United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-89/032
September 1989
Superfund
Record of Decision
Doepke Disposal (Holliday), KS
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R07-89/032
J. Recipient1* Accession No.
4. Title «nd Subtitle
SUPERFUND RECORD OF DECISION
Doepke Disposal (Holliday), KS
First Remedial Action - Final
5. Report Date
09/21/89
7 Author(s)
8. Performing Organization RepL No
9. Performing Organization Name and Address
ia ProjectTaaJoWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addrm*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Vs- . ,\
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
V
16. Abstract (Umit: 200 words) -
The Doepke Disposal (Holliday) site is an inactive industrial- waste landfill located
east of Holliday, Johnson County, Kansas. The 80-acre site is within 500 feet of the
Kansas River and lies upstream of the well field and Kansas River water intakes that
supply water to approximately 200,000 county residents. Additional features bordering
the site include an inactive landfill and an active landfill. During the 1950s and
early 1960s the site was used as a landfill for residential refuse. In 1963 Doepke
Disposal Service, Inc. leased the property and operated a commercial and industrial
waste landfill until 1970, when the State shut down the operation. Materials such as
fiberglass, fiberglas resins, paint sludges, spent solvents, metal sludges, soaps, and
pesticides were reportedly disposed of at the landfill. In 1966 fire debris and up to
374 drums of solvents and organochlorine and organophosphate pesticides were disposed
of at the site as a result of a fire at a Kansas City chemical plant. Initially wastes
and residues brought to the site were burned, however, in the late 1960s burning
operations ceased and solid wastes were buried onsite and liquids were disposed of in
two surface impoundments. In 1977 rock material excavated during the construction of
an interstate was dumped onsite and in some cases over the deposited waste. The
current owner uses portions of the site for storage of clay, crushed shales, and
crushed limestone. The primary contaminants of concern (See Attached Sheet)
KS
17. Document Analysis a. Descriptors
Record of Decision - Doepke Disposal (Holliday) ,
First Remedial Action - Final
Contaminated Media: soil, gw, sw
Key Contaminants: VOCs (benzene, toluene, xylenes), organics
metals (chromium, lead)
b. Identifiers/Open-Ended Terms
(PAHs, pesticides, PCBs),
c. COSATI Field/Group
18. Availability Statement
18. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
79
22. Price
(See ANSI-Z39 18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R07-89/032
Doepke Disposal (Holliday), KS
First Remedial Action - Final
n.6. Abstract (continued)
affecting the soil and ground water are VOCs including benzene, toluene, and xylene;
other organics including PAHs, PCBs, and pesticides, and metals including chromium and
lead.
The selected remedial action for this site includes removal and offsite treatment of
approximately 96,000 gallons of liquids currently ponded underground in former surface
impoundments; construction of a multilayer cap over the majority of the waste disposal
area; collection of ground water seepage and offsite treatment at a POTW, as necessary;
ground water monitoring; and implementation of deed and ac'cess restrictions. The
estimated present worth cost for this remedial action is '$5,970,000, which includes an
estimated annual O&M cost of $107,000 for 30 years. / ,
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Doepke Disposal (Holliday) Site
Johnson County, Kansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Doepke Disposal (Holliday) site, Johnson County, Kansas,
chosen in accordance with CERCLA,. as amended by SARA and, to the
extent practicable, the National Contingency Plan. This decision
is based on the administrative record file for the site.
The State of Kansas concurs on the selected remedy.
ASSESSMENT OF THE SITE v
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this ROD, may present a current or potential threat
to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The selected response action addresses all identified
remedial action objectives. This action reduces the threat of
direct contact with waste materials, and eliminates the potential
for future contamination of offsite ground water and surface
water.
The major components of the selected remedy include:
- Removal and offsite treatment of contaminated liquids
currently ponded underground in the former surface
impoundment area; and
Construction of an impermeable multi-layer cap over the
majority of the waste disposal area; and
- Collection and, if necessary, offsite treatment of
significant ground water seepage; and
Extended ground water monitoring to evaluate the
effectiveness of the remedy; and
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- Deed and access restrictions; and
If necessary, the response action will be modified to
include partial ground water controls. These controls
would include construction of a clay cutoff wall, and
extraction and offsite treatment of collected ground
water.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. However, the selected
remedy does not involve treatment of the majority of the
contaminants at the site; and therefore, the remedy does not
satisfy the statutory preference for remedial actions in which
treatment which permanently and significantly reduces the volume,
toxicity or mobility of the hazardous substances, pollutants, and
contaminants is a'principal element. The remedy includes
treatment of a discrete portion of the liquids contained in the
source area; however, most sources will remain untreated. The
large extent of the landfill, the heterogeneity of the wastes,
and the fact that there are no identifiable hot spots that
represent the major sources of contamination preclude a remedy in
which contaminants could be excavated and treated effectively.
Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Horrors Kay Date
Bfegional^ Administrator
Region VII
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ROD Decision Summary
Doepke Disposal (Holliday) Site
Johnson County/ Kansas
Site M»™«»f Location, and Description
The Doepke Disposal (Holliday) Superfund site, hereafter
called the Doepke-Holliday site or the site, lies approximately
3/4 mile east of the town of Holliday, Kansas and one mile west
of Lake Quivera. The site is approximately 500 feet south of the
Kansas River, and 2,700 feet upstream of the alluvial well field
and Kansas River water intake for the Johnson County Water
District Number 1, which supplies drinking water for
approximately 200,000 persons. See Figure I for regional
location.
The Doepke-Holliday site is located on the southern bluffs N
of the Kansas River Valley, at the intersection of Holliday Drive
and Interstate 435, in Johnson County, Kansas. As seen on Figure
2, which represents the site as it exists today, the site is
bounded by Holliday Drive to the north, Interstate 435 to the
east, the inactive Overland Park Landfill to the south, and the
active Johnson County Landfill to the west.
The site is an inactive industrial waste landfill situated
on the upland area of an 80.3 acre property. An active entrance
road to the adjacent Johnson County Landfill crosses the site.
The highest natural point of the site is 975 feet above mean sea
level (msl), and is on a ridge located along the southern
boundary. The site slopes from this high point north towards the
river with a total drop in relief of approximately 175 feet.
The major topographic feature of the site during active
landfill operations was a deep ravine that extended from the
center of the site northward towards the Kansas River. The
present topography of the site is substantially altered from the
active landfill topography. The ravine has since been filled
with landfill wastes and later with rock rubble resulting from
the construction of Interstate 435.
Deffenbaugh Industries, Inc., the current owner of the site,
has established a crushed shale storage pile on the south side of
the site. The shale pile rises about 50 feet above the
surrounding area, and is positioned over the area where two
surface impoundments were once located during the later years of
site operation.
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DOEPKE-HOLLIDAY SITE
REGIONAL UOCAT.ON
USGS MAP EDWAROSVILLE. KS 1934
QUADRANGLE LOCATION
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N
Fiaure 2
MW-8B
MW-8A
JOHNSON
COUNTY
LANDFILL
ACCESS
ROAD
ROCK
FILL
SHALE
PILE
MW-5
DEFFENBAUGH
"OPERATIONS
OVERLAND PARK
LANDFILL
DOEPKE-HOLLIDAY SITE
3
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Site History and Enforcement Activities
The land or portions thereof, now being called the Doepke-
Holliday site, was used for residential trash disposal during the
1950s and early 1960s. Following accepted practice for that
time, all trash was burned.
The City of Overland Park operated a landfill (now inactive)
to the south of the Doepke-Holliday site. This landfill-
received residential and commercial trash during the late 1950s
and early 1960s. Interpretation of aerial photographs from this
time period indicates that operations of this landfill extended
onto the present day Doepke-Holliday site.
In 1963, Mr. A. W. Doepke leased the property now called the
Doepke-Holliday site for the purpose of operating a landfill.
The Doepke Disposal Service, Inc. operated a commercial and
industrial waste landfill on the site until 1970. Figure 3
depicts the active landfill. The landfill reportedly received a
variety of materials including, but not limited to, fiberglass
and fiberglass resins, paint sludges, spent solvents, metal '
tailings, soaps and pesticides. In addition, the site reportedly
received fire debris and up to 374 drums in 1966 as the result of
a fire at the Thompson-Hayward chemical plant on Greystone Avenue
in Kansas City, Kansas. The drums were said to have contained
various solvents and organochlorine and organophosphate
pesticides.
Initially, wastes were burned, and the residues from the
burning were disposed of in the closed end of the ravine on the
southern portion of the site. In the late 1960s, burning
operations were discontinued. At this point, solid wastes were
buried on site, and liquids were disposed of in two surface
impoundments. These surface impoundments sometimes overflowed
during heavy rains, discharging the contents of the impoundments
onto adjoining land and into the Kansas River. At the direction
of the Kansas Department of Health and Environment (KDHE) and the
Johnson County Health Department, waste disposal operation ceased
in 1970.
Beginning in late 1977, rock materials excavated during
construction of Interstate 435 were dumped on the site. These
excavated materials were placed in the ravine on the site, and
were dumped directly over portions of the site where wastes had
been deposited.
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N
Figure 3
EXTENT OF
LANDFILL
OPERATIONS
INTERIOR
ROAD
SURFACE .
IMPOUNDMENTS
BURN-
AREA
DEFFENBAUGH
OPERATIONS
OVERLAND PARK
LANDFILL
DOEPKE-HOLLIDAY SITE
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The current owner of the Doepke-Holliday property,
Deffenbaugh Industries, Inc. (Deffenbaugh), operates the Johnson
County sanitary landfill located on separate property to the west
and southwest of the site. Deffenbaugh uses portions of the site
for storage of clay, crushed shale, and crushed limestone which
are used in Deffenbaugh's disposal operations at the Johnson
County Landfill. Also, Deffenbaugh's scale house and access road
for the Johnson County Landfill are located on the site. In
addition, Deffenbaugh conducts some other aspects of its.business
at the site, including storage and management of portable toilets
and dismantling of underground storage tanks removed from other
locations.
The Doepke-Holliday site was placed on the National
Priorities List (NPL) in December 1982. Between 1981 and 1986,
the EPA conducted several limited investigations and assessments
of the site. Pursuant to an Administrative Order on Consent of
December 17, 1987, as amended on November 10, 1988, Deffenbaugh
Industries, Inc., conducted a Remedial Investigation and
Feasibility Study (RI/FS) of the site under the guidance and
oversight of the EPA. Other potentially responsible parties ^
(PRPs) have been advised of their potential liability for
response costs; however, special notice procedures pursuant to
section 122(e) of CERCLA have not been initiated.
Highlights of Community Participation
The RI/FS reports and Proposed Plan for the Doepke-Holliday
site were released to the public in August 1989. These documents
were made available to the public as part of the administrative
record maintained at the EPA, Region VII office, and at the
Johnson County Public Library in Merriam, Kansas. The notice of
availability for these documents was published in the Overland
Park Sun and other Sun newspapers on August 4, 1989. A public
comment period was held from August 4, 1989 through August 25,
1989. In addition, a public meeting was held on August 16, 1989.
At this meeting, representatives of the EPA answered questions
about problems at the site and the remedial alternatives under
consideration. A response to the comments received during this
period is included in the Responsiveness Summary, which is a part
of this Record of Decision.
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of site Characteristics
A variety of site investigations have been conducted at the
site since 1981. The most recent and the most comprehensive has
been the RI/FS conducted by Deffenbaugh Industries under the
guidance and oversight of the EPA. The RI/FS was conducted to
identify the types, quantities, and locations of contaminants,
and to develop alternatives for solving the problems they
present. The results of the RI show a range of contamination
problems involving surface soil, subsurface soil, ground water
and ground water seeps containing varying levels of volatile
organic compounds (VOCs), polynuclear aromatic hydrocarbons
(PNAs), pesticides, polychlorinated biphenols (PCBs) and heavy
metals. Summary discussions of the findings of the RI/FS are
in this and subsequent sections of the ROD Decision Summary. The
Remedial Investigation, Public Health Assessment and Feasibility
Study reports should be consulted for more in-depth information.
Hydrology
The Kansas River (approximate elevation of 740 feet msl) and^
the 100-year flood stage (approximate elevation of 766 feet msl)
are 40 to 60 feet lower than the lowest point on the north
boundary of the Doepke-Holliday site. Most surface and
subsurface drainage from the site eventually flows to the Kansas
River.
Most of the surface runoff at the site flows toward the
north through erosional channels and existing stream channels.
Several rock and concrete drainageways were installed along the
north and east sides of the site when the I-435/Holliday Drive
interchange was constructed. These drainageways channel surface
runoff and ground water seepage from the site into a culvert at
the northeast corner of the site and then northward into the
Kansas River.
Geology
Surface materials on the site consist primarily of fill
materials placed there during and subsequent to disposal
operations. Logs from monitoring the wells and trenches dug
at the site show that these fill materials consist of sandstone
and limestone rubble, crushed shales, and clays. The thickness
of the fill materials varies greatly. Excluding the shale
stockpile, the thickest fill occurs in the ravine where it is
over 40 feet deep. Very few natural soil materials remain onsite
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The rock strata at the site lies horizontally and
consists of a series of alternating Pennsylvanian age limestone
and shale units of the Kansas City Group and a small portion of
the Lansing Group. Over 150 feet of the Lansing and Kansas City
Groups are freshly exposed along the road-cuts on the east and
north sides the site. Figure 4 shows a generalized cross section
of the site from north to south along the buried ravine.
Hydroqeolocrv
Jointing is visibly present in the limestones at the site
and may also be present in the shales, although jointing is
better developed in the limestones than in the shales. There is
also evidence that the limestone joints have been subject to
solution activity. The presence of shallow ground water flow
along these joints is evidenced by the presence of many ground
water seeps on the exposed rock faces at the site. Most of the
seeps at the site occur at the contact point between a limestone
unit and an underlying shale units. Infiltrating surface water
flows along the joints in the limestone until it encounters the
less permeable shale unit. The infiltrate then flows laterally v
until it reaches either an outcrop or a fracture or joint in the
shale. If the water reaches an outcrop, it emerges as a seep; if
it reaches a joint or fracture it may migrate into the next lower
unit.
Ground Water Contamination
Waste disposal occurred on the topographically highest
portion of the site. The uppermost bedrock unit in this area is
a limestone member of the Plattsburg Formation. This remnant of
the Plattsburg Formation is also the uppermost water bearing
unit at the site, and direct infiltration from the source areas
has contaminated the ground water. This unit is of small extent,
and is not a source of drinking water. The potential for vertical
migration of contaminated ground water to underlying units is
limited by the presence of several intervening low permeability
shale units. Lateral migration of contaminated ground water in
any direction results primarily in nearby surface discharge,
because the lateral extent of this unit is very small.
Therefore, the degree of hydraulic communication between
contaminated ground water and offsite ground water systems is
very limited.
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ELEVATION
(FT. MSL)
980
860
040
020
000
880
860
840
820
800
780
760
GEOLOGICAL CROSS SECTION
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k-rywv"jvv%v»/>riv»vvvrifv-jp*Tr^-*vi*.-./v*-_-rtVs.»*Y^-jBrvvvr^*-*^vivr^^
EXPLANATION
D
FLL MATERUL
LMESTONE
SHALE
WELL SCREENS
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Analytical results from onsite monitoring wells indicate
that shallow ground water contains a wide variety of
contaminants including volatile organic compounds (VOCs), semi-
volatile organics, pesticides and heavy metals in a range of
concentrations. See Table 1 for a summary of analyses. The
majority of the organic ground water contaminants were found at
concentrations less than 500 micrograms per liter (ug/1).
Several VOCs were found in excess of 500 ug/1 including benzene
(up to 890 ug/1), toluene (up to 4,130 ug/1), ethylbenzerie (up to
13,400 ug/1), and xylenes (up to 459,000 ug/1).
Analytical results from ground water seeps that occur at the
perimeter of the site indicate that the seeps contain fewer
contaminants at smaller concentrations than the shallow ground
water that occurs near the source. See Table 2 for a summary of
analyses. Organic contaminants were found in most samples to be
at concentrations less than 20 ug/1.
Soils/Wastes
The RI also included subsurface sampling of soils and/or *
waste materials in the former disposal areas. Trenches were dug
in the area of the surface impoundments and in the burn area at
the top of the ravine. A variety of waste materials were
encountered including oily liquids and sludges, asphalts, crushed
drums, fiberglass, fiberglass resins, tires, charred debris, and
reagent bottles.
The large extent, inaccessability, and heterogeneous nature
of the wastes make it impractical to characterize the source area
with a high level of confidence. However, analyses of soil/waste
samples from trenches in the waste disposal zones indicates the
area is contaminated with polycyclic aromatic hydrocarbons
(PAHs), phthalates, VOCs, and, to a lesser degree,
pesticides/PCBs and heavy metals. See Table 3 for a summary of
analyses. Those PAHs detected at concentrations greater than
100,000 micrograms per kilogram (ug/kg) include fluorene,
phenanthrene, anthracene, and 2-methylnapthalene. The VOCs that
occurred the most often and in the highest concentrations were
ethylbenzene (up to 624,000 ug/kg) and xylenes (up to 3,360,000
ug/kg). PCBs were found at concentrations up to 370,000 ug/kg.
Heavy metals which occured at elevated concentrations (greater
than 10 times background) include chromium, copper, lead,
mercury, and zinc.
