhis from Bell Spring Run 1s
unlikel, because the top car~ivores :n this aquatic system are Eallftsh
and creeK chubs, both of which are non-game fish.
It i~ unlikely that contaminated sediments in Bell Spring Run would
affect the activities at the ~FC, even though it lies down~t~eam of the
contaminated areas. Water flow through the ~FC precludes contamination
0f fish raised in t:h~ hatchery because the water for the hatchery comes
fr-om Gray Spring or Hopewell Run (F'igure 13). However, contamination in
Bell Spring .Run could affect Hope'.o/ell :iarsh, Reservoir A, the hatchery
hold! ng house, a"nd the ~FC Academy. The slow flow through Hopewell .
-------
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WATER FLOW THRCXJGH THE
LEETDWN NATIONAL FISHERIES CENTER
L5ETOWN PESTICIDE SITE. LEETOWN. WV
!"= 500'
Flflur* 13
-------
-Z3-
~.arsh would allow oust. if not all. of the sedi:'lents to settle out before
they reached' Reservoir A. However. neicher. of chese facilicies are
occu?ied by fish for any significant length of ciMe. In addition, fish
used in the Aca~emy are incinerated after use and are not consumed.
:"he ;.resent data base is not 3dequate t.o fu'l:' characterize che t~rea~
to rapcors and/or waterfowl t~at ~ay feed on the fish trom local streams.
Development of such a data bas-a would have,requred a greatly-expanded
ecological investi~ation. However,. the approach taken to the environmental
as~essoent is justified based on the absenc~ of threatened or endan~ered
s?ecies of ?iscivorous birds or terrestrial ~redators, and ac objecti~e
evaluation as a result of field reconnaissance. that the potential ror
adverse impact to aquatic and terriestrial biota is low.
K-3~ Quantitative Risks:
Carcincge~ risk calculatiocs wete developed for ~ of the 8 all
areas under investigation. The conclusions for each area is summarized
below. It has ~een determined that the only areas which present a potent~al
health risks are:
~
The Pesticide Pile Area (Robinson Pr~pert1)
..
The Former Jefferson Orchard pesticide Mid ng Area (Robi ~son?rop.erty)
\
..
The Former Crimm Orchard Packing Shed (Tabb Sarn)
~ese areas only present a threat to a certain po~ulation under a
s?ecific and conservative exposure ~cenerio. The exposure scenerio
J~,~l~~ed for these areas is directed at farmers who may- till the land
for 12 days per 1ear, 10 hours a day over a period of ~o years. The
route or exposure which presents the risk involved is through Inhalation/der~l.
ex?osure to contaminated dust adsorbed duri ng tllliug operations. It should
~e noted that th~.areas in question are not presently being cultivated,
and no ~nown plans for cultivatiort are evident. .
:he other five areas of po~ential contamination were eliminated from
alter~ative developement based on the risk assessment for each area or
based.on exp~c;ed contaminant leve: ovp.r an area of. historic application
of ?estic1.des.'
A summary of the avenge total carcinogenic risk for 6 of the a sit~
areas is found in Table 13.
The Jefferson County landfill and the WV-DOH Landfill were not
subjected to risk calculations ~ased on the lack of significant contami~ation
~ound there. . .
The ~arcinogens ri:>k fr"m t'JO sceneries based on milk consumption
3re ?resented in Table 1!.. This illustrates that even under the most
=~nservative exposur~ scenerto (i.e., drinking milk produced from ene
~airy far~ Qver a~ expecce~ lifeti~e) the calculated total carcinogen
risk is 1.3 x 1~.-:''' (1 in 7 ,30(})..
"
-------
SludV Area
hUIUOI Pu:tlicidu PUu Auta
PU:'Ikllht Milling Aroa
CIIIIIIII Orchard Padino Shod
"
JuUorson Orchard
Crimm Orchard
SuspuClud Pesliclde Land'arm
Tabl. 13
SUMMAUV Of AVU\AHE IOIAt CAUCINOGLNIC IUSKS
tUl0WN .)(SIlCIOt: Sill
I lHOWN. Wl5 r VIUGINIA
Oltrmal
EIII)OSUres
II Ihalalional/ln ue s I ion al
--!lIlw'sures IndlHlin!] Ar50ni(;
5.4- 10-6
(I In 18.000)
5 1 I( 10-2
(1 in 20)
3.9 - 10-fa
(1 in 26.000)
1/ II IU-l
«1 In MJ)
. .
5.1. 10-6
«1 in 196.000)
4 5 I( 1U-3
(1 in 2l5)
1.4 x 10-6
(1 In 136.000)
.
2.6 - 10-6
«1 In 400.000)
.
67 - 10-1
. (1 In 1.!~OO.OOO)
2.6 1110-:1 .
«1 in 3(0)
Inhalaliollal/h IU0:. IIUIIiII
.r 1(1)()5~ 05 f. ~1II1i1!i.L I\r ~!!!!!!.:
5 U I( )0"4
(I 11\ 1,/0(1)
4 :I I( 10 '1
. (I In 2.3(111)
.t'
~ 1 ;( 10' ~
t-
(I In ".~(III)
02 II 10'~
(1 III 11.(I(Iil)
29111n-~
(I in J4.~IIU)
I.".) I( 1O't)
(I In 1J4.01U1)
-------
[---
I
/:-c..
Tabl. 14
CARCINOGENIC'"RISJC:FROM MILX CONSUMPTION
LEETOWN PESTICIDE SITE
LEETOWN, WEST VIRGINIA
Entire Lifetime Entire Lifetime
Milk Consumctlon Mille Consumpt'on
Oirec! frO!TI DOdson from MOIVA Milk
Contaminant Dairy. Farm ~rOducer! AssOciat!on
DDT/m~tacOljtes 2.6 x 10-6 2.1 x 10-9
alCha - ~HC 1.9 x 10-5 1.$ x 10-8
~e~a - SHC . 7.9 x 10-7. 6.3 )( 10-10
;a~ma .; SHC 2.9 x 10-7 2.3 x 10-10
~o)(ap"ene 9.7 )( 10-5 7.7 x 10-9 .
chlordal'e 5.5 )C 10-e 4.4 x 10-9
aldrin 3.7 x 10-8 2.9 x 10-11
di eldrin 2.6 x 10-7 2.1 x 10-10
Total Risk - 1.3 x 10-4 9.9 x 10-8
(1 in 7.800) (1 in 10.000.000)
. NOTE:
RiSk is cased on average concentrations of pesticides found in cornfields.
For this site, the av.rag. contaminant concentrations in th. suspected
P.sticid'.landfarm arll were selected as b.ing repre s.mativi of comfi.:"s
int"e area. Dairy farmers typically have severa. cornfields, and it was
assumed that Mr. Dodson operates in tn. same mann.r. .
Source:' NUS CorpOration. Pittsb.ur9h, Pennsylvania, February 1986
.
-------
-24-
A more realisti~ scenerio is illustrated by calculating the risk of
:nilk ~onsumption from the' :1aryland/V1rgin1a ~ilk Producers AssC'ciation.
This total carc1noge,'i~ risk is calculated to be 9.9 :< LO--3 or [ in [0
:ni1110n people. This is ~ased on dilution of mil~ Ero~ the Dodson Far:n
and consumption of milk over a period of 70 years.
L.
Remedial Action Technolo~y Screening
The Qajor objectives for remedial action to be taken at the L~rtown
pesticide site are to mitigate or ~inimize potential health risks associated
with the exposure scenerio descriJed i~ 'the Heal~h and Environmental
I~pacts sec~ion of this document.
Any remedial a~tion i~ple:nentad a~ the 3 (out of 8) sites identified
as posing a significant health threat f~om tilling operations, must take
i,to consideration potential impa~ts to any wetlands or floodplains
adja~ent to or part of these areas.
I .
I
I
The ~ational Contingen~y Plan specifies 'that remedial alternatives
should be classified as either sour~e control or offsite (management of
:nigratlon) remedi31 actions (40CFR 300.68(d».. Source control remedial
actions address situations in whi~h hazardous substances remain at or
near the areas 1n whi~h they were originally lo~ated and are not adequately
conta1ned to prevent migration into the envtronment. Offsite remedial
actions address situations tn whi~h the hazardous substances have migrated
from their original lo~ations. Alternatives developed ~y fall solely
1n either classification or :nay involve a combination of source ~ontrol
and management of :nigration measures, as problems at the site may di~tate.
In order to determine remedial alternatives at leetown, feasible
te~hnologies were identified for ~onsideration. Available technologies
~ere then screened to eliminate all but the most feasible and implementable
altr.~nativc~. This s~reening criteria employed in identifying these
te~hnologies are as follows:
o
~
Techni~al aspe~ts
Environmental ~onsiderations
Publ1~ health effe~ts
Institutional issues
Site spe~ifi~ issues'
CostS (order of magnitude ~omparisons)
o
o
..
o
Parti~ular emphasis withi" ea~h criteria is listed below:
o
Te~hni~al aspe~ts
- ?erfo~n~e 9tandard
- Reliability 9tandard
~ I:nplementabl1lty standard
- Safety standard
~
E~vlronmental Considerations
- Reduction of environmental i~pa~ts
- ?rotection of natural resour~es
-------
-:25-
~
Public health effects
Exposure pathwiy reduc~ions
~igration pathway reductions
o
Institutional issues
- Compliance with ~CP
- Compliance with other environmental laws
- Complianc~ with state and local regulations
o
Site specific issues
- Site conditions
o
Costs
- Capital
-: Operation and maintenance
Present worth analysis
.- Sensitivity analysis
A summary of technologies considered and ~heir applicability to the
Leetown si~e is found in Table 15.
The technologies suitable for reme1iation of ch~ Leetown Pesticide
Si te have been identi Hed and a p~el1minary e\'aluation of their appl1cabUi ty
has been completed. . The technologies that were retained for further.
evaluation and development of remedial alternatives have beert summarized
in Table 16.
These technologies will be combined to form the remedial action
alternatives for cleanup of pp.~tic~ae-contaminated soils and containerized
. pesticides pre~ent at the site. . . .
M.
Development of Remedial Aceion Alternatives
Various remedial action alternatives were dev~loped by assembling
appropriate remedial technologies into groups of actions to address the
objectives of remedial acti~n. The de~elopment of remedial action
alternatives to remediate the site consistent ~.th various categories of
cleanup i5 required by the NCP, Section 300.68.
. I
-------
. .General Rosponse
Aclion
No ACIion
C.onlainmenl
Pumping
ColleCIion
Oi\lersion
.
!
Complele Removal
Parlial Removal
Onsile Tu.almenl
OU~ile Treaunenl
In-5;.... -.realmenl
Simage
I
I
Tabla 16
GEhEftAl RESt»ONSE ACliONS Arm ASSOCIAUO IU.MI"OIAI. 1lCIiNOI nG11 S
lEElOWN rESIICIOE SITE .
lEETOW't WEST VIRGINIA
Technologies.
Some monitoring and analyses may be performed.
Capping. groundwaler conlainmtnl barrier walls,
bulkheads, gas barriers.
Groundwaler pumping. liquid removal, dredging.
Sedlmenlallon basins, french drains. gas veniS. gas
collecllon syslems.
Grading. dikes and berms, slream diversion dilches,
trenches. lerraces and benches, r.hules and downplpes.
levees, seepage basins.
Tanks, drums, 50115, sedimenls. liquid wasles.
conlaminaled struclures, sewers and waler pipes.
Tanks, drums, solis, sedlmenls. liquid wasles.
Incinerallon. solidUIcallon, land Irealment biological.
chemical. and physical Ir81,menl.
.lncineraUon. biological. chemical. and physical uealment
Permeable uealmenl beds, blorecl.-.mallon, soil flushing.
peuualilalion, land farming- .
Temporary slorage struclures.
COIHnWII15
._-- -.
Allplicable re:'l'0nsa
Call1lillU . ap"liI: ohio
NOl apl1licahlo
So,limenlahon. t:onl.ul .11'11111 0111111
Dikes. {lr ading. IrClu:hos. 51! o ill II.
diversions- apl)licahlo
Applicahle rO~IJ()I\so
Al1llliubio !eSIWlIso
API)Iit:ilblo rosllon50.
