EPA Superfund
Record of Decision;
PB95-964005
EPA/ROD/R04-95/201
December 1994
Brantley Landfill Site,
Island, KY
12/14/1994
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BRANTLEY LANDFILL SITE
ISLAND, KENTUCKY
REGION IV
ATLANTA, GEORGIA
RECORD OF DECISION
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RECORD OF DECISION
BRANTLEY LANDFILL SITE
TABLE OF CONTENTS
Page
DECLARATION FOR THE RECORD OF DECISION i
SUMMARY OF REMEDIAL ALTERNATIVES SELECTION 1
1.0 SITE NAME, LOCATION. AND DESCRIPTION 1
1.1 Site Location 1
1.2 Demographics 1
1.3 Physiography 1
1.4 Hydrology 2
1.5 Soils 2
1.6 Structure and Hydrogeology 3
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 5
2.1 Site Background 5
2.2 Enforcement Activities 7
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION ... 7
4.0 SCOPE AND ROLE OF RESPONSE ACTION 8
5.0 SUMMARY OF SITE CHARACTERISTICS 8
5.1 Nature and Extent of Contamination 8
5.1.1 Salt Cake fines (Source Material) .... 8
5.1.2 Air 8
5.1.3 Soil 9
5.1.4 Vadose zone gases 10
5.1.5 Surface Water 10
5.1.6 Sediment 11
5.1.7 Ground Water 12
5.2 Contaminant Fate and Transport 14
5.2.1 Source Material 14
5.2.2 Air 14
5.2.3 Soils 15
5.2.4 Surface Water and Sediment 15
5.2.5 Groundwater 16
6.0 SUMMARY OF SITE RISKS 19
6.1 Contaminants of Concern 19
6.2 Exposure Assessment 19
6.3 Toxicity Assessment 20
6.3.1 Carcinogens 21
6.3.2 Non-carcinogens 21
6.4 Risk Characterization 22
6.4.1 Air Pathway . . .- 22
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6.4.2 Soil Pathway 23
6.4.3 Surface Water Pathway 23
6.4.4 Sediment Pathway 23
6.4.5 Groundwater Pathway . 24
6.5 Ecological Assessment 25
6.6 Risk Uncertainty 25
6.7 Remedial Action Objectives 26
7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES 27
7.1 Alternative 1 27
7.2 Alternative 2 28
7.3 Alternative 3 28
7.4 Alternative 4 29
7.5 Alternative 5 30
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .... 30
8.1 Threshold Criteria 31
8.1.1 Overall Protection of Human Health and
the Environment 31
8.1.2 Compliance with Applicable or Relevant
and Appropriate Requirements 31
8.2 Primary Balancing Criteria 32
8.2.1 Long-Term Effectiveness and Permanence . 32
8.2.2 Reduction of Toxicity, Mobility, or
Volume Through Treatment 33
8.2.3 Short-Term Effectiveness 33
8.2.4 Implementability 34
8.2.5 Cost 35
8.3 Modifying Criteria 35
8.3.1 State Acceptance 35
8.3.2 Community Acceptance 35
9.0 THE SELECTED REMEDY 36
9.1 Phase I: Surface Water Infiltration 37
9.1.1 Additional Sampling and Installation of
Ground Water Monitoring Wells 37
9.1.2 Source Control: Landfill Cap 38
9.1.3 Shallow Ground Water Remediation .... 38
9.2 Phase II: Deep Ground Water Remediation and Ground
Water Infiltration 39
9.2.1 Deep Ground Water Remediation 39
9.2.2 Landfill Leachate 39
9.3 Performance Standards 41
9.4 Compliance Testing and Monitoring 43
9.5 Site-specific ARARs 44
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RECORD OF DECISION
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10.0 STATUTORY DETERMINATIONS 46
10.1 Protection of Human Health and the Environment . . 46
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements 46
10.3 Cost Effectiveness 46
10.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable . . 47
10.5 Preference for Treatment as a Principal Element . . 47
11.0 SIGNIFICANT CHANGES TO ALTERNATIVE 4 47
APPENDIX A - LIST OF FIGURES
APPENDIX B - LIST OF TABLES
APPENDIX C - RESPONSIVENESS SUMMARY
APPENDIX D - STATE CONCURRENCE
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Brantley Landfill Site
Island, McLean County, Kentucky
Statement of Basis and Purpose
This decision document presents the selected remedial action for the
Brantley Landfill Site, in Island, Kentucky, which was chosen in
accordance with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the Administrative
Record for this Site.
The Commonwealth of Kentucky concurs with the selected remedy.
Assessment of the Site
Actual of threatened releases of hazardous substances from this Site,
if not addressed by implementing the response action selected in this
Record of Decision (ROD), may present an imminent and substantial
endangermerit to public health, welfare, or the environment.
Description of the Selected Remedy
The selected remedy includes:
o Restriction of access to the landfill Site by fencing and posting
of signs.
o Incorporation of restrictive covenants in property deeds to
prevent access to the Site and to prevent installation of
drinking water wells onsite.
o Installation of piezometers and monitoring wells.
o Construction and maintenance of a new landfill cap which
minimizes surface water infiltration. Regrading areas of the
Site to improve runoff and minimize erosion. Regrading of the
Site will eliminate the onsite surface pond at the southern end
of the landfill.
o Monitoring ground water levels and quality in and around the
landfill for a period of time. Modeling the expected restoration
of landfill ground water quality.
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o Estimating the dissolved contaminant mass, and its rate of
migration out of the landfill. Projecting the time for a
substantial portion of the residual dissolved contaminant mass to
migrate from the landfill. Projecting also the time for the same
mass of dissolved contaminants to be removed by short-term
leachate collection.
o Contingent installation of a short-term leachate collection
system.
o Contingent installation of a long-term leachate collection
system.
o Installation of an alkaline recharge trench to restore shallow
ground water adjacent to the landfill.
o Monitoring the natural attenuation of contaminant concentrations
in deep ground water.
o Monitoring ground water in the coal seam adjacent to the
abandoned mine works. Monitoring ammonia emissions from the
abandoned mine works at closed mine shafts.
o Classification of the shallow and deep aquifers.
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, because treatment of the principal threats of
the Site was not found to be practicable, this remedy does not satisfy
the statutory preference for treatment as a principal element.
Because this remedy will result in hazardous substances on-site, 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.
Richard D. Green
Associate Director
Office of Superfund and Emergency Response
Date
11
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
Brantley Landfill Site
1.0 SITE NAME, LOCATION, AND DESCRIPTION
1.1 Site Location
The parcel of land which includes the Brantley Landfill Site
consists of approximately 35 acres located west of the
intersection of KY Highway 85 and US 431 in Island, McLean
County, Kentucky. The Brantley Landfill Site (the Site)
encompasses approximately four acres of the 35-acre tract. The
Site is bound to the north by KY Highway 85, to the south by the
City of Island Wastewater Treatment Plant (WWTP), to the east by
Mrs. Peggy Drake's residence (owner of the parcel) and the City
of Island, and to the west by an unnamed tributary to Cypress
Creek. The landfill was located in a former strip mine pit from
which the No. 9 Coal seam was extracted for commercial sale.
Figure 1 (Appendix A) is a vicinity map indicating the location
of the landfill relative to the City of Island.
1.2 Demographics
Populated areas in the vicinity of the Brantley Landfill Site
are: the City of Island, located 500 feet east of the Site, and
the unincorporated community of Buttonsberry, located
approximately 2,000 feet west of the Site. Land use within a 1-
mile radius of the landfill is primarily restricted to
agriculture and residences.
The most recent census information from the U.S. Department of
Commerce, Bureau of Census, indicates that the City of Island, as
of 1988, had a population of 640. Because the Bureau of Census
only surveyed incorporated areas, the nearby community of
Buttonsberry was not included. The only source of population on
Buttonsberry was published by Rand McNally in 1983 listing a
population of 150 (Decker, 1990; Kentucky Department for Research
and Planning).
1.3 Physiography
The City of Island and McLean County area are situated
physiographically in what is referred to as the Western Kentucky
coal fields region. The coal fields are located in the interior
low plateaus province of the interior plains region.
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Geologically, the area is in the southeastern section of the
eastern interior (or Illinois) basin. The region is
characterized by low rolling hills formed of Pennsylvanian age
sandstones and Quaternary alluvium deposits from the Green River
and its tributaries. The alluviated valleys comprise the
majority of the area and have a general elevation of 380 to 420
feet. The Brantley Landfill Site is located topographically just
above the Quaternary alluvium in the Pennsylvanian age._ Carbondale
Formation at an elevation of approximately 400 feet.
1.4 Hydrology
Cypress Creek is the primary surface water body and flows north
by northwest into the Green River. Flanking the western boundary
of the Brantley Landfill site is an unnamed tributary to Cypress
Creek. This tributary is an ephemeral stream which originates
approximately 1/2-mile north of the Site in a reclaimed strip
mine. It flows south approximately 2 miles before flowing north
by northwest into Cypress Creek. Cypress Creek drains into the
Green River which is a tributary to the Ohio River.
The Brantley Landfill Site has two primary surface water
features: erosion ditches (located on the western slope of the
landfill face and varying in depth from a few inches to 1 foot),
and a pond located at the southern end of the property. The
erosion ditches, which were formed by surface water runoff from
precipitation, were regraded and covered during the Remedial
Investigation. The pond was probably constructed as a settling
basin during strip mine operations and varies in depth from
several inches to 3 feet.
1.5 Soils
Three types of soils were encountered at the Site: Udorthents,
Loring Soils and native soils.
Ddorthents — The Udorthents series is found over abandoned
mine sites and consists of strip-mined spoil material which
is generally a mixture of soil, coal and rock fragments.
These soils were encountered on the landfill and to the
north, south, and west of the landfill. Rock fragments
encountered do account for a large percentage of this soil
but fragment size ranged from sand to cobble size. Shale
fragments constitute the most frequently encountered rock
fragment type. No limestone fragments were encountered. To
the west of the landfill this soil type can be encountered
at depths of up to 30 feet or more.
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Loring Soils — Lorings series soils (LoC) are hill and slope
soils that can be subdivided by the angle (percent grade) of
the slope they cover. The Brantley Site is located on a
hill with an 8 to 10 percent grade classifying the Loring
soil cover as a Loring silt loam, 6 percent to 12 percent
slopes. This soil was encountered only to the east of the
landfill. The soils were typically found over sandstone
bedrock at depths ranging from 2 to 10 feet. Typically
these soils were hard, dense, and had a high sand content.
Native Soils — Undisturbed soils encountered below ground
surface, overlain by strip mine spoils (Udorthens) along the
western end of the landfill. This soil typically was
composed of orange brown, silty, plastic clay overlying
either hard dense bluish underclay, silt-stone, or shale.
1.6 Structure and Hydrogeology
Structure - The landfill Site and the surrounding area is located
in the Southern Illinois Basin. The landfill is situated at the
outcrop face of the No. 9 Coal seam. The landfill is located
between the sandstone of the Carbondale Formation which is the
uppermost unit to the east of the landfill and the
stratigraphically lower siltstone/shale of the Carbondale
Formation that is directly beneath the No. 9 Coal seam (beneath
and west of the landfill-) . All the underground mine works are
located to the east/northeast of the landfill area. See Figure
2. The Remedial Investigation (RI) Report contains details of
corings on the north/northeast side of the landfill. Only one of
the four corings attempted encountered the No. 9 Coal seam. The
rest encountered voids which are suspected to be abandoned
mineworks. The top of the No. 9 Coal mine works was encountered
at elevations of 403.73, 404.07, and 406.35 feet mean sea level
in mine work borings/corings K13, K14 and L6, respectively.
The Landfill Site structure can be characterized as a series of
conformably deposited homoclinal beds of Pennsylvanian age
sandstone, siltstone, shale, coal, and underclay. The
generalized cross sections extrapolated from coring logs of deep
wells, mine work boring/coring logs, and U.S. Geological Survey
(USGS) information have indicated a south to southeasterly dip at
2.7 to 5.4 degrees. The other dominant structural feature of the
Site area is the sandstone ridge that extends continuously along
most of the length of the eastern side of the landfill. The
sandstone, more resistant to weathering than the other rocks, has
formed a resistant cap above shale, coal and siltstone. Local
ground water wells in the town of Island, Kentucky, are located
in this Carbondale Sandstone Formation.
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Hydrogeology - The Site's hydro-geological regime can be
subdivided into four possible water-bearing zones: the
Quaternary alluvium deposits, the shallow (Udorthents series)
unconsolidated mine spoils, the Undesignated Pennsylvanian
Sandstone (UPS), and the deeper siltstone/shale sequence beneath
the landfill. In addition, the landfill by virtue of its
location is somewhat connected to the shallow ground water
regimes, and can be considered to be a ground water sink. This
sink probably intercepts shallow ground water flow in the
vicinity of the Site. Once intercepted by the landfill, most
ground water then apparently migrates into the underground mine
works. The Quaternary alluvium along the Green River yields
water and supplies the town of Island. At the Brantley Site,
however, the alluvium has been eroded to expose Pennsylvanian
sections. The surficial aquifer consists of ground water moving
through shallow deposits such as salt cake fines, strip mine
spoils, and native soils. The surficial aquifer was encountered
at depths greater than 10 feet and extends to the bedrock
interface. Away from the influence of the landfill sink however,
the ground water is thought to migrate west, or possibly
southwest. Primary recharge to this aquifer is through
percolation.
The UPS aquifer consists of ground water moving through primary
and secondary porosity in the sandstone formed to the east of the
landfill. Ground water is believed to flow south/southeast away
from the landfill. This sandstone ridge represents a topographic
high that may be a ground water divide, whereby ground water may,
to a small extent, follow topography to the west, and structure
to the south/southeast. The Carbondale sandstone was encountered
at depths very close to the surface to 10 feet below the ground
surface in vapor probe installations, mine work borings, and
monitoring well K13S. The aquifer is approximately 17 feet thick
and is underlain by a shale. Aquifer recharge is thought to be
through percolated precipitation in the sandstone outcrop
(recharge) area. Ground water flow direction is believed to be
structurally controlled (along dip) from the west of the landfill
to south/southeastward toward the town of Island. Aquifer
recharge is thought to be a combination of downward percolation
of precipitation in the siltstone outcrop (recharge) area to the
west of the landfill and possibly through recharge from the
overlying shallow mine spoils aquifer. The deep aquifer extends
downward to the shale interface to the south. At the northern
end of the landfill, the siltstone is locally absent.
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Site Background
Coal mining in the area of Island, Kentucky, first began in the
late 1800s and continued into the 1970s. The parcel of property
where the Site is located was topographically and geologically
where the No. 9 seam outcropped (along the eastern hillside of
the Site). Due to the structural attitude of the seam (a
south/southeasterly dip), vertical shafts were drilled east of
the community and underground mining was performed updip to the
west to prevent flooding of work areas. Dip in structural
geology refers to the angle that a structural surface (i.e.,
bedding or fault plane) makes with a horizontal plane.
In the late 1960s, the remaining coal from the seam was excavated
by strip mining. The seam was approximately 48 inches thick and
dipped into the underground mine works located downdip
(south/southeast) of the Site. During excavations into the east
wall of the strip pit, an underground passageway was encountered.
After removal of some of the coal support pillars from the
underground mine, the area was filled with clay mine spoils and
closed.
In 1977, Barmet Aluminum Corporation contacted Mr. Doug Brantley
to locate a disposal site for the salt cake fines generated at
its Livia, Kentucky aluminum recycling operation. Salt cake
fines are a fine, dust-like material containing aluminum nitride,
sodium and potassium chloride, and other constituents such as
heavy metals. When water is allowed to come in contact with the
stored salt cake fines, the soluble salts are dissolved, the
aluminum nitride in the fines evolve into ammonia gas, and the
aluminum metal and aluminum carbide reacts with water to evolve
into hydrogen, methane, acetylene gases, hydrogen sulfide and
hydrogen cyanide.
Mr. Brantley, who represents Doug Brantley and Sons, Inc. of
Frankfort, Kentucky, located an abandoned mine pit in Island,
Kentucky and entered into a leasing arrangement with the owner of
the property, Mrs. Peggy Drake. An engineering firm, Kenvinrons,
Inc. of Frankfort, Kentucky was then retained to assist in
writing an operation plan for landfill disposal. In 1978,
Kenvinrons submitted an industrial landfill permit application to
the Kentucky Department for Environmental Protection (KDEP),
Division of Hazardous Waste and Waste Management. Mr. Brantley
stated that during the approximately two-year operation of the
Site (May 1978 to November 1980), salt cake fines were the only
material disposed of in the landfill (with the exception of
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diesel fuel as a dust control measure). A total of 250,306 tons
of salt cake fines were deposited in the landfill.
In 1979, the Kentucky Division of Air Pollution Control conducted
a compliance inspection based on complaints from area residents
that unpleasant odors were coming from the landfill during
disposal activities. At the time of the inspection, the landfill
was found to be in violation of 401 KAR 63:010, Section 3(1) (c) ,
and 401 KAR 63:010, Section 3(2) regarding: "... failure to take
reasonable precautions to prevent particulate matter from
becoming airborne and' allowing the discharge of visible fugitive
dust emissions beyond the property lines of the landfill". On
several occasions, diesel fuel reportedly was applied to the
fines in the landfill in an attempt to reduce the amount of
fugitive salt cake fines and gaseous emissions exiting the
property. During subsequent KDEP inspections, officials noted
vigorous reactions with water and complained of irritating
gaseous emissions continuing to be released from the landfill.
This discovery prompted KDEP to submit a letter to the United
States Environmental Protection Agency (EPA) in 1980 requesting
an evaluation of salt cake fines in reference to 40 CFR 261.23
(a) (4), hazardous waste characteristic of reactivity. EPA
concluded that the salt cake fines should be regulated as a
hazardous waste, based on information supplied by KDEP inspection
reports. In November 1980, KDEP notified Barmet of its intent to
regulate salt cake fines- as a hazardous waste and requested that
Barmet register as a hazardous waste generator under the Resource
Conservation and Recovery Act. The Brantley Landfill officially
closed on November 15, 1980.
In 1981, Barmet Aluminum Corporation filed a civil action in the
United States District Court against the EPA and KDEP, protesting
their intent to regulate salt cake fines as a hazardous waste.
The United States District Court, Western District of Kentucky
handed out a decision on August 5, 1981, declaring that salt cake
fines are not a hazardous waste material within the meaning of
the Solid Waste Disposal Act, 42 U.S.C.S. 6901, et seq. and KRS
Chapter 224. Following this ruling, the Brantley Landfill
remained under investigation by EPA officials regarding
complaints about gaseous emissions at the Site.
In 1987, EPA conducted field investigations at the Brantley
Landfill, collecting air, soil, water, and sediment samples for
analysis. Results of the analysis revealed slightly higher
ammonia concentrations than background and elevated metals
concentrations below the landfill cap.
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2.2 Enforcement Activities
In June of 1988, the Site was proposed for inclusion on EPA's
National Priorities List (NPL), and became final on February 21,
1990. In February and March 1989, EPA sent notice letters to the
Potentially Responsible Parties (PRPs) offering them the
opportunity to voluntarily conduct the Remedial Investigation
(RI) and Feasibility Study (FS) at the Site. On January 10,
1990, EPA and Barmet Aluminum Corporation signed an agreement
called an Administrative Order by Consent (also known as a
"Consent Order") under which Barmet would conduct the RI and FS
to determine the type and extent of contamination at the Site and
identify alternatives for remedial action. The Consent Order
also included a requirement for the restriction of access to the
Site. In March 1990, Barmet installed a chain-link fence around
the Site.
During the RI process, in late August/early September 1993, EPA
authorized Barmet to perform minimal repairs to the landfill cap
in order to prevent further erosion and subsequent exposure of
source material. The RI and FS reports were finalized in June
and July, 1994, respectively.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Pursuant to CERCLA §113(k)(2)(B)(i-v) and §117, the RI and FS
Reports, and the Proposed Plan for the Brantley Landfill Site
were released to the public for comment on July 20, 1994. These
documents were made available to the public in the Administrative
Record located in the information repositories maintained at the
EPA Region IV Record Center and the Island City Hall in Island,
Kentucky. In addition, the Proposed Plan Fact Sheet was mailed
to the individuals on the Site mailing list on July 18, 1994.
The notice of the availability of these documents and
notification of the Proposed Plan Public Meeting was announced in
the McLean County News on July 12, 1994. A public comment period
was held from July 20, 1994 through August 19, 1994. In addition
a public meeting was held on July 26, 1994 at the Island
Elementary School. At this meeting, representatives from EPA
answered questions about problems at the Site and the remedial
alternatives under consideration. A response to the comments
received during the comment period, including those raised during
the public meeting are addressed in the Responsiveness Summary
which is part of this Record of Decision. The Responsiveness
Summary also incorporates a transcript of the Proposed Plan
public meeting.
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4.0 SCOPE AND ROLE OF RESPONSE ACTION
This response action for the Brantley Landfill Site will address
all known concerns at the Site (e.g., ground water contamination,
soil contamination, and direct gaseous emissions from the
landfill), and will monitor ammonia gas migration and ground
water leachate to the underground mine works.
The intent of this response action is to mitigate the threats to
human health at the Site by controlling the source material.
Source control along with the contingent removal of contaminated
landfill leachate will reduce the potential for migration of
contaminants into the ground water and underground mine works.
Also, shallow ground water adjacent to the landfill will be
restored. A monitoring program of the abandoned coal mine works
will be implemented to assess the effectiveness of the remedy,
and the extent of offsite migration.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 Nature and Extent of Contamination
5.1.1 Salt Cake fines (Source Material)
A source characterization study was conducted to investigate the
chemical and physical nature of the source material within the
landfill. Figure 3 shows each of the source sampling locations
from the landfill. The analysis of source samples consisted of
four subsamples derived from each sample location: as received
salt cake fines representing the material as it currently exists
in situ; water from reaction with salt cake fines; evolved gases
from the reaction of salt cake fines and water, and; residual
salt cake fines solids subsequent to the reaction with water
(decanted).
Source material is completely contained within the landfill.
Source material samples were also subjected to analysis of the
hazardous waste characteristics (ignitability, corrosivity, and
reactivity) and were found to exhibit none.
5.1.2 Air
The analysis of source material gas evolution showed that ammonia
is the predominant gaseous by-product of salt cake fines/water
contact. The characterization of the nature and extent of
possible air contamination emanating from the Site required
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performance of a dispersion modeling analysis based on the
emission estimates derived from the data and information
collected during the June 12, 1992 field investigation. The
emissions monitoring program involved implementation of an
indirect measurement approach employing path-integrated Fourier-
transform infrared (FTIR) spectroscopy.
Exposures were predicted with respect to the EPA 24-hour and
annual exposure criteria of 0.4 and 0.1 mg/m3 and the KNREPC
8-hour site perimeter exposure criterion of 0.4 mg/m3. The table
below compares the maximum potential 8-hour Site perimeter, and
EPA's 24-hour and annual residential exposures to applicable
exposure criteria.
,, ' ..CoftpariAflJtt of Applica1>i« ISxpoffttr* Criteria - ••-,.;"
to :MaximJim;:lPradI
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No volatile organic compounds were identified in Site soil
samples. Petroleum (diesel fuel) products were found in soils on
the southern boundary of the landfill. This was expected due to
the limited historical use of diesel products as a dust
suppressant. Coal and coal tar products were also expected
considering that the area was historically stripped for coal.
Pesticide/PCB compounds were reported in soil samples collected
from ten sampling locations onsite and three background samples.
However, the number of pesticides detected in the three offsite
background samples indicate that there has been historical
application (aerial) of these types of compounds for general pest
control purposes.
5.1.4 Vadose zone gases
A total of eleven vapor probes were installed around the
perimeter of the landfill in order to determine if subsurface
gases were migrating from the landfill through the vadose zone.
No acetylene, ammonia, hydrogen cyanide or hydrogen sulfide was
detected in any probe sample during any sampling quarter.
Methane was only detected in the first two quarters at
concentrations ranging from 2.6 ppm to 3,400 ppm.
Methane in the mine works could be naturally occurring from the
abandoned mine works and the reported sewage that has been
disposed of in them.
5.1.5 Surface Water
Surface water samples were collected from two locations in the
onsite pond on the southern boundary of the landfill, and three
locations from the unnamed tributary (upstream, instream and
downstream) . Figure 5 shows the surface water sampling
locations. The unnamed tributary represents a dynamic
environment with influx/outflux of constituents with
precipitation events and seasons. The onsite pond, on the other
hand, serves as a sink for source constituents emanating from the
landfill source material and surrounding properties with no
definable outflux.
Onsite Pond
Onsite pond aluminum concentrations were considerably higher than
those observed in the unnamed tributary and may indicate that the
pond has received significant aluminum loading from the landfill
runoff. Ammonia concentrations ranged from 2.8 to 47.8 mg/L.
These concentrations are approximately two orders of magnitude
higher than the corresponding background action levels (lOOx
background concentration). Background action levels were used to
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assess possible site-related contributions to surface water
contamination. Chlorides, in the form of sodium and potassium
salts, make up a large fraction of the salt cake fines mass.
Chlorides concentrations were found to range from 48.5 to
243.4 mg/L. Elevated chlorides concentrations may be directly
attributed to salt cake fines impacts.
Unnamed Tributary
No downstream sodium, potassium, sulfate, chloride, and ammonia
concentration exceeded the corresponding background action level.
Aluminum was detected in one downstream sample (SW/B15/G; 485
ug/1) above the quarter-specific background action level.
In no instance was any one pesticide/PCB compound detected in two
consecutive quarters in the unnamed tributary or onsite pond.
5.1.6 Sediment
Sediment samples were collected from three locations in the
unnamed tributary and two locations from the onsite pond (See
Figure 5). All samples were collected from 0 to 6 inches below
ground surface. The existence of coal-related constituents in
area surface waters was expected since most of the area around
the Brantley Landfill has been strip mined for coal (upstream and
downstream). No instream sediment sample had an ammonia,
chloride, aluminum, sodium or potassium concentration in excess
of the corresponding background action level.
Leachable ammonia concentrations for pond sediments ranged
between 2.3 and 6.79 mg/1 indicating salt cake fines impacts.
Pond sediment leachable chlorides were found to range from 3.7 to
6.51 mg/1. This was not unexpected as it is likely that
unreacted salt cake fines have been transported to the pond with
Site runoff. Pond sediment sodium concentrations were found to
range from 250 mg/kg to 389 mg/kg. Based on knowledge of salt
cake fines composition, these sodium levels have been attributed
to historic Site impacts. On-site pond sediment aluminum
concentrations ranged from 14,800 and 16,200 mg/kg. These
concentrations were approximately three times the observed
instream concentrations (4,510 to 6,030 mg/kg).
With the exception of manganese in the second phase sample at
SD/C16/G (272 mg/kg versus 245.5 mg/kg action level), no
inorganic or wet chemistry parameter was detected in any instream
sediment sample above the corresponding background action level.
The unnamed tributary sediments downstream of the Site were found
to contain more numerous organic compounds compared to upstream
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samples. The greatest number of compounds were reported at
location SD/C16 during Phase I sampling. This sampling location
is just upstream of Tram Road in a fairly stagnant stretch of the
unnamed tributary- Roadway runoff could account for semivolatile
contaminants detected. The suite of pesticide compounds detected
in sediments varied between the unnamed tributary and the onsite
pond. The highest reported sediment pesticide detected was
aldrin at 2.4J p.g/kg at background location SW/H3.
5.1.7 Ground Water
To determine if ground water had been impacted offsite, six
residential wells within a 1-mile radius of the Site were sampled
during the first and second quarters. Some of these wells were
found to be either abandoned or cisterns, or used for washing
cars and yards, or for heating purposes. Currently all Island
citizens are connected to city water for potable water use.
Residential well sampling was discontinued after the second
quarter because no contaminants were detected at unacceptable
levels during the first two quarters.
A total of twelve monitoring wells (six shallow and six deep)
were installed to monitor the groundwater at the Site. See
Figure 6. Two of the shallow wells (GMW/K13/S and GMW/O8/S)
represent background in the shallow aquifer. Both wells were
installed east of the landfill in apparently unimpacted zones.
An additional shallow groundwater monitoring well was installed
north of Kentucky Highway 85 in a former strip mine area
(GMW/L1) . This well location was selected in order to provide
some appreciation for shallow groundwater quality in mine spoils
absent any possible salt cake fines impacts. Only one deep
monitoring well was installed east of the landfill due to the
presence of the former underground mine works void in this area.
Due to the drilling hazards associated with the underground mine
works (i.e.. explosion hazards) on and in the vicinity of the
Site, it was not possible to establish a definitive upgradient
background location in the shale (deep) aquifer.
Shallow aquifer
Ten pesticide compounds were detected in shallow background
groundwater samples during the RI process. The pesticide hits
reported in the background wells indicate that a non Site-related
source exists and that their presence may be associated with
general pesticide use in the area.
No shallow onsite monitoring well produced a sample with
aluminum, potassium or sodium concentrations in excess of the
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corresponding background action level. The background action
levels were used to directly determine whether onsite
concentrations were significantly higher than natural and/or non
site-related anthropogenic levels. The chloride concentration in
each shallow monitoring well sample during each quarter was found
to be above the background action level. The maximum reported
chloride concentration was in the first quarter sample from well
GWM/I10/SG (379 mg/1). Shallow wells GWM/H13/SG and GWM/H16/SG
consistently produced samples with ammonia concentrations in
excess of background. The maximum detected ammonia level was
2.9 mg/1 (GWM/H16/SG; first quarter).
Beryllium, cadmium, chromium, cobalt, copper, iron, magnesium,
manganese, mercury, nickel, silver, zinc, sulfates, ammonia and
chlorides were each detected in at least one -shallow monitoring
well sample at a concentration in excess of the background action
level.
Sulfate in excess of the background action level was reported
during at least two quarterly sampling events in GWM/H13/SG,
GWM/H16/SG and GWM/I10/SG. Sulfates are expected in former
mining areas and result from the oxidation of sulfide compounds
present in coal and associated formations (i.e. iron pyrite).
Sulfates concentrations observed in shallow onsite wells may be
attributable to mine spoil impacts.
Deep aquifer
Fewer pesticide compounds were identified in deep groundwater
samples compared to shallow. GMW/H16/DG produced samples with
the most numerous detected compounds. As was the case with
shallow groundwater, compound detection between quarters was
inconsistent on a well-specific basis.
No aluminum, antimony, lead, selenium, thallium, vanadium or
cyanide results in excess of the applicable background action
levels were reported in any deep monitoring well over the course
of the RI. Every deep monitoring well sample had ammonia and
chloride concentrations above the corresponding background action
level. The background action levels for ammonia and chlorides
were 1.1 mg/1 and 57 mg/1, respectively. Deep wells GWM/H16/DG
and GWM/O8/DG produced samples with ammonia and chloride
concentrations at least one to two orders of magnitude above the
action levels (ranging from 81.2 to 386 mg/1 and 4,830 to 12,800
mg/1, respectively). Both GWM/H16/DG and GWM/I18/DG produced
four quarterly samples with sulfates concentrations in excess of
the background action level (1053.7 mg/1).
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Mine spoils located along the western perimeter of the landfill
have been identified as the potential source of many of the
inorganic and wet chemistry parameters detected in onsite wells.
Formal classification of the Brantley Site ground water was not
performed during the RI. However, ground water was not found to
be present in quantities likely to be used as drinking water
sources or at depths likely to be reached in attempts to secure
such quantity. Deeper zones, if accessed, are likely to be
brackish, or tainted with naturally occurring hydrocarbons.
5.2 Contaminant Fate and Transport
5.2.1 Source Material
The source material (salt cake fines) may be characterized as a
fine-grained solid with a consistency generally similar to that
of a coarse sand. The material (in-situ) is not subject to wind
dispersion. The landfill cap serves to suppress dust generation
in the absence of bulk material movement. As a result, source
material does not warrant specific fate and transport evaluation.
The constituents of salt cake fines are, however, subject to
significant fate and transport phenomena. The soluble fraction
of the bulk material (primarily sodium and potassium chlorides,
and ammonia) are readily transported by water passing through the
material. The primary origin of infiltration which may contact
source material is infiltration of precipitation through the
landfill cap. Solubilized constituents are expected to leave the
landfill through migration of groundwater.
Another documented indirect transport mechanism for source
related constituents is air. Gaseous by-products are formed by
the reaction of salt cake fines with water. Ammonia is by far
the most abundant gas produced in this reaction. Based on
previous air pathway analysis at the landfill, ammonia was
identified as the primary air pathway contaminant of concern.
5.2.2 Air
An interim cap repair measure was performed on the eroded areas
of the landfill in order to minimize water infiltration and
reduce gaseous ammonia emissions. The cap was installed in six-
inch compacted lifts to a thickness of 3-feet. The clay that was
used for the cap had a tested permeability of 10"7 cm/sec.