10
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TABLE 1
DOEPKE-HOLLIDAY SITE
SUMMARY OF ORGANIC CHEMICAL ANALYSES FOR
GROUND WATER SAMPLES**
SEMI-VOLATILES
Phenol
Benzoic Acid
Naphthalene
4-Chloroaniline
Diethylphthalate
Pentachlorophenol
Di-N-Butylphthalate
1,2-Dichlorobenzene
2,4-Dimethylphenol
Isophorone
Dibenzofuran
Fluorene
Acenaphthene
VOLATILES
Chlorobenzene
Chloroethane
1,1-Dichloroethene
1,1-Dichloroethane
Benzene
4-Methyl-2-Pentanone
2-Hexanone
Toluene
Ethyl Benzene
Total Xylenes
Trichloroethene
PESTICIDES/PCBs
Alpha-BHC
Gamma-BHC
Aldrin
Heptachlor Epoxide
Endosulfan I
4,4'-DDE
Endosulfan II
Endrin Aldehyde
Endosulfan Sulfate
Chlordane
Beta-BHC
Delta-BHC
4,4'-ODD
4,4'-DDT
Heptachlor
Dieldrin
CONCENTRATION (ug/1)
13
150
150
62
350
152
20
14
33
18
3
4
5
63
18
51
32
890
296
15
4130
13400
459000
57
0.80
3.80
0.34
2.10
2.80
0.55
0.32
0.35
0.34
5.40
0.21
0.66
0.10
0.10
0.50
0.10
** Values shown are maximum concentration detected.
11
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TABLE 2
DOEPKE-HOLLIDAY SITE
SUMMARY OF ORGANIC CHEMICAL ANALYSES FOR
SEEP WATER SAMPLES**
Semi Volatiles
1,2-Dichlorobenzene
Di-N-Butylphthalate
Bis(2-Ethyl Hexyl)Phthalate
Volatiles
4-Methyl-2-Pentanone
Vinyl Acetate
Methylene Chloride
1,1-Dichloroethene
1,2-Dichloroethane
Trans 1,2-Dichloroethene
Dichloromethane
Pesticides/PCBs
Chlordane
Beta-BHC
Alpha-BHC
Delta-BHC
Endosulfan I
Endosulfan Sulfate
4,4'-ODD
4,4'-DDT
Dieldrin
Heptachlor
Heptachlor Epoxide
Concentration (ug/1)
14
710
22
10.0
10.5
5.7
5.5
10.0
5.0
5.7
1.0
0.2
0.1
0.7
0.1
0.5
0.1
0
0
0.5
0.1
** Values shown are maximum concentration detected.
12
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TABLE 3
DOEPKE-HOLLIDAY SITE
SUMMARY OF CHEMICAL ANALYSES FOR
SOIL/WASTE SAMPLES**
SEMIVOLATILES
1,4-Dichlorobenzene
1,2-Dichlorobenzene
Naphthalene
2-MethyInaphthalene
Acenaphthene
Diethylphthalate
4-Chlorophenyl Phenyl Ether
Fluorene
Phenanthrene
Anthracene
Di-N-Buyhlphthalate
Fluoranthene
Pyrene
Butyl Benzyl Phthalate
Benzo(a)anthracene
Bis(2-ethylhexyl)phthalate
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Dibenzo(a,h) anthracene
Benzo(g,h,ijperylene
Dibenzofuran
N-Nitrosodiphenylamine
4-Chloroaniline
Acenaphthylene
VOLATILES
Methylene Chloride
Acetone
1,1-Dichloroethene
Trichloroethene
Benzene
4-Methy1-2-pentanone
Toluene
Chlorobenzene
Ethyl Benzene
Total XyJ.enes
1,2-Dichloroethene
2-Hexanone
2-Butanone
Tetrachloroethene
CONCENTRATION (ua/kq)
6200
670
30000
275000
7610
61800
748
161000
650000
292000
3200
77000
58000
11000
31400
26000
36200
45000
44000
37100
18000
7000
15000
5830
2360
28800
2440
60900
129000
118
48
350
37500
3910
53
624000
3360000
306
29800
32
24
13
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TABLE 3 (Continued)
PESTICIDES/PCBs
Alpha-BHC
Beta-BHC
Delta-BHC
Aldrin
4,4'-DDE
4,4'-ODD
4,4'-DDT
Endosulfan Sulfate
Chlorodane
Endosulfan II
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
METALS
Aluminum
Antimony
Arsenic
Barium
Berylium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Cyanide
Boron
(ug/kg)
12
38
10
960
6600
4400
7800
16
300
68
3200
370000
17000
1100
(mg/kg)
22900
14
22
1300
3
7
70000
1400
22
1500
150000
800
8900
1400
7
78
4000
16
3690
102
1400
36
1110
** Values shown are maximum concentration detected
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Summary of Site Risks
Human Health Risks
A Public Health Assessment (PHA) was performed as part of
the RI/FS process. The PHA defines the types and extent of
public health hazards posed by actual or potential exposure to
hazardous materials in the environmental media at the site. It
analyzes site conditions and the potential risks to human health
assuming no cleanup action is taken.
As discussed in the previous section, analytical results
from the RI indicate that organic and inorganic chemical
substances occur at varying concentrations within all of the
environmental media sampled. Surface and subsurface soils at the
site are contaminated with PAHs, phthalates, VOCs, pesticides,
PCBs, and heavy metals. Note that much of the site has been
covered with clean fill materials. As would be expected, the
highest concentrations generally occur below the surface in the
former waste disposal areas. Shallow ground water contains
varying levels of VOCs, semi-volatile organics, pesticides, and v
heavy metals. Chemicals were also found in ground water seeps
which discharge to the surface at the perimeter of the site, but
at generally lower concentrations.
More than 60 different chemicals have been detected in the
environmental media at the site. For purposes of conducting the
PHA, a smaller group of representative or indicator chemicals was
selected to characterize the site risks. The indicator chemicals
were selected on the basis of concentration, prevalence, the
likelihood of human exposure in consideration of site-specific
conditions, toxicity, and mobility or persistence in the
environment. See Table 4 for the measured indicator chemical
concentrations.
Two present worker exposure scenarios and two hypothetical
exposure scenarios were studied in detail:
- Workers in the portable commodes division exposed to
contaminated surface soils by the inhalation, dermal, and
ingestion exposure routes.
- Onsite driver exposure to surface soil via inhalation of
contaminated dust.
- A child trespasser exposed to surface soil by the
inhalation, ingestion, and dermal routes.
15
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TABLE 4
MEASURED INDICATOR CHEMICAL CONCENTRATIONS
IN ENVIRONMENTAL MEDIA
Indicator
Chemical
Surface Soil (mcr/kq)
1. 1,1-Dichloroethylene
2. Xylene
3. Benzene
4. Benzo[a]pyrene
5. Bis(2-ethylhexyl)phthalate
6. Aroclor 1248
Aroclor 1254
Aroclor 1260
7. alpha-HCCH
8. Lead
9. Chromium
Ground Water (mcr/L)
1. 1,1-Dichloroethylene
2. Xylene
3. Benzene
4. Benzo[a]pyrene
5. Bis(2-ethylhexyl)phthalate
6. Aroclor 1248
Aroclor 1254
Aroclor 1260
7. alpha-HCCH
8. Lead
9. Chromium
Concentration
Conservative
Mean Upper Bound Maximum
ND
9.611
ND
3.831
6.804
0.111
0.079
0.393
ND
135.0
585.0
0.0054
65.403
0.0118
ND
ND
ND
ND
ND
0.00027
0.0108
0.0168
ND
27.00
ND
4.99
10.177
0.22
0.079
0.468
ND
135.0
585.0
0.006
109.001
0.0388
ND
ND
ND
ND
ND
0.00061
0.0243
0.0236
ND
27.00
ND
4.99 ,
21.00
0.22
0.12
1.43
ND
400
1,400.0
0.0064
459.0000
0.0453
ND
ND
ND
ND
ND
0.0008
0.030
0.059
16
-------
TABLE 4 (continued)
MEASURED INDICATOR CHEMICAL CONCENTRATIONS
IN ENVIRONMENTAL MEDIA
Indicator
Chemical
Concentration (mg/L)
Conservative
Mean Upper Bound Maximum
Seep Water (mg/L)
1. 1,1-Dichloroethylene 0.0051 0.0054 0.0055
2. Xylene ND ND ND
3. Benzene ND ND ND
4. Benzo[a]pyrene ND ND ND
5. Bis(2-ethylhexyl)phthalate 0.0113 0.022 0.022
6. Aroclor 1248 ND ND ND
Aroclor 1254 ND ND ND
Aroclor 1260 ND ND ND
7. alpha-HCCH 0.000062 0.000077 0.0001
8. Lead 0.0017 0.0017 0.0017
9. Chromium ND ND ND
ND - Not detected
Mean - Average of all site data including the detection limits of
non-detectable compounds
Conservative Upper Bound - Average of only the detectable
compounds
Maximum - The highest concentration reported
17
-------
- Potential future site usage scenario assuming full-time
onsite worker exposure to surface soils from the
inhalation, ingestion, and dermal contact routes.
The present worker exposure scenario only includes those
mowing vegetation, handling portable toilets, and cutting apart
tanks within the confines of the disposal area. This scenario
assumes an exposure frequency of 180 days/year for 40 years.
The driver exposure scenario was developed to estimate the
risks to workers not directly engaged in activities within the
disposal area but who are working in the vicinity of the disposal
area. These workers would be exposed through inhalation and/or
ingestion of fugitve dust only.
The trespasser exposure scenario assumes that a trespasser
between the ages of 12-18 years visits the site 28 days per year
for 7 years.
Lastly, the worker exposure scenario under future site usage
was used to represent health risks at the site assuming that ^
future site use involved construction/excavation activities.
Exposure to offsite populations is not considered
significant, because the amounts of chemicals released into the
air through volatilization or the generation of fugitive dust is
small due to the fact that most of the former disposal areas are
covered with clean soils, clays, shales and/or rock debris. Much
of this area is also vegetated. The small generation rate
combined with exponential dilution of chemicals with distance
from the source make it very unlikely that any offsite
populations will be significantly exposed. Exposure via
ingestion of contaminated water is not considered in this
assessment, because the contaminated ground water is not a source
of drinking water, and contaminants are not migrating offsite in
large enough concentrations to impact water quality in the Kansas
River. Potential usage of the contaminated ground water as a
drinking water source is not considered a possibility, because
the contaminated ground water unit is shallow, of limited extent,
and does not possess sufficient yield (less than 1 gpm) to
provide enough water for this use.
All chemicals are toxic at some dose; thus, the key issue in
risk assessment is not establishing toxicity itself, but rather
in defining the levels of exposure which cause undesirable
effects.
18
-------
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day) -1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper-bound" reflects the conservative estimate
of risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Excess lifetime cancer risks are determined by multiplying
the intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk of 1E-6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of *
site-related exposure to a carcinogen over a 70-year lifetime
under the specified exposure conditions at the site.
Risk estimates were derived using three different data sets
representing:
1. Average exposure conditions,
2. Conservative upper bound exposure conditions, and
3. MaviTnum nnssi hi *» e>vr>oRiiTp onnri i t-i ons .
t. . <_uus>ti.L vdtAvts uppei. jjuunu Cfxpuauj^e t-i-u.
3. Maximum possible exposure conditions.
Average exposure conditions are represented by mean
concentration values which were calculated using the average of
all site data including the detection limits of non-detectable
compounds. Conservative upper-bound conditions are represented
by the mean of all concentration values above detection limits.
Maximum exposure conditions are represented by the highest
concentrations reported.
The quantified carcinogenic risks for each exposure scenario
outlined above are presented in Tables 5-1 through 5-4.
For assessment of the non-carcinogenic effects of the
indicator chemicals, a hazard index approach was used. Briefly,
the hazard index approach compares the average daily intake for
each indicator chemical for each population to a published
acceptable intake for chronic exposure (AIC). The EPA derived
19
-------
acceptable intake values for chronic exposure are calculated from
human epidemiological studies or animal studies to which
uncertainty factors have been applied to account for the use of
animal data to predict effects on humans. These values represent
the highest chronic exposure level not causing adverse effects
[i.e., no observable adverse effect level (NOAEL)]. To assess
the overall potential for non-carcinogenic effects from multiple
chemicals using the hazard index, the ratio of the daily exposure
(DE) to the acceptable intake for chronic exposure (AIC) is
summed. This approach assumes multiple sub-threshold exposures
can result in an adverse effect if the magnitude of the hazard
index is greater than one. Conversely, if the hazard index is
less than one, the chemicals are not considered to represent a
human health concern.
Non-carcinogenic hazards for each exposure scenario are
presented in Tables 5-5 through 5-8.
The following conclusions regarding site hazards can be made
based on the data presented in the PHA and RI reports:
1. Contaminants are not migrating offsite in large enough *
concentrations to impact water quality in the Kansas River.
Most measured concentrations of chemicals in seep water and
offsite drainage are below federal maximum contaminant levels
(MCLs) and Kansas action levels (KALs). These data minimize the
human health concern regarding the ingestion of these discharges
from the Kansas River or the Johnson County Water District No. 1
intake. Site discharges mixing with the Kansas River would lower
the concentration many thousands of times below the already low
concentrations detected (See RI report). This does not preclude
the possibility that offsite migration could become significant
in the future, and contaminant tranport studies indicate that
this potential exists.
2. The summation of non-carcinogenic hazard indices is less
than one for each exposure scenario studied. Therefore, the
indicator chemicals do not represent a human health concern when
only non-carcinogenic effects are considered.
3. The site currently poses no significant carcinogenic risks
to onsite workers or the casual trespasser who are exposed to
contaminated surface soils by the inhalation, dermal contact, and
ingestion exposure routes. Note that these scenarios assume
contact with surface soils only, and that waste materials in the
sub-surface remain undisturbed.
20
-------
Table 5-1
Inhalation, D
Indicator Ch
Indicator
Chemical
A.
1
2
3
4
5
6
7
8
9
Inhalation
1,1-DCE
Benzene
BMP
DEHP
Aroclor 1248
Aroclor 1254
Aroclor 1260
alpha-HCCH
Chromium
r«A ^^* ^k^BA^WH
OTTTI«I. an
emicals P
Upper Bo
d Ingestion Exposure to Potentially Carcinogenic
'resent in Surface Soil Using Mean, Conservative
und, and Maximum Concentrations
Daily Exposure* Cancer
(m^kg/day) Pot Factor?
Mean Cons. Max.
ND
ND
L38E-09
2.45E-09
4.00E-11
2.84E-11
L41E-10
ND
2.11E-07
ND
ND
L80E-09
3.66E-09
7.92E-11
2.84E-11
1.68E-10
ND
2.11E-07
ND
ND
L80E-09
7.56E-09
7.92E-11
4.32E-11
5.15E-10
ND
5.04E-07
1.2
0.029
6.1
0.000684
7.7
7.7
7.7
11
41
Sub-total
B.
1
2
3
4
5
6
7
8
9
Dermal
1,1-DCE
Benzene
BMP
DEHP
Aroclor 1248
Aroclor 1254
Aroclor 1260
alpha-HCCH
Chromium
ND
ND
L67E-07
2.97E-07
4.85E-09
3.45E-09
L72E-08
ND
2.56E-05
ND
ND
2.18E-07
4.45E-07
9.61E-09
3.45E-09
2.05E-08
ND
2.56E-05
ND
ND
2.18E-07
9.18E-07
9.61EX»
5^4E-09
6.25E-08
ND
6.12E-05
0.6
0.029
11.5
0.000684
7.7
7.7
7.7
11
NA
Lifetime Can cert
Risk
Mean Cons. Max.
—
—
8.41E-09
L68E-12
3.08E-10
2.19E-10
L09E-09
—
8.63E-06
&64E-06
...
...
L93E-06
2.03E-10
3.74E-08
2.66E-08
L32E-07
—
...
...
...
L10E-08
2.51E-12
6.10E-10
2.19E-10
L30E-09
...
8.63E-06
&65E-06
...
—
2.51E-06
3.04 E- 10
7.40E-08
2.66E-08
L57E-07
—
...
...
— \
1.10E-08
5.17E-12
6.10E-10
3.33 E-10
3.96E-09
...
2 07E-05
2.07E-05
...
...
2.51E-06
6.28E-10
7.40E-08
4.04E-08
4.81E-07
...
...
Subtotal
2.12E-06 2.77E-06 3.10E-06
-------
Table 5-1 continued
Indicator
Chemical
C.
1
2
3
4
5
6
7
8
9
Ingestion
1,1-DCE
Benzene
B[a]P
DEHP
Aroclor
Aroclor
Aroclor
1248
1254
1260
alpha-HCCH
Chromium
Daily Exposure* Cancer
(mg/kg/day) Pot Factor§
Mean Cons. Max.
ND
ND
3.85E-07
6.84E-07
L12E-08
7.95E-09
3.95E-08
ND
5.89E-05
ND
ND
5.02E-07
L02E-06
2.21E-08
7.95E-09
4.71E-08
ND
5.89E-05
ND
ND
5.02E-07
2.11E-06
2.2 IE-OS
L21E-08
L44E-07
ND
L41E-04
0.6
0.029
11.5
0.000684
7.7
7.7
7.7
11
NA
Sub-total
Total
Lifetime Cancert
Risk
Mean Cons. Max.
...
4.43E-06
4.68E-10
8.60E-08
6. 12 E- 08
3.04E-07
...
...
4.R8E.Q6
1-56E-05
...
5.77E-06
7.00E-10
1.70E-07
6.12E-08
3.63E-07
...
...
6.37E-06
1.78E-05
...
5.77E-06
1
1
9
1
2
3
.45 E-09
.70E-07
.30E-08
.HE-Ofe
...
—
.1-TF-Ofi
.10E-05
*The inhalation, dermal, and ingestion daily exposure in mg/kg/day was calculated by
multiplying 0.00036, 0.0437, and 0.1006 mg/kg body weight/day respectively, of soil times
the corresponding concentration of the chemical in soil. These doses are based on a body
weight of 70 kg.
{Cancer potency factors are from the Superfund Public Health Evaluation Manual (1986)
with updates from EPA's Carcinogenic Assessment Group (CAG)
"^Lifetime cancer risks are calculated by multiplying the daily intake by the cancer
potency factor.
Mean- average of all site data including the detection limits of non-detectable compounds
Conservative Upper Bound - average of only the detectable compounds
Maximum • the highest concentration reported.
ND = not detected
NA = Not applicable
22
-------
Table 5-2
A*ft^ wh^iM^b*MB^^AA ^*» AMb»^ ••k«**«^ ^•^•••^•^iia 4bw*i^*iBM*^ w ** ^MA«* ^*^j MT^ ******* w»w^fc*» .^ » ^^a* J^ •«^i*-^i» * ^^WWWt
by Inhalation, Dermal, and Ingestion Exposure to Potentially Carcinogenic
Indicator Chemicals Present in Surface Soil Using Mean, Conservative
Upper Bound, and Maximum Concentrations
Indicator
Chemical
A.