Apl)licablo 'USpOIlSO
Nol a11111ic.ahlo
Nol api)liulJlo
..
f
-------
GEN£ltAlRESPONSE ACnONS AND ASSOCIATED RUAEDaAl UCIiNOlOGIlS
t EHOWN PES HCIOE SITE' r-
LEBOWN. WEST ,VIRGINIA
IIAC.::: tWO
Guneral Respons8 '
Action
TechnologIes
Onsi'e Oisposal
,Landlills: land appUutlon.
OUsile Disposal
LandliUs. surface Impoundments; ~~nd applicalion.,
AllernaUve. Water
Supply
CIsterns. aboveground ,.nks. deeper 0.
upgradlenl wells. municipal waler syslom. relocation o'
Inlake strudure. IndIvidual "ealmbnl devices.
Relot;aUon
Reloca'e residents tempor.rlly or pe.manently,
Cun1l1lC1i1 :.
--.------.- .
'andhlls - al1ldu:ahlo
t andhlls - applicahl6 ,
Not apl)hcaidu
"
Not apl)lir.ahlo
-------
Tabl. 16
SUMMARY OF APPLICA8LS REMEDIAL TeCHNOLOGIES
LScroWN PESTICIDE SITE
LSETOWN. WEST VIRGINIA
~~c~noloav
Comment
r.10n1torrng
~urnishes data for turt"er assessmentS: status updates
5011 Cover
COntains COntaminantS and
exposure and otfsite migration
mitigates
potential
for
Multimedia Cap
Similar to soil cover; provides greater security. cetter
control of surfac. water infiltration
=)(cavatlon
Can ce used to consolidC2t. ContaminantS on site or to
prepare contaminat.d media tor r,moval Options
Removal'
InvOlves tranSporting contaminants to a new locatiOn on.
site or to an otfm. treatment/disposal flcility
I
Results." in placement of contaminants In a slcure waste
disposal facilirf. titner on sit' or in I remotl facility
Landfill
Otfsite Oisposal
Tra:1Sportatlo., of contaminants. to an approvld. otfsitl
disposal facility
Onsitl Trlatmlnt
Invol"IS anaerobic dlstruc:tfon. 'of Plstlcidl~contamin.tld
soils in I Sp.Cilllv-constru~'d plot on sitl
AnClllarv Technolooils
Surface Water Oive"ion
Sedimlntation Control
Bacldilling
Grading and Rlvegetat:on .
-Required constr:ucti~n to complemlnt tn, abo"e major rlmldlal actiC]ns.
-------
-2j-
:ne ~:c? !.o cn 300.6d (:)(t) speci.:ies f1....e.<.;a~eg?t'ies of si::e,remedi1~ion
as jefi~ed below:
Ca~egory
Deseri ~don
I
~o Accion Alcernacive
II
Some.~1nor cunscruccio~ and/or sampli~g apd c~s:1~g
of ~he environmenc ~ay b~ ~cco~plished under chis
al:~rnacive. '
III
Alcernatives which reduce and/or mitigate the receptors'
~isk of e~posure ~o the conta~inants buc,do not
fully comply wich all environmental and publi~ healch
standards.
1'1
Alternatives which e~ceed applicable and relevant
Federal public health ~nd environmental standards.
'.J
Alternativ'!s which prov1.de treat:TIent of the 'Jaste -\nd
reduce it' toxicity or which remove che eo"~am1nati~g
~ater1.al, to an approved, offslt& facility.
Remedial action alterna:ives were developed to provide a solution
consi stent "1 th the 51 ce rehlediation catp.gor1es identified above. as
ap~roprlate, for the teeto.Jft Pesticide Site.
.~.
cesc~iption of Remedial Action Alternatives
Remedial alternatives have been developed to address the three sou~=e
areas at the Leecown Pesciclde Site chae havo! been deter1Dined eo be.
candidates for remedial aceion, on the basis of boeh exeenc of contamlnaeion
and public health and environmeneal risk assessmene. These source areas
~re as follows:
o For~er Pesticide Pile Area, (Pesticide Pile)
o ~ormer'Jefferson Orchard Pesticide ~1~lng Area (Pesticide ~t~1n~ Area)
o 'For~er Cr1alm Orch,ud Packin~ Shed (pat:king Shed)
Due to the proxi:TIity of the P..sticide Pile Area and the Pesticide
,~1xl~g Area, these t~o source ar~as have been considered as a single
source. Consistent treatment of these areas as a sln~le sour~3 also
pensitted parallel developlllent of alter.natives, which ~reatly faclLi'
tated comparison betveer. alternatives.
3ecause of its spat!al distlnccion from the first two source areas
and the small quantities of contaminated s011s present, the packlns shed'
~J~ ~een consistently t~~at~d separacely in development of alternatives. '
Ho'...ever, in order to ::lake opt1::!al 'Jse .)f facllales proposed in conjllnct10n
'~th the alternatives incor~oratin~ onsite treatMent landf1lling, and
b~cause of the ~in1~l quantities of ~aterial lnvol~ed at the packin~
:;:-:ed. a,ld the comparacively hi~h '.101 t costs of constructin~ a t~e3c:tenc
cell ~r landf~lt a~ ~he pac~ing ~he~, a separate treatment cell and/or
tandf11i has not been proposed Eor ~his area. ~ather. it has been assuMed
,
-------
1-
-27-
c!:ac concaminaced soil~ from che packing shed c;uld be accor.1mondaced it
such facilicies ar~ conscrucced for concaminant svu~ces on t~e ~obinson
~ropeC't:y.
Coincident with the remedial accion altet'oacivesdeveloped in t:,1s
section, the pesticide Materials andassociac~d contaminated maCcr1als
presently located in the for~er' Crimm Orchard packing shed ~ill ,e ['e~ove1.
~is action is defined i~ the FS buc is not affiliated ~i:h any specific
altet'~acive. It 1s assumed ::,ac chese ~acerlalswill ~e removed under
all alee~'native remedial aceio:'1s e:
-------
-28-
sl~e re~ediation. as defined in ~~e ~C' 40 CFR 300.68 (f)(l)«(v). ~l:hough
placem~~c of a soil cap over :he cont3mi~ated soils ~ill reduce che
opporcunicy for ~eneration ~f co~t3~inat~d dusts. i~ ~ay not fulfill all
or che Federal regulattons (e.g.. RCR.A) regarding the disposal of hazartious
substances.
Cuntaminated soils from the Pesr.~clde Pile and the Mixing ~reas
~ould ~e consolidated to reduce surf~ce area and enh~nce the cosc
et:ecciveness of che cap cons:ructlon. Because greater volumes uf
co~tami~ated 50113 are present at the ~ile ~re~. location of ~he capped
~eposit iri its vicinity would be most 3pproprta,e. Ftgure14 provides &
conceptual drawing s':towtng. a pocentlaLconfiguration for the capped
.deposic and a cypical Jectlon showing.cap construction.
The cap ~ould consist of 18 inches of soil fill w1ch an overlying
tupsoll de?'th of 6 lnches t~ permic E:tfctlve establishr.;ar.t of vegetation.
!he plan layout would require a~out 40.000 square fee., with the contaminaced
solls placed to an average depth of abouc ~ feet. Such an areawnuld
provide scorage for approxl~acely 3.500 cubic yards of contamt~ated soil.
Cap construction should requlreapproxl~acely 2,220 c~bic: yards of 50il
fill and '740 cubic yards of topsoil.
Aprr~xlmately 2,580 cubic yards of' contaminacedsoll are anticlpaced
frotl che pesticide pile arESa and about 890 cubic ya.'ds frolll the pe:"ticlde
~lxln8 area. These volumes assume excavation to a de?th of 6 inches for
areas of 3 and 1 acre at che pesticide pile and mi~ing areas, respectively.
i
For chis Alternative ancillary construction would be necessary to
. support thecon»truction actton: Thi~ construction il~cludes:
- access roads
- parkins lot
- decontaml~atlon pads
~ surface water diversion channel
- runoff diversion channel
- sedimentzt10n channel
- diversion dike'
- site restoration
~-4.
Remedial Ac:don Alternative ~o. t.. - ~ulti-aledta Cap:
The lnstallation of a ~ulti-aledia ca~, rather than a cap of local
soil. will satisfy the requirements of che ~esciurce Conservation and
Recovery Ac:~ (RCRA) for the closure of a wasce area as a land disposal
~n1t. In this manner, this alcernative .will :ueet the requirements of,
Category ~II of the requislce levels of remedial action.
-:he intent of chis alternative is idencical to that ~f Alcernative
':".3. The l
-------
iTI'lCAt UCIION
CAHtU
NO I 10 Si Ait
NOiio*oiiiOM(MCOMiiiu fUMOVIi ONtf
MOtMttlUIIOWCtlWIHOl
SUfcf*C€ WAItH WVINSION WICH
or
:>pji i. A I- M CHUN
IU bl Al I
ALURNAflVE 3A
Pt STIC IDE SITE. LEE TOWN. WV
joo
3OO
Will M III I
Figure 14
-------
'-29-
canca~inarics of concern are noC readi~y 501ubl~ in aqudOus media.
The cap would consisc of a 24-inch layer of i:JIper'/ious clay, a 4-
lnch s~nd cushien, a 30-~il imper'/iou$ ~embrance, an inrilcra:lonconduccin;
zone of ~ravel 12 inches in chickness, filcer fabric, an 18-inch Layer of
soil filt,and 6 i~ches of overLying copsoil.
che cap ~ill be sli~hcly in e~cess of 5 feet.
In cocal, tilr. chic~ne~s of
Yastesacche pesCicide pile and ~ixin~ areas would be excavaced ;nd
consolijated in a single area as before, wi~h lnscallacion of a mul:i-
. ~edia cap over chis de?osit~ The pocential for concami~ant migration via
wi nd or wacer erosion would be [!Ii c igaced anti che exposur.~ pachway of
concern w~uld thus be disrupted. As with Alternative ~o. 3,che capp~d
deposit ~ould remove a portion of the area on the Robinson property from
future agricultural use~ but consolidation of che wastes from the ?roperty
into a single, capped deposit would minimize the surface ~rea involved, .
as well as the actendant cost for cap con$cructlon.
Figure 15 provides a conceptual design of the capped deposit ~rea
and multi-media cap, with typical sections to sht)w the cap design.
This cap wtl~ provide storage capacity for abouc 3,S70cubtc yards of
contaminated soils at an average depth of 6 feet.. !he site preparatton
and construction requi remen,ts at the pesti cide pile area are. identical
to tnose specified for Al~.rnatlve ~o. 3 and are not repeated in detail
here.
The contents of the packing shed will be handled as specified in
Sl!ctlon~. As proposed in Alternative ~o. 3 chis alternative proposes
consolidation of the c~ntam1nated so11s to an area immediately east of
che shed area. By so doing the case of capping =an be greatly reduced,
since less surface area will be invoJ.ve_. In addition, it would not be
9ractical to construct the multi-medIa-cap on in-place soils 1n view of
the constralnts of the existing structure overlyi,! the 50115. Figure
16 provides a ,planv1ewof the proposed alternat.lv'! as well as a cypical.
section of the multi-media cap..' ..
~-5.
Remedial Action Alr::ernative ~o. 5 - Onsite t;..ndf1l1:
!his alternative provides for the ~i5posal of the contaminated soils
from all three areas 1n .an onstte landfill. The opc1nlal location for che
tandfillwould be close co the pesticide pile area on the Rob1n10n pr~perty
because of the gresr::er volume of conr::a~lnated 50ils in this area. It
would not be cost effective to construct an onsi~e landfitl on the Tabb
property for the 2& cubic yards of contamlnated soi18 to be excavated
from beneath the shed. .
This alternative would comply wlth the requirements of Re~edial
Action 'Category No. tV., exceeding Federal requirements for waste dlsposal.