The original FTIR air emissions study was performed prior to cap
repairs in June of 1992. There have been no post cap repair
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studies to verify that air emissions have been eliminated from
the landfill. However, EPA's Air Superfund document, Volume JI -
Baseline Air Emissions at Superfund Sites, provide an emission
rate equation for closed landfills which was used to
theoretically estimate the effectiveness of the repairs. It was
estimated from this equation that for a closed landfill covered
with soil and/or clay caps, installation of a 100 cm thick soil
and clay cover will conservatively result in a total reduction of
the baseline volatile contaminant emissions, and accordingly the
predicted maximum potential exposures by at least 95 percent.
5.2.3 Soils
The concentrations of organic constituents identified in Site
soils do not warrant specific fate and transport modeling.
Inorganic constituents found in Site soils, although exhibiting
significant concentrations, were comparable to background (i.e.
mine spoils) levels. With the exception of two isolated
locations (SO/18 and SO/K10), no marked deviations from
background soil concentrations (mine spoils) were noted. General
soil conditions are considered representative of strip mine area
soils comprised primarily of mine spoils.
Based on Site layout and history, the principal route for soil to
ground water contaminant transport would be expected to occur at
depth. Leachate emanating from the landfill could impact
subsurface soils and contaminants would continue to transfer from
soil to ground water with seasonal ground water elevation
fluctuations. The existence of this route (for shallow ground
water) would manifest itself in the form of significantly
elevated concentrations of soluble salt cake fines constituents
(i.e. chlorides) in shallow wells. However, this pattern was not
observed. Furthermore, as indicated by GWM/L1 data, mine spoils
(absent any salt cake fines influence) provide a significant
source of ground water contaminants.
There is no evidence of a soil to surface water cross media
transport pathway. No appreciable surface water quality
differences were noted between upstream and downstream sampling
locations in the unnamed tributary. The unnamed tributary has
shown significant visible impacts from acid mine drainage caused
by the extensive strip mining activities up and downstream of the
Site.
5.2.4 Surface Water and Sediment
Organic analyses results for the unnamed tributary samples do not
indicate Site-related impacts. The number of pesticides detected
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in surface water samples was greater in downstream sample
SW/C16/G. Pesticide patterns were sporadic at best and no
reported hit exceeded 4 parts per trillion. As a result, these
findings do not warrant specific fate and transport modeling.
With few exceptions, downstream samples in the unnamed tributary
had inorganic and wet chemistry parameter concentrations below
corresponding background action levels. Background action level
exceedances were not noted to be consistent for any parameter.
Aluminum and barium were detected at elevated concentrations
(relative to quarter-specific action levels) at locations
SW/C16/G during first and third quarter sampling, respectively.
The reported concentrations were, however, comparable to
background results obtained for other quarterly events. The
magnitude and frequency of these departures from background does
not indicate a predictable Site-related cause/effect
relationship.
Onsite pond surface water samples were found to contain elevated
concentrations of source material constituents. The pond,
however, is a receptor for salt cake fines constituents
introduced through surface runoff collection and/or perched
groundwater seepage (landfill leachate) . The pond does not have
a discharge point through which contaminants could be transported
to other surface water bodies. Because the pond has been shown
to serve as a sink for contaminants emanating from the landfill,
sediment from this feature would be expected to be qualitatively
representative of potential Site-related impacts. Qualitative
correlation of pesticide results between surface water bodies is
low.
Downstream sediment inorganic and wet chemistry results from the
unnamed tributary were found to be remarkably similar to
background. Onsite pond sediments were found to have elevated
aluminum, barium, chromium, cobalt, copper, magnesium, nickel,
potassium, sodium, vanadium, ammonia, and chloride concentrations
compared to instream background action levels. As previously
discussed, the onsite pond has no discharge point or outlet. As
a result, transport is not a concern relative to these
contaminants.
5.2.5 Groundwater
The groundwater medium represents the most complex environmental
medium and also the medium which has the most uncertainty, due to
a lack of data. As a result, a series of potential transport
scenarios were devised in the RI Report using the available data
to depict groundwater transport phenomena in the shallow and deep
aquifers at the Site. Chlorides were selected as the key
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parameter in the transport modeling due to their persistent
nature, extremely high solubility in water, and therefore maximum
potential for transport above all other detected constituents..
Shallow Aouifer
UPS Sandstone (East of the Landfill)
There are two shallow monitoring wells (O8 and K13) screened in
the UPS sandstone, east of the landfill. The groundwater
elevation in O8 is higher than in K13 which indicates that there
is at least some component of groundwater flow towards the
landfill. However, the primary groundwater flow direction
appears to be aligned with the dip to the south/southeast, away
from the landfill.
West of the Landfill
Fundamental transport modeling for the unconsolidated aquifer was
performed using the computer model: GWPath: Groundwater
Pathline and Travel Time Analysis, Version 4.0, particle tracking
program. The model is based on Darcy's Law for incompressible
fluids. Data generated using GWPath were used to approximate the
movement of potentially affected groundwater during the life of
the landfill (16 years) and for a 50-year period.
The conclusions of the model suggests that to date, groundwater
contamination should not- have reached the shallow monitoring
wells west of the landfill (40-45 feet). The 50-year plot
indicates that the contamination still would not have reached the
unnamed tributary to Cypress Creek at its closest point to the
landfill (165 feet). However, chlorides were detected during
quarterly groundwater monitoring in each of the shallow wells
west of the landfill in concentrations ranging from 8.2 to 379
mg/1. One explanation for the observed chloride migration is
mass transfer by diffusion. Diffusion calculations predicted
concentrations consistent (on the same order of magnitude) with
those observed in the shallow wells.
In summary, one contaminant transport mechanism in the shallow
aquifer appears to be mass transfer by diffusion. Another
potential transport mechanism could be localized areas of .
enhanced hydraulic conductivity (i.e. shallow monitoring well
H16) that were not identified by drilling and/or slug testing of
the shallow monitoring wells.
Landfill
Groundwater entering the landfill through precipitation and/or
groundwater infiltration, appears to primarily be draining into
the abandoned underground mine works to the east of the landfill
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(see Figure 2) . This is supported by the contamination in
monitoring well O8D which is apparently monitoring leachate
draining through the underground mine works due to improper
placement of the filter pack during .well completion. Other data
to support the hypothesis of eastward migration are the mineworks
borings that were drilled along the eastern side of the landfill.
These borings registered flammable gas levels greater than 100%
of the Lower Explosive Limit (LED / and qualitative ammonia gas
readings at approximately 150 ppm. This suggests that at a
minimum, ammonia is leaving the landfill in the vapor phase. The
source of combustible gases cannot be determined due to naturally
occurring gases released from the coal and reported sewage that
has been disposed of in the abandoned mine works.
Groundwater elevations in the landfill, estimated from levels
taken during hand augering attempts within the landfill, suggest
that a volume of approximately 10,000,000 gallons of water has
accumulated over the life of the landfill (i.e. 16 years).
Deep Aquifer
Based on groundwater elevations in the deep monitoring wells,
groundwater flow generally follows the direction of structural
dip to the south/southeast.
The groundwater analytical results from monitoring well O8D
indicate that it is the most impacted well onsite and is also the
farthest well from the landfill. In 50 years, the contamination
is predicted to have reached one-third of the distance to 08D (91
feet) . Since deep monitoring well 08D is 300 feet east of the
landfill, contamination must have migrated to O8D by some route
other than the deep shale aquifer (i.e. the underground mine
works).
Two exceptions to the deep groundwater regime exist: I18D and
K7D. These two monitoring wells show impacts from salt cake
fines constituents. Monitoring well K7 is upgradient of the
landfill approximately 25 feet. Mass transport by diffusion
coupled with periodic pumping during purging and sampling may
explain the levels of indicator constituents and the increase in
chlorides from first to fourth quarter. Monitoring well 118 is
south of the landfill approximately 100 feet. The most likely
explanation for the presence of indicator constituents in this
well is a southerly component to groundwater flow away from the
landfill.
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6.0 SUMMARY OF SITE RISKS
A Baseline Risk Assessment (BRA) was conducted and the results
are presented in Section 7.0 of the RI Report. The BRA provides
the basis for taking action and indicates the exposure pathways
that need to be addressed by the remedial action. It serves as
the baseline indicating the risks that could exist if no action
is taken at the Site. This section of the ROD summarizes the
results of the BRA conducted for the Brantley Landfill Site.
6.1 Contaminants of Concern
The contaminants of concern (COCs) for the baseline risk
assessment are shown in Tables 1 through 5 (Appendix B) on a
medium-specific basis. These COCs were determined through
screening analysis. The risk/hazard screening analysis was
performed using medium-specific exposure formulae. Those
compounds/parameters contributing 99 percent of the calculated
screening analysis risk and/or hazard, and those contaminants
which were found to exceed Applicable or Relevant and Appropriate
Requirements (ARARs) were retained as COCs. Those
compounds/parameters posing an individual carcinogenic risk in
excess of 1E-7 and/or hazard quotient in excess of 0.1 were also
retained as contaminants of concern.
6.2 Exposure Assessment
The objective of the exposure assessment is to estimate the
magnitude of potential human exposure to the contaminants of
concern at the Brantley Landfill Site. For exposure to occur,
four essential elements must exist, i.e. (a) a source and
mechanism of chemical release to the environment, (b) an
environmental transport medium (e.g., air, groundwater), (c) a
point of potential contact (exposure point) with the contaminated
medium and (d) an exposure route (e.g., inhalation, ingestion) at
the contact point.
The Brantley Landfill Site area of concern encompasses
approximately four acres. Access to the Site by motorized
vehicle (truck and car) has been restricted to one road access
from Kentucky Highway 85. There are three gates in the fence
which was constructed to preclude access to the landfill area of
the Site. These gates are kept locked at all times. There is
one private residence on the property but no homes are within the
area of concern (fenced area).
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Because the Site is not developed, current residential
risk/hazard characterization is not appropriate but future
residential risk/hazard projections have been made. Current Site
workers are subject to potential exposure to environmental media
contaminants. Future Site resident risk/hazard characterization
was performed on the basis of baseline (existing) contaminant
concentrations. Onsite workers would be expected to be exposed to
the same contaminant concentrations, but at lower exposure
frequencies/duration, and lower ingestion/contact rates.
Therefore, remedial action goals based on residential use will be
protective of current and future workers.
Following is a list of potential exposure routes for Site
residents and workers.
Inhalation of gaseous contaminants emanating from the
landfill (ammonia only)
Ingestion (potable use) of contaminated groundwater from the
mine spoils and bedrock aquifers
Ingestion of and dermal contact with contaminated soils
Ingestion of and dermal contact with contaminated sediment
in adjacent streams and onsite pond during recreational use
Ingestion of contaminated surface water from adjacent
streams and onsite pond during recreational use
The air pathway was evaluated on the basis of acute and chronic
exposure based on maximum 24 hour and annual average ammonia
concentrations, respectively. For soils, sediment, and surface
water media, the maximum reported concentration of each
contaminant was used in the calculation of potential risk/hazard.
For groundwater, the maximum four quarter average concentration
on a well-specific basis (for both background and onsite) was
used to compute the risk/hazard associated with potable use of
the shallow and deep water bearing zones. The concentrations
used to compute risk/hazard are presented along with frequency of
detection, range and background concentration information in
Tables 6 through 10. Figures 7 through 10, and Tables 14 and. 15
provide the exposure assumptions used in the baseline risk
assessment.
6.3 Toxicity Assessment
The objective of the toxicity assessment is to further determine
the potential hazard posed by the chemicals of concern for which
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exposure pathways have been identified. Contaminant-specific
standards that are applicable or relevant and appropriate
requirements (ARARs) are used when available to determine
acceptable levels. Also, health-based levels are determined by
using reference doses (RFDs) for noncarcinogens and EPA slope
factors (SFs) for carcinogens. The EPA has established a
classification system for rating the potential carcinogenicity of
environmental contaminants based on the weight of scientific
evidence. Table 11 presents the EPA weight-of-evidence
classifications system for carcinogenicity. Table 12 summarizes
toxicological data obtained for all contaminants of concern
identified at the Brantley Landfill NPL Site including the
carcinogenicity classification.
6.3.1 Carcinogens
The EPA has established Slope Factors (SFs) for carcinogenic
compounds. The SF is defined as a plausible upper-bound estimate
of the probability of a response (cancer) per unit intake of a
chemical over a lifetime. The potential risk posed by a
contaminant is computed by multiplying the chronic daily intake
(GDI in mg/kg/day) by the Slope Factor (SF in (mg/kg/day) ~l) .
6.3.2 Non-carcinogens
EPA has derived Reference Dose (RfD) values for substances that
can produce systemic toxic responses at doses greater than
experimentally-derived threshold levels. A chronic RfD is
defined as an estimate of a daily exposure level for the human
population, including sensitive subpopulations, that is iikely to
be without an appreciable risk of deleterious effects during a
lifetime. The hazard quotient is computed by dividing the GDI by
the RfD (in mg/kg/day).
EPA has set standard limits (acceptable risk levels) for
carcinogens and non-carcinogens to evaluate whether significant
risk is posed by a contaminant (or combination of contaminants).
For carcinogens, the acceptable risk range is 10~4 to 10~6. These
risk levels correlate with one in 10,000 and one in 1,000,000
excess cancer incidents resulting from exposure to environmental
contaminants. The 10'6 point of departure is generally applied
for exposures which occur in a residential exposure setting while
the 10"4 point of departure generally applies to industrial
occupational exposure settings. For non-carcinogens, systemic
toxic effects are generally considered possible if the hazard
quotient exceeds unity (1).
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6.4 Risk Characterization
The objective of the risk characterization is to estimate the
overall potential adverse effect by utilizing the exposure
information and dose-response data for each exposure scenario
previously presented. Table 13 provides a summary risk
characterization which is applicable to hypothetical future Site
residents maximally exposed to each contaminated media. In order
to arrive at these "worst case" receptor exposure scenario, the
following assumptions were made:
• The individual would reside onsite for a period of 30 years
during which he/she would be exposed to soil, surface water,
and sediment at the maximum concentration detected in each
medium.
• The individual would derive 100 percent of domestic potable
water from either the hypothetical "worst case" shallow well
or the hypothetical "worst case" deep well.
6.4.1 Air Pathway
The air pathway was evaluated on the basis of acute and chronic
exposure based on maximum 24 hour and annual average ammonia
concentrations, respectively. The air pathway risk/hazard posed
by the Brantley Landfill-Site was evaluated through monitoring
and modeling exercises under worst-case gas emission conditions
prior to repair of the landfill cap.
Maximum eight hour air concentrations were projected to exceed
the KAR fenceline standard of 0.4 mg/m3 in all directions. The
highest anticipated offsite eight hour maximum ammonia
concentration was between 1.2 and 1.4 mg/m3 along the southern
property line.
The maximum projected 24 hour ammonia concentration at an
existing residence was modeled at 0.545 mg/m3. The highest
projected 24 hour maximum offsite ammonia concentration was
between 0.7 and 0.8 mg/m3.
The IRIS-derived reference concentration for ammonia is 0.1 mg/m3
for chronic exposure. Exceedance of this standard was projected
to occur exclusively in the immediate vicinity of the former cap
breach, extending only slightly (approximately 100 feet) beyond
the fence which encircles the landfill.
Cap repair measures are believed to have effectively eliminated
the most prominent source of direct gaseous emission from the
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landfill. As a result, the hazard associated with the air
pathway is no longer considered unacceptable under current
conditions.
6.4.2 Soil Pathway (Direct Ingestion «"<* Dermal Contact)
Figure 7 and Table 14 provide the risk formulae and risk/hazard
assumptions applied for soils at the subject Site. The
risk/hazard formulae are standard for calculating residential
exposure (through chronic daily intake) for residents.
Soil arsenic accounted for 99.8 percent of the computed
carcinogenic risk. As shown in Table 14, the total (combined
ingestion and dermal contact) potential cancer risk for the
surface soil pathway using maximum concentrations is 1E-4. This
value is at the upper bound of the acceptable range of 1E-4 to
1E-6. The combined soil ingestion and dermal contact exposure
pathway hazard index was calculated to be 1.5. This hazard index
is slightly above the most stringent threshold of unity (1) .
Arsenic (hazard quotient (HQ) = 0.47), aluminum (HQ = 0.12),
chromium (HQ = 0.07), iron (HQ = 0.8) and vanadium (HQ = 0.03)
account for the potential hazard related to soil.
6.4.3 Surface Water -Pathway (Direct Ingestion)
Figure 8 presents the formulae used to compute chronic daily
intake (GDI) and risk/hazard via the surface water pathway under
a recreational use scenario.
The total risk computed for the surface water pathway was 7E-6.
This value is within the acceptable risk range of 1E-4 to 1E-6.
The hazard index for surface water is 0.4. Ammonia, arsenic and
thallium accounted for the majority of the computed surface water
hazard index. Only one sample (SW/J17/C; first quarter) had a'
reported ammonia concentration in excess of 34 mg/1 (the RfD -
equivalent drinking water concentration) .
6.4.4 Sediment Pathway (Direct Ingestion and Dermal Contact)
Figure 9 and Table 15 provide the risk formulae and assumptions
to calculate the risk/hazard associated with sediment exposure (s)
under recreational use. The Kentucky Department of Environmental
Protection (KDEP) , Risk Assessment Section (RAS) provided
standard default sediment exposure frequency values for use in
this baseline risk assessment . These values are presented on
Table 15. Due to the similarity of potential uses of the two
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surface water bodies, risks/hazards were computed using maximum
contaminant levels from pond or unnamed tributary sediments.
Aluminum, barium, chromium, manganese, nickel, vanadium, and
tetrachlorobenzene accounted for greater than 95 percent of the
calculated potential hazard. Both the computed risk and the
hazard index for sediments are below the most stringent EPA
thresholds.
6.4.5 Groundwater Pathway (Direct Ingestion)
Figure 10 presents the formulae used to compute GDI and
risk/hazard via the groundwater pathway.
Shallow Groundwater
Arsenic and beryllium account for greater than 99 percent of the
total potential risk (8E-4) posed by ingestion of shallow
groundwater. No other parameter posed an individual risk in
excess of 1E-6 although chlorinated pesticides as a group present
a cumulative potential risk of 3.8E-6.
A hazard index of 1262 was computed for the shallow groundwater
exposures. This value is three orders of magnitude higher than
EPA's hazard threshold of one. Approximately 99 percent of the
potential hazard was attributable to manganese (1248). The
abundance of manganese in the shallow monitoring wells is due to
mine spoils impacts. Manganese is commonly found in coal and
coal spoils. Aluminum, arsenic, cadmium, chromium, cobalt, iron,
manganese, mercury, nickel, silver, sodium, vanadium, and zinc
each had individual hazard quotients in excess of 0.1.
Deep Groundwater
The computed potential carcinogenic risk is 3E-4 and the deep
groundwater "worst case" hazard index is 570. Arsenic and
beryllium were shown to account for nearly 99 percent of the
total carcinogenic risk. Manganese (94.7 percent), iron (1.9
percent), ammonia (1.4 percent) and sodium (0.8 percent)
accounted for the vast majority of the potential non-carcinogenic
hazard posed by "worst case" deep groundwater.
Tables 16 to 18 show the exposure point concentrations, and
risks/hazards associated with ground water and soil.
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6.5 Ecological Assessment
The RI identified three potential habitats of concern at the
Brantley Landfill Site and immediate vicinity: the terrestrial
habitat, the onsite pond at the southern end of the landfill, and
the unnamed tributary to Cypress Creek.
The approximately four-acre fenced area consists of partially
vegetated gently rolling hills with a small freshwater pond (man-
made sedimentation basin) at its southern end. The Site is
located between two rural communities, and is bounded on the west
by a fresh ephemeral stream (an intermittent unnamed tributary to
Cypress Creek). Prime agricultural land adjoins the unnamed
tributary on the west. No endangered or threatened species, nor
wetlands were identified on or in the vicinity of the Brantley
Landfill.
Two phases of aquatic toxicity testing were performed. The
toxicity testings indicated toxicity in the form of mortality or
sickness in test organisms. The first phase of testing was a 48-
hour screen.of surface water and sediment elutriates on Daphnids
(Daphnia magna) and Fathead minnows (Pimephales promelas) , and
the second phase was a 96-hour screen.
The results of the toxicity testing and the lower pH reported in
upstream samples indicate that the intermittent stream has been
heavily impacted by historical acid mine runoff originating
upstream of the Site. Also, the unnamed tributary is a very low
flow intermittent stream with insufficient flow to maintain
aquatic life throughout most of the spring, summer and early
fall, depending upon rainfall. The onsite pond would be
considered a limited habitat due to the fact that it dries to an
approximately three foot diameter puddle during dry months.
6.6 Risk Uncertainty
There is a generally recognized uncertainty in human risk values
developed from experimental data. This is primarily due to the
uncertainty of data extrapolation in the areas of (1) high to low
dose exposure, and (2) animal data to human experience. The
site-specific uncertainty is mainly in the degree of accuracy of
the exposure assumptions. Most of the assumptions used in this
and any risk assessment have not been verified. For example, the
degree of chemical absorption from the gut or through the skin or
the amount of soil contact is not known with certainty.
In the presence of such uncertainty, EPA and the risk assessor
have the obligation to make conservative assumptions such that
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the chance is very small for the actual health risk to be greater
than that determined through the risk process. On the other
hand, the process is not to yield absurdly conservative risk
values that have no basis in reality. That balance was kept in
mind in the development of exposure assumptions and pathways and
in the interpretation of data and guidance for this baseline risk
assessment.
In spite of attempts to control the overall conservatism of the
baseline risk assessment, limitations related to the database and
the uncertainty surrounding future Site use scenarios tends to
amplify the conservatism of the default exposure assumptions.
Database limitations identified for the Brantley Site are
primarily related to investigative approach. Most sampling was
focused on areas where impacts were suspected. Uncertainties
related to exposure settings, frequencies, durations, and
reasonable maximum exposure concentration are a function of the
inability to accurately project future Site usage.
6.7 Remedial Action Objectives
The groundwater and soil pathways were the only pathways to pose
a risk and/or hazard above the most stringent thresholds. For
these two pathways, remediation goal options were developed to
meet the following objectives:
• Prevent direct ingestion of source material constituents and
soil contaminants
• Prevent exposure by the air/ground water pathways
• Prevent migration of source material constituents to the
air, ground water, and underground mine works.
• Prevent ingestion of water from the landfill having
unacceptable levels of site contaminants
• Prevent further contamination/migration of ground water at
unacceptable contaminant levels
Table 19 presents remediation goal options for the surface soil
at the Brantley landfill Site. Tables 20 and 21 presents
remediation goals for the shallow and deep aquifers,
respectively.
Ground water and soil remediation goals are based on health-based
goals, chemical-specific ARARs, and/or a range of background
concentrations. The range of background concentrations was
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determined using the four quarter average concentration for each
background well. The range of background concentration was used
as a remediation goal because for some contaminants the chemical-
specific ARAR and the health-based goals were lower than
background conditions. Background is an important factor at this
Site because some of the contaminants encountered at the Site are
commonly associated with coal mining (e.g., iron, manganese).
Actual or threatened releases for hazardous substances from this
Site, if not addressed by implementing the response actions in
this ROD, may present an imminent and substantial endangerment to
public health, welfare and the environment.
7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
The following remedial alternatives were selected for evaluation:
• Alternative 1: No Action
Institutional Controls
• Alternative 2:
• Alternative 3:
• Alternative 4:
• Alternative 5:
Cap and Contingent Long-term Leachate
Extraction
Cap and Contingent Short- and Long-term
Leachate Extraction
Excavation and Place in Offsite Landfill
7.1 Alternative 1: No Action
CERCLA requires that a No-Action alternative be considered as a
"baseline case" for evaluating all other alternatives. Because
the salt cake fines will remain at the Brantley Site, Site
characterization data would be collected and evaluated.
Groundwater would be sampled annually at all installed wells.
The samples would be analyzed for the COCs identified during the
RI. In addition, the results of this evaluation would be used to
maintain, increase, or decrease the number and types of samples
and analyses required.
The cost for site monitoring under Alternative 1 is approximately
$17,000.00 per year and the present worth for Alternative 1 is
$260,000.
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7.2 Alternative 2: Institutional Controls
Alternative 2 relies on institutional controls and fencing to
prevent direct human exposure to the source material. The site
would be regularly inspected to assure cap and fence integrity.
Deed restrictions would prevent access to onsite groundwater.
Landfill leachate would be monitored semi-annually to determine
the attenuation of ammonia and chlorides and to check for
leaching of metals from salt cake fines. Groundwater
contamination and levels would also be monitored semi-annually.
Under Alternative 2, a one-time monitoring of air emissions would
be conducted using an Open-path FTIR spectroscopy to confirm that
ammonia emissions from the landfill to air have been effectively
attenuated by recent cap improvements. A monitoring program of
the abandoned coal mine works would be implemented. The
monitoring program would include ambient air monitoring at
previously closed mine shafts southeast of the site and
monitoring of groundwater in the coal seam beyond the boundary of
the abandoned mine works (presumed to be southeast and down-dip
of the closed shafts) . This monitoring would indicate mine work
transport of salt cake fines constituents, if occurring.
The capital cost for Alternative 2 is $66,000, the O&M cost is
$50,000 and the present worth is $835,000.
> •
7 .3 Alternative 3: Cap and Drainage Improvements and Long-term
Leachate Extraction
Alternative 3 would be designed to minimize the infiltration of
water into the landfill through the installation of a new
landfill cap. This alternative incorporates all elements of
Alternative 2. A large component of the volume of contaminated
groundwater flowing from the landfill into the adjacent mine
works arises from surface water percolation into the landfill and
mine spoils immediately adjacent to the landfill. Under existing
conditions approximately 2,000,000 gallons per year (gpy) of
surface water infiltrate the landfill. Capping the landfill and
the adjacent mine spoils area would reduce, perhaps prevent,
future offsite migration of soluble materials from salt cake
fines and eventually lead to attenuation of existing groundwater
contamination. Construction of a low permeability cap across the
existing landfill and mine spoil area would reduce water
infiltration to approximately 5,200 gpy.
RI data suggest that the rate of groundwater infiltration into
the landfill is small compared to surface water infiltration. At
this time, groundwater gradients around the landfill are
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uncertain. Alternative 3 would include the contingency for long-
term leachate extraction measures to address contaminant
migration caused by groundwater infiltration. Groundwater
levels and quality would be monitored after installation of the
new landfill cap, both in the landfill and surrounding
groundwater. At that time, an analysis of the ground water
infiltration to the landfill, contaminant migration from the
landfill, rate of restoration of ground water in the landfill,
and implementable rates of leachate collection, treatment and
offsite disposal, among other factors would be performed. The
primary criterion to determine whether to install the long-term
leachate removal system would be that such system would
significantly improve the time for restoration of site
groundwater.
Shallow groundwater adjacent to the western side of the landfill
is in contact with mine spoils and contains metals at
concentrations greater than those found in offsite wells.
Alternative 3 incorporates alkaline recharge trenching to
increase the pH of shallow groundwater and reduce metals
concentrations to acceptable levels. To encourage surface water
runoff it would be necessary to elevate the topography of the
existing landfill at the extreme northern end. Regrading the
south end of the landfill would eliminate the onsite pond.
The extent of the deep ground water contamination would be
determined, and the natural attenuation of contaminant
concentrations of the deep aquifer would be monitored. Also, the
shallow and deep aquifers would be classified.
The costs for Alternative 3 are presented as ranges to account
for contingent leachate extraction. The capital cost for
Alternative 3 is $626,000 to $786,000, the O&M cost is $57,000 to
$223,000 and the present worth is $1,500,000 to $4,200,000.
7.4 Alternative 4: Cap/Drainage Improvements and Contingent
Short- and Long-term Leachate Extraction
Alternative 4 incorporates the elements of Alternative 3 — a new
landfill cap, an alkaline recharge trench, monitoring of ground
water and abandoned mine works, monitoring of the natural
attenuation of the deep aquifer, classification of the ground
water, and contingent long-term leachate collection, treatment
and disposal. Alternative 4 adds provisions for short-term
removal of landfill leachate currently accumulated in the
landfill, should that become necessary and if it is practicable.
The leachate would be treated onsite and the residuals from
treatment are disposed offsite. The system envisioned under
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Alternative 4 would be designed to completely drain the landfill
in three years instead of allowing an estimated 10 million
gallons of accumulated leachate to drain naturally over a longer
period of time.
The costs for Alternative 4 are presented as ranges to account
for contingent leachate extraction. The capital cost for
Alternative 4 is $3,600,000, the O&M cost is $57,000 to $223,000,
and the present worth is $4,500,000 to $7,000,000.
7.5 Alternative 5: Excavation and Place in Offsite Landfill
Alternative 5 calls for disposal of the salt cake fines in an
offsite landfill. The landfill would be constructed to the
required RCRA standards at a site yet to be determined.
The Brantley Landfill is 60 feet deep at its deepest point. The
removal of salt cake fines from the landfill would require
special equipment and excavation techniques. A large portion of
the salt cake fines at the site have hardened and must be broken
up with a pneumatic hammer mounted on a trackhoe. Over a three-
year period the material would be shipped to a newly constructed
landfill. For purposes of estimating the costs of this
alternative, a landfill meeting RCRA Subtitle C minimum
requirements would be assumed to be feasible.
Fugitive ammonia emissions could potentially occur along the
route of transport to the off site landfill. As a result, DOT
prohibits the transport of wet salt cake fines. The way to
prevent ammonia emissions during transport and landfilling would
be to dry the salt cake fines at the site and thereby drive the
ammonia off the salt cake fines. The ammonia would be
subsequently collected and disposed of/destroyed at the Brantley
site.
The capital cost for Alternative 5 is $26,000,000, the O&M cost
is $52,000 and the present worth is $27,000,000.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed comparative analysis using the nine evaluation
criteria set forth in the NCP was performed on the five remedial
alternatives developed during the FS. The advantages and
disadvantages were compared to identify the alternative with the
best balance among these nine criteria.
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8.1 Threshold Criteria
8.1.1 Overall Protection of Human Health and the Environment
Evaluation of the overall protectiveness of an alternative should
focus on whether it achieves adequate protection by eliminating,
reducing, or controlling the risks posed through each pathway
through treatment, engineering, or institutional controls.
Altenative 1 does not reduce site risks posed by direct contact
with salt cake fines and contaminated groundwater.
Alternative 2 prevents direct human contact with salt cake fines
and ingestion of contaminated groundwater by institutional
controls. Water migration from the landfill ceases in
approximately 15 years.
Alternative 3 prevents direct human contact with salt cake fines
by institutional controls, reduces offsite migration of
contaminated groundwater, poses no significant risks to workers
or to the community. Also, it does not adversely impact the
environment.
Alternative 4 prevents direct human contact with salt cake fines
by institutional controls and reduces offsite migration of
contaminated groundwater'.
Alternative 5 prevents direct human contact with salt cake fines
by institutional controls and reduces (possibly eliminates)
offsite migration of contaminated groundwater.
8.1.2 Compliance with Applicable or Relevant and Appropriate
Requ i rementB (ARARs)
This evaluation criterion is used to determine whether or not
each alternative will meet all the federal and state applicable
or relevant and appropriate requirements identified in previous
stages of the remedial process. The identified ARARs and "To-Be-
Considered" (TBC) criteria for this Site are listed in Section
9.5.
Alternatives 1 and 2 would attain Maximum Contaminant Levels
(MCLs) and TBCs in groundwater after 10 to 15 years.
Alternatives 3 and 4 would attain MCLs and TBCs by eliminating
offsite migration of contaminants after about 12 and 3 years,
respectively. The quality of shallow groundwater adjacent to the
landfill would be immediately improved by the installation of
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alkaline recharge trenches but no time estimate can be made for
achieving MCLs or TBCs for metal concentrations.
Under Alternative 5, MCLs and TBCs would be attained after about
four years. The landfill would be constructed and operated in
compliance with Federal and State Solid Waste ARARs.
Transportation of the fines to the new landfill would comply with
DOT regulations.
8.2 Primary Balancing Criteria
8.2.1 Long-Term Effectiveness and Permanence
Evaluating alternatives under this criterion addresses the
results of a remedial action in terms of the risk remaining at
the site after meeting response objectives. The primary focus of
this evaluation is the extent and effectiveness of the controls
that may be required to manage the risk posed by treatment
residuals and or untreated wastes.
Alternative 1 does not reduce the long term risks associated with
direct human contact with salt cake fines. Long-term, residual
risk to the environment dissipates, as continued surface water
infiltration flushes soluble compounds from the salt cake fines
and leachate. Long-term, protection against direct exposure to
salt cake fines cannot be assured, as the landfill cap and
fencing will deteriorate. This may present risks from less
soluble components of salt cake fines such as metals, but the
risk level is expected to be comparable to that posed by exposure
to the mine spoils in the area.
Under Alternative 2, long-term risks associated with direct human
contact with salt cake fines and contaminated site groundwater
are adequately controlled by institutional controls.
Long-term residual risks associated with direct human contact
with salt cake fines are adequately controlled by institutional
controls under Alternatives 3 and 4. These alternatives
permanently reduce (possibly eliminates) offsite migration of
contaminated groundwater by minimizing surface infiltration
through the cap over the landfill and adjacent mine spoils area.