1
2
3
4
5
6
7
8
9
Inhalation
1,1-DCE
Benzene
BMP
DEHP
Aroclor 1248
Aroclor 1254
Aroclor 1260
alpha-HCCH
Chromium
Daily Exposure* Cancer
(mgfltg/dfly) Pot Factor?
Mean Cons. Max.
ND
ND
7.66E-11
L36E-10
2.22E-12
1.58E-12
7.86E-12
ND
L17E-08
ND
ND
9.98E-11
2. 04 E- 10
4.40E-12
L58E-12
9.36E-12
ND
L17E-08
ND
ND
9.98E-11
4.20E-10
4.40E-12
2.40E-12
2.86E-11
ND
2.80E-08
1.2
0.029
6.1
0.000684
7.7
7.7
7.7
11
41
Sub-total
B.
1
2
3
4
5
6
7
8
9
Dermal
1,1-DCE
Benzene
BMP
DEHP
Aroclor 1248
Aroclor 1254
Aroclor 1260
alpha-HCCH
Chromium
ND
ND
L15E-08
2.04E-08
3. 33 E- 10
2.37E-10
L18E-09
ND
1.76E-06
ND
ND
L50E-08
3.05E-08
6.60E-10
2.37E-10
1.40E-09
ND
L76E-06
ND
ND
L50E-08
6.30E-08
6.60E-10
3.60E-10
4.29E-09
ND
4.20E-06
0.6
0.029
11.5
0.000684
7.7
7.7
7.7
11
NA
Lifetime Can cert
Risk
Mean Cons. Max.
...
...
4.67E-10
9.31E-14
L71E-11
L22E-11
6.05E-11
...
4.80E-07
4AOE-07
...
...
L32E-07
L40E-11
2.56E-09
L82E-09
9.08E-09
...
...
...
...
6.09E-10
L39E-13
3.39E-11
L22E-11
7.21E-11
...
4.80E-07
4£OE-07
...
...
L72E-07
2.09E-11
6.08E-09
182E-09
1.08E-08
...
...
...
... V
6.09 E-10
2.87E-13
3.39E-11
1.85 E-ll
2 20 E-10
...
1.15E-06
1.15E-06
...
...
1.72E-07
4.31E-11
5.08 E-09
2.77E-09
3.30E-08
...
...
Sub-total
1.90E-07 2.13E-07
23
-------
Table 5-2 continued
Indicator
Chemical
C.
1
2
3
4
5
6
7
8
9
Ingestion
1,1-DCE
Benzene
B[a]P
DEHP
Aroclor
Aroclor
Aroclor
1248
1254
1260
alpha-HCCH
Chromium
Daily Exposure* Cancer
(mg/kg/day) Pot Factor?
Mean Cons. Max.
ND
ND
2.11E-08
3.74E-08
6.11E-10
4.35E-10
2.16E-09
ND
3.22E-06
ND
ND
2.74E-08
5.60E-08
L21E-09
4.35E-10
2.57E-09
ND
3.22E-06
ND
ND
2.74E-08
L16E-07
L21E-09
6.60E-10
7.87E-09
ND
7.70E-06
0.6
0.029
11.5
0.000684
7.7
7.7
7.7
11
NA
Sub-total
Total
Lifetime Cancert
Risk
Mean Cons. Max.
...
...
2.42E-07
2.56E-11
4.70E-09
3.35E-09
1.66E-08
...
...
2.67E-07
&93E-07
...'
...
3.16E-07
3.83E-11
9.32E-09
3.35E-09
1.98E-08
...
...
S.4SE-07
1.02E-06
...
3.16E-07
7
9
5
6
3
.90E-11
.32E-09
08E-09
06E-08
...
...
.91E-07
1.75E-06
"The inhalation, dermal, and ingestion daily exposure in mg/kg/day was calculated by
multiplying 0.00002, 0.003, and 0.0055 mg/kg body weight/day respectively, of soil times
the corresponding concentration of the chemical in soil. These doses are based on a body
weight of 70kg.
§Cancer potency factors are from the Superfund Public Health Evaluation Manual (1986)
with updates from EPA's Carcinogenic Assessment Group (CAG)
^Lifetime cancer risks are calculated by multiplying the daily intake by the cancer
potency factor.
Mean- average of all site data including the detection limits of non-detectable compounds
Conservative Upper Bound - average of only the detectable compounds
Maximum - the highest concentration reported.
ND = not detected
NA = not applicable
24
-------
Table 5-3
Estimation of Lifetime Cancer Risks to the Driven Traversing the Site
Posed by Inhalation Exposure to Potentially Carcinogenic Indicator
Chemicals Present in Surface Soil Using Mean, Conservative Upper
Indicator
Chemical
A.
1
2
3
4
5
6
7
8
9
Inhalation
1,1-DCE
Benzene
BMP
DEHP
Aroclor 1248
Aroclor 1254
Aroclor 1260
alpha-HCCH
Chromium
Daily Exposure* Cancer
(mg/kg/day) Pot. Factor$
Mean Cons. Max.
ND
ND
L15E-09
2. 04 E- 09
3.33 E- 11
2.37E-11
L18E-10
ND
1.76E-07
ND
ND
1.50E-09
3.05E-09
6.60E-11
2.37E-11
1.40E-10
ND
1.76E-07
ND
ND
L50E-09
6.30E-09
6.60E-11
3.60E-11
4.29E-10
ND
4.20E-07
1.2
0.029
6.1
0.000684
7.7
7.7
7.7
11
41
Total
Lifetime Cancert
Risk
Mean Cons. Max.
...
7.01E-09
L40E-12
2.56E-10
L82E-10
9. 08 E- 10
...
7.20E-06
7.20E-06
...
9.13E-09
2.09E-12
5.08E-10
1.82E-10
1.08E-09
...
7.20E-06
7.21E-06
9
4
5
2
3
1
\
.13E-09
31E-12
08E-10
77E-10
30E-09
72E-05
1.72E-05
*The inhalation daily exposure in mg/kg/day was calculated by multiplying 0.0003
mg/kg body weight/day of soil times the corresponding concentration of the chemical in
soil. These doses are based on a body weight of 70 kg.
{Cancer potency factors are from the Super-fund Public Health Evaluation Manual (1986)
with updates from EPA's Carcinogenic Assessment Group (CAG)
t Life time cancer risks are calculated by multiplying the daily intake by the cancer
potency factor.
Mean- average of all site data including the detection limits of non-detectable compounds
Conservative Upper Bound - average of only the detectable compounds
Maximum - the highest concentration reported.
ND = not detected
NA = not applicable
25
-------
Table 5-4
^^f^ •••««*«» *M^T«M» -*^* ^MMM»^* ••»»••••»* • 1 1 • • • • ^••^••M^ ^^ ••^•^»» * ^BV^^B vr *•» — w ^^ ™— ^^
-------
Table 5-4 continued
Indicator
Chemical
C.
1
2
3
4
5
6
7
8
9
Ingestion
1,1-DCE
Benzene
B[a]P
DEHP
Aroclor 1248
Aroclor 1254
Aroclor 1260
alpha-HCCH
Chromium
Daily Exposure* Cancer
(mg/kg/day) Pot Factor}
Mean Cons. Max.
ND
ND
5.01E-07
8.90E-07
L45E-08
L03E-08
5.14E-08
ND
ND
ND
ND
6.53E-07
L33E-06
2.88E-08
1.03E-08
6.12E-08
ND
ND
ND
ND
6.53E-07
2.75E-06
2.88E-08
1.57E-08
1.87E-07
ND
ND
0.6
0.029
11.5
0.000684
7.7
7.7
7.7
11
NA
Sub-total
Total
Lifetime Cancert
Risk
Mean Cons. Max.
• ••
...
5.76E-06
6.09 E- 10
L12E-07
7.96E-08
3.96E-07
...
...
fi.35E.Ofi
1.00E-O4
*••
...
7.51E-06
9.11E-10
2.22E-07
7.96E-08
4.71E-07
...
...
&2SE-06
1.03E-04
...
...
7.51E-06
1.88E-09
2.22 E-07
1.21E-07
1.44 E-06
""" \
...
9.29E.Q6
2.31E-04
•The inhalation, dermal, and ingestion daily exposure in mg/kg/day was calculated by
multiplying 0.0038, 0.0569, and 0.1308 mg/kg body weight/day respectively, of soil times
the corresponding concentration of the chemical in soil. These doses are based on a body
weight of 70 kg.
§Cancer potency factors are from the Superfund Public Health Evaluation Manual (1986)
with updates from EPA's Carcinogenic Assessment Group (CAG)
'Lifetime cancer risks are calculated by multiplying the daily intake by the cancer
potency factor.
Mean* average of all site data including the detection limits of non-detectable compounds.
Conservative Upper Bound - average of only the detectable compounds
Maximum • the highest concentration reported.
ND = not detected
NA = not applicable
27
-------
Table 5-5
Summary of Lifetime Non-Cancer Hazard to Workers On Site From
Inhalation, Dermal, and Ingestion Exposure to Site Surface Soil Using
Mean, Conservative Upper Bound, and Maximum Concentrations
Indicator
Chemical
Daily
Mean
Exposure CPE)
Cons.
Max.
AIC
PEAIC Ratioi
Mean
Cons.
Max.
Inhalation Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
2.45E-09
2.11E-07
4.86E-08
3.46E-09
ND
3.66E-09
2.11E-07
4.86E-08
9.72E-09
ND
7.56E-09
5.04E-07
1.44 E-07
9.72E-09
9.00E-03
2.00E-02
5.00E-03
4.30E-03
4.00E-01
Sub-total
...
L22E-07
4.21E-05
L13E-05
865E-09
5.36E-05
...
L83E-07
431E-05
L13E-05
2.43E-08
5.36E-05
...
3.78E-07
1.01E-04
3.35 E-05
2.43E-08
1.35 E-04
\
Dermal Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
2.97E-07
2.56E-05
5.90E-06
4.20E-07
ND
4.45E-07
2.56E-05
5.90E-06
1.18E-06
ND
9. 18 E-07
6.12E-05
1.75E-05
1.18E-06
9.00E-03
2.00E-02
5.00E-03
L40E-03
2.00E+00
Sub-total
...
L49E-05
5.11E-03
4.2 IE- 03
2.10E-07
9.34E-03
...
2J22E-05
5.11E-03
4.21E-03
5.9QE-Q7
9.35E-03
...
4.59E-05
1.22 E-02
1.25E-02
5.90E-07
2.48E-02
Ingestion Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
6.84 E-07
5.89E-05
1.36E-05
9.67E-07
ND
1.02E-06
5.89E-05
1.36E-05
2.72E-06
ND
2.11E-06
1.41E-04
4.02 E-05
2.72E-06
9.00E-03
2.00E-02
5.00E-03
L40E-03
2.00E+00
Sub-total
...
3.42E-05
L18E-02
9.70E-03
4.83E-07
2.15E-02
...
5.12E-05
L18E-02
9.70E-03
1.36E-06
2.15E-02
...
1.06 E-04
2.82E-02
2.87E-02
1.36E-06
5 70E-02
Total t 8X8E-02 S49E-02 8-19E-02
*A hazard index greater than one for a specific indicator chemical indicates a potential
human health risk. For multiple exposures, the hazard index can exceed one if the
chemicals do not induce the same effect by the same mechanism. AIC = Acceptable Intake
Chronic (mg/kg/day) are reference doses in the SPHEM. For 1,1-DCE, DEHP, and
chromium, AICs by the inhalation route were unavailable and the AIC by the oral route was
applied for purposes of comparison. ND = not detected, tCombined non-cancer hazards
were calculated by summing the dermal, inhalation and ingestion DEiAIC ratios.
28
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Tabled
Estimation of Lifetime Non-Cancer Hazards to the Child Trespasser Due to
Mean, Conservative Upper Bound, and Maximum Concentrations
Indicator
Chemical
Daily
Mean
ETDOSUTP fDE)
Cons. Max.
AIC
DE;AIC Ratio*
Mean Con;. Max.
Inhalation Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
1.T7E-09
1.52E-07
3.51E-08
2.50E-09
ND
2.65E-09
L52E-07
3.51E-08
7.02E-09
ND
5.46E-09
3.64E-07
1.04E-07
7.02E-09
9.00E-03
2.00E-02
5.00E-03
4.30E-03
4.00E-01
Sub-total
...
8.85E-08
3.04E-05
8.16E-06
6.25E-09
3.87E-05
...
L32E-07
3.04E-05
8.16E-06
1.76E-08
3.87E-05
Dermal Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
2.59E-07
2.22E-05
5.13E-06
3.65E-07
ND
3.87E-07
2.22 E-05
5.13E-06
1.03 E-06
ND
7.98E-07
5.32E-05
1.52E-05
1.03 E-06
9.00E-03
2.00E-02
5.00 E- 03
L40E-03
2.00E+00
Sub-total
...
L29E-05
4.45E-03
3.66E-03
183E-07
8.12E-03
...
L93E-05
4.45E-03
3.66E-03
513E-07
8.13E-03
...
2.73E-07
7J28E-05
2.42 E-05
1.76E-08
9.73E-05
\
...
3.99 E-05
1.06 E-02
1.09E-02
5 13E-07
2 15E-02
Ingestion Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
4.69E-07
4.04E-05
9.32E-06
6.63 EX)7
ND
7.02E-07
4.04 E-05
9.32E-06
1.86 E-06
ND
1.45 E-06
9.66 E-05
2.76E-05
1.86 E-06
9.00E-03
2.00E-02
5.00E-03
L40E-03
2.00E+00
Subtotal
...
2.35E-05
8.07E-03
6.65E-03
3.32E-07
L48E-02
...
3.51E-05
8.07E-03
6.65E-03
9.32E-07
L48E-02
...
7J25E-05
1.93E-02
1.97E-02
9.32E-07
3.91E-02
Total t 230E-02 &30E-02 &07E-02
*A hazard index greater than one for a specific indicator chemical indicates a potential
human health risk. For multiple exposures, the hazard index can exceed one if the
chemicals do not induce the same effect by the same mechanism. AIC = Acceptable Intake
Chronic (mg/kg/day) are published reference doses in the SPHEM. For 1,1-DCE, DEHP,
and chromium, AJCs by the inhalation route were unavailable and the AIC by the oral route
was applied for purposes of comparison. tCombined non-cancer hazards were calculated
by summing the dermal, inhalation and ingestion DEiAIC ratios.
29
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Tables?
Estimation of Lifetime Non-Cancer Hazards to Drivers Traversing the Site
Upper Bound, and Maximum Concentrations
Indicator
Chemical
In
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
Daily Exposure fPE)
Mean Cons. Max.
sure
ND
2.04E-09
1.76E-07
4.05E-08
2.88E-09
ND
. 3.05E-09
1.76E-07
4.05E-08
8.10E-09
ND
6.30E-09
4.20E-07
1.20E-07
8.10E-09
AIC
9.00E-03
2.00E-02
5.00E-03
4.30E-03
4.00E-01
Sub-total
DE:AIC Ratio*
Mean Cons. Max.
• ••
L02E-07
3.51E-05
9.42E-06
7.21E-09
4.46E-05
**.
L53E-07
3.51E-05
9.42E-06
2.03E-08
4.47E-05
...
3.15E-07
8.40E-05
2.79E-05
2.03E-08
1.12E-04
Total t
4w46E-05 4.47E-05 1.12E-04
*A hazard index greater than one for a specific indicator chemical indicates a potential
human health risk. For multiple exposures, the hazard index can exceed one if the
chemicals do not induce the same effect by the same mechanism. AIC = Acceptable Intake
Chronic (mg/kg/day) are published reference doses in the SPHEM. For 1,1-DCE, DEHP,
and chromium, AICs by the inhalation route were unavailable and the AIC by the oral route
was applied for purposes of comparison. ^Combined non-cancer hazards were calculated
by summing the dermal, inhalation and ingestion DEiAIC ratios.
30
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Table 5-8
Estimation of lifetime Non-Cancer Hazards Under the Hypothetical Future
Site Usage Scenario: Worker Exposure Due to Dermal, Inhalation, and
Ingestion Exposure to Site Surface Soil Tiring Mean, Conservative Upper
Bound, and Maximum Concentrations
Indicator
Chemical
Daily
Mean
Exposure fPE)
Cons.
Max.
AIC
JJELA.IC Ratio*
Mean
Cons.
Max.
Inhalation Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
2.59E-08
2.22 E-06
5.13E-07
3.65E-08
ND
3.87E-08
2.22 E-06
5.13E-07
1.03E-07
ND
7.98E-08
5.32E-06
1.52E-06
1.03E-07
9.00E-03
2.00E-02
5.00E-03
4.30E-03
4.00E-01
Sub-total
...
L29E-06
4.45E-04
L19E-04
9.13E-08
5.65E-04
...
L93E-06
4.45E-04
L19E-04
2.57E-07
5.66E-04
Dermal Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
3.87E-07
3.33E-05
7.68E-06
5.47E-07
ND
5.79E-07
3.33E-05
7.68E-06
1.54E-06
ND
1.19E-06
7.97E-05
2.28E-05
1.54 E-06
9.00E-03
2.00E-02
5.00E-03
L40E-03
2.00E+00
Sub-total
...
L94E-05
6.66E-03
5.49E-03
2.73E-07
L22E-02
...
2.90E-05
6.66E-03
5.49E-03
7.68E-07
L22E-02
...
3.99E-06
1.06E-03
3.53E-04
2.57E-07
1.42E-03
V
...
5.97E-05
1.59E-02
1.63 E-02
7.68E-Q7
3.22 E-02
Ingestion Exposure
1.
2
3
4
5
1,1-DCE
DEHP
Chromium
Lead
Xylene
ND
8.90E-07
7.65E-05
1.77E-05
1.26E-06
ND
1.33E-06
7.65E-05
1.77E-05
3.53 E-06
ND
2.75E-06
1.83E-04
5J23E-05
3.53 E-06
9.00E-03
2.00E-02
5.00E-03
L40E-03
2.00E+00
Subtotal
...
4.45E-05
1.53E-02
1.26E-02
6.29E-Q7
2.80E-02
...
6.66E-05
L53E-02
L26E-02
1.77E-06
2.80E-02
...