Th i 5 l s true since compliance wi cn thew'VD~R requ~ rement for 3 feet of.
compacted. clay at the base of the capped deposit exceeds Federal guidellneo.
E~cavation ~f contamin3:ed :oils'at both the pesticide plle area and
the pes.t1clde ~1JC1ng atea will. require the construction of the salDe system.
3ict!.
-------
Vftfl -1 ( A' I I i
Vfijtf^"' r\\r*:
-n\( /" V r--
y/cy <^~y,_ ///
A'//7 \ r l us
S.«v*'- i-j"
II1 ' V ; '••» :.-'-» '
!!>. ' » • '. > -- —: \ -
\ INOI IO» Ol llf.M O* CUNSUUC I ION nil.
\ ll(KariONAI4OC.IU4NMUMS All IUI
•^A
ItCM*)
HUPOHAHI Omf
SfUMlNIAIlUN UlNINCH. CHANNil
-. SUHFAI t WAUH UlVlHSKJN [MICH
[SIIMAIIQ AMI A
Mill It Ml 1IIA CAI> SI i |l"H
HOI lu Si Ail
MULT I MEDIA CAP ALT|RNATiyE 4A
PESIIClDE SHEj L-EETOWN.WV
Figure 16
-------
3 NG. 5
-"C 35 sg
EXCAVATED -NO i
^
cory. y^~
PLAN OF PACKING SHED
PLAN OF MULT1- MEDIA CAP
•«"
VSOL
12" CONDUCTING 3
MB-smTvenc
2'-O* CLAY S0».
SOUS
CROSS SECTION C-C'
MULT1-MEDIA CAP ALTEHNAT1VE
LEETOWN PESTICIDE SITE, LEETOWN. WV
N4CT TO SCiLS
-------
-30-
jf acces. roads, parking areas, jecontamination ~ads and surface ~ater
concrols as sp~cif1eJ fJr Al~er~acive ~o. 3. A total of 3,780 c~bic
yard~ of ~ontaminated soils a ~ravel ~ro~ che source areas will ~e
accommodared by che landfill is ?ec~een ~he ~wo source areas, c~e :ol~ow1~g
addiconal conscruction will be required co avoid che need co use Rouce
.15/1 .tc bri~d concaminaced 5011s from c~e pesticide ~1~!ng area t~ che landfiLL
site. . .
o
Access road - 1,100 fc x 15 Et
,
o
Sed1~ntat10n channel - 2,370 cu yd
~
L'pgradlent surEace ~ater diversion - 1,550 cu yd
These fac11ities have been shown in plan view on Figure 17.
Reclamation of excavat10n at both the pest1cide pile area and che
~est1c1de mixin~ areas is.1dentical co that identified for Alcernative
~o. 4 and 19 incorporated in che description of the current alternative
by reference. PestS cide materials, floor'1 ng. and che .spray wagon at 'the
pacKing shed would be transported offsite for d1sposal as noted 1n Section
~.
N-6.
Remedial Alcer~a~1ve ~o. ~ - Offsite Disposal:
\
Thi. alternative has been proposed to fulfill the requireMentS of
Categor, V of the requ1site levels of remedial action (offsite disposal).
Offs!te di-posal provide, a high degree of s1te re~ediation because 1t
removes the contaminated s011s to an approved, secure, hazardou8 waste
dispolal facility. In accordance wtth the EPA Offs1ts Dispolal Policy
(£PA. December 5, 1985), the opeion 'of treating the contallinated soils
v1a 'offsite incineraelon has been proposed in ~onjuaction with removal of
the wastes to a dtspolal faciliey.
Inc1neration of the wastes wa. ~11~1nated in the init1al screening
of remedial.technologles on the basts of COlt, pr1:arlly b.caus. of the
. low heat value of the contaminated sotls. However. if treat~enc of the
soils 11 requ1red p~10r to disposal. incineratlon 1s che only log1cal,
comme~clally available option. . .
3y removtng the waste~ from the 9ice, the ~otent1al for generatlon
of dust em1ssions contaminated with pestlcidel wtll 08 miti~ated to th.
extent that contaminated materials have been removed fr~m the sites.
Conta~inated soils ae both the pestlcide pile area and the ~8Iticid.
~1xing area would be excavated and crans ported to an offsice disposal
~rea, ;,11th 'Jr without ofhite treat:l!:!nt prior to d1sposal'. ~e necessary
construction (1.e., access road, parking 3rea, decontamination pad, and
surface water controls) to support excavation at these two sites and site
~e9torat1on requ1rements do not d1ffer from chat specified io Alternative
~o. :) .
-------
Mil II Ml I.'A l AC It | INI H III IAC|
h »l 10 i- At 1
ONSlTE LANDFILL ALTERNATIVE 5
IEETOWN PESTlCldlE SITE, LE|TOWN,WV
aoo
100
it •* I M t t I I
Flgura 11
-------
-31-
~e esti~ted vcluoe of conta~inaced soils CO be excavaced from che
t~c siees is 3,~70 ~ubic yarjs. In addicion. c;nt4mi~ated gravel from
:~e :econcaminacion ~ads and a por~ion of t~e ac=ess road .ould ~~quire
of=~ite disposal, bringi~g ~~e total volume ~f ~aterial to a~out 3,SaO
cubic yards. Assuming haulage tru~k capacity to ,e aboue 13 cubic yards
in order co achieve a eotal leaded 5ross ~ehicle wei~he of 32.5 cons :~
r~~i n -.Ii t~i:\ r.aulage 11:111 ts on Se'( undar: road'.ravs, a t:otal of ~olJ
:ruck~oads .ould ~e required in order to re~ove the ~aterials. F~r
:~e ?ur?ose of cose developoene in this FS, i~ was also assumed chat
:~ese seils woul.d be t:'ansporeed. co a di s posal si te approxi~aeely !.Z0.
~iles from the Leeeown Pesticide Site. T:anspor: would be by licensed
~aulers 1n confor~ance with r.egulations of the U.S. De?art:nent ~f
T:ansportaclon (DOT) and also 1n accordance with the ~PA Offsiee Disposal
?~~1c1 (EPA, Dece~ber 5, 1985). ~n option for tr~at~ent of soil prior to
disposal has also been included.
Figure 18 provides a plan view of areas to be excavated from the
pesticide pile and ~ixin~ areas. Ancillary construction has also becn
shown. In cor.junction with this alternaeive, contaminaeed soils frolL
beneaeh to'! packin! s;..ed would be excavaeed and eransported offs1te for
:isposal, with or ~ithout prior treat~ent. ~ecessary supportin! construct10n
actIvfl:ies (1.e., i:lprove_nt of haulage route!!, and surface watet-
controls) and site restoration requirements do not ~iffer from tMose
specIfied fer Aleernaelve 5 for ehls area.
An antlcipated 28 cublb yard. of ~ontamln.ted soils will be excavated
from chis siee. As noted 1n Section ~ reeoval of drum=ed and powdered
. ?e9t1cldcs, as well as coneaminated' flooring and eimbers from the eueern
portlon of the packing shed, will be undertaken In conjunction with this
re~edlal action.
~-7.
Remedial Action Alternative 7 - Onslt. Treat:lent:
This remedial action alternative l~corporates an 1nnovative technology
for destructlon of pesticide contaminatl~n in soils. This level of
remediat10n would conforti to Category V, as outlined in Section 3.1, for
e~e pesticide contaminants. Oestru~ti~n of ehe onsite contaminants (i~e.,
OpT and it3 ~e:abolites). can ~e 3chieved by anaerob1c biodegradaeion in
soecially prepared treat:Dent plots.
Treatment and/or destruc:I~n of the wastes on site 1s desIrable 10
that dedicatIon of lands i" the site vicinIty for disposal of ehe wastes
is ta=porary, no waste transport from the source areas i5 required, except
for transport of two loads of 90il from the packin! shed to the Robinson
~roperty, and no hazardous waste disposal capacity at offsit. locatlons
15 necessary.
As shown In Fliure 19, a s1ngle treat~ent cell would be created on .
~~e Robinson properey, in t~e general vicinicy of the pesticide pile
~rea. Construct1on activities would be very 3i:D11ar to those i~~ncif1ed
i~ Alternatlve 5 for the onslce landfill. .!he small quant~ty of ~~ntaminate~
so~ls at the packing shed (about 28 cub1c yards) would be incorporaeed
into the e~eat~ent cell ~ith soils fro~ the pesticlde mi~lng area and the
~estlcide pile area (about 3,500 cubic yards). Some add1Clonal 'Iolume
-------
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(BIS!INC OHAINMif **T
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QNSITE 1BEATMENI AL1ERNA1IVE 7
ANAEROBIC BlOOEGRApAT(ON PROCESS
IEEIOWN PESIICIOE SITE . LEE"
Figure 1ft
JOO
JOO
-------
-32-
would be required for contaminated portions of access road~ and
decontamination pads.
The central treatment cell will consist of a clay bed, constructed
on a graded area. Organic nutrients will be added to the co~taminated
salls In the cell to enhance rapid er.haustlon of available oxygen via
cx1dation. The mixture will th~n be saturated with water, and covered
with a membrane to maintain saturation and retard oxygen pe~etratlon
into the cell. The degradation of contaminants will be monitored
periodically durin~ the traatment process to define. the endpoint. Sln~~
this is a passive treatment pr.>cess, there will be minimal attendant
cperation and maintenance costs.
Ancillary construction at each of che three ar~as, as well as
restoration requirements for the excavated and disturbed a~eas, are
1dentical to those specified for Alternative 5 (Onsite Landfill).
O.
Recommended Alternative
Section 300.~8 (1) of the National Contingency Plan states that the
appropriat~ extent of remedy shall be deter~ined by the lead agency's
selection of a remedial alternative which the agency determines is cost-.
effective and which effecti..,ely mitigates or aUnimizes damage to and
Drovides adequate protection of the. public health, welfare and envi ronmental.
In selecting a remedial alternative EPA considers all environmental laws
that are appHcable aad reUvant. Based on che evaluation of cost-
effec~ivenes8 of each of the proposed alternativl!s, the c01ll1D8nts received
from the public, Inf~rmation from the Feasibility Study and information
from the West Virginia Oepartment of Natural Resources we recommend that
Alternative No.7 as described above, be implemented. at the Leetown
P~sticide Site. .
!his.se~ected remedy will ~e designed to eliminate DDT aad other
pesticide contamination through oasite destruction of the chemicals by
anaerobic biodegradation. .
Destruction of these wastes onsite Is a desirable alternative In
. that dedication of lands In the site vicinity for treatment of the wastes
15 temporary, waste transport from the source ~reas over public roads.
1s'l11!1.ited (two truc.k .loats of contaminated sou. from the packing shed to
the treatment bed wtll be needed) and no hazardous waste dispolal capacity
at an off31te a~RA facility will be necessarY.
A single. treatment cell would be constructed on the Robinson property
in the vicinity of the pesticide pile area (Figure 1?). 'ntls treatment
cell will consist of a lined bed, conseructed on . graded area. Organic
nutrients v:ll be added to the contaminared soils 1n the cell to enhance'
rapid. exn~u~t~on ot available oxygen by oxidation. The mixture ~ll be
saturated ~~th waeer, and covered with a membrane to maintain saturation
and retard ~xy~en penetration Into the cell. The d~~radatlon of contaminants
will be monitored ~eriodically during treatment to define the endpoine.
In the. pest1cide pile area an access road will be required from Route
1.5/\ to the edge of the work area. 1'hisroadway will be 350 feet 1n
len~th a..nd 15 feee 1n width and. will consist; of a 1:!-1nch layer of gravel.
-------
-)3-
A parkin~ Lot ~tLl be ~equ!red ~ith space !or about 5.vehicles near
Route 15/1. !his area will also b~ surf~ced witr. graveL. .
A decontamination pad will be ~equired to decontaminate aLL vehicles
exiting the area. !his pad. wiLL consist cf a 12-inch ~raveL Layer ".,ith a '
30-~il Qembrane underlayment and wiLL be situated near the edge of the
working a~ea. Its dim~nsions will be approxi~ateLy 20 feet by 40 feet.