Under Alternative 5, long-term risks associated with direct human
contact with salt cake fines are adequately controlled by
engineering controls at the offsite landfill. It permanently
eliminates offsite migration of contaminated groundwater.
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8.2.2 Reduction of Toxicity, Mobility, or Volume Through
Treatment
This evaluation criterion addresses the statutory preference for
remedial actions employing treatment technologies that
permanently and significantly reduce hazardous substances'
toxicity, mobility, or volume.
Alternatives 1, 2, 3 and 4 do not reduce the toxicity, mobility,
or volume of contaminants in any media by treatment.
Alternative 5 incorporates reverse osmosis (RO) and evaporation
to reduce the volume of contaminated leachate by up to about 80%.
Drying of wet salt cake fines and associated volatilization of
ammonia removes the residual ability of salt cake fines to
release ammonia.
8.2.3 Short-Term Effectiveness
The short-term effectiveness of a remedial alternative is
evaluated relative to its effect on human health and the
environment during the RA's implementation.
Alternative 1 prevents direct human contact with salt cake fines
in the short term but does not immediately achieve the remedial
response objective (RRO)'of preventing offsite migration of
contaminated groundwater. Offsite migration of groundwater
continues indefinitely because surface water continues to
infiltrate the landfill and exit the landfill via the adjacent
mine works. The ammonia and chlorides contamination will
eventually subside due to leaching of the salt cake fines by
surface water infiltration. It will require approximately 14
years to achieve the RRO for ammonia (34 ppm) in the landfill
leachate.
Alternative 2 prevents direct human contact with salt cake fines
immediately through the use of institutional controls. The time
required for ammonia and chlorides contamination to cease
migrating offsite is the same as for Alternative 1.
Implementation of Alternative 2 poses no significant risks to
workers or the community.
The RRO of preventing direct human contact with salt cake fines
is achieved immediately under Alternative 3 by institutional
controls. Implementation of this alternative does not adversely
impact the environment. The flowrate of water from the landfill
will decrease steadily with time and the landfill will drain
completely in about 12 years. Alkaline recharge trenches are
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installed on the western perimeter of the landfill to raise the
pH of shallow groundwater and to reduce the shallow groundwater
concentrations of metals. It is anticipated that an immediate
improvement in shallow groundwater quality will be achieved, but
the time required to achieve quantitative goals for metal
concentrations can not be determined.
The RRO of preventing direct human contact with salt cake fines
is achieved immediately under Alternative 4 by institutional
controls. Both Alternatives 3 and 4 quickly reduce offsite
migration of contaminated groundwater through installation of cap
and site drainage improvements. Under Alternative 4 the landfill
is de-watered if necessary and practical, after the landfill cap
is constructed. Alternative 4 thereby assures that contaminant
migration ceases within a reasonable time. Accumulated
contaminant mass may or may not be significant, and the rate of
migration may vary over a wide range. Information about
groundwater/leachate behavior will necessarily be gathered as the
alternative is implemented, and this information will serve as a
basis for assessing the need for, and rate of dewatering which is
both practical and effective. The rate of leachate migration
from the landfill will decrease steadily with time.
Implementation of Alternative 4 poses no significant risks to
workers or the community, and does not adversely impact the
environment.
Under Alternative 5, the RRO of preventing direct human contact
with salt cake fines is achieved in four years by excavation,
drying, and landfilling the salt cake fines offsite. Alternative
5 prevents offsite migration of contaminated groundwater after
about four years. Implementation of Alternative 5 poses
significant risks to workers. Excavation and removal of salt
cake fines from the narrow fill area at depths up to 60 feet will
expose workers to risks comparable to risk experienced by strip
miners. Worker risks are compounded by the fact that workers
must wear protective equipment during excavation and removal of
salt cake fines. Engineering controls will be employed to
minimize ammonia emissions from the landfill during excavation
and removal.
8.2.4 Implementabi1ity
The implementability criterion addresses the technical and
administrative feasibility of implementing an alternative and the
availability of various services and materials it requires.
Alternatives 2, 3, and 4 pose no significant implementability
challenges.
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Alternative 5 presents a significant technical challenge to
control fugitive ammonia emissions during salt cake fines
excavation and transportation. Further, siting and permitting of
a landfill will require significant administrative effort, which
will delay salt cake fines relocation.
8.2.5 Cost
A detailed cost estimate is developed for each remedial
alternative based on engineering analyses, estimates by suppliers
of necessary technology, and costs for similar actions (such as
excavation) at other CERCLA and RCRA sites.
The annual operating cost for Alternative 1 (for site monitoring
and site security) is about $17,000, and the present worth is
$260,000.
The capital cost for Alternative 2 is $66,000, the O&M cost is
$50,000 and the present worth is $835,000.
The costs for Alternative 3 are presented as ranges to account
for contingent leachate extraction. The capital cost for
Alternative 3 is $626,000 to $786,000, the O&M cost is $57,000
to $223,000 and the present worth is $1,500,000 to $4,200,000.
The capital cost for Alternative 4 is $3,600,000, the O&M cost is
$57,000 to $223,000 and the present worth is $4,500,000 to
$7,000,000.
The capital cost for Alternative 5 is $26,000,000, the O&M cost
is $52,000 and the present worth is $27,000,000.
8.3 Modifying Criteria
8.3.1 State Acceptance
This assessment evaluates the technical and administrative issues
and concerns the state may have regarding each alternative. This
criterion is largely satisfied through state involvement in the
entire remedial process. EPA and the KNREPC are in agreement on
the selected alternative. Please refer to the Responsiveness
Summary which contains a letter of concurrence from the KNREPC.
8.3.2 Community Acceptance
This assessment evaluates issues and concerns the public may have
regarding each alternative. EPA solicited input from the
community on the Proposed Plan for cleanup of the Brantley
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landfill Site. Although public comments indicated no specific
opposition to the preferred alternative, some local residents
expressed their concerns during the Proposed Plan public meeting.
Please refer to the Responsiveness Summary which contains a
transcript of the public meeting.
9.0 THE SELECTED REMEDY
Based upon consideration of the CERCLA requirements, the NCP, the
detailed analysis of the alternatives using the nine criteria,
and public and state comments, EPA has selected a source control
remedy for this Site. At completion of the remedy, the soil and
ground water risks associated with the Site will be below
acceptable levels, and protective of human health and the
environment. The total present worth cost of the selected
remedy, Alternative 4, is estimated at a range of total cost from
$1,500,000 to $7,000,000 depending on the need for contingency
measures.
The selected remedy for the Brantley Landfill Site will be
divided into two phases. Phase I will address surface water
infiltration, and Phase II will address any ground water
infiltration to the landfill. The purpose of the phasing is to
address the surface water threat while collecting additional
information on the ground water in and around the landfill. As
part of Phase I, confirmatory sampling will be done to determine
the appropriateness of the background levels chosen for the Site.
The information collected on ground water will be used to
determine whether to implement a short-term leachate removal
system, a long-term leachate collection system, or to allow the
natural attenuation of the landfill leachate and deep aquifer.
Hydrogeologic work conducted during the RI indicates that water
infiltration into the landfill from adjacent aquifers is small
compared to the rate of surface water infiltration. These
observations suggest that the impact on ground water at the Site
and the leached out state of the salt cake fines is largely due
to continuing surface water infiltration which migrates offsite
predominantly via the No. 9 coal mine works. Consequently,
capping the landfill and the adjacent mine spoils area will
reduce, and perhaps prevent, future offsite migration of soluble
materials from salt cake fines and eventually lead to attenuation
of existing ground water contamination.
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9.1 Phase I: Surface Water Infiltration
9.1.1 Additional Sampling and Installation of Ground Water
Monitoring Wells Prior to Installment of the Mew Cap
Surface water samples will be collected quarterly at a lake that
is situated approximately 0.5 miles south of the landfill. The
Commonwealth of Kentucky is concerned that the lake is a possible
discharge body for water from the landfill entering the mine
works. The number of samples to be collected will be determined
during the remedial design.
Piezometers, and additional shallow and deep monitoring wells
will be installed onsite and offsite prior to the installation of
the cap to measure water levels in the landfill, confirm shallow
water bearing zone stratigraphy, and more thoroughly define
shallow groundwater hydraulic gradients. The number and location
of these wells will be determined during the remedial design.
The monitoring program of the abandoned coal mine works will
include ambient air monitoring at previously closed mine shafts
southeast of the site and monitoring of groundwater in the coal
seam beyond the boundary of the abandoned mine works (presumed to
be southeast and down-dip of the closed shafts). Monitoring in
the coal seam will indicate mine work transport of salt cake
fines constituents, if occurring, while avoiding the hazards of
drilling in the void space of the mine works. The location and
number of monitoring wells will be determined during remedial
design.
Water level monitoring will determine the approximate volume of
leachate contained within the landfill. Groundwater levels, and
quality in and around the landfill will be monitored before,
during and after the installation of the new landfill cap.
Through the collection of leachate samples the present leachate
contaminant concentrations within the landfill will be
determined. This information will be utilized to determine the
potential net source strength of all the remaining salt cake
fines in the landfill, and the effect and relative contribution
.to ground water quality in the landfill from inflow of any mine-
drainage contaminated ground water. Sampling zones should be, to
the extent practicable, "fully penetrating" within the landfill
to provide a vertically averaged leachate concentration.
Sampling locations should also consider the potential spatial
variations in leachate concentrations.
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Through the collection of salt cake fine samples the degree of
source material depletion (contaminant concentrations) just below
the water table, and at the base of the landfill will be
determined. An analysis will be conducted of the "water from
reaction" of salt cake fines below the water table. This "water
from reaction" data will allow for enhanced prediction of the
long-term leachate composition once the water level declines
following landfill capping. Samples will be collected from
approximately 2 to 4 feet below the water level in the landfill
at the time of sampling, as well as from the base of the
landfill.
9.1.2 Source Control: Landfill Cap
Source control remediation will address the contaminated soils
and source material at the Site. The landfill cap will be
constructed to minimize surface water infiltration into the
landfill.
Prior to construction of the clay cap, it will be necessary to
elevate the topography of the existing landfill at the extreme
northern end to encourage surface water runoff. A clayey soil
with a maximum saturated hydraulic conductivity of IxlO"6 cm/s
will be placed on this area to achieve the required elevations.
At the south end of the landfill, existing grades are too severe
to prevent erosion. Because of proximity to the landfill,
regrading the southern end of the landfill with a maximum 3:1
slope, and benching, will eliminate the onsite pond. The water
from the pond will be disposed of offsite at an approved
facility.
A 2-foot cap will be constructed of clay which possesses an in-
place recompacted permeability coefficient equal to or less than
1 x 10"7 cm/s. The cap will be installed at the landfill and
adjacent mine spoils area.
9.1.3 Shallow Ground Water Remediation
Shallow groundwater adjacent to the western side of the landfill
is in contact with mine spoils. This shallow groundwater
contains metals at concentrations greater than those found in
offsite wells. These higher metal concentrations are largely
attributable to the low pH of shallow groundwater adjacent to the
landfill. As a general rule, metal solubility is inversely
proportional to pH; therefore, the solubility of metals increase
in the low pH environment created by the production of sulfuric
acid. Therefore, an alkaline recharge trench will be installed
to increase the pH of shallow groundwater and reduce metals
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concentrations in shallow groundwater to acceptable levels. The
actual design and location of the alkaline recharge trench will
be determined during the remedial design.
Phase I will also include shallow ground water classification
using EPA Ground Water Classification System.
9.2 Phase II: Deep Ground Water Remediation and Ground Water
Infiltration
9.2.1 Deep Ground Water Remediation
The natural attenuation of the deep ground water in the shale
underlying the landfill will be monitored during this phase. One
year of deep ground water data will be collected, beginning in
Phase I, from all deep wells to determine the extent of ground
water contamination, and to classify the ground water in the deep
aquifer. After this time, the deep ground water data will be
evaluated to determine the time required for natural attenuation
of contaminants in the deep aquifer, and to determine if the no
further action alternative is indeed the appropriate remedy for
this aquifer.
9.2.2 Landfill Leachate
Ground water levels and quality will be monitored for
approximately one year after the installation of the new landfill
cap, both in the landfill and surrounding ground water. This
information will be crucial along with the data collected before
and during the installation of the cap, in evaluating the
implementability of the short-term, and long-term leachate
collection systems.
Contingent Short-Term Leachate Collection System;
The short-term leachate collection system is a one time removal
of contaminated leachate within the landfill. The one time
removal will occur if the drainage rate and concentrations of
contaminated water in the landfill are unacceptable, and if the
ground water inflow to the mine, the contaminant reduction rate,
and the contaminant mass flux out of the landfill are acceptable
after the removal is conducted. Pre-capping data collection will
allow for a reasonable estimation of the time and resources
required to remove the contaminated ground water in storage via a
"pump and treat" system.
The different stages of the treatment process will include
pretreatment, reverse osmosis, evaporation and offsite disposal.
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Contingent Long-Term Leachate Collection System;
Alternative 4 includes the contingency for long-term leachate
extraction measures to address contaminant migration caused by
groundwater infiltration. Due to the lack of sufficient data
concerning ground water contamination and migration at the Site
EPA is not presenting the criteria associated with the
implementation of this remedy. However, the decision process
will consider, but not be limited to, the following factors:
The projected time frame before the landfill leachate
concentration declines to the point it no longer contributes
to violation of ground water ARARs outside the landfill.
Environmental and human health risks from continued
contaminant leaching to ground water from the landfill after
it is capped.
The amount of contaminated water leaving the landfill via
the underground mine, compared to the amount of contaminated
water leaving the landfill through the surrounding aquifer
material.
The time that further leachate migration from the landfill
will be contained by a "pump and treat" system.
The cost of a "pump'and treat" system for the landfill.
The incremental impact of continued discharge of
contaminated water out of the landfill on ground water
already contaminated by the landfill.
The projected rate of decline of further contaminant mass
flux into the aquifer material and underground mine without
the long-term "pump and treat" option.
These decision factors are generally consistent with the factors
used to compare the need for active ground water remedial action
versus natural attenuation, as outlined in the EPA document
Guidance on Remedial Actions for Contaminated Ground Water at
Superfund Sites.
Environmental data collected during the RD and post capping
period will be used to evaluate the need for a long-term "pump
and treat" remediation. These data include, but are not limited
to: the to-date depletion of contaminant mass in the salt cake
fines; the projected future depletion rate and depletion time
frame of remaining contaminant mass in the salt cake fines; the
changes in leachate concentration which occur following the
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Brantley Landfill Site
Record of Decision
Page 41
landfill capping; the amount of leachate outflow from the
landfill through the underground mine; the amount of leachate
outflow from the landfill through the aquifer material
surrounding the landfill; the rate of decline of further
contaminant mass flux into the aquifer material and underground
mine; and, the estimated total contaminant mass flux out of the
landfill which has already occurred.
A "pump and treat" system will likely be considered favorably if,
for example, the following conditions are noted:
There is an unacceptable additional risk or potential
additional risk to human or environmental receptors without
the long-term "pump and treat" system.
The estimated time required for natural attenuation outside
the landfill to attain ground water ARARs with the "pump and
treat" system is much shorter (approximately one third to
one half the time, or less) than the time required for
natural attenuation outside the landfill to attain ARARs
without the "pump and treat" system.
.The previous total contaminant mass flux out of the landfill
(as measured by dissolved chlorides in the ground water) is
not substantially greater than the post-capping contaminant
mass flux out of the landfill.
The conceptual design for a long-term system which extracts,
treats and disposes of landfill leachate includes pretreatment,
reverse osmosis, evaporation and offsite disposal.
9.3 Performance Standards
The remediation goal options listed on Tables 19 through 21 of
Appendix B of this document were evaluated by EPA's Remedial
Project Manager, in coordination with EPA's Regional
toxicologist, to determine the remediation levels for ground
water and soil at the Brantley Landfill Site. The following
remediation levels should be attained in order to insure
protectiveness of human health and the environment.
Surface Soil:
Once the new landfill cap is in-place, surface soil
concentrations shall not exceed the levels specified below.
Aluminum 7E+05 mg/kg
Arsenic 30 mg/kg
Iron 7E+04 mg/kg
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Brantley Landfill Site
Record of Decision
Page 42
Ground Water:
Shallow ground water concentrations should be reduced to attain
the following levels:
Aldrin 0.04
Aluminum 7,065 - 47,075 \Lg/L
Arsenic 50 Hg/L
Beryllium 4 (ig/L
Cadmium 5 \Lg/L
Chromium 100 M-g/L
Cobalt 2,000 \ig/L
Iron 17,080 - 85,500 |lg/L
Manganese 1,359 - 12,100 |ig/L
Mercury 2 \ig/L
Nickel 100 H-g/L
Silver 100 \Lg/L
Sodium 10,678 - 144,000 \ig/L
Vanadium 200 [ig/L
Zinc 5,000 jxg/L
Chlorides 250 mg/L
Sulfates 250 mg/L
Deep ground water beneath the landfill should attain the
following levels:
Aluminum 29,373 - 36,920 ug/L
Arsenic 50 |o.g/L
Barium 2000 |ig/L
Beryllium 4 p.g/L
Cadmium 5 |ig/L
Chromium 100 \ig/L
Cobalt 2,000 |lg/L
Iron 42,605 - 62,275 Ug/L
Manganese 687 - 961 |ig/L
Nickel 100 n.g/L
Potassium 1.4E+06 Hg/L
Sodium 119,250 - 137,750 Hg/L
Vanadium 200 |ig/L
Zinc 5,000 (ig/L
Ammonia 34 |lg/L
Chlorides 250 mg/L
Sulfates 250 mg/L
The following cleanup levels for the landfill leachate should be
attained if the leachate contingencies mentioned in Section 9.2.2
of this ROD are implemented.
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Brantley Landfill Site
Record of Decision
Page 43
Short-term Leachate Collection System (one-time leachate
removal): It will be required, under this scenario, to
remove all of the water in the landfill (as much as
technically possible), or remove water in the landfill until
the leachate attains the same shallow ground water standards
specified in this ROD.
Long-term Leachate Collection System (ground water is
infiltrating the landfill): Under this scenario, ground
water within the landfill should attain the same shallow
ground water standards specified in this ROD.
9.4 Compliance Testing and Monitoring
A one-time monitoring of air emissions will be conducted using an
Open-path FTIR spectroscopy to confirm that ammonia emissions
from the landfill to the ambient air have been effectively
mitigated or eliminated by the new cap.
Quarterly monitoring will be performed on all piezometers and
monitoring wells including those installed in Phase I. Deep
monitoring well 08D shows ground water quality impacts believed
to be directly related to the contaminated ground water flow
along the floor of the underground mine. Therefore, any ground
water sample collected from this monitoring well will directly
show changes to ground water quality as the water levels in the
landfill decline once the cap is in place.
EPA will evaluate the monitoring performed prior to, during and
after installation of the new cap to determine if the short-term,
or long-term leachate contingencies are necessary to reduce
levels of contaminants to acceptable levels within a reasonable
time frame.
No later than five years from the date of commencement of
remedial construction, a five year review will be completed for
the Brantley Landfill Site since waste remains on-site. Five
year reviews regularly occur after the first five-year review at
intervals of no greater than five years. EPA will re-evaluate
the effectiveness of all the components of this response action,
such as source control and ground water restoration and may make
recommendations to improve its capabilities.
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Brantley Landfill Site
Record of Decision
Page 44
9.5 Site-specific ARARs
The remedy will comply with all applicable portions of the
following Federal and State regulations:
Chemical-specific ARARs:
Safe Drinking Water Act .Maximum Contaminant Levels (MCLs), 40 CFR
Part 141. MCLs have been set for toxic compounds as enforceable
standards for public drinking water systems. Applicable as
standards of protection for ground water that is a source of
drinking water.
Clean Air, Act National Emission Standards for Hazardous Air
Pollutants (NESHAPs), 40 CFR Part 61. Establishes emission
standards, monitoring, and testing requirements, and reporting
requirements for eight pollutants in air emissions. Applicable
since one or more of the listed pollutants may be released via
air emissions during site remediation.
Clean Water Act, Water Quality Criteria (WQC) , 40 CFR 403. The
Clean Water Act developed the WQC for the protection of human
health and aquatic life. These regulations are relevant and
appropriate for the quality of surface water discharges of
metals, ammonia, and chlorides to the unnamed tributary if a
short-term, or long-term, leachate system is installed at the
Site, and the treated effluent is discharged to the tributary.
401 KAR 63:021. Regulates existing (as of November 11, 1986)
sources emitting toxic (other than NESHAP) air pollutants,
including ammonia gas. Applicable to the emission of toxic air
pollutants; significant emission levels, and threshold ambient
concentration limits for ammonia gas.
Kentucky Water Quality Standards, 401 KAR 5:031. Water quality-
criteria for protection of aquatic life, including free ammonia,
chlorides, arsenic, and other metals. Applicable to discharge of
ammonia, chlorides and metals to surface water if a short-term or
long-term leachate collection system is installed at the Site.
Action-specific ARARs:
Clean Water Act Discharge Limitations NPDES Permit 40 CFR 122,
125, 129. 136 and Pretreatment Standards 40 CFR 403.5. Prohibits
unpermitted discharge of any pollutant or combination of
pollutants to waters of the U.S. from any point source, including
storm water runoff from industrial areas. Standards and
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Brantley Landfill site
Record of Decision
Page 45
limitations are established for these discharges and discharges
to POTW. Categorical pretreatment standards will be applicable
to the Site only if discharge to a POTW is necessary for the
disposal of pretreated ground water in the event that leachate
contingencies are implemented.
Clean Air Act New Source Performance Standards, Section 111; 40
CFR 60. Establishes standards of performance for new air
emission sources. Applicable to emissions during remedial
actions.
401 KAR Chapter 5. KPDES requirements and water quality
standards. Applicable to discharge of ground water flow from
landfill to surface water.
KRS 224.01-400. Specifies reporting and cleanup requirements for
releases or threatened releases of hazardous substances,
pollutants or contaminants. Applicable to pollutants or
contaminants that may be released during the implementation of
the remedy.
Other Criteria To-Be-Considered:
Secondary Drinking Water Standards (SMCLs), 40 CFR 143. SMCLs
are non-enforceable goals regulating the aesthetic quality of
drinking water.
EPA Drinking Water Health Advisories. Advisories based upon
current understanding of toxicology of contaminants. Applicable
as a standard of protection for ground water that is a source of
drinking water.
EPA Regulations on Ambient Air Monitoring, 40 CFR 53.22, 40 CFR
53.34. Test procedures for ammonia in air. Applicable to the
discharge of air contaminants from the landfill.
Covers for Uncontrolled Hazardous Waste Sites, EPA/540/2-85/002.
Provides guidance for cover design, gas and infiltration control,
cost estimation, and construction.
EPA Ground Water Protection Stratecrv. Protection and
classification of ground water regarding potential use as a
drinking water source.
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Brantley Landfill Site
Record of Decision
Page 46
10.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA must select remedies that are
protective to human health and the environment, comply with
applicable or relevant and appropriate requirements (unless a
statutory waiver is justified), are cost-effective, and utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
In addition, CERCLA includes a preference for remedies that
employ treatment that permanently and significantly reduce the
volume, toxicity or mobility of hazardous waste as their
principal element. The following sections discuss how this
remedy meets the statutory requirements.
10.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
preventing infiltration of surface water into the source
material. This prevents future offsite migration of landfill
leachate. Also, the implementation of institutional controls and
a monitoring program will ensure that the public is not affected
by Site-related contaminants in the future. The selected remedy
contains contingencies for leachate removal, treatment and
disposal should the monitoring reveal that the cap system is not
enough to lower the concentrations of contaminants in the
landfill in a reasonable time.
No short-term threats are associated with the selected remedy.
In addition, no adverse impacts are expected from the remedy.
10.2 Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will be in full compliance with all
applicable or relevant and appropriate requirements (ARARs)
outlined in Section 9.5 of this document.
10.3 Cost Effectiveness
The selected remedy, Alternative 4, was chosen because it
provides the best balance among criteria used to evaluate the
alternatives considered in the Detailed Analysis. The
alternative was found to achieve both adequate protection of
human health and the environment and to meet the statutory
requirements of Section 121 of CERCLA. The selected remedy was
found to be cost-effective when compared to other acceptable
alternatives. The net present worth value of Alternative 4
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Brantley Landfill Site
Record of Decision
Page 47
ranges from $1,500,000 to $7,000,000 depending on whether or not
the contingency measures are implemented.
10.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
EPA and the KNREPC have-determined that the selected remedy
represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective
matter. Of those alternatives that are protective of human
health and the environment and comply with ARARs, EPA and KNREPC
have determined that the selected remedy provides the best
balance of trade-offs in terms of long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability and
cost, while also considering the statutory preference from
treatment as a principal element and considering State and
community acceptance.
10.5 Preference for Treatment as a Principal Element
If treatment of the landfill leachate is found necessary, the
remedy provides for reducing contaminants in ground water
leachate through neutralization, reverse osmosis and evaporation.
The selected remedy will- also be evaluated at intervals of no
less than five years starting from the day of construction
commencement (during remedial design) and, if it is not meeting
the standards set forth in this Record of Decision, will be
upgraded to meet them.
11.0 SIGNIFICANT CHANGES TO ALTERNATIVE 4
This ROD divides Alternative 4 of the Feasibility Study (FS) into
two distinct phases in order to address surface water
infiltration and ground water infiltration separately. The FS
and Proposed Plan present this alternative with much less detail
than this ROD. Because some aspects of Alternative 4 discussed
in the FS were totally dependant on future sampling results a
phased approach to performing this alternative was chosen. Also,
because of concerns expressed by the Commonwealth of Kentucky
during the public comment period, EPA has included additional
sampling not specified in the FS or Proposed Plan.
The Commonwealth of Kentucky is very concerned about the lake
situated south of the site being a possible end point for
contaminants migrating through the underground mine works. For
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Brantley Landfill Site
Record of Decision
Page 48
this reason, the selected remedy will now include the sampling of
this lake to determine if it contains Site-related contaminants
at concentrations of concern.
Other concerns expressed by the Commonwealth of Kentucky include
EPA's selection of background concentrations as remediation goal
options (RGOs), and Site impacts on this wells. The
Responsiveness Summary to this ROD (See Appendix C) explains in
detail, how this background levels were determined and the reason
to include them as RGOs. In regards to Site impacts to these
wells, EPA believes that the RI data do not show any significant
impact from salt cake fines to the background monitoring wells.
However, additional sampling of the background wells will be
conducted during Phase I of this remedy to confirm the background
concentrations. In the event that the confirmatory sampling
significantly differ from the background levels specified in this
ROD, a ROD amendment will be issued to revise the background
RGOs.
The FS states that the ground water surrounding the Brantley
Landfill Site has not been officially classified. Therefore, EPA
has included the classification of the shallow and deep aquifers
as part of the selected remedy.
-------
APPENDIX A
LIST OF FIGURES
-------
Figure 1. site vicinity Map
LOUISVILLE
.LEXiNGTDN
r-BRANTLEY
1 LANDFILL
UNNAMED
TRIBUTARY TD
CYPRESS CREEK
SURFACE WATER
RAILROAD
tnviron.-.erital and Safety Des:;ns. Inc
BRANTLEY LANDFILL
SITE
FIGURE 1
SITE VICINITY
BRA'.'LEY L-NDFILL SITE
MC_£AN cc. KENTL::
-------
I
to
460-1
455-
WEST
K13
453.71' MINE WORK
K13S BORING
\\V/V/\VV vVxVAVvV- 'V A\A N..> VV/\\ \\x.'L-..^~—-
ZKX®^*KS*/^^^^^
0^x'>.V>-;> 0.6-1.4 ohm-m \s-^Vv^N \>- -~"- -"
^Vs<X''x' i ANDFILL ^'- -\\-'^ ••.'>X-<^-_.r •-_ .:
v\\vyv/'\x'-''\'-'' 'SAIT CAKF FIMFS) ''•.'•s-.'-'.-.s.-,- \v-\V -•'i •
a
to
O
h
O
O
n
w
(0
o
nm iwu
wonci
- JIKXXT SM*U
- IHW.I.OV ma t*mc
50
HOR. SCALE
50
•3
FEET
VERT. SCALE 1"»10'
VERT. EX. =5X
>50 ohm-m
LEGEND
HORIZONTAL LANDFILL BOUNDARY AS DEFINED
BY EM-31 & EM-34 SURVEYS
SLOPE OF LANDFILL WALL UNKNOWN
BOTTOM OF LANDFILL AS DEFINED BY TDEM
1.0
444.84'
VALUES IN OHM-METERS
GROUND WATER ELEVATION RECORDED
DURING 2nd QUARTERLY SAMPLING EVENT
i_ T."Zn RANGE OF EQUIVALENCE
fl (ERROR BAR AS DEFINED BY TDEM SURVEY)
H SCREENED INTERVALS
NOTE: TDEM = TIME DOMAIN ELECTROMAGNETIC SURVEY
-------
Figure 3. Source Characterization Sample Locations
BCDEFGH JKLUNOP
\
c
\
12
K
\
I
1 60
SCALE
HtHpou sw*a: t
1 60
FEET
114 -5fl.
n; -SURFACE
rt -SURFACE
JIA -SURFACE
«; -SURFACE AM) Bono*
J 0 -SURFACE AMO Bonou
OS -SURFACE
ji4 -BOTTOM
e/w Safrty Drtiyni. Inc.
8
F!C'J = £ 3
SCARCE
SAWPLL LOCATIONS
RANTLrr LiNOFlLL SITE!
-c o*iE.oj/ic/9* low
A-3
-------
Figure 4. Shallow Soil Sampling Locations
\ /
X
\l 'WO -. • LW^ILL LIMITS
*. \ \ >/ — • — - «CP€RTY IOUND*B
*" V'O" I r-:-CC
\
\/
\
- S-J.-LOV SOIL
- *:::TION*L SOIL SA^PLCS CM*BC" ;j;
^c-10 rcci TRO- rstciNw. LOC*T::--
(WTT SHOWN TO ;c*_E FOR>
OyS U^ 03/099*
A-4
-------
Figure 5. Surface Water and Sediment Sampling Locations
- - LANDFILL LIMITS
- - PROPERTY BOUNDARY
- VATER
*l - SURFACE WATER SAMPLE
nd (£*CH QUARTER IN CIRCLE FILLED)
(REPRESENTS QUAATER SAMPLED)
*' - SEOiUENT SAMPLE
nd (EACH QUARTER IN SQUARE FiLLEO)
(REPRESENTS QUARTER SAMPLED)
NOTE. SURFACE WATER AND SEDiuEwT
SAMPLES WERE COLLECTED
FROM SAME LOCATION
r i Kntcx «.
r I. NtLl. B.I
NC LOCATIONS
^JDWC NAL/C- BF>f<50f B^
A-5
-------
Figure 6. Ground Water Monitoring Well Locations
\
l(K 0 IOC
- UANDTILL LIMITS
— - - PROPERTY BOUNDARY
« - DEEP WELL
$• - SMALLO1-' vELL
NOTE QU*Btt=-.r CBOUNOW*TE« SAMPLES WERE
COLLECT; ruou EACH WELL fon Out T£A>>.
WIIH i-r c«cEPiiON OF us
A-6
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Figure 7. Formulae for Calculating Carcinogenic and
Non-carcinogenic Risk for Soil
The following formulae for computing soil risk (carcinogenic and non-carcinogenic) were excerpted from RAGS,
Volume I, Part A.'
RESIDENTIAL SCENARIO
SOIL INGESTION PATHWAY
Age-adjusted Ingestion Factor
fF~a*j (mg-yr/kg-day)
**"•
where:
Default Values
age-adjusted soil ingestion factor (mg-yr/kg-day) 114 mg-yr/kg-day
average body weight from ages 1-6 (kg) 15 kg
average body weight from ages 7-31 (kg) 70 kg
exposure duration during ages 1-6 (yr) 6 years
exposure duration during ages 7-31 (yr) 24 years
ingestion rate of soil age 1-6 (mg/day) 200 mg/day
ingestion rate of soil age 7-31 (mg/day) 100 mg/day
DERMAL CONTACT PATHWAY
Age-adjusted Contact Factor (CF,oaMi)
(mg-yr/kg-day) = SA.r.^ x AF x ED.r. , + SA.r,... x AF x ED.r,.,
BWMoM BW^.ji
where:
Default Values
age-adjusted contact factor (mg-yr-event/kg-day) 2600 mg-yr-«vent/kg-day
skin surface area available for contact (cmVevent) 3730 cmVevenf
skin surface area available for contact (cmVevent) 3500 cmVevenf
AF soil to skin adherence factor (mg/cm2) 1 mg/cm:
ED^.,^ exposure duration during age 1-6 (yr) 6 yr
exposure duration during age 7-3 1 (yr) 24 yr
A-7
-------
Figure 7. (continued)
Carcinogens
Riak=
Formulae for Cplr"lnring Carcinogenic and Non-carcinogenic Risk for
Soil
RISK (HAZARD INDEX) BASED ON COMBINED DAILY ABSORBED DOSE (INGESTION + DERMAL
CONTACT)
Non-Carcinogens
Hazard IndexB
EF» x ABS)/ATHC))/(RfDexADJ))
x EF, x ABS)/ATc))x(SF./ADJ)))
Default Values
Chemical-specific
350 days/year
10,950 days
25,550 days
0.01 (Organic Compounds)*
0.001 (Metals)
Chemical-specific
Chemical-specific
0.8 Volatiles*
0.5 Semi-volatiles*
0.2 Metals'
where:
C.