1.37E-04
3.66E-02
3.74E-02
1.77E-06
7.41E-02
Total t 448E-02 4JOSE-02 LOSE-01
*A hazard index greater than one for a specific indicator chemical indicates a potential
human health risk. For multiple exposures, the hazard index can exceed one if the
chemicals do not induce the same effect by the same mechanism. AIC = Acceptable Intake
Chronic (mg/kg/day) are published reference doses in the SPHEM. For 1,1-DCE. DEHP,
and chromium, AICs by the inhalation route were unavailable and the AIC by the oral route
was applied for purposes of comparison. tCombined non-cancer hazards were calculated
by summing the dermal, inhalation and ingestion DEiAIC ratios.
31
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4. Analysis of the potential future site use scenario indicates
that the site may, if no cleanup action is performed, present a
significant carcinogenic risk to a full-time worker engaged in
construction activities over a long period of time.
It should be noted that the future use scenario does not
account for two factors which may have caused the risks to be
underestimated. 1) Risk calculations are made using surface soil
concentrations, and typical construction/excavation activities
would likely result in contact with soils/wastes in the
subsurface where contaminant concentrations are greater. 2)
Volatile concentrations are not significant in the surface soils
and therefore were not considered a significant factor in the
evaluation of site hazards. However, there are significant
levels in soils and wastes at various depths below the surface,
which could pose a hazard to someone engaged in excavation
activities from a sudden as well as a chronic exposure
standpoint.
Also, under a construction/excavation scenario, transport of
onsite contaminants to offsite areas by water or airborne *
transport mechanisms could become significant.
Environmental Risks
The site is adjacent to a sanitary landfill and industrial
complex with controlled access and such sufficient activity that
the potential for utilization as a terrestrial ecosystem is very
limited. Currently less than five acres of the 80.3 acre site
has been left undisturbed. Vegetative cover over the landfill
is greater than 50% and has occurred naturally since site closure
so phytotoxic effects are not evident. Forested areas occur near
the site, and numerous animals have been observed onsite
including deer, rabbits, racoons, and oppossums.
Contaminants occur in seep water and offsite drainage at
very low levels, and in most cases below ambient water quality
criteria for protection of freshwater aquatic life. Therefore,
offsite migration is not expected to have an impact on water
quality in the Kansas River, particularly since the volume of
offsite drainage is relatively small. However, there is the
potential for offsite migration to become significant in the
future.
According to the Kansas Biological Survey, there are no
records of threatened or endangered species on the site. Within
32
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a- 5 mile radius of the site, two species of fish have been
recorded and are currently listed by the U.S. Fish and Wildlife
Services (USFWS) as candidate species. One species of snake has
been recorded and is protected by the State of Kansas as a
threatened species. The bald eagle, a regular winter visitor to
the Kansas River, is listed by both the USFWS and the State of
Kansas as an endangered species.
Under current conditions, no adverse impacts are identified
for the general terrestrial or aquatic ecosystems; and therefore,
there is no indication that threatened or endangered species will
be adversely affected. In the event that offsite migration were
to increase, this assessment would have to be reevaluated.
It is concluded that, actual or threatened releases of
hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to public
health, welfare, or the environment.
Role and Scope of the Response Action
/
As required by the National Contingency Plan, the general
goal and objective of the response action is to effectively
mitigate and minimize damage to and provide adequate protection
of public health and the environment. The specific goals and
objectives of the response action for the Doepke-Holliday site
are as follows:
1. Reduce or eliminate the threat of direct contact, ingestion,
or inhalation of particulates containing benzene, xylenes, PCBs,
1,1-dichloroethylene, alpha-hexachlorocyclohexane, bis(2-ethyl
hexyl)phthalate, benzo(a)pyrene, lead, chromium, and other
contaminants contained in soil and solids buried at the site.
Also, reduce the potential for inhalation of volatilized organics
such as benzene, 1,1-dichloroethylene, and xylenes.
2. Prevent future contamination of ground water migrating
through contaminated soils and buried wastes to seeps, alluvium
wells, and the Kansas River with resultant leaching of
contaminants, such as the compounds of PCBs, benzene, xylenes,
alpha-hexachlorocyclohexane, 1,1-dichloroethylene, bis(2-ethyl
hexyl)phthalate, benzo(a)pyrene, lead, chromium, and other
contaminants.
33
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3. Reduce or eliminate the potential for transport of onsite
contaminants to offsite areas by water or airborne transport
mechanisms.
4. Prevent the potential for offsite exposure to unacceptable
levels of ground water and soil/waste contaminants.
These goals and objectives can be accomplished by full or
partial removal of wastes from the site, full or partial •
treatment of the wastes, and/or full or partial containment of
wastes.
Description of Alternatives
The response action alternatives considered for
implementation at the Doepke-Holliday site are outlined below.
The alternatives were developed from a wide range of potentially
applicable technologies that were screened for applicability to
response objectives and site characteristics.
\
o Alternative 1: No Action;
o Alternative 2: Capping;
o Alternative 3: Capping and Partial Source Removal;
o Alternative 4: Capping and Partial Ground Water Control;
o Alternative 5: Capping, Partial Source Removal, and
Partial Ground Water Control; and
o Alternative 6: Complete Excavation and Offsite Disposal.
All of the alternatives except "No Action" would include (a)
additional investigations or activities to establish the
northern, western, and southern extent of contaminated soils and
buried wastes, (b) additional investigations to evaluate the
vertical extent of contaminated ground water on the Doepke-
Holliday property and the southern extent of contaminated ground
water, and (c) extended ground water monitoring to evaluate the
effectiveness of the response actions.
34
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Alternative 1. - No Action:
The NCP and the Superfund process requires that the "No
Action" alternative be considered at every site. This
alternative provides a baseline for comparison. Under this
alternative, no further action would be taken to control
contamination associated with the site.
Alternative 2 - Capping:
The major features of the capping alternative consist of
investigations to establish the lateral extent of the waste
disposal area, installation of an impermeable multi-layer cap
over the majority of the waste disposal area, site security
barriers, land use restrictions, and extended ground water
monitoring of existing and new monitoring wells.
The site will be capped with a final cover designed and
constructed to provide long-term minimization of the migration of
liquids through the capped area. The cap will also be designed
and constructed to promote drainage and minimize erosion of the
cover. Long-term operation and maintenance (O&M) will be
conducted to monitor the ground water around the landfill, and to
ensure the integrity of the cap.
It is anticipated that installation of the impermeable cap
will reduce infiltration through the disposal area to the point
that concentrations of contaminants in seep water discharges will
drop significantly. Since the majority of the ground water
discharge originates as precipitation, it is likely that many of
the ground water seeps will not continue to flow. Also, the
capping alternative should eliminate all health risks posed by
direct contact with the waste disposal areas.
The estimated construction cost of this remedy is
$4,130,000, with annual O&M costs estimated to be $72,000. The
estimated time to implement this remedy and to meet the cleanup
goals is 16 to 20 months.
Alternative 3. - Capping and Partial Source Removal:
The major components of this response action are the same as
for alternative 2. Additionally, approximately 96,000 gallons of
liquids currently ponded below grade in the former surface
impoundment area will be evaluated for removal. The liquid will
be collected by either pumping or other conventional dewatering
techniques and containerized. The liquid will then be
transported to an offsite permitted facility for treatment and
disposal.
35
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This alternative also includes short-term collection and
offsite treatment, as necessary, of significant ground water
seepage. The major offsite discharge (referred to as seep no. 1
in the RI/FS reports) will be collected and pumped to a holding
tank. The water will be analyzed and, if necessary, taken to an
offsite permitted facility for treatment prior to release.
The estimated construction cost of this remedy is
$4,330,000, with annual O&M costs estimated to be $107,000. The
estimated time to implement this remedy and to meet the cleanup
goals is approximately 28 to 32 months.
Alternative 4. - Capping and partial ground water control:
This response action includes 'the components of alternative
2 with the addition of partial ground water control measures.
These measures would include a clay cutoff wall constructed
through the Interstate 435 construction fill to native bedrock in
the former ravine area on the site. A ground water collection
and extraction system would be installed to remove contaminated
ground water intercepted by the clay cutoff wall. The collected *
ground water would be temporarily stored onsite, and then
periodically transported offsite to a permitted treatment
facility.
The estimated construction cost of this remedy is
$5,110,000, with annual O&M costs estimated to be $109,000. The
estimated time to implement this remedy and to meet the cleanup
goals is approximately 28 to 32 months.
•Alternative 5_ - Capping, Partial Ground Water Control and Partial
Source Removal:
Alternative 5 is a combination of the features of
Alternatives 3 and 4. The response action includes the
components of Alternative 2, plus the partial source removal
measures of Alternative 3 and the partial ground water control
measures of Alternative 4.
The estimated construction cost of this remedy is
$5,230,000, with annual O&M costs estimated to be $109,000. The
estimated time to implement this remedy and to meet the cleanup
goals is approximately 30 to 34 months.
36
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Alternative 6 - Complete Excavation and Offsite Disposal:
This alternative proposes complete excavation of the
disposal areas, transportation, and disposal at appropriate
offsite permitted facilities. Approximately 318,000 cubic yards
of materials will need to be excavated and disposed of. The
nature of the bulk of these materials is largely unknown.
Therefore, the most effective methods of excavation, treatment
and disposal have not been defined.
After the wastes have been excavated, the area will be
backfilled with waste rock fill and graded. In additon,
sedimentation and erosion controls and surface water diversions
will be required during the remediation period. Ground water will
be monitored for 5 years to demonstrate the effectiveness of the
alternative.
Implementation of this alternative would significantly
reduce contaminant migration through removal of the source
materials. Removal of the source materials would also eliminate
the potential for exposure to hazardous substances through direct\
contact.
The estimated construction cost of this remedy is
$110,780,000, with annual. O&M costs estimated to be $32,000. The
estimated time to implement this remedy and to meet the cleanup
goals is approximately 24 to 26 months.
gtmnna-ry of the Comparative Analysis of Alternatives
The alternative selected by this ROD is Alternative 3:
Capping and Partial Source Removal. This section provides the
basis for determining that the selected alternative provides the
best balance of tradeoffs with respect to the nine evaluation
criteria. Further information on this alternative is provided in
the following section, The Selected Remedy.
Threshold Criteria:
Overall Protection. Alternatives 2 and 3 would be
approximately equal in their ability to protect offsite water
quality by reducing to a minimum the amount of precipitation that
can come into contact with the contaminant sources. In addition,
the source contaminants would be contained in a manner to prevent
humans from contact.
37
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Alternatives 4 and 5 would provide some additional
protection for offsite water quality by intercepting a primary
pathway for offsite ground water migration. This would further
aid in preventing potential deterioration of offsite water
quality. Alternatives 4 and 5 would protect against direct
contact with source contaminants in the same manner as
Alternatives 2 and 3.
The source removal component of Alternatives 3 and 5 would
further enhance the protection of offsite water quality.
Ultimately, Alternative 6 would provide the greatest overall
protection of human health and the environment through complete
removal of all source contaminants to permitted facilities for
treatment and/or disposal. However, the risks associated with
excavation activities and the extensive truck traffic required
for removal could be significant over the short term.
In summary, Alternative 2 would provide sufficient overall
protection of human health and the environment. Alternatives 3
and 4 would offer slightly better protection through two \
different approaches to contaminant control: Alternative 3
through partial source removal, and Alternative 4 through
interception of already contaminated ground water. Alternative 5
would combine all of these protective measures. Alternative 6
would offer the greatest overall protection through removal of
all source materials; however, the short term risks associated
with implementation of this alternative could be significant.
Compliance with ARARs. All alternatives except "No Action"
would meet all applicable or relevant and appropriate
requirements of Federal and State of Kansas environmental laws.
No waiver of any ARARs would need to be invoked under any of the
action alternatives.
Chemical-specific ARARs: CERCLA Section 121 states that
remedial actions shall attain Federal Water Quality Criteria
(FWQC) where they are relevant and appropriate under the
circumstances of the release or threatened release. FWQC for the
protection of aquatic life are considered relevant and
appropriate to ground water seeps discharging to the Kansas
River. Water Quality Standards promulgated by the State of
Kansas (KWQS) are also considered relevant and appropriate to the
ground water discharges. In addition, the State of Kansas has
established Kansas Action Levels and Alternate Kansas Action
Levels (KALs/AKALs) which are guidelines for ground water
cleanup. AKALs apply to alluvial aquifers and/or specific
38
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aquifers which surface through springs or seeps to become
contributors to the surface waters of the State. AKALs are "to
be considered" (TBC) relevant to the circumstances of this
release. The most stringent of these standards and guidelines,
for a particular contaminant, will be applied to the ground water
seeps to determine compliance.
These standards and guidelines are currently being met by
most contaminants in the ground water seep discharges at -the
perimeter of the site. It is anticipated that the capping remedy
of Alternative 2, by reducing infiltration through the source
areas, would reduce contaminant concentrations in these seeps to
levels well below ARARs and TBCs, in addition to significantly
reducing the volume of seepage.
Alternatives 3 and 4, through two different approaches to
contaminant control, would provide additional assurances that
contaminant-specific ARARs would be met. Implementation of
Alternative 5 would combine these additional assurances.
Implementation of Alternative 6 would eliminate the \
potential for further leaching of contaminants through removal of
the source materials; therefore, this alternative would provide
the greatest reduction in offsite migration and, the greatest
assurance that contaminant-specific ARARs would be met.
Location-specific ARARs: None were found to be either
applicable or relevant and appropriate to the Doepke-Holliday
site. The site is not in a flood plain, and none of the
alternatives should interfere with wetlands or critical habitats.
Action-specific ARARs: Site closure under Alternatives 2
through 5 will comply with all action-specific ARARs. The
facility ceased operation in November 1979 prior to the effective
date of RCRA (November 19, 1980), and these alternatives do not
involve placement/disposal of RCRA-regulated waste; therefore,
the RCRA Subtitle C closure standards are not applicable.
However, the standards have been determined to be relevant and
appropriate to the types of wastes being managed and the
circumstances of the release. Closure of the area will comply
with appropriate portions of the RCRA regulations affecting
landfill closure. Specifically, the site wiil be capped with a
final cover designed and constructed to provide long-term
minimization of the migration of liquids through the capped area,
and to maintain its integrity over time while functioning with
minimum maintenance (40 CFR §§264.111, 264.228, 264.258, and
264.310)
39
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In addition, the cap will be designed and constructed to
promote drainage and minimize erosion of the cover. Consistent
with the requirements of 40 CFR §264.117, long-term operation and
maintenance (O&M) will be conducted to monitor the ground water
around the landfill, and to ensure the integrity of the cap.
The RCRA minimum technology requirements are not applicable
to the capping alternatives, because the remedy does not .involve
a new RCRA unit, a lateral expansion of an existing unit, or a
replacement unit. In addition, these requirements are not
considered relevant and appropriate, because the wastes are
widely dispersed and not contained in a RCRA-type unit.
The partial source removal component of Alternative 3
involves removal of liquids and transport to an offsite permitted
treatment facility. The liquid will be analyzed to determine
whether it requires pretreatment at a permitted RCRA facility
prior to discharge to a publically owned treatment works (POTW).
Similarly, the seepage collection component of Alternative 3v
and the ground water control component of Alternative 4 involve
transport of contaminated water to an offsite permitted treatment
facility. Collected water will be periodically analyzed, and if
contaminant levels exceed the chemical-specific ARARs and TBCs
described above, the contaminated water will be transported to a
POTW for treatment prior to discharge. If the contaminant levels
exceed the pretreatment criteria for wastewater discharge to a
POTW, the contaminated water would be treated at a permitted RCRA
facility prior to discharge to a POTW; however, it is not
expected that this situation will occur.
Alternative 6 will require permitted facilities which can
accept over 300,000 cubic yards of wastes and soils. The nature
of the bulk of these wastes is largely unknown; and therefore,
the most effective methods of treatment and disposal have not
been defined. It is expected that the volume and heterogeneity
of the wastes will make a workable approach to treatment and
disposal of these wastes difficult to design.
Alternative 6 is likely to involve the excavation and
placement of RCRA-regulated hazardous waste; therefore, the RCRA
land disposal regulations (LDRs) are applicable requirements.
This alternative is also likely to involve the excavation and
placement of wastes containing hazardous substances,'where those
substances are not RCRA-regulated waste; in this case, the RCRA
LDRs are not applicable requirements. The EPA is undertaking a
LDR rulemaking that will specifically apply to soil and debris.
40
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Until that rulemaking is completed, the CERCLA program will not
consider LDRs to be relevant and appropriate to soil and debris
that do not contain RCRA-regulated waste.
Some materials may be classified as RCRA regulated wastes,
while other materials may not. Similarly, LDRs may apply to some
wastes and not others. Classifications will be dependant on the
nature of waste characterization. It is anticipated that
consistent application of ARARs will pose significant
difficulties.
Primary Balancing Criteria:
Long-Term Effectiveness and Permanence. Alternatives 2, 3,
4, and 5 offer similar levels of long-term effectiveness and
permanence; although, Alternatives 3, and 4 offer an
enhancement of long-term effectiveness over Alternative 2 through
partial removal of contaminants, thereby slightly reducing the
potential for offsite migration of contaminants. Alternative 5
would provide both partial source removal and ground water
collection, thereby offering the combined reductions in
contaminant migration offered by Alternatives 3 and 4.
Alternative 6 would provide complete removal of contaminant
sources; and therefore, would offer the most reliable and
permanent long-term remediation.
Long-term controls for Alternatives 2 and 3 would include
cap maintenance, continued ground water and seeps monitoring, and
land use and access restrictions. Alternatives 4 and 5 would
require these same long-term controls in addition to maintenance
of the ground water controls. Alternative 6 would require ground
water and seeps monitoring for only five years. In addition,
Alternatives 3, 5, and 6 would require the availability of a
permitted facility for removed waste disposal, and Alternatives 4
and 5 require continued availability of a permitted facility to
treat intercepted ground water.
In summary, Alternative 6 would provide the greatest long-
term effectiveness and permanence, and require the least long-
term controls. Alternatives 2, 3, 4, and 5 provide similar long-
term effectiveness and permanence; although, Alternatives 3, 4,
and 5 offer a slight enhancement of long-term effectiveness over
Alternative 2 through partial removal and treatment of
contaminants. Alternatives 4 and 5 require slightly greater
long-term controls than alternatives 2 and 3 due to continued
interception and treatment of ground water.