Decontamination wash wtLl be coLlected afid will be transported offsite
for treat~ent and disposal in accordance with the EPA offsite disposaL
policy. lhe pad itself will be disposed 1n the capped deposit during
'site restoration. .
It will also b~ necessary to construct an upgradient surface water'
diversion channel to controL surface water runoff from entering the ~ork
area. Construction of this channeL is anticipated to involve excavation
or 295 cubic yards of so{l~
A diversion channel -.,iLL be required to divert runoff that ~ouLd
normallY flow in the nacuraL drdnage adjacent to the pUearea during
the period. necessary to excavate conta~inated sed.i~ents ~ro. the drainage.
Constr.1ction of this channlll is anticipated to require excavation of
abou~ 3.330 cubic y~rdsof soil. Lnad~Ltion. an 13-i~ch layer of rock
. (1,210 cubic yards) will be required. to stabilize the channel to discourage
flood1ng during significant rainfall events. The stone protection will
pro~ide i~med.iate erosion contro,l.
A sedi~entationchannel will be created. by excavating about 1,650
cuoic yards of soil between the capped. area and the diverted stream to
collect runoff and pr~vide for retancion of suspended. sedi~ents ~urlng
the course of che excavacion. 'nte ,ed.i-ntation channel will provide
,.ad,e~uate detention seorage and 'ed.i~enc volUM for che 25-year design
stor~. in accordance wich !ederal hazardous ~a.te landfill regulacions
(RCRA).
.
.:
. Restoration of the excavMtion ac the pesticide pile area will require
approx1=ttely 2.220 cubic 1ard. of topsoil and backfill soil to achieve
proper grades and reestablish positive site drainage. A?p~oxi~ately
L70,700 square feec (4 acres) of surface area will require revegetacion
at this site. . .
For the pescicide ~1xin~ area supporting construction activities u~der
this alternacive are s1~llar to those specified. for the pesticide pUe
area. these include an access ro~d from Route 1;/1 with parkin; facilities,
a decontamination pad. and surface water contrQls. as noted. below:
..
Access roa4 - approxi~ately 100 fc x 15 ft
.
Parking area - 1,250 sq feet
..
Decontamination pad - 800 sq ft
.
Surf~c. water diversion (encirclln~ the work area to intercept
run-on) ~xcavation of ~pprox1=atl!ly 250 cubic yards of soU will
be required.
-------
-)i.-
~iversio~ di~e a~d sediment control
A di~e of about 2S~ ~: in length will be constructad along 3all
Sprir.g Run andwill r:ont1:'\ue along the eastarn and 'Jestar"lends or'the
~ork area. Approx1~ately SZO cubic yarjs of soil fill w1~1 be requir~d.
The t)ur?Ose of this dike '"i 11 Je to prevent (loading of the work area
tram 3elL 5prtn~ Run during the excavacion of concaminacad soiLs. A
sedi~ent3tion channel ~ill ;e conscruc:ed ~1thin the di
-------
-35-
1<-3 of this docu=ent (Q'Ji\ntit.1cive RisKs). This target conce.1tC'3tio', is
~uch lower than would be requi~ed Eo~ der~al con~act (3,~00 ug/~g)
prl=arily bacause of the greater adsorption of t~ese co!U?cunds :~rough
tha tunss and the gastrointestinal tract then through :he skin. ~eeting
the 10-) inhalation risk wo~ld be equivalent to the LO-6 car~lnogenic
risk for de~al contac~. !he action levels set ror contamination reduction
are less t~an the background levels round in the ~eetown Orchard areas.
The risks assocla:ed
are somewhat: 6reater
therefore our target
background leveLs.
with teetown's orchards under the-exposure scenerio,
than 10-5, (actual average risk 8.2 x 10-5);
leveL will reduce the risks to a point greater than
Th~s alternative will not remediate arsenic or lead contaminant
levels fo~nd in the soits of the three remedial action areas. The levels
of arsenic and l~ad in these areas are statistically comparabLe to typical
average Levels found in U.S. orchards. . .
Table 17 shows the levels of arsenic and lead d~tected in the areas
of concern. ~is table shows that the arsenic and lead levels that are
exhibited Ln the Robinson Properey (non-disposal) areas are similar to
those levels fouad iN the pesticide pile area and the mixing area.
However, the average concentration of arsenic and lead found 1n the
orchards that are now the USF&W properties are somewhat lower. This 1s
explai:1ed by the age of the orchaJ:'d areas. The orchard that olTee occupied &
the Robir.son Pro~.rty area was oLder and more extensively used than the
orchards that spread over what is now USF&W lands. Therefore, the
accu=ulation of lead arsenate fa pesticide) 1s greater in this area.
However. the risks associated with these concen:~ations of arsenic and
lead are within the sa~e order of ~gnitude fros the old orchard to the
new orchcrd (or fros the Robinson Property to t~. USF&W Property). This
is unl1ke the r1sks frolll DDT and its IDetacoUtu which wa~ an order of
ugni tude higher risk level at :he Robinson Prof8rty disposal areas than
in the Orchard Background areils. Therefore it can be concbded that the
arsenic and lead derived Eros histori~al Lead arsenate spraying froG
agricultural activities and is somewhat consistant over the orch~rd areas.
On the other hand the contrast of DDT Levels and risks between the d~sposal
are3s and the orchard background areaa indicates that this elevatton in
the disposal areas was caused b~ non-agricultural circumstances. For the
~estictde pile the cause i. .~dtcative of the dumping incident while in
the pesticide ~1x1ng areas (including the packing shed) the cause see~s
to oe from historical sLoppy housekeeping.
~
~.
Operation and ~aintenan~e (O&M)
Operac:ton and ~a1nter.ance activ1tt-.s for this site will be ',ery
li~ited. All sampling to verify degradation of the treatment bp~ 50ils
is considered part of ehe remedial action and will be fund financed
until the remedy is considered complete. Upon reachin~ conta~in~nt tar~et
tdvels and/or the re~edy is officially ~ompleted, the treat~ent bed will
be e~cavated and distributed 6ver the area of land near the constr4ct1~n
site (restricted to the Robinson Property). Subsequently this aloea' will
seeded fo~ reve!etation. All temp~:ar1 ancillary construction will be
~~moved at ~his time. These act1vitie, will al.o be considered part of
.~G rp.medY and eli~ibl. for tr~st fund monies.
- .
-------
::'",)caCl )1'1
Orchard backgr~und
(::snw Areas)
')rc:hard 'Jac:kiJround
(Roblnson ?ropercy Area)
'1i xi ng Area
?estic:ide Pile Area
Location
Orc:hard background
( US nw Areas)
Orchard background
(Robinson Property Area)
'1h1n~ Area
Pesticide Pile Area
~:. . .1..
'!'a,le l i
Arse~ic and ~ead t~vel~
l~ l~et,)wn ?~sclcidd Scud~
(c~nc:e~crl:~~ns ~n u~;~~)
.~s. h~~o!
\')-33
ll1:'1~3
Z3-110
21-759
?b Range
t
36-)4l
:. i 4-991 "
104-328
44-1,040
Avg' .
Concentr.
3&
1 I ~
62
l37
Avg.
C,~"centr .
2'J9
712 .
199
304
Deteccion
Freoucncv
7/7
2/2
3/ )
15/15
Deteccion
Freq'.1ency
7/7
2/2
3/3
15/15
._-\~~us:~r.!
.\vet'a~e
~ 1
11~
6!
91i
Adjusted
Averaqe
217
732
199
267
. Adjusted average ~btained by eli=1nati~g the high "and low sample
concentration, wher3 significant.number ~f sa=ple, allow. "
-------
-36-
The EPA 'Jill thel'\ u:1dert~ke operatiol'\ 'and ~ai:1tena:'\ce ac:ivities for:
a ?eriod or one year. These actioC\s -ill. consist or lr.spectiol'\s and
possi~le landscaping (if needed) of the seeded ar:ea to insure a ?roper
and healthy vegetation gr:oweh and semi-annual ~round~ater sampli:'\g i:'\ the
monitor:ing ~ell neework cOl'\structed around the treat~el'\e ~ed area. These
samples should be al'\alyzed for: metals and ~eseicides only. .
Due to the c~ntam1nant destruction c~pabilities'or t~is process, and
the adsor,;)in~ nature ot the site contaminants to aClbient soi1,- it is
anticipated that state O&M activities -ill not last over: two years (1ear:s
3 and :. followi:'\g remedy comp1ee~on). These activi:ies _i:~ consist of
mO~lto:ing -ell samplin~ (se~i-annually) for ~etals and pesti~ides and
?eriodi,: inspections of :~e :reat~ent area (Robinson Pr:~perey ) eo ~onitor
the veg~e3elve cover. The coses for these actions have 'Jeen ~sti~ated at
510,000 for the firse year and 57,500 for the second. All O&M activity
w111 be ne~otiaeed and approved in an executed State-Superfund Contract.
between EPA and t~e State of ~est Vir:ginia for this si~e.
R.
Comp:iance with Other Environmencal law~
R-l.
General:
The r:emedial aceion alternative was evaluated in the =ontext of site
remediation in compliance with the ~ational Oil and Hazardous Substances
Polluti~n Contingency Plan ~~CP) which requires that Federal, state and
local laws and re~ulations be considered.
Applicable Federal regulations include the following:
o Resource Consev~,1on and Recovery Act (RCRA), CFR Title 40,
Chapter 1, Parts 264 and 265
o Clean Water Act (C~A)
o Executive OrA~~ 11990-Wetlands Protection
o Executive vrde~ 11998-Floodpla1n Protection .
o .Occupational Safety and Healch Administration (OSHA) guidelines
o Depart~ent of Transportation (DOT) hazardous materials transportation
re~ulations
State .reg~lations applicable to hazardous and soLid wastes and
~onstruction ac~ivittes that may be applicable to the selected remedy
found in the followtnS sactions of the West Virginia Administrative Rules:
o
Wese Vi r~in1a Department of ~acurai Resources (WV~NR) ,Chapter
20-SE, "Hazardous Yaste~ana~ement Regulations" (:985).
Commissioner of High~aYI. Chapter 30-5~, "T~ansporation of
Hazardous W.1Stes by Highway 'transportation" (1985).
WDSR, Chapur 20-5F. "Legislative Regul.1tions for SoUd WastP.
:1anagement" (L984).
Surface Water Resources Branch, Chapter 20-5 and 20-5A, q~equirements
C,.J'J~rnl ng Water Qual1 ty Standards" (1983)
o
't.
~
.1
-------
-)i-
3ased on a ~e~ci:1g '.,ri c~ r~presentacbes <)f the Jer.'fet"son C<)unty
Commissioners, Jefferson Count? Depart:nenc ,)f :;ea1~:" ar'ld Jef:u$on Counc'l
?~anning Commission, ic does noC appear t~ac Jerf~rson C~uncy ha~ a~y .
regulations In addici:'1 to che scace r~g~lacion~ ioverning c~e ,r~~edia1 ,
action conr:.emplaced at che Leeto..m E'estidde Sice.
R2.
?-e50ur~e Conservation and ~ecovery Acc (~CRA):
~e desi?;:1, construc:ion and operHion {)f che pLoposed t:r'~at::!e!'lc ~ed
i~chis opcion will ~eec substanciv~ requir~menr:.5 ~r RCRA Par( 2~~
Subpar: !<, Surface !:npounc~ent ':!.e,;~13tions and Subpart F I Gr.)und..ac~r
Prat~ctl0n Regulations. . .
All wor~ ~ercalnl~g co r:.he above re~ulations~ or si~i1ar state.
standards, will be clo~e1y coordi~ar:.ed with the regulacory offi~e wi chin
che Scace of ~est Virginia D~R and E?A's RCRA Branch when necessary.
R:3.
Wetlands/Flvodplains Assessmenc:
Wir:.h respect to environ:nencaL co"sideractons, emphasists placed'
upon whether the action co oe caken Wille)(ert detrimental effeces ;:'1.