EFR
AT^c
ATC
ABS
RfD
SF0
ADJ
Chemical concentration in soil
Residential exposure frequency
Averaging time (non-carcinogen)
Averaging time (carcinogen)
Absorption factor (unitless)
Reference Dose (mg/kg/day)
Slope Factor (mg/kg/day)'1
Administered to Absorbed Adjustment Factor
Notes: .
'Reference: Risk Assessment Guidance for Superfund, Volume I-Human Health Evaluation Manual, Part A,
USEPA/OERR, EPA/540/1-89/002. December 1989 (RAGS, Volume I, Pan A), and Risk Assessment Guidance for
Superfund, Volume J-Human Health Evaluation Manual, Supplemental Guidance-Standard Default Exposure Factors-
Interim Final. USEPA/OERR, OSWER Directive: 9285.643. March 25, 1991.
"Absorbed doses for ingestion exposure are tssumod to be the equivalent of administered doses (100% oral
ingestion). Therefore, no conversion factor is incorporated into the associated formulae.
•Dermal pathway adjustment factors provided by Mr. Glenn Adams, USEPA Region IV Risk Assessment Section,
personal conversation, July 13, 1993.
'Skin surface area values used were provided by Ms. Sally Willey, Kentucky Department of Environmental
Protection, Risk Assessment Section during conversations held in Frankfort, Kentucky, June 1993.
A-8
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Figure 8. Formulae for Calculating Carcinogenic and
Non-carcinogenic Hazard for Surface water
The following formulae for computing surface water riak/hazard (carcinogenic and non-carcinogenic) were excerpted from
RAGS, Volume I. Put A.'
RECREATIONAL USE SCENARIO
CHRONIC DAILY INTAKE
SURFACE WATER (SW) INGESTION PATHWAY
Age-adjusted Ingestion Factor
(mg-yr/kg-
-------
Figure 9. Formulae for Calculating Carcinogenic and
Non-carcinogenic Risk for Sediment
The following formulae for computing sediment risk (carcinogenic and non-carcinogenic) were excerpted from
RAGS, Volume I, Part A/
RECREATIONAL SCENARIO
SEDIMENT INGESTION PATHWAY
Age-adjusted Ingestion Factor
&mtMj (mg-yr/kg-day) = E^
where:
Default Values
age-adjusted sediment ingestion factor (mg-yr/kg-day) 114 mg-yr/kg-day
average body weight from ages 1-6 (kg) 15 kg
average body weight from ages 7-31 (kg) 70 kg
exposure duration during ages 1-6 (yr) 6 years
exposure duration during ages 7-31 (yr) 24 years
ingestion rate of sediment age 1-6 (mg/day) 200 mg/day
ingestion rate of sediment age 7-31 (mg/day) 100 mg/day
DERMAL CONTACT PATHWAY
Age-adjusted Contact Factor
(mg-yr/kg-day) = SA.r.^ x AF x ED.r. . + SA.r,,, x AF x ED.r,,,
"V'tici* BW.^7.3|
where:
Default Values
age-adjusted contact factor (mg-yr-«vent/kg-day) 2600 mg-yr-event/kg-day
skin surface area available for contact (cmVevent) 3730 cmVevent^
skin surface area available for contact (cmVevent) 3500 cmVevenf
AF sediment to skin adherence factor (mg/cm2) 1 mg/cm2
exposure duration during age 1-6 (yr) 6 yr
exposure duration during age 7-3 1 (yr) 24 yr
A-10
-------
Figure 9. (continued)
Formulae for Calculating Carcinogenic and Non-carcinogenic Risk for Sediment
Brantley Landfill NFL Site
Island, Kentucky
RISK (HAZARD INDEX) BASED ON COMBINED DAILY ABSORBED DOSE (DIGESTION + DERMAL
CONTACT)
Non-Carcinogens
Hazard Index=
(C. x((IFwdAll8xl(r) + (((CF.^xlO-'kg/mg x EFR x ABSJ/AT^xCSF^ADJ))
where: Default Values
C. Chemical concentration in sediment Chemical-specific
EFR Recreational exposure frequency (lifetime weighted average) 112 days/year
ATNC Averaging time (non-carcinogen) 10,950 days
ATC Averaging time (carcinogen) 25,550 days
ABS Absorption factor (unitless) 0.01 (Organic Compounds)*
0.001 (Metals)
RfD Reference Dose (mg/kg/day) Chemical-specific
SF0 Slope Factor (mg/kg/day)'1 Chemical-specific
ADJ Administered to Absorbed Adjustment Factor 0.8 Volatiles'
0.5 Semi-volatiles
Notes:
•Reference: Risk Assessment Guidance for Superfund, Volume I-Human Health Evaluation Manual, Pan A,
USEPA/OERR, EPA/540/1-89/002. December 1989 (RAGS, Volume I, Pan A), and Risk Assessment Guidance for
Superfund, Volume 1-Human Health Evaluation Manual. Supplemental Guidance-Standard Default Exposure Factors-
Interim Final. USEPA/OERR. OSWER Directive: 9285.6-O3, March 25, 1991.
b Absorbed doses for ingestion exposure are assumed to be the equivalent of administered doses (100% oral
ingestion). Therefore, no conversion factor is incorporated into the associated formulae.
c Dermal pathway adjustment factors provided by Mr. Glenn Adams, USEPA Region IV Risk Assessment
Section, personal conversation, July 13, 1993.
* Skin surface area values used were provided by Ms. Sally Willey, Kentucky Department of Environmental
Protection, Risk Assessment Section during conversations held in Frankfort, Kentucky, June 1993.
A-ll
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Figure 10. Formulae for Calculating Carcinogenic Risk and
Non-carcinogenic Hazard for Ground Water
The following formulae for computing groundwater risk/hazard (carcinogenic and non-carcinogeaic) were excerpted from RAGS,
Volume I, Pan A.
Residential Scenario
Chronic Dairy Intake
Groundwater Ingestion Pathway
Age-adjusted Ingeotioo Factor
(mg-yr/kg-day)
BW.
BW,
where:
BW.
ED,
ED,
age-adjusted groundwater ingestion factor (Iher-yr/kg-day)
avenge body weight from ages 1-6 (kg)
avenge body weight from ages 7-31 (kg)
exposure duration during ages 1-6 (yr)
exposure duration during ages 7-31 (yr)
ingestion rate of groundwater age 1 -6 (mg/day)
ingestion rate of groundwater age 7-31 (mg/day)
Default Values
1.1 1-year/kg-day
15kg
70kg
6 years
24 years.
1 liter/day
2 liter/day
Risk (Hazard Index)
Non-Carcinogens
Hazard Index«=b
(Cowx((IFOWMxEFItyATHC) /RfD.
Carcinogens
Risk=
(Cowx((IF(IWMxEFllVATc) xSF.
where:
C.
EFR
ATNC
ATC
RID.
SF0
Notes:
Chemical concentration in groundwater
Residential exposure frequency
Averaging time (non-carcinogen)
Averaging time (carcinogen)
Reference Dose (mg/kg/day)
Slope Factor (mg/kg/day)"1
Default Values
Chemical-specific
350 days/year
10,950 days
25,550 days
Chemical-specific'
Chemical-specific
Reference: Risk Assessment Guidance for Superfund, Volume I-Human Health Evaluation Manual,
Pan A, USEPA/OERR, EPA/540/'1-891002, December 1989 (RAGS. Volume I, Part A), and Risk
Assessment Guidance for Superfund, Volume I-Human Health Evaluation Manual, Supplemental
Guidance-Standard Default Exposure Factors-Interim Final, USEPA/OERR, OSWER Directive:
9285.643, March 25, 1991. Absorbed doses for ingestion exposure are assumed to be
the equivalent of administered doses (100% oral ingestion). Therefore, no conversion factor is
incorporated into the associated formulae.
Ammonia hazard quotient computed by dividing groundwater concentration by 34 mg/L (RfD
equivalent concentration.
A-12
-------
APPENDIX B
LIST OF TABLES
-------
Table 1. Source Material Constituents
T«hU 1
, Souret M«tM»t Ccn*th*«rt* i;
By SnbMBplt Medium «f Dttocttea -
-
/* -.
pannttir
Volitilw
ToiUilie
Etnytbenzane
Xylcms
Benzene
Stmi-VflUtilM
Naphthalene
2-Mithybuphthslam
PhtiunthniM
Tiuiwthyipyndim
DinNthyfaiaphthal«m
M«t{iytiiisphthalana (M
Mobcutar SuKur
Trims thytaaphthalene
Mtthylcvfaazole
PMtieidMfPCBt
gamma-BHC
dttta-BHC
Endrin
4,4'-ODT
Aroclor-1242
Aroclor-1254
Mettli
All TAL M«tak
Othen
pH
Ammonia
Chloride
Sulfates
Sulfides
Diajel Range Organic!
lAppfictbl* Ssnrw Ktttriil SabtimpI* '>
h
A« D«e«1«t^
X
X
X
X
X
X
X
X
X
X
, X
X
X
X
X (-Sb,Cd,Ag)
X
X
X
X
- IMittr Iraqi
iUtetttQ
X
X
X
X
X
X
X
X
X
X(-
Sb,Be,Cd,Cr,Co,Mn,H
g,Ni,Ag,and Tl)
X
X
X
X
lUtldBil Sa1UJ«
X
X
X
X
X
X
. X
X
X
X
X (-Cd,H8,Ag,)
X
X
X
':•••••'&
OHG««
X
X
X
X
Not
Applicable
Not
Applicable
Not
Applicable
X
X
Nota:
An 'X' indicates that the listed compound or clement was identified in the source suiaimple "Source potential Contaminants
of Concern'
B-l
-------
Table 2. Surface Soil Contaminants of Concern
Table 2
Surface Sett Caatanuaants «f Concern
Aluminum
Arsenic
Chromium
Iron
Vanadium
Notes:
Compounds/parameters listed are those which accounted for 99 percent of the risk and/or
hazard computed in the screening risk analysis (Appendix L). Due to the highly disturbed
nature of soils, background was defined as any orfsrte soil sample (0-12 or 12-24 inch depth).
B-2
-------
Table 3. Surface Water contaminants of Concern
Table 3
Surface Water Contaminants of Concern
Parameter
Benzene
Oieldrin
Aluminum
Arsenic
Iron
Selenium
Sodium
. Thallium
. Cyanide
Ammonia
lastreara Surface
Water
X
X
Onsite Pond
X
X
X
X
X
X
X
X
Notes:
X indicates the surface water source type from which the contaminant exposure concentration
was derived.
B-3
-------
Table 4. Sediment Contaminants of Concern
Table 4
Sediment Contaminants *f Concern
faranatar
Tetrachlorobenzene
alpha-Chlordane
Heptachlor epoxide
Dieldrin
gamma-BHC
detta-BHC
beta-BHC
Aluminum
Barium
Manganese
Nickel
Vanadium
ftutraam Sadimttrt*
X
X
X
Qnaha fond
X
X
X
X
X
X
X
X
X
Notes:
X indicates the sediment source type from which the contaminant exposure concentration was derived.
B-4
-------
Table 5. Ground Water contaminants of Concern
TiW«: 5
firaondwitM CwUfflinMt* of Concern
*Wlow
Aqtiiw
(Coopesltt
O»u Jet)
Hiplichlor
ilpht-BHC
biti-BHC
gimmi-BHC
AUrin
Dieldrin
Hiplichlor
ipoiide
Aluminum
Arsinic
Beryllium
Cidmium
Chromium
Cobitt
Iron
Minginese
Mercury
Nickel
Silver
Sodium
Vanidium
Zinc
Chlorides
Sulfite
•
Shallow
.Background
ilphfBHC
Aldrin
Dieldrin
Aluminum
Antimony
Artmic
Birium
Beririum
Cidmium
Chromium
Cobitt .
Iron
Minginese
Nickel
Sodium
Vinidium
Sulfitu
OMpAquiftr
-
CMWH1MJG
OitUrin
Hiptichlor
ipoiide
Aluminum
Befyffium
Cidmium
Chromium
Cobilt
Iron
Minginese
Nickel
Sodium
Zinc
Ammonia
Chlorides
Sutfites
:
:
GMW/K7/DC
Biuini
Wuminum
Anuic
Birium
Chromium
Iron
Mingineu
Nickel
Sodium
Chlorides
CMWTUBftK
Aluminum
Arsinic
Chromium
Inn
Minginoe
Sodium
Chlorides
Sulfites
6MWW8/DC
Oiildrin
Akiminvm
Amnic
Birium
Btryium
Chromium
Iron
Minginese
Nickil
Poluitum
Sodium
Vinidium
Ammonii
. Chlorides
SuHiles
BKkground
W«ll*
6MW/H1UDC &
CMWfllO/DG
Binzini
Hiptichlor
Aluminum
Arsinic
Birium
Chromium
Inn
Minginese
Nickel
Sodium
Thiltium
Vinidium
Sulfites
Notes:
Shallow aquifer contiminints of concern wera derived from i hypotheticil 'worst-cise' shallow well. Individual shillow welt did not necessarily produce
simples with unacceptable concentrations of eich of these parameters.
B-5
-------
Table 6. Statistical Summary of Surface Soil
STATISTICAL SUMMARY OF SURFACE
BRANTLEV LANDFILL NPL SITE
ISLAND. KENTUCKY
TOT
OF
PARAMETER rv
2— M«tiy%wphtwJ«rw
rtMUllly^^
Pytw
Fkjormtwrw
Bno(a)mtv«c»w
Chn/Mn*
Bvuo(b/k)«jotantwTW
Ptwnol
O«TWtiy>rwpr>twl«rw
2-P-ButOJt»*ho«Y)«»wlol
1 -FtwnyMwmrw
Prapwiytxruodiail*
AWrh
Enbo«ull«n «u««»
Endrtikalarw •
(Mb-BHC
Endoulfanl
<.<'-DOO
<.<'-DOT
•Ipfw-Chlordarw
g«mm«-BHC
Endo«ufl«nll
gimmi-Cnkxdrw
AnxMor-1242
<.4'-ODE
HwplacMo «pojdd«
txU-BHC
OWdrh
Mctxuycftlor
Endrti
«*fw-BHC
Enditi XaVlyd*
H«>lachlor
SOIL (0-ir DEPTH) ORQANICS HITS
SAMPUH3 WHT« Hrg
3LLECTED «.«,,
;
s
0
2
0
0
2
1
3
0
i
2
7
3
2
4
|
0
a
2
2
1
0
3
0
0
3EROF AVEJ
ABOVE
WOUND
0
Q
0
0
0
0
0
2
1
Q
0
1
a
i
i
3
3
0
2
0
1
2
2
1
1
0
0
1
2
1
0
4
0
0
0
WOE OF
HTB u
et
114
too
HA
43
NA
NA
'SI
I2O
02
ra
no
KA
350
1.08
CM
0«
NA
0.1
oje
1.44
O.I
OJ7
0.1S
Ojt
NA
03>
0.06
0.44
021
NA
O.W
K*
NA
NA
MIS RANGE
N1UUM
4S
62
04
NA
39
NA
NA
49
120
76
75
110
NA
150
O.IS
0.14
029
NA
O.O9
015
0.17
0.17
Oil
O.IS
0.28
NA
0.13
O.OS
0.17
OJ7
NA
010
NA
NA
NA
»— ^MHM-
^^•^^^^•^^•^
UANMUU
1C
10(
210
NA
47
NA
NA
65
120
12
110
110
NA
350
2.0
12
0.71
NA
0.12
0.4S
T£
0.31
031
022
02S
NA
083
. O.OS
078
057
NA
. ' 1.8
NA
NA
NA
NOTES:
TOTAL NUMBER OF SAMPLES: Tha column glvo tw tobtf number of umpl«t eo(l«c<«d enrtt horn 0-19* d«pr>. xcludng •/! btckQrcund >ampta>.
TOTAL NUMBER OF MT8: Thf» column MIcalM tw number of n» (vduv > CROL) npocwd h Kitemn fo-ird«pH).
NUMBER OF HfrS ABOVC BACKGROUND: Tub column tidlcMM tw rumbv of Mb tl« «v« o>«««r dan 2 6m<« tw IWIQ4 bKkgiound conCBTtHlon
tiat occurred h tw •otwm (0-24" cfcpfi)
AVCRAOE OF HITS: Tn« nwan «*kj* of dl (0-1? ctapti) Ml. «ckjdhg bickgrond. r«po>1«d Hxing tw nvMl^ann hx ««ch parv
MINIMUM: Tn* mnlmum Nl f«portKl by tw Mxxrtory for Moh p«r*m«v.
MAXIMUM: Th* mnlmum h« nporud by tw UboraHxy kx «ch pt
T4A' hoVulM twt tw M«t(ttc4 lurtctian could nol b* cataultNd or
HITS. MINIMUM3. «nd MAXIMUMS ••nportad huoAtg.
Pwaa« not* tu< tw oompwtoon of tw b«ckgrotftd action wwf (BAL) to onifl* pwarrwt* conc«nv«xn» wa0 u*«d cnfy for r^
Th* BAL wai not u««d vKCOvWy to «MmHat« «ny organic compound lor tvt umpto trwdium « • COPc
B-6
-------
Table 6. (continued)
TABLE
STATISTICAL SUMMARY OF SURFACE SOIL (0-1 2" DEPTH) METALS HITS
BRANTUEY LANDFILL NPL SITE
ISLAND. KENTUCKY
TOTAL NUMBER TOTAL NUMBER. NUMBER OF AVERAGE OF RANGE
OF SAMPLES OFHfTS HfT3 ABOVE HITS MINIMUM MAXIMUM
PARAMETER COLLECTED
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALUUM
VANADIUM
ZINC
CYANIDE
CHLORIDES (MO/KG)
AMMONIA (MG/KG)
0
0
9
9
9
9
9
9
"9
9
9
9
9
9
9
9
9
9
9
9 '
9
9
9
9
9
9
BACKGROUND
9
0
e
9
9
0
e
9
9
9
9
9
9
9
0
8
7
1
0
3
0
9
9
2
9
2
2
0
2
0
0
0
2
3
1
2
2
2
2
0
0
I
3
1
0
0
0
1
2
2
2
2
23934.0
NA
13.3
NA
NA
NA
2238.0
28.7
9.6
50.2
31990.0
22.6
3101.9
NA
NA
23.4
1591.4
0.9
NA
NA
NA
31.9
64.9
0.7
77.0
18.0
6770
NA
1.6
NA
NA
NA
217
10
1.9
4
13200
7.7
. 455
NA
NA
5.6
903
NA
NA
NA
NA
13.8'
18.5
0.54
1.49
11.4
68400
NA
34.6
NA
NA
NA
7190
87.3
19.1
279
59500
46.6
8120
NA
NA
38.9
2960
NA
NA
NA
NA
53.3
227
0.83
. ' 339
24
NOTES:
TOTAL NUMBER OF SAMPLES: Thl» column grve* the total number of samples collected oosltt from 0-12' depth, excluding all background samples.
TOTAL NUMBER OF HfTS: Thl« column Indicate! the number of hits (value* > CRQL) reported In solemn (0-1 f depth).
NUMBER OF HITS ABOVE BACKGROUND: This column Indicate* the number of hits that were greater than 2 times the average background concentration
that occurred In the solemn (0-24* depth).
AVERAGE OF HITS: The mean vnlue of all (0-12* depth) hits, excluding background, reported during the Investigation for each parameter.
MINIMUM: The minimum hit reported by the laboratory for each parameter.
MAXIMUM: The maximum hit reported by the laboratory for each parameter.
•NA' Indicate* that the statistical function could not be calculated or was not applicable: no con«trt-j«nt wai reported above the background action level.
HITS. MINIMUMS. and MAXIWUMS are reported In mg/Vg.
B-7
-------
W
i
00
TABLE
STATISTICAL SUMMARY OF SURFACE WATER ORGANICS HITS
BRANTLEY LANDFILL NPL SITE
ISLAND, KENTUCKY
PARAMETER
Benzene
Chloroethane
4-chloro-3-methylpheno!
bela-BHC
delta- BHC
gamma-BHC
Heptachlor
Dleldrln
4.4'-DDD
4.4'-DDE
Endosulfan sulfate
Melhoxychlor
alpha-Chlordane
gamma-Chlordane
Heptachlor epoxlde
Endrln
Endosulfan 1
Endrln aldehyde
TOTAL NUMBER
OF SAMPLES
COLLECTED
15
15
15
15
15
15
15
15
15
16
15
15
15
15
15
15
15
15
TOTAL NUMBER
OF HITS
2
1
0
0
2
3
1
3
0
3
3
2
2
3
2
1
2
1
NUMBER OF
HITS ABOVE
BACKGROUND
2
1
0
0
0
3
1
3
0
3
3
2
2
3
2
1
1
1
AVERAGE OF
HITS
3
6
NA
NA
0.0006
0.0012
0.0013
0.0039
NA
0.0027
0.0059
0.017
0.0007
0.0041
0.0057
0.0067
0.0048
0.019
HITS
MINIMUM
3
NA
NA
NA
0.00023
0.00036
NA
0.00039
NA
0.00075
0.00054
0.0015
0.00019
0.0007
0.0035
NA
0.0043
x NA
RANGE
MAXIMUM
3
NA
NA
NA
0.00097
0.0016
NA
0.0076
NA
0.0055
0.014
0.032
0.002
0.0086
0.0078
NA
0.0053
NA
H
(D
NOTES: •»•
6 t
TOTAL NUMBER OF SAMPLES: This column gives tho total number of samples collected onslte (pond and unnamed tributary). excludlnDall background samples.
TOTAL NUMBER OF HITS: This column Indicates the number of hrts (values > CROL).
NUMBER OF HITS ABOVE BACKGROUND: This column Indicates the number of hits that were greater than 2 times the quarterly background concentration
AVERAGE OF HITS: The mean value of all hits, excluding background, reported during the Investigation for each parameter.
MINIMUM: The minimum hit reported by the laboratory for each parameter.
MAXIMUM: The maximum hit reported by the laboratory for each parameter.
*NA* Indicates that the statistical function could not be calculated or was not applicable.
HITS. MINIMUMS. and MAXIMUMS are reported In ug/l.
Please note that the comparison of the background action level (BAL) to onslte parameter concentrations was used only for reference.
The BAL was not used exclusively to eliminate any organic compound for this sample medium as a COPC.
-------
Table 7. (continued)
TABLE
STATISTICAL SUMMARY OF SURFACE WATER INORGANIC/WET CHEMISTRY RESULTS
BRANTLEY LANDFILL NPL SITE
ISLAND. KENTUCKY
PARAMETER
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
CYANIDE
CHLORIDES (MG/L)
AMMONIA (MG/L)
SULFATES (MG/L)
TOTAL NUMBER
OF SAMPLES
COLLECTED
15
15
15
15
15
15
15
15
15
15
15
15
15
15 '
15
15
15
15
15
15
15
15
15
15
15
15
15
TOTAL NUMBER
OF HITS
12
0
6
12
0
0
15
0
14
5
14
0
15
15
0
15
15
4
0
15
1
1
13
3
15
15
13
NUMBER OF
HITS ABOVE
BACKGROUND
6
0
3
4
0
0
0
0
0
5
4
0
0
0
0
0
5
4
0
1
1
1
0
3
4
7
0
AVERAGE OF HIT RANGE
HITS MINIMUM MAXIMUM
1536.8
NA
5.2
37.6
NA
NA
NA
NA
NA-
7.5
2076.9
NA
NA
NA
NA
NA
8420.7
6.4
NA
42447.0
3.1
5.1
NA
22.0
72.1
10.6
NA
160
NA
3.4
17.5
NA
NA
NA
NA
NA
5.6
64.3
NA
NA
NA
NA
NA
3760
3
NA
23200
3.1
5.1
NA'
10
0.1
0.1
KAV
3540
NA
6.4
94
NA
NA
NA
NA
NA
9.9
3060
NA
NA
NA
NA
NA
29500
13.1
NA
12COOO
3.1
5.1
NA
28.4
243.4
47.8
NA
NOTES:
TOTAL NUMBER OF SAMPLES: Thli column glveithe loUlnumbti of lamplei collected cmHe (pond and unnamed tributary), excbding «lt background templet
TOTAL NUMBER OF HITS: Thli cobmn Indicate, the number of hHi (valuet > CRQL).
NUMBER OF HITS ABOVE BACKGROUND: Thli column Indicate! th« number of hlti that were gr..l.r than i llm.i
the quarterly background concentration.
AVERAQE OF HITS: The mean value of all hrU. excluding background. reeported during the Investigation for each parameter.
MINIMUM: Tha minimum hit reported by the laboratory for each parameter.
MAXIMUM: Tha maitlmum hit reported by the laboratory for each parameter.
•NA* Indicates that the •tatlitlcal function could not ba calculated or wet not applicable.
HITS. MINIMUMS. and MAXIMUMS are reported In ug/1; Wat chtmlitry paramateri are reported In mg/1.
B-9
-------
Table 8. Statistical summary of Sediment
TABLE
STATISTICAL SUMMARY OF SEDIMENT ORQANICS HITS
BRANTLEY LANDFILL NPL SITE
ISLAND. KENTUCKY
•
PARAMETER
Naphthalene
2-Methylnaphthatene
Phenan throne
Pyrene
Fluoranthene
Tetrachtorobenzene
1-Methylnaphthalene
3imethylnaphthalene
Trimethylnaphthalene
4.4'-DDD
4.4'-DDE
AMrin
Ehdosutfan sulfate
alpha— Chlordane
-leptachlor epoxida
Endosulfan I
Dleldrin
Endrin ketone
Endrin aldehyde
gamma- BHC
delta -BHC
beta -BHC
alpha -BHC
gamma-Chlordane
4.4--DDT
vlethoxychlor
Endosulfan II
TOTAL NUMBER
OF SAMPLES
COLLECTED
8
e
8
e
e
8
e
e
8
8
8
8
8
8
e
e
e
8
8
8
8
8
8
8
8
8
8
TOTAL NUMBER
OF HITS
2
5
4
4
7
2
1
3
2
1
3
2
1
2
1
2
1
1
NUMBER OF
HITS ABOVE
BACKGROUND
1
1
1
2
1
1
1
1
1
1
5
0
1
2
2
1
3
2
1
3
2
1
0
0
1
1
1
AVERAGE OF HIT RANGE
HITS MINIMUM MAXIMUM
82
180
93
55
56
82
180
330
110
0.48
0.31
0.96
1.6
0.21
0.91
0.12
0.58
0.19
0.12
0.45
0.21
2.4
0.071
0.085
0.61
0.45
0.19
NA
NA
53
49.
NA
NA
NA
.- NA
' NA
0.12
0.1
0.68
0.099
0.11
0.62
NA
0.53
0.16
NA
0.063
. 0.19
NA
0.059
0.085
0.49
NA
NA
NA
NA
170
61
NA
NA
NA
NA
NA
0.84
0.55
1.4
3.1
0.48
1.2
NA
0.67
0.21
NA
0.9
0.23
NA
0.082
0.085
0.72
• NA
NA
NOTES:
TOTAL NUMBER OF SAMPLES: Thh column gb*» the total number of aamplei collected oniKi. including all background Mmpki.
TOTAL NUMBER OF HITS: Thlt column Indfcatee tha numbar of hlte (value* > CRQL).
NUMBER OF HITS ABOVE BACKGROUND: Thlt column bidfcatai tha numbai of htti that were gr.«l«r than Z tlmei lha avaraga background concentration
that wai reported for both pha»a«.
AVERAGE OF HITS: Tha maan value of aJl hRi. excluding background, reported during the Inveillgillon for each parameter.
. MNIMUM: The minimum hi reported by tha laboratory for each parameter.
MAXIMUM: The maximum hK reported by the laboratory tor each parameter.
TM' Indicate* that tha etatiaacal function could not ba calculated or wai not applicable.
HITS. MNIMUM3, and MAMMUMS are reported In ug/Vg
Plecea note that tha comparison of tha background action level (BAL) to ontHe ptremeter conctnlutlona wai uied only for refcrtnc*
The BA1 w«« nol ut«d e»rlii«tw«lw In •liml««t««*«*/rtin*r*t^*A«-».~..'"«i-. »i.i. ..— ~i. -.j .-««-
B-10
-------
Table 8. (continued)
TABLE
STATISTICAL SUMMARY OF SEDIMENT INORGANIC/WET CHEMISTRY HITS
BRANTLEY LANDFILL NFt SITE
ISLAND. KENTUCKY
TOTAL NUMBER
OFSAMF1ES
TOTAL NUMBER
OF HITS
PARAMETER COLLECTED
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY -
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
CYANIDE
CHLORIDES (MG/L
AMMONIA (MG/LL
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
e
e
8
0
6
8
5
0
8
6
7
8
8
8
8
8
0
7
3
0
0
8
0
8
. 8
0
8
4
NUMBER OF
HITS ABOVE
BACKGROUND
A
0
0
4
0
0
0
5
6
4
0
0
4
2
0
1
3
0
0
1
0
1
0
0
4
4
AVERAGE OF HITS RANGE
HITS MINIMUM MAXIMUM
10445.0
NA
NA
53.9
NA
NA
NA
16.3
7.2
15.1
NA
NA
1607.1
210.3
NA
21.5
1288.9
NA
NA
231.6
NA
22.1
NA
NA
5.2
1.8
4160
NA
NA
19.6
NA
NA
NA
11-
4.6
8.2
NA
NA '
478
132
NA
12.7
793
NA
NA
121
NA
11.7
NA
NA
3.7
0
16200
NA
NA
88.2
NA
NA
NA
21
10.8
22.9
NA
NA
2640
272
NA
33.2
1880
NA
NA
389
NA
28.1
NA
NA
6.51
6.79
NOTES:
TOTAL NUMBER OF SAMPLES: Thto column grvee the total numb«r of camples collected oniite. excluding all background sample*.
TOTAL NUMBER OF HITS: This column Indicates the number of hto (value* > CRQL).
NUMBER OF HITS ABOVE BACKGROUND: Thto column Indicates the number of hfo thai were greater than 2 time* the average background
concentration that were reported during the Mdlment collection.
AVERAGE OF HITS: The mean value of all hto, excluding background, reported during the Investigation for each parameter.
MINIMUM: The minimum htt reported by the laboratory for each parameter.
MAXIMUM: The maximum hit reported by the laboratory for each parameter.
•NA' Indicate* that the statfttlcal function could not be calculated or wa« not applicable.
HFTS. MINIMUMS. and MAXIMUMS are reported In mg/hg.
B-ll
-------
w
»-«
to
TABLE
STATISTICAL SUMMARY OF
ORGANICS HITS IN
SHALLOW AQUIFER
BRANTLEY LANDFILL NPL SITE
ISLAND. KENTUCKY
PARAMETER
1,1.1 -Trichtaroethane
2 - Methylnaphthalene
Naphthalene
Heptachlor
4,4'-DDE
alpha-BHC
beta-BHC
gamma-BHC
Aldrln
Dleldrin
Endosulfan 1
Endosulfan suKate
EndoauHan II
alpha-Chlordane
gamma -Chbrdano
Heptachlor Epoxlde
4,4' -ODD
Endrin
p.p'-Methoxychlor
Endrin Aldehyde
TOTAL NUMBER
OF SAMPLES
COLLECTED
16
16
16
16
16
16
16
16
16
16
16
16
16.
16
16
16
16
16
16
16
TOTAL NUMBER
OF HITS
2
2
1
2
2
4
2
1
2
2
3
2
2
3
2
5
1
1
1
1
NUMBER OF
HITS ABOVE
BACKGROUND
2
2
1
2
2
2
2
1
1
2
3
2
2
0
2
5
1
0
0
1
BACKGROUND
AVERAGE
NA
NA
0.32
NA
0.0007
0.0035
NA
0.0008
0.0023
0.002
NA
0.0004
NA
0.0012
NA
NA
NA
0.0032
0.0021
0.0006
AVERAGE OF
HITS
1.18
1.31
0.53
0.0056
0.0023
0.0018
0.0035
0.00456
0.0021
0.0025
0.0015
0.0009
0.001
0.0003
0.0013
0.0006
0.00037
0.00043
0.0009
0.00075
MAXIMUM 4 QTR
AVERAGE
1.75
2.25
0.63
0.0125
0.0032
0.0068
0.009
0.0054
0.005
0.0039
0.0036
0.0022
0.0018
0.0038
0.0031
0.0013
0.00044
0.0005
.0.001
0.00075
RANGE
MINIMUM
2
2
NA
0.0065
0.0038
0.0007
0.0034
NA
0.0032
0.0042
0.002
0.0014
0.0013
0.0003
0.0021
0.0005
NA
NA
NA
NA
MAXIMUM
3
5
NA
0.037
0.005
0.019
0.029
NA
0.008
0.0062
0.0057
0.0035
0.0045
0.0006
0.0049
0.0026
NA
NA
NA
NA
w
H
(I)
*O
•
W
(T
ft
H-
O
ft
H-
O
H
W
H
i
H
N
o
Hi
W
ff
f»
H
O
*
Jt»
$
NOTES:
' TOTAL NUMBER OF SAMPLES: Thl* column give* the total number of samples collected onstte from • hollow MW*. excluding all background sample*.