41
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Reduction of Toxicity Mobility and Volume. Alternative 2
would not provide destruction or treatment of any contaminants.
Alternative 3 provides for destruction or treatment of a portion
of the source contaminants. Alternative 4 provides for treatment
of a portion of the ground water seepage. Alternative 5 provides
for destruction or treatment of a portion of the source
contaminants, and treatment of intercepted ground water.
Alternative 6 would result in the destruction or treatment of a
substantial portion of the site contaminants.
Alternatives 2, 3, 4, and 5 would reduce mobility through
capping of the disposal areas. Alternatives 4 and 5 would
additionally reduce mobility by intercepting and extracting a
portion of the ground water. Alternative 6 would accomplish the
greatest mobility reduction through total source removal.
Alternatives 3, 4, and 5 would accomplish slight volume
reduction through the treatment and discharge of contaminated
water. Alternative 6 would result in the most significant volume
reduction through treatment and discharge of contaminated water
and dewatering liquids, and/or treatment or incineration of \
wastes.
In summary, Alternative 2 would result in decreased mobility
of contamination due to capping, but provide no reduction in
toxicity or volume. Alternative 3 would offer a slightly greater
reduction in mobility through treatment of a portion of the
source contaminants. Alternative 3 would also offer some
reduction in toxicity and volume through treatment of a portion
of the source contaminants. Similarly, Alternative 4 offers
slight reductions in mobility, toxicity, and volume not provided
by Alternative 2 through interception and treatment of a portion
of the ground water seepage. Alternative 5 combines the
reductions of Alternatives 2, 3, and 4. Alternative 6 offers the
greatest achievable reduction in mobility at the site through
complete source removal, and substantial volume and/or toxicity
reduction through incineration or other treatment of dewatering
liquids and soils/wastes.
Short-term Effectiveness. Alternatives 2 and 4 would be
similar with respect to short-term effectiveness, with the
exception of a small difference in length of time for
construction activities. The potential for direct public
exposure to any contamination should be minimal for these
alternatives. Potential exposure of workers to contaminants
could occur during the removal activities of Alternatives 3, 5,
and 6. This is particularly true for Alternative 6 where there
42
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is potential for fire and explosion, physical hazards, and sudden
exposure to currently unidentified sources of volatile organic
contaminants. No significant environmental impacts are
anticipated from implementation of any alternative. Alternative
6 could generate significant amounts of sediment and runoff
during implementation; however, the use of appropriate
engineering controls would minimize the potential for adverse
impacts.
Similar worker protection and access control are required
for Alternatives 2 through 5. Alternative 6 would require
significantly greater amounts of access control, worker
protection, and traffic control.
In summary, all alternatives except Alternative 6 are very
similar in short-term effectiveness with the exception of small
differences in implementation time. Alternative 6 may pose
significant implementation hazards due to the magnitude and
'diversity of the materials to be removed.
Implementability. The ground water control measures of '
Alternatives 4 and 5 would pose certain construction difficulties
due to bedrock and topographic constraints. These constraints
would also pose construction difficulties in the implementation
of Alternative 6, since much of the wastes and soils to be
removed are located along steep slopes. Site restoration in
Alternative 6 would be significantly more difficult than for all
other alternatives. Alternatives 2 and 3 would encounter only
minimal construction difficulties, although Alternative 3 would
include the additional difficulty of removing the ponded liquids.
The administrative feasibility of Alternatives 4 and 5 would
be dependant on acceptance of the intercepted ground water by a
permitted treatment facility on a long-term basis. Alternatives
3 and 5 would require the short-term availability of a permitted
treatment facility to accept up to 100,000 gallons of liquid
wastes. Alternative 6 would require permitted facilities which
could accept over 300,000 cubic yards of wastes and soils. The
volume and heterogeneity of the wastes makes a workable approach
to treatment of these wastes difficult to design. Additionally,
Alternative 6 would require the availability of permitted haulers
to complete over 21,000 trips during the 24 to 26-month
excavation period.
In summary, Alternative 6 would encounter the most
administrative constraints, since it would require substantial
and potentially unavailable facilities. Alternative 6 would also
43
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encounter some significant technical constraints due to the
location, volume, and unknown characteristics of the materials to
be removed. Alternative 2 would have relatively few
implementation constraints, all of which are also relevant to the
other alternatives. Alternatives 4 and 5 would require very
skilled construction, since a high level of difficulty would be
encountered. Alternative 3 would entail only moderate
construction complexity and administrative constraints.
Cost. Each alternative was evaluated for estimated costs of
implementation. Estimated costs include capital costs as well as
annual operation and maintenance costs. The net present worth of
these costs provides the basis for comparison.
Alternatve 1, the no-action alternative, has no costs. The
estimated costs for the remaining alternatives are summarized in
Table 6.
Modifying Criteria;
State Acceptance. The State of Kansas supports the selected'
alternative.
Community Acceptance. A public comment period was held from
August 4, 1989, through August 25, 1989. In addition, a public
meeting was held on August 16, 1989, to explain the preferred
remedy and elicit comments from the public. Public comments
received during the comment period indicate that a majority of
the community supports the major components of the selected
remedy. All comments received from the public are addressed in
the attached Responsiveness Summary.
The Selected Remedy
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, the
U.S. EPA and the State of Kansas have determined that Alternative
3: Capping and Partial Source Removal is the most appropriate
remedy for the Doepke-Holliday site in Johnson County, Kansas.
Alternatives 3, 4, and 5 perform similarly well when
evaluated against the primary balancing criteria, and they
outperform Alternatives 2 and 6. The reasons that Alternative 3
is selected over Alternatives 4 and 5 are: A) there are
potentially significant uncertainties associated with the
constructability of the clay cutoff wall and extraction system;
44
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TABLE 6
SUMMARY OF COST ANALYSIS OF ALTERNATIVES
ALTERNATIVE
2 - Capping
3 - Capping with
partial source
removal
4 - Capping with
partial ground
water controls
5 - Capping, partial
source removal and
ground water controls
6 - Complete excavation
Capital
Cost
4,130,000
4,330,000
5,110,000
5,230,000
110,780,000
Annual
O&M
Cost
72,000*
107,000*
Present
Worth
Cost***
5,240,000
5,970,000
109,000* 6,790,000
109,000* 6,910,000
32,000** 110,920,000
PW Factor for capital costs = 1.000
PW Factor for 30 years O&M = 15.372
PW Factor for 5 years O&M = 4.329
* Constant for 30 years
** Constant for 5 years
*** Interest (discount rate) = 5%
45
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B) if the multi-layer impermeable cap performs as expected, there
will be no need for ground water controls; C) the selected
alternative (Alternative 3) includes collection and analysis of
significant ground water seepage which, for the near-term, will
achieve many of the same benefits of the ground water controls of
Alternative 4; and, D) if need be, the remedy can be later
modified to include the ground water controls of Alternative 4.
The major components of the selected, remedy include-the
following:
- Removal and offsite treatment of contaminated liquids
currently ponded underground in the former surface
impoundment area; and
- Construction of an impermeable multi-layer cap over the
majority of the waste diposal area; and
- Collection and offsite treatment, as necessary, of
significant ground water seepage; and
\
- Extended ground water monitoring to evaluate the
effectiveness of the remedy; and
- Deed and access restrictions; and
- If necessary, the response action will be modified to
include the ground water controls of Alternative 4:
construction of a clay cutoff wall, and extraction and
offsite treatment of collected ground water.
Successful removal of the liquid currently ponded
underground in the former surface impoundment area is dependant
on the assumption that this is a discrete source situated in a
relatively impermeable sedimentary formation that can be removed
through pumping or other conventional dewatering techniques. If
it were discovered that these liquids are in free communication
with the shallow ground water, the advisability of this action
will be reevaluated.
Pre-design work will include A) additional investigations to
firmly establish the northern, western, and southern extent of
contaminated soils and buried wastes; and, B) additional
investigations to evaluate the vertical extent of contaminated
ground water, and the southern extent of contaminated ground
water. The results of these investigations will be used to
define the extent of the impermeable multi-layer cap, and the
nature of the extended ground water monitoring network.
46
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TABLE 7
CAPITAL COST SUMMARY
ALTERNATIVE 3 - CAPPING WITH
PARTIAL SOURCE REMOVAL
ITEM
UNIT TOTAL
QUANTITY UNITS COST ($) COST (S)
Contractor Mobilization
and Demobilization
LS
1300.00
1,300
Well Installation
Cap Boundary Trenches
(approx. 20 @ 20' deep
x 50' long)
South Lagoon - Dewater,
Transport & Treatment
Seep Well, Pump,
Pipeline & Tank
New Road to Seep
Storage Tank
Cap System
Topsoil (6")
Clean Fill (18")
Sand (12")
HOPE Liner 1,
Geotextile Membrane 1,
Clay (24")
Seed & Fertilizer
Asphalt Cap
Asphalt Layer (2")
Drainage Layer (6")
Geotextile Membrane
HOPE Liner
Rough Grading
Drainage Channels
35
2,200
96,000
1
100
24,800
74,400
49,600
339,000
339,000
99,200
31
50,800
940
50,800
50,800
133,300
5,000
LF
CY
GAL
LS
LF
CY
CY
CY
SF
SF
CY
AC
SF
CY
SF
SF
SY
LF
75.00
4.00
0.75
44,620.00
55.00
6.00
6.00
10.00
0.30
0.15
4.70
1650.00
0.75
10.00
0.15
0.30
0.09
10.00
2,625
8,800
72,000
44,620
5,500
148,000
446,400
496,000
401,700
200,850
466,240
51,150
38,100
9,400
7,620
15,240
11,997
'0,000
47
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TABLE 7 (continued)
CTEM
UNIT TOTAL
QUANTITY UNITS COST f$) COST
Site Security Fencing
Rock Barrier
Chain Link
Decontamination Station
Decontamination Wastes
Disposal
3,000
5,500
1
1
LF
LF
LS
LS
9.50
11.00
20000.00
20000.00
28,500
60,500
20,000
20,000
Construction Subtotal
Bid Contingencies (15%)
Scope Contingencies (20%)
2,607,342
391,101
521,460
Construction Total
Permitting and Legal (5%)
Service During Construction (10%)
Engineering Design Cost (8%)
3,519,911
175,996
351,991
281,593
Total Capital Cost
4,330,000
48
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TABLE 8
OPERATION AND MAINTENANCE COSTS
ALTERNATIVE 3 - CAPPING
ITEM
Continued Monitoring
Labor
Equipment
Sampling/Analysis
Seep Water Disposal
Mowing and General
Maintenance & Upkeep
Asphalt Cap Maintenance
Option Subtotal
Scope Contingencies (15%)
Total Annual O&M Costs
QUANTITY
80
60
32
UNITS
HR
HR
EA
UNIT
COST
40
25
1000
TOTAL
COST
3,200
1,500
32,000
1500 KGAL
31
5600
AC
SY
20
700
0.8
30,000
21,700
4,480
92,880
15,932
107,000
49
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The extended monitoring program will include sampling and
analysis of ground water seeps and the primary pathway for
offsite ground water migration. Contaminant concentrations will
be compared with Federal Water Quality Criteria for the
protection of aquatic life (FWQC), Kansas Water Quality Standards
(KWQS), and Alternate Kansas Action Levels (AKALs) to determine
compliance of the remedy. As discussed in the previous section,
Summary of the Comparitive Analysis of Alternatives, the
appropriate standard or criteria for a'particular contaminant is
considered to be the most stringent of these three. Contaminants
which have been detected in the seep water in excess of ARARs and
TBCs are summarized in Table 9.
Collection and analysis of significant ground water seepage
(referred to as seep no. 1 in the RI/FS reports) will be carried
out during the remedial action period and for some reasonable
time after completion of the remedial action. If continued
analysis of the collected water demonstrates that offsite
migration of contaminants is not significant (i.e., below
chemical-specific ARARs and TBCs as discussed), and that the
ground water monitoring program will be sufficiently protective,
this action will be discontinued. The remedy will be modified tov
include ground water controls if the extended monitoring program
identifies a significant increase in the offsite migration of
contaminants.
The capital costs and O&M costs for this remedy are detailed
in Tables 7 and 8, respectively. The use of specific dimensions
and technologies is for costing purposes only and actual design
may differ.
It is anticipated that the selected remedy will achieve all
of the remediation goals described in a previous section of the
ROD Decision Summary, Role and Scope of the Response Action.
Specifically, placement of the impermeable multi-layer cap will
control health risks posed by direct contact with contaminated
soils and waste materials, and eliminate the potential for
significant offsite migration of contaminants.
Since contaminants will remain onsite above health-based
levels. Section 121 (c) of SARA requires that the remedial action
be reviewed at least every five years to assure that human health
and the environment are protected. It is anticipated that this
requirement will be satisfied through extended ground water
monitoring.
Statutory Determinations
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
50
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TABLE 9
DOEPKE-HOLLIDAY SITE
SUMMARY OF COMPOUNDS DETECTED IN SEEP WATER
THAT EQUAL OR EXCEED
CHEMICAL-SPECIFIC ARARs & TBCs
Compound
Aluminum
Cadmium
Copper
Silver
Endosulfan
Sulfate
Chlordane
DDT
Dieldrin
Endosulfan
Heptachlor
Cone.*
fncr/1)
4.2
0.005
0.013
0.05
0.001
0.001
0.0001
0.0001
0.0001
0.0005
AKAL
fmo/H
0.75
KWQS
fmo/1)
0.00012
FWQC
fmcr/11
0.0011
0.012
0.00012
0.00022
0.0024
0.0011
_ —
0.00022
0.00052
0.0000043
0.000001
0.0000019
0.000056
0.0000038
0.0000043
0.000001
0.000001
__„
* Maximum Concentration Detected
AKAL - Alternate Kansas Action Level
KWQS - Kansas Water Quality Standard for Protection of Aquatif
Life
FWQC - CWA Ambient Water Quality Criteria for Protection of
Freshwater Aquatic Life (Chronic)
51
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addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this site must comply
with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws,
unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
following sections discuss how the selected remedy meets these
statutory requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the
environment through installation of a multi-layer impermeable cap
over the majority of the waste disposal areas. Placement of the
cap will minimize or eliminate health risks posed by direct
contact with contaminated soils and waste materials. Also, cap
design will be consistent with appropriate portions of the RCRA ;
landfill closure requirements, thereby minimizing the likelihood
of contaminant migration to offsite areas. There are no short-
term threats associated with the selected remedy that cannot be
readily controlled. In addition, no adverse cross-media impacts
are expected.
Compliance With Applicable or Relevant and Appropriate
Requirements
The selected remedy of capping and partial source removal
will comply with all applicable or relevant and appropriate
chemical-, action-, and location-specific requirements (ARARs).
The ARARs are presented below.
Chemical-specific ARARs:
Clean Water Act (CWA) Ambient Water Quality Criteria for the
protection of aquatic life. Contaminants in ground water
seeps discharging to surface waters will comply with these
criteria.
CWA Publicly-Owned Treatment Works (POTW) standards.
Contaminated water will meet pretreatment standards prior to
discharge to a POTW.
Kansas Water Quality Standards (KWQS). Contaminants in the
ground water seeps will comply with these standards.
52
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Clean Air Act (CAA) National Air Quality Standards for Total
Suspended Particulates may be applicable during cap
installation.
Action-specific ARARs:
RCRA requirements for landfill closure (40 CFR 264.111,
264.228, 264.258, and 264.310), which require that the site
will be capped with a final cover designed and constructed to
provide long-term minimization of the migration of liquids
through the capped area, and to maintain its integrity over
time while functioning with minimum maintenance. RCRA
minimum technology requirements are not ARAR.
40 CFR 264.117(a)(1) Subpart G Post-Closure and Monitoring
requirements for thirty years or another period determined
by the Regional Administrator.
Location-specific ARARs:
No location-specific ARARs were found to be either ,v
applicable or relevant and appropriate to the Doepke-
Holliday site.
Other Criteria, Advisories or Guidance To Be Considered for This
Remedial Action (TBCs):
Alternate Kansas Action Levels (AKALs). Contaminants in the
ground water seeps will comply with these guidelines.
Local deed restrictions will be necessary to prohibit
excavation at the site after remedial action is complete.
Cost-Effectiveness
The selected remedy has been determined to provide overall
effectiveness proportional to its costs. The selected remedy
provides protection of human health and the environment which is
similar to those alternatives involving ground water controls yet
is about 20 % less expensive. The selected remedy effectively
reduces the hazards posed by all of the contaminants at the site,
yet is an order of magnitude less expensive than the alternative
involving complete excavation.
Utilization of Permanent Solutions' and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable
It has been determined that the selected remedy represents
the maximum extent to which permanent solutions and treatment
53
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technologies can be utilized in a cost-effective manner for the
Doepke-Holliday site. Of those alternatives that are protective
of human health and the environment and comply with ARARs, the
selected remedy provides the best balance of tradeoffs in terms
of long-term effectiveness and permanence, reduction toxicity,
mobility, or volume achieved through treatment, short-term
effectiveness, implementability, cost, also considering the
statutory preference for treatment as a principal element and
considering State and community acceptance.
The only alternative providing significantly better long-
term effectiveness and permanence involves complete excavation
and treatment of the contaminant sources. This alternative is
not considered practicable due to technical constraints, the
potential for significant short-term risks to public health, and
the prohibitive costs.
Preference for Treatment as a Principal Element
Treatment of the bulk of the contaminant sources at the site
was new found to be practicable; and therefore, the remedy does *
not satisfy the statutory preference for treatment as a principal
element of the remedy. The remedy includes treatment of a
discrete portion of the liquids contained in the source area;
however, the large extent of the .landfill, the heterogeneous
disposition of the wastes, and the fact that there are no
identified hot spots that can be considered to represent the
major sources of contamination preclude implementation of a
remedy in which contaminants could be excavated and treated
effectively.
The preference for remedies which involve treatment is
inherent to the process used to evaluate and compare
alternatives. This is demonstrated by the fact that Alternatives
3, 4, and 5, which involve some treatment, out perform
Alternative 2, containment only, when these alternatives are
evaluated against the balancing criteria. However, the treatment
components of Alternatives 3, 4, and 5 are not considered a
principal element of these remedies, because the majority of the
contaminants would remain untreated.