. environme~tal values. In particular, these concerns ~elate co l~~3CCS to
sensitive habitats and unique species. In addit~on, the degree or physical
alteration to the floodplain configuration must be consldered. F~deral
legislation mandating evalJation of the!e lssues may be found in Executive
Order 11990 (Wetlands Protection) and 11988 (Floodpla1ns), as well as ln
Appendix A to 40 CFR. Part &, which contains a statement ~f procedures on
floodplain manage~ent ana wetlands pr~tect1on as a adjunct to the ~aclonal
Env.ror.mental Policy Ace (~EPA). !he ~EL-\ requires that alll'llajor Federal'
actions consider potential environmental i~pact in a formal assessment.
Rowever. actions at CERCU sites were admin1straci"l!ly excluded from the
assessment ?rocedures under ~EPA. with the stipula:ion that the RI/FS
process addr~ss environmental impacts 1n a manner that. is ":unctionally
~quivalent" to the ~EPA requirement!. .
A primary ~oal of che weelands and flood?lain 1e~islatlon ..as co
require F~der11 a~encle$ co justify t~e n~ed to underta~e a specirtc
~onstruc:10n activity wtthin a wetland or :loodpla\n, as opposed t~ in an
adjacent irea of lower e~vironmental sensitivity. In the context 0f
CERCt.A aceions at th~ Leeto"," Pesttcide Site, a porelon ofche arus to
~e r~oediated already L1e ~ith1n che tesrr1ceed zones, and the question.
ac~ually becomes oae of balancin~ whether short-term detrimenc associated
~th r~medial construction actlv1tes within the floodplain or wecland,
~111 be offset byehe l~n~-te~ Jeneflts ~alned via ~itl~ation of d
co~cam1nant ,ouree.
~lth respect to the Leetown Pest1cide Slte. the pe1t1c1de m1~ing
lrea lles '~th~n areas identlfied JY the Federal E:ner~ency ~an3gement
A~~ncy (F~=1A) ~s c:Jmpone:1t5 0: the 11)1)~year floodway or Bell Spri:1~ ~un.
,.
-------
-38-
.Jo'liously, i: is not possible :0 consider r~:edia.1. a~::on -::hout:
unde~taking construction activity -i:hin :he :~ood-ay. 7he cJn=~?t~a:
desi;n for the selec:ed re~edi~l al:ernati~e ~as :~cor?ora:e~ ~rote~::o"
against potential :~oodi~gduring co~s:ruct:on, and has ~lso propo;ed
:leans or surface \,;~,H' control to ?re'/e!1t or ~i t:igate excessi':e sed:'0e~:a
or :~e receiving streacs as a re~ul: or ~art:h-~ovi~g act:ivit:i~s.
:he ul:i:ate location of t:he onsit:e crea:~ent bed is ?roposed :J ~e
-ell ~eyorid :he li~1t5 of the :OG-ye~r floodway, and r~s:oracion of :he
~xcavated areas -ich1n che :~oodways has ~een proposed :0 establisn a '
surface :opography that wi:1 ~e consistent with si~e drai~a~e pa::er~s
and ;JtlJ. not pose any future i~pac:s t:o t:he :looc'Ja".
EPA's ~EPA Compliance 5ec:ion has established that :wo of the t:hree
recedial s:.:~s arr located ~i:hin wetlands. 7hese areas are :he ~1xing
area and t:he pesticide pile ~~ea. 7he wetland is the Bell Spring Run and
:ributary :~oodplains~ .
Because of :he seler.ted :~medial action will t:ake place in t:his
'Jet~and, an assessazent of :hese ac:ions :!lust be 61v.', in th1s document.
:'he wec',ands assessment =onS\:HS of five requirementJ wh1ch oust ~e
addr~~sed: .
l )
1)
the reason why :he action must be taken in a wetland
a descrtption ot significan; fac:s considared in mak1ng this
decision
a sta~ecent indicating -hether the proposed act10n confor~s
to state wetland procec:lon scandards
a desc~tDtio~ of the sce~s caken to ~nl=ize ha~ co che
wet:and..., and
'a descri ptlon of how the action affec.ts Che values of che wetlands
-
J)
:.)
5 )
~e racionale for supporting 'Jetland ,excavatlon to i~ple!"lent :,e
recedial action is chat it is necessary to remove conta=1n~~ts from the
soi:s/sedt3!nts in order to el1m1.nate potential threats to che public
health. ~i:h r~spect co this ;1te, the cwo areas (Jf chree) that are
considered :or :,emed1atlor., already lie wichin che designated werland
area. It would ~ot be possi~le CQ consider any cype of remedial action
'Ji:hout undercaki~g construcc10n a~:ivities -~thin chac ~e:l~nd. Therefore,
except for a no-ac:10nalternacive. taking action wich1~ che designated
-etland is unavoid~ble.
Sign1:icanc facts constdered ir. ~aking the decision co :ake recedial
action have already been discussed in th1s document. ?ar:1cular ecphasis
;or action 15 placed in the Hea~ch and EnvirJnmencal I=pac:s Sec:ion
(Sections K-lr; K-lg; K-lh; K-2 and K-3) of this do~c~ent.
C'l~rently cherI! are no specificSca:e ~etlands proteccion standards.
:n :hc absence of State regula:ions, SPA suidellnes In wetlandprotec:ion
~:l be Eol~owed whenever and wherever applicable. Sceps will be undertaken
~uring design and i=ple~nt~:lon of :~ts alternative CJ ~1ni=ize :he
::lpac: of conscruccion ac:i~i:: on the -etlands. Ancillary construction
5::,uc:ures needed for ?rooer i~?lccencacion of chis al:ernative are
~~=?orar: for che =os~ par:. rne surface waCer diversion channel, thac
-------
:t..l!1=':: ':'~.
\'a::Je
:-!Y~";':'J~Y
~a:=c
)\.:o:~:y
:'.)cd c ~ai :\'-
~;u:t'icnt :yc:cs
71abi :ac
30c~ o~cono:ui C
7a::e ~.j
::pac: J: ~c~edial Ac:~.)~ i:\
at ~cetJwn ?esti:i~c
~c::J.~~S
:Jl:ac:
.'.
....
J
.
.
....
.J
:-eC:'.11 :::Ie~t.
~any of these ~ffects ace on~y short te~. Stream substrate and
~enthos sho~l~ recover by one growing ~eason via sedimentation and
I
:.::~~'=
a. S~l5i~:
dr:-?c: In
::Jod :')~t:)t i: ;:JQlld ~3
:emo\'ea
~. :\0 ~=pact CJ ~:Juniwat=:- C'clilsc~acge ~ue
to ~arst tcC'rai:\ .
'- .
~~~uc~d ~hor~:i~e
a~choC'~~~ ~y eli~i:\at~~~
veget3'::':):'\
a. SutC'ie~ts :emoved
~. :J~:.cants :-emovec
a. ~r~::Iary producers :emoved
~. ~ecom?osers:detrit~s cemoved
-' nutrient export reduced ,
d. seco~dary produce:, ~~11ization reduced
~. transport of t,oJClcants in food chai:'!
removed
a. substr~te removed for benthic 1nver:e~rices
~. roosting structure and forage species
:":::Ioved for ~irds
a. no,:~pact co passive use'
......
-------
-39-
di~~~:3 ~acural ::ow away from ~ro7-osed exc3va~io~ 1~eas ~ea~ ~~e ~escicic~
?lie area, ~ill ,e ?er~ane~t. This is ~ai~L: d~e CJ c~e :3CC C~ac ~e~ovi~~
:~is scruccure ac :~e e~d of conscruc:i0n aci:i~i:i~s ~ay cause ~ore ?r a
$edi~encacion ?rob~e~ downstream :hac ~oulj :e ~cavi~g ic in ~lace.
3~cause c~is scruc:~re ~ill ~e pe~anenc consideracion ~il: ,e ~:~en c~
~i~i~g ~~e ,occom of :~is c~annel ~i:h a :aterial :~at .i~~ :acilita:e
:~ve~e:3:iJn ,y ?r?viJi~~ an arci:i~ial rooe 3YSCe~. An~ r?ads c~at ~re
;:.aced :0 ,e C'):-:5:r'Jctec :or chis 3c:i'Jn loii:l':H~ ~e5i5!':ed eo ::li::i:i:e' ::-:e
i:pac: their c?ris:ructi~n _uu:d ~a~e ~n the ~e:land area. )n~y ?hysical
':~sh cleani::; ~ec~ods ~iil je e~plQ:e1 .hen ::ee~ed, ~nd any re~-~etation ~i:l
';e done '.rich Mcive to:ecland species, if ~ossi:,le. ~e ac:i"ons ?rJpos~d i.'" cr.e
-et~ands ac this site have a greacer ?osi~ive ~a~~it~de or i~pac: for c~ose
.eclands than ne~ative i~pact. ~xis:in~ contami~acion or ?est1~ides .~ll
~e destroyed and ca~en ouc of :~e biogeoche~ical cyc~eof ~~e environ~ent.
7able 18 di3plays che i::!pact Ji ffere:'\c =,unctions ::Ia:' ha'v'e 6n che wetlands :'~l
:uescion.
s.
Evaluation of Alter~ati~es ~oc Selected
The ~o Action alcernacive is required co ':)e cO:'1sider-ed' in c~e ~C? as
a ~aseli~e case. ~nder chis alcarnatl...e, no wor~ will be ?p.r:or~ed :0
i~orove sice conditions, and rece?cors '.richi~ che study ar-ea .rtll continue
, :J be suo;ecc co edsting condi cions.
\
I
. ~~ SCP reaul r-es reme~~al. ac:tion c" be caken at CERCL\ 91 tes i. n
or-~er- co "preve:'\: or ~i:'\i~i%e che release of hazardous subscaac:es. so
that che? do not .~i~race co cause substantial dan~e: co present or fucure
?ublic heal:.h or 'Jel.fare. or co che envi. ronment." Three source areas
~a'Je bee!! idenci:1ed which exhibic contaoinanc 1e'/els subst,lntialty in
~x=ass of local or nacional 'ack~round levels fQr jgriculcural or orchard
areas. !~ addition, che ?otent1al exists for unacceptable healch r-isks
to :ocal residents U chese areas are brought 'jnd~r ~anagement fer crop
production with attendant cil1age. . .
~erefore. che ~o Action alcer~ative ~ould leave contaminants on
source areas in excess of :'Iorul background levels as ~ell as i n ~xcess
of those suggesced by rel~vant environmental and public health guidelines.
:~ addition to s011 erosi~n. any ?Otenctal dis:urbanc~ of the soil
..ill release dust. resulcin~ 1n boch 'der~al a"d i:'lhalational/ingestional
ex?osures. There 19 no ind1cacion chat this ~as'oc:curred in che past or
:~at it ~ll occur in t~e future. ~owever, the pocantial exists for
chan~es in present land 'Jse at the sourc:e areas whidt ~ould 1nvclve
:illa~e of these soils.
"
Althou;h casual intr~~ers and trespassers are not vie~ed as rec:eptors
at chis sice, Ear~ an1~ls could regularl~ cooe inco concac: ~ch the
contam1~ated soils. ~orses. and possibly dairy caccle. could graze on ,or
~ear the source areas and c'ere~y ~e exposed :0 pesticides in che soil or
~~ :~e v~~e~3tion. .
-------
-~:)-
~e ~ost critical ex?osu(e ~at~~ay and s~bsequenr healch risk at ~~
, si:e is c~e inhalation ~f and de(~al c~ncacc ~ich'co~caoinated soits
~u~ing a~riculcural ac:ivicie~. '~any of :he ~esticides decected i~ c~e
50i:5. are knoW':\ or sU$pec:ed huean car::i:'lo~ens. ~esidual .leve.ls of
~esti~ides in the orchard areas are :y~i::al of ~rch'rd areas throughout
che ~nited Scates. However. che pesticide pi~e. pesticide ~ix1ng area,
and c~e pac~1n~ shed exhi=iced levels of ~escici~es chat ~ere subscantia:
in excess 0: :~e :ocal a~ricul:~ral or orchard levels.