TOTAL NUMBER OF HITS: Thl* column Indicate* the number of htt» (value* > CRQL) reported In mavlx.
NUMBER OF HITS ABOVE BACKGROUND: Thl* column Indicate* the number of hit* that were greater than 2 Hme* the average background concenvatlon.
BACKGROUND AVERAGE: shows the mean value calculated for each constituent from GWM/ltOOand GWM/H130. Half of the CRQL or lowest hit was used for all V qualified values.
MAXIMUM 4 OTR AVERAGE: This column shows the maximum average calculated at an onsrte monitoring well during the quarterly tamping
AVERAGE OF HITS: The mean value of all hits, excluding background, reported during the Investigation for each parameter.
MINIMUM: The minimum hit reported by the laboratory for each parameter.
MAXIMUM: The maximum hit reported by the hboratory for each parameter.
•NA' Indicate* that the statistical function could not be calculated or was not applicable.
HITS. MINMUM3. ar>d MAXIMUM3 eie reported In ug/1.
Plsase not* that to comparison of to background action Isvel (BAL) to onslt* paramtlsr coocsfi»arJon* wat used only for reference.
The BAL was not used exclusively to eliminate any organic compound for this sample medium as • COPC.
H-
Ml
-------
w
I
TABLE
STATISTICAL SUMMARY OF INORGANIC/WET CHEMISTRY IN THE SHALLOW AQUIFER
BRANTLEY LANDFILL NPL SITE
ISLAND, KENTUCKY
TOTAL NUMBER TOTAL NUMBER NUMBER OF BACKGROUND AVERAGE OF MAXIMUM 4 QTR
OF SAMPLES OF HITS HITS ABOVE AVERAGE HITS AVERAGE
PARAMETER COLLECTED
Alt/Ml MUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
CYANIDE
CHLORIDES (mg/1)
AMMONIA (mg/l)
SULFATES (mq/l)
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
7
15
15
15
RANGE
MINIMUM MAXIMUM
BACKGROUND
15
0
11
13
5
7
14
. 13
15
12
15
15
15
4
15
15
4
15
0
8
15
0
15
12
15
0
0
0
0
3
3
0
4
10
1
1
10
10
4
12
0
4
0
0
0
7
0
14
5
10
32800
40.7
15.8
120
1.8
5.2
260000
66.8
116
49.6
51315
200000
12100
0.18
206
18800
2.7
144000
NA
41.9
297
NA
13.9
0.8
1540
17580.7
NA
6.1
52.4
2.4
6.2
281285.8
101.4
404.3
27.9
21743.3
407257.1
66424.0
0.4
503.7
6108.6
6.2
109993.3
NA
13.1
626.0
NA
219.5
0.9
2213.0
38400
NA
9.2
70.7
7.8
13.2
365000
252.2
857.7
87.2
54925
735000
177500
1.1
1006.5
10750
15.1
136250
NA
24.8
1333
NA
277.
2.4
1 5070
3710.0
NA
1.5
1.0
0.5
1.5
1.5
4.0
22.2
2.0
3250.0
68900.0
3280.0
0.1
72.9
1800.0
2.0
77900.0
NA
2.0
82.1
NA
8.2
• 0.0
221.0
59000.0
NA
17.3
102.0
13.3
21.7
426000.0
456.0
1090.0
142.0
129000.0
935000.0
271000.0
3.1
1130.0
14700.0
25.4
'151000.0
NA
56.2
1540.0
NA
379.0
2.9
7580.0
NOTES:
TOTAL NUMBER OF SAMPLES: This column gives the total number of sample* collected onsHe from shallow MWs. Deluding all background samples.
TOTAL NUMBER OF HITS: Thli column Indicate* the number of hits (value* > CROL) reported In matrix.
NUMBER OF HFTS ABOVE BACKGROUND: Thl* column Indicate* the number of hits that were greater than 2 time* the average background concentration.
BACKGROUND AVERAGE: show* the mean value calculated for each constituent fromGWM/IIOD and GWM/HI3D. Half of the CRQL or lowest hit was used for all V qualified value*.
MAXIMUM 4 QTR AVERAGE: TN* column (hows the maximum average calculated at an onslte monitoring well during the quarterly groundwater tampllng event.
AVERAGE OF HITS: The mean value of ad hits, excluding background, reported during the Investigation for each parameter.
MINIMUM: The minimum hit reported by the laboratory for each parameter.
MAXIMUM: The maximum hrt reported by the laboratory for each parameter.
•NA' Indicates that the statistical function could not be calculated or was not applicable.
HfT8, MNMUM3, and MAXIMUM9 are reported In ug/1 unless noted.
(D
vo
o
O
(D
P.
-------
TABLE
STATISTICAL SUMMARY OF OROAMCS HITS IN DEEP AQUIFER
BRANTLEY LANDFILL NPL SITE
ISLAND. KENTUCKY
TOTAL NUMBER TOTAL NUMBER NUMBER OF
OF 8AMPUES OF HIT! HITS ABOVE
PARAMETER COLLECTED BACKGROUND
Btnnn*
}-M»nrin*pnri«i»n«
Nipnfitkm*
Phenol
FluOIVM
M'-OOE
•lph*-BHC
o.mm*-8HC
OMtfto
4ph*-ChlordBn«
H«cboMor
H*pt»cNoi Epoido*
Enooiulhnl
Enobtufen SulUkj
4.4--DOO
«.«'-OOT
EnAIn
EndilnkAlon*
p.p--M.r»«Tehlor 10
0
4
4
I
1
3
1
t
t
1
0
t
0
0
1
1
1
t
• • 1
BACKGROUND
AVERAGE
(GMW/HmilO/OO)
2.3
NA
NA
NA
NA
0.00045
0.00038
0.0015
NA
O.OO0376
0.2S
NA
000051
000157
NA
NA
NA
NA
NA
.
MAXIMUM 4 OTH
AVERAGE
(OMW/IH/DG)
NA
NA
NA
NA
NA
0.0034
NA
NA
NA
00011
NA
NA
NA
NA
NA
NA
NA
NA
NA
MAXIMUM 4 OTR
AVERAGE
(QMVWKr/Oa)
O.U
NA
NA
NA
NA
0.0007
NA
0.0038
NA
NA
NA
NA
NA
NA
NA
0,00 II
NA
NA
NA
MAXIMUM 4 OTR
AVERAGE
(OUWXM/OG)
NA
313
1
1.35
NA
NA
NA
. ' NA
O.OOO3
NA
NA
NA
NA
NA
NA
NA
NA
0.0008
NA
MAXIMUM 4 OTH
AVERAGE
(OMW/M1IVDO)
NA
18
15
O.U
O.U
0.0078
0.0008
NA
0.001 1
NA
NA
0.0008
NA
NA
0.0003
NA
0.0003
NA
000075
MAXIMUM 4 OTR
AVERAGE
(TOTAL WEIU)
OU
18
II
1.3S
O.U
0.0078
0.0008
00031
DOOM
OOOll
NA
0.0006
NA
•NA
0.0003
0.0011
0.0003
0.0008
000075
RANOE
MNIMUM MAXIMUM
NA
1
1
1
NA
00011
0.0003
NA
00001
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
U
«
3
NA
00045
00037
NA
0.0073
NA
NA
NA
NA
NA
NA
HA
NA
NA
NA
w
M
NOTE!:
TOTAL NUMBER OF SAMPLES: Thto column g*v*« tw total numbw of MmplM eollMtod onill* (torn thtllow MW«. txoludlng ill background
TOTAL NUM1ER OF HITS' Thh column InolcalM »!• numbw of hlft (v*luM > OROL) r*pOf ted In fncklc.
NUKEn Of HITB ABOVE BACKGROUND: Thl* column IndVMtM *>• numbM ol hlk thai •*••• QTMIM Vian 2 *m*« ft* •v*r»Q» bAOkoround ooncw*a«on.
eACKOnOUNOAVERAOE: ihow. •.. m»«n >•!»• wloulatod hx «Mh oon«llu««l hem QWM/1IOO km«4l Ml wn u»dlot if V qualHtod MluM
UAJIIMUM 4 QTR AVERAQE: Thto column thowt •>• majOmum *v«(«0* oaJouhlid •! Anonilto monitoring w«H duflng VM quwtotV grounoWttor ••mpdng «v«nl. PtMM«noto tMton«-h»]f V* IOWM!
ImH of on*- It** t>« low**! CntX «*M u**d tn tilt o«lou)tton lot AN V OAJ*IVI«d voluM.
AVERAGE OF HITi: Th« m«n >«lu« ol »H hlfc. •tcluolng bMkground. l«por»d dutlng fw InvMllgtOon l« ««oh pwwiulw.
MINIMUM: Th* minimum nil t«pof tod by tw UboiBtofy Iof*«)np«f«m«l*r.
MAXIMUM: Th« mulmum hit t»po>l>d bf »>• Uboilonr lot »K^ pxutnlM.
•NA* InoloalM tMt tM lUltfc*! lunclon oould not b« otlouUted or wu nol •ppllottbl*.
HI!t M1NIMUMS. *nd MAX1UUU8 «• i«po>tod In ug/l.
Pliin nol* ti«t •*• oompwtaon ol VM background •cton l«v*l (BAL) to onclfci p*r»m«l«r oono«nti«Von* w** u*»d only lor r«l»f*no».
Th« BAL wtm not u*«d »Bclu«fv»V ka cUmln*!* mnf oiganlo compound fof ttkt ••mpkt maolum •• • COPC.
H-
Ml
(0
n
-------
Table 10. (continued)
ABLE
:TATISTICAL SUMMARY OF INORGANIC/WET CHEMISTRYIN THE DEEP AQUIFER
RANTLEY LANDFILL NPL SITE
'.LAND, KENTUCKY
TOTAL NUMBER TOTAL NUMBER NUMBEROF BACKGROUND . MAXIMUM 4 QTR MAXIMUM 4 OTR MAXIMUM 4 QTR: MAXIMUM 4 OTf) MAXIMUM 4 OTR
CF8AMPLES OF HlT3 HlTSABOVE ...; AVERAGE •;.' •>:'.-AVErMOe '.. AVERAGE AVER**; : AVERAGE . AVERAOE ; : :
ARAMETER COLLECTED
LUMINUM
•/TIMONY
tSENIC
\RIUM
iRYLUUM
VOM1UM
\LCIUM
flOMIUM
38ALT
)PPER
ON
VQNE3IUM
\NOANESE
'OCIHY
:KEL
TASSIUM
LENIUM
.VER
OIUM
ALLIUM
•JAOIUM
1C
ANIDE
UORIDES (mg/1)
MONIA (mg/1)
.FATES (mfl/T)
10
18
10
18
10
16
16
18
to
10
10
16
10
10
10
10
10
10
10
16
10
18
8
18
18
16
BACKGROUND ! (GMV
10
0
7
15
2
2
16
14
8
11
10
16
16
3
13
16
0
1
10
0
0
11
0
18
18
16
0
0
4
4
1
2
16
8
3
3
3
14
10
3
7
0
0
1
10
0
0
3
0
16
to
14
. RANGE
MINIMUM
MAXIMUM
«Hi34-iio£a) (GMWAie/baV .: . (GMW/KT/CC) (GMW/os/Ca) .,.i. .:.:., (GMW^uerooi. frOtALVvELLs) .. . .;
34005.5
NA
3.0
2188
NA
NA
55257
62.S
27.0
40.7
56160
30042.0
668
0.15
60.0
11028,5
1.1
NA
1310OO
1.2
44.5
168
NA
28.5
0.55
02.1
14412.5
NA
33
103.4
NA
NA
724500
43.7
4.0
30.2
10215
277000
1000.5'
NA
24.5
17400
NA
NA
373750
NA
2.7
33.4
NA
1270.8
2.2
1382.5
22782.5
NA
6.8
468.8
NA
NA
917500
331.6
12.1
10.1
40050
252250
2002.5
0.14
72.8
14547.5
NA
NA
1 1 18750
NA
6.7
76.4
NA
3200
2.4
103
27045
NA
0
468
0.46
NA
1266750
318.0
21
65.4
36017.5
81175
761.5
0.14
143.4
275250
NA
NA
4427500
NA
30.6
140.0
NA
0625
124.4
507
ease
NA
NA
58.8
0.81
6.4
848750
25.2
620.1
10.4
02400
638500
78725
0.6
7183
38825
NA
3.4
•0939500
NA
3.0
1230.6
NA
8680
220.1
5033
27045
NA
0
468
0.81
6.4
1205750
332
820
85.4
02400
838500
78725
0.8
718
275250
NA
3.4
4427500
NA
30.8
1230.6
NA
0625
220.1
5033
43SO.O
NA
1,5
1.0
0.5
1.5
383000,0
3.0
4.0
2.0
6050.0
3100,0
120.0
0.1
5.5
0600.0
NA
2.0
308000.0
NA
2.0
2.0
NA
713.0
1.8
121.0
55100,0
NA
JOO
1030.0
5.0
13.5
2290000.0
662.0
057.0
173.0
133000.0
876000.0
102000.0
2.1
1047.0
352000.0
NA
10.0
5870000.0
NA
75.1
2010.0
NA
12800.0
3880
7070.0
ES:
OTAL NUMBER OF SAMPLES: This column gives the total number of samples collected onsite from shallow MWs. excluding all background samples.
OTAL NUMBER OF HITS: This column Indicates lh» number of hits (values > CRQL) reported h matrix.
.'UMBER OF HITS ABOVE BACKGROUND: This column Indicates the number of hits that wore greater than 2 times tie average background concentration.
VCKGROUND AVER/WE: show* In* mean value calculated for each constituent from OWM/1100 end GWM/HT3D. Half of (he CflCt or lowest hit was used for all IT qualified valuea.
AXIMUM 4 OTR AVERAGE: This colurm shows the maximum average calculated at en onslte monitoring well during the qjarterty groundwaler samplhg event. Please note that one-half the lowest detection
limit or one-hen til lowest CRDL was used In this celculatlon for all IT qualified values.
INIMUM: The mhlmum hit reported by Ihe laboratory for each parameter.
AXIMUM. The maximum hit reported by the laboratory for each parameter.
IA' Indicates tfiat lh« statistical function could not be calculated or was not applicable.
TS. MINIMUMS. md MAXIMUMS are reported ti upj/l unless noted.
B-15
-------
Table 11. EPA Weiffht-of-Evidence Classification
System for Carcinogenicity
GROUP
A
Bl or B2
C
D
E
DESCRIPTION
Human carcinogen
Probable human carcinogen
Bl indicates that limited data are available.
B2 indicates sufficient evidence in animals and
inadequate or no evidence in humans.
Possible humans carcinogen
Not classifiable as to human carcinogenicity
Evidence of human noncarcinogenicity for humans
B-16
-------
H
(I)
W
I
TOXICOLOGICAL DATABASE INFORMATION
FOR POTENTIAL CONTAMINANTS OF CONCERN
BRANTLEY LANDFILL NPL SITE
ISLAND. KENTUCKY
PARAMETER
VOLATILE3
Benzene
Chloroelhane
Ethylbanzena
Toluene
1.1.1-TrlchloroBthnne
Xylena
3EMI-VOLATILE3
Benzo(b)fluoranthena
Banzo(k)fluoranthene
Dlmathylnaphthalane
Fluoranthene
Fluorene
Methylcarba/ola
1 -Methylnaphthalene
2-Methylnaphthnl«na
Molecular Sulfur
Naphthalene
Phenanthrena
Phenol
Pyrene
Tetrachlorobenzane
Trlmethylnaphthalene
trlmathylpyrldlne
SLOPE
FACTOR
ORAL
(MQ/KQ/DAY)-1
2.9E-02 1
ND
ND
ND
ND
''. ND
7.3E+00 3
7.3E+00 3
ND
ND
ND
2.0E-02 17
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
TOXICITY REFERENCE
EQUIVALENCY DOSE
FACTOR ORAL
(UNITLESS) (MQ/KQ/DAY)
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
1.0E-01
1.0E-01
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.1
0.2
0.09
2
ND
ND
ND
0.04
O.04
ND
0.04
0.04
ND
0.04
0.03
0.8
0.03
0.0003
ND
0.001
1
1
2
1
1
1
0
9
2
11
1
1
1
14
UF
ND
ND
1000
1000
ND
100
ND
ND
ND
3000
3000
ND
ND
ND
ND
1000
ND
100
3000
ND
ND
ND
MF
ND
ND
1
1
ND
1
ND
ND
ND
1
1
ND
ND
ND
ND
1
ND
1
1
ND
ND
ND
CANCER BUPERFUNO
CLASS RAL
(ug/L).
A
ND
D
D
D
D
B2
B2
ND
D
D
ND
ND
ND
ND
D
ND
D
D
ND
ND
ND
100
ND
1000
3000
1000
40000
0.2
0.2
ND
ND
1400
ND
ND
ND
ND
100'
Ni> '••
eooo
1100
ND
ND
ND
ARAR OTHER
(MCL) (••« not**)
(mg/L) (mg/L)
0.005
ND
0.7
1
0.2
10
0.0002
0.0002
ND
ND
ND
ND
ND
ND
ND.
ND
ND
ND
ND
ND
ND
ND-
0.2
ND
. 0.7
1
0.02
10
ND
ND
ND
ND
1.4
ND
ND
ND
ND
0.02
ND
4
ND
ND
ND
ND
8
4
4
5
4
7
5
5
-------
HI
H
w
H
00
TOXICOLOGICAL DATABASE INFORMATION
FOR POTENTIAL CONTAMINANTS OF CONCERN
BRANTLEY LANDFILL NPL SITE
ISLAND. KENTUCKY
PARAMETER
PESTICIDES
4.4--DDD
4.4'-DDE
4,4'.DDT
Aldrln
Aroclor-1242
Aroclor-1254
Dleldrln
Endoiullan 1
EndoBullan II
Endoiulfan eulfata
Endrln
Endrln oldehydo
Endrln keytone
Heptachlor
Haptachlor epoxlda
Mathoxyehlor
alpha-Chlordana
bata-BHC
delts-BHC
gamma-BHC (Llndana)
oamma-Chlordana
SLOPE
FACTOR
ORAL .
(MO/KQ/DAY)-1
2.4E-01
3.4E-01
3.4E-01
1.7E+01
7.7E+00
7.7E+00
1.6E+01
NO
NO
ND
ND
ND
ND
4.3E + 00
9.1E+00
ND
.3E4-00
.8E+00
.3E+00
.3E+00
.3E+00
TOXICITY REFERENCE
EQUIVALENCY DOSE
FACTOR ORAL
(UNITLES8) (MQ/KQ/DAY)
1
1
1
1
1
1
1
1
1
1
1
IB
2
1
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
0.0005
0.0005
O.OOOS
3E-05
ND
ND
5E-05
5E-05
3E-03
5E-05
0.0003
0.0003
0.0003
3E-O5
1.3E-05
0.005
6E-03
0.0003
0.0003
0.0003
6E-05
19
19
1
1
1
2
2
15
1
10
IS
1
1
1
1
ie
18
1
1
UF
ND
ND
100
1000
ND
ND
100
CANCER 8UPERFUND
MF CLASS RAL
(UQ/L)
ND
ND
1
1
ND
ND
1
B2
B2
B2
B2
B2
B2
B2
not Hated In HEAST
3000
ND
100
ND
ND
1000
1000
1000
ND
ND
1000
1000
1
ND
1
ND
ND
1
1
1
ND
ND
1
1
ND
ND
D
ND
ND
B2
D
B2
C
D
B2
B2
ND
ND
ND
0.2
0.5
0.5
0.2
ND
ND
ND
3
ND
ND
0.4
SO
n
NO
ND
2
2
ARAR OTHER
(MCL) (••« notM)
(mg/L) (mg/L)
ND
ND
ND
ND
0.0005
0.0005
ND
ND
ND
ND
0.002
ND
ND
0.0002
0.04
0.002
ND
ND
0.0002
0.002
ND
ND
ND
0.0003
0.0005
0.0005
0.0005
ND
ND
ND
0.002
ND
ND
0.0001
0.04
0.002
ND
ND
0.0002
0.002
6
4
4
6
4
5
4
.7
5
7
H
to
n
8
-------
w
I
TOXICOLOGICAL DAT
FOR POTENTIAL CONT
BRANTLEY LANDFILL N
ISLAND, KENTUCKY
PARAMETER
INORGANICS/WET CHEMISTRY
Aluminum
Ammonia
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chlorides
Chromium
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
ManQnnese (food)
Manganese (water)
Mercury
Nickel
Potatilum
Selenium
Silver
Sodium
Sulfntoj
Sullldes
Thallium (as sulfate/chlorlde lalt)
Vanadium
Zinc
pH
ABASE INFORMATION
AMINANTS OF CONCEF
PL SITE
SLOPE
FACTOR
ORAL
(MQ/KQ/DAY)-1
ND
NO
ND
1.75 1
ND
4.3E+00 1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
. ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NOT APPLICABLE
N
•
TOXICITY
EQUIVALENCY
FACTOR
(UNITLESS)
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
REFERENCE
DOSE
ORAL
(MG/KQ/DAY)
2.0
1
0.0004
0.0003
0.07
0.005
0.0005
ND
ND
1
0.08
ND
0.02
0:3
ND
ND
0.14
0.005
0.0003
0.02
50
0.005
0.005
34
ND
ND
8E-05
7-43 0.007
0.3
NOT APPLICABLE
12
20
1
13
1
13
1
1
2
1
13
2
1
13
1
2
1
UF
ND
ND
1000
3
3
100
10
ND
ND
100
ND
ND
100
ND
ND
ND
1
1
1000
300
ND
3
3
ND
ND
ND
3000
100
3
-
MF
ND
ND
ND
ND
10
ND
ND
5
ND
ND
ND
1
1
1
1
ND
1
1
ND
ND
ND
1
1
1
-
CANCER
CLASS
ND
D
D
A
D
B2
B1
ND
ND
D
ND
D
D
ND
B2
ND
ND
ND
D
D
ND
ND
ND
ND
ND
ND
D
D
D
-
8UPERFUND
RAL
-------
TOXICOLOGICAL DATABASE INFORMATION
FOR POTENTIAL CONTAMINANTS OF CONCERN
BRANTLEY LANDFILL NPL SITE
ISLAND, KENTUCKY
SLOPE
FACTOR
ORAL
PARAMETER (MQ/KQ/DAY)-1
TOXICITY
EQUIVALENCY
FACTOR
(UNITLE8S)
REFERENCE
DOSE CANCER SUPERFUND ARAR OTHER
ORAL UF MF CLASS RAL (MCL) (s*«not**)
(MQ/KQ/DAY) (ug/L) (mg/L) (mg/L)
H
9
!2. (continued
w
I
to
o
NOTES:
1 - IRIS (Integrated Risk Information System) search date 8-10/93.
- 2 - HEAST (Health Effects Summary Table*) 92/93 version.
3 - Toxlcrty Equivalency Factor established In Interim USEPA, Region IV guidance 2/11192; concentration multiplied by TEF to adjust concentration
and resulting cancer risk relative to Benzo(a)pyrene.
4 • MCL (or Treatment Technology (TT) based MCL)
- 5 • Lifetime Health Advisory for 70 Kg adult
- 8 - 10 day Health Advisory for 10 KG child
- 7 - DWEL
• 8 • SMCL (aesthetic based)
9 • RID for naphthalene used as surrogate RtO, te« #10.
• to- Surrogate RID's suggested by Kevin Koporec. USEPA Office of Health Assessment, phone conversation 2/2/94.
- 11 - RfD (or pyrene used as surrogate RfD for non-methylated PAHs, see #10
- 12 - Screening RID provided In USEPA Region III Screening Table, see #1O.
• 13 -Provisional RfD, see #10.
- 14 -RfD for pyrldlne used as surrogate RfD for trlmethylpyrldlne, see #10.
- 13 - RID for Endoiutfan used as surrogate RfD, see #10.
- 18 - RfD for Endrln used as surrogate RfD, sea #10.
- 17 • SFo for Carbazole used as surrogate SFo, see #10.
• 18- gamma-BHC risk values used as surrogate* for delta-BHC risk values per 2/4/94 phone conversation with Jim Holder, USEPA Point of Contact for delta-BHC.
• 19 - RfD for 4,4'.DDT applied to 4,4'-DDD & 4,4'-DDE; application considered appropriate due to structural similarity,
- 20 - The Inhalation RfC for airborne Ammonia Is 0.1 mg/cublc meter (IRIS); HEAST provide* a drinking water equivalent concentration of 34 mfl/l; this value was used
to calculate an equivalent RtD-ornl of 1.0 mg/kg-day.
ND - No data available
PCB. PCB-Aroclor. and Aroclor refer to Polychlorlnated Blphenyls.
RAL denotes the Removal Action Level as published In 'Numeric Removal Action Levels for Contaminated Drinking Water Sites' USEPA/OSWER-ERD, November 1992.
-------
•fllE RISK CHARACTERIZATION SUMMARY
-------
Table 14. Assumptions for ingestion and Dermal Contact Exposure
to Soil Contaminants of Concern
* *' '' ','*'-'' \ . '-','' T«M«, ;,'-'/''
-;• :ait«t«npti4B» fa/Wtftiea aid fiontl '&atftt's2*«ftm te ial'.CoitiailMBt* «f Coactrn ..
">f?"X"'. ^ '-\%«t1«M'8r««iyU«d^;Wl.;S^^«d,'^(«rt»4j> -, ' ,
_ fff f< f - .^ , * t. *
-v/x*-' -;£<"/ "*„'"•>
< '><*>/" ^~tl' -., ,v
:t*trm t&ttf'Kfilfaft '•'•
',^-ftrtwAMt ,
V'"',V'*«*a«'t '-' *
' ' " " ' V '^ ' f f .' ' ' J. v
>OJIAL' , % v/ ; '-';- ;, ' , ' -':
Daily tofl ingtrtion kvtl
Frtetion of tkm on-nt* in eontminatid
mas
Portion of ingastid contaminant absorbed
Days pir yaar on-th«
Ytars on-stti
Body wi ioht
Ufitime
200 mo
100%'
100%
3SO days
6 y«ars
IS kg
100 mg
100V
100%
350 days
24 years
70kg
Aviraging time based on 30 yiari for non-
carcinogens, and 70 years for carcinogens (see Soil
Exposure Formulae Key)
DERMAL
Skin ana contaminated
Soil adherence per cm1 of skin •
Portion of contaminant absorbed
Days per year on- site
Yeart on-lite
Body weight
Lifetime
3730 cm1
1 RIB
0.01 (Organic!) *
0.001 (Mitals)
350 days
6 years
IS kg
3500 em2
1 mg
0.01 (Orgmict) '
0.001 (Metald
350 days
24 years
70 kg
Averaging time based on 30 years for non-
carcinogens. and 70 ytart for carcinogens lue Soil
Exposure Formulae Key)
Notts:
References values from USEPA. RAGS. 12/89, OSWER Directive #9285.6-03, and US EPA. Region IV New \rntm Guidance IZ'11/92).
Uniform contaminant distribution over the entire Site area is assuned. No fraction of'ti™ factor wai imlatd in the is calculation:, uniform
exposure to the entire Site at average contaminant concentrations (conservative); only analytical hits used tc compute comarcinant averages.
1.0% (Organic*) or 0.1% (Metals) dermal transfer assuned; includes consideration of soil miuiz effect
B-22
-------
Table 15. Assumptions for Ingestion and Dermal Contact Exposure
to Sediment Contaminants of Concern
' ,' ' , .. - ' ' T*bU
, ,* ::A*»WBptp>n« JorJnjefctionandTJMtml tot«*ci,fxpe*iai to tt&atitt Cottttmmntt al .Ceactm
,,'•","""- " HrintifyUa)raiSPtah«.W»na.K«JtucV "
" ' t&potun
Child fUorMtJoral Itor
Adidt lUorMtiotuI Uar
ORAL
DeSy tal ingestion level
Friction of time on-tite in contiminitid ireu
Portion ef ingested eontiminint absorbed
Oeys per yeer an-shi'
Yeers on-*hi
Body weight
lifetime ,
200 mg
100%'
100%
140 deyi
6 yeert
15kg
100 mg
100%'
100%
IIMdeys
24 yetrs
70kg
Averaging lime besed on 30 yurs for non-cercinogens,
end 70 yeirs for ciranogens (set Sediment Exposure
Fomulie Kiy)
DERMAL
Skin ire< conlim'mited
Soil edherence per cm' of sfcin
Portion of conleminent ibsorted
Deys per yeer on-site
Yeirs on-site
Body weight
lifetime
3730 em'
1 mg
0.01 (Orgtnics) '
0.001 (Mctits)
140 diys
6 yeen
15 kg
3500 cm'
1 mg
0.01 (Orgenics) '
0.001 (Meteb)
104 deys
24 yetrs
70 kg
Avenging time bised on 30 yeirs for non-cgrcinogens,
end 70 yitrs for carcinogens (see Sediment Exposure
Formulie Key)
Reference* -.-^ue* from USEPA, RAGS, 12/88. OSWfR Directive »9286.6-O3, twj USE PA. ftegion IV New Interim Guidance (2/1 1/02).
Uniform contaminant distribution over the entire Site «raa U *s*umed. No lr*ctlon of time ftctor WM u-Jltzed In tho»« calculation*, uniform
oxpocure to the entire Site at maximum contaminant concentration* w«* iwcumod (or con*erv«ti«m.
1 -0V (Organic*) or 0.1 X (Metali) derm*! t ran* (or •**umed; include* con*ider«uoo of »oil matrix effect.
The lifetime weignted average exposure frequency it 112 day>/vo"F; iryjrvkJuai lifeatage exposure frocuencie* wtye
communication with Sally Wiley. KDEP, f\i»k Amenment Section. Jufy 13.1 993 .
per p«f»onal
B-23
-------
Table 16. Exposure Point Concentrations and Risks/Hazards
Associated with Shallow Ground Water
PARAMETER
Aldrin
Arsenic
Beryllium
PARAMETER
Aluminum
Arsenic
Beryllium
Cadmium
Chlorides
Chromium
Cobalt
Iron
Manganese
Mercury
Nickel
Silver
Sodium
Sulfates
Vanadium
Zinc
RISK BASED RGO (mg/L)
RISK = 1E-04
0.0004
0.004
0.002
RISK = 1E-05
0.00004
0.0004
0.0002
RISK = 1E-06
0.000004
0.00004
0.00002
HAZARD BASED RGO (mg/L)
HQ = 10
824
0.09.
1
0.1
ARAR
1
17
85
1
0.09
6
1
9667
ARAR
2
85
HQ = 1
82
0.009
0.1
0.01
ARAR
0.1
2
9
0.1
0.009
0.6
0.1
967
ARAR
0.2
9
HQ = 0.1
8
0.0009
0.01
0.001
ARAR
0.01
0.2
0.9
0.01
0.0009
0.06
0.01
97
ARAR
0.02
0.9
EXPOSURE POINT
CONCENTRATION
(mg/L)
0.000005
0.00917
0.0078
EXPOSURE POINT
CONCENTRATION
(mg/L)
38.4
0.00917
0.0078
0.0132
277
0.2522
0.8517
54.9
177.5
0.0011
1.007
0.0151
136.3
5070
0.0248
1.33
B-24
-------
Table 17. Exposure Point Concentrations and Risks/Hazards
Associated with Deep Ground Water
PARAMETER
Arsenic
Beryllium
PARAMETER
Aluminum
Ammonia
Arsenic
Barium
Beryllium
Cadmium
Chlorides
Chromium
Cobalt
Iron
Manganese
Nickel
Potassium
Sodium
Sulfates
Vanadium
Zinc
RISK BASED RGO (mg/L)
RISK = 1E-04
0.004
0.002
RISK = 1E-05
0.0004
0.0002
RISK = 1E-06
0.00004
0.00002
HAZARD BASED RGO (mg/L)
HQ = 10
824
340
0.09
20
1
0.1
ARAR
1
17
86
1
6
14216
9666
ARAR
2
85
HQ = 1
82
34
0.009
2
0.1
0.01
ARAR
0.1
2
9
0.1
0.6
1422
967
ARAR
0.2
9
HQ = 0.1
8
3
0.0009
0.2
0.01
0.001
ARAR
0.01
0.2
0.9
0.01
0.06
142
97
ARAR
0.02
0.9
EXPOSURE POINT
CONCENTRATION
(mg/L)
0.0085
0.00081
EXPOSURE POINT
CONCENTRATION
(mg/L)
27.95
229
0.0085
0.469
0.00081
0.0064
9625
0.337
0.62
92.4
76.7
0.72
275.8
4427
5033
0.046
1.231
B-25
-------
Table 18. Exposure Point Concentrations and Risks/Hazards
Associated with Surface Soil
PARAMETER
Arsenic
PARAMETER
Aluminum
Arsenic
Iron
RISK RASED RGO (mg/kg)
RISK = IE- 04
30
RISK = 1E-05
3.0
RISK = 1E-06
0.3
HAZARD BASED RGO (mg/kg)
HQ = 10
NA
700
7E+05
HQ e 1
7E+05
70
7E+04
HQ = 0.1
7E+04
7.0
7E+03
EXPOSURE POINT
CONCENTRATION
(mg/kff)
34.6
EXPOSURE POINT
CONCENTRATION
(mg/kg)
88400
34.6
59500
B-26
-------
Table 19. Remediation Goal Options for Surface Soil, mg/kg
PARAMETER
ALUMINUM
ARSENIC
IRON
Risk Based
1E-04
NA
30
NA
Hazard Based
HQ=1
TE+flS
70
7E+04
BACKGROUND RANGE
7,985 - 14J50
4.5- 13
16,500 - 35,750
Notes:
NA - Not Applicable
B-27
-------
Table 20. Remediation Goal Options for Shallow Aguifer, (ig/L
PARAMETER
ALDRIN
ALUMINUM
ARSENIC
BERYLUUM
CADMIUM
CHROMIUM
COBALT
IRON.