Alternative 6, complete excavation and offsite
treatment/disposal, is the only alternative which involves
treatment as a principal element; however, this alternative is
not practicable to implement due to technical constraints, the
potential for significant health risks during implementation, and
the prohibitive costs. See the Summary of Comparative Analysis
of Alternatives Section for more discussion on the disadvantages
of this alternative.
54
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RESPONSIVENESS SUMMARY
DOEPKE-HOLLTDAY SITE
I. RESPONSES TO WRITTEN COMMENTS
A. Responses to Written Comments in the August 24. 1989
Wyss. P.E.. Chief Engineer/Director of Production Services,
District No. 1 of Johnson County.
Comment 1: We feel that the proposed plan to cap the contaminated area should
sufficiently reduce the amount of leachate formed, and thus lessen the risk of
contaminants migrating from the site.
EPA Response 1: We agree. The multi-layer impermeable cap in the
Selected Alternative will significantly reduce the amount of
precipitation infiltrating into the contaminated materials on the site,
thereby significantly reducing the amount of leachate formed and
significantly reducing contaminant migration via ground water. The
Selected Alternative will be protective of public health and the
environment and will comply with Federal and Kansas requirements that are
legally applicable or relevant and appropriate to this action.
Comment 2: We are concerned with the runoff from the cap that is redirected
through the concrete and earthen drainage channels. Since this runoff would
ultimately drain into the Kansas River, we propose that this runoff be sampled
after sufficient amounts of rainfall.
EPA Response 2: Runoff from the cap will not come in contact with any
contaminated materials, so there is no demonstrated needed to sample and
analyze the runoff. Runoff from the cap will consist of precipitation
flowing over the cap surface and of infiltration flowing through the
drainage layer in the multi-layer cap system. The design of the cap will
keep runoff separated from contact with the contaminated soils and
materials currently on the site. The Remedial Design and Remedial Action
will include provisions and activities to ensure that the materials
brought on site to construct the cap are not contaminated.
Comment 3: We encourage a stringent monitoring program of all existing and
proposed monitoring wells as well as ground seeps.
EPA Response 3: The Selected Alternative includes a long-term
monitoring program of existing and future monitoring wells and of ground
water seeps.
Comment 4: Should the monitoring program reveal that the cap is ineffective,
the addition of a partial groundwater control system would be in the best
interest of the Water District and the people it serves.
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Responsiveness Summary
Doepke-Holliday Site
EPA Response 4: If ground water monitoring indicates an increase in
contaminant migration, the Selected Alternative would be modified to
include partial ground water control measures.
B. ppgpnnctf* to Written Comment in the August 25. 1989 Letter from William
G. Beck. Tqthrop Kbontz & Norquist. on the behalf of Browning—Ferris
Industries of Kansas City. Inc.
Comment 1: We suggest: that the Record of Decision, when issued, should
explicitly defer the selection of the final design of the impermeable
multi-layer cap to the remedial design phase. By testing the anticipated
performance of several different possible design options, an alternative
design which is better in performance or cost effectiveness may be discovered.
EPA Response 1: We agree, as this is consistent with our guidance for
the preparation of Records of Decision. The selection of the final
design for the impermeable multi-layer cap will performed during Remedial
Design.
C. Responses to Written Comments in the August 25. 1989 Letter from Ronald
D. Deffenbaugh. Deffenbauon Industries. Inc. ;
i ,
Comment 1: We agree that doing additional site investigations in an attempt
to locate buried drums would probably be detrimental to the site. Detrimental
effects to the site may include risk of fire or explosion, worker exposure
during intrusive site investigations and the uncertainty of drum integrity
after 20 years.
EPA Response 1: We agree. The potential short-term negative impacts on
public health and the environment are significantly greater than the
long-term benefits posed by the additional site investigation to locate
buried drums containing liquids and the removal of the located drums
still containing liquids. After 20 years of burial, it is doubtful that
the drums still have enough integrity to hold liquids. The additional
site investigation will yield numerous indications of buried metallic
objects, few of which are expected to be buried drums and none of which
are expected to be buried drums containing liquids. The intrusive
activities to unearth the buried metallic objects located by the
additional site investigation would probably be unproductive, yet will
pose the potential risks of fire or explosion and of worker exposure to
unknown hazardous materials.
Comment 2: As the RI fieldwork was performed, it was noted that the south
lagoon is situated in the Vilas Shale formation. The Vilas Shale is a
relatively impermeable sedimentary formation. Data obtained from the adjacent
monitoring well does not indicate significant groundwater contaminants
associated with the contaminants detected in the south lagoon. We feel that
since the lagoon is now intact in a tight shale formation that the potential
for off-site migration is low. In addition, the proposed cap should further
minimize any migration potential of this source area.
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Responsiveness Summary
Doepke-Hblliday Site
EPA Response 2: As stated in the RI Report, the south lagoon was
observed to contain petroleum type sludges and used oil filters, some of
which appeared to be charred or burnt. It is agreed the Vilas Shale is
relatively impermeable, as otherwise the now subsurface south lagoon
would not still contain liquids after 20 years of burial. However, it is
not agreed that the potential for off-site migration is low.
Furthermore, the additional pressures posed by the cap construction
equipment and by the cap may cause contaminant migration from the south
lagoon or may increase existing contaminant migration from the. south
lagoon.
Comment 3: It is stated that significant groundwater seepage will be
collected and analyzed. If the collected water is found to be contaminated in
excess of the Kansas Action Levels (KAL's), it will be taken off-site for
treatment. We believe since the site has been idle for 20 years, it would be
premature to install collection devices when the significant groundwater
seepages can be effectively monitored in their current state. In the future,
if significant contamination does appear in excess of KAL's, collection
devices could easily be installed for subsequent treatment.
EPA Response 3: We agree that the significant ground water seepages canv
be effectively monitored in their current state. However, for the
remedial action period and for some time after, EPA believes it would be
prudent to implement this action as an additional assurance that the
Selected Alternative will be protective of public health and the
environment. For that reason, the Selected Alternative includes the
collection and analysis of significant ground water seepage and, if the
collected water is found to be contaminated in excess of Applicable or
Relevant and Appropriate Requirements (ARARs), offsite treatment of the
collected ground water seepage. If it is demonstrated over after a
reasonable period that extended monitoring of the seepage will be
sufficiently protective, then collection of the seepage will be
discontinued.
D. Responses to Written Comments in the August 24. 1989 Letter from Craig A.
IHbow and M. Troy Gordon. Sierra Club. Kanza Group of the Kansas Chapter
Comment 1: Alternative 1—No Action—fails to comply with federal and state
(ARARs) regulations. Since failure to take action would threaten the public
health, we find this alternative to be,completely unacceptable.
EPA Response 1: We agree.
Comment 2: Alternative 2—Capping—along with the remaining alternatives does
comply with the applicable regulations.
EPA Response 2: We agree.
Comment 3: In regard to Alternative 2, capping will prevent precipitation
from entering the disposal site, but still permits the potential for
contaminants to migrate into the ground water and the Kansas River. It also
fails to protect against continued contamination from the buried drums, as
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Responsiveness Summary
Doepke-Hblliday Site
well as contamination from liquids ponded below grade in the south lagoon
area. Therefore, capping alone is unacceptable.
EPA Response 3: Alternative 2 would comply with ARARs and would be
protective of public health and the environment. The major transport
mechanism for contaminant migration into the ground water and the Kansas
River is the infiltration and percolation of precipitation into and
through contaminated materials on the site. Because capping will
significantly reduce the amount of precipitation entering and flowing
through contaminated materials on the site, capping will significantly
reduce contaminant migration into the ground water and the Kansas River.
As stated in a previous EPA response, the short-term negative impacts of
buried drum removal significantly outweigh the long-term benefits of
buried drum removal.
Comment 4: If capping is utilized as an option, or in conjunction with
another alternative, it must encompass the entire disposal site to be
effective and must be composed of a RCRA multilayer cap. If the disposal area
is found to include any portion of the adjacent Deffenbaugh site or the old
Overland Park landfill, it will be necessary to cap the additional land.
\
EPA Response 4: All of the capping alternatives include additional
investigations during Remedial Design to evaluate the extent of the cap
needed to cover contaminated materials. If the additional investigations
indicate that contaminated materials extend onto adjacent properties, the
cap will be designed to extend onto those adjacent properties to cover
contaminated materials. As stated in a previous EPA response, it is
premature now to select the final design for the cap. The final design
for the multi-layer impermeable cap will be selected during Remedial
Design. The final design will be consistent with the relevant and
appropriate RCRA requirements for landfill closure.
Comment 5: In regard to Alternative 3—Capping and Partial Source Removal, in
addition to the benefits of capping, the partial source removal as proposed by
the EPA would potentially remove the liquid contaminants in the south lagoon
area. Effective partial source removal would also mandate the Deffenbaugh
proposal to excavate the buried drums be adopted. The long-term benefits from
the excavation of the buried drums outweighs the risk of contamination, as
well as the dangers associated with the removal process.
EPA Response 5: The Feasibility Study Report prepared by Deffenbaugh
Industries, Inc., proposed that additional investigations be performed to
locate buried drums in a specific area (the vicinity of the shale pile)
and that only intact buried drums containing liquids be removed. As
stated in a previous EPA response, the search for buried drums containing
liquids would be detrimental to public health and the environment. The
potential short-term negative impacts on public health and the
environment are significantly greater than the long-term benefits posed
by the additional site investigation to locate buried drums containing
liquids and the removal of the located drums still containing liquids.
After 20 years of burial, it is doubtful that the drums still have enough
integrity to hold liquids. The additional site investigation will yield
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Doepke-Hblliday Site
numerous indications of buried metallic objects, few of which are
expected to be buried drums and none of which are expected to be buried
drums containing liquids. The intrusive activities to unearth the buried
metallic objects located by the additional site investigation would
probably be unproductive, yet will pose the potential risks of fire or
explosion and of worker exposure to unknown hazardous materials.
Comment 6: In regard to Alternative 3—Capping and Partial Source Removal,
partial source removal fails to protect against migration of contaminants
through ground water and into the Kansas River. This deficiency makes this
alternative unacceptable from a public health viewpoint.
EPA Response 6: Alternative 3 would comply with ARARs and would be
protective of public health and the environment. The major transport
mechanism for contaminant migration into the ground water and the Kansas
River is the infiltration and percolation of precipitation into and
through contaminated materials on the site. Because capping will
significantly reduce the amount of precipitation entering and flowing
through contaminated materials on the site, capping will significantly
reduce contaminant migration into the ground water and the Kansas River.
In addition, no significant migration of contaminants into the ground v
water and the Kansas River has been observed during the last 8 years of
monitoring this uncontrolled site.
Comment 7: In regard to Alternative 4—Capping and Partial Ground Water
Control, partial ground water control helps to prevent contaminated ground
water from entering the Kansas River, if done in conjunction with capping.
Ground water control is essential to the protection of the drinking water of
Johnson County. Ground water control without partial source removal, however,
guarantees the continuing of leachate from the drums, as well as hazardous
liquids at the iinpoundment area. The foregoing problems render this
alternative unacceptable from an environmental, viewpoint.
EPA Response 7: Alternative 4 would comply with ARARs and would be
protective of public health and the environment. As previously stated,
capping without any other actions would comply with ARARs and would be
protective of public health and the environment. Capping will
significantly reduce the amount of precipitation entering and flowing
through contaminated materials on the site, thereby significantly
reducing the formation of contaminated leachate from the buried drums,
hazardous liquids in the south lagoon area, and contaminated soils and
materials at the site. This, in turn, will significantly reduce
contaminant migration into the ground water and the Kansas River. The
partial ground water control proposed in Alternative 4 would manage only
one flow path of ground water migration to the. Kansas River and would not
account for all ground water migration off of the site. The
inappropriateness of a drum search and removal has been discussed under
previous EPA responses.
Comment 8: In regard to Alternative 4—Capping and Partial Ground Water
Control, it will be necessary that the collected ground water be taken to a
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facility specifically designed for the treatment of contaminated water. Care
must be taken to prevent the discharge of inadequately treated water.
EPA Response 8: As discussed in the Feasibility Study Report, the
collected ground water would be transported by tank truck to a wastewater
treatment facility. The collected ground water would be sampled and
analyzed to evaluate whether the collected ground water requires
pretreatment prior to discharge to the wastewater treatment facility. If
necessary, the collected ground water will be pretreated prior- to
discharge to the wastewater treatment facility. These steps will be
taken so as not to cause non-compliance problems for the treatment
facility in regard to its discharge permit requirements.
' i
Comment 9: In regard to Alternative 5—Capping, Partial Ground Water Control,
and Partial Source Control, this option combines the foregoing benefits of
alternatives two, three, and four. While long-term contamination of the area
will remain in the absence of complete excavation of the disposal site, this
alternative is acceptable from a public health and environmental perspective.
The costs associated with this option are only 23% higher than the alternative
preferred by the EPA and the additional annual costs would be minimal. The
increased,benefits of this alternative justify the additional costs. \
i i
EPA .Response 9: With the exception of "No Action", all of the
alternatives would comply with ARARs and would be protective of public
health and the environment. The Selected Alternative involves capping,
partial source removal through the removal of ponded liquids in the south
lagoon area and, as an additional assurance, collection and treatment (as
necessary) of significant seepage. It is uncertain at this time whether
partial ground water control would provide any increased benefits,
because the measures included in the Selected Alternative are expected to
significantly reduce contaminant migration to the ground water and the
Kansas River. Extended monitoring of ground water and seepage is a
fundamental part of the Selected Alternative. The Selected Alternative
includes a contingent action: if continued ground water monitoring
indicates an increase in contaminant migration, the Selected Alternative
would be modified to include partial ground water control measures.
Comment 10: In regard to Alternative 6—Complete Excavation and Off site
Disposal, this option provides the only complete solution to resolving the
site's contamination. It most effectively protects the public against the
risk of contamination of its drinking water supplies. The cost of
implementing this alternative, however, would be prohibitive. If this
alternative were selected, there would need to be assurances that adequate
treatment facilities are available for the large volume of excavated
materials.
EPA Response 10: With the exception of "No Action", all of the
alternatives would comply with ARARs and would be protective of public
health and the environment. It is agreed that the cost of implerenting
Alternative 6 would be prohibitive, plus there would need to be
assurances that adequate disposal facilities are available for the large
volume of excavated materials. It should be noted that this alternative
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Responsiveness Summary
Doepke-Hblliday Site
would protect the public drinking water supply in Johnson County, however
it poses potential risks to the public along the transportation route and
in the vicinity of the disposal facility.
Comment 11: We feel that alternative six is the optimal long-term solution.
However, recognizing the cost constraints involved, we advocate adoption of
alternative five. The benefits of alternative five include shielding the site
from precipitation, removal of the sources of contamination, and protection
against contaminated ground water entering the Kansas River. Alternative five
should be adopted with the following modifications. The cap should be an RCRA
multi-layer cap and should cover the entire disposal site, including any
adjacent tracts which were also used for disposal. Deffenbaugh's proposal to
remove the drums must be implemented. Care must also be taken to assure
prevention of the discharge of inadequately treated water after collection.
EPA Response 11: All of the alternatives, with the exception of "No
Action", would comply with ARARs and would be protective of public health
and the environment. We do agree that Alternative 6 may be the optimal
solution in regard to long-term effectiveness. However, long-term
effectiveness is only one of the several criteria that must be balanced
against in the selection process. For the short-term, Alternative 6 ;
poses significant potential risks to the public health and the
environment associated with potential exposures during waste excavation
and transportation activities. Furthermore, Alternative 6 involves the
relocation of wastes from one site to another site.
Alternative 5 does not include removal of the bulk of the sources of
contamination. The site consists of a heterogeneous mix of wastes and
contaminated soils. For Alternative 5, only a partial removal of
contamination sources is proposed: removal of ponded liquids in the south
lagoon area. A drum search and removal program is not feasible for this
site, because of the potential risk and non-productiveness reasons stated
in previous EPA responses.
As previously stated, capping without any other actions would comply with
ARARs and would be protective of public health and the environment.
Capping will significantly reduce the amount of precipitation entering
and flowing through contaminated materials on the site, thereby
significantly reducing the formation of contaminated leachate. This, in
turn, will significantly reduce contaminant migration into the ground
water and the Kansas River. The partial ground water control proposed in
Alternative 5 would manage only one flow path of ground water migration
to the Kansas River and would not account for all ground water migration
off of the site.
It is uncertain at this time whether partial ground water contro.l would
provide any increased benefits, because the measures included in the
Selected Alternative are expected to significantly reduce contaminant
migration to the ground water and the Kansas River and may reduce ground
flow to the point where ground collection may not be practicable. The
Selected Alternative includes a contingent action: if continued ground
water monitoring indicates an increase in contaminant migration, the
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Responsiveness Summary
Doepke-Holliday Site
Selected Alternative would be modified to include partial ground water
control measures.
As stated in previous EPA responses, it is premature to select the final
design of the multi-layer impermeable cap. The final design of the cap
will be consistent with the relevant and appropriate RCRA requirements
for landfill closure. The cap will be designed to cover the extent of
contaminated materials as established by additional investigations. Care
will be taken to prevent the discharge of inadequately treated' water.
Comment 12: He believe it is essential that the implementation of the
selected remedial action must be closely monitored by the EPA. Maintaining
public confidence and assurance of quality work necessitates that the EPA not
contract with a private firm having any potential conflict of interest.
EPA Response 12: It is now unknown whether EPA or potentially
responsible parties will implement the remedial action. In either case,
EPA will closely monitor the implementation of the remedial action to
assure that quality work is performed. It is also now unknown whether
EPA will use contractor support to monitor the remedial action. If
contractor support is used, standard EPA contract language will be used *
to preclude the use of contractors having actual, potential, or perceived
conflicts of interest, at the risk of breach of contract and of
contractor debarment from future Federal contracting.
E. Responses to Written Comments in the August 24. 1989 Latter from John P.
Cl*a^TV. Assistant Project M^naqT. and Robert F. Wells. Vice President
and Treasurer. T H Agriculture & Nutrition Company. Inc.