!~ addition :0 this route ~r ex?osure, che potential for future
5round~at~r contamination ~as ~val~ated in the Rt. Detailed calculations
.~re ~resented i~ che ~t a~d are summar1zed herein. :heoretical .leachate
:once~~~acions ~ere developed, for the ~axi~u~ concentrations of ~.~'-ab!
and :oYa~he~e. ,ased on soll/secUClent adsorption coefficients. Travel'
;i~e t~rou~h t~e unsaturated tune and theoretical ~ater table input
concentrations ~ere predicted using an unsaturated zone assess~ent model.
~esults of th~s ~ocaLi~g indi:ated' that approxi~.te11 250 years
would elapse before the DOT reached the water table. However, che
conc~ntraticns ~ould be so low that i~gestion of the actual per~olate
'-"ould resu.lc ill a !i!"k of 3.7 x lO-7 (or l additional case of cancer 1:\'
an exposed populat10n of 2.7 ~il~ion people).
Arsenic re~ins bound tQ the soil particles and is not likely to
, I
~ove into the groundwater within the observed ~ange of pK. Arsenic ~as
~ot detected at concentrat1~nl in excess of the laboratory detection
:1::11t in any of the groundwater samples ':oll.:cted at chis stee.
..
Ic 1.9 evident t~at, even under worst-case condi:ions, there is lictle
apparen,t pocent1al f~r groundwater' contamination at the Laetown Pestic1de
51ce.
~e ~enerat10n ~f fug1cive ~ust
'reati~g any s1g~if1cant risk at the
:~ndl:ions, .the g~eatast risk (4.4 x
?ile.
from the three sourc~ areas is not
present ti~e. ~nder worst-case
lO-8) was presented by che pesticide
~o Action 1~ the source areasw1l~ continue to ex~ose fa~ an1~als
grazi:'tg th~"e areas or eaclng slla~e grown in chese areas. . I: 1s dlfficul:
':o.,uant1~y the risks to far2 ani:uls, but ex;iosuras c~uld occur ~ither
through der=al contact or through ingestion or vegetation that has taken
J~ pesticides.. Human eXj)osure via through this, route is considered min1:nal.
For Alternat1'/e 2, :10 Action-~onitoring, would present che sallie
, ?cce~t1al public healc~ r1s~s as ~escrloed 10 the ~0-Act1on option.
:-Iowever, a wltl-':Iedia salllpl.ln; i,rograaa ~Ul be established for early
~eteccion of any ::1i~ration of co"taminants 1" che environment.
Al:ernative 3 involves capplng the contaminants, after consoLidation,
.r1,:h a sollcover. Sln~e the 9Ca~e re~ulations f~r. t~e disposal of
'~zar:ous substance~ are ~o~ewhat :o(e stri:'tgent chan the Federal RCR~
~:and~rds, all St3~~ siandards ~ould ~Ot 08 !ulf11led. Due,in part, to
:he j)resence of !':i~hly fo.lded caroonate bedrock ur.derl:,in~ the Robinson
'r~:er':1, c~~ ?roject.area does ~ot ~ee~ all :onaitlons for 9icin; a
?ec~nent hazardous ~aste facilitY, .
-------
, ,
.-""...-
~i:h ~especc :~ ~3~d'us~, the conscruc:!~~ ~~ ~ c3?=ed de~csf: ~ou:~
~=qu!~= a ~O:1~-C~~ ~eSp.~'aci:Jn or l3nd ');'1 r;~e ::b:,i:"1so:1 ;J:'");:Jen:,. ~:1 ~:':c:'
:J ;r")cecc c~e i~cegricy or c~~ cap SYSCe~. Ad~i:1ijc~3:!~~ conSC~3;~:1
~ou:j ~e requi~~d r~~arii~~ f~cure us~ 0f chis ~rea.
Alc~rnaci'le ~ dlr~c:s chac a ~ulci-~edia C3p ~~ c:JnSC=uc:cd In :~e
~~:i~son prJp~:':: ~ver :~e consoli:aced cJ~:a~i:1ac~d 3~i:l. 7~is
~::e:'~a:i'le would i:1clud~ ~osc Jr :~e :e~i~:1 r~c:~~e~~3:f~:1s ~e:3i:c~
i~c~e c3?pi:1g :'eg~la:ions ~:1der ~CRA. As i~ Al:=r:1aci'l~ J C~is J~Ci?n
~:J~s ~OC ~eec all condi::ons for ~l:i~g a ;:Jer~a:1~~C hazardous .a~:~
facility. ~~ addition ad~i:1iscraci'le cons:rai~c~ or :3:1d use wou~j ~e
'e~~ssary fJr ~~is
Jpti::Jn.
Al:er~aci'le 5 descri~es c::Jnstruccion of a per~aoenc on-si:~ :a:1dfi:l
:'.Jr d.isposal Jf :!'Ie wasces i~ ~ues:i.on. ~is ~andfill will ::'e
-------
Alternat1v~
-------c----.-.-
I. No Actt,)n
2 . No AI: t I on
WI th Monitoring
3. Consol-&date
Contamlnat~d
50118, Cons-
truct Soil Cap
Technical
-- h' a I" bli !.!1_-
Not Ap-pl1cable.
Env. monitoring of
&olls, ..edlm~nt,
surfac~ water and
ground water uslnK
established stand-
ard aampllng meth-
ods. PesttcldelJ
and Iqorganlc m~-
tah ana1ys18
would be pt:rformed
I n accordance wi th .
standard ~thods.
All construct10n
activities In thl~
option are co~mon-
ly p~rformed by
applicable con-
tracto,rs.
t:llvlrollmental
, Concerns
S~dl~cnt~Clon load-
log to streams may
Increase contamina-
tion In stream aedl-
ments. Fish arid
benthic community.
may become more ad-
veul y affected.
Even with no action
r:h~re h 11 ttleap"
rarcnt potential for
grouII11 water conta-
mination. '
- -
Same 8a I. lIowever,
any increaae in
strca~ contaminants
~40uld be detected
an~ mitigative act-
I~ns could be Ini-
tiated.
Excavation of 8011s
would take place In
riparian wetlands
and within the 100
yr. flood plain. The
Impact to this area
1& short-term and
m~asures to minimize
damit~c will b~
IInel.' r l .,\lcn. Tr 8nti-
1'.1 b \0.' I 9
AlcernatlJcs HHlrlx
I.ectllwn t'elitlddc Sitc
Institutional
Issues
No Action clrcumu-
~nt8 NCt' ~Irectlvc
to prevent or mlnl-
ml~e the future rc-
I~asc of hazardous
sublltancea.
Same all I.
.--------
Project area does
not mt:et itll ~CKA
8 it I ng .,.111<11 t lor-s
for a permanent
hazardous waste'
facility. State re-
guiatlona for dis-
posal of hazardous
6ubtitancI'tf would'
nu, t\l> !,..llv m..t.
t'lib II c lie.. I t!\
t:val u<\t luns, I'lih I Ie Cn"'mcht Ii
----- ----
Contamination 8urfdl'c No action WiSS
801ls would n'mal:} nut ,'odorl;ed by
source of potcntlal the local govc:rn-
hcalth risks to Indl- Plent or the local
vlduals who may till pub I te.
0:- disturb the land
tn any mann~r. Farm'
animals who may gra~e
on or near the source
arcas would he eXI)ON-
ed to p~StlctdC8. Any
utilization of theNc
animals (mllklngl
s I aUKht er) ,may paSN
on contamination to
humllf.s. '
Same alt I.,
-----
Wcul.t eliminate pub-
Itc health threat If
Noll cap Int~~rccy Is
maintained. '
--------
No at~tton with
monlc-orlnK was
not tully endors-
ed by th~ local
governlDcnt. Tlw
County Commt:i:;-
loners would pre-
fcr that t:I'A pur~
chase the land
and place 8 reN-
t r I c t Ion 011 the
pruverty. The PII-
bJlc did nut,colR-
Plent UI) chis al-
ternall vc.
No Commt'nts.
t'reNenl
Worlh
$ 0
------
$227,01/0
$-i4 f;tiO() -
I
I
I
-------
T~dll\l ('ill
-~..!..!~~~tivc_- -- _.__t'caslbl I 1-.!1_.---
). Cu,ltlnuiltloli
...
4. Consolidate
- CQntamlnated
Soils. Cons-
.truct Hultl-
Hedla Cap
~. l~onstuct Ion
of Omilte Land-
fl1 1
bA. EXC8v8tiO('-
wi th Offsl te
Disposal at
lIazardous Waste
FacUity
All plannl!d acti-
vities ar~ cowmon-
OilY pl!rforme-d and
can be Iml)lemented
by an I!Aperlenced
contractor.
The rl!qulr~d con-
struction ar.tlvl-
tie. are feasible
and can be Imple-
mented at the Rob-
Inson Property.
Geologic rock out-
crops may pose
some dl fflcuity
during c.:;nstruc-
tloo.
t:xcavation and
transport of con-
taminated s'.)11
i8 commonly l>er-
forml!d an~ Is
jmplcmcntable for
[hili lilte.
Ell\: I rOI\lDenta 1
Co~~-----
port at Ion of packtn~
sht:d IIIdtcrlal to
oftslte dldposal may
be of some concern
It a relea~e occurs
durln~ transport.
Same ali J.
Same as ) and 4.
-franlipo~t of conta-
minated material
would take about 260
truck loads. total-
Ine approx. 220.000
truck miles. Thh
Incrcasc the chsnces
Ino:t~tutlonal I'ubi'lc IItoalth
Issues t:valuatlllll:i
--- ----- ---- ------
Lon~-te~m reserva-
tion of land at the
construction site.
by way of a~ Insti-
tutional control.
may be necessary to
prcv~nt loss of In-
°grety to the cap
b tem.
Allliough cap systl!m Sallie as ).
Incorporatcs all
recommended techni'-
cal design for a
cap. the site still
does not meet all
conditions -tor a
pcrmanent hazardous
waste fact 11 ty.
Long-term land res-
trictions to pro-
tect the cap Inte-
~rety would need to
be Implemented for
this option.
Conceptual design
mel!ts State land-
fill construction
lit anda rdli. Thelic
.tandards exceed
RCRA requirements.
Institutional con-
trols on land use
would be necessary
for thla option.
Siting r~qulrements
for this IDodflll
r~malos an Issue.
All transporta(ion Pot~ntlal risk to
performed by per- public receptors from
mlttl!d transpor- vehicular mishap dur-
tel's. The waste InK trantiport of
would only go to a wa~te6.
permitted COmPIYlng\
haz.ardous walite fa-
Hay result 10 morc
frequent exposure to
81 te remedlat Ion
workers. Would ell-
III10ate public h~alth
risks with land uSe
contrl)lso.
Il'rlosenl
I'uhllc Comments . ~orth
---- -
No Cummcllts.
-----
$1,021,01
No Co;.;;-.;;t--s:---- f-fl-:i~3,OI
No Comments.
$1,965-;6
I
-------
~t.~!nat.!~__. ~-
Continuati,,;\ .>f
/,1.
Techni.~ai \ EllvtrullmL!lItal hu>titutiollal
t'~al>t I" I.~~l.._-- --- on _~:~~:..e 011>___- --- 0 ltiliUe Ii
C.lntillJlilldted I>oi l!i b~ required ,"or
. 0
. tllto ,'nvi rOllment. this option.
Dlid optio~ would
olliy trandfer wadte
from une plac~ to
another.
SaPie as 6.
6-8 Excavat ton
with Offsite
Inclnceration
of Soi 15
~. Ohsite
Treatment of
Soils Through
Anaerobic 11&0-
degradatio:1
Som~quedtion on
total 1estruction
of pesticide a due
to low fuel value
of the IiO~ 18.
Would not elimin-
ate lead or ars~n-
Ic In soil there-
fore residual ash
may need to be
trandported to a
hazarduu6 waste
facility.
8iolo~lca\ degra-
dation had been
..sed to destroy
DOT and other pes-
ticides for many
years. Treatment
Isa known and
accepted aiethod
for contaminant
. destruction. Field
te.:it and bench
sca les tud I.es
would be necelisary
for proper Imple-
mentation.