MANGANESE
MERCURY
NICKEL
SILVER
SODIUM
VANADIUM
ZINC
MCL
—
—
SO
4
5
100
—
—
—
2
100
—
—
—
—
Other Criteria
0.3 HA
50 - 200 SMCL
—
—
—
—
NA
300 SMCL
50 SMCL
—
—
100 SMCL
17,000 HA
NA
5,000 SMCL
Risk Based
1E-06
0.04UE-05)
NA
0.04
0.02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Haurd Based
HQ=1
NA
82,000
9
100
10
100
2,000
9.000
100
9
600
100
967.000
200
9,000
BACKGROUND RANGE
NA
7,065 • 47,075
3.7 - 15.8
0.31-19
1.3 -5.2
212 - 78.6
11.6-116
17,080 • 85^00
1,359 • 12,100
0.05 - 0.23
82.2 - 206
1.4-4
10,678 • 144,000
12.1 -71.4
179 - 297
«^yw;' ,' ' •*, , >j" '"„';• ?h't.' •£">,* ""'4,' "''' ','--*' "' >/> - - "'; ''; " ' - ,r-y '.yZj''3fs$ys't&,?'"yx:'4 /''?£"; V">f;„. •' ':,» " '" '" , ''"y'."'^'.^';-";,'''. f>$$r^ , "" ' *'
CHLORIDES (rag/L)
SULFATES (mg/L)
~
—
250 SMCL
250 SMCL
NA
SA
250 SMCL
250 SMCL
12.2 - 17.3
47.4 - 1540
Notes:
NA - Not Applicable
MCL - Maximum Contaminants Level
SMCL - Secondary MCL
HA - Health Advisory
B-28
-------
Table 21. Remediation Goal Options for Deep Aquifer, |0.g/L
PARAMETER
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
IRON
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
MCL
—
50
2000
4
5
100
_-
—
—
100
—
—
—
—
Other Crlkri*
50 - 200 SMCL
—
—
—
—
—
NA
300 SMCL
50 SMCL
—
NA
17,000 HA
NA
5,000 SMCL
Risk Based
1E-06
NA
0.04
NA
0.02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Hazard Based
HQ=1
82,000
9
2000
100
10
100
2,000
9,000
100
600
1.4E-rf
967.000
200
9000
BACKGROUND RANGE
29,373 . 36,920
2.7 -5.2
185 - 229
0.25
1.1 - 13
59.4 - 60.4
22-31
42,605 • 62,275
687-961
65.2 - 71.0
10,035 - 13,765
119,250 - 137,750
37 .5 - 48.0
158 - 160
/:•'.,,',/••'' ' ,•.,„'* ,/••" • ' ' , ' , •• "', '>;, *-?&',:,' <•,',/'•&„' ' ' ' •
t — " ~ - - " - - ' -A- ' - - "' - •;:"%,-,"'' "',"rw. -
AMMONIA (mg/L)
CHLORIDES (mg/L)
SULFATES (mg/L)
—
—
...
30 HA
250 SMCL
250 SMCL
NA
NA
NA
34
250 SMCL
250 SMCL
0.6- 1
19.3 - 122
54 - 1000
Notes:
NA - Not Applicable
MCL - Maximum Contaminants Level
SMCL - Secondaiy MCL
HA - Health Advisory
B-29
-------
APPENDIX C
RESPONSIVENESS SUMMARY
-------
BRANTLEY LANDFILL SITE
ISLAND, KENTUCKY
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public
comment period from July 20, 1994 through August 19, 1994, for
interested parties to comment on the Remedial Investigation (RI)
and Feasibility Study (FS) results and the Proposed Plan for the
Brantley Landfill Site (the Site) in Island, Kentucky. The
Proposed Plan, included as Attachment A of this document,
provides a summary of the Site's background information leading
up to the public comment period.
EPA held a public meeting at 7:00 pm on July 26, 1994, at the
Island Elementary School, Island, Kentucky, to outline the RI/FS
and describe EPA's proposed remedial alternatives for the
Brantley Landfill Site. All the comments received by EPA during
the public comment period were considered in the final selection
of a remedial alternative for the areas of contamination at the
Brantley Landfill Site.
The Responsiveness Summary, required by the Superfund Law,
provides a summary of citizen's comments and concerns identified
and received during the public comment period, and EPA's
responses to those comments and concerns.
This Responsiveness Summary is organized into the following
sections and attachments:
I. RESPONSIVENESS SUMMARY OVERVIEW: This section outlines the
purpose of the public comment period and the Responsiveness
Summary. It also references the background information
leading up to the public comment period.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This
section provides a brief history of the interests and
concerns of the community regarding the Brantley landfill
Site.
III. SUMMARY OF MAJOR QUESTIONS AND CONCERNS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA'S RESPONSES TO THESE COMMENTS:
This section summarizes the comments received by EPA during
the July 26, 1994 public meeting, and provides EPA's
responses to these comments.
IV. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA'S RESPONSES TO THESE COMMENTS: This section contains
letters received by EPA as well as EPA's written
response to the letters.
-------
ATTACHMENT A: Attachment A contains the Proposed Plan for the
Brantley Landfill Site which was mailed to the information
repository on July 20, 1994 and to individuals on the Site
mailing list on July 18, 1994.
ATTACHMENT B: Attachment B includes A public notice regarding
the Brantley Landill Site that was published in an area
newspaper.
ATTACHMENT C: Attachment C includes a copy of the official
transcript of the Public Meeting on the Proposed Plan for the
Brantley Landfill Site.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Prior to the Brantley Landfill Site's closure in October 1990,
the Kentucky Department of Air Pollution Control received
numerous complaints from community members regarding site-
generated ammonia odors, the Site's effects on surrounding
vegetation, and fugitive dust emissions. Since the Site's
closure, state and local officials received periodic complaints
regarding site-generated ammonia odors. These complaints
coincide with periods of rain, fog, and damp climatic conditions.
EPA conducted community interviews on August 27 & 28, 1990. A
community relations plan was finalized on December 28, 1990 to
improve communication between the residents in the communities
affected by the Site and the government agencies performing
remedial activities at the Site.
A Fact Sheet was mailed to the public in April 1992 to inform
interested citizens and local officials of the nature and status
of EPA's activities at the Site. A kick-off meeting to announce
the beginning of the RI/FS was held on May 14, 1992 at 7:00 pm in
the Island elementary School. During this meeting, the citizens
expressed the following site-related major concerns:
1. Fear of explosion due to gas buildup in mines and
homes .
2. Request for air and water samples within "30 days" to
determine if area was a safe place to live.
3 . Concern that community would have to wait two years
before getting any further information.
4. Fear of EPA sitting on information.
5. Concern about drinking contaminated wacer from private
wells or city water wells.
A second Fact Sheet was sent to the Site's mailing list in July
1993 updating the public on the Remedial Investigation and future
actions to be conducted at the Site.
-------
In July 1994, a Proposed Plan Fact Sheet was sent to the mailing
list notifying the public of the findings of the RI/FS and to
present EPA's preferred alternative to remediate the Brantley
Landfill Site.
III. SUMMARY OF MAJOR QUESTIONS AND CONCERNS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA'S RESPONSES TO THESE COMMENTS
The following is a summary of the major verbal comments,
concerns, and questions raised during the public meeting, on July
26, 1994 by local residents together with EPA's responses.
COMMENT: A citizen expressed concerns for his kids, friends, and
his own health if the source material is disturbed during
installation of the new landfill cap.
EPA RESPONSE: EPA stated that there were two primary reasons for
selecting Alternative 4 over 5. First, EPA does not want to
disturb the source material because it will cause more harm to
the local population. And, second, by excavating the source
material the problem is moved somewhere else, and the citizens of
that area will have the same problems that citizens near the
Brantley Landfill Site had when the material was excavated.
COMMENT: A citizen was concerned about past and present people
living near the Site that have been breathing the air coming from
the landfill before it was capped. The citizen also stated that
the air was monitored at that time but does not know what
happened to the records.
EPA RESPONSE: EPA responded that at that time EPA was not
involved with the Site nor had seen any data from that time. EPA
explained that the level at which ammonia can be smelled is less
than the level at which it can cause health effects. So, ammonia
is smelled before it will actually cause any health effects. EPA
also stated that its real mandate is to make sure that there are
no current or future problems to the Site. EPA asked a State
representative if there was any data from the 80's when the Site
was a problem. The State representative responded that there was
no emission specific data.
COMMENT: A citizen asked EPA's experience in dealing with salt
cake fines. Also, if the salt cake fines will remain onsite once
the cap is in-place.
EPA RESPONSE: EPA responded to the first question that the
contaminants in fresh salt cake fines in the landfill have been
analyzed, and that it was determined that a lot of the salt cake
-------
fines, the chlorides and ammonia compounds, have already reacted
with water, and released. EPA answering this citizen's second
question stated that the metals and the materials that have not
reacted, and that will not come in contact with water will remain
there.
COMMENT: A citizen stated that a State Inspector took pictures
on two occasions. The first set of pictures was of the dumping,
and the Inspector lost them. After the second set, the Inspector
was dismissed. The citizen also said that the Inspector
installed air monitors in his mom and dad's driveway.
EPA RESPONSE: EPA stated that this was before EPA got involved
with the Site.
IV. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA'S RESPONSES TO THESE COMMENTS
The attached written comments were received during the public
comment period. EPA's responses to these comments are also
attached and were mailed to the party addressed.
-------
Post Office Box 1070
Frankfort. Kentucky 40602
[502] 875-2428
[5021 875-2845 (FAX!
1 August 18, r994
Liza I. Montalvo
Remedial Project Manager
U.S. EPA
345 Courtland Street, N.E.
Atlanta, GA 30365
VIA FAX
Re: Proposed Plan, Brantley Landfill Superfund Site, Island,
McClean County, Kentucky
Dear Ms. Montalvo:
These comments are submitted on behalf of the Kentucky
Resources Council, Inc, a nonprofit membership organization
dedicated to the prudent use and conservation of the natural
resources of the Commonwealth of Kentucky. The Council has the
following concerns regarding the RI/FS and proposed plan for the
Brantley site.
Identification of '"background" levels of hazardous
constituents in soil. It appears that the three "background" soil
samples were in disturbed areas or areas on site potentially
affected by waste management activities, including the spraying
of oil or diesel fuel for dust control. It appears that the
detection of petroleum compounds and PCBs/pesticides in these
background samples resulted in their elimination from the
contaminants of concern (COCs) list for soils, even though those
compounds are present at the site. The Council believes that this
is inappropriate, and since those chemicals pose risks to human
health and the environment, and since their presence is not due
to natural background, that they must be addressed in the remedy.
Constituents to be monitored in groundwater. The fact sheet
lists contaminants of concern found in the shallow and deep
aquifers at the site. The Council urges that all hazardous
constituents present in any media at the site be monitored on a
continuing basis in groundwater, due to the uncertainty about
where in the landfill some constituents might be concentrated,
and the differential rates of migration for different hazardous
constituents.
Groundwater cleanup levels. It is not clear from the fact
sheet how these levels were arrived at, nor is it clear how the
-------
constituents were identified for which cleanup levels would be
set. The Council would urge that the levels be set at the lower
of MCLs or state water quality standards. These would appear to
be the relevant and appropriate standards, particularly in light
of the uncertainties regarding groundwater flow, and in light of
the requirement under CERCLA and state law to protect future uses
of groundwater. It is apparent from Table 1.0 that these
standards have not been applied in all cases. Moreover, there are
no cleanup levels set for many constituents present at the site,
including PCBs, chlorinated pesticides, benzene, dieldrin, and
heptachlor. (Except PCBs, all of the above have been identified
as constituents of concern for either the deep or shallow
aquifer). As stated below, KRC does not agree that, based on the
information in the fact sheet, natural attenuation is appropriate
for the deep aquifer. However, even if it were the appropriate
remedy, cleanup levels for site constituents would need to be set
for the deep aquifer in order to monitor the performance of the
remedy and to determine whether natural attenuation was indeed
occurring (or for example, whether due to failure of the cap
and/or leachate collection system, additional migration of
constituents to deep groundwater was occurring) .
Soil cleanup levels. The soil cleanup levels set forth in
the fact sheet appear to be quite high (e.g. 700,000 ppm
aluminum) . The Council urges EPA not to finalize cleanup levels
for soil or groundwater before receiving detailed comments from
the Kentucky NREPC regarding the risk assessment upon which these
levels are based.
Remediation of the deep aquifer. Natural attenuation appears
clearly inappropriate, particularly in light of uncertainty about
flow direction. The Council urges EPA to set forth sufficiently
protective cleanup levels for the deep and shallow aquifers for
all constituents present at the site, and do further
investigation regarding groundwater flow, including through the
abandoned mine works. In any event, continuing monitoring to
determine the effectiveness of the remedy should be performed for
both the deep and shallow aquifers. Although the fact sheet notes
that there are no current users of the contaminated groundwater,
CERCLA and state law require the protection of future uses of
groundwater.
Environmental risk assessment. EPA asserts that a pond that
is dry in some parts of the year is not a significant aquatic
habitat. This statement appears to ignore the signficance of such
ponds to amphibian and invertebrate populations, which may be
even more sensitive to hazardous constituents than the species
for which warmwater aquatic habitat criteria are set.
Migration of gases through soil and underground mine works.
As the Council urged in its comments of May 14, 1992, sampling
for explosive gases, volatile organic compounds, hydrogen
-------
sulfide, and hydrogen cyanide in the basements of residents in
the vicinity of the site should be conducted. It appears that
volatile organics were detected in some soil vapor probes at some
times, and unacceptable levels of explosive gases were detected
in the underground mine works. Follow-up sampling should be done
to ensure that residents.in the vicinity are not in danger due to
migration of these gases.
Thank you for your consideration of these comments.
Sincerely,
Liz Natter
-------
Post Office Box 1 070
Frankfort. Kentucky 40602
[502] 875-2428
[502] 875-2845 [FAX]
August 18, 1994
Liza I. Montalvo
Remedial Project Manager
U.S. EPA
345 Courtland Street, N.E.
Atlanta, GA 30365
VIA FAX
Re: Proposed Plan, Brantley Landfill Superfund Site, Island,
McClean County, Kentucky
Dear Ms. Montalvo:
Please accept this one additional comment on behalf of
Kentucky Resources Council, Inc. regarding the proposed plan for
the above-referenced Superfund site.
The Council is concerned that soil cleanup levels were
established for only 3 constituents: aluminum, iron, and arsenic.
In order to establish that the remedy is successful, it would
seem that cleanup levels would be required for all hazardous
constituents, or constituents of concern present at the site. At
a minimum, those constituents that were most toxic, most
persistent, and most mobile should be measured for the purposes
of determining the success of the remedy. The Council urges that
cleanup levels be set for all constituents present at the site or
known to be components of the wastes including mercury, benzene,
cyanides, sulfides, PCBs, chromium, vanadium, etc.
Thank you for your consideration of these comments.
Sincerely ,
Natter
-------
UNITED STATES ENVIRONMENVAL PROTECTION AGENCY
REGION .V .
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 3O365
September 2, 1994
4WD-NSRB
Liz Natter
Kentucky Resources Council
Post Office Box 1070
Frankfort/ Kentucky 40602
SUBJ: Response to Comments on Proposed Plan
Brantley Landfill Site
Island, Kentucky
Dear Ms. Natter:
This letter provides U.S. Environmental Protection Agency
(EPA)'s responses to the Kentucky Resources Council (KRC)'s
comments on the Proposed Plan for the Brantley Landfill Site in
Island, Kentucky, on two comment letters dated August 18, 1994.
The underlined sentence corresponds to the first sentence of the
comment letters.
Identification of "background" levels of hazardous
constituents in soil. The three background soil samples were not
located in areas potentially impacted by waste management
activities, as your letter stated. On the contrary, one of the
background samples (LI) was off site, in a reclaimed mine spoil
area north of Kentucky Highway 85, and the other two (08 and M15)
were east of the landfill in presumably native soils.
All petroleum products, and each pesticide/PCBs compound
detected in surface soil (0 - 12") samples were carried forward
to the baseline risk assessment as potential COCs. A risk/hazard
screening analysis was performed to directly determine the COCs.
Those compounds contributing 99 percent of the calculated
screening analysis risk or hazard, and those which were found to
exceed ARARs were retained as COCs. Those compounds posing an
individual carcinogenic risk in excess of 1E-7 and/or hazard
quotient in excess of 0.1 were also regained as COCs (for more
details see Section 7.0, RI Report). None of the petroleum
products nor pesticide/PCBs identified as soil potential COCs
exceeded any of these parameters. Therefore, they were not
included as soil COCs.
Constituents to be monitored in ground water. The remedy to
be implemented at the Brantley Landfill Site calls for the
quarterly monitoring of those hazardous constituents identified
in the baseline risk assessment. This includes pH, sodium,
chlorides, ammonia, sulfates, and the full metals (TAL) analyses.
-------
Ground water cleanup levels. The baseline risk assessment:
identified remediation goal options (RGOs) for those contaminants
contributing to the risks associated with the ground water
pathway. These RGOs are based on health-based goals (risks or
hazards), and ARARs (MCLs, SMCLs, and Health Advisories).
The Brantley Landfill Site is located in a former strip mine
pit. Background in this area consists of areas impacted by mine
spoils. Therefore, background is a very important factor in
deciding the cleanup levels to be attained for some contaminants
which are commonly encountered in mine spoils (i.e., iron,
manganese) at concentrations higher than areas not impacted by
mine spoils. EPA cannot set cleanup standards for ground water
remediation below background. For this reason, a range of
background concentrations was incorporated as a remediation goal
option.
There are three shallow background monitoring wells, K12,
08, and LI, and two deep background wells, H13 and 110, at the
Site. The arithmetic average of the four quarters of data for
each of the wells was determined for those contaminants that
presented risks for the ground water pathway (see attached Tables
1 and 2) .
Tables 3 and 4, also attached, show the remediation goal
options for the shallow and deep aquifers, respectively. For
those contaminants with MCLs, the MCL was selected as the cleanup
level (arsenic, barium, beryllium, cadmium, chromium, mercury,
and nickel). For contaminants without MCLs, a comparison was
made between SMCLs, Health Advisory (HA), health-based levels,
and background concentrations to determine the appropriate or
more stringent cleanup level. When the SMCL or HA is lower than
background (aluminum, iron, manganese, sodium), background was
selected as the cleanup level. For iron and manganese, the
hazard-based number is lower than background. For aluminum and
sodium, the hazard-based number is higher than the background
range, so background was the more stringent standard. For
contaminants with SMCLs or HA higher than background, the SMCL or
HA was selected (ammonia, silver, zinc, chlorides and sulfates).
For contaminants with no MCLs or SMCLs, the health-based level
was selected as the cleanup level (cobalt, vanadium, and
potassium).
Soil cleanup levels. The risk characterization identified
aluminum, arsenic, and iron as the only contaminants contributing
to most of the risks associated with the soil pathway. For these
contaminants, health-based goals were selected as the appropriate
cleanup level. The cleanup levels for aluminum and iron may
appear high. However, they both are naturally occurring in soil
and have relatively low toxicity.
-------
Remediation of the deep aquifer. In the Feasibility Study
(FS) report a ground water analytical model was used to assess
the deep aquifer's capacity to sustain pumping in a pump-and-
treat scenario. It was concluded from this model that this
aquifer was not capable of sustaining a significant flow under a
pump-and-treat scenario. Also/ it is unlikely that such a system
will enhance remediation of the impacted aquifer at rates
significantly faster than natural attenuation/degradation.
These, and other reasons for allowing natural attenuation of the
deep aquifer are explained in detail in the FS report.
Environmental risk assessment. The pond at the southern end
of the landfill is believed to be a man-made basin used during
coal mining operations. This pond is considered a sink for
source material constituents due to surface water runoff. Due to
the fact that the pond is almost dry during some seasons of the
year, the pond is considered a limited aquatic habitat. However,
in order to prevent any future danger to other populations, this
pond will be removed during the installation of the new landfill
cap.
Migration of gases through soil and underground mine works.
The presence of explosive gases at the underground mine works is
not due to site-related contaminants but to other factors such as
the coal mine and reported sewage discharges to the mine. Most
of the vapor probes sampled did not show any volatile compounds
on a consistent basis. Furthermore, many compounds detected were
attributed to exogenous sources unrelated to gases emanating from
the landfill. A detailed explanation of these compounds can be
found in the RI report.
A monitoring program of the underground mine works will be
implemented as part of the selected remedy to determine if site-
related gases are migrating through the underground mine works,
and to the ambient air. If data collected shows unacceptable
levels of site-related gases, EPA will take the necessary
measures to prevent further migration of these gases.
The Council is concerned that soil cleanup levels were
established for only 3 constituents; aluminum, iron, and arsenic.
As previously mentioned, these were the only contaminants
contributing to the risks associated to the soil pathway.
Therefore, these contaminants are more suitable to determine the
success of the new cap in preventing direct ingestion of soil
contaminants .
If you have any questions regarding these responses, or
should you want to further discuss this letter, please contact me
at (404) 347-7791 VMX 4138.
-------
Sincerely,
'
Liza I. Montalvo
Remedial Project Manager
Kentucky/Tennessee Section
cc: Harold Taylor, EPA
Rick Hogan, KDEP
-------
TABLE 1. AVERAGE BACKGROUND CONCENTRATION
Shallow Monitoring Wells
Parameter
ALDRIN
ALUMINUM
ARSENIC
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
IRON
MANGANESE
MERCURY
NICKEL
SILVER
SODIUM
VANADIUM
ZINC
GWMK13SG"
0.025C
47,075
5.9
2.9
1.3C
78.6
49.5
85,500
2,164
0.23
96.2
1.4C
35,475
71.4
274
GHM08SG*
0.019
7,065
3.7
0.31C
1.3C
21.2
11.6
17,080
1,359
0.05C
82.2
1.8
10,678
12.1
179
GWMLlGb
0.05C
32,800
15.8
0.5C
5.2
66.8
116
31,900
12,100
0.2C
206
2C
144,000
41.9
297
"' '-4 -; ,- %; ,;, '' -",-'<, '«'; - -,; > x/-", , v\ t •"-/%•'<* U4'' ' '^•^^^^^^^^^^^^Z^^^^V
CHLORIDES (mg/L)
SULFATES (mg/L)
17.3
47.4
12. 2d
76d
13.9
1540
Notes :
a - Arithmetic average of 4 quarters of
b - Only one round of sampling
c - Based on non-detects
d - Based on 3 quarters of data
data
-------
TABLE 2. AVERAGE BACKGROUND CONCENTRATION (|ig/L)
Deep Monitoring Wells
Parameter
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM11
CADMIUMb
CHROMIUM
COBALT
IRON
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
:-',„ -«^V^^>^'W'f^'
AMMONIA (mg/L)
CHLORIDES (mg/L)
SULFATES (mg/L)
GWMH13DG*
29,373
5.2
185
0.25
1.3
59.4
22.3
42,605
687
65.2
13,765
119,250
37.5
160
%
-------
TABLE 3. REMEDIATION COAX. OPTIONS FOR THE SHAL.I/OH AQUIFER, (IO/L
PARAMETER
ALDRIN
ALUMINUM
ARSENIC
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
IRON
MANGANESE
MERCURY
NICKEL
SILVER
SODIUM
VANADIUM
ZINC
MCL
50
4
5
100
2
100
Other
Criteria
0.3 HA
50-200 SMCL
NA
300 SMCL
50 SMCL
100 SMCL
17,000 HA
NA
. 5,000 SMCL
Risk Based
1E-06
0.04 (IE-OS)
NA
0.04
0.02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Hazard
Ba»«d
HQ«1
NA
82,000
9
100
10
100
2,000
9,000
100
9
600
100
967,000
200
9,000
BACKGROUND RANGE
NA
7,065 - 47,075
3.7 - 15.8
0.31 - 2.9
1.3 - 5.2
21.2 - 78.6
11.6 - 116
17,080 - 85,500
1,359 - 12,100
0.05 - 0.23
82.2 - 206
1.4 - 4
10,678 - 144,000
12.1 - 71.4
179 - 297
CHLORIDES
(mg/L)
SULFATES
(mg/L)
---
250 SMCL
250 SMCL
NA
NA
250 SMCL
250 SMCL
12.2 - 17.3
47.4 - 1540
Notes:
NA - Not Applicable
MCL - Maximum Contaminants Level
SMCL - Secondary MCL
HA - Health Advisory
-------
TABLE 4. REMEDIATION GOAL OPTIONS FOR THE DEEP AQUIFER,
PARAMETER
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
IRON
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
$&f$i$,"&/&9$Se$'«t; ' ','
AMMONIA
(mg/L)
CHLORIDES
(mg/L)
SULFATES
(mg/L)
KCL
50
2000
4
5
100
100
'(,'„?",', S'/'i'Sf&frJ'
Other
Criteria
50-200 SMCL
NA
300 SMCL
50 SMCL
NA
17,000 HA
NA
5,000 SMCL
w^$%f^m&$jt
._* f $. JL.-*S#trStf.J*.
30 HA
250 SMCL
250 SMCL
Risk
Baaed
1B-06
NA
0.04
NA
0.02
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
^|^;v^>%yb«
NA
NA
NA
Hazard
Based
HQ-1
82,000
9
2000
100
10
100
2,000
9,000
100
600
• 1.4E+6
967,000
200
9000
b^^di^filil
34
250 SMCL
250 SMCL
BACKGROUND RANGE
29,373 - 36,920
2.7 - 5.2
185 - 229
0.25
1.1 - 1.3
59.4 - 60.4
22 - 31
42, 605 - 62,275
687 - 961
65.2 - 71.0
10.035 - 13,765
119,250 - 137,750
37.5 - 48.0
158 - 160
•#•* strtAfJS5&tJ&5&&bffi£.tJX.& v SsSSVftZ&ff •
0.6 - 1
19.3 - 122
54 - 1000
Notes :
NA -
MCL
SMCL
HA -
Not Applicable
Maximum Contaminants Level
- Secondary MCL
Health Advisory
-------
ATTACHMENT A: PROPOSED PLAN
-------
tf CD 87*
SUPERFUND PROPOSED PLAN FACT SHEET
BRANTLEY LANDFILL SUPERFUND SITE
ISLAND, MCLEAN COUNTY, KENTUCKY
REGION IV
July 1994
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) is
issuing this Proposed Plan Fact Sheet for the Brantley
Landfill Superfund Site (the Site) in Island, McLean
County, Kentucky. This Proposed Plan is issued to
present a cleanup plan, referred to as the preferred
alternative, to address the contamination at the Site. As
the lead agency for oversight of the remedial activities at
the Site, EPA has worked in conjunction with the
Kentucky Natural Resources and Environmental
Protection Cabinet (KNREPC). In its support role,
KNREPC has reviewed this preferred alternative and
concurs with EPA's recommendations. In accordance
with Section 117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA)
of 1980, EPA is publishing this Proposed Plan to
provide an opportunity for public review and comment
on all the cleanup alternatives under consideration for
this Site.
This Fact Sheet summarizes key information that is
contained in the Remedial Investigation (RI) and
Feasibility Study (FS) reports. The RI and FS reports
are more complete sources of information regarding the
remedial activities at the Site and are part of the
Administrative Record for the Site. The Administrative
Record consists of technical reports and reference
documents used by EPA to compile the Proposed Plan.
These documents can be found in the Information
Repository located at the Island City Hall. EPA and the
State encourage the public to review this information,
especially during the public comment period, to better
understand the Site, the Superfund Process, and the
intent of this Proposed Plan. In addition to the local
Information Repository, EPA maintains a copy of the
Administrative Record in the Record Center at EPA's
regional office in Atlanta, Georgia. Addresses for the
two locations are provided below.
Island City Hall
160 South First Street
Island, Kentucky 42350
(502)486-9948
Contact: Ms. Janet Hughes
Superfund Records Center
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404)347-0506
PUBLIC MEETING NOTICE
DATE: July 26, 1994
TIME: 7:00 pm
PLACE: Island Elementary School
(Gymnasium)
Hwy. 431 (1/2 mile south of
Intersection with Hwy. 85)
Island, Kentucky
(502) 486-3252
PUBLIC COMMENT PERIOD
July 20, 1994 to August 19,1994
-------
BACKGROTTND INFORMATION
The Brantley Landfill Site is located 500 feet west of the
City of Island, and approximately 2000 feet east of the
unincorporated community of Buttonsberry in Kentucky
(See Figure 1). The Site consists of approximately four
acres owned by Mrs. Peggy Drake. The Site is bordered
to the north by KY Highway 85, to the south by the City
of Island Waste Water Treatment Plant (WWTP), to the
east by Mrs. Peggy Drake's residence and the Town of
Island, and to the west by an unnamed tributary to
Cypress Creek. The landfill was formerly a strip mine
pit from which the No. 9 Coal seam was extracted for
commercial use.
^ \
Buttonsberry ^,
•-/ i
Figure 1.0
Site Vicinity
Brantley Landfill Site
In 1977, Barmet Aluminum Corporation contacted Mr.
Doug Brantley to locate a disposal site for the salt cake
fines generated at its Livia, Kentucky aluminum
recycling operation.
Mr. Brantley, who represents Doug Brantley and Sons,
Inc. of Frankfort, Kentucky, located an abandoned mine
pit in Island, Kentucky and entered into a leasing
arrangement with the owner of the property, Mrs. Peggy
Drake. In 1978, Kenvinrons, Inc. of Frankfort,
Kentucky, an engineering firm, submitted an industrial
landfill permit application to the Kentucky Department
for Environmental Protection (KDEP), Division of
Hazardous Waste and Waste Management. Mr. Brantley
stated that during the approximately two-year operation
of the Site (May 1978 to November 1980), salt cake
fines were the only material disposed of in the landfill
(with the exception of diesel fuel as a dust control
measure). A total of 250,306 tons of salt cake fines
were deposited in the landfill.
In 1979, the Kentucky Division of Air Pollution Control
conducted a compliance inspection based on complaints
from area residents that unpleasant odors were coming
from the landfill during disposal activities. At the time
of the inspection, the landfill was found to be in
violation of 401 KAR 63:010, Section 3(l)(c), and 401
KAR 63:010, Section 3(2) regarding: *... failure to take
reasonable precautions to prevent paniculate matter from
becoming airborne and allowing the discharge of visible
fugitive dust emissions beyond the property lines of the
landfill". On several occasions, diesel fuel reportedly
was applied to the fines in the landfill in an attempt to
reduce the amount of fugitive salt cake fines and
gaseous emissions exiting the property. During
subsequent KDEP inspections, officials noted vigorous
reactions with water and complained of irritating gaseous
emissions continuing to be released from the landfill.
This discovery prompted KDEP to submit a letter to
EPA in 1980 requesting an evaluation of salt cake fines
in reference to 40 CFR 261.23 (a)(4), hazardous waste
characteristic of reactivity. EPA concluded that the
waste should be regulated as a hazardous waste, based
on information supplied by KDEP inspection reports. In
November 1980, KDEP notified Barmet of its intent to
regulate salt cake fines as a hazardous waste and
requested that Barmet register as a hazardous waste
generator under the Resource Conservation and
Recovery Act (RCRA). The Brantley Landfill officially
closed on November 15, 1980.
In 1981, Barmet Aluminum Corporation filed a civil
action in a United States District Court against the
USEPA and KDEP, protesting their intent to regulate
salt cake fines as a hazardous waste. The United States
District Court, Western District of Kentucky handed out
a decision on August 5, 1981, declaring that salt cake
fines are not a hazardous waste material within the
meaning of the Solid Waste Disposal Act, 42 U.S.C.S.
6901, et seq. and KRS Chapter 224. Following this
ruling, the Brantley Landfill remained under
investigation by EPA officials regarding complaints
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about gaseous emissions at the Site.
In 1987, EPA conducted field investigations at the
Brantley Landfill, collecting air, soil, water, and
sediment samples for analysis. Results of the analysis
revealed slightly higher ammonia concentrations than
background and elevated metals concentrations below the
landfill cap.