Comment 1: EPA's proposal to collect and analyze the seep water does not
appear to be technically supported by the data and would not provide benefits
to the public or environment. Since the late 1970's or early 1980's, USEPA
has monitored the effluent from Seep #1 at the Doepke-Holliday landfill for
all compounds on the Priority Pollutant List. The EPA analytical data base
indicates that only trace levels of organics and metal compounds have been
detected throughout the many years of sampling and analysis. The Public
Health Assessment concludes that "The concentration of indicator chemicals in
groundwater and seepwater at the site poses no significant risk to public
health or the environment because the concentrations of indicator chemicals in
the seepwater are below the maximum contaminant levels (MCLS)."
EPA Response 1: The Public Health Assessment was limited to evaluations
of certain indicator chemicals, and the conclusions stated in the Public
Health Assessment are limited to only those certain indicator chemicals.
However, as presented in Table 3-6 of the Feasibility Study Report, the
concentrations of several organic and metal compounds (non-indicator
chemicals) in the seep water have exceeded contaminant-specific ARARs.
The cap in the Selected Alternative is expected to reduce contaminant
migration and to decrease ground water seep discharges, if not eliminate
them. However, for the remedial action period and for some time after,
EPA believes it would be prudent to implement this action as an
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Doepke-Holliday Site
additional assurance that the Selected Alternative will be protective of
public health and the environment. For that reason, the Selected
Alternative includes the collection and analysis of significant ground
water seepage and, if the collected water is found to be contaminated in
excess of ARARs, off site treatment of the collected ground water seepage.
If it is demonstrated over after a reasonable period that extended
monitoring of the seepage will be sufficiently protective, then
collection of the seepage will be discontinued.
Comment 2: The RI/FS documents, which were reviewed by EPA, make no
recommendations or provisions for collection of seep waters due to the fact
that only trace levels of selected compounds have-been detected. We believe
that the Proposed Remedial Alternative No. 3 (capping and partial source
removal) will not adversely influence the documented water quality in the seep
effluent but will eventually reduce the average discharge rate and
additionally reduce the amount of contaminants potentially entering the Kansas
River.
EPA Response 2: The collection of significant site seepage for analysis
and possible treatment was addressed in a Feasibility Study supplement \
that was prepared by EPA and included in the site's Administrative
Record. We agree that capping and partial source removal will not
adversely influence water quality in the seep effluent and will
eventually reduce the average discharge rate and the amount of
contaminants potentially entering the Kansas River. However, as stated
in the previous response, EPA believes it to be prudent to include the
collection, analysis, and treatment as necessary of seep water in the
Selected Alternative, as an additional assurance that the Selected
Alternative will be protective of public health and the environment.
Comment 3: It is unclear from the Proposed Plan whether the final remedy will
include indefinite collection of the seep water. Continual monitoring of the
seep appears to be a rational approach to implement during and subsequent to
the remedial action to assess a potential change of water quality. Provisions
for more frequent seep sampling during the remedial action would provide
adequate information to determine if seep waters should be collected and
treated. The Remedial Design/Remedial Action work plan could include a
contingency if future analytical data support this proposed action.
EPA Response 3: The Selected Alternative includes the collection and
analysis of significant ground water seepage and, if the collected water
is found to be contaminated in excess of Applicable or Relevant and
Appropriate Requirements, off site treatment. This management of seepage
is included in the Selected Alternative as an additional assurance that
fre Selected Alternative will be protective of public health and the
environment. If it is demonstrated over a reasonable period that
extended monitoring of the seepage will be sufficiently protective, then
collection of the seepage will be discontinued.
Comment 4: The Proposed Plan indicates that EPA is considering the inclusion
of a rock fill layer on top of the final site cap. We believe EPA should
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Doepke-Holliday Site
consider the long term econonic and technical disadvantages of the rock fill
layer. If future groundwater monitoring indicates that additional remedial
action would be required, it may be necessary to remove the rock fill layer
for investigation purposes. This procedure would be extremely costly and
could delay investigation activities. In light of these potential concerns,
we recommend that EPA reject the proposed rock fill layer concept.
EPA Response 4: The Feasibility Study Report incorporated into all
capping alternatives the proposed inclusion of an interim soil, cap and
rock fill layer between the waste deposits and the multi-layer cap. The
Record of Decision did not incorporate the interim soil cap and rock fill
layer into the alternatives that it presented and evaluated. We agree
that the rock fill layer poses several disadvantages. For that reason,
the rock fill layer was not included in the Record of Decision
alternatives. However, the feasibility of incorporating the rock fill
layer into the Selected Alternative will be rigorously evaluated during
Remedial Design.
Comment 5: The proposal to remove and dispose of approximately 96,000 gallons
of liquids currently ponded underground in the area of the southern lagoon is
premature and unsupported by data. Neither Deffenbaugh nor EPA has collected v
and analyzed any of these "liquids" proposed to be removed. There is no
chemical data available for these liquids, yet they have been alleged to be a
"source" of contamination. These liquids may simply be groundwater which has
collected and become perched on the upper rock units. If the liquids do not
constitute a "source", they should be left in place and not "pumped and
treated" unless alternatives No. 4 or 5, as identified in the proposed plan,
are implemented.
EPA Response 5: As stated in the RI Report, the south lagoon was
observed to contain petroleum type sludges and used oil filters, some of
which appeared to be charred or burnt. Analytical results for "soil"
samples collected in the south lagoon area indicate significant
contamination by metals, semi-volatile organic compounds, and volatile
organic compounds, with concentrations of up to several hundred parts per
million. Some or all of the liquid ponded in the south lagoon area may
have been perched ground water. However, the observation of petroleum
type sludges and the high solubility of contaminants in water indicate
that the ponded liquids are contaminated. As stated in a previous EPA
response, additional pressures posed by the cap construction equipment
and by the cap may cause contaminant migration from the south lagoon or
may increase existing contaminant migration from the south lagoon.
Therefore, partial source removal is warranted.
Comment No. 6: We are concerned that EPA's Proposed Plan does not take into
account effects of wastes placed into the Overland Park municipal landfill,
which is immediately adjacent to the Doepke-Holliday landfill. High
concentrations of lead and other organic compounds have been detected by
Deffenbaugh at the Overland Park Landfill and not coincidentally, lead has
been detected in the surface and subsurface soils at the Doepke-Holliday site.
These wastes placed by Overland Park into their landfill may have adversely
affected the groundwater quality and/or soils on the Doepke-Holliday site.
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Doepke-Holliday Site
The Remedial Investigation clearly points out in Section 4.2.3 the presence of
highly contaminated material exposed on the surface of the Overland Park.
property. Section 3.7.1 of the Feasibility Study states that "previous
landfill activities for the Doepke-Hblliday site and the Overland Park
demolition landfill to the south were intertwined with little apparent regard
to property lines." Section 4.2.3 of the Remedial Investigation also
indicates that landfilling activities were contiguous operations, straddling
property boundaries. This information indicates that Overland Park may have
placed waste materials, similar to the contaminated superficial soils, into
the Doepke-Hblliday landfill. Deffenbaugh could not gain access to the
Overland Park Landfill property for extensive investigation when it conducted
the RI/FS. Hence, the data EPA relied upon in formulating the Proposed Plan
does not account for the effects of possible wastes at the Overland Park
Landfill on the remedial actions at the Doepke-Hblliday site. It is
essential, therefore, that EPA conduct supplemental investigations at Overland
Park to determine the impact on remediation at the Doepke-Holliday landfill.
The remedial alternatives contained in the FS such as the extent of the
Doepke-Holliday cap boundaries should then be adjusted based on the results of
the investigations.
EPA Response 6: The Selected Alternative includes (a) additional \
investigations to establish the northern, western, and southern extent of
contaminated soils and buried wastes and (b) additional investigations to
evaluate the vertical extent of contaminated ground water on the
Doepke-Holliday property and the southern extent of contaminated ground
water. These investigations will extend to the south onto the Overland
Park Landfill property. The findings from these investigations will be
used to adjust, as necessary, design features of the Selected
Alternative, such as the extent of the cap.
Comment 7: The FS states that EPA should conduct the investigations at the
Overland Park landfill prior to Remedial Design for the Doepke-Holliday site.
EPA's Proposed Plan for remediation and cleanup, however, does not address the
Overland Park landfill nor its potential impact on the remediation at the
site. Because the potential wastes at Overland Park can significantly affect
the overall remedial action at the Doepke-Holliday Landfill, we urge EPA to
address this issue prior to issuing the Record of Decision and, at a minimum,
include Overland Park as potentially responsible party for the Doepke-Holliday
site.
EPA Response 7: The Selected Alternative includes additional
investigations to the south, which will address conditions at the
Overland Park Landfill property. Given the facts that (a) the Overland
Park Landfill received similar or less contaminated wastes that the
Doepke-Holliday landfill, (b) the two landfills were similarly operated,
and (c) the two landfills are similarly geologically situated, the data
from the additional investigations to the south on the Overland Park
Landfill property are not expected to impact the type of remediation
selected for the site. Rather, the data are expected to impact the size
of remediation (such as, the extent of the cap) necessary for the site,
which may be both the Doepke-Holliday property and the Overland Park
landfill property. For those reasons, the additional investigations will
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be conducted during the Remedial Design phase, prior to final design of
the remedial action. EPA intends to seek any information that the City
of Overland Park may have on waste disposal operations at the Overland
Park landfill.
F. Responses to Written Comments in the August 23. 1989 Letter from Randy D.
Director. Environmental Deartment. Johnson County. Kansas
Comment 1: In regard to Section 2.4.1 (page 2-18) of the Remedial •
Investigation Report, what "other subsurface groundwater systems" are located
on the site?
EPA Response 1: Prior to the Remedial Investigation, five monitoring
wells had been installed at the site: EPA Well, MW-1, MW-2, MW-3, and
MW-4. The October 1987 RI/FS Work Plan called for additional monitoring
wells to provide a better definition of the chemical characteristics of
aquifers and "other subsurface groundwater systems." Five new monitoring
wells were installed during the RI: three were installed with screened
interval in the aquifer in the Plattsburg Formation and two were
installed with screened interval in the "subsurface groundwater system"
present in the 1-435 construction rubble fill. In addition to ground v
water present in aquifers in geologic formations, ground water flows down
the slope of the old ravine atop geologic formations through the 1-435
construction rubble fill and waste deposits.
Comment 2: In regard to Section 2.4.1 (page 2-18) of the Remedial
Investigation Report, only five groundwater monitoring wells were utilized.
The only argument for not using more is that the heterogeneity of landfill
materials encountered defies thorough site characterization. Due to the low
mobility of many of the pollutants found, it would appear that more wells
would be necessary to better define the extent of groundwater contamination.
EPA Response 2: When the RI/FS Work Plan was developed in October 1987,
it was thought that five additional monitoring wells would provide enough
data to sufficiently characterize the site's hydrogeology for RI/FS
purposes. The Remedial Investigation did yield sufficient data upon
which to base the Feasibility Study, Proposed Plan, and Record of
Decision. The Selected Alternative includes additional investigations
to refine further the hydrogeological characterization of the site. The
information from these additional investigations will be used during
Remedial Design to design the Selected Alternative's ground water
monitoring program, that will be used to evaluate the effectiveness of
the Selected Alternative in mitigating contaminant migration.
Comment 3: In regard to page 2-19 of the Remedial Investigation Report, the
Plattsburg Formation has three members: Spring Hill Limestone, Hickory Creek
Shale, and Merriam Limestone.
EPA Response 3: As indicated by the monitoring well records and Exhibits
3-1 and 3-2 in the Remedial Investigation Report, monitoring wells MW-5,
MW-6, and MW-7 were installed with screened interval across all three
members of the Plattsburg Formation.
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Conment 4: In regard to page 2-26 of the Remedial Investigation Report, a
third round of groundwater samples was collected in June 1988 for confirmation
of previous data. The results were not included with the sample analysis.
Did they confirm the previous data?
EPA Response 4: The analytical results from the third round of ground
water sampling in June 1988 confirmed the analytical results from the
previous two sampling rounds in February and March 1988, in that the June
1988 results did not produce any findings or conclusions other than that
drawn from the previous results.
Garment 5: In regard to page 3-7 of the Remedial Investigation Report, we
agree it is difficult, if not impossible, to discern who operated where on the
Doepke and Overland Park landfills. The boundaries are poorly defined. There
is no question that much more work is needed to define the extent of
contamination on what is now Overland Park property. A field investigation by
Division staff on the Overland Park property revealed a number of extensive
asphalt-like sludge deposits on the site. The PS addresses this concern.
However, what will it take to get access to the Overland Park property?
EPA Response 5: The Selected Alternative includes additional v
investigations to be conducted during the Remedial Design phase that will
address the extent of contamination and other concerns in regard to the
Overland Park Landfill property. Under various statutory authorities,
EPA has several means at its disposal to gain access to the Overland Park
Landfill property to enable performance of these additional
investigations.
Comment 6: In regard to page 3-46 of the Remedial Investigation Report, as
noted in the RI, three data points give only an approximate and rough estimate
of the surface of the groundwater table, gradient and the direction of the
groundwater flow. How will this be addressed in the remediation efforts? A
small amount of groundwater re-enters which bedrock formation? In regard to
Conclusion 2 on page 5-52 of the Remedial Investigation Report, how was it
determined that groundwater flow in bedrock units other that the Plattsburg
Limestone is less significant? In regard to Conclusion 3 on page 5-52 of the
Remedial Investigation Report, will additional data be collected to
characterize additional flow paths extending west and south from the area?
EPA Response 6: As stated in a previous EPA response, the current
hydrogeological characterization of the site was sufficient to enable
preparation of the Feasibility Study, Proposed Plan, and Record of
Decision. However, the current hydrogeological characterization is not
complete, as indicated by the questions in this comment. The Selected
Alternative includes additional investigations, to be conducted during
the Remedial Design phase, having the objective to refine and expand the
current hydrogeological characterization both vertically to deeper
formations and horizontally to the south.
Comment 7: In regard to page 7-2 of the Remedial Investigation Report, if
there is concern that highway spraying for weed control may have impacted the
seep samples, then will additional samples be collected in such'a manner to
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Doepke-Holliday Site
eliminate this problem? Also, were all seep samples collected from water
which was exposed to the atmosphere for an extended period of time?
EPA Response 7: The Selected Alternative includes additional
investigations to be conducted during the Remedial Design phase and an
expanded monitoring program to be conducted during and after Remedial
Action implementation. Collection and analysis of seep water samples are
part of both the additional investigations and the expanded monitoring
program. The seep water sampling design will include provisions that
will allow the impact of any highway spraying for weed control to be
evaluated and will move the sample collection point closer to the seep
discharge point.
Comment 8: In regard to page 7-5 of the Remedial Investigation Report, what
is the second data gap relating to groundwater conditions at the CHS?
EPA Response 8: The word "second" was omitted from the fourth sentence
in the second whole paragraph on page 7-5. The two data gaps are: (a)
lack of information on potential contaminant migration vertically into
deeper geological formations and (b) insufficient characterization of
potential contaminant migration horizontally to or from the south. \
Comment 9: In regard to Feasibility Study Alternative 1—No Action, this
action is unacceptable since it does not provide for any protection of human
health or the environment.
EPA Response 9: We agree.
Comment 10: In regard to Feasibility Study Alternative 2—Capping, the
heterogeneous nature of waste distribution and the resultant inability to
identify all potential areas of high concentrations of contaminants prevent
this alternative from being acceptable to the County. The relative location
of the site to the Water District Number 1 intake requires further
identification and removal of the worst concentrations of contaminants.
EPA Response 10: All of the alternatives, with the exception of "No
Action", would comply with all Federal and Kansas legally applicable or
relevant and appropriate requirements and would be protective of public
health and the environment. As has been found at other sites, capping is
an effective method (and sometimes the only method) for management of
heterogeneous waste deposits in landfills such as that present at the
Doepke-Holliday site. As stated in previous EPA responses, the cap will
result in a significant reduction in contaminant migration to ground
water and the Kansas River.
Comment 11: In regard to Feasibility Study Alternative 3—Capping with Rock
Fill, this is essentially the same as Alternative 2, but allows for the
disposal of waste rock from Johnson County landfill operations as part of the
capping process. This alternative is unacceptable for the same reasons as for
Alternative 2. Also, the addition of the rock would increase the difficulties
in removal of waste areas at a later date, if this were found to be necessary.
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EPA Response 11: EPA did not incorporate the rock fill layer into any of
the alternatives presented and evaluated in the Record of Decision. The
rock fill layer is not integral part of the Selected Alternative. As
stated in previous EPA responses, whether the rock fill layer will be
included in the Selected Alternative will be rigorously evaluated during
Remedial Design.
Comment 12: In regard to Feasibility Study Alternative 4—Capping with Rock
Fill with Partial Source Removal (USEPA's Preferred Alternative), this
alternative provides for the removal of approximately 96,000 gallons of
liquids currently ponded underground. Also, it provides for identification
and possible removal of other high concentration areas, such as the
Thompson-wayward drums. Criteria to be used to determine liquids removal
would be linked to industrial pretreatment criteria for Metal Finishing
Standards. This should not be the only criteria, however, to determine
disposal through a wastewater treatment facility. Treatability studies would
also be necessary prior to any consideration for disposal at a County
wastewater treatment facility. Also, since there is extensive removal of
contaminants, use of waste rock as part of the capping procedure is
acceptable. The County would also expect additional groundwater monitoring
wells to be installed. \
EPA Response 12: The Selected Alternative is Record of Decision
Alternative 3, which has significant differences from Feasibility Study
Alternative 4. The Selected Alternative does not include the rock fill
layer and the search for and removal of buried drums containing liquids
in the vicinity of the shale pile. As stated in previous EPA responses,
whether the rock fill layer is included in the Selected Alternative will
be rigorously evaluated during Remedial Design. Also as stated in
previous EPA responses, the drum search and removal program was not
included because it probably would be non-productive and its potential
risks to public health and the environment outweigh its benefits.
Furthermore, the partial source removal proposed in Feasibility Study
Alternative 4 would not involve extensive removal of contaminants.
Extensive removal of contaminants in the heterogeneous waste deposits in
the landfill is part of only the alternatives in which complete
excavation and offsite disposal are proposed.