Only concernd for
this opt ion would be
limited waste m3te-
riald transport from
packing shE:d area.
WoulJ permanently
dest .oy .."ntamlnants
th£refor~ removing
them from the bio-.
geochemical environ-
ment. Concerns in-
volving.wetlands and
floodplal nt> also
appl y L~ dlis
opti on.
Any i ncl nerator
us~d would need to
be RCMA permitted.
Land use controls
would be unneces-
tiary.
.-
Treatillent ce 11
~ould meet all sub-
stantive require-
ments of the RCItA
surf ace i mpoundmcnt
regu~atlons. Land
use controls would
only be necessary
for the tlllle it
takes to degrade
the contaminants.
(Estimated 1-2 ~rs)
. .
"ub 1& c IIE.'
-------
- -
RESPONSIVENESS SU~4MARY
lEETOWN PESTICIDE SITE
JEFFERSON COUNTY, WEST VIRGINIA
MARCH 19R6
This community relations resconsiveness summary is divided into the followina
sec:tions:
Section r:
Section
Section III:
Section IV:
Overview - A discussion of the EPA's oreferred remedial action
alternative and anticicated oublic reaction to this
alternative. '
r r :
8ac~around of Co~munity tnvolvement anrl Concerns - A or;ef
hi story of the COiTiinunitv's interest in a;;crinvolve~ent with the
Leetown Pesticide Site, includina ~ discussion of concerns
raised by community memoers and officials duri,na remedial
olanninq activities.
~mary 0' Puhlic Com~ent~ Rer.eived Durina ~ Puolic Co~ment
Period and AQenc)'Resconses - A summary of ~omments cateQorized
by tODic and fol owed by EPA resoonse!. .
, .
~emaininq Concerns - A rlescriDtio" of remainina community
concerns that should be considered as the EPA and the State of
West Vi rqinia DeDart~ent 0' Na tura 1, Resources (WVDNR) conr!uC't.
the remedia 1 desi Qn and remedia 1 acti on at t;,e Lcetown
Pesticide SHe.
!n,addition to sections I throuahIV, ,a list 0' EPA community rplations
activities conducted at the Leetown Pestfcirle Site is included as Attachment A
cf this resconsiveness summar~
r.
OVERVIEW
The Remedial rnvest1qatfon (Rn ReDort aild the Feasibilitv StudY (FS) Reonrf'
were' released to the DubHe for review and c()m~ent. 0" MarCh /;, lQSM. This
marked ttie oceninq of the comment oef'iod, 'which extentled to Marc,", 27. Ourina
the comme»t oeriod, the EPA ~ecommended a Dreferred remedial alternative 'I"'O~
amonq the s~ven alternativ~s oresented in th~ FS r~cort..
:I".~ recommended alternative was destribed in rletail in Secticn' 3.0 of the
recort as Alternative No 7. This alternative consists o',consolidatinQ
contaminated 50;15 from three source areas int.o a soeciallY-DreDared treatment.
hed and saturating the soils with water to Dromote bioloaica1 deqradation 0' ,
the oesticides. The orOaress 0' the biodearadation win 'be monitored untiT
. cesticide levels Mave been I"'l!duced to acceotah1e leveh. The tr!!at.mllnt berl
will then be disas:iemb1ed and the so11$ will he reoraded to "hand with tMe
5urroundinq area. Post-closure Qroundwater monitori"~ ~~uld be conducted for
t.,.,o years.
1
-------
J .'
-~
Comments received durinq the oublic comment oert~d ~uQQest tha: the Qeneral
oubl;c does not object to the recommended alternative and is suooortive of the
intent to restore the land to a usahle condition. Local officials, however,
obiected to the remedial action ~lternative on t~e hasis of cost. Thev vo;ce~
a ;reference for buyinQ the orooerty in Question, fencinq it, and restrictino
its use via restrictive covenants placed on the deed. EPA refected tMis
proposal on the qrounds that land'acQuisiti.on for the ouroose of restrictino
its use was not cermitted by EPA oolicy. rn addition, EPA Questions the fact
that land use restrictions ,could be ouaranteed via a covenant on the deerl.
II. BACXGROUND OF COMMJNITY INVOLVEMENT AND CONCERNS
The Leletown Pesticide Si'te history ;s believed t'o date back to l
-------
'-
L
Concern that money was seeminolv beinq waste4 in sinQlinQ out the Lp.etown
Pesticide Site for scrutiny when the enti~e county and much of the ~~ate
had been sprayed wi th DOT.
2.
Concern that the RI/FS was oossib1y ~eino oerformerl to advance some
hidden aqenda of the National Fisheries Center, located within the
qeneralstudy ar~a. . . .
3.
Concern that Jefferson County had an unusually hion incidencp c' cance~.
esoecially in younq women.
4.
Concern ~hat the Jeffe~s~n County Landfill had ~een unfairlvincluded in
the study.
I I 1.
SUMMARY OF PUBLIC COMMENTS R£CtaED OURIN& PUBLIC COMMENT ~ERIOD AND
AGENCY RESPONSES '
Comments paised durinq the Leetown P!sticide Site oublir. comment oeriOd are
sum~arized briefly below. T~e comment oeriod was held from MarCh ~ to March
27, 1986 to receive comments from the puhl ic on the draft Feasibil itv Study
(FS). The comments received durino the commentoeriod are cateQorized bv
'relevant topics. At thetim~ of the public comment oeriod. EPA had focused on
Alternative No.7 (Onsite Treatmp.nt) as the orefer?"ed alternat.ive.
Re8edfa1 A1ternatfve P~ference5
1.
The Jefferson County Commissioners suaaested that purchase of ~ne
property and institution of r@strictiv~ ~ovenan~s on the deed to preclude
access and/or tillaqe of the contaminated s011sin the future could be an
effective means of addressinq public heatth concerns. The Risk
Assessment performed as part of the RI ReDort inri~cated that unacceDtable
additional cancer risk would only occur in a situation in whiC"
individuals inhaled dust emissions from ~hese areas durinG tillaae.
EPA Response: Beyond the fact that land purchase fOr the ouroose 0'
restricting access to contaminated areas is not an allowable use of
Superfund monies, the EPA is concerne~ that restrictive covenants may not
,ensure that access is permanently controlled.
Technica1 .1uest1ons/('oncerfls Reqardfnq ~ellf!dfa1 A1ternathes
1.
One commentor Questioned the death to whi,:" oesticidl, contaPl;nat;on
extends in tt:e areas of contaminated soil. and further 'uqQested that a
poss;bl~ means of control would be to Dlnw the contaminated 50i1s under,
below the de~th generally Den~trated durinq normal tt11aQe ocerations (~.
8 inches) .
E?A Resconse: ThedeDth of CJntamination bv cesticides has been fou~d to
b"eabout 6-8 .fnches. atthouah addit:ional inves-tiaation is necp.ssarv In
those areas found to be contaminated at the surface to more creci selv
define the vertical (and hor,zontal) extent of contamination 'or the
purpo~es of taktnq remedial action.
J
-------
~ .
..~~
2.
A commentor wanted to know. the lenqth of time required for DDT to deqrac~
naturally in the environment.
3.
E?A Resco~se:The exact duration required for complete deqradation of
the DOT is not known; however, it i$ known that one of the reasons for
the persistence of DDT and other ~hlorinated chydrOCarbon cesticides is
their resistance to biodegradation. Biodeqradation of these oesticides
is oPtim~led under anaerobic (;,e;. without air) conditions; natural
condi ti ons are predomi nantl y aerobi c in. the surf~ce soi 1 s. One of the
orincioles employed by the crooosed biodeqradation orocess outlined in
the FS is to create an anaerobic environment to enhance the sceed with
which th~ pesticides are deqraded.'
A commentor questioned how the lead and arsenic levels found coincident
with the organic pesticides would be handled bv the onsite treatment
technoloqy. .
4.
EPA Response: The preferred alternative will not re(4'Jce lead or arsenic
levels. The lead and arsenic levels found cOincidp.nt with the most
intensive pesticide contamination aDoear to be consistent with levels
documented by the literature and by field samolfnQ at the Leetown
Pesticide Site to occur in orchard areas. These levels of lead. and
arsenic apparently have resulted from use of lead arsenates as
pesticides. and, there,fore. did not arise as a result of disoosal of
hazardous wastes, but, rather, as a result 0' use ~, aorichemicals.
Those levels found are co"sistant with orchardhackQround revels in both
the Leetown area and ether orchards in the United States. Based on this.
the deci~ion not to mitiqate levels of le~d and arsenic has Deen made.
A commentor requested information reQardinQ t.he contents of the drums in
the for~er Crimm Orchard Packinq Shed.
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5.
EPA ~esoonse: The drums at the Cri~m Orchard contain.d pesticide
mate.rial The EPA presented an overview 0' the contaminant levels found
at each of the suspected sources of contamination. For more deta;1ed
information reqardinq contaminant levers. the EPA referred the Dublic to
the RI Report which is avaiTable at the Charles Town Librarv. as we'l as
in the offices of the County Commissioners.
A commentor asked where the offsite dis'posal would CJccur, if required.
.E?A Resconse: There are a limited "umber of disoosa1
mei pt of hazardous. ma teri a 1 s under the Resourc.e
Recovery ~ct (RCRA). The only sites available in the
are in Ohio and New York. .
sftes accroved for
Conservation and
nort.heastern U. S.
6.
Acommentor Questioned the schedule for future activities, as~umi~Q
aoproval of addit;onal monies for SUDe~fund.
E?A Re~conse: Followinq the close of the cublic comment period, EPA will
pr:eoare 3 formal' Record .of Decision (ROD) identHvinq thl! recommenrled
alternative. As soon as the RGD is finalized and monies become
aV3i1able. EPA w11l initiate desiQn of the a1ternative. Since this is a
rehtively simDle design prOblem, a ceriod of three to six months will tip.
:required for complete des1!:1n. After selection of a const'ruction
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sub con t r a c to r, a b 0 u t t if 0 m 0 nth s w i 11 be. r e Qui r e rl '0 r con S t r u c t ion.
assuming fa~orable weather conditions.
7.
One :cmmentor questioned whether wastes ot~er than those frOM the lee~own
Pestic~de Site could be clace~ in any onsite landfill const~ucted as car~
of remedial action at the sites.
EP~ Resconse: . Any onsite landfill or caoced deeosit would be :onstructerl
with cacacity only q~eat enouqh to house 'contaminated soils anrl ot":er-
~ontaminated m~teria1s frem ancillary construction (e.a., roadwav5,
decont.:mination pads) from the three sites identified. No other
materials would be placed int~ the discosal areas.
Public Health/EnvironMental Concerns
1.
One commentor asked whet~e~ the cumulative effect of al1 oesticides found
at the Leetown Site had been considered in the develo~ment of the risk
assessment. .
2.
EPA Resconse: The EPA i~dtcat~d that the risks had h~en estimated
through a complex modelinq process which takes into consideration all
.reasonab1e contamfnant miqration pathways. exoosure durations. and
exposed populations. and that cumulative effects had been considered.
A commentor questfon~d whether a health study (f.e.. eDiC;emioloqical
study) had been. done in concert with the RIfFS. Other commentors
suqgested th~t there is a ca~cer oroblem fn Jefferson County. oresumahly
as a ~esu1t of the intensive orchdrd deve100ment i~ the area and the fact
that many of the former orc~ards are oresentlv the sites of rp.sidential
d~v~lopments. . . .
EPA Response: EPA indicated that no eoirlemioloqical study had heen
performed. and that. rather than focusinq on cast effects. the attemot in
developinq the risk assessment has been to estimate the risk to both the
general puolic and the envirO'nment hased on CUI'rent levels of
'~ntaminants found durinq the RI. as wet1 as postulated miqration 0"
~hese contaminants to potential receptors.
Th~ WVDNR indicated that mortality records necessary to investiQate the
incidence of cancer in Jefferson County could be obtained via the state
public health office. This is. h~wever, beyond the scope of the present
study. . .