In June of 1988, the Site was proposed for inclusion on
EPA's National Priorities List (NPL), and became final
on February 21, 1990.
In February and March 1989, EPA sent notice letters to
the Potentially Responsible Parties (PRPs) offering
them the opportunity to voluntarily conduct the RI and
FS at the Site. On January 10, 1990, EPA and Barmet
Aluminum Corporation signed an agreement called an
Administrative Order by Consent (also known as a
"Consent Order") under which Barmet would conduct
the RI/FS to determine the type and extent of
contamination at the Site and identify alternatives for
Remedial Action. The Consent Order also included a
requirement for the restriction of access to the site. In
March 1990, Barmet installed chain-link fence around
the Site.
During the RI process, continued erosion and loss of
vegetative cover on the landfill cap material dramatically
increased exposure of salt cake fines at the face of the
landfill. This posed potential air (emission and
particulates) and surface water runoff problems from the
landfill. In late August/early September 1993, Barmet,
with EPA's authorization, performed minimal repairs to
the southern end of the landfill cap where erosion and
exposure of the salt cake fines were the greatest to
prevent further erosion of the landfill cap and subsequent
exposure of the salt cake fines to the atmosphere. The
RI and FS reports were finalized in June and July 1994,
respectively.
THE REMTDTAT. INVESTIGATION
The RI at the Brantley Landfill Site was conducted from
March 1992 to September 1993. Specific objectives of
the RI were:
• to define the nature and extent of contamination
in environmental media (air, surface water,
sediment, soil, and ground water);
to characterize the chemical composition,
location, volume, and mobility of salt cake fines
deposited in the landfill, and;
to assess the threat to human health and the
environment posed by present and future Site
conditions.
KEY FINDINGS OF THE REMEDIAL
INVESTIGATION
Source Characterization
The approach for the Source Characterization Study was
developed as a part of the effort to determine potential
source-related (salt cake fines) contaminants of concern
at the Site. The source material may be characterized as
a fine-grained solid with a consistency generally similar
to that of coarse sand. Salt cake fines (SCFs)
constituents include ammonia, chlorides, metals, and
pesticides/PCBs. The material (in-situ) is not subject to
wind dispersion. The landfill cap serves to suppress dust
generation in the absence of bulk material movement.
Solubilized constituents (primarily sodium and potassium
chlorides, and ammonia) are expected to leave the
landfill through migration of ground water. Another
indirect transport mechanism occurs in the air. Gaseous
by-products are formed by the reaction of salt cake fines
with water (e.g., ammonia, hydrogen sulfide, hydrogen
cyanide, and acetylene) and released into ambient air.
Air
The principal concern at this Site was the generation of
ammonia gases due to the reaction of SCFs with water
in areas where the landfill cap was severely eroded and
the SCFs were partially exposed. An Air Pathway
Characterization Study (Air Study) was conducted to
assess the presence and ambient concentrations of
ammonia (NH,) and other contaminants suspected to be
present, including acetylene (CjH,), hydrogen cyanide
(HCN), and hydrogen sulfide (H^S). This study was
conducted prior to landfill cap repairs.
The only gas phase air contaminant of concern detected
was ammonia. Maximum potential offsite exposure
exceeding EPA requirement and KDEP exposure criteria
occur mostly in areas adjacent to and north and east of
the Site. The residence for which the highest exposures
were predicted is located onsite approximately 500 feet
north of the source area. The Site perimeter location at
which the highest KDEP exposure was predicted is on
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the west side of the Site and closest to the emissions
source area.
Soil
A total of 28 soil samples were collected and analyzed
for depths of 0 to 12 inches and 12 to 24 inches from
areas most likely impacted by source material (e.g.
perimeter of the landfill, runoff channels, and possible
contamination sinks). Three background soil locations,
one offsite in a reclaimed mine spoil area and two onsite
in presumably native soils, were sampled for
comparison.
As expected, petroleum (diesel fuel) products, and coal
and coal tar products were identified in soil samples.
Petroleum products would be expected due to the limited
historical use of diesel products as a dust suppressant,
and coal and coal tar products would also be expected to
be ubiquitous considering that the area was historically
stripped for coal. Some pesticide/PCB compounds were
detected in soil samples as well as in background
samples. The number of pesticides detected in the
background samples indicate that there has been
historical (aerial) application of these types of
compounds for general pest control purposes. The
contaminants of concern (COCs) identified in soil are:
aluminum, arsenic, chromium, iron and vanadium.
Vadose Zone Gases
A total of 11 soil vapor probes were installed around the
landfill to determine if subsurface gases generated in the
landfill were migrating through the vadose zone.
Vadose zone samples were analyzed for volatile organic
compounds, hydrogen sulfide, hydrogen cyanide, and
ammonia. No volatile compounds were detected on a
consistent basis, and no ammonia, hydrogen cyanide or
hydrogen sulfide were detected in any of the soil vapor
probes.
Surface Water and Sediment
All surface water runoff from the Site flows either to the
unnamed tributary to Cypress Creek (west of the Site) or
to the onsite pond (south of the landfill) (See Figure
2.0). Surface water and sediment samples were
collected from two locations in the onsite pond and three
locations in the unnamed tributary on the southern
boundary of the landfill.
The onsite pond surface water samples were found to
contain elevated concentrations of source material
constituents (e.g, aluminum, arsenic, iron, selenium,
sodium, cyanide, and ammonia). This was expected due
to the fact that the onsite pond serves as a sink for salt
cake fines constituents introduced through surface water
runoff collection and/or landfill leachate. The
contaminants of concern detected in the sediments of the
onsite pond are: heptachlor epoxide, dieldrin, gamma-,
delta-, and beta-BHC, aluminum, barium, manganese,
nickel, and vanadium.
The unnamed tributary has shown significant visible
impacts from acid mine, drainage caused by the extensive
strip mining activities upstream and downstream of the
Site. The COCs in the unnamed tributary are: benzene
and thallium (surface water); tetrachlorobenzene, alpha-
chlordane, and dieldrin (sediment).
Unnaoed TribiKsry
to Cypress Creek
Figure 2.0
BrjnUey UndflLl Site
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Ground Water
The ground water medium represents the most complex
environmental medium at this Site, and also the medium
which has the most uncertainty. As a result, a series of
potential flow directions were developed and then tested
with the available data for confirmation. Twelve (12)
ground water monitoring wells (six shallow and six
deep) were installed to assess ground water quality in the
shallow and deep aquifers.
Shallow Aquifer
The shallow aquifer consists of ground water moving
through shallow deposits such as salt cake fines, strip
mine spoils, and native soils. The data collected at the
Site has identified three distinct ground water units: (1)
the Undesignated Pennsylvanian Sandstone (UPS) aquifer
(background), east of the landfill; (2) the unconsolidated
materials (mine spoils and native soils), west of the
landfill, and; (3) the landfill itself, a ground water sink.
The primary ground water flow direction of the UPS
Sandstone aquifer is to the south/southeast away from
the landfill. The unconsolidated materials aquifer has a
ground water flow to the west toward the unnamed
tributary to Cypress Creek with a seasonal influx of
ground water into the landfill. Once ground water enters
the landfill through precipitation and/or ground water
infiltration, its primary outlet for offsite migration is
thought to be the underground mine works, away from
the landfill, to the east. Ground water elevations in the
landfill suggest that a volume of approximately
10,000,000 gallons of water has accumulated over the
life of the landfill (i.e. 16 years).
Shallow ground water adjacent to the landfill is slightly
impacted by ammonia and chlorides from salt cake fines
and exhibits elevated concentrations of several metals.
The contaminants of concern detected in the shallow
aquifer are: chlorinated pesticides, aluminum, arsenic,
beryllium, cadmium, chromium, cobalt, iron,
manganese, mercury, nickel, silver, sodium, vanadium,
zinc, chlorides, and sulfates.
Deep Aquifer
The deep aquifer consists of ground water moving
through fractures in the siltstone/shale sequence found at
depth beneath the landfill. Only one deep well was
installed east of the landfill because of the presence of
the underground mine works in this area. As a result of
the numerous uncertainties associated with the
underground mine works, its connection to the landfill,
the community, and the high levels of explosive gases
encountered, no wells were installed within the landfill.
Ground water flow direction is believed to be from the
west of the landfill to the south/southeastward toward the
town of Island.
Within the deep aquifer, two exceptions to the ground
water model exist. These are for the wells located south
and northwest of the landfill which also show impacts of
salt cake fines constituents. The presence of indicator
constituents in the deep well south of the landfill
demonstrates a southerly component to ground water
flow away from the landfill. For the deep well north of
the landfill, the periodic pumping during purging and
sampling is one element that may explain die levels of
indicator constituents and the increase in chlorides from
first to fourth quarter. The ground water analytical
results indicate that the deep well located east of the
landfill is the most impacted well onsite. Contaminant
concentrations from this well are the result of migration
through the underground mine works.
The contaminants of concern identified for the deep
aquifer are: aluminum, ammonia, arsenic, benzene,
beryllium, cadmium, chlorides, chromium, cobalt,
dieldrin, heptachlor, iron, manganese, nickel, sodium,
sulfates, vanadium, and zinc.
Underground Mine Works
When drilling began in late Summer 1992, unacceptable
levels of explosive gases, and ammonia gas readings of
approximately ISO ppm, were detected along the eastern
perimeter of the landfill where the underground mine
works were encountered. This suggests that at a
minimum, ammonia is leaving the landfill in the vapor
phase. The source of combustible gases cannot be
determined due to naturally occurring gases released
from the coal and the reported sewage that has been
disposed of in the abandoned mine works.
SUMMARY OF RISK ASSESSMENT
During the RJ, an analysis was conducted to estimate the
human health and environmental problems that could
result if the contamination identified at the Site was not
cleaned up. This analysis is known as the Baseline Risk
Assessment (BRA) and was focused on the potential
current and future risks associated with exposure to Site
contaminants of concern.
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HUMAN RISK
An evaluation was undertaken of all potential exposure
routes which could connect contaminants of concern at
the Site with current Site workers and future Site
residents. For the Brantley Landfill Site, the following
potential exposure pathways were evaluated:
« Air Pathway - Inhalation of gaseous
contaminants emanating from the landfill
(ammonia only)
• Soil Pathway - Ingestion of and dermal contact
with contaminated soils
• Ground Water Pathway - Ingestion (potable use)
of contaminated ground water from the mine
spoils and bedrock aquifers
• Sediment Pathway - Ingestion of and dermal
contact with contaminated sediment in adjacent
streams and onsite pond during recreational use
• Surface Water Pathway - Ingestion of
contaminated surface water from adjacent
streams and onsite pond during recreational use
Of these five exposure scenarios only two produced
unacceptable risks to human health, the ground water
and soil pathways. The hazard associated with the air
pathway is no longer considered unacceptable under
current conditions due to the interim cap repairs
performed during the RI which have minimized water
infiltration and reduced gaseous ammonia emissions from
the landfill. However, the extent to which this measure
has reduced gaseous emissions has not been confirmed.
Currently, neither the unconsolidated mine spoils aquifer
nor the deep aquifer are being used as a potable water
source. The Town of Island municipal water system
derives its raw water supply from well fields along the
Green River approximately three miles north/northeast
of the Site.
Of the contaminants of concern previously identified in
Site media, two human carcinogens were detected.
Benzene was detected in ground water and salt cake
fines, and arsenic was detected in the source material,
and in ground water and soil above background action
levels. Cadmium, classified as a probable human
carcinogen, was also detected in ground water.
However, only cadmium and arsenic were found to have
unacceptable risk to human health.
Based on the results of the RI/FS reports and the risk
assessment, cleanup levels were developed that would be
protective of human health and the environment. Tables
1.0 and 2.0 present the cleanup levels, for the
contaminants of concern detected in ground water and
soil, respectively. Cleanup levels for the Brantley
Landfill Site were selected based on the appropriate
remediation goal. The ground water remediation goals
are based on Federal and State standards, referred to as
Maximum Contaminant Levels (MCLs), Secondary
MCLs, Health AdTisory (HA), and background
concentrations. The soil clean up levels were established
to minimize Site risks.
ENVIRONMENTAL RISK
A qualitative risk assessment was conducted to determine
if contaminants present at the site have impacted plant
life or animals in the area. A literature review along
with terrestrial and aquatic assessments were conducted
to determine if any endangered, threatened, or otherwise
ecologically sensitive species and/or habitats requiring
protection were located on or near the Brantley Landfill.
The landfill and immediate vicinity contain three
potential habitats of concern: the terrestrial habitat, the
unnamed tributary to Cypress Creek, and the onsite
pond. The results of the literature review and terrestrial
assessment concluded that there were neither any
endangered or threatened species, nor wetlands on or in
the vicinity of the landfill.
A toxicity testing was performed on samples from the
unnamed tributary and the onsite pond. The results of
the testing indicate that the effects of low pH in the
unnamed tributary are due to historical acid mine runoff
or other upstream factors. The onsite pond provides a
limited aquatic habitat due to the fact that the pond dries
out during dry months.
For more information about the risks posed by the
contamination at the Brantley Landfill Superfund Site,
see the Baseline Risk Assessment in the RI Report on
file at the information repository in the Island City Hall.
SCOPE OF THE PROPOSED ACTION
Using the information gathered during the Remedial
Investigation and Baseline Risk Assessment, EPA
identified the following remedial response objectives for
the Brantley Landfill Site.
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1) Prevent direct ingestion of hazardous
constituents of the source material, and soil
contaminants.
2) Prevent exposure by the air/ground water
pathways.
3) Prevent migration of hazardous components
of the source material to the air, ground water,
and underground mine works.
4) Prevent ingestion of water having site
contaminants in excess of MCLs/SMCLs.
5) Prevent further contamination/migration of
ground water at contaminant levels in excess of
MCLs/SMCLs.
This Proposed Plan for the Brantley Landfill Site
addresses ground water and soil contamination, direct
gaseous emissions from the landfill, and ammonia gas
migration to the underground mine works.
This response action is proposed to mitigate the threats
to human health at the Site by controlling to the source
material. Source control along with the removal of
contaminated leachate at the landfill would reduce the
potential for migration of contaminants into the ground
water and underground mine works. Also, the proposed
action will restore shallow ground water adjacent to the
landfill, and will provide a monitoring program of the
abandoned coal mine works.
SUMMARY OF ALTERNATIVES
Based on the results of the RI, a Feasibility Study (FS)
was conducted to ascertain, develop, and compare
remedial action alternatives to mitigate actual and
potential threats to public health resulting from the
migration of site related contaminants to environmental
media. Five remedial alternatives were developed in the
FS. The FS describes the alternatives considered, as
well as the process and criteria used to eliminate
potential remedial alternatives from further evaluation
and consideration.
As required by CERCLA, a no further action alternative
was evaluated to serve as a basis for comparison with
the other active cleanup methods. The cleanup methods
to address site related contamination which exceeds the
cleanup goals stated in the table below are presented
herein.
Alternative 1: No Action
CERCLA requires that the "No Action" alternative be
evaluated at every Superfund Site to establish a baseline
for evaluating all other alternatives. Under Alternative
1, no further remedial response is conducted. Site
characterization data would be collected and evaluated
under this alternative. The estimated cost of this
alternative is $260,000.
Alternative 2: Institutional Controls
This alternative consists of institutional controls such as
deed restrictions and fencing, to prevent direct human
exposure to the source material. Ground water and
other environmental media would be sampled semi-
annually, and analyzed for the COCs identified during
the RI. The leachate is analyzed to monitor the
attenuation of ammonia and chlorides and to verify that
metals are not leaching out of the SCFs. A one-time
ambient air monitoring would be conducted to confirm
that ammonia emissions have been effectively attenuated
by recent cap improvements. Also, a monitoring
program of the abandoned coal mine works will be
conducted including ambient air monitoring at closed
mine shafts and monitoring of ground water in the coal
seam beyond the boundary of the abandoned mine
works. The estimated cost of this alternative is
$835,000.
Alternative 3: Cap and Dn""»g
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Table 1.0 - Ground Water Cleanup Levels (ppb)
PARAMETER
ALDRIN
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
IRON
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
SODIUM
VANADIUM
ZINC
„ ' '>, '
f ._._.
AMMONIA (ppm)
CHLORIDES (ppm)
SULFATES (ppm)
SHALLOW AQUIFER
0.04
7,065 - 47,075
50
NA
4
5
100
2,000
17,080 - 85,500
1,359- 12,100
2
100
NA
100
10,678 - 144,000
200
5,000
* ' "
NA
250
250
DEEP AQUIFER
NA
29,373 - 36,920
50
2000
4
5
100
2,000
42,605 - 62,275
687-961
NA
100
1.4E+6
NA
119,250- 137,750
200
5,000
\ t f f
f J-- .. ^ f
34
250
250
NA - DM .pplkmble
Table 2.0 - Soil Cleanup Levels (mg/kg)
PARAMETER
ALUMINUM
ARSENIC
IRON
CLEANUP LEVEL (mg/k«)
7E+05
30
7E+04
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aquifer is allowed to attenuate naturally. The estimated
cost of this alternative including the contingency measure
is $4,200,000.
Alternative 4: Cap/Drainage Improvements.
Contingent Short- and Long-Term
Leachate Collection
Alternative 4 incorporates the elements of Alternative 3
including the long-term contingency measure. This
alternative adds provisions for short-term removal,
treatment and offsite disposal of landfill leachate
currently accumulated in the landfill. The
implementation of the short-term leachate collection
system would depend on the dissolved contaminant mass,
and its rate of migration from the landfill, among other
factors. This information would be gathered during
RD/RA. The estimated cost of this Altenative is
$7,000,000.
Alternative 5: Excavate. Drv SCFs. and Place
in Offsite Landfill
Alternative 5 calls for excavation and disposal of the
SCFs in an offsite landfill. The landfill is de-watered
before excavation begins. The SCFs would be dried at
the Site prior to its transportation to prevent ammonia
emissions. For a period of three years, the material will
be shipped to a newly constructed landfill. The new
landfill would be constructed to the required Resource
Conservation and Recovery Act (RCRA) standard at a
site yet to be determined. The estimated cost of this
alternative is $27,000,000.
The Feasibility Study Report presents a more thorough
description and evaluation of these alternatives. A copy
of this and other documents are available for public
reading at the information repository located in the
Island City Hall.
COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA has established the criteria for use in comparing the
advantages/disadvantages of each alternative. The
alternatives are evaluated against one another by using a
standard set of nine criteria. The nine evaluation criteria
fall into three groups: threshold criteria, primary
balancing criteria, and modifying criteria.
"Threshold Criteria": These two statutory
requirements must be met by each alternative and are
described as follows:
1. Overall Protection of Human Health and the
Environment addresses how an alternative as a
whole will protect human health and the
environment. This includes an assessment of
how the public health and environmental risks
are properly eliminated, reduced, or controlled
through treatment, engineering controls, or
controls placed on the property to restrict access
and (future) development.
2. Compliance with Applicable or Relevant and
Appropriate Requirements fARARsI addresses
whether or not a remedy complies with all state
and federal environmental and public health laws
and requirements that apply or are relevant and
appropriate to the conditions and cleanup options
at a specific site. If an ARAR cannot be met,
the analysis of the alternative must provide the
grounds for invoking a statutory waiver.
"Primary Raianrlng Criteria": These are five
considerations used to develop a decision as to which
alternative would be best to use.
3. Long-Term Effectiveness and Permanpnrp
refers to the ability of an alternative to maintain
reliable protection of human health and the
environment over time once the cleanup goals
have been met.
4. Reduction of Toxicitv. Mobility, or Volume
are the three principal measures of the overall
performance of an alternative. The 1986
amendments to the Superfund statute emphasize
that, whenever possible, EPA should select a
remedy that uses a treatment process to
permanently reduce the level of toxicity of
contaminants at the site; the spread of
contaminants away from the source of
contamination at the site.
5, Short-Term Effectiveness refers to the
likelihood of adverse impacts on human health
and the environment jthat may be posed during
the construction and implementation of an
alternative until the cleanup goals are achieved.
6. Implementabilitv refers to the technical and
administrative feasibility of an alternative,
including the availability of materials and
services needed to implement the alternative.
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7. Cost includes the capital (up-front) cost of
implementing an alternative, as well as the cost
of operating and maintaining the alternative over
the long term, and the net present worth of both
capital and operation and maintenance costs.
"Modifying Criteria": These two considerations are
used to determine the acceptability of the alternatives to
the public and local officials.
8. State Acceptance addresses whether, based on
its review of the RI/FS and Proposed Plan, the
State concurs with or opposes the alternative
EPA is proposing as the remedy for the site.
9. Community Acceptance addresses whether the
public concurs with EPA's Proposed Plan.
Community acceptance of this Proposed Plan
will be evaluated based on comments received at
the upcoming public meeting and during the
comment period.
Table 3.0 provides an evaluation and comparison
between the alternatives in terms of the nine evaluation
criteria. The following is additional information
regarding two of these criteria, State and Community
involvement, that is not explained in Table 3.0.
State Acceptance
The Commonwealth of Kentucky is currently reviewing
this Proposed Plan.
Community Acceptance
The purpose of this Proposed Plan and the upcoming
comment period is to encourage input from the public
during the remedy selection process. Community
acceptance of the preferred alternative will be evaluated
after the public comment period. The Agency will
prepare a response to each comment received which will
be provided in the Responsiveness Summary which is
part of the Record of Decision for the Site.
ASSISTANCE GRANTS ARE AVAILABLE
To assist communities in interpreting the technical
findings at Superfund Sites, communities may apply for
Technical Assistance Grants of up to $50,000. Congress
and EPA have established requirements for the use of
this grant. Citizens who are interested in applying for a
TAG may contact Ms. Sharon Chandler at (404) 347-
2234.
EPA'S PREFERRED ALTERNATIVE
In summary, based on the information available at this time, EPA is proposing Alternative 4.
ALTERNATIVE 4: CAP DRAINAGE IMPROVEMENTS
CONTINGENT SHORT- AND LONG-TERM LEACHATE COLLECTION
Estimated cost: $7,000,000
Alternative 4 includes the construction of a new landfill cap with elimination of the onsite surface pond at the
southern end of the Site, long-term leachate collection, an alkaline recharge trench (surface water is directed to
trenches which contain alkaline materials such as lime, and water from the trenches recharges shallow ground
water raising its pH which restores the water by lowering metals concentrations), and ground water and
abandoned mine works monitoring. Also, a short-term removal system of accumulated landfill leachate would be
implemented unless data collected during RD/RA demonstrates that such system is not necessary.
This Alternative represents the best balance among the criteria used to evaluate remedies. Alternative 4 is
believed to be protective of human health and the environment, would attain ARARs, would be cost effective, and
would utilize permanent solutions and alternative treatment technologies or source technologies to the maximum
extent practicable. Based on comments received from the public during the upcoming comment period, EPA, in
consultation with the Commonwealth of Kentucky, may later modify the preferred alternative or select another
remedial alternative presented in this Proposed Plan.
10
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Table 3.0 - Comparative Analysis of Remedial Alternatives
Criteria
8hor1-Term Effectlveneae
Tlma Until Remedial Response
Objective! (RROI ere
Achieved
• Prevent direct contact with
•alt cake flnaa
• Prevent offelte migration of
contaminated ground water
• Worker Protection
• Community Protection
• Environmental Impacta
Long-Tarm Efteclfveneee and
Parma nenoa
Magnitude of ReaMusI Risk:
• Direct Contact/SCFa
Ingestlon
• Ground Water tngeetlon
Adequacy and Reliability of
Controla
Artsrrurflvs: 1
No Action
Ooea not maintain protection
from direct expoaure to aalt
cake finea.
Offefta migration of
contaminated ground water
ceaaea after 10 to 16 yeara
Not applicable
Not applicable
Not applicable
Riak remalna at near current
(low) levela.
Risk reduced due to the
dissipation of chlorides and
ammonia concantrationa.
No controls.
Attematl»2:
Immediately achieves protection
from direct expoaure to salt cake
fines.
Same aa Altemetlve 1
No significant riak.
No community Impacts.
No environmental Impacta due to
Implementation.
Same aa Alternative 1 .
Same as Alternative 1.
Inatttutional controls are reliable In
the ahort-term.
Artsmative S:
Cap •nd Drainage
Improvement*, Contingent
Long-tarn Laacfiata Extraction
Same aa Alternative 2.
Offalta migration of
contaminated ground water
ceaaea after about 1 2 years.
Same aa Alternative 2.
Same aa Alternative 2.
Same aa Alternative 2.
Same aa Alternative 1 .
Permanently ellmlnatea
migration of contaminants Into
ground water.
Same aa Alternative 2 with
reapect to Inatrtutlonal controla.
Cap maintenance and
contingent leechate extraction
provides adequate control for
prevention of offsrte
contaminant migration.
Altsjfnnlvej 4t
Contingent Short- and long-
term Laaohat* CefaeHon
Same aa Altemetlve 2.
OffsKe migration of
contaminated ground water
ceaaea after about 3 years.
8ame aa Alternative 2.
Same as Alternative 2.
Same aa Alternative 2.
Same aa Alternative 1 .
Same ae Alternative 3.
Same aa Alternative 3.
Aftsmadva 6:
Excavate. Dry SCFe, and Plaoe In
Offelte LamtfBI
Same as Alternative 2.
Offsrte migration of contaminated
ground water ceaaea after about 4
yeara.
Phvelcal riaka associated with salt
cake flnee excavation.
Potential for Impact of fugitive
ammonia air emlaalona.
Potential for Impact of fugitive
ammonia air emlaalona.
Realdual riak remalna at offette
land fin.
Same aa Alternative 3.
High level of certainty that site
risks associated with contact with
tart cake finea and contaminated
ground water will be permanently
eliminated. Controla at offsrte
landfill adequate.
11
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Table 3.0 - Comparative Analysis of Remedial Alternatives (Continued)
Crtterte
Reduction of Tojdchy. Mobility or
Volume Through Treatment
Imple menta bKrty
Coat
Compliance wfth ARARa
• Ground water MCLe. SMCU end
reference doaage oral (RDol for
ammonia
Ovarel Protection of Mumen H««hh
and the Environment
Ahsmativa: 1
No Action
None.
Not applicable.
O&M Coat I17K
Praaent Worth .. I260K
Achievee RDo for
ammonia and SMCL for
chlorideeln 10 to 16
yeera. Metala In ground
water will peraiat.
Not protective.
Alternative 2: ..
InatnuttoruH Control* .
None.
No barrier* to implementation.
Capital Coat .. .. »66K
O&M Coat . *60K
Praaent Worth I836K
Seme ea Alternative 1 .
Immediately protective with
respective to direct human
contact with aalt cake fhwa.
Protective of humen health and
the environment with reapect to
SCFa related ground weter
contemination after 10 to 16
year*.
AftametfveS:
Cap and Drainage
Long'term Laaohat* Extraction
None.
Same a* AKamatlve 2.
Cep. Coet I786K
O&M Coet I223K
Pro. Wor «4.2M
Offaite ground water
contaminant migration potential
ceaae* after about 1 2 year*.
MCLa for metal* In shallow
ground watar am achieved by
alkaline recharge tranchea In
leaa time than Attemetlvee 1
end 2. The time required to
achieve MCLe can not be
ettlmeted.
Same ea Alternative 2. Rl«ke
poaed by metal* In ground
water mitigated by alkaline
recherge trenchea.
Art*mative4:
Contingent Short- and Long-
None.
Same aa Alternative 2.
Capital Coat »3.6M
O&M Coat »223K
Pra. Wor «7M
Offaite ground water
contaminant migration potential
ceaae* after about 3 year*.
Shallow ground water; aame a*
Alternative 3.
Same ee Alternative 2 except
groundwater protectlvenese 1*
achieved In about 3 year*.
Alternative 6:
Excavate. Dry SCFa, and Place In
Oftarta Undfln
Entrelned ammonia la
remove from landfill leechate.
Technical: fugitive air emliilona.
Admlnlitratlva: ehlng and
permitting at the new offaHe
lendfin.
Capital Coat I26M
O&M Coat I62K
Preeant Worth .., I27M
Offsrte ground water contaminant
migration potential caeaea after
about 4 year*. Transportation
and landfllling comply.
Same es Alternative 4.
12
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GLOSSARY OF TERMS USED IN THIS FACT SHEET:
Aquifer: An underground geological formation, or group of formations, containing useable amounts of groundwater that
can supply wells and springs.
Administrative Record: A file which is maintained and contains all information used by the lead agency to make its
decision on the selection of a method to be utilized to clean up/treat contamination at a Superfund site. This file is located
in the information repository for public review.
Applicable or Relevant and Appropriate Requirements (ARARs): The federal and state requirements that a selected
remedy must attain. These requirements may vary among sites and various alternatives.
Baseline Risk Assessment: A means of estimating the amount of damage a Superfund site could cause to human heath
and the environment. Objectives of a risk assessment are to: help determine the need for action; help determine the levels
of chemicals that can remain on the site after cleanup and still protect health and the environment; and provide a basis
for comparing different cleanup methods.
Carcinogenic: Any substance that can cause or contribute to the production of cancer; cancer producing.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): A federal law passed in 1980
and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The Acts created a special tax
paid by producers of various chemicals and oil products that goes into a Trust Fund, commonly known as Superfund.
These Acts give EPA the authority to investigate and clean up abandoned or uncontrolled hazardous waste sites utilizing
money from the Superfund Trust or by taking legal action to force parties responsible for the contamination to pay for
and clean up the site.
Exposure Route: Path for contaminants to reach people either working or residing near a site.
Ground voter: Water found beneath the earth's surface that fills pores between materials such as sand, soil, or gravel
(usually in aquifers) which is often used for supplying wells and springs. Because groundwater is a major source of
drinking water there is growing concern over areas where agricultural and industrial pollutants or substances are getting
into groundwater.
Health Advisory: Concentrations of contaminants in drinking water at which adverse health effects would not be expected
to occur for an exposure of a specified duration.
Information Repository: A file containing accurate up-to-date information, technical reports, reference documents,
information about the Technical Assistance Grant, and any other materials pertinent to the site. The Administrative
Record which contain copies of all legal documents used to select the method of treatment is also in the repository. This
file is usually located in a public building such as a library, city hall or school, that is accessible for local residents.
Maximum Contaminant Levels (MCLs): The maximum permissible level of a contaminant in water delivered to any user
of a public water system. MCLs are enforceable standards.
National Oil and Hazardous Substances Contingency Plan (NCP): The federal regulation that guides determination of
the sites to be corrected under the Superfund program and the program to prevent or control spills into surface waters
or other portions of the environment.
National Priorities List (NPL): EPA's list of the most serious uncontrolled or abandoned hazardous waste sites identified
for possible long-term remedial action under Superfund. A site must be on the NPL to receive money from the Trust
Fund for remedial action. The list is based primarily on the score a site receives from the Hazard Ranking System
(HRS). EPA is required to update the NPL at least once a year.
-------
Parts per billion (ppb)/Parts per million (ppm): Units commonly used to express low concentration of contaminants.
For example, 1 ounce of ammonia in 1 million ounces of water is 1 ppm ammonia.
Record of Decision (ROD): A public document that announces and explains which method has been selected by the
Agency to be used at a Superfund site to clean up the contamination.
Remedial Design/Remedial Action (RD/RA): RD: the phase of Superfund process that follows the Remedial
Investigation/Feasibility Study which includes development of engineering drawings and specifications for site cleanup
and health and safety plans. RA: the actual construction or implementation phase of a Superfund site cleanup that follows
the Remedial Design.
Remedial Investigation/Feasibility Study (RI/FS): The Remedial Investigation is an in-depth, extensive sampling and
analytical study to gather data necessary to determine the nature and extent of contamination at a Superfund site; to
establish criteria for cleaning up the site. The Feasibility Study is a description and analysis of the potential cleanup
alternatives for remedial actions; and support the technical and cost analyses of the alternatives. The Feasibility study
also usually recommends selection of a cost-effective alternative.
Responsiveness Summary: A summary of oral and written public comments received by EPA during a public comment
period and EPA's responses to those comments. The Responsiveness Summary is a key part of the Record of Decision.
Vadose zone: Zone between the ground surface and the upper surface of the ground water.
Volatile Organic Compounds (VOCs): Any organic compound that evaporates readily into the air at room temperature.
14
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PUBLIC PARTICIPATION
EPA invites comment from the community on any or all of the remedial action alternatives contained in this Proposed
Plan. Although EPA has indicated a preferred alternative, this preference should not be construed as the selection of a
remedy; rather, the Proposed Plan is a preliminary determination based on available information. EPA encourages public
participation in the remedy selection process and has, therefore, established a 30-day public comment period from July
20 through August 20, 1994.
A public meeting is scheduled during the comment period. The meeting will be held at the Island Elementary School
on Tuesday, July 26 at 7:00 pm. At that time, EPA will review the results of the RI and FS and will formally present
its Proposed Plan. There will also be an opportunity for the public to have questions answered and provide oral or
written comments.
Comments will be summarized and responses provided in the Responsiveness Summary section of the Record of Decision.