Under the Selected Alternative, the liquids currently ponded underground
in the south lagoon area would be removed and transported to an off site
permitted facility for treatment and disposal. Whether this treatment is
at a NPDES permitted facility (publicly owned treatment works) or at a
RCRA permitted facility will be established by treatability evaluations
(and possibly treatability studies) to be conducted during Remedial
Design.
All of the Record of Decision alternatives include an expanded and
extended ground water monitoring program. In addition, the Selected
Alternative includes collection, analysis, and possible treatment of
significant ground water seepage at the site.
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Doepke-Hblliday Site
Comment 13: In regard to Feasibility Study Alternative 5—Capping with Rock
Fill and Partial Groundwater Control, this alternative incorporates the
components of Feasibility Study Alternative 3; however, it does not provide
for any source removal. It is, therefore, unacceptable to the County.
EPA Response 13: As stated in previous EPA responses, all of the
alternatives, with the exception of "No Action" would conply with Federal
and State legally applicable or relevant and appropriate requirements and
would be protective of public health and the environment.
Comment 14: In regard to Feasibility Study Alternative 6—Capping with Rock
Fill, Partial Groundwater Control, and Partial Source Removal, this
alternative incorporates the components of Feasibility Study Alternatives 4
and 5. It would be the most thorough remediation effort other than complete
excavation. USEPA stated at the public meeting that off-site movement of
groundwater will be all but stopped by the capping process. They: do not
believe, therefore, that groundwater remediation is necessary at this time.
If future monitoring reveals contamination movement off-site, then groundwater
controls would be considered. The County agrees with this logic; however,
additional investigative work should be done to better characterize the nature
and movement of the groundwater. v
EPA Response 14: Feasibility Study Alternative 6 does not involve ground
water remediation. It would provide for management of one ground water
flow path and would not account for all ground water flow off of the
site. The Selected Alternative includes (a) additional investigations
to be conducted during Remedial Design to refine and expand the site's
hydrogeological characterization, (b) collection, analysis, and possible
treatment of significant ground water seepage at the site, (c) expanded
and extended ground water monitoring, and (d) a contingent action to
implement partial ground water control measures if ground water
monitoring indicates an increase in contaminant migration.
Comment 15: In regard to Feasibility Study Alternative 7—Complete Excavation
and Off-site Disposal, based on the RI findings, complete excavation and
off-site disposal does not appear necessary to protect human health and the
environment.
EPA Response 15: We agree. All of the alternatives, with the exception
of "No Action", would protect public health and the environment. The
prohibitive costs and significant potential risks associated with this
alternative do not justify its minimal additional benefits.
Comment 16: The County can accept the preferred action plan found in
Feasibility Study Alternative 4; however, in lieu of groundwater cleanup,
additional monitoring systems must be added. Also, the County should be
involved with sampling and data analysis. County representatives should also
be allowed to observe the remediation efforts. If, during remediation
efforts, a significant groundwater contamination problem becomes apparent,
groundwater cleanup will have to reconsidered.
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EPA Response 16: As stated in previous EPA responses, the Selected
Alternative is Record of Decision Alternative 3, which is different from
Feasibility Study Alternative 4. None of the alternatives involved
ground water cleanup. The partial ground water control measures proposed
in seme alternatives would provide for management of one ground water
flow path and would not account for all ground water flow off of the
site. As previously stated, the Selected Alternative includes (a)
additional investigations to be conducted during Remedial Design to
refine and expand the site's hydrogeological characterization,, (b)
collection, analysis, and possible treatment of significant ground water
seepage at the site, (c) expanded and extended ground water monitoring,
and (d) a contingent action to implement partial ground water control
measures if ground water monitoring indicates an increase in contaminant •
migration.
The County will be informed in advance of ground water sampling events.
County representatives will be allowed to observe these events and, if
the County so desires, the County may collect split samples for their
independent analysis. County representatives will be allowed to observe
the remedial action construction activities. EPA will keep the County
apprised of progress and developments. EPA encourages the participation ^
of the County.
Comment 17: The County fully supports the need for additional investigation
in the following areas: (1) verification of the western limits of the disposed
wastes, (2) verification of the northern edge of the disposed wastes, (3)
location of the drums disposed as a result of a fire in 1966 at the
Thompson-Hayward Chemical Company, (4) relationship of the Doepke-Holliday
Site to the Overland Park landfill, and (5) determination of groundwater
contamination in formations below the Plattsburg.
EPA Response 17: The Selected Alternative includes additional
investigations to be conducted during Remedial Design for the all listed
areas, with the exception of the drum search. As stated in previous
EPA responses, the drum search and removal program was not included in
the Selected Alternative because it probably would be non-productive and
its potential risks to public health and the environment outweigh its
benefits.
F. Responses to Written Comments in the August 25. 1989 Letter from Von
Beoudher. Engineering Technician. City of Shawnee. Kansas
Comment 1: The City of Shawnee has a keen interest in the clean-up and
management of the Doepke-Hblliday Site, and would appreciate being kept
informed of any progress and developments as they occur.
EPA Response 1: The City of Shawnee will be kept informed of progress
and developments as they occur.
Comment 2: We support a thoroughly planned and evaluated alternative which
best protects human health and the environment, as opposed to a "hurry up and
get it behind us" approach. It is hoped that the alternative which is
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Doepke-Holliday Site
ultimately implemented will be based on suf f icient data and analysis to
adequately define the actual extent of the hazard to public health during both
the short and long term.
EPA Response 2: We agree that the approach taken has been deliberate.
The site has been investigated numerous times since the closure of the
landfill in 1970. Over the past 2 years, a Remedial Investigation and
Feasibility Study was performed to evaluate the site's characteristics
and to evaluate alternatives to remedy its hazards. The Selected
Alternative will comply with Federal and Kansas legally applicable or
relevant and appropriate requirements and will be protective of public
health and the environment. The Selected Alternative includes additional
investigations during Remedial Design and extended monitoring after
Remedial Action implementation to assure its effectiveness in protecting
public health and the environment.
II. RESPONSES TO ORAL COMMENTS AT THE PUBLIC MELTING ON AUGUST 16, 1989
A. Responses to Oral Comments of Johnna Lingle, County Commissioner, Johnson
Countv. Kansas
Comment 1: This site is within my district as County Commissioner. I am very
interested in what EPA is proposing as well as what role the Johnson County
Environmental Department might be in this process.
EPA Response 1: The Proposed Plan and the Preferred Alternative were
presented earlier in the Public Meeting. EPA has kept the Johnson County
Environmental Department, as well as the Kansas Department of Health and
Environment, apprised throughout the process. EPA has shared
documentation on progress and findings of the Remedial Investigation and
Feasibility Study. EPA has met with the Johnson County Environmental
Department and has provided them with the Remedial Investigation, Public
Health Assessment, and Feasibility Study reports when the reports were
completed. EPA will continue to share information with the Johnson
County Environmental Department, as well as the Kansas Department of
Health and Environment.
Comment 2: It is very important for us to know that there is protection for
our citizens and also to know about the local tax dollars that would be
involved. We need to have a cooperative effort, not only for what has been
done so far, but also in the future.
EPA Response 2: We agree.
B. Responses to Oral Comments of Craig Trfl-ow and Diane Amst,
members of the Sierra Club
Comment 1: Who will be responsible for monitoring to assure that
contamination is not migrating to the Kansas River? Will it be EPA or
Deffenbaugh or another agency?
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EPA Response 1: EPA will be ultimately responsible to ensure that the
monitoring is performed. EPA does not now have an agreement with any of
the Potentially Responsible Parties concerning the implementation of the
remedial action. EPA will be responsible to make sure that it gets done,
but EPA does not now know who will actually carry out the remedial
action.
After EPA has selected a remedy for the site, ordinarily EPA first seeks
implementation of the remedial action by Potentially Responsible Parties
identified by EPA. If the Potentially Responsible Parties agree that
they will implement the remedial action, then they might perform the
monitoring under the oversight of EPA. EPA would review the results from
their monitoring, as well as from time to time collecting split samples
for independent analysis. EPA would be basically managing the monitoring
effort, whether it is done by EPA or a Potentially Responsible Party or,
in the long-term, by the State of Kansas. Under the Superfund law, after
EPA has completed the remedial action, the State is responsible for
performing the required operation, maintenance and monitoring activities,
if the Potentially Responsible Parties have not agreed to perform those
activities.
\
Comment 2: If Deffenbaugh were to agree to do the monitoring, would EPA have
any oversight to the extent that EPA is not only reviewing the results, but
actually collecting samples for analysis on occasion?
EPA Response 2: Yes, EPA would require the prior approval by EPA of the
sample collection and analysis procedures to be utilized. From time to
time, EPA would collect splits of the samples collected by the
Potentially Responsible Parties and have the splits independently
analyzed. Also, EPA may perform independent sampling efforts.
Comment 3: Has EPA provided such oversight of past sampling activities?
EPA Response 3: EPA has provided oversight of past sampling activities.
Comment 4: Are any of the migrating substances on EPA's "too hazardous list"?
Which ones have been detected?
EPA Response 4: Up to seventy different chemicals on the Priority
Pollutant List have been detected in samples collected on the site. Some
of these are hazardous at varying degrees of toxicity.
The concentrations that have been detected in seepage that is going off
the site have not been significantly large. However, the Selected
Alternative includes the collection of seepage from the major seep on the
site and, in the event concentrations in the seepage exceed ARARs, the
seepage would be treated prior to discharge.
Many of the chemicals have been detected in the fill material, but in
either the ground water or the seepage. Part of the reason for requiring
a cap is to minimize the amount water that is entering the fill area, and
therefore minimize the opportunity for off site migration.
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Comment 5: Does the Preferred Alternative include any flood plain barrier, as
required by EPA regulations for the management of PCBs?
EPA Response 5: EPA has regulations regarding the siting of hazardous
waste management facilities within flood plains. The Doepke-Holliday
Site is not located in the flood plain of the Kansas River. The lowest
elevation waste deposits on the site are approximately 100 feet higher
than the maximum record flood stage. Therefore, the Selected Alternative
does not include any flood barriers.' However, the Selected Alternative
includes a cap and runoff controls to keep water from contacting any of
the waste sources.
Comment 6:' Aren't there special regulations that just deal with cleanup of
PCBs? -'
EPA Response 6: There are regulations specifically for the cleanup of
PCB spills. However, those regulations do not apply to the situation
present at this site, because the PCBs are in a landfill and are not the
result of a recent spill.
Comment 7: What are the underlying assumptions that were made to determine y
which remedial action alternative is most cost!-effective?
EPA Response 7: Cost-effectiveness is one of the balancing criteria used
in the alternative evaluation and selection process.
There are two primary criteria used in the evaluation and selection
process. These criteria, which are referred to as the threshold criteria,
are (1) the requirement to be protective of public health and the
environment and (2) the requirement to comply with all Federal and State
legally applicable or relevant and appropriate standards and regulations.
If the alternative meets these minimum threshold criteria, then it is
evaluated further against the balancing criteria.
The balancing criteria include cost-effectiveness, implementability, and
other criteria that are subjective in nature. There is no set rule for
cost-effectiveness that says a cost-benefit ratio or similar factors have
to be a certain level.
Comment 8: If contaminant level increases are detected in the future by the
long-term monitoring, would there be additional design activity then to take
this into account?
EPA Response 8: In the event that monitoring shows that there is an
increase in contaminant migration, additional action would be taken.
Comment 9: Would there be a public report in the Federal Register or in the
local newspaper if something like that happened?
EPA Response 9: If EPA significantly modifies the remedy for the site,
EPA would issue a public notice. However, this notice would not be in
the Federal Register.
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Comment 10: Would the monitoring results—such as, greater quantities,
different constituents or chemicals, or a larger proportion being detected
from the acutely toxic list—be available to the public?
EPA Response 10: All monitoring data that EPA collects on sites is
available to the public. The public can gain access to this data by
submitting a request to EPA.
C. Responses to Oral Oomments of Don Durham
Comment 1: When does EPA start the process?
EPA Response 1: After the public comment period, the next step in the
process will be to respond to the comments and to sign the Record of
Decision. Following that, there will be period during which EPA will
probably issue notice letters to and possibly negotiate with the
Potentially Responsible Parties in regard to their implementation of the
remedial action. Following that, Remedial Design will be initiated
either by EPA using Superfund money or by Potentially Responsible Parties
under EPA oversight. Remedial Design will take 6 to 12 months. Then
bids for the remedial action contract will be let using the documents \
prepared during Remedial Design. It might take another 4 to 6 months
until the remedial action contract is awarded. It would probably be 12
to 18 months from now before remedial action construction is started.
The exact duration of the remedial action construction will become more
evident during the design period, but it probably will take another 12 to
18 months. It would probably be 2 to 3 years from now before the remedial
action is completed.
Comment 2: On the funding, does EPA already have the money in Superfund or
has it been budgeted or will it have to be budgeted?
EPA Response 2: There is certain amount of Superfund monies that are
budgeted. Currently, EPA is working on the budget for Fiscal Year '90,
looking at sites projected for remedial action during the year that
begins this October. EPA does not currently foresee any funding
problems. EPA expects that when projects become ready for action, EPA
will have the funds to do the work. But that is not to say that a
situation may not develop when there are projects ready for action but
the funds are not quite yet available. However, if the Potentially
Responsible Parties implement the remedial action, then EPA would not
have to use the Superfund trust fund.
Comment 3: Where will the collected seepage be treated?
EPA Response 3: The actual facility where the collected seepage will be
treated has not been established yet. If the level of contaminants in
the collected seepage do not exceed ARARs, the collected seepage will be
discharged to the Kansas River. If the level of contaminants exceed
ARARs but meet pretreatroent standards, the collected seepage will be
transported to a publicly owned wastewater treatment plant for treatment
and disposal. If the level of contaminants exceed pretreatment
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Doepke-Holliday Site
standards, the collected seepage will be treated to reduce the level
below pretreatment standards and then will be treated at a publicly owned
wastewater treatment plant.
Comment 4: The purpose of the cap is to keep precipitation from infiltrating,
therefore the cap will increase the amount of runoff. Will the cap cause any
flooding problems, particularly in the lowland area by Holliday Drive and
1-435?
EPA Response 4: The cap will increase the rate of runoff. However, it is
expected that the cap will not result in a major difference in the rate
of runoff, because not that large an area will be capped. Nevertheless,
the design of the remedial action will include provisions to handle the
runoff without causing erosion or flooding problems.
Comment 5: In regard to long-term monitoring, what is long-term: 10 years, 50
years, or what?
EPA Response 5: The long-term monitoring will be for a minimum of 30
years.
Comment 6: What are the planned deed restrictions? What is the eventual land
use for the site?
EPA Response 6: The deed restrictions must be commensurate with the
level of risk associated with the site. Under the Selected Alternative,
the contaminants would not removed from the site. As long as the
contaminants remain on the site, intrusive activities and residential
land use on the site will not be acceptable. Deed restrictions will be
used to assure that land use is not changed from the present.
Water District No. 1
Comment 1: In regard to partial source removal, does this only include
removal of liquids ponded underground in the south lagoon area or does this
also include removal of buried drums?
EPA Response 1: The Selected Alternative does not include a search for
and removal of buried drums. Based on the previous investigative work
and the nature of the landfill, the buried drums would be very difficult
to locate. To locate the buried drums will entail two steps. First, a
surface geophysics survey would be used to locate buried metallic
deposits. Then, there would be excavation activities to unearth the
buried metallic deposits. Given that this was a landfill, it is expected
that the excavation activities would unearth mostly buried scrap metal
and white goods (refrigerators, washing machines, etc.) with little
success in finding buried drums. These excavation activities would pose
the potential risk of fire and explosion and the potential risk of worker
exposure to unknown hazardous materials in the heterogeneous landfill.
These excavation activities would have unjustifiable short-term potential
risks to public health and the environment.
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Comment 2: What is in the buried drums?
EPA Response 2: Considering how long the drums have been buried and that
they were either steel or fiberboard drums, the buried drums probably are
no longer intact. It would be very difficult to locate the buried drums
and, if they were located, it is doubtful that the buried drums would
contain anything significant.
D. Responses to Oral Comment'^ of Betgy Betros. Johnson County Epv,''''n"'TT>en't'^i
Qrapa r Lllient
Comment 1: Would you expand on the reasoning behind not including the clay
barrier and other partial ground water controls in the Preferred Alternative?
The long-term monitoring proposed in the Preferred Alternative may not be
sufficiently responsive to avert downstream problems. If the long-term
monitoring indicates a problem, enough offsite migration of contaminants may
have already occurred to cause a problem at the nearby Kansas River intake of
Johnson County Water District No. 1. Also, what will be the frequency of
monitoring?
EPA Response 1: Ground water is currently not flowing offsite in that
significant of a quantity or in significant concentrations of *
contaminants to warrant installation of the partial ground water controls
at this time. Furthermore, after the cap is in place, ground water flow
will be significantly reduced. The monitoring program will provide
sufficient time to take actions to avert downstream problems, because
monitoring will be on a quarterly basis and contaminant migration levels
are not expected to have a sudden increase.
Comment 2: It appears that Doepke-Holliday waste disposal operations extended
onto the Overland Park landfill property. Will the Overland Park Landfill
property be investigated? Will the cap for the Doepke-Holliday Site extend
onto the Overland Park landfill property?
EPA Response 2: During the preliminary stages of Remedial Design, there
will be additional investigations to establish the extent of the cap and
to characterize further the hydrogeology of the site. These
investigations will extend onto the Overland Park landfill property. If
the investigations indicate that the cap should extend onto the Overland
Park landfill property, then the cap will so designed and constructed
under this action.
Comment 3: Have contaminants from the buried drums leached far enough to have
been detected by the existing monitoring wells?
EPA Response 3: Some contaminants have been detected in ground water
samples from the existing monitoring wells. It is uncertain whether
these contaminants originated from what might have been originally in the
buried drums. The hydrogeological study performed as part of the
Remedial Investigation and Feasibility Study indicates that some of the
contaminants which are expected to migrate may not have yet reached the
extent of the current monitoring system. There is a possibility, if no
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Doepke-Hblliday Site
action is taken, that the level of contaminants detected by the
monitoring system will increase in the future. With the cap in place,
the potential of this happening would be reduced.
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