3.
A former resid~nt indfcated that he~ domestic well had ~qone ~ad~ in
1980. exhibitinq a ~kerosene~ odor, and that she was awc!re of fO'Jr wells
which hac become unfit for use in the Leet(lwn area. AlthOUQh the NUS
samplinq 0' her well tn'AuQust 19A4 found no evidence of contimination.
she indicated that the pr,blemwas.most evident in the sorinQ and fall
during hi'}h water table ronditions. This former residen~ comolained 0'
chronic health prob1ems possihly attributed to the 'water Quaiity in the
domestic well. Althou~h this Individual has moved from the Leetown area.
the well in Questior. is still beinq used by the current occuoant of thp.
residence. ..'..
.......
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EP~ ReSDonse: £PA indicate'd that the resident's well hac1 been satl'loled
and found to be uncontaminated. and that no further samolinq had occurr@d'
to establish wh~therseasonal conditions m~y exert an effect ~n the
con~aminati0~ of the well.
4:
Sevenl commentors questioned the man"e!" in which risks had he~n
ce~cl"'1'1ined ana ~sked whettler an "acceotable" level of DOT residual in
scilrad been establish~d.
E?A Resconse: Risks were Qetermine~ on the basis of detailedtl'lodelinq of
t1ie various €XDosure oo!thways. wi th "D~ci fic assumotions reqardinQ the
duration of exoosurP. ar.d tyoe of exoosure (i.e.. <1ermal contact,
inhalation. ingestion) tot"e varioiJs receotors. The actual calculations
, areava;1able in Aocend~x E to the RI RF'oort. '40 soecific "acr.eotahle"
level of DOT residual in soil was found. Action level:;. that is, taraet
levels for remediation of the site to r~duce the risk to an accectable
level, arereportc!d in Section 8.0 of the RI Report.
s.
One commentor asked i' beef cattle had been inclurteo in the risk
asse~sment scenarios. .
E?,~ Response: 13ecf cattle were! nof; scecif~cal1,v included in ,the risk
assessment calclOla.tior.s~ However, the major com."oditv oroduced' from
li~estock i~ t~e immediate site a~ea is milk. Calculations were
performed to demonstta.te tndt the risk to the Qeneral cODulation from
ingesting milk produced from cattle in the site area was wit"in
acceptab 1 e 11 mi ts., .
6.
Ln resconse to item no. 5 of this section. a commer.tor Questioned whetner
milk from the dairy cattle had actually beerl tested. .
EPA ResDonse: Under t~e SCODe of worle of the site investiaation EPA's
objective was to determine whether the Desticide residual lev~ls in the
~ail could produce a health risk via 1nQestion of mi'llc from cattle
grazing 0" such are~s and/or fed si1aQe oroduced 0" these areas. N~
specific authority exists for EPA to enqaQe in d orOQram of monitorina df
pesticide levels In milk from dairy cattle. Perio~ic mcnitorinQ is
undertaken by thl! Maryland and Virqinia Milk Produt:ers Association i\nrt
severe penalties art:! imposed on those mem"€'rs of the association wl'iose
milk is fou~d to contain c!st{cides in excess of the acceDtable threshold
limits.
7.
Commentors asked whether studies had been done to det~rmine the levels of
cesticides which miaht be excected to be found i" ~arden ~!oos. Ln
particular, one former. resident indicated that her 'ami1y aarden had been
adjacent to the Crimm Orchard orooerty to t~e west.
rn addition. comme"tors questioned how the dairy .:attle aca~!ired t:he
pesticides in their systems. "
. .
E?A Resoonse: UDtake of oesticides cy oarden veaetables is soecific to
tii"e Dirtic:ular ...e~etable crOD beinQ considered. EP~ did samcl~ 3nd
analyze corn grain from the susDected cesticide landfarm area. and did
not find cest1cides in the qrain dbove detectanle limits. .,
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With respect to the oarden adjacent to tne Cri~m Orchard, while the
garden may have been adjacent to the orchard, the. most intensivp.
contamination found at the orchard was at the former oackinq shed, which
is located ~n the central oortion of the orooerty, a sionificart distance
from adjacent orooerties to the wesL .
8.
Based on orevious studies, little systemic uotake of oesticides has heen
recorded in" cor;'!. Cattle aooear to acquire oesticides throuqh actu3l
ingestion of contaminated soils.
Several commentors noted that abandoned orchards iw the Leetown area were
now housing develop1nents and Questioned what would haPDen' if the orchardS
within the study area wer~ out to the same us~. -
ill Respon!:e: EPA noted that the only exoos.ure oathwav found in
. conjunction with the contaminant lev~ls at the study area sites to
prOduce an un~cceptable health risk was that of inhalation 0' dust
emissions from tillage operations. If the areas were to become housinQ
developmeni:::;, the same con~iderations would ore~ai1 relative to
activities which would oenerate dust emissions. However, the final ris~
level- presented from ti11aqe ~perations is a chronic level based on 40
years of annual ti1lfnQ and inhalation of the dust oarticles.
Construction activities associated with development would not take place
,over a long period 0' time. Therefor~, the shortened eXDosure duration
greatly red~ces the associated risk.
. Pub Hc. Participation Process
1.
-Oriecommentcr ouestioned whether March 27 was the final date for
submission of commen~s, and also what form the submission had totakp.
'ill Response: March 27 f~ tt'e final date
comments can be either wr1tten or verbal.
contacts for submission of comments were
meeting.
Costs/Funding Issues
for receipt of comments. These
Names and phone numbers 0' EPA
provided to those attendinQ the
1.
A commentor asked for clarification between Alternative No.7 (Onsit£:
Treatment) and Alternative 68 (Offsite Disposal with Treat~ent).
inferring that the only difference was in the hiqher cost of the latter
at ternative ($7M vS - SlM). .
EPA ResDonse: EPA indicated that while both alternatives would achieve
diStruction of the wastes, the onsite treatment alternative would not
require transport of the contaminated soils over qreat distances on
public highways. with the attendant risk of accidental sDil11qe. Onsite
treatment via biodegradation would a150 not require oermanent containment
of the soils, as would be the case with the offsite disposal oDtion.
Even if t.he soils could be successfully treated via incineration to
remove the pesticides, it is 1ikely that the residual ash would reQuire
special handling as.a hazardous waste in view of its heavy metal content.
. I
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-1.
Use of a RCRA-apprOVl!d hazardous waste la"ndfill to store the materia 1 s
would be reQuirp.d. Space at such landfills is currentlYClt a o"emium.
and one of EPA's goals in site remediation is to destroy wastes without
the need for their transport to RCRA-accroved facilities. .
Other Issues
1.
A "umber of commentors indicated that mixinq areas such as those
identified at the former Crimm and Jefferson Orchards during the RI exist
throughout Jefferson County. In particular. one com~entor indicated that
"at least 20" such areas exist. In reference to the Leetown Pesticide
Site. one commentor suqqested that cesticides had been mixed at the
intt!rsection of Routes 1 and 15 and Hocewell Run in Leetown. crocer.
Another commentor indicated that the "larqest orchard in the world" had
at one time operated about 2 miles_south of the Leetown area, occupyinq a
total of about 3.00q acreL . .
EPA ResJ)onse: EPA indicated that there are three separate qrouos
involved in Superfu"d Sites: 1) Site Discovery, 2) Emerqer.cy Resconse.
and 3) Remedial Planninq. Information relative to new sites should be .
directed to the Site Discove,'y GrO!Jp for aDDroDriate action. It would
not be. appropriate to attempt to address each of these areas in
conjunction with the present site. The WVDNR f1Jrther suqqested that it
would be interested i" followinq up on information about such hazardous
waste actiVities. .
2.
One commentorquestioned. whether the prop!rty owner (i.e., Luol a
Robinson) would be reimbursed for temporary or permanent use of her
property for remedial action.
EPA Response: Superfund does not make any provision for comDensatinq
individuals for temporary or permanent loss of property as a result of
remedial action. The EPA went on to indicate that the present instance
is somew~at unusual. since normally the property taken in remedial action
is a part of the hazardous waste site. instead of that of a crivate
citizen (i.e.. the Robinsons). . .
3.
.A commentor asked for definition of the lfability conferred by law on the
person or firm that placed the pesticide contamination on the land.
EPA Response: EPA conducts a search for potential responsible Dartles
T151'Ps) at Superfund Sites. This search .is presently in proqress for the
Leetown Pesticide Site. After PRPs are identified. they are qiven the
opportunity to undertake the reco~~ended remedial action defined by the
EPA following cOMpletio~ of the FS. If. they decline, EPA wi11 take the
necessary action. using monies from the SUDerfund, and will then attemat.
tl) recover these costs from the PRPs.
4.
A ~ommentor asked w~.ther the monit~rinq wells installed around the
.landfil1 woutd be used for further monitorinCi. and. if so, who would Day
fo,. the ana t YSi~.
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EPA Response: The landfill monitorinq wells are ava;1able for use by.
eith~r the WVDNR or Jefferson County for future monitorinq activities.
Mr. L~e Snyder. manaqer of the Jefferson County Landfill. indicated that
the> County Commissioners were stronoly' considerino monitorino. and that.
the cost of analyses would be reduced by focusinQ 0" parameters which
would indicate the possibility of groundwater contaminaticn ~y ~he
landfill. If indications were found that contamination was occurrinG.
then more detailed analyses could be performed to characterize the exact
chemical constit~ents of the contamination.
IV.
REMAININ6PUBlIC CONCERNS
Issues and concerns expressed durinc; the comment oer-iod that the EPA
unable to address during remedial planninq activities include:
was
1.
Concern re~ains that many pesticide mixino areas other than at the Crimm
and Jefferson Orchards nave not been identified and that these area~ may
hdve been or eventually will be develoeed for residential use.
EPA ind1cate~ that information ahout unidentified sites .should be
reported to the EPA Site Discovery Group for aeeropr1ate action. WVDHR
also expressed interest in learninq about such sites.
2. . Concern remains that' human health may have been affected by this site.
One family, in part1cuhr, noted an increase 1n health problems durinq
periods of high water table conditions. and other residents exDressed
concern that the county had a h1oh-1nc1dence of cancer.
. WVDNR indica~ed that mortality records were keDt by the state public
health office regarding the incidence of cancer in the county. These
records are available to the pubic.
3.
The county ~omm1ssioners rematn concerned that federal funds are beina
wasted. They continue to feel that the land ~hould be eurchased and its
use restr1ctl!d.
At this time, it 15 EPAls policy not to use SUDerfund monies to purchase
land for the purpose 0' isoht1nq contamination from ttoe Dublfc or the
environ~ent through total land use restrictions (exceDt POSSibly for the
. purpose 0' human relocation issues). EPA also stated that the aqency's
intent is to restore the use of ~he land in ouest1on. not to olace
permanent constrains on its use. Furthermore, theY"'! is the POSSibility
that the rest.rictions on use may not be strictly observed.
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Attachment A
Community Relations Activities Conducted
At Th~ Leetown Pesticide Site
o
A press release announced the public meetinQ to discuss the uocomino
RI/FS activities. August 1984.
An RI/FS fact sheet was distributed to interested carties. Auqust 1~A4.
o
o
A public info,rmational meetinQ was held at the J~fferson County Court
House on August 23. 1984. '
EPA met with the l~cal public health offiter to discuss samDlinq olans.
November 198~ ' ,
o
o
EPA rnet with county commissioners to advise them of the dve fn.iection
process p1anned for site-related groundwater studtes. AQency oersonnel
also went door-to-door in the immediate study area to exolain the
process to residents who miqht be affected. July 23. lQAS. '
A press release announced the availability of the draft RI and FS
r~ports at local reqositories. It a150 announced the ooeninq of the
comment oeriod and the uocoming oublic meeting, March 1986.
o
o
Fact sheets identifying the oreferred remedial alternative were mailed to
interested parties, M3rch 1986.
o
A public meeting to discuss the
held On March 20, 1986. '
preferred remedial altern.ative was
10 .
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