This document will present EPA's final selection for remedial response. Written comments should be forwarded to Liza
I. Montalvo, EPA Remedial Project Manager (RPM) at the address below. Questions regarding the comment period or
public meeting should be directed to Liza I. Montalvo or Suzanne Durham, Community Relations Coordinator.
Liza I. Montalvo
Remedial Project Manager
U.S. Environmental Protection Agency (EPA)
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-7791
If you or someone you
and mail this form to:
Name:
MAILING LIST ADDITIONS/CORRECTIONS
know would like to be placed on the Brantley Landfill Site mailing list, please fill out
Suzanne Durham
Community Relations Coordinator
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Address:
Affiliation:
Phone:
-------
United States Environmental Protection Agency
Region IV, North Superfund Remedial Branch
345 Courtland Street, N.E.
Atlanta, Georgia 30365
OFFICIAL BUSINESS
PENALTY FOR PRIVATE USE, $300
Please Deliver To:
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ATTACHMENT B: PUBLIC NOTICE
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.U.S. EMVWOMMEMTAL PBOTECTIOM AGENCY
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McLean County News
Tuesday, July 12, 1994
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ATTACHMENT C: TRANSCRIPT
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U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
***********************
RE: BRANTLEY LANDFILL SITE
ISLAND, KENTUCKY
* * *
********************
A Public Hearing was held at 7:00 P.M., Central
Daylight Saving Time, on Tuesday, July 26, 1994, at Island
Elementary School, Island, Kentucky, to receive public
comments regarding the Brantley Landfill Site, Island,
Kentucky.
APPEARANCES FOR EPA:
Suzanne Durham
Community Relations Coordinator
Liza Montalvo
Remedial Project Manager
Glenn Adams
Toxicolbgist in Water Division
Harold W. Taylor
Chief of Kentucky/Tennessee
Section, North Superfund
Remedial Branch
Tom Seibert
Kentucky Air Quality Program
Rick Hogan
Chief Federal Superfund Section
Kentucky Department for
Environmental Protection
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MS. DURHAM: Good evening and welcome. My name
2 is Suzanne Durham and I'm the Community Relations
3 Coordinator for the Brantley Landfill Superfund Site
4 located here in Island, Kentucky. I'm with the U. S.
5 Environmental Protection Agency in Atlanta, Georgia. We
6 are here tonight to discuss the long-term investigation
7 which has been conducted at the site and to announce EPA's
8 proposed plan for clean-up action, but more importantly, we
9 are here to listen to you, the members of the community who
10 are most impacted by this site.
n Before we go any further, let me introduce the
12 staff from EPA and the State. To my immediate left is Liza
13 Montalvo. Liza is the Remedial Project Manager who handles
j^J the day-to-day technical activities at the site. To her
15 left is Glenn Adams. He is a Toxicologist in our Water
16 Division. Across the table from him in the blue shirt is
17 Harold Taylor. He is the Chief of the Kentucky/Tennessee
18 Section, North Superfund Remedial Branch. Liza and I both
19 work for Harold. To his left is Rick Hogan with the
20 Kentucky Superfund Program. To my right at this table is
21 Tom Seibert. He's with the Kentucky Air Quality Program.
22 Local officials, we have Martin Eaton who is a City
23 Councilman. You all probably recognize him.
2
-------
i to you about the site history. She will give you some
2 details about the long-term investigation. She will speak
3 briefly about the risk assessment that was done. She will
4 go through all alternatives that are under consideration
5 for clean-up and then, she will outline in detail EPA's
6 preferred alternative. Then I'll come back in a few
7 minutes and give you more details about the community
8 involvement program. I'll ask that you hold all questions
9 until the end of our presentation and I promise you we will
10 get to each and every one of those questions. We will try
11 to keep our presentation as short as we can so that we can
12 get to that. Liza.
13 MS. MONTALVO: I'm going to give you now a
14 description of the site. The site is located on the west
15 side of Island, Kentucky in southern McLean County. It
16 consists of approximately four (4) acres and it is bordered
17 by Kentucky Highway 85 to the north, the City of island
18 Sewage Treatment Plant to the south, and residential and
19 agricultural areas to the east and west. Here I am going
20 to show you the site location map. There's the site,
21 Island, and the unincorporated city of Buttonsberry.
22 I'll give you a little bit of site history. The
23 site was formerly a coal mine pit from which the No. 9 coal
24 seam was extracted for commercial use. From May, 1978 to
25 November of 1980, Doug Brantley and Sons disposed of
-------
approximately two hundred fifty thousand (250,000) tons of
salt cake fines from Barmet Aluminum, Incorporated's Livia
i
3 J plant. Salt cake fines was the only waste disposed of at
•i this site. In August of 1980, Doug Brantley and Sons were
5 cited for violations regarding dust, fugitive dust and
6 odors emanating from the landfill. On February 24th of
7 1990, the site was included on EPA's National Priorities
8 List. In January of 1990, Barmet and EPA got into an
9 agreement called a Consent Order in which Barmet agreed to
10 perform the remedial investigation and the feasibility
11 study at the site. The Consent Order also included
12 restrictions to the site in which Barmet put on a chain
13 link fence at the site. During the remedial investigation,
14 we found that erosion was being—the landfill cap was being
15 eroded and the salt cake fines were being exposed. So,
16 Barmet made interim repairs to the cap repairing mainly
17 these areas where the salt cake fines were exposed.
18 Going to the remedial investigation findings, the
19 remedial investigation field activities were conducted from
20 March of 1992 until September of 1993. During this time,
21 the first thing we did was to sample for two (2) quarters
22 thlT_residential wells. Some of the residential wells were
23 not in use, others were used only for washing the cars or
2- for heating boilers and under the current use of those
25 residential wells, there is no current risk and also the
-------
residential wells—actually the City of Island gets its
2 water from wells along .the Green River approximately like
3 three (3) miles north from the landfill. During this time,
4 we analyzed the constituents or what salt cake fines
5 consist of and it mainly consist of ammonia, chlorides and
6 a wide variety of metals including aluminum, chromium,
7 iron. We also did an air characterization in which the
8 only contaminant of concern detected in the air was
9 ammonia. We also took samples from the surface soil at the
10 landfill and the results of the samples indicated that
11 petroleum products were found. This is attributed to the
12 diesel fuel that was used at the landfill as a dust control
13 measure. We also found, of course, coal products and coal
14 tar products. These were found because of the historical
15 history for coal that was going on at the site before it
16 was a landfill. The primary contaminants detected in the
17 soil at the site were aluminum, arsenic, chromium, iron and
18 vanadium.
19 Let me show you, this is the site and in this area
20 here is where the minimal repairs were performed back in
21 September of 1993. So, it wasn't really in the whole site,
22 buT^this was the area of the exposed salt cake fines.
23 Continuing with the remedial investigation, we also
2^ analyzed surface water and sediment. We collected samples
25 from the unnamed tributary to Cypress Creek and the onsite
-------
1 pond. So, as we can see on here, this here is upstream and
2 going downstream from the unnamed tributary and here is the
3 pond which is at the southern end of the landfill. We
4 found that the onsite pond contained elevated
s concentrations of salt cake fines. This is because the
6 surface water runoff from the landfill comes into this area
7 and it likely collects in there. We also found that the
8 unnamed tributary was highly impacted by acid mine drainage
9 and not by contaminants from the landfill.
10 Going to the ground water, we found two (2)
11 aquifers within the landfill, the shallow aquifer and the
12 deep aquifer. In the shallow aquifer, we can talk about
13 three (3) units. We call the first one the UPS or the
14 Undesignated Pennsylvania Sandstone. It is located at the
15 east side of the landfill and ground water flows mainly
16 from the south to the southeast. I have here —let me see
17 if i can show you. I'll let you know later on. I wanted
18 to show you the shallow aquifer and the deep aquifer. On
19 the west side of the landfill, we have the mine spoils
20 which the flow is to the west towards the unnamed tributary
21 and we have the landfill itself. The landfill itself can
22 be-^considered a ground water sink. In the landfill, we
23 have approximately ten million gallons of leachate
24 accumulated at the landfill.
25 Talking a little bit about the deep aquifer, the
-------
1 deep aquifer is found beneath the landfill with ground
2 water flow to the south-southeast. Three (3) wells were
3 the most impacted wells and I'm going to show you the
4 wells. First of all, we have Well 08D east of the landfill
5 which was highly contaminated with salt cake fine
6 constituents because we believe that the leachate from the
7 landfill flows towards the underground mine works which
8 were found east of the landfill during the remedial
9 investigation. We also found high concentrations on the
10 well, the deep well south of the landfill which is here
11 close to the pond. I18D we believe is the southerly
12 component of ground water flow. Also, the well north of
13 the landfill, we .found chloride concentration increasing
14 from the first quarter to the fourth quarter. We believe
15 that it was mainly caused by the purging that was done
16 during the sampling. The contaminants detected overall in
17 the shallow well, from the shallow aquifer, as well as the
18 deep aquifer, are mainly aluminum, ammonia, arsenic,
19 chromium, cobalt, iron, manganese, nickel, sulfates and
20 zinc, among others.
21 Now, going to the underground mine works. The
22 underground mine works were encountered east of the
23 landfill. When drilling began in the landfill, high
2* concentrations of ammonia gas were found. Also, methane
25 and other combustible gases were found in this area east of
-------
1 the landfill where we encountered the underground mine
2 works. Now, the methane and other combustible gases are
3 believed to be either naturally occurring or because of the
4 reported sewage that the underground mine works were
5 subject of.
6 We did a baseline risk assessment to determine the
7 risks that can pose the contaminants at the landfill. We
8 did a human risk and we did an environmental risk. Going
9 to the human risk, we analyzed the potential risk to
10 current workers and to future residents associated, of
11 course, with exposure to site related contaminants. We
12 evaluated five (5) different pathways from air, soil,
13 ground water, sediment and surface water. For the air, we
14 evaluated inhalation mainly of ammonia. For the soil, we
15 evaluated the ingestion and/or dermal contact of the
16 contaminated ^soil. Ground water, the ingestion of
17 contaminated ground water from the mine spoils and the
18 aquifers. For sediment and surface water, we analyzed the
19 ingestion of sediment and surface water from the unnamed
20 tributary and from the pond during any recreational use.
21 From all these five (5) different pathways, we only found
22 tirat the ground water and the soil pathways were the only
23 ones to show unacceptable risks. However, we have to
24 notice here that neither one of the aquifers identified for
25 the Brantley Landfill are currently being used for drinking
-------
i water. We have a table in your handouts of the risk
2 summary and at this time, I would like our toxicologist,
3 Glenn Adams, just to go over it a little bit. Glenn.
4 GLENN ADAMS: I know it's hot, so I'm going to
5 try to keep mine kind of brief here. What I'm going to do
6 is kind of explain the risks, if we can. Risk being the
7 likelihood of chemical substance at a site to cause health
8 effects in people on the site or nearby areas to the
9 natural environment. The risk assessment doesn't analyze
10 that risk. It's a structured process of evaluating current
11 and future risks posed by those environmental contaminants.
12 Some of the basic questions answered with this risk
13 information is how bad is a site, how bad could it become
14 if nothing was done at the site, does the site warrant any
15 remedial action, how much should be cleaned up at the site,
16 and what would be the result of the remedial action. I
17 know I'm kind of going through this fast, so if anybody has
18 any questions, I'll be glad to try to answer them when we
19 get through. Liza kind of covered a little of this, but
20 for risks to occur at a site, a hazardous substance must be
21 present and a means for exposure to exist and that's the
22 parthway she was talking about. If it's present in the
23 ground water, for it to exist, then we must drink that
2^ ground water or be exposed to that ground water. A lot of
25 times we look at future risks. We assume that someone may
-------
i in the future be exposed to this and that's how we
2 calculate those risks, with a second assumption made about
3 potential exposure now and in the future. Exposure
4 assumptions allow an objective evaluation of what-if
5 questions regarding a potential risk and again the need for
6 clean-up of a site depends on the outcome of the risk
7 assessment.
8 One of the things you always hear us say is
9 acceptable risk. Every person has a different perception
10 of what is acceptable or not, but how EPA has defined
11 acceptable risk, where we are talking about carcinogenic
12 risk, it is based on a risk factor of like ten to the minus
13 four or ten to the minus six risk which means one in ten
14 thousand is equivalent to ten minus four, one in a million,
15 ten to minus six. What that means is that's an excess
16 canvass area. . If a million people were exposed to a
17 certain concentration of the population, a certain
18 percentage of those are going to get cancer based on
19 national statistics, now one additional cancer would occur.
20 It does not mean a cancer death or that that cancer will
21 actually occur, but the chances are that that would occur.
22 The- risk found—that was our upper found estimates which
23 basically means that ninety-nine point nine per cent
24 (99.9%), it's not going to occur at any greater risk than
25 we have calculated, that it would be lesser than that, if
10
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1 anything. I know that's not too clear, but like I said,
2 I'll try to answer any specific questions you have about
3 that. The other type of risk, you have the cancer and the
4 non-cancer. Of course, non-cancer is systemic risks. The
5 exposure dose calculated based on concentrations at the
6 site is divided by a reference dose which is an EPA number
7 or health-base number. It says anything below that, you
8 are not going to see any health effects and if you divide
9 that number and you come up with a number greater than one
10 (1) , which is a called a hazard quotient, there is a
11 potential for health effects. If it is below that number,
12 we do not believe there is any potential for health effects
13 to occur. To use Lisa's slide again, the things we looked
14 at were, we looked at the current workers at the site and
15 the potential for future residential use of the site of
16 exposure pathways for air, soil, ground water, sediment and
17 surface water. We looked at ingestion exposure like ground
18 water, a certain number of liters per day. We also looked
19 at dermal exposure for the air pathways, a certain
20 breathing rate based on the release of gases at the site.
21 For like sediment and surface water, no one has forgot
22 their drinking water, but you might be wading in it and get
23 . incidental ingestion as with the soil and hand-to-mouth
2J activity. We looked at this for future residents for
25 children as well as adults.
11
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1 This is the table Lisa was talking about that is in
2 your handout. Like I said, these numbers are again based
3 on ten to minus four, one in ten thousand. Seven to minus
A six means seven in one million. These hazard index numbers
5 are the whole numbers that you equate to one. If it's
6 above one, there is a potential for a risk to occur.
7 Something I would like to add, what we have is the soil
8 came out at the bottom end of our acceptable exposure
9 level. Both the shallow and the deep ground water came out
10 above those levels and, also the same soil, the deep and
11 shallow ground water was a non-carcinogenic risk. Most of
12 these risks on soils, it's almost a hundred per cent (100%)
13 based on exposure to arsenic in the soils which is
14 naturally occurring and is found outside the area. The
15 ground water, the majority of the risk again is based on
16 arsenic being in the ground water and the soils. The
17 ground water for the hazard index was mostly based on
18 manganese which again, both of these are naturally
19 occurring elements that are found in the area.
20 I will be here to answer any questions you might
21 have when Liza gets through. Feel free to ask anything you
22 have and I'll try to answer it the best I can.
23 LIZA MONTALVO: Before we continue with the
24 baseline risk assessment, I would like to explain to you,
25 this is a cross-section of the landfill. This area is
12
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1 where we have the salt cake fines. On the west side of the
2 landfill is the aquifer which is composed of the mine
3 spoils. On the east side of the landfill is where the
4 underground mine works were encountered and we can see it
5 in this area. This is the coal seam and above the coal
6 seam, we have the shallow ground water. This shallow
7 aquifer was used for background concentrations because it
8 wasn't found to contain any contaminants related to the
9 salt cake fines, and beneath the landfill here we have the
10 deep aquifer.
11 Continuing with the risk assessment, we also did an
12 environmental risk in which we did toxicity testing on the
13 unnamed tributary and the onsite pond. In both of these
14 water bodies, we found that there would be only limited
15 aquatic habitat in the unnamed tributary because it is
16 highly impacted by acid mine drainage and the onsite pond
17 because it dries out most of the year.
18 Every time we are going to analyze the different
19 alternatives we can evaluate to determine which one would
20 clean up the site, we have to determine certain objectives
21 to clean up the site. Our objectives to clean up the
22 Br"a~htley Landfill site are to prevent direct ingestion of
23 salt cake fine constituents and of soil contaminants; to
24 prevent exposure by the air or ground water pathways; to
25 prevent migration of salt cake fine constituents to the
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1 air, ground water, and also to the underground mine works;
2 we will also prevent ingestion of water from the landfill
3 having unacceptable levels of site contaminants; and we are
4 going to prevent further contamination or migration of
5 ground water at unacceptable levels. This is the basis to
6 determine the different alternatives we are going to use to
7 clean up, as potential clean-ups for the site.
8 We did what we call a feasibility study in which we
9 evaluated five (5) different alternatives or five (5)
10 different ways of cleaning up the site. We evaluated from
11 a no-action alternative in which no further action was
12 going to be performed, but only monitoring. For
13 Alternative No. 2, we have institutional controls with
14 restriction to the landfill. Number 3 and No. 4 include
15 the installation of a new landfill cap, and No. 3 calls for
16 a contingent of long-term leachate extraction systems.
17 Number 4 incorporates a short-term leachate extraction
18 system to remove all the water that is contained within the
19 landfill, which we said it was approximately like ten
20 million gallons of ground water. Number 5 will include
21 excavation of the salt cake fines and take this to a newly
22 constructed off site landfill and, as we can see, we have a
23 minimum cost of Two Hundred Sixty Thousand ($260,000.00) to
24 Twenty-Seven Million Dollars ($27,000,000.00) with the
25 excavation. Doing a thorough evaluation of all these five
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1 (5) alternatives, EPA really believes that the best
2 alternative"to clean up the Brantley Landfill site and that
3 will cover all of the objectives will be Alternative No. 4.
4 Alternative No. 4 incorporates everything that Alternatives
5 2 and 3 have and I'm going to explain in detail Alternative
6 No. 4. Alternative 4 will have deed restrictions which
7 will prevent access to the site and prevent the
8 installation of drinking water wells onsite, this means
9 within the landfill. This is going to be done to prevent
10 direct human exposure to the salt cake fines and salt cake
11 fine constituents. After this, we are going to install a
12 new landfill cap. With a new landfill cap, the southern
13 end of the landfill is going to be regraded and the onsite
14 pond will be eliminated. The new landfill cap will
15 minimize surface water infiltration and why we would like
16 to minimize surface water infiltration is mainly because
17 the ground water there in the landfill is coming from this
18 surface water infiltration to the landfill. We estimated
19 that approximately two million gallons per year were coming
20 through surface water infiltration to the landfill. So,
21 the cap will minimize the infiltration. The estimates that
22 we~~have is that it will minimize the infiltration from two
23 million gallons to approximately five thousand two hundred
24 (5,200) gallons per year, and that is a very big
25 difference. We are going to implement under Alternative 4
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1 a monitoring program of the ambient air, the abandoned coal
2 mine, and we are going to monitor the ground water levels
3 and the quality of the leachate and the ground water in and
4 around the landfill. We are going to determine if ground
5 water infiltration is occurring to the landfill. We
6 believe that there are two (2) sources of water
7 infiltration to the landfill; one, through surface water
8 and the other one, through ground water infiltration, but
9 this hasn't been tested yet. So, we are going to monitor
10 it to determine if there is any ground water infiltrating
n to the landfill. Once we have all this data, the ground
12 water level in the landfill and the quality, we are going
13 to do some models to see the expectation on the restoration
14 • of the ground water with the landfill ground water quality,
is and at this same time and during the remedial design, we
16 are going to be determining the implemental rate of any
17 leachate extraction system, the treatment it requires and
18 the off site disposal of the leachate. All this is going to.
19 be done because we have a contingency, we should say double
20 contingency in this alternative. We can have short-term
21 leachate extraction system which is pumping and treatment
22 and-off site disposal of the accumulated leachate. The data
23 to determine if such system would be implemented would be
24 collected through the remedial design. We are going to
25 collect the change in ground water and water levels in the
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1 landfill before, during and after the landfill cap is put
2 on. We are going to determine also the concentration of
3 the sole contaminants that we have and the landfill
4 leachate and the ground water quality, and the way we can
5 determine the ground water quality in the landfill is
6 through Monitoring Well 08 which, as I said before, is the
7 one that we vere taking samples from the leachate because
8 there was leachate going through the underground mine works
9 to this well. Based on all these results, we are going to
10 evaluate also a long-term leachate extraction. Let me tell
11 you first that the short-term extraction will be to extract
12 the leachate that is contained within the landfill. The
13 long-term leachate extraction system will be implemented
14 only if there is ground water infiltration to the landfill.
15 Also under this alternative, we are going to restore the
16 shallow ground water which is west of the landfill. We
17 found that west of the landfill, we have high
18 concentrations of metals and this high concentrations of
19 metals are mainly because the pH in the mine spoils is low.
20 So, by putting on an alkaline recharge trench on this west
21 side of the landfill, we are going to increase the pH of
22 tHe" ground water and that will decrease the concentration
23 of metals in the west side of the landfill. This is what
24 EPA believes will be the best alternative, but however, it
25 may change depending on your concerns at the site.
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1 This is the end of my presentation. I am going to
2 let Suzanne Durham give you the community relations
3 details.
4 MS. DURHAM: Thank you, Liza. Making the final
5 clean-up decision is probably the most important decision
6 ever made for a Superfund site and that's why we are here
7 tonight. We want to help in making that final decision.
8 The administrative record for the Brantley Landfill
9 Superfund site is located at City Hall. That
10 administrative record contains all documents the EPA used
11 in developing our proposed plan. I urge you all to go by
12 there, review those documents, and submit written comments
13 to the Agency. Everything you tell us tonight and
14 everything you submit in writing must be carefully
15 considered before a final decision can be made. The
16 comment period began July 20 and extends through August 19,
17 1994. So, you still have time to review that AR and submit
18 written comments. We expect to sign a recommended decision
19 by the end of September of this year. When that occurs, it
20 will outline in detail our final decision. At that time,
21 I will issue a notice in your local paper telling you
22 exactly what that decision is.
23 Now, we are almost ready to move into the question
24 and answer period, so I have a few ground rules; As you can
25 see, we have a Court Reporter here tonight. It is very
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1 important that we get a verbatim transcript so that we can
2 respond accurately to your questions and comments.
3 Therefore, I ask that only one person speak at a time.
4 Please stand, move forward in front of the Court Reporter
5 so that she can hear you very clearly, state your name,
6 spell it if it has a difficult spelling, then limit your
7 comments and questions to two (2) each and let us move on
8 to someone else. If your question doesn't get answered, I
9 promise we will get back with you to get yours answered.
10 Now, I think Harold is going to do the moderating, so I'll
11 just turn it over to him.
12 HAROLD TAYLOR: All right. Who has got the first
13 question tonight? I'll try and either answer your question
14 or direct it to the proper person here tonight. We need to
15 have a door price for the first question. It's always the
16 hardest one to get. Somebody has got to have a question.
**
17 Going once. Yes, sir, what's your name?
18 ERIC DANIELS: I live on the north side of this
19 thing and my biggest concern is my health and my kids and
20 my fellow friends here. Now, you all are going to take
21 action on No. 4 here, right?
22 MR. TAYLOR: That's what we are proposing.
23 MR. DANIELS: Which is not disturbing it, cap it
24 and everything like that. Now, me, I haven't had no smell
25 since they quit dumping it, but I ain't talking about these
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1 others because I know they probably have because from their
2 water on the other side. To me, I think if they get in
3 there and disturb it, you're going to have a bigger health
4 problem than ever. You know, if it comes down to cleaning
5 that, I don't think I ought to be living out there. Are
6 they going to come in here and buy my place out where I can
7 move out and get my family out of this mess?
8 MR. TAYLOR: That's why we are proposing
9 Alternative 4, not 5, which is just to leave it in place
10 and that's primarily for two (2) reasons. The primary
11 reason is obviously we don't want to disturb it because it
12 will cause more harm to the local population and that's
13 what we are trying to stop. Secondly, wherever we carry
14 this, you know, you just move one problem somewhere else
15 and, of course, the people when we move it will have the
16 same problem when you deposit it that you're having when we
17 dug it up. So," we looked at that alternative just to see
18 what the pros and cons would be and we believe the cons
19 outweigh the pros and we see this as the best alternative.
20 MR. DANIELS: Well, I would rather see them do
21 something to try to seal it off someway before they try to
22 diglit up because I believe that would be a big help.
23 MR. TAYLOR: That's what Alternative 4 is, just
24 putting a better cap on.
25 MR. DANIELS: I mean I can't speak for everybody
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1 because some people in town on the other side might be
2 smelling it right now, I don't know. On my side, I haven't
3 since we got them stopped. Second of all, I know you all
4 are probably offering me a favor, but twelve (12) or
5 thirteen (13) years ago a bunch of us went up there to
6 Frankfort to try to get this stopped before it got started
7 and nobody listened to us. I think they need to learn to
8 listen up there to the community first.
9 MR. TAYLOR: Next question.
10 MARTHA CRABTREE: I'm Martha Crabtree and I'm
11 also a neighbor of this and you said you were interested in
12 the future residents. I want to know about the past and
13 the present people that live by it, the current people that
14 live around this and the ones that have been breathing it
15 for years. I'm interest in what is going to happen. Some
16 of them, something has already happened to and I'm
17 interested in "the others. What is going to be done about
18 that?
19 MR. TAYLOR: Let me let Glenn Adams, our
20 toxicologist, answer that question or try to.
21 MR. ADAMS: We had some air monitoring from
22 t iae past and it probably wasn' t when it was as bad as when
23 everybody was smelling it because some of the cap had been
2- placed on it by that time. Those risks did show to be
25 unacceptable long-term. Luckily it wasn't a long-term.
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i What we consider long-term is thirty (30) years. That is
2 why we went back and repaired the cap to keep any emissions
3 out. Right now we do not have monitoring data on the
4 repaired cap. On this alternative, this is something we
5 want to mention, we will go back, and I think first to
6 answer your question too, they will not be disturbing the
7 cap that is on there and there should not be any odor
8 because we will not be exposing any salt cake fines. So,
9 therefore, we will eliminate that risk. That's the reason
10 why we want to cap it is to keep any emissions and odors
11 out, if we can. Also, we will monitor that to make sure
12 that is the case.
13 . MARTHA CRABTREE: What I was talking about was
14 before it was capped, when it was so bad before it was even
15 capped at all.
16 GLENN ADAMS: As far as I know, we have no data
17 on that time. The EPA was not involved with it at that
18 time. I know you all were smelling it and that was bad
19 enough. One thing about ammonia is the odor is really
20 terrible, but the level at which you can smell it is at
21 least a quarter of the magnitude or smaller than the level
22 whTch can cause health effects. So, you're going to smell
23 it a good bit before—that's one of its luxuries. You can
24 smell it and get away from it before it is going to
25 actually harm you, but as far as we know, we have some data
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1 that indicates levels that causes acute problems very
2 short-term. It was for a long term and that's one of the
3 reasons why we are concerned about this, wanting to get a
4 better cap on it so you won't have that problem.
5 MARTHA CRABTREE: It was monitored at that
6 time. I don't know what happened to the records, but it
7 was monitored.
8 MR. ADAMS: Like I say, that was before EPA was
9 involved and I haven't seen that data. I don't know
10 whether the State has any of it or not.
11 MR. TAYLOR: A question that frequently comes up
12 is what happened in the past and unfortunately, we really
13 can't speak to it. Our real mandate is to make sure there
14 are no current or present or future problems to the site.
15 I know it's a concern and I believe this gentleman here is
16 with Air Quality group in Kentucky that was around back in
17 the early 80's when the site was a problem. I don't know
18 if you have that data back at the office or not.
19 TOM SEIBERT: There is no air emissions specific
20 data.
21 MR. TAYLOR: He is saying there was no specific
22 data. Back in that time frame, I imagine there was very
23 little air monitoring going on.
24 TOM SEIBERT: No, it was strictly treated over at
25 the plant.
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1 MARTHA CRABTREE: I know at that time "ve were
2 complaining about breathing it and how it would burn when
3 you breathe and kill the flowers and all that.
4 MR. TAYLOR: Unfortunately that was when the
5 worst releases were going on because that's when the
6 material was freshest and it was not covered, those kind of
7 things. A lot of that has, of course, already reacted.
8 That'.s two (2) questions. Again, if there are any
9 more questions, we will be here after the meeting if
10 anybody wants to ask questions after the meeting. So, if
11 there aren't any questions, we will adjourn and we will be
12 glad to answer any questions you might have. Yes, sir.
13 MARTIN EATON: Do you have—-what experience do you
14 have with salt cake fines and dealing with them? Do you
15 have any past experience or what is the past experience?
16 MR. TAYLOR: It's really depending on—the only
17 National Priorities List site that I have had personal
18 experience with is the proposed site where most of the salt
19 cake fines are now. I guess I really don't quite
20 understand the question about experience. We have looked
21 at the salt cake fines from, you know, the kind of
22 contaminants fresh salt cake fines would have and we have
23 looked at salt cake fines in the landfill and we have
24 determined a lot of the materials, the chlorides and the
25 ammonia compounds have already reacted with water. Those
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1 compounds have already been released. So, a lot of the
2 salt cake fines that are there have reacted already.
3 MR. EATON: I guess what I'm trying to maybe
4 understand is when this is capped and eliminates a large
5 part of the surface water, this is something that will be
6 with us from now on. These don't deteriorate or this type
7 item.
8 MR. TAYLOR: These are mainly metals, aluminum
9 chlorides, cadmium, those kind of things. So, the metals
10 will just stay there. The ones that haven't reacted and
11 don't come in contact with water will stay there. So, yes,
12 the materials will stay there and won't need to be
13 disturbed basically forever. Yes, sir, you have a
14 question.
15 GARY CRABTREE: They dumped a lot of this at Fort
16 Hartford Stone over around Hartford. They dumped it back
17 in the underground, in the limestone. Could that be
18 getting in the ground water running in there which leaches
19 out into the river?
20 MR. TAYLOR: We will probably have a meeting
21 such as this on the Fort Hartford site within the next
22 three (3) to six (6) months to go over alternatives for the
23 Fort Hartford Coal site.
2^ GARY CRABTREE: When this was all taking place up
25 here, my mother and dad lived right above it over there.
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i There was a State Inspector who took pictures of this and
2 sent them to Frankfort. They lost the first set. The
3 second set he took, he was dismissed. Do you remember
4 that? There's a lot of history behind this thing. This
5 guy put monitors in my mom and dad's driveway.
6 MR. TAYLOR: Air monitors?
7 GARY CRABTREE: Yeah. Mom may know his name. I
8 know they lost the first set of pictures of them dumping
9 and the second set, .he was dismissed. He didn't get to
10 take a third set.
11 MR. TAYLOR: Again that was before my time.
12 GARY CRABTREE: We remember it. If Dad was here,
13 he would remember his name.
14 MR. TAYLOR: Well, again, if there aren't any
15 more questions, we appreciate everyone coming out tonight
16 and we will be around up front if you want to come talk to
17 us after the meeting. Thank you very much for coming.
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1 STATE OF KENTUCKY)
) ss: REPORTER'S CERTIFICATE
2 COUNTY OF DAVIESS)
3 I, Anna Lois Thompson, Notary Public in and for the
4 State of Kentucky at Large, do hereby certify that the
5 foregoing U. S. Environmental Protection Agency public
6 hearing was held at the time and place as stated in the
7 caption to the foregoing proceedings; that the appearances
8 were as stated in the caption; that said proceedings were
9 taken by me in shorthand notes and on an electronic
10 recording machine and was thereafter, by me, accurately and
11 correctly transcribed into the foregoing twenty-six (26)
12 typewritten pages; and that no signature was requested to
13 the foregoing transcript.
14 WITNESS my hand and notarial seal on this the 28th
15 day of July, 1994.
16
17
Notary Public,State of Kentucky at Large
18 My commission expires June 21, 1996.
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APPENDIX D
STATE CONCURRENCE
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PHILLIP J. SHEPHERD X^^^V BRERETON C. JONES
SECRETARY fSff &&', \& GOVERNOR
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
November 22, 1994
Ms. Liza Montalvo, RPM
North Superfund Remedial Branch
Waste Management Division
United States Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: Brantley Landfill Superfund Site revised Draft Record of
Decision (ROD)
Dear Ms. Montalvo,
The Commonwealth of Kentucky Division of Waste Management
(KDWM) has reviewed the revised November 8, 1994 Draft ROD for the
subject property. With exception to two items, KDWM is generally
pleased. As communicated in a phone conversation between you and
William Hill following a review from KDWM of the subject report,
you agreed to make changes to satisfy our concerns with these
items. Specifically, paragraph 2, page 37, sentence two should
state that ground water quality, in addition to ground water levels
will be monitored before, during, and after the installation of the
new landfill cap; and Action-specific ARAR KRS 224.01-400. page 45,
should not be restricted.to the air pathway only. Contingent upon
the above referenced changes, KDWM concurs with the selected
remedy.
Caroline P. Haight, Director
Division of Waste Management
cc: Jeffrey W. Pratt (KDWM)
Rick Hogan (KDWM)
Larry Moscoe (DOL)
Randy McDowell (DOL)
Barbara Cornett (Enf)
Printed on Recycled Paper
An Equal Opportunity Employer M/F/D